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0264 In a claim by a plaintiff against a religious organization in which the plaintiff seeks punitive damages, the statutory requirement of a motion to amend the complaint based on a showing that there is a substantial likelihood of success should be interpreted to mean only that the plaintiff must prove to the court that there is enough evidence to get the claim for punitive damages to a jury, and, so interpreted, is constitutional.
ROWE v SUPERIOR COURT (Religious Puni's) 15 CA4 1711 [See: CivC 3343; CCP 425.14]
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