California, United States of America
The following excerpt is from Bennett v. Bank of Am. Corp., B249521 (Cal. App. 2015):
The trial court ruled that in their cause of action for fraudulent concealment, the Bennetts did not simply allege concealment, but alleged that defendants made affirmative misrepresentations regarding the need for financial documentation. Relying on Lazar v. Superior Court (1996) 12 Cal.4th 631, 645, the trial court ruled that the Bennetts were required to allege such misrepresentations with "specificity, including what was said, when it was said, by what means, and the authority of that person to speak on behalf of the company." They also had to allege how they reasonably relied on the misrepresentations and how they were damaged. The trial court ruled that the Bennetts adequately alleged all the elements of a fraud cause of action for misrepresentation except for damages.
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