Fill and Sign the Causing Act Form

IN THE _______________ COURT OF _________________________ (County) , _____________________________________ (State) ______________________________________ PLAINTIFF (Name of Plaintiff) V. CAUSE NO. ______,______ ______________________________________ DEFENDANTS (Names of Defendants) COMPLAINT COMES NOW ____________________________________ (Name of Plaintiff) , Plaintiff in the above-styled and numbered cause, by and through his attorney, and files this his Complaint against Defendants, ________________________________________ _______________________________________ (Names of Defendants) , and in support thereof would show unto the Court the following matters and facts: 1. Plaintiff is an adult resident citizen of ___________________________________ ______________________________________________________ (city, county, state) . 2. Defendant A _______________________________________________________ (name of corporation) , is a corporation organized and existing under the laws of __________________________________ (name of state) , engaged in the business of a collection agency, with its principal place of business located at ____________________ ________________________________________________________________________ ___________________________________ (street address, city, county, state, zip code) . 3. Defendant B _______________________________________________________ (name of corporation) , is a corporation organized and existing under the laws of __________________________________ (name of state) , engaged in the business of owning and operating appliance stores, with its principal place of business located at ________________________________________________________________________ ________________________________________________________________________ __________________________________ (street address, city, county, state, zip code) . 4. Defendant A was the agent of Defendant B , and in doing the things hereafter alleged, was acting within the course and scope of that agency and employment. 5. On or about __________________________________ (date of purchase) , plaintiff purchased a ______________________________________ (name of appliance) from Defendant B for _________________________ ( dollar amount) , which plaintiff agreed to pay in ____________________ (number of installments) equal installments of ________________________ ( dollar amount) , with the first installment due on ______________________________________ (date) , and subsequent installments due on the ______ day of each succeeding month. Plaintiff paid all of such installments, except the installment due on __________________________________________ (date) . Because of exceptionally heavy household expenses, plaintiff was unable to make the payment for that installment. Thereafter, on or about _____________________________ __________ (date) , Defendant B turned over plaintiff's account for collection to Defendant A . 6. On or about ____________________________________ (date) , Defendant A , through its agent or employee, without right or legal authority, maliciously circulated and published libelous matter on cards concerning plaintiff as follows: (describe libelous publications) ____________________________________________________________ ________________________________________________________________________ ________________________________________________________________________ _______________________________________________________________________ . 7. Defendant A , through its agent or employee, distributed such cards on the door, windows, and on a stick in plaintiff's yard which cards remained in place for the entire day of __________________________________________ (date) until plaintiff returned home from work around ____________________ (time) . During this time such signs and the messages on them could be and were viewed and read by the general public walking or driving past plaintiff's house. The foregoing acts and circumstances caused plaintiff great mental pain and anguish, exposed plaintiff to public ridicule, and injuriously affected plaintiff's good name. 8. As a result of the insult and shock of exposure to public ridicule, directly caused by the acts of Defendant A , which acts were approved and/or ratified by Defendant B , plaintiff was confined to bed and was unable to work because of extreme nervousness and severe headaches. Since that time plaintiff has been physically and emotionally unable to perform plaintiff's work and earn plaintiff's livelihood. 9. Defendant A willfully and maliciously posted such notices with the consent of Defendant B and with a conscious intent to humiliate and disgrace plaintiff and to inflict pain and mental anguish on plaintiff in an attempt to coerce plaintiff to pay the account. 10. That the aforesaid actions of Defendants were in gross violation of the federal Fair Debt Collection Practices Act ( 15 U.S.C. 1692 , et. seq .) 11. As a direct and proximate result of the conduct of Defendant A , its agents and/or employees, as described above, plaintiff suffered a severe shock to plaintiff's nervous system to the extent that plaintiff's health and emotional well-being have been greatly impaired, and plaintiff has incurred medical expenses and a loss of earnings and of earning capacity, all in the total amount of _____________________ (dollar amount) . WHEREFORE, plaintiff requests judgment against Defendants, and each of them, for: 1. Actual damages in the amount of ________________________ ( dollar amount) ; 2. Punitive damages in the amount of _______________________ ( dollar amount) . 3. Interest on such damages as allowed by law; 4. Costs of suit; and 5. Such other and further relief as the court deems just and proper. Respectfully submitted on this ________________________________________ (date) . ____________________________________ (Name of Plaintiff) By: ________________________________ (Name of Plaintiff’s Attorney) State Bar No. ___________________ His Attorney OF COUNSEL: __________________________________________ (Name of Plaintiff’s Attorney) Post Office Box _________-________ City, State, Zip Code ______________________________________________________ Telephone: _______-_______-__________