Plaintiff, Graham Sterling, brings this action against Defendant, JustTheJob, for breach of contract and negligence.
Plaintiff entered into a contract with Defendant for the construction of a patio at Plaintiff’s residence. Despite receiving payment for the job, Defendant failed to complete the patio to the agreed upon specifications and in a timely manner.
Additionally, during the course of the construction, Defendant’s employees negligently buried Plaintiff’s cat, Fluffy, six feet under cement, causing emotional distress and the loss of a beloved pet.
As a result of Defendant’s breach of contract and negligence, Plaintiff has suffered damages including, but not limited to, the cost of completing the unfinished patio, veterinary and burial expenses for Fluffy, and emotional distress.
Plaintiff demands a trial by jury and seeks damages in an amount to be determined at trial, but not less than the cost of completing the patio and the expenses incurred as a result of Defendant’s negligence.
Plaintiff also requests a permanent injunction ordering the defendant to stop any further work at the plaintiff’s residence.
Plaintiff also request a punitive damages for the deliberate act of causing harm to the pet and the emotional distress caused by that.
Plaintiff also request court costs and attorney’s fees.
Plaintiff demands judgment against Defendant for all damages, costs, and fees incurred as a result of Defendant’s breach of contract and negligence.