Fill and Sign the Complaint Mississippi 497314774 Form

IN THE CIRCUIT COURT OF       COUNTY, MISSISSIPPI PLAINTIFF VS. CIVIL ACTION NO.       DEFENDANTS COMPLAINT COMES NOW the Plaintiff,       , and would show as follows, to - wit: 1. That he/she is a resident citizen of the City of       ,       County, Mississippi, and that the Defendant,       , is a Mississippi corporation, domiciled in       County, Mississippi, and located at       ,       , Mississippi, service of process may be had upon the registered agent for said corporation, being       ,       ,       , Mississippi, in the       Judicial District of       County, Mississippi; and service of process may be had upon the Defendant,       , by service on him/her at his/her place of business, located at       ,       , Mississippi, in       County, Mississippi, his place of business being known as       . 2. The Plaintiff would show that he/she is the owner of a certain automobile being a       , Model Number       and that he/she used the automobile, from the time he/she had possession of same, primarily, in       . 3. Plaintiff would show that on or about       ,       he/she 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/she 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/she 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       repair, in the sum of $       ; (b) Check Number       , dated       ,       , drawn on       account,       , to       , for       repair, in the sum of $       ; and (c) Check Number       , dated       ,       , drawn on       account, by       to       for       for       car, in the sum of $       . 5. Plaintiff would show that he/she paid in excess of       ($       ) 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 Plaintiff 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/her property, being the       automobile aforesaid and Defendants asserted that the Plaintiff has no further interest in it whatsoever, and Plaintiff would show that the Defendants have converted the said automobile maliciously, willfully and wantonly, with intent to deprive the Plaintiff of his/her property and that they have converted the property to their own use through devious and sundry means, being an act of trover. 8. Plaintiff alleges that he/she 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       ($       ) for the said automobile and the further sum of       ($       ) Dollars for the deprivation foisted upon the Plaintiff for the use of his/her vehicle and the further sum of       ($       ), as punitive damages for the willful, wanton and malicious action of the Defendants, individually and collectively. WHEREFORE, Plaintiff brings this his/her 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 in the sum of       ($       ) for the said automobile and the further sum of       ($       ) for the deprivation foisted upon the Plaintiff for deprivation of use of his/her vehicle and the further sum of       ($       ), as punitive damages for the willful, wanton and malicious action of the Defendants, individually and collectively, for a total sum of       ($       ) 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, _______________________________________       Attorney for       Of Counsel:                         Telephone:       MSB #       Attorney for       STATE OF MISSISSIPPI 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/her oath that the matters and facts contained in the above and foregoing Complaint are true and correct as set forth. SWORN TO AND SUBSCRIBED before me, this the       day of       ,       . _________________________________________ NOTARY PUBLIC My Commission Expires:       ____________________________ ATTORNEY FOR PLAINTIFF