IN THE COURT OF COMMON PLEAS
XXX
XXX, )
XXX, )
XXXX )
)
Plaintiff )
)
vs )
)
XXX Department of Parks & Recreation )
XXX
XXXX5 )
)
Defendant )
Now comes the Plaintiff, ZZZ, hereby submits his/her complaint as follows:
1. That the XXX Department of Parks & Recreation is in control of the
property located right outside the plaintiff’s home. The city therefore owns the rights
and responsibilities that come with the tree.
2. The tree has been dead for years and constantly has branches falling on the plaintiff’s
sidewalk and in front of her home, thereby causing disturbance and nuisance. This is
because they create a danger to passers-by and the plaintiff as well.
3. On or about the XXX, the plaintiff submitted a formal online
complaint to the defendant department. The complaint was later updated the next day,
the XXX and allocated SR Number XXX.
4. The Defendant department informed the plaintiff that they had created a work order
for the tree and expects to address the issue within 120 days from the date of the tree
assessment.
5. However, upon the lapse of the 120 days from the date the defendant department
received the complaint and beyond, no action has been taken in accordance with their
notification to the plaintiff.
REASONS WHEREFORE, the Plaintiff, XXXX prays for judgement against the
defendant in an amount yet to be determined, and to ensure compliance in the removal of the
dead tree and a replanting of a healthier tree.
XXXX,
XXX
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