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 Plaintiff, ) VERIFIED COMPLAINT FOR:
)
13 vs. ) 1. PARTITION AND ACCOUNTING
)
14 _____________________________and DOES 1 ) 2. QUIET TITLE
)
15 through 25, inclusive; and all persons unknown )
)
16 claiming legal or equitable right, title estate, lien, or )
)
17 interest in the real property described in the )
)
18 Complaint adverse to Plaintiff’s title/interest, or any )
)
19 cloud upon Plaintiff’s title/interest thereto, named )
)
20 herein as DOES 26 through 100, inclusive, )
)
21 Defendants. )
)
22 ________________________________________ )

23

24 Plaintiff, ______________hereby files a Verified Complaint and alleges as follows:

25

26

27
ALLEGATIONS COMMON TO AND INCLUDED IN
28

- 1 -
VERIFIED COMPLAINT FOR PARTITION AND ACCOUNTING; QUIET TITLE
 1 ALL CAUSES OF ACTION
2 1. Plaintiff, _______________ (hereinafter “Plaintiff”) holds a one half undivided
3
interest as a joint tenant in the certain real properties known as _____________________________,
4
(hereinafter “______ Property”), ________________________________, (hereinafter “______
5

6
Property”), (hereinafter “_______ Property”).

7 2. Plaintiff is informed and believes, and thereon alleges, that defendant _______

8 (hereinafter “Defendant”) is a resident of the County of ________, State of California,

9
and Defendant also holds a one half undivided interest as a joint tenant in the _________ Property,
10
Property and ___ Property.
11
3. On or about _______________ Plaintiff and Defendant purchased the real property
12

13 located at ___________________, (hereinafter “__________ Property”) with each holding a one half

14 undivided interest as a joint tenant.

15
4. On or about _________________ Plaintiff and Defendant purchased the real property
16
located at ________________, (hereinafter “___________ Property”).
17
5. The real properties which are the subject of this action are as follows:
18

19 A. __________ Property -located at ____________________________________,

20 and legally described as:

21
INSERT FULL LEGAL DESCRIPTION FROM THE DEED AND THE ASSESSOR’S
22
PARCEL NUMBER A.P.N. _______________.
23
B. __________Property -located at ____________________________, and legally
24

25 described as: INSERT FULL LEGAL DESCRIPTION FROM THE DEED AND THE

26 ASSESSOR’S PARCEL NUMBER A.P.N. _____________.

27

28

- 2 -
VERIFIED COMPLAINT FOR PARTITION AND ACCOUNTING; QUIET TITLE
 1 6. Plaintiff is unaware of the true names and capacities of Defendants sued herein, as
2 DOES 1 through 100, inclusive.
3
7. At all times herein relevant, Defendants DOES 1 through 100, inclusive, and each of
4
them, were agents of Defendant.
5

6
8. Plaintiff is the owner of an undivided one half interest in the _________ Property,

7 _______ Property and __________ Property, as a joint tenant which is co-owned by Defendant, and

8 which Plaintiff reasonably believes will be materially affected by this action. Defendant claims an
9
undivided one half interest in the _________ Property, _______ Property, and _________ Property as
10
a joint tenant which is co-owned by Plaintiff and which Plaintiff reasonably believes will be
11
materially affected by this action.
12

13 To purchase the entire document visit:

14

15
https://legaldocspro.myshopify.com/products/sample-complaint-for-
16
quiet-title-and-partition-for-california
17

18

19

20

21

22

23

24

25

26

27

28

- 3 -
VERIFIED COMPLAINT FOR PARTITION AND ACCOUNTING; QUIET TITLE