N.Y. Real Property Actions & Proceedings Law § 1515: Complaint

§ 1515. Complaint. 1. The complaint must state that the action is

brought pursuant to this article and must set forth facts showing:

a. The plaintiff's estate or interest in the real property, the

particular nature of such estate or interest, and the source from or

means by which the plaintiff's estate or interest immediately accrued to

him; and if his estate or interest therein is for a term of years, that

the balance remaining of such term of years is not less than five.

b. That the defendant claims, or that it appears from the public

records or from the allegations of the complaint, that the defendant

might claim an estate or interest in the real property, adverse to that

of the plaintiff, and the particular nature of such estate or interest.

Where the people of the state of New York are made a party defendant, as

provided in this article, the summons and complaint must be served upon

the attorney-general who must appear in behalf of the people, and the

complaint shall set forth detailed facts showing the particular nature

of the estate or interest and the reason for making the people a party

defendant. Upon failure to state such facts, the complaint shall be

dismissed as to the people of the state of New York.

c. Whether any defendant is known or unknown, and whether any

defendant is or might be an infant, have a developmental disability or

mental illness, or abuse alcohol.

d. Whether the judgment will or might affect a person or persons not

in being or ascertained at the commencement of the action, who by any

contingency contained in a devise or grant or otherwise, could afterward

become entitled to a beneficial estate or interest in the property

involved; and whether every person in being who would have been entitled

to such estate or interest if such event had happened immediately before

the commencement of the action is named as a party thereto.

2. The complaint must describe the property claimed with common

certainty, by setting forth the name of the township or tract and the

number of the lot, if there is any, or in some other appropriate manner,

so that from the description possession of the property claimed may be

delivered where the plaintiff is entitled thereto, and may contain an

allegation that no personal claim is made against any defendant other

than a defendant who shall assert a claim adverse to the claim of the

plaintiff set forth in the complaint. The demand for judgment may be to

the effect that the defendant and every person claiming under him be

barred from all claim to an estate or interest in the property described

in the complaint, or that possession be awarded the plaintiff, or it may

combine two or more of said demands with other demand for appropriate

relief.

3. In an action brought as specified in subdivision 3 of section 1501,

if the complaint admits the defendant's right of dower in the property

described therein, or in any part thereof, it must demand judgment that

her dower be admeasured.