Texas Mechanics and Materialmen's Liens Guide

COMPLAINT TO ENFORCE MECHANIC'S AND MATERIALMEN'S LIEN

IN THE CIRCUIT COURT OF

COUNTY, MISSISSIPPI

PLAINTIFF

VS.

DEFENDANT

NO.

COMES NOW and shows unto this Honorable Court the following matters and facts, to-wit:

I.
JURISDICTION

1. , is a Mississippi corporation, licensed to do and doing business in the State of Mississippi.

2. The Defendant, , is an corporation, fully qualified to do business in the State of Mississippi, whose Registered Agent in the State of Mississippi is:

, Mississippi,

3. That this Court has jurisdiction of the parties and the subject matter herein.

II.
THE CLAIM

4. Plaintiff provided certain services and labor for the Defendant on certain oil wells located in County, Mississippi.

5. That as a result of the work performed by the Plaintiff, , certain itemized invoices were forwarded to the Defendant showing the amount due from the Defendant to the Plaintiff, copies of said invoices being attached hereto and made a part hereof as though copied in full words and figures.

III.

THE LIENS

6. That on or about the day of , 20, certain Material men's and Laborer's Liens were filed of record upon certain wells owned and/or operated by the Defendant in County, Mississippi, which wells are more specifically described as:

7. That the drilling units wherein the wells described above are located are more particularly described as:

8. That since the performance of the work listed on the invoices attached to the liens, the Plaintiff has not performed any additional work for the Defendants.

9. The Defendants have made no payments on these invoices, and therefore, the Defendant currently owes unto the Plaintiff the total sum of $ for work performed and services provided to the Defendants, plus interest at % APR from date of service.

IV.
CONFLICTING CLAIMS

10. Insofar as Plaintiff has knowledge, there are no other claimants asserting material men and laborer's liens against the interest of the Defendant herein as to the wells recited above.

WHEREFORE, PREMISES CONSIDERED, Plaintiff demands judgment of and from the Defendant, , in the principal amount of $ with interest thereon at % APR from date of invoice until paid in full, including all costs of Court and reasonable attorney's fees incurred in this matter in accordance with law.

FURTHER, Plaintiff demands that the liens and claims of the Plaintiff be declared to be superior to any claim against said real property that may be asserted by any other claimants; and that the property be ordered sold by special execution in order to satisfy the judgment so rendered, as provided by the statutes of the State of Mississippi.

And Plaintiff demands a judgment for such other further and general relief to which it may be entitled.

Respectfully submitted,

Of counsel:

Telephone:

MSB #

Attorney for