The following brief form has been adopted by the State Bar Association, and has been deemed suitable and sufficient.

STATE OF MICHIGAN In the Circuit Court for the County of............................

John Doe, Plaintiff, vs.

Richard Roe, Defendant.

To the Circuit Court for the County of................................

John Doe, the plaintiff in this suit, by............................, his attorney, complains of Richard Roe, defendant herein, the said Richard Roe having been duly summoned to answer the said John Doe, of a plea of trespass on the case, and says:

138. Mich. Com. Laws 1915, Sec. 12,404; Judicature Act Mich., Chap. 13. Sec. 1.

139. Mich. Cir. Ct. Rule, Sec. 6

1. That on....................day of................................, 19........, the defendant offered to sell him a certain farm then owned by the defendant, described as.................................

2. That to induce the plaintiff to purchase said farm the defendant represented to the plaintiff that the said farm was thoroughly tile drained throughout.

3. That the plaintiff was thereby induced to purchase said farm for $...................., which was then and there paid to the defendant, relying on the truth of the said representations.

4. That the said representations were not true; and a large part of said farm was entirely without tile drain.

5. That the defendant made the said representations fraudulently, knowing them to be false and for the purpose of inducing the plaintiff to purchase the said farm.

6. In the alternative, that the defendant, in consideration of the purchase of the said farm by the plaintiff, warranted that the said land was thoroughly tile drained throughout.

7. That the said farm was not as warranted, but a large part of it was wholly without any tile drains.

8. Wherefore the plaintiff claims a judgment for the sum of............................dollars.

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