CAUSE NO. _______________
____________________________ IN THE JUSTICE COURT
vs PRECINCT FOUR
____________________________ RANDALL
COUNTY, TEXAS
PLAINTIFF’S COMPLAINT FOR EVICTION SUIT
NOW
COMES ____________________________________________ hereinafter referred to as
Plaintiff, and files this complaint on
_________________________________________________
______________________________________________________________________________,
hereinafter
referred to as Defendant(s), and as grounds for this action, respectfully shows
the Court the following:
1.
Plaintiff resides in Randall County, Texas. Defendant’s address is _______________
_____________________________________________________________________________. Plaintiff knows of no other home or work
address of the Defendant in the County where premises are located. Service is required on defendant by personal
service at home or work or by alternate service under Rule 742 if necessary.
2.
On the _____ day ____________, 200___, Plaintiff, as landlord, and
Defendant, as tenant, entered into a contact by the terms of which Plaintiff
let and leased to Defendant for the terms of ______ months, the following
described real property located in Justice Precinct One, Randall County, Texas,
to-wit: ____________________________________________________
______________________________________________________________________________
and
on the _____ day ____________, 200___, under such lease contract, Defendant
entered into possession of said premises from that date to the present
time. Said contact of rental was
mutually entered into between Plaintiff and Defendant and provided that
Defendant as tenant, would have use of such premises for said term and would
pay to Plaintiff on the _______ day of each month, the sum of $ ____________,
as rental thereof.
3. The
aforesaid lease contact specifically proved that should Defendant, as tenant,
violate any of the provisions of said contact or default in payment of rent, as
the same should become due and payable; Plaintiff, as landlord, would have the
right and be entitled to terminate the lease, together with Defendant’s right
of possession thereunder, and that, upon such termination, Plaintiff would have
the right to re-enter said premises and repossess the same fully as though said
lease had terminated by the expiration of the rental period, and that Defendant
would quietly and peaceably surrender and yield up possession of said premises
to Plaintiff.
4. On the _____ day ____________, 200___,
Defendant, as tenant, defaulted in paying rent under the said contract, and
though demanded of him, he has failed and refused and still refuses to pay
Plaintiff the rental under such contract now due to Plaintiff in the total sum
of $________.
5. Plaintiff being the person entitled
thereto as landlord, on the _____ day ____________, 200___, made demand in
writing of Defendant for possession of such premises, and such notice and
demand was:
______ 1. Delivered to Defendant in person.
______2. Delivered to Defendant’s family member in person
______3. Affixed to said property’s main entrance.
______4. Mailed to Defendant on the same day.
6. Defendant has held over and continues
to hold over said premises willfully and without force after such termination
of the time for which the same were let and leased to him, after demand, made
in writing for the possession thereof by Plaintiff, who is entitled to the
possession thereof, and has retained, and still retains possession thereof to
Plaintiff’s damage in the sum of $ ___________, being the rental value of said
premises during such holding over.
7. Plaintiff would further show the Court
that he is hereby entitled to reasonable attorney fees.
WHEREFORE, PREMISES CONSIDERED,
Plaintiff prays that Defendant be cited to appear herein as required by law,
that, upon hearing hereof, restitution of said premises be made to Plaintiff,
and that Plaintiff recover of Defendant his rent, reasonable attorney fees and
costs, and for such other relief as he may show himself justly entitled.
_____________________________________ ______________________________
Plaintiff Phone
________________________________________________________________________
Plaintiff’s Address
SWORN TO AND SUBSCRIBED
before me this _____ day ____________, 200___.
_____________________________
Court
Clerk/Judge