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27 COMES NOW, Plaintiff, ____________________________,_ and alleges as follows:
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INTRODUCTION
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COMPLAINT FOR BREACH OF CONTRACT, BREACH OF COVENANT OF GOOD FAITH AND FAIR
DEALING, NEGLIGENCE, DECLARATORY RELIEF
1 1. Plaintiff ______________ (Plaintiff) at all times herein mentioned was, and is, an
2 individual residing in the City of ________, State of California.
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2. Plaintiff is informed and believes, and on that basis alleges, that defendant,
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_______________(__________) at all times herein relevant was, and now is, a corporation duly
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organized and existing under the laws of the State of California, licensed to do business and actually
7 doing business as an insurer and issuing insurance Policies in the state of California, with its principal
13 doing business as an insurance agent for insurance Policies issued in the state of California, with its
14 principal place of business in the City of _______, County of __________, State of California.
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4. This Court is the proper Court for the trial of this action because the Property
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owned by Plaintiff is, and at all relevant times mentioned herein was, located at
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_________________________, (Property).
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20 otherwise, of defendants named herein as DOES 1 through 100, inclusive, are unknown to Plaintiff
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at this time, who therefore sues said defendants by such fictitious names. Plaintiff is informed and
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believes and therefore alleges that each of the defendants designated herein by fictitious name is in
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some manner responsible for the events and happenings herein referred to, and caused damages
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25 proximately and foreseeably thereby to Plaintiff as hereinafter alleged. Plaintiff asks leave of the
26 Court to amend this Complaint when the true names and capacities have been ascertained.
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6. That at all times herein mentioned, each and every defendant herein was the agent,
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- 2 -
COMPLAINT FOR BREACH OF CONTRACT, BREACH OF COVENANT OF GOOD FAITH AND FAIR
DEALING, NEGLIGENCE, DECLARATORY RELIEF
1 servant, employee, partner and/or joint venturer of the other defendants herein; that at all said times,
2 each of said defendants was acting within the course and scope of said agency, service, employment,
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partnership and joint venture.
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GENERAL ALLEGATIONS
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7. Plaintiff repeats and realleges the allegations of paragraphs 1 through 6 of this
13 "Personal injury" means injury, other than "bodily injury," arising out of one or more of the
14 following offenses:
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d. oral or written publication of material that slanders or libels a person or organization
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or disparages a person's or organization's goods, products or services; or
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e. oral or written publication of materials that violates a person's right of privacy."
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19 Attached hereto as Exhibit "A" and incorporated herein are copies of the Policies from
20 ____________through ____________.
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To purchase the entire 10 page document visit:
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23 https://legaldocspro.myshopify.com/products/sample-complaint-
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against-insurance-company-for-bad-faith-in-california
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COMPLAINT FOR BREACH OF CONTRACT, BREACH OF COVENANT OF GOOD FAITH AND FAIR
DEALING, NEGLIGENCE, DECLARATORY RELIEF