Quiet Title Action

Complaint to Quiet Title

In the Court of (County), (State)

Plaintiff

V. Cause No.

Defendants

and all persons unknown, claiming any legal or equitable right, title, estate, lien or interest in the property described in the complaint named as DOES 1 through 10

Complaint to Quiet Title

Comes now (Name of Plaintiff), Plaintiff in the above-styled and numbered cause, by and through his Attorney, and files this his Complaint against Defendants, (Names of Defendants), and in support thereof would show unto the Court the following matters and facts:

1. Plaintiff is an adult resident citizen of (city, county, state).

2. Defendant (Name of Defendant) is an adult resident citizen of (city, county, state), and may be served with process and other writs of this Court at (street address, city, county, state, zip code).

3. Defendant (Name of Defendant) is an adult resident citizen of (city, county, state), and may be served with process and other writs of this Court at (street address, city, county, state, zip code).

4. Plaintiff has no knowledge of the true names and identities of Defendants sued in this action as DOES 1–10 and therefore sues them by such fictitious names. This Complaint will be amended when the true identities are ascertained.

5. The property which is the subject matter of this action situated in the County of , State of , and described as follows:

(Insert Legal Description)

6. Defendants designated as DOES 1 through 10 “all persons unknown, claiming any legal or equitable right, title, estate, lien or interest in the property described in the Complaint.”

7. Plaintiff is now, and at all times mentioned in this Complaint, was an owner of and in the possession of all the real property described in Paragraph 5 above, said real property to be hereinafter referred to as the Property.

8. Defendants, and each of them in this action, claim an interest and estate in the Property adverse to plaintiff.

9. Defendants' claims are based on

10. Plaintiff has had exclusive, complete, actual, open, notorious, hostile, and continuous possession of the Property adverse to defendants for more than years. Plaintiff has paid all taxes levied or assessed against the property and all other assessments during the past years. Plaintiff has made and paid for all repairs, upkeep, and insurance on the property for the past years. Defendants, and each of them, have failed and refused to pay for any taxes, insurance, or upkeep on the Property and their claims to ownership cause great and irreparable harm to plaintiff. Plaintiff is unable to borrow against the property to make necessary repairs, which lack of repair results in waste of the Property. Further, the adverse claims of Defendants tend to depreciate greatly the value of the Property.

11. Unless Defendants are enjoined from asserting their adverse claims to the Property, Defendants will continue to assert their adverse claims resulting in irreparable harm, damage, and injury to plaintiff. Plaintiff has no adequate remedy at law.

WHEREFORE, Plaintiff requests judgment against Defendants and each of them, known or unknown, as follows:

1. That Defendants be required to set forth the right, nature, and virtue of their claim to the Property, and that all adverse claims of the Defendants be determined by decree of this Court;

2. That it be declared and adjudged that Plaintiff is the owner of the Property and entitled to possession;

3. That it be declared and adjudged that the Defendants have no estate, right, title, or interest whatsoever in or to the Property or any part of it.

4. That Defendants be permanently enjoined and restrained from asserting any estate, right, title, or interest whatsoever, in or to the Property or any part of it, adverse to Plaintiff;

5. For costs; and

6. For such other and further relief as the court may deem proper.

Respectfully submitted,

OF COUNSEL: