Complaint for Accounting

COMPLAINT FOR ACCOUNTING

State Bar No:

Attorney for (Or "In Pro Per")

SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF

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.

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.

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 . Plaintiff is informed and believes and thereon alleges that the amount due to Plaintiff exceeds $

VIII.

Plaintiff has demanded an accounting of the aforementioned 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.

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.

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.