§ 9-11-112. Form of complaint for specific performance of contract to convey land

§ 9-11-112. Form of complaint for specific performance of contract to convey land

 

IN THE _____ COURT OF _____ COUNTY

 

 

 

STATE OF GEORGIA

 

 

 

A.B.,

)

 

 

 

)

 

 

Plaintiff

)

 

 

 

)

 

 

 

)

 

 

v.

)

Civil action

 

 

)

File no. _____

 

C.D.,

)

(Clerk will insert

 

Defendant

)

number.)

 

--COMPLAINT--

 

The defendant C.D., herein named, is a resident of _____ (street), _____ (city), _____ County, Georgia, and is subject to the jurisdiction of this court.

 

--1.--

 

On or about December 1, 1966, plaintiff and defendant entered into an agreement in writing, a copy of which is hereto annexed as Exhibit A.

 

--2.--

 

In accordance with said agreement, plaintiff tendered to defendant the purchase price and requested a conveyance of the land, but defendant refused to accept the tender and refused to make the conveyance.

 

--3.--

 

Plaintiff now offers to pay the purchase price.

 

Wherefore, plaintiff demands:

 

(1) That defendant be required specifically to perform said agreement,

 

(2) Damages in the sum of $1,000.00, and

 

(3) That, if specific performance is not granted, plaintiff have judgment against defendant in the sum of $10,000.00.

 

 

______________________________________

 

 

Attorney for plaintiff

 

 

______________________________________

 

 

Address