“The essential elements to pleading an action for negligent entrustment of a motor vehicle under California law are: 1. The driver of the vehicle was negligent in its operation; 2. The defendant either owned the vehicle operated by the driver or possessed the vehicle with the owner’s permission; 3. The defendant knew or should have known the driver was incompetent or unfit to drive the vehicle; 4. The defendant permitted the driver to operate the vehicle; and 5. The driver’s incompetence or unfitness to drive was a substantial factor in causing harm to the plaintiff.”
[California Elements of an Action [certain citations omitted]]
