Form 3-45

This cause of action may be brought against a spouse, a third party, or both. This material can be incor­porated, if appropriate, as an integral part of the divorce pleading to be inserted as a paragraph preced­ing the prayer. (If the material is incorporated in the respondent’s pleading, it should be reworded to reflect that the respondent, rather than the petitioner, is the complainant.) Additional service is required if a third party is added as a co-respondent.

Civil Conspiracy

1.Civil Conspiracy

Beginning in [date] [Respondent and Co-Respondent[s]/Co-Respondents], [names of two or more persons], entered into a conspiracy to accomplish an unlawful purpose and/or to accomplish a lawful purpose by unlawful means, by: [describe the alleged conspiracy]. There was a meeting of the minds [between/among] [Respondent and Co-Respondent[s]/Co-Respondents] on the object of the course of action. Co-Respondent, [name of co-respondent], may be served with citation at [address, city, state]. [Repeat for other co-respondents as appli­cable.]

2.Damages

This action proximately resulted in damages to Petitioner for which Petitioner now seeks relief. Those damages include [state damages alleged].

3.Exemplary Damages

[Respondent and Co-Respondent[s]/Co-Respondents] acted with malice in engaging in such conduct, thus entitling Petitioner to exemplary damages within the jurisdictional limits of this Court.

4.Prayer

Petitioner prays for judgment against [Respondent and Co-Respondent[s]/Co-Respondents] in a sum within the jurisdictional limits of this Court for [his/her] actual dam­ages as alleged, [include if applicable: for exemplary damages,] for prejudgment and postjudg­ment interest as allowed by law, for costs of court, and for general relief.