This sample complaint for fraudulent transfer in California includes a cause of action under the Uniform Voidable Transactions Act found in Civil Code section 3439 et seq., and also includes causes of action for common law fraudulent transfer as well as violations of the California bulk sale law. The sample document on which this preview is based is 10 pages and includes brief instructions and a verification. The author is a freelance paralegal that has worked in California and Federal litigation since 1995 and also collected unpaid California judgments for over 20 years and has used this sample for many years.

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Any Attorney or Party
Any Street
Any Town, CA 99999
555-555-5555
Any Attorney or Party
Superior Court of the State of California
For the County of ______________
Any Plaintiff,
Plaintiff,
vs.
Any Defendant, DOES 1 through 100, inclusive,
Defendant.
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Case No.
COMPLAINT FOR:
1. FRAUDULENT TRANSFER UNDER THE
UNIFORM FRAUDULENT TRANSFER ACT
[CIVIL CODE § 3439, et seq.]
2. COMMON LAW FRAUDULENT TRANSFER
3. VIOLATION OF BULK SALE LAW
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COMPLAINT FOR FRAUDULENT TRANSFER

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1COMES NOW the Plaintiff, _______________ , an individual (“Plaintiff”) who alleges as
follows:
1. Plaintiff is now, and at all times mentioned herein was, an individual, residing in
and doing business in the City of _________, County of _____________, State of California.
2. Plaintiff is informed and believes, and on that basis alleges, that Defendants,
____________________________________ are, and at all times mentioned herein were,
__________________________, organized and existing pursuant to the laws of the State of
_______________, and were authorized to, and are, doing business in, the city of ______, County of
_____________, State of California. Thus this Court has jurisdiction to hear this case and venue is
proper.
3. Plaintiff is ignorant of the true names and capacities of Defendants sued herein as
DOES 1 through 100, inclusive, and therefore sues these Defendants by such fictitious names.
Plaintiff will amend this complaint to allege their true names and capacities when ascertained.
Plaintiff is informed and believes, and on that basis alleges, that each of the fictitiously named
defendants claims an interest in the property hereinafter described and which is the subject of this
action, or were responsible in some manner for the damages suffered by Plaintiff.
4. From and after _______, Plaintiff has been the holder of a certain claim
against Defendant _________. This claim consists of all right, title and interest, to the Judgment
entered and filed on _________, in the Superior Court of California, County of
__________________, Case Number ______, in the total sum of $__________, against Defendant
___________. Said Judgment arises from an action filed on or about _________________, in the
afore-mentioned Court. Defendant __________ was duly served in said action on or about
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COMPLAINT FOR FRAUDULENT TRANSFER

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_____________. Said Judgment was entered in favor of Plaintiff against Defendant __________, and
has never been appealed nor been vacated or modified. No part of said Judgment has been satisfied.
To view the sample document on which this preview is based visit:
https://www.scribd.com/doc/117980857/Sample-Complaint-for-
Fraudulent-Transfer-in-California#
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COMPLAINT FOR FRAUDULENT TRANSFER