Complaint for injunction mississippi 497314389 form
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IN THE CHANCERY COURT OF COUNTY, MISSISSIPPI
, BY AND THROUGH ,
, AND , A MAJORITY OF
THE BOARD OF DEACONS
VS.
COMPLAINT FOR INJUNCTION
COMES NOW the Plaintiff, , and are represents the following:
1.
(a) is an unincorporated association located on , , County, Mississippi.
, , and are each adult resident citizens of County, Mississippi, and
constitute a majority of the Board of Deacons of .
(b) is an adult resident citizen of the Judicial District of County,
Mississippi and may be served at his/her residence, , , Mississippi.
2.
For a number of years, Rev. has been the Pastor of , and has rendered pastoral
services in County, Mississippi.
3.
On , 20 , pursuant to proper notice, a special meeting of the Board of Deacons
of were convened. At said meeting a majority of the Board of Deacons voted to recommend
to the membership of that Rev. be immediately terminated as Pastor of said Church.
4.
On , 20 , pursuant to proper notice, a special meeting of the members of
were convened. At said meeting, a majority of the members in attendance voted for the
immediate termination of Rev. as Pastor of said church.
5.
On , 20 a letter were transmitted to Rev. advising him/her of his/her
termination as Pastor.
6.
Not withstanding the fact that Rev. had actual notice of his/her termination, Rev.
appeared at in County, Mississippi, on , , 20 , and conducted services. Said
conduct was willful, wanton and malicious and in direct violation of the mandates of the Board
of Deacons and members of .
WHEREFORE, PREMISES CONSIDERED, Plaintiff prays that on final hearing hereof,
that this Court will enter its Judgment:
1. Enjoining Rev. from entering on the premises of and enjoining him/her from
acting in any pastoral capacity for said church.
2. Awarding Plaintiff reasonable attorney's fees, litigation expenses and court costs.
Plaintiff prays for general relief.
Respectfully submitted, this ______ day of _________________________ , 20 ______ .
________________________________________
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