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Fill and Sign the Sample Civil Form 4 in the Court of County Ab

Fill and Sign the Sample Civil Form 4 in the Court of County Ab

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IN THE CIRCUIT COURT OF __________ COUNTY, ALABAMA _________________ * * Plaintiff,* * VS.*CIVIL ACTION NO.: * _________________ *CV-_______________ * Defendant. * COMPLAINT FOR SPECIFIC PERFORMANCE COMES NOW the Plaintiff and respectfully shows unto the Court as follows:1.Plaintiff and Defendant are both over the age of nineteen (19) years. Plaintiff is a resident citizen of _________________________________, and Defendant is a resident citizen of _____________________________________.2.On or about the ____ day of _________, ________, the parties entered into a contract, a copy of which is attached hereto as Exhibit A, for the sale and purchase of certain personal property as follows: [describe the property].3.Plaintiff is now, and has been at all times relevant to this cause, ready, willing, and able to carry out and perform the terms, provisions, and obligations of said contract. 4.Plaintiff has offered to perform his/her/its obligations under said contract.5. Plaintiff has demanded that Defendant perform his/her/its obligations under said contract, but Defendant has failed and/or refused to do so.6. The said personal property which is the subject of said contract is of such a unique nature or character that damages would be an inadequate remedy and that specific performance is the only complete remedy available to the Plaintiff.WHEREFORE, the Plaintiff prays the Court for the following relief:(a) a decree directing the specific performance of the said contract by the Defendant; (b)a decree directing the Defendant to execute a bill of sale conveying the said personal property to Plaintiff pursuant to the terms and provisions of said contract, upon payment by the Plaintiff of the purchase price which Plaintiff offered to pay; and (c) an award to the Plaintiff of Plaintiff’s attorney’s fees and costs to be paid by Defendant; and (d)an award to the Plaintiff of such other, further or different relief as may be just and proper.ADDITIONALLY, and in the alternative, in the event the Court denies specific performance of the said contract, the Plaintiff demands judgment against the Defendant in excess of the jurisdictional limits of this court, compensatory damages flowing from the breach of said contract, plus interest, and costs. _________________________________________(Attorney for Plaintiff) OF COUNSEL:________________________ PLAINTIFF DEMANDS A TRIAL BY JURY _____________________________________________ DEFENDANT MAY BE SERVEDAS FOLLOWS________________________________________________________________

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