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

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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 _______ per cent 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.