IN THE COUNTY COURT COLUMBIA COUNTY, FLORDA

BEST BUY CARS, INC.

A Florida Corporation,
Plaintiff,
Vs. CASE NO.
MARGARET DONOFREY and
HENRY DONOFREY, individually,
Defendants.

COMPLAINT FOR DAMAGES

Plaintiff, BEST BUY CARS, INC., sues Defendants, MARGARET DONOFREY

and HENRY DONOFREY, individually, and says :

COUNT I　AGAINST MARGARET DONOFR ＥＹ

　　１ This is a cause of action for damages in excess of $2, 500 but not exceeding
$10,000.
2 At all times material to this cause of action, Plaintiff has been and is a Florida
corporation engaged in the trade of selling automobiles to the public.
3 On or about January 21, 1990, Defendant MARGARET DONOFREY was a
customer at Plaintiff,s place of business for the purpose of purchasing an automobile,
a 1989 Alora Supra.
4 As partial payment for this automobile, defendant MARGARET DONOFREY
offered as trade the automobile she was driving, a 1988 Matsuda A 240, subject to
security interest of National Motors Financing Corporation.
5 Defendant MARGARET DONOFREY falsely represented to Plaintiff,contrary to
the title certificate which listed Defendant HENRY DONOFREY as joint owner, that
she was the sole owner by way of a court order awarding her sole title in her divorce
proceeding
6 Defendant MARGARET DONOFREY knew that her representation was false
because she knew that no such court order has ever been issued.
7 Defendant MARGARET DONOFREY made the false representation in order to
induce Plaintiff to accept the Matsuda automobile as a trade.
8 Plaintiff relied on the false representation, of Defendant MARGARET
DONOFREY and did accept the trade. Pursuant to standard business Procedure,
Plaintiff paid off the security interest of National Motors Financing Corporation in
order that Plaintiff could then obtain full title to the Matsuda automobile.
9 As a result of The false representation of Defendant MARGARET DONOFRE
plaintiff now has an actual equitable interest in the Matsuda of $ 4,147. 34, yet no
legal title interest in the automobile.
10 The false representation of Defendant MARGARET DONOFREY was made
with knowledge of its falsity, with the purposeful intent to deceive Plaintiff, and in
reckless disregard and great indifference to the rights of Plaintiff.
11 Plaintiff has been required to retain an attorney for the purpose of bringing this
suit and is obligated to pay a reasonable fee for this attorney's services.
WHEREFORE, Plaintiff demands judgment against Defendant MARGARET
DONOFREY for damages and attorney's fees, and demands trial by jury of all issues
so triable.

COUNT II AGAINST HENRY DONOFREY

12 Plaintiff re-alleges paragraph l through 5, 8, 9, and 11 of this complaint and

by this reference makes them part of this count.
13 Defendant HENRY DONOFREY has title interest in the Matsuda automobile.
14 Defendant HENRY DONOFREY has been unjustly enriched by Plaintiff's
satisfaction of the security interest on the Matsuda automobile, to the detriment of
Plaintiff.
WHEREFORE, Plaintiff demands judgment against IENRY DONOFREY for
compensatory damages of $4, 147. 34 and demands trial by jury of all issues so
triable.

POE, WILSON &HIGH

Attorneys for Plaintiff
9900 South Drive,River Springs, FL 32699
(904) 555 -5555
By:_____________(律师签名）
Fla. Bar No. :______（律师执照号）