1 Any Attorney or Party

Any Street
2 Any Town, CA 55555

3 714-555-5555

4 Any Attorney or Party

5

6

7

8 Superior Court of the State of California

9 For the County of _________________

10

11 Any Plaintiff, ) Case No
)
12 ) UNLIMITED CIVIL-DEMAND OVER $25,000
Plaintiff, )
13 ) VERIFIED COMPLAINT FOR:
)
14 vs. ) 1. MONEY HAD AND RECEIVED
) 2. FRAUD
15 Any Defendant, and DOES 1 through 100, ) 3. CONVERSION
inclusive, ) 4. VIOLATION OF PENAL CODE SECTION
16 ) 496(a)
Defendants. )
17 )
)
18 )
)
19 )

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- 1 –
VERIFIED COMPLAINT FOR CONVERSION, FRAUD, ETC.
1 Be sure to remove this notice and all other notices before using
2

3
this document.
4 Plaintiff, ___________, an individual, by and though their undersigned counsel, hereby files a
5
Complaint and alleges as follows:
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ALLEGATIONS COMMON TO AND INCLUDED IN ALL CAUSES OF ACTION
7

8
1. Plaintiff, _______________ an individual, (“Plaintiff”) is now, and at all relevant

9 times mentioned herein was, an individual, residing in the City of __________, County

10 of_____________, State of California.
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2. Plaintiff is informed and believes, and thereon alleges, that defendant __________, an
12
individual, (“Defendant ____”) is now, and at all relevant times mentioned herein was, an individual,
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residing in the City of _________, County of ________, State of California. Thus this Court is the
14

15 proper Court for the trial of this action.

16 3. Plaintiff is informed and believes, and thereon alleges, that he is unaware of the true
17
names or capacities, whether they are individuals or business entities, of Defendant DOES 1 through
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100, inclusive, and sues them by such fictitious names. Plaintiff will seek leave of this Court to insert
19
their true names and capacities once they have been ascertained.
20

21 4. Plaintiff is informed and believe and upon such information and belief alleges,

22 that Defendant _________, and DOES 1 through 100 inclusive, were, at all times herein mentioned,
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authorized and empowered by each other to act, and did so act, as agents of each other, and all of the
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things herein alleged to have been done by them were done in the capacity of such agency. Upon
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information and belief, all Defendants are responsible in some manner for the events described herein
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27 and are liable to Plaintiff for the damages he has incurred.

28

- 2 –
VERIFIED COMPLAINT FOR CONVERSION, FRAUD, ETC.
1 5. On or about ___________, Plaintiff received a check in the amount of $_________
2 (“Check”) from the _______ client trust account as his share of a settlement of a civil case
3
for_____________________. A true and correct copy of said check is attached hereto as Exhibit “1”
4
and incorporated herein by reference.
5

6
6. Plaintiff is developmentally disabled and has a learning disability and does not have a

7 bank account.

8 7. On or about ___________, Defendant _________, who at that time was the girlfriend
9
of Plaintiff, verbally promised Plaintiff that if he would deposit the Check into her bank account that
10
she would then withdraw the funds from her bank account and give the funds back to him.
11
8. Plaintiff endorsed the Check to Defendant _________ and she then deposited the
12

13 Check into her bank account.

14 9. After Defendant _________ deposited the Check into her bank account she terminated
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her relationship with Plaintiff and has refused, and continues to fail and refuse, to give the funds to
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Plaintiff.
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10. On _________, counsel for Plaintiff, sent a letter to Defendant _________ demanding
18

19 that she give the funds to Plaintiff no later than _________. A true and correct copy of said letter is

20 attached hereto as Exhibit “2” and incorporated herein by reference.
21
11. Defendant _________ failed to respond to the letter sent to her and has failed and
22
refused, and continues to fail and refuse to give the funds to Plaintiff as she had verbally promised
23
him.
24

25 Be sure to modify these paragraphs to suit your individual
26
situation. Do NOT just use the wording here unless it definitely applies
27

28 to your particular situation.
- 3 –
VERIFIED COMPLAINT FOR CONVERSION, FRAUD, ETC.
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2

3 https://legaldocspro.myshopify.com/products/sample-verified-
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complaint-for-damages-under-penal-code-section-496c
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- 4 –
VERIFIED COMPLAINT FOR CONVERSION, FRAUD, ETC.