(Address and introduction.)

1. That plaintiff is the owner in his own right and fee simple to the following described real estate, to-wit: (here insert complete legal description), and has been the owner of such real estate for....................years last past and that the value thereof is....................dollars.

2. That heretofore on or about the..................day of..................

while plaintiff was such owner as aforesaid, plaintiff made and executed a contract in writing with one John Doe for the sale of said land and premises, a true copy of said contract being as follows: (here insert copy of contract).

3. That thereafter on the....................day of....................the said John Doe caused the said contract to be recorded in the office of the register of deeds of said county of................in liber

....................of....................on page....................as in and by the record thereof now remaining in said register's office and whereto reference is prayed.

4. That thereafter on or about the................day of.................., the said John Doe having made default in the terms and conditions of said contract in writing and having failed to make the payments thereon as provided therein, this plaintiff in accordance with the terms and conditions of said contract elected

58. Compiled Laws 1915, Section 12378.

to declare the same void by reason of such default and thereafter resumed full possession of said land and the whole thereof and still is in possession thereof. That plaintiff thereafter applied to the said John Doe and requested him to execute a release in writing of the said agreement in order that the same might be cancelled, which request the said John Doe refused and still refuses.

5. That the record of said agreement constitutes a cloud on the title to said plaintiff of said land and premises and tends to depreciate the value thereof and to embarrass this plaintiff in effecting a sale thereof.

Wherefore plaintiff prays as follows:

(a) That said contract in writing may be decreed to be null and void and a cloud upon the title of this plaintiff to the said land.

(b) That the record of said agreement now remaining in the office of the register of deeds, aforesaid, be decreed to be discharged and to be null and void and of no effect.

(c) That plaintiff have leave to cause such decree to be recorded in the office of the said register of deeds for the county of.....................

(d) That plaintiff may have such other and further relief in the premises as shall be agreeable to equity and good conscience.

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

Attorney for Plaintiff.