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William Duff,Plaintiff,
v.
IN THE 7TH JUDICIAL CIRCUIT COURT OF MISSOURICOUNTY OF CLAY - DIVISION 2
) CASE NO. 07CY-CV06125
) ACTION) FOR TRESPASS, AND) TRESPASS ON THE CASE
OFFICER WILLIAM FRAZIER, (SERIAL 3092)AND
OFFICER ALAN ROTH (SERIAL # 4090)Defendants.
) VERIFIED
MOTION FOR WRIT OF REPLEVIN
Comes now; William Duff (hereinafter Duff, he, him, I, me), one of the people of
Missouri, in this court of record, to seek replevin of specific property being held by
William Frazier (defendant herein) or his agents and who is attempting to dispose of
said property unlawfully, to wit;
1. Duff is the owner and/or the person lawfully entitled to the possession of the
property described as one 1996 Buick Riviera 1G4GD2215T4710668 (see Bill of
Sale copies attached)
2. The property is wrongfully detained by the defendant, and is held by an officer
under legal process who has refused delivery on demand
3. Defendant intends to dispose of Duff's Property on or about July 31, 2007
4. The instant petition proceeds upon the law of this case as referenced in Exhibit F
and the underlying action;
Factual Basis;
1. Duff owes no debt to defendant or its agents as related to the claim(s)
heretofore made;
william duff Page 1
AUG 0 1 2007
Clay County Circuit7<S)b3007
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4748495051525354555657
2. Defendant, armed with a gun, did, on or about June 5, 2007, seize Plaintiffs
Automobile and personal property therein and claimed to deliver same to tow
lot without Plaintiffs consent, wrong act or court order, judgment or ruling.
ARGUMENT;
Plaintiff, here states, that Frazier and his agents possess no lawful right, title or interest
in the property afore mentioned For the purpose of this writ, Duff wishes the immediate
return of the automobiles referenced above.
PRAYER, Duff demands this court issue order of this court for writ of replevin with
bond waived to be served immediately upon whoever has possession of the automobiles
herein identified and for that property to be returned to Duff, and for all costs related
thereto to be taxed against defendant and his agents, and for all other relief this court
can and should provide. Duff will provide last known location of said property to
Sheriff.
Respectfully
WilliamPlaintiff
Date:
william duff Page 2 7/31/2007
BILL OF SALE
I, Johnny Jones, the sole owner of all right, title and interest of every kind,
in the property described in detail at ebay.com in ebay.com's item #
4545916022, a 1996 Buick Riviera vin # Ig4gd2215t4710668, do cede all
right, title and interest to said property, as described above, to William D
Duff of 3030 NW Oak crest dr. K.C, Mo. 64151 in return for Two
Thousand-Eight Hundred-Fifty ($ 2,850.00) U.S. dollars tendered at the
signing of this document and in satisfaction of the auction agreement
between the parties as a result of the ebay auction.
J
-ones (Print Date
name here
Witness Signed
>TWitness: Signed
Linda Talley