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:
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.
1---2name: purchase-agreement-breach-complaint3description: Drafts a U.S. civil complaint for breach of a real estate purchase agreement, covering jurisdiction, venue, parties, contract terms, breach allegations, damages, and remedies including specific performance. Use when preparing a breach of purchase agreement complaint, real estate contract dispute pleading, or specific performance action.4license: Apache-2.05---67# Complaint for Breach of Purchase Agreement89Drafts a complaint asserting breach of a real estate purchase agreement with jurisdiction-appropriate pleading structure, breach elements, damages analysis, and remedy-specific allegations.1011## Prerequisites12131. **Executed agreement** — purchase agreement plus all addenda, disclosures, and amendments.142. **Property identification** — street address, legal description, parcel/APN.153. **Party information** — full legal names, entity types, formation states, principal places of business, registered agents.164. **Performance timeline** — deposits, escrow instructions, conditions precedent, inspections, financing milestones.175. **Breach evidence** — notice of breach, cure demands, refusal or failure to perform, key communications.186. **Damages support** — contract price, market value, carrying costs, replacement transaction costs, mitigation efforts.197. **Jurisdiction and venue** — forum selection clause, place of performance, defendant residence or business location, party citizenship if diversity.208. **Requested remedies** — damages, specific performance, injunctive relief, attorneys' fees, interest, costs.2122If any prerequisite is missing, pause and ask — do not assume or fill gaps.2324## Output Structure2526### Step 1 — Caption and Preliminary Statement2728Draft the caption with court name, division, parties, case number placeholder, and jury demand if applicable.2930Follow with a preliminary statement (3–6 sentences) summarizing the contract, the breach, and relief sought.3132### Step 2 — Jurisdiction and Venue3334| Element | Plead |35|---|---|36| Subject matter jurisdiction | State law basis, diversity (citizenship + amount in controversy), or federal question |37| Forum selection / choice-of-law | Quote clause; plead compliance or enforceability |38| Venue | Statutory basis tied to property location, performance location, or defendant residence |3940`[VERIFY: Local rules for jurisdiction and venue pleading requirements.]`4142### Step 3 — Parties4344For each party: role in transaction, entity type, formation state, address, and agency or authority facts. Distinguish individuals from entities.4546### Step 4 — Factual Allegations4748Draft a chronological narrative covering: negotiation, execution, material terms, performance obligations, breach, notice, and cure demand/failure. Cite specific contract sections and dates.4950### Step 5 — Cause of Action (Breach of Contract)5152Plead each element with supporting allegations:5354| Element | Allegations Required | Source |55|---|---|---|56| Valid contract | Offer, acceptance, consideration, parties, signatures, effective date | Executed agreement |57| Plaintiff performance | Deposits paid, conditions satisfied, readiness and ability to close | Escrow records |58| Defendant breach | Specific obligation breached, date of breach, failure or refusal to perform | Notices, correspondence |59| Causation and damages | Direct and foreseeable losses resulting from breach | Damages worksheet |6061### Step 6 — Remedy-Specific Allegations6263Include as applicable:6465- **Specific performance** — allege uniqueness of real property, inadequacy of legal remedy, plaintiff's readiness and ability to perform66- **Injunctive relief / lis pendens** — allege irreparable harm, property at risk of transfer or encumbrance67- **Escrow relief** — allege entitlement to deposit return or disbursement6869### Step 7 — Damages7071| Category | Measure | Source |72|---|---|---|73| Benefit of bargain | Contract price vs. market value | Appraisal, listing data |74| Consequential | Foreseeable losses (financing, relocation, taxes) | Invoices, statements |75| Incidental | Transactional costs, escrow fees | Receipts |76| Reliance | Out-of-pocket expenditures in reliance on contract | Financial records |77| Mitigation | Actions taken to reduce loss; offset amounts | Timeline, records |7879### Step 8 — Prayer for Relief8081Number each request:8283- [ ] Compensatory damages (specific amount or "according to proof" per local rule) `[VERIFY]`84- [ ] Specific performance (if property is unique and legal remedy inadequate)85- [ ] Pre-judgment and post-judgment interest at statutory rate `[VERIFY: applicable rate]`86- [ ] Attorneys' fees and costs (only if contractual or statutory basis exists)87- [ ] Equitable relief tied to escrow or title8889### Step 9 — Execution and Filing Components9091- **Verification** — include only if jurisdiction requires `[VERIFY]`92- **Signature block** — attorney name, bar number, firm, address, contact93- **Exhibits** — contract, addenda, notices, escrow instructions, key correspondence94- **Civil cover sheet** — attach per local court rules `[VERIFY]`9596## Guidelines9798- Identify property with both street address and legal description.99- Quote or attach only the contract provisions necessary to establish breach.100- Plead conditions precedent as required by local rules `[VERIFY]`.101- Do not request attorneys' fees absent a contractual or statutory basis.102- Do not include settlement communications or inadmissible offers (FRE 408).103- Redact confidential personal information per court privacy rules.104- For any jurisdiction-specific assumption not confirmed by provided materials, flag with `[VERIFY]`.105- Output is draft work product for attorney review — not a filing-ready document.
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