Fill and Sign the Complaint Reformation

IN THE ________________________ (Name of Court) COURT OF _______________________ (Name of County), _______________________ (Name of State) _________________________________ PLAINTIFF (Name of Plaintiff) V. CAUSE NO. ____________ _________________________________ DEFENDANT (Name of Defendant) Complaint for Correction and Reformation of Judgment COMES NOW _____________________________ (Name of Plaintiff) , Plaintiff in the above-styled and numbered cause, by and through its attorney, and files this its Complaint for Correction and Reformation of Judgment, and in support thereof would show unto the Court the following matters and facts: 1. Plaintiff is a corporation existing under the laws of the state of _____________________________ (name of state) , with its principal office located at ________________________________________________________________________ ___________________________________ (street address, city, county, state, zip code) , and is, therefore, a citizen of ___________________________________ (name of state) . 2. Defendant ________________________________________ (Name of Corporate Defendant) is a corporation organized and existing under the laws of the State of ________________________________ (name of state) , and is, therefore, a citizen of _________________________________ (name of state) . 3. On _______________________________ (date) , Defendant filed a Complaint in this Court against Plaintiff, being Civil Action No. _____________________ (case number) , by which suit Defendant sought the rescission or, in the alternative, modification of a Lease Agreement covering certain real property situated described in Exhibit A attached hereto and made a part hereof, all as more fully appears from the original Complaint, a true and correct copy of which is attached hereto as Exhibit B and made a part of this Complaint by reference. A copy of said Lease Agreement is attached hereto as Exhibit C . 4. Subsequently, in order to settle the controversy and end the litigation, a stipulation and transaction of compromise was effected by and between the parties, the terms of which were incorporated in and made by the Decree of this Court, a true and correct copy of which is attached hereto as Exhibit D and made a part of this Complaint by reference. 5. Paragraphs ________ (numbers) of the above-mentioned Decree provide as follows: (quote provisions of cited paragraphs) ________________________________ ________________________________________________________________________ ________________________________________________________________________ ________________________________________________________________________ _______________________________________________________________________ . 6. As is shown in the original Complaint, John Doe w as the owner of the real property cover by the Lease. It was the intention of the interested parties that John Doe be confirmed as the sole owner of said real property. Through error, Jane Doe, who died in __________________________________ (date) was also recognized in the decree as an owner of a said real property. The estate of Jane Doe was closed and the assets distributed on __________________________________ (date) , and John Doe was the devisee of the said real property pursuant to the last will and testament of Jane Doe. WHEREFORE, Plaintiff requests that Defendant be duly served with copies of this Complaint and cited to appear and answer; after proceedings are had, there be judgment rendered correcting and reforming the compromise agreement and Decree of this Court to the end that John Doe be recognized as the sole owner the real property covered by said Lease Agreement and described in Exhibit C attached hereto. Plaintiff further requests all necessary orders and full, general, and equitable relief. Respectfully submitted this __________________________________ (date) . _________________________________________ (Name of Plaintiff) By: ______________________________________ _________________________________________ (Name & Signature of Plaintiff’s Attorney) State Bar No. __________________ Plaintiff’s Attorney Certificate of Service This is to certify that I, _____________________________________ (Name of Attorney) , attorney for Plaintiff ___________________________________ (Name of Plaintiff) , have this date served a true and correct copy of the above and foregoing Complaint for Correction and Reformation of Judgment by U.S. Mail, postage fully prepaid, to the following counsel of record for Defendant: ___________________________________ (Name of Attorney) _______________________________________ Post Office Box ________________________________________________ City, State, Zip Code This the _____ day of ____________________________, 20_____. Respectfully Submitted, ___________________________________ (Name of Attorney) State Bar No. _______________ Attorney for Plaintiff OF COUNSEL: ________________________________ (Name of Plaintiff’s Attorney) Post Office Box ________________________ ___________________________________________ City, State, Zip Code Telephone: ________________________