CASE NUMBER:
SHORT TITLE:
CAUSE OF ACTION—Fraud
Page
(number)
Cross-ComplaintComplaintATTACHMENT TO
(Use a separate cause of action form for each cause of action.)
FR- 1. Plaintiff (name):
alleges that defendant (name):
defrauded plaintiff as follows:on or about (date):
FR-2.
Intentional or Negligent Misrepresentation
as stated in Attachment FR-2.a as follows:
as follows:
as stated in Attachment FR-2.b
b. These representations were in fact false. The truth was
c. When defendant made the representations,
defendant knew they were false, or
FR-3. Concealment
as stated in Attachment FR-3.a as follows:a. Defendant concealed or suppressed material facts
b. Defendant concealed or suppressed material facts
defendant was bound to disclose.
Code of Civil Procedure, § 425.12
www.courtinfo.ca.gov
CAUSE OF ACTION—Fraud
a. Defendant made representations of material fact
defendant had no reasonable ground for believing the representations were true.
d. Defendant made the representations with the intent to defraud and induce plaintiff to act as described
in item FIR-5. At the time plaintiff acted, plaintiff did not know the representations were false and believed
they were true. Plaintiff acted in justifiable reliance upon the truth of the representations.
by telling plaintiff other facts to mislead plaintiff and prevent plaintiff from discovering the concealed
or suppressed facts.
c. Defendant concealed or suppressed these facts with the intent to defraud and induce plaintiff to act
as described in item IFIR-5. At the time plaintiff acted, plaintiff was unaware of the concealed or suppressed
facts and would not have taken the action if plaintiff had known the facts.
Form Approved for Optional Use
Judicial Council of California
PLD-C-001(3) [Rev. January 1, 2007]
PLD-C-001(3)
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