Venue needs to be alleged in the introductory paragraphs of the complaint.

All the proper legal elements to prove a cause of action must be stated in the complaint.

Each cause of action must be separately stated in the complaint.

A summons and complaint may be served on an individual living in California by mail alone.

Service of a summons and a complaint on a corporation may be made by serving any shareholder of the corporation.

If a complaint contains redundant, immaterial, impertinent, or scandalous matter, the proper response by the defendant is a motion to dismiss.

If a complaint is so vague or ambiguous that the defendant cannot respond to it, the defendant may file a demurrer.

A defendant may raise certain defenses either in the answer or by a demurrer.

As a general rule, the defendant must serve an answer to the complaint within 30 days after service.

An affirmative defense raises matters that are put in issue by the defendant's denial of the allegations in the complaint

A defendant may file a cross-complaint against the plaintiff within the time the defendant has to answer the complaint.

A plaintiff does not need to reply to the defendant's cross-complaint since it will be assumed that the plaintiff denies all allegations of the cross-complaint.

The caption is used to identify the names of the parties, the court in which the case is being filed, and the title of the action.

A defendant may respond to an allegation in the complaint by admitting, denying, or claiming a lack of knowledge, information or belief.

A cross-complaint is compulsory if the claim arises out of the same transaction or occurrence on which the complaint is based.

Failure to file a compulsory cross-complaint will thereafter bar the claim.

A permissive cross-complaint is one that may be, but does not have to be brought in the same action.

A nonparty may want to intervene in an action if their interests are affected by the outcome of the litigation.

The reason why some cross-complaints are compulsory and some against others are always permissive is because the defendants should not be compelled to litigate their claims against other parties in the forum and at the same time chosen by plaintiffs.

Since federal courts are courts of limited jurisdiction the complaint must specifically allege jurisdiction so the court can easily verify that the action is properly being brought in federal court.

Notice pleading is a short plain statement in the claim showing that the pleader is entitled to relief,

In federal and state courts, some allegations such as fraud and mistake must be pleaded with particularity .

Fact pleading requires specific facts to be alleged so that the party knows the basis for the complaint.

Causes of action are not theories of recovery, but are maxims of law.

In federal court, theories of recovery are referred as counts.

Personal service is required for service out of state.

To require personal service on an out of state defendant is very costly and could act as a barrier for plaintiffs to file suit.

Service out of state is permitted by certified mail and return receipt requested.

A plaintiff has three years to serve a summons and complaint upon a defendant (CCP Sec. 583.210 (a)

California is a code pleading state.