The following is a form of a bill of complaint to quiet the title to real estate where the vendor has forfeited a land contract and repossessed himself of the premises, the cloud on the title consisting of a quit-claim deed by the vendor of the land contract to some third party.

State of Michigan, in the Circuit Court for the County of

...................., in Chancery; to the Circuit Court for the County of...................., in Chancery:

The plaintiff, herein, John Doe, of the City of Detroit, county of...................., and State of Michigan, complains of the defendant herein (here join as defendants original vendee, his vendee, and their spouses), and respectfully shows unto this Honorable Court as follows:

1. That this plaintiff is the owner of (here state either legal or equitable title, as the case may be) in and to the following described real estate to-wit: (here insert complete legal description of the real estate), and further that neither of the above mentioned defendants are in possession of said premises or any part thereof.

2. That on the....................day of...................., A. D. 19......the said defendants entered into a contract with the plaintiff whereby the plaintiff contracted to sell, and the said defendants contracted to buy the above described real estate for a certain valuable consideration therein named, a true copy of such contract being hereto attached, marked Exhibit "A," and made a part thereof, reference to which is hereby prayed.

3. That by the terms and conditions of said contract the said defendants had agreed to pay monthly installments thereon amounting to $....................; that said contract contained a clause providing that in the event the said defendants failed, neglected, or refused to comply with the terms of such contract, that this plaintiff and the vendor thereof might declare such contract forfeited, retain all payments made thereunder as liquidated damages and repossess himself of the premises.

4. That on the....................day of...................., A. D. 19......, certain payment had become due on the said contract which the defendants had wholly failed, neglected, and refused to pay, although repeatedly demanded from them by this plaintiff, such payments in the aggregate amounting to $.................... (here state details of the indebtedness accrued on the contract, that although this plaintiff often requested defendants to keep up their payments and covenants in said contract, they utterly failed and neglected so to do; that on the....................day of

....................A. D. 19......, this plaintiff served upon them a formal notice declaring said contract forfeited; that said notice was duly followed by summary proceedings begun by this plaintiff before (here state officer before whom summary proceedings were begun), and that said proceedings terminated in a judgment duly rendered by said commissioner that plaintiff have judgment of restitution of said premises on the..................

day of...................., A. D. 19......, all of which reference to the files and records of said commissioner's court, file No................., is hereby prayed, which said writs were on the....................day of....................A. D. 19......, recorded with the register of deeds of..................county, Michigan, in liber................, page................, reference to which is hereby prayed.

5. That after the plaintiff had repossessed himself of the said premises as hereinbefore set forth, to-wit, on the................

day of...................., A. D. 19......, said defendants, for the pur pose of embarrassing this plaintiff and casting a cloud on the title to said real estate, executed a quit claim deed to (here state vendee of the vendee), for the above described premises, which deed has been recorded in liber....................in the office of the register of deeds of....................county.

6. That said quit-claim deed thus executed by the defendants constitutes a cloud upon the title of this plaintiff to said lots.

7. That plaintiff is wholly without adequate remedy except in a Court of Equity.

Wherefore plaintiff prays:

(a) That said quit-claim deed above described may be decreed to be null and void and of no effect whatsoever as against the title of this plaintiff and that the same be delivered up to be cancelled.

(b) That the said defendants (here name them), be decreed to have no right, title, or interest in and to the above described real estate, either by virtue of said land contract or said quitclaim deed.

(c) That the plaintiff may have permission to record the decree which may be entered in said cause, and that such decree, when recorded, shall stand in effect as a cancellation of said deed, and as a bar against any of said defendants asserting title in and to said real estate.

(d) That plaintiff may have such other, further, and different relief as shall be agreeable to equity.

...........................................................

Attorney for Plaintiff.

State of Michigan, County of......................

ss.

John Doe, being first duly sworn, deposes and says that he has read the foregoing bill of complaint by him subscribed and knows the contents thereof and that the same is true of his own knowledge except as to the matters therein alleged to be on information and belief, and as to those matters, he believes it to be true.

....................................................................

Subscribed and sworn to before me this....................day of

...................., A. D. 19.......

Notary Public, Wayne County, Michigan. My commission expires.................................................................