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Complaint Breach Of Covenant Of Good Faith And Fair Dealing
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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
IMPLIED COVENANT OF
GOOD FAITH AND FAIR
DEALING

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.

<>. California 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:

1. ____

2. ___

3. ___

4. For such other and further relief as the court deems proper.

 

 DATED: _______________  __________________________________________
   (Signature)

 

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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