PLD-C-001(3) SHORT TITLE: CASE NUMBER: 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): FR-2. defrauded plaintiff as follows: 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. Page Page 1 of 2 Form Approved for Optional Use Judicial Council of California PLD-C-001(3) [Rev. January 1, 2007] CAUSE OF ACTION--Fraud Code of Civil Procedure, § 425.12 www.courtinfo.ca.gov American LegalNet, Inc. www.FormsWorkflow.com PLD-C-001(3) SHORT TITLE: CASE NUMBER: CAUSE OF ACTION--Fraud (number) FR-4. Promise Without Intent to Perform a. Defendant made a promise about a material matter without any intention of performing it in Attachment FR-4.a as follows: as stated 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 follows: as stated in Attachment FR-5 FR-6. Because of plaintiff's reliance upon defendant's conduct, plaintiff has been damaged Attachment FR- 6 as follows: as stated in FIR - 7. Other: Page PLD-C-001(3) [Rev. January 1, 2007 CAUSE OF ACTION--Fraud Page 2 of 2