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l4. That plaintiffs repeat and reatlege paragraphs of the ~
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Complaint marked and numbered "t" through ''4" as if set forth here in full, !
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j; and allege further that on the 23rd day of March, t976, ptaintiffs did execute ~
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i~ documents purporting to be Deeds of the aforesaid premises , and pur-
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~ porting to convey the titl~ thereof to the defendants as more fuily appears ~
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from the annexed copies of said Deeds .
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l5. That there was a failure in consideration in the transfer ;
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: af said lots, and that at no time did the Grantees set forth in the annexed i~
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' Deed, pay to the plaintiffs any sum of money far said tots. ~
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16. That plaintiffs have no adequate rQmedy at law.
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' Vb'HEREFORE, the plaintiffs pray that this Court may
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' adjudge and decree that the said Deeds from the plaintiffs to the said ~
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d~fendants are fraudutent and void and that the said Deeds be set aside and ~
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' cancelled of record; for judgment estabiishing a trust in favor of the plaintiffs',
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and directing ~ recor~veyance of the property so tia t the plaintiffs may be '
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again restored to their rights in the property; and for such other, further and !
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difFerent relief as to the Court may seem just, equitable and proper in the }
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PHILIP C. SCHIFFM~N, ESQ.
, _ . Attorney for P[aintiffs
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~ ' ? , ~ ' ; Office and Post Office Address
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~ ll East Main Street f
• ~ ~ ~ • ~ Washi ngtonvi l le , N . Y . t0992
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S.:r. (9l4) 496-7333 j
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~ BOOK 2~Q PAGf ~j'
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