SUPERIOR COURT OF THE STATE
COUNTY OF ___Insert Name
of County Where Action Will be filed_____
- [PLAINTIFF(S) NAMES]
- [DEFENDANT(S) NAMES]
- CASE NO: _______
- COMPLAINT FOR
- UNFAIR BUSINESS PRACTICES
[Bus & Prof Code §17200]
IDENTIFICATION OF PARTIES
BASIS OF JURISDICTION
STATEMENT OF FACTS
Plaintiff complains and for causes of
action alleges as follows:
FIRST CAUSE OF ACTION
(Violation of Business
and Professions Code # 17200 Against ___)
[xx]. Defendant__, ___ is__, and
at all times herein mentioned was__, a resident__ of the City
of ___, County of __, State of California.
[xx]. 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 ___.
3. 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.
4. 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.
fraudulent, deceptive, unfair, other wrongful conduct----]
6. 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 _____.
7. 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
5. For injunctive relief
4. For such other and further relief
as the court may deem proper.
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: _________________ ___________________________________