Complaint for Replevin

IN THE COUNTY COURT,

IN AND FOR MARION COUNTY, FLORIDA

REDACTED                                                 Case Number:

Plaintiff

vs.

REDACTED

Defendant

____________________________________/

COMPLAINT FOR REPLEVIN

            Plaintiff, Redacted, sues Defendant, Redacted, and alleges:

1. This is an action to recover personal property in Marion County, Florida.

2. The description of the property is (list

property): a golf cart and miscellaneous items contained therein. To the best of Plaintiff’s knowledge, information and belief, the value of the property is: $5,700.00.

1. Plaintiff is (complete the appropriate letter or modify paragraph if the right to possession arose in another manner):

a. The owner of the above described property having acquired title by purchase.

1. To Plaintiff’s best knowledge, information and belief, the property is located at:

Redacted

2559 SW HWY 484

Redacted, FL 34473.

1. The property is wrongfully detained by Defendant. The Defendant came into possession of the property by (describe how the Defendant came into possession of said property):

Plaintiff paid a 6 month storage fee to store golf cart in Defendant’s shed until October 2009.

To Plaintiff’s best knowledge, information and belief, Defendant detains this property because (give reasons): The Defendant obtained a new management company without Plaintiff’s knowledge and Plaintiff believes that the new management will not honor storage agreement for golf cart.

1. The property has not been taken for any tax, assessment or fine, pursuant to law.

2. The property has not been taken under an execution or attachment against Plaintiff’s property.

WHEREFORE, Plaintiff demands judgment for possession of the property or damages for its wrongful detention and/or value.

STATE OF FLORIDA

COUNTY OF MARION

The undersigned, being first duly sworn, says that: he/she is the agent for the above-named Plaintiff; that the foregoing is a just and true statement of the amount owing by the above-named Defendant to said Plaintiff, exclusive of all set-offs and just grounds of defense; and, that this suit is brought in good faith and with no intention to annoy said Defendant.

Plaintiff

Telephone Number

SWORN TO AND SUBSCRIBED before me, on _____________________, 20____, by ________________________,

who is personally known to me / who presented ___________________________as proof of identification.

By_________________________________________

Notary Public, State of Florida Deputy Clerk