9-11-112. Form of complaint for specific performance of contract to convey land.

IN THE COURT OF COUNTY

STATE OF GEORGIA

A.B., )

Plaintiff )

)

v. ) Civil action

) File no.

C.D., ) (Clerk will insert

Defendant ) number.)

COMPLAINT

The defendant C.D., herein named, is a resident of (street), (city), County, Georgia, and is subject to the jurisdiction of this court.

1.

On or about December 1, 1966, plaintiff and defendant entered into an agreement in writing, a copy of which is hereto annexed as Exhibit A.

2.

In accordance with said agreement, plaintiff tendered to defendant the purchase price and requested a conveyance of the land, but defendant refused to accept the tender and refused to make the conveyance.

3.

Plaintiff now offers to pay the purchase price.

Wherefore, plaintiff demands:

That defendant be required specifically to perform said agreement,#

Damages in the sum of $1,000.00, and#

That, if specific performance is not granted, plaintiff have judgment against defendant in the sum of $10,000.00.#

1. Attorney for plaintiff Address