[COURT NAME]

District Court, [COUNTY] County, State of Nevada

***

[PLAINTIFF NAME],

an [Entity Type & State of Organization],
Plaintiff,

v.

[DEFENDANT NAME],

an [Entity Type & State of Organization],
Defendant.

Case No.: [_]
Dept. No.: [_]

VERIFIED COMPLAINT FOR BREACH OF CONTRACT

[// GUIDANCE: Nevada follows “notice-pleading” under Nev. R. Civ. P. 8(a). Allege only those facts necessary to give the defendant fair notice of the claim and the relief sought. Attach the operative contract as “Exhibit 1” and reference it throughout the pleading.]

I. PARTIES, JURISDICTION, AND VENUE

1. Plaintiff. [PLAINTIFF NAME] (“Plaintiff”) is a [corporation/LLC/individual] organized and existing under the laws of [STATE] with its principal place of business at [ADDRESS].

2. Defendant. [DEFENDANT NAME] (“Defendant”) is a [corporation/LLC/individual] organized and existing under the laws of [STATE] with its principal place of business at [ADDRESS].

3. Jurisdiction. This Court has subject-matter jurisdiction under Nev. Const. art. 6, § 6 and Nev. Rev. Stat. § 4.370 because the amount in controversy exceeds $[THRESHOLD] exclusive of interest and costs.

4. Venue. Venue is proper in this Court under Nev. Rev. Stat. § 13.010 because (a) Defendant resides and/or does business in this county, and/or (b) the contract was executed and/or is to be performed in this county.

II. GENERAL ALLEGATIONS

5. On or about [DATE], Plaintiff and Defendant entered into a written contract entitled “[TITLE]” (the “Agreement”), a true and correct copy of which is attached hereto as Exhibit 1 and incorporated by reference.

6. Under the Agreement, Plaintiff agreed to:
   a. [Describe Plaintiff’s primary obligations]; and
   b. [Optional second obligation].

7. In consideration, Defendant agreed to:
   a. Pay Plaintiff [SPECIFIC PAYMENT TERMS]; and
   b. [Any additional obligations].

8. Plaintiff has fully performed, tendered performance, and/or been excused from further performance under the Agreement.

9. Beginning on or about [DATE], Defendant materially breached the Agreement by:
   a. Failing to pay $[AMOUNT] when due;
   b. [Describe additional breaches].

10. As a direct and proximate result of Defendant’s breaches, Plaintiff has suffered damages in an amount to be proven at trial but no less than $[AMOUNT], plus prejudgment interest as permitted by Nev. Rev. Stat. § 17.130.

III. FIRST CAUSE OF ACTION

Breach of Contract (Against Defendant)

11. Plaintiff realleges and incorporates by reference Paragraphs 1 through 10 as though fully set forth herein.

12. Existence of Contract. The Agreement constitutes a valid and enforceable contract.

13. Plaintiff’s Performance. Plaintiff performed all conditions, covenants, and promises required of it, or such performance was waived or excused by Defendant.

14. Defendant’s Breach. Defendant failed to perform its contractual obligations by the acts and omissions alleged above.

15. Damages. Plaintiff has been damaged in an amount exceeding $[AMOUNT] as a foreseeable result of Defendant’s breach.

16. Attorney’s Fees. Pursuant to [Agreement § ___] and/or Nev. Rev. Stat. § 18.010(2)(b), Plaintiff is entitled to recover reasonable attorney’s fees and costs incurred herein.

IV. 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 at the statutory rate;

C. Reasonable attorney’s fees and costs;

D. Such other and further relief as the Court deems just and proper.

V. DEMAND FOR JURY TRIAL

Pursuant to Nev. R. Civ. P. 38(b) and Nev. Rev. Stat. § 16.010, Plaintiff demands a trial by jury on all triable issues.

VI. NRCP 16.1 INITIAL DISCLOSURE CERTIFICATION

Plaintiff understands the duty to exchange NRCP 16.1 initial disclosures within 14 days after the early case conference and will comply therewith.

VII. AFFIRMATION (NRS 239B.030)

The undersigned hereby affirms that this document does not contain the social security number of any person.

VIII. VERIFICATION

I, [NAME], am the [TITLE] of Plaintiff in the above-entitled action. I have read the foregoing Complaint and know the contents thereof. The same is true of my own knowledge, except as to those matters stated on information and belief, and as to those matters I believe them to be true.

Executed on [DATE], at [CITY], [STATE].

[NAME], [TITLE]
Plaintiff

IX. SIGNATURE BLOCK

DATED: [DATE] Respectfully submitted,

[LAW FIRM NAME]
By: _________
[ATTORNEY NAME] (Bar No. [#####])
[Address]
Tel: [###-###-####]
Email: [email]
Attorneys for Plaintiff

OPTIONAL ATTACHMENTS

1. Exhibit 1 – Contract.
2. Summons (prepared in compliance with NRCP 4).

KEY NEVADA-SPECIFIC PRACTICE NOTES

[// GUIDANCE: 1. Service – File the complaint and obtain a summons. Serve Defendant under NRCP 4 within 120 days or seek enlargement for good cause.
2. Discovery – Unless exempted, hold the early case conference within 30 days after service of the answer and exchange NRCP 16.1 disclosures within 14 days thereafter. Nevada presumptively limits (a) 10 depositions per side (Rule 30(a)(2)(A)), (b) 25 interrogatories including subparts (Rule 33(a)(1)), and (c) 40 requests for production (Rule 34(b)(2)(A)).
3. Case Management – The court will issue a scheduling order following the Early Case Conference Report (NRCP 16.1(b)(3)). Calendar a potential mandatory settlement conference approximately 60 days before trial.
4. Jury Waiver – Nevada recognizes contractual jury waivers only if made “knowingly and voluntarily.” Verify the Agreement’s waiver clause before demanding a jury.
5. Injunctive Relief – If immediate relief is needed, prepare a motion for preliminary injunction under NRCP 65 and post the requisite security.
6. Fee Shifting – Cite both contractual fee provisions and Nev. Rev. Stat. § 18.010(2)(b) (unreasonable defense) to preserve flexibility.
7. Offers of Judgment – Consider an early Offer of Judgment under Nev. R. Civ. P. 68 to leverage cost-shifting.
8. Pleading Amendments – Amend as of right within 21 days after service of the answer (NRCP 15(a)(1)(B)) or thereafter with leave of court.]

This template is court-ready but must be tailored to the specific facts, parties, and contractual provisions of each case.