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. BREACH OF CONTRACT
15 through 100, inclusive )
) 2. VIOLATION OF CIVIL CODE SECTION
16 Defendants. ) 1102, et seq.
)
17 ________________________________________ ) 3. FRAUD BY CONCEALMENT

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19

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- 1 -
COMPLAINT FOR BREACH OF CONTRACT, FRAUD, ETC.
 1 To view many more sample legal documents created by me, visit
2

3
this website: https://legaldocspro.myshopify.com/products
4 Plaintiff, ______________hereby files a Complaint and alleges as follows:
5
ALLEGATIONS COMMON TO AND INCLUDED IN
6
ALL CAUSES OF ACTION
7

8
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, __________ ("broker"), is now, and at all times mentioned in this
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complaint was, a duly licensed California real estate broker, licensed under the laws of the State of
13
California, license number __________, doing business at _____________ in the City of ________,
14

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

16 Defendant does business within its jurisdictional area.

17
3. Defendant, __________ ("agent"), is now, and at all times relevant to this action was,
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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
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21 action as Defendant does business within its jurisdictional area.

22 4. Defendant, __________ ("seller"), is now, and at all times mentioned in this complaint
23
was, an individual residing in __________ County, California. This Court is the proper Court for the
24
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
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27 business entities, of Defendant DOES 1 through 100, inclusive, and sues them by such fictitious

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COMPLAINT FOR BREACH OF CONTRACT, FRAUD, ETC.
 1 names. Plaintiff will seek leave of this Court to insert their true names and capacities once they have
2 been ascertained.
3
6. Plaintiff is informed and believe and upon such information and belief alleges,
4
that the defendant, _______________, and DOES 1 through 100 inclusive, were, at all times herein
5

6
mentioned, authorized and empowered by each other to act, and did so act, as agents of each other,

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

8 agency. Upon information and belief, all Defendants are responsible in some manner for the events
9
described herein and are liable to Plaintiff for the damages it has incurred.
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7. The real property (Subject Property) that is the subject matter of this action is
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commonly described as __________________________________ in the City of ___________,
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13 County of ___________, California, and legally described as INSERT FULL LEGAL

14 DESCRIPTION FROM THE DEED AND THE ASSESSORS PARCEL NUMBER A.P.N.
15
_______________.
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8. 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.
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19 Be sure to modify these paragraphs to suit your individual

20
situation. Do NOT just use the wording here unless it definitely applies
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to your particular situation.
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- 3 -
COMPLAINT FOR BREACH OF CONTRACT, FRAUD, ETC.
 1 FIRST CAUSE OF ACTION FOR BREACH OF CONTRACT
2 (As against all Defendants)
3
9. Plaintiff realleges the allegations contained in paragraphs 1 through 8, inclusive,
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hereinabove, as though set forth in full herein, and incorporates them into this cause of action by
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reference.

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

8 which plaintiff agreed to purchase and seller agreed to sell the Subject Property. A copy of the written
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purchase and sale agreement ("the agreement") is attached hereto to this complaint as Exhibit
10
__________ and is incorporated herein by reference. The agreement includes a provision for recovery
11
of attorney fees by the prevailing party in the event an action is brought under the
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13 agreement.

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complaint-for-real-estate-fraud-against-seller-broker-and-agent
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COMPLAINT FOR BREACH OF CONTRACT, FRAUD, ETC.