What is the evidentiary test for a motion for summary adjudication on a punitive damages claim?

convincing evidence that the defendant has been guilty of oppression, fraud, or malice." Cal. Civ. Code 3294(a); see also Basich v. Allstate Ins. Co., 87 Cal.App.4th 1112, 1121 (2001) ("[O]n a motion for summary adjudication with respect to a punitive damages claim, the higher evidentiary standard applies. If the plaintiff is going to prevail on a punitive damages claim, he or she can only do so by establishing malice, oppression or fraud by clear and convincing evidence.").