With no explanation, chose the best option from "A", "B", "C" or "D". v. Uvawas, 922 F.Supp. 1450, 1480-81 (C.D.Cal.1996) (sustaining conclusory allegation that manufacturer “knew” of employees’ allegedly illegal and fraudulent activities as sufficient to plead punitive , damages prayer under Section 3294); Grecco v. Sanofi Winthrop Pharmaceuticals, No. C-96-3876 FMS, 1997 WL 68551, at *4, 1997 U.S. Dist. LEXIS 23391, at *12-13 (N.D.Cal. Feb. 13, 1997) (“California law allows for punitive damages with respect to plaintiffs causes.of action but requires a plaintiff to plead specific facts to support such a prayer... Under federal pleading standards, however, such allegations suffice because the elements of malice, fraud or oppression can be generally averred.”); Pease & Curren Refining, Inc. v. Spectro-lab, Inc., 744 F.Supp. 945, 948-49 (C.D.Cal.1990) (<HOLDING>), abrogated on other grounds Stanton Road

A: holding that our liberal rules of notice pleading do not require that specific evidentiary detail be alleged in the complaint
B: holding that liberal pleading standards of rules 8 and 9 applied to prayer for punitive damages
C: holding a court may not award punitive damages
D: recognizing the liberal notice and simplified pleading principles underlying the federal rules of civil procedure
B.