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 number.) Defendants ) 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