California, United States of America
The following excerpt is from Carey v. Trucchi, D072933 (Cal. App. 2018):
A party must allege its entitlement to special damages with certainty and particularity. (See, e.g., Shook v. Pearson (1950) 99 Cal.App.2d 348, 352 ["The facts as to special damages must be stated with particularity. The amount of such damages must
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