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Anatomy Of The Collections Process:  An Overview With Efficiency Tips From A Seasoned Collections Lawyer

Attachment  9

Suit On Account

NO. ______________

§IN THE

§

VS.§

§COURT OF

§

                           and§

§

§                    COUNTY, TEXAS

PLAINTIFF’S ORIGINAL PETITION

1.  Parties.  Plaintiff is                          , whose address is . Defendant is                     , who may be served by delivering citation to its registered agent,                   , at the registered office at____________; or to its president,                      , at                                .  Defendant,         [guarantor]           , may be served with process at                    .

[Note:  if used in County, County Courts-at-Law or District Courts, will need to include statement of the applicable Discovery Level.  See Tex.R.Civ.Proc. Rule 190, et seq.]

2.  Facts.  As shown in the attachments, Plaintiff sold to Defendant                         goods, services, wares, and merchandise, which said Defen­dant accepted and thereby became bound to pay to Plaintiff in ___________ County the stated price thereof, which was a reason­able and fair, usual and customary price.  Under the Guaranty included in said attachments, Defendant _________________ personally guaranteed payment of any and all indebtedness or other liability which the Defendant __________________ may owe to Plaintiff.

3.  Debt.  The balance due and owing to Plaintiff on said account is $                .  Although often requested, Defen­dants have failed and refused to pay the amount due.

[4.  Attorney’s Fees.  The failure of Defendants to pay the account has made it necessary for the Plaintiff to employ the undersigned attorneys to sue on the account.  Plaintiff has made a demand on Defendants for the balance due and is entitled to reasonable attorney’s fees pursuant to Civil Practice and Remedies Code §38.01 et. seq. [and the agreement of the parties].  A reasonable attorney’s fee would be $                      .  Note - Do

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