Fill and Sign the Enforce Lien 497329266 Form

IN THE ___________ COURT OF _______________ (County) , _______________ (State) _______________________________, INC. PLAINTIFF V. CAUSE NO. ________________ ______________________________ DEFENDANT COMPLAINT COMES NOW _______________________________, Inc., Plaintiff in the above-styled and numbered cause, by and through its attorneys, and files this its Complaint against Defendant, ___________ , and in support thereof would show unto the Court the following matters and facts: I. Plaintiff is a corporation organized and existing under the laws of the state of ____________________, with its principal office located at _____________________________ _________________________________________ (street address, city, county, state, zip code). II. Defendant resides at of _____________________________________________________ ______________________ (street address, city, county, state, zip code) . III. Plaintiff owns in fee the premises ____________________________ (Premises) located at ____________________________________________________________________________ (street address, city, county, state, zip code) , and more particularly described as follows: ______________________________________________________________________________ ______________________________________________________________ (l egal description) . IV. By written agreement dated __________________ (date) , Plaintiff leased the Premises to Defendant for a term of ________________ (number of months or years) , terminating on _____________________ (date) . A copy of the Lease is attached as Exhibit A , and made a part of this pleading. V. On or about __________________ (date) , Defendant took possession of the Premises pursuant to the Lease and thereafter paid the rents until _________________ (date) . VI. Defendant failed to pay the $______________ rent due under the Lease on _______ _________________________ (date) , and despite Plaintiff's demand on Defendant for payment, Defendant has failed to pay any part of the rent. VII. Defendant owns, uses, and/or keeps the following-described personal property on the leased premises: ________________________________________________________________ _____________________________________________________ (Describe personal property) . VIII. This personal property is not located in a dwelling house, apartment, or other place used exclusively as a home or residence for Defendant and Defendant's family, and the property is not exempt from execution. IX. By virtue of _______________________________ ( cite applicable statute) , Plaintiff has a lien on the said personal property for the $_____________ rent due Plaintiff from Defendant and unpaid for the leased premises. WHEREFORE, Plaintiff requests: 1. Judgment against Defendant for $________, with interest at the rate of ______% per annum from _________________ (date) ; 2. A declaration form this honorable Court that Plaintiff has a lien on Defendant's personal property described above for $____________, pursuant to _____________________ ( cite applicable statute) ; 3. Foreclosure of the lien as determined in this action against Defendant's described personal property and by its sale in the manner provided by law, with application of the proceeds of the sale to the satisfaction of Plaintiff's lien; 4. Judgment against Defendant for any deficiency that may remain after the sale of the personal property and application of the proceeds of the sale to the satisfaction of Plaintiff's lien; 5. Award to Plaintiff of costs and disbursements incurred in this proceeding; and 6. Such other and further relief as the Court deems fit and proper. Respectfully submitted, ______________________, INC. By: _______________________________ State Bar No. _____________ One of Its Attorneys OF COUNSEL: ______________________________________ (Name of Law Firm) ______________________________________ (Address) ______________________________________ (City, State and Zip Code) _______________________ (Telephone)