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Fill and Sign the Permissive Cross Complaint from Kinsey Law Offices Attorney Form

Fill and Sign the Permissive Cross Complaint from Kinsey Law Offices Attorney Form

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-1- 1 23456789 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. -2- 1 23456789 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. -3- 1 23456789 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 -4- 1 23456789 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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