Fill and Sign the Specific Performance 497295740

IN THE CIRCUIT COURT OF __________ COUNTY, ALABAMA _________________ * * Plaintif, * * VS. * CIVIL ACTION NO.: * _________________ * CV-_______________ * Defendant. * COMPLAINT FOR SPECIFIC PERFORMANCE COMES NOW the Plaintif and respectfully shows unto the Court as follows: 1. Plaintif and Defendant are both over the age of nineteen (19) years. Plaintif 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. Plaintif 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. Plaintif has ofered to perform his/her/its obligations under said contract. 5. Plaintif 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 specifc performance is the only complete remedy available to the Plaintif. WHEREFORE, the Plaintif prays the Court for the following relief: (a) a decree directing the specifc 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 Plaintif pursuant to the terms and provisions of said contract, upon payment by the Plaintif of the purchase price which Plaintif ofered to pay; and (c) an award to the Plaintif of Plaintif’s attorney’s fees and costs to be paid by Defendant; and (d) an award to the Plaintif of such other, further or diferent relief as may be just and proper. ADDITIONALLY, and in the alternative, in the event the Court denies specifc performance of the said contract, the Plaintif 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 Plaintif) OF COUNSEL: ________________________ PLAINTIFF DEMANDS A TRIAL BY JURY _____________________________________________ DEFENDANT MAY BE SERVED AS FOLLOWS ________________________________ ________________________________