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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
ACCOUNTING

Plaintiff complains and for causes of action alleges as follows:

PRELIMINARY ALLEGATIONS

<>. 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.

 

FIRST CAUSE OF ACTION

(For Money Against ____)

<>. Plaintiff__ incorporate__ in this Cause of Action Paragraphs ___ through ___ herein the same as though fully set out in this Cause of Action at length.

<>. Within the last ___ (two or four) years on or about ___, 19__, at ___, California, defendant__ became indebted to plaintiff__ in the sum of $__ for money had and received by defendant__ for the use and benefit of plsintiff__.


<>. Neither the whole nor part of this sum has been paid [except the sum of $__] although demand therefor has been made, and there is now due, owing, and unpaid the sum of $___ with interest thereon at the rate of __ percent per annum from ___, 19__.

 

SECOND CAUSE OF ACTION

(For Money Lent Against ____)

<>. Within the last __ years on or about ___, 19__ at ___, California, defendant__ became indebted to plaintiff__ in the sum of $___ for money lent by plaintiff__ to defendant__ at defendant__ request.


<>. Neither the whole nor any part of the above sum has been paid, [except the sum of $__] although payment has been demanded, leaving a balance due, owing, and unpaid to plaintiff in the sum of $___, together with interest thereon at the rate of ___ per annum from ___, 19__.

 

THIRD CAUSE OF ACTION

(For Money Paid Against ____)

<>. Within the last __ years on or about ___, 19__ at ___, California, defendant__ became indebted to plaintiff__ in the sum of $___ for money paid, laid out, and expended for defendant at defendant__ instance and request.


<>. Neither the whole nor any part of the above sum has been paid, [except the sum of $__] although payment has been demanded, leaving a balance due, owing, and unpaid to plaintiff in the sum of $___, together with interest thereon at the rate of ___ per annum from ___, 19__.

 

FOURTH CAUSE OF ACTION

(For Work, Labor and Materials Against ____)

<>. Within the last ___ years on or about ___, 19__ at ___, California, defendant__ became indebted to plaintiff__ for work and labor done by plaintiff__ for defendant at the special instance and request of defendant__, and for materials furnished in connection with the work and labor, for the sum of $___ which sum defendant__ agreed to pay plaintiff__.


<>. Neither the whole nor any part of the above sum has been paid, [except the sum of $__] although demand therefor has been made, and there is now due and owing, and unpaid the sum of $__, with interest thereon at the rate of ___ percent per annum from ___, 19__.

 

FIFTH CAUSE OF ACTION

(For Work, Labor and Services Against ____)

<>. Within the last __ years on or about ___, 19__ at ___, California, defendant__ became indebted to plaintiff__ in the agree sum of $__ for work, labor, and services rendered by plaintiff__ at the special request of defendant__.


<>. Neither the whole nor any part of the above sum has been paid [except the sum of $__] not withstanding that demand has been made for payment, and there is now due, owing, and unpaid from defendant to plaintiff the sum of $___, together with interest thereon at the rate of __ percent per annum from ___, 19__.

 

SIXTH CAUSE OF ACTION

(For Quantum Meruit Against ____)

 

<>. Within the last __ years on or about ___, 19__ at __, California, plaintiff__ rendered work, labor, and services to defendant__ at the special request of defendant__ for which defendant__, then and there, promised to pay plaintiff__ the reasonable value of such services.


<>. At all times herein mentioned, the above services were and are of the reasonable value of $___.


<>. No part of the above sum has been paid, [except the sum of $__] not withstanding that plaintiff has demanded payment therefor, and there is now due, owing, and unpaid from defendant to plaintiff the sum of $___.

 

 

 

WHEREFORE, plaintiff__ pray__ judgment against defendant__ and each of them, as follows:

<> For damages for ____ according to proof.

<>. For interest from ____ at the rate of 10% per annum.

<>. For such other and further relief as the court may deem 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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