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IN THE _________________ COURT OF __________________ (County),
____________________ (State)
________________________ PLAINTIFF
(Name of Plaintiff)
V. CAUSE NO. ______,______
_____________________________ DEFENDANTS
(Name of Director) Missouri Department of Revenue,
____________________ and ___________________
COMPLAINT
COMES NOW _____________________ (Name of Plaintiff) , Plaintiff in the
above-styled and numbered cause, and files this his Complaint against Defendants,
_____________________________________________ (Names of Defendant) , and in
support thereof would show unto the Court the following matters and facts:
1.
Plaintiff is an adult resident citizen of ___________________________________
_______________________________ (street address, city, county, state, zip code) .
2.
______________________ (Defendant Alpha) is an adult resident citizen of
______________________________________________________________________
(street address, city, county, state, zip code) .
3.
_______________________ (Defendant Beta) is an adult resident citizen of
______________________________________________________________________
(street address, city, county, state, zip code) .
4.
Defendant ______________________ (Name of Director) Missouri Department
of Revenue, is being named a party to this suit so that he will issue a replacement
certificate of title to Plaintiff upon proof of Plaintiff’s case and a ruling by this Honorable
Court in Plaintiff’s favor. ______________________ (Name of Director) may be served
with process of this Court at his office located at ________________________________
_______________________________ (street address, city, county, state, zip code) .
5.
On or about __________________ (date) , Plaintiff purchased an automobile
from Defendant Alpha , which automobile can be more particularly described as (put as
much of the following information in the complaint as you know) :
Make ______________________________________
Model _____________________________________
Year _______________________________________
VIN ________________________________________
6.
On or about _______________________ (date) , Plaintiff discovered that
Defendant Alpha did not have title to said automobile.
7.
Title to said automobile is listed in the name of Defendant Beta , who has
abandoned said title.
8.
Plaintiff submits that he is a good faith purchaser for value of said automobile
and was defrauded by Defendant Alpha . Plaintiff furthers offer as proof of ownership
the following: (cancelled check, bill of sale, letters, etc., that would show that you
purchased the automobile from Defendant Alpha) ___________________________
_______________________. Copies of the aforesaid are attached hereto as Exhibits
A, B, C, etc . and made a part of this Complaint by reference thereto.
WHEREFORE, Plaintiff requests that this Honorable Court issue a judgment that
he is the true and rightful owner of said Automobile and that Missouri Department of
Revenue should issue to him a certificate of title pursuant to the laws of the state of
Missouri to that effect.
Respectfully submitted,
_____________________________
Printed Name of Plaintiff
_____________________________
Signature of Plaintiff
State of Missouri
County of _____________
Personally appeared before me, the undersigned authority in and for the
aforesaid jurisdiction, the within named ______________________ (Name of Plaintiff) ,
who, after being by me first duly sworn, did depose and say that the facts set forth in the
above and foregoing Complaint are true and correct as therein stated.
_____________________________
Printed Name of Plaintiff
_____________________________
Signature of Plaintiff
Sworn to and subscribed before me, this the ___ day of __________, 20_____.
_____________________________
Notary Public or Deputy Clerk
My Commission Expires: SEAL
_____________________
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