Sample California Complaint For Real Estate Fraud Against Seller, Broker And Agent 2r4j58

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Any Attorney or Party Any Street Any Town, CA 55555

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714-555-5555

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Any Attorney or Party

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Superior Court of the State of California

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For the County of _________________

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) ) ) Plaintiff, ) ) vs. ) _____________________________and DOES 1 ) ) ) through 100, inclusive ) ) Defendants. ) ________________________________________ ) Any Plaintiff,

Case No. Unlimited Civil, Demand over $25,000.00 COMPLAINT FOR: 1.

BREACH OF CONTRACT

2. VIOLATION OF CIVIL CODE SECTION 1102, et seq. 3.

FRAUD BY CONCEALMENT

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26 27 28 - 1 COMPLAINT FOR BREACH OF CONTRACT, FRAUD, ETC.

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this website: https://legaldocspro.myshopify.com/products Plaintiff, ______________hereby files a Complaint and alleges as follows:

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ALLEGATIONS COMMON TO AND INCLUDED IN

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ALL CAUSES OF ACTION

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1.

Plaintiffs, __________, and _______, (“Plaintiff” or “Plaintiffs” ) are now, and at all

relevant times mentioned herein were, individuals, residing and working in the County of _____________, State of California. 2.

Defendant, __________ ("broker"), is now, and at all times mentioned in this

complaint was, a duly licensed California real estate broker, licensed under the laws of the State of California, license number __________, doing business at _____________ in the City of ________,

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County of ___________, California. Thus this Court is the proper Court for the trial of this action as

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Defendant does business within its jurisdictional area.

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3.

Defendant, __________ ("agent"), is now, and at all times relevant to this action was,

a duly licensed real estate agent, licensed under the laws of the State of California, license number

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__________, and an employee of broker. Thus this Court is the proper Court for the trial of this action as Defendant does business within its jurisdictional area. 4.

Defendant, __________ ("seller"), is now, and at all times mentioned in this complaint

was, an individual residing in __________ County, California. This Court is the proper Court for the trial of this action as seller presently residing within its jurisdictional area.

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5.

Plaintiff is unaware of the true names or capacities, whether they are individuals or

business entities, of Defendant DOES 1 through 100, inclusive, and sues them by such fictitious

28 - 2 COMPLAINT FOR BREACH OF CONTRACT, FRAUD, ETC.

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names. Plaintiff will seek leave of this Court to insert their true names and capacities once they have

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been ascertained.

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6.

Plaintiff is informed and believe and upon such information and belief alleges,

that the defendant, _______________, and DOES 1 through 100 inclusive, were, at all times herein mentioned, authorized and empowered by each other to act, and did so act, as agents of each other,

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and all of the things herein alleged to have been done by them were done in the capacity of such

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agency. Upon information and belief, all Defendants are responsible in some manner for the events

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described herein and are liable to Plaintiff for the damages it has incurred.

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7.

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The real property (“Subject Property”) that is the subject matter of this action is

commonly described as __________________________________ in the City of ___________,

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County of ___________, California, and legally described as

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DESCRIPTION FROM THE DEED AND THE ASSESSOR’S PARCEL NUMBER A.P.N.

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_______________.

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8.

INSERT FULL LEGAL

On or about __________ , broker and agent represented seller in seller's effort to sell

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Subject Property described in paragraph 5 of this complaint.

Be sure to modify these paragraphs to suit your individual

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situation. Do NOT just use the wording here unless it definitely applies to your particular situation.

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28 - 3 COMPLAINT FOR BREACH OF CONTRACT, FRAUD, ETC.

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FIRST CAUSE OF ACTION FOR BREACH OF CONTRACT

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(As against all Defendants)

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9.

Plaintiff realleges the allegations contained in paragraphs 1 through 8, inclusive,

hereinabove, as though set forth in full herein, and incorporates them into this cause of action by reference. 10.

On or about __________ , plaintiff and seller entered into a written agreement in

which plaintiff agreed to purchase and seller agreed to sell the Subject Property. A copy of the written purchase and sale agreement ("the agreement") is attached hereto to this complaint as Exhibit __________ and is incorporated herein by reference. The agreement includes a provision for recovery of attorney fees by the prevailing party in the event an action is brought under the agreement.

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