What is the model indictment for real estate disputes?

Plaintiff: Chen * *, female, aged 25, living in. * * Road, * * District, * * City. Chen * *, male, 54 years old, lives in Beijing First People's Hospital. * * Road, * * District, * * City.

Miao * * *, female,1born on May 23rd, 955, with the same address as above.

Defendant: Lin * *, male, 48 years old, domicile. * * Road, * * District, * * City.

Litigation request:

1. Order the defendant to continue to perform the matters stipulated in the Shanghai Real Estate Sales Contract and the supplementary agreement signed by both parties, and transfer the disputed house to the plaintiff;

2. The defendant was ordered to bear the plaintiff's lawyer fee of 20,000 yuan;

3. The defendant was ordered to compensate the plaintiff for losses such as property management fee 1328.3 1 yuan and agency fee of 7550 yuan, totaling * * * 8878.438+0 yuan;

The defendant was sentenced to bear the legal costs of this case.

Facts and reasons:

The plaintiff and the defendant signed a Shanghai real estate purchase and sales contract (hereinafter referred to as "the contract") at Room 3, Lane 0/6, # Road, Baoshan District, this city on * * *, 20**, with the intermediary service of Shanghai * * Real Estate Consultant Co., Ltd. The plaintiff will be told to your hospital in early February, 2006, because the defendant is unwilling to perform the house delivery and transfer procedures agreed in the contract. The defendant promised to agree to hand over the house and handle the transfer formalities, and both parties reached a settlement agreement. Subsequently, the plaintiff withdrew the lawsuit and signed a supplementary agreement with the defendant. According to the supplementary agreement, the price of the disputed house was changed to 728,020 yuan; The original defendant and the defendant went through the transfer formalities in Baoshan District Real Estate Trading Center on September 2nd. The defendant paid all the house payment according to the contract and supplementary agreement, but despite repeated reminders from the plaintiff, the defendant refused to go through the transfer formalities for various reasons. During this period, the defendant still owes the house property management fee, water and electricity fee 128438+0 yuan, and the intermediary fee of 7,550 yuan that the defendant should pay is also paid in advance by the plaintiff.

The plaintiff believes that the buyers and sellers of real estate should be honest and trustworthy, and the settlement agreement and supplementary agreement are also expressions of the true meaning of both parties and should be performed according to the contract. The defendant's breach of contract has brought huge losses to the plaintiff, and the plaintiff has to file a lawsuit to safeguard his legitimate rights and interests, so please make a judgment as required.

I am here to convey

* * * District People's Court

Shaping people:

Agent: * * * *

Date: * * year * * month * *