§ FORM 19 COMPLAINT FOR FRAUD

Codes > Mississippi Rules of Civil Procedure > Chapter XI > Appendix A > FORM 19

FORM 19. 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 with the intention that plaintiff should rely upon them].

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

    Wherefore plaintiff demands judgment against defendant in the sum of _______ dollars and costs.

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