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Complaint For Fraud
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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 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.

 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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