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Star & Alans Corrected 1st Amended Complaint Law Suit

Star & Alans Corrected 1st Amended Complaint Law Suit

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Published by: earthica on Nov 09, 2011
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01/16/2012

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Alan Gjurovich; Star: Hills,temporary mailing location:CARE OF : [ PO BOX 71537, Bakersfield, California 93387][non domestic without the U.S.]SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF KERNCASE#: S-1500-CV-271292-SPC1
st
AMENDEDAlan Gjurovich; Star: Hills, VERIFIED COMPLAINT FOR ENFORCEMENTOF RESCISSION OF ALLEGED MORTGAGEPlaintiffs, CONTRACT; FRAUD; CONSTRUCTIVE FRAUDDECEIT; CIVIL DAMAGES FOR CRIMINAL-VS- TORTS OF FRAUD FORGERY; PERJURY;FALSIFYING DOCUMENTS TRESPASSING;MERS; MERS PRESIDENT TERRORIST THREATS;BREACH OF FIDUCIARY& CEO BILL BECKMANN; INVOLUNTARY TRUST;BREACH OF TRUST;GMAC MORTGAGE LLC; GMAC WRONGFUL CONVERSION OF REALMORTGAGE LLC PRESIDENT PROPERTY; EQUITABLE, DECLARATORY &NICK CANALE Jr.; GMAC INJUNCTIVE RELIEF; QUIET TITLE; ABUSEMORTGAGE LLC VICE OF PROCESS; GENERAL NEGLIGENCE;PRESIDENT & LOAN SERVICER, INTENTIONAL NEGLIGENCE, ETC.,Charles R. Hoecker;GMAC OF Alan Gjurovich & Star: Hills.MORTGAGE, LLC; ETSSERVICES LLC PRESIDENTJOHN DOE 2, ETS SERVICES LLC;ETS SERVICES LLC SALESTRUSTEE Omar Solorzano; ETSSERVICES LLC MANAGERSJOSEPH A. PENSABENA; MARK E.LAHIFF; Adam Leppo ETSSERVICES LLC TRUSTEE SALEOFFICER; John Does 3-99,Defendants. _________________________________ 
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COMES NOW Alan Gjurovich & Star: Hills (hereafter Alan & Star) WITH THEIR VERIFIED CIVIL COMPLAINT FOR ENFORCEMENT OF RESCISSION OFALLEGED MORTGAGE CONTRACT; QUIET TITLE; EQUITABLE, INJUNCTIVE, &DECLARATORY RELIEF; FRAUD; PROMISSORY FRAUD; FRAUDULENTINDUCEMENT; CONSTRUCTIVE FRAUD, DECEIT; NEGLIGENCE, CIVIL DAMAGESFOR CRIMINAL TORTS OF FRAUD, FORGERY, PERJURY, FALSIFYINGDOCUMENTS, TRESPASSING, TERRORIST THREATS, BREACH OF TRUST;BREACH OF FIDUCIARY; WRONGFUL CONVERSION OF REAL PROPERTY;INVOLUNTARY TRUST, BREACH OF TRUST, GENERAL NEGLIGENCE &INTENTIONAL NEGLIGENCE, ETC., AS FOLLOWS:
FACTS & ALLEGATIONS
PARTIES & RELATIONSHIPS1. Alan Gjurovich (hereafter Alan) is a sovereign man of God living on the land in the De-Jure Country called California Republic, WHO OBTAINED A FIFTY (50 %)PERCENT OWNERSHIP INTEREST IN THE “REAL PROPERTY”COMMONLY REFERRED TO AS BEING LOCATED AT [3018 LINDENAVENUE, BAKERSFIELD CALIFORNIA] ”
ON OCTOBER 5, 2009 BY WAY 
 OF A QUIT CLAIM DEED EXECUTED BY THE OWNER OF THE SAIDPROPERTY Star:Hills,THE LEGAL DESCRIPTION OF THE SAID PROPERTY IS:ONE HALF OF Lot 17 in Block 26 of Skyline Park Subdivision No. 2according to the map thereof filed on August 13, 1923, and recorded in Book 3,pages 88 to 93, inclusive, of Maps, in the Office of the County Recorder of saidCounty. APN: 123-330-06.” COMMONLY REFERRED TO AS [ “3018 LINDENAVENUE, BAKERSFIELD, CALIFORNIA”] .& ASSUMED ONE HALF OF THE ALLEGED LIEN ON THE PROPERTY
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CLAIMED BY DEFENDANT GMAC MORTGAGE LLC VIA ALLEGEDMORTGAGE RE FINANCE LOAN #: 40824789, WHICH IS RECORDED INTHE KERN COUNTY RECORDERS OFFICE, & THUS IS AN INTERESTEDPARTY TO SAID ALLEGED LOAN, WHOSE RIGHTS IN SAID PROPERTYARE PRESENTLY DETRIMENTALLY AFFECTED BY SAID ALLEGEDLYCLAIMED LIEN. SEE: CERTIFIED COPY OF ALLEGED QUIT CLAIM DEEDRECORDED IN KERN COUNTY RECORDERS OFFICE, DOCUMENT NUMBER #: 0209147487, ATTACHED TO THE PRIOR COMPLAINT AS AN EXHIBIT &IS HEREBY INCORPORATED INTO THIS COMPLAINT BY REFERENCE ASIF FULLY SET FORTH & IS HEREBY MADE A PART OF THIS COMPLAINTAlan Gjurovich IS SUING TO QUIET TITLE ON THE FOR MENTIONEDPROPERTY FOR A COURT DETERMINATION THAT HE IS THE LAWFULOWNER OF HALF RIGHTS & INTERESTS TO THE SAID PROPERTYPURSUANT TO THE SAID QUIT CLAIM DEED EXECUTED BY Star: Hills INOctober of 2009 as set forth herein, a copy of said quit claim deed is attached tothe prior complaint as exhibit which is hereby incorporated into this complaint as if fully set forth and is made a part of this complaint, which Mandatory JudicialNotice is hereby Requested of the Court pursuant to the express provisions of California Evidence Code Section 451-453 Et Sequiter, AGAINST THE ADVERSECLAIMS OF DEFENDANT GMAC MORTGAGE LLC, TO LEGAL TITLE BYWAY OF PURCHASE AT AN ALLEGED PUBLIC SALE OF THE SAIDPROPERTY PURSUANT TO AN ALLEGED FORECLOSURE AGAINST Star:Hills WHO IS ALSO SUING DEFENDANTS IN THIS ACTION FOR QUIETTITLE ON HER HALF OWNERSHIP INTEREST AGAINST THE SAME
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