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ELKE GORDON SCHARDT
State Bar No. 152114
44319 Lowtree Avenue
Lancaster, CA 93534
(661) 940-5900
Attorney for Plaintiff
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF KERN
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SUSAN JENNIFER ARN ) Case No.
)
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) VERIFIED COMPLAINT FOR
13 Plaintiff, ) QUIET TITLE
) (Civil-Unlimited)
14 V. )
15 )
DEBORAH LYNN HUERTA,an individual )
16 SALVADOR RODRIGUEZ FLORES, aka )
17 SALVADOR RODRIGUEZ, AKA SAL )
RODRIGUEZ, an Individual, And as Group )
18 and all persons unknown, claiming any legal or )
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equitable right, title, estate, lien or ANY )
interest in the property described in the complaint )
20 adverse to the plaintifFs title, or any cloud on )
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plaintifPs title, named as Does I through 50 )
)
22 Defendants. )
23 )
)
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Plaintiff SUSAN JENNIFER ARN, an individual alleges herein as follows:
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INTRODUCTION
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28 1. This action seeks: to quiet title to the subject property
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VERIFIED COMPLAINT FOR QUIET TITLE
THE REAL PROPERTY
The subject of this action is certain real property comprising an improved parcel of land
within the County of Kern, State of California, commonly known as 24575 Equestrian Dr.,
Tehachapi, CA 93561, APN: 224-021-29-00-0, consisting of the real property in the City of
Tehachapi, County of Kern, State of California, legally described as follows:
PARCEL 2 IN THE UNINCORPORATED AREA OF THE COUNTY OF KERN, STATE
9 OF CALIFORNIA, AS PER PARCEL MAP NO. 9466 FILED SEPTEMBER 30, 1991 IN
10 BOOK 42 PAGE(S) 180-181 OF PARCEL MAPS IN THE OFFICE OF THE COUNTY
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RECORDER OF SAID COUNTY, APN 224-021-29-00-0
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13 PARTIES
14 Plaintiff SUSAN JENNIFER ARN is an individual who purchased the Property in 1994
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pursuant to a land sale contract. Plaintiff requests quiet title herein.
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Defendant DEBORA HUERTA is and at all relevant times was, an individual residing in the
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18 State of California. Defendant has not been a co-owner of record since the acquisition of the
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Property in 1994
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Defendant SALVADOR RODRIGUEZ FLORES, aka SALVADOR RODRIGUEZ, aka
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22 SAL RODRIGUEZ is and at all relevant times was an individual residing in the State of
23 California. Defendant has not been a co-owner of record since the acquisition of the property
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in 1994.
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26 The Defendants named herein as "All persons unknown, Claiming Any Legal or Equitable
27 Right, Title, Estate, Lien, or interest In the Property Described in the Complaint Adverse to
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Plaintiffs title, Or Any Cloud Upon Plaintiff's Title thereto" (the" unknown Defendants")
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30 (collectively with defendants, the "defendants" are unknown to Plaintiff Plaintiff is
VERIFIED COMPLAINT FOR QUIET TITLE
informed and believes, and on that basis alleges, that the Unknown Defendants, and each of
them, claim some right, title, estate, lien, or interest in the real property and real property
interest that are adverse to PlaintifFs property interests at issue in this action.
7. Plaintiff does not know the true names and capacities of the defendants sued as Does 1
through 10, inclusive, and therefore sues these defendants by such fictitious names. Upon
information and belief, Defendant may have granted interests in the Property and/or soon will
grant such ownership interests. Plaintiff does not currently know the true names and
10 capacities of those who may claim an ownership interest in the Property, but Plaintiff will
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amend her complaint to add the true names and capacities of these defendants when they are
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13 ascertained.
14 JURISDICTION
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8. This Court has jurisdiction over this matter because the amount in question exceeds the
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jurisdictional minimum for this Court.
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9. Venue is proper in this Court because the real property that is the subject of this action is
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located in the County of Kern, in the State of California.
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22 ALLEGTIONS COMMON TO ALL CLAMS FOR RELIEF
23 10. This case involves a five (5) acre rural property located at 24575 Equestrian Dr. Tehachapi,
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California 93561 (the "Property" ):
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26 11. The property is designated in the Kern County recorder's Office as APN: 224-021-29-00-0,
27 and legally described as follows:
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PARCEL 2 IN THE UNINCORPORATED AREA OF THE COUNTY OF KERN, STATE
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30 OF CALIFORNIA, AS PER PARCEL MAP NO. 9466 FILED SEPTEhKER 30, 1991 IN
VERIFIED COMPLAINT FOR QUIET TITLE
I BOOK 42 PAGE(S) 180-181 OF PARCEL MAPS IN THE OFFICE OF THE COUNTY
RECORDER OF SAID COUNTY
12. In 1994, Plaintiff purchased the Property under a land sale contract and it was
unimproved at time of purchase. Plaintiff made the down payment and sought to obtain a
loan to commence improving the property and pay off the balance of the land sale contract.
13. In 1994 Plaintiff could not qualify for a loan on the property to purchase a mobile home to
be located on the property, drill a well, construct outbuildings add fences and cross fence the
10 property to be suitable for horses and dogs.
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14. David G. Parfitt, at all times was Plaintiff s long time friend, and trusted friend. Plaintiff
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13 and David Parfitt agreed that the property was to be placed initially in his name for the
14 purpose of obtaining a loan to benefit Plaintiff so that she could buy a mobile home to be
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placed on the property as residence for Plaintiff, The plaintiff and David Parfitt further
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agreed that she would make all payments on the loan and that the property would be
18 quitclaimed back to her after having made payments for a number of years and/or was able to
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refinance in her own name.
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15. In reliance on their agreement Plaintiff has made all payments on the loan and improved the
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22 property. Plaintiff placed the mobile home on the property, paid for placement, permits,
23 service connections, and further improved the property using her own funds. Plaintiff drilled
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a well, fenced and cross fenced the property and built structures suitable to house horses and
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26 dogs.
27 16. Plaintiff alleges and asserts that David G. Parfitt in 1994, placed his name on title to the
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property, and became the owner of record for the Property solely for the purpose of securing
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the loan for the benefit of Plaintiff
VERIFIED COMPLAINT FOR QUIET TITLE
17. David G. Parfitt agreed to deed the property back to PlaintilF to reflect her ownership at a
later date when Plaintiff had made loan payments and improved her credit rating and
standing.
18. In March 2006, David Parfitt in compliance with the parties'greement delivered a signed,
notarized Quitclaim deed to Plaintiff quitclaiming his interest in the property to Susan
Jennifer Arn. A true and correct copy of the quitclaim deed is attached as Exhibit I to this
complaint.
19. Plaintiff alleges and asserts that she is the owner of the property, has paid all loan payments,
property taxes, insurance and improvements and maintenance on the property since 1994.
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13 Plaintiff continues making payments on the loan and plaintiff fully complied with the
14 agreement made between plaintiff and her friend David Parfitt.
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20. PlaintifF has resided at the property since purchase in 1994, and continues to reside at the
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property and paid property taxes, insurance and maintenance and upkeep since 1994.
18 21. David Parfitt did not at any time reside at the property nor pay property taxes, insurance,
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upkeep and improvements to the property since 1994. Plaintiffs claim of ownership and
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possession of the property has been uninterrupted since 1994.
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22 22. In April 2022 Plaintiff learned through an announcement on public media that her friend
23 David G. Parfltt had died on 4-12-2022. Plaintiff recorded the quitclaim Deed to the Property
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with the Kern County recorder. Exhibit 1 is a true and correct copy of the recorded Quitclaim
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26 deed, recorded as Document No. 222056421 on 4-12-2022.
27 23. Plaintiff was informed and believes that on 11-8-2021, Defendant HUERTA and
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SALVADOR RODRIGUEZ, coerced and influenced David G. Parfitt, to execute a Grant
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Deed on the Property granting the property to DEBORAH LYNN HUERTA AND
VERIFIED COMPLAINT FOR QUIET TITLE
I SALVADOR RODRIGUEZ FLORES AS JOINT TENANTS. Plaintiff is informed and
believes that defendant SALVADOR RODRIGUEZ FLORES is a neighbor of David G.
Parfitt and alleged to be the husband of DEBORAH LYNN HUERTA.
5 24. On or about June 21, 2022, Defendant HUERTA informed Plaintiff that she and SAL own
the property and that she seeks to evict and oust Plaintiff from the property, and sell it.
25. Defendants HUERTA and RODRIGUEZ have never resided at the Property, have not made
any payments on the property, have not paid property taxes, insurance and upkeep for the
10 property since 1994 or any time thereafter.
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26. Plaintiff is informed and believes that Defendant RODRIGUEZ FLORES is the neighbor of
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13 David Parfitt and DEBORAH HUERTA is related to Defendant RODRIGUEZ FLORES and
14 was informed and believes that they are husband and wife.
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27. Plaintiff alleges that DEBORAH HUERTA and SALVADOR RODRIGUEZ FLORES at all
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times were informed and had full knowledge that the property in Tehachapi belonged to
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18 Plaintiff, that Plaintiff asserted and claimed ownership at all times and that David Parfitt
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made no claim to said property at any time. Defendants are believed to have coerced and
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taken advantage of David Parfitt, and had him sign documents and deeds all in their effort to
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22 take his property.
23 28. Plaintiff alleges that in 2013 her iriend David Parfitt instructed the lender to add her to the
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loan on the property. Plaintiff alleges that Plaintiff and David Parfitt held a joint bank
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26 account where Plaintiff deposited her income and the loan payments were withdrawn
27 automatically by the lender.
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29. Plaintiff is informed and believes that David Parfitt at the time of signing the Grant Deed
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30 had been ill, had been in the hospital, had memory Ioas and dementia and was unaware of
~ COMPLAINT FOR QUIET TITLE
what documents he signed including signing a Grant Deed to Plaintiffs property and a deed
for his personal residence transferring the property to defendants HUERTA AND
RODRIGUEZ.
VALUE OF THE PROPERTY
30. Upon information and belief, Plaintiff alleges that there are no known encumbrances of
record to the property except the loan obtained for the purchase of the mobile home obtained
10
by David Parfitt for the benefit of Plaintiff
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31. Upon Information and belief, Plaintiff alleges that the value of the Property including
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13 improvements is estimated to be $ 196,000 as of the date if this Complaint which is in excess
14 of the encumbrances of record in the approximately amount of $ 40,000 and costs of sale in
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relation to the Property.
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FIRST CAUSE OF ACTION
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18 (Quiet Title Against all Defendants)
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32. Plaintiff hereby incorporates by reference the allegations contained in paragraphs 1 through
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31 above as though fully set forth herein.
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22 33. By virtue of the foregoing facts, with Plaintiff having resided at the property since 1994,
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paid property taxes, insurance and improvements since 1994, Plaintiff is entitled to a judicial
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declaration that Plainfiff is the 100% owner of the subject Property
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26 34. Accordingly, Plaintiff seeks to quiet title to the Property in PlaintifF s name alone and
27 expunge the grant deed recorded by Defendants in their effort to take the real property owned
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by Plaintiff.
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30 35. Plaintiff seeks to expunge the deed recorded by Defendants for their own benefit and
VERIFIED COMPLAINT FOR QUIET TITLE
contrary to Plaintiff s claim of ownership.
PRAYER FR RELIEF
36. Wherefore, Plaintiff prays for judgment as follows against all Defendants.
37. For an order quieting title to the subject property in Plaintiff and expunge the deed recorded
by defendants.
38. For a judicial declaration that Plaintiff is the full legal and beneficial owner of the Property.
39. For attorney's fees, if allowed by law
10 40. For costs of suit; and
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12proper.'5
41. For such other and further relief as the court may deem just and
ELKE GO~N SCHARDT, Attorney for Plaintiff
Susan Jennifer'Arn
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VERIFIED COMPLAINT FOR QUIET TITLE
1 VERIFICATION
Ihave read the foregoing VERIFIED COMPLAINT FOR QUIET TITLE and know its contents.
The matters stated in the foregoing document are true of my own knowledge except as to those
matters which are stated on information and belief and, as to those matters, I believe them to be
I declare under penalty of perjury under the laws of the State of California that the foregoing is
10 true and correct.
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Executd on June 2022 at Lancaster, California
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15 SUSAN JENNY ARN,plaintiff
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VERIFIED COMPLAINT FOR QUIET TITLE
EXHIBIT 1
0(jjtgt 20
Jon Lltaulst Assessor- Recorder 8/1 2/2022
RECORDING REQUESTED BY: Kern Counlr Orl feint Records
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Document Title(s): fg(2/k@a Oo.cl
Documents believed to be exempt from paying the 075 Building ittomes dh Jobs Act fee
must cite a valid exemption on the face of the document.The following exemptions may apply:
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with a amsfcr subject to dm 'mposl&m of twuwlbr tas;
Rcomded in mmneedon with a previous uaesfcr of real pmpeny that was subject to doeumaatary
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Doc: KN:2022 00056421
Page 2 of 2 Requested By:nhewks, Printed: 6/30/2022 3:44 PM
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ELKE GORDON SCHARDT State Bar No. 152114 44319 Lowtree Avenue Lancaster, CA 93534 (661) 940-5900 Attorney for Plaintiff SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF KERN 10 SUSAN JENNIFER ARN ) Case No. ) 12 ) VERIFIED COMPLAINT FOR 13 Plaintiff, ) QUIET TITLE ) (Civil-Unlimited) 14 V. ) 15 ) DEBORAH LYNN HUERTA,an individual ) 16 SALVADOR RODRIGUEZ FLORES, aka ) 17 SALVADOR RODRIGUEZ, AKA SAL ) RODRIGUEZ, an Individual, And as Group ) 18 and all persons unknown, claiming any legal or ) 19 equitable right, title, estate, lien or ANY ) interest in the property described in the complaint ) 20 adverse to the plaintifFs title, or any cloud on ) 21 plaintifPs title, named as Does I through 50 ) ) 22 Defendants. ) 23 ) ) 24 25 Plaintiff SUSAN JENNIFER ARN, an individual alleges herein as follows: 26 INTRODUCTION 27 28 1. This action seeks: to quiet title to the subject property 29 30 VERIFIED COMPLAINT FOR QUIET TITLE THE REAL PROPERTY The subject of this action is certain real property comprising an improved parcel of land within the County of Kern, State of California, commonly known as 24575 Equestrian Dr., Tehachapi, CA 93561, APN: 224-021-29-00-0, consisting of the real property in the City of Tehachapi, County of Kern, State of California, legally described as follows: PARCEL 2 IN THE UNINCORPORATED AREA OF THE COUNTY OF KERN, STATE 9 OF CALIFORNIA, AS PER PARCEL MAP NO. 9466 FILED SEPTEMBER 30, 1991 IN 10 BOOK 42 PAGE(S) 180-181 OF PARCEL MAPS IN THE OFFICE OF THE COUNTY 11 RECORDER OF SAID COUNTY, APN 224-021-29-00-0 12 13 PARTIES 14 Plaintiff SUSAN JENNIFER ARN is an individual who purchased the Property in 1994 15 pursuant to a land sale contract. Plaintiff requests quiet title herein. 16 Defendant DEBORA HUERTA is and at all relevant times was, an individual residing in the 17 18 State of California. Defendant has not been a co-owner of record since the acquisition of the 19 Property in 1994 20 Defendant SALVADOR RODRIGUEZ FLORES, aka SALVADOR RODRIGUEZ, aka 21 22 SAL RODRIGUEZ is and at all relevant times was an individual residing in the State of 23 California. Defendant has not been a co-owner of record since the acquisition of the property 24 in 1994. 25 26 The Defendants named herein as "All persons unknown, Claiming Any Legal or Equitable 27 Right, Title, Estate, Lien, or interest In the Property Described in the Complaint Adverse to 28 Plaintiffs title, Or Any Cloud Upon Plaintiff's Title thereto" (the" unknown Defendants") 29 30 (collectively with defendants, the "defendants" are unknown to Plaintiff Plaintiff is VERIFIED COMPLAINT FOR QUIET TITLE informed and believes, and on that basis alleges, that the Unknown Defendants, and each of them, claim some right, title, estate, lien, or interest in the real property and real property interest that are adverse to PlaintifFs property interests at issue in this action. 7. Plaintiff does not know the true names and capacities of the defendants sued as Does 1 through 10, inclusive, and therefore sues these defendants by such fictitious names. Upon information and belief, Defendant may have granted interests in the Property and/or soon will grant such ownership interests. Plaintiff does not currently know the true names and 10 capacities of those who may claim an ownership interest in the Property, but Plaintiff will 11 amend her complaint to add the true names and capacities of these defendants when they are 12 13 ascertained. 14 JURISDICTION 15 8. This Court has jurisdiction over this matter because the amount in question exceeds the 16 jurisdictional minimum for this Court. 17 18 19 9. Venue is proper in this Court because the real property that is the subject of this action is 20 located in the County of Kern, in the State of California. 21 22 ALLEGTIONS COMMON TO ALL CLAMS FOR RELIEF 23 10. This case involves a five (5) acre rural property located at 24575 Equestrian Dr. Tehachapi, 24 California 93561 (the "Property" ): 25 26 11. The property is designated in the Kern County recorder's Office as APN: 224-021-29-00-0, 27 and legally described as follows: 28 PARCEL 2 IN THE UNINCORPORATED AREA OF THE COUNTY OF KERN, STATE 29 30 OF CALIFORNIA, AS PER PARCEL MAP NO. 9466 FILED SEPTEhKER 30, 1991 IN VERIFIED COMPLAINT FOR QUIET TITLE I BOOK 42 PAGE(S) 180-181 OF PARCEL MAPS IN THE OFFICE OF THE COUNTY RECORDER OF SAID COUNTY 12. In 1994, Plaintiff purchased the Property under a land sale contract and it was unimproved at time of purchase. Plaintiff made the down payment and sought to obtain a loan to commence improving the property and pay off the balance of the land sale contract. 13. In 1994 Plaintiff could not qualify for a loan on the property to purchase a mobile home to be located on the property, drill a well, construct outbuildings add fences and cross fence the 10 property to be suitable for horses and dogs. 11 14. David G. Parfitt, at all times was Plaintiff s long time friend, and trusted friend. Plaintiff 12 13 and David Parfitt agreed that the property was to be placed initially in his name for the 14 purpose of obtaining a loan to benefit Plaintiff so that she could buy a mobile home to be 15 placed on the property as residence for Plaintiff, The plaintiff and David Parfitt further 16 17 agreed that she would make all payments on the loan and that the property would be 18 quitclaimed back to her after having made payments for a number of years and/or was able to 19 refinance in her own name. 20 15. In reliance on their agreement Plaintiff has made all payments on the loan and improved the 21 22 property. Plaintiff placed the mobile home on the property, paid for placement, permits, 23 service connections, and further improved the property using her own funds. Plaintiff drilled 24 a well, fenced and cross fenced the property and built structures suitable to house horses and 25 26 dogs. 27 16. Plaintiff alleges and asserts that David G. Parfitt in 1994, placed his name on title to the 28 property, and became the owner of record for the Property solely for the purpose of securing 29 30 the loan for the benefit of Plaintiff VERIFIED COMPLAINT FOR QUIET TITLE 17. David G. Parfitt agreed to deed the property back to PlaintilF to reflect her ownership at a later date when Plaintiff had made loan payments and improved her credit rating and standing. 18. In March 2006, David Parfitt in compliance with the parties'greement delivered a signed, notarized Quitclaim deed to Plaintiff quitclaiming his interest in the property to Susan Jennifer Arn. A true and correct copy of the quitclaim deed is attached as Exhibit I to this complaint. 19. Plaintiff alleges and asserts that she is the owner of the property, has paid all loan payments, property taxes, insurance and improvements and maintenance on the property since 1994. 12 13 Plaintiff continues making payments on the loan and plaintiff fully complied with the 14 agreement made between plaintiff and her friend David Parfitt. 15 20. PlaintifF has resided at the property since purchase in 1994, and continues to reside at the 16 17 property and paid property taxes, insurance and maintenance and upkeep since 1994. 18 21. David Parfitt did not at any time reside at the property nor pay property taxes, insurance, 19 upkeep and improvements to the property since 1994. Plaintiffs claim of ownership and 20 possession of the property has been uninterrupted since 1994. 21 22 22. In April 2022 Plaintiff learned through an announcement on public media that her friend 23 David G. Parfltt had died on 4-12-2022. Plaintiff recorded the quitclaim Deed to the Property 24 with the Kern County recorder. Exhibit 1 is a true and correct copy of the recorded Quitclaim 25 26 deed, recorded as Document No. 222056421 on 4-12-2022. 27 23. Plaintiff was informed and believes that on 11-8-2021, Defendant HUERTA and 28 SALVADOR RODRIGUEZ, coerced and influenced David G. Parfitt, to execute a Grant 29 30 Deed on the Property granting the property to DEBORAH LYNN HUERTA AND VERIFIED COMPLAINT FOR QUIET TITLE I SALVADOR RODRIGUEZ FLORES AS JOINT TENANTS. Plaintiff is informed and believes that defendant SALVADOR RODRIGUEZ FLORES is a neighbor of David G. Parfitt and alleged to be the husband of DEBORAH LYNN HUERTA. 5 24. On or about June 21, 2022, Defendant HUERTA informed Plaintiff that she and SAL own the property and that she seeks to evict and oust Plaintiff from the property, and sell it. 25. Defendants HUERTA and RODRIGUEZ have never resided at the Property, have not made any payments on the property, have not paid property taxes, insurance and upkeep for the 10 property since 1994 or any time thereafter. 11 26. Plaintiff is informed and believes that Defendant RODRIGUEZ FLORES is the neighbor of 12 13 David Parfitt and DEBORAH HUERTA is related to Defendant RODRIGUEZ FLORES and 14 was informed and believes that they are husband and wife. 15 27. Plaintiff alleges that DEBORAH HUERTA and SALVADOR RODRIGUEZ FLORES at all 16 times were informed and had full knowledge that the property in Tehachapi belonged to 17 18 Plaintiff, that Plaintiff asserted and claimed ownership at all times and that David Parfitt 19 made no claim to said property at any time. Defendants are believed to have coerced and 20 taken advantage of David Parfitt, and had him sign documents and deeds all in their effort to 21 22 take his property. 23 28. Plaintiff alleges that in 2013 her iriend David Parfitt instructed the lender to add her to the 24 loan on the property. Plaintiff alleges that Plaintiff and David Parfitt held a joint bank 25 26 account where Plaintiff deposited her income and the loan payments were withdrawn 27 automatically by the lender. 28 29. Plaintiff is informed and believes that David Parfitt at the time of signing the Grant Deed 29 30 had been ill, had been in the hospital, had memory Ioas and dementia and was unaware of ~ COMPLAINT FOR QUIET TITLE what documents he signed including signing a Grant Deed to Plaintiffs property and a deed for his personal residence transferring the property to defendants HUERTA AND RODRIGUEZ. VALUE OF THE PROPERTY 30. Upon information and belief, Plaintiff alleges that there are no known encumbrances of record to the property except the loan obtained for the purchase of the mobile home obtained 10 by David Parfitt for the benefit of Plaintiff 11 31. Upon Information and belief, Plaintiff alleges that the value of the Property including 12 13 improvements is estimated to be $ 196,000 as of the date if this Complaint which is in excess 14 of the encumbrances of record in the approximately amount of $ 40,000 and costs of sale in 15 relation to the Property. 16 FIRST CAUSE OF ACTION 17 18 (Quiet Title Against all Defendants) 19 32. Plaintiff hereby incorporates by reference the allegations contained in paragraphs 1 through 20 31 above as though fully set forth herein. 21 22 33. By virtue of the foregoing facts, with Plaintiff having resided at the property since 1994, 23 paid property taxes, insurance and improvements since 1994, Plaintiff is entitled to a judicial 24 declaration that Plainfiff is the 100% owner of the subject Property 25 26 34. Accordingly, Plaintiff seeks to quiet title to the Property in PlaintifF s name alone and 27 expunge the grant deed recorded by Defendants in their effort to take the real property owned 28 by Plaintiff. 29 30 35. Plaintiff seeks to expunge the deed recorded by Defendants for their own benefit and VERIFIED COMPLAINT FOR QUIET TITLE contrary to Plaintiff s claim of ownership. PRAYER FR RELIEF 36. Wherefore, Plaintiff prays for judgment as follows against all Defendants. 37. For an order quieting title to the subject property in Plaintiff and expunge the deed recorded by defendants. 38. For a judicial declaration that Plaintiff is the full legal and beneficial owner of the Property. 39. For attorney's fees, if allowed by law 10 40. For costs of suit; and 11 12proper.'5 41. For such other and further relief as the court may deem just and ELKE GO~N SCHARDT, Attorney for Plaintiff Susan Jennifer'Arn 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 VERIFIED COMPLAINT FOR QUIET TITLE 1 VERIFICATION Ihave read the foregoing VERIFIED COMPLAINT FOR QUIET TITLE and know its contents. The matters stated in the foregoing document are true of my own knowledge except as to those matters which are stated on information and belief and, as to those matters, I believe them to be I declare under penalty of perjury under the laws of the State of California that the foregoing is 10 true and correct. 11 Executd on June 2022 at Lancaster, California 12 13 14 5 15 SUSAN JENNY ARN,plaintiff 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 VERIFIED COMPLAINT FOR QUIET TITLE EXHIBIT 1 0(jjtgt 20 Jon Lltaulst Assessor- Recorder 8/1 2/2022 RECORDING REQUESTED BY: Kern Counlr Orl feint Records 12:00 PM Recorded Is Ibo tatplosl ot Public 00c»: 222056421 cttn rr PER 1 Pscex 2 2$ .00 g&RPI Many ' /rf Pyt 0.00 pf) i3trjf 3+ IIIIIIIIIIIIIIIIIIIIIIII 0.00 g+ fWf i/i 020.00 Document Title(s): fg(2/k@a Oo.cl Documents believed to be exempt from paying the 075 Building ittomes dh Jobs Act fee must cite a valid exemption on the face of the document.The following exemptions may apply: ~ (choo)t applicsblo) 0 0 ~ OC 273881(exi)t Remuded domuncat is oupessly esceaucd sots paymem of teoordng fees (PRO Govt ageaoyx Recorded in GC 27388, l(aX2): 0 GC 27388.1: with a amsfcr subject to dm 'mposl&m of twuwlbr tas; Rcomded in mmneedon with a previous uaesfcr of real pmpeny that was subject to doeumaatary ~ tnuw far tsu, recorded an , in docament (last sem ccrc rsovrtrd oc or ervr rccwvy I, re sj fiocoumcrcuumpian 27388.1(aX2): Remuded in connect that is a tosenlbd dwesing to sn wivb ~ transfer of real pmpcrty a Ckmu» of Owsershp Rcport (PCOnj lt regcacd udrh rolmlsrlosr 0 ~an Io wt (OX2)r Rccmded in eoanacaoo with a luscious tnmsfcr of real pmpeny that is a msidentioi dweniog GC 273$E I recorded oo , in docaaueu tsam low lsvs ouwdrd m «elle'ovns I, ccrc 0 GC 27388. 1(OX I): The fee csp of $ 223 reached; 0 the fee cap of 8223 mscbed pteviously ie Ihc fonowiug GC 27388.1(OXI): oevssouxs) which wwe meerdcd on , Iaeevsncsxs) tuber Sew tms mrvvdaf oc w 4hr dwswy I. jural 0 oc 27388.1(OXI): Nec mused to msl propmty. Failure to include a valid exemption will result in the imposition of the 075 Building Homes dt Jobs Act fee. Fees collected are deposited to thc state and may not be available for refund. Eoaeiaa Eases a aae AO KERN IXIVBR Potu OI BI/I e Page of 2 3:OO P)t Requested By: nhawks, Printed: 6/30/2022 Non-Order Search 1 Ooc: KN:2022 00056421 Rmxmpng ~ Sy SasM KenMd er k'n ~ p).IE&7W ~es Aim)z ~. 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