Alabama

Civil Procedure

Form 2 – Complaint on a promissory note

1. Defendant on or about ______, 19__, executed and delivered to Plaintiff a promissory note [in the following words and figures: (here set out the note verbatim)]; [a copy of which is hereto annexed as Exhibit A]; [whereby Defendant promised to pay to Plaintiff or order on _____, 19__. the sum of ________________ dollars with interest thereon at the rate of _____ percent per annum] [and agreed to pay a reasonable attorney’s fee for collection and waived exemptions from execution].

2. Defendant owes to Plaintiff [the amount of said note] [$ _____ that is due on said note] and interest.

Wherefore Plaintiff demands judgment against Defendant for the sum of ____ dollars, interest, attorney’s fee, and costs.

[Signed]:_____________

Attorney for Plaintiff

Address: ___________________

Committee Comments

In paragraph 1, the pleader may use the material in one of the three sets of brackets. His choice will depend upon whether he desires to plead the document verbatim, or by exhibit, or in general terms.

In paragraph 2, the pleader may use the material in either set of brackets. His choice will depend upon whether part of the note has already been paid.