Fill and Sign the Enclosed Herewith Please Find the Original Petition for Adoption and Other Related Matters Form

- 1 - IN THE ______________ COURT OF ______________ COUNTY STATE OF ________________ )) ) Petitioner/Plaintiff, ))) NO. Vs. )) ) Respondent/Defendant ) ) COMPLAINT Comes now the Plaintiff, __________________________, and files this complaint against the Defendant, ___________________________, and for cause would show unto the Court as follows, to-wit: 1. The Plaintiff is an adult resident citizen of _______________County, _________________, whose address is _____________________________________________. 2. The Defendant is an adult resident citizen of ________________ County, _________________, whose address is _____________________________________________. 3. At all times herein mentioned, Defendant, _____________________, was the owner and operator of a _______________ (describe automobile) automobile which is the vehicle operated by _____________________ in the incident complained of. 4. (Skip this paragraph if driver is not an employee of Defendant) On or about ______ day of _______________
September 13 , 2010 at about 8:30 (the time of the event), defendant took from his garage located in the area of a residence located at the address listed above, a vehicle which was equipped with a key-operated lock. 5. At all reasonable times within the course of the action complained of, defendant operated the vehicle located at (describe automobile) by operating (insert the vehicle's name and model number), which is one that the owner of the vehicle (the vehicle owner) would not normally authorize the vehicle operator to operate. 6. At all reasonable times within the course of the action complained of, defendant had the keys to the vehicle located at the location listed above. 7. At all reasonable times within the course of the action complained of, at the time of the incident complained of, defendant was operating the vehicle located at the location listed above. 8. At all reasonable times within the course of the action complained of, defendant had the keys to the vehicle located at the location listed above. 9. That on September 13, 2010 at about 8:30 while defendant was operating the vehicle located at the location listed above, plaintiff and a passenger in plaintiff's vehicle had been drinking alcoholic beverages pursuant to state law as is hereunder. That plaintiff and defendant, both were intoxicated at the time that plaintiff attempted to leave the area where defendant had locked his vehicle and when plaintiff and defendant departed the area where defendant had locked his vehicle together. 10. That as a result of defendant's act to lock the vehicle, the lock was broken and the vehicle was substantially impounded and the keys were withheld. 11. That defendant had been charged with the following prior to the time he allegedly locked the car which is the vehicle operated by plaintiff, in fact by the police: on or about in the county of nassau, state of new york. 12. That the above is in actual fact the true substance of the alleged unlawful use of the vehicle with the keys unlawfully withheld. 13. That in reliance upon the above statement in its pleading in liming, the plaintiff would prove the following: 1. That defendant is guilty that he: (a) has deprived the plaintiff of the use of his automobile; 4 (b) operated the defendant's automobile after being drunk; and 5 (c) in attempting to leave the area where the vehicle was locked, attempted to drive away. That as a result of defendant's act of unlawfully detaining and withholding the.