What is the burden of pleading fraud in relation to the disclosure of confidential information?

Fraud must be pleaded with specificity. (Small v. Fritz Companies, Inc. (2003) 30 Cal.4th 167, 184.) "'"Thus "'the policy of liberal construction of the pleadings . . . will not ordinarily be invoked to sustain a pleading defective in any material respect.'" [Citation.] [] This particularity requirement necessitates pleading facts which "'show how, when, where, to whom, and by what means the representations were tendered."' [Citation.]" A plaintiff's burden in asserting a fraud claim against a corporate employer is even greater. In such a case, the plaintiff must 'allege the names of the persons who made the allegedly fraudulent representations, their authority to speak, to whom they spoke, what they said or wrote, and when it was said or

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written.' [Citation.]" (Lazar v. Superior Court (1996) 12 Cal.4th 631, 645.)

b. Fiduciary and Confidential Relationships with Respect to Clergy.