[Insert caption.

COMPLAINT

Plaintiff states:

1. Plaintiff is an adult resident of ________ County, Michigan.

2. Defendant is a Michigan corporation with its principal place of business in

________ County, Michigan.

3. Defendant entered into a contract with Plaintiff to construct a greenhouse

according to Plaintiff’s plans and specifications for a total price of $45,000. A copy
of the contract is attached as exhibit 1.

4. Plaintiff has paid Defendant the sum of $35,000 pursuant to the contract.

5. Defendant began to construct the greenhouse. However, the building measured 40

feet by 40 feet, not 40 feet by 50 feet as specified. Moreover, Defendant used double-
paned glass rather than triple-paned glass on that portion of the building it erected.

6. Plaintiff promptly brought these matters to Defendant’s attention during

construction. Defendant promised and agreed to replace the double-paned glass with
triple-paned glass and to accept $37,000 rather than $45,000 as the total purchase
price in light of the nonconforming size of the building.

7. Defendant did not complete construction of the building and advised Plaintiff on
[date], that it was unwilling or unable to complete the construction. Defendant also
did not replace the double-paned glass with triple-paned glass.

8. Plaintiff retained the services of the Acme Greenhouse Building Company to

replace the double-paned glass with triple-paned glass and to complete the
construction of the greenhouse according to the original specifications, except at the
smaller size. Construction has been acceptably completed at a cost to Plaintiff of
$18,500, net of the double-paned glass that Acme Greenhouse Building Company
was able to exchange and receive credit for.

9. Defendant’s conduct as described in this complaint constituted a breach of the

contract between the parties.

10. Plaintiff has been damaged by Defendant’s breach in the amount of $16,500,
which consists of the increased price Plaintiff has had to pay, plus the amount of
$9,500 in rent that Plaintiff had to pay for another greenhouse during the two and
one-half month delay that Defendant’s nonperformance caused.

PLAINTIFF REQUESTS that this court enter judgment in her favor and against
Defendant in the amount of $26,000, plus interest at the statutory rate from the date of
filing and that the court grant her such other and different relief as the court deems
warranted.

[Firm name]

By: /s/____________________________
Dated: ____________________ [Typed name of attorney] (P________)
Attorney for Plaintiff
[Address, telephone]

[Optional jury demand.]