If applicable, incorporate the breach of contract text as paragraph 3. of form 19-9 in this chapter.
Grounds for Summary Judgment—Breach of Contract
3.Grounds. The pleadings, affidavits, and discovery documents, such as deposition transcripts, answers to interrogatories, and admissions, on the file herein or attached hereto show that there is no genuine issue as to any material fact in this cause, in that—
a.Plaintiff and Defendant entered into a contract, as described in Plaintiff’s original petition on file herein, under which Defendant became obligated to pay Plaintiff for certain goods, services, or money furnished to Defendant by Plaintiff, as evidenced by [describe evidence].
b.Plaintiff performed all his obligations under the agreement by delivering the specified goods, services, or money to Defendant, as evidenced by [describe evidence].
c.Defendant breached the contract, as evidenced by [describe evidence].
d.As a result of the breach, Plaintiff sustained damages in the amount of $[amount], as evidenced by [describe evidence].