Kinsey Law Offices 
Complaint For Conversion (Theft)
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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
CONVERSION

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, namely: ______


<>. 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 $______.


[----CONTINUE-----]

 


<>. 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 _____, 19___;


[----<>. 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 in

pursuit of the converted property in the sum of _____;-----]
[-----<>. For punitive and exemplary damages in the sum of _____;-----
<>. For costs of suit herein incurred; and


<>. For such other and further relief as the court may deem proper.

 

 

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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