SUPERIOR COURT OF THE STATE
COUNTY OF ________
- [PLAINTIFF(S) NAMES]
- [DEFENDANT(S) NAMES]
- CASE NO: _______
- COMPLAINT FOR
Plaintiff complains and for causes of
action alleges as follows:
FIRST CAUSE OF ACTION
(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
<>. [----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:
4. For such other and further relief
as the court may deem 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: _________________ ___________________________________