Kinsey Law Offices 
Complaint For Unfair Business Practices
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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
UNFAIR BUSINESS PRACTICES

Plaintiff complains and for causes of action alleges as follows:

FIRST CAUSE OF ACTION

(Violation of Business and Professions Code # 17200 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.

<>. [---Describe fraudulent, deceptive, unfair, other wrongful conduct----]


<>. By reason of Defendant___, ____, fraudulent, deceptive, unfair, and other wrongful conduct as herein alleged, said Defendant___ has___ violated California Business and Professions Code #17200\et seq.\ by consummating an unlawful, unfair, and fraudulent business practice, designed to deprive plaintiff__ of _____.


<>. By reason of the foregoing, Plaintiff__ has___ suffered and continues___ to suffer damages in a sum which is, as yet unascertained. Plaintiff___ will ask leave of court to amend ___ complaint when the true nature and extent of ___ damages have been ascertained.

 

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

1. For damages in the amount of $_______

2. For interest from ______ at 10% per annum from _______.

3. For punitive damages according to proof,

4. 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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