Complaint for Divorce

Complaint

IN THE COURT OF ,

(Name of Plaintiff) CAUSE NO.

V.
(Name of Defendant)

COMPLAINT

COMES NOW (Name of Plaintiff), Plaintiff in the above-styled and numbered cause, and files this his Complaint against Defendant, , and in support thereof would show unto the Court the following matters and facts:

1.

Plaintiff is an adult resident citizen of .

2.

Defendant is an adult resident citizen of .

3.

On or about , Plaintiff was, ever since has been, and now is, the owner and entitled to possession of an undivided one-half interest in the following-described personal property (hereinafter called Automobile):

One (1) Motor Vehicle more particularly described as follows:

• Make

• Model

• Body Type

• Vehicle Identification Number (VIN)

• Year:

4.

On that date Automobile was of the value of $ , and Plaintiff's undivided interest in Automobile was of the value of $ .

5.

On that date in Defendant, without Plaintiff's assent or authority, wrongfully and unlawfully took possession of Automobile and converted the property to his own use and benefit, depriving Plaintiff of the same, to Plaintiff's damage in the sum of $ , the reasonable market value of Plaintiff's interest in the property on that date.

6.

Plaintiff has often demanded the return of the Automobile, or the value of Plaintiff's interest in the Automobile, but Defendant has refused, and still refuses, to either return the Automobile to Plaintiff or to compensate Plaintiff for the value of Plaintiff's interest in the Automobile. A copy of Plaintiff's written demand is attached as Exhibit A and incorporated by reference.

7.

Plaintiff desires a partition of the property described above. The parties have been unable to agree as to the manner in which the property shall be divided.

8.

There are no liens or encumbrances on the Automobile and no person other than Plaintiff and Defendant is interested in the property as owner or otherwise.

Plaintiff requests judgment against Defendant for:

1. The return of the Automobile, or compensation for the value of Plaintiff's interest in the property, in the amount of $ ;

2. $ for loss of use of the Automobile;

3. For the partition of the Automobile according to the respective rights of the parties;

4. If partition cannot be had without prejudice to the owners, or if Automobile cannot be divided, then for the sale of Automobile and division of the proceeds of sale according to the respective interests of the parties;

5. Costs of suit; and

6. Such other and further relief as the court deems just and proper.

Respectfully submitted,