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Raul M. Montes, State Bar No. 1011 Su; rior Court of California
‘ounty of Los Angeles
Law Offices of Raul M. Montes,
A Professional Corporation SEP 07 2018
650 Sierra Madre Villa Ave., Suite 304
oO, Pasadena, California 91107-2071
OticenClark
of Court
Deputy
&:
Telephone: (626) 515-7011
Attorneys for Armando Salazar
fs
SUPERIOR COURT OF THE STATE OF CALIFORNIA
10
FOR THE COUNTY OF LOS ANGELES
1
12 ARMANDO SALAZAR, Case No. BC720688
13 Plaintiff, VERIFIED COMPLAIN
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CONSTRUCTIVE Rami
14 39
VS. TRUST AND FRAUD?
Been
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16 NORA CARRILLO; ROBERT WSO
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SALAZAR AND DOES 1 TO 20 =]a eS
17 Ba
inclusive oo a
18 of
Defendants.
19
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Plaintiff, Armando Salazar, alleges o6aoo o
21
22 FIRST CAUSE OF ACTION
(Constructive Trust — Breach of Confidential Relationship)
23 Against Defendants Nora Carrillo and Does Ito 10
24
1 Defendant Nora Carrillo is at all times herein mentioned was, a resident of
25
County of Los Angeles, California.
26
ee. 27 2. Defendant Robert Salazar is at all times herein mentioned was, a resident of
se!
28
County of Los Angeles, California
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1
Complaint for Constructive Trust
Fe
e e
3 Plaintiff is ignorant of the true names and capacities of the defendants sued
herein as DOES 1 to 20, inclusive, and therefore sues these defendants by such fictitious
names. Plaintiff will amend this complaint to allege their true names and capacities when
ascertained. Plaintiff is informed and believes and thereon alleges that each of the
fictitiously named defendants is responsible in some manner for the occurrences herein
alleged and that Plaintiff's damages as herein alleged were proximately caused by such
defendants.
10 4 Plaintiff is informed and believes and thereon alleges that, at all times
1
herein mentioned, defendants DOES 1 to 20, inclusive, were the agents and employees of
12
each of the other defendants, and in doing the things herein alleged were acting within the
13
14 course and scope of such agency and employment and with the permission and consent of
15 his/her codefendant.
16
5 The real property which is the subject of this complaint (herein referred to
17
18 as the “Subject Property”) is commonly known as 2736 Earle Ave., located in the City of
19 Rosemead, County of Los Angeles, State of California, and is legally described as
20
follows:
21
22 LOT 63 OF TRACT 5242 AS PER MAP RECORDED IN BOOK 56 PAGE 77
OF MAPS, IN THE OFFICE OF THE COUNTY RECORDER OF SAID
23 COUNTY.
24
APN: 5283-003-010
25
26
6 The Subject Property was initially acquired by Fela Salazar and her
wR. 27 predeceased husband, Armando G. Salazar, as their family residence. Plaintiff and
net
28
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Complaint for Constructive Trust
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Defendants Nora Carrillo and Robert Salazar are children of Fela Salazar and her
predeceased husband.
7 At all relevant times herein mentioned, it was the desire and intent of Fela
Salazar to leave the Subject Property to either Plaintiff and or Robert Salazar to be used
as their residence. The Subject Property became vested in the names of Fela Salazar, a
widow, and Armando Salazar, an unmarried man and Robert Salazar, a single man all as
joint tenants pursuant to a Grant Deed dated May 1, 2009. A true and correct copy of the
10 Grant Deed dated May 1, 2009 that was recorded on December 22, 2009, as Instrument
11 No. 20091951279 with the Los Angeles County Recorder’s Office is attached hereto as
12
Exhibit 1 and incorporated herein by reference. The vesting of the Subject Property in
13
14 names of Fela Salazar’s two sons, Plaintiff Armando Salazar and Defendant Robert
15 Salazar was a gift made without consideration.
16
8 As part of her estate planning, Fela Salazar by Grant Deed dated April 19,
17
18 2012 subsequently conveyed her remaining one-third (1/3) interest in the Subject
19 Property to Fela Salazar, Trustee of the Fela Salazar Revocable Living Trust dated April
20
19, 2012 (hereinafter referred to as the “Trust”). A true and correct copy of the Grant
21
22 Deed Dated April 19, 2012 that was recorded on April 25, 2012, as Instrument No.
23 20120611201 with the Los Angeles County Recorder’s Office is attached hereto as
24
Exhibit 2 and incorporated herein by reference.
25
9 Pursuant to the terms of the Trust, upon her death, Fela Salazar’s interest in
26
27 the Subject Property was to be distributed in equal shares to her two sons, Plaintiff
neh
at 28
Armando Salazar and Defendant Robert Salazar.
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Complaint for Constructive Trust
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10. In September 2012, in the weeks prior to the death of Fela Salazar,
Defendant Robert Salazar stated to his mother, Fela Salzar, in the presences of Plaintiff
Armando Salazar and Defendant Nora Carrillo, that he did not want any interest in the
Subject Property. At that time, Defendant Robert Salazar represented and promised both
his mother, Fela Salazar and to Plaintiff, that Defendant Robert Salazar would sign a deed
to relinquish any interest in the Subject Property to Plaintiff Armando Salazar in
accordance with the express wishes of their mother Fela Salazar.
10 11. Within approximately one or two weeks after Defendant Robert Salazar’s
11
representations and promises as herein alleged, Fela Salazar died on or about September
12
27,2012. Defendant Robert Salazar had failed to sign a deed to relinquish any interest
13
14 in the Subject Property as he had represented and promised. At the time of Fela Salazar’s
15 death, the Subject Property remained vested in the Trust, Plaintiff and Defendant Robert
16
Salazar, each as to an undivided one-third (1/3) interest.
17
18 12. Subsequent to the death of Fela Salazar, Defendant Robert Salazar
19 reaffirmed his representations and promises to Plaintiff that he, Defendant Robert
20
Salazar, had no interest in the Subject Property, that he would sign a deed to convey his
21
22 interest in the Subject Property to Plaintiff, and that Subject Property belonged to
23 Plaintiff.
24
13. At all relevant times herein mentioned, subsequent to the death of Fela
25
Salazar, Defendant Nora Carrillo acknowledged and represented to Plaintiff that the
26
re
eat.
27 Subject Property belonged to Plaintiff Armando Salazar pursuant to their mother’s
28
expressed wishes.
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Complaint for Constructive Trust
BC
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14. At all relevant times mentioned herein, Plaintiff reposed trust and
confidence in his brother Defendant Robert Salazar and his sister Defendant Nora
Carrillo. By virtue of the parties’ familial relationship, and by virtue of the Plaintiff
having placed confidence in the fidelity and integrity of the Defendants Nora Carrillo and
Robert Salazar entrusting Defendants to fulfill their mother’s expressed wishes to transfer
ownership of Defendant Robert Salazar’s interest in the Subject Property to Plaintiff and
entrusting Defendant Robert Salazar’s representations and promises to do so, entrusting
10 Defendant Nora Carrillo’ representations and promises made subsequent to Fela Salazar’s
11
death that the Subject Property belonged to Plaintiff, a confidential relationship existed at
12
all times herein mentioned between Plaintiff and Defendants Nora Carrillo and Robert
13
14 Salazar.
15 15. Subsequently, by Grant Deed dated May 10, 2013, Nora Carrillo, as
16
successor Trustee of the Trust, distributed the Trust’s one-third (1/3) interest in the
17
18 Subject Property to Plaintiff and Defendant Robert Salazar, resulting in the vesting of the
19 Subject Property in the names of Plaintiff and Defendant Robert Salazar, each as to an
20
undivided one-half (1/2) interest. A true and correct copy of the Grant Deed Dated May
21
22 10, 2013 that was recorded on May 23, 2013, as Instrument No. 20130775933, with the
23 Los Angeles County Recorder’s Office is attached hereto as Exhibit 3 and incorporated
24
herein by reference.
25
16. Subsequent to the distribution of Trust’s one-third (1/3) interest in the
26
iat 27 Subject Property to Plaintiff and Defendant Robert Salazar, Defendant Robert Salazar
ae?
tor 28
continued to reaffirm his representations and promises to Plaintiff that the Subject
sat
opt:
5
Complaint for Constructive Trust
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Property belonged to Plaintiff and that Defendant Robert Salazar would sign a deed
transferring his interest in the Subject Property to Plaintiff.
17. Subsequent to the distribution of Trust’s one-third (1/3) interest in the
Subject Property to Plaintiff and Defendant Robert Salazar, Defendant Nora Carrillo
continued to reaffirm her representations and promises to Plaintiff that the Subject
Property belonged to Plaintiff and that she would pursue the conveyance of Defendant
Robert Salazar’ interest in the Subject Property to Plaintiff.
10 18. At all relevant times mentioned herein, Plaintiff was justified in relying on
11 the representations and promises by both Defendants Nora Carrillo and Robert Salazar
12
that the Subject Property belonged to Plaintiff and that Defendant Robert Salazar’s
13
14 interest in the Subject Property would be conveyed to Plaintiff.
15 19. In reliance on the representations and promises by both Defendants Nora
16
Carrillo and Robert Salazar, Plaintiff expressed his intentions to Defendants Nora Carrillo
17
18 and to Robert Salazar to invest substantial funds in renovating, remodeling and
19 improving the Subject Property. Both Defendants Nora Carrillo and Robert Salazar, in
20
response, expressly reaffirmed to Plaintiff that the Subject Property was his property and
21
22 encouraged Plaintiff to expend funds to renovate, remodel and improve the Subject
23 Property.
24
20. In reliance on the representations and promises of both Defendants Nora
25
Carrillo and Robert Salazar, Plaintiff expended more than $135,000 to renovate, remodel
26
st 27 and improve the Subject Property. Further, in reliance on the representations and
5a
- 28
ee promises of both Defendants Nora Carrillo and Robert Salazar, Plaintiff Armando Salazar
pot!
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Complaint for Constructive Trust
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did not seek contribution for property taxes, insurance and repairs and maintenance for
the Subject Property.
21. Unbeknownst to Plaintiff, by Grant Deed dated October 22, 2014,
Defendant Robert Salazar conveyed his interest in the Subject Property to Defendant
Nora Carrillo. Plaintiff is informed and believes and thereon alleges that in an effort to
suppress the fact of the conveyance, the Grant Deed dated October 22, 2014 was not
recorded until almost one (1) year later, on September 11, 2015. A true and correct copy
10 of the Grant Deed Dated October 22, 2014, that was recorded on September 11, 2015, as
11
Instrument No. 20151129042, with the Los Angeles County Recorder’s Office is attached
12
hereto as Exhibit 4 and incorporated herein by reference. Plaintiff did not discover the
13
14 existence of the Grant Deed dated October 22, 2014 until a period within the last three
15 years from the date of this Complaint.
16
22. Upon discovery of the conveyance of Defendant Robert Salazar’s interest
17
18 in the Subject Property to Defendant Nora Carrillo, Defendant Nora Carrillo expressly
19 represented and promised to Plaintiff that the Subject Property belonged to him and that
20
she would convey to Plaintiff the interest she acquired from Defendant Robert Salazar.
21
22 23. In March 2018, in violation of the confidential relationship, Defendant
23 Nora Carrillo stated that she would not transfer the Subject Property to Plaintiff. Plaintiff
24
Armando Salazar made demand upon Defendant Nora Carrillo to convey the undivided
25
one-half interest in the Subject Property presently vested in her name to him. Defendant
26
ae 27 Nora Carrillo refused and continues to refuse to do so.
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Complaint for Constructive Trust
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24. Plaintiff is informed and believes and thereon alleges that at all relevant
times, Defendants acted in concert and conspired against Plaintiff in an effort to retain
ownership of an undivided one-half (1/2) interest in the Subject Property to induce
Plaintiff to expend funds to renovate, remodel and improve the Subject Property and
without any contribution for taxes, insurance, and repairs and maintenance.
25. By virtue of Defendant Nora Carrillo’s violation of the relationship of trust
and confidence then existing between Plaintiff and Defendant Nora Carrillo, Defendant
10 Nora Carrillo holds the Subject Property as a constructive trustee for Plaintiff’s benefit.
11 SECOND CAUSE OF ACTION
12 (Constructive Trust — Constructive Fraud)
Against Defendants Nora Carrillo and Does 1 to 10
13
14 26. Plaintiff refers to and herein incorporates Paragraphs 1 through 24 of the
15 First Cause of Action.
16
27. By virtue of her fraudulent acts, Defendant Nora Carrillo holds the Subject
17
18 Property as a constructive trustee for Plaintiff’s benefit.
19 THIRD CAUSE OF ACTION
20 (Fraud)
Against All Defendants
21
22 28. Plaintiff refers to and herein incorporates Paragraphs 1 through 24 of the
23 First Cause of Action.
24
29. At the time the Defendants Nora Carrillo and Robert Salazar made the
25
promises herein alleged to the Plaintiff, the Defendants had no intention of performing
26
ae 27 them.
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28
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Complaint for Constructive Trust
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30. The promises made by Defendants that the Subject Property belonged to
Plaintiff and that they would convey the Subject Property to Plaintiff were made, in part,
to induce the Plaintiff to expend more than $135,000 to renovate, remodel and improve
the Subject Property and to avoid any contribution for the Subject Property’s taxes,
insurance, and repairs and maintenance.
31. The Plaintiff, at the time this promise was made and at the time the Plaintiff
took the actions herein alleged, was ignorant of the Defendants’ secret intention not to
10 perform and the Plaintiff could not, in the exercise of reasonable diligence, have
11
discovered the Defendants’ secret intentions. In reliance on the promises of the
12
Defendants, the Plaintiff expend more than $135,000 to renovate, remodel and improve
13
14 the Subject Property and did not request or seek any contribution for the Subject
15 Property’s taxes, insurance, and repairs and maintenance. If the Plaintiff had known of
16
the actual intention of the Defendants, the Plaintiff would not have taken such action.
17
18 32. As a proximate result of the fraudulent conduct of the Defendants as herein
19 alleged, the Plaintiff was induced to expend more than $135,000 to renovate, remodel and
20
improve the Subject Property and did not request or seek any contribution for the Subject
21
22 Property’s taxes, insurance, and repairs and maintenance and has not received the
23 undivided one-half (1/2) interest in the Subject Property previously vested in the name of
24
Defendant Robert Salazar and now held by Defendant Nora Carrillo, by reason of which
25
the Plaintiff has been damaged in an amount according to proof at trial.
26
27 33. The aforementioned conduct of the Defendants was an intentional
at
Int 28
ae misrepresentation, deceit, or concealment of a material fact known to the Defendants with
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Complaint for Constructive Trust
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the intention on the part of the Defendants of thereby depriving the Plaintiff of property
or legal rights or otherwise causing injury, and was despicable conduct that subjected the
Plaintiff to a cruel and unjust hardship in conscious disregard of the Plaintiff's rights, so
as to justify an award of exemplary and punitive damages.
FOURTH CAUSE OF ACTION
(Constructive Fraud)
Against All Defendants
34. Plaintiff refers to and herein incorporates Paragraphs 1 through 24 of the
10 First Cause of Action and Paragraphs 30 through 32 of the Third Cause of Action.
11 35. By virtue of the familial relationship between Plaintiff and Defendants
12
Nora Carrillo and Robert Salazar, and the facts and circumstances herein alleged, the
13
14 Defendants owed to the Plaintiff a fiduciary duty, and by virtue of the Plaintiff having
15 placed confidence in the fidelity and integrity of the Defendants Nora Carrillo and Robert
16
Salazar, a confidential relationship existed at all times herein mentioned between the
17
18 Plaintiff and Defendants Nora Carrillo and Robert Salazar.
19 36. Despite having voluntarily accepted the trust and confidence reposed in
20
Defendants Nora Carrillo and Robert Salazar by Plaintiff that the Subject Property
21
22 belonged to him and that the undivided one-half (1/2) interest in the Subject Property
23 vested in the name of Defendant Robert Salazar and now held by Defendant Nora
24
Carrillo, and in violation of this relationship of trust and confidence, the Defendants Nora
25
Carrillo and Robert Salazar abused the trust and confidence of the Plaintiff by refusing to
26
ee 27 convey the undivided one-half (1/2) interest in the Subject Property previously vested in
nae?
28
= the name of Defendant Robert Salazar and now held by Defendant Nora Carrillo.
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Complaint for Constructive Trust
@ @
WHEREFORE, Plaintiff prays judgment against defendant as follows:
On the First and Second Causes of Action:
1 For an order declaring that Defendant Nora Carrillo holds an undivided
one-half (1/2) interest in the Subject Property in trust for Plaintiff;
2. For an order compelling Defendant Nora Carrillo to convey to Plaintiff the
undivided one-half (1/2) interest in the Subject Property previously vested in the name of
Defendant Robert Salazar and now held by Defendant Nora Carrillo;
10 On the Third Cause of Action:
1
3 For general damages in an amount according to proof at trial;
12
4 For special damages in an amount according to proof at trial;
13
14 5 For punitive damages in an amount appropriate to punish the Defendants
15 and deter others from engaging in similar misconduct;
16
On the Fourth Cause of Action:
17
18 6. For general damages in an amount according to proof at trial;
19 7 For special damages in an amount according to proof at trial;
20
On all Causes of Action:
21
22 For costs of suit incurred herein; and
23 For such other and further relief as the court deems proper.
24
Law Offices of Raul M. Montes,
25 A Professional Corporation
26
eg
27 Dated: September 5, 2018 by: Lid be Deen
tes Raul M. Montes,
ier 28
Attorney for Armando Salazar
Ine
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Complaint for Constructive Trust
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VERIFICATION
I, Armando Salazar, declare:
I have read the foregoing COMPLAINT FOR CONSTRUCTIVE
TRUST AND FRAUD and know the contents thereof. The same is true of my own
knowledge, except as to those matters which are therein alleged on information and
belief, and as to those matters, I believe it to be true.
I declare under penalty of perjury under the laws of the State of California that the
10 foregoing is true and correct.
We
11 Dated: September 5, 2018
12
13 Armando Salazar
14
15
16
17
18
19
20
21
22
23
24
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Complaint for Constructive Trust
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This page is part of your document - DO NOT DISCARD &
“OF. 105 >
20091951279
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Recorded/Fileg In Official Records
Recorder's Office, Los Angeles County,
California
SAtirons> 12/22/09 hT 02:54PM
FEES: 16 00
‘TAXES 0,00
0 00
PAID: 16.00
AANA | | I | | | | UTC LEADSHEET
IMAI | | | | tl 200912220050023
00001685126
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- Counter (Hard Copy)
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023s
THIS FORM IS NOT TO BE DUPLICATED a
Non-Order Search Page 8 of 23 = By: Mary Linegerger , Printed: 4/12/2017 5:01 PM
Doe: 2009-1951279 DED 12-22-2009
@ -
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RECORDING REQUESTED BY:
4
PTO
“AND WHEN RECORDED MAIL TO: 12/22/2009
FELA SALAZAR
2736 Earle Aveaue
Rosemead, CA 91770
"20091951279"
AP. . 528 3-003" ‘O16 (SPACE ABOVE THIS LINE IS FOR RECORDER'S USE)
GRANT DEED
THE UNDERSIGNED GRANTOR(S) DECLARE(S) that documentary transfer tax is}$ 00 (County) $.00 (City) No Consideration
( ) computed on full value of property conveyed, or
( ) computed on full value less flens or encumbrances remaining at time of sale
(X) City of Rosemead
FOR A VALUABLE CONSIDERATION, receipt of which is hereby acknowledged, Fela Salazar, a Widow and
Armando Salazar, an Unmarried Man as Joint Tenants
hereby GRANT(S) to Fela Salazar, a Widow and Armando Salazar, an Unmarrled Man and Robert Salazar,
a Single Man all as Joint Tenants
the following described real property in the City of Rosemead, County of Los Angeles, State of California
Lot 63 of Tract 5242 as per map recorded in Book 56 Page 77 of Maps, in the Office of the County
Recorder of sald County.
"This is a bonafide gift and the grantor received nothing In return, R&T 11911.”
Dated: Nox
Fela Salazar
\ 2009
q
RIS Armando Salazar
V7
STATE OF Cauigorn ir
COUNTY OF
on Marq Nery
_L.d.
2005 BEFORE me Qreeres Zimmse:
Tt Tame and
mMadal
title OF tlfreonidery
can Tepe me
.
personally appeared Fern Sacazad, LrAAN OO KRAZAR —
Personally known to me (or proved to me on the basis of 7sanstactory evidence) to be the person(s) whose name(s) is/are subscribed to the
within instrument and acknowledged to me that he/she/they executed the same in his/her/their authorized capacltyties), and that by
the person(s) or the entity upon behalf of which the person(s) acted, executed the instrument
his/her/their signature(s) on the instrument
WITNESS my
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Signature
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WOWIT PRK
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tg ComeyMoy 207
18 2000
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Grant Need (258) 19-05 MATL TAX STATEMENTS AS DIRFCTED ABOVE
Non-Order Search Page 9 of 23 Requested By: Mary Linegerger , Printed: 4/12/2017 5:01 PM
Doe: 2009-1951279 DED 12-22-2009
_—
State of California
County of Loz Aasoeuss
on_Max 1, 2004 before me, Cina E> Q lLrmermoaa>, Nop ent Petes
‘(nsett Namy of Notary Publis
and TWe)
personally appeared_Cera Sarazac, Jom Pagid. LAZA Fe,
who proved to me on the basis of satisfactory evidence to be the person(s) whose
name(s) is/are subscribed to the within instrument and acknowledged to me that
he/she/they executed the same in his/her/thelr authorized capacity(les), and that by
hisfherithelr signature(s) on the instrument the person(s), or the entity upon behalf of
which the person(s) acted, executed the Instrument.
\ certify under PENALTY OF PERJURY under the laws of the State of California that the
foregoing paragraph is true and correct.
7"
L yy CHASLCS ZIMMERMANN:
Comm, # 1578437
WITNESS
(y oe NOTARY PUBLIC
Otor
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ind and official seal. a ay Commtsp te 1, ay
CHARLES 78" ue
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Signature (Seal) ‘or
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Non-Order Search Page 10 of 23 Requested By: Mary Linegerger , Printed: 4/12/2017 5:01 PM
Doe: 2009-1951279 DED 12-22-2009
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EXHIBIT 2
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A
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Res orders Ofte, LoeAngeles Coury,
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THIS FORM IS NOT TO BE DUPLIC A ED ; l
By:
|
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RECORDING REQUESTED BY
“Laurenge E, Clark
.
NAME
MAILING
AODRESS
WHEN RECORDED MAIL TO
Fela
2736
Salazar
Earle Avenue
iN i
*2012061120 1
cry, stare Rosemead, CA 91770
ZIP CODE
SPACE ABOVE THIS LINE RESERVED FOR RECORDER'S USE
TITLE(S)
Grant Deed
KBR.
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= IS” 15.201
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Non-Order Search
Page 12 of 23 Requested By: Mary Linegerger , Printed: 4/12/2017 5:01 PM
Doe: 2012-611201 DED 04-25-2012
. ee. ‘
@
: RECORDING REQUESTED BY
JLaurance E. Clark
‘
AND WHEN RECORDED MAIL DOCUMENT AND.
‘TAX STATEMENT TO:
NAME Fela Salazar
street 2736 Earle Avenue
AGQDRESS
R u PAGE | SIZE OA MISC | LONG | RFD COPY
ciry, state & Rosemead, CA 91770
ZIP CODE
A L 465 426 | PCOR | NCOR| SMF | NCHG eae
TITLE ORDER NO,
ESCROW NO, Tt: cry UNL
‘SPACE ABOVE THIS LINE FOR RECORDER'S USE ONLY
GRANT DEED The undersigned grantor(s) declare(s)
TRA: DOCUMENTARY TRANSFER TAX $ ZERO
co computed on full value of property conveyed, or
APN: 5283-003-010 computed on full value fess liens and encumbrances remaining at time of sale,
Unincorporated Area Cityot Rosemead
FOR VALUABLE CONSIDERATION, receipt of which is hereby acknowledged,
| (We) Eela Salazar, a Widow
(NAME OF GRANTOR(S))
hereby remise, rele
andase
grantto Fela Salazar, Trustee of The Fela Salazar Revocable
Living Trust dated April /4 20/2. as to her i/3 interest
(NAME OF GRANTEE(S)) in the
the following described real property in the Cityof Roseme
ad County of Los Angeles '
State of California :
(Insert Legal Description)
Lot 63 of Tract 5242 as per Map recorded in Book 56
Page 77 of Maps, in the
office of the County Recorder of said County
.
Commonly known as: 2736 Earle Avenue, Rosem
ead, CA 91770
“This conveyance transfers an interest into
a Living Trust, R & T 11930",
oatdint 7/2. bre yee
Fela Salazar
STATE OF CALIFORNIA
COUNTYOF Los Angeles }
}
On April J 1, 2012. before me, S plic
{hero wiser name and inte ofthe at icor) i personally appeared
FELA_ SALAZAR
who proved to me on the basis of sallsfaciory evidence to be
the Ms) whose: (s) subscribed to the within instrument
nowledged to me that hegShG/they executed the same in hist feheir authorized
1) on the instrument the ersonjs), ‘or the entity upon apackh les), and thet by hi it
behalf of which the @@rsgmts) acted, executed the instrument,
‘certify under PENALTY OF PERJURY under the laws of the
State of California that the foregoing pai graph Is true and correct,
WITNESS my han
‘SUE HASSELER
‘Bignature
(SEAL) COMM. # 1628011
ak
i Sue dsseler NOTARY PUBLIC, CALIFORN!
= ‘108 ANGELES COUNTY
My Camo, Expires Jan t 2019
Sue Hesnoter, Ne, CNSA
MAIL TAX STATEMENT AS DIRECTED ABOVE
Comm Exp atte RIAA
Or
Non-Order Search
Page 13 of 23
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HS state e ‘pest att Assiovied FILED Raul M. Montes, State Bar No. 1011 Su; rior Court of California ‘ounty of Los Angeles Law Offices of Raul M. Montes, A Professional Corporation SEP 07 2018 650 Sierra Madre Villa Ave., Suite 304 oO, Pasadena, California 91107-2071 OticenClark of Court Deputy &: Telephone: (626) 515-7011 Attorneys for Armando Salazar fs SUPERIOR COURT OF THE STATE OF CALIFORNIA 10 FOR THE COUNTY OF LOS ANGELES 1 12 ARMANDO SALAZAR, Case No. BC720688 13 Plaintiff, VERIFIED COMPLAIN REDS ft co me Pa se CONSTRUCTIVE Rami 14 39 VS. TRUST AND FRAUD? Been 8 22zs TO 15 GZxr G. 16 NORA CARRILLO; ROBERT WSO ae oo SALAZAR AND DOES 1 TO 20 =]a eS 17 Ba inclusive oo a 18 of Defendants. 19 oe et ago a ws 20 boas Plaintiff, Armando Salazar, alleges o6aoo o 21 22 FIRST CAUSE OF ACTION (Constructive Trust — Breach of Confidential Relationship) 23 Against Defendants Nora Carrillo and Does Ito 10 24 1 Defendant Nora Carrillo is at all times herein mentioned was, a resident of 25 County of Los Angeles, California. 26 ee. 27 2. Defendant Robert Salazar is at all times herein mentioned was, a resident of se! 28 County of Los Angeles, California ee Oe 1 Complaint for Constructive Trust Fe e e 3 Plaintiff is ignorant of the true names and capacities of the defendants sued herein as DOES 1 to 20, inclusive, and therefore sues these defendants by such fictitious names. Plaintiff will amend this complaint to allege their true names and capacities when ascertained. Plaintiff is informed and believes and thereon alleges that each of the fictitiously named defendants is responsible in some manner for the occurrences herein alleged and that Plaintiff's damages as herein alleged were proximately caused by such defendants. 10 4 Plaintiff is informed and believes and thereon alleges that, at all times 1 herein mentioned, defendants DOES 1 to 20, inclusive, were the agents and employees of 12 each of the other defendants, and in doing the things herein alleged were acting within the 13 14 course and scope of such agency and employment and with the permission and consent of 15 his/her codefendant. 16 5 The real property which is the subject of this complaint (herein referred to 17 18 as the “Subject Property”) is commonly known as 2736 Earle Ave., located in the City of 19 Rosemead, County of Los Angeles, State of California, and is legally described as 20 follows: 21 22 LOT 63 OF TRACT 5242 AS PER MAP RECORDED IN BOOK 56 PAGE 77 OF MAPS, IN THE OFFICE OF THE COUNTY RECORDER OF SAID 23 COUNTY. 24 APN: 5283-003-010 25 26 6 The Subject Property was initially acquired by Fela Salazar and her wR. 27 predeceased husband, Armando G. Salazar, as their family residence. Plaintiff and net 28 er a - me 2 Complaint for Constructive Trust e e Defendants Nora Carrillo and Robert Salazar are children of Fela Salazar and her predeceased husband. 7 At all relevant times herein mentioned, it was the desire and intent of Fela Salazar to leave the Subject Property to either Plaintiff and or Robert Salazar to be used as their residence. The Subject Property became vested in the names of Fela Salazar, a widow, and Armando Salazar, an unmarried man and Robert Salazar, a single man all as joint tenants pursuant to a Grant Deed dated May 1, 2009. A true and correct copy of the 10 Grant Deed dated May 1, 2009 that was recorded on December 22, 2009, as Instrument 11 No. 20091951279 with the Los Angeles County Recorder’s Office is attached hereto as 12 Exhibit 1 and incorporated herein by reference. The vesting of the Subject Property in 13 14 names of Fela Salazar’s two sons, Plaintiff Armando Salazar and Defendant Robert 15 Salazar was a gift made without consideration. 16 8 As part of her estate planning, Fela Salazar by Grant Deed dated April 19, 17 18 2012 subsequently conveyed her remaining one-third (1/3) interest in the Subject 19 Property to Fela Salazar, Trustee of the Fela Salazar Revocable Living Trust dated April 20 19, 2012 (hereinafter referred to as the “Trust”). A true and correct copy of the Grant 21 22 Deed Dated April 19, 2012 that was recorded on April 25, 2012, as Instrument No. 23 20120611201 with the Los Angeles County Recorder’s Office is attached hereto as 24 Exhibit 2 and incorporated herein by reference. 25 9 Pursuant to the terms of the Trust, upon her death, Fela Salazar’s interest in 26 27 the Subject Property was to be distributed in equal shares to her two sons, Plaintiff neh at 28 Armando Salazar and Defendant Robert Salazar. Is a i on 3 Complaint for Constructive Trust e e 10. In September 2012, in the weeks prior to the death of Fela Salazar, Defendant Robert Salazar stated to his mother, Fela Salzar, in the presences of Plaintiff Armando Salazar and Defendant Nora Carrillo, that he did not want any interest in the Subject Property. At that time, Defendant Robert Salazar represented and promised both his mother, Fela Salazar and to Plaintiff, that Defendant Robert Salazar would sign a deed to relinquish any interest in the Subject Property to Plaintiff Armando Salazar in accordance with the express wishes of their mother Fela Salazar. 10 11. Within approximately one or two weeks after Defendant Robert Salazar’s 11 representations and promises as herein alleged, Fela Salazar died on or about September 12 27,2012. Defendant Robert Salazar had failed to sign a deed to relinquish any interest 13 14 in the Subject Property as he had represented and promised. At the time of Fela Salazar’s 15 death, the Subject Property remained vested in the Trust, Plaintiff and Defendant Robert 16 Salazar, each as to an undivided one-third (1/3) interest. 17 18 12. Subsequent to the death of Fela Salazar, Defendant Robert Salazar 19 reaffirmed his representations and promises to Plaintiff that he, Defendant Robert 20 Salazar, had no interest in the Subject Property, that he would sign a deed to convey his 21 22 interest in the Subject Property to Plaintiff, and that Subject Property belonged to 23 Plaintiff. 24 13. At all relevant times herein mentioned, subsequent to the death of Fela 25 Salazar, Defendant Nora Carrillo acknowledged and represented to Plaintiff that the 26 re eat. 27 Subject Property belonged to Plaintiff Armando Salazar pursuant to their mother’s 28 expressed wishes. er oe 4 Complaint for Constructive Trust BC e e 14. At all relevant times mentioned herein, Plaintiff reposed trust and confidence in his brother Defendant Robert Salazar and his sister Defendant Nora Carrillo. By virtue of the parties’ familial relationship, and by virtue of the Plaintiff having placed confidence in the fidelity and integrity of the Defendants Nora Carrillo and Robert Salazar entrusting Defendants to fulfill their mother’s expressed wishes to transfer ownership of Defendant Robert Salazar’s interest in the Subject Property to Plaintiff and entrusting Defendant Robert Salazar’s representations and promises to do so, entrusting 10 Defendant Nora Carrillo’ representations and promises made subsequent to Fela Salazar’s 11 death that the Subject Property belonged to Plaintiff, a confidential relationship existed at 12 all times herein mentioned between Plaintiff and Defendants Nora Carrillo and Robert 13 14 Salazar. 15 15. Subsequently, by Grant Deed dated May 10, 2013, Nora Carrillo, as 16 successor Trustee of the Trust, distributed the Trust’s one-third (1/3) interest in the 17 18 Subject Property to Plaintiff and Defendant Robert Salazar, resulting in the vesting of the 19 Subject Property in the names of Plaintiff and Defendant Robert Salazar, each as to an 20 undivided one-half (1/2) interest. A true and correct copy of the Grant Deed Dated May 21 22 10, 2013 that was recorded on May 23, 2013, as Instrument No. 20130775933, with the 23 Los Angeles County Recorder’s Office is attached hereto as Exhibit 3 and incorporated 24 herein by reference. 25 16. Subsequent to the distribution of Trust’s one-third (1/3) interest in the 26 iat 27 Subject Property to Plaintiff and Defendant Robert Salazar, Defendant Robert Salazar ae? tor 28 continued to reaffirm his representations and promises to Plaintiff that the Subject sat opt: 5 Complaint for Constructive Trust . e e Property belonged to Plaintiff and that Defendant Robert Salazar would sign a deed transferring his interest in the Subject Property to Plaintiff. 17. Subsequent to the distribution of Trust’s one-third (1/3) interest in the Subject Property to Plaintiff and Defendant Robert Salazar, Defendant Nora Carrillo continued to reaffirm her representations and promises to Plaintiff that the Subject Property belonged to Plaintiff and that she would pursue the conveyance of Defendant Robert Salazar’ interest in the Subject Property to Plaintiff. 10 18. At all relevant times mentioned herein, Plaintiff was justified in relying on 11 the representations and promises by both Defendants Nora Carrillo and Robert Salazar 12 that the Subject Property belonged to Plaintiff and that Defendant Robert Salazar’s 13 14 interest in the Subject Property would be conveyed to Plaintiff. 15 19. In reliance on the representations and promises by both Defendants Nora 16 Carrillo and Robert Salazar, Plaintiff expressed his intentions to Defendants Nora Carrillo 17 18 and to Robert Salazar to invest substantial funds in renovating, remodeling and 19 improving the Subject Property. Both Defendants Nora Carrillo and Robert Salazar, in 20 response, expressly reaffirmed to Plaintiff that the Subject Property was his property and 21 22 encouraged Plaintiff to expend funds to renovate, remodel and improve the Subject 23 Property. 24 20. In reliance on the representations and promises of both Defendants Nora 25 Carrillo and Robert Salazar, Plaintiff expended more than $135,000 to renovate, remodel 26 st 27 and improve the Subject Property. Further, in reliance on the representations and 5a - 28 ee promises of both Defendants Nora Carrillo and Robert Salazar, Plaintiff Armando Salazar pot! Bb 6 Complaint for Constructive Trust e e did not seek contribution for property taxes, insurance and repairs and maintenance for the Subject Property. 21. Unbeknownst to Plaintiff, by Grant Deed dated October 22, 2014, Defendant Robert Salazar conveyed his interest in the Subject Property to Defendant Nora Carrillo. Plaintiff is informed and believes and thereon alleges that in an effort to suppress the fact of the conveyance, the Grant Deed dated October 22, 2014 was not recorded until almost one (1) year later, on September 11, 2015. A true and correct copy 10 of the Grant Deed Dated October 22, 2014, that was recorded on September 11, 2015, as 11 Instrument No. 20151129042, with the Los Angeles County Recorder’s Office is attached 12 hereto as Exhibit 4 and incorporated herein by reference. Plaintiff did not discover the 13 14 existence of the Grant Deed dated October 22, 2014 until a period within the last three 15 years from the date of this Complaint. 16 22. Upon discovery of the conveyance of Defendant Robert Salazar’s interest 17 18 in the Subject Property to Defendant Nora Carrillo, Defendant Nora Carrillo expressly 19 represented and promised to Plaintiff that the Subject Property belonged to him and that 20 she would convey to Plaintiff the interest she acquired from Defendant Robert Salazar. 21 22 23. In March 2018, in violation of the confidential relationship, Defendant 23 Nora Carrillo stated that she would not transfer the Subject Property to Plaintiff. Plaintiff 24 Armando Salazar made demand upon Defendant Nora Carrillo to convey the undivided 25 one-half interest in the Subject Property presently vested in her name to him. Defendant 26 ae 27 Nora Carrillo refused and continues to refuse to do so. sab ia 28 pet eo ioe 7 Complaint for Constructive Trust e e 24. Plaintiff is informed and believes and thereon alleges that at all relevant times, Defendants acted in concert and conspired against Plaintiff in an effort to retain ownership of an undivided one-half (1/2) interest in the Subject Property to induce Plaintiff to expend funds to renovate, remodel and improve the Subject Property and without any contribution for taxes, insurance, and repairs and maintenance. 25. By virtue of Defendant Nora Carrillo’s violation of the relationship of trust and confidence then existing between Plaintiff and Defendant Nora Carrillo, Defendant 10 Nora Carrillo holds the Subject Property as a constructive trustee for Plaintiff’s benefit. 11 SECOND CAUSE OF ACTION 12 (Constructive Trust — Constructive Fraud) Against Defendants Nora Carrillo and Does 1 to 10 13 14 26. Plaintiff refers to and herein incorporates Paragraphs 1 through 24 of the 15 First Cause of Action. 16 27. By virtue of her fraudulent acts, Defendant Nora Carrillo holds the Subject 17 18 Property as a constructive trustee for Plaintiff’s benefit. 19 THIRD CAUSE OF ACTION 20 (Fraud) Against All Defendants 21 22 28. Plaintiff refers to and herein incorporates Paragraphs 1 through 24 of the 23 First Cause of Action. 24 29. At the time the Defendants Nora Carrillo and Robert Salazar made the 25 promises herein alleged to the Plaintiff, the Defendants had no intention of performing 26 ae 27 them. 6gh 28 ie er = io 8 Complaint for Constructive Trust e e 30. The promises made by Defendants that the Subject Property belonged to Plaintiff and that they would convey the Subject Property to Plaintiff were made, in part, to induce the Plaintiff to expend more than $135,000 to renovate, remodel and improve the Subject Property and to avoid any contribution for the Subject Property’s taxes, insurance, and repairs and maintenance. 31. The Plaintiff, at the time this promise was made and at the time the Plaintiff took the actions herein alleged, was ignorant of the Defendants’ secret intention not to 10 perform and the Plaintiff could not, in the exercise of reasonable diligence, have 11 discovered the Defendants’ secret intentions. In reliance on the promises of the 12 Defendants, the Plaintiff expend more than $135,000 to renovate, remodel and improve 13 14 the Subject Property and did not request or seek any contribution for the Subject 15 Property’s taxes, insurance, and repairs and maintenance. If the Plaintiff had known of 16 the actual intention of the Defendants, the Plaintiff would not have taken such action. 17 18 32. As a proximate result of the fraudulent conduct of the Defendants as herein 19 alleged, the Plaintiff was induced to expend more than $135,000 to renovate, remodel and 20 improve the Subject Property and did not request or seek any contribution for the Subject 21 22 Property’s taxes, insurance, and repairs and maintenance and has not received the 23 undivided one-half (1/2) interest in the Subject Property previously vested in the name of 24 Defendant Robert Salazar and now held by Defendant Nora Carrillo, by reason of which 25 the Plaintiff has been damaged in an amount according to proof at trial. 26 27 33. The aforementioned conduct of the Defendants was an intentional at Int 28 ae misrepresentation, deceit, or concealment of a material fact known to the Defendants with ae iY = oe 9 Complaint for Constructive Trust . e e the intention on the part of the Defendants of thereby depriving the Plaintiff of property or legal rights or otherwise causing injury, and was despicable conduct that subjected the Plaintiff to a cruel and unjust hardship in conscious disregard of the Plaintiff's rights, so as to justify an award of exemplary and punitive damages. FOURTH CAUSE OF ACTION (Constructive Fraud) Against All Defendants 34. Plaintiff refers to and herein incorporates Paragraphs 1 through 24 of the 10 First Cause of Action and Paragraphs 30 through 32 of the Third Cause of Action. 11 35. By virtue of the familial relationship between Plaintiff and Defendants 12 Nora Carrillo and Robert Salazar, and the facts and circumstances herein alleged, the 13 14 Defendants owed to the Plaintiff a fiduciary duty, and by virtue of the Plaintiff having 15 placed confidence in the fidelity and integrity of the Defendants Nora Carrillo and Robert 16 Salazar, a confidential relationship existed at all times herein mentioned between the 17 18 Plaintiff and Defendants Nora Carrillo and Robert Salazar. 19 36. Despite having voluntarily accepted the trust and confidence reposed in 20 Defendants Nora Carrillo and Robert Salazar by Plaintiff that the Subject Property 21 22 belonged to him and that the undivided one-half (1/2) interest in the Subject Property 23 vested in the name of Defendant Robert Salazar and now held by Defendant Nora 24 Carrillo, and in violation of this relationship of trust and confidence, the Defendants Nora 25 Carrillo and Robert Salazar abused the trust and confidence of the Plaintiff by refusing to 26 ee 27 convey the undivided one-half (1/2) interest in the Subject Property previously vested in nae? 28 = the name of Defendant Robert Salazar and now held by Defendant Nora Carrillo. Pet ‘ER ioe 10 Complaint for Constructive Trust @ @ WHEREFORE, Plaintiff prays judgment against defendant as follows: On the First and Second Causes of Action: 1 For an order declaring that Defendant Nora Carrillo holds an undivided one-half (1/2) interest in the Subject Property in trust for Plaintiff; 2. For an order compelling Defendant Nora Carrillo to convey to Plaintiff the undivided one-half (1/2) interest in the Subject Property previously vested in the name of Defendant Robert Salazar and now held by Defendant Nora Carrillo; 10 On the Third Cause of Action: 1 3 For general damages in an amount according to proof at trial; 12 4 For special damages in an amount according to proof at trial; 13 14 5 For punitive damages in an amount appropriate to punish the Defendants 15 and deter others from engaging in similar misconduct; 16 On the Fourth Cause of Action: 17 18 6. For general damages in an amount according to proof at trial; 19 7 For special damages in an amount according to proof at trial; 20 On all Causes of Action: 21 22 For costs of suit incurred herein; and 23 For such other and further relief as the court deems proper. 24 Law Offices of Raul M. Montes, 25 A Professional Corporation 26 eg 27 Dated: September 5, 2018 by: Lid be Deen tes Raul M. Montes, ier 28 Attorney for Armando Salazar Ine at on ll Complaint for Constructive Trust . e @ VERIFICATION I, Armando Salazar, declare: I have read the foregoing COMPLAINT FOR CONSTRUCTIVE TRUST AND FRAUD and know the contents thereof. The same is true of my own knowledge, except as to those matters which are therein alleged on information and belief, and as to those matters, I believe it to be true. I declare under penalty of perjury under the laws of the State of California that the 10 foregoing is true and correct. We 11 Dated: September 5, 2018 12 13 Armando Salazar 14 15 16 17 18 19 20 21 22 23 24 25 26 ‘ 27 ~ 28 wee ne ae bo on 12 Complaint for Constructive Trust @ ‘Sh Ka? to Pat Be er i EXHIBIT 1 @ 1 This page is part of your document - DO NOT DISCARD & “OF. 105 > 20091951279 2 {aaa ean) a i I l il | | | I | | | Il ll a Recorded/Fileg In Official Records Recorder's Office, Los Angeles County, California SAtirons> 12/22/09 hT 02:54PM FEES: 16 00 ‘TAXES 0,00 0 00 PAID: 16.00 AANA | | I | | | | UTC LEADSHEET IMAI | | | | tl 200912220050023 00001685126 IAA SEQ 01 - Counter (Hard Copy) wu NA il ORCA til A Sk: 023s THIS FORM IS NOT TO BE DUPLICATED a Non-Order Search Page 8 of 23 = By: Mary Linegerger , Printed: 4/12/2017 5:01 PM Doe: 2009-1951279 DED 12-22-2009 @ - . qe RECORDING REQUESTED BY: 4 PTO “AND WHEN RECORDED MAIL TO: 12/22/2009 FELA SALAZAR 2736 Earle Aveaue Rosemead, CA 91770 "20091951279" AP. . 528 3-003" ‘O16 (SPACE ABOVE THIS LINE IS FOR RECORDER'S USE) GRANT DEED THE UNDERSIGNED GRANTOR(S) DECLARE(S) that documentary transfer tax is}$ 00 (County) $.00 (City) No Consideration ( ) computed on full value of property conveyed, or ( ) computed on full value less flens or encumbrances remaining at time of sale (X) City of Rosemead FOR A VALUABLE CONSIDERATION, receipt of which is hereby acknowledged, Fela Salazar, a Widow and Armando Salazar, an Unmarried Man as Joint Tenants hereby GRANT(S) to Fela Salazar, a Widow and Armando Salazar, an Unmarrled Man and Robert Salazar, a Single Man all as Joint Tenants the following described real property in the City of Rosemead, County of Los Angeles, State of California Lot 63 of Tract 5242 as per map recorded in Book 56 Page 77 of Maps, in the Office of the County Recorder of sald County. "This is a bonafide gift and the grantor received nothing In return, R&T 11911.” Dated: Nox Fela Salazar \ 2009 q RIS Armando Salazar V7 STATE OF Cauigorn ir COUNTY OF on Marq Nery _L.d. 2005 BEFORE me Qreeres Zimmse: Tt Tame and mMadal title OF tlfreonidery can Tepe me . personally appeared Fern Sacazad, LrAAN OO KRAZAR — Personally known to me (or proved to me on the basis of 7sanstactory evidence) to be the person(s) whose name(s) is/are subscribed to the within instrument and acknowledged to me that he/she/they executed the same in his/her/their authorized capacltyties), and that by the person(s) or the entity upon behalf of which the person(s) acted, executed the instrument his/her/their signature(s) on the instrument WITNESS my oe bt Signature ia cond IsTu4s? i WOWIT PRK i et omshapbet tg ComeyMoy 207 18 2000 1 tea area for offical notary seal) fet er i oe Grant Need (258) 19-05 MATL TAX STATEMENTS AS DIRFCTED ABOVE Non-Order Search Page 9 of 23 Requested By: Mary Linegerger , Printed: 4/12/2017 5:01 PM Doe: 2009-1951279 DED 12-22-2009 _— State of California County of Loz Aasoeuss on_Max 1, 2004 before me, Cina E> Q lLrmermoaa>, Nop ent Petes ‘(nsett Namy of Notary Publis and TWe) personally appeared_Cera Sarazac, Jom Pagid. LAZA Fe, who proved to me on the basis of satisfactory evidence to be the person(s) whose name(s) is/are subscribed to the within instrument and acknowledged to me that he/she/they executed the same in his/her/thelr authorized capacity(les), and that by hisfherithelr signature(s) on the instrument the person(s), or the entity upon behalf of which the person(s) acted, executed the Instrument. \ certify under PENALTY OF PERJURY under the laws of the State of California that the foregoing paragraph is true and correct. 7" L yy CHASLCS ZIMMERMANN: Comm, # 1578437 WITNESS (y oe NOTARY PUBLIC Otor a ind and official seal. a ay Commtsp te 1, ay CHARLES 78" ue 1 Signature (Seal) ‘or Na 5 v 13, 2000) - (St seb ACK PARA WP OP [Rev 0808) =ra: ioe: Non-Order Search Page 10 of 23 Requested By: Mary Linegerger , Printed: 4/12/2017 5:01 PM Doe: 2009-1951279 DED 12-22-2009 Oe mm sat aR EXHIBIT 2 @ & This page is part of yourdocument -*DO NOT DISCARD A GES 201206112 mot wna Pages Res orders Ofte, LoeAngeles Coury, “ES ALPORN 04/25/12rehr 10:52AM AOA AAA 00005706119 ENE SEQ 01 DAR - Mail (Hard Copy) A AIOE THIS FORM IS NOT TO BE DUPLIC A ED ; l By: | D RECORDING REQUESTED BY “Laurenge E, Clark . NAME MAILING AODRESS WHEN RECORDED MAIL TO Fela 2736 Salazar Earle Avenue iN i *2012061120 1 cry, stare Rosemead, CA 91770 ZIP CODE SPACE ABOVE THIS LINE RESERVED FOR RECORDER'S USE TITLE(S) Grant Deed KBR. wee rae o pee = IS” 15.201 on Non-Order Search Page 12 of 23 Requested By: Mary Linegerger , Printed: 4/12/2017 5:01 PM Doe: 2012-611201 DED 04-25-2012 . ee. ‘ @ : RECORDING REQUESTED BY JLaurance E. Clark ‘ AND WHEN RECORDED MAIL DOCUMENT AND. ‘TAX STATEMENT TO: NAME Fela Salazar street 2736 Earle Avenue AGQDRESS R u PAGE | SIZE OA MISC | LONG | RFD COPY ciry, state & Rosemead, CA 91770 ZIP CODE A L 465 426 | PCOR | NCOR| SMF | NCHG eae TITLE ORDER NO, ESCROW NO, Tt: cry UNL ‘SPACE ABOVE THIS LINE FOR RECORDER'S USE ONLY GRANT DEED The undersigned grantor(s) declare(s) TRA: DOCUMENTARY TRANSFER TAX $ ZERO co computed on full value of property conveyed, or APN: 5283-003-010 computed on full value fess liens and encumbrances remaining at time of sale, Unincorporated Area Cityot Rosemead FOR VALUABLE CONSIDERATION, receipt of which is hereby acknowledged, | (We) Eela Salazar, a Widow (NAME OF GRANTOR(S)) hereby remise, rele andase grantto Fela Salazar, Trustee of The Fela Salazar Revocable Living Trust dated April /4 20/2. as to her i/3 interest (NAME OF GRANTEE(S)) in the the following described real property in the Cityof Roseme ad County of Los Angeles ' State of California : (Insert Legal Description) Lot 63 of Tract 5242 as per Map recorded in Book 56 Page 77 of Maps, in the office of the County Recorder of said County . Commonly known as: 2736 Earle Avenue, Rosem ead, CA 91770 “This conveyance transfers an interest into a Living Trust, R & T 11930", oatdint 7/2. bre yee Fela Salazar STATE OF CALIFORNIA COUNTYOF Los Angeles } } On April J 1, 2012. before me, S plic {hero wiser name and inte ofthe at icor) i personally appeared FELA_ SALAZAR who proved to me on the basis of sallsfaciory evidence to be the Ms) whose: (s) subscribed to the within instrument nowledged to me that hegShG/they executed the same in hist feheir authorized 1) on the instrument the ersonjs), ‘or the entity upon apackh les), and thet by hi it behalf of which the @@rsgmts) acted, executed the instrument, ‘certify under PENALTY OF PERJURY under the laws of the State of California that the foregoing pai graph Is true and correct, WITNESS my han ‘SUE HASSELER ‘Bignature (SEAL) COMM. # 1628011 ak i Sue dsseler NOTARY PUBLIC, CALIFORN! = ‘108 ANGELES COUNTY My Camo, Expires Jan t 2019 Sue Hesnoter, Ne, CNSA MAIL TAX STATEMENT AS DIRECTED ABOVE Comm Exp atte RIAA Or Non-Order Search Page 13 of 23