Sample California Complaint Against Landlord

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. BREACH OF CONTRACT
) 2. BREACH OF COVENANT OF GOOD FAITH
14 Any Defendant, and DOES 1-100, inclusive, ) AND FAIR DEALING
) 3. BREACH OF COVENANT OF QUIET
15 Defendants. ) ENJOYMENT OF THE PREMISES
) 4. TRESPASS
16 ) 5. NUISANCE [CIVIL CODE 3479]
) 6. INTENTIONAL INFLICTION OF EMOTIONAL
17 ) DISTRESS
) 7. NEGLIGENT INFLICTION OF EMOTIONAL
18 ) DISTRESS
) 8. NEGLIGENCE
19 ) 9. WRONGFUL EVICTION [ CIVIL CODE 789.3]
) 10.CONSTRUCTIVE EVICTION
20 ) 11. UNCURED BUILDING VIOLATIONS [CIVIL
) CODE 1942.4]
21 )
) UNLIMITED CIVIL, DEMAND OVER $25,000
22 )
)
23 )
24
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- 1 -
CIVIL COMPLAINT
1 For more information on my California eviction document
2
3
collection containing over 30 sample documents including this sample
4
complaint against a landlord in California selling at a huge discount
5
6 visit
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http://legaldocspro.net/california-eviction-litigation-document-package/
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using this document.
12 Plaintiff, _________________, hereby complains and alleges as follows:
13
1. Plaintiffs (Plaintiffs) are now, and at all times relevant herein were, individuals and
14
residents of the City of _________________, County of _________, State of California.
15
2. Defendant _________ (Defendant) is, and at all times relevant herein was, an
16
17 individual, and an owner of the real property located at ________________________, (Property)
18 3. This court is the proper court for trial in this action in that the actions and omissions of
19
Defendants as alleged herein were made within this Courts jurisdictional area.
20
4. Plaintiffs are unaware of the true names or capacities, whether they are individuals or
21
business entities, of Defendant DOES 1 through 100, and therefore sues them by such fictitious
22
23 names and will seek leave of this Court to insert true names and capacities once they have been
24 ascertained.
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5. At all times mentioned herein, Defendants, and each of them, inclusive of DOES
26
1 through 100, were authorized and empowered by each other to act, and did so act, as agents of each
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other, and all of the things herein alleged to have been done by them were done in the capacity of
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- 2 -
CIVIL COMPLAINT
1 such agency. Upon information and belief, all Defendants are responsible in some manner for the
2 events described herein and are liable to Plaintiffs for the damages they have incurred.
3
FIRST CAUSE OF ACTION
4
BREACH OF CONTRACT
5
6
(Against all Defendants)
7 6. Plaintiffs refer to, and incorporate by reference, the allegations of paragraphs 1 through
8 5 of this complaint, as though fully set forth herein.

9
7. On ______________, Plaintiffs entered into a written contract with Defendant for the
10
rental of real property located at _________________, for a monthly rental rate of $______________
11
for a period of one year. The term was to begin on ____________. A true and correct copy of said
12
13 written contract is attached hereto as Exhibit 1 and incorporated herein by reference.
14 8. At the walk-through on _____________, Plaintiffs noted several problems with the

15
Property and informed ________________, the agent for Defendant. The move-in date was delayed
16
to allow Defendant to fix the problems.
17
9. On __________, Plaintiffs began moving into the Property. On ___________
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19 Plaintiffs spent their first night in the property. That evening numerous fleas were found in the
20 Property. Plaintiffs were both bitten by the fleas numerous times.

21
10. On _______________, Plaintiffs telephoned ______________and explained the flea
22
infestation problem. ____________ informed Defendant about the flea infestation. Due to the flea
23
infestation problem, Plaintiffs were unable to unpack their belongings, use most of the house, and
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25 unable to load their rented moving truck.
26 11. On _______ Plaintiffs then contacted _____________ again regarding rent deductions
27
due to the flea infestation problem.
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- 3 -
CIVIL COMPLAINT
1 12. On __________ Plaintiffs then had their movers remove all of their belongings from the
2 Property to allow for the pest control service to remove the fleas. They then moved their belongings
3
back in. The technician hired by Defendant who worked with the company known as ____________
4
verified the flea infestation in the inside of the Property and also on the outside.
5
6
13. On ___________, _____________ confirmed that Defendant would pay for the
7 _______________ service.
8
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CIVIL COMPLAINT

Sample California Complaint Against Landlord

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1 Any Attorney or Party

4 Any Attorney or Party

8 Superior Court of the State of California

9 For the County of _________________

11 Any Plaintiff, ) Case No.

26 http://legaldocspro.net/newsletter.htm and enter your e-mail

9 Be sure to remove this notice and all other notices before

17 individual, and an owner of the real property located at ________________________, (Property)

8 5 of this complaint, as though fully set forth herein.

13 written contract is attached hereto as Exhibit 1 and incorporated herein by reference.

14 8. At the walk-through on _____________, Plaintiffs noted several problems with the

20 Property. Plaintiffs were both bitten by the fleas numerous times.

25 unable to load their rented moving truck.

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