Permissive Cross Complaint

COMPLAINT FOR INJUNCTION

COMPLAINT FOR INJUNCTION

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 defendants by 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. Beginning on or about , 20 and continuing to the present time, Defendants, and each of them, wrongfully and unlawfully .

VI. On or about , 20 and a number of times since then, Plaintiff has demanded that defendants stop their wrongful conduct described above. Defendants, and each of them, have refused and still refuse to refrain from their wrongful conduct.

VII. Defendants' wrongful conduct, unless and until enjoined and restrained by order of this court, will cause great and irreparable injury to Plaintiff in that .

VIII. Plaintiff has no adequate remedy at law for the injuries currently being suffered in that (it will be impossible for Plaintiff to determine the precise amount of damage which will suffer if Defendants' conduct is not restrained) (Plaintiff will be forced to institute a multiplicity of suits to obtain adequate compensation for injuries.

IX.

As a result of defendants' wrongful conduct, plaintiff has been damaged in the sum of $ . Plaintiff will be further damaged in like manner so long as defendants' conduct continues. The full amount of such damage is not now known to Plaintiff and Plaintiff will amend this complaint to state such amount when the same becomes known to or on proof thereof.

WHEREFORE, Plaintiff pray judgment against Defendant and each of them, as follows:

• For an order requiring defendants to show cause, if any they have, why they should not be enjoined as hereinafter set forth, during the pendency of this action;
• For a temporary restraining order, a preliminary injunction, and a permanent injunction, all enjoining defendants, and each of them, and their agents, servants, and employees, and all persons acting under, in concert with, or for them:
• A. From ;
• B. To ;
• For damages in the sum of $ plus damages in such further sums as may be sustained and as are ascertained before final judgment herein;
• For attorney fees herein incurred;
• For costs of suit herein incurred; and
• For such other and further relief as the court deems 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.