IN THE CIRCUIT COURT OF COUNTY, MISSISSIPPI
PLAINTIFF
VS. NO.
DEFENDANTS
COMPLAINT FOR REPLEVIN
COMES NOW Plaintiff, , by and through its attorney and files this Complaint for
Replevin pursuant to Section 11-37-101 et seq., Mississippi Code of 1972, as amended, and in
support thereof would show unto the Court the following facts:
1. Plaintiff, , is an corporation with its principal offices located in .
2. Defendant, , a resident County, Mississippi, resides at , and may be
served with process at said address.
3. Defendant, , is a resident of County, Mississippi, and may be served with
process of this Court at .
4. Heretofore, on or about Defendant, executed a Lease, hereinafter
"Agreement" in favor of Plaintiff, a copy of which is attached hereto as Exhibit " ". By
execution of said Agreement, Defendant, , agreed to make monthly rental payments of
DOLLARS ($ ). Defendant is now in default. Plaintiff is entitled to late charges
and attorney's fees in event of default.
5. Plaintiff is the holder of legal title to the collateral described in the lease and is
entitled to immediate possession thereof.
6. Plaintiff, in good faith, believes the value of the security to be DOLLARS
($ ).
7. Plaintiff is entitled to possession of said security under the terms and conditions of the
Agreement. The Defendant, , is in default under the terms and conditions of said
Agreement. The property described in the aforesaid Agreement is in the possession of the
Defendant, , and the Defendants wrongfully detain same.
8. Plaintiff is entitled to possession of said security upon a hearing hereof.
9. Defendant, , has attempted to assign or sublet the security described in the lease
and has relinquished possession thereof to Defendant, , without the consent of Plaintiff
and in contravention of the Agreement. Plaintiff therefore deems itself insecure and its prospect
of payment impaired and desires for the Court to accelerate the indebtedness due, which total
amount due plus attorney's fees to be paid by Defendant to retain and regain this security.
WHEREFORE, PREMISES CONSIDERED, Plaintiff prays that the Clerk of the Circuit
Court of County, Mississippi, summon Defendants to be and appear at a hearing on
Plaintiff's Complaint for Replevin to be held on the date shown on the Summons to show cause
why Plaintiff should not be awarded possession of its security; and that, at said hearing, the
Court find that Plaintiff is entitled to immediate possession of its security, to be disposed of in
accordance with the provisions of the Uniform Commercial Code; Plaintiff further prays for
such other relief which may be entitled and a reasonable attorney's fee.
Respectfully submitted,
_______________________________________
Attorney for
Of Counsel:
Telephone:
MSB #
Attorney for
STATE OF MISSISSIPPI
COUNTY OF
PERSONALLY appeared before me, the undersigned authority in and for the
county and state aforesaid, the within named who after being by me first duly sworn, did
state on his/her oath that the matters and facts set forth in the above foregoing Complaint for
Replevin are true and correct as therein stated.
GIVEN UNDER MY HAND AND OFFICIAL SEAL, this the day of
, .
_______________________________
NOTARY PUBLIC
My Commission Expires:
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