| name | breach-of-purchase-agreement-complaint |
| title | Complaint for Breach of Purchase Agreement |
| description | Drafts a filing-ready U.S. complaint for breach of a purchase agreement. Trigger when the user requests a breach-of-contract complaint, forum-selection analysis, or remedy package for a real-estate or asset purchase dispute. |
| author | CaseMark |
| author_url | https://github.com/CaseMark/skills/tree/main/skills/legal/breach-of-purchase-agreement-complaint |
| license | Apache-2.0 |
| version | 0.1.0 |
| execution_mode | open |
| jurisdiction | us |
| practice | contracts |
| language | en |
| tags | ["drafting","litigation","pleading"] |
Complaint for Breach of Purchase Agreement
Produces a court-ready complaint with jurisdiction, liability elements, and damages precision for purchase-agreement disputes.
Prerequisites
Gather before drafting:
- Executed agreement — including amendments, riders, addenda, notices, cure letters, and payment records.
- Party data — legal names, entity types/formation states, addresses, registered agents.
- Transaction timeline — negotiation, execution, performance milestones, breach event, notice, and mitigation efforts with supporting evidence.
- Jurisdictional directives — target court, forum-selection and choice-of-law terms, arbitration scope, local filing requirements.
- Damages inputs — direct, consequential, incidental amounts; interest expectations; attorney-fee basis.
Workflow
1. Filing Scaffold
Generate caption, court heading, case-number placeholder, title of action, attorney block, and party designation blocks in court-compliant order.
2. Jurisdiction and Venue
Plead each ground with paragraph-supported facts:
- Subject-matter jurisdiction — diversity, federal question, or state-law basis.
- Personal jurisdiction — defendant presence, contacts, or minimum contacts.
- Venue — contract formation/performance/breach location; defendant residence.
- Forum-selection / choice of law — enforce contractual forum and governing-law clauses; note arbitration scope.
3. Parties
For each party: legal name, capacity/status, role in transaction, full address. Include aliases, registered agent (defendant), and guarantors/assignees/successors as needed.
4. Factual Chronology
Numbered paragraphs in strict temporal order. Attach exhibit references to each key event.
5. Breach of Contract Cause of Action
Map each element to specific facts and exhibits:
- Formation — valid agreement, authority, consideration, essential terms.
- Duty — exact breached provision and expected performance.
- Breach — specific act/omission, date, breach-notice timeline.
- Plaintiff performance — performance completed or valid excuse.
- Causation and damages — direct link between breach and resulting harm.
6. Damages Ledger
Itemize by category with calculation method and supporting evidence:
