Should Background Checks Be Required for Board Members?
23152 B 3/6/95 deft ordered to multiple offender program , 30 days in jail 18 months suspended license
14601.2a 9/9/97, then failure to pay fine
8. Said Contract is in default in that Defendant Collis failed to make 2 the partial monthly payment due and owing November 28, 2002 in the sum of $76.07, or any of the regular payments of $148.93 due thereafter. There is currently due, owing, and unpaid to Plaintiff on account of the Contract the sum of $3,354.68, together with other charges as provided in the Contact.
9. It is provided by the terms of the Contract that upon any default thereunder Plaintiff may take and have immediate possession of the motor vehicle.
10. Neither the motor vehicle, nor any part thereof, has been taken for tax, assessment or fine, pursuant to statute, or seized under an execution or attachment against the property of Plaintiff. Plaintiff is entitled to immediate possession thereof.
11. Defendants, and each of them, claim to have some claim, right or interest in and to the motor vehicle, or in the Contract, but Plaintiff avers that such right, claim or interest, if any, is subordinate to that of Plaintiff.
12. Defendants, and each of them, without the consent of plaintiff wrongfully detained the motor vehicle from the possession of plaintiff. Copies of the relevant pages of the Kelley Blue Book Auto Market Report March-April 19 2003 are attached hereto as Exhibit "C," and by this reference incorporated herein as though set forth in full. Based on that Exhibit "C," at the commencement of this action, average wholesale and retail values of the subject motor vehicle were in the sum of $4,100 and $6,225 respectively.
13. Plaintiff is informed and believes and thereon alleges that defendants, and each of them, are currently in possession of the motor vehicle and are concealing same from Plaintiff.