SUPERIOR COURT OF THE STATE
COUNTY OF ________
- [PLAINTIFF(S) NAMES]
- [DEFENDANT(S) NAMES]
- CASE NO: _______
- COMPLAINT FOR
Plaintiff complains and for causes of
action alleges as follows:
FIRST CAUSE OF ACTION
(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___
<>. 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
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
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: _________________ ___________________________________