Fillable PLAINTIFFS PETITION FOR EX PARTE WRIT OF RE-ENTRY (El Paso County)

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PLAINTIFFS PETITION FOR EX PARTE WRIT OF RE-ENTRY (El Paso County)

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SWORN PETITION FOR WRIT OF RE-ENTRY
Page 1 of 3
NO. _________________
_______________________,
Plaintiff,
v.
_______________________,
Defendant.
§
§
§
§
§
§
§
JUSTICE OF THE PEACE COURT
PRECINCT NO. _____, PLC. ______
EL PASO COUNTY, TEXAS
PLAINTIFF’S PETITION FOR EX PARTE WRIT OF RE-ENTRY
UNDER TEXAS PROPERTY CODE §92.009
TO THE HONORABLE JUDGE OF THIS COURT:
Plaintiff, _____________________ (name), files this sworn petition against
___________________________ (Defendant’s name), Defendant, and respectfully shows that
Court the following:
1. Plaintiff reside at __________________________________ (street address), in
the City of ________________(city), Texas, ________ (zip code), located within Justice
Precinct ___, Place ____ of El Paso County, Texas.
2. Per Tex. Prop. Code §92.003, Defendant may be served at
_____________________________________________ (Defendant’s home or work address), or
_____________________________________________ (Defendant’s property management
company’s address), or __________________________________________ (Defendant’s on-site
property manager’s address or rent collector’s address). Plaintiff requests that citation be issued
and Defendant be personally served at the address listed in this paragraph. If necessary,
alternative service is requested under Tex. R. Civ. P. 742a.
3. The events described in this petition took place within the jurisdiction of this
Justice Court precinct.
FACTS
4. Plaintiff, as tenant, on or about the ____________________ (date of rental
agreement), leased the above described premises from Defendant, as landlord. The lease is
_______________ (oral / written). The lease is currently in effect.
SWORN PETITION FOR WRIT OF RE-ENTRY
Page 2 of 3
5. On or about the the _____________________________ (date of lock-out),
Defendant locked out Plaintiff from the above rented property. Plaintiff demanded a key or
access to the presmises but Defendnat has refused to provide access to the property to Plaintiff in
violation of §92.0081 of the Texas Property Code.
OTHER FACTS
6. The Court should also be aware of the following:
______________________________________________________________________________
______________________________________________________________________________
______________________________________________________________________________
______________________________________________________________________________
_____________________________________________________________________________.
CAUSE OF ACTION
Violation of Texas Property Code §92.0081
7. Defendant violated §92.0081 of the Texas Property Code by unlawfully locking
Plaintiff out of Plaintiff’s rental unit.
8. Plaintiff requests that the Court issue an Ex Parte Writ of Re-Entry that entitles
Plaintiff to immediate possession of the rental property as permitted by section 92.009(c) of the
Texas Property Code.
REQUEST FOR RELIEF
13. Plaintiff requests that the Court find Defendant liable and grant Plaintiff the
following relief from Defendant:
a. an Ex Parte Writ of Re-entry under Texas Property Code 92.009(c) directed to
Defendant;
b. that said Writ of Re-entry be served on Defendant in accordance with law;
c. that Defendant be prohibited from interfering with Plaintiff’s peaceful possession
of the premises;
d. that all court costs be assessed against Defendant;
e. and for such other relief as Plaintiff may be lawfully entitled until such time
proper notice and hearing is held before this Court.
SWORN PETITION FOR WRIT OF RE-ENTRY
Page 3 of 3
Respectfully Submitted,
____________________________________
Signature
____________________________________
Printed Name
____________________________________
Address
____________________________________
Phone Number (Daytime)
UNSWORN DECLARATION UNDER
§132.001 OF THE TEXAS CIVIL PRACTICE AND REMEDIES CODE
My name is , my date of birth is ,
(First) (Middle) (Last)
and my address is , , , ,
(Street) (City) (State) (Zip Code)
. I declare under penalty of perjury that the foregoing is true and correct.
(Country)
Executed in County, State of Texas, on ______, _______,
(County) (Month) (Date)
20 .
(Year)
DECLARANT
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PLAINTIFFS PETITION FOR EX PARTE WRIT OF RE-ENTRY (El Paso County)

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Completed 5 August 2020

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