Any Attorney or Party

1 Any Street
Any Town, CA 99999
2
555-555-5555
3
Any Attorney or Party
4

8 SUPERIOR COURT FOR THE STATE OF CALIFORNIA

9 COUNTY OF ________________________

10
Any Plaintiff, Case No.:
11
Plaintiff, UNLIMITED CIVIL; DEMAND OVER
12 $25,000
vs.
13 VERIFIED COMPLAINT FOR:
Any Defendant, and DOES 1 through 50,
14 inclusive, 1. FRAUD
2. RESCISSION OF CONTRACT
15 Defendants. 3. REFORMATION OF CONTRACT
4. USURY VIOLATION
16 5. UNFAIR BUSINESS PRACTICES
6. CANCELLATION OF WRITTEN
17 INSTRUMENTS
7. DECLARATORY RELIEF
18 8. INJUNCTIVE RELIEF
9. ACCOUNTING
19

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COMPLAINT FOR FRAUD, RESCISSION OF CONTRACT

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 1 Plaintiff, ______________hereby complains and alleges as follows:
2 THE PARTIES
3 1. Plaintiff, ____________, (hereinafter referred to as Plaintiff) is and at all times
4 mentioned herein was, an individual, over the age of majority, residing in the City
5 of______________, County of _________, State of California, and the owner of certain real
6 property commonly known as _____________________________________County, California
7 ("the Property") which is legally described as follows:
8 INSERT FULL LEGAL DESCRIPTION FROM DEED
9
APN:
10
2. Defendant, _______________ herein referred to as ("Defendant"), upon
11
information and belief, is and at all times mentioned herein was, an individual, over the age of
12

13 majority, residing in the City of______________, County of _________, State of California

14 3. Based upon information and belief, Plaintiff alleges that Defendant is not a

15 licensed California real estate broker and is not exempt from the California Usury Laws
16
regarding the amount of interest that can be charged on a loan.
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4. The court is the proper court for trial in this action in that the Property is within
18
this Court's jurisdictional area.
19
5. Plaintiff is unaware of the true names or capacities, whether they are individuals
20

21 or business entities, of Defendant DOES 1 through 50, and therefore sues them by such fictitious

22 names and will seek leave from this Court to insert their true names and capacities once they
23 have been ascertained.
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6. At all times mentioned herein, Defendants, and each of them, inclusive of DOES
25
1 through 50, were authorized and empowered by each other to act, and did so act, as agents of
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each other, and all the things herein alleged have been done by them were done in the capacity of
27

28 such agency. Upon information and belief, all Defendants are responsible in some manner for

COMPLAINT FOR FRAUD, RESCISSION OF CONTRACT

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 the events described herein are liable to Plaintiff for the damages that she has incurred.
1

2 FIRST CAUSE OF ACTION

3 (Fraud as against all Defendants)

4 7. Plaintiff realleges and incorporates by reference paragraphs 1 through 6, above, as

5
though fully set forth herein.
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8. On or about __________, in the City of _______, County of ________, State of
7
California, Defendant made verbal and written representations to Plaintiff that he would loan her
8
the sum of $_________ in order that Plaintiff could make upgrades to the Property. The verbal
9

10 and written representations were that Defendant was an honest individual that merely wanted to

11 invest some money in real property. The verbal and written representations were in fact false, but
12 that fact was not known at the time by Plaintiff.
13
9. The true facts were that Defendant never intended to loan Plaintiff the entire sum
14
of $___________ as he had promised and instead intended to change the terms of the loan that
15
he made to Plaintiff to increase both the total principal amount due and the interest rate.
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17 To purchase the entire 16 page document visit:

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20 rescission-of-contract-in-california
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COMPLAINT FOR FRAUD, RESCISSION OF CONTRACT

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