IN THE CIRCUIT COURT OF [COUNTY/CITY NAME]

COMMONWEALTH OF VIRGINIA

[PLAINTIFF FULL LEGAL NAME],
  Plaintiff,

v. Civil Action No.: ______

[DEFENDANT FULL LEGAL NAME],
  Defendant.

COMPLAINT

(Breach of Contract)

[// GUIDANCE: This template is drafted for a garden-variety breach-of-contract action in Virginia Circuit Court. Tailor each bracketed placeholder and optional section to the facts of your case. Keep Virginia’s fact-pleading standard (Rule 1:4) in mind—conclusory allegations are insufficient.]

TABLE OF CONTENTS

1. Parties ..................................................................................... ¶ 1
2. Jurisdiction and Venue .............................................................. ¶¶ 2-3
3. Factual Allegations ................................................................ ¶¶ 4-13
4. Count I – Breach of Contract ............................................. ¶¶ 14-18
5. Damages .................................................................................. ¶¶ 19-21
6. Conditions Precedent ............................................................ ¶ 22
7. Prayer for Relief ...................................................................... ¶ 23
8. Jury Demand (Optional) ....................................................... ¶ 24
9. Reservation of Rights ............................................................ ¶ 25
10. Request for Service ................................................................ ¶ 26
11. Signature Block & Certificate ............................................ p. 10

PARTIES

1. Plaintiff [PLAINTIFF NAME] (“Plaintiff”) is a [TYPE OF ENTITY / INDIVIDUAL], organized and existing under the laws of [STATE OF ORGANIZATION] with its principal place of business at [ADDRESS] and is authorized to do business in Virginia.

2. Defendant [DEFENDANT NAME] (“Defendant”) is a [TYPE OF ENTITY / INDIVIDUAL], with its principal place of business/residence at [ADDRESS]. Defendant transacts business in this Commonwealth and is subject to the personal jurisdiction of this Court.

JURISDICTION & VENUE

3. This Court has subject-matter jurisdiction because the amount in controversy exceeds $25,000, exclusive of interest and costs. Personal jurisdiction is proper under Virginia’s long-arm statute and Rule 3:1.

4. Venue is proper in this Circuit because (i) the cause of action arose here, (ii) Defendant resides/has its principal place of business here, and (iii) the contract was negotiated and/or performed here.

[// GUIDANCE: For Category A venue, specify facts tying the claim to the forum. Attach a separate Motion to Transfer if needed.]

FACTUAL ALLEGATIONS

5. On or about [DATE], Plaintiff and Defendant entered into a written agreement titled “[CONTRACT NAME]” (the “Contract”). A true and correct copy of the Contract is attached as Exhibit A.

6. Under the Contract, Plaintiff agreed to:
 a. [Describe primary obligations]
 b. [Describe any secondary obligations].

7. In exchange, Defendant agreed to:
 a. Pay Plaintiff $[AMOUNT] according to the payment schedule set forth in Section [§] [NUMBER] of the Contract; and
 b. [Other obligations].

8. Plaintiff fully performed, or substantially performed, all of its material obligations under the Contract, or Plaintiff’s performance was excused.

9. Defendant materially breached the Contract by:
 a. Failing to pay the [AMOUNT] due on [DUE DATE];
 b. [Describe any additional breaches].

10. On [DATE], Plaintiff provided Defendant with written notice of default and an opportunity to cure within [NUMBER] days, as required by Section [§] [NUMBER] of the Contract. Defendant failed and refused to cure.

11. As a direct and proximate result of Defendant’s breach, Plaintiff has suffered damages in excess of $[AMOUNT], exclusive of prejudgment interest, attorneys’ fees, and costs.

12. All conditions precedent to filing this action have occurred, have been performed, or have been waived.

13. Plaintiff expressly reserves the right to amend this Complaint to assert additional facts or causes of action revealed through discovery.

COUNT I – BREACH OF CONTRACT

14. Plaintiff realleges and incorporates by reference paragraphs 1-13.

15. A valid, enforceable Contract exists between Plaintiff and Defendant.

16. Plaintiff performed its obligations under the Contract, or such performance was excused.

17. Defendant breached the Contract as set forth above.

18. Defendant’s breach has caused Plaintiff to sustain monetary damages, including but not limited to unpaid contract sums, incidental and consequential damages, interest, and attorneys’ fees as allowed by law and the Contract.

DAMAGES

19. Plaintiff seeks recovery of:
 a. Principal amount due: $[AMOUNT];
 b. Pre- and post-judgment interest at the legal rate or the rate specified in the Contract, whichever is higher;
 c. Incidental and consequential damages in an amount to be proven at trial;
 d. Reasonable attorneys’ fees and costs as provided by the Contract or applicable law.

20. Plaintiff’s damages continue to accrue.

21. Plaintiff is entitled to recover the foregoing amounts together with such other and further relief as the Court deems just and proper.

CONDITIONS PRECEDENT

22. All contractual and statutory conditions precedent to bringing this action have been satisfied, performed, or lawfully excused.

PRAYER FOR RELIEF

23. WHEREFORE, Plaintiff respectfully requests that the Court enter judgment in its favor and against Defendant as follows:
 a. Awarding damages in an amount no less than $[AMOUNT];
 b. Awarding pre- and post-judgment interest;
 c. Awarding attorneys’ fees and costs as permitted;
 d. Awarding such other and further relief as the Court deems just and proper.

JURY DEMAND (Optional)

24. Pursuant to Rule 3:21 of the Rules of the Supreme Court of Virginia, Plaintiff demands a trial by jury on all issues so triable.

[// GUIDANCE: Strike this paragraph if Plaintiff elects to proceed without a jury.]

RESERVATION OF RIGHTS

25. Plaintiff reserves the right to pursue all additional remedies, including equitable relief, and to amend this Complaint in accordance with the Rules of Court.

REQUEST FOR SERVICE

26. Plaintiff requests the Clerk to issue a Summons for [DEFENDANT NAME], to be served by the Sheriff of [COUNTY/CITY] at [SERVICE ADDRESS], together with a copy of this Complaint and plaintiff’s exhibits.

[// GUIDANCE: If using private process or the Secretary of the Commonwealth, revise this paragraph accordingly and prepare the requisite forms.]

SIGNATURE BLOCK & CERTIFICATE

Respectfully submitted,

plaintext

[ATTORNEY NAME] (VSB No. [#####])
[FIRM NAME]
[STREET ADDRESS]
[CITY], VA [ZIP]
Telephone: [###-###-####]
Facsimile: [###-###-####]
Email: [EMAIL ADDRESS]
Counsel for Plaintiff

Verification (If Required)

plaintext
I, [PLAINTIFF REPRESENTATIVE NAME], hereby affirm under penalty of perjury that the factual allegations contained in the foregoing Complaint are true and correct to the best of my knowledge, information, and belief.

[NAME], [TITLE]
Date: _______
[// GUIDANCE: Virginia does not require a verified complaint in ordinary contract actions, but verification may be advisable if you anticipate affirmative defenses challenging standing or factual specificity.]

ATTACHMENTS

• Exhibit A – Executed Contract
• Exhibit B – Notice of Default (if any)
• Civil Action Cover Sheet (required by the Clerk).

[// GUIDANCE: Ensure all exhibits are properly labeled and redacted, if necessary, before filing.]

DISCOVERY LIMITS & EARLY CASE MANAGEMENT (Informational – Not Filed With Complaint)

• Interrogatories: Limited to 30, including sub-parts (Rule 4:8).
• Requests for Admission: Limited to 30, including sub-parts (Rule 4:11).
• Depositions: No presumptive numerical limit; each oral deposition is limited to 7 hours on one day absent court order or stipulation (Rule 4:5).
• Initial disclosures are not mandatory; consider a tailored discovery plan and scheduling order per local practice.

[// GUIDANCE: Circulate these limits internally and incorporate them into your discovery calendar; they do not belong in the pleading.]

[END OF DOCUMENT]