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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.
C. D. and E. F.,
W   Complaint
 Defendants
1. Allegation of jurisdiction. 2. Defendant C. D. on or about XXXX 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 XXX the sum of five thousand dollars with interest thereon at the rate of XXX percent. per annum]. 3. Defendant C. D. owes to plaintiff the amount of said note and interest. 4. Defendant C. D. on or about XXX 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 XXX 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.

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