United States District Court

For the
Third District of Texas
Second Division
John Doe
Plaintiff

-VJJP Contractors
Defendant

Case No.- 042899

Jury Trial- No
COMPLAINT FOR A CIVIL CASE ALLEGING BREACH
OF CONTRACT
I.

The Parties to This Complaint

A. The Plaintiff
Name: John Doe
Street Address: 1234 Bal Harbor Ln
City and County: Frisco/ Denton
State and Zip Code: Texas/ 75033
Telephone Number: (214)555-3115
E-mail Address: Johnd89@yahoo.com

B. The Defendant
Name: JJP Contractors
Street Address: 2005 Preston Rd
City and County: Frisco/ Collin
State and Zip Code: Texas/ 75035
Telephone Number: (214)555-9876
E-mail Address: jjpcontractors@gmail.com
II.

Basis for Jurisdiction

A. The Plaintiff
The Plaintiff, John Doe, is a citizen of the State of Texas.
B. The Defendant
The defendant, JJP Contractors, is incorporated under the laws of the State of
Texas, and has its principal place of business in the State of Texas.
C. The Amount of Controversy
The amount in controversy is more than $75,000, not counting interest and costs
of court, because the amount of damage caused by the faulty installation of the
plumbing system totals $140,000.

III.
Statement of Claim
The plaintiff, John Doe, and the defendant, JJP Contractors, made a contract on August
21, 2016. This contract was written. Under that contract, JJP Contractors was required to
fully install the plumbing system in John Does home to regulation standards, and John
Doe was required to pay $70,000 for this service up front.
IV. Relief
Due to the installation of the plumbing system, which did not meet regulation standards,
the house was damaged. The leaking system caused foundation problems, which totalled
$55,000. It also ruined all of the custom hardwood floors that costed $60,000 to be
replaced. The final expense of $25,000 was the expense of having the plumbing system
repaired to meet the regulation standards and work properly.
V. Certification and Closing
Under Federal Rule of Civil Procedure 11, by signing below, I certify to the best of my
knowledge, information, and belief that this complaint: (1) is not being presented for an
improper purpose, such as to harass, cause unnecessary delay, or needlessly increase the
cost of litigation; (2) is supported by t=existing law or by a nonfrivolous argument for
extending, modifying, or reversing existing law; (3) the factual contentions have
evidentiary support or, if specifically so identified, will likely have evidentiary support

after a reasonable opportunity for further investigation or discovery; and (4) the
complaint otherwise complies with the requirements of Rule 11.
Date of signing: January 6, 2017
Signature of Attorney:
Printed Name of Attorney: McKenzie Koch
Bar Number: 123456
Name of Law Firm: Smith and Jones Law Office
Street Address: 1387 Legacy Dr
State and Zip Code: Texas/ 75033
Telephone Number: (214)555-9009
E-mail Address: koch@smithandjones.com

United States District Court

For the
Third District of Texas
Second Division
John Doe
Plaintiff

-VJJP Contractors
Defendant

Case No.- 042899

Jury Trial- No
COMPLAINT FOR A CIVIL CASE ALLEGING BREACH
OF CONTRACT
I.

The Parties to This Complaint

A. The Plaintiff
Name: John Doe
Street Address: 1234 Bal Harbor Ln
City and County: Frisco/ Denton
State and Zip Code: Texas/ 75033
Telephone Number: (214)555-3115
E-mail Address: Johnd89@yahoo.com

B. The Defendant
Name: JJP Contractors
Street Address: 2005 Preston Rd
City and County: Frisco/ Collin
State and Zip Code: Texas/ 75035
Telephone Number: (214)555-9876
E-mail Address: jjpcontractors@gmail.com
II.

The Answer and Defenses to the Complaint

A. Answering the Claims for Relief
(1) JJP Contractors did sign a written contract on August 21, 2016 agreeing to
complete the plumbing work in John Does home to regulation standards. The cost of
these services was agreed to be $70,000.
(2) The installation of a plumbing system that did not meet regulatory standards did
occur.
B. Presenting Defenses to the Claims for Relief
(1) The manner of serving the defendant with the summons and complaint was
insufficient because it was served by the plaintiff, John Doe, himself.
C. Asserting Affirmative Defenses to the Claims for Relief
(1) The plaintiffs claim for JJP Contractors being required to fully install the
plumbing system in John Does home to regulation standards is barred by the plaintiffs
assumption of risk once the full payment was made to JJP Contractors.
III.

Certification and Closing

Under Federal Rule of Civil Procedure 11, by signing below, I certify to the best of my
knowledge, information, and belief that this complaint: (1) is not being presented for an
improper purpose, such as to harass, cause unnecessary delay, or needlessly increase the
cost of litigation; (2) is supported by existing law or by a nonfrivolous argument for
extending, modifying, or reversing existing law; (3) the factual contentions have
evidentiary support or, if specifically so identified, will likely have evidentiary support
after a reasonable opportunity for further investigation or discovery; and (4) the
complaint otherwise complies with the requirements of Rule 11.
Date of signing: January 6, 2017
Signature of Attorney:
Printed Name of Attorney: McKenzie Koch
Bar Number: 123456
Name of Law Firm: Smith and Jones Law Office
Street Address: 1387 Legacy Dr
State and Zip Code: Texas/ 75033
Telephone Number: (214)555-9009

E-mail Address: koch@smithandjones.com

United States District Court

For the
Third District of Texas
Second Division
John Doe
Plaintiff

-VJJP Contractors
Defendant

Case No.- 042899

Jury Trial- No
COMPLAINT FOR A CIVIL CASE ALLEGING BREACH
OF CONTRACT
The Parties to This Complaint
The Plaintiff
Name: John Doe
Street Address: 1234 Bal Harbor Ln
City and County: Frisco/ Denton
State and Zip Code: Texas/ 75033
Telephone Number: (214)555-3115
E-mail Address: Johnd89@yahoo.com

The Defendant
Name: JJP Contractors
Street Address: 2005 Preston Rd
City and County: Frisco/ Collin
State and Zip Code: Texas/ 75035
Telephone Number: (214)555-9876
E-mail Address: jjpcontractors@gmail.com
I.

Instructions

Following Rules 26 and 34 of the federal Rules of Civil Procedure, the United States
shall produce copies of the requested documents within the thirty day time frame from the
service of this discovery request. All documents should be delivered to 1387 Legacy Dr.
If you object to share any of the requested documents under the grounds of privilege,
work product, or other grounds, your response should include the acknowledgement of existence
of the document and the specific grounds for your objection. If the objected to document
contains relevant non-objectionable matter, you should produce it, with the objectionable matter
removed.
II.

Definitions

The following definitions apply to these document production requests:

1. Document: As per Rule 34 (a) of the Federal Rules of Civil Procedure,
document includes electronically-stored information and all media on which
information is stored or recorded.
2. Communication: Communication is defined as the transmission of information
(facts, ideas, inquiries, or otherwise) through written, verbal, or any other form
3. Pertaining: Pertaining means relating to, referring to, describing, evidencing, or
constituting
4. And/Or: The connectives and and or shall be construed either disjunctively or
conjunctively as necessary to bring within the scope of the discovery request

III.

Document Production Requests

1. All documents pertaining to the original work contract between JJP Contractors
and Mr. John Doe.
2. All documents containing estimates for the repairs of the Plaintiffs home due to
the plumbing system failure.
Date: January 8, 2017
Sign name: _______________________

Print Name: McKenzie Koch

Contract of Services
By signing below, I, _______________________, agree to the following terms and
conditions produced by JJP Contractors:
For the payment of $70,000, JJP Contractors will fully install a whole-home
plumbing system that meets all regulatory standards.
Half of the payment will be paid at the start of the construction, and the last half of
the payment will be paid at the conclusion of the construction.
Payment, in full, signifies satisfaction with the product and thus terminates JJP
Contractors liability.

Signature: _________________________
Printed Name: John Doe
Date: August 21, 2016

JTs Foundation Repairs

Estimate of repair

Date: September 25, 2016

Client: John Doe
Address: 1234 Bal Harbour Ln
Frisco, Tx 75033
Concrete

$30,000

Machinery and additional

supplies

$10,000

Labor

$15,000

Total

$55,000

Estimate from: Tom Peters

Flooring Estimate
Employee: Megan Jones
Client: John Doe
Address: 1234 Bal Harbour Ln
Frisco, Tx 75033

Materials
Hand-scraped Oak

$1.50 per sq. ft.

Square feet

36,000

Materials Total

$54,000

Labor
Labor Cost

$300 per hour (for 3 professionals)

Hours

20

Labor Total

$6,000

Grand Total

$60,000

FIX IT FAST PLUMBING

Estimate of Services
Client Name: John Doe
Client Address: 1234 Bal Harbour Ln
Frisco, Tx 75033
Materials

$20,000

Labor ($75 per hour per

person)

$5,000
Sub-total:
Discount:
Total:

25,000
-0.00
$25,000

Additional Comments: _________________________________

____________________________________________________
____________________________________________________
____________________________________________________