Fill and Sign the Shoplifting Store Form

IN THE ______________ COURT OF _______________ (County), _______________ (State) ________________________ PLAINTIFF (Name of Plaintiff) V. CAUSE NO. _______,_______ _________________________ DEFENDANTS (Name of Defendants) 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, _____________________ (name of plaintiff) , is now, and at all times relevant to this action was, a resident of ___________________ (county) 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 ___________________ (county) , __________________ (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) 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 ________ (his/her) 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) 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 (specify particular item of merchandise) _________________ ________________________________________ costing $__________, and departed from the store. As Plaintiff proceeded along a public thoroughfare in the City of ________________ (city) , ____________________ (county) 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 (identify item store manager accused plaintiff of stealing; for example: bottle of perfume") __________________________ , 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, _______________________ (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: ______-______-__________