Legal Court Complaint

LEGAL COURT COMPLAINT

IN THE COURT OF COUNTY,

Case No.:     Judge:

Plaintiff: (hereinafter "Plaintiff") alleges as follows against Defendant: (hereinafter "Defendant").

RECITALS

WHEREAS, Plaintiff resides at and is the party asserting the claims set forth herein;

WHEREAS, Defendant maintains a principal place of business or residence at and engaged in the acts giving rise to this Complaint within this jurisdiction;

WHEREAS, the acts and omissions of Defendant described below have caused Plaintiff to suffer damages for which Plaintiff seeks relief by this action.

NOW, THEREFORE, Plaintiff brings this Complaint and alleges as follows.

1. JURISDICTION AND VENUE

1.1 This Court has subject-matter jurisdiction under the applicable statutes and common law because the matter in controversy exceeds the jurisdictional minimum of this Court and because the events giving rise to this action occurred within this county. Basis for jurisdiction:

1.2 Venue is proper in this Court pursuant to the venue statutes and rules because Defendant resides or transacts business in this county and the acts complained of occurred here.

2. PARTIES

2.1 Plaintiff is: with the address set forth above.

2.2 Defendant is: and may be served at the address set forth above or at such other place as may be discovered through service of process.

3. STATEMENT OF FACTS

3.1 On or about , Defendant engaged in the following conduct:

3.2 As a direct and proximate result of Defendant's actions and omissions described above, Plaintiff suffered the damages described below.

4. CAUSES OF ACTION

Count I — Breach of Contract:

4.1 Plaintiff and Defendant entered into a valid and enforceable agreement evidenced by the following terms: .

4.2 Defendant materially breached the agreement by:

4.3 As a direct result of the breach, Plaintiff has incurred damages in the amount of: $, and such other relief as the Court deems just and proper.

Count II — Negligence:

4.4 Defendant owed Plaintiff a duty of care and breached that duty by the acts described in Section 3. The breach was a proximate cause of Plaintiff's harms, including but not limited to:

5. DAMAGES

5.1 Plaintiff seeks recovery of compensatory damages, including economic and non-economic losses, as follows:

5.2 Plaintiff further seeks interest, costs of suit, reasonable attorneys' fees where authorized by contract or statute, and any other relief the Court deems appropriate.

6. JURY DEMAND

Plaintiff hereby demands a trial by jury on all issues so triable. Demand jury trial

7. NOTICES

8. SERVICE OF PROCESS

Service of process should be made upon Defendant at the address listed above or at such other location as Defendant may be found. Process may be served by any person authorized under the applicable rules of civil procedure.

9. GOVERNING LAW; MISCELLANEOUS PROVISIONS

9.1 Governing Law. This Complaint and any judgment or order entered hereunder shall be governed by and construed in accordance with the laws of the State of , without regard to conflict of law principles.

9.2 Entire Agreement. To the extent this Complaint refers to agreements between the parties, such agreements (including any written exhibits cited herein) constitute the entire understanding between the parties with respect to the subject matter specified and supersede all prior negotiations and agreements.

9.3 Severability. If any provision of this Complaint is determined to be invalid or unenforceable by a court of competent jurisdiction, the remaining provisions shall remain in full force and effect.

9.4 Amendments and Waiver. No amendment, waiver or modification of any provision of this Complaint shall be effective unless made in writing and signed by the party to be charged.

10. PRAYER FOR RELIEF

WHEREFORE, Plaintiff requests that the Court enter judgment in Plaintiff's favor and against Defendant as follows:

Plaintiff further requests such other and further relief as the Court deems just and proper.

VERIFICATION

Under penalty of perjury under the laws of the State of , I declare that I am the Plaintiff (or am authorized to act on behalf of Plaintiff), I have read the foregoing Complaint and the factual allegations contained therein are true and correct to the best of my knowledge, information and belief.

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