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
- INJUNCTION
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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.
<>. Beginning on or about ___, 19__, and continuing to
the present time, defendants, and each of them, wrongfully and
unlawfully ___.
<>. On or about ___, 19__, and a number of times since
then, plaintiff__ has__ demanded that defendants stop their wrongful
conduct described above. Defendants, and each of them, have refused
and still refuse to refrain from their wrongful conduct.
<>. Defendants' wrongful conduct, unless and until enjoined
and restrained by order of this court, will cause great and irreparable
injury to plaintiff__ in that ___.
<>. Plaintiff__ has__ no adequate remedy at law for the
injuries currently being suffered in that ___ (it will be impossible
for plaintiff__ to determine the precise amount of damage which
__ will suffer if defendants' conduct is not restrained) (plaintiff
will be forced to institute a multiplicity of suits to obtain
adeauate compensation for ___ injuries.
<>. As a result of defendants' wrongful conduct, plaintiff__
has__ been damaged in the sum of $___. Plaintiff__ will be further
damaged in like manner so long as defendants' conduct continues.
The full amount of such damage is not now known to plaintiff__,
and plaintiff__ will amend this complaint to state such amount
when the same becomes known to __, or on proof thereof.
WHEREFORE, plaintiff__ pray__ judgment
against defendant__ and each of them, as follows:
1. For an order
requiring defendants to show cause, if any they have, why they
should not be enjoined as hereinafter set forth, during the pendency
of this action;
2. For a temporary restraining order, a preliminary injunction,
and a permanent injunction, all enjoining defendants, and each
of them, and their agents, servants, and employees, and all persons
acting under, in concert with, or for them:
A. From ___;
B. To ___;
3. For damages in the sum of $___, plus damages in such further
sums as may be sustained and as are ascertained before final
judgment herein;
4. For attorney fees herein incurred;
5. For costs of suit herein incurred; and
6. For such other and further relief as the court deems 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: _________________ ___________________________________
