IN THE ____________ COURT OF _______________ (County), _________________ (State)
______________________ PLAINTIFF
(Name of Plaintiff)
V. CAUSE NO. ______,______
_______________________ DEFENDANT
(Name of Defendant)
COMPLAINT
COMES NOW ____________________ (Name of Plaintiff) , Plaintiff in the above-styled
and numbered cause, by and through his attorneys, and files this his Complaint against
Defendant, ____________________ (Name of Defendant) , and in support thereof would show
unto the Court the following matters and facts:
1. Plaintiff _____________________ (Name of Plaintiff) , is, and at all times mentioned
was, residing at _______________________________________________________________
_____________ (street address, city, state, zip code) .
2. Defendant, ____________________ (Name of Defendant) , is, and at all times
mentioned was, residing at ______________________________________________________
_____________________ (street address, city, state, zip code) .
3. Plaintiff is, and at all times mentioned was, the owner of real property (the Premises )
located at ____________________________________________________________________
__________ (street address, city, state, zip code) , and being more particularly described in
Exhibit A attached hereto and made a part hereof.
4. On or about ______________ (date of license) , Plaintiff gave Defendant a license to
use the Premises for the storage of lumber and other materials to be used by Defendant in
erecting a building for (state purpose) _____________________________________________
____________________________________________________________________________
on adjoining real property, until such time as Plaintiff should elect to terminate the license.
5. In accordance with the license, Defendant on or about _______________ (date) ,
c ommenced to store lumber on the Premises, and continued thereafter to do so.
6. On __________________ (date) , Plaintiff notified Defendant of Plaintiff's election to
terminate the license on _________________ (date) , and thereby became entitled to exclusive
possession of the Premises on that date. A copy of the notice is attached as Exhibit B , and
incorporated by reference.
7. Defendant has failed and refused to deliver up possession of the Premises by
__________________ (date) , as requested, but, rather, continues in possession without
Plaintiff's permission or consent.
8. The reasonable rental value of the Premises is $_________ per day, and the damages
to Plaintiff proximately caused by Defendant's unlawful detention have accrued at that rate since
___________________ (date) , and will continue to accrue at that rate so long as Defendant
continues to occupy the Premises .
WHEREFORE, Plaintiff requests judgment against Defendant for:
1. Possession of the Premises ;
2. Damages for the unlawful detention of the premises at the rate of $_________ per day
from __________________ (date) , until restoration of possession of the Premises to
Plaintiff;
3. Costs of suit; and
4. Such other and further relief as the court may deem just and proper.
Dated: ________________
Respectfully submitted,
_______________________
(Name of Plaintiff)
By: _______________________________
(Name of Plaintiff’s Attorney)
State Bar No. _____________
OF COUNSEL:
________________________
(Name of Plaintiff’s Attorney)
Post Office Box ________-__________
__________________________________
City, State, Zip Code
Telephone: _______-______-________
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