Fill and Sign the John Doe James Doe and John Form

John Lawyer, Esq.12 Main Street Anywhere, USAAttorneys for Plaintiffs JOHN DOE, JAMES DOE AND JOHN SMITH,Plaintiffs,v. ABC INC., INVESTMENTS, INC.,Defendants. SUPERIOR COURT OF NEW JERSEY [insert] COUNTYCHANCERY DIVISIONDOCKET NO._______________CIVIL ACTIONVERIFIED COMPLAINTPlaintiffs, John Doe, James Doe, and John Smith, maintaining their principal place of business at [insert address], by way of verified complaint against the defendants, say:1.The plaintiffs, all United States citizens and residents of [insert] County, are the principal owners and operators of a restaurant/commercial establishment commonly known as [insert]. [insert] is located at [insert address] (hereinafter the leased space).2.The defendant, ABC Inc. (hereinafter ABC ), is a tenant who holds leasehold rights to the leased space under the terms of a written lease agreement with the defendant Investments, Inc., which is dated [insert]3.The defendant Investments, Inc., is, upon information and belief, the owner of the leased space.4. On or about [insert date], the plaintiffs and ABC entered into a sublease agreement which entitled the plaintiffs to take occupancy and possession of the leased space. Prior to the plaintiffs taking occupancy, ABC had utilized the leased space for a commercial use (i.e., restaurant).5.At or about the same time that entered into the sublease agreement with the plaintiffs, the parties executed a separate agreement which purported to sell ABC s liquor license and certain assets to the plaintiffs. The plaintiffs also executed a [insert] year promissory note for the benefit of defendant ABC to finance, in part, the purchase price of the license and assets.6. After taking occupancy of the leased space the plaintiffs spent over $[insert]in fit-up and for permanent improvements to the leased space.7. Additionally, the plaintiffs purchased the rights for a liquor license from the defendant ABC for $[insert] dollars.8. Finally, the plaintiffs incurred equipment leasing costs of approximately $[insert] for equipment to be used for the business at the leased space.9. The magnitude of the plaintiffs substantial investment, fit-up and installation of improvements were disclosed to the defendants prior to the plaintiffs occupancy.10.The sublease between the plaintiffs and ABC provided for an initial term to commence on [insert], and terminate on [insert]. See 2 therein.11. The sublease further provided that the plaintiffs were given [insert]year option periods which could be exercised by the plaintiffs giving written notice of their intentions at least [insert] months prior to [insert date], or, by no later than [insert date]. See 5 therein.12. Due to an honest mistake, written notice of the plaintiffs intentions to exercise their first [insert] year option period was not given until [insert].13.The defendant ABC has refused to accept the plaintiffs [insert], notice and has advised that the lease term shall terminate on [insert]. COUNT ONE 14.Due to the substantial investment made to the leased space, the subleasehold documents executed by the parties, and the course of conduct between the parties there exists special circumstances and/or equitable reasons for this court to enforce the plaintiffs [insert], notice to exercise their first [insert]year option period.15.The defendant ABCs failure to accept and honor the [insert], notice will cause unconscionable harm to the plaintiffs if not remedied by this court.WHEREFORE, the plaintiffs demand judgment against the defendants:a.Declaring that the plaintiffs have substantially complied with the sublease provisions for renewal;b.Declaring that the plaintiffs are entitled to the peaceful enjoyment of the leasehold at the leased space through [insert].c.Declaring that the plaintiffs have not forfeited any option to extend the sublease for a [insert] year period upon the same terms and conditions as set forth in the sublease;d.Restraining and estopping the defendants from either (i) interfering with the plaintiffs peaceful enjoyment of the leased space or with the future interests of the plaintiffs with respect therto; or (ii) entering into negotiations or continuing negotiations with respect to the leased space with any third party and from advertising the leased space is available and from offering the leased space to any third party for subletting; ande.For any other relief the court deems is just and necessary. COUNT TWO 16.The plaintiffs hereby repeat the allegations of the first count of this verified complaint as if same was fully set forth herein.17.The actions of the defendants have caused and will continue to cause great damage to the plaintiffs if not remedied by this court. 18.If not remedied, the defendants shall be unjustly enriched to the detriment of the plaintiffs.WHEREFORE, the plaintiffs demand judgment against the defendants:a.Declaring that the plaintiffs have substantially complied with the sublease provisions for renewal;b.Declaring that the plaintiffs are entitled to the peaceful enjoyment of the leasehold at the leased space through [insert date];c.Declaring that the plaintiffs have not forfeited any option to extend the sublease for a [insert] year period upon the same terms and conditions as set forth in the sublease;d.Restraining and estopping the defendants from either (i) interfering with the plaintiffs peaceful enjoyment of the leased space or with the future interests of the plaintiffs with respect therto; or (ii) entering into negotiations or continuing negotiations with respect to the leased space with any third party and from advertising the leased space is available and from offering the leased space to any third party for subletting; ande.For any other relief the court deems is just and necessary. DESIGNATION OF TRIAL COUNSEL Pursuant to R. 4:25-4, John Lawyer, Esq., is hereby designated as trial counsel in the within matter for the plaintiffs. CERTIFICATION Pursuant to Rule 4:5-1, I hereby certify that the matter in controversy is not the subject of any other action pending in any court or a pending arbitration proceeding; and further that no other action or arbitration proceeding is contemplated; and further that there are no other parties who should be joined in this action with the exception of the matter entitled ABC Steakhouse v.Investments, Inc., Docket Number [insert]_________________________________ Dated: JOHN LAWYER VERIFICATION STATE OF:ss.:COUNTY OF :JOHN DOE, of full age, being duly sworn, according to law, upon his oath deposes and says:1. I am one of the Plaintiffs in the foregoing Complaint.2.I hereby certify that the allegations contained in the foregoing Complaint are true to the best of my knowledge and belief. I am aware that if any statements made by me are willfully false, I am subject to punishment._________________________JOHN DOESworn and subscribed to before me this ______ day of _______________, 2002.___________________________John Lawyer, AnAttorney At Law In The State OfNew Jersey