SHORT TITLE:

CASE NUMBER:

PLD-C-001(3)

CAUSE OF ACTION—Fraud

(number)

ATTACHMENT TO

Complaint

Cross-Complaint

(Use a separate cause of action form for each cause of action.)

FR- 1. Plaintiff (name):

alleges that defendant (name):

on or about (date):

defrauded plaintiff as follows:

FR-2.

Intentional or Negligent Misrepresentation 
 a. Defendant made representations of material fact

as stated in Attachment FR-2.a

as follows:

b. These representations were in fact false. The truth was

as stated in Attachment FR-2.b

as follows:

c. When defendant made the representations,
defendant knew they were false, or 
defendant had no reasonable ground for believing the representations were true.

d. Defendant  made  the  representations  with  the  intent  to  defraud  and  induce  plaintiff  to  act  as  described
       in item  FIR-5. At  the  time plaintiff  acted,  plaintiff  did  not  know  the representations were false and believed
       they were true. Plaintiff acted in justifiable reliance upon the truth of the representations.

FR-3.

Concealment
a. Defendant concealed or suppressed material facts

as stated in Attachment FR-3.a

as follows:

b. Defendant concealed or suppressed material facts
defendant was bound to disclose.

by telling plaintiff other facts to mislead plaintiff and prevent plaintiff from discovering the concealed 
or suppressed facts.

c. Defendant concealed or suppressed these facts with the intent to defraud and induce plaintiff to act
    as described in item IFIR-5. At the time plaintiff acted, plaintiff was unaware of the concealed or suppressed
    facts and would not have taken the action if plaintiff had known the facts.

Form Approved for Optional Use
Judicial Council of California
PLD-C-001(3) [Rev. January 1, 2007]

CAUSE OF ACTION—Fraud

Page

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Code of Civil Procedure, § 425.12
www.courtinfo.ca.gov

CASE NUMBER:

PLD-C-001(3)

SHORT TITLE:

(number)

CAUSE OF ACTION—Fraud 

FR-4.

Promise Without Intent to Perform 
a.  Defendant made a promise about a material matter without any intention of performing it

as stated

in Attachment FR-4.a

as follows:

b. Defendant's promise without any intention of performance was made with the intent to defraud and induce

plaintiff to rely upon it and to act as described in item FR-5. At the time plaintiff acted, plaintiff was unaware of 
defendant's intention not to perform the promise. Plaintiff acted in justifiable reliance upon the promise.

FR-5.  In justifiable reliance upon defendant's conduct, plaintiff was induced to act

as stated in Attachment FR-5

as follows:

FR-6.  Because of plaintiff's reliance upon defendant's conduct, plaintiff has been damaged

as stated in

Attachment FR- 6

as follows:

FIR - 7.  Other:

PLD-C-001(3) [Rev. January 1, 2007

CAUSE OF ACTION—Fraud 

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