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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 William Duff, Plaintiff, v. IN THE 7 TH JUDICIAL CIRCUIT COURT OF MISSOURI COUNTY 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 Circuit 7 <S)b3 007

Motion Replevin

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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

Page 2: Motion Replevin

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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

Page 3: Motion Replevin

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