Sample California Complaint for Quiet Title and Adverse Possession | Complaint | Plaintiff

1 Any Attorney or Party

Any Street
2 Any Town, CA 55555

3 714-555-5555

4 Any Attorney or Party

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8 Superior Court of the State of California

9 For the County of _________________

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11 Any Plaintiff, ) Case No.
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12 Plaintiff, ) VERIFIED COMPLAINT FOR:
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13 vs. ) 1. QUIET TITLE AND ADVERSE POSSESSION
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14 _____________________________and DOES 1 ) 2. DECLARATORY RELIEF
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15 through 25, inclusive; and all persons unknown )
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16 claiming legal or equitable right, title estate, lien, or )
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17 interest in the real property described in the )
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18 Complaint adverse to Plaintiff’s title/interest, or any )
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19 cloud upon Plaintiff’s title/interest thereto, named )
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20 herein as DOES 26 through 100, inclusive, )
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21 Defendants. )
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22 ________________________________________ )

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VERIFIED COMPLAINT FOR QUIET TITLE AND ADVERSE POSSESSION, DECLARATORY RELIEF
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4 Plaintiff, ______________hereby files a Verified Complaint and alleges as follows:
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1. Plaintiff ______, (hereinafter “Plaintiff”) is an individual residing in the City of
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___________, County of __________, State of California and is the owner by adverse possession of
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real property (hereinafter “Property”) located in __________ County, California and more

9 specifically described as: INSERT FULL LEGAL DESCRIPTION FROM THE DEED AND

10 THE ASSESSOR’S PARCEL NUMBER A.P.N. ALSO ADD THE STREET ADDRESS IF
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APPLICABLE.
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2. Plaintiff has possession of all real property described in paragraph 1 of this complaint
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by actual, open, hostile, continuous, and exclusive possession.
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15 3. Plaintiff's possession has been actual, open, hostile, continuous, and exclusive since

16 LIST DATE HERE, in excess of the 5-year period set forth in Code of Civil Procedure sections
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318, 319 and 321 through 323.
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4. Plaintiff has been in possession of the real property described in paragraph 1 of
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this complaint by virtue of LIST HERE THE SPECIFIC TYPE OF WRITTEN INSTRUMENT,
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21 JUDGMENT, OR DECREE SUCH AS A TAX DEED EXECUTED ON _________ BY

22 ______________, AND RECORDED ON ___________.
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5. Plaintiff has been in continuous possession during the 5-year period described
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in paragraph 3 of this complaint, adverse to defendants and to all other persons, in support of
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plaintiff's title to the real property and as curative of any defects in the LIST HERE THE
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27 SPECIFIC TYPE OF WRITTEN INSTRUMENT, JUDGMENT, OR DECREE SUCH AS A

28 TAX DEED, or other defects which might have existed with reference to it.

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VERIFIED COMPLAINT FOR QUIET TITLE AND ADVERSE POSSESSION, DECLARATORY RELIEF
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quiet-title-and-partition-for-california
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VERIFIED COMPLAINT FOR QUIET TITLE AND ADVERSE POSSESSION, DECLARATORY RELIEF

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