Fill and Sign the Instructions for Complaint for Divorce with Minor Holmes County 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 _______________
1/2/2003. 5. Defendant, was the owner and operator of a (describe automobile) automobile which is the vehicle operated by the plaintiff. 6. At all times herein mentioned, plaintiff drove the vehicle in violation of the provisions of article 2, chapter 13, § 37-1., ,7. Defendant, at all times herein mentioned, was aware of and consented to the operation of the vehicle by the plaintiff. 8. Defendant and all passengers present were, a passenger is subject to license-suspension, shall be subject to a non-revocable order directing them to notify DMV of change of address within 2 days. 9. Any such order shall be in writing, and shall contain a description of the vehicle and the date the order was received by the county. 10. The order shall give the person named in the order the right to request to appear before the court upon request, at a date that will not be unreasonably delayed.” the complaint was served on , defendant, as the defendant, and on , the defendant in his capacity as a parent or guardian of the plaintiff, as the parent or guardian of the plaintiff, and on , the defendant as counsel for defendant. The complaint also was served on , and on , all other occupants of the automobile, who appear in person in the county. Respondent filed a petition for an order requiring that the automobile be returned to the petitioner. That petition stated as follows: “respondent has been informed of the fact that petitioner has owned the vehicle for approximately one year, and during this period the car has not been in respondent's possession for longer than ten days. Since respondent was aware that petitioner owned and operated the vehicle and for a number of years prior to the commencement of this matter, (the last time that the car was rented with respondent as a driver) was informed by an acquaintance that respondent intended to lease the vehicle to another of petitioner's acquaintances, this information and the fact that the car had been rented at least since the last time petitioner rented it, was well known to respondent. Respondent, however, knew that the car would not be returned to petitioner, and, in the absence of any other relevant fact, was not required to disclose that the car was rented. The parties subsequently exchanged a copy of the pleadings as follows: “on september 7, 2003 respondent received notice from DMV that it had filed a lien against the car and its contents on the records