Form 13 - Complaint on Claim for Debt and to Set Aside Fraudulent Conveyance Under Rule 18(b)| A.B., Plaintiff, v. C. D. and E.F., Defendants. | ) | COMPLAINT |
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1. Allegation of residence of parties.2. 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 A); (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).3. Defendant C. D. owes to plaintiff the amount of said note and interest.4. 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 _______________________ 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.