Kinsey Law Offices 
Complaint For Constructive Trust
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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
CONSTRUCTIVE TRUST

Plaintiff complains and for causes of action alleges as follows:

FIRST CAUSE OF ACTION

(For ________ 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.


<>. As a proximate result of the defendant___ fraudulent misrepresentatios and otherwise wrongful conduct as elleged herein, Plaintiff__ is__ [----state threatened damages---]


<>. By reason of the fraudulent and otherwise wrongful manner in which the defendants___, or any of them, obtained their alleged right, claim or interest in and to the property, defendant___, and each of them, have no legal or equitable right, claim or interest therein, but, instead, Defendant___, and each of them are involuntary trustees holding said property and profits therefrom in constructive trust for Plaintiff___ with the duty to convey the same to Plaintiff___ forthwith.

 

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

<>. For a declaration that Defendant___ hold the ___ as constructive trustees for the benefit of the Plaintiff___;
<>. For costs of suit incurred herein; and
<>. 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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