On a motion for an order requiring a vexatious litigant to post security, what is the burden on the moving party?

On a motion for an order requiring a vexatious litigant to post security, the moving party must make a showing there is no reasonable likelihood plaintiff will prevail in the action. (Golin v. Allenby (2010) 190 Cal.App.4th 616, 642.) This showing is ordinarily made by the weight of the evidence, but a lack of merit may also be shown by demonstrating plaintiff cannot prevail as a matter of law. (Ibid.) The burden is on the moving defendant. (Id. at p. 640.)