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    (Name, Address Of Party or attorney)
    State Bar No: ______
    (____) _____ - ________
    Attorney for _______ (Or "In Pro Per")



COUNTY OF ________






CASE NO: _______

Plaintiff complains and for causes of action alleges as follows:


(For ________ Against ____)


<>. 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.

<>. [----- Allege the relationship between plaintiff and defendant or other circumstances appropriate to an accounting-----]

<>. As a result of the aforementioned ______, defendant___ has___ received money, a portion of which is due to plaintiff____ from defendant____, as previously alleged.

<>. The amount of money due from defendant____ to plainfiff____ is unknown to plaintiff___ and cannot be ascertained without an accounting of the _____[-----receipts and disbursements of the aforementioned transactions-----]. Plaintiff__ is___ informed and believes and thereon alleges that the amount due to plaintiff___ exceeds $_____.

<>. Plaintiff___ has___ demanded an accounting of the aforementioned _____[---transactions----] from defendant___ and payment of the amount found due but defendant has failed and refused, and continues to fail and refuse, to render such an accounting and to pay such sum.



WHEREFORE, plaintiff__ pray__ judgment against defendant__ and each of them, as follows:

<>. For an accounting between plaintiff___ and defendant___;
<>. For the amount found to be due from defendant to plaintiff as a result of the accounting and interest on that amount from and after ____, 19___;
<>. For costs of suit herein incurred.
<>. For such other and further relief as the court may deem proper.


 DATED: _______________  __________________________________________






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.



DATED: _________________ ___________________________________

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