Fill and Sign the Complaint Petition or Declarationfor Harassment in Attempting to Collect Debtharassing and Malicious Information

IN THE ____________________COURT OF _________________________ (County), __________________________________ (State)______________________________________________PLAINTIFF(Name of Plaintiff)V.CAUSE NO. ______,_____________________________________________________ DEFENDANTS(Names of Defendants) COMPLAINT COMES NOW ____________________________________ (Name of Plaintiff) , Plaintiff in the above-styled and numbered cause, by and through his attorney, and files this his Complaint against Defendants, ________________________________________ ____________________________________ (Names of Defendants), and in support thereof would show unto the Court the following matters and facts: 1. Plaintiff is an adult resident citizen of ___________________________________ _________________________________________________ (city, county, state). 2. Defendant A _______________________________________________ (name of corporation), is a corporation organized and existing under the laws of (name of state), engaged in the business of a collection agency, with its principal place of business located at (street address, city, county, state, zip code). 3. Defendant B is an adult resident citizen of _______________________________ _________________________________________ (city, county, state), and resides at ________________________________________________________________________ ________________________________________________________________________ ________________________ (street address, city, county, state, zip code). 4. Defendant B was the agent and employee of Defendant A, and in doing the things hereafter alleged, was acting within the course and scope of that agency and employment. 5. In an attempt to collect an indebtedness owed to __________________________ ___________________ (name of creditor) by plaintiff, Defendant A adopted a course of deliberate harassment, designed to embarrass, humiliate, and subject plaintiff to disgrace resulting in plaintiff and his family suffering mental anguish. 6. On or about ______________________________________ (date), Defendant B, while acting in the course and scope of his employment for Defendant A, telephoned plaintiff's employer, _______________________________________________________ (name of employer), at ____________________________________________________ _____________________________________________________ (address of employer), and stated to plaintiff's employer that (describe harassing telephone call) ___________ ________________________________________________________________________ _______________________________________________________________________________________________________________________________________________________________________________________________________________________. 7. The acts of Defendant A through Defendant B as alleged above, were done and performed wantonly, willfully, and maliciously, in total disregard of plaintiff's rights. 8. The aforesaid actions of Defendants were in gross violation of the federal Fair Debt Collection Practices Act (15 U.S.C. 1692, et. seq.) 9. As a result of the acts of Defendants , which were intended to wound feelings and produce mental anguish and suffering and from which such result should be reasonably anticipated as a natural consequence, plaintiff suffered severe distress of body and mind and great mental anguish, embarrassment, and humiliation, to plaintiff's damage in the amount of __________________________ (dollar amount). 10. The said acts and conduct of Defendants constituted a willful and wanton trespass on and into the innermost being of plaintiff and represented a wrongful attempt to collect a debt accompanied by insult, abuse, oppression, mental anguish, and suffering of the person and mind of plaintiff. Defendants should be punished for such acts and conduct and should be required to pay exemplary damages to prevent Defendants from engaging in these practices in the future and as an example to others who might attempt such collection efforts. 11. The aforesaid representations made by Defendants to plaintiff's employer were fraudulent, in that (set forth basis of fraudulent representation) ___________________ ________________________________________________________________________ ________________________________________________________________________ _______________________________________________________________________.WHEREFORE, plaintiff requests judgment against Defendants, and each of them, for:1. Actual damages in the amount of _______________________ (dollar amount);2. Punitive damages in the amount of _______________________ (dollar amount).3. Interest on such damages as allowed by law;4. Costs of suit; and5. Such other and further relief as the court deems just and proper.Respectfully submitted on this ________________________________________ (date). ____________________________________ (Name of Plaintiff) By: ________________________________ (Name of Plaintiff’s Attorney) State Bar No. __________________ His Attorney OF COUNSEL: _________________________________________(Name of Plaintiff’s Attorney)Post Office Box ________-_________City, State, Zip Code ______________________________________________Telephone: ________-________-___________