Fill and Sign the Repossession 497330026 Form

IN THE ______________________ COURT OF ______________________ (County), _________________________________ (State) ________________________________________ PLAINTIFF (Name of Plaintiff) V. CAUSE NO. ______,______ ______________________________ ___________ DEFENDANT (Name of Defendant) COMPLAINT COMES NOW ____________________________________ (Name of Plaintiff), Plaintiff in the above-styled and numbered cause, by and through his attorneys, and files this his Complaint against Defendant, ___________________________________ (Name of Defendant), and in support thereof would show unto the Court the following matters and facts: 1. Plaintiff is an adult resident citizen of ___________________________________ ____________________________________ (city, county, state) . 2. Defendant is, and at all times mentioned was, a corporation organized and existing under the laws of ______________________________ (state) , engaged in the general credit and collection business, including the repossession of automobiles for creditors holding liens on those automobiles. 3. On _____________________________ (date of repossession) , plaintiff was the owner of a (describe auto, e.g., year, make, and model) __________________________ ______________________________________________________ automobile , subject to a retail installment sales contract in favor of __________________________________ _________________________ (name of bank or finance company) . On that date, defendant, by its agents or employees, illegally unlocked or broke into the automobile owned by plaintiff, converted it to defendant's own use and drove the automobile from plaintiff's residence at _____________________________________________________ __________________________________ (street address, city, county, state, zip code) to ________________________________________________________________________ ___________________________________ (street address, city, county, state, zip code) . 4. Plaintiff demanded that defendant return the automobile to him, but the demand was refused by defendant. Plaintiff was wrongfully compelled to pay ________________ ( dollar amount) in cash to defendant before regaining possession of the automobile. 5. As a direct result of the illegal conversion on the part of defendant, plaintiff was compelled to spend _______________________ ( dollar amount) to locate and recover the automobile. 6. Defendant's action in taking and converting plaintiff's automobile was willful, intentional, and malicious and with the intent to oppress and harass plaintiff. 7. As a direct result of the wrongful conversion of the automobile, and because of the manner in which it was taken without his knowledge or consent, plaintiff has been caused to suffer embarrassment and humiliation in plaintiff's community, and plaintiff has been held up to public ridicule. 8. As a direct result of the conversion of the automobile by defendant, plaintiff's credit has been impaired, and plaintiff has been damaged. 9. As a direct result of the repossession of the automobile by defendant, plaintiff has been damaged in the amount of ________________________ ( dollar amount) as well as punitive damages as set forth below. WHEREFORE, plaintiff requests judgment against defendant for: 1. Damages in the amount of ___________________ ( dollar amount) to with interest on that amount at the legal rate from ______________________________ (date) ; 2. Punitive damages in the amount of ______________________ ( dollar amount) . 3. Costs of suit; and 3. Such other and further relief as the court deems just and proper. Respectfully submitted on this ___________________________________ (date) . ____________________________________ (Name of Plaintiff) By: ________________________________ (Name of Plaintiff’s Attorney) State Bar No. __________________ One of His Attorneys OF COUNSEL: ________________________________________ (Name of Plaintiff’s Attorney) Post Office Box _________-________ City, State, Zip Code ______________________________________________________ Telephone: ________-________-___________