12345678910111213141516171819202122232425262728Any AttorneyAny StreetAny Town, CA 55555714-555-5555Attorney for PlaintiffS...
12345678910111213141516171819202122232425262728ALL CAUSES OF ACTION11. Plaintiffs, __________, and _______, (“Plaintiff” o...
123456789101112131415161718192021222324252627286. Plaintiff is informed and believe and upon such information and belief a...
12345678910111213141516171819202122232425262728industry, and that the Defendants would apply the sum of $________ paid to ...
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Sample California complaint for unfair business practices

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This sample California complaint for unfair business practices pursuant to California Business and Professions Code Sections 17200, et seq., which is known as the Unfair Competition Law or UCL. The sample contains causes of action for fraud and conversion. The sample could be modified to add other causes of action as well. This is a preview of the sample complaint sold by LegalDocsPro.

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Sample California complaint for unfair business practices

  1. 1. 12345678910111213141516171819202122232425262728Any AttorneyAny StreetAny Town, CA 55555714-555-5555Attorney for PlaintiffSuperior Court of the State of CaliforniaFor the County of _________________Any Plaintiff,Plaintiff,vs._____________________________1and DOES 1through 100, inclusiveDefendants.________________________________________)))))))))))))Case No.COMPLAINT FOR:1. FRAUD2. CONVERSION3. UNFAIR BUSINESS PRACTICESPlaintiff, ______________1hereby files a Complaint and alleges as follows:ALLEGATIONS COMMON TO AND INCLUDED IN- 1 -COMPLAINT FOR FRAUD, CONVERSION, UNFAIR BUSINESS PRACTICES
  2. 2. 12345678910111213141516171819202122232425262728ALL CAUSES OF ACTION11. Plaintiffs, __________, and _______, (“Plaintiff” or “Plaintiffs” ) are now, and at allrelevant 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 andcommonly known as ________________ (“Subject Property”).2. Plaintiff is informed and believes, and thereon alleges, that defendant______________________________________ (“_____”) is now, and at all relevant timesmentioned herein was, a company doing business at _________________________. Thus this Courtis the proper Court for the trial of this action.3. Plaintiff is informed and believes, and thereon alleges, that defendant______________________________________________, (“____________”) is now, and at allrelevant 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, anindividual, and one of the principal owners and operators of Defendants __________,and worked at their offices located at ___________________________. Thus this Court is the properCourt for the trial of this action. Defendant _________ was authorized by, and was acting on behalfof, 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 orbusiness entities, of Defendant DOES 1 through 100, inclusive, and sues them by such fictitiousnames. Plaintiff will seek leave of this Court to insert their true names and capacities once they havebeen ascertained.- 2 -COMPLAINT FOR FRAUD, CONVERSION, UNFAIR BUSINESS PRACTICES
  3. 3. 123456789101112131415161718192021222324252627286. 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 hereinmentioned, 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 suchagency. Upon information and belief, all Defendants are responsible in some manner for the eventsdescribed herein and are liable to Plaintiff for the damages it has incurred.7. On or about _____________, both Plaintiffs signed a written contract (“TheAgreement”) with Defendants, __________________. The essential terms of The Agreement werethat 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 loanthat Plaintiffs owed to ____________ that secured the Subject Property. The Agreement was signedby 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 byreference.9. On or about __________, in the City of _______, County of ________, State ofCalifornia, Defendant _______, who was authorized by, and acting on behalf of Defendants__________ and ________, made verbal and written representations to both Plaintiffs. The verbaland written representations were that all Defendants had many years of experience in the real estate- 3 -COMPLAINT FOR FRAUD, CONVERSION, UNFAIR BUSINESS PRACTICES
  4. 4. 12345678910111213141516171819202122232425262728industry, and that the Defendants would apply the sum of $________ paid to Defendants by bothPlaintiffs to the loan that Plaintiffs owed to ___________that secured the Subject Property. Theverbal and written representations were in fact false, but that fact was not known at the time byPlaintiffs.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 notdiscovered until …To purchase the entire sample document on which this preview isbased visit: http://www.scribd.com/doc/117352108/Sample-Complaint-for-Unfair-Business-Practices-in-CaliforniaTo view collections of documents for sale by LegalDocsPro visithttp://www.scribd.com/LegalDocsPro/collections- 4 -COMPLAINT FOR FRAUD, CONVERSION, UNFAIR BUSINESS PRACTICES

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