In the early fall of the year, Allison Amato agreed to pay Michael Quinn $4,500 to paint the outside of her house. Quinn demanded $2,000 up front to purchase paint and other materials and as a deposit to help pay his workers. Allison paid the initial deposit, and on the day painting was set to begin, no one appeared on the job. Allison repeatedly attempted to reach Quinn, but she could only reach his voice mail. Two months went by after Allison realized she had been taken by Quinn. Her house was in bad need of painting, and she noticed that recent rains had caused additional damage. Now that cold weather had set in, she saw that she would not be able to have the house painted until the spring. As soon as the winter weather broke, Allison contacted Always Perfect Painting, a company that received rave reviews online. The initial appraisal assessed damage to her house over the winter from lack of paint in the amount of $2,500. In addition, Always Perfect Painting quoted a price of $5,500 for the job. Allison hired Always Perfect Painting to repair the damage and to do the paint job, paying the company a total amount of $8,000. As soon as the work was performed, she contacted a lawyer to begin a lawsuit against Quinn.

A lawsuit begins with a pleading called a complaint, drafted by an attorney or a paralegal. Using the scenario above, draft a complaint that includes the following:

  • The name of the case and the court in which the case is filed.
  • The names of the parties and a correctly formatted caption.
  • Numbered short paragraphs setting forth the facts of the case, including the grounds for liability of the defendant.
  • A clause at the end demanding judgment and damages, including all money damages Allison should claim in order to make her “whole.”
  • Create any information that is missing, such as the parties’ addresses, dates, and name of the court where the complaint will be filed.

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