FORM 66-2 COMPLAINT FOR REFORMATION OF DEED: FRAUD ON PART OF DEFENDANT

• Jurisdiction: Oregon

Form 66-2 Complaint for Reformation of Deed: Fraud on Part of Defendant

IN THE___COURT OF THE STATE OF OREGON FOR THE COUNTY OF___

__________ Plaintiff,

v.

__________ Defendant.

Case No.___

COMPLAINT

(REFORMATION OF DEED)

Plaintiff alleges:

1.

On or about___, 20___, plaintiff and defendant reached agreement for the purchase and sale of real property, located in __________County, Oregon. Defendant retained another parcel to the south of the subject property.

2.

Plaintiff agreed to pay defendant $___ . In return defendant was to give plaintiff a warranty deed to the property.

3.

Defendant altered the property description in the deed after plaintiff had reviewed it. As altered, the property description read as set forth in Exhibit 1, which is attached and incorporated by reference.

4.

The deed description did not include a strip of land approximately 10 feet wide along the southern boundary of the property. A corrected description is set forth in Exhibit 2, which is attached and incorporated by reference. The corrected language is underlined.

5.

At the time of closing, plaintiff believed the property description in the deed included the additional strip of land. Defendant knew plaintiff was unaware the deed description had been altered and intended that plaintiff should rely on her statement that she would make no changes to the deed after plaintiff reviewed it.

6.

At closing on ___, 20___, defendant executed and delivered the warranty deed to plaintiff. Plaintiff paid $___and signed a note and mortgage for the balance of $___.

7.

On ___, 20___, plaintiff had the deed recorded at the recorder's office in___County.

8.

About one year after closing, plaintiff...