Bill of Particulars language question...

[cdbourbon]

Have been poring over the site for several days, yet can't seem to find the answer to this.

Am being sued for Breach of Contract and Common Counts in California. Currently preparing  a demand for BoP using this sample found in another thread. It was noted that the following text areas are intended to be edited as fitting: [goods sold and delivered] [money had and received] [money lent or paid] [quantum meruit].

My question: is retaining only "goods sold and delivered" sufficient for my the demand ("setting forth all items and details of the account on which the cause of action for goods sold and delivered of plaintiff’s complaint is based")?

Or should it be: "goods sold and delivered, money had and received, and money lent or paid..."

I know it's a pedantic question, but I don't want to make a rookie mistake that might blow back on me later.

Thank you.

[Rookie]

Here is what I put in mine:

To plaintiff,  XXXI, LLC and XXX., plaintiff’s attorney of record:

 

 

DEMAND IS HEREBY MADE UPON YOU pursuant to Code of Civil Procedure § 454 
to furnish to defendant, (your name), within ten (10) days hereafter, a bill of particulars 
setting forth the items and details of the account on which the cause of action for all goods sold and delivered of plaintiff's complaint is based, including:

 

1.     The original signed credit card agreement

2.     The balance on the account from zero to the present and include:

·       the date of each item or transaction;

·       a description of the services, materials or goods supplied or other considerations rendered;

    the price or charge made for each such item or transaction

[cdbourbon]

Thank you.