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4 Elements of a Breach of Contract Claim (and more) The existence of a contract; Performance by the plaintiff or some justification for nonperformance; Failure to perform the contract by the defendant; and, Resulting damages to the plaintiff.
Include references to the terms that were breached, quoting relevant sections of the contract, and detail how the other party was in breach of said term(s). List the responsibilities and obligations you deem to be unmet, and explain how the other party is in breach of them.
The existence of a contract; Performance by the plaintiff or some justification for nonperformance; Failure to perform the contract by the defendant; and, Resulting damages to the plaintiff.
In order to sue successfully for damages arising out of a breach of contract, you must demonstrate that there was a contract in existence, that the other side failed to perform their part of the bargain satisfactorily and that you suffered a loss as a result.
You can try to reach an agreement with the plaintiff. If you reach an agreement BE CAREFUL to confirm the agreement in writing, and if the plaintiff agrees to dismiss the lawsuit, make sure it is actually dismissed before the time is up for you to file your answer. Otherwise, default may still be entered against you.