STATE OF MICHIGAN

In the Circuit Court for the County of....................

In Chancery

John Doe, Plaintiff, vs.

Richard Roe, Defendant,

To the Circuit Court for the County of....................

John Doe, of the City of...................., County of...................., and State of Michigan, plaintiff herein, complains of Richard Roe, defendant herein and respectfully shows unto this Honorable Court:

I. That he now is and for a long time prior hereto, has been the owner in his own right, in fee simple of all that certain piece or parcel of land situated in the City of....................

in said county ...................., and State of Michigan, described as follows: (here insert description as in the contract), of the value of .................... dollars, and as such owner did on the

....................day of...................., 19...., enter into an agreement to sell the same to Richard Roe, the defendant herein, for the sum of....................dollars, to be paid as follows:.........................

And the said defendant did covenant and agree to pay said sum above mentioned, and to pay said sums with interest thereon at the time set forth in said contract, a true copy of which is hereto attached, marked "Exhibit A" and made a part of this bill of complaint, and also agreed to pay and satisfy all taxes and assessments of every nature that should by any lawful authority be levied or assessed upon said land, until the whole of said purchase money, as well as interest and principal should be fully paid.

II. That in consideration of the premises the plaintiff, did in said land contract, covenant and agree that upon the full payment of the said purchase money in the manner aforesaid, and upon the full performance by the said defendant of the said covenants and agreement on his part to be kept and performed, this plaintiff, would by a good and sufficient deed of conveyance, grant and convey the said above described land belonging to the said plaintiff, to the said defendant, his heirs, and assigns, forever, in fee simple.

III. That by the terms of said land contract, the defendant might take possession of said premises and continue in the actual occupation thereof so long as he should perform his part of the covenants and agreements in said contract contained, and that if the said defendant should fail to perform his part of the covenants and agreements, or any part thereof, then this plaintiff might and should have the right to declare the said contract null and void and to retain all sums of money that might have been paid on said premises and might and should have the right to take immediate possession of the said premises.

IV. That the said defendant has made default in the performance of his part of the covenants and agreements in the said land contract, and has not paid to this plaintiff the installment of the purchase money which fell due on the....................

day of................, A. D. 19.... (state breaches in full), although the time for the payment of such installment has long since elapsed and that there is now due and unpaid to this plaintiff on said contract for principal and interest, the sum of...............

dollars.

V. That the said defendant has also made default in the payment of taxes lawfully levied on said premises and has failed to pay the taxes for the year 19......, although the time limit by law for the payment thereof has long since elapsed and this plaintiff, for his own protection, has been compelled to pay and has paid such taxes amounting to the sum of

....................dollars, on or about the....................day of...................

19......; and that the said defendant is equitably indebted to this plaintiff in said sum with interest from said last mentioned date.

VI. That on the....................day of....................A. D. 19......, plaintiff duly served on the defendant a notice of forfeiture, declaring said contract duly and legally forfeited and the contractual relations between the plaintiff and defendant duly terminated and severed; that on the................day of................

A. D. 19......, plaintiff duly made a demand on the defendant for the surrender to the plaintiff of possession of said premises; that thereupon said defendant forthwith surrendered to the plaintiff possession of said premises and that plaintiff has been in possession of said premises ever since, and that the forfeiture of said contract is legal and complete. Wherefore plaintiff prays as follows:

1. That a decree may be entered in this cause, decreeing that said contract heretofore existing between the plaintiff and defendant covering the above described real estate has been legally forfeited and terminated by this plaintiff and that the plaintiff is the sole owner of said property, free from any and all claims of the defendant growing out of said contract.

2. That this plaintiff may have such further, other or different relief as shall be agreeable to equity and good conscience.

And this plaintiff will ever pray, etc.

...............................................................

Plaintiff.

Attorney for Paintiff.