FILE,'
`JAN 2 3 202I v3OPIA LESLIE MASON
`CIRCUIT CLERK
`IN THE CIRCUIT COURT OF MISSISSIPPI COUNTY, ARKANSAS
`CHICKASAWBA DISTRICT
`CIVIL DIVISION
`KAREN WALLACE
`DBA: WALLACE PROPERTIES
`VS. No. 47BCV-25-W1
`PLAINTIFF
`R1_-
`THERESA MULLENS DEFENDANT
`COMPLAINT
`Plaintiff, Karen Wallace, doing business as Wallace Properties, by her attorney,
`Johnny Dunigan, for her Complaint against the Defendant states:
`1. This Court has jurisdiction over the subject matter of this claim under Ark.
`Code Ann. § 18-16-301, et seq. and venue is proper.
`2. Plaintiff owns and is entitled to possession of property located at 408 Nelson
`St., Apt. 11, Leachville, Arkansas.
`3. On or around May 3, 2022, pursuant to a verbal rental agreement with
`Plaintiff the Defendant took possession of the above-described premises. The parties
`agreed the Defendant would pay Two Hundred Dollars ($200.00) each month for rent.
`4. The Defendant has failed and refused to meet and fulfill her obligations
`pursuant to the rental agreement, has unlawfully failed and refused to quit possession of
`said property upon request and demand and has unlawfully detained the same. The
`Defendant has failed to pay the monthly rent and is delinquent in the amount of One
`Hundred Dollars ($100.00) for November 2024, and Two Hundred Dollars ($200.00) for
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`January 2025. The missed payments are in direct violation of the rental agreement. See
`Exhibit "A" attached hereto.
`5. The Defendant has unlawfully held and refused to quit possession of said
`property after three days' notice to quit and demand made in writing for possession
`thereof by Plaintiff pursuant to Ark. Code Anno. § 18-60-304, a copy of which Notice is
`attached hereto as Exhibit "B" and incorporated herein by reference as if set forth word
`for word.
`6. The Plaintiff had been damaged in the sum of $300.00 as a result of such
`unlawful detainer, and will be damaged in the sum of $6.67 for each day after January 31,
`2025, that the Defendant remains in possession of the above-described premises.
`7. If, within five (5) days, excluding Sundays and legal holidays, following
`service of this summons, complaint, and notice seeking a writ of possession against the
`defendant named herein, the defendant has not filed a written objection to the claim for
`possession made by the plaintiff in this complaint, the clerk of the court should
`immediately issue a Writ of Possession directed to the sheriff commanding him to cause
`the possession of the property described in this complaint to be delivered to the Plaintiff
`without delay.
`8. That if the Defendant has damaged the property, she should be responsible
`for any and all repairs.
`9. Plaintiff requests her attorney fees and costs be paid by Defendant because
`of Defendant's breach and refusal to vacate.
`WHEREFORE, Plaintiff prays for judgment for the immediate possession of said
`property; for damages in the amount of $300.00 and $6.67 for each day beyond January
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`31, 2025, that Defendant remains in possession of said property and for any damages
`which may accrue or may be revealed by inspection of the premises; for a Writ of
`Possession should the defendant not file a timely written objection; for the cost of this
`action; for attorney's fees; and for any other proper relief to which the plaintiff may be
`entitled.
`Respectfully submitted,
`Karen Wallace
`Petitioner
`By:
`Joliny Dun an
`ArOirEar No. 2003141
`Attorney for Petitioner
`P.O. Box 405
`Monette, Arkansas 72447
`Phone: (870) 486-1355
`Fax: (870) 486-1356
`johnnydunigan@yahoo.com
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`FILED
`JAN 2 3 2025
`LESLIE MASON
`CIRCUIT CLERK
`IN THE CIRCUIT COURT OF MISSISSIPPI COUNTY, ARKANSAS
`CHICKASAWBA DISTRICT
`CIVIL DIVISION
`KAREN WALLACE
`DBA: WALLACE PROPERTIES PLAINTIFF
`VS. No. 47BCV-25-
`THERESA MULLENS DEFENDANT
`AFFIDAVIT
`COMES NOW the Plaintiff, Karen Wallace, by its agent, Charles Brooks, pursuant to the
`provisions of Ark. Code Ann. §18-60-301 et seq., and for her cause of action against the
`Defendant, Theresa Mullens, in reference to the dwelling located at 408 Nelson St., Apt. 11,
`Leachville, Arkansas, states:
`The Defendant Theresa Mullens has failed to pay rent in a timely manner since November 2024
`and has not paid full rent for November 2024 and January 2025. The defendant owes $300.00
`in rent. The Plaintiff is entitled to possession of the dwelling located at 408 Nelson Street, Apt.
`11, Leachville, Arkansas. The Defendant unlawfully detains the premises after lawful demand
`therefor made. A three (3) day Notice to Vacate is attached as Exhibit B.
`STATE OF ARKANSAS
`COUNTY OF Cr -e•:(11Nek0
`Sworn to and subscribed before me this
`My cpmmission expires:
`2/2/10G
`EXHIBIT
`Charles Brook,
`Property Manager for Wallace Properties
`aa-4. day of January, 2025.
`NOTARY PUBLIC
`.. .. . ...
`ROTARY
`•: ••• • :•
`JOHNNY DUNIGAN
`MY COMMISSION # 12346226
`EXPIRES: February 2, 2026
`Craighead County
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`NOTICE TO VACATE TO THERESA MULLENS AND ALL OCCUPIERS OF
`THE PREMISES LOCATED AT 408 NELSON STREET, APT. II,
`LEACHVILLE, ARKANSAS
`TO: Theresa Mullens and all occupiers of the premises
`408 Nelson St., Apt. 11
`Leachville, Arkansas
`You are hereby notified that you are to vacate the dwelling owned by Karen
`Wallace. The address of the property is 408 Nelson Street, Apartment 11, Leachville,
`Arkansas.
`The termination is based on the following reasons:
`Nonpayment of monthly rent payments and allowing unauthorized tenants
`in violation of the lease.
`If you fail to quit the premises within three (3) days of service of this notice,
`appropriate action will be brought against you, and you may be required to pay the costs
`of court and attorney's fees.
`2-4 YOU HAVE 3 DAYS FROM THE / 3 - DAY OF JANUARY 2025, TO
`VACATE THE PREMISES.
`.5"-; \•-•t/1 Law Office of Johnny Dunigan
`219 West Drew
`A - 4 7 70-(762,c7 :::=?Q__?e,j,„t P.O. Box 405
`M nette, AR 72447
`(870) 486-1355
`By:
`s...64a J ny Dunigan, 2003141
`1/(‘____ Attorney for Karen Wallace
`Arit.ra'h. (c77+-71 ‘-`"'
`EXHIBIT
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