1 Any Attorney or Party

Any Street
2 Any Town, CA 99999

3 555-555-5555

4 Any Attorney or Party

8 Superior Court of the State of California

9 For the County of ______________

10

11 Any Plaintiff, ) Case No.

)
12 ) COMPLAINT FOR:
Plaintiff, )
13 ) 1. FRAUDULENT TRANSFER UNDER THE
vs. ) UNIFORM VOIDABLE TRANSACTIONS ACT
14 ) [CIVIL CODE 3439, et seq.]
Any Defendant, DOES 1 through 100, inclusive, )
15 ) 2. COMMON LAW FRAUDULENT TRANSFER
Defendant. )
16 ) 3. VIOLATION OF BULK SALE LAW
)
17 )
)
18

19
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28

- 1 -
COMPLAINT FOR FRAUDULENT TRANSFER
 1 COMES NOW the Plaintiff, _______________ , an individual (Plaintiff) who alleges as
2 follows:
3
1. Plaintiff is now, and at all times mentioned herein was, an individual, residing in
4
and doing business in the City of _________, County of _____________, State of California.
5

6
2. Plaintiff is informed and believes, and on that basis alleges, that Defendants,

7 ____________________________________ are, and at all times mentioned herein were,

8 __________________________, organized and existing pursuant to the laws of the State of

9
_______________, and were authorized to, and are, doing business in, the city of ______, County of
10
_____________, State of California. Thus this Court has jurisdiction to hear this case and venue is
11
proper.
12

13 3. Plaintiff is ignorant of the true names and capacities of Defendants sued herein as

14 DOES 1 through 100, inclusive, and therefore sues these Defendants by such fictitious names.
15
Plaintiff will amend this complaint to allege their true names and capacities when ascertained.
16
Plaintiff is informed and believes, and on that basis alleges, that each of the fictitiously named
17
defendants claims an interest in the property hereinafter described and which is the subject of this
18

19 action, or were responsible in some manner for the damages suffered by Plaintiff.

20 4. From and after _______, Plaintiff has been the holder of a certain claim
21
against Defendant _________. This claim consists of all right, title and interest, to the Judgment
22
entered and filed on _________, in the Superior Court of California, County of
23
__________________, Case Number ______, in the total sum of $__________, against Defendant
24

25 ___________. Said Judgment arises from an action filed on or about _________________, in the

26 afore-mentioned Court. Defendant __________ was duly served in said action on or about
27

28

- 2 -
COMPLAINT FOR FRAUDULENT TRANSFER
 1 _____________. Said Judgment was entered in favor of Plaintiff against Defendant __________, and
2 has never been appealed nor been vacated or modified. No part of said Judgment has been satisfied.
3
FIRST CAUSE OF ACTION
4
(Fraudulent transfer under the Uniform Voidable Transactions Act as against all Defendants)
5

6
5. Plaintiff refers to and incorporates herein Paragraphs 1 through 4, inclusive, of the

7 Complaint as though set forth in full herein.

8 6. On or about __________, Defendant __________ and Defendant ___________

9
entered into an Agreement in which Defendant _______purchased all of the assets of Defendant
10
__________ for the sum of $__________. Said assets included (1) _____ customer lists, (2) certain
11
computers and equipment, (3) certain inventories of raw material, and (4) ________ license rights to
12

13 manufacture and sell _____.

14 7. Defendant ___________ did not assume all of the liabilities and obligations of
15
Defendant ___________, but only assumed the following liabilities, (1) Building rent of $______,
16
and (2) _______ liabilities for customer returns in the approximate amount of $_______. The
17
liabilities not assumed by Defendant ___________ included the claim of Plaintiff.
18

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fraudulent-transfer-in-california
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- 3 -
COMPLAINT FOR FRAUDULENT TRANSFER