replied 6 months ago.
something like thisIN THE DISTRICT COURT OF MARYLAND FOR MONTGOMERY COUNTYABC CONTRUCTION *
v. * Case No.: (###) ###-####0000
A/C AND HEATIN G *
COMPLAINT/BREACH OF CONTRACTCOMES NOW, the Plaintiff, ABC CONSTRUCTION (hereinafter referred to as Plaintiff), by and through the undersigned counsel of ATTORNEY, Esq., and respectfully ***** ***** A/C and Heating, (hereinafter referred to as Defendant) and states the following:1. That the Plaintiff is a Contractor for, but not limited to, construction and repair work of hair salons in the State of Maryland.
2. That the Defendant has been conducting business in the State of Maryland for more than one year prior to filing this Complaint.3. That on or about November 2, 2000 Plaintiff entered into a contract with the Defendant in order for the Defendant to complete Heating, Ventilation, and Air Conditioning services for two different hair salons.4. That the Contract provided for the Defendant to complete work at two hair salons one salon in Cockeysville and one salon in Owings Mill for a total price of seventeen thousand two hundred dollars ($17,200.00). (See Agreement, Attached as Exhibit 1).5. That on or about November 2, 2000, Plaintiff provided Defendant with a deposit of eight thousand five hundred dollars ($8,500.00) for both the Cockeysville and Owings Mill jobs.6. That on or about November 24, 2000, Plaintiff provided Defendant with another payment of one thousand two hundred dollars ($1,200.00).7. That on or about December 14, 2000, Plaintiff provided Defendant with another payment in the amount of two thousand dollars ($2,000.00).8. That on or about August 28, 2001, Plaintiff provided Defendant with another payment in the amount of three thousand five hundred dollars ($3,500.00).
9. That Defendant completed the Cockeysville job as per the parties’ agreement.10. That Defendant began work on the Owings Mill job; however never completed the job.11. That Plaintiff attempted to contact the Defendant on numerous occasions to determine why the job had not been completed.12. That on or about October 9, 2001, Plaintiff sent a letter to Defendant demanding that the work be completed at the Owings Mill job.
13. That Defendant never returned to the job site to complete the work that was already begun.14. That Plaintiff had to contract another company to complete the job that the Defendant was originally contracted to complete.15. That Plaintiff expended an additional six thousand six hundred seventy-eight dollars and forty-nine cents ($6,678.49) for another company to complete the rest of the work at the Owings Mill hair salon that Defendant was contacted to complete. (See Invoice 300, Invoice 325, and Proposal/Contract Attached hereto as Exhibits 2, 3, and 4).16. That Plaintiff paid the Defendant a total amount of fifteen thousand two hundred dollars ($15,200.00) towards the total amount for the job of seventeen thousand two hundred dollars ($17,200.00).17. That monies were demanded and the Defendant has refused to pay. (See Letter Dated April 16, 2002, Attached as Exhibit 5).18. That Defendant breached the terms of the contract by failing to complete the work at Owings Mill hair salon.19. That Plaintiff is requesting a judgment in the amount of four thousand six hundred seventy-eight dollars and forty-nine cents ($4,678.49)20. That the amount requested by the Plaintiff is determined by taking the additional expenses incurred by the Plaintiff in order to contract another company to complete the work at the Owings Mill hair salon which equals the amount of six thousand six hundred seventy-eight dollars and forty-nine cents ($6,678.49) and subtract the $2,000.00 remaining on the contract with the Defendant.21. That Defendant is in breach of the terms of the Contract for failure complete the work at the Owings Mill hair salon.WHEREFORE, Plaintiff, ABC Construction, jointly and severally, demands judgment against Defendant, A/C and Heating, in the amount of $4,678.49.Respectfully submitted,_______________________
Attorney for Plaintiff
Telephone NumberI DO SOLEMNLY DECLARE AND AFFIRM UNDER THE PENALTIES OF PERJURY THAT THE CONTENTS OF THE FOREGOING COMPLAINT/BREACH OF CONTRACT ARE TRUE AND CORRECT TO THE BEST OF MY KNOWLEDGE, INFORMATION, AND BELIEF.