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 ) UNLIMITED CIVIL-DEMAND OVER $25,000
Plaintiff, )
13 ) COMPLAINT FOR:
)
14 vs. ) 1. NEGLIGENCE
) 2. GROSS NEGLIGENCE
15 Any Defendant, and DOES 1 through 100, ) 3. PREMISES LIABILITY
inclusive, )
16 )
Defendants. )
17 )
)
18 )
)
19 )

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- 1
COMPLAINT FOR NEGLIGENCE, GROSS NEGLIGENCE AND PREMISES LIABILITY
 1 Be sure to remove this notice and all other notices before using
2

3
this document.
4 Plaintiff, ___________, an individual, by and though their undersigned counsel, hereby files a
5
Complaint and alleges as follows:
6
1. Plaintiff, _______________ an individual, (Plaintiff) is now, and at all relevant
7

8
times mentioned herein was, an individual, residing in the City of __________, County

9 of_____________, State of California.

10 2. Plaintiff is informed and believes and based thereon alleges that Defendant,
11
_____________________, a business entity form unknown, (Defendant ________) is now, and at
12
all times relevant hereto was, a business entity whose exact form of organization is unknown and
13
doing business in the City of ______, County of ______, State of California.
14

15 3. Plaintiff is informed and believes, and thereon alleges, that he is unaware of the true

16 names or capacities, whether they are individuals or business entities, of Defendant DOES 1 through
17
100, inclusive, and sues them by such fictitious names. Plaintiff will seek leave of this Court to insert
18
their true names and capacities once they have been ascertained.
19
4. Plaintiff is informed and believe and upon such information and belief alleges,
20

21 that Defendant _________, and DOES 1 through 100 inclusive, were, at all times herein mentioned,

22 authorized and empowered by each other to act, and did so act, as agents of each other, and all of the
23
things herein alleged to have been done by them were done in the capacity of such agency. Upon
24
information and belief, all Defendants are responsible in some manner for the events described herein
25
and are liable to Plaintiff for the damages he has incurred.
26

27 5. This is the proper county and court for the trial of this action as the injuries to Plaintiff

28 occurred within this judicial district.

- 2
COMPLAINT FOR NEGLIGENCE, GROSS NEGLIGENCE AND PREMISES LIABILITY
 1 SECOND CAUSE OF ACTION
2 (Gross Negligence as against Defendant, _______, a business entity form unknown and Does
3
1 through 100, inclusive)
4
14. Plaintiff hereby incorporates by reference paragraphs 1 through 13, inclusive of this
5

6
Complaint as if set forth in full in this paragraph.

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complaint-for-gross-negligence-in-california
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COMPLAINT FOR NEGLIGENCE, GROSS NEGLIGENCE AND PREMISES LIABILITY