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



COUNTY OF ________






CASE NO: _______

Plaintiff complains and for causes of action alleges as follows:


(For Conspiracy 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__, Defendant___ and each of them knowingly and willfully conspired and agreed among themselves to _____.

<>. [----Here and in subsequent paragraphs as necessary, allege facts constituting the tort or other civil wrong committed by defendants and the injury caused thereby to plaintiff.----]

<>. Defendant___ and each of them did the acts and things herein alleged pursuant to, and in furtherance of, the conspiracy and above-alleged agreement.
<>. Defendant___ , furthered the conspiracy by cooperation with [---or--- lent aid and encouragement to----or---ratified and adopted the acts of----] defendants, ____ in that _______.

<>. As a proximate result of the wrongful acts herein alleged plaintiff___ has___ been generally damaged in the sum of $____.

<>. [---Here and in subsequent paragraphs, allege items of special damages----]

<>. Defendant___ did the things herein alleged maliciously and to oppress plaintiff___. Plaintiff___ is__ therefore entitled to exemplary or punitive damages in the sum 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 may deem proper.


 DATED: _______________  __________________________________________






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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