1 Any Attorney or Party

Any Street
2 Any Town, CA 55555

3 714-555-5555

4 Any Attorney or Party

8 Superior Court of the State of California

9 For the County of ________________

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11 Any Plaintiff, ) Case No.

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12 Plaintiff, ) UNLIMITED CIVIL, DEMAND OVER $25,000
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13 vs. ) COMPLAINT FOR:
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14 Any Defendant, and DOES 1-5 ) 1. BREACH OF CONTRACT
) 2. MISAPPROPRIATION OF TRADE SECRET
15 Defendants. ) 3. ACCOUNTING
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Plaintiff, _________________, hereby complains and alleges as follows:
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- 1 -
COMPLAINT
 1 1. Plaintiff, __________________(hereinafter referred to as Plaintiff) is and at all times
2 mentioned herein was, an individual, over the age of majority, residing in the City of _________,
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County of _________, State of California.
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2. Defendant ______________, (hereinafter referred to as Defendant) upon
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information and belief, is now, and at all times mentioned herein was, a corporation, organized and

7 existing under the laws of the State of California, doing business in City of _________, County of

8 _________, State of California.

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3. This court is the proper court for trial in this action in that the actions and omissions of
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Defendant as alleged herein were made within this Courts jurisdictional area.
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4. Plaintiff is unaware of the true names or capacities, whether they are individuals or
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13 business entities, of Defendant DOES 1 through 50, and therefore sues them by such fictitious names

14 and will seek leave of this Court to insert true names and capacities once they have been ascertained.
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5. At all times mentioned herein, Defendants, and each of them, inclusive of DOES
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1 through 50, were authorized and empowered by each other to act, and did so act, as agents of each
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other, and all of the things herein alleged to have been done by them were done in the capacity of
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19 such agency. Upon information and belief, all Defendants are responsible in some manner for the

20 events described herein and are liable to Plaintiff for the damages they have incurred.
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FIRST CAUSE OF ACTION
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(BREACH OF CONTRACT AS AGAINST ALL DEFENDANTS)
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6. Plaintiff refers to, and incorporates by reference, the allegations of paragraph 1
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25 through 5, as though fully set forth herein.

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- 2 -
COMPLAINT
 1 7. On or about ___________________, Plaintiff and Defendant entered into a written
2 contract (Contract). A true and correct copy of said contract is attached hereto as Exhibit A and
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incorporated herein by reference.
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8. The essential terms of the Contract were that Plaintiff would receive four percent
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(4%) of the net sales indefinitely on any product purchased and used, or sold by, Defendant that

7 utilized any formulations, or forms of formulating knowhow, proprietary chemistry and containing

8 any of the industrial additives of which Plaintiff made Defendant aware of. Plaintiff was also to
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receive compensation for any other various services performed by him for Defendant. The formulas
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provided to Defendant by Plaintiff were developed by Plaintiff over the course of his many years
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working in the industrial lubricant and chemical field.
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13 9. Plaintiff performed all obligations to Defendant except those obligations Plaintiff was

14 prevented or legally excused from performing.

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COMPLAINT