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1 Any Attorney or Party

Any Street
2 Any Town, CA 55555

3 714-555-5555

4 Any Attorney or Party

8 Superior Court of the State of California

9 For the County of _________________

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11 Any Plaintiff, ) Case No.


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12 Plaintiff, ) VERIFIED COMPLAINT FOR:
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13 vs. ) 1. BREACH OF CONTRACT
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14 Any Defendant, and DOES 1-100, inclusive, ) 2. FORECLOSURE OF MECHANICS LIEN
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15 Defendants. ) UNLIMITED CIVIL, DEMAND OVER $25,000
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COMPLAINT FOR BREACH OF CONTRACT AND FORECLOSURE OF MECHANICS LIEN
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Plaintiff, _________________, hereby complains and allege as follows:
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1. Plaintiff is now, and at all relevant times mentioned in this complaint was, a
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corporation organized and existing under the laws of the State of California, with its principal place

7 of business in __________ County, California, duly licensed by the Contractors State License Board

8 of California in License Number _____________ to perform the work alleged in this complaint.
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2. At all times relevant mentioned in this complaint plaintiff was, and is, doing business
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under the fictitious name of __________. Plaintiff has filed the statement and published the notice
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required by section 17918 of the Business and Professions Code.
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13 3. Plaintiff is informed and believes, and based thereon alleges, that defendant _______

14 (hereinafter Defendant) is an individual and a resident of the County of ________, State of


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California.
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4. Plaintiff is ignorant of the true names and capacities of the Defendants sued herein as
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Does 1 through 100, inclusive, and therefore sues these Defendants by such fictitious names and will
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19 seek leave of this Court to insert true names and capacities once they have been ascertained.

20 5. At all times mentioned herein, Defendants, and each of them, inclusive of DOES 1
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through 100, 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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25 events described herein and are liable to Plaintiff for the damages they have incurred.

26 6. The real property ("the Property") referred to in this complaint is located in the City of
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__________, County of __________, State of California, and is commonly known as
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COMPLAINT FOR BREACH OF CONTRACT AND FORECLOSURE OF MECHANICS LIEN
1 __________ [address or location]. The real property is more particularly described as INSERT
2 FULL LEGAL DESCRIPTION FROM THE DEED AND THE ASSESSORS PARCEL
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NUMBER A.P.N. ALSO ADD THE STREET ADDRESS IF APPLICABLE.
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8 foreclosure-of-mechanics-lien-in-california
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COMPLAINT FOR BREACH OF CONTRACT AND FORECLOSURE OF MECHANICS LIEN

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