Fill and Sign the Adjudicate Form

IN THE CHANCERY COURT OF _________ COUNTY, _______________ _______________, a Corporation ) ) ) V. ) NO. ) THE KNOWN AND UNKNOWN HEIRS, SUCCESSORS AND ASSIGNS OF: __________, DECEASED, __________ A/K/A MRS. __________, __________ A/K/A __________, __________ ) ) ) ) ) ) ) THE KNOWN AND UNKNOWN HEIRS, SUCCESSORS AND ASSIGNS OF __________, DECEASED; ) ) ) ) ) THE KNOWN AND UNKNOWN HEIRS, SUCCESSORS AND ASSIGNS OF __________ ) ) ) THE KNOWN AND UNKNOWN HEIRS, SUCCESSORS AND ASSIGNS OF __________, __________, __________, __________, __________ AND __________ ) ) ) ) COMPLAINT TO ADJUDICATE TITLE COMES NOW, PLAINTIFF, __________, a __________ Corporation, by and through its counsel of record, and petitions this Court To Adjudicate Title of the subject property. I. That Defendant, __________, is an adult resident citizen of __________ County, __________, who may be served with the process of this Court at her address of __________. That Defendant, __________, is an adult resident citizen of __________ County, __________, who may be served at his address of __________. That the other Defendants' street addresses and/or post office boxes are unknown after diligent search and inquiry. II. That the Plaintiff, __________, a __________ corporation, acting by and through its duly authorized President, __________, is an adult resident citizen of __________ County. III. The Plaintiff would show unto this Court that the deraignment of title of the subject property, including some muniments, which subject property is described as the South ½ of the NW 1/4 of the SE 1/4 of Section __, Township ____, Range ____, __________ County, __________ is as follows: 1. The land was patented out of the sovereign and passed by mesne conveyances. 2. In __________ Deed Book 90, Page 411, dated November 3, 1924, filed for record on __________, __________ granted unto __________ the N '/2 of the SE 1/4, Section 17, T3N, R3E. 3. In __________ Deed Book 91, Page 429, dated __________, filed for record on __________, __________ granted unto __________ his undivided '/2 interest in the N '/2 of the SE 1/4, Section 17, T3N, R3E. 4. In __________ Deed Book 104, Page 394, dated __________, filed for record __________, __________ granted unto __________ the 5 '/2 of the NW 1/4 of the SE 1/4, Section 17, T3N, R3E. 5. In __________ Deed Book 111, Page 485, dated __________, filed for record __________, __________ quitclaimed unto __________, the 5 '/2 of the NW 1/4 of the SE 1/4, Section 17, T3N, R3E. 6. In __________ Deed Book 111, Page 487, dated __________, filed for record __________, __________ granted unto __________ the 5 '/2 of the NW 1/4 of the SE 1/4, Section 17, T3N, R3E. 7. In __________ Deed Book 122, Page 377, dated __________, filed for record __________, __________ granted unto __________ and __________ the 5 '/2 of the NW 1/4 of the SE 1/4, Section 17, T3N, R3E. 8. In __________ Deed of Trust Book 38, Page 241, dated __________, filed for record __________, __________ unto __________ and __________, Beneficiary, in original principal sum of $102.00, due __________, covering the 5 '/2 of the NW 1/4 of SE 1/4, Section 17, T3N, __________E and the N '/2 of the NW 1/4 of the SE 1/4, Section 17, T3N, R3E. This Deed of Trust has been satisfied. 9. In __________ Deed of Trust Book 39, Page 204, dated __________ filed for record __________, __________ unto __________ Trustee and __________ Beneficiary, in the original principal sum of $324.00, due __________, covering the NW 1/4 of the SE 1/4, Section 17, T3N, R3E. This Deed of Trust has been satisfied. 10. By virtue of a Trust document on file in Deed Book 590, Page 26 and in Deed Book 601, Page 655, __________, is the Trustee of the __________ Trust. Said subject premises is included within the Trust. 11. In __________ Deed Book 772, Page 665, dated __________, filed for record __________, __________ granted unto __________, the S 1/2 of theNW 1/4 of the SE 1/4 of Section 17, T3N, R3E. 12. In __________ Chancery Cause #__________, the Estate of __________, Deceased, filed for record on __________, recites that __________ died intestate on __________, and was survived by his widow, Mrs. __________, as his sole and only heir. The court file was closed on __________. 13. In __________ Chancery Cause #__________, the Estate of __________, Deceased, filed for record __________, recites that __________ died testate on __________ and that all possessions and property are bequeathed and devised unto Mrs. __________, his wife. The court file was closed on __________. 14. As a matter in pias upon information and belief: __________ and __________ are deceased. The interest of __________ descended into the __________ Land Trust. 15. As to matter in pias upon information and belief any interest of __________ descended to his wife, __________. 16. a. A purported Last Will and Testament of Mrs. __________, under date of __________ devised and bequeathed to __________ and wife, __________, or the survivors of them, all her property of every kind and description, real, personal, or mixed, wheresoever situated, which she owned at the time of her death. b. This will is not known to have been probated. 17. a. A purported Last Will and Testament of __________, under date of __________, recited to devise and bequeath to her daughter, __________, all the remainder of her possession whether real, personal or mixed of whatsoever kind and wherever situated. b. This will is not known to be probated. 18. If the referenced will of Mrs. __________ is found to be invalid upon information and belief, the possible heirs of Mrs. __________a/k/a Mrs. __________ upon information and belief would be as follows: __________ died intestate and without children. She had seven (7) siblings, all of whom are deceased as of ____. The siblings and such as is known of the heirs is as follows: 1. __________ (two sons) 2. __________ (two children) 3. __________ (one child) 4. __________ (one child) 5. __________, widow of __________ (two children, one being __________) 6. __________ (one child) IV. Defendants' and Plaintiffs predecessors in possession, __________ Land Trust and __________ have been in actual, open and notorious, uninterrupted continual occupancy of the subject property, respectively, and as deeded since ____, and ouster claim title by adverse possession, pursuant to ___________ Code __________, Section __________. V. Defendants' and Plaintiffs predecessors in possession, __________, his heirs and the __________ Land Trust have paid in full all taxes levied against the subject property from ____ to the present. VI. Defendants' and Plaintiffs predecessors in possession, __________, his heirs and the __________ Land Trust have paid in full all insurance coverage for the subject property. WHEREFORE PREMISES CONSIDERED, Plaintiff seeks that this Court vest full fee simple title by adverse possession to the subject property as follows: Unto __________: The South 1/2 of the NW 1/4 of the SE 1/4 of Section 17, Township 3 North, Range 3 East, __________ County, __________. Plaintiff further prays that it be granted such other relief, either general or specific, or both, to which they may be further entitled in the premises. Respectfully submitted, __________________________