How do I plead a breach of contract?

As a general matter, to allege a breach of contract, a plaintiff must plead (and prove) the following: (1) the existence of an enforceable agreement; (2) performance by plaintiff; (3) the defendant breached the agreement ; and, (4) the plaintiff sustained damages as a direct result of the defendant's breach. Oct 9, 2017. (fhnylaw.com)

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