Fill and Sign the Complaint for Accounting Form

-1- 1 2 34 5 6 7 8 9 101112 13 1415 16 17 18 19 20 21 22 2324 25 262728 (Name, Address Of Party or attorney) _____________________________ _____________________________ _____________________________ State Bar No: __________________ (____) _____ - _________________ Attorney for _______ (Or "In Pro Per") SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF ________ PLAINTIFF(S) NAMES )CASE NO.: _______Plaintiffs ) ) v) ) DEFENDANT(S) NAMES ) Defendants) ) ---------------------------------------------------------------- COMPLAINT FOR ACCOUNTING Plaintiff complains and for causes of action alleges as follows: FIRST CAUSE OF ACTION (For ________________ Against ________) I. Defendant ____, _____ is ____, and at all times herein mentioned was ____, a resident____ of the City of _____, County of ____, State of California. II. Defendant ____, _____, is ____, and at all times herein mentioned, was ____ a Corporation organized and existing under the laws of the State of California with principle offices located at _____, in the City of _____, County of _____. III. -2- 1 2 34 5 6 7 8 9 101112 13 1415 16 17 18 19 20 21 22 2324 25 262728 Plaintiff____ is ____ ignorant of the true names and capacities of defendants sued herein as DOES I through X, inclusive, and therefore sues____ these defendants by such fictitious names. Plaintiff____ will amend this complaint to allege their true names and capacities when ascertained. IV. Plaintiff____ is ____ informed and believes____ and thereon alleges____ that, at all times herein mentioned, each of the defendants sued herein was the agent and employee of each of the remaining defendants and was at all times acting within the purpose and scope of such agency and employment. V. [----- Allege the relationship between plaintiff and defendant or other circumstances appropriate to an accounting-----] VI. As a result of the aforementioned ____________, Defendant _____ has_____ received money, a portion of which is due to Plaintiff________ from Defendant ________, as previously alleged. VII. The amount of money due from Defendant ________ to Plaintiff________ is unknown to Plaintiff_____ and cannot be ascertained without an accounting of the _________[-----receipts and disbursements of the aforementioned transactions-----]. Plaintiff____ is _____ informed and believes and thereon alleges that the amount due to Plaintiff_____ exceeds $_________. VIII. Plaintiff_____ has_____ demanded an accounting of the aforementioned _________[--- transactions----] from Defendant _____ and payment of the amount found due but Defendant has failed and refused, and continues to fail and refuse, to render such an accounting and to pay such sum. -3- 1 2 34 5 6 7 8 9 101112 13 1415 16 17 18 19 20 21 22 2324 25 262728 WHEREFORE, Plaintiff____ pray____ judgment against Defendant ____ and each of them, as follows: For an accounting between Plaintiff_____ and Defendant _____; For the amount found to be due from Defendant to Plaintiff as a result of the accounting and interest on that amount from and after ________, 20_____; For costs of suit herein incurred. For such other and further relief as the court may deem proper. DATE: ____________________ ____________________ (Signature) VERIFICATION I, _____, am a _____in the above-entitled action. I have read the foregoing _____and know the contents thereof. The same is true of my own knowledge, except as to those matters which are therein alleged on information and belief, and as to those matters, I believe it to be true. I declare under penalty of perjury that the foregoing is true and correct and that this declaration was executed at , California. DATE: ____________________ ____________________ (Signature)