§ Form20 Complaint for Fraud

Form20. Complaint for Fraud.

    1. On or about the ______ day of ______, defendant and plaintiff were negotiating concerning the purchase by plaintiff from defendant of the following described property:

[describe property].

    2. At that time defendant represented to plaintiff that [here set out representations with particularity].

    3. The representations made by defendant were false (and defendant knew that they were false) (and defendant, without knowledge of the true facts, recklessly misrepresented them) (and were made by mistake but with the intention that plaintiff should rely upon them).

    4. Plaintiff believed the representations and in reliance upon them purchased the property.

    Wherefore, (etc. as in Form 16).