Chapter 2 - FORM 2-8 : VERIFIED COMPLAINT—WITH SAMPLE CLAIMS FOR BREACH OF EMPLOYMENT AGREEMENT AND INJUNCTIVE RELIEF

• Jurisdiction: Colorado

Form 2-8: Verified Complaint—With Sample Claims for Breach of Employment Agreement and Injunctive Relief

District Court, __________ County, Colorado Court Address:	▲ COURT USE ONLY ▲
Plaintiff(s): v. Defendant(s):
Attorneys for Plaintiff (Name and Address) Phone Number: FAX Number: E-mail: Atty. Reg. #:	Case Number: Div.: Ctrm.:
VERIFIED COMPLAINT

Plaintiff, through its undersigned counsel, for its Verified Complaint against the above-named Defendant states as follows:

PARTIES, JURISDICTION, AND VENUE

1. Plaintiff [name] is [a resident of (county) County, Colorado] OR [a (type of business entity) organized under the laws of (state) with its principal place of business at (street address), (city), (state and zip code)].

2. Defendant [name] is [a resident of (county) County, Colorado] OR [a (type of business entity) organized under the laws of (state) with its principal place of business at (street address), (city), (state and zip code)]. [If defendant is not organized under Colorado law, add: As a nonresident of Colorado, Defendant is subject to the jurisdiction of this Court because (insert basis of jurisdiction).]

3. [If applicable, add: (name of Defendant) is in the business of (describe type of business).]

4. Pursuant to Rule 98 of the Colorado Rules of Civil Procedure, venue for this action properly lies in Denver County, Colorado because [specify basis for venue per C.R.C.P. 98, and cite relevant subsection of C.R.C.P. 98].

5. This Court has jurisdiction over the subject matter at issue because this is a civil action for damages and/or equitable relief. Colo. Const. Art. VI, § 9(1).

NATURE OF THE COMPLAINT

6. Plaintiff incorporates by reference the foregoing paragraphs as though fully set forth here.

7. This is a civil action seeking damages and injunctive relief arising out of Defendant's breach of covenants not to compete and not to solicit clauses set forth in the employment agreement between Plaintiff and Defendant entitled [title of employment agreement], dated [date of employment agreement].

GENERAL ALLEGATIONS

8. Plaintiff incorporates by reference the foregoing paragraphs as if more fully set forth here.

9. On or about [date], Defendant entered into a [title of employment agreement] ("Agreement") with Plaintiff, which is attached to this Complaint as Exhibit A and incorporated by reference.

10. As consideration for the Agreement, Defendant received [insert consideration Defendant received for signing the employment...