Case No. ______________

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

• Plaintiff, [ENTER NAME], is an individual, a resident of [ENTER ADDRESS].
• Defendant, [ENTER NAME] of address is a Home Owner’s Association of address [ENTER ADDRESS].

JURISDICITON AND VENUE

• 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.
• 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, _______.

FACTS

• [ENTER FACTS].    

CLAIMS FOR RELIEF

COUNT 1

Trespass

• 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

• 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

1. Plaintiff hereby incorporates by reference all the allegations contained in all the preceding paragraphs of this complaint as though fully stated herein.
2. 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.
3. 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.

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:

1. Declaratory relief;
2. Actual damages for the blameworthy conduct of the Defendant as alleged herein;
3. Punitive damages;
4. Interest as provided by law;
5. An award of fees and costs;
6. Such other relief as the Court deems just and proper.

Respectfully submitted:

Dated: __________

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]