Sample Adversary Complaint for Fraud

Document Sample
Sample Adversary Complaint for Fraud
1 Any Party

Any Street

2 Any Town, CA 55555



3 714-555-5555



4 Plaintiff, In Pro Per



5



6



7



8 UNITED STATES BANKRUPTCY COURT



9 CENTRAL DISTRICT OF CALIFORNIA



10



11 IN RE: ________________, ) Case No.

)

12 Debtors, ) Chapter 7

)

13 Any Plaintiff ) Adv. Proc No.

)

14 Plaintiff, ) COMPLAINT TO DETERMINE NON-

) DISCHARGEABILITY OF DEBT

15 vs. )

) (Hearing date to be set by summons)

16 Any Defendant, )

)

17 Defendant. )

)

18 )

)

19



20 COMPLAINT TO DETERMINE NON-DISCHARGEABILITY OF DEBT

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COMES NOW, _____________________Pro Se (“Plaintiff”), for his complaint

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against the Defendant, ______________ (“Defendant”), and alleges as follows:

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1. This is a core proceeding over which this court has jurisdiction under Title 28

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25 U.S.C. § 157(b).



26 ///

27

///

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- 1 -

COMPLAINT TO DETERMINE NON-DISCHARGEABILITY OF DEBT

1 2. Defendant is the debtor in this chapter 7 case which was filed on __________,



2 the Deadline to file a complaint for determination of dischargeability is _________, so this complaint

3

is timely. Plaintiff is a creditor of defendant by virtue of the following facts:

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a. On or about ___________, Defendant published specific public solicitations

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on the internet, requesting loans for real estate projects that promised large, prompt returns on

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7 investments. Plaintiff inquired into Defendant’s solicitation, wherein Defendant formally offered



8 Plaintiff an investment opportunity in the form of a loan that guaranteed a large, prompt return on his

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principal, plus interest.

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b. On or about _____________, __________ and Plaintiff agreed to specific

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terms of a loan. _________________represented to Plaintiff that in exchange for

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13 _______________________ (__________), he would provide him with a repayment of that amount



14 on or before ____________, plus ______________ ($_____________) i

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