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    Complaint To Impose Constructive Trust

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    smallhagrid
    This document is a complaint filed in a California Superior Court. It alleges that the plaintiff has been damaged due to the fraudulent misrepresentations and wrongful conduct of the defendant(s). The complaint includes causes of action for fraud and requests that the court declare the defendant(s) hold property in constructive trust for the benefit of the plaintiff. It also requests costs, damages, and any further relief deemed proper by the court. The plaintiff signs a verification stating they believe the contents of the complaint to be true and correct.

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    Attribution Non-Commercial (BY-NC)
    Download as DOCX, PDF, TXT or read online from Scribd

    Complaint To Impose Constructive Trust

    Uploaded by

    smallhagrid
    3K views5 pages
    This document is a complaint filed in a California Superior Court. It alleges that the plaintiff has been damaged due to the fraudulent misrepresentations and wrongful conduct of the defendant(s). The complaint includes causes of action for fraud and requests that the court declare the defendant(s) hold property in constructive trust for the benefit of the plaintiff. It also requests costs, damages, and any further relief deemed proper by the court. The plaintiff signs a verification stating they believe the contents of the complaint to be true and correct.

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    Complaint to Impose Constructive Trust

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    © Attribution Non-Commercial (BY-NC)

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    This document is a complaint filed in a California Superior Court. It alleges that the plaintiff has been damaged due to the fraudulent misrepresentations and wrongful conduct of the defendant(s). The complaint includes causes of action for fraud and requests that the court declare the defendant(s) hold property in constructive trust for the benefit of the plaintiff. It also requests costs, damages, and any further relief deemed proper by the court. The plaintiff signs a verification stating they believe the contents of the complaint to be true and correct.

    Copyright:

    Attribution Non-Commercial (BY-NC)
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    3K views5 pages

    Complaint To Impose Constructive Trust

    Uploaded by

    smallhagrid
    This document is a complaint filed in a California Superior Court. It alleges that the plaintiff has been damaged due to the fraudulent misrepresentations and wrongful conduct of the defendant(s). The complaint includes causes of action for fraud and requests that the court declare the defendant(s) hold property in constructive trust for the benefit of the plaintiff. It also requests costs, damages, and any further relief deemed proper by the court. The plaintiff signs a verification stating they believe the contents of the complaint to be true and correct.

    Copyright:

    Attribution Non-Commercial (BY-NC)
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    of 5

    c Y

      
    Y

    
    (Name, Address of Party or Attorney)
    ____________
    ____________
    ____________
    State Bar No: ______
    (____) _____ - ________
    Attorney for _______ (Or "In Pro Per")
    
    SUPERIOR COURT OF THE STATE OF
    CALIFORNIA
    COUNTY OF ________
    
     c cYY YYY$ c%&&&&&&&YY
      
    !YY YYYYY
    YY$ YY
    YYY YY$c $'
    YY cYY
    "#YY YY
    YY
    YYY YY
    YY
    YYY YY
    (( c cYY YY
    ( ) 
    YY
    &&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&YY

    Plaintiff complains and for causes of


    action alleges as follows:
    FIRST CAUSE OF ACTION
    (For ________ Against ____)
    
    <>. Defendant__, ___ is__, and at all
    times herein mentioned was__, a
    resident__ of the City of ___, County of
    __, State of California.
    <>. Defendant__, ___, is__, and at all
    times herein mentioned, was__ a
    Corporation organized and existing
    under the laws of the State of California
    with principle offices located at ___, in
    the City of ___, County of ___.
    <>. Plaintiff__ is__ ignorant of the true
    names and capacities of defendants
    sued herein as DOES I through X,
    inclusive, and therefore sues__ these
    defendants by such fictitious names.
    Plaintiff__ will amend this complaint to
    allege their true names and capacities
    when ascertained.
    <>. Plaintiff__ is__ informed and
    believes__ and thereon alleges__ that, at
    all times herein mentioned, each of the
    defendants sued herein was the agent
    and employee of each of the remaining
    defendants and was at all times acting
    within the purpose and scope of such
    agency and employment.
    <>. As a proximate result of the defendant___ fraudulent misrepresentations and otherwise
    wrongful conduct as elleged herein, Plaintiff__ is__ [----state threatened damages---]
    <>. By reason of the fraudulent and otherwise wrongful manner in which the defendants___, or
    any of them, obtained their alleged right, claim or interest in and to the property, defendant___,
    and each of them, have no legal or equitable right, claim or interest therein, but, instead,
    Defendant___, and each of them are involuntary trustees holding said property and profits
    therefrom in constructive trust for Plaintiff___ with the duty to convey the same to Plaintiff___
    
    forthwith.

    
    [HEREFORE, plaintiff__ pray__
    judgment against defendant__ and each
    of them, as follows:
    <>. For a declaration that Defendant___ hold the ___ as constructive trustees for the benefit of the
    Plaintiff___;
    <>. For costs of suit incurred herein; and
    <>. For such other and further relief as the court may deem proper. 
    Y( (%
    Y&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&&Y
    &&&&&&&&&&&&&&&Y
    YYY Yc* Y

    
    GERIFICATION
    
    
    I, ___, am a ___in the above-entitled
    action. I have read the foregoing ©©©and
    know the contents thereof. The same is
    true of my own knowledge, except as to
    those matters which are therein alleged
    on information and belief, and as to
    those matters, I believe it to be true.
    I declare under penalty of perjury that
    the foregoing is true and correct and
    that this declaration was executed at
    Long Beach, California.
    
    
    DATED: _________________
    ___________________________________
    Y

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