[COURT CLERK’S BLANK LINE FOR CASE NUMBER]

IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON
FOR THE COUNTY OF [COUNTY]

I. PARTIES

1. Plaintiff. [PLAINTIFF NAME] (“Plaintiff”) is a resident of, and at all relevant times conducted business in, the State of Washington, County of [COUNTY].

2. Defendant. [DEFENDANT NAME] (“Defendant”) is a [corporation/LLC/individual] with its principal place of business at [ADDRESS] and, at all relevant times, transacted business in the State of Washington.

[// GUIDANCE: If additional parties (e.g., guarantors) exist, insert separate paragraphs for each.]

II. JURISDICTION & VENUE

3. This Court has subject-matter jurisdiction under the Washington Constitution art. IV, § 6 and RCW 2.08.010 (general jurisdiction of superior courts).

4. Personal jurisdiction is proper because Defendant purposely availed itself of the privilege of conducting business in Washington, and the claims arise out of those activities.

5. Venue is proper in [COUNTY] County under RCW 4.12.025(1) because Defendant resides in, and the contract was executed and/or breached in, this county.

III. FACTUAL ALLEGATIONS

6. On or about [DATE], Plaintiff and Defendant entered into a written contract titled “[CONTRACT NAME]” (the “Agreement”), a true and correct copy of which is attached hereto as Exhibit A.

7. Under the Agreement, Defendant was obligated to [describe key obligations] by no later than [DATE/PERFORMANCE BENCHMARK].

8. Plaintiff fully performed, or stood ready, willing, and able to perform, all of its obligations under the Agreement.

9. Defendant breached the Agreement by, among other things, [detail specific breaches, e.g., failure to pay, late delivery, non-conforming goods/services].

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

IV. CAUSE OF ACTION – BREACH OF CONTRACT

11. Plaintiff realleges and incorporates by reference paragraphs 1 – 10 above as though fully set forth herein.

12. A valid and enforceable Agreement exists between the parties.

13. Plaintiff has performed all conditions precedent.

14. Defendant materially breached the Agreement.

15. Defendant’s breach caused Plaintiff damages, including without limitation:
    a. Direct monetary loss;
    b. Incidental and consequential damages; and
    c. Pre- and post-judgment interest at the maximum rate allowed by law.

16. Plaintiff is entitled to recover all such damages, together with attorneys’ fees and costs as provided in the Agreement and RCW 4.84.330.

V. ATTORNEYS’ FEES & COSTS

17. The Agreement contains a bilateral attorneys’ fees clause. Pursuant thereto—and independently under RCW 4.84.330—Plaintiff is entitled to an award of its reasonable attorneys’ fees, expert fees, and costs incurred herein.

VI. CONDITIONS PRECEDENT & NOTICE

18. To the extent the Agreement requires notice of default and an opportunity to cure, Plaintiff provided written notice to Defendant on [DATE], which Defendant ignored.

[// GUIDANCE: If no notice is required, delete paragraph 18.]

VII. PRAYER FOR RELIEF

WHEREFORE, Plaintiff respectfully requests that the Court enter judgment in its favor and award:

A. Compensatory damages in an amount to be proved at trial, but not less than $[AMOUNT];

B. Incidental, consequential, and special damages as allowed by law;

C. Pre- and post-judgment interest;

D. Reasonable attorneys’ fees, expert fees, and costs;

E. Such injunctive or equitable relief as the Court deems just and proper; and

F. Any additional relief the Court deems equitable and just.

VIII. DEMAND FOR JURY TRIAL (OPTIONAL)

Plaintiff demands a trial by jury on all issues so triable.
[// GUIDANCE: Delete if jury trial is not desired or waived.]

IX. RESERVATION OF RIGHTS & AMENDMENT

Plaintiff reserves the right to amend this Complaint to assert additional claims or parties as discovery progresses, consistent with the Washington Superior Court Civil Rules.

X. DISCOVERY LIMITATIONS STATEMENT

Pursuant to Washington Superior Court Civil Rule 26 and applicable local rules:

1. Interrogatories are limited to [number] interrogatories, including sub-parts, absent agreement or court order.

2. Depositions are limited to [number] per side and [time limit] hours each, absent agreement or court order.

[// GUIDANCE: Tailor the above to the specific county’s Local Civil Rules; many counties default to the federal 10-deposition / 30-interrogatory scheme, but local variations exist.]

XI. CERTIFICATION UNDER CR 11

The undersigned certifies that the claims herein are warranted by existing law or a good-faith argument for its extension or modification, and that this pleading is not presented for any improper purpose.

DATED this ___ day of [MONTH], 20__.

Respectfully submitted,

[ATTORNEY NAME], WSBA No. _____
[LAW FIRM NAME]
[ADDRESS]
[PHONE] | [EMAIL]
Attorney for Plaintiff [PLAINTIFF NAME]

XII. VERIFICATION – RCW 9A.72.085

I, [PLAINTIFF REPRESENTATIVE NAME], declare under penalty of perjury under the laws of the State of Washington that I am the Plaintiff [or authorized representative], I have read the foregoing Complaint, and the facts stated are true and correct to the best of my knowledge.

Executed at [City], Washington, on [DATE].

[PLAINTIFF REPRESENTATIVE NAME]
Title: [Title, if entity plaintiff]

SUMMONS (Attach as Separate First Page for Service)

[// GUIDANCE: Washington practice requires a Summons meeting the form prescribed in CR 4 (a)(2). Attach the Summons ahead of the Complaint when serving; include a 20-day response period (60 days if served outside WA).]

SERVICE & FILING CHECKLIST (Do NOT file with court)

[// GUIDANCE:

1. File original Summons & Complaint with Clerk of Court.
2. Cause Summons & Complaint to be served per CR 4 (personal service, substitute service, or first-class mail/acknowledgment).
3. File Proof/Declaration of Service promptly.
4. Calendar Defendant’s 20-day (in-state) or 60-day (out-of-state) answer deadline.
5. Schedule an early discovery conference under CR 26(f) and local rules.]

[// GENERAL GUIDANCE]

1. Attach the operative contract as Exhibit A and any relevant notices/correspondence as sequential Exhibits.
2. Double-check local rules for font, margin, and line-numbering requirements (most counties require 14-point type and line numbers).
3. If injunctive relief is a priority, prepare and file a motion for temporary restraining order (TRO)/preliminary injunction concurrently with the Complaint.
4. If the contract contains a forum-selection or arbitration clause, analyze and address those issues before filing in Superior Court.
5. Maintain consistency of defined terms (e.g., “Agreement,” “Plaintiff,” “Defendant”) throughout all pleadings and discovery.