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- 1
VERIFIED COMPLAINT FOR FINANCIAL ELDER ABUSE, FRAUD, QUIET TITLE, ETC.
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Plaintiff, ___________, an individual, by and though their undersigned counsel, hereby files a
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Complaint and alleges as follows:
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ALLEGATIONS COMMON TO AND INCLUDED IN ALL CAUSES OF ACTION
12 times mentioned herein was, an individual, residing in the City of __________, County
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of_____________, State of California and is the owner of real property (hereinafter Subject
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Property) commonly known as LIST COMPLETE STREET ADDRESS OF PROPERTY located
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in the City of __________, County of _______, State of California, and more specifically described
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23 3. The defendants herein named as "all persons unknown claiming legal or equitable
24 right, title estate, lien, or interest in the real property described in the Complaint adverse to Plaintiffs
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title/interest, or any cloud upon Plaintiffs title/interest thereto, named herein as DOES 26 through
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100, inclusive, are unknown to Plaintiff. These unknown Defendants, and each of them, claim some
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VERIFIED COMPLAINT FOR FINANCIAL ELDER ABUSE, FRAUD, QUIET TITLE, ETC.
1 right, title, estate, lien, or interest in the hereinafter-described property adverse to Plaintiff's title; and
2 their claims, and each of them, constitute a cloud on Plaintiff's title to that property.
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4. Plaintiff is informed and believes, and upon such information and belief alleges, that
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she is unaware of the true names or capacities, whether they are individuals or business entities, of
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Defendant DOES 1 through 25, inclusive, and sues them by such fictitious names. Plaintiff will seek
7 leave of this Court to insert their true names and capacities once they have been ascertained.
8 5. Plaintiff is informed and believe and upon such information and belief alleges,
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that Defendant ___________ and DOES 1 through 100 inclusive, were, at all times herein mentioned,
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authorized and empowered by each other to act, and did so act, as agents of each other, and all of the
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things herein alleged to have been done by them were done in the capacity of such agency. Upon
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13 information and belief, all Defendants are responsible in some manner for the events described herein
14 and are liable to Plaintiff for the damages she has incurred.
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6. The proper county for the trial of this action is the County of _________ because the
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real property described in paragraph 1 of this complaint is located within this judicial district.
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7. On or about ___________, Defendant ________ made a verbal representation to
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19 Plaintiff that Plaintiff needed to add Defendant _________ On title to the Subject Property in order to
25 Defendant Plaintiff signed a Joint Tenancy Grant Deed which transferred title to the Subject Property
26 into the names of Plaintiff and Defendant ____ as joint tenants. Defendant ____ took Plaintiff to a
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notary public named ________. ______ also prepares Plaintiffs taxes. _________ prepared and
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VERIFIED COMPLAINT FOR FINANCIAL ELDER ABUSE, FRAUD, QUIET TITLE, ETC.
1 acted as notary for the documents adding Defendant ____ as a joint tenant on title to the Subject
2 Property. Said Joint Tenancy Grant Deed was recorded with the County Recorder for the County of
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___________on _____________ at ________ as Instrument No. _______. A true and correct copy of
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said recorded Joint Tenancy Grant Deed is attached hereto as Exhibit 1 and incorporated herein by
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reference.
7 10. Plaintiff is __ years of age, does not read or write and has limited education. The first
20 hereinabove, as though set forth in full herein, and incorporates them into this cause of action by
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reference.
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VERIFIED COMPLAINT FOR FINANCIAL ELDER ABUSE, FRAUD, QUIET TITLE, ETC.