Fill and Sign the Reform Deed

IN THE ___________ COURT OF ____________ (County) , _______________ (State) ______________________ PLAINTIFFS (Name of Plaintiff) V. CAUSE NO. -______,_________ ______________________ DEFENDANT (Name of Defendant) Complaint to Reform Deed— Mistake in Erroneous Names of Two Grantees COMES NOW _____________________ (Name of Plaintiff) , Plaintiff in the above-styled and numbered cause, and files this his Complaint against Defendant, and in support thereof would show unto the Court the following matters and facts: 1. Plaintiff is an adult resident citizen of ___________________________________ _____________________________ (city, county, state) . 2. Defendant is an adult resident citizen of ________________________________ _____________________________ (city, county, state) . 3. On _______________ (date) , _____________________ (name of property owner ) , was the owner of a parcel of land located in ________________ (county) County, _______________ (state) , legally described as follows: (set forth description) ______________________________________________________________________ ______________________________________________________________________ _____________________________________________________________________. 4. On that date, Plaintiff and _____________________ (name of property owne r ) , the Owner, entered into a written agreement, under the terms of which the Owner was to convey to Plaintiff , the grantee described in the above-described Agreement, the property described above, in consideration of the sum of _______________ (dollar amount) . A copy of the Agreement is attached marked Exhibit A and made a part of this Complaint. 5. On that date, Plaintiff paid Owner, the sum of _________________ (dollar amount) , and Owner executed and delivered to Plaintiff a _____________ (warranty) deed, which both parties supposed would pass title only to Plaintiff. However, Owner’s attorney, who drew up the deed, mistakenly described an additional grantee ___________________ (Defendant) in the Deed as follows: (set forth description) ______________________________________________________________________ ______________________________________________________________________ _____________________________________________________________________. 6. Plaintiff did not discover the mistake of the attorney for Owner until ____________________ (date) , although Plaintiff used due diligence in reference to discovery of the mistake. 7. Plaintiff immediately on discovery of the mistake, and on ________________ (date) , made written demand on Defendant for the reformation of the Deed to conform to the agreement, but Defendant failed and refused, and still fails and refuses, to reform the Deed. WHEREFORE, Plaintiff requests that: 1. The Deed be reformed so as to conform to the actual agreement of the parties; 2. Plaintiff be awarded for costs of suit; and 3. And if Plaintiff has prayed for wrong and improper relief, then he prays for such other, further and general relief as she may be entitled to in the premises, and as in duty bound, he will ever pray. (Attach exhibit(s)) Respectfully submitted, ____________________________ (Printed Name of Plaintiff) ____________________________ (Signature of Plaintiff) STATE OF _______________ COUNTY OF ______________ Personally appeared before me, the undersigned authority in and for the aforesaid jurisdiction, the within named _____________________ (Printed Name of Plaintiff) who, after having been first duly sworn, stated on oath that the matters and facts set forth in the above and foregoing Petition are true and correct as therein stated. _______________________ (Printed Name of Plaintiff) _______________________ (Signature of Plaintiff) SWORN to and subscribed before me, this the ____________________ (date) . __________________________________ Notary Public My Commission Expires: ________________________