To prevail on a breach of contract action, the plaintiff must prove (1) a valid contract; (2) a material breach; and

(3) damages. The elements of a cause of action for unjust enrichment are: 1. plaintiff conferred a benefit on the defendant, who has knowledge of that benefit; 2. the defendant accepts and retains the conferred benefit; and 3. under the circumstances it would be inequitable for the defendant to retain the benefit without paying for it.
INSERT PARAGRAPH NUMBER - #]. Plaintiff realleges and incorporates the allegations set forth in paragraphs __-__ above as if set forth herein in full. # Plaintiff has conferred a benefit on the defendant, who has knowledge thereof. # Defendant voluntarily accepted and retained the benefit conferred. # The circumstances render Defendants retention of the benefit inequitable unless the Defendant pays to Plaintiff the value of the benefit. # Defendant has been unjustly enriched at the expense of Plaintiff # Plaintiff is entitled to damages as a result of Defendants unjust enrichment, including the disgorgement of all monies unlawfully accepted by Defendant from Plaintiff. WHEREFORE, Plaintiff demands monetary damages against Defendant for unjust enrichment and such other relief this Court deems just and proper. WHEREFORE, Plaintiff demands monetary damages against Defendant for slander of title and such other relief this Court deems just and proper.