California, United States of America
The following excerpt is from Looney v. Superior Court, 16 Cal.App.4th 521, 20 Cal.Rptr.2d 182 (Cal. App. 1993):
19 Indeed, we have recently applied that same reasoning to our analysis and construction of section 425.14 (which imposes a differently worded but similar pre-pleading hurdle on a plaintiff with a punitive damage claim against a religious organization). (See Rowe v. Superior Court (1993) 15 Cal.App.4th 1711, 19 Cal.Rptr.2d 625.)
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