Pro Se 9, Complaint to Require Performance of a Contract to Convey Real Property

The following involves a diversity of citizenship case: a citizen from one State (plaintiff) sues a citizen (defendant) of another State. In the following form, there is a statement of claim that describes the subject of the filed complaint: real property owned by the defendant. You can see the entire form to better understand the importance of completing and submitting this form.

Extracted Text for Proper Search

Pro Se 9 (Rev. 12/16) Complaint to Require Performance of a Contract to Convey Real Property	
U	NITED 	S	TATES 	D	ISTRICT 	C	OURT	
for the
__________ District of __________
__________ Division
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)Case No.	
(to be filled in by the Clerk’s Office)
Plaintiff(s)
(Write the full name of each plai ntiff who is filing this complaint.
If the names of all the plain tiffs cannot fit in the space above,
please write “see attached” in  the space and attach an additional
page with the full list of names.)	
-v-	
Defendant(s)
(Write the full name of each defe ndant who is being sued.  If the
names of all the defendants cannot fit in the space above, please
write “see attached” in the  space and attach an additional page
with the full list of names.)	
COMPLAINT TO REQUIRE PERFORMANCE 
OF A CONTRACT TO CONVEY REAL PROPERTY	
(28 U.S.C. § 1332; Diversity of Citizenship)
I. The Parties to This Complaint A. The Plaintiff(s)
Provide the information below for each plaintiff named in the complaint.  Attach additional pages if 
needed.Name
Street Address
City and County
State and Zip Code
Telephone Number
E-mail Address
B. The Defendant(s) Pro	
vide the information below 	for each defendan	t name
d 	in th	e complain	t, whether the d	efendant is an 
individual, a 	
govern	ment agency, an organization	, or 	a corporation.  	For an individual 	defendant, 
include the person's job or title (if known).  Attach additional pages if 	
needed.	
Page 1 of  7

Pro Se 9 (Rev. 12/16) Complaint to Require Performance of a Contract to Convey Real Property	
Defendant No. 1
Name
Job or Title 	
(if known)	
Street Address
City and County
State and Zip Code
Telephone Number
E-mail Address 	
(if known)	
Defendant No. 2
Name
Job or Title 	
(if known)	
Street Address
City and County
State and Zip Code
Telephone Number
E-mail Address 	
(if known)	
Defendant No. 3
Name
Job or Title 	
(if known)	
Street Address
City and County
State and Zip Code
Telephone Number
E-mail Address 	
(if known)	
Defendant No. 4
Name
Job or Title 	
(if known)	
Street Address
City and County
State and Zip Code
Telephone Number
E-mail Address 	
(if known)	
Page 2 of  7

Pro Se 9 (Rev. 12/16) Complaint to Require Performance of a Contract to Convey Real Property
II. Basis for JurisdictionFederal courts are courts of limited  jurisdiction (limited power).  Under  28 U.S.C. § 1332, federal courts may
hear cases in which a citizen of one State sues a citizen  of another State or nation and the am	
ount at stake is	
m	

ore than $75,000.  In that kind of case, called a diversity  of citizenship case, no defendant may	
 be a citizen of	
the sam	

e State as any plaintiff.  Explain how  these jurisdictional requirements have been met.
A. The Plaintiff(s) 1. If the plaintiff is an individual
The plaintiff,  	
(name)	, is a citizen of the
State of 	
(name)	.
2.	
If the plaintiff is a corporation
The plaintiff,  	(name)	, is incorporated
under the laws of the State of 	
(name	 )	, and
has its principal place of business in the State of 	
(name)	.
(If more than one plaintiff is named in the compla int, attach an additional page providing the same
information for each additional plaintiff.)
B. The Defendant(s) 1. If the defendant is an individual
The defendant,  	
(name)	, is a citizen of the
State of 	
(name) 	.  Or is a citizen of	 (foreign nation)	
.
2  If the defendant is a corporation The defendant,  	
(name)	, is incorporated under
the laws of the State of 	
(name)	, and has its principal
place of business in the State of	
 (name)	.
Or is incorporated under the laws of 	
(foreign nation	) ,
and has its principal place of business in 	
(name)	.
(If more than one defendant is named in the compla int, attach an additional page providing the same 
information for each additional defendant.)	
Page 3 of  7

Pro Se 9 (Rev. 12/16) Complaint to Require Performance of a Contract to Convey Real Property	
C. The Amount in ControversyThe amount in controversy–the amount the plaintiff cl aims the defendant owes or the amount at stake–is
more than $75,000, not counting interest and costs of court, because 	
(explain)	:   
III. Statement of Claim A. Describe the real property owned by the defendant(s) that is the subject of this complaint.  Include the address or location of the property.
B. Describe the terms of the contract you entered into  with the defendant(s) to purchase the real property at 
issue.  Attach the contract as an exhibit.
1. When did you enter into the contract with the defendant(s)?
2. What is the purchase price you agreed to pay?
3. Describe your obligations under the contract.  Include any terms regarding required deposits.
4. Describe the defendant(s)’ obligations u	
nder the contract, including the obligation to convey the
 
real p	
roperty 	at issue.	
Page 4 of  7

Pro Se 9 (Rev. 12/16) Complaint to Require Performance of a Contract to Convey Real Property	
C. Describe when and how you complied with, or attempted to comply with, all of your obligations under 
the contract, including payment of the purchase price.  If you have not complied with all of your 
obligations under the contract, explain how you are ready and able to comply with those obligations.
D. Describe when and how you requested that the defendant(s) convey the real property at issue and when  and how the defendant(s) refused to do so.  Attach copies of any correspondence with the defendant(s).
IV. Relief What is your requested form of relief?  	
(check all that apply)	
’ Specific performance of the contract.  	(Explain why specific performance is the only adequate remedy and why 
damages would not suffice.)  	
’ Damages sustained as 	a result of the defendan	t(s)’ refusal to comply with the contract.  (Describ	e 
the  damages 	
you are requesting.) 	
Page 5 of  7

Pro Se 9 (Rev. 12/16) Complaint to Require Performance of a Contract to Convey Real Property	
’If specific performance cannot be granted, damages in the amount of $ .	
(Describe the damages you are requesting.) 	 
’ Other relief.
V. Certification and Closing Under Federal Rule of Civil Procedure 11, by signing belo w, I certify to the best of my knowledge, information, 
and belief that this complaint: (1) is not being presen ted for an improper purpose, such as to harass, cause 
unnecessary delay, or needlessly increase the cost of litigation; (2) is supported by existing law or by a 
nonfrivolous argument for extending, modifying, or revers ing existing law; (3) the factual contentions have 
evidentiary support or, if specifically so identified,  will likely have evidentiary support after a reasonable 
opportunity for further investigation or discovery;  and (4) the complaint otherwise complies with the 
requirements of Rule 11.
A. For Parties Without an Attorney I agree to provide the Clerk	
’s Office with any chan	ges to my add	ress where case–related p	ap	ers may b	e 
served	
.  I understand that my failure to keep a current address on file with the Clerk’s Office may resu	lt 
in th	
e dismissal o	f my case.	
Date of signing:
Signature of Plaintiff
Printed Name of Plaintiff 
B. For Attorneys Date of signing:	
Page 6 of  7

Pro Se 9 (Rev. 12/16) Complaint to Require Performance of a Contract to Convey Real Property	
Signature of Attorney
Printed Name of Attorney
Bar Number
Name of Law Firm
Street Address
State and Zip Code
Telephone Number
E-mail Address	
Page 7 of  7