What is the burden of making a motion for a vexatious litigant to post security?

action. In moving for an order requiring a vexatious litigant to post security,⁵ the defendants had the burden of showing there was no reasonable likelihood plaintiff would prevail in the action. (Golin v. Allenby (2010) 190 Cal.App.4th 616, 640, 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 court's decision that a vexatious litigant does not have a reasonable chance of success in the action is based on an evaluative judgment in which the court weighs the evidence. If there is any substantial evidence to support the court's determination, it will be upheld. (Id. at p. 636.)