Additional Cause of Action – Breach of Fiduciary Duty

VERIFIED COMPLAINT

&BLANK& CAUSE OF ACTION

               (Breach of Fiduciary Duty Against &DependentCounsel& and Does 51-250)

  1. Plaintiff realleges foregoing paragraphs 1 through &Blank& and incorporates them herein by reference.
  2. &DependentCounsel& has a fiduciary relationship with &Client&.
  3. &DependentCounsel& breached fiduciary duties to &Client&.
  4. &DependentCounsel&’s breach of fiduciary duties caused damage to &Client&.
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