Fill and Sign the Complaint to Terminate Lease Form

IN THE _____________ COURT OF _________________ COUNTY, ___________________ _________________ vs._________________ COMPLAINT The ______________ (“District”), an agency of the State of ______________________, 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 _________________________, created under Sections _______________________ et seq. of the _________________________ Code. 2. The Defendant _________________________ (“_________________________”) is an adult whose last known address is ________________, __________________________, ______________________________. 3. This Court has jurisdiction over the parties and the subject matter pursuant to _____ Code Ann. § ________ and _________________________ Rules of Civil Procedure Rule _____. Venue is proper pursuant to _____________ Code Ann. § __________. Background Facts 4. On or about _____________, 20__, the District and ______________________ ("_________________________") entered into two Lease Agreements ("Leases") pursuant to which Homes agreed to rent certain property in _________________________________ County, _________________________ described as Lots _____ and ______, _____________. The lease terms were for a period of ____ years commencing ____________, 20____ and ending ___________ , 20__. 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 __________________ 20_____, 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 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 enti tled 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,