IN THE CIRCUIT COURT OF COUNTY, MISSISSIPPI
APPELLANT
NO.
APPELLEE
COMPLAINT
1.
is a community hospital organized and existing under the laws of the State of
Mississippi, and files this Complaint by its governing body, the Board of Trustees.
2.
, an adult resident citizen of County, and may be personally served with
copies of this Complaint and the Summons , Mississippi.
3.
owns a certain office building located at in the City of ,
County, Mississippi.
4.
By written agreement dated , , leased the above described
premises to for a term of years, commencing on , , and
terminating on , . The lease provided for equal monthly installments of
$ , payable in advance on the day of each month. A copy of the lease is attached
hereto as Exhibit A and incorporated herein by reference.
6.
By letter dated , , made written demand on to vacate the
premises and surrender possession thereof to . refused and failed to do so and still
holds possession of the premises without permission to consent, express or implied. A copy of
the letter is attached hereto as Exhibit B and incorporated herein by reference.
7.
has performed all conditions precedent to the payment of rent by .
8.
is now liable for double rent, pursuant to Miss. Code Ann. 89 - 1 - 25, in equal
monthly installments of $ , commencing on , , and continuing until
vacates the premises and Surrenders possession thereof to . There is now due and
owing from for double rent from the period of , to
, , a total of $ .
9.
In the alternative, 's failure to vacate the premises on , ,
constitutes unjust enrichment and has caused actual damages to . There is now due and
owing from for unjust enrichment and actual damages, from the period of
, to , , a total of $ . Additional unjust enrichment and
actual damages will be due from and after , , so long as refuses
to vacate the premises and surrender possession thereof to .
requests that the Court enter judgment as follows:
1. Judgment for for double rent in the amount of $ , plus pre-judgment
Interest and court costs, and such other relief as the Court deems appropriate in the
circumstances, or in the alternative,
2. Judgment for for unjust enrichment and actual damages in the amount of
$ , plus attorneys' fees and expenses of this litigation, plus pre-judgment interest court costs
and such other relief as the Court deems appropriate in the circumstances.
This the day of , 20 .
Respectfully submitted,
_______________________________________
Attorney for
Of Counsel:
Telephone:
MSB #
Attorney for
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