Case No. ______________
[ENTER NAME],
Plaintiff
vs.
[ENTER NAME],
Defendant
Case No. ______________
Honorable: _____________
COMPLAINT
1. COMES NOW Plaintiff [ENTER NAME], with this complaint against the
Defendant [ENTER NAME]. Plaintiff action seeks to hold Defendant liable for their
blameworthy actions and/or inactions towards Plaintiff, as described below.
2. Plaintiff therefore seeks damages and declaratory relief against the Defendant.
PARTIES
3. Plaintiff, [ENTER NAME], is an individual, a resident of [ENTER
ADDRESS].
4. Defendant, [ENTER NAME] of address is a Home Owner’s Association of
address [ENTER ADDRESS].
JURISDICITON AND VENUE
5. This Court has jurisdiction over the Defendant because Defendant has
conducted business and/ or committed torts in a manner to establish contacts necessary for
the imposition of the jurisdiction of this Court. This Court has jurisdiction over the subject
matter because the damages are within the jurisdictional limits of this court.
6. Venue is proper in this this County pursuant to ___________ because the facts
constituting the causes of action herein occurred in whole or in part in _________ County,
_______.
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FACTS
7. [ENTER FACTS].
CLAIMS FOR RELIEF
COUNT 1
Trespass
8. Plaintiff hereby incorporates by reference all the allegations contained in all
the preceding paragraphs of this complaint as though fully stated herein.
COUNT 2
Intentional infliction of Emotional Distress
9. Plaintiff hereby incorporates by reference all the allegations contained in all
the preceding paragraphs of this complaint as though fully stated herein.
COUNT 3
Declaratory Relief
10. Plaintiff hereby incorporates by reference all the allegations contained in all
the preceding paragraphs of this complaint as though fully stated herein.
11. There now exists, between the parties hereto, a dispute and controversy to
which the Plaintiff and the Defendant are entitled to have a declaration of their rights and
further relief relating to the facts and circumstances as set forth in this action.
12. Plaintiff respectfully request this Honorable Court issue a declaratory
judgment declaring that the actions and/or inactions of the Defendant violates the rights of
Plaintiff, and issue appropriate remedies thereof.
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PRAYER FOR RELIEF
WHEREFORE, the Plaintiff is entitled to damages from the Defendant, and he hereby
prays that judgment be entered in his favor and against the Defendant and the following relief
be issued:
i. Declaratory relief;
ii. Actual damages for the blameworthy conduct of the Defendant as alleged herein;
iii. Punitive damages;
iv. Interest as provided by law;
v. An award of fees and costs;
vi. Such other relief as the Court deems just and proper.
Respectfully submitted:
Dated: __________
______________________________
[ENTER NAME]
.
Pro se
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CERTIFICATE OF SERVICE
I hereby certify on the ____________day of _______________, 2023, that a true and correct
copy of the foregoing Complaint were served by placing a copy in the United States Postal
Service, with postage prepaid, addressed upon the following:
SERVICE ON:
[ENTER ADDRESS]
______________________________
[ENTER NAME].
Pro se
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