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-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: PRELIMINARY ALLEGATIONS 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. FIRST CAUSE OF ACTION (For Money Against ___ _) V. Plaintiff__ incorporate__ in this Cause of Action Paragraphs ___ through ___ herein the same as though fully set out in this Cause of Action at length. VI. Within the last ___ (two or four) years on or about ___________, 20____, at ___________, California, Defendant _____________ became indebted to Plaintiff ____________ in the sum of $_____ for money had and received by Defendant______ for the use and benefit of Plaintiff. VII. Neither the whole nor part of this sum has been paid [except the sum of $_____] although demand therefor has been made, and there is now due, owing, and unpaid the sum of $______ with interest thereon at the rate of ______ percent per annum from ___, 20_____. SECOND CAUSE OF ACTION (For Money Lent Against _____________) VIII -3- 1 2 34 5 6 7 8 9 101112 13 1415 16 17 18 19 20 21 22 2324 25 262728 Within the last ____ years on or about __________, 20_______ at ______, California, defendant ___________ became indebted to Plaintiff__________ in the sum of $______ for money lent by Plaintiff ____ to Defendant_______ at Defendant ______ request. IX. Neither the whole nor any part of the above sum has been paid, [except the sum of $_________] although payment has been demanded, leaving a balance due, owing, and unpaid to Plaintiff in the sum of $______, together with interest thereon at the rate of ______ per annum from ______, 20______. THIRD CAUSE OF ACTION (For Money Paid Against ____) X. Within the last ______ years on or about _______, 20______ at _______, California, Defendant ________ became indebted to Plaintiff _______ in the sum of $________ for money paid, laid out, and expended for Defendant at Defendant_______ instance and request. XI. Neither the whole nor any part of the above sum has been paid, [except the sum of $______] although payment has been demanded, leaving a balance due, owing, and unpaid to Plaintiff in the sum of $______, together with interest thereon at the rate of ___ per annum from ______, 20_____. FOURTH CAUSE OF ACTION (For Work, Labor and Materials Against ____) XII. Within the last ______ years on or about _______, 20_____ at ______, California, Defendant_________ became indebted to Plaintiff _________ for work and labor done by Plaintiff _________ for Defendant at the special instance and request of Defendant, and for materials furnished in connection with the work and labor, for the sum of $________ which sum Defendant ________ agreed to pay Plaintiff. -4- 1 2 34 5 6 7 8 9 101112 13 1415 16 17 18 19 20 21 22 2324 25 262728 XIII. Neither the whole nor any part of the above sum has been paid, [except the sum of $______] although demand therefor has been made, and there is now due and owing, and unpaid the sum of $______, with interest thereon at the rate of ______ percent per annum from ______, 20_____. FIFTH CAUSE OF ACTION (For Work, Labor and Services Against ____) XIV. Within the last _______ years on or about _______, 20_____ at _________, California, Defendant________ became indebted to Plaintiff____________ in the agree sum of $______ for work, labor, and services rendered by Plaintiff ________ at the special request of Defendant. XV. Neither the whole nor any part of the above sum has been paid [except the sum of $_______] not withstanding that demand has been made for payment, and there is now due, owing, and unpaid from Defendant to Plaintiff the sum of $________, together with interest thereon at the rate of ______ percent per annum from ________, 20______. SIXTH CAUSE OF ACTION (For Quantum Meruit Against ____) XVI Within the last _______ years on or about _______, 20_____ at ______, California, Plaintiff _______ rendered work, labor, and services to Defendant ______ at the special request of Defendant_______ for which Defendant, then and there, promised to pay Plaintiff______ the reasonable value of such services. XVII. At all times herein mentioned, the above services were and are of the reasonable value of $_______. -5- 1 2 34 5 6 7 8 9 101112 13 1415 16 17 18 19 20 21 22 2324 25 262728 XVIII No part of the above sum has been paid, [except the sum of $_________] not withstanding that Plaintiff has demanded payment therefor, and there is now due, owing, and unpaid from Defendant to Plaintiff the sum of $__________. WHEREFORE, Plaintiff_______ pray________ judgment against Defendant _____________ and each of them, as follows: For damages for ____ according to proof. For interest from ____ at the rate of 10% per annum. For such other and further relief as the court may deem proper. DATE: ____________________ ____________________ (Signature) VERIFICATIONI, ___, 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)