We need to write a complaint for a breach of contract /fraud complaint involving a company that signed an asset purchase agreement with us and then backed away.
We seek to file the complaint in New York court, but the contract selects and is governed by Delaware Law. We believe that the motion writer can be anywhere in the US and then their work product can be reviewed and submitted to the courts by separate New York counsel.
We are looking for a motion writer who has experience in complaint writing involving Delaware statue and case law involving the following legal issues:
i) contracts. Despite the fact that the defendant signed the contract, we believe that they will attempt to back out based on technical issues of offer/acceptance,
ii) detrimental reliance
ii) damages involving 'benefit of the bargain'
We would need work product (i.e. the draft complaint) done within a week and preferably faster.