Sample Fraud Complaint For California 695b25

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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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Any Plaintiff,

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Plaintiff,

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vs. Any Defendant, and DOES 1-5

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Defendants.

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) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

Case No. COMPLAINT FOR: 1. RECOVERY OF COMPENSATION PAID TO UNLICENSED CONTRACTOR [BUS. & PROF. § 7031(b)] 2. NEGLIGENCE 3. FRAUD

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Plaintiff, _________________, hereby complains and alleges as follows:

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1.

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Plaintiff _________________________, (hereinafter referred to as

_________________________) is now, and all times herein mentioned was, an individual residing in

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the City of Westminster, County of Orange, State of California.

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2.

Upon information and belief, Defendant, _______________________________

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(hereinafter referred to as ______________) is now, and at all times mentioned herein was, an

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individual residing in the City of ____________, County of _______________, State of California.

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3.

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that are the subject of this complaint occurred in the City of _____________, County of ______, State of California.

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This court is the proper court for trial in this action in that actions and omissions

Plaintiff _________________________ is unaware of the true names or capacities,

whether they are individuals or business entities, of Defendant DOES 1 through 100 inclusive, and

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therefore sues them by such fictitious names and will seek leave of this Court to insert true names and

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capacities once they have been ascertained.

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5.

At all times mentioned herein, Defendants, and each of them, inclusive of DOES

1 through 100, 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

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

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

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FIRST CAUSE OF ACTION RECOVERY OF COMPENSATION PAID TO UNLICENSED CONTRACTOR AS AGAINST

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ALL DEFENDANTS

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6.

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Plaintiff _________________________ repeats, repleads and realleges each and

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every allegation set forth in paragraphs 1 through 5, inclusive, of this complaint, as though set forth

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hereat.

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7.

On or about ________________, Plaintiff _________________________, paid

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the sum of $15,000.00 to Defendant ___________as an advance payment for services to be rendered

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in which Defendant _____________was to perform construction work, including the addition of a

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new master bedroom and bathroom, and remodeling of existing rooms and kitchen, at the real

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property located at ____________________________Plaintiff _________________________ paid

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an additional $_______________ to Defendant _____________ in several payments over the next

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several months.

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