Fill and Sign the In the Circuit Court of the First Judicial District of Hinds County Form

IN THE CIRCUIT COURT OF _____________ COUNTY, MISSISSIPPI _____________ PLAINTIFFVS.NO. __________________________ DEFENDANT VERIFIED COMPLAINT _____________ ("_____________"), pursuant to Miss. Code Ann. Section 11- 37-101 (1972), as amended, files its Verified Complaint against _____________ ("_____________") to replevin certain property in _____________'s possession. In support thereof, _____________ states the following: Parties 1. _____________ is a Wisconsin corporation with its principal place of business in _____________ Wisconsin.2._____________ is an adult resident citizen of Rankin County, Mississippi, who nay be served with process at _____________, _____________, Mississippi _____________. Facts 3. On _____________, _____________ purchased one (1) 1988 Case Crawler/Dozer-Long Track, model 850D, Serial Number _____________ and one (1) Belshe #2400 Trailer, model FB24 -2AP, Serial Number _____________ (collectively, the "Subject Property").4. The Subject Property has a current estimated book value of $36,250.00 as set forth on Exhibit "A" attached hereto.5.As part of the consideration for the purchase of the Subject Property, _____________ executed a Retail Installment Contract (Security Agreement) (the "Security Agreement") on _____________, giving to the holder thereof a security interest in the Subject Property until the purchase price was paid in full. A true and correct copy of the Security Agreement is attached hereto as Exhibit "B".6.The Security Agreement was assigned to _____________ and the lien was noted on a UCC-l Financing Statement which was duly recorded in the office of the Chancery Clerk of _____________ County, Mississippi. A true and correct copy of the Financing Statement is attached hereto as Exhibit "C".7. _____________ has defaulted in the payment of the indebtedness secured by the Subject Property and is now indebted to _____________ under the Security Agreement in the sum of $_____________, which is due and owing to _____________ as of _____________, together with additional interest, late charges, attorney fees and legal expenses. As a result of the default, _____________ is entitled to the immediate possession of the Subject Property in order to exercise its rights in accordance with the terms of the Security Agreement and applicable state law.8._____________ wrongfully withholds and detains possession of the Subject Property at his address in Rankin County, Mississippi.WHEREFORE, _____________ requests that this Court issue an Order directing the Clerk of this Court to issue a Writ of Replevin for the immediate seizure of the Subject Property upon _____________ posting a good and valid Replevin Bond in favor of _____________ for double the value of the the Subject Property, conditioned to pay any damages which may arise from the wrongful seizure of the Subject Property by _____________ and to summons _____________ to be and appear before this Court and to answer this suit, and that upon a final hearing in this cause, the Court should make and enter a judgment herein awarding _____________ possession of the Subject Property to enable it to exercise its rights according to the terms of the Security Agreement and applicable state law. Alternatively, _____________ requests such other and further relief as the Court deems just and appropriate. DATED: _____________ Respectfully submitted, __________________________