Fill and Sign the Complaint for on Open Account for Goods Sold and Delivered with Stipulation for Attorneys Fees Breach of Oral or Implied Form

IN THE _______________ COURT OF __________________ (County), ____________________ (State) ______________________________ PLAINTIFF (Name of Plaintiff) V. CAUSE NO. _______,________ _____________________________ DEFENDANT (Name of Defendant) COMPLAINT COMES NOW _____________________________ (Name of Plaintiff) , Plaintiff in the above-styled and numbered cause, by and through his attorneys, and files this his Complaint against Defendant , ________________________________ (Name of Defendant) , and in support thereof would show unto the Court the following matters and facts: 1. Plaintiff is an adult resident citizen of ________________________________________ (city, county, state) . 2. Defendant is an adult resident citizen of ______________________________________ (city, county, state) . 3. Defendant owes Plaintiff $_____________ for goods sold and delivered by Plaintiff to Defendant at _________________________________________________________________ ( street address, city, county, state, zip code) between _____________________ (date) and _______________________ (date) . 4. Notwithstanding demand made for payment, Defendant has failed, neglected, and refused to pay the above-specified sum or any part of such sum. 5. At the time the goods were sold and delivered to Defendant by Plaintiff , Defendant agreed in writing to pay all costs, including reasonable attorney's fees incurred by Plaintiff for referral of the account to an attorney for collection, if such referral became necessary. A copy of this writing, marked Exhibit A , is attached and incorporated by reference. Plaintiff has incurred attorney's fees in the amount of ____________ Dollars ($____________) for referral of the account, which fees are reasonable. THEREFORE, Plaintiff requests judgment against Defendant for: 1. The sum of ____________ Dollars ($____________) principal with legal interest from _______________________ (date) . 2. Attorney fees in the amount of ____________ Dollars ($____________); 3. Costs of suit; and 4. Such other and further relief as the court deems just and proper. Respectfully submitted, ________________________________ (Name of Plaintiff) By: _______________________________ (Name of Plaintiff’s Attorney) State Bar No. _____________ One of His Attorneys OF COUNSEL: __________________________ Post Office Box ________-________ City, State, Zip Code Telephone: ______-______-________