Fill and Sign the Lexis Nexis Data over 500 Pages of Outline and Actions Form

1 [INSERT CAPTION AND STYLE] 2 COMPLAINT (BREACH OF CONTRACT) 3 PARTIES 4 5 6 7 1. The Plaintiff, [insert name of plaintiff] at all times relevant hereto, is an adult citizen of the State of [insert state jurisdiction] and resides in [insert county name]. 2. The Defendant, [insert name of defendant] at all times relevant hereto, is: 8 9 (INSERT 1 OR MORE OF THE FOLLOWING) (1) a corporation incorporated under the laws of the State of [insert state of 10 incorporation] and is [or is not] authorized to do business as a foreign corporation 11 in this State, and is subject to service of process by and through its registered 12 agent: [insert name and address of registered agent]; 13 14 (2) an adult citizen of the State of [insert defendant’s state of residency] who resides 15 at [inserts defendant’s street address, city and zip code] and is subject to service 16 of process. 17 FACTS 18 3. On or about [insert date] the Plaintiff and Defendant entered into a written 19 20 contract, a copy of which is attached hereto, made a part hereof, and is marked as Exhibit A 21 (hereinafter referred to as the Contract) [or, if a copy of the contract is not attached, state the 22 reasons why it is not attached]. Said contract provides that the laws of the State of [insert state 23 of jurisdiction] shall govern the Contract. 24 4. Pursuant to the Contract, the Plaintiff agreed to: [insert a description of 25 the plaintiff’s duties and obligations under the contract], and the Defendant agreed to: [insert a 26 description of defendant’s duties and obligation under the contract]. 27 28 -1- 1 2 5. On or about [insert date] the Defendant breached the Contract by: [insert facts giving rise to defendant’s breach of the contract, e.g., failure to perform duty or obligation]. 3 6. On or about [insert date] Plaintiff gave notice of breach of contract and demand 4 for performance to the Defendant. Thereafter, Defendant: [insert facts averring a tort claim 5 6 independent from the breach of contract, e.g., conduct constituting malice, gross negligence or 7 reckless disregard for the rights of others]. 8 9 7. Plaintiff has performed all conditions precedent to recovery and has not excused defendant’s non-performance or breach of the Contract. 10 CLAIMS 11 COUNT I: 12 8. The Defendant’s breach of the Contract delineated hereinabove proximately 13 14 caused Plaintiff to suffer: [insert amount of contract damages]. COUNT II: 15 16 17 18 9. The conduct of Defendant complained of hereinabove constitutes: [insert theory of liability, e.g., gross negligence, reckless disregard for safety of others, etc.] for which the Defendant should be punished and deterred from similar conduct in the future. The conduct 19 of the Defendant complained of herein was: [insert nature of conduct, e.g., malicious, 20 21 outrageous, intentional, egregious, willful, wanton, reckless, etc.] DEMAND FOR RELIEF: 22 23 WHEREFORE, the Plaintiffs pray for the following relief: 24 1. Trial by jury; 25 2. Judgment for Plaintiff(s) and against the Defendant(s); 3. An award of damages in an amount which will fully and fairly compensate 26 27 Plaintiff for [insert types of damages from claims section above]. 28 -2- 1 4. 2 An award of punitive damages in amount which is reasonably and rationally related to the egregiousness of Defendant’s conduct, and which is reasonably and 3 rationally related to the financial net worth of the Defendant, and which is in the 4 public interest; 5 6 5. allowed by statute); 7 8 Reasonable attorney fees, costs and expenses (if provided for in the Contract or 6. Such other and further relief as may be deemed just and proper in the premises. 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -3-