FORM 12. COMPLAINT ON CLAIM FOR DEBT AND TO SET ASIDE FRAUDULENT CONVEYANCE UNDER RULE 18(b)

Effective Date: 1/1/2001

A. B.,
Plaintiff
)
)
vs. ) COMPLAINT
C. D. and E. F.,
Defendants
)
)

1. Defendant C.D. on or about _______ executed and delivered to plaintiff a promissory note [in the following words and figures: (here set out the note verbatim)]; [a copy of which is hereto annexed as Exhibit 1]; [whereby defendant C.D. promised to pay to plaintiff or order on the sum of five thousand dollars with interest thereon at the rate of percent per annum].

2. Defendant C.D. owes to plaintiff the amount of said note and interest.

3. Defendant C.D. on or about conveyed all his property, real and personal [or specify and describe] to defendant E.F. for the purpose of defrauding plaintiff and hindering and delaying the collection of the indebtedness evidenced by the note above referred to.

Wherefore plaintiff demands:

(1) That plaintiff have judgment against defendant C.D. for five thousand dollars and interest;(2) that the aforesaid conveyance to defendant E.F. be declared void and the judgment herein be declared a lien on said property; (3) that plaintiff have judgment against the defendants for costs and disbursements.

Effective Date Obsolete Date
01/01/2001 View