name: breach-of-purchase-agreement-complaint
language: en
description: >-
Drafts a filing-ready U.S. complaint for breach of a purchase agreement.
Trigger when the user requests a breach-of-contract complaint, forum-selection
analysis, or remedy package for a real-estate or asset purchase dispute.
tags:
- drafting
- litigation
- pleading
Complaint for Breach of Purchase Agreement
Produces a court-ready complaint with jurisdiction, liability elements, and damages precision for purchase-agreement disputes.
Prerequisites
Gather before drafting:
- Executed agreement — including amendments, riders, addenda, notices, cure letters, and payment records.
- Party data — legal names, entity types/formation states, addresses, registered agents.
- Transaction timeline — negotiation, execution, performance milestones, breach event, notice, and mitigation efforts with supporting evidence.
- Jurisdictional directives — target court, forum-selection and choice-of-law terms, arbitration scope, local filing requirements.
- Damages inputs — direct, consequential, incidental amounts; interest expectations; attorney-fee basis.
Workflow
1. Filing Scaffold
Generate caption, court heading, case-number placeholder, title of action, attorney block, and party designation blocks in court-compliant order.
2. Jurisdiction and Venue
Plead each ground with paragraph-supported facts:
- Subject-matter jurisdiction — diversity, federal question, or state-law basis.
- Personal jurisdiction — defendant presence, contacts, or minimum contacts.
- Venue — contract formation/performance/breach location; defendant residence.
- Forum-selection / choice of law — enforce contractual forum and governing-law clauses; note arbitration scope.
3. Parties
For each party: legal name, capacity/status, role in transaction, full address. Include aliases, registered agent (defendant), and guarantors/assignees/successors as needed.
4. Factual Chronology
Numbered paragraphs in strict temporal order. Attach exhibit references to each key event.
5. Breach of Contract Cause of Action
Map each element to specific facts and exhibits:
- Formation — valid agreement, authority, consideration, essential terms.
- Duty — exact breached provision and expected performance.
- Breach — specific act/omission, date, breach-notice timeline.
- Plaintiff performance — performance completed or valid excuse.
- Causation and damages — direct link between breach and resulting harm.
6. Damages Ledger
Itemize by category with calculation method and supporting evidence:
- Expectancy/direct — contract-differential or replacement-cost.
- Consequential — foreseeable losses tied to breach.
- Incidental — re-listing, storage, administrative costs.
- Fees/costs — only if contract or statute authorizes.
7. Prayer for Relief
State each relief bucket explicitly: damages (sum or proof at trial), specific performance (if unique subject matter), pre/post-judgment interest, costs, attorney fees (if authorized), injunctive relief (if warranted).
8. Closing Blocks
- Jury demand and filing-status labels.
- Liquidated-damages interpretation or damages-cap caveats.
- Verification block — unsworn declaration or notarized statement per jurisdiction; penalty-of-perjury wording if required.
- Attorney signature block — name, bar number, firm, address, phone, email, date.
9. Compliance Checklist
Append to the draft:
10. Verification Markers
Insert [VERIFY] on any assertion of statute, rule, interest rate, filing prerequisite, or remedy authorization not directly supplied by user materials.
Pitfalls
- Keep factual allegations separate from legal conclusions in each paragraph.
- Quote contract language directly for breach-trigger allegations — do not paraphrase.
- Never invent forum, amount-in-controversy, or statutory authority.
- Preserve forum-selection, arbitration, and liquidated-damage clauses as written.
- Do not embed settlement posture or demand-letter language in the pleading.
- Flag all unverified legal assertions with
[VERIFY] and confirm with user before finalizing.