Complaint To Recover Possession Of Personal Property. Files. Complaint To Recover Possession Of Personal Property.Plaintiff is a corporation licensed in NC and NJ. 2. Lack enough information to respond to Plaintiff's allegations. This article discusses how to start a replevin action. It also addresses how to amend your complaint if necessary and how to appeal. First, choose the consumer complaint form that fits your problem. In a replevin action, also called a "claim and delivery", a party seeks to have the court order the delivery of property they claim legally belongs to them. The plaintiff must determine if the defendant is a corporation and sue in the complete corporate name. Under South Carolina law, a replevin claim is formally called an "action of claim and delivery".