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JOHN LAWYER, ESQ.12 MAIN STREETANYWHERE, USAAttorney for Plaintiff_____________________________JOHN DOE,Plaintiff(s),v.JANE DOE,Defendant(s)._____________________________SUPERIOR COURT OF NEW JERSEYLAW DIVISION:SPECIAL CIVIL PART[insert] COUNTYDOCKET NO.: CIVIL ACTIONCOMPLAINT (CONTRACT)Plaintiff, John Doe, maintaining his principal place of residence at [insert address], by way of Complaint against the Defendant hereby says:1.Defendant, upon information and belief, is the owner of a residence at [insert address].2.On or about [insert date], the parties entered into a written lease agreement for plaintiff s residential use of [insert address].3. Pursuant to this lease agreement, a security deposit of $[insert] was posted by plaintiff. 4.The [insert date] lease was defective in that it did not indicate where plaintiff s security deposit was being held.5. Furthermore, at no time during the tenancy did defendant identify the specific location of plaintiffs security deposit.6. Plaintiff vacated the premises at [insert address] on [insert date]7. However, it was not until [insert date], that plaintiff was in receipt of an invoice from an entity known as [insert]., which indicated that the entire amount of the security deposit plus $[insert], was being charged to plaintiff s account. Accordingly, no security deposit was being returned to plaintiff.8. Plaintiff has received no further communication regarding the return of his security deposit.9.Defendant has violated New Jersey s Security Deposit Act which is codified at N.J.S.A. 46:8-19 et. seq., by failing to disclose the location of plaintiff s security deposit when the lease was executed. 10.Additionally, defendant violated New Jersey s Security Deposit Act by failing to account as to plaintiff s security deposit within thirty (30) days of plaintiff s vacating the rental premises.11.Finally, defendant has made a number of bogus, unauthorized and unwarranted deductions from plaintiff s security deposit thus warranting the imposition of damages against defendant for violation of the Security Deposit Act.WHEREFORE, the Plaintiff demands judgment against the Defendant as follows:a.Pursuant to N.J.S.A. 46:8-21.1 plaintiff seeks the return of any and all security deposit monies deposited under the [insert] lease including the doubling of said amount;b.Costs of suit; c.Attorneys fees;d.For such other relief as the Court may deem equitable and just. DESIGNATION OF TRIAL COUNSEL Pursuant to R. 4:25-4, John Lawyer, Esq. Is hereby designated as trial counsel in this matter. CERTIFICATION I hereby certify that the matter in controversy in this action is not the subject of any other actions pending in any court or of a pending arbitration proceeding, no other action or arbitration proceeding, no other action or arbitration is contemplated and no other parties must be joined in this action.Dated: ______________________________JOHN LAWYER, ESQ.