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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 _________________

10

11 Any Plaintiff, ) Case No.


)
12 Plaintiff, )
) Unlimited Civil, Demand over $25,000.00
13 vs. )
) COMPLAINT FOR:
14 _____________________________and DOES 1 )
) 1. NEGLIGENCE
15 through 100, inclusive )
) 2. BREACH OF CONTRACT
16 Defendants. )
)
17 ________________________________________ )

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- 1 -
COMPLAINT FOR NEGLIGENCE AND BREACH OF CONTRACT
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4 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

9 relevant times mentioned herein were, individuals, residing and working in the County of

10 _____________, State of California.


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2. Defendant __________ ("escrow holder") is, and at all times mentioned in this
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complaint was, a corporation organized and existing under the laws of California, with its principal
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place of business located at ______________ in the City of ______________, County of _______,
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15 California. Thus this Court is the proper Court for the trial of this action as Defendant does

16 business within its jurisdictional area.


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3. Plaintiff is unaware of the true names or capacities, whether they are individuals or
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business entities, of Defendant DOES 1 through 100, inclusive, and sues them by such fictitious
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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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21 been ascertained.

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of-contract

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COMPLAINT FOR NEGLIGENCE AND BREACH OF CONTRACT

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