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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 _________________

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11 Any Plaintiff, ) Case No


)
12 ) UNLIMITED CIVIL-DEMAND OVER $25,000
Plaintiff, )
13 ) VERIFIED COMPLAINT FOR:
)
14 vs. ) 1. MONEY HAD AND RECEIVED
) 2. FRAUD
15 Any Defendant, and DOES 1 through 100, ) 3. CONVERSION
inclusive, ) 4. VIOLATION OF PENAL CODE SECTION
16 ) 496(a)
Defendants. )
17 )
)
18 )
)
19 )

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VERIFIED COMPLAINT FOR CONVERSION, FRAUD, ETC.
1 Be sure to remove this notice and all other notices before using
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this document.
4 Plaintiff, ___________, an individual, by and though their undersigned counsel, hereby files a
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Complaint and alleges as follows:
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ALLEGATIONS COMMON TO AND INCLUDED IN ALL CAUSES OF ACTION
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1. Plaintiff, _______________ an individual, (Plaintiff) is now, and at all relevant

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

10 of_____________, State of California.


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2. Plaintiff is informed and believes, and thereon alleges, that defendant __________, an
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individual, (Defendant ____) is now, and at all relevant times mentioned herein was, an individual,
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residing in the City of _________, County of ________, State of California. Thus this Court is the
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15 proper Court for the trial of this action.

16 3. Plaintiff is informed and believes, and thereon alleges, that he is unaware of the true
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names or capacities, whether they are individuals or business entities, of Defendant DOES 1 through
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100, inclusive, and sues them by such fictitious names. Plaintiff will seek leave of this Court to insert
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their true names and capacities once they have been ascertained.
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21 4. Plaintiff is informed and believe and upon such information and belief alleges,

22 that Defendant _________, and DOES 1 through 100 inclusive, were, at all times herein mentioned,
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authorized and empowered by each other to act, and did so act, as agents of each other, and all of the
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things herein alleged to have been done by them were done in the capacity of such agency. Upon
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information and belief, all Defendants are responsible in some manner for the events described herein
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27 and are liable to Plaintiff for the damages he has incurred.

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VERIFIED COMPLAINT FOR CONVERSION, FRAUD, ETC.
1 5. On or about ___________, Plaintiff received a check in the amount of $_________
2 (Check) from the _______ client trust account as his share of a settlement of a civil case
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for_____________________. A true and correct copy of said check is attached hereto as Exhibit 1
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and incorporated herein by reference.
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6. Plaintiff is developmentally disabled and has a learning disability and does not have a

7 bank account.

8 7. On or about ___________, Defendant _________, who at that time was the girlfriend
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of Plaintiff, verbally promised Plaintiff that if he would deposit the Check into her bank account that
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she would then withdraw the funds from her bank account and give the funds back to him.
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8. Plaintiff endorsed the Check to Defendant _________ and she then deposited the
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13 Check into her bank account.

14 9. After Defendant _________ deposited the Check into her bank account she terminated
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her relationship with Plaintiff and has refused, and continues to fail and refuse, to give the funds to
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Plaintiff.
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10. On _________, counsel for Plaintiff, sent a letter to Defendant _________ demanding
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19 that she give the funds to Plaintiff no later than _________. A true and correct copy of said letter is

20 attached hereto as Exhibit 2 and incorporated herein by reference.


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11. Defendant _________ failed to respond to the letter sent to her and has failed and
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refused, and continues to fail and refuse to give the funds to Plaintiff as she had verbally promised
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him.
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25 Be sure to modify these paragraphs to suit your individual


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situation. Do NOT just use the wording here unless it definitely applies
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28 to your particular situation.


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VERIFIED COMPLAINT FOR CONVERSION, FRAUD, ETC.
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complaint-for-damages-under-penal-code-section-496c
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VERIFIED COMPLAINT FOR CONVERSION, FRAUD, ETC.

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