IN THE ____________ COURT OF ___________ COUNTY
IN AND FOR THE STATE OF ______________

[ENTER NAME],
Plaintiff
vs.
[ENTER NAME],
Defendant

Case No. ______________
Honorable: _____________

COMPLAINT

1. COMES NOW Plaintiff [ENTER NAME], with this complaint against the
Defendant [ENTER NAME], and alleges as follows:
PARTIES

2. Plaintiff, [ENTER NAME], is an individual of address [ENTER ADDRESS].
3. Defendant, [ENTER NAME], is an individual of address [ENTER
ADDRESS].

JURISDICITON AND VENUE

4. This Court has subject matter jurisdiction under __________, on the basis of
__________.
5. Venue is proper in this Court under ___________ as Plaintiff and/or
Defendant is subject to personal jurisdiction in this state. Plaintiff and/or Defendant lives
within the jurisdiction of this Court. Besides, a substantial part of the acts and omissions
forming the basis of these claims occurred in this County and arose from the actions or
inactions of the Defendant.

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FACTS

6. On or about [ENTER DATE], the Plaintiff gave his services to the Defendant,
who is a general contractor.
7. The Plaintiff sent invoices to the Defendant for the work done. Notably, the
Plaintiff sent invoices as follows:

i. First Invoice- [Enter Date sent]
ii. Second Invoice- [Enter Date sent]
8. However, the Defendant has failed to settle the invoices in full.
9. Plaintiff therefore files this complaint to obtain the payment.

CLAIMS FOR RELIEF
COUNT 1
Breach of Contract

10. The preceding paragraphs are fully incorporated herein.
11. The Plaintiff and the Defendant entered into an agreement in which the
Plaintiff would perform services for the Defendant.
12. The Plaintiff duly performed all the services according to the agreement.
13. The Defendant breached the agreement by failing to settle the Plaintiff’s
invoices in full.
14. As a result of the Defendant’s failure to pay the invoices, the Plaintiff lost the
money he is entitled to as a result of the fulfillment of his obligations under the agreement.

CLAIMS FOR RELIEF
COUNT 2

Breach of implied duty of good faith and fair dealing
15. The preceding paragraphs are fully incorporated herein.

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16. First, a contractual relationship existed between Plaintiff and Defendant.
Notably, the parties had entered an agreement in which the Plaintiff would perform services
for the Defendant.
17. Part of the implied duties of the Defendant included the duty to ensure
Plaintiff’s enjoyment of his rights under the agreement.
18. Defendant failed to pay the Plaintiff for his services, as expected under the
agreement.
19. As a result of the Defendant’s failure to pay the invoices, the Plaintiff lost the
money he is entitled to as a result of the fulfillment of his obligations under the agreement.

COUNT 2
Unjust enrichment

20. The preceding paragraphs are fully incorporated herein.
21. The Defendant unjustly enriched himself when he failed to settle the
Plaintiff’s invoice in full, for services Plaintiff had already done in satisfaction of his
contractual obligations.
22. As a result of the Defendant’s failure to pay the invoices, the Plaintiff lost the
money he is entitled to as a result of the fulfillment of his obligations under the agreement.

PRAYER FOR RELIEF

WHEREFORE, the Plaintiff is entitled to damages from the Defendant, and he hereby
prays that judgment be entered in his favor and against the Defendant as follows:
i. The Defendant pays the Plaintiff ALL pending amounts from the Plaintiff’s invoice.
ii. Compensatory damages for the Defendant’s conduct.
iii. Punitive damages to deter the Defendant from committing the conduct in the future.
iv. Interest as provided by law;
v. An award of fees and costs;

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vi. Such other relief as the Court deems just and proper.

Respectfully submitted:

Dated: __________

______________________________
[ENTER NAME]
Pro se

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CERTIFICATE OF MAILING

I, [ENTER NAME], hereby certify that on [ENTER DATE], a copy of the foregoing
Complaint has been sent to the Defendant in the following address:

[ENTER DEFENDANT’S ADDRESS]

______________________________
[ENTER NAME]
Pro se

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