This sample California complaint for quiet title is verified and also includes causes of action for partition and accounting, and quiet title for California is used when a party wishes to have the Court partition certain real property, and also to quiet title to certain real property as well as obtain an accounting from the defendant. This is a preview of the sample complaint sold by LegalDocsPro.
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Any Plaintiff
Any Street
Any Town, CA 55555
714-555-5555
Plaintiff, In Pro Per
Superior Court of the State of California
For the County of _________________
Any Plaintiff,
Plaintiff,
vs.
_____________________________1and DOES 1
through 25, inclusive; and all persons unknown
claiming legal or equitable right, title estate, lien, or
interest in the real property described in the
Complaint adverse to Plaintiff’s title/interest, or any
cloud upon Plaintiff’s title/interest thereto, named
herein as DOES 26 through 100, inclusive,
Defendants.
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Case No.
VERIFIED COMPLAINT FOR:
1. PARTITION AND ACCOUNTING
2. QUIET TITLE
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VERIFIED COMPLAINT FOR PARTITION AND ACCOUNTING; QUIET TITLE
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Plaintiff, ______________1hereby files a Verified Complaint and alleges as follows:
ALLEGATIONS COMMON TO AND INCLUDED IN
ALL CAUSES OF ACTION
1. Plaintiff, _______________ (hereinafter “Plaintiff”) holds a one half undivided
interest as a joint tenant in the certain real properties known as _____________________________,
(hereinafter “______ Property”), ________________________________, (hereinafter “______
Property”), (hereinafter “_______ Property”).
2. Plaintiff is informed and believes, and thereon alleges, that defendant _______
(hereinafter “Defendant”) is a resident of the County of ________, State of California,
and Defendant also holds a one half undivided interest as a joint tenant in the _________ Property,
Property and ___ Property.
3. On or about _______________ Plaintiff and Defendant purchased the real property
located at ___________________, (hereinafter “__________ Property”) with each holding a one half
undivided interest as a joint tenant.
4. On or about _________________ Plaintiff and Defendant purchased the real property
located at ________________, (hereinafter “___________ Property”).
5. The real properties which are the subject of this action are as follows:
A. __________ Property -located at ____________________________________,
and legally described as:
INSERT FULL LEGAL DESCRIPTION FROM THE DEED AND THE ASSESSOR’S
PARCEL NUMBER A.P.N. _______________.
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VERIFIED COMPLAINT FOR PARTITION AND ACCOUNTING; QUIET TITLE
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B. __________Property -located at ____________________________, and legally
described as: INSERT FULL LEGAL DESCRIPTION FROM THE DEED AND THE
ASSESSOR’S PARCEL NUMBER A.P.N. _____________.
16. Plaintiff is unaware of the true names and capacities of Defendants sued herein, as
DOES 1 through 100, inclusive.
7. At all times herein relevant, Defendants DOES 1 through 100, inclusive, and each of
them, were agents of Defendant.
8. Plaintiff is the owner of an undivided one half interest in the _________ Property,
_______ Property and __________ Property, as a joint tenant which is co-owned by Defendant, and
which Plaintiff reasonably believes will be materially affected by this action. Defendant claims an
undivided one half interest in the _________ Property, _______ Property, and _________ Property
as a joint tenant which is co-owned by Plaintiff and which Plaintiff reasonably believes will be
materially affected by this action.
9. On or about ______, Plaintiff and Defendant purchased the __________ property by
their both putting equal amounts of money into the purchase, deposit down payment and closing
costs. The terms of the parties agreement was to purchase the property, renovate the interior and
exterior and thereafter retain a licensed real estate agent to rent and subsequently list and sell the
property for a profit. Based on the parties agreement, Plaintiff and Defendant contributed one half of
the purchase price and closing costs associated with the transaction.
10. On or about ______________, Plaintiff and Defendant purchased the __________
property by their both putting equal amounts of money into the purchase, deposit down payment and
closing costs. The terms of the parties agreement was to purchase the property, renovate the interior
and exterior and thereafter retain a licensed real estate agent to rent and subsequently list and sell the
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VERIFIED COMPLAINT FOR PARTITION AND ACCOUNTING; QUIET TITLE
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property for a profit. Based on the parties agreement, Plaintiff and Defendant contributed one half of
the purchase price and closing costs associated with the transaction.
11. On or about __________, Plaintiff and Defendant purchased the _____ property
by their both putting equal amounts of money into the purchase, deposit down payment and
closing costs. The terms of the parties agreement was to purchase the property, renovate the
interior and exterior and thereafter retain a licensed real estate agent to rent and subsequently list
and sell the property for a profit. Based on the parties agreement, Plaintiff and Defendant
contributed one half of the purchase price and closing costs associated with the transaction.
12. On or about ______________________, Plaintiff and Defendant purchased the
_________ property by their both putting equal amounts of money into the purchase, deposit
down payment and closing costs. The terms of the parties agreement was to purchase the
property, renovate the interior and exterior and thereafter retain a licensed real estate agent to
rent and subsequently list and sell the ________ Property for a profit. Based on the parties
agreement, Plaintiff and Defendant contributed one half of the purchase price and closing costs
associated with the transaction.
13. After commencement of this action, Plaintiff will procure a title report which will
reveal Plaintiff has no information or belief as to any other person or entity having an interest in the
___________ Property, ________ Property, and ______ Property.
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VERIFIED COMPLAINT FOR PARTITION AND ACCOUNTING; QUIET TITLE