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