BREACH OF CONTRACT COMPLAINT PDF



Breach Of Contract Complaint Pdf

SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF. SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK REBECCA BROADWAY LIMITED PARTNERSHIP and SPRECHER/FORLENZA PRODUCTIONS INC., Plaintiffs, -against- MARK CHRISTOPHER HOTTON, SHERRI HOTTON, and JOHN/JANE DOES 1-3, Defendants. Index No. VERIFIED COMPLAINT Plaintiffs Rebecca Broadway Limited Partnership (the “Partnership”) and Sprecher/, CIVIL COMPLAINT BREACH OF CONTRACT The Self-Help Center provides a free document review service. To obtain an appointment to have your documents reviewed, you must first fully complete the forms. Please use black ink. Self-Help Center Locations: Information L-1009 (Rev. March 2012) CIVIL CASE TIME SCHEDULE SUPERIOR COURT OF CALIFORNIA, COUNTY OF ORANGE CIVIL CASE TIME ….

[PDF] Complaint Breach of Contract DRAFT Free Download PDF

I .. I~. Parlux v. Shawn Carter - complaint.pdf - Free download as PDF File (.pdf), Text File (.txt) or read online for free., Complaint Page 5 of 10 28. Accordingly, Defendant Makemson is liable in damages to Welch in excess of $30,000.00, the exact amount to be proven at trial, arising out of Makemson’s negligent breach of her fiduciary duty to Welch. COUNT II: RECKLESS BREACH OF FIDUCIARY DUTY 29. Plaintiff re-alleges the allegations set forth in Paragraphs 1-24 above.

Parlux v. Shawn Carter - complaint.pdf - Free download as PDF File (.pdf), Text File (.txt) or read online for free. Pro Se 4 (Rev. 12/16) Complaint for a Civil Case Alleging Breach of Contract V. Certification and Closing Under Federal Rule of Civil Procedure 11, by signing below, I certify to the best of my knowledge, information, and belief that this complaint: (1) is not being presented for …

Most contracts end when both parties have fulfilled their contractual obligations, but it's not uncommon for one party to fail to completely fulfill their end of the contract agreement.Breach of contract is the most common reason contract disputes are brought to court for resolution. 02/05/2018В В· In case any of the parties breaches the contract, the other party has a right to file a lawsuit against the party that breached the contract. The letter should include the details regarding the breach. The letter should include the contact details of the recipient, subject and the details of the contract that has been breached.

Pro Se 4 (Rev. 12/16) Complaint for a Civil Case Alleging Breach of Contract V. Certification and Closing Under Federal Rule of Civil Procedure 11, by signing below, I certify to the best of my knowledge, information, and belief that this complaint: (1) is not being presented for … The breach of contract demand letter is a pre-trial court document which may be used in any litigation proceeding at a later time. There are usually demands that are made in the letter that allow the parties to resolve the matter before resorting to legal action. Depending on the agreement and the violation, it will be up to the parties involved to settle the breach.

complaint for breach of contract, unjust enrichment, conversion, breach of trust, equitable accounting, and for declaratory and injunctive relief demand for jury trial case 1:17-cv-06687 document 1 filed 09/01/17 page 1 of 22 21/08/2019В В· A Breach of Contract Notice (which can also be called a Notification of Contract Breach) is a document by which a party to a contract informs the other party that they have breached the agreement. A breach simply means that one party didn't fully perform the obligations they were supposed to under the contract.

SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK REBECCA BROADWAY LIMITED PARTNERSHIP and SPRECHER/FORLENZA PRODUCTIONS INC., Plaintiffs, -against- MARK CHRISTOPHER HOTTON, SHERRI HOTTON, and JOHN/JANE DOES 1-3, Defendants. Index No. VERIFIED COMPLAINT Plaintiffs Rebecca Broadway Limited Partnership (the “Partnership”) and Sprecher/ CIVIL COMPLAINT BREACH OF CONTRACT The Self-Help Center provides a free document review service. To obtain an appointment to have your documents reviewed, you must first fully complete the forms. Please use black ink. Self-Help Center Locations: Information L-1009 (Rev. March 2012) CIVIL CASE TIME SCHEDULE SUPERIOR COURT OF CALIFORNIA, COUNTY OF ORANGE CIVIL CASE TIME …

Sample California complaint for breach of contract and. The breach of contract demand letter is a pre-trial court document which may be used in any litigation proceeding at a later time. There are usually demands that are made in the letter that allow the parties to resolve the matter before resorting to legal action. Depending on the agreement and the violation, it will be up to the parties involved to settle the breach., DOWNLOAD PDF. DOWNLOAD PDF . Share. Embed. Description Download Complaint Breach of Contract DRAFT Comments. Report "Complaint Breach of Contract DRAFT" Please fill this form, we will try to respond as soon as possible. Your name. Email. Reason. Description. Submit Close. Share & Embed "Complaint Breach of Contract DRAFT" Please copy and paste this embed script to where you want to ….

IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT IN

Breach of contract complaint pdf

Breach of contract complaint against Dennis Hastert (PDF. 15/08/2011В В· You are hereby summoned to answer the complaint in this action and to serve a copy of your answer, or if the complaint is not served with this summons, to serve a notice of appearance, on the Plaintiff within 20 days after the service of this summons, exclusive of the day of service (or within 30 days after the service is, Filing a Breach of Contract Complaint. A party to a contract dispute who feels the other party is in breach of the contract, should provide a breach of contract letter to the breaching party that he will be taking action for breach of contract. This is the first, formal step to resolving the issue. Sending a dated breach of contract letter.

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Breach of contract complaint pdf

CIVIL COMPLAINT SAMPLE California Courts. CIVIL COMPLAINT BREACH OF CONTRACT The Self-Help Center provides a free document review service. To obtain an appointment to have your documents reviewed, you must first fully complete the forms. Please use black ink. Self-Help Center Locations: Information L-1009 (Rev. March 2012) CIVIL CASE TIME SCHEDULE SUPERIOR COURT OF CALIFORNIA, COUNTY OF ORANGE CIVIL CASE TIME … 15/09/2019 · When one party to a contract fails to perform his or her obligation under it without a valid excuse, he or she is in breach of contract. If a contract that you signed is not being fulfilled, you may wish to write to the other party about the breach..

Breach of contract complaint pdf


As a proximate result ofDefendant's breach ofthe contract, as set forth above, Plaintiff has suffered damage in an amount to be shown according to proof at trial, but not limited to, the cost of repairing and replacing the defective materials and workmanship, testing and investigation of A. Count I - Breach of Contract Defendant sets forth both a demurrer to Count I and objects to this count for lack of specificity. This court sustains the objections to Count I based on insufficient specificity. To establish a cause of action for breach of contract, the plaintiff must allege (1) the existence o f

COMPLAINT—Contract Code of Civil Procedure, § 425.12 Form Approved for Optional Use Judicial Council of California PLD-C-001 [Rev. January 1, 2007] STREET ADDRESS: exceeds $10,000 but does not exceed $25,000 ACTION IS RECLASSIFIED by this amended complaint or cross-complaint from unlimited to limited 3. a. Each plaintiff named above is a 25/04/2016 · Breach of contract complaint against Dennis Hastert Contents. Original Document (PDF) » Related Article » Contributed by: Tom Palmer, The Chicago Tribune « Page Note 1 of 6 0 » To print the

COMPLAINT FOR BREACH OF CONTRACT CLAIM NOT SUBJECT TO MANDATORY ARBITRATION COMES NOW Plaintiff Slayden/Sundt, a Joint Venture, and for the causes of action against Defendant Multnomah County, complains and alleges as follows: I. PARTIES 1.1 Pro Se 4 (Rev. 12/16) Complaint for a Civil Case Alleging Breach of Contract V. Certification and Closing Under Federal Rule of Civil Procedure 11, by signing below, I certify to the best of my knowledge, information, and belief that this complaint: (1) is not being presented for …

sounds in negligence, breach of contract and breach of warranties, among other things. 25. The Complaint in the Omnibus action alleges that Morrison Homes, Inc. is responsible for damages as a result of the construction defects caused by Subcontractor. 26. Despite being placed on notice of the Omnibus action, Insurer has refused to View Complaint for Breach of Verbal or Oral Contract; View Complaint regarding Breach of contract, Fair dealing, Fraud, Conversion, Accounting, Trade Secrets Act. Agreement to Merge Businesses; View Complaint regarding Breach of Contract, Implied Contract, Good Faith and Fair Dealing, Promissory Estoppel, Emotional Distress

Some of the forms, such as the form for a generic complaint, apply to different types of cases. Others apply only to specific types of cases. Be careful to use the form that fits your case and the type of pleading you want to file. Be careful to change the information the form asks for to fit the facts and circumstances of your case. complaint for: (1) breach of contract - violation of the implied covenant of good faith and fair dealing (2) intentional interference with contractual relations; (3) violation of cal. civ. code §§ 1750, et seq.; (4) violation of cal. bus. & prof. code § 17200, et seq.; (5) declaratory relief pursuant to the declaratory judgment act, 28 u.s.c. § 2201 jury trial demanded case 3:16-cv-06450

Parlux v. Shawn Carter - complaint.pdf - Free download as PDF File (.pdf), Text File (.txt) or read online for free. 21/08/2019В В· A Breach of Contract Notice (which can also be called a Notification of Contract Breach) is a document by which a party to a contract informs the other party that they have breached the agreement. A breach simply means that one party didn't fully perform the obligations they were supposed to under the contract.

Legal Malpractice v. Breach of Fiduciary Duty Determining

Breach of contract complaint pdf

SUPERIOR COURT OF CALIFORNIA COUNTY OF ORANGE SELF. Pro Se 4 (Rev. 12/16) Complaint for a Civil Case Alleging Breach of Contract V. Certification and Closing Under Federal Rule of Civil Procedure 11, by signing below, I certify to the best of my knowledge, information, and belief that this complaint: (1) is not being presented for …, complaint for breach of contract, unjust enrichment, conversion, breach of trust, equitable accounting, and for declaratory and injunctive relief demand for jury trial case 1:17-cv-06687 document 1 filed 09/01/17 page 1 of 22.

SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF

Free Breach of Contract Demand Letter PDF Word. sounds in negligence, breach of contract and breach of warranties, among other things. 25. The Complaint in the Omnibus action alleges that Morrison Homes, Inc. is responsible for damages as a result of the construction defects caused by Subcontractor. 26. Despite being placed on notice of the Omnibus action, Insurer has refused to, sounds in negligence, breach of contract and breach of warranties, among other things. 25. The Complaint in the Omnibus action alleges that Morrison Homes, Inc. is responsible for damages as a result of the construction defects caused by Subcontractor. 26. Despite being placed on notice of the Omnibus action, Insurer has refused to.

complaint for breach of contract, unjust enrichment, conversion, breach of trust, equitable accounting, and for declaratory and injunctive relief demand for jury trial case 1:17-cv-06687 document 1 filed 09/01/17 page 1 of 22 07/09/2019В В· A Breach of Contract Notice (which can also be called a Notice to Rectify a Breach of Contract) is a document by which a party to a contract informs the other party that they have breached the agreement. A breach simply means that one party didn't fully perform the obligations they were supposed to under the contract.

DOWNLOAD PDF. DOWNLOAD PDF . Share. Embed. Description Download Complaint Breach of Contract DRAFT Comments. Report "Complaint Breach of Contract DRAFT" Please fill this form, we will try to respond as soon as possible. Your name. Email. Reason. Description. Submit Close. Share & Embed "Complaint Breach of Contract DRAFT" Please copy and paste this embed script to where you want to … her fiduciary duty by reason of this direct conflict.8 Such a breach gives rise to an action on behalf of the client for proximately-resulting damages. 9 II. Asserting Claims for Both Legal Malpractice and Breach of Fiduciary Duty When defense counsel reviews a complaint alleging both legal malpractice and breach of …

Plaintiff will include a Verification with their Complaint, where they state under penalty of perjury that everything in the Complaint is true to the best of their knowledge. Verification is required for some types of cases and optional in others. Read the Complaint carefully, to determine if it is verified. The Common Breach of Contract Examples Breach of Contract Scenario 1 "My wife and I decided we wanted a brick outdoor wood fire oven. We did some shopping around and found a company that did designs we really liked for reasonable prices.

sample breach of contract, common counts, and fraud complaint. David Jordan, Esq. State Bar # 69052 LAW OFFICES OF DAVID JORDAN 222 West Broadway, Suite 500 In breach of clause ___ of the contract, the Defendant had failed to deliver the Goods to the Plaintiff at all. By reason of the Defendant’s breach of contract, the Plaintiff has suffered loss and damage.

Every single day, a contract form is signed by someone around the globe to imply a service agreement and approve the terms and conditions of an authorized person. However, on the other side of the planet, there are also those who keep breaking the regulations and cause a breach of contract wherein trouble, as well as a conflict, can arise between the involved parties. COMPLAINT FOR BREACH OF CONTRACT CLAIM NOT SUBJECT TO MANDATORY ARBITRATION COMES NOW Plaintiff Slayden/Sundt, a Joint Venture, and for the causes of action against Defendant Multnomah County, complains and alleges as follows: I. PARTIES 1.1

21/08/2019В В· A Breach of Contract Notice (which can also be called a Notification of Contract Breach) is a document by which a party to a contract informs the other party that they have breached the agreement. A breach simply means that one party didn't fully perform the obligations they were supposed to under the contract. sample breach of contract, common counts, and fraud complaint. David Jordan, Esq. State Bar # 69052 LAW OFFICES OF DAVID JORDAN 222 West Broadway, Suite 500

15/09/2019В В· When one party to a contract fails to perform his or her obligation under it without a valid excuse, he or she is in breach of contract. If a contract that you signed is not being fulfilled, you may wish to write to the other party about the breach. 15/09/2019В В· When one party to a contract fails to perform his or her obligation under it without a valid excuse, he or she is in breach of contract. If a contract that you signed is not being fulfilled, you may wish to write to the other party about the breach.

Some of the forms, such as the form for a generic complaint, apply to different types of cases. Others apply only to specific types of cases. Be careful to use the form that fits your case and the type of pleading you want to file. Be careful to change the information the form asks for to fit the facts and circumstances of your case. Filing a Breach of Contract Complaint. A party to a contract dispute who feels the other party is in breach of the contract, should provide a breach of contract letter to the breaching party that he will be taking action for breach of contract. This is the first, formal step to resolving the issue. Sending a dated breach of contract letter

COMPLAINT FOR BREACH OF CONTRACT CLAIM NOT SUBJECT TO MANDATORY ARBITRATION COMES NOW Plaintiff Slayden/Sundt, a Joint Venture, and for the causes of action against Defendant Multnomah County, complains and alleges as follows: I. PARTIES 1.1 contract but Adonis Mendoza never signed a Narconon contract. A signed contract would have rendered the payment nonrefundable. The unsigned contract is attached as Exhibit "A." It . was never revealed that Narconon is a scientology facility. Pablo Mendoza is a Catholic. 8. On or about September 16, 2008 Narconon charged on American Express

Every single day, a contract form is signed by someone around the globe to imply a service agreement and approve the terms and conditions of an authorized person. However, on the other side of the planet, there are also those who keep breaking the regulations and cause a breach of contract wherein trouble, as well as a conflict, can arise between the involved parties. In breach of clause ___ of the contract, the Defendant had failed to deliver the Goods to the Plaintiff at all. By reason of the Defendant’s breach of contract, the Plaintiff has suffered loss and damage.

Page 2 - COMPLAINT FOR BREACH OF CONTRACT AND QUANTUM MERUIT Plaintiff Oracle America, Inc. (“Oracle “) brings this Complaint against Defendant Oregon Health Insurance Exchange Corporation, doing business as Cover Oregon (“Cover Oregon”), for breach of contract and quantum meruit based on Cover Oregon’s continued use of Every single day, a contract form is signed by someone around the globe to imply a service agreement and approve the terms and conditions of an authorized person. However, on the other side of the planet, there are also those who keep breaking the regulations and cause a breach of contract wherein trouble, as well as a conflict, can arise between the involved parties.

IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND

Breach of contract complaint pdf

GENERAL JURISDICTION DIVISION &' 09 18 3'l CA'l. BREACH OF CONTRACT COMPLAINT . Employment Details . Use a separate line for each job site where you worked. Be sure the job site addresses listed, IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT, IN AND FOR MIAMI-DADE COUNTY, FLORIDA OFFICE OF THE ATTORNEY GENERAL, DEPARTMENT OF LEGAL AFFAIRS, STATE OF FLORIDA, Plaintiff, CASE NO. v. DONALD ROBERT GILLETTE, individually and as President, Director and Owner of Federal Careers Institute Inc. and franchisor of Federal Careers Institute of South Florida Inc., ….

IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT IN. View Complaint for Breach of Verbal or Oral Contract; View Complaint regarding Breach of contract, Fair dealing, Fraud, Conversion, Accounting, Trade Secrets Act. Agreement to Merge Businesses; View Complaint regarding Breach of Contract, Implied Contract, Good Faith and Fair Dealing, Promissory Estoppel, Emotional Distress, 02/05/2018В В· In case any of the parties breaches the contract, the other party has a right to file a lawsuit against the party that breached the contract. The letter should include the details regarding the breach. The letter should include the contact details of the recipient, subject and the details of the contract that has been breached..

NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION UNITED

Breach of contract complaint pdf

IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT IN. A breach of a partnership agreement is a contract that details the rights and obligations of each partner in the business. If the breach happens, one has a cause of action that can be taken against the other and vice versa. This should be the point of reference in case of a breach. Pro Se 4 (Rev. 12/16) Complaint for a Civil Case Alleging Breach of Contract V. Certification and Closing Under Federal Rule of Civil Procedure 11, by signing below, I certify to the best of my knowledge, information, and belief that this complaint: (1) is not being presented for ….

Breach of contract complaint pdf

  • sample breach of contract common counts and fraud complaint
  • [PDF] Complaint Breach of Contract DRAFT Free Download PDF

  • 25/04/2016В В· Breach of contract complaint against Dennis Hastert Contents. Original Document (PDF) В» Related Article В» Contributed by: Tom Palmer, The Chicago Tribune В« Page Note 1 of 6 0 В» To print the Sample California complaint for breach of contract and common counts - Free download as Word Doc (.doc), PDF File (.pdf), Text File (.txt) or read online for free. This sample California complaint for breach of contract and common counts for California includes causes of action for open book account, account stated and goods sold and delivered.

    COMPLAINT—Contract Code of Civil Procedure, § 425.12 Form Approved for Optional Use Judicial Council of California PLD-C-001 [Rev. January 1, 2007] STREET ADDRESS: exceeds $10,000 but does not exceed $25,000 ACTION IS RECLASSIFIED by this amended complaint or cross-complaint from unlimited to limited 3. a. Each plaintiff named above is a A. Count I - Breach of Contract Defendant sets forth both a demurrer to Count I and objects to this count for lack of specificity. This court sustains the objections to Count I based on insufficient specificity. To establish a cause of action for breach of contract, the plaintiff must allege (1) the existence o f

    her fiduciary duty by reason of this direct conflict.8 Such a breach gives rise to an action on behalf of the client for proximately-resulting damages. 9 II. Asserting Claims for Both Legal Malpractice and Breach of Fiduciary Duty When defense counsel reviews a complaint alleging both legal malpractice and breach of … Breach of Contract Complaint form. • A copy of the pre-complaint notice sent to the contractor. • A copy of the post office receipt showing that you sent the notice by certified mail.

    Auto Tort Contract Provisionally Complex Civil Litigation (Cal. Auto (22)-Personal Injury/Property Breach of Contract/Warranty (06) Rules of Court Rules 3.400-3.403) Damage/Wrongful Death Breach of Rental/Lease Uninsured Motorist (46) (if the Contract (not unlawful detainer Antitrust/Trade Regulation (03) case involves an uninsured or wrongful Page 2 - COMPLAINT FOR BREACH OF CONTRACT AND QUANTUM MERUIT Plaintiff Oracle America, Inc. (“Oracle “) brings this Complaint against Defendant Oregon Health Insurance Exchange Corporation, doing business as Cover Oregon (“Cover Oregon”), for breach of contract and quantum meruit based on Cover Oregon’s continued use of

    Parlux v. Shawn Carter - complaint.pdf - Free download as PDF File (.pdf), Text File (.txt) or read online for free. COMPLAINT FOR BREACH OF CONTRACT CLAIM NOT SUBJECT TO MANDATORY ARBITRATION COMES NOW Plaintiff Slayden/Sundt, a Joint Venture, and for the causes of action against Defendant Multnomah County, complains and alleges as follows: I. PARTIES 1.1

    sample breach of contract, common counts, and fraud complaint. David Jordan, Esq. State Bar # 69052 LAW OFFICES OF DAVID JORDAN 222 West Broadway, Suite 500 sample breach of contract, common counts, and fraud complaint. David Jordan, Esq. State Bar # 69052 LAW OFFICES OF DAVID JORDAN 222 West Broadway, Suite 500

    sounds in negligence, breach of contract and breach of warranties, among other things. 25. The Complaint in the Omnibus action alleges that Morrison Homes, Inc. is responsible for damages as a result of the construction defects caused by Subcontractor. 26. Despite being placed on notice of the Omnibus action, Insurer has refused to 02/05/2018В В· In case any of the parties breaches the contract, the other party has a right to file a lawsuit against the party that breached the contract. The letter should include the details regarding the breach. The letter should include the contact details of the recipient, subject and the details of the contract that has been breached.

    complaint for: (1) breach of contract - violation of the implied covenant of good faith and fair dealing (2) intentional interference with contractual relations; (3) violation of cal. civ. code §§ 1750, et seq.; (4) violation of cal. bus. & prof. code § 17200, et seq.; (5) declaratory relief pursuant to the declaratory judgment act, 28 u.s.c. § 2201 jury trial demanded case 3:16-cv-06450 COMPLAINT I. PRELIMINARY STATEMENT 1. This is an action for breach of contract. II. PARTIES 2. Plaintiff Dr. Edward 0. Blews, Jr. is a resident of the District of Columbia and performed work for the Council for Christian Colleges & Universities ("CCCU") until his termination on October 12, 2013, effective October 22, 2013. 3. Defendant CCCU is

    View Complaint for Breach of Verbal or Oral Contract; View Complaint regarding Breach of contract, Fair dealing, Fraud, Conversion, Accounting, Trade Secrets Act. Agreement to Merge Businesses; View Complaint regarding Breach of Contract, Implied Contract, Good Faith and Fair Dealing, Promissory Estoppel, Emotional Distress As a proximate result ofDefendant's breach ofthe contract, as set forth above, Plaintiff has suffered damage in an amount to be shown according to proof at trial, but not limited to, the cost of repairing and replacing the defective materials and workmanship, testing and investigation of

    Breach of Contract Complaint form. • A copy of the pre-complaint notice sent to the contractor. • A copy of the post office receipt showing that you sent the notice by certified mail. Breach of Contract Complaint Form For Owners and Primary Contractors Before you file a complaint Before filling out a complaint, you may want to read “Resolving Disputes With Your Contractor.” You must give the contractor written notice that you plan to file a complaint with us at least 30 calendar days before you file the complaint. Even

    contract but Adonis Mendoza never signed a Narconon contract. A signed contract would have rendered the payment nonrefundable. The unsigned contract is attached as Exhibit "A." It . was never revealed that Narconon is a scientology facility. Pablo Mendoza is a Catholic. 8. On or about September 16, 2008 Narconon charged on American Express 07/09/2019В В· A Breach of Contract Notice (which can also be called a Notice to Rectify a Breach of Contract) is a document by which a party to a contract informs the other party that they have breached the agreement. A breach simply means that one party didn't fully perform the obligations they were supposed to under the contract.

    Breach of contract complaint pdf

    Common Breach of Contract Examples Breach of Contract Scenario 1 "My wife and I decided we wanted a brick outdoor wood fire oven. We did some shopping around and found a company that did designs we really liked for reasonable prices. COMPLAINT FOR BREACH OF CONTRACT CLAIM NOT SUBJECT TO MANDATORY ARBITRATION COMES NOW Plaintiff Slayden/Sundt, a Joint Venture, and for the causes of action against Defendant Multnomah County, complains and alleges as follows: I. PARTIES 1.1