A BILL IN EQUITY FOR SUBROGATION AND SUBSTITUTION

To the Honorable Judges of the [Court Name]:

In the Matter of

[Complainant Name], Plaintiff,

v.
[ALL CAPS NAME Name], Defendant.
[JUDGE Name], Defendant.
[ATTORNEY Name], Defendant
[CLERK Name], Defendant
[CEO Name], Defendant
[CFO Name], Defendant

The Complaint of [Plaintiff's Name], respectfully shows:

I. Parties and Jurisdiction

1. The Complainant, [Complainant 's Full Name], is an individual residing at
[Plaintiff's Address] in the County of [Complainant 's County], State of [Plaintiff's State].

2. The defendant, [ALL CAP NAME Full Name], is an individual residing at

[Defendant's Address] in the County of [Defendant's County], State of [Defendant's
State].

3. The defendant, [JUDGE Full Name], is an individual residing at [Defendant's

Address] in the County of [Defendant's County], State of [Defendant's State].

4. The defendant, [ATTORNEY Full Name], is an individual residing at [Defendant's

Address] in the County of [Defendant's County], State of [Defendant's State].

5. The defendant, [CLERK Full Name], is an individual residing at [Defendant's

Address] in the County of [Defendant's County], State of [Defendant's State].

6. This Court has jurisdiction over this matter pursuant to [Cite the relevant statute,
rule or constitutional provision].

II. Facts
4. On or about [Date of Loan Agreement], the Complainant tendered special deposit
money order the sum of [consideration description] to the defendant, which was
evidenced by delivery. A true and correct copy of the Loan Agreement, special deposit
receipts (USPS form 3811, 3817) is attached hereto as Exhibit "A,B,C."

5. Pursuant to the Loan Agreement, the defendant (ALL CAP NAME) agreed to repay
the loan in full by [Repayment Date], with interest at the rate of [Interest Rate] per
annum.

6. The defendant (ALL CAP NAME) has defaulted on the Loan Agreement by failing
to make the required payments, despite the plaintiff's repeated demands.

III. Subrogation and Substitution

8. The Complainant is entitled to subrogation, which allows the plaintiff to step into
the shoes of the original creditor and exercise all rights and remedies that the original
creditor had against the defendant.

9. The Complainant is also entitled to substitution, which allows the plaintiff to be

substituted as the rightful party in interest in place of the original creditor and to seek
all remedies available under the Loan Agreement and applicable law.

10. A surety's right to be subrogated to the securities held by the creditor, upon
paying the latter's claim, is a right that becomes an inchoate right as soon as the surety
assumes the relation of suretyship, and when he pays the creditor, his right to be
subrogated to any securities or remedies held by the latter relates back to the time
when he entered into the contract of suretyship, and his right to be reimbursed from
the fund or other security to which he has become subrogated is an equity that is
antecedent and superior to any claim thereto that may be made by the holder of an
equitable assignment thereof taking with notice of the surety's antecedent equity.

11. The Complainant has no adequate remedy at law, and this action is necessary to
protect the Complainant’s rights and interests in the loan and to obtain complete and
adequate relief.

IV. Prayer for Relief

WHEREFORE, the Complainant respectfully requests that this Court:

A. Adjudge and declare that the plaintiff is entitled to subrogation and substitution
in the place and stead of the original creditor;
 B. Order the defendant (creditors- CFO,CEO,CLERK etc to pay to the Complainant
the principal balance of the loan (or order full accounting including credit
enhancements, together with accrued interest and any applicable fees.

C. Grant such other and further relief as this Court may deem just and proper.

Respectfully submitted,

[Plaintiff's Name], Plaintiff

[Plaintiff's Address]
[Plaintiff's City, State, Zip Code]
[Plaintiff's Telephone Number]
[Plaintiff's Email Address]
Dated: ______________________
VERIFICATION
I, [Plaintiff's Name], declare under penalty of perjury that the foregoing is true and
correct to the best of my knowledge, information, and belief.
Executed on this _____ day of ________, 20.

[Plaintiff's Name]
STATE OF [Plaintiff's State]
COUNTY OF [Plaintiff's County]
Subscribed and sworn to before me this _____ day of ________, 20.

Notary Public
My Commission Expires: ____________