Answering an alter ego complaint in California

Answering an alter ego complaint in California is the topic of this blog post.

Answering an alter ego complaint in California would be required when a complaint contains alter ego allegations which are known in the legal field as corporate veil piercing allegations because they are used to "pierce the corporate veil" and have a court disregard the corporate entity, which will allow a plaintiff to add an individual person, or persons, or even another corporation as a defendant and seek to hold them responsible for the debts or other liabilities of the main corporation.

Alter ego allegations are generally used against smaller corporations, particularly corporations with few owners. In my personal experience, many creditors will file a complaint with alter ego allegations with little, if any evidence to support the allegations of the complaint in the hopes that this will somehow give them leverage.

You cannot totally avoid the possibility that someone may seek to hold them personally liable for the debts for a corporation which they own or control, particularly in California. But you need to file an answer to any complaint seeking to impose alter ego liability on them, and be sure to claim indemnity from the corporation in the answer, and possibly in a cross-complaint as well, pursuant to California Corporations Code § 317(a)-[c] as most California corporate articles do allow the corporate directors and officers to claim indemnity from the corporation to the fullest extent of the law.

In answering an alter ego complaint in California be sure you include all of the specific information you have in the affirmative defenses as to why the Court should not deviate from the usual legal doctrine of the separation of corporate and individual legal identity and existence, such as you did not personally guarantee any debts to the Plaintiff, etc.

Also be sure to send specially prepared interrogatories and requests for production of documents to the plaintiff asking them to state all facts that support their alter ego allegations, identify all persons with personal knowledge, produce all documents supporting the allegations, etc.

Sample answer to an alter ego complaint in California for sale.

Attorneys or parties in the State of California who wish to view a sample answer to a complaint for alter ego allegations that includes numerous affirmative defenses regarding many of the issues discussed in this blog post sold by the author can see below.

Sample Answer to Alter Ego Complaint for California by Stan Burman on Scribd


The author of this blog post, Stan Burman, is a freelance paralegal that has worked in California and Federal litigation since 1995 and created over 300 sample legal documents for sale.

For licensed attorneys and law firms that need assistance with any California or Federal litigation matters, Mr.  Burman is available on a freelance basis. Mr. Burman may be contacted by e-mail at for more information. He accepts payments through PayPal which means that you can pay using most credit or debit cards.

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Please note that the author of this blog post, Stan Burman is NOT an attorney and as such is unable to provide any specific legal advice. The author is NOT engaged in providing any legal, financial, or other professional services, and any information contained in this blog post is NOT intended to constitute legal advice.

The materials and information contained in this blog post have been prepared by Stan Burman for informational purposes only and are not legal advice. Transmission of the information contained in this blog post is not intended to create, and receipt does not constitute, any business relationship between the author and any readers. Readers should not act upon this information without seeking professional counsel.