Sample California Complaint Against Landlord

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This sample California complaint against a landlord has eleven causes of action for breach of contract, breach of covenant of good faith and fair dealing, breach of covenant of quiet enjoyment of premises, trespass, nuisance, intentional infliction of emotional distress, negligent infliction of emotional distress, negligence, wrongful eviction due to violations of Civil Code section 789.3, constructive eviction due to intolerable living conditions and damages for uncured building violations under Civil Code section 1942.4.  The complaint requests exemplary and punitive damages on the trespass, intentional infliction of emotional distress and wrongful eviction causes of action and attorney's fees on the wrongful eviction cause of action pursuant to Civil Code section 789.3(d) and uncured building violations under Civil Code section 1942.4(b)(2). The sample has been revised and updated as of  February 4, 2017, is 16 pages, can be modified for most situations and includes brief instructions.

The author is a freelance paralegal who has worked in California and Federal litigation since 1995.  Note that the author is NOT an attorney and no guarantee or warranty is provided.