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COMPLAINT FOR BREACH OF CONTRACT, FRAUD, ETC.
1 To view many more sample legal documents created by me, visit
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this website: https://legaldocspro.myshopify.com/products
4 Plaintiff, ______________hereby files a Complaint and alleges as follows:
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ALLEGATIONS COMMON TO AND INCLUDED IN
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ALL CAUSES OF ACTION
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1. Plaintiffs, __________, and _______, (Plaintiff or Plaintiffs ) are now, and at all
9 relevant times mentioned herein were, individuals, residing and working in the County of
15 County of ___________, California. Thus this Court is the proper Court for the trial of this action as
22 4. Defendant, __________ ("seller"), is now, and at all times mentioned in this complaint
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was, an individual residing in __________ County, California. This Court is the proper Court for the
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trial of this action as seller presently residing within its jurisdictional area.
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5. Plaintiff is unaware of the true names or capacities, whether they are individuals or
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27 business entities, of Defendant DOES 1 through 100, inclusive, and sues them by such fictitious
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COMPLAINT FOR BREACH OF CONTRACT, FRAUD, ETC.
1 names. Plaintiff will seek leave of this Court to insert their true names and capacities once they have
2 been ascertained.
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6. Plaintiff is informed and believe and upon such information and belief alleges,
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that the defendant, _______________, and DOES 1 through 100 inclusive, were, at all times herein
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mentioned, authorized and empowered by each other to act, and did so act, as agents of each other,
7 and all of the things herein alleged to have been done by them were done in the capacity of such
8 agency. Upon information and belief, all Defendants are responsible in some manner for the events
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described herein and are liable to Plaintiff for the damages it has incurred.
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7. The real property (Subject Property) that is the subject matter of this action is
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commonly described as __________________________________ in the City of ___________,
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14 DESCRIPTION FROM THE DEED AND THE ASSESSORS PARCEL NUMBER A.P.N.
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_______________.
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8. On or about __________ , broker and agent represented seller in seller's effort to sell
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Subject Property described in paragraph 5 of this complaint.
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to your particular situation.
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COMPLAINT FOR BREACH OF CONTRACT, FRAUD, ETC.
1 FIRST CAUSE OF ACTION FOR BREACH OF CONTRACT
2 (As against all Defendants)
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9. Plaintiff realleges the allegations contained in paragraphs 1 through 8, inclusive,
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hereinabove, as though set forth in full herein, and incorporates them into this cause of action by
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reference.
7 10. On or about __________ , plaintiff and seller entered into a written agreement in
8 which plaintiff agreed to purchase and seller agreed to sell the Subject Property. A copy of the written
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purchase and sale agreement ("the agreement") is attached hereto to this complaint as Exhibit
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__________ and is incorporated herein by reference. The agreement includes a provision for recovery
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of attorney fees by the prevailing party in the event an action is brought under the
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13 agreement.
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complaint-for-real-estate-fraud-against-seller-broker-and-agent
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COMPLAINT FOR BREACH OF CONTRACT, FRAUD, ETC.