What is the test for making a strong showing of misconduct?

A strong showing of misconduct is not necessary to demonstrate the existence of a triable issue of fact. In Jack v. Wood (1968) 258 Cal.App.2d [217 Cal.App.3d 560] 639, 65 Cal.Rptr. 856, which also involved a determination of the validity of a release, the court noted, "[o]nly a slight showing is needed to raise a triable issue of fact, nor is it required that all elements of the cause of action need be substantiated by evidence. [Citation]." Jack v. Wood, supra, 258 Cal.App.2d at p. 648, 65 Cal.Rptr. 856.