The cause of action attachments to a California complaint

PLD-PI-001 is a shell. The allegation that makes it a legal claim sits on one of these six attachments, and the complaint form says so at item 10: each complaint must have one or more causes of action attached. This page explains what each attachment asks for. It does not tell you what to write, and it is not legal advice.

All six carry the same instruction — use a separate cause of action form for each cause of action — and all six are optional-use forms under the same authority, each revised January 1, 2007.

Motor Vehicle — PLD-PI-001(1)

The item numbering runs MV-1 and MV-2. MV-1 names the plaintiff and asks for the date and the place. MV-2 is the part that does the work: it splits the defendants into separate groups, each with its own name lines and Doe ranges.

• The defendants who operated a motor vehicle.
• The defendants who employed persons who operated a motor vehicle in the course of their employment.
• The defendants who owned the motor vehicle that was operated with their permission.
• The defendants who entrusted the motor vehicle.
• The defendants who were the agents and employees of the other defendants and acted within the scope of the agency.
• A final block for defendants liable for other reasons, listed in an attachment.

Those categories are the reason this form exists rather than the general negligence one. In a vehicle case the driver is often not the only party who can be responsible, and the form is built to record that. How fault is decided · who is liable in a truck case.

General Negligence — PLD-PI-001(2)

The shortest of the six. Item GN-1 names the plaintiff, names the defendant and the Doe range, and alleges that the defendant negligently caused the damage to the plaintiff on a date and at a place — then gives one open block headed "description of reasons for liability". That block is the whole allegation. It is used where no more specific attachment fits.

Intentional Tort — PLD-PI-001(3)

Structurally identical to general negligence, with the word "negligently" removed: the defendant caused the damage, on a date, at a place, with an open block for the reasons for liability. The distinction matters more than the form's length suggests, because a deliberate act and a careless one are treated very differently — by the law, and by insurance policies, which routinely exclude intentional acts.

Products Liability — PLD-PI-001(5)

The most structured of the six. Items Prod. L-1 to L-3 identify the product and the injury, and record that the product was defective when it left each defendant's control, that it was being used in a reasonably foreseeable manner, that the danger was not readily apparent, and that adequate warnings were not given. There are boxes recording whether the plaintiff was a user, a bystander or a purchaser.

Then three counts, each with its own list of defendants:

• Count One — Strict liability, against those who manufactured or assembled the product, those who designed and manufactured component parts supplied to the manufacturer, and those who sold the product to the public.
• Count Two — Negligence, against defendants who owed a duty to the plaintiff.
• Count Three — Breach of warranty, separated into an express warranty, which may be written or oral, and an implied warranty.

Premises Liability — PLD-PI-001(4)

Item Prem.L-1 asks for the date and a description of the premises and the circumstances of the injury. Then three counts, because three different regimes can govern the same fall.

• Count One — Negligence, against the defendants who negligently owned, maintained, managed and operated the premises. This is the ordinary case. Premises liability claims.
• Count Two — Willful Failure to Warn, which the form ties to Civil Code section 846. On land used recreationally an owner generally owes no duty of care to keep the premises safe. The form's boxes track the exceptions: whether the plaintiff was a recreational user, an invited guest, or a paying guest.
• Count Three — Dangerous Condition of Public Property, against public entities that owned property on which a dangerous condition existed. It records that the entity had actual or constructive notice in sufficient time before the injury to have corrected it, or alternatively that the condition was created by its own employees. Claims against a government entity.

A fourth item, Prem.L-5, carries the agency and employment allegations against other defendants, in the same shape as the motor vehicle form.

Exemplary Damages — PLD-PI-001(6)

Not a cause of action but an add-on. Item EX-1 alleges that the defendant was guilty of malice, oppression or fraud as those terms are defined in Civil Code section 3294, and that the plaintiff should recover damages to make an example of and to punish the defendant, in addition to actual damages. EX-2 is an open block for the facts supporting the claim.

EX-3 is the interesting one. It offers two boxes: that the amount of exemplary damages sought is not shown, pursuant to Code of Civil Procedure section 425.10 — or an amount. In a personal injury case the first box is the one the statute contemplates, because that section says the amount demanded is not stated.

Common questions

Can one complaint use more than one attachment?

Yes, and it is common. Each form carries the instruction "use a separate cause of action form for each cause of action", and item 10 of the complaint has a box for each. A crash on business premises can be both a motor vehicle and a premises liability claim.

What is the difference between the motor vehicle and general negligence forms?

The motor vehicle form breaks the defendants into groups — who drove, who owned, who entrusted the vehicle to the driver, and who is liable through an agency or employment relationship. The general negligence form is a single open block. The motor vehicle form exists because vehicle cases routinely have more than one responsible party.

Why does the premises liability form have three counts?

Because three different legal regimes can apply to the same fall. Ordinary negligence covers most private property. A separate count covers recreational land, where the owner generally owes no duty unless the failure to warn was willful or the entrant paid or was expressly invited. A third covers public property, which has its own notice requirements.

Sources: forms PLD-PI-001(1) through PLD-PI-001(6), Judicial Council of California, each approved for optional use and revised January 1, 2007, authority Code Civ. Proc., § 425.12 — item text read from the published forms, retrieved 1 September 2026. Civ. Code, § 846 (no duty of care to a recreational user, and the willful-failure-to-warn, consideration and express-invitation exceptions; amended Stats. 2018, ch. 92, § 33); Civ. Code, § 3294 (malice, oppression, fraud); Code Civ. Proc., § 425.10 (amount demanded not stated).