This sample California complaint for breach of contract also includes causes of action for common counts including open book account, account stated and goods sold and delivered. The sample on which this preview is based is 6 pages and includes brief instructions. The sample document is sold on scribd.com by LegalDocsPro.

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Any Attorney or Party
Any Street
Any Town, CA 55555
714-555-5555
Any Attorney or Party
Superior Court of the State of California
For the County of _________________
Any Plaintiff,
Plaintiff,
vs.
Any Defendant, and DOES 1-5
Defendants.
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Case No.
COMPLAINT FOR:
1. BREACH OF CONTRACT
2. COMMON COUNT-OPEN BOOK ACCOUNT
3. COMMON COUNT-ACCOUNT STATED
4. COMMON COUNT-GOODS SOLD AND
DELIVERED
UNLIMITED CIVIL, DEMAND OVER $25,000
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COMPLAINT

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http://www.scribd.com/doc/46189400/Sample-Complaint-for-Breach-
of-Contract-for-California
Plaintiff, _________________, hereby complains and alleges as follows:
1 1. Plaintiff, __________________(hereinafter referred to as Plaintiff) is and at all times
mentioned herein was, an individual, doing business under the name of _______________in the City
of _________, County of _________, State of California. Plaintiff has complied with the fictitious
business name laws and is doing business under the fictitious name of ___________.
2. Defendant ______________, (hereinafter referred to as Defendant) upon information
and belief, is now, and at all times mentioned herein was, a Corporation duly organized and existing
under the laws of the State of California, and doing business in the City of
_________, County of ___________, State of California.
3. This court is the proper court for trial in this action in that the principal place of
business of Defendant is located within this Court’s jurisdictional area.
4. Plaintiff is unaware of the true names or capacities, whether they are individuals or
business entities, of Defendant DOES 1 through 50, and therefore sues them by such fictitious
names and will seek leave of this Court to insert true names and capacities once they have been
ascertained.
5. At all times mentioned herein, Defendants, and each of them, inclusive of DOES
1 through 50, were 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
such agency. Upon information and belief, all Defendants are responsible in some manner for the
events described herein and are liable to Plaintiff for the damages he has incurred.
FIRST CAUSE OF ACTION
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COMPLAINT

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(BREACH OF CONTRACT)
6. Plaintiff repeats, repleads and realleges each and every allegation set forth
in paragraphs 1 through 5, inclusive, of this complaint, as though set forth hereat.
7. Beginning on __________ and continuing through ______________ Plaintiff and
Defendant entered into a verbal contract in which Plaintiff promised to deliver various video
products such as DVD’s and other similar products to Defendant who promised to pay Plaintiff for all
video products delivered to Defendant.
8. Plaintiff and Defendant had done business together for several years.
9. Plaintiff performed all obligations to Defendant except those obligations Plaintiff
was prevented or legally excused from performing.
10. Defendant breached the contract on or about ____________ by failing to pay
Plaintiff pursuant to written invoices sent to Defendant by Plaintiff.
11. As a direct and proximate result of the breach of contract by Defendant, Plaintiff
has suffered damages in an amount not as yet ascertained, but said damages will be a minimum of
_____________, plus interest at the legal rate of 10% per annum from and after ______________,,
and will be proven at time of trial.
SECOND CAUSE OF ACTION
(COMMON COUNT-OPEN BOOK ACCOUNT)
12. Plaintiff repeats, repleads and realleges each and every allegation set forth in
paragraphs 1 through 12, inclusive, of this complaint as though set forth hereat.
13. Defendant became indebted to Plaintiff within the last four years on an open book
account for money due.
14. Plaintiff has demanded that Defendant pay the amount owing but Defendant has
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COMPLAINT

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failed and refused, and continues to fail and refuse, to pay the amount owing.
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COMPLAINT