Transcription of CAUSE OF ACTION—Fraud - California
1 CASE NUMBER:SHORT TITLE: CAUSE OF ACTION FraudPage(number)Cross-ComplaintComplain tATTACHMENT 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) or Negligent Misrepresentation as stated in Attachment follows:as follows:as stated in Attachment These representations were in fact false. The truth wasc. When defendant made the representations,defendant knew they were false, or stated in Attachment follows:a. Defendant concealed or suppressed material factsb. Defendant concealed or suppressed material factsdefendant was bound to of Civil Procedure, OF ACTION fraud a.
2 Defendant made representations of material factdefendant had no reasonable ground for believing the representations were 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 telling plaintiff other facts to mislead plaintiff and prevent plaintiff from discovering the concealed or suppressed Defendant concealed or suppressed these facts with the intent to defraud and induce plaintiff to act as described in item IFIR-5.
3 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 Approved for Optional UseJudicial Council of CaliforniaPLD-C-001(3) [Rev. January 1, 2007]PLD-C-001(3)Page 1 of 2 CASE NUMBER:SHORT TITLE: CAUSE OF ACTION fraud Page(number) statedin Attachment follows:b. Defendant's promise without any intention of performance was made with the intent to defraud and induceplaintiff to rely upon it and to act as described in item FR-5. At the time plaintiff acted, plaintiff was unaware of defendant's intention not to perform the promise. Plaintiff acted in justifiable reliance upon the stated in Attachment FR-5FR-5.
4 In justifiable reliance upon defendant's conduct, plaintiff was induced to actas follows:as stated inFR-6. Because of plaintiff's reliance upon defendant's conduct, plaintiff has been damagedAttachment FR- 6as follows:FIR - 7. Other:Promise Without Intent to Perform a. Defendant made a promise about a material matter without any intention of performing itCAUSE OF ACTION fraud PLD-C-001(3)Page 2 of 2 PLD-C-001(3) [Rev. January 1, 2007]
