submitted by PHIL HOROWITZ

SUPERIOR COURT OF THE STATE OF CALIFORNIA

IN AND FOR THE COUNTY .....................

COMPLAINT FOR DAMAGES ARISING FROM BREACH OF CONTRACT, BAD FAITH, INTENTIONAL MISREPRESENTATION, NEGLIGENT MISREPRESENTATION, INTENTIONAL INTERFERENCE WITH BUSINESS RELATIONS, NEGLIGENCE, DISCRIMINATION, DISCHARGE IN VIOLATION OF PUBLIC POLICY, INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS, FOR ATTORNEYS' FEES AND COSTS AND FOR PUNITIVE DAMAGES

JURY TRIAL DEMANDED

Amount Demanded Exceeds $25,000 (Gov't. Code 72055)

Plaintiff .............. complains against defendants, and each of them, demands a trial by jury of all issues and for causes of action alleges:

FACTS COMMON TO MORE THAN ONE CAUSE OF ACTION

FIRST CAUSE OF ACTION

Breach of Contract

As a first, separate and distinct cause of action, plaintiff complains against defendants CORP and DOES ONE through TWENTY, and each of them, and for a cause of action alleges:

SECOND CAUSE OF ACTION

Bad Faith

As a second, separate and distinct cause of action, plaintiff complains against defendants CORP and DOES ONE through TWENTY, and each of them, and for a cause of action alleges:

THIRD CAUSE OF ACTION

Intentional Misrepresentation By Making

Of Promises Without Intent to Perform

As a third, separate and distinct cause of action, plaintiff complains against defendants CORP, INDIV and DOES TEN through THIRTY, and for a cause of action alleges:

FOURTH CAUSE OF ACTION

Negligent Misrepresentation

As a further, fourth, separate and distinct cause of action, plaintiff complains against defendants CORP, INDIV and DOES FIVE through FIFTEEN and TWENTY FIVE through THIRTY FIVE, and each of them, and for a cause of action alleges:

FIFTH CAUSE OF ACTION

Intentional Interference With Business Relations

As a further fifth, separate and distinct cause of action, plaintiff complains against defendants INDIV and DOES TWENTY through FORTY, and each of them, and for a cause of action alleges:

SIXTH CAUSE OF ACTION

Negligence

As a sixth, separate and distinct cause of action, plaintiff complains against defendants CORP, INDIV and DOES ONE through THIRTY, and each of them, and for a cause of action alleges:

SEVENTH CAUSE OF ACTION

............ Discrimination in Violation of the

California Fair Employment and Housing Act

As a seventh, separate and distinct cause of action, plaintiff complains against defendants CORP, INDIV and DOES ONE through THIRTY, and each of them, and for a cause of action alleges:

EIGHTH CAUSE OF ACTION

Discharge in Violation of

Public Policy

As an eighth, separate and distinct cause of action, plaintiff complains against defendants CORP, INDIV and DOES ONE through THIRTY, and each of them, and for a cause of action alleges:

NINTH CAUSE OF ACTION

Intentional Infliction of

Emotional Distress

As a ninth, separate and distinct cause of action, plaintiff complains against all defendants, and each of them, and for a cause of action alleges:

DAMAGES

PRAYER

Wherefore plaintiff prays for judgment against defendants, and each of them, as follows:

1. For a money judgment representing compensatory damages including lost wages, earnings, retirement benefits and other employee benefits, and all other sums of money, together with interest on these amounts, according to proof;

2. For a money judgment for mental pain and anguish and emotional distress, according to proof;

3. For an award of punitive damages, according to proof;

4. For costs of suit and attorney fees;

5. For prejudgment and postjudgment interest;

6. For any other relief that is just and proper.

7. For attorney fees pursuant to C.C.P. 1021.5 and Gov't. Code 12965(b).

Dated:

LAWLESS, HOROWITZ & LAWLESS

by _________________________________

Phil Horowitz Attorneys for Plaintiff

JURY TRIAL DEMANDED

Plaintiff demands trial of all issues by jury.

Dated:

LAWLESS, HOROWITZ & LAWLESS

by _________________________________

Phil Horowitz Attorneys for Plaintiff