§ 9-11-113. Form of complaint on claim for debt and to set aside fraudulent conveyance under section 9-11-18

IN THE _____ COURT OF _____ COUNTY

STATE OF GEORGIA

A.B.,

)

Plaintiff

)

Civil action

)

File no. _____

C.D. and E.F.,

)

(Clerk will insert

Defendant

)

number.)

--COMPLAINT--

The defendant C.D., herein named, is a resident of _____ (street), _____ (city), _____ County, Georgia, and is subject to the jurisdiction of this court. (Add appropriate statement about domicile of defendant E.F.)

--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 $5,000.00 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 $10,000.00 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.

______________________________________

Attorney for plaintiff

______________________________________

Address