STATE OF MICHIGAN
____ JUDICIAL CIRCUIT COURT
COUNTY OF [COUNTY]
| [PLAINTIFF NAME], | Case No. _ |
| Plaintiff, | Hon. __ |
| v. | |
| [DEFENDANT NAME], | |
| Defendant. |
COMPLAINT FOR BREACH OF CONTRACT
AND DEMAND FOR JURY TRIAL
[// GUIDANCE: This template is drafted for filing in a Michigan Circuit Court (amount in controversy > $25,000). For District Court filings, adjust the caption, monetary threshold, and any court-specific requirements.]
TABLE OF CONTENTS
- Parties, Jurisdiction, and Venue
- General Allegations / Factual Background
- Cause of Action – Breach of Contract
- Damages
- Conditions Precedent & Procedural Compliance
- Demand for Jury Trial (Optional)
- Prayer for Relief
- Reservation of Rights
- Signature Block
- Verification & Certification
1. PARTIES, JURISDICTION, AND VENUE
1.1 Plaintiff. [PLAINTIFF NAME] (“Plaintiff”) is a [corporation/LLC/individual/other] organized under the laws of [STATE] with its principal place of business at [ADDRESS].
1.2 Defendant. [DEFENDANT NAME] (“Defendant”) is a [corporation/LLC/individual/other] organized under the laws of [STATE] with its principal place of business at [ADDRESS].
1.3 Jurisdiction. This Court has subject-matter jurisdiction because the amount in controversy exceeds $25,000, exclusive of interest, costs, and attorney fees.
1.4 Venue. Venue is proper in this Court because (i) the contract at issue was negotiated and/or to be performed in [COUNTY] County, Michigan, (ii) Defendant transacts business in this county, and/or (iii) the events giving rise to this action occurred here.
1.5 Personal Service. Defendant is subject to personal jurisdiction in Michigan and will be served in accordance with the Michigan Court Rules.
[// GUIDANCE: When completing, attach a civil summons and any court-specific cover sheet. Confirm service method complies with current Michigan Court Rules on process service.]
2. GENERAL ALLEGATIONS / FACTUAL BACKGROUND
2.1 Contract. On [DATE], Plaintiff and Defendant entered into a written contract titled “[CONTRACT TITLE]” (the “Agreement”), a true and correct copy of which is attached as Exhibit A.
2.2 Key Terms. Under the Agreement:
(a) Plaintiff agreed to [describe obligations – e.g., supply goods, perform services].
(b) Defendant agreed to [describe obligations – e.g., pay $___ per unit, remit milestone payments, etc.].
(c) The Agreement provided for payment within [NUMBER] days of invoice, interest on late payments, and [any relevant clauses].
2.3 Plaintiff’s Performance. Plaintiff fully performed, or substantially performed, all of its contractual obligations, or such performance was excused or prevented by Defendant.
2.4 Defendant’s Breach. Beginning on or about [DATE], Defendant failed to [describe breach – e.g., remit payment, accept delivery, perform required services].
2.5 Notice and Opportunity to Cure. On [DATE], Plaintiff provided written notice of default to Defendant and demanded cure within [NUMBER] days. Defendant failed and refused to cure.
2.6 Damages. As a direct and proximate result of Defendant’s breach, Plaintiff has suffered damages currently estimated at $[AMOUNT], plus continuing interest, costs, and attorney fees as allowed by law and the Agreement.
3. CAUSE OF ACTION – BREACH OF CONTRACT
3.1 Plaintiff incorporates by reference paragraphs 1.1 through 2.6 as though fully set forth herein.
3.2 A valid, enforceable contract existed between the parties.
3.3 Plaintiff performed, or was excused from performing, all conditions precedent.
3.4 Defendant materially breached the Agreement as described above.
3.5 Plaintiff has been damaged in an amount to be proven at trial.
WHEREFORE, Plaintiff respectfully requests that this Court enter judgment in its favor and against Defendant as set forth below.
4. DAMAGES
4.1 Compensatory Damages. $[AMOUNT] for unpaid sums, lost profits, and other general damages.
4.2 Incidental & Consequential Damages. All incidental and consequential damages recoverable under Michigan law.
4.3 Pre- and Post-Judgment Interest. At the highest lawful rate or the contractual rate, whichever is greater.
4.4 Attorney Fees & Costs. Pursuant to the Agreement and/or applicable law.
5. CONDITIONS PRECEDENT & PROCEDURAL COMPLIANCE
5.1 All conditions precedent to Plaintiff’s claims have occurred, been satisfied, or been waived.
5.2 Plaintiff has complied with all applicable Michigan Court Rules, including verification and signature requirements, and will file any required case inventory addendum or alternative dispute resolution statements in accordance with local practice.
[// GUIDANCE: If the contract contains notice, mediation, or other pre-suit requirements, state compliance here and attach supporting exhibits.]
6. DEMAND FOR JURY TRIAL (OPTIONAL)
Plaintiff demands a trial by jury of all issues so triable as of right.
[// GUIDANCE: Delete this section if no jury is sought or if the contract contains an enforceable jury-trial waiver.]
7. PRAYER FOR RELIEF
Plaintiff respectfully requests that the Court:
A. Enter judgment against Defendant for compensatory, incidental, and consequential damages in an amount to be proven at trial but not less than $[AMOUNT];
B. Award pre- and post-judgment interest;
C. Award contractual and/or statutory attorney fees, costs, and expenses;
D. Grant permanent injunctive relief requiring Defendant to [specific performance, cease and desist, etc.], if equitable relief is warranted;
E. Grant such other and further relief as the Court deems just and equitable.
8. RESERVATION OF RIGHTS
Plaintiff reserves the right to amend this Complaint to conform to the evidence, add additional parties or claims, and seek all other relief available at law or in equity.
9. SIGNATURE BLOCK
Respectfully submitted,
[LAW FIRM NAME]
Attorneys for Plaintiff
By: _____
[ATTORNEY NAME] (P__)
[ADDRESS]
[PHONE]
[EMAIL]
Date: _______
10. VERIFICATION & CERTIFICATION
I, [PLAINTIFF REPRESENTATIVE NAME], state that I have read the foregoing Complaint, that the factual statements made herein are true to the best of my knowledge, information, and belief, and that this pleading is not being filed for any improper purpose.
[PLAINTIFF REPRESENTATIVE NAME]
[Title / Capacity]
Date: _______
[// GUIDANCE: Michigan requires a signed “verification” or “certification” that the pleading is well-grounded in fact and law and not interposed for an improper purpose. This template combines both. Adapt to current court rule language.]
EXHIBIT A – Contract (Agreement)
[Attach the operative contract and any relevant amendments or purchase orders.]
[// GUIDANCE: After filing the Complaint and Summons, ensure timely service under the Michigan Court Rules (personal service or certified mail with restricted delivery, return receipt requested). Calendar the responsive pleading deadline (typically 21 days after service within Michigan, 28 days if served outside the state). Coordinate early discovery in compliance with Michigan’s discovery-limit tracks and the court’s scheduling order.]