Kinsey Law Offices 
Complaint For Specific Performance
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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
SPECIFIC PERFORMANCE

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.

<>. On or about ___, 19__, in the City of ___, County of ___, State of California, Plaintiff and defendant entered into a written agreement, a copy of which is attached hereto as Exhibit "A" and made a part hereof. By the terms of said written agreement, ___.


<>. The consideration set forth in the agreement was the fair and reasonable.


<>. Plaintiff has performed all conditions, covenants, and promises required by him on his part to be performed in accordance with the terms and conditions of the contract.


<>. Defendant has failed and refused, and continues to fail and refuse, to perform the conditions of the contract on his part in that ___.


<>. Plaintiff has no adequate legal remedy in that ___ (damages, if awarded, cannot be properly ascertained since there is no fixed market value and damages will be inadequate to compensate.


<>. By the terms of said written agreement, the Plaintiff is entitled to recover reasonable attorney fees incurred in the enforcement of the provisions of the agreement. By reason of the aforementioned breach of the defendant, the Plaintiff has been forced to secure the services of the legal firm of KINSEY AND LASHLEE to prosecute this lawsuit.

 

WHEREFORE, plaintiff__ pray__ judgment against defendant__ and each of them, as follows:

<>. For damages for ____

<>. For an order requiring defendant to _____

<>. 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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