On October 22, 2020 a
Complaint,Petition
was filed
involving a dispute between
Taylor, Tyson,
and
Does 1-25,
Work4Good, A California Corporation,
for Unlimited Civil Complaint - Real Property
in the District Court of San Bernardino County.
Preview
1 Law Office ofRobert William Morris
Robert William Morris CSB 165431 E
2 1200 California Street Suite 260
Redlands California
COUNiY OF s N C NARDINCa
SAN BERNAR i cJ lS7RIGT
3 Post Office Box 3018
Lake Arrowhead California 92352 0GT 2 ZpZrQ
4 California State Bar 165431
909 792 6455 1
BY
5
rv JSN I5
Attorney for Plaintiff
6 Tyson Taylor
7
8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 COUNTY OF SAN BERNARDINO SAN BERNARDINO NSTICE CENTER
10 TYSON TAYLOR an individual S y 4 a y 1
t
11 Plaintiff VERIFIED COMPLAINT FOR
1 PRESCRIPTIVE EASEMENT
12 v 2 EQUITABLE EASEMENT
3 QUIET TITLE
13 WORK4GOOD a California corparation 4 DECLARATORY RELIEF
and DOES 1 through 25 Inclusive
14 j
2
n
Defendants
15
16 PLAINTIFF COMPLAINS AND ALLEGES AGAINST DEFENDANT AS FOLLOWS
17 1 Plaintiff TAYLOR TYSON an individual resides int the Unincorporated area of San
18 Bernardino County commonly known as Lake Arrowhead State of California hereinafter referred
19 to as PLAINTIFF
20 2 Defendant WORK4GOOD is a California non profit corporation with its primary business
21 in the City of Los Angeles County of Los Angeles State of California hereinafter referred to as
22 DEFENDANT
23 3 The property at issue in this Complaint is located at 333 Maple Drive in the Unincorporated
24 area of San Bernardino County commonly known as Lake Arrowhead County of San Bernardino
25 State of California with the legal description of Tract 2262 Lot 193 Tract No 2262 Lakeside Tract
26 R Lot 193 hereinafter referred to as the PROPERTY
27 4 T he true names and capacities whether individual corporate associate or otherwise of
28 Defendants DOES 1 through 25 inclusive are unknown to PLAINTIFF who therefore sues the
1
1 Defendants by such fictitious names PLAINTIFF is informed and believes and thereon alleges that
2 each of the Defendants designated herein as a fictitiously named Defendant is in some manner
3 responsible for the events and happenings herein referred to either contractually or tortuously and
4 caused the damage to the PLAINTIFF as herein alleged When PLAINTIFF ascertain the true names
5 and capacities of DOES 1 through 25 inclusive PLAINTIFF will ask leave of this Court to amend
6 his complaint by setting forth such
7 5 PLAINTIFF is further informed and believes and on that basis alleges that all of the
8 Defendants whether named or fictitiously designated were the agents servants officers directors
9 employees partners representatives consultants contractors ancVor joint venturers of the other
10 Defendants and that the acts of each Defendant herein alleged were within the course and scope of
11 his her or its agency service or employment and were done with the permission and consent ofeach
12 other Defendant
13 6 PLAINTIFF is informed and believes and on that basis alleges that each of the Defendants
14 is responsible in some manner deed or action for PLAINTIFF S damages herein alleged
15 FACTS OF CASE
16 7 PLAINTIFF purchased the residence located at 333 Maple Drive in the Unincorporated area
17 of San Bernardino County commonly known as Lake Arrowhead County of San Bernardino State
California 29 2012 hereinafter referred to as the RESIDENCE The
18 of on or about
May
19 RESIDENCE has been PLAINTIFF s only residence since PLAINTIFF purchased the RESIDENCE
20 8 PLAINTIFF received and timely paid each and every property tax bill received from the
21 Office ofthe Assessor for the County of San Bernardino for the RESIDENCE
22 9 Unbeknownst to PLAINTIFF and to PLAINTIFF s surprise DEFENDANT acquired legal
23 title to the PROPERTY via an Office of the Assessor for the County of 5an Bernardino tax sale on
24 May 11 2019 The RESIDENCE is located on two parcels and has been since its construction in
25 1948 A reasonable inspection by DEFENDANT would have revealed that the PROPERTY was not
26 vacant nor has it been vacant since at least 2012 when PLAINTIFF purchased the RESIDENCE
27 10 Unbeknownst to PLAINTIFF the tax bill PLAINTIFF timely paid to the Office of the
28 Assessor for the County of San Bernardino County for 333 Maple Drive was only for one ofthe two
2
Document Filed Date
October 22, 2020
Case Filing Date
October 22, 2020
Category
Unlimited Civil Complaint - Real Property
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
1 Law Office ofRobert William Morris Robert William Morris CSB 165431 E 2 1200 California Street Suite 260 Redlands California COUNiY OF s N C NARDINCa SAN BERNAR i cJ lS7RIGT 3 Post Office Box 3018 Lake Arrowhead California 92352 0GT 2 ZpZrQ 4 California State Bar 165431 909 792 6455 1 BY 5 rv JSN I5 Attorney for Plaintiff 6 Tyson Taylor 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 COUNTY OF SAN BERNARDINO SAN BERNARDINO NSTICE CENTER 10 TYSON TAYLOR an individual S y 4 a y 1 t 11 Plaintiff VERIFIED COMPLAINT FOR 1 PRESCRIPTIVE EASEMENT 12 v 2 EQUITABLE EASEMENT 3 QUIET TITLE 13 WORK4GOOD a California corparation 4 DECLARATORY RELIEF and DOES 1 through 25 Inclusive 14 j 2 n Defendants 15 16 PLAINTIFF COMPLAINS AND ALLEGES AGAINST DEFENDANT AS FOLLOWS 17 1 Plaintiff TAYLOR TYSON an individual resides int the Unincorporated area of San 18 Bernardino County commonly known as Lake Arrowhead State of California hereinafter referred 19 to as PLAINTIFF 20 2 Defendant WORK4GOOD is a California non profit corporation with its primary business 21 in the City of Los Angeles County of Los Angeles State of California hereinafter referred to as 22 DEFENDANT 23 3 The property at issue in this Complaint is located at 333 Maple Drive in the Unincorporated 24 area of San Bernardino County commonly known as Lake Arrowhead County of San Bernardino 25 State of California with the legal description of Tract 2262 Lot 193 Tract No 2262 Lakeside Tract 26 R Lot 193 hereinafter referred to as the PROPERTY 27 4 T he true names and capacities whether individual corporate associate or otherwise of 28 Defendants DOES 1 through 25 inclusive are unknown to PLAINTIFF who therefore sues the 1 1 Defendants by such fictitious names PLAINTIFF is informed and believes and thereon alleges that 2 each of the Defendants designated herein as a fictitiously named Defendant is in some manner 3 responsible for the events and happenings herein referred to either contractually or tortuously and 4 caused the damage to the PLAINTIFF as herein alleged When PLAINTIFF ascertain the true names 5 and capacities of DOES 1 through 25 inclusive PLAINTIFF will ask leave of this Court to amend 6 his complaint by setting forth such 7 5 PLAINTIFF is further informed and believes and on that basis alleges that all of the 8 Defendants whether named or fictitiously designated were the agents servants officers directors 9 employees partners representatives consultants contractors ancVor joint venturers of the other 10 Defendants and that the acts of each Defendant herein alleged were within the course and scope of 11 his her or its agency service or employment and were done with the permission and consent ofeach 12 other Defendant 13 6 PLAINTIFF is informed and believes and on that basis alleges that each of the Defendants 14 is responsible in some manner deed or action for PLAINTIFF S damages herein alleged 15 FACTS OF CASE 16 7 PLAINTIFF purchased the residence located at 333 Maple Drive in the Unincorporated area 17 of San Bernardino County commonly known as Lake Arrowhead County of San Bernardino State California 29 2012 hereinafter referred to as the RESIDENCE The 18 of on or about May 19 RESIDENCE has been PLAINTIFF s only residence since PLAINTIFF purchased the RESIDENCE 20 8 PLAINTIFF received and timely paid each and every property tax bill received from the 21 Office ofthe Assessor for the County of San Bernardino for the RESIDENCE 22 9 Unbeknownst to PLAINTIFF and to PLAINTIFF s surprise DEFENDANT acquired legal 23 title to the PROPERTY via an Office of the Assessor for the County of 5an Bernardino tax sale on 24 May 11 2019 The RESIDENCE is located on two parcels and has been since its construction in 25 1948 A reasonable inspection by DEFENDANT would have revealed that the PROPERTY was not 26 vacant nor has it been vacant since at least 2012 when PLAINTIFF purchased the RESIDENCE 27 10 Unbeknownst to PLAINTIFF the tax bill PLAINTIFF timely paid to the Office of the 28 Assessor for the County of San Bernardino County for 333 Maple Drive was only for one ofthe two 2