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IN THE DISTRICT COURT OF MCCURTAIN COUNTY, STATE OF OKLAHOMA
MAMIE MILLIGAN,
PLAINTIFF,
Vs. No. ( V5 “LU -o7
CUTINA ADAMS,
IN HER CAPACITY AS K’S OFFICE
THE PERSONAL REPRESENTATIVE COURT CLERK’
OF THE ESTATE OF JAMAL CLAY. County of McCurtain, State of Oklahoma
? FILED
DEFENDANT.
bad 10 2021
KATHY GRAY, Court Clerk
°y Deputy
FIRST AMENDED PETITION
Comes now Plaintiff and shows the Court:
1. A warranty deed purporting to bear the signature of Mamie Milligan was recorded
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 legal description omitted the section, range, and township, and is:
All that part of Section 31, Township 7 South, Range 24 East:
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.6. 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,
a
JU /PRATT
OBA # 16932
2108 SE Washington, Ste. B
Idabel, OK 74745
(580) 366-4111
ATTORNEY FOR PLAINTIFF[001-557116 Book 0083 Py: 743
cansnoi7 1038 am Pp, 07430763 WARRANTY DEED
"Fee. $1300 Doc: $225 (iedivdual Fare)
WONOW ALL MEN BY THESE PRESENT . "
‘That il
part___of the first part,
in consideration of the sum of, Twelve Thandred dollars and other valuable
isi Bons, ir 1, i lich is | de bargain, sell
cova stages meth oO NW Ath
we “Vine \5 0 & JaTh4S
Ge pot eras and ota eras in commen, with ie ht of survivors, te whee sais We eal
ees tots 8 oe
Beg, Sow 0 Cor Lot 5 BIK % lene Pine Ackl
TH ATO £lo5' STO" wios' TO BEG
together with all the improvements thereon and the appurtenances theretinto belonging, and warrant the
title 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, foraver, free; clear and discharged of and
from all former grants, charges. taxes, judgments, morigages and other liens and incumbrances of what-
soever nature. .
i dt i
Signed and deli mis aay of 1 Jaye 2~lT
wt Woo, '
Ti ipa
INDIVIDUAL ACKNOWLEDGEMENT
: be
etore me, the undergned, & i gra for jhe ead County on aay of.
ee ome Ansan and Stane, on te - 4.
10 me known io be the identical parton cee rns amc SO
cin ba sare os ED BD Be vse ct and ood or
gee and purposes teria eat forth,
‘Gwen under my hand ang al oe Gay and year lat above writen, 1
syenennen oases f= LE moan ease Lf
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IN THE DISTRICT COURT OF MCCURTAIN COUNTY, STATE OF OKLAHOMA MAMIE MILLIGAN, PLAINTIFF, Vs. No. ( V5 “LU -o7 CUTINA ADAMS, IN HER CAPACITY AS K’S OFFICE THE PERSONAL REPRESENTATIVE COURT CLERK’ OF THE ESTATE OF JAMAL CLAY. County of McCurtain, State of Oklahoma ? FILED DEFENDANT. bad 10 2021 KATHY GRAY, Court Clerk °y Deputy FIRST AMENDED PETITION Comes now Plaintiff and shows the Court: 1. A warranty deed purporting to bear the signature of Mamie Milligan was recorded 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 legal description omitted the section, range, and township, and is: All that part of Section 31, Township 7 South, Range 24 East: 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.6. 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, a JU /PRATT OBA # 16932 2108 SE Washington, Ste. B Idabel, OK 74745 (580) 366-4111 ATTORNEY FOR PLAINTIFF[001-557116 Book 0083 Py: 743 cansnoi7 1038 am Pp, 07430763 WARRANTY DEED "Fee. $1300 Doc: $225 (iedivdual Fare) WONOW ALL MEN BY THESE PRESENT . " ‘That il part___of the first part, in consideration of the sum of, Twelve Thandred dollars and other valuable isi Bons, ir 1, i lich is | de bargain, sell cova stages meth oO NW Ath we “Vine \5 0 & JaTh4S Ge pot eras and ota eras in commen, with ie ht of survivors, te whee sais We eal ees tots 8 oe Beg, Sow 0 Cor Lot 5 BIK % lene Pine Ackl TH ATO £lo5' STO" wios' TO BEG together with all the improvements thereon and the appurtenances theretinto belonging, and warrant the title 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, foraver, free; clear and discharged of and from all former grants, charges. taxes, judgments, morigages and other liens and incumbrances of what- soever nature. . i dt i Signed and deli mis aay of 1 Jaye 2~lT wt Woo, ' Ti ipa INDIVIDUAL ACKNOWLEDGEMENT : be etore me, the undergned, & i gra for jhe ead County on aay of. ee ome Ansan and Stane, on te - 4. 10 me known io be the identical parton cee rns amc SO cin ba sare os ED BD Be vse ct and ood or gee and purposes teria eat forth, ‘Gwen under my hand ang al oe Gay and year lat above writen, 1 syenennen oases f= LE moan ease Lf