Good afternoon listmates, hope everyone is enjoying this great weather.  I am the long-time attorney for a machine shop manufacturer who recently contracted with an engineering company to design and build a robotic machine to help make some sort of small steel object.  The client paid the engineering company a ton of money but when the machine was delivered, it does not work and can’t be adjusted to work properly.  I am a pretty decent litigator and will draft a suit for breach of contract and other causes of action but I have never drafted a complaint when the machine does not work and is not fit for the purpose intended.  Can anyone send me a sample complaint or tell me the index # for a case with similar facts? Matt Worner mtw@wornerlaw.com     

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