Fill and Sign the Indaiana Landlord Sample Security Deposit Return Notice Form

IN THE COUNTY COURT OF _____________ COUNTY NAME OF PLAINTIFF )       ) ) V. ) NO.       ) ) NAME OF DEFENDANT )       ) ) COMPLAINT COMES NOW __________, Plaintiffs in the above styled cause, by and through counsel, and files this civil action against __________, Defendants, and in support thereof would show the following: 1. Plaintiffs __________ hereinafter "the __________") are adult resident citizens of __________, __________ County, __________. 2. Defendants __________ (hereinafter "the __________") are adult resident citizens of __________, __________County, __________, who may be served with process at their residence, __________. 3. On or about __________ 6, _____, the __________ leased the residence located at __________ from the __________. In connection with the execution of the lease, the __________ provided the __________ with a security deposit in the amount of ______________ and No/100 Dollars ($00.00) for the purposes of securing the __________' performance in accordance with the terms of the lease. A copy of said lease is attached hereto as Exhibit "A" and incorporated herein by reference. 4. Approximately ______ (____) months into the lease term, the __________ purchased a new home. Pursuant to an agreement with the __________, the __________ located a new tenant satisfactory to the __________ and the __________ terminated and released the __________ from the existing lease and executed a new lease with the new tenants. A copy of the Release is attached hereto as Exhibit "B" and incorporated herein by reference. The lease with the new tenants provided the __________ with a higher rent and will expire ______ (___) months later than the __________' lease. A copy of said new lease is attached hereto as Exhibit "C' and incorporated herein by reference. - 1 - 5. After the __________ vacated the property and the new tenants moved in, the __________ on __________ ___, ____, requested a return of their security deposit. However, the __________ refused. Thereafter, on __________ ___, _____, the __________' attorney, on their behalf, made demand on the __________ pursuant to __________ Code Ann. Sec. __________, for the return of the security deposit and/or an itemization of any amount which the __________ claimed to be due from the security deposit. A copy of said __________ ___, _____ letter is attached hereto as Exhibit "D" and incorporated herein by reference. 6. In response to the __________ ___, _____ letter the __________ responded with a letter dated __________ __, _____. A copy of said letter is attached hereto as Exhibit "E" and incorporated herein by reference. While the __________ admit that the lease was terminated and the __________ released, the __________ refuse to return the security deposit without setting forth any legitimate basis for withholding said sum. 7. Approximately ______ (____) months into the lease term, the __________ purchased a new home. Pursuant to an agreement with the __________, the __________ located a new tenant satisfactory to the __________ and the __________ terminated and released the __________ from the existing lease and executed a new lease with the new tenants. A copy of the Release is attached hereto as Exhibit "B" and incorporated herein by reference. The ease with the new tenants provided the __________ with a higher rent and will expire _____ (___) months later than the __________' lease. A copy of said new lease is attached hereto as Exhibit "C' and incorporated herein by reference. 8. After the __________ vacated the property and the new tenants moved in, the __________ on __________ ___, ____, requested a return of their security deposit. However, the __________ refused. Thereafter, on __________ ___, _____, the __________' attorney, on their behalf, made demand on the __________ pursuant to __________ Code Ann. Sec. __________ for the return of the security deposit and/or an itemization of any amount which the __________ claimed to be due from the security deposit. A copy of said __________ ___, _____ letter is attached hereto as Exhibit "D" and incorporated herein by reference. 9. In response to the __________ ___, _____ letter the __________ responded with a letter dated __________ __, _____. A copy of said letter is attached hereto as Exhibit "E" and incorporated herein by reference. While the __________ admit that the case was terminated and the __________ released, the __________ refuse to return the security deposit without setting forth any legitimate basis for withholding said sum. 10. More than ________ (____) days have passed since the __________ made demand on the __________ for return of their security deposit. However, the __________ have failed or refused to return the security deposit willfully and intentionally and without any legitimate or just reason for withholding the security deposit or any portion thereof. As a result, the __________ are entitled to a judgment against the __________, jointly and severally, in the principal sum of ___________ and No/100 Dollars ($00.00), plus additional damages of __________/100 Dollars ($00.00), as provided by __________ Code Ann. Sec. __________, pre - judgment and post - judgment interest, reasonable attorneys' fees and all costs of court. - 2 - WHEREFORE, PREMISES CONSIDERED, Plaintiffs __________ pray that summons issue against the Defendants __________, that the Defendants be cited to appear and answer herein, that upon a final hearing of __________, have a judgment entered against the Defendants, jointly and severally, in the principal amount of _____________ and No/100 Dollars ($00.00), plus damages in the amount of ______________ and No/100 Dollars ($00.00) as provided by __________ Code Ann. Sec. __________ pre - judgment or post - judgment interest, reasonable attorney's fees and all costs of court. AND, Plaintiffs pray for such other general and specific relief, which may be proper in the premises. THIS, the ____________ day of __________, _____. Respectfully submitted, _________________________ BY: _________________________ Attorney for Plaintiffs - 3 -