Kinsey Law Offices 
Complaint For Breach Of Contract
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    (Name, Address Of Party or attorney)
    ____________
    ____________
    ____________
    State Bar No: ______
    (____) _____ - ________
    Attorney for _______ (Or "In Pro Per")

 

SUPERIOR COURT OF THE STATE OF CALIFORNIA

COUNTY OF ________

 

[PLAINTIFF(S) NAMES]
Plaintiffs,

 

v.

 

 
[DEFENDANT(S) NAMES]
Defendants
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CASE NO: _______
 
COMPLAINT FOR
BREACH OF CONTRACT

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: _________________ ___________________________________

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