Fill and Sign the Answer and Counterclaim to Confirm Title 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 __________)))) __________'S ANSWER AND COUNTERCLAIM TO CONFIRM TITLECOMES NOW, __________, by counsel, and files her Answer to the Complaint and Counterclaim to Confirm Title in the above styled and numbered cause on __________ __, ____, stating the following facts:1. Defendant admits that she is an adult resident citizen of __________ County, __________, as alleged in Paragraph No.1.2. Defendant admits the statements in Paragraph No.2.3. Defendant admits the deraignment of title stated in Paragraph No.3 of the Complaint except Item No.5 which shows a quitclaim deed from __________ who is a stranger to the title and this deed has no bearing on the true deraignment.4. Defendant is the sole owner of an undivided one-half interest in the 20-acre tract title to which is sought to be confirmed by this action.5. Defendant acquired title as a beneficiary in the Last Will and Testament of __________ dated __________ __, ____. 6. Defendant denies the allegations of adverse possession in Paragraph No. 4 in that tenants in common cannot gain title by adverse possession. 7. Defendant admits that __________ heirs and others have paid the taxes on the property, but would show that the arrangement with Defendant's predecessor in title was that gravel and timber sales would be accumulated and offset against the taxes; therefore, the resources of the land actually paid the taxes to which this Defendant is entitled to credit for her share of the land resources used for such purpose.8. In answer to Paragraph No.6 of the Complaint, this Defendant states that this has been raw timber land and does not have any information regarding nor does she believe that there is insurance coverage on the subject property.9. Defendant moves the Court to dismiss the Complaint insofar as her ownership of an undivided one-half interest in the subject property is concerned. COUNTERCLAIM COMES NOW, __________, and makes her Answer a Counterclaim, adopting by reference all statements made herein before, and for cause of action states the following facts:1. Defendant is an adult resident citizen of __________ County, __________, and the Plaintiff is a __________ corporation with notice of the filing of this counterclaim being served on said Defendant by serving its counsel of record as shown by the certificate annexed hereto.2. Defendant is the sole owner of an undivided one-half interest in the following described property situated in __________ County, __________, to-wit:5 1/2 of the NW 1/4 of the SE 1/4 of Section 17, Township 3 North, Range 3 East, __________ County, __________.3. Defendant deraigns her title to said property by virtue of Paragraphs III, 1-18, as shown by Exhibit "A" attached hereto, being pages out of the Complaint to Adjudicate Title filedby __________ in this cause on ________ _____, 20____. 4. Defendant alleges that __________ acquired an undivided one-half interest in the subject property on __________ __, ____, and that his interest passed to his wife, __________, upon his death on __________ __, ____, and that __________'s interest passed to __________ upon her death on __________ __, ____, by virtue of her Will dated __________ __, ____ wherein she devised the subject land to __________ and __________, or the survivor of them, thereby __________ became the owner of said property because __________ passed away prior to the death of __________ having died on __________ __, ____. __________ devised the property to this Defendant by Will dated __________ __, ____, she having passed away on __________ __, ____. 5. Defendant has incurred $00.00 in legal fees in defending the suit brought by __________ and the Court should award her damages against __________ in the amount of $00.00 based upon the provisions of the frivolous lawsuit statute. WHEREFORE, Plaintiff brings this cause of action under her Counterclaim and prays for a Judgment awarding her the fee simple title to an undivided one-half interest in the land described herein, and a Judgment for the sum of $00.00 for attorney's fees and related expenses connected with defending the suit of __________. Respectfully submitted,_____________________