SUPERIOR COURT OF THE STATE
OF CALIFORNIA
COUNTY OF ________
- [PLAINTIFF(S) NAMES]
- Plaintiffs,
- v.
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- [DEFENDANT(S) NAMES]
- Defendants
- ________________________________
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- CASE NO: _______
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- COMPLAINT FOR FRAUD
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Plaintiff complains and for causes of
action alleges as follows:
FIRST CAUSE OF ACTION
(For Fraud 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 ___ falsely and fraudulently represented
to plaintiff that ___.
<>. The representations made by defendant were in fact
false. The true facts were:___
<>. When the defendant made these representations ___ knew
them to be false, and these representations were made by defendant
with the intent to defraud and deceive plaintiff and with the
intent to induce plaintiff to act in the manner herein alleged.
(--AND ___ At the time defendant made the promises to plaintiff,
defendant had no intention of performing them.
<>. Plaintiff, at the time these representations were made
by defendant and at the time plaintiff took the actions herein
alleged, was ignorant of the falsity of defendant's representations
and believed them to be true. (---OR ___ Plaintiff, at the time
this promise was made and at the time plaintiff took the actions
herein alleged, was ignorant of defendant's secret intention
not to perform and plaintiff could not, in the exercise of reasonable
diligence, have discovered defendant's secret intention.) In
reliance on these representations, plaintiff was induced to and
did ___. Had plaintiff known the actual facts, ___ would not
have taken such action. (---OR ___ If plaintiff had known of
the actual intention of defendant, plaintiff would not have taken
such action.) Plaintiff's reliance on defendant's representations
was justified because ___.
<>. As a proximate result of defendant's fraud and deciet
and the facts herein alleged, plaintiff was ___ by reason of
which plaintiff has been damaged in the sum of $___.
<>. In doing the acts herein alleged, defendant acted with
oppression, fraud, and malice, and plaintiff is entitled to punitive
damages in the sum of $___.
WHEREFORE, plaintiff__ pray__ judgment
against defendant__ and each of them, as follows:
1. For general damages
in the sum of $___;
2. For damages for ___ in the sum of $___;
3. For punitive damages in the sum of $___;
4. For costs of suit incurred herein; and
5. For such other and further relief as the court may deem proper.
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DATED: _______________ |
__________________________________________ |
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(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: _________________ ___________________________________
