SUPERIOR COURT OF THE STATE OF CONNECTICUT
JUDICIAL DISTRICT OF [PLACEHOLDER—JUDICIAL DISTRICT] AT [PLACEHOLDER—VENUE]
Docket No.: ___
[PLAINTIFF NAME],
Plaintiff,
v.
[DEFENDANT NAME],
Defendant.
COMPLAINT
[// GUIDANCE: This template is drafted for a breach-of-contract action in the Connecticut Superior Court. It incorporates Practice Book pleading requirements, service mechanics, and discovery-limit references. Replace bracketed placeholders, delete guidance boxes, and conform to local standing orders.]
TABLE OF CONTENTS
- Parties ..................................................................................... ¶¶ 1-2
- Jurisdiction and Venue ................................................... ¶¶ 3-5
- Factual Allegations .......................................................... ¶¶ 6-18
- Count I – Breach of Contract ......................................... ¶¶ 19-25
- Damages ............................................................................. ¶¶ 26-28
- Conditions Precedent ...................................................... ¶ 29
- Jury Demand (Optional) .................................................. ¶ 30
- Prayer for Relief ..................................................................... p. 7
- Certification (Conn. Practice Book § 10-14) ........................ p. 8
- Signature Block ................................................................... p. 8
PARTIES
1. Plaintiff [PLAINTIFF NAME] (“Plaintiff”) is a [corporation/LLC/individual] organized under the laws of [STATE] with its principal place of business at [ADDRESS].
2. Defendant [DEFENDANT NAME] (“Defendant”) is a [corporation/LLC/individual] organized under the laws of [STATE] with its principal place of business at [ADDRESS] and may be served through [REGISTERED AGENT / CONNECTICUT STATE MARSHAL] pursuant to Conn. Gen. Stat. §§ 52-57 & 52-59b.
[// GUIDANCE: For service, complete Judicial Branch Form JD-CV-1 “Summons” and arrange service via a State Marshal. Attach the Marshal’s Return once completed.]
JURISDICTION AND VENUE
3. This Court has subject-matter jurisdiction under Conn. Gen. Stat. § 51-164s because the amount in controversy exceeds $15,000, exclusive of interest and costs.
4. Personal jurisdiction over Defendant exists under Conn. Gen. Stat. § 52-59b(a) because Defendant [transacts business / contracts to supply services or things] in Connecticut.
5. Venue is proper in this Judicial District pursuant to Conn. Gen. Stat. § 51-345 because [the cause of action arose / Defendant conducts business] here.
FACTUAL ALLEGATIONS
6. On or about [DATE], Plaintiff and Defendant executed a written agreement titled “[TITLE OF AGREEMENT]” (the “Agreement”). A true and correct copy is attached as Exhibit A.
7. Under the Agreement, Plaintiff agreed to [BRIEFLY DESCRIBE PLAINTIFF’S OBLIGATIONS].
8. In consideration, Defendant agreed to [BRIEFLY DESCRIBE DEFENDANT’S OBLIGATIONS], including payment of $[AMOUNT] (the “Contract Price”) on or before [DATE].
9-17. [SET FORTH RELEVANT CHRONOLOGICAL FACTS IN SEPARATE, NUMBERED PARAGRAPHS—E.G., PERFORMANCE BY PLAINTIFF, NON-PERFORMANCE BY DEFENDANT, DEMANDS, NOTICES, ETC.]
18. To date, Defendant has failed and refused to perform as required, specifically by [DESCRIBE BREACH—E.G., NON-PAYMENT, LATE DELIVERY, DEFECTIVE PERFORMANCE], despite Plaintiff’s written notice and opportunity to cure dated [DATE].
COUNT I – BREACH OF CONTRACT
19. Plaintiff repeats and realleges paragraphs 1 through 18 as if fully set forth herein.
20. The Agreement is a valid, binding contract supported by adequate consideration.
21. Plaintiff fully performed, or was ready, willing, and able to perform, all material obligations under the Agreement.
22. Defendant materially breached the Agreement by [RESTATE BREACH].
23. As a direct and proximate result, Plaintiff has sustained damages in an amount not less than $[AMOUNT] and continuing.
24. Pursuant to the Agreement, Defendant is liable for interest at [INTEREST RATE]% per annum on all sums past due.
25. Plaintiff has incurred and will continue to incur attorneys’ fees and costs, which are recoverable under [CONTRACTUAL FEE-SHIFTING CLAUSE] and Conn. Gen. Stat. § 52-249(a).
DAMAGES
26. Compensatory damages in an amount to be proven at trial, presently estimated to exceed $[AMOUNT].
27. Pre- and post-judgment interest at the contractual or statutory rate.
28. Reasonable attorneys’ fees, marshal’s fees, and all taxable costs of suit.
CONDITIONS PRECEDENT
29. All conditions precedent to Defendant’s obligations have occurred, been fulfilled, or have been waived.
JURY DEMAND (OPTIONAL)
30. Plaintiff hereby demands a trial by jury on all issues so triable as of right.
[// GUIDANCE: Omit ¶ 30 if no jury demand is intended. File the Jury Claim form (JD-CL-53) and pay the statutory fee within the Practice Book deadline.]
PRAYER FOR RELIEF
WHEREFORE, Plaintiff respectfully requests that the Court enter judgment in its favor and against Defendant as follows:
A. Compensatory damages in an amount to be determined at trial but not less than $[AMOUNT];
B. Pre- and post-judgment interest as allowed by contract or statute;
C. Reasonable attorneys’ fees and costs pursuant to the Agreement and Conn. Gen. Stat. § 52-249(a);
D. Such other and further relief, at law or in equity, as the Court deems just and proper.
CERTIFICATION PURSUANT TO CONN. PRACTICE BOOK § 10-14
I hereby certify that to the best of my knowledge, information, and belief there is good ground to support this Complaint and it is not interposed for delay.
SIGNATURE BLOCK
Respectfully submitted,
[ATTORNEY NAME] (Juris No. ______)
[LAW FIRM NAME]
[ADDRESS]
[PHONE] | [EMAIL]
Counsel for Plaintiff [PLAINTIFF NAME]
Date: [DATE]
[// GUIDANCE:
1. Discovery Limits – Connecticut Practice Book §§ 13-6 et seq. impose numerical limits on interrogatories and automatic disclosure obligations. After service of process, comply with the Scheduling Order and Standing Orders for the assigned Judicial District.
2. E-Service – Register the matter in the Judicial Branch E-Services portal per Practice Book § 10-13.
3. Return Date – Select a Tuesday at least six days after service (Conn. Gen. Stat. § 52-48). Enter that date on the Summons and utilize it for the caption.
4. Amount in Demand – If the claim is < $15,000, file in the regular docket; if < $5,000, consider Small Claims.
]