[COURT NAME]
[COUNTY], [STATE]
[PLAINTIFF NAME], )
Plaintiff, )
) Case No. [CASE NUMBER]
v. )
)
[DEFENDANT NAME], )
Defendant. )
COMPLAINT FOR COLLECTIONS
1. Parties
1.1 Plaintiff [PLAINTIFF NAME] is a [BUSINESS ENTITY] with its principal place of business at [ADDRESS].
1.2 Defendant [DEFENDANT NAME] is an individual or entity residing or doing business at [ADDRESS].
2. Jurisdiction and Venue
2.1 This Court has jurisdiction under [STATUTE].
2.2 Venue is proper in [COUNTY] because Defendant resides here or the contract was performed here.
3. Factual Allegations
3.1 Plaintiff extended goods or services to Defendant under [CONTRACT/ACCOUNT], dated [DATE].
3.2 Defendant agreed to pay the amounts due under the contract or account.
3.3 Defendant has failed to pay despite demand.
3.4 The amount due and owing is $[AMOUNT], plus interest and allowable fees.
4. Cause of Action - Breach of Contract
4.1 Plaintiff realleges the foregoing paragraphs.
4.2 A valid contract existed, Plaintiff performed, Defendant breached, and Plaintiff was damaged.
5. Cause of Action - Account Stated (Optional)
5.1 Plaintiff provided statements of account to Defendant.
5.2 Defendant failed to object and an account stated was formed in the amount of $[AMOUNT].
6. Cause of Action - Unjust Enrichment (Optional)
6.1 Defendant received the benefit of goods or services and failed to pay.
7. Damages
7.1 Plaintiff seeks the principal balance of $[AMOUNT], interest at [RATE] per [MONTH/YEAR], and allowable attorney fees and costs.
8. Prayer for Relief
Plaintiff requests judgment against Defendant as follows:
a. Damages in the amount of $[AMOUNT].
b. Pre-judgment and post-judgment interest as allowed by law.
c. Attorney fees and costs if authorized by contract or statute.
d. Such other relief as the Court deems just.
9. Jury Demand
Plaintiff demands a trial by jury if required and if demanded.
10. Signature Block
text
Dated: [DATE]
______________________________
[ATTORNEY NAME]
[LAW FIRM]
[ADDRESS]
[PHONE]
[EMAIL]
Attorney for Plaintiff