Complaint for Defamation and False Accusation

COMPLAINT

IN THE COURT OF (County), (State)

PLAINTIFF
(Name of Plaintiff)

V. CAUSE NO.

DEFENDANTS
(Name of Defendants)

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, (name of plaintiff), is now, and at all times relevant to this action was, a resident of County, (state), residing at (address of plaintiff).

2. Defendant (name of retailer) is now, and at all times relevant to this action was, a corporation organized and existing by virtue of the laws of the (state of incorporation), with its registered office in the County of , (state), which corporation has an agent and employee residing and employed within this jurisdiction on whom service of process may be had.

3. Defendant (name of store manager) is now, and at all times relevant to this action was, a resident of County, (state), residing at (address of store manager).

4. At all times mentioned in this complaint, Defendant (manager) was the agent and employee of Defendant (company) and acting within the scope of (his/her) authority as such and in the furtherance of the business of employer.

5. At all times mentioned in this complaint, Defendant (name of retailer) was engaged in the retail merchandise business and in the furtherance of that business, it kept and maintained a store in the City of (city), County, (state), where it kept goods, wares, and merchandise for sale to the general public, and the general public was especially invited to enter the store and make purchases of such goods, wares, and merchandise.

6. At all times mentioned in this complaint, Defendant (name of retailer) engaged Defendant (name of store manager), as its manager, in general charge of the operation and management of the above-mentioned store. On (date), at the special invitation of Defendants, Plaintiff entered the store, purchased, and paid for costing $ , and departed from the store. As Plaintiff proceeded along a public thoroughfare in the City of , County, (state), Defendant (name of store manager) walked hurriedly toward Plaintiff and falsely and maliciously accused Plaintiff in a loud and commanding voice, as follows: "I want to see what is in that bag; you have stolen a , or words to that general effect. Defendant (name of store manager) approached Plaintiff on the public thoroughfare, and in the presence of other persons, forcibly and unlawfully seized the bag held by Plaintiff and looked into it and forcibly and unlawfully removed plaintiff from the public street and into the store. Defendant (name of store manager) there and then compelled Plaintiff to go to (his/her) office and remain there for approximately (period of time).

7. As a direct and proximate result of the false accusation, and Plaintiff's unlawful detention, Plaintiff was humiliated, embarrassed, and shocked, suffered great and lasting mental anguish, and was thereby injured and damaged in Plaintiff's good name and reputation, and as a proximate result thereof, Plaintiff has been damaged in the sum of $ .

WHEREFORE, Plaintiff requests judgment against Defendants, and each of them, jointly and singly, for the following:

1. Compensatory damages in the amount of $ ;

2. Interest on such damages awarded according to law;

3. Costs of suit; and

4. Such other and further relief as the court deems just and proper.

Dated: .

Respectfully submitted,

OF COUNSEL: