1 Any Attorney or Party

Any Street
2 Any Town, CA 99999

3 555-555-5555

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 ) COMPLAINT FOR:
Plaintiff, )
13 ) 1. COMMON LAW FRAUDULENT TRANSFER
vs. )
14 ) 2. RESULTING TRUST
Any Defendant, DOES 1 through 100, inclusive, )
15 ) 3. CONSTRUCTIVE TRUST
Defendant. )
16 )
)
17 )
)
18

19
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- 1 -
COMPLAINT FOR FRAUDULENT TRANSFER, RESULTING TRUST AND CONSTRUCTIVE TRUST
 1

2 COMES NOW the Plaintiff, _______________ , an individual (Plaintiff) who alleges as

3 follows:
4
1. Plaintiff is now, and at all times mentioned herein was, an individual, doing business
5
in the City of ___________, ______________, State of California.
6

7
2. Plaintiff is informed and believes, and on that basis alleges, that Defendant,

8 _______________(Defendant) is now, and at all relevant times mentioned herein was, an

9 individual, residing in the City of _______, County of ________ State of California. Venue is proper
10
as Defendant resides in this judicial district.
11
3. Plaintiff is ignorant of the true names and capacities of Defendants sued herein as
12
DOES 1-100, inclusive, and therefore sues these Defendants by such fictitious names. Plaintiff will
13

14 amend this complaint to allege their true names and capacities when ascertained. Plaintiff is informed

15 and believes, and on that basis alleges, that each of the fictitiously named defendants claims an
16
interest in the property hereinafter described and which is the subject of this action, or were
17
responsible in some manner for the damages suffered by Plaintiff.
18
ALLEGATIONS COMMON TO ALL CAUSES OF ACTION
19

20 4. On or about __________, in Case No. ______in the Superior Court of California,

21 County of ________, a judgment in the total amount of $_______ was entered in favor of Plaintiff
22
and against _______. Said Judgment was entered in favor of Plaintiff against _________, and has
23
never been appealed nor been vacated or modified. No part of said Judgment has been satisfied. A
24
certified copy of said judgment is attached hereto as exhibit 1 and incorporated herein by reference.
25

26 5. On or about _________, Plaintiff recorded an Abstract of Judgment as Document

27 Number__________ with the County Recorder of the County of _____. The recording of the Abstract
28 of Judgment created a judgment lien against all real property in which __________ held an interest

- 2 -
COMPLAINT FOR FRAUDULENT TRANSFER, RESULTING TRUST AND CONSTRUCTIVE TRUST
 1 whether present or future, vested or contingent, legal or equitable pursuant to the provisions of Code
2 of Civil Procedure 697.310(a) and Code of Civil Procedure 697.340(a). A certified copy of said
3
recorded Abstract of Judgment is attached hereto as exhibit 2 and incorporated herein by reference.
4
6. On or about _______ , ________ had an interest in the real property commonly known
5

6
as ______________with Assessors Parcel Number ___________ and legally described as follows:

7 INCLUDE FULL LEGAL DESCRIPTION OF REAL PROPERTY INCLUDING

8 ASSESSORS PARCEL NUMBER

9
7. On or about _______ a Quitclaim Deed was recorded as Document Number
10
____________________ with the County Recorder of the County of _____ in which
11
_________________quitclaimed all of his interest in the previously described real property
12

13 to_________________, Trustee of the _________ Living Trust dated _________. A certified copy of

14 said recorded Quitclaim Deed is attached hereto as exhibit 3 and incorporated herein by reference.
15
8. Plaintiff is informed and believes and based thereon alleges that on or about
16
______________, ___________ passed away.
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21 common-law-fraudulent-transfer-in-california
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COMPLAINT FOR FRAUDULENT TRANSFER, RESULTING TRUST AND CONSTRUCTIVE TRUST