SUPERIOR COURT OF THE STATE
COUNTY OF ________
- [PLAINTIFF(S) NAMES]
- [DEFENDANT(S) NAMES]
- CASE NO: _______
- COMPLAINT FOR BREACH OF
- IMPLIED COVENANT OF
- GOOD FAITH AND FAIR
Plaintiff complains and for causes of
action alleges as follows:
FIRST CAUSE OF ACTION
(For Breach Of Implied Covenant
Of Good Faith And Fair Dealing 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.
law implies a covenant of good faith and fair dealing in all
contracts between parties entered into in the State of California.
<>. As a result of the actions of defendants___, and each
of them, set forth hereinabove, said defendant___ have___ violated
the implied covenant of good faith and fair dealing contained
in ___ as against said Plaintiff___ herein, and as a result thereof,
Plaintiff___ is__ entitled to damages as prayed.
<>. The actions of said defendant___, in ____[--e.g. as
hereinbefore described---] in violation of said implied covenant
of good faith and fair dealing have caused the Plaintiff___ to
suffer damages in that ____ in the amount of ____.
WHEREFORE, plaintiff__ pray__ judgment
against defendant__ and each of them, as follows:
4. For such other and further relief
as the court deems proper.
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: _________________ ___________________________________