This sample cross-complaint for indemnity, contribution and declaratory relief for California includes five (5) causes of action. The sample is used when a defendant in a lawsuit wants to file a cross-complaint against a party or parties alleging that they are responsible for any damages suffered by the plaintiff in the original lawsuit and they should be required to indemnify the cross-complainant for any damages they are found liable for. The author is a freelance paralegal that has worked in California and Federal litigation since 1995 and has used this sample for many years. Note that the author is NOT an attorney and no guarantee or warranty is provided.

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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.
Any Cross-Complainant.
Cross-Complainant,
vs.
Any Cross-Defendant, and ROES 1-5,
Cross-Defendants.
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Case No.
Unlimited Civil, Demand over $25,000
CROSS-COMPLAINT FOR:
11. IMPLIED EQUITABLE INDEMNITY;
2. EQUITABLE INDEMNITY;
3. CONTRIBUTION;
4. APPORTIONMENT OF FAULT, AND
5. DECLARATORY RELIEF
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CROSS-COMPLAINT FOR INDEMNITY, CONTRIBUTION, ETC.

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document.
1CROSS-COMPLAINT
Cross-Complainant, _________________, for causes of action against Cross-Defendants,
_____________________________., alleges as follows:
1. At all times mentioned herein, Cross-Complainant _________________ was an
individual.
2. At all times mentioned herein, Cross-Defendants,____________________________.,
(“Cross-Defendants”) were individuals.
3. The true names and capacities of Cross-Defendants Roes 1 through 5, inclusive,
are unknown to Cross-Complainant, who therefore sues said Cross-Defendants and each of them, by
such fictitious names. Cross-Complainant will seek leave of court to amend this Cross-Complaint to
insert the true names and capacities of fictitiously named Cross-Defendants when the same have been
ascertained. Cross-Complainant is informed and believes and based thereon alleges that each Cross-
Defendant herein designated as a “ROE” is legally responsible in some manner for the acts,
occurrences, damages, and liabilities hereinafter alleged, and actively and passively caused and
contributed to the various damages referred to herein.
4. Cross-Complainant is informed and believes and based thereon alleges that at all
times herein mentioned, each Cross-Defendant designated herein is or was the agent, partner,
employee, co-developer, joint venturer, subcontractor, consultant, and/or supplier of each of the
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CROSS-COMPLAINT FOR INDEMNITY, CONTRIBUTION, ETC.

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remaining Cross-Defendants and was at all times herein mentioned, acting within the course and
scope of said agency and employment.
5. On or about ___________ an action entitled ________________with Case Number
______________________________was filed in the Superior Court for the County of __________,
alleging that Cross-Complainant was liable to Plaintiff for damages arising from the allegations set
forth in Plaintiff’s Complaint. Cross-Complainant incorporates herein by reference, the contents of
the Complaint, without admitting the allegations contained thereof, the truth of which is expressly
denied. The Complaint alleges that Plaintiff has been damaged as the result of defaults in the payment
of certain notes.
6. On or about ___________________ a Cross-Complaint was filed in this action by
____________________________-, naming Cross-Complainant, _________________ as one of the
Cross-Defendants (“_________ Cross-Complaint”). The _____Cross-Complaint alleges that Cross-
Complainant _________________ is obligated to indemnify ______________, for any damages for
which they may be found liable to Plaintiff, and also seeks contribution by Cross-Complainant
_________________ as well as requesting declaratory relief. Cross-Complainant incorporates by
reference, the contents of the _____________ Cross-Complaint, without admitting the allegations
thereof, the truth of which is expressly denied.
FIRST CAUSE OF ACTION
Implied Equitable Indemnity
(As Against all Cross-Defendants.)
7. Cross-Complainant refers to, and incorporates by reference, the allegations of
Paragraphs 1 through 6 of this Cross-Complaint, as though fully set forth herein.
8. Cross-Complainant is informed and believes, and based thereon alleges, that they
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CROSS-COMPLAINT FOR INDEMNITY, CONTRIBUTION, ETC.

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are in no way responsible for the damages alleged in Plaintiff’s Complaint, or the ________ Cross-
Complaint. However, if Cross-Complainant is found responsible under the law for any of the
allegations contained in Plaintiff’s Complaint, or the _________________ Cross-Complaint, then
Cross-Complainant is informed and believes, and based thereon alleges, that the conduct, in whole or
in part, of the Cross-Defendants, and each of them, contributed to the happening of the acts alleged in
Plaintiff’s Complaint, and/or the _________________ Cross-Complaint on file herein.
9. By reason of the foregoing allegations, if Plaintiff recovers judgment against
Cross-Complainant, then Cross-Complainant is entitled to a judgment, over and against the Cross-
Defendants herein, and each of them, for their faire share of Plaintiff’s Judgment. And if Cross-
Complainant is found liable on the _________________ Cross-Complaint then Cross-Complainant is
entitled to a judgment, over and against the Cross-Defendants, and each of them, for their fair share
of any judgment rendered against Cross-Complainant on the _________________ Cross-Complaint.
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complaint-for-indemnity-for-california
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CROSS-COMPLAINT FOR INDEMNITY, CONTRIBUTION, ETC.