| name | purchase-agreement-breach-complaint |
| title | Complaint for Breach of Purchase Agreement |
| description | 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. |
| author | CaseMark |
| author_url | https://github.com/CaseMark/skills/tree/main/skills/legal/purchase-agreement-breach-complaint |
| license | Apache-2.0 |
| version | 0.1.0 |
| execution_mode | open |
| jurisdiction | us |
| practice | real-estate |
| language | en |
| tags | ["drafting","litigation","pleading"] |
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.
