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COMPLAINT FOR DAMAGES FOR SLANDER
1 both their personal and professional life, and is well respected in both their local business community,
2 as well as their local community.
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2. Defendant ______________, (hereinafter referred to as Defendant) upon
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information and belief, is now, and at all times mentioned herein was, an individual, over the age of
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majority, residing in the City of _________, County of _________, State of California.
7 3. This court is the proper court for trial in this action in that the actions and omissions of
8 Defendant as alleged herein were made within this Courts jurisdictional area.
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4. Plaintiff is unaware of the true names or capacities, whether they are individuals or
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business entities, of Defendant DOES 1 through 50, and therefore sues them by such fictitious
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names and will seek leave of this Court to insert true names and capacities once they have been
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13 ascertained.
14 5. At all times mentioned herein, Defendants, and each of them, inclusive of DOES
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1 through 50, were authorized and empowered by each other to act, and did so act, as agents of each
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other, and all of the things herein alleged to have been done by them were done in the capacity of
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such agency. Upon information and belief, all Defendants are responsible in some manner for the
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19 events described herein and are liable to Plaintiff for the damages they have incurred.
26 made the following defamatory statement about, of, and concerning Plaintiff:
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_____________________. Defendant made said statement in person to _______________________.
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COMPLAINT FOR DAMAGES FOR SLANDER
1 8. ______________reasonably understood that the statement referred to Plaintiff and
2 reasonably understood them to mean that Plaintiff was ______________________________.
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9. The aforesaid defamatory statement made allegedly by Defendant was and is false and
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was not privileged. Defendant made said statement knowing the falsity thereof or without using
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reasonable care to determine the truth or falsity thereof.
7 10. Defendant made the aforesaid defamatory statement with malice and with the intent to
8 injure Plaintiffs good name and reputation and to interfere with their employment, in that defendant
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harbored ill-will toward Plaintiff.
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11. The aforesaid defamatory statement has harmed plaintiffs reputation; such a statement
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has a tendency to injure and has injured Plaintiff in their occupation, their future business and
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13 employment prospects have been severely harmed, Plaintiff has had to incur substantial expense, in
14 order to redress the harm they have suffered, all to Plaintiffs general and actual damages, including
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exemplary and punitive damages, in an amount which far exceeds the jurisdictional minimum of this
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Court, and which will be proven at trial.
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SECOND CAUSE OF ACTION
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20 12. Plaintiff realleges and incorporates by reference paragraphs 1 through 11, above, as
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though fully set forth herein.
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13. Plaintiff is informed and believes that on ________________, at ____, California,
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Defendant made the following defamatory statement about, of, and concerning Plaintiff:
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COMPLAINT FOR DAMAGES FOR SLANDER
1 15. The aforesaid defamatory statement made allegedly by Defendant was and is false and
2 was not privileged. Defendant made said statement knowing the falsity thereof or without using
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reasonable care to determine the truth or falsity thereof.
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16. Defendant made the aforesaid defamatory statement with malice and with the intent to
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injure Plaintiffs good name and reputation and to interfere with their employment, in that defendant
8 17. The aforesaid defamatory statement has harmed plaintiffs reputation; such a statement
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has a tendency to injure and has injured Plaintiff in their occupation, their future business and
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employment prospects have been severely harmed, Plaintiff has had to incur substantial expense, in
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order to redress the harm they have suffered, all to Plaintiffs general and actual damages, including
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13 exemplary and punitive damages, in an amount which far exceeds the jurisdictional minimum of this
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COMPLAINT FOR DAMAGES FOR SLANDER
1 21. The aforesaid defamatory statement made allegedly by Defendant was and is false and
2 was not privileged. Defendant made said statement knowing the falsity thereof or without using
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reasonable care to determine the truth or falsity thereof.
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22. Defendant made the aforesaid defamatory statement with malice and with the intent to
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injure Plaintiffs good name and reputation and to interfere with their employment, in that defendant
8 23. The aforesaid defamatory statement has harmed plaintiffs reputation; such a statement
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has a tendency to injure and has injured Plaintiff in their occupation, their future business and
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employment prospects have been severely harmed, Plaintiff has had to incur substantial expense, in
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order to redress the harm they have suffered, all to Plaintiffs general and actual damages, including
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13 exemplary and punitive damages, in an amount which far exceeds the jurisdictional minimum of this
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COMPLAINT FOR DAMAGES FOR SLANDER
1 27. The aforesaid defamatory statement made allegedly by Defendant was and is false and
2 was not privileged. Defendant made said statement knowing the falsity thereof or without using
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reasonable care to determine the truth or falsity thereof.
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28. Defendant made the aforesaid defamatory statement with malice and with the intent to
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injure Plaintiffs good name and reputation and to interfere with their employment, in that defendant
8 29. The aforesaid defamatory statement has harmed plaintiffs reputation; such a statement
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has a tendency to injure and has injured Plaintiff in their occupation, their future business and
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employment prospects have been severely harmed, Plaintiff has had to incur substantial expense, in
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order to redress the harm they have suffered, all to Plaintiffs general and actual damages, including
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13 exemplary and punitive damages, in an amount which far exceeds the jurisdictional minimum of this
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COMPLAINT FOR DAMAGES FOR SLANDER
1 33. The aforesaid defamatory statement made allegedly by Defendant was and is false and
2 was not privileged. Defendant made said statement knowing the falsity thereof or without using
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reasonable care to determine the truth or falsity thereof.
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34. Defendant made the aforesaid defamatory statement with malice and with the intent to
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injure Plaintiffs good name and reputation and to interfere with their employment, in that defendant
8 35. The aforesaid defamatory statement has harmed plaintiffs reputation; such a statement
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has a tendency to injure and has injured Plaintiff in their occupation, their future business and
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employment prospects have been severely harmed, Plaintiff has had to incur substantial expense, in
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order to redress the harm they have suffered, all to Plaintiffs general and actual damages, including
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13 exemplary and punitive damages, in an amount which far exceeds the jurisdictional minimum of this
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prepare a Summons, and a Civil Cover Sheet when you file the
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complaint. Some counties have a local cover sheet as well. Check your
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6 local rules.
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8 Dated________________ _______________________________________________
ANY ATTORNEY OR PARTY
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COMPLAINT FOR DAMAGES FOR SLANDER