When a plaintiff pleads a violation of a statutory duty, does she have to specifically allege the applicable statute or regulation?

When a plaintiff pleads a violation of a statutory duty, " 'we think it obvious that a litigant seeking to plead the breach of a mandatory duty must specifically allege the applicable statute or regulation. Only by so doing may the [defendant] be advised of the factual and legal basis of the claim against it.' (Lehto v. City of Oxnard (1985) 171 Cal.App.3d 285, 292-293.) If a plaintiff fails to identify the provision of law allegedly violated by the defendant, she 'fail[s] to meet her burden of stating and substantiating a legally sufficient claim of unlawfulness.' (Bernardo v. Planned Parenthood Federation of America (2004) 115 Cal.App.4th 322, 352.)" (Marzec v. Public Employees' Retirement System (2015) 236 Cal.App.4th 889, 901-902.)

In the present case, plaintiff alleges a variety of specific violations of the LPS Act, including the following: