Fill and Sign the Comes Now the Plaintiff and Would Show as Follows to Wit Form

- 1 - IN THE COURT OF COUNTY, ) )))))))) Petitioner/Plaintiff, V. CAUSE NO. Defendant/Respondent, COMPLAINT COMES NOW the Plaintiff, ____________, and would show as follows, to-wit:1. That he is a resident citizen of the City of ____________, ____________ County, ____________, and that the Defendant, ____________, is a ____________ corporation, domiciled in ____________County, ____________,and located at ________________________, service of process may be had upon the registered agent for said corporation, being ____________, ____________________________________, in the _________ Judicial District of ____________ County, ____________; and service of process may be had upon the Defendant, ____________, by service on him at his place of business, located at ____________________________________, in ____________County, ____________, his place of business being known as ____________. 2. The Plaintiff would show that he is the owner of a certain automobile being a 20____ ________________________, Model Number ____________ and that he used the automobile, from the time he had possession of same, primarily, in attending to his duties as past or of ____________ located in the City of ____________, ____________. 3. - 2 - Plaintiff would show that on or about ____________, he delivered the said vehicle to the Defendant corporation, through its president, ____________, and, at that time, contracted with the Defendants for the repair of said vehicle. Plaintiff would further show that he was advised and told by the Defendants, through their agents and servants, that the Defendants had to order parts for the automobile and that Plaintiff would be required to make payments on same. 4. Plaintiff would show that he did indeed make payments to the Defendants, as follows, as evidenced by: (a) Check Number ____________, dated ____________, drawn on ____________ account, by ____________ to Defendant ____________ for deposit on transmission repair, in the sum of $____________; (b) Check Number ____________, dated ____________, drawn on ____________ account, ____________, to ____________, for transmission repair, in the sum of $____________; and 5. Plaintiff would show that he paid in excess of ________________________ ($____________) Dollars to Defendants for repairs to said vehicle. 6. Plaintiff would show that the Defendants, through their agent and servant, ____________, Defendant, and president of Defendant corporation, ____________, refused to accept any further sums from the Plaintiff and refused to acknowledge that the car belongs to the Plainti ff and refused to return the car to the Plaintiff, all despite the Plaintiff's demand and offer to tender any balance due, if any, for repairs. 7. Plaintiff would show that the Defendants have wholly converted to their own use his property, being the ____________ automobile aforesaid and Defendants asserted that the Plaintiff has no further interest in it whatsoever, and Plaintiff would show that the Defenda nts have converted the said automobile maliciously, willfully and wantonly, with intent to deprive the Plaintiff of his property and that they have converted the property to their own use through devious and sundry means, being an act of trover. 8. - 3 - Plaintiff alleges that he has no way of knowing whether the Defendants still have the vehicle in their possession and demands damages from said Defendants in the sum of ____________ ($____________) Dollars for the said automobile and the further sum of ____________ ($____________) Dollars for the deprivation foisted upon the Plaintiff for the use of his vehicle and the further sum of ____________ ($____________) Dollars, as punitive damages for the willful, wanton and malicious action of the Defendants, individuall y and collectively. WHEREFORE, Plaintiff brings this his cause of action in trover and conversion against the Defendants, as shown aforesaid, and asks that a jury hear this cause and asks for damages i n the sum of ____________ ($____________) Dollars for the said automobile and the further sum of ____________ ($____________) Dollars for the deprivation foisted upon the Plaintiff for deprivation of use of his vehicle and the further sum of ____________ ($____________) Dollars, as punitive damages for the willful, wanton and malicious action of the Defendants, individually and collectively, for a total sum of ____________ ($____________) Dollars and demands judgment in the premises for same, together with all lawful costs and expenses for the bringing of this action. A Jury is requested. Respectfully submitted, ________________________, Plaintiff STATE OF ____________ COUNTY OF ____________ ________________________ came and appeared before me, the undersigned authority, in and for the jurisdiction aforesaid, the within named ________________________, who, having been by me first duly sworn, states on his oath that the matters and facts contai ned in the above and foregoing Complaint are true and correct as set forth. SWORN TO AND SUBSCRIBED before me, this the _______ day of ____________, 20___. ____________________________________ NOTARY PUBLIC My Commission Expires:________________________ _________________________ ATTORNEY FOR PLAINTIFF