[// GUIDANCE: This template is drafted for filing in a Maryland Circuit Court.
If your amount in controversy is ≤ $30,000 and you prefer District Court, adjust the caption to “IN THE DISTRICT COURT OF MARYLAND FOR [COUNTY]” and substitute District-Court rule citations (Md. Rule 3-) for Circuit-Court citations (Md. Rule 2-).]

TABLE OF CONTENTS

1. Caption
2. Complaint
   2.1 Parties
   2.2 Jurisdiction & Venue
   2.3 Factual Allegations
   2.4 Count I – Breach of Contract
   2.5 Damages
   2.6 Conditions Precedent
   2.7 Prayer for Relief
   2.8 Jury Demand
3. Verification (Optional)
4. Certificate of Service

1. CAPTION

IN THE CIRCUIT COURT FOR [COUNTY] COUNTY, MARYLAND
Civil Action No.: _____

[PLAINTIFF FULL LEGAL NAME],
  Plaintiff,
v.
[DEFENDANT FULL LEGAL NAME],
  Defendant.

COMPLAINT FOR BREACH OF CONTRACT

2. COMPLAINT

Plaintiff, by and through undersigned counsel, alleges:

2.1 Parties

1. Plaintiff [PLAINTIFF NAME] (“Plaintiff”) is a [STATE] [corporation/LLC/individual] with its principal place of business at [ADDRESS].
2. Defendant [DEFENDANT NAME] (“Defendant”) is a [STATE] [corporation/LLC/individual] with its principal place of business at [ADDRESS], and may be served pursuant to Md. Rule 2-121 at [SERVICE ADDRESS].

2.2 Jurisdiction & Venue

3. This Court has subject-matter jurisdiction under Md. Code Ann., Cts. & Jud. Proc. § 1-501, because the amount in controversy exceeds $30,000 exclusive of interest, costs, and attorney’s fees.
4. Venue is proper in this Court under Md. Code Ann., Cts. & Jud. Proc. § 6-201(a) because Defendant resides and/or carries on regular business in [COUNTY] County, Maryland, and the contractual obligations at issue were to be performed here.

[// GUIDANCE: If relying on a contractual forum-selection clause, quote it here.]

2.3 Factual Allegations

5. On or about [DATE], Plaintiff and Defendant entered into a written contract titled “[TITLE OF CONTRACT]” (the “Agreement”).
6. Under the Agreement, Plaintiff agreed to:
    a. [PLAINTIFF OBLIGATION 1];
    b. [PLAINTIFF OBLIGATION 2].
7. In consideration, Defendant agreed to:
    a. [DEFENDANT OBLIGATION 1];
    b. Pay Plaintiff [$_] according to the schedule set forth in Section [] of the Agreement.
8. Plaintiff fully performed, or was ready, willing, and able to perform, all material obligations required of it under the Agreement.
9. Beginning on or about [DATE], Defendant materially breached the Agreement by:
    a. Failing to make payments totaling [$_____] when due; and/or
    b. [OTHER BREACHES].
10. Despite written notice dated [DATE] and a reasonable cure period as required by Section [__] of the Agreement, Defendant has failed and refused to cure its breaches.
11. As a direct and proximate result of Defendant’s breaches, Plaintiff has suffered damages in excess of $75,000, exclusive of interest, costs, and attorney’s fees.

2.4 Count I – Breach of Contract

12. Plaintiff realleges and incorporates paragraphs 1–11 as if fully set forth herein.
13. The Agreement constitutes a valid, binding, and enforceable contract supported by mutual consideration.
14. Defendant’s acts and omissions described above constitute material breaches of the Agreement.
15. Plaintiff has been damaged by Defendant’s breaches in an amount to be proven at trial but not less than [$ AMOUNT].

2.5 Damages

16. Plaintiff seeks:
     a. Compensatory damages of [$ AMOUNT];
     b. Pre- and post-judgment interest at the legal rate pursuant to Md. Code Ann., Cts. & Jud. Proc. § 11-107;
     c. Reasonable attorney’s fees and costs as provided in Section [__] of the Agreement and/or Md. Rule 2-705;
     d. Such other and further relief as the Court deems just and proper.

2.6 Conditions Precedent

17. All conditions precedent to Plaintiff’s right to relief have been satisfied, waived, or excused.

2.7 Prayer for Relief

WHEREFORE, Plaintiff respectfully requests that this Court enter judgment in its favor and against Defendant as follows:
A. Awarding compensatory damages in an amount to be determined at trial;
B. Awarding contractual and statutory interest;
C. Awarding reasonable attorney’s fees and costs;
D. Granting such further legal or equitable relief, including injunctive relief, as the Court deems appropriate.

2.8 Jury Demand

Pursuant to Md. Rule 2-325(a), Plaintiff demands a trial by jury on all issues so triable.

3. VERIFICATION (OPTIONAL)

[// GUIDANCE: Verification is not generally required under Md. Rule 2-303(b), but some practitioners include it for evidentiary leverage.]

I, [NAME OF AUTHORIZED REPRESENTATIVE], being duly sworn, depose and state that I am [TITLE] of Plaintiff, that I have read the foregoing Complaint, and that the facts stated therein are true and correct to the best of my knowledge, information, and belief.

[NAME]
Date: ______

4. CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this _ day of _, 20___, a copy of the foregoing Complaint was served, together with Civil-Action Cover Sheet and Summons, in accordance with Md. Rule 2-121, upon:

[DEFENDANT NAME]
c/o [REGISTERED AGENT/ADDRESS]

[ATTORNEY NAME] (Bar No. ______)
[LAW FIRM NAME]
[ADDRESS]
[TEL] | [EMAIL]
Counsel for Plaintiff

[// GUIDANCE:
1. Discovery Limits – Circuit-Court discovery is governed by Md. Rules 2-401 et seq.; interrogatories are presumptively limited to 30 unless otherwise ordered. Insert any scheduling-order placeholders if known.
2. Service – Ensure summons is issued by the Clerk and served per Md. Rule 2-121 (sheriff, private process, or certified mail with restricted delivery).
3. Statute of Limitations – Contract actions in Maryland are subject to a three-year limitation period. See Md. Code Ann., Cts. & Jud. Proc. § 5-101.]