Fill and Sign the Seeking Damages 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 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 an adult resident citizen of ______________________________________ (city, county, state) . 3. On _________________ (date) , Plaintiff was the owner and had right of possession to certain personal property, described as follows: (describe personal property) _____________ ____________________________________________________________________________ . This personal property was stored at ______________________________________________ __________________________ (street address, city, county, state, zip code) . 4. On _________________ (date) , Defendant, with knowledge that the personal property was owned by Plaintiff, took and unlawfully converted it to his own use and benefit. 5. On finding out that Defendant had unlawfully converted Plaintiff's personal property, Plaintiff demanded that Defendant return it or reimburse Plaintiff for its value. However, Defendant refused to return the personal property to Plaintiff or to reimburse him for the value, and has continually refused to do so up to the time of filing this suit. 6. At the time and place of the conversion of Plaintiff's personal property, its market value was $____________, for which Plaintiff is entitled to recover, as well as ______ % percent legal interest on the value of the personal property from the date of the conversion up to the present. 7. The taking and conversion of the personal property by Defendant was done willfully and maliciously, with a reckless disregard for Plaintiff's rights. After demand was made on Defendant to return the personal property or reimburse Plaintiff for its value, Defendant willfully and maliciously refused to return the personal property, or reimburse Plaintiff. For such willful and malicious acts on the part of Defendant, Plaintiff seeks $____________ as punitive damages in addition to ____________ his actual damages. Wherefore, premises considered, Plaintiff requests that he receive: 1. A judgment against Defendant for the market value of the personal property converted by Defendant at the time and place of the conversion, this value being $__________; 2. Interest on this amount at the rate of ______ percent from the date of conversion to the present date; 3. Punitive Damages in the amount of $____________ for the willful and malicious acts of Defendant; 4. Interest on such judgment from its date at the rate of _____ %; 5. All costs of suit; 6. And all other and further relief as Plaintiff may be entitled to receive. Respectfully submitted this the ________________ (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: _______-______-__________