VICTORIA HOLDING

1 330 N. MACLAY AVENUE, STE 202

SAN FERNANDO, CA 91340
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ATTORNEY IN PRO PER
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SUPERIOR COURT OF CALIFORNIA
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COUNTY OF RIVERSIDE
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9 ) Case No.:
VICTORIA HOLDING, an individual )
10 ) COMPLAINT FOR UNLAWFUL DETAINER
Plaintiff, ) AFTER SALE
) (CCP § 1161)
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vs. )
12 MARIA CARRILLO, and DOES 1 through )
20, inclusive. )
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Defendant
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Plaintiff alleges as follows:
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1. At all times mentioned herein, plaintiff was and now is a competent
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adult residing in the City of San Fernando, County of Los Angeles, State of
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California.
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2. Plaintiff is the owner of the premises located at 806 S. Riverside
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Avenue Rialto, California in Riverside County.
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3. Plaintiff believes that defendants are competent adults residing in
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the City of Rialto, County of Riverside, State of California.
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4. The true names and capacities of defendants sued as Does are
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 1 unknown to plaintiff. Plaintiff will seek leave of court to amend this

2 complaint when said true names and capacities have been determined.

3 5. At all times mentioned herein, each of the defendants, including

4 the defendants served as Does herein, was the agent and /or employee of each

5 of the remaining defendants and in doing what is mentioned herein was acting

6 within the scope of such agency and/or employment. Plaintiff is further

7 informed and believes and thereupon alleges that each of the defendants,

8 including the defendants served as Does herein, claims some type of

9 possessory interest in the premises.

10 6. Plaintiff entered into possession of said premises as owner of

11 record. Defendants are no longer tenants of previous owner, nor are they

12 tenants of the current owner of record.

13 7. Plaintiff has acquired ownership interest in the premises and

14 consequent right to possession. Plaintiff is now the owner of record,

15 holding legal entitlement to the premises as purchaser.

16 8. Plaintiff caused the defendants to be served with a written notice

17 to quit. Said notice required defendants to deliver possession of the

18 premises within three days following service of the notice. A copy of this

19 notice is attached hereto as Exhibit B and incorporated herein by this

20 reference.

21 9. The notice to quit was served on the defendants pursuant to CCP

22 Section 1162 in the manner shown on the Proof of Service, which is part of

23 Exhibit B.

24 10. The period stated in the notice to quit expired on June 27, 2006,

25 and defendants failed to comply with the notice by that date, that is,

COMPLAINT FOR UNLAWFUL DETAINER - 2

 1 they failed to quit the premises and deliver up possession to plaintiff

2 11.Defendants continue in possession of the premises without

4 plaintiff’s permission or consent.

5 12.Plaintiff is informed and believes and thereupon alleges that the

6 reasonable rental value of the premises is the sum of $33.65 per day, and

7 damages to plaintiff caused by defendants’ unlawful detention thereof have

8 accrued at said rate since May 27, 2006 and will continue to accrue at said

9 rate so long as defendants remain in possession of the premises.

10 WHEREFORE, plaintiff prays judgment against defendants, and each of

11 them as follows:

12 1. For immediate possession of the premises;

13 2. For damages at the rate of $33.65. according to proof at trial, for

14 each day defendants continue in possession of the premises, commencing

15 September 25, 2005.

16 3. For costs of suit incurred herein; and

17 4. For such other and further relief as the court may deem just and

18 proper.

19 DATED:
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20 VICTORIA HOLDING

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COMPLAINT FOR UNLAWFUL DETAINER - 3

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VERIFICATION
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I, VICTORIA HOLDING, am the Plaintiff in the above entitled
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action. I have carefully read the foregoing complaint and know
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its contents. The same is true of my own knowledge, except as
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to those matters which are therein alleged on information and
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belief, and as to those matters, I believe it to be true and
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correct and that this declaration was executed in San Fernando,
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California on this ___________________ day of __________ 2006.
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Dated:
14 ________________________
VICTORIA HOLDING
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COMPLAINT FOR UNLAWFUL DETAINER - 4