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
- ACCOUNTING
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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.
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DATED: _______________ |
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(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: _________________ ___________________________________
