(Address.) (Introduction.)

I. That the plaintiff, A. B., is the owner in fee simple in his own right of the following described real estate, to-wit: (Here described premises) did on the......................day of....................

enter into an agreement in writing with one C. D., whereby the said C. D. agreed to purchase said real estate and wherein the plaintiff agreed to sell and said C. D. agreed to buy such real estate according to the terms and conditions of such agreement, a true copy of which is hereto attached marked "Exhibit A" and made a part hereof.

II. That said C. D. paid to plaintiff the sum of....................

dollars, part of said purchase money at the time of the execution of said agreement and plaintiff delivered an abstract of his title to the said premises to the said C. D. and has always been ready and willing to perform his part of said agreement and has repeatedly communicated such fact to the said C. D. and on being paid the remainder of his said purchase money with interest, to convey said premises to the said C. D., his heirs and to let him into possession of said real estate.

III. That notwithstanding that plaintiff has always been ready and willing to perform said agreement and has furnished the said C. D. with an abstract of title showing a marketable title in plaintiff, the said defendant has wholly failed, neglected and refused to carry out his part of agreement.

IV. That plaintiff hereby offers to specifically perform said agreement on his part on being paid the said purchase money and interest and to execute a proper conveyance of said described premises to the said C. D. and to let him into possession of the same according to the tender and effect of said agreement.

V. That the value of the subject matter of this litigation is in excess of $100.00 and that this plaintiff is without remedy in the premises except in a court of equity.

WHEREFORE plaintiff prays:

1. That the said C. D., defendant, may be compelled by a decree of this Honorable Court specifically to perform said agreement with plaintiff and to pay the plaintiff the remainder of said purchase money with interest on the same from the time said purchase money ought to have been paid.

2. That plaintiff shall have such other and further relief as equity may require.

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