Fill and Sign the Mississippi Trespass Form

IN THE CHANCERY COURT OF       COUNTY, MISSISSIPPI       ,       ,       , and       , PLAINTIFFS VS. NO.             , DEFENDANT COMPLAINT FOR TRESPASS AND DAMAGES FOR UNLAWFULLY CUTTING AND REMOVING TREES COMES NOW, Plaintiffs herein, by and through counsel of record and files this their Complaint for Trespass and Damages for Unlawfully Cutting and Removing Trees, and would represent and show unto this Court the facts following, to - wit: 1. Plaintiff       is an adult resident citizen of       County, Mississippi, residing in       , Mississippi       , whose mailing address is       ,       , MS       ; Plaintiff       is an adult resident citizen of       County, Mississippi, residing with       in       , MS, whose mailing address is       ,       , MS       ; Plaintiff       is an adult resident of       County,       Judicial District, residing at       ,       , MS       ; Plaintiff       is an adult resident citizen of       County,       Judicial District, residing at       ,       , MS       ; Plaintiff       is an adult resident citizen of       County,       Judicial District, residing at       ,       , MS       ; Plaintiffs       and       are non-residents of the State of Mississippi, and are residents of       County,       , residing at       ,       ,       . All of the Plaintiffs except       are represented herein by       ,       , their duly appointed Attorney in Fact; copies of such Powers of Attorney are attached hereto as an Exhibit and fully incorporated herein by reference. 2. Defendant,       , is an adult resident citizen of       County, Mississippi, residing at       ,       , MS       where he/she may be served with process of this Court by serving him/her at said address. 3. Jurisdiction and venue is vested in the Chancery Court of       County, Mississippi, based upon the land which is the subject matter being located in       County, Mississippi and the act herein complained of having occurred in       County, Mississippi. 4. Plaintiffs are the owners in fee simple absolute of the following described land located in       County, Mississippi, more particularly described as follows, to - wit:       5. Heretofore, prior to             ,       , the Defendant entered upon the land of Plaintiffs and illegally, unlawfully and without Plaintiffs consent, permission or knowledge cut and removed in excess of       marketable trees as set forth herein, to-wit:       6. Plaintiffs demand the following relief: (1) Compensatory damages for double the fair market value of the trees cut and taken away of $       times       equals $       , as provided for by Section 95-5-10(1) Mississippi Code of 1972, Annotated as amended along with reforestation costs of $       per acre on the       (       ) acres cut which equals the sum of $       ; and. (2) A statutory penalty of $       per tree as provided for by Section 95-5-10(2), MCA1 1972 as amended for a total sum of $       ; and, (3) Expenses of obtaining a survey by       , Professional Land Surveyor No.       of the lands upon which the timber was cut of $       ; and, (4) Expenses of a timber cruise and estimate performed by       of $       ; and, (5) All the reasonable expenses herein incurred including expert witness fees and attorney fees as provided by Section 95 - 5 - 10(3), MCA, 1972, as amended as well as suit monies for having to file this action against the Defendant. WHEREFORE, PREMISES CONSIDERED, Plaintiffs pray that process will issue to the Defendant, in the manner and time as prescribed by statute and upon a hearing hereon, award the Plaintiffs the following relief: A. (1) Compensatory damages for double the fair market value of the trees cut and taken away of $       times       equals $       , as provided for by Section 95-5-10(1) Mississippi Code of 1972. Annotated as amended along with re-forestation costs of $       per acre on the       (       ) acres cut which equals the sum of $       ; and. (2) A statutory penalty of $       per tree as provided for by Section 95-5- 10(2), MCA, 1972 as amended for a total sum of $       ; and, (3) Expenses of obtaining a survey by       , Professional Land Surveyor No.       of the lands upon which the timber was cut of $       ; and, (4) Expenses of a timber cruise and estimate performed by       of $       ; and, (5) All the reasonable expenses herein incurred including expert witness fees and attorney fees as provided by Section 95 - 5 - 10(3), MCA, 1972, as amended as well as suit monies for having to file this action against the Defendant. Aggregate damages as set forth herein in sub - paragraphs 1 through 4 $       ; and, Plaintiffs request that this Court, pursuant to statute, shall affix attorney fees and expert witness fees, as an additional portion of the damages not included in the figure contained in this paragraph ($       ). B. If your Plaintiffs have prayed for wrong, improper or insufficient relief, then they now pray for such other, further, special or general relief to which in equity this Court shall deem mete and proper in the premises. Respectfully submitted, _______________________________________       Attorney for       Of Counsel:                         Telephone:       MSB #       Attorney for