Fill and Sign the Counter Defendant Form

IN THE COUNTY COURT OF ___________ COUNTY, ___________ * PLAINTIFF COUNTER-DEFENDANT VS. CAUSE NO. ___________ DEFENDANTS/ * COUNTER-PLAINTIFFS MOTION TO TRANSFER Comes now the plaintiff/counter-defendant in the above styled cause and moves Court pursuant to Miss. Code Ann. Section 9-9-21 (1972), as amended, to transfer this action to the Circuit Court of Rankin County, Mississippi. For grounds of its motion, plaintiff/counter-defendant would show unto the Court the following: 1. That plaintiff/counter-defendant filed an original open account lawsuit against defendants/counter-plaintiffs in this action. 2. That in their answer to the complaint, defendants/ counter-plaintiffs filed a counterclaim against plaintiff/counter-defendant seeking sums greater than $50,000. See Exhibit "A". 3. That this claim for damages is in excess of the jurisdictional amount allowed before this Court. 4. That Section 9-9-21 allows the parties to enter a motion to transfer this acti on to the Circuit Court as a result of the amount sought in defendants'/counter-plaintiffs' counterclaim. 5. That all parties have agreed to this transfer. WHEREFORE, PREMISES CONSIDERED, plaintiff/counter-defendant moves this Court to transfer the above styled action to the Circuit Court of ___________ County, ___________ pursuant to Section ___________. This the ___________ day of ___________, 19___ Respectfully submitted, * BY:_________________________* Attorney for Plaintiff/ Counter-defendant in Defense of Counterclaim * CERTIFICATE OF SERVICE I, ___________, attorney for Plaintiff, Counter-defendant on the Counterclaim filed against it by Defendants/Counter-plaintiffs, do hereby certify that I have this mailed a true and correct copy of Motion to Transfer to the following counsel of record at their usual business address: * * This the ___________ day of ___________, 19___. *