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PLAINTIFF’S ORIGINAL COMPLAINT – 1
Pranav Jidt
Attorneys’ Business Address
City, ST ZIP Code
Phone | Fax
Email
Plaintiff in pro per
IN THE COURT OF COMMON PLEAS
IN AND FOR THE COUNTY OF CUYAHOGA
PRANAV JIDT,
Plaintiff,
vs.
LUIS CASTELLANO,
Defendant
Case No.: Number
PLAINTIFF’S ORIGINAL COMPLAINT
NOW COMES Pranav Jidt, Plaintiff, and files this Complaint against Luis Castellano,
Defendant, and for cause would show this Honorable Court as follows:
A. PARTIES
1. Plaintiff Pranav Jidt is a law-abiding male adult citizen of sound mind and a resident of
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PLAINTIFF’S ORIGINAL COMPLAINT – 2
[Insert Address].
2. Defendant Luis Castellano is a male adult citizen of sound mind whose known address to
Plaintiff is 25687 Byron Drive, North Olmstead, OH 44070.
B. JURISDICTION AND VENUE
3. Jurisdiction exists in this Court pursuant to Article IV, § 4 of the Ohio Constitution.
4. Venue is proper in this Court because the causes of action took place in Cuyahoga
County.
C. STATEMENT OF FACTS
5. On or around January 2022, Plaintiff hired Defendant to conduct renovations at his
house.
6. Defendant began renovations in Plaintiff’s house on February 11, 2022.
7. Plaintiff paid Defendant $40,500 for him to do the work.
8. Defendant was supposed to complete renovations by April 30, 2022.
9. However, Defendant did not conduct the renovations as agreed. He did the work halfway
in some areas and did not work at all in others. The particulars are as follows:
a. Paint baseboards (upstairs) – 50% complete
b. Replace shoe molding (upstairs) – 0% complete
c. Resurface kitchen cabinets – poorly done. Plaintiff had to hire another painter to
properly do the work for $1,500.
d. Sand and re stain kitchen and living room floor – 80% complete. Plaintiff had to buy
a new floor.
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PLAINTIFF’S ORIGINAL COMPLAINT – 3
e. Re grout tiles in the foyer area – 20% complete. Defendant charged Plaintiff an extra
$1,000 when the cost had already been included.
f. Replace chandelier in the foyer area – Plaintiff did most of the work himself despite
paying extra.
g. Replace transition strip from tiles and kitchen to carpet – 40% complete
h. Sand and re stain half bath – the plumbing job was poorly done. It led to water
damage in Plaintiff’s bathroom.
i. Sand and re stain railings on the stairs and upstairs – work was poorly done. Plaintiff
had to hire another painter to do it properly for $250.
j. Paint 2 accent walls downstairs – 0% complete
k. Change 2 nd floor toilet/bathroom floor – toilet does not work
l. Change showerhead and accessories in the upstairs bathroom – all accessories failed
and had to be repaired by another plumber.
m. Drywall sides and ceiling – defendant hired another person to do the work but failed
to pay him. The other contractor calls Plaintiff every day asking for payment.
n. Install soundproof insulation ceiling – Defendant charged Plaintiff $500 to install
insulation in the whole basement but installed only a few from 42 bags.
o. Build bathroom downstairs – 0% complete
p. Install barn door downstairs – 0% complete
q. Build bar (floating shelves) – 0% complete. Defendant wanted Plaintiff to pay an
extra $4,000 when it was already included.
r. Install recessed lighting – 0% complete
s. Install speaker wires – work was poorly done. Plaintiff had to pay someone else to do
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PLAINTIFF’S ORIGINAL COMPLAINT – 4
the work properly.
t. Install carpet – 0% complete. Defendant wanted Plaintiff to pay an extra $5,000 when
it was already included.
u. Install laminate floors close by the bar area – 0% complete. Defendant wanted
Plaintiff to pay an extra $1,000 when it was already included.
v. Install pool table drop lights – Defendant wanted Plaintiff to pay an extra $400 when
it was already included.
w. Install drop lights on the bar counter top – Plaintiff had to pay the electrician more.
10. As a result of the poor work done by Defendant, Plaintiff’s sinks and bathrooms were
leaking water and his basement was not finished. Plaintiff had to move in to a house with
no kitchen or working bathroom for 2 weeks. He also had to pay extra money to dispose
the trash that Defendant was supposed to dispose. Defendant was supposed to paint the
entire house in two coats, but he did it only once.
11. Due to the poor work done, Plaintiff had to hire other people to redo it.
12. The total cost that was incurred by Plaintiff is $____________.
D. CAUSES OF ACTION
Negligence
13. Plaintiff hereby incorporates the facts in paragraphs 1-12 of this Complaint as though set
out in full herein.
14. “As to the elements of a cause of action in negligence it can be said that it is rudimentary
that in order to establish actionable negligence, one must show the existence of a duty, a
breach of the duty, and an injury resulting proximately therefrom.” Jeffers v. Olexo, 43
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PLAINTIFF’S ORIGINAL COMPLAINT – 5
Ohio St. 3d 140 (1989), citing Di Gildo v. Caponi (1969) 18 Ohio St. 2d 125 [47 O.O. 2d
282.
15. Defendant owed Plaintiff a duty to perform renovations at Plaintiff’s house in a
workmanlike manner. Defendant breached this duty when he did the work poorly and
completely failed to do the work in some areas as detailed in paragraph 9 of this
Complaint.
16. Plaintiff tried to get Defendant to do the work properly to no avail. Defendant totally
abandoned the project despite being paid in full.
17. As a result of Defendant’s actions and/or omissions, the house was left inhabitable as
Plaintiff could not access any kitchen or bathroom for two weeks.
18. Plaintiff had to hire other people to properly do the work and pay them despite the fact
that he had already paid Defendant to do the renovations.
19. Defendant is liable for negligence and ought to pay damages to Plaintiff.
Breach of Contract
20. Plaintiff hereby incorporates the facts and cause of action in paragraphs 1-19 of this
Complaint as though set out in full herein.
21. “Generally, a plaintiff must present evidence on several elements to successfully
prosecute a breach of contract claim. Those elements include the existence of a contract,
performance by the plaintiff, breach by the defendant, and damage or loss to the
plaintiff.” Doner v. Snapp, 98 Ohio App. 3d 597 (1994), citing Am. Sales, Inc. v. Boffo
(1991) 71 Ohio App. 3d 168, 175, 593 NE 2d. 316, 321.
22. Plaintiff and Defendant entered into an agreement in which they agreed that Defendant
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PLAINTIFF’S ORIGINAL COMPLAINT – 6
would conduct renovations in Plaintiff’s house by April 30, 2022.
23. Plaintiff fulfilled his contractual obligations by paying Defendant as agreed and ensuring
that Defendant had access to his house.
24. However, Defendant did not complete his contractual obligations. He did poor work and
entirely nothing in some areas of the house. Plaintiff tried to convince Defendant to
complete renovations properly as agreed but Defendant failed to do so. As at April 30,
2022, Defendant had only completed about 40% of the renovations.
25. As a result of Defendant’s failure to fully complete renovations, Plaintiff had to hire other
people to do the same work he had hired Defendant to do. Plaintiff spent an extra
$_________ to pay them.
26. Defendant is liable for breach of contract and ought to pay damages to Plaintiff.
E. PRAYER FOR RELIEF
REASONS WHEREFORE, PREMISES CONSIDERED, Plaintiff respectfully requests this
Honorable Court to grant him the following reliefs:
i. GRANT judgment in favor of Plaintiff and against Defendant;
ii. AWARD Plaintiff damages for negligence and breach of contract in the sum of
$___________;
iii. AWARD Plaintiff punitive damages;
iv. AWARD Plaintiff costs of this suit;
v. AWARD Plaintiff pre- and post-judgment interests;
vi. GRANT Plaintiff such equitable relief as this Court deems fair; and
vii. GRANT Plaintiff such further relief as this Court deems proper in the circumstances.
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PLAINTIFF’S ORIGINAL COMPLAINT – 7
Dated this ____ day of July, 2022.
Respectfully Submitted,
___________________________________
Pranav Jidt,
Plaintiff in pro per
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PLAINTIFF’S ORIGINAL COMPLAINT – 8
VERIFICATION
I, Pranav Jidt, do hereby swear under penalty of perjury that I have read the foregoing
Complaint, that its contents are true except those matters stated upon information and belief,
which I believe to be true.
Dated this ____ day of July, 2022.
Respectfully Submitted,
___________________________________
Pranav Jidt,
Plaintiff in pro per
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