__[Attorney name]__
__[Telephone number]__

Attorney for Plaintiff, __[name]__

            _ _ _ _ _ _ Court, County of _ _ _ _ _ _
                   __[_ _ _ _ _ _ District]__

_ _ _ _ _ _ _ _ _ _ _ _ _  )   No. _ _ _ _ _ _
vs.                                                        )COMPLAINT FOR DECLARATORY
                                                                          )RELIEF ON __[STATUTE/
_ _ _ _ _ _ _ _ _ _ _ _ _  )   ORDINANCE]__
_________________________  )

     Plaintiff, __[name]__, alleges:
     1.   Plaintiff is now, and at all times mentioned in this
complaint has been, __[e.g., a corporation duly organized and
existing under the laws of the State of California]__.
     2.   Defendant, __[name]__, is now, and at all times
mentioned in this complaint has been, a governmental entity
organized and existing under
                           [Option 1]
the __[Constitution/laws]__ of the State of California.
                           [Option 2]
an ordinance of the __[e.g., County of _ _ _ _ _ _]__.
Defendant, __[name]__, is __[title]__ and the person charged with
__[describe responsibility for administering statute or
     3.   Plaintiff does not know the true names of defendants
sued as Doe 1 through Doe __[number of fictitiously named
               4.   On or about __[date]__, a __[statute/ordinance]__ 
described as __[specify]__ was enacted by the __[e.g., California
State Legislature/City Council of _ _ _ _ _ _ _ _]__. A copy of
this __[statute/ordinance]__ is attached as Exhibit A and is
incorporated by reference. This __[statute/ordinance]__ is in
full force and effect.
     5.   __[State facts showing that statute or ordinance is
being applied or could be applied to plaintiff and that
application of the statute or ordinance interferes with or
impairs plaintiff's rights and privileges]__.
                      [Add if appropriate]
     6.   __[State facts showing that plaintiff has exhausted all
administrative remedies]__.
     [7.] An actual controversy now exists between plaintiff and
defendants concerning their respective rights and duties.
Plaintiff contends that the __[statute/ordinance]__ is invalid
and unenforceable on its face and as applied to plaintiff in that
__[state facts and contentions regarding statute's or ordinance's
invalidity or unenforceability]__. Defendants dispute plaintiff's
contentions and contend that the __[statute/ordinance]__ is valid
and enforceable and applies to plaintiff.
     [8.] Plaintiff desires a judicial determination and
declaration of plaintiff's and defendants' respective rights and
duties concerning whether plaintiff's activities violate the
__[statute/ordinance]__ and with respect to the validity and
enforceability of the __[statute/ordinance]__ as applied to
plaintiff. Such a declaration is necessary and appropriate at
this time so that plaintiff may ascertain __[his/her/its]__
rights and duties without being subjected to liability for
violation of the __[statute/ordinance]__. __[State any facts
showing harm that may result to plaintiff if declaratory relief
is not obtained]__.
     WHEREFORE, plaintiff demands judgment as follows:
     1.   That the Court declare plaintiff's and defendants'
respective rights and duties under the __[statute/ordinance]__
and declare that the __[statute/ordinance]__ is not valid and
enforceable against plaintiff.
     2.   For costs of this action and all other just relief.

Date: _ _ _ _ _ _                                       [Signature]
                                                                                                                                            __[Typed name]__
                                                                                                                                            __[Title if relevant]__

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Legal Forms : Set Two