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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

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8 Superior Court of the State of California

9 For the County of _________________

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11 Any Plaintiff, ) Case No.
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12 Plaintiff, ) COMPLAINT FOR:
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13 vs. ) 1. BAD FAITH RETENTION OF SECURITY
) DEPOSIT [CIVIL CODE §1950.5(l)
14 Any Defendant, and DOES 1-100, inclusive, ) 2. BREACH OF COVENANT OF GOOD FAITH
) AND FAIR DEALING
15 Defendants. ) 3. CONVERSION
) 4. UNFAIR BUSINESS PRACTICES
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) UNLIMITED CIVIL, DEMAND OVER $25,000
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28 address.
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CIVIL COMPLAINT
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12 Plaintiff, _________________, hereby complains and alleges as follows:
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1. Plaintiffs (“Plaintiffs”) are now, and at all times relevant herein were, individuals and
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residents of the City of _________________, County of _________, State of California.
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16 2. Defendant _________ (“Defendant”) is, and at all times relevant herein was, an

17 individual, and an owner of the real property located at ________________________, (“Property”)
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3. This court is the proper court for trial in this action in that the actions and omissions of
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Defendants as alleged herein were made within this Court’s jurisdictional area.
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4. Plaintiffs are unaware of the true names or capacities, whether they are individuals or
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22 business entities, of Defendant DOES 1 through 100, and therefore sues them by such fictitious

23 names and will seek leave of this Court to insert true names and capacities once they have been
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ascertained.
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5. At all times mentioned herein, Defendants, and each of them, inclusive of DOES 1 through
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100, were authorized and empowered by each other to act, and did so act, as agents of each other, and
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28 all of the things herein alleged to have been done by them were done in the capacity of such agency.

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CIVIL COMPLAINT
1 Upon information and belief, all Defendants are responsible in some manner for the events described
2 herein and are liable to Plaintiffs for the damages they have incurred.
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FIRST CAUSE OF ACTION
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BAD FAITH RETENTION OF SECURITY DEPOSIT [CIVIL CODE §1950.5(l)]
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(Against all Defendants)

7 6. Plaintiffs refer to, and incorporate by reference, the allegations of paragraphs 1 through

8 5 of this complaint, as though fully set forth herein.
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7. On ______________, Plaintiffs entered into a lease agreement with Defendant for the
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rental of real property located at _________________, (Premises) for a monthly rental rate of
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$______________ for a period of one year. The term was to begin on ____________. A true and
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13 correct copy of said lease agreement is attached hereto as Exhibit “1” and incorporated herein by

14 reference.
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8. Pursuant to the terms of the lease agreement, Plaintiffs provided the sum of $_____ to
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Defendant as and for a security deposit.
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9. On __________, Plaintiffs vacated the Premises at the expiration of the lease
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19 agreement.

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CIVIL COMPLAINT