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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 _________________

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11 Any Plaintiff, ) Case No.


)
12 Plaintiff, ) COMPLAINT FOR:
)
13 vs. ) 1. BREACH OF CONTRACT
) 2. BREACH OF COVENANT OF GOOD FAITH
14 Any Defendant, and DOES 1-100, inclusive, ) AND FAIR DEALING
) 3. BREACH OF COVENANT OF QUIET
15 Defendants. ) ENJOYMENT OF THE PREMISES
) 4. TRESPASS
16 ) 5. NUISANCE [CIVIL CODE 3479]
) 6. INTENTIONAL INFLICTION OF EMOTIONAL
17 ) DISTRESS
) 7. NEGLIGENT INFLICTION OF EMOTIONAL
18 ) DISTRESS
) 8. NEGLIGENCE
19 ) 9. WRONGFUL EVICTION [ CIVIL CODE 789.3]
) 10.CONSTRUCTIVE EVICTION
20 ) 11. UNCURED BUILDING VIOLATIONS [CIVIL
) CODE 1942.4]
21 )
) UNLIMITED CIVIL, DEMAND OVER $25,000
22 )
)
23 )

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address.
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- 1 -
CIVIL COMPLAINT
1 For more information on my California eviction document
2

3
collection containing over 30 sample documents including this sample
4
complaint against a landlord in California selling at a huge discount
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using this document.
12 Plaintiff, _________________, hereby complains and alleges as follows:
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1. Plaintiffs (Plaintiffs) are now, and at all times relevant herein were, individuals and
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residents of the City of _________________, County of _________, State of California.
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2. Defendant _________ (Defendant) is, and at all times relevant herein was, an
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17 individual, and an owner of the real property located at ________________________, (Property)

18 3. This court is the proper court for trial in this action in that the actions and omissions of
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Defendants as alleged herein were made within this Courts jurisdictional area.
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4. Plaintiffs are unaware of the true names or capacities, whether they are individuals or
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business entities, of Defendant DOES 1 through 100, and therefore sues them by such fictitious
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23 names and will seek leave of this Court to insert true names and capacities once they have been

24 ascertained.
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5. At all times mentioned herein, Defendants, and each of them, inclusive of DOES
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1 through 100, 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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CIVIL COMPLAINT
1 such agency. Upon information and belief, all Defendants are responsible in some manner for the
2 events described herein and are liable to Plaintiffs for the damages they have incurred.
3
FIRST CAUSE OF ACTION
4
BREACH OF CONTRACT
5

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(Against all Defendants)

7 6. Plaintiffs refer to, and incorporate by reference, the allegations of paragraphs 1 through

8 5 of this complaint, as though fully set forth herein.


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7. On ______________, Plaintiffs entered into a written contract with Defendant for the
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rental of real property located at _________________, for a monthly rental rate of $______________
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for a period of one year. The term was to begin on ____________. A true and correct copy of said
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13 written contract is attached hereto as Exhibit 1 and incorporated herein by reference.

14 8. At the walk-through on _____________, Plaintiffs noted several problems with the


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Property and informed ________________, the agent for Defendant. The move-in date was delayed
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to allow Defendant to fix the problems.
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9. On __________, Plaintiffs began moving into the Property. On ___________
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19 Plaintiffs spent their first night in the property. That evening numerous fleas were found in the

20 Property. Plaintiffs were both bitten by the fleas numerous times.


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10. On _______________, Plaintiffs telephoned ______________and explained the flea
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infestation problem. ____________ informed Defendant about the flea infestation. Due to the flea
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infestation problem, Plaintiffs were unable to unpack their belongings, use most of the house, and
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25 unable to load their rented moving truck.

26 11. On _______ Plaintiffs then contacted _____________ again regarding rent deductions
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due to the flea infestation problem.
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CIVIL COMPLAINT
1 12. On __________ Plaintiffs then had their movers remove all of their belongings from the
2 Property to allow for the pest control service to remove the fleas. They then moved their belongings
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back in. The technician hired by Defendant who worked with the company known as ____________
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verified the flea infestation in the inside of the Property and also on the outside.
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13. On ___________, _____________ confirmed that Defendant would pay for the

7 _______________ service.

8
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11
complaint-against-landlord
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CIVIL COMPLAINT