Form 12 - Complaint on claim for debt and to set aside fraudulent conveyance under Section 15-6-18(b)A.B., Plaintiff
vs. 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 of 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 _____ 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.