Draft Fraudulent Property Complaint

I need a cleanly drafted civil complaint that I can file in Idaho state court (with the option to remove to federal court if strategy warrants). The action targets a residential real-estate transaction in which the lender proceeded even after knowing the chain of title was built on false records.

Scope of the pleading
• Plead for declaratory judgment that the fraudulent deeds, mortgages, and liens are void.
• Include quiet-title counts so the current purchasers obtain clear, marketable title.
• Add a well-supported claim for compensatory damages arising from the clouded title and related costs.

Legal framework
The facts touch both federal veterans-housing protections and Idaho property law, so the complaint must cite controlling Idaho statutes, relevant federal regulations, and any on-point veterans’ benefit provisions.

Facts & evidence at your disposal
I can supply internal communication evidence from the lender, witness statements, and official county-record documents establishing the falsity of the instruments. Draft the statement of facts so these materials are referenced logically and satisfy Rule 8 pleading standards while anticipating heightened fraud-pleading requirements.

What I expect
1. Captioned complaint formatted for Idaho district court.
2. Separate sections: jurisdiction/venue, parties, factual background, causes of action, prayer for relief.
3. Precise citations, numbered paragraphs, and a verification page.
4. A brief cover memo explaining any strategic choices or alternative theories you see.

If you have Idaho or federal real-estate litigation experience—especially with veteran-related loans—please mention it along with a timeline for the first draft.