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Any Attorney
Any Street
Any Town, CA 55555
714-555-5555
Attorney for Plaintiff
Superior Court of the State of California
For the County of _________________
Any Plaintiff,
Plaintiff,
vs.
_____________________________1and DOES 1
through 100, inclusive
Defendants.
________________________________________
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Case No.
COMPLAINT FOR:
1. FRAUD
2. CONVERSION
3. UNFAIR BUSINESS PRACTICES
Plaintiff, ______________1hereby files a Complaint and alleges as follows:
ALLEGATIONS COMMON TO AND INCLUDED IN
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COMPLAINT FOR FRAUD, CONVERSION, UNFAIR BUSINESS PRACTICES

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ALL CAUSES OF ACTION
11. Plaintiffs, __________, and _______, (“Plaintiff” or “Plaintiffs” ) are now, and at all
relevant times mentioned herein were, individuals, residing and working in the County of
_____________, State of California, and are the record owners of the real property located at and
commonly known as ________________ (“Subject Property”).
2. Plaintiff is informed and believes, and thereon alleges, that defendant
______________________________________ (“_____”) is now, and at all relevant times
mentioned herein was, a company doing business at _________________________. Thus this Court
is the proper Court for the trial of this action.
3. Plaintiff is informed and believes, and thereon alleges, that defendant
______________________________________________, (“____________”) is now, and at all
relevant times mentioned herein was, a company doing business at _________________________.
Thus this Court is the proper Court for the trial of this action.
4. Plaintiff is informed and believes, and thereon alleges, that defendant
______________, (“___________”) is now, and at all relevant times mentioned herein was, an
individual, and one of the principal owners and operators of Defendants __________,
and worked at their offices located at ___________________________. Thus this Court is the proper
Court for the trial of this action. Defendant _________ was authorized by, and was acting on behalf
of, Defendants ___________, when he made the representations to Plaintiff alleged in this complaint.
5. Plaintiff is unaware of the true names or capacities, whether they are individuals or
business entities, of Defendant DOES 1 through 100, inclusive, and sues them by such fictitious
names. Plaintiff will seek leave of this Court to insert their true names and capacities once they have
been ascertained.
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COMPLAINT FOR FRAUD, CONVERSION, UNFAIR BUSINESS PRACTICES

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6. Plaintiff is informed and believe and upon such information and belief alleges,
that the defendants, _______________, and DOES 1 through 100 inclusive, were, at all times herein
mentioned, authorized and empowered by each other to act, and did so act, as agents of each other,
and all of the things herein alleged to have been done by them were done in the capacity of such
agency. Upon information and belief, all Defendants are responsible in some manner for the events
described herein and are liable to Plaintiff for the damages it has incurred.
7. On or about _____________, both Plaintiffs signed a written contract (“The
Agreement”) with Defendants, __________________. The essential terms of The Agreement were
that both Plaintiffs were to pay the sum of $_________ to Defendants. In exchange, Defendants,
agreed to perform all acts necessary to modify the loan that Plaintiffs owed to ________________
that secured the Subject Property, and Defendants were to apply the sum of $________ to the loan
that Plaintiffs owed to ____________ that secured the Subject Property. The Agreement was signed
by Defendant _________, who was authorized by, and acting on behalf of, Defendants ________
and ______________.
FIRST CAUSE OF ACTION
(Fraud as against all Defendants)
8. 1Plaintiff realleges the allegations contained in paragraphs 1 through 17, inclusive,
hereinabove, as though set forth in full herein, and incorporates them into this cause of action by
reference.
9. On or about __________, in the City of _______, County of ________, State of
California, Defendant _______, who was authorized by, and acting on behalf of Defendants
__________ and ________, made verbal and written representations to both Plaintiffs. The verbal
and written representations were that all Defendants had many years of experience in the real estate
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COMPLAINT FOR FRAUD, CONVERSION, UNFAIR BUSINESS PRACTICES

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industry, and that the Defendants would apply the sum of $________ paid to Defendants by both
Plaintiffs to the loan that Plaintiffs owed to ___________that secured the Subject Property. The
verbal and written representations were in fact false, but that fact was not known at the time by
Plaintiffs.
10. The true facts were that __________________________________.
11. On or about _____, and based on the representations made by Defendant __________,
Plaintiffs signed The Agreement, and paid the sum of $________ to Defendants.
12. The full extent of the fraud perpetrated upon Plaintiffs by Defendants was not
discovered until …
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COMPLAINT FOR FRAUD, CONVERSION, UNFAIR BUSINESS PRACTICES