Forms and instructions for filing a civil action in county court
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IN THE COUNTY COURT OF_________ COUNTY, ____________ PLAINTIFF ) )) ) NO. V. )) NAME OF DEFENDANT ) ) COMPLAINT COMES NOW __________, Plaintiff by and through counsel and files this civil action against __________and in support thereof would show the following: 1. Plaintiff is a __________ business corporation with its principal place of business in __________, __________ County, __________. 2. Defendant is a rural water association with its principal place of business in __________, __________ County, __________ which may be served with process by serving its registered agent, __________, __________, __________, __________. 3. Defendant entered into a contract and agreement with Plaintiff whereby Defendant agreed to pay and compensate Plaintiff for a __________ on or about __________, ____ and the Defendant assumed responsibility for the payment of same. The sales agreement signed by __________ is attached hereto as Exhibit "A". An invoice is attached hereto as Exhibit "A-1". 4. Defendant has become indebted to Plaintiff pursuant to said contract and agreement in the amount of $_________ and late charges of ___% per month through __________, 20__. Plaintiff has made demand upon Defendant pursuant to __________ Code Ann. Sec. ______; however, Defendant has failed and/or refused to pay said indebtedness. COUNT I. CLAIM BASED ON OPEN ACCOUNT 5. The allegations of paragraphs 1 through 4 as set forth above are realleged in full and incorporated herein by reference.
(b 3. On or about, may 7, 2014, a lien has been filed in the office of, district, office in the county , , township, and county or in the United States district court for the state of florida, , county, florida, for payment of the balance on the late account for the amount of 20 years 2% of the unpaid balance of the principal of, , (which shall be the accrued rate of 6 per cent per annum of the then principal amount of the interest on said bill of exchange). Count 7. (a) in its complaint , the defendant alleges, and the plaintiff relies upon, that the plaintiff had entered into a contract and agreement with the defendant whereby the defendant agreed to pay and compensate the plaintiff for the principal of the bill of exchange and that defendant assumed liability for the payment of the same. The sales agreement signed by the defendant is attached hereto as exhibit “a". An invoice is attached hereto as exhibit “a-1. (b) the defendant also alleges, and the plaintiff relies upon, that the defendant entered into an agreement and was contractually bound to pay plaintiff an amount per month for the payment of the principal of the bill of exchange, and that the defendant failed to perform said obligation. The allegation in paragraph 1 of the complaint concerning the purchase of said bill of exchange is not contradicted by the complaint in paragraph 5. The allegation in paragraph 2 that the bill of exchange was not delivered with a bill of exchange is not contradicted by the charge in paragraph 3 at (a) of the plaintiff's complaint against the defendant. Count 8. (a) on or about, may 7, 2014, a lien has been filed in the office of,, district, , township, and county or in the united states district court for the state of Florida , , county, florida, for payment of the balance on the current account for the amount of 20 years 2% of the unpaid balance of the principal of. Count 9. (a) the defendant alleges and the plaintiff relies upon, and the complaint is in opposition to, that the plaintiff entered into a contract and agreement with the defendant whereby the defendant agreed to pay and compensate plaintiff for the principal of the current account, and that defendant assumed liability for the payment of the same. The sales agreement signed by the defendant is attached hereto as exhibit “a". An invoice is attached hereto as exhibit ‐a-1
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