“Pursuant to section 430.10(f) of the Code of Civil Procedure, the party against whom a complaint has been filed may object on the ground that the pleading is “uncertain” which includes the objection that it is “ambiguous and unintelligible.” California law requires that a complaint set out a “statement of the facts constituting the cause of action, in ordinary and concise language.” The requirement is that the allegations be “sufficiently clear to apprise the defendant of the issues he is to meet” or “the nature, source, and extent” of the cause of action. The “ ‘purpose of a complaint is to furnish the defendants with certain definite charges which can be intelligently met …. The point is that the accuser must place his finger squarely and directly upon whatever dereliction is relied upon [by plaintiff].'”
[California Affirmative Defenses [certain citations omitted]]
