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    Sample Complaint For Specific Performance in California

    Uploaded by

    Stan Burman
    this sample complaint for specific performance in California includes causes of action for breach of contract, specific performance and claim and delivery. The author is a freelance paralegal who has worked in California litigation since 1995 and has used this sample for many years. Note that the author is NOT an attorney and no guarantee or warranty is provided.

    Copyright:

    © All Rights Reserved
    Download as DOC, PDF, TXT or read online from Scribd

    Sample Complaint For Specific Performance in California

    Uploaded by

    Stan Burman
    2K views3 pages
    this sample complaint for specific performance in California includes causes of action for breach of contract, specific performance and claim and delivery. The author is a freelance paralegal who has worked in California litigation since 1995 and has used this sample for many years. Note that the author is NOT an attorney and no guarantee or warranty is provided.

    Original Title

    Sample Complaint for Specific Performance in California

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    © © All Rights Reserved

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    DOC, PDF, TXT or read online from Scribd

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    this sample complaint for specific performance in California includes causes of action for breach of contract, specific performance and claim and delivery. The author is a freelance paralegal who has worked in California litigation since 1995 and has used this sample for many years. Note that the author is NOT an attorney and no guarantee or warranty is provided.

    Copyright:

    © All Rights Reserved
    Download as DOC, PDF, TXT or read online from Scribd
    Download as doc, pdf, or txt
    2K views3 pages

    Sample Complaint For Specific Performance in California

    Uploaded by

    Stan Burman
    this sample complaint for specific performance in California includes causes of action for breach of contract, specific performance and claim and delivery. The author is a freelance paralegal who has worked in California litigation since 1995 and has used this sample for many years. Note that the author is NOT an attorney and no guarantee or warranty is provided.

    Copyright:

    © All Rights Reserved
    Download as DOC, PDF, TXT or read online from Scribd
    Download as doc, pdf, or txt
    of 3

    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, ) COMPLAINT FOR:
    )
    13 vs. ) 1. BREACH OF CONTRACT
    )
    14 _____________________________and DOES 1 ) 2. SPECIFIC PERFORMANCE
    )
    15 through 100, inclusive ) 3. CLAIM AND DELIVERY
    )
    16 Defendants. )
    )
    17 ________________________________________ )

    18

    19
    Plaintiff, ______________hereby files a Complaint and alleges as follows:
    20
    ALLEGATIONS COMMON TO AND INCLUDED IN
    21

    22 ALL CAUSES OF ACTION

    23 1. Plaintiffs, __________, and _______, (Plaintiff or Plaintiffs ) are now, and at all
    24
    relevant times mentioned herein were, individuals, residing and working in the County of
    25
    _____________, State of California.
    26
    2. Plaintiff is informed and believes, and thereon alleges, that defendant
    27

    28 ______________________________________ (_____) is now, and at all relevant times

    - 1 -
    COMPLAINT FOR BREACH OF CONTRACT, SPECIFIC PERFORMANCE
    1 mentioned herein was, a company doing business at _________________________. Thus this Court
    2 is the proper Court for the trial of this action.
    3
    3. Plaintiff is informed and believes, and thereon alleges, that defendant
    4
    ______________________________________________, (____________) is now, and at all
    5

    6
    relevant times mentioned herein was, a company doing business at _________________________.

    7 Thus this Court is the proper Court for the trial of this action.

    8 4. Plaintiff is informed and believes, and thereon alleges, that defendant


    9
    ______________, (___________) is now, and at all relevant times mentioned herein was, an
    10
    individual, and one of the principal owners and operators of Defendants __________,
    11
    and worked at their offices located at ___________________________. Thus this Court is the proper
    12

    13 Court for the trial of this action. Defendant _________ was authorized by, and was acting on behalf

    14 of, Defendants ___________, when he made the representations to Plaintiff alleged in this complaint.
    15
    5. Plaintiff is unaware of the true names or capacities, whether they are individuals or
    16
    business entities, of Defendant DOES 1 through 100, inclusive, and sues them by such fictitious
    17
    names. Plaintiff will seek leave of this Court to insert their true names and capacities once they have
    18

    19 been ascertained.

    20 6. Plaintiff is informed and believe and upon such information and belief alleges,
    21
    that the defendants, _______________, and DOES 1 through 100 inclusive, were, at all times herein
    22
    mentioned, authorized and empowered by each other to act, and did so act, as agents of each other,
    23
    and all of the things herein alleged to have been done by them were done in the capacity of such
    24

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

    26 described herein and are liable to Plaintiff for the damages it has incurred.
    27
    7. On or about _____________, both Plaintiffs signed a written contract (The
    28

    - 2 -
    COMPLAINT FOR BREACH OF CONTRACT, SPECIFIC PERFORMANCE
    1 Agreement) with Defendants, __________________. The essential terms of The Agreement were
    2 ________________________________________. A true and correct copy of The Agreement is
    3
    attached hereto as Exhibit A and incorporated herein by reference.
    4
    FIRST CAUSE OF ACTION
    5

    6
    (Breach of contract as against all Defendants)

    7 8. Plaintiff realleges the allegations contained in paragraphs 1 through 17, inclusive,

    8 hereinabove, as though set forth in full herein, and incorporates them into this cause of action by
    9
    reference.
    10

    11
    To purchase the entire document visit:
    12
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    13

    14 specific-performance-in-california
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    - 3 -
    COMPLAINT FOR BREACH OF CONTRACT, SPECIFIC PERFORMANCE

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