[COURT NAME]
[COUNTY], [STATE]
[PLAINTIFF NAME], )
Plaintiff, )
) Case No. [CASE NUMBER]
v. )
)
[DEFENDANT NAME], )
Defendant. )
COMPLAINT FOR FRAUD
1. Parties
1.1 Plaintiff [PLAINTIFF NAME] is a [PERSON/ENTITY] located at [ADDRESS].
1.2 Defendant [DEFENDANT NAME] is a [PERSON/ENTITY] located at [ADDRESS].
2. Jurisdiction and Venue
2.1 This Court has jurisdiction under [STATUTE].
2.2 Venue is proper in [COUNTY] because the fraudulent conduct occurred here or Defendant resides here.
3. Factual Allegations
3.1 On [DATE], Defendant represented that [MISREPRESENTATION].
3.2 The representation was false when made and Defendant knew it was false or made it with reckless disregard.
3.3 Defendant intended that Plaintiff rely on the representation.
3.4 Plaintiff reasonably relied on the representation and suffered damages.
4. Cause of Action - Fraudulent Misrepresentation
4.1 Plaintiff realleges the foregoing paragraphs.
4.2 Defendant made a material misrepresentation of fact, with knowledge of falsity, intending reliance, and Plaintiff justifiably relied to its detriment.
5. Cause of Action - Fraudulent Concealment (Optional)
5.1 Defendant concealed or suppressed material facts that Defendant had a duty to disclose.
6. Cause of Action - Negligent Misrepresentation (Optional)
6.1 Defendant made false statements without reasonable grounds for believing them to be true.
7. Damages
7.1 Plaintiff seeks compensatory damages, consequential damages, and, where permitted, punitive damages.
8. Prayer for Relief
Plaintiff requests judgment against Defendant as follows:
a. Compensatory damages in an amount to be proven at trial.
b. Consequential and punitive damages as allowed by law.
c. Pre-judgment and post-judgment interest.
d. Costs and any other relief the Court deems just.
9. Jury Demand
Plaintiff demands a trial by jury on all issues so triable.
10. Signature Block
text
Dated: [DATE]
______________________________
[ATTORNEY NAME]
[LAW FIRM]
[ADDRESS]
[PHONE]
[EMAIL]
Attorney for Plaintiff