General Form of Complaint for Quantum Meruit - For Services Rendered

The phrase quantum meruit means as much as he has deserved. When a person employs another to do work for him, without any agreement as to his compensation, the law implies a promise from the employer to the workman that he will pay him for his services, as much as be may deserve or merit. In such case the plaintiff may suggest in his Complaint that the defendant promised to pay him as much as he reasonably deserved, and then state that that defendant has failed to pay such amount.

The following form is a complaint that adopts the "notice pleadings" format of the Federal Rules of Civil Procedure, which have been adopted by most states in one form or another.