IN THE CIRCUIT COURT OF THE STATE OF XXX
IN AND FOR THE COUNTY OF XXX
|
XXX;
Plaintiff, vs.
THE RESIDENCES AT OMNI APARTMENTS; Defendant. |
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Case No.
PLAINTIFF’S ORIGINAL COMPLAINT |
NOW COMES XXX, Plaintiff, and files this Complaint against The Residences at Omni Apartments, Defendant, and for cause would show this Honorable Court as follows:
PARTIES
- Plaintiff Alicia XXX is a female adult of sound mind and a resident of XXX County, Commonwealth of XXX,
- Defendant Residences at Omni Apartments are apartment housing units leased out to tenants at XXX.
JURISDICTION AND VENUE
- Jurisdiction exists in this Court pursuant to Section 23A.010 of Kentucky Revised Statutes.
- Venue is proper in this Court because the causes of action herein took place within Jefferson County and Defendant is a resident of XXX.
STATEMENT OF FACTS
- Defendant contacted Plaintiff through its employee/agent and informed her that she had been living on Defendant’s apartments located at XXX XXX for the past two years.
- Defendant informed Plaintiff that a woman named “Oldham” had lived in the apartments.
- However, Plaintiff has never lived or even gone to the aforementioned address of Defendant’s apartments.
- During the past two years, Plaintiff has resided in XXX.
- Plaintiff has never entered into a lease agreement or tenancy contract with Defendant.
- Plaintiff seeks to be granted the reliefs requested herein.
ARGUMENT
- Plaintiff incorporates all foregoing paragraphs by reference as though set out in full herein.
- Plaintiff has never lived in Defendant’s apartments.
- While Defendant insists that a woman named “XXX” lived in the apartments for the past two years, it is a case of identity theft of Plaintiff’s name by the person who allegedly lived in the apartments for the past two years.
- Section 514.160(1) of the XXX Revised Statutes provides that: “A person is guilty of the theft of the identity of another when he or she knowingly possesses or uses any current or former identifying information of the other person or family member or ancestor of the other person, such as that person’s or family member’s or ancestor’s name, address, telephone number, electronic mail address, Social Security number, driver’s license number, birth date, personal identification number or code, and any other information which could be used to identify the person, including unique biometric data, with the intent to represent that he or she is the other person for the purpose of: © Making financial or credit transactions using the other person’s identity.”
- Someone else used Plaintiff’s maiden name, Oldham, to enter into contract with Defendant and live in Defendant’s apartments.
- That person used Plaintiff’s name so that Plaintiff would be held liable for whatever breach or violation by that person.
- Defendant is now pursuing Plaintiff under the impression that Plaintiff is the woman who lived in the aforementioned address of Defendant’s apartments.
PRAYER FOR RELIEF
REASONS WHEREFORE, PREMISES CONSIDERED, Plaintiff respectfully requests this Honorable Court to GRANT her the following reliefs:
- GRANT judgment in favor of Plaintiff and against Defendant;
- ISSUE a declaration that this is a case of identity theft;
- AWARD Plaintiff such equitable relief as this Court deems fair under the circumstances; and
- AWARD Plaintiff such further relief as this Court deems proper.
Dated this XXX,
Respectfully Submitted,
XXX,
Plaintiff in pro per
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