Complaint for Unlawful Detainer

State Bar No:

Attorney for

SUPERIOR COURT OF THE STATE OF CALIFORNIA

COUNTY OF

v

COMPLAINT FOR UNLAWFUL DETAINER

Plaintiff complains and for causes of action alleges as follows:

I.

Plaintiff, , is an individual and is now and at all times mentioned in this complaint was, a resident of County, California.

II.

Plaintiff is now and at all times mentioned in this complaint was, the of located at and further described as

III.

Defendants, , are now, and at all times mentioned in this complaint were, individuals residing in County, California.

IV.

Plaintiff does not know the true names of defendants DOES 1 through 25, and therefore sues them by those fictitious names.

V.

Plaintiff is informed and believes that each defendant was in some manner legally responsible for the events alleged in this complaint.

VI.

On or about , plaintiff and defendants entered into a for the premises described above, under the terms of which plaintiff leased the premises to defendant for the term of at the agreed monthly rent of $ payable in advance on the first day of each month commencing on and terminating on .

VII.

The specified in paragraph was made with

VIII.

Defendants not named in paragraph are

IX.

Defendants entered into possession of the premises on , and paid the monthly rent pursuant to the lease terms from to . Defendants continue to occupy the premises.

X.

Defendants have not paid rent installments as required by the terms and conditions of the since and continuing to the present.

The sum of $ , which represents the unpaid rent, is now due and payable to plaintiff.

XI.

Plaintiff has performed all conditions of the .

XII.

On , the following notice was served on :

The notice was served by .

XIII.

The notice specified in paragraph included an election of forfeiture. A copy of this notice is attached as Exhibit .

XIV.

The period in the notice specified in paragraph expired on , but defendants have neither nor vacated the premises.

XV.

Defendants continue in possession of the premises without plaintiff's permission and despite the notice served on defendants as specified in paragraph .

XVI.

The fair rental value of the premises is $ per day. Damages have accrued at this rate since and will continue to accrue until defendants have vacated the premises.

XVII.

Defendants' tenancy is subject to the local rent control or eviction control ordinance of .

Plaintiff has met all applicable requirements of the ordinance.

XVIII.

The written provides that if any party is compelled to bring an action at law to enforce the agreement or recover possession of the premises, the prevailing party will recover reasonable attorney fees.

WHEREFORE, plaintiff requests judgment against defendant, and each of them, of:

Immediate possession of the premises;

Past due rent in the sum of $ ;

Forfeiture of the agreement;

Damages at the rate of $ per day;

Statutory damages of $600 pursuant to Code of Civil Procedure section 1174(b);

Reasonable attorney fees;

Costs incurred in this proceeding; and

Any further relief the court considers just and proper.

VERIFICATION

I, , am a in the above-entitled action. I have read the foregoing and know the contents thereof.

I declare under penalty of perjury that the foregoing is true and correct and that this declaration was executed at , California.