Fill and Sign the Complaint for Damages and Declaratory Judgment Form

IN THE CIRCUIT COURT OF ___________ COUNTY, __________ NAME OF PLAINTIFF )       ) ) V. ) NO.       ) ) NAME OF DEFENDANT )       ) ) COMPLAINT FOR DAMAGES AND DECLARATORY JUDGMENT COMES NOW __________, Plaintiff, in the above styled and numbered cause, and for her cause of action against the Defendant, __________, would show as follows: 1. That the Plaintiff is an actual adult resident citizen of __________ County, __________, residing at __________. 2. That the Defendant, __________, is a non - resident of the State of __________, whose street and Post Office address is,__________; and, that by entering into a contract within the State of __________ and by committing a tort within the State of __________, and more specifically within __________ County, __________, he has subjected himself to the jurisdiction of this Court. 3. That Defendant is not to be found within the State of __________, after diligent search and inquiry, and may be served with process of this Court by certified mail pursuant to Rule ___ of the __________ Rules of Civil Procedure. 4. That on or about the ____ day of __________, ____, Defendant mailed to Plaintiff's employer, Trans Union Corporation, the original of the photocopied letter attached hereto as Exhibit A. 5 That the debt referred to in Exhibit A, as modified by the agreement of the parties, had been fully satisfied by the Plaintiff, prior to __________ __, ____, and Defendant was aware of the same at the time he mailed the letter in question. 6. That the statements contained in Exhibit A, as to Plaintiff's alleged delinquency, are false and Defendant knew them to be false, at the time the letter was mailed to Plaintiff's employer. 7. That Defendant knew at the time he mailed the letter that, because of the nature of __________'s business activities, Plaintiff's employer actively discourages conduct of the type alleged in the letter, and that the receipt of the letter would adversely affect Plaintiff's relationship with her employer, and would jeopardize her employment by __________. 8. Defendant also knew at the time he mailed the letter in question that the statements made therein would be read by third persons, including Plaintiff's superiors, colleagues and subordinates. 9. That as a direct and proximate result of the statements made in Exhibit A and the dissemination of the same to Plaintiff's co - workers, Plaintiff's reputation and character have been irreparably damaged, and her business relationship with her employer has likewise been irreparably damaged. 10. The publication of the false and misleading statements contained in Exhibit A has also caused the Plaintiff severe emotional and psychological distress, and was deliberately calculated to produce such effects. WHEREFORE, Plaintiff brings this action against the Defendant, __________, and prays that non - resident process be issued to Defendant as required by the __________ Rules of Civil Procedure, and that upon a full and complete hearing herein, the Court would enter judgment as follows: A. A money judgment against __________ in the full amount of $00.00 for actual damages for libel, intentional interference with a business relationship, and intentional infliction of severe emotional and psychological distress; and, B. A judgment for punitive damages in the amount of $00.00; and, C. A declaratory judgment pursuant to Rule 56 of the __________ Rules of Civil Procedure, finding that the debt alleged by Defendant in Exhibit A has been fully and completely satisfied; and, D. A judgment for Plaintiff's reasonable attorney's fees. Respectfully submitted, _______________________ By: __________, Attorney Of Counsels: _______________________