(Address and Introduction.)

1. That on or about the....................day of.................... one

A. B. was the owner in fee simple of all that (here describe the land), and being such owner, the said A. B. made a verbal agreement with this plaintiff whereby the said A. B. agreed to sell and convey to this plaintiff all said land and premises in fee simple for the sum of....................dollars, to be paid as follows:

(Here state specifically the terms of payment), together with interest at the rate of....................per cent. per annum, payable annually, on the whole sum from time to time when paid, and to give to this plaintiff immediate possession thereof. Said agreement further provided that this plaintiff was to pay all the taxes and assessments that should thereafter be assessed on said land; and this plaintiff thereby agreed to purchase the said land, to pay for the same in the same manner aforesaid, and to comply in all respects to the terms and conditions to the foregoing verbal agreement, but no written agreement or memorandum was made or signed by the said A. B. or by this plaintiff.

2. And that in pursuance of the said agreement the said A.

B. then on or about the said day of....................19......, delivered possession of the said land and premises to this plaintiff, who then entered into possession and occupation thereof and of the whole thereof, and ever since that time this plaintiff has been and still is in such possession and occupation in accordance with, and relying upon the said agreement.

3. And that in accordance with the said agreement this plaintiff has paid to the said A. B., the said sum of...................dollars, parcel of said purchase money at the expiration of one year from said first mentioned day, and the said sum of....................

dollars, parcel of said purchase money at the expiration of two years therefrom, and also paid the interest as provided in and by the said verbal agreement, and the said A. B. accepted such payments so made as payments made in accordance with said agreement, and this plaintiff has also paid and satisfied all taxes and assessments that have been assessed on said land since the time of the making of the said agreement in accordance therewith, and has hitherto fully performed the said agreement on his part.

4. That during the time this plaintiff has been in possession of said land as aforesaid, and relying wholly upon said agreement, he has, at his own expense, built and erected thereon the following improvements (here state in detail the character of the improvements made), at an expense of....................dollars, and has treated, managed and used said land as his own property, all with the knowledge and consent and acquiescence of said defendant A. B.

5. That this plaintiff has fully performed his portion of said agreement, and has complied with the terms thereof, and on the

....................day of...................., plaintiff applied to the said A. B.

and offered then and there to pay him the sum of....................

dollars, being the remainder of the purchase money provided by said contract, together with all interest thereon, and then and there requested the said A. B. to receive and accept the same to convey the said land and premises to this plaintiff by a good and sufficient deed of conveyance, as in and by the said agreement he had agreed to do; and this plaintiff then also presented to the said A. B. the draft of a deed of conveyance in fee simple, and in the presence of a notary public, whose presence was procured by this plaintiff; this plaintiff then requested the said A. B. to accept the said money so offered as aforesaid and to execute the said deed and to acknowledge the execution thereof before the said notary, and this plaintiff well hopes that the said A. B. would have then received and accepted the said money so tendered and offered, and would have executed and acknowledged the said deed, as in justice and equity, he ought to have done, but so to do the said A. B. then utterly refused, and thenceforward has continually refused and still refuses, although he, the said A. B., still holds the title to the said land in his own name and is well able to convey the same as aforesaid.

6. That this plaintiff has always been ready and willing to sell his right and willing to perform this said agreement fully and specifically, and hereby tenders to the said A. B., defendant, all moneys, principal as well as interest, which may be found to be due and owing him on said agreement.

Wherefore, plaintiff prays:

1. The said A. B. may be decreed to specifically perform the said agreement and contract on his part.

2. That an account may be taken of the amount due and owing by this plaintiff to the said A. B. on said agreement for the purchase money aforesaid, with accrued interest thereon, and plaintiff hereby offers to pay to the said A. B. forthwith the full sum found to be owing thereon, and in case the said A. B. shall refuse to receive or accept the same, plaintiff prays leave to deposit said payment with the register of this court to be paid to the said A. B. as this court shall direct.

3. That upon the payment to the said A. B., or to the register of this court, this plaintiff be decreed to be the owner of said lands and premises, and of each and every part thereof, and that such decree may stand as a conveyance of said property, and that plaintiff shall have leave to cause such decree to be recorded in the office of the register of deeds of....................

County, as a conveyance to him of said land and premises.

4. That this plaintiff may have such further or such other or different relief, as shall be agreeable to equity and good conscience and the plaitniff will ever pray.

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Signature of Plaintiff

Attorney for Plaintiff.