With no explanation, chose the best option from "A", "B", "C" or "D". under Section 3294. See, e.g., Mantic Ashanti’s Cause v. Godfather’s Pizza, No. 98-CV-2264 W, 1999 U.S. Dist. LEXIS 16675, at *18-19 (S.D. Cal. June 1, 1999) (“[C]onclusory assertions that the defendants acted with ‘malice’ or with ‘conscious disregard’ for plaintiffs rights are facially sufficient under federal pleading requirements and adequate to state a claim for punitive damages under Section 3294.”); Jackson v. East Bay Hosp., 980 F.Supp. 1341, 1353-54 (N.D.Cal.1997) (“[DJespite section 3294’s specific requirement that a pleading allege oppression, fraud, or malice, these ‘may be averred generally.’ ”) (quoting Fed.R.Civ.P. 9(b)); Bure v. Lohrey Enters., 984 F.2d 1015, 1018 (9th Cir.1993); see also Primerica Fin. Servs., Inc. v. Mitchell, 48 F.Supp.2d 1363, 1371 (S.D.Fla.1999) (<HOLDING>); 5 Charles Alan Wright & Arthur R. Miller,

A: holding that the federal false claims act is an antifraud statute to which rule 9bs heightened pleading requirements apply
B: holding that federal courts could not impose heightened pleading requirement in civil rights cases alleging municipal liability because such requirement conflicted with rule 8
C: holding that the fact that federal rule of civil procedure 9b requires a heightened pleading standard for some claims but not for a section 1983 claim against a municipality means that the rules do not require a heightened pleading standard for such a claim
D: holding that district court could not apply florida statute requiring heightened pleading for punitive damages because statute conflicted with lenient requirements of rules 8 and 9b
D.