State Court Complaint - Contract Breach

TEMPLATE – STATE COURT COMPLAINT (BREACH OF CONTRACT)
Superior Court of the District of Columbia – Civil Division

TABLE OF CONTENTS

1. Caption
2. Preliminary Statement / Nature of the Action
3. Jurisdiction and Venue
4. Parties
5. Factual Allegations
6. Count I – Breach of Contract
7. Damages
8. Prayer for Relief
9. Jury Demand
10. Rule 11 Certification
11. Verification (Optional)
12. Certificate of Service

1. CAPTION

              SUPERIOR COURT OF THE DISTRICT OF COLUMBIA
                             CIVIL DIVISION

[PLAINTIFF NAME],                                       )
   [Entity Type, e.g., a Delaware corporation],         )
   [Principal Place of Business Address],               )
                                                        )
                 Plaintiff,                             )
                                                        )
        v.                                              ) Civil Action No. __________
                                                        )
[DEFENDANT NAME],                                       )
   [Entity Type],                                       )
   [Principal Place of Business Address],               )
                                                        )
                 Defendant.                             )
                                                        )

                                           COMPLAINT

2. PRELIMINARY STATEMENT / NATURE OF THE ACTION

1. Plaintiff [PLAINTIFF NAME] (“Plaintiff”) brings this action against Defendant [DEFENDANT NAME] (“Defendant”) for damages and other relief arising out of Defendant’s material breach of that certain [TITLE OF WRITTEN AGREEMENT] dated [DATE] (the “Agreement”).
2. Plaintiff seeks compensatory, consequential, and other damages, pre- and post-judgment interest, costs, attorneys’ fees where recoverable, and such further relief as the Court deems just and proper.

3. JURISDICTION AND VENUE

3. This Court has subject-matter jurisdiction under D.C. Code § 11-921 because the amount in controversy exceeds $10,000 exclusive of interest and costs.
4. Personal jurisdiction is proper under D.C. Code § 13-423(a)(1) & (a)(2) because Defendant transacted business and contracted to supply services or things in the District of Columbia.
5. Venue is proper in this Court pursuant to DCSC R. 12-I because the cause of action arose in the District of Columbia and/or Defendant may be found here.

4. PARTIES

6. Plaintiff is a [corporation/limited liability company/individual] organized under the laws of [STATE] with its principal place of business at [ADDRESS].
7. Defendant is a [corporation/limited liability company/individual] organized under the laws of [STATE] with its principal place of business at [ADDRESS].
8. At all relevant times, Defendant conducted business within the District of Columbia.

5. FACTUAL ALLEGATIONS

9. On or about [DATE], Plaintiff and Defendant entered into the Agreement, a true and correct copy of which is attached hereto as Exhibit A.
10. The Agreement obligated Defendant to [briefly describe key performance obligations] by no later than [DEADLINE].
11. Plaintiff fully performed, or was ready, willing, and able to perform, all of its material obligations under the Agreement.

12. Beginning on or about [DATE], Defendant materially breached the Agreement by, among other things:
      a. [BREACH #1—e.g., “Failing to deliver conforming goods”];
      b. [BREACH #2]; and
      c. [BREACH #3].

13. Plaintiff provided Defendant with written notice of breach on [DATE] pursuant to Section [X] of the Agreement, but Defendant failed to cure within the contractual [__-day] cure period.

14. As a direct and proximate result of Defendant’s breaches, Plaintiff has suffered damages in an amount to be proven at trial but presently estimated to exceed $[AMOUNT].

6. COUNT I – BREACH OF CONTRACT

15. Plaintiff realleges and incorporates by reference Paragraphs 1–14 as though fully set forth herein.
16. The Agreement is a valid and enforceable contract supported by adequate consideration.
17. Plaintiff performed all conditions precedent, or such conditions have been waived or excused.
18. Defendant’s acts and omissions described above constitute material breaches of the Agreement.
19. Plaintiff has been damaged and continues to suffer damages as a result of Defendant’s breach.

7. DAMAGES

20. Plaintiff seeks:
      a. Direct and consequential damages in an amount to be determined at trial;
      b. Pre-judgment and post-judgment interest at the maximum legal rate;
      c. Reasonable attorneys’ fees and litigation costs to the extent recoverable under [cite Agreement section or legal basis]; and
      d. Such other and further relief as the Court deems just and proper.

8. PRAYER FOR RELIEF

WHEREFORE, Plaintiff respectfully requests that the Court enter judgment in its favor and against Defendant as follows:
A. Awarding damages as set forth above;
B. Awarding pre- and post-judgment interest;
C. Awarding costs and attorneys’ fees as permitted; and
D. Granting such other and further relief as the Court deems just and proper.

9. JURY DEMAND

Pursuant to DCSC R. 38, Plaintiff demands a trial by jury on all issues so triable.

10. RULE 11 CERTIFICATION

Pursuant to DCSC R. 11, the undersigned counsel certifies that to the best of counsel’s knowledge, information, and belief, formed after an inquiry reasonable under the circumstances, this pleading is not presented for any improper purpose, the claims and legal contentions are warranted by existing law or by a non-frivolous argument for the extension, modification, or reversal of existing law, and the factual contentions have evidentiary support.

11. VERIFICATION (OPTIONAL – ONLY IF REQUIRED)

I, [NAME], being first duly sworn, depose and say that I am [TITLE] of Plaintiff; that I have read the foregoing Complaint and know the contents thereof; and that the same is true to the best of my knowledge, information, and belief.

_________________________________  
[NAME]  
[DATE]

Subscribed and sworn to before me on this ___ day of __________, 20__.  
_________________________________  
Notary Public
My commission expires: __________

12. CERTIFICATE OF SERVICE

I hereby certify that on this ___ day of __________, 20__, I caused a copy of the foregoing Complaint, together with civil cover sheet and summons, to be served upon Defendant in accordance with DCSC R. 4 by [method of service].

_________________________________
[ATTORNEY NAME] (Bar No. ________)
[Law Firm Name]
[Address]
[Phone] | [Email]
Counsel for Plaintiff

KEY D.C.-SPECIFIC PRACTICE NOTES

• Pleading Standard: DCSC R. 8(a) requires a “short and plain statement.” Avoid unnecessary evidentiary detail.
• Service: The Clerk issues the summons; service must be completed within 90 days (DCSC R. 4(m)).
• Discovery Limits: Initial disclosures are required under DCSC R. 26(a)(1) unless the case falls under an exempt category. The presumptive limits on interrogatories (40), depositions (10 per side), and requests for production (no numerical limit) apply unless modified by court order or stipulation (DCSC R. 26, 30, 33).
• Case Tracking: Within 60 days of service on the first defendant, a Civil Tracking Conference Statement (Form CV-491/492) is due under Administrative Order 20-17.
• Mandatory Mediation: Most contract matters are referred to the Court’s Multi-Door Dispute Resolution Division prior to trial.