COMPLAINT.

XXXXX

IN THE CIRCUIT COURT FOR THE COUNTY OF XXX

XXXX

Plaintiff,                                                           Case No.

v.

[INSERT DEFENDANTS’ NAMES]

Defendant.

COMPLAINT.

NOW COMES Plaintiff, XXXX, pro se and for his Complaint says unto this

Honorable Court as follows:

  1. Plaintiff files this Complaint seeking redress for the following claims: tortious interference with contractual relations and slander.
  1. The parties involved are Plaintiff’s former friends, herein referred to as the Defendants, who conspired to interfere with a valid contractual agreement and made defamatory statements about the Plaintiff, in violation of his rights under the First Amendment.
  1. JURISDICTION AND VENUE.

 

  1. The subject matter of this Complaint arises under the laws of the United States, specifically the First Amendment of the Constitution which guarantees the right to free speech.
  1. The Court has jurisdiction over this matter pursuant to 28 U.S.C. § 1331, as it involves a federal question. Additionally, this Court has personal jurisdiction over the Defendants as they reside within the Eastern District of Michigan.
  1. That the amount in controversy is in excess of $25,000.00, thus, jurisdiction and venue is proper before this Honorable Court.
  1. PARTIES.
  1. Robert Anderson, hereinafter referred to as the “Plaintiff,” is a resident of [Your City], [Your State].
  2. [Defendant’s Full Name #1] is a resident of [Defendant’s City], [Defendant’s State].
  3. [Defendant’s Full Name #2] is a resident of [Defendant’s City], [Defendant’s State].
  • COMMON FACTUAL ALLEGATIONS.
  1. The Plaintiff had a contractual relationship with [Defendant’s Full Name #1]’s son, [Son’s Full Name], who was hired by the Plaintiff as an employee on [Start Date] and entered into a noncompete agreement on [Date of Noncompete Agreement], which is attached hereto as Exhibit A.
  2. The noncompete agreement specifically prohibited [Son’s Full Name] from engaging in any business that would compete with the Plaintiff for a period of [Duration of Noncompete].
  3. Upon the Defendants’ discovery of the noncompete agreement, they conspired with [Son’s Full Name] to breach the contract by encouraging him to disregard its terms, all while exploiting their friendship with the Plaintiff.
  4. The Defendants deliberately made false and defamatory statements, suggesting that the Plaintiff would not object to [Son’s Full Name] engaging in competing business activities, thereby interfering with the contractual relations between the Plaintiff and [Son’s Full Name].
  5. That as a result of the above, the Plaintiff has suffered damages in an amount in excess of $25,000.00.

COUNT I

TORTIOUS INTERFERENCE WITH CONTRACTUAL RELATIONS.

Plaintiff hereby restates the allegations contained in paragraphs 1 through 14 as if fully

restated herein.

  1. Plaintiff hereby restates the allegations contained in paragraphs 1 through 8 as if fully restated herein.
  2. Tortious interference with contractual relations occurs when a third party intentionally and improperly interferes with the performance of a contractual relationship, causing harm to one of the parties.
  3. Tortious Interference occurs when someone intentionally interferes with someone else’s business. Tortious interference arises when two parties have entered into a contract or an advantageous business relationship, and another party undermines the contract or advantageous business relationship.
  4. In undermining the relationship, another party commits some improper act, usually done intentionally, that:
  1. Causes a breach of the contract or disruption of the business relationship between the Plaintiff and the third party; and
  1. Results in damage to the plaintiff.
  1. For a Plaintiff to prove tortious interference, he or she has to successfully prove the following elements:
  1. A valid contract exists;
  2. The third party (Defendant) was aware of the contract;
  • There was an unjustified and intentional interference by the third party; and
  1. The Plaintiff suffered damages due to the defendant’s actions.
  1. In the present case, the Plaintiff will successfully prove the above-mentioned elements:
  1. A valid contract exists.

 

  1. The Plaintiff and the [INSERT DEFENDANT’S NAME] entered into a noncompete agreement specifically prohibiting [Son’s Full Name] from engaging in any business that would compete with the Plaintiff for a period of [Duration of Noncompete] hence a valid contract exists.
  1. The third party (Defendant) was aware of the contract.

 

  1. The said Defendant having signed the contract was well aware of its existence.
  • There was an unjustified and intentional interference by the third party.

 

  1. In the present case, the [INSERT DEFENDANT’S NAME] intentionally acted wrongfully and with malice when he acted in contravention of the contract between him and the Plaintiff for the following reasons:
  1. The primary purpose of the Defendant’s conduct was to cause the breach of contract; and
  1. The Defendant was substantially certain that this would be the result of their conduct.

 

  1. The Plaintiff suffered damages due to the defendant’s actions.
  1. The Plaintiff suffered harm due to the Defendants’ actions including but not limited to loss of Plaintiff’s competitive advantage, loss of business and goodwill.
  1. The Defendants’ actions constituted tortious interference with contractual relations. They intentionally and unjustifiably interfered with the contractual agreement between the Plaintiff and [Son’s Full Name], causing a breach of contract and resulting in damages to the Plaintiff.

COUNT II

SLANDER.

  1. Plaintiff hereby restates the allegations contained in paragraphs 1 through 19 as if fully restated herein.
  1. Slander refers to the oral communication of false statements that harm an individual’s reputation, causing material or emotional harm.
  1. The Defendants’ defamatory statements about the Plaintiff, suggesting that the Plaintiff would condone a breach of the noncompete agreement, constitute slander. These false statements have damaged the Plaintiff’s reputation and caused emotional distress.
  1. PRAYER FOR RELIEF.

WHEREFORE, Plaintiff, Robert Anderson, hereby prays this Honorable Court enter a Judgment in his favor and against the Defendants, [INSERT NAMES], as follows:

  1. Compensatory damages for the harm caused by the Defendants’ tortious interference with contractual relations and slander.
  1. Punitive damages as deemed appropriate by the Court, to deter such misconduct in the future.
  2. Injunctive relief to prevent the Defendants from further interfering with the contractual relationship between the Plaintiff and [Son’s Full Name].
  3. Attorneys’ fees and costs incurred in pursuing this action, as allowed by law.
  4. Any other relief deemed just and equitable by the Court.

Dated:                                                                                                  Respectfully submitted,

[INSERT YOUR DETAILS]

 

 

 

 

 

 

 

 

 

 

 

 

VERIFICATION.

I declare under penalty of perjury that the foregoing statements are true and correct to the best of my knowledge and belief.

Dated: [Date]

[Your Full Name] [Your Signature]

At Legal writing experts, we would be happy to assist in preparing any legal document you need. We are international lawyers and attorneys with significant experience in legal drafting, Commercial-Corporate practice and consulting. In the last few years, we have successfully undertaken similar assignments for clients from different jurisdictions. If given this opportunity, The LegalPen will be able to prepare the legal document within the shortest time possible. You can send us your quick enquiry ( here )