Fill and Sign the Petition to Set Aside Conveyance Form

IN THE CHANCERY COURT OF ____________ COUNTY NAME OF PLAINTIFFS ) ) ) V. ) NO. ) ) NAME OF DEFENDANTS ) ) ) PETITION TO SET ASIDE CONVEYANCE COME NOW, the Plaintiffs herein, _____________, _____________, ________________, ________________ and ________________, by and through counsel, and file this Complaint To Set Aside Conveyance, and in support thereof would state as follows. I. Plaintiffs have an interest in the perpetual care cemetery known as ________________ hereinafter described. II. Defendant, ________________, is a corporation organized and existing under the laws of the State of __________, which may be served with process by service on the registered agent, who is ________________, ________________, __________, __________. III. Defendant, ________________, is a corporation organized and existing under the laws of the State of __________ which may be served with process by service on it's registered agent, ________________, ________________, __________, __________. IV. Defendant, ________________, is an adult resident citizen of __________ County, __________, who may be served with process at ________________, __________, __________. V. Defendants, _____________ and _____________, are adult resident citizens of __________ County, _________, who may be served with process at ___________, __________, __________. VI. ________________ was set up as a perpetual care cemetery and owned certain real property located in __________ County, __________, more particularly described as follows, to-wit: Situated in the County of __________, State of __________ to-wit: XI. That on ________ __, __________, ________________, conveyed said property to the City of __________; thereafter on ____________, __________, the City of __________ conveyed said property back to ________________ and wife, ________________ d/b/a ________________. A copy of said deeds are attached hereto as "Exhibits F and G". XII. That on ____________, __________, _____________ and wife, ______________, President and Secretary, respectively of _____________ conveyed said property to _____________. This is the last recorded conveyance is the subject property. A copy of said deed is attached hereto as "Exhibit H". XIII. Plaintiffs would show that any conveyance by or from _____________, ________________ or ____________ to ________________ and ________________ should be set aside and that all of said property was being utilized as a perpetual care cemetery and any conveyance from the perpetual care cemetery to an individual is void and should be stric ken as a cloud on the title to said property. Specifically, the ____ acres conveyed to ________________ and wife, ________________ should be conveyed by this Court to ________________ for the use and benefit of the perpetual care cemetery. WHEREFORE, PREMISES CONSIDERED, Plaintiffs pray that upon a hearing in this cause, that the Court decree that the above mentioned deeds conveyed to and from ________________ and wife, ________________, be set-aside and held for naught and accordingly stricken from the land records of __________ County, __________, and further that the Court decree that title be quieted and confirmed in ________________ as to that propert y described hereinabove, Further, if Plaintiffs have prayed for improper or insufficient relief, then they hereby pray for such other, further or more general relief as he may be entitled in the premises. Respectfully Submitted, __________________________________