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BLANK TEMPLATE — Complaint and Summons
King County District Court, Civil Division
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This is general information, not legal advice. Filing a lawsuit has real
steps and deadlines; consider consulting an attorney. Replace EVERY
[bracket] with your own facts. Do not file another owner's numbers or
details as your own.

Format to Washington GR 14:
  - Letter-size (8.5 x 11), white paper, black text, printed one side.
  - First page: top margin AT LEAST 3 INCHES (room for the court stamp).
    This is the most common rejection reason.
  - All other margins (sides, bottom, top of later pages): at least 1 inch.
  - 12-point font, 1.5 line spacing. No color, no highlighting.


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THE COMPLAINT
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IN THE KING COUNTY DISTRICT COURT, STATE OF WASHINGTON
[DIVISION] DIVISION

[YOUR NAME(S)], Plaintiff(s),
v.                                          No. __________
DWELLINGS SEATTLE, INC., a Washington corporation;
and [PRINCIPAL NAME], individually, Defendants.

COMPLAINT FOR DAMAGES


I. PARTIES
1. Plaintiff [YOUR NAME] is the owner of the rental property at
   [PROPERTY ADDRESS].
2. Defendant Dwellings Seattle, Inc. is a Washington corporation
   (UBI 604 007 760, 3806 California Ave SW, Seattle).
3. Defendant [PRINCIPAL NAME] is listed in Secretary of State records as a
   governor/president who, on information and belief, controlled the
   company's trust account.

II. JURISDICTION AND VENUE
4. The amount in controversy is $[AMOUNT], within District Court limits
   and not over $100,000.
5. Venue is proper in King County because the property is here and the
   events occurred here.

III. FACTS
6. On [DATE], Plaintiff and Dwellings Seattle, Inc. entered a Property
   Management Agreement.
7. The Agreement required the company to collect rent from Plaintiff's
   tenants, hold it in trust, and remit it monthly less its fee.
8. Plaintiff's tenants paid rent.
9. The company collected [NUMBER] months of rent and did not remit it to
   Plaintiff.
10. The amount owed to Plaintiff is $[AMOUNT].
11. Plaintiff demanded payment in writing on [DATE] and terminated the
    Agreement on [DATE].
12. No payment or accounting followed.

IV. CAUSES OF ACTION  (state each in its own short paragraph)
13. Breach of Contract (against Dwellings Seattle, Inc.).
14. Conversion (against both Defendants).
15. Breach of Fiduciary Duty (against both Defendants — the company was
    Plaintiff's agent holding Plaintiff's funds in trust).
16. Money Had and Received (against both Defendants).

    (Owners have included the conversion and fiduciary-duty claims
    because, unlike a plain contract claim, they can attach to the
    individual and may survive a bankruptcy. Whether to plead them is
    your decision; consider legal advice.)

V. PRAYER FOR RELIEF
Plaintiff requests judgment against both Defendants, jointly and
severally, for $[AMOUNT]; prejudgment interest; costs and any attorney's
fees allowed; and other relief the court finds just.

Dated: [DATE]
/s/ [YOUR NAME]
[YOUR ADDRESS]
[YOUR PHONE]   [YOUR EMAIL]


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THE SUMMONS
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[Same caption as the Complaint.]

TO THE DEFENDANTS: A lawsuit has been started against you. To defend, you
must respond to the Complaint in writing and serve a copy on the
plaintiff(s) within 20 days after service of this Summons (60 days if
served outside Washington), or a default judgment may be entered against
you. If you serve a notice of appearance, you are entitled to notice
before default. You may demand that the plaintiff(s) file this lawsuit
with the court; that demand must be in writing and served on the
plaintiff(s), and within 14 days after service the plaintiff(s) must file,
or service is void. If you wish to consult an attorney, do so promptly.
This Summons is issued under RCW 4.28 and CRLJ 4.

Dated: [DATE]
/s/ [YOUR NAME]
Address where the defendant must serve their response:
[YOUR ADDRESS]

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