1. On or about December 1, 1936, plaintiff and defendant entered into an agreement in writing, a copy of which is hereto annexed as Exhibit A. 2. In accord with the provisions of said agreement plaintiff tendered to defendant the purchase price and requested a conveyance of the land, but defendant refused to accept the tender and refused to make the conveyance. 3. Plaintiff now offers to pay the purchase price. Wherefore plaintiff demands (1) that defendant be required specifically to perform said agreement, (2) damages in the sum of one thousand dollars, and (3) that if specific performance is not granted plaintiff have judgment against defendant in the sum of ten thousand dollars. NOTE—Here, as in Form 3, plaintiff may set forth the contract verbatim in the complaint or plead it, as indicated, by exhibit, or plead it according to its legal effect. Furthermore, plaintiff may seek legal or equitable relief or both. Form 13. Complaint on Claim for Debt and to Set Aside Fraudulent Conveyance Under Rule 18(b) A. B., Plaintiff } v. } Complaint C. D. and E. F., Defendants } 1. Defendant C. D. on or about __________ executed and delivered to plaintiff a promissory note [in the following words and figures: (here set out the note verbatim)]; [a copy of which is hereto annexed as Exhibit A]; [whereby defendant C. D. promised to pay to plaintiff or order on __________ the sum of five thousand dollars with interest thereon at the rate of __________ percent per annum]. 2. Defendant C. D. owes to plaintiff the amount of said note and interest. 3. Defendant C. D. on or about __________ conveyed all his property, real and personal [or specify and describe] to defendant E. F. for the purpose of defrauding plaintiff and hindering and delaying the collection of the indebtedness evidenced by the note above referred to. Wherefore plaintiff demands: (1) That plaintiff have judgment against defendant C. D. for ten thousand dollars and interest; (2) that the aforesaid conveyance to defendant E. F. be declared void and the judgment herein be declared a lien on said property; (3) that plaintiff have judgment against the defendants for costs. Form 14. Complaint for Negligence Under Federal Employers’ Liability Act 1. Allegation of jurisdiction. 2. During all the times herein mentioned defendant owned and operated in interstate commerce a railroad which passed through a tunnel located at __________ and known as Tunnel No. __________. 3. On or about June 1, 1936, defendant was repairing and enlarging the tunnel in order to protect interstate trains and passengers and freight from injury and in order to make the tunnel more conveniently usable for interstate commerce. 4. In the course of thus repairing and enlarging the tunnel on said day defendant employed plaintiff as one of its workmen, and negligently put plaintiff to work in a portion of the tunnel which defendant had left unprotected and unsupported. 5. By reason of defendant’s negligence in thus putting plaintiff to work in that portion of the tunnel, plaintiff was, while so working pursuant to defendant’s orders, struck and crushed by a rock, which fell from the unsupported portion of the tunnel, and was (here describe plaintiff’s injuries). 6. Prior to these injuries, plaintiff was a strong, able-bodied man, capable of earning and actually earning __________ dollars per day. By these injuries he has been made incapable of any gainful activity, has suffered great physical and mental pain, and has incurred expense in the amount of __________ dollars for medicine, medical attendance, and hospitalization. Wherefore plaintiff demands judgment against defendant in the sum of __________ dollars and costs. Form 15. Reserved Form 16. Reserved

Vegas Law