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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.


)
12 Plaintiff, )
) UNLIMITED CIVIL, DEMAND OVER $25,000.00
13 vs. )
) COMPLAINT FOR:
14 Any Defendant; and DOES 1 through 100, )
inclusive, ) 1. BREACH OF CONTRACT
15 ) 2. FRAUD-INTENTIONAL
) MISREPRESENTATION
16 Defendants. ) 3. PROFESSIONAL NEGLIGENCE
)
17 _________________________________________ )

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27 Plaintiffs, __________ and ___________, hereby complain and allege as follows:
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COMPLAINT FOR BREACH OF CONTRACT, FRAUD, PROFESSIONAL NEGLIGENCE
1 1. Plaintiffs ____________ and ____________, (hereinafter referred to as Plaintiffs) are
2 now, and all times herein mentioned were, individuals residing in the City of ______________,
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County of _____________, State of California.
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2. Defendant ______________ (hereinafter referred to as Defendant) upon information
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and belief, is now, and at all times mentioned herein was, an individual, and a licensed attorney doing

7 business in the City of __________, County of ___________, State of California.

8 3. This court is the proper court for trial in this action in that the legal services that were
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provided by Defendant _________ to Plaintiffs were provided in the City of ___________, County of
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____________, State of California.
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4. Plaintiffs are unaware of the true names or capacities, whether they are individuals or
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13 business entities, of Defendant DOES 1 through 100 inclusive, and therefore sue them by such

14 fictitious names and will seek leave of this Court to insert true names and capacities once they have
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been ascertained.
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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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19 other, and all of the things herein alleged to have been done by them were done in the capacity of

20 such agency. Upon information and belief, all Defendants are responsible in some manner for the
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events described herein and are liable to Plaintiffs for the damages they have incurred.
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FIRST CAUSE OF ACTION
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BREACH OF CONTRACT AS AGAINST DEFENDANT ____________
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25 6. Plaintiffs repeat, replead and reallege each and every allegation set forth in paragraphs

26 1 through 5, inclusive, of this complaint, as though set forth hereat.


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7. On or about ______________, Plaintiffs entered into a contract with Defendant
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COMPLAINT FOR BREACH OF CONTRACT, FRAUD, PROFESSIONAL NEGLIGENCE
1 ________. The contract specified that Defendant ________ would provide legal services to
2 Defendants, in the case of _____________ Case No. ____________, in the __________ County
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Superior Court, __________ District (herein after referred to as the case). Plaintiffs paid Defendant
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an initial retainer of $_________ when said contract was entered into. Plaintiffs paid an additional
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$____________ to Defendant ________ subsequent to the signing of said contract. A true and

7 correct copy of said contract is attached hereto as Exhibit 1 and incorporated herein by reference.

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professional-negligence-in-california
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COMPLAINT FOR BREACH OF CONTRACT, FRAUD, PROFESSIONAL NEGLIGENCE