用于最后通牒的起訴書樣本（言必行，行必果）
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
___________________________________
*
China Promotion (USA), Inc. *
111 Nowhere Lane S.W. * Civil Action No. 00002
Washington, D.C. 11111 *
Plaintiff *
v. *
*
Campaign Office of Candidate Gush *
111 Happy Road *
Washington, D.C. 11112 *
Defendant *
___________________________________*
COMPLAINT FOR MONEY DUE AND OWING
COMES NOW the Plaintiff into court, by and through counsel, Deguang Zhang,
Esq., and states the following as and for its Complaint:
1. Jurisdiction of this Honorable Court is founded upon Title 11, District of
Columbia Code, Section 921 as amended (1981 ed.).
2. Defendant, Campaign Office of Candidate Gush, by and through Mr.
Campaign Director, owes Plaintiff USD $78,000.00, plus accrued interest of
USD $7,814.00, on an account in arrears for fees and expenses associated
with Mr. Candidate Gush’s campaign for the Office of Sino-U.S. Relationship
between March 2005 and June 2005.
3. Despite repeated demands, Defendant has failed and refused to pay Plaintiff.
4. The terms of the account as set forth on exhibit “A,” attached hereto, provide
for finance charges of 1.5% a month (18% per annum) on all invoices not paid
within 30 days and attorney’s fees in the amount of 50%.
WHEREFORE, the premises considered, Plaintiff prays for judgment against
Defendant in the principal amount of USD $78,000.00, plus accrued interest of USD
$7,814.00, reasonable attorney fees and costs.
DISTRICT OF COLUMBIA, SS;
Deguang Zhang, being first duly sworn, deposes and says that he is an agent of
the Plaintiff with the authority to verify this Complaint and that the foregoing is a just
and true statement of the amount due and owing to Plaintiff exclusive of all set-offs
and just grounds of defense.
______________________
Deguang Zhang
Subscribed and sworn before me this 16th day of June, 2006.
_______________________
Notary Public, D.C.
Respectfully submitted,
Zhang, Wang & Lee, L.L.P.
______________________________________
Deguang Zhang, D.C. Bar No. 1234567
Attorney for Plaintiff
666 East Changan Boulevard
Beijing 100001, China
010-1234-5678
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