The following is an additional cause of action that may be brought against a spouse. This material can be incorporated, if appropriate, as an integral part of the divorce pleading to be inserted as a paragraph preceding the prayer. (If the material is incorporated in the respondent’s pleading, it should be reworded to reflect that the respondent, rather than the petitioner, is the complainant.) Include in the divorce pleading any further statements required by Tex. R. Civ. P. 47, tailored as appropriate for the relief sought.
Wrongful Interference with an Existing Contract
1.Wrongful Interference with an Existing Contract
On [date] and continuing thereafter, Respondent, without justification or excuse, willfully and intentionally interfered with an existing contract between Petitioner and [name].
2.Damages
This action proximately resulted in damages to Petitioner for which Petitioner now seeks relief. Those damages include [state specific damages alleged].
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Include 3. if applicable. |
Respondent acted with malice in engaging in this conduct, thus entitling Petitioner to exemplary damages within the jurisdictional limits of this Court.
4.Prayer
Petitioner prays for judgment against Respondent in a sum within the jurisdictional limits of this Court for [his/her] actual damages as alleged, [include if applicable: for exemplary damages,] for prejudgment and postjudgment interest as allowed by law, for costs of court, and for general relief.