Sample Complaint

Sample Complaint

STATE OF. ) SUPERIOR COURT
) SS:
COUNTY OF ) SITTING IN

KAREN ADAMS, )
Plaintiff )
)
v. ) CAUSE:000-111-222-333
)
CHANDLER DEPARTMENT )
STORE, INC; PAT CURRAN, )
STORE MANAGER, )
Defendant )
)
) JURY TRIAL
) DEMANDED

COMPLAINT

1. At all times mentioned, the defendant was and still is engaged in operating a department store at 123 Mall Plaza in the City of Valparaiso, County of Porter and State of Indiana.
2. On November, 1, 2006, at about one o’clock in the afternoon of that day, plaintiff was lawfully in defendant’s store for the purpose of purchasing certain of the merchandise, and, while waiting for a salesperson took her own bottle of perfume out of her purse and applied some then put the perfume back into her purse.
3. After a salesman never came to help her, plaintiff left the store.   As she was leaving, she was forcibly and violently seized and laid hold of by a store detective, employed by defendant, and acting under such employment and within the scope of their authority.
4. At the same time the store detective falsely, publicly, and maliciously accused the plaintiff of having stolen from the defendant one bottle of Chanel No. 5 perfume.
5.Thereupon, the detective, acting as an agent and servant of the defendant acting under their employment as such within the scope of their authority,   forcibly took her purse and searched it, finding the plaintiff’s bottle of perfume she had brought into the store.
6. The store detective then called the store manager to the security office, where plaintiff     explained that she had not stolen the bottle, and that it in fact belonged to her.
7. At this point, the manager, whom seemed nervous at this point, offered to release plaintiff on the condition that she would sign a form, releasing the store of liability.
8. Plaintiff refused to sign release, and the manager, acting as an agent of defendant of employer, and within the scope...