1 IN THE 7TH JUDICIAL CIRCUIT COURT OF MISSOURI

2 COUNTY OF CLAY - DIVISION 2

3
4 William Duff, ) CASE NO. 07CY-CV06125
5 Plaintiff,
6 ) ACTION
7 v. ) FOR TRESPASS, AND
8 ) TRESPASS ON THE CASE
9 OFFICER WILLIAM FRAZIER, (SERIAL 3092)
10 AND
11 OFFICER ALAN ROTH (SERIAL # 4090) ) VERIFIED
12 Defendants.
13
14
15 MOTION FOR WRIT OF REPLEVIN
16
17 Comes now; William Duff (hereinafter Duff, he, him, I, me), one of the people of
18 Missouri, in this court of record, to seek replevin of specific property being held by
19 William Frazier (defendant herein) or his agents and who is attempting to dispose of
20 said property unlawfully, to wit;
21 1. Duff is the owner and/or the person lawfully entitled to the possession of the
22 property described as one 1996 Buick Riviera 1G4GD2215T4710668 (see Bill of
23 Sale copies attached)
24 2. The property is wrongfully detained by the defendant, and is held by an officer
25 under legal process who has refused delivery on demand
26 3. Defendant intends to dispose of Duff's Property on or about July 31, 2007
27 4. The instant petition proceeds upon the law of this case as referenced in Exhibit F
28 and the underlying action;
29 Factual Basis;
30 1. Duff owes no debt to defendant or its agents as related to the claim(s)
31 heretofore made;

AUG 0 1 2007

william duff Page 1

Clay County Circuit7<S)b3007
32 2. Defendant, armed with a gun, did, on or about June 5, 2007, seize Plaintiffs
33 Automobile and personal property therein and claimed to deliver same to tow
34 lot without Plaintiffs consent, wrong act or court order, judgment or ruling.
35
36 ARGUMENT;
37 Plaintiff, here states, that Frazier and his agents possess no lawful right, title or interest
38 in the property afore mentioned For the purpose of this writ, Duff wishes the immediate
39 return of the automobiles referenced above.
40
41 PRAYER, Duff demands this court issue order of this court for writ of replevin with
42 bond waived to be served immediately upon whoever has possession of the automobiles
43 herein identified and for that property to be returned to Duff, and for all costs related
44 thereto to be taxed against defendant and his agents, and for all other relief this court
45 can and should provide. Duff will provide last known location of said property to
46 Sheriff.
47
48 Respectfully
49
50
51 William
52 Plaintiff
53
54
55 Date:
56
57

william duff Page 2 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 Date

name here
Witness Signed
>T
Witness: Signed
Linda Talley