Form Approved for Optional Use
Judicial Council of California PLD-
PI-001(4) [Rev. January 1, 2007]
CAUSE OF ACTION—Premises Liability
Code of Civil Procedure, § 425.12
www.courts.ca.gov
PLD-PI-001(4)
CASE NUMBER:
SHORT TITLE:
CAUSE OF ACTION—Premises Liability
(number)
Page
ATTACHMENT TO
Complaint
Cross-Complaint
(Use a separate cause of action form for each cause of action.)
Prem.L-1.
(name):
alleges the acts of defendants were the legal (proximate) cause of damages to plaintiff.
On (date):
plaintiff was injured on the following premises in the following
fashion (description of premises and circumstances of injury):
Prem.L-2.
Count One—Negligence The defendants who negligently owned, maintained, managed and
operated the described premises were
(names):
Does
to
Prem.L-3.
Count Two—Willful Failure to Warn [Civil Code section 846] The defendant owners who willfully
or maliciously failed to guard or warn against a dangerous condition, use, structure, or activity were
(names):
to
Does
Plaintiff, a recreational user, was
an invited guest a paying guest.
Prem.L-4.
Count Three—Dangerous Condition of Public Property The defendants who owned public property
on which a dangerous condition existed were
(names):
Does
to
a.
The defendant public entity had actual
constructive notice of the existence of the
dangerous condition in sufficient time prior to the injury to have corrected it.
b.
The condition was created by employees of the defendant public entity.
Prem.L-5.a.
Allegations about Other Defendants The defendants who were the agents and employees of the other
defendants and acted within the scope of the agency were
(names):
Does
to
b. The defendants who are liable to plaintiffs for other reasons and the reasons for their liability are
described in attachment Prem.L-5.b
as follows (names):
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