1 Any Attorney or Party

Any Street
2 Any Town, CA 55555

3 714-555-5555

4 Any Attorney or Party

8 Superior Court of the State of California

9 For the County of _________________

10

11 Any Plaintiff, ) Case No.

)
12 Plaintiff, )
) UNLIMITED CIVIL, DEMAND OVER $25,000.00
13 vs. )
) COMPLAINT FOR:
14 Any Defendant; and DOES 1 through 100, )
inclusive, ) 1. BREACH OF CONTRACT
15 ) 2. BREACH OF COVENANT OF GOOD FAITH
) AND FAIR DEALING
16 Defendants. ) 3. NEGLIGENCE
) 4. DECLARATORY RELIEF
17 _________________________________________ )

18

19
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27 COMES NOW, Plaintiff, ____________________________,_ and alleges as follows:
28
INTRODUCTION
- 1 -
COMPLAINT FOR BREACH OF CONTRACT, BREACH OF COVENANT OF GOOD FAITH AND FAIR
DEALING, NEGLIGENCE, DECLARATORY RELIEF
 1 1. Plaintiff ______________ (Plaintiff) at all times herein mentioned was, and is, an
2 individual residing in the City of ________, State of California.
3
2. Plaintiff is informed and believes, and on that basis alleges, that defendant,
4
_______________(__________) at all times herein relevant was, and now is, a corporation duly
5

6
organized and existing under the laws of the State of California, licensed to do business and actually

7 doing business as an insurer and issuing insurance Policies in the state of California, with its principal

8 place of business in the City of _________, County of __________, State of California.

9
3. Plaintiff is informed and believes, and on that basis alleges, that defendant,
10
____________ (________) at all times herein relevant was, and now is, a corporation duly
11
organized and existing under the laws of the State of California, licensed to do business and actually
12

13 doing business as an insurance agent for insurance Policies issued in the state of California, with its

14 principal place of business in the City of _______, County of __________, State of California.
15
4. This Court is the proper Court for the trial of this action because the Property
16
owned by Plaintiff is, and at all relevant times mentioned herein was, located at
17
_________________________, (Property).
18

19 5. The true names and/or capacities, whether individual, corporate, associate or

20 otherwise, of defendants named herein as DOES 1 through 100, inclusive, are unknown to Plaintiff
21
at this time, who therefore sues said defendants by such fictitious names. Plaintiff is informed and
22
believes and therefore alleges that each of the defendants designated herein by fictitious name is in
23
some manner responsible for the events and happenings herein referred to, and caused damages
24

25 proximately and foreseeably thereby to Plaintiff as hereinafter alleged. Plaintiff asks leave of the

26 Court to amend this Complaint when the true names and capacities have been ascertained.
27
6. That at all times herein mentioned, each and every defendant herein was the agent,
28

- 2 -
COMPLAINT FOR BREACH OF CONTRACT, BREACH OF COVENANT OF GOOD FAITH AND FAIR
DEALING, NEGLIGENCE, DECLARATORY RELIEF
 1 servant, employee, partner and/or joint venturer of the other defendants herein; that at all said times,
2 each of said defendants was acting within the course and scope of said agency, service, employment,
3
partnership and joint venture.
4
GENERAL ALLEGATIONS
5

6
7. Plaintiff repeats and realleges the allegations of paragraphs 1 through 6 of this

7 complaint as though set forth in full herein.

8 8. From ____________to the present, in return for substantial premiums, ____________

9
through their agent ____________ located in ____________, California sold plaintiff annual liability
10
insurance Policies (the Policies) which provided insurance coverage for, among other things, personal
11
injury as defined in the Policies. Said definitions include the following:
12

13 "Personal injury" means injury, other than "bodily injury," arising out of one or more of the

14 following offenses:
15
d. oral or written publication of material that slanders or libels a person or organization
16
or disparages a person's or organization's goods, products or services; or
17
e. oral or written publication of materials that violates a person's right of privacy."
18

19 Attached hereto as Exhibit "A" and incorporated herein are copies of the Policies from

20 ____________through ____________.
21
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against-insurance-company-for-bad-faith-in-california
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- 3 -
COMPLAINT FOR BREACH OF CONTRACT, BREACH OF COVENANT OF GOOD FAITH AND FAIR
DEALING, NEGLIGENCE, DECLARATORY RELIEF