Verified Complaint In Replevin {JDF 116}

JDF 116 R 8 - 1 8 VERIFIED COMPLAINT IN REPLEVIN Page 1 of 4 County Court District Court County, Colorado Court Address: Plaintiff(s)/Petitioner(s): v. Defendant(s)/Respondent(s): COURT USE ONLY Attorney or Party Without Attorney (Name and Address): Phone Number: E - mail: FAX Number: Atty. Reg. #: Case Number: Division Courtroom VERIFIED COMPLAINT IN REPLEVIN The Plaintiff(s) brings this action to recover the possession of p ersonal property pursuant to Rule of Civil Procedure 104 or Rule of County Court Civil Procedure 404. In support of this Complaint, the Plaintiff(s) states: 1. This County Court District Court has jurisdiction over this matter pursuant to 24713 - 6 - 104(1), C.R.S. based on the value of the personal property claimed being $ . 2. Venue is proper as the Defendant(s) resides in this county, and all acts pert aining to the claims identified in this complaint took place in this county. 3. A complete list and valuation of the personal property claimed is attached to this Complaint and marked as 4. Plaintiff is the owner of the property claimed or is en titled to possession of the property because : 5. possession. American LegalNet, Inc. www.FormsWorkFlow.com JDF 116 R 8 - 1 8 VERIFIED COMPLAINT IN REPLEVIN Page 2 of 4 6. The means by which the Defendant(s) came into possession of the property and the specific facts constituting detention against the right of the Plaintiff(s) to possession are as follows: (State the source of your right to the property, how the Defenda nt(s) took possession, and why you believe the Defendant(s) is/are wrongfully detaining the property from you.) 7. and belief, the Defendant(s) residence and business address are as follows: Residence Address Business Address 8. To the best of Plaintiff(s) knowledge, information and belief, the property at issue presently is located at the following address: 9. Plaintiff(s) has made demand upon the Defendant(s) for return of the property. Plaintiff(s) has not received the property from the Defendant(s) despite such demand and c ontinues to be deprived of the use and enjoyment of the property. 10. The property at issue has not been taken for a tax assessment or a fine pursuant to statute; or seized under an execution against the property of the Plaintiff(s); or if so seized, it is b y statute exempt from seizure. 11. Pursuant to CRCP 104 or CRCCP 404, the Plaintiff(s) is entitled to an order of this Court directing the valu e thereof, if delivery cannot be made, and for damages for detention of the property. American LegalNet, Inc. www.FormsWorkFlow.com JDF 116 R 8 - 1 8 VERIFIED COMPLAINT IN REPLEVIN Page 3 of 4 WHEREFORE, Plaintiff(s) respectfully requests the following relief: That the Court issue an Order to Show Cause directed to the Defendant(s) to show cause why the property listed in the Complaint should not be taken from the Defendant(s) and delivered to the Plaintiff(s); That the Court set a Show Cause Hearing within 14 days as required by CRCP Rule 104(c) or CRCCP 404(c), to make a preliminary determination concerning the right to possession of all property described in the Complaint; That the Court enter judgment for the Plaintiff(s) for the possession of the property listed in the C omplaint or for the value thereof, in case delivery cannot be made, plus d amages for detention and for any property not returned or returned in damaged condition; and That the Court award the Plaintiff(s) court costs, attorney fees (if any), plus such other relief as is just and proper. Other: By checking t his box, I am acknowledging I am filling in the blanks and not changing anything else on the form. By checking this box, I am acknowledging that I have made a change to the original content of this form. VERIFICATION I declare under penalty of perjur y under the law of Colorado that the foregoing is true and correct. Executed on the day of , , at (date) (month) (year) (city or other location, and state OR country (printed name of Plaintiff/Petitioner) Signature of Plaintiff/Petitioner Address P h one Number (Home) (W ork) VERIFICATION I declare under penalty of perjury under the law of Colorado that the foregoing is true and correct. Executed on the day of , , at (date) (month) (year) (city or other location, and state OR country (pri nted name of Plaintiff/Petitioner) Signature of Plaintiff/Petitio ner Address P h one Number (Home) (W ork) American LegalNet, Inc. www.FormsWorkFlow.com JDF 116 R 8 - 1 8 VERIFIED COMPLAINT IN REPLEVIN Page 4 of 4 E XHIBIT A Property Seized Value TOTAL American LegalNet, Inc. www.FormsWorkFlow.com