COMPLAINT

Plaintiff, A. B., sues defendant, C. D., and alleges:

1. This is an action for specific performance of a contract to convey real property in …. County, Florida.

2. On …..(date)….., plaintiff and defendant entered into a written contract, a copy being attached.

3. Plaintiff tendered the purchase price to defendant and requested a conveyance of the real property described in the contract.

4. Defendant refused to accept the tender or to make the conveyance.

5. Plaintiff offers to pay the purchase price.

WHEREFORE plaintiff demands judgment that defendant be required to perform the contract for damages.