1 Any Attorney or Party

Any Street
2 Any Town, CA 55555

3 714-555-5555

4 Any Attorney or Party

8 Superior Court of the State of California

9 For the County of _________________

10

11 Any Plaintiff, ) Case No

)
12 ) UNLIMITED CIVIL-DEMAND OVER $25,000
Plaintiff, )
13 ) VERIFIED COMPLAINT FOR:
)
14 vs. ) 1. FINANCIAL ELDER ABUSE
) 2. FRAUD
15 Any Defendant, and DOES 1 through 25, ) 3. CANCELLATION OF WRITTEN INSTRUMENT
inclusive; and all persons unknown claiming ) UNDER CIVIL CODE 3412
16 legal or equitable right, title estate, lien, or ) 4. QUIET TITLE
) 5. CONSTRUCTIVE TRUST
17
interest in the real property described in the )
Complaint adverse to Plaintiffs title/interest, )
18 or any cloud upon Plaintiffs title/interest )
thereto, named herein as DOES 26 through )
19 100, inclusive, )
)
20 )
Defendants. )
21 )

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- 1
VERIFIED COMPLAINT FOR FINANCIAL ELDER ABUSE, FRAUD, QUIET TITLE, ETC.
 1 To view over 300 sample legal documents sold by LegalDocsPro
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Be sure to remove this notice and all other notices before using
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6 this document.
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Plaintiff, ___________, an individual, by and though their undersigned counsel, hereby files a
8
Complaint and alleges as follows:
9

10
ALLEGATIONS COMMON TO AND INCLUDED IN ALL CAUSES OF ACTION

11 1. Plaintiff, _______________ an individual, (Plaintiff) is now, and at all relevant

12 times mentioned herein was, an individual, residing in the City of __________, County
13
of_____________, State of California and is the owner of real property (hereinafter Subject
14
Property) commonly known as LIST COMPLETE STREET ADDRESS OF PROPERTY located
15
in the City of __________, County of _______, State of California, and more specifically described
16

17 as: LIST COMPLETE LEGAL DESCRIPTION OF PROPERTY INCLUDING THE

18 ASSESSORS PARCEL NUMBER.

19
2. Plaintiff is informed and believes, and thereon alleges, that defendant __________, an
20
individual, (Defendant ____) is now, and at all relevant times mentioned herein was, an individual,
21
residing in the City of _________, County of ________, State of California.
22

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
25
title/interest, or any cloud upon Plaintiffs title/interest thereto, named herein as DOES 26 through
26
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.
3
4. Plaintiff is informed and believes, and upon such information and belief alleges, that
4
she is unaware of the true names or capacities, whether they are individuals or business entities, of
5

6
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,
9
that Defendant ___________ and DOES 1 through 100 inclusive, were, at all times herein mentioned,
10
authorized and empowered by each other to act, and did so act, as agents of each other, and all of the
11
things herein alleged to have been done by them were done in the capacity of such agency. Upon
12

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
16
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
18

19 Plaintiff that Plaintiff needed to add Defendant _________ On title to the Subject Property in order to

20 maintain her property tax base and avoid an increase in taxes.

21
8. Plaintiff has a total of three daughters or sons __________________ It was Plaintiffs
22
intent to leave her interest in the Subject Property to all three daughters.
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9. On or about ______, based on the verbal representation made to Plaintiff by
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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
27
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
3
___________on _____________ at ________ as Instrument No. _______. A true and correct copy of
4
said recorded Joint Tenancy Grant Deed is attached hereto as Exhibit 1 and incorporated herein by
5

6
reference.

7 10. Plaintiff is __ years of age, does not read or write and has limited education. The first

8 language of Plaintiff is Spanish although she does speak English.

9
11. Plaintiff is informed and believes, and upon such information and belief alleges that,
10
the Subject Property has a current fair market value of $____________.
11

12 Be sure to modify these paragraphs to suit your individual

13
situation. Do NOT just use the wording here unless it definitely applies
14

15 to your particular situation.

16
FIRST CAUSE OF ACTION
17
(Financial Elder Abuse as against all Defendants)
18

19 12. Plaintiff realleges the allegations contained in paragraphs 1 through 11 inclusive,

20 hereinabove, as though set forth in full herein, and incorporates them into this cause of action by
21
reference.
22

23
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VERIFIED COMPLAINT FOR FINANCIAL ELDER ABUSE, FRAUD, QUIET TITLE, ETC.