Fill and Sign the Petition Relief Form

IN THE __________________ COURT OF ___________________________ (County) , _________________________________ (State) __________________________________________ PLAINTIFF (Name of Plaintiff) V. CAUSE NO. ______ , ______ ___________________________________________ DEFENDANT (Name of Defendant) COMPLAINT COMES NOW __________________________________________ (Name of Plaintiff) , Plaintiff in the above-styled and numbered cause, by and through his attorneys, and files this his Complaint against Defendant, __________________________________ (Name of Defendant) , and in support thereof would show unto the Court the following matters and facts: 1. Plaintiff is an adult resident citizen of ___________________________________ ______________________________________________________ (city, county, state) . 2. Defendant is an adult resident citizen of _________________________________ _____________________________________________ (city, county, state) and may be served with process at _____________________________________________________ ________________________________________________________________________ (street address, city, county, state, zip code) . 3 . At all times mentioned, Plaintiff owned an easement (hereinafter called Easement) on real property located in _________________________________________ ________________________________________ (city, county, state), as described in the _____________________________________ (Deed or Other Instrument that Conveyed Easement to Plaintiff) dated ______________________________________ (date) , a copy of which _____________________________________ (Deed or other Instrument) is attached hereto as Exhibit A and incorporated herein by reference. 4. That said Easement of Plaintiff can be more particularly described as (Legal Description of Easement) __________________________________________________ ________________________________________________________________________ _______________________________________________________________________. 5. At all times mentioned, Defendant owned real property located in ____________ _____________________________________________________ (city, county, state) , as described in the Deed to Defendant dated ____________________________________ (date) , a copy of which Deed is attached hereto as Exhibit B and incorporated herein by reference. 6. Plaintiff’s Easement and Defendant's property are adjacent to each other in _______________________________________________ (county and state) , with the (e.g., northern) ______________________________ boundary of Plaintiff’s Easement also being Defendant's (e.g., southern) ____________________________ boundary. 7. On or about _____________________________________________ (date) , Defendant built a fence located on part of Plaintiff’s Easement without the permission of Plaintiff and without any lawful right. Defendant has repeatedly refused Plaintiff’s requests to remove said fence from Plaintiff’s Easement. Wherefore, Plaintiff requests: 1. Issuance of an injunction ordering Defendant to remove said fence from the Easement of Plaintiff within thirty (30) days of the issuance of such injunction. 2. That Plaintiff receive costs and expenses incurred in the action; and 3. That Plaintiff receive such other and further relief as the court deems proper. Witness my signature this the _____ day of ______________________________, 20_____. ____________________________________ (Signature of Plaintiff) ___________________________________ _ (Printed Name of Plaintiff) STATE OF ____________________________ COUNTY OF ______________________________ Personally appeared before me, the undersigned authority in and for the jurisdiction aforesaid, the within-named _______________________________________ ( Name of Plaintiff) who, being by me first duly sworn according to law, states on oath that the allegations of the above and foregoing Petition are true and correct as therein stated and set forth. ____________________________________ (Signature of Plaintiff) SWORN TO AND SUBSCRIBED BEFORE ME on this the _____ day of ____________________________, 20_____. ____________________________________ Notary Public My Commission Expires: ________________________