1 Any Attorney or Party

Any Street
2 Any Town, CA 55555

3 714-555-5555

4 Any Attorney or Party

8 Superior Court of the State of California

9 For the County of _________________

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11 Any Plaintiff, ) Case No.

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12 Plaintiff, ) UNLIMITED CIVIL, DEMAND OVER $25,000
)
13 vs. ) COMPLAINT FOR:
)
14 Any Defendant, and DOES 1-50, inclusive, ) 1. BREACH OF CONTRACT
)
15 Defendants. ) 2. COMMON COUNT-OPEN BOOK ACCOUNT
)
16 ) 3. COMMON COUNT-ACCOUNT STATED
)
17 ) 4. COMMON COUNT-GOODS SOLD AND
) DELIVERED
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26 using this document.

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28 Plaintiff, _________________, hereby complains and alleges as follows:

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COMPLAINT
 1 1. Plaintiff, __________________(hereinafter referred to as Plaintiff) is and at all times
2 mentioned herein was, an individual, doing business under the name of _______________in the City
3
of _________, County of _________, State of California. Plaintiff has complied with the fictitious
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business name laws and is doing business under the fictitious name of ___________.
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2. Defendant ______________, (hereinafter referred to as Defendant _____) upon

7 information and belief, is now, and at all times mentioned herein was, a Corporation duly organized

8 and existing under the laws of the State of California, and doing business in the City of
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_________, County of ___________, State of California.
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3. Defendant ____________, (hereinafter referred to as Defendant ____) upon
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information and belief is now, and at all times mentioned herein was, an individual living and doing
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13 business in the City of _________, County of __________, State of California, and is a major

14 shareholder, if not the only shareholder of Defendant ___________________>

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4. This court is the proper court for trial in this action in that the principal place of
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business of Defendant is located within this Courts jurisdictional area.
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5. Plaintiff is unaware of the true names or capacities, whether they are individuals or
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19 business entities, of Defendant DOES 1 through 50, and therefore sues them by such fictitious

20 names and will seek leave of this Court to insert true names and capacities once they have been
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ascertained.
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6. At all times mentioned herein, Defendants, and each of them, inclusive of DOES
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1 through 50, were authorized and empowered by each other to act, and did so act, as agents of each
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25 other, and all of the things herein alleged to have been done by them were done in the capacity of

26 such agency. Upon information and belief, all Defendants are responsible in some manner for the
27
events described herein and are liable to Plaintiff for the damages he has incurred.
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COMPLAINT
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california-with-alter-ego-allegations
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COMPLAINT