Permissive cross complaint from kinsey law offices attorney form
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10111213141516171819202122232425262728 ( 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 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.
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10111213141516171819202122232425262728 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 ca pacities
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.
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10111213141516171819202122232425262728 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. DATE: ____________________
____________________ (Signature)
VERIFICATION
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10111213141516171819202122232425262728 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.
DATE: ____________________
____________________ (Signature)
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