California, United States of America
The following excerpt is from Rogers v. Ridgecrest Reg'l Hosp., F076751 (Cal. App. 2019):
the litigation privilege of section 47, subdivision (b), plaintiff has not carried her burden of demonstrating an amendment could supply the missing elements of causation and injury. (See Blank v. Kirwan, supra, 39 Cal.3d at p. 318 [plaintiff has the burden of demonstrating a reasonable possibility an amendment will cure a defect in the complaint].)
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