Preview
IN THE DISTRICT COURT OF MCCURTAIN COUNTY, STATE OF OKLAHOMA
MAMIE MILLIGAN,
PLAINTIFF,
Vs. No. C > - 21 - 2”
CUTINA ADAMS,
IN HER CAPACITY AS
THE PERSONAL REPRESENTATIVE
OF THE ESTATE OF JAMAL CLAY,
COURT CLERK'S OF
DEFENDANT. County of McCurtain, Sar. ue
FILED
PETITION FEB 24 2021
Comes now Plaintiff and shows the Court: KATHY GRAY, Court Clerk
By.
1. A warranty deed purporting to bear the signature of Mamie Milligan was recorded Pu
May 15, 2017 at Book 963, Page 743 in the McCurtain County Clerk’s Office. It falsely
purported to convey the following real property to Jamal Clay.
Begin 30 feet North of the NW corner of Lot 5 Block 8 of Lone Pine Addition;
Thence North 70 feet, Thence East 105 feet;
Thence South 70 feet, Thence West 105 feet to the POB.
2. A copy of the deed is attached hereto.
3. The signature on the deed is not the signature of Mamie Milligan. Mamie Milligan
did not intend to convey the subject real property to Jamal Clay. Mamie Milligan had
entered into an agreement to sell the real property to Jamal Clay, but he had not paid the
entire purchase price. There is justly due and owing to Mamie Milligan $3,250.00.
4. Defendant is the duly appointed and acting personal representative of the estate of
Jamal Clay, Jamal Clay being deceased. See case number PB-20-04, filed in the District
Court of McCurtain County, State of Oklahoma.
5. The Court should vacate the deed and place Plaintiff in possession of the real property,
or in the alternative, determine Defendant owns the real property upon the payment of the
balance, or in the alternative, grant Plaintiff judgment against Defendant for $3,350.00, or
in the alternative, determine the defendants are claiming some right, title, lien, estate,
encumbrance, claim, assessment or interest in and to the real property, adverse to Plaintiff
which constitute a cloud upon the title of Plaintiff, and said Defendants have no right,
title, lien, estate, encumbrance, claim, assessment or interest, either in law or in equity, in
and to the real property.Thus, Plaintiff prays that the Court vacate the deed, or in the alternative,
determine Defendant owns the real property upon the payment of the balance, or in the
alternative, grant Plaintiff judgment against Defendant for $3,350.00, for all relief set out
above, and for all other relief to which they are entitled.
Respectfully submitted,
of
JUSTIWR. PRATT
OBA # 16932
2108 SE Washington, Ste. B
Idabel, OK 74745
(580) 366-4111
ATTORNEY FOR PLAINTIFFea
Ory
2001-567116 Book 0963 Pg: 743
38 am Pg 0743-0743 WARRANTY DEED
06/15/2017 10:
‘Fee: $ 13.00 Doc: $2.25 (individual Form)
e - Mi ‘County Clerk
KNOW ALL MEN BY THESE PRESENT! i .
mat _AMgme A4i' aan sing le peison
Y NV part___of the first part,
in consideration of the sum of elye bh dollars and other valuable
considerations, in hand paid, the receipt of which is hereby fed, does hereby grant, bargain, sell
and convey unto Sarna vay STON W at at
we Tiel, 0 8 7474S
the whole estate the vest in
as joint tenants and not as tenants in common, with the right of survivorship,
of either, parties of the second part, the following described real property and
"
wenocsnace Molar County, State of Oklahoma, to-wit:
beg B04) Hus Cor Lot 5 BIK G Lene One Ack
+H ATO’ flo5’ $70’ wiles’ TO BEG
4
together with all the improvements thereon and the appurtenances thereunto belonging, and warrant the
titie to the same.
TO HAVE AND TO HOLD said described premises unto the said parties of the second part, as
such joint tenants, and to the heirs and assigns of the survivor, forever, fred, clear and discharged of and
from alt former grants, charges, taxes, judgments, mortgages and other liens and incumbrances of what-
soever nature. ihe
Signed and delivered this Y "day of Nn er + 20f 7
ww 1,
iat, o
f
vy Aaa
STATE OF Of} INDIVIDUAL ACKNOWLEDGEMENT
COUNTY OF hk
focjhe said County and State, nts “7 Peay a fa4
Before ie, the undersigned, a Notary Pp, in
201] ceronaiy eveanea Mayme Aili gan
the within and forging instrument and acknowledged to me that Sh <&
sone soar ow be Gasca porn
aan mrcara ce. LAESEPB. hes wswin tn rina ss ao puts se th,
Card mtnndapsaje ny and yaar en.
wyemaneenone fo HBO) any sc ¢F
Preview
IN THE DISTRICT COURT OF MCCURTAIN COUNTY, STATE OF OKLAHOMA MAMIE MILLIGAN, PLAINTIFF, Vs. No. C > - 21 - 2” CUTINA ADAMS, IN HER CAPACITY AS THE PERSONAL REPRESENTATIVE OF THE ESTATE OF JAMAL CLAY, COURT CLERK'S OF DEFENDANT. County of McCurtain, Sar. ue FILED PETITION FEB 24 2021 Comes now Plaintiff and shows the Court: KATHY GRAY, Court Clerk By. 1. A warranty deed purporting to bear the signature of Mamie Milligan was recorded Pu May 15, 2017 at Book 963, Page 743 in the McCurtain County Clerk’s Office. It falsely purported to convey the following real property to Jamal Clay. Begin 30 feet North of the NW corner of Lot 5 Block 8 of Lone Pine Addition; Thence North 70 feet, Thence East 105 feet; Thence South 70 feet, Thence West 105 feet to the POB. 2. A copy of the deed is attached hereto. 3. The signature on the deed is not the signature of Mamie Milligan. Mamie Milligan did not intend to convey the subject real property to Jamal Clay. Mamie Milligan had entered into an agreement to sell the real property to Jamal Clay, but he had not paid the entire purchase price. There is justly due and owing to Mamie Milligan $3,250.00. 4. Defendant is the duly appointed and acting personal representative of the estate of Jamal Clay, Jamal Clay being deceased. See case number PB-20-04, filed in the District Court of McCurtain County, State of Oklahoma. 5. The Court should vacate the deed and place Plaintiff in possession of the real property, or in the alternative, determine Defendant owns the real property upon the payment of the balance, or in the alternative, grant Plaintiff judgment against Defendant for $3,350.00, or in the alternative, determine the defendants are claiming some right, title, lien, estate, encumbrance, claim, assessment or interest in and to the real property, adverse to Plaintiff which constitute a cloud upon the title of Plaintiff, and said Defendants have no right, title, lien, estate, encumbrance, claim, assessment or interest, either in law or in equity, in and to the real property.Thus, Plaintiff prays that the Court vacate the deed, or in the alternative, determine Defendant owns the real property upon the payment of the balance, or in the alternative, grant Plaintiff judgment against Defendant for $3,350.00, for all relief set out above, and for all other relief to which they are entitled. Respectfully submitted, of JUSTIWR. PRATT OBA # 16932 2108 SE Washington, Ste. B Idabel, OK 74745 (580) 366-4111 ATTORNEY FOR PLAINTIFFea Ory 2001-567116 Book 0963 Pg: 743 38 am Pg 0743-0743 WARRANTY DEED 06/15/2017 10: ‘Fee: $ 13.00 Doc: $2.25 (individual Form) e - Mi ‘County Clerk KNOW ALL MEN BY THESE PRESENT! i . mat _AMgme A4i' aan sing le peison Y NV part___of the first part, in consideration of the sum of elye bh dollars and other valuable considerations, in hand paid, the receipt of which is hereby fed, does hereby grant, bargain, sell and convey unto Sarna vay STON W at at we Tiel, 0 8 7474S the whole estate the vest in as joint tenants and not as tenants in common, with the right of survivorship, of either, parties of the second part, the following described real property and " wenocsnace Molar County, State of Oklahoma, to-wit: beg B04) Hus Cor Lot 5 BIK G Lene One Ack +H ATO’ flo5’ $70’ wiles’ TO BEG 4 together with all the improvements thereon and the appurtenances thereunto belonging, and warrant the titie to the same. TO HAVE AND TO HOLD said described premises unto the said parties of the second part, as such joint tenants, and to the heirs and assigns of the survivor, forever, fred, clear and discharged of and from alt former grants, charges, taxes, judgments, mortgages and other liens and incumbrances of what- soever nature. ihe Signed and delivered this Y "day of Nn er + 20f 7 ww 1, iat, o f vy Aaa STATE OF Of} INDIVIDUAL ACKNOWLEDGEMENT COUNTY OF hk focjhe said County and State, nts “7 Peay a fa4 Before ie, the undersigned, a Notary Pp, in 201] ceronaiy eveanea Mayme Aili gan the within and forging instrument and acknowledged to me that Sh <& sone soar ow be Gasca porn aan mrcara ce. LAESEPB. hes wswin tn rina ss ao puts se th, Card mtnndapsaje ny and yaar en. wyemaneenone fo HBO) any sc ¢F