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IN THE COUNTY COURT, FOURTH

JUDICIAL CIRCUIT, IN AND FOR

DUVAL COUNTY, FLORIDA

CASE NO.:

DIVISION:

,

Plaintiff,

v.

,

a Florida corporation,

Defendant.

________________________________/

COMPLAINT

The Plaintiff, _________________________, (hereinafter Plaintiff) sues the

Defendant, ___________________________, a corporation (hereinafter Defendant),

and alleges as follows:

1. This is an action for damages that does not exceed $15,000.00.

2.. ___________________________________, a corporation, is authorized to do

business in the State of Florida, and is doing business in Duval County, Florida, by virtue of the

fact that it conducts business affairs at [street address], Jacksonville, Florida.

3. On or about [date], Plaintiff and Defendant entered into an agreement wherein

Plaintiff would provide ___________________ services to Defendant for consideration of

$____________________ per month. A copy of the contract is attached as Exhibit A.

4. On or about [date], Plaintiff and Defendant added an addendum pursuant to the

terms of the contract stating __________________________________________________. A

copy of the addendum is attached as Exhibit B.

5. Per the terms of the agreement, any and all changes to the agreement must be

made in writing..

6. On or about [date], Plaintiff sought to resume cleaning duties in accordance with

the above mentioned agreement and addendum, however, Defendant denied Plaintiff the

opportunity to comply with the agreement.

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7. Defendant prevented Plaintiff from performing agreed upon services until [date].

8. Defendant refused to compensate Plaintiff during the period of time in which

Defendant prevented Plaintiff from performing services under the agreement.

9. Defendant failed to properly compensate Plaintiff at the agreed upon rate during

the period of time when Defendant prevented Plaintiff from performing agreed upon services.

10. Due to the failure of the Defendant to pay Plaintiff in accordance with the

agreement mentioned above, Plaintiff has been required to retain the undersigned law firm for

the prosecution of this suit. The Plaintiff has agreed to pay and the attorney has agreed to accept

any Court awarded attorneys fees and costs.

11. Plaintiff has entered into a pure contingency contract with the undersigned which

specifically provides for attorneys fees for litigating entitlement and amount of attorneys fees

after making recovery for the Plaintiff.

WHEREFORE, Plaintiff demands judgment in the amount of $___________________,

together with interest thereon, costs and attorney fees with prejudgment interest pursuant to the

terms of the agreement.

DEMAND FOR JURY TRIAL

Plaintiff demands trial by jury.

Respectfully submitted,

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EXHIBIT A

EXHIBIT B