[COURT NAME]
[COUNTY], [STATE]
[PLAINTIFF NAME], )
Plaintiff, )
) Case No. [CASE NUMBER]
v. )
)
[DEFENDANT NAME(S)], )
Defendant(s). )
COMPLAINT FOR PARTITION
1. Parties and Property
1.1 Plaintiff and Defendant(s) are co-owners of the real property located at [ADDRESS], legally described as [LEGAL DESCRIPTION].
1.2 Plaintiff owns [PERCENT]% and Defendant(s) own [PERCENT]% of the property.
2. Jurisdiction and Venue
2.1 This Court has jurisdiction under [STATUTE].
2.2 Venue is proper in [COUNTY] because the property is located here.
3. Facts Supporting Partition
3.1 The parties cannot agree on use or disposition of the property.
3.2 Partition in kind is [PRACTICAL/IMPRACTICAL] due to [REASONS].
3.3 Partition by sale is necessary to equitably divide interests.
4. Accounting (Optional)
4.1 Plaintiff requests an accounting of contributions for taxes, insurance, maintenance, and improvements.
5. Cause of Action - Partition
5.1 Plaintiff realleges the foregoing paragraphs.
5.2 Plaintiff seeks partition of the property and allocation of proceeds according to ownership interests.
6. Prayer for Relief
Plaintiff requests that the Court:
a. Order partition in kind or by sale as appropriate.
b. Appoint a referee or commissioner to conduct the partition or sale.
c. Order an accounting and equitable adjustments among the co-tenants.
d. Award costs and any other relief the Court deems just.
7. Jury Demand
Plaintiff demands a trial by jury if required and if demanded.
8. Signature Block
text
Dated: [DATE]
______________________________
[ATTORNEY NAME]
[LAW FIRM]
[ADDRESS]
[PHONE]
[EMAIL]
Attorney for Plaintiff