Fill and Sign the Slander Mississippi Form

IN THE CHANCERY COURT OF       COUNTY, MISSISSIPPI       PLAINTIFFS VS. NO.             DEFENDANTS COMPLAINT TO CONFIRM TITLE AND REMOVE CLOUDS and COMPLAINT FOR SLANDER OF TITLE COME NOW PLAINTIFFS and file this their Complaint to Confirm Title and to Remove Clouds and in support hereof would show the following, to-wit: 1. Defendants are adult resident citizens of       County, Mississippi and may be served with process of this Court at       . 2. Plaintiffs are the owners of the legal and equitable title to the following described property (hereafter "The Property"):       3. Plaintiffs are and have been in open, visible, hostile, notorious, peaceful, continuous and uninterrupted adverse possession of The Property for more than       (       ) years. 4. Plaintiffs have exercised acts of ownership of The Property to the exclusion of everyone else for more than       (       ) years, including but not limited to, erecting posted signs around The Property, entering upon The Property regularly, traversing and maintaining lanes and woods roads across The Property, cutting brush, grass and trees from The Property, hunting, patrolling The Property and evicting trespassers. Other than trespassers who have been evicted from The Property and other than the Plaintiffs and their invitees, no other persons have entered upon The Property for more than       (       ) years. 5. Defendants obtained a purported Warranty Deed on or about       from       a copy of said deed being attached hereto as Exhibit "       ". Defendants have caused said deed to be recorded in the land records of       County, Mississippi in Deed Book       at page       . Plaintiffs would show that at the time the deed was obtained by Defendants the said       had not been on The Property in over       (       ) years nor had his/her predecessor in title. Said deed is a cloud on Plaintiffs' title and should be canceled and removed. 6. Defendants       and       have filed before the Board of Supervisors of       County, Mississippi, a Petition to Establish Private Way, a copy of which is attached hereto as Exhibit "2". In said Petition, Plaintiffs claim to be the owners of The Property. Said Petition is a cloud on Plaintiffs' title and should be canceled and removed. 7. Defendants obtained the deed, attached hereto as Exhibit "       ", knowing that The Property was surrounded on       (       ) sides by other properties of Plaintiffs, and Defendants knew that Plaintiffs had exercised exclusive use and control over The Property for more than       (       ) years and that there was no access to The Property by either public or private road. Defendants obtained and recorded the deed (Exhibit "       ") and filed the Petition (Exhibit "       ") with the express willful motive and intent to slander Plaintiff's title and with reckless disregard for Plaintiffs rights. Plaintiffs are entitled to punitive damages from Defendants. 8. Alternatively, Plaintiffs have exercised exclusive use, and possession of lanes and roadways over along and across The Property for more than       (       ) years. Said use has been and continues to be open, visible, hostile, notorious, peaceful, continuous and uninterrupted adverse use and possession. Plaintiffs have utilized said lanes and roadways to access other properties of Plaintiffs which surround The Property on       (       ) sides Alternatively, Plaintiffs have obtained an easement by adverse possession for ingress and egress over The Property along the existing lanes and woods roads which traverse said property. 9. Plaintiffs are entitled to damages for intentional slander of title and their attorneys’ fees and costs. WHEREFORE, PREMISES CONSIDERED, Plaintiffs pray that this Complaint be received and filed and that process be issued to the Defendants requiring them to answer this Complaint in accordance with law, and that upon a hearing hereof, the Court will enter Judgment for the Plaintiffs as follows: a. Confirming Plaintiffs' title to The Property by adverse possession; b. Removing and canceling the Clouds on Plaintiffs' title caused by the recording of the Deed (Exhibit "       ") and caused by the filing of the Petition (Exhibit "       "); c. Awarding Plaintiffs damages and punitive damages against Defendants for slander of title; d. Alternatively, confirming Plaintiffs' title to an easement for ingress and egress over the lanes and woods roads which traverse The Property; e. Awarding Plaintiffs reasonable attorneys fees and costs. Plaintiffs pray for general relief. Respectfully submitted, _______________________________________       Attorney for       Of Counsel:                         Telephone:       MSB #       Attorney for       BY: ________________________       MSB #       ACKNOWLEDGMENT STATE OF MISSISSIPPI COUNTY OF       PERSONALLY appeared before me, the undersigned authority in and for the county and state aforesaid, the within named       , who acknowledged to me on information and belief that all matters, facts and things set forth in the above and foregoing COMPLAINT TO CONFIRM TITLE AND REMOVE CLOUDS AND COMPLAINT FOR SLANDER OF TITLE are true and correct as therein stated. GIVEN under my hand and official seal this the       day of       , 20       . _______________________________ NOTARY PUBLIC My Commission Expires: