Fill and Sign the Security Deposit 497319466 Form

JOHN LAWYER, ESQ. 12 MAIN STREET ANYWHERE, USA Attorney for Plaintiff _____________________________ JOHN DOE, Plaintiff(s), v. JANE DOE, Defendant(s). _____________________________ SUPERIOR COURT OF NEW JERSEY LAW DIVISION:SPECIAL CIVIL PART [insert] COUNTY DOCKET NO.: CIVIL ACTION COMPLAINT (CONTRACT) Plaintiff, John Doe, maintaining his principal place of residence at [insert address], by way of Complaint against the Defendant hereby says: 1. Defendant, upon information and belief, is the owner of a residence at [insert address]. 2. On or about [insert date], the parties entered into a written lease agreement for plaintiff = s residential use of [insert address]. 3. Pursuant to this lease agreement, a security deposit of $[insert] was posted by plaintiff. 4. The [insert date] lease was defective in that it did not indicate where plaintiff = s security deposit was being held. 5. Furthermore, at no time during the tenancy did defendant identify the specific location of plaintiff = s security deposit. 6. Plaintiff vacated the premises at [insert address] on [insert date] 7. However, it was not until [insert date], that plaintiff was in receipt of an invoice from an entity known as [insert]., which indicated that the entire amount of the security deposit plus $[insert], was being charged to plaintiff = s account. Accordingly, no security deposit was being returned to plaintiff. 8. Plaintiff has received no further communication regarding the return of his security deposit. 9. Defendant has violated New Jersey = s Security Deposit Act which is codified at N.J.S.A. 46:8-19 et. seq., by failing to disclose the location of plaintiff = s security deposit when the lease was executed. 10. Additionally, defendant violated New Jersey = s Security Deposit Act by failing to account as to plaintiff = s security deposit within thirty (30) days of plaintiff = s vacating the rental premises. 11. Finally, defendant has made a number of bogus, unauthorized and unwarranted deductions from plaintiff = s security deposit thus warranting the imposition of damages against defendant for violation of the Security Deposit Act. WHEREFORE, the Plaintiff demands judgment against the Defendant as follows: a. Pursuant to N.J.S.A. 46:8-21.1 plaintiff seeks the return of any and all security deposit monies deposited under the [insert] lease including the doubling of said amount; b. Costs of suit; c. Attorney = s fees; d. For such other relief as the Court may deem equitable and just. DESIGNATION OF TRIAL COUNSEL Pursuant to R. 4:25-4, John Lawyer, Esq. Is hereby designated as trial counsel in this matter. CERTIFICATION I hereby certify that the matter in controversy in this action is not the subject of any other actions pending in any court or of a pending arbitration proceeding, no other action or arbitration proceeding, no other action or arbitration is contemplated and no other parties must be joined in this action. Dated: ______________________________ JOHN LAWYER, ESQ.