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1 _________________________________________________ 
COMPLAINT
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TIMOTHY L. MCCANDLESS, ESQ. SBN 147715LAW OFFICES OF TIMOTHY L. MCCANDLESS13240 Amargosa RoadVictorville, California 92392(760) 951-3663 Telephone(909) 382-9956 FacsimileAttorney for 
 Plaintiffs
«Client_FirstName» «Client_LastName» and Merly Mahinay
SUPERIOR COURT FOR THE STATE OF CALIFORNIAIN AND FOR COUNTY OF «File_Court»
«Client_LastName» «Client_FirstName»,Plaintiffs,V.«Def_First»«Def_Last»«Def_Last» andDOES 1 through 50 inclusiveDefendants.CASE NO: «File_CrtCaseNum»
COMPLAINT FOR:MONETARY DAMAGESSTATUTORY DAMAGES, PUNITIVEDAMAGES, INJUNCTIVE RELIEF ANDDECLARATORY RELIEF
1. VIOLATION OF CALIFORNIA CIVILCODE §2923.6;2. VIOLATION OF BUSINESS ANDPROFESSIONS CODE §17200;3. BREACH OF COVENANT OF GOODAND FAIR DEALING;4. INJUNCTIVE RELIEF;5. VIOLATION OF CIVIL CODE §1572;6. FRAUD;7. DECLARATORY RELIEF;8. INTENTIONAL MISREPRESENTATION;9. TO SET ASIDE FORECLOSURE10. VIOLATION OF CALIFORNIA CIVILCODES §2923.5 AND §2924.
Plaintiffs, «Client_LastName»«Client_FirstName», (Hereinafter referred as “Plaintiffs”) allegeherein as follows:
 
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COMPLAINT
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I.GENERAL ALLEGATIONS
1.
Plaintiffs, «Client_FirstName»«Client_LastName»at all times relevant have beenresidents of the County of «Client_City», State of California and the owners of RealProperty, including but not limited to the property at issue herein,
«Client_Address»
The Legal descriptions are as follows:Put in APN #Put in legal description.
2.
Defendant, INSERT LENDER. (hereinafter “INSERT LENDER”) at all times hereinmentioned was doing business in the County of San Bernardino, State of California andwas the original Lender for Plaintiff’s Trust Deed and Note.
3.
Mortgage Electronic Registration Systems Inc., (hereinafter “MERS”) at all timesherein mentioned was presumed to being doing business in the County of «Client_City», State of California and alleged to be the Beneficiary regardingPlaintiffs’ Real Property as described above and as Situated in «Client_City»CountyCalifornia
4.
Defendant, INSERT DEFENDANT - note that this is the def who is on default.(hereinafter “INSERT DEFENDANT”) at all times herein mentioned was doing business in the County of «Client_City», State of California and was listed on the Notice of Default for the above named Real Property.
 
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COMPLAINT
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5.
Defendant, INSERT DEFENDANT. (hereinafter “INSERT SHORT NAME OFDEFENDANT”) at all times herein mentioned was doing business in the County of San Bernardino, State of California and was listed on the Notice of Default for theabove named Real Property.
6.
Plaintiffs are ignorant of the true names and capacities of defendants sued herein asDOES 1 through 50, inclusive, and therefore sues these defendants by such fictitiousnames and all persons unknown claiming any legal or equitable right, title, estate, lien,or interest in the property described in the complaint adverse to plaintiff(s title, or anycloud on Plaintiffs title thereto. Plaintiff will amend this complaint to allege their truenames and capacities when ascertained.
7.
Plaintiffs are informed and believe and thereon allege that, at all times hereinmentioned each of the defendants sued herein was the agent and employee of each of the remaining defendants. Plaintiffs allege that each and every defendant alleged hereinratified the conduct of each and every other defendant. Plaintiffs further allege that atall times said defendants were was acting within the purpose and scope of such agencyand employment.
8.
Plaintiffs purchased the foregoing Real Property and on or about INSERT DATE OFDOTfinanced their purchase through INSERT ORIGINAL LENDERby virtue of aTrust Deed and Notes securing the Loans. (See Exhibit “A”)
9.
Plaintiffs are informed and believe that directly after INSERT ORIGINAL LENDER caused Mortgage Electronic Registration Systems (“MERS”) to go on title as the“Nominee Beneficiary” this is routinely done in order to hide the true identity of thesuccessive Beneficiaries when and as the loan was sold. MERS, however, acted as if 
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