Documente Academic
Documente Profesional
Documente Cultură
Sample Only
[PLAINTIFF(S) NAMES]
Plaintiffs,
v.
[DEFENDANT(S) NAMES]
Defendants
________________________________
)
)
)
)
)
)
)
)
)
)
)
<>. Defendant__, ___ is__, and at all times herein mentioned was__, a
resident__ of the City of ___, County of __, State of California.
<>. Defendant__, ___, is__, and at all times herein mentioned, was__ a
Corporation organized and existing under the laws of the State of California
with principle offices located at ___, in the City of ___, County of ___.
<>. Plaintiff__ is__ ignorant of the true names and capacities of defendants
sued herein as DOES I through X, inclusive, and therefore sues__ these
defendants by such fictitious names. Plaintiff__ will amend this complaint to
allege their true names and capacities when ascertained.
<>. Plaintiff__ is__ informed and believes__ and thereon alleges__ that, at all
times herein mentioned, each of the defendants sued herein was the agent
and employee of each of the remaining defendants and was at all times
acting within the purpose and scope of such agency and employment.
[---ALTERNATIVE ALLEGATIONS---]
<>. On or about ___, 19__, in ___, California, plaintiff__ and
defendant__ entered into a written [---or oral---] contract whereby
plaintiff__ and defendant__ agreed ____.
<>. On or about ____, defendant__, with intent to deceive
plaintiff__ and to induce ___ to enter into said contract, [--set forth
misrep, falsity, defendant's knowledge---]. Plaintiff, in reasonable
reliance thereon, entered into said contract
<>. Under the terms of the contract, plaintiff has ___ [---facts
showing P's performance, excuse for nonperformance,
impossibility---], and plaintiff has [---describe consideration
supplied by plaintiff---].
<>. Under the terms of the contract, defendant has [---facts
showing defendant's nonperformance---]
VERIFICATION
I, ___, am a ___in the above-entitled action. I have read the foregoing ___and
know the contents thereof. The same is true of my own knowledge, except as
to those matters which are therein alleged on information and belief, and as
to those matters, I believe it to be true.
I declare under penalty of perjury that the foregoing is true and correct and
that this declaration was executed at Long Beach, California.