Conner v. Bitercase, No. LA CV 12-01131

COMPLAINT FOR FRAUD

State Bar No:

Attorney for (Or "In Pro Per")

COMPLAINT FOR FRAUD

Plaintiff complains and for causes of action alleges as follows:

FIRST CAUSE OF ACTION

(For Fraud Against )

I.

Defendant is and at all times herein mentioned was a resident of the City 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.

On or about , defendant falsely and fraudulently represented to plaintiff that

VI.

The representations made by defendant were in fact false. The true facts were:

VII.

When the defendant made these representations knew them to be false, and these representations were made by defendant with the intent to defraud and deceive plaintiff and with the intent to induce plaintiff to act in the manner herein alleged. (--AND At the time defendant made the promises to plaintiff, defendant had no intention of performing them.

VIII.

Plaintiff, at the time these representations were made by defendant and at the time plaintiff took the actions herein alleged, was ignorant of the falsity of defendant's representations and believed them to be true. (---OR Plaintiff, at the time this promise was made and at the time plaintiff took the actions herein alleged, was ignorant of defendant's secret intention not to perform and plaintiff could not, in the exercise of reasonable diligence, have discovered defendant's secret intention.) In reliance on these representations, plaintiff was induced to and did Had plaintiff known the actual facts, would not have taken such action. (---OR If plaintiff had known the actual intention of defendant, plaintiff would not have taken such action.) Plaintiff's reliance

WHEREFORE, plaintiff pray judgment against defendant and each of them, as follows:

For general damages in the sum of $;

For damages for in the sum of $;

For punitive damages in the sum of $;

For costs of suit incurred herein; and

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.