Complaint for Breach of Purchase Agreement

Drafts a complaint asserting breach of a real estate purchase agreement with jurisdiction-appropriate pleading structure, breach elements, damages analysis, and remedy-specific allegations.

Prerequisites

Executed agreement — purchase agreement plus all addenda, disclosures, and amendments.
Property identification — street address, legal description, parcel/APN.
Party information — full legal names, entity types, formation states, principal places of business, registered agents.
Performance timeline — deposits, escrow instructions, conditions precedent, inspections, financing milestones.
Breach evidence — notice of breach, cure demands, refusal or failure to perform, key communications.
Damages support — contract price, market value, carrying costs, replacement transaction costs, mitigation efforts.
Jurisdiction and venue — forum selection clause, place of performance, defendant residence or business location, party citizenship if diversity.
Requested remedies — damages, specific performance, injunctive relief, attorneys' fees, interest, costs.

If any prerequisite is missing, pause and ask — do not assume or fill gaps.

Output Structure

Step 1 — Caption and Preliminary Statement

Draft the caption with court name, division, parties, case number placeholder, and jury demand if applicable.

Follow with a preliminary statement (3–6 sentences) summarizing the contract, the breach, and relief sought.

Step 2 — Jurisdiction and Venue

| Element | Plead | |---|---| | Subject matter jurisdiction | State law basis, diversity (citizenship + amount in controversy), or federal question | | Forum selection / choice-of-law | Quote clause; plead compliance or enforceability | | Venue | Statutory basis tied to property location, performance location, or defendant residence |

[VERIFY: Local rules for jurisdiction and venue pleading requirements.]

Step 3 — Parties

For each party: role in transaction, entity type, formation state, address, and agency or authority facts. Distinguish individuals from entities.

Step 4 — Factual Allegations

Draft a chronological narrative covering: negotiation, execution, material terms, performance obligations, breach, notice, and cure demand/failure. Cite specific contract sections and dates.

Step 5 — Cause of Action (Breach of Contract)

Plead each element with supporting allegations:

| Element | Allegations Required | Source | |---|---|---| | Valid contract | Offer, acceptance, consideration, parties, signatures, effective date | Executed agreement | | Plaintiff performance | Deposits paid, conditions satisfied, readiness and ability to close | Escrow records | | Defendant breach | Specific obligation breached, date of breach, failure or refusal to perform | Notices, correspondence | | Causation and damages | Direct and foreseeable losses resulting from breach | Damages worksheet |

Step 6 — Remedy-Specific Allegations

Include as applicable:

Specific performance — allege uniqueness of real property, inadequacy of legal remedy, plaintiff's readiness and ability to perform
Injunctive relief / lis pendens — allege irreparable harm, property at risk of transfer or encumbrance
Escrow relief — allege entitlement to deposit return or disbursement

Step 7 — Damages

| Category | Measure | Source | |---|---|---| | Benefit of bargain | Contract price vs. market value | Appraisal, listing data | | Consequential | Foreseeable losses (financing, relocation, taxes) | Invoices, statements | | Incidental | Transactional costs, escrow fees | Receipts | | Reliance | Out-of-pocket expenditures in reliance on contract | Financial records | | Mitigation | Actions taken to reduce loss; offset amounts | Timeline, records |

Step 8 — Prayer for Relief

Number each request:

[ ] Compensatory damages (specific amount or "according to proof" per local rule) [VERIFY]
[ ] Specific performance (if property is unique and legal remedy inadequate)
[ ] Pre-judgment and post-judgment interest at statutory rate [VERIFY: applicable rate]
[ ] Attorneys' fees and costs (only if contractual or statutory basis exists)
[ ] Equitable relief tied to escrow or title

Step 9 — Execution and Filing Components

Verification — include only if jurisdiction requires [VERIFY]
Signature block — attorney name, bar number, firm, address, contact
Exhibits — contract, addenda, notices, escrow instructions, key correspondence
Civil cover sheet — attach per local court rules [VERIFY]

Guidelines

Identify property with both street address and legal description.
Quote or attach only the contract provisions necessary to establish breach.
Plead conditions precedent as required by local rules [VERIFY].
Do not request attorneys' fees absent a contractual or statutory basis.
Do not include settlement communications or inadmissible offers (FRE 408).
Redact confidential personal information per court privacy rules.
For any jurisdiction-specific assumption not confirmed by provided materials, flag with [VERIFY].
Output is draft work product for attorney review — not a filing-ready document.