Fill and Sign the Complaint Mississippi 497314492 Form

IN THE CHANCERY COURT OF       COUNTY, MISSISSIPPI       vs.       COMPLAINT The       (“District”), an agency of the State of Mississippi, files its Complaint for damages, declaratory relief and to remove a cloud from the District's title to certain property. In support of its claim for relief, the District states the following: Parties and Jurisdiction 1. The District is an agency of the State of Mississippi, created under Sections 51 - 9 - 101 et seq. of the Mississippi Code. 2. The Defendant       (“       ”) is an adult whose last known address is       ,       , Mississippi       . 3. This Court has jurisdiction over the parties and the subject matter pursuant to Miss. Code Ann. § 11 - 17 - 35 and Mississippi Rules of Civil Procedure Rule 57. Venue is proper pursuant to Miss. Code Ann. § 11 - 5 - 1. Background Facts 4. On or about       ,       , the District and       ("       ") entered into two Lease Agreements ("Leases") pursuant to which       agreed to rent certain property in       County, Mississippi described as Lots       and       ,       . The lease terms were for a period of       years commencing       ,       and ending       ,       . A true and correct copy of the Leases are attached as Exhibits "A" and "C." 5. Under the Leases, the Lessees or Assignees agreed to pay annual rents of $       for each lot. 6. On             ,       , said Leases were assigned by       to       True and correct copies of the Assignments of Lease are attached as Exhibits "B" and "D." 7.       has failed to pay the annual rents of $       for the years       and       . The total rent now due and owing is $       8. The District has attempted to notify       of the past due rent at his last known address. 9.       is in default under the Leases and has not cured the default. Consequently, the Leases have terminated pursuant to paragraphs 10 and 11 thereof, and the District is entitled to possession of the property. Claim for Relief 10. As a result of his default in payment of fixed rents under the Leases,       is in default of the Leases and liable for past due annual rents, all attorney's fees, expenses and costs in enforcing the provisions of the Leases. 11. As a result of his/her default in payment of fixed rents under the Leases, the District is entitled to a judgment declaring that the Leases are terminated and that the District is entitled to possession of the property. 12. The Leases remain recorded on the real property records, which cast doubt or suspicion on the District's title and right to possession of the property. The District, as owner of the property, is entitled to a judgment that all claims of the Defendant in and to the property be canceled and removed as clouds upon the District's title. WHEREFORE, the District demands the following relief: a. Actual damages against       in the amount of $       representing past due rents for       and       . b. All rents accruing through the date of entry of a judgment. c. All reasonable attorney's fees, expenses and costs incurred in enforcing the provisions of the Leases. d. Interest on the judgment from the date of judgment until the judgment is paid. e. A judgment declaring that the Leases are terminated and that the District is entitled to possession of the Property; f. A judgment that all claims of       be canceled and removed as clouds upon the District's title; and g. Any other and further relief as the Court deems just and appropriate. This the       day of       , 20       . Respectfully submitted, _______________________________________       Attorney for       Of Counsel:                         Telephone:       MSB #       Attorney for