Motion,Ex Parte: Priority Motor Group, Inc. vs. Lopez Geraldo, Pedro Anselmo

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                              COMMONWEALTH OF MASSACHUSETTS                                        9/3/2021
                              1                          ;
       MIDDLESEX, SS.                                                                              RECEIVED
                                                                      SUPERIOR COURT
                                                                      C. A. NO.:2177CV00895
      PRIORTY MOTOR GROUP. INC.,                       9/3 [2071          On        an     ex.
          Plaintiff,
      Vv.
                                                      review of documents                        basis
                                                      DEND_          Pf short order Gu
                                                                                                             len
     PEDRO ANSELMO LOPEZ GERALDO.
         Defendant                                     will. 1ssve.            doh Thy,
      PLAINTIFF’S MOTION FOR INJ JUNCTIVE                    RELIEF & DECLARATORY JUDGMENT
                      i           I
                                                                                                             ou ly
                 ‘NOW COMES the plaintiff, Priority   Motor Group, Ine., and moves to obtain injunctive and
     declaratory relief. As grounds therefore, th e plaintiff states as follow                              2°
                                                                               s:

             1. The verified com plaint pleads that the defendant is in possession                          o cost
                                                                                    and control ofa 2021
                                                                        6591 (hereinafter “vehicle”), and OX change
     Dodge Ram'Truck Prom: aster 1500, VIN: 3C6LRVNGIMES4
     that the vehicle has not been paid in full for yet the defendant
                                                                        maintains possession and control      yelucles
     of same.
                                                                                                  OL jautu
           2. The plaintiff requests that this Honorable Court decl
                                                                    lare and establish that the plaintiff        moi
                                                                                                                 of   -


     has a superior right to the vehicle:
                                                                                                     ore:
        3. The plaintiff requests that this Honorable Court order
                                                                       Geraldo to return the vehicleto the
 plaintiff forthwith or alternatively, permit the plainti ff or its agent
                                                                           to repossess the vehicle;
                                                                                                             toh
        4. The plaintiff request that this Honorable Court enter
                                                                  judgment in its favor in the amount
 of $2,111.25 plus court costs and fees to com pensate
                                                         the plaintiff for fees paid to register the
 vehicle; and :

        5. The plaintist request that this Honorable Court order the defend
                                                                            ant to Tetrieve a 2015
 Honda Civic, VIN: 19XFB2F57FE2            1802
                                             A (hereinafter “automobile”) within three (3) days or
 alternatively permitting the plaintiff to tow the automobile to-a stoi
                          |                                                 rage lot whereby the defendant
 would be responsible for any storage costs.

       6. The plaintiff request that this Honorable Court order the
                                                                       defendant, be enjoined from
driving, transferring, selling, stripping, damaging, dispos
                                                              ing or otherwise using the vehicle and
further that the plaintiff be entitled to c ‘ause the immediate reposs
                                                                          ession of the vehicle,

                                                 PRIORITY MOTOR GROUP, INC., By its
                                                 attorney,