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 _________________

10

11 Any Plaintiff, ) Case No.

)
12 Plaintiff, ) COMPLAINT FOR:
)
13 vs. ) 1. INDEPENDENT ACTION IN EQUITY TO SET
) ASIDE AND VACATE JUDGMENT FOR LACK OF
14 Any Defendant, and DOES 1-100, inclusive, ) PERSONAL JURISDICTION
) 2. INDEPENDENT ACTION IN EQUITY TO SET
15 Defendants. ) ASIDE AND VACATE JUDGMENT FOR
) EXTRINSIC FRAUD OR MISTAKE
16 )
) UNLIMITED CIVIL, DEMAND OVER $25,000
17 )
)
18 )
)
19 )
)
20 )

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- 1 -
COMPLAINT TO SET ASIDE AND VACATE VOID JUDGMENT
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3 Plaintiff, _________________, hereby complain and allege as follows:
4
1. Plaintiffs (Plaintiffs) are now, and at all times relevant herein were, individuals and
5
residents of the City of _________________, County of _________, State of California.
6
2. Defendant _________ (Defendant) is, and at all times relevant herein was, an
7

8 individual, residing in and doing business in the City of _________________, County of _________,

9 State of California.
10
3. This court is the proper court for trial in this action in that the judgment being sought
11
to be vacate was entered, and defendants are currently residing within, this Courts jurisdictional area.
12
4. Plaintiffs are unaware of the true names or capacities, whether they are individuals or
13

14 business entities, of Defendant DOES 1 through 100, and therefore sues them by such fictitious

15 names and will seek leave of this Court to insert true names and capacities once they have been
16 ascertained.
17
5. At all times mentioned herein, Defendants, and each of them, inclusive of DOES
18
1 through 100, were authorized and empowered by each other to act, and did so act, as agents of each
19

20
other, and all of the things herein alleged to have been done by them were done in the capacity of

21 such agency. Upon information and belief, all Defendants are responsible in some manner for the
22 events described herein and are liable to Plaintiffs for the damages they have incurred.
23
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- 2 -
COMPLAINT TO SET ASIDE AND VACATE VOID JUDGMENT