Fill and Sign the Summerlin Et Al V Shellpoint Mortgage Services Et Al No Form

IN THE CIRCUIT COURT OF ____________________ COUNTY, ALABAMA (MORTGAGOR), *Plaintiff,* * vs. *CIVIL ACTION NO. * (MORTGAGEE) * Defendant. * COMPLAINT COMES NOW PLAINTIFF and brings me this complaint against Defendant and respectfully shows unto the Court as follows:1.Plaintiff is a citizen of the State of Alabama and is at least 19 years of age.2. Defendant is a corporation doing business in the State of Alabama having its principal place of business at ________________________.3. Plaintiff executed a mortgage and promissory note on ________________, _______, to Defendant, ___________________________. The indebtedness was secured to real property found in ___________________ County, Alabama to wit: (DESCRIBE PROPERTY) _________________________________________________ ________________________________________________________________________ ________________________________________________________________________4. Attached hereto is a copy of aforesaid mortgage and promissory note and marked as Exhibit 1 and 2 respectively. Aforesaid exhibits are incorporated into this Complaint.5. Plaintiff avers that Defendant, ________________________, failed to make material disclosures as required by the Federal Truth-in-Lending Act. More particularly, Defendant failed to disclose to Plaintiff the total amount of interest due under the mortgage and promissory note. Defendant has not cured the non-disclosure at this time.6. Plaintiff avers that this action is commenced within three years of execution of the said promissory note and mortgage.7. Plaintiff avers that the Defendant's failure to disclose entitles Plaintiff to rescind the promissory note and mortgage.WHEREFORE, Plaintiff prays that this Honorable Court grant, declare and award Plaintiff damages in the amount of ______________________________, including reasonable attorney's fee; the aforesaid promissory note and mortgage null and void; and such other relief the Honorable Court deems just and proper. Attorney for Plaintiff________________________