Chapter 15 - EXHIBIT 15A • SAMPLE COMPLAINT FOR CONVERSION

• Jurisdiction: Colorado

EXHIBIT 15A • SAMPLE COMPLAINT FOR CONVERSION

[ ] District Court [ ] County Court County, Colorado Court Address:	COURT USE ONLY
Plaintiff(s): v. Defendant(s):
Attorney or Party Without Attorney (Name and Address) Phone Number: E-mail: Atty. Reg. #:	Case Number: Div.: Ctrm.:
COMPLAINT AND JURY DEMAND[1 ]

Plaintiff, by his/her/its counsel, complains against the Defendant(s) as follows:

PARTIES, JURISDICTION, AND VENUE

1. The Plaintiff is [a resident of (county) County, Colorado OR a (type of business entity) organized under the laws of (state) with its principal place of business at (street address), (city), (state and zip code)].

2. The Defendant is [a resident of (county) County, Colorado OR a (type of business entity) organized under the laws of (state) with its principal place of business at (street address), (city), (state and zip code)].

3. [If the defendant does not reside in Colorado or is not organized under Colorado law, add: As a nonresident of Colorado, the defendant is subject to the jurisdiction of this court pursuant to the Colorado Long-Arm Statute, as it has transacted business and committed tortious acts within this State pursuant to C.R.S. § 13-1-124.]

4. This Court has jurisdiction over the subject matter at issue because this is a civil action for damages and/or equitable relief. Colo. Const. Art. VI, § 9(1). [Adjust as needed to address requirements of federal rules or statutes.]

5. Venue in this court is proper pursuant to [specify basis for venue, per C.R. C.P. 98, and cite relevant subsection of C.R.C.P. 98]. [Adjust as needed to address requirements of federal rules or statutes.]

FIRST CLAIM FOR RELIEF (Conversion)

6. Plaintiff incorporates the foregoing allegations.

7. Plaintiff is [the rightful owner of OR entitled to immediate possession of (describe personal property, such as: monies in the form of cash, insurance premiums, checks, stocks, etc.)].

8. On or about [date] Defendant converted [describe personal property, such as: personal property OR monies in the form of (cash, insurance premiums, checks, stocks, etc.)] that was the property of the Plaintiff by exercising dominion and control over the property by [describe act of dominion or control].

9. [Where the defendant is in lawful possession of the property in question, add: On (date) the plaintiff demanded the return of the (personal property), but the defendant failed to return the property to the plaintiff and continues to refuse to return it.]

10. Defendant's exercise of dominion or control over Plaintiff's personal property is unauthorized.

11. Plaintiff has demanded that Defendant return the personal property to Plaintiff.

12. To date, Defendant has failed and refused to return the personal property to Plaintiff.

13. As of the date Defendant refused to return this [personal property], the [personal property] had a value of...