§ 9-11-105.Form of complaint for goods sold and delivered
Chapter 11. Civil Practice Act · Article 10. Forms · Last amended 1980 · Last verified July 17, 2026
In one sentenceO.C.G.A. § 9-11-105 sets out a sample complaint for a seller suing over unpaid goods, alleging that the defendant owes a stated sum for goods the plaintiff sold and delivered within a given date range and seeking judgment for that sum, interest, costs, and attorney fees where applicable.
Full Text of § 9-11-105
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IN THE ______________________ COURT OF ______________________ COUNTY
A.B., STATE OF GEORGIA Plaintiff ) ) v. ) ) Civil action C.D., ) File no. ______________________ Defendant ) (Clerk will insert ) number.)
COMPLAINT The defendant C.D., herein named, is a resident of ______________________ (street), ______________________ (city), ______________________ County, Georgia, and is subject to the jurisdiction of this court.
Defendant owes plaintiff $10,000.00 for goods sold and delivered by plaintiff to defendant between June 1, 1966, and December 1, 1966.
Wherefore, plaintiff demands judgment against defendant for the sum of $10,000.00, interest, costs, and attorney fees (where applicable).
______________________ Attorney for plaintiff ______________________ Address
Plain-English Summary
This form covers a seller pursuing payment for goods handed over but never paid for. Rather than attaching an invoice or itemized ledger, the complaint identifies the transaction by a window of time — the period during which the goods were sold and delivered — and states the total sum owed.
After the article’s standard residency and jurisdiction paragraph, the complaint needs only one sentence: the defendant owes the plaintiff a stated amount for goods sold and delivered between two given dates. The closing demand follows the pattern shared with the note and account forms — the sum owed, interest, costs, and attorney fees where applicable.
Skipping the exhibit that the account form calls for shows how far Georgia’s short, plain statement standard tolerates compact factual allegations: a date range and a dollar figure are enough to put a defendant on notice of the claim, leaving the underlying sales records to come out later in discovery or at trial.
Frequently Asked Questions
What period does the complaint need to identify?
The date range during which the plaintiff sold and delivered the goods to the defendant.
Does this form require attaching an invoice or itemized list?
No. Unlike the open-account form, no exhibit is called for here; a date range and a total sum suffice.
What relief does the plaintiff seek?
The unpaid sum, interest, costs, and attorney fees where applicable.
Does the complaint have to prove the goods were delivered?
Proof comes later, at trial. The complaint only needs to allege that the sale and delivery occurred within the stated period.
Could this template be adapted for services instead of goods?
The printed form covers goods specifically, but the same bare-bones approach reflects how little Georgia’s notice-pleading standard demands for other simple unpaid-debt claims.
Amendment History
Ga. L. 1966, p. 609, § 105; Ga. L. 1980, p. 649, § 3.
Source & verification. Section text and amendment history are
reproduced verbatim from the Official Code of Georgia Annotated, published by the
Official Code of Georgia Annotated, Georgia Code Revision Commission / LexisNexis. Last verified July 17, 2026.
· Official source
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