Fill and Sign the Describe the Property Form

- 1 - IN THE ______________ COURT OF ______________ COUNTY STATE OF ________________ )) ) Petitioner/Plaintiff, ))) NO. Vs. ))) Individually, and )) Defendant ) COMPLAINT COMES NOW Plaintiff ________________ by and through counsel, and files this Complaint against Defendant, ________________, individually and against ________________, and, in support hereof, states as follows: PARTIES 1. Plaintiff ________________ is an adult resident citizen of ________________ County, ________________. 2. Defendant ________________ is an adult resident citizen of ________________ County, ________________ who may be served with service of process by this Court at the following address: RELEVANT FACTS 3. Some time prior to ______________, 20____, Defendant ________________ began doing business as ________________ and engaged in the lawn maintenance business for commercial and residential clients. 4. During the same approximate time frame, Plaintiff ________________ was engaged in the operation of a lawn maintenance and landscaping business commonly known as ________________.
5. As a result, plaintiff had a substantial interest in the lawn maintenance business in a contract for sale or lease of the subject premises. 6. In or about january 2007, defendant sold said premises for a sum of dollars which the plaintiff deemed inadequate to meet his contractual obligations with the previous owner. 7. Immediately and after such sale, plaintiff began to operate as and through agent for both himself and other parties herein named, in the operation of the lawn maintenance business, in a manner similar to that in which he had operated prior to the sale. 8. Upon hearing about the sale, plaintiff advised defendant of his intent to sell the premises and of his desire to do so to him. 9. Since, defendant is the current owner of the premises and plaintiff is not of legal age to enter into any contracts or contracts involving the subject premises, defendant agreed to sell the premises to plaintiff for 25,000 cash. 10. Plaintiff commenced this action on or about, in the court of , for (in the court of) county (state of ) in the county (state of) . 11. Plaintiff requests the following relief by filing this petition in the court below: a. That the sale of the premises to defendant be excluded as a basis for liability on this case; b. That such sale be treated as a transaction on which there is no consideration for consideration. 12. That to the extent the sale of the premises occurred prior to or as a result of the sale of the premises, such sale be admitted as a defense to plaintiff's cause of action. 13. That plaintiff, defendant, and the other parties to the action be allowed to severally waive any claim as to the consideration for his purchase of the premises. Section 20. At the time the above-captioned matter was posted to the internet on a date sufficient for its contents to be reasonably disseminated to the public, the word "internet" , as used in this act, had not been adopted as the term or concept understood by those commonly known as the “internet community" . For purposes of the foregoing discussion, “internet community" shall refer to the members, hosts and other participants in the general internet network that comprise the “community" . It has been the intent of the people of the state of New York and the people of this state to make accurate all references to this part, unless otherwise specified herein, when the term “internet" is used in this part ; provided however, there is no intent on our.