Sample Civil Complaint Breach of Contract Florida


The plaintiff wrongly relied on the defendant`s promise that the parties would be married and live together in the apartment. . As a result of the defendant paying mortgage payments or other equivalent rent to the plaintiff, the defendant permanently or indefinitely deprived the plaintiff of his property. COMES NOW, the plaintiff, Layla REDACTED by and through her undersigned lawyer, sues the defendant, Jim REDACTED, and claims the following: In December 2010, the plaintiff returned to her home country, Belgium, pending approval of her fiancé visa. The circumstances are such that it would be unfair for the defendant to retain the benefit without paying the fair value. This is a lawsuit for breach of the implied contract, confiscation of promissory notes, unjust enrichment, conversion, reform, constructive trust and resulting trust. The plaintiff purchased the property and included the defendant`s name in the deed, with the intention that the defendant would soon be her husband. Since the end of the relationship, the defendant has completely stopped paying for the mortgage, so the plaintiff must pay for the property in which the defendant currently lives. The defendant knows that the plaintiff is granting her a benefit for which she receives no compensation. Because of the defendant`s intimate relationship with the plaintiff, the defendant acquired property that he did not pay for and therefore should not keep with fairness and conscience. In February 2012, the plaintiff began planning a trip to visit her fiancé at her home in Ocala, but after further discussion of the visit, the defendant told the plaintiff that he did not want her to visit him. Shortly after that conversation, the defendant decided to end his relationship and engagement and informed the plaintiff that he had decided to live in his home without her. By paying the mortgage on the house in which the defendant lives, on the understanding that the defendant would make the payments, the plaintiff granted an advantage to the defendant.

. For this reason, the plaintiff requests that the judgment be registered and awarded in his favor against the defendant: damages, injunction, costs, attorneys` fees and expenses, expert fees, damages, interest, the goods will be auctioned to the plaintiff with the proceeds and any other compensation that this court deems fair and reasonable. The defendant should reasonably have heeded the plaintiff`s promise of confidence. The defendant has been chronically late since the beginning of his agreement with the plaintiff and/or has missed payments on the mortgage. Witness fees, damages, interest, property will be auctioned with the proceeds to the plaintiff and any other relief that this court deems just and reasonable. Since the defendant did not respect his wishes, it is now unfair that he should be included in the document and reformed to reflect these changes. . Injustice could only be avoided by enforcing the promise. The plaintiff allowed the defendant to be named on the title to the property, provided that he made the mortgage payment while making payments on the $12,000.00 loan used for the down payment, which was exclusively in her name. During her absence from the defendant, the plaintiff began planning her marriage and preparing for life with her new husband. . The plaintiff has asked the defendant to make the agreed payment, but the defendant denies and denies the plaintiff access to his property.

The plaintiff began paying the loan in August 2011, the defendant was supposed to start paying the mortgage in September 2011, but did not start payments until October 2011. In the meantime, the plaintiff relied on her fiancé, the defendant, to find them a house to buy. The defendant was not entitled to such a large amount of funding, so the plaintiff herself applied for and received funding. The defendant found a property that the plaintiff had purchased on the assumption that she and the defendant would live there as husband and wife. The plaintiff purchased exclusively all furniture and supplies for the property. . For this reason, the plaintiff requests that the judgment be registered and awarded in his favor against the defendant: damages, injunction, costs, fees and expenses of lawyer, expert. . . .