Fill and Sign the Holding over Form

IN THE ______________________ COURT OF _______________________ (County), _________________________________________ (State) ____________________________________________ PLAINTIFF V. CAUSE NO. _____-_____ ____________________________________________ DEFENDANT COMPLAINT COMES NOW ________________________________________, Plaintiff in the above-styled and numbered cause, by and through his attorneys, and files this his Complaint against Defendant, _____________________________________ , and in support thereof would show unto the Court the following matters and facts: I. Plaintiff resides at of ________________________________________________ ________________________________________________________________________ ________________________________________________ (street address, city, county, state, zip code) . II. Defendant resides at of _______________________________________________ ________________________________________________________________________ _______________________________________________________ (street address, city, county, state, zip code) and may be served with process at said address. 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 ______________________________________________ ________________________________________________________ (Agreement) dated _____________________________ (date), Plaintiff contracted to purchase the Premises from Defendant on or before ______________________________ (date). A copy of said Agreement is attached as Exhibit A and made a part of this pleading. Said Agreement provides that possession of Premises was to be granted to Plaintiff upon delivery of the deed to the Premises by Defendant to Plaintiff. V. Upon payment of the purchase price of the Premises to Defendant by Plaintiff, Defendant delivered the deed to the Premises to Plaintiff, and a copy of said deed is attached hereto as Exhibit B and made a part of this pleading. However, Plaintiff has refused to deliver possession of Premises to Plaintiff and Defendant still resides on said Premises. WHEREFORE, Plaintiff requests that: 1. Judgment be granted against Defendant awarding possession of the Premises to Plaintiff; 2. A warrant be immediately issued to remove Defendant from possession of the Premises . 3. Plaintiff be rewarded all costs of this proceeding; 4. Plaintiff be rewarded rent of $__________ per day for each day Defendant has unlawfully remained on Premises. 5. Plaintiff be awarded a reasonable attorney fee; and 6. Plaintiff be awarded such other relief as the Court deems proper. Respectfully submitted, ____________________________________ PLAINTIFF By: ________________________________ (Attorney) State Bar No. _____________ One of Its Attorneys OF COUNSEL: ___________________________________________________ Post Office Box _____-_______ City, State, Zip Code ______________________________________________________ Telephone: ______-______-__________