[Insert caption.]
COMPLAINT
Plaintiffs state:
1. Plaintiffs are spouses and adult residents of ______County, Michigan.
2. Defendants are spouses and adult residents of ______County, Michigan.
3. This action seeks an order of the court vesting legal title to real property in Plaintiffs. The real property at issue is legally described as the north 15 feet of Lot 16, Bransdorfer Addition, City of ______, ______County, Michigan.
4. Plaintiffs are the owners in fee simple as tenants by the entireties of the real property immediately to the north of the property at issue. Plaintiffs’ property is legally described on their deed as Lot 17, Bransdorfer Addition, City of ______, ______County, Michigan.
5. Defendants are record title holders to the property at issue as well as the balance of Lot 16.
6. Beginning in 1944 and continuing until 1975, legal title to both Lots 16 and 17 was vested in John and Mary Doe, spouses. The Does constructed a residence, with attached garage and surrounding landscaping. The balance of the two lots remained vacant land and was kept as a pasture.
7. In 1975, John and Mary Doe conveyed the real property upon which their residence, garage, and landscaping were located to Plaintiffs. The parties understood and agreed as to what part of the real estate owned by the Does was being transferred and, at the time of the conveyance, believed that all of the property being transferred was contained in Lot 17. The deed was drafted on that basis.
8. Plaintiffs took possession of the property. The Does retained title to the remaining property until 1992, when they transferred the remaining property, described in the deed as Lot 16, to Defendants.
9. Since 1975 Plaintiffs have been in possession of the property they purchased, including the house, attached garage, and surrounding landscaped area. Plaintiffs’ possession has been actual, visible, open, notorious, exclusive, continuous, and uninterrupted. Plaintiffs have excluded others from the use of their property, and they hold it under a claim of right as described above.
10. In [year], the City of ______began to install a curb and gutter on ______Street, adjacent to both Lots 16 and 17. In connection with the assessment to the lots associated with those improvements, Plaintiffs became aware that the deed they received did not contain a legal description of all of the property that they had purchased from John and Mary Doe in 1975. Despite Defendants’ being advised that Plaintiffs have possessed the property to the edge of the landscaped area, as alleged in this complaint, Defendants have failed and refused to execute recordable documents necessary to correct the recorded title and transfer the north 15 feet of Lot 16 to Plaintiffs.
PLAINTIFFS REQUEST that this court enter judgment in their favor declaring that they are the lawful owners of the north 15 feet of Lot 16, Bransdorfer Addition, City of ______, ______County, Michigan, and award Plaintiffs such other and different relief as the court deems warranted.
Dated: ______/ [Firm name]By: /s/______
[Typed name of attorney] (P____)
Attorney for Plaintiff
[Address, telephone]