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, ) Unlimited Civil, Demand over $25,000.00
vs. )
13 ) COMPLAINT FOR:
)
14 Any Defendants, and DOES 1-5, inclusive, ) 1. DECLARATORY RELIEF
)
15 Defendants. ) 2. BREACH OF FIDUCIARY DUTY
)
16 )
)
17 )
)
18 )
)
19

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28

- 1

COMPLAINT FOR DECLARATORY RELIEF AND BREACH OF FIDUCIARY DUTY

 1 Be sure to remove this notice and all other notices before using
2

3
this document.
4 Plaintiff, ______________hereby files a Complaint and alleges as follows:
5
ALLEGATIONS COMMON TO AND INCLUDED IN
6
ALL CAUSES OF ACTION
7

8
1. Plaintiffs __________ (Plaintiff or Plaintiffs) are, and at all times relevant to this

9 complaint were, individuals and owners of units in the condominium project known as __________

10 (the Project).
11
2. Defendant __________ (the Association) is, and at all times relevant to this complaint
12
was, a nonprofit corporation organized and existing under the laws of the State of California, and the
13
Declaration of Covenants, Conditions and Restrictions binding on the Project. A true and accurate
14

15 copy of the Covenants, Conditions and Restrictions (the CC&Rs), and amendments to the CC&Rs,

16 are attached hereto to this complaint as Exhibit __________ and are incorporated herein by reference.
17
The purpose of the association is to act as a management body for the preservation, maintenance,
18
architectural control and improvement of the common areas of the Project.
19
3. Defendants, __________ (directors), and each of them are, and at all times relevant to
20

21 this complaint were, members of the board of directors of the association. Directors also each own

22 units in the Project.

23
4. Plaintiffs are unaware of the true names or capacities, whether they are individuals or
24
business entities, of Defendant DOES 1 through 100, inclusive, and sues them by such fictitious
25
names. Plaintiffs will seek leave of this Court to insert their true names and capacities once they have
26

27 been ascertained.

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COMPLAINT FOR DECLARATORY RELIEF AND BREACH OF FIDUCIARY DUTY

 1 5. Plaintiffs are informed and believe and upon such information and belief allege, that
2 the defendant, _______________, and DOES 1 through 100 inclusive, were, at all times herein
3
mentioned, authorized and empowered by each other to act, and did so act, as agents of each other,
4
and all of the things herein alleged to have been done by them were done in the capacity of such
5

6
agency. Upon information and belief, all Defendants are responsible in some manner for the events

7 described herein and are liable to Plaintiffs for the damages they have incurred.

8 6. The real property (Subject Property) that is the subject matter of this action is
9
commonly described as __________________________________ in the City of ___________,
10
County of ___________, California, and legally described as INSERT FULL LEGAL
11
DESCRIPTION FROM THE DEED AND THE ASSESSORS PARCEL NUMBER A.P.N.
12

13 _______________.

14 7. Pursuant to the Association's Articles, Bylaws and Amendments to those documents,

15
the powers of the association are to be exercised by and through its board of directors. A true and
16
accurate copy of the Articles, Bylaws and Amendments to those documents are attached hereto to this
17
complaint as Exhibit __________ and incorporated herein by reference.
18

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complaint-for-declaratory-relief-against-condo-association-in-
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COMPLAINT FOR DECLARATORY RELIEF AND BREACH OF FIDUCIARY DUTY