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IN THE CIRCUIT COURT OF COUNTY, MISSISSIPPI PLAINTIFFVS. NO. AND DEFENDANTS COMPLAINT COMES NOW Plaintiff, , a national banking institution, by and through its
undersigned counsel, and brings this action against the above named Defendants as follows:1.Plaintiff is a national banking institution, domiciled in , Mississippi, with
branch offices in , County, Mississippi.2. Defendant, , is an adult resident citizen of , County, Mississippi.
Defendant, , is an adult resident citizen of , County, Mississippi.3. The Court has jurisdiction over the persons and the subject matter involved in this
action and venue is appropriate in this county.4. On , , , a Mississippi corporation ("Maker"), for good and valuable
consideration then and there made and executed its promissory note to the order of Plaintiff in
the sum of $ and payable , , a copy of which note is annexed hereto and made a
part hereof as Exhibit " ".5. Said note was a continuation, renewal, extension and/or addition to a note made
by Maker on , , and secured as was the note attached hereto as Exhibit " ".6. guaranties of payment, copies of which are attached hereto and made a part
hereof as Exhibits " " and " ", wherein, as consideration of Plaintiff's financial
accommodations given, or to be given to said Maker, Defendants guaranteed the prompt
payment of all indebtedness or liabilities which the Maker, as of the date of the said guarantee or
at any time thereafter, might owe to the Plaintiff.7. 8.In , , Maker, being in default in the payments due under said note, filed for
protection under Chapter 11 of the United States Bankruptcy Code. 9. While Maker was conducting business under said Chapter 11, it made certain
payments and received certain credits on the note.
10.The collateral which secured said note was resorted to by Maker and its creditors,
and sold in commercially reasonable sales, by and with the consent and approval of the
Bankruptcy Court, and the proceeds thereof applied to the indebtedness due under said note.11.The full amount of principle in the sum of $ is now due and owing on
Maker's said note.12. Maker has been unable to pay the obligation due, despite Plaintiff's repeated
requests, and it remains in default in the payments thereof.13.Defendants, as Maker's Guarantors, now owe Plaintiff $ , the unpaid
principle, plus interest due on said note by virtue of Defendants' said guaranties, no part of which
has been paid by Defendant although duly demanded.WHEREFORE, Plaintiff demands judgment against Defendant for the sum of $
together with interest and costs.DATED: Respectfully submitted,_______________________________________ Attorney for
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