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.

)
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.
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2. Plaintiff is informed and believes, and thereon alleges, that defendant
27

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

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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
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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.
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7. On or about _____________, both Plaintiffs signed a written contract (The
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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.
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To purchase the entire document visit:
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https://legaldocspro.myshopify.com/products/sample-complaint-for-
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COMPLAINT FOR BREACH OF CONTRACT, SPECIFIC PERFORMANCE