Fill and Sign the Holdover Form

IN THE CIRCUIT COURT OF ____________ COUNTY, ______________ NAME OF APPELLANT )       ) ) V. ) NO.       ) ) NAME OF APPELLEE BY ITS BOARD OF TRUSTEES, ) )       ) COMPLAINT 1. __________ Hospital is a community hospital organized and existing under the laws of the State of __________, and files this Complaint by its governing body, the Board of Trustees. 2. Dr. __________, an adult resident citizen of __________ County, and may be personally served with copies of this Complaint and the Summons at __________, __________. 3. __________ Hospital owns a certain office building located at __________ in the City of __________, __________ County, __________. 4. By written agreement dated __________ __, _____, __________ County Hospital leased the above-described premises to Dr. __________ for a term of _____ years, commencing on ________ __, _____, and terminating on __________ __, _____. The lease provided for equal monthly installments of $00.00, payable in advance on the first day of each month. A copy of the lease is attached hereto as Exhibit A and incorporated herein by reference. 6. By letter dated ________ __, _____, __________ Hospital made written demand on __________ to vacate the premises and surrender possession thereof to __________ County Hospital. __________ refused and failed to do so and still holds possession of the premises without permission to consent, express or implied. A copy of the letter is attached hereto as Exhibit B and incorporated herein by reference. 7. __________ County Hospital has performed all conditions precedent to the payment of rent by _________________. 8. __________ is now liable for double rent, pursuant to ___________ _________, in equal monthly installments of $00.00, commencing on ________ __, _____, and continuing until __________ vacates the premises and Surrenders possession thereof to __________ County Hospital. There is now due and owing __________ County Hospital from __________ for double rent from the period of ________ __, _____ to ________ __, _____, a total of $ 00.00. 9. In the alternative, __________'s failure to vacate the premises on __________ __, _____, constitutes unjust enrichment and has caused actual damages to __________ County Hospital. There is now due and owing __________ County Hospital from __________ for unjust enrichment and actual damages, from the period of ________ __, _____ to ________ __, _____, a total of $00.00. Additional unjust enrichment and actual damages will be due __________ County Hospital from and after ________ __, _____, so long as __________ refuses to vacate the premises and surrender possession thereof to __________ County Hospital. __________ Hospital requests that the Court enter judgment as follows: 1. Judgment for __________ County Hospital for double rent in the amount of $00.00, plus pre - judgment Interest and court costs, and such other relief as the Court deems appropriate in the circumstances, or in the alternative, 2. Judgment for __________ County Hospital for unjust enrichment and actual damages in the amount of $00.00, plus attorneys' fees and expenses of this litigation, plus pre - judgment interest, court costs and such other relief as the Court deems appropriate in the circumstances. This the ____ day of ________, _____. Respectfully submitted, ________________________