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Fill and Sign the County Missisippi Form

Fill and Sign the County Missisippi Form

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IN THE CHANCERY COURT OF COUNTY, MISSISIPPI , BY AND THROUGH , , AND , A MAJORITY OF THE BOARD OF DEACONSVS. DEFENDANT'S MOTION FOR PAYMENT OF BACK- PAY WAGES AND FOR OTHER RELIEF COMES NOW, the Defendant, , by and through counsel and files this, his/her Motion For Payment of Back-Pay Wages and For Other Relief and would show unto the Court as follows: 1. Reverend last presided over services at on , , 20 . 2. Reverend was paid $ by check for his/her services on , 20 , but a stop payment was placed on said payment and this amount remains due and payable to Reverend . 3. This Honorable Court handed down its Preliminary Injunction on , 20 , which said Injunction stated that Reverend should be enjoined and prohibited from entering on the land and premises of until further order of this Court. Reverend has obeyed the Order of this Court and has not entered on the land or premises of the Church since the date of the Preliminary Injunction. 4. On , 20 , this honorable Court handed down its Order Calling Meeting of Membership of which said Order directed that a meeting of the membership should be held to conduct a vote to determine whether Reverend should continue as the pastor of . 5. On , 20 , a meeting of the membership was held at as instructed by this Court's Order of , 20 at which time the members in attendance voted to discharge Reverend as Pastor. 6. Reverend would respectfully request that the Court order the Plaintiffs to pay $ for the services conducted by Reverend on , 20 . 7. Reverend would respectfully request that the Court order the Plaintiffs to pay $ as back-pay wages for the period from , 20 to , 20 . 8. Reverend would respectfully request that the Court order the Plaintiffs to pay $ as his/her annual revival payment for . 9. Reverend would respectfully request that the Court Order the Plaintiffs to pay $ as his/her annual bonus for 20 . 10. Reverend would respectfully request that the Court Order the Plaintiffs to pay his/her attorney's fees and costs of court.WHEREFORE, PREMISES CONSIDERED, Reverend respectfully prays that this honorable Court will order the Plaintiffs herein to pay $ for back-pay wages for , 20 ; $ as 20 back-pay wages for the Period from , 20 to , 20 ; $ as annual revival pay; $ as annual bonus and all attorney's fees and costs of court.RESPECTFULLY SUBMITTED, this the day of , 20 . __________________________________________

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