Fill and Sign the Complaint in the Circuit Court of Lafayette County Form

IN THE CIRCUIT COURT OF * COUNTY, MISSISSIPPI* PLAINTIFFVS. CAUSE NO. ** DEFENDANT COMPLAINT Comes now the plaintiff, *, by and through his attorney, andfiles this his complaint against the defendant, *, and for cause ofaction, would show unto the Court the following, to-wit: I. The plaintiff, *, is an adult resident citizen of LowndesCounty, Mississippi, residing at *, *, Mississippi. The defendant, *, is an adult resident of * County, Mississippi. II. On * *, * the defendant, *, executed a GENERAL AFFIDAVIT before the Justice Court of Rankin County, Mississippi, chargingthe plaintiff with the felony criminal offense of Burglary of aDwelling House, said house being located at *, Brandon,Mississippi. A true copy of said affidavit is attached herto asExhibit "A" and made a part hereof as if copied in full herein. III. As a result of the execution of said affidavit, awarrant was issued for the plaintiff, he was arrested and placedin the Rankin County Jail where he remained until on or about* *, * when said affidavit was dismissed by the CountyCourt of Rankin County. IV. At the time of the execution of said affidavit, thehouse located at *, Brandon, Mississippi, was leased to one * * andthe rent for the month of April, 1992, was paid in full. On * *,1992, at the request of the said * *, the plaintiff did in fact goto said residence and remove certain articles of personalproperty, all of which belonged to * * and were removed with hispermission. V. At the time of the execution of the aforementionedaffidavit, the defendant had no probable cause to believe thatthe plaintiff had committed the offense charged, or any otheroffense, in that the defendant knew that the plaintiff hadremoved the aforementioned articles with the permission of theirowner, * *. VI. As a direct and proximate result of the defendant'sactions, as described above, the plaintiff has suffered thefollowing damages: a. Damage to his good name and reputation. b. Emotional and psychological trauma. c. Embarrassment. d. Inconvenience. e. Physical pain and suffering. f. Mental pain and suffering. V. Based upon the acts of the defendant, as described above, plaintiff alleges that the defendant is guilty of maliciousprosecution in that. a. There was the institution of an original criminal judicial proceeding against the plaintiff. b. Said proceeding was at the instance of thedefendant. c. Said proceeding terminated in the plaintiff's favor. d. There was malice in the institution of saidproceeding. e. There was want of probable cause for saidproceeding. f. The plaintiff suffered damages as a result of saidproceeding. VI. Plaintiff alleges that he is entitled to be compensatedby the defendant for his actual damages, as described above;and, in that the actions of the defendant were malicious,intentional and exhibited a reckless disregard for the rights ofthe plaintiff, that he is entitled to recover punitive damages fromthe defendant. VII. WHEREFORE, PRKKISES CONSIDERED, plaintiff sues and demandsjudgment of and from the defendant in the sum of $100,000.00 asactual damages and $100,000.00 as punitive damages, plus interestand all costs of this action. Respectfully Submitted, ***, Plaintiff Attorney For The Plaintiff***MSB No. * 4