Fill and Sign the Complaint to Adjudicate Title Mississippi Form

IN THE CHANCERY COURT OF       COUNTY, MISSISSIPPI       , a Mississippi Corporation VS. THE KNOWN AND UNKNOWN HEIRS, SUCCESSORS AND ASSIGNS OF:       , DECEASED,       A/K/A Mr./Ms.       ,       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 Mississippi 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, Mississippi, who may be served with the process of this Court at his/her address of       ,       , Mississippi       . That Defendant,       , is an adult resident citizen of       County, Mississippi, who may be served at his/her address of       ,       , Mississippi,       . That the other Defendants' street addresses and/or post office boxes are unknown after diligent search and inquiry. II. That the Plaintiff,       , a Mississippi 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       ,       County, Mississippi, is as follows: 1. The land was patented out of the sovereign and passed by mesne conveyances. 2. In       Deed Book       , Page       , dated             ,       , filed for record             ,       ,       granted unto       , the       . 3. In       Deed Book       , Page       , dated             ,       , filed for record             ,       ,       granted unto       , his undivided       interest in the       . 4. In       Deed Book       , Page       , dated             ,       , filed for record             ,       ,       granted unto       , the       of the       , Section       . 5. In       Deed Book       , Page       , dated             ,       , filed for record             ,       ,       quitclaimed unto       , the       , Section       . 6. In       Deed Book       , Page       , dated             ,       , filed for record             ,       ,       granted unto       , the       , Section       . 7. In       Deed Book       , Page       , dated             ,       , filed for record             ,       ,       granted unto       and       , the       , Section       . 8. In       Deed of Trust Book       , Page       , dated             ,       , filed for record             ,       ,       unto       , Trustee and       , Beneficiary, in original principal sum of $       , due             ,       , covering the       ,       and the       , Section       ,       . This Deed of Trust has been satisfied. 9. In       Deed of Trust Book       , Page       , dated             ,       , filed for record             ,       ,       unto       , Trustee and       , Beneficiary, in the original principal sum of $       , due             ,       , covering the       . This Deed of Trust has been satisfied. 10. By virtue of a Trust document on file in Deed Book       , Page       and in Deed Book       , Page       ,       , is the Trustee of the       Land Trust. Said subject premises is included within the Trust. 11. In       Deed Book       , Page       , dated             ,       , filed for record             ,       ,       granted unto       , the       . 12. In       Chancery Cause #       , the Estate of       , Deceased, filed for record             ,       , recites that       died intestate on             ,       , and was survived by his widow/widower , Mr./Ms.       , as his/her sole and only heir. The court file was closed             ,       . 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 Mr./Ms.       , his/her husband/wife . The court file was closed             ,       . 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/her husband/wife ,       . 16. a. A purported Last Will and Testament of Mr./Ms.       , under date of             ,       , devised and bequeathed to       and husband/wife ,       , or the survivors of them, all his/her property of every kind and description, real, personal, or mixed, wheresoever situated, which he/she owned at the time of his/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 his/her daughter/son ,       , all the remainder of his/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 Mr./Ms.       is found to be invalid upon information and belief, the possible heirs of Mr./Ms.       a/k/a Mr./Ms.       upon information and belief would be as follows:       died intestate and without children. He/She had       siblings, all of whom are deceased as of       . The siblings and such as is known of the heirs is as follows: 1.       (       ) 2.       (       ) 3.       (       ) 4.       (       ) 5.       (       ) 6.       (       ) 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 Mississippi Code of 1972 Annotated, Section 15 - 1 - 13. V. Defendants' and Plaintiffs predecessors in possession,       , his/her 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/her 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       , Township       , Range       ,       County, Mississippi. 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, _______________________________________       Attorney for       Of counsel:                         Telephone:       MSB #       Attorney for