DOCUMENT 2

ELECTRONICALLY FILED
10/25/2019 9:35 AM
38-CV-2019-900619.00
CIRCUIT COURT OF
HOUSTON COUNTY, ALABAMA
CARLA H. WOODALL, CLERK
IN THE CIRCUIT COURT OF HOUSTON COUNTY, ALABAMA

FREEDOM MORTGAGE CORPORATION;

PLAINTIFF

VS.
CIVIL ACTION NUMBER:
HOLLY JINKS;

DEFENDANT.

COMPLAINT

COMES NOW the Plaintiff in the above-styled cause and represents unto this Honorable

Court as follows:

1. Plaintiff, Freedom Mortgage Corporation (“Plaintiff”) is qualified to do business in

Alabama and is doing business in Houston County, Alabama.

2. Defendant Holly Jinks is over the age of 19 years and is a resident citizen of Houston

County, Alabama.

3. Plaintiff avers that by virtue of the foreclosure sale held on October 15, 2019 of that

certain mortgage originally between Holly Jinks and Mortgage Electronic Registration

Systems, Inc. acting solely as nominee for Freedom Mortgage Corporation, which said

mortgage was recorded in the Office of the Judge of Probate of Houston County,

Alabama, at MTG 2420 Page 382; Plaintiff is now the owner of the following-described

real property located and situated in Houston County, Alabama, to wit:

COMMENCING AT THE INTERSECTION OF THE NORTH

LINE OF THE NE1/4 OF THE SW1/4 OF SECTION 16, TlN,
R27E AND THE SOUTHWESTERLY RIGHT OF WAY OF A
PAVED COUNTY ROAD (80` ROW) AND RUN IN A
SOUTHEASTERLY DIRECTION ALONG SAID RIGHT OF
WAY OF SAID PAVED COUNTY ROAD A DISTANCE OF 663
FEET TO A SET IRON PIPE AND THE POINT OF
BEGINNING; THENCE CONTINUE ALONG SAID RIGHT OF
WAY S34°06`E A DISTANCE OF 147.60 FEET TO A SET IRON
PIPE; THENCE S57°00`W, 133.83 FEET TO AN EXISTING
 DOCUMENT 2

IRON PIPE AND FENCE CORNER; THENCE N33°00`W

ALONG SAID FENCE A DISTANCE OF 147.58 FEET TO AN
EXISTING IRON PIPE AND FENCE CORNER; THENCE
N57°00`E ALONG SAID FENCE A DISTANCE OF 131 FEET
TO THE POINT OF BEGINNING. SAID LOT BEING
LOCATED IN THE ABOVE MENTIONED FORTY AND
PURPORTING TO CONTAIN 0.448 ACRES.

Also known as 4290 D Hodge Rd, Cottonwood, AL 36320.

4. Plaintiff avers that on or about October 17, 2019, Plaintiff served or caused to be served

upon the Defendant a written Demand for Possession of the subject real property

pursuant to Section 6-5-251 Code of Alabama (1975).

5. Plaintiff avers that the Defendant has failed and refused to vacate the aforesaid property

despite Plaintiff’s demands to do so.

WHEREFORE, PREMISES CONSIDERED, Plaintiff demands possession of the

aforesaid real property and an order that the Defendant has forfeited her right to redemption for

failing to vacate the property plus such other, further and different relief Plaintiff is entitled to

under these premises and costs of court.

/s/ Evan Eberhardt

Evan Eberhardt
Attorney for Plaintiff
Jauregui, Lindsey, Longshore & Tingle
244 Inverness Center Drive
Suite 200
Birmingham, AL 35242
Phone: (205) 970-2233
eeberhardt@jandllawfirm.com

/s/ Jason B. Tingle

Jason B. Tingle
Attorney for Plaintiff
Jauregui, Lindsey, Longshore & Tingle
244 Inverness Center Drive
Suite 200
Birmingham, AL 35242
Phone: (205) 970-2233