(Title and Introduction.)

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

N. E. 513; Delano v. Saylor (Ky.), 113 S. W. 888; Lowe v. Maynard (Ky.) 115 S. W. 214; Wright v. Yates, 140 Ky. 283, 130 S. W. 1111; Elliott v. Walker, 145 Ky. 71, 140 S. W. 51; Groves v. Stouder (Okla.) 161 Pac. 239; Cleveland v. Bergen Bldg. & Imp. Co. (N. J. Eq.), 55 Atl. 117; Elterman v. Hyman, 192 N. Y. 113, 127 Am. St. Rep. 862, 15 Ann. Cas. 819, and note, 84 N. E. 739; Ihrke v. Continental Life Ins. & Investment Co., 91 Wash. 342 L. R. A. 1916 F. 430, 157 Pac. 866; Townsend v. Vanderwerker, 160 U. S. 171, 40 L. Ed. 383, 16 Sup. Ct.

258; Everett v. Mansfield, 148 Fed. 374, 8 Ann. Cas. 956, 78 C. C. A. 188, 137 Fed. 190; Gerstell v. Shirk, 210 Fed. 223, 127 C. C. A. 41; Howard v. Linnhaven Orchard Co., 228 Fed. 523; Williams v. Shuman, 141 Ga. 114, 80 S. E. 625; Young v. Walker, 224 Mass. 491, 113 N. E. 363.

13. Old Second National Bank v. Savings Bank, 115 Mich. 548. See Sec. 155 ante for full collection of authorities on this subject.

14. Gates on Real Property, Sec. 617.

(here insert date contract was entered into), and at this date plaintiff was and is the owner of that certain parcel or tract of land lying and being situate in the county of....................and state of...................., known and described as (here insert complete legal description of real estate).

2. That on the day and date aforesaid, plaintiff entered into a written contract with the said....................(here insert the name of defendant or defendants), for the sale and transfer of said described and to the said....................(here insert the name of defendant), which said agreement provided (here insert brief description of the terms of the agreement and especially the provisions which the defendant has violated), a true copy of such agreement being hereto attached and marked "Exhibit A" and made a part hereof.

3. That simultaneous with the execution of said contract the same was duly delivered to the parties thereto and said defendant thereupon paid to this plaintiff thereunder, as provided therein, the sum of....................dollars and possession of said premises was thereupon surrendered to the said defendant.

4. That in and by the terms of said contract there became due on the....................day of....................the sum of....................

dollars, as one of the installments of the principal of said contract, together with interest thereon from the....................day of

....................(here describe fully the payments which became due under the terms of the contract and upon which the vendee became in default, including taxes or any other arrearages under the contract), and that there is now due and wholly unpaid under and by viitue of the terms of said contract, the sum of....................dollars.

5. That it is provided by the terms of said contract that if the defendant made default in any of the payments which became due thereunder, all his rights under said contract would thereby cease and determine and be forfeited. That said defendant has defaulted in making the payments and in performing the conditions of said contract as hereinbefore set forth and that all his rights under said contract have ceased and determined.

6. That this plaintiff is ready and willing to carry out his part of said contract, but the defendant has failed, neglected and refused to pay the amount due thereon and has made default therein and that there is due, owing and payable to this plaintiff upon and by virtue of said contract, the sum of..............

......................dollars with interest from the........................day of

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

7. That no proceedings at law have been had for the recovery of the debt secured by said contract or any part thereof and that said debt has never been collected or paid.

WHEREFORE, Plaintiff prays, as follows:

(a) That an account may be taken under the direction of the Court of the amount due this plaintiff upon said contract for principal or interest or both, or for any taxes so secured by said contract and that the defendant may be decreed to pay to this plaintiff the amount due and payable to him, on taking such account together with the costs of this suit at a day to be appointed by this Court for that purpose and that in default of such payment, the defendants herein and all persons claiming under or through them or any of them may be forever barred or foreclosed of and from all right and equity of redemption and all claim and interest of, in and to the lands and tenements described in said contract.

(b) That in default of said payment that the said land and tenements may be sold under the direction of this Court and the money arising from such sale or so much thereof as may be necessary, be applied to satisfy and pay the charges of such sale and the amount so found due and payable to this plaintiff, with the said costs, and that the defendants herein and all persons claiming or to claim under them or any of them who may come into the possession of said lands or tenements or any of them since the filing of the notice of the pendency of this suit as provided by law, or after having received actual notice of such pendancy, be decreed to deliver and yield possession thereof to the purchaser or purchasers at said sale, upon his or their producing the deed or deeds therefore executed by the officer or person appointed by the Court to conduct such sale, together with a certified copy of the order of the Court confirming such sale, after the order has become absolute.

(c) That the said defendant....................may be decreed to pay to this plaintiff the balance of the debt due and payable to him remaining unsatisfied after such sale of said contract premises and that the plaintiff may have execution therefor and for his costs according to the rules and practices of this Court.

8. That plaintiff may have such other further and different relief as shall seem to the Court just and equitable in the premises.