NRCP

Form 13 – Complaint on Claim for Debt and to Set Aside Fraudulent Conveyance Under Rule 18(b)

Form 13. Complaint on Claim for Debt and to Set Aside Fraudulent Conveyance Under Rule 18(b)

  • A. B., Plaintiff }

    v. } 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 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].

    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 ten 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.