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