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 _________________

10

11 Any Plaintiff, ) Case No.

)
12 Plaintiff, ) COMPLAINT FOR:
)
13 vs. ) 1. BAD FAITH RETENTION OF SECURITY
) DEPOSIT [CIVIL CODE 1950.5(l)
14 Any Defendant, and DOES 1-100, inclusive, ) 2. BREACH OF COVENANT OF GOOD FAITH
) AND FAIR DEALING
15 Defendants. ) 3. CONVERSION
) 4. UNFAIR BUSINESS PRACTICES
16 )
) UNLIMITED CIVIL, DEMAND OVER $25,000
17 )
)
18 )
)
19 )
)
20 )
)
21 )
)
22 )
)
23 )

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http://freeweeklylegalnewsletter.gr8.com/ and enter your e-mail
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28 address.
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CIVIL COMPLAINT
 1 For more information on my California eviction document
2

3
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4
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12 Plaintiff, _________________, hereby complains and alleges as follows:
13
1. Plaintiffs (Plaintiffs) are now, and at all times relevant herein were, individuals and
14
residents of the City of _________________, County of _________, State of California.
15

16 2. Defendant _________ (Defendant) is, and at all times relevant herein was, an

17 individual, and an owner of the real property located at ________________________, (Property)

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3. This court is the proper court for trial in this action in that the actions and omissions of
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Defendants as alleged herein were made within this Courts jurisdictional area.
20
4. Plaintiffs are unaware of the true names or capacities, whether they are individuals or
21

22 business entities, of Defendant DOES 1 through 100, and therefore sues them by such fictitious

23 names and will seek leave of this Court to insert true names and capacities once they have been
24
ascertained.
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5. At all times mentioned herein, Defendants, and each of them, inclusive of DOES 1 through
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100, were authorized and empowered by each other to act, and did so act, as agents of each other, and
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28 all of the things herein alleged to have been done by them were done in the capacity of such agency.

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CIVIL COMPLAINT
 1 Upon information and belief, all Defendants are responsible in some manner for the events described
2 herein and are liable to Plaintiffs for the damages they have incurred.
3
FIRST CAUSE OF ACTION
4
BAD FAITH RETENTION OF SECURITY DEPOSIT [CIVIL CODE 1950.5(l)]
5

6
(Against all Defendants)

7 6. Plaintiffs refer to, and incorporate by reference, the allegations of paragraphs 1 through

8 5 of this complaint, as though fully set forth herein.

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7. On ______________, Plaintiffs entered into a lease agreement with Defendant for the
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rental of real property located at _________________, (Premises) for a monthly rental rate of
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$______________ for a period of one year. The term was to begin on ____________. A true and
12

13 correct copy of said lease agreement is attached hereto as Exhibit 1 and incorporated herein by

14 reference.
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8. Pursuant to the terms of the lease agreement, Plaintiffs provided the sum of $_____ to
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Defendant as and for a security deposit.
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9. On __________, Plaintiffs vacated the Premises at the expiration of the lease
18

19 agreement.

20
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23
bad-faith-retention-of-security-deposit-in-california
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CIVIL COMPLAINT