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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 Plaintiff, )
) UNLIMITED CIVIL, DEMAND OVER $25,000
13 vs. )
) COMPLAINT FOR:
14 Any Defendant, Does 1-50, inclusive, )
) 1. DAMAGES FOR VIOLATIONS OF
15 Defendants. ) CALIFORNIA FAIR DEBT COLLECTION
) PRACTICES ACT
16 ) 2. DAMAGES FOR VIOLATIONS OF FEDERAL
) FAIR DEBT COLLECTION PRACTICES ACT
17 )
)
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)
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)
20 )

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- 1 -
CIVIL COMPLAINT
1 To view over 300 sample legal documents for California and
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4 Plaintiff, _________________, hereby complains and alleges as follows:
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1. Plaintiff, __________________(Plaintiff) is and at all times mentioned herein was,
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an individual, over the age of majority, residing in the City of _________, County of _________,
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State of California.

9 2. Defendant, ________ , ("defendant corporation") is now, and at all times mentioned in

10 this complaint was a corporation organized and existing under the laws of the State of California,
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with its principal place of business in ________ County, California.
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3. Defendant, ________ , ("individual defendant") is now, and at all times mentioned in
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this complaint was an individual and an employee of defendant corporation. At all times mentioned in
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15 this complaint, individual defendant was acting within the course and scope of their employment with

16 defendant corporation.
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4. Plaintiff is unaware of the true names and capacities of defendants Does 1 through 50,
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inclusive, and each of them, and therefore sues these defendants by those fictitious names. Plaintiff
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will ask leave to amend this complaint to state their true names and capacities when they have been
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21 ascertained. Plaintiff is informed and believes, and on that basis alleges, that each of the defendants

22 named as a Doe was in some manner responsible for the injury and damage suffered by plaintiff as
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alleged in this complaint. Plaintiff is informed and believes, and on that basis alleges, that some of
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the defendants were the agents and employees of their codefendants, and each of them, and in doing
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the things alleged in this complaint were acting within the scope of their authority as agents and
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27 employees, with the permission and consent of their codefendants, and each of them.

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CIVIL COMPLAINT
1 FIRST CAUSE OF ACTION
2 (Damages for violations of California Fair Debt Collection Practices Act as against
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Defendant________________)
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5. Plaintiff realleges and incorporates by reference paragraphs 1 through 4, above, as
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though fully set forth herein.

7 6. This action is brought in part under the California Fair Debt Collections Practices Act

8 found in Civil Code sections 1788 et seq.,


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7. Defendant corporation operates ________ , in ________, California, and is in the
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business of debt collection. Defendant corporation is a debt collector as defined in Civil Code Section
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1788.2(c) of the California Fair Debt Collection Practices Act.
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violations-of-fair-debt-collection-practices-act-fdcpa
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CIVIL COMPLAINT

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