Fill and Sign the Contract Interference Form

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 [INSERT CAPTION AND STYLE] COMPLAINT (TORTIOUS INTERFERENCE WITH CONTRACT) PARTIES 1. The Plaintiff(s), [ insert name of plaintiff ] at all times relevant hereto, is/are adult citizens of the State of [ insert state jurisdiction] and reside in [ insert county name ], and are the heirs and wrongful death beneficiaries of the decedent, [ insert decedent’s name ]. 2. The Defendant(s), [ insert names of each defendant ] at all times relevant hereto, is: (INSERT 1 OR MORE OF THE FOLLOWING PARAGRAPHS) (1) a corporation incorporated under the laws of the State of [ insert state of incorporation] and is [or is not ] authorized to do business as a foreign corporation in this State, and is subject to service of process by and through its registered agent: [ insert name and address of registered agent ]; (2) an adult citizen of the State of [ insert defendant’s state of residency ] who resides at [ inserts defendant’s street address, city and zip code ] and is subject to service of process pursuant to the laws of the State of [ e.g., state of filing, or long-arm statute, choice of law provision, statute if diverse jurisdiction ]. FACTS 3. On or about [ insert date ] the Plaintiff and [ insert name of other contracting party] (hereinafter referred to as the 3 rd Party), entered into a written contract, a copy of which is attached hereto, made a part hereof, and is marked as Exhibit A (hereinafter referred to as the Contract) [ or, if a copy of the contract is not attached, state the reasons why it is not attached ]. Said contract provides that the laws of the State of [ insert state of jurisdiction ] shall govern the Contract. - 1 - 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 4. Pursuant to the Contract, the Plaintiff agreed to: [ insert a description of the plaintiff’s duties and obligations under the contract ], and the 3 rd Party agreed to: [ insert a description of defendant’s duties and obligation under the contract ]. 1. On or about [ insert date ] the 3 rd Party breached the Contract by: [ insert facts giving rise to defendant’s breach of the contract , e.g., failure to perform duty or obligation ]. 2. The Defendant interfered with the performance of the Contract by: [ insert description of the Defendant’s acts constituting interference ] causing the 3 rd Party to breach the Contract. 3. Plaintiff has performed all conditions precedent to recovery and has not excused defendant’s non-performance or breach of the Contract. CLAIMS 8. The Defendant’s acts delineated hereinabove were willful and intentional. 9. The Defendant’s acts delineated hereinabove were done with the unlawful purpose of causing damage and loss to the Plaintiff. 10. The Defendant’s acts delineated hereinabove were calculated to cause loss and damage to Plaintiff in his/her lawful business or undertakings. 11. The Defendant’s acts delineated hereinabove proximately caused Plaintiff to suffer: [ insert amount of contract damages or other loss ]. DEMAND FOR RELIEF 10. WHEREFORE, the Plaintiffs pray for the following relief: 1. Trial by jury; 2. Judgment for Plaintiff and against the Defendant; - 2 - 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 3. An award of damages in an amount which will fully and fairly compensate Plaintiff for [ insert types of damages from claims section above ]. 4. Reasonable attorney fees, costs and expenses ( if provided for in the Contract or allowed by statute ); 5. Such other and further relief as may be deemed just and proper in the premises. - 3 -