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The following is a sample Complaint appearing with the exception of this introduction much the way it would when the Complaint is filed with the Court.  

IN THE STATE COURT OF FULTON COUNTY

STATE OF GEORGIA

 

JOHN DOE,                                     )

            Plaintiff,                                )

                                                           )  Civil Action File 

vs.                                                      )  No. _______________

JANE ROE                                       )

           Defendant.                            )

 COMPLAINT

            COMES NOW, John Doe, Plaintiff in the above styled action, and files and serves this Complaint and shows this Court as follows:

1.                   

            Defendant is subject to the jurisdiction of this Court. 

2.                   

            Venue in this Court is proper. 

3.                   

            Defendant is in breach of the contract a copy of which attached as Exhibit A and Defendant owes Plaintiff not less than $22,320.00 as reflected in the statement to Defendant a copy of which is attached hereto as Exhibit B.

4.                   

            Defendant is indebted to Plaintiff for pre-judgment interest at the legal rate. 

5.                   

            Defendant is indebted to the Plaintiff in the amount of 15% of first $500.00 of principal and interest and 10% of all principal and interest thereafter as shown above for attorney's fees as specified in Exhibit "A"; however, if the principal sum set forth in paragraph two (2) above is paid within ten (10) days from service herewith, then the attorney's fees provision of the contract attached as Exhibit "A" will not be enforced.

6.                   

            Defendant is indebted to Plaintiff for attorneys fees and expenses as Defendant has been stubbornly litigious and has unnecessarily expanded this litigation. 

             WHEREFORE, Plaintiff demands judgment against Defendant as follows:

            (a)            principal in the amount of $22,320.00;

            (b)            pre-judgment interest to date together with interest accruing from this date to the date of judgment;

            (c)            attorneys' fees and expenses; and

            (d)            costs of this action.

 

                                                                        LAW OFFICES OF

                                                                        DAVID J. REED

 

 

 

                                                                        ____________________

                                                                        David J. Reed

                                                                        State Bar No. 597601

                                                           

1503 Bombay Lane

Oakbrook Centre

Roswell, GA  30076

(770) 751-0900

 
 
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Last modified: December 05, 2006