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COMPLAINT

Plaintiff, A. B., sues defendant, C. D., and alleges:

1. This is an action to recover possession of personal property in ……………….. County, Florida.

2. The description of the property is:

(list property)

To the best of plaintiff’s knowledge, information, and belief, the value of the property is $……….

3. Plaintiff is entitled to the possession of the property under a security agreement dated ………., a copy of the agreement being attached.

4. To plaintiff’s best knowledge, information, and belief, the property is located at ……….

5. The property is wrongfully detained by defendant. Defendant came into possession of the property by (method of possession). To plaintiff’s best knowledge, information, and belief, defendant detains the property because (give reasons).

6. The property has not been taken for any tax, assessment, or fine pursuant to law.

7. The property has not been taken under an execution or attachment against plaintiff’s property.

WHEREFORE plaintiff demands judgment for possession of the property.

NOTE: Paragraph 3 must be modified if the right to possession arose in another manner. Allegations and a demand for damages, if appropriate, can be added to the form.