Complaint
(Breach of Employment Contract) (NY)

Summary

This template is a Complaint (Breach of Employment Contract) that asserts claims relating to a breach of an employment agreement under New York law, whether by the employer or the employee. This template includes practical guidance, drafting notes, and alternate clauses. In drafting the complaint, remember that this document frames the legal and factual issues that govern discovery, pretrial motions, and the elements you must prove at trial. Moreover, the complaint provides the first opportunity to introduce the plaintiff's claims to the court and opposing parties. Therefore, the complaint should not only be clear, accurate, and legally and technically sufficient, but it should also tell the plaintiff's story in a compelling way and justify the plaintiff's claims. For resources on employment litigation, see Employment Litigation Resource Kit. For more information on topics that could apply in a New York breach of contract litigation, see Restrictive Covenants (NY) and Trade Secret Protection (NY). For more information on restrictive covenant and trade secret misappropriation claims, see Restrictive Covenant and Trade Secret Misappropriation Claims: Key Initial Considerations and Tips for Seeking TROs, Preliminary Injunctions, and Other Relief.