COMPLAINT
Plaintiff, A. B., sues defendant, C. D., and alleges:
1. This is an action for damages that (insert jurisdictional amount).
2. Before the institution of this action plaintiff and defendant had business transactions between them.
3. (Use A or B).
A. Plaintiff and defendant agreed on the balance due on
…..(date)……
[OR]
B. Plaintiff sent a statement to defendant on …..(date)….. and defendant failed to object within a reasonable time after receiving the statement.
4. (Use A or B).
A. Defendant expressly promised to pay plaintiff the balance
due. [OR]
B. Defendant implicitly promised to pay plaintiff the amount set forth in the statement.
Defendant has not paid plaintiff the amount owed on the account.
$………., plus interest since …..(date)……
WHEREFORE plaintiff demands judgment for damages against defendant.
NOTE: Attach a copy of any accounts, statements, or other documents required to be attached or incorporated by rule 1.130.