What is the test for a motion to compel a plaintiff to furnish security in a personal injury case?

"The vexatious litigant statutes ( 391-391.7) are designed to curb misuse of the court system by those persistent and obsessive litigants who, repeatedly litigating the same issues through groundless actions, waste the time and resources of the court system and other litigants." (Shalant v. Girardi (2011) 51 Cal.4th 1164, 1169.) Section 391.1 provides that in any litigation pending in a California court, the defendant may move for an order requiring the plaintiff to furnish security on the ground the plaintiff is a vexatious litigant and has no reasonable probability of prevailing against the moving defendant. The action is stayed pending determination of the motion. ( 391.6.) If, after a hearing, the court finds for the defendant on these points, it must order the plaintiff to furnish security "in such

Page 8