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(Name, Address of Party or Attorney)
____________
____________
____________
State Bar No: ______
(____) _____ - ________
Attorney for _______ (Or "In Pro Per")

SUPERIOR COURT OF THE STATE OF
CALIFORNIA
COUNTY OF ________

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Plaintiff complains and for causes of

action alleges as follows:
FIRST CAUSE OF ACTION
(For ________ Against ____)

<>. Defendant__, ___ is__, and at all
times herein mentioned was__, a
resident__ of the City of ___, County of
__, State of California.
<>. 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 ___.
<>. 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.
<>. 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.
<>. As a proximate result of the defendant___ fraudulent misrepresentations and otherwise
wrongful conduct as elleged herein, Plaintiff__ is__ [----state threatened damages---]
<>. By reason of the fraudulent and otherwise wrongful manner in which the defendants___, or
any of them, obtained their alleged right, claim or interest in and to the property, defendant___,
and each of them, have no legal or equitable right, claim or interest therein, but, instead,
Defendant___, and each of them are involuntary trustees holding said property and profits
therefrom in constructive trust for Plaintiff___ with the duty to convey the same to Plaintiff___

forthwith.


[HEREFORE, plaintiff__ pray__
judgment against defendant__ and each
of them, as follows:
<>. For a declaration that Defendant___ hold the ___ as constructive trustees for the benefit of the
Plaintiff___;
<>. For costs of suit incurred herein; and
<>. For such other and further relief as the court may deem proper. 
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GERIFICATION


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: _________________
___________________________________
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