1 Any Party

Any Street
2 Any Town, CA 99999

3 555-555-5555

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
13 vs. )
) COMPLAINT FOR DAMAGES FOR SLANDER
14 Any Defendant, Does 1-50, inclusive, ) AND SLANDER PER SE
)
15 Defendants. )
)
16 )
)
17

18
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20 http://www.legaldocspro.net/newsletter.htm and enter your e-mail

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address. Be sure to remove this notice and all other notices before
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23 using this document.

24 Plaintiff, _________________, hereby complains and alleges as follows:
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1. Plaintiff, __________________(hereinafter referred to as Plaintiff) is and at all times
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mentioned herein was, an individual, over the age of majority, residing in the City of _________,
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County of _________, State of California. Plaintiff has always enjoyed a very good reputation in
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COMPLAINT FOR DAMAGES FOR SLANDER
 1 both their personal and professional life, and is well respected in both their local business community,
2 as well as their local community.
3
2. Defendant ______________, (hereinafter referred to as Defendant) upon
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information and belief, is now, and at all times mentioned herein was, an individual, over the age of
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majority, residing in the City of _________, County of _________, State of California.

7 3. This court is the proper court for trial in this action in that the actions and omissions of

8 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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business entities, of Defendant DOES 1 through 50, and therefore sues them by such fictitious
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names and will seek leave of this Court to insert true names and capacities once they have been
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13 ascertained.

14 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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such agency. Upon information and belief, all Defendants are responsible in some manner for the
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19 events described herein and are liable to Plaintiff for the damages they have incurred.

20 FIRST CAUSE OF ACTION

21
(Slander Per Se Civil Code 46)
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6. Plaintiff realleges and incorporates by reference paragraphs 1 through 5, above, as
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though fully set forth herein.
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25 7. Plaintiff is informed and believes that on ________________ at ________, Defendant

26 made the following defamatory statement about, of, and concerning Plaintiff:
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_____________________. Defendant made said statement in person to _______________________.
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COMPLAINT FOR DAMAGES FOR SLANDER
 1 8. ______________reasonably understood that the statement referred to Plaintiff and
2 reasonably understood them to mean that Plaintiff was ______________________________.
3
9. The aforesaid defamatory statement made allegedly by Defendant was and is false and
4
was not privileged. Defendant made said statement knowing the falsity thereof or without using
5

6
reasonable care to determine the truth or falsity thereof.

7 10. Defendant made the aforesaid defamatory statement with malice and with the intent to

8 injure Plaintiffs good name and reputation and to interfere with their employment, in that defendant
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harbored ill-will toward Plaintiff.
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11. The aforesaid defamatory statement has harmed plaintiffs reputation; such a statement
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has a tendency to injure and has injured Plaintiff in their occupation, their future business and
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13 employment prospects have been severely harmed, Plaintiff has had to incur substantial expense, in

14 order to redress the harm they have suffered, all to Plaintiffs general and actual damages, including
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exemplary and punitive damages, in an amount which far exceeds the jurisdictional minimum of this
16
Court, and which will be proven at trial.
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SECOND CAUSE OF ACTION
18

19 (Slander Per Se Civil Code 46)

20 12. Plaintiff realleges and incorporates by reference paragraphs 1 through 11, above, as
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though fully set forth herein.
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13. Plaintiff is informed and believes that on ________________, at ____, California,
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Defendant made the following defamatory statement about, of, and concerning Plaintiff:
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25 _____________________. Defendant made said statement in person to ______________________.

26 14. ______________reasonably understood that the statement referred to Plaintiff and

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reasonably understood them to mean that Plaintiff was ______________________________.
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COMPLAINT FOR DAMAGES FOR SLANDER
 1 15. The aforesaid defamatory statement made allegedly by Defendant was and is false and
2 was not privileged. Defendant made said statement knowing the falsity thereof or without using
3
reasonable care to determine the truth or falsity thereof.
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16. Defendant made the aforesaid defamatory statement with malice and with the intent to
5

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injure Plaintiffs good name and reputation and to interfere with their employment, in that defendant

7 harbored ill-will toward Plaintiff.

8 17. The aforesaid defamatory statement has harmed plaintiffs reputation; such a statement
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has a tendency to injure and has injured Plaintiff in their occupation, their future business and
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employment prospects have been severely harmed, Plaintiff has had to incur substantial expense, in
11
order to redress the harm they have suffered, all to Plaintiffs general and actual damages, including
12

13 exemplary and punitive damages, in an amount which far exceeds the jurisdictional minimum of this

14 Court, and which will be proven at trial.

15
THIRD CAUSE OF ACTION
16
(Slander Per Se Civil Code 46)
17
18. Plaintiff realleges and incorporates by reference paragraphs 1 through 17, above, as
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19 though fully set forth herein.

20 19. Plaintiff is informed and believes that on ________________, at _____, California,

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Defendant made the following defamatory statement about, of, and concerning Plaintiff:
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_____________________. Defendant made said statement in person to _______________________.
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20. ______________reasonably understood that the statement referred to Plaintiff and
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25 reasonably understood them to mean that Plaintiff was ______________________________.

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27

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COMPLAINT FOR DAMAGES FOR SLANDER
 1 21. The aforesaid defamatory statement made allegedly by Defendant was and is false and
2 was not privileged. Defendant made said statement knowing the falsity thereof or without using
3
reasonable care to determine the truth or falsity thereof.
4
22. Defendant made the aforesaid defamatory statement with malice and with the intent to
5

6
injure Plaintiffs good name and reputation and to interfere with their employment, in that defendant

7 harbored ill-will toward Plaintiff.

8 23. The aforesaid defamatory statement has harmed plaintiffs reputation; such a statement
9
has a tendency to injure and has injured Plaintiff in their occupation, their future business and
10
employment prospects have been severely harmed, Plaintiff has had to incur substantial expense, in
11
order to redress the harm they have suffered, all to Plaintiffs general and actual damages, including
12

13 exemplary and punitive damages, in an amount which far exceeds the jurisdictional minimum of this

14 Court, and which will be proven at trial.

15
FOURTH CAUSE OF ACTION
16
(Slander Per Se Civil Code 46)
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24. Plaintiff realleges and incorporates by reference paragraphs 1 through 23, above, as
18

19 though fully set forth herein.

20 25. Plaintiff is informed and believes that on ________________, at ____, California,

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Defendant made the following defamatory statement about, of, and concerning Plaintiff:
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_____________________. Defendant made said statement in person to _______________________.
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26. ______________reasonably understood that the statement referred to Plaintiff and
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25 reasonably understood them to mean that Plaintiff was ______________________________.

26

27

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COMPLAINT FOR DAMAGES FOR SLANDER
 1 27. The aforesaid defamatory statement made allegedly by Defendant was and is false and
2 was not privileged. Defendant made said statement knowing the falsity thereof or without using
3
reasonable care to determine the truth or falsity thereof.
4
28. Defendant made the aforesaid defamatory statement with malice and with the intent to
5

6
injure Plaintiffs good name and reputation and to interfere with their employment, in that defendant

7 harbored ill-will toward Plaintiff.

8 29. The aforesaid defamatory statement has harmed plaintiffs reputation; such a statement
9
has a tendency to injure and has injured Plaintiff in their occupation, their future business and
10
employment prospects have been severely harmed, Plaintiff has had to incur substantial expense, in
11
order to redress the harm they have suffered, all to Plaintiffs general and actual damages, including
12

13 exemplary and punitive damages, in an amount which far exceeds the jurisdictional minimum of this

14 Court, and which will be proven at trial.

15
FIFTH CAUSE OF ACTION
16
(Slander per Se Civil Code 46)
17
30. Plaintiff realleges and incorporates by reference paragraphs 1 through 29, above, as
18

19 though fully set forth herein.

20 31. Plaintiff is informed and believes that on ________________, at _____, California,

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Defendant made the following defamatory statement about, of, and concerning Plaintiff:
22
_____________________. Defendant made said statement in person to _______________________.
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32. ______________reasonably understood that the statement referred to Plaintiff and
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25 reasonably understood them to mean that Plaintiff was ______________________________.

26

27

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COMPLAINT FOR DAMAGES FOR SLANDER
 1 33. The aforesaid defamatory statement made allegedly by Defendant was and is false and
2 was not privileged. Defendant made said statement knowing the falsity thereof or without using
3
reasonable care to determine the truth or falsity thereof.
4
34. Defendant made the aforesaid defamatory statement with malice and with the intent to
5

6
injure Plaintiffs good name and reputation and to interfere with their employment, in that defendant

7 harbored ill-will toward Plaintiff.

8 35. The aforesaid defamatory statement has harmed plaintiffs reputation; such a statement
9
has a tendency to injure and has injured Plaintiff in their occupation, their future business and
10
employment prospects have been severely harmed, Plaintiff has had to incur substantial expense, in
11
order to redress the harm they have suffered, all to Plaintiffs general and actual damages, including
12

13 exemplary and punitive damages, in an amount which far exceeds the jurisdictional minimum of this

14 Court, and which will be proven at trial.

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PRAYER FOR RELIEF
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Plaintiff prays for relief as follows:
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1) For economic damages, to be proven at trial;
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19 2) For general and compensatory damages, to be proven at trial;

20 3) For exemplary and punitive damages to be proven at trial;

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4) For costs of suit herein incurred;
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5) For interest on all sums awarded at the maximum allowable rate;
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6) For such other and further relief as the Court may deem just and proper.
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25 Be sure to modify these paragraphs to suit your individual

26
situation. Do NOT just use the wording here unless it definitely applies
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28 to your particular situation. Remember that EACH slanderous

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COMPLAINT FOR DAMAGES FOR SLANDER
 1 statement is a separate cause of action. And remember that you have to
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3
prepare a Summons, and a Civil Cover Sheet when you file the
4
complaint. Some counties have a local cover sheet as well. Check your
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6 local rules.
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8 Dated________________ _______________________________________________
ANY ATTORNEY OR PARTY
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COMPLAINT FOR DAMAGES FOR SLANDER