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 Conversion 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.
<>. At all times herein mentioned, and in particular
on or about ____, 19___, plaintiff___ was___, and still is_____[---
entitled to the possession of the following personal property,
<>. On or about ____, 19___, and at _____, California,
the above-mentioned property had a value of $______.
<>. On or about _____, 19___, defendant _____[----took
the above-mentioned property from plaintiff's possession and
converted the same to ___ own use.
[----OPTIONAL: WHERE LAWFULLY ACQUIRED----]
<>. On or about ____, 19___, plaintiff___ demanded the
immediate return of the above-mentioned property but defendant___
failed and refused, and continues___ to fail and refuse, to return
the property to plaintiff___. A copy of plaintiff___ written
demand for return of the property is attached hereto as Exhibit
_____ and made a part hereof.
[---OPTIONAL IF SEEKING ALTERNATIVE
DAMAGES UNDER CC 3336-----]
<>. As a proximate
result of defendant's___ conversion, plaintiff suffered the following
damages which are the natural, reasonable, and proximate results
of the conversion: _______, all to plaintiff's____ damage in
the sum of $______.
<>. Between the time of defendant's___ conversion of the
above-mentioned property to ___ own use and the filing of this
action plaintiff___ expended the following time and money in
poursuit of the converted property, all to plaintiff's___ further
damage in the sum of $_____.
<>. The aforementioned acts of defendant___ were___ wilful,
wanton, malicious, and oppressive, were undertaken with the intent
to defraud, and justify the awarding of exemplary and punitive
damages in the amount of $_______.
WHEREFORE, plaintiff__ pray__ judgment
against defendant__ and each of them, as follows:
<>. For the
value of the property converted in the sum of $_____;
<>. For interest at the legal rate on the foregoing sum
pursuant to Section 3336 of the Civil Code, from and after _____,
[----<>. For damages for the proximate and forseeable loss
resulting from defendant's conversion in the sum of $_____;-----]
[-----<>. For damages for time and money properly expended
pursuit of the converted
property in the sum of _____;-----]
[-----<>. For punitive and exemplary damages in the sum
<>. For costs of suit herein incurred; and
<>. For such other and further relief as the court may
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: _________________ ___________________________________