SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF ________
- [PLAINTIFF(S) NAMES]
- Plaintiffs,
- v.
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- [DEFENDANT(S) NAMES]
- Defendants
- ________________________________
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- CASE NO: _______
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- COMPLAINT FOR
- BREACH OF CONTRACT
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Plaintiff complains and for causes of action alleges as
follows:
FIRST CAUSE OF ACTION
(For Breach Of Contract 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.
<>. On or about ___, 19__, in the City of ___, County
of ___, State of California, Plaintiff and defendant entered
into a written agreement, a copy of which is attached hereto
as Exhibit "A" and made a part hereof. By the terms
of said written agreement, ___.
<>. The consideration set forth in the agreement
was the fair and reasonable.
<>. Plaintiff has performed all conditions, covenants,
and promises required by him on his part to be performed in accordance
with the terms and conditions of the contract.
<>. On or about ___, 19__ the defendant__ breached
the said agreement by _____.
<>. By reason of defendant__ breach of said contract
as herein alleged, the plaintiff__ has__ suffered damages in
the sum of $__.
<>. By the terms of said written agreement, the Plaintiff
is entitled to recover reasonable attorney fees incurred in the
enforcement of the provisions of the agreement. By reason of
the aforementioned breach of the defendant, the Plaintiff has
been forced to secure the services of the legal firm of THE LAW
OFFICES OF EUGENE E. KINSEY, INC. to prosecute this lawsuit.
WHEREFORE, plaintiff__ pray__ judgment against defendant__
and each of them, as follows:
<>. For compensatory damages in the sum of $___;
<>. For interest on the sum of $___ from and after
___, 19__ to date of judgment;
<>. For reasonable attorney fees according to proof;
<>. For costs of suit herein incurred; and
<>. For such other and further relief as the court
may deem proper.
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.
DATED: _________________ ___________________________________
