Motion Replevin

IN THE 7TH JUDICIAL CIRCUIT COURT OF MISSOURI COUNTY OF CLAY - DIVISION 2

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) CASE NO. 07CY-CV06125

William Duff, Plaintiff,

) ACTION ) FOR TRESPASS, AND ) TRESPASS ON THE CASE

v.

OFFICER WILLIAM FRAZIER, (SERIAL 3092) AND OFFICER ALAN ROTH (SERIAL # 4090) Defendants.

) VERIFIED

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MOTION FOR WRIT OF REPLEVIN

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Comes now; William Duff (hereinafter Duff, he, him, I, me), one of the people of

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Missouri, in this court of record, to seek replevin of specific property being held by

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William Frazier (defendant herein) or his agents and who is attempting to dispose of

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said property unlawfully, to wit;

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1. Duff is the owner and/or the person lawfully entitled to the possession of the

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property described as one 1996 Buick Riviera 1G4GD2215T4710668 (see Bill of

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Sale copies attached)

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2. The property is wrongfully detained by the defendant, and is held by an officer under legal process who has refused delivery on demand

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3. Defendant intends to dispose of Duff's Property on or about July 31, 2007

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4. The instant petition proceeds upon the law of this case as referenced in Exhibit F

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and the underlying action; Factual Basis; 1. Duff owes no debt to defendant or its agents as related to the claim(s) heretofore made;

AUG 0 1 2007 william duff

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Clay County Circuit7<S)b3007

2. Defendant, armed with a gun, did, on or about June 5, 2007, seize Plaintiffs

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Automobile and personal property therein and claimed to deliver same to tow

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lot without Plaintiffs consent, wrong act or court order, judgment or ruling.

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ARGUMENT;

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Plaintiff, here states, that Frazier and his agents possess no lawful right, title or interest

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in the property afore mentioned For the purpose of this writ, Duff wishes the immediate

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return of the automobiles referenced above.

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PRAYER, Duff demands this court issue order of this court for writ of replevin with

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bond waived to be served immediately upon whoever has possession of the automobiles

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herein identified and for that property to be returned to Duff, and for all costs related

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thereto to be taxed against defendant and his agents, and for all other relief this court

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can and should provide. Duff will provide last known location of said property to

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Sheriff.

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Respectfully

William Plaintiff Date:

william duff

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7/31/2007

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

name here Witness Signed

>T Witness: Signed Linda Talley

Date