Sample complaint for breach of contract and common counts in California
This sample complaint for breach of contract and common counts for California includes causes of action for open book account, account stated and goods sold and delivered. It was based on a complaint for a video distributor who sold DVD's and other items to a video store who failed to pay. The complaint can be modified for use with other contract actions. The author is a freelance paralegal that has worked in California and Federal litigation since 1995 and has used this sample for many years. Note that the author is NOT an attorney and no guarantee or warranty is provided.