Complaint,Petition: AJAX 2021-F REO CORP -v- Peralta et al Print

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                                this judicial district.
 2           4.       The true names and legal capacities of the defendants named herein as DOES 1 through
 3   100, inclusive, whether individual, corporate, associate, or otherwise are unknown to Plaintiff, who
 4   therefore sues said defendants, and each of them, by their fictitious names. When the true names and
 5   capacities of the DOE Defendants, or any of them, are ascertained, Plaintiff will seek leave to amend
 6   this complaint to insert the same.
 7           5.       The Defendants herein named as "ALL OTHER PERSONS UNKNOWN, CLAIMING
 8   ANY RIGHT, TITLE, ESTATE, LIEN, OR INTEREST IN THE REAL PROPERTY DESCRIBED IN
 9   THE COMPLAINT, ADVERSE TO PLAINTIFF'S OWNERSHIP INTEREST OR ANY CLOUD ON
10   PLAINTIFF'S RIGHT THERETO" (hereinafter sometimes referred to as the "Unknown Defendants")
11   are unknown to Plaintiff. Plaintiff is informed and believes and thereon alleges that the Unknown
12   Defendants, and each of them, claim some right, title, estate, lien, or interest in the hereinafter described
13   real property adverse to Plaintiffs rights, title and interest in that same real property. Plaintiff names
14   the Unknown Defendants pursuant to Code of Civil Procedure section 762.060(a)
15           6.       Venue for this action is with the Superior Court for the State of California in and for the
16   County of San Bernardino pursuant to Code of Civil Procedure section 760.050, in that the real property
17   that is the subject of this action is located in said county and state.
18           7.      The real property that is the subject of this lawsuit is commonly known as 624 East
19   Ralston Street, Ontario, California 91761 (the "Subject Property"), and is legally described as follows:
20
             THE SOUTH ONE HALF OF LOT 36 OF TRACT NO. 2441, IN THE CITY OF
21           ONTARIO, COUNTY OF SAN BERNARDINO, STATE OF CALIFORNIA, AS PER
             MAP RECORDED IN BOOK 34, PAGE(S) 79, OF MAPS, IN THE OFFICE OF THE
22           COUNTY RECORDER OF SAN BERNARDINO COUNTY.
23           8.      Plaintiff purchased the Property at foreclosure sale that went forward on January 9, 2023,
24   and was the highest bidder at the foreclosure sale, having bid $314,841.93. A Trustee's Deed Upon Sale
25   conveying the Property to Plaintiff was recorded on May 2, 2023, in the San Bernardino County
26   Recorder's Office as Document No. 2023-0106013, and a true and correct copy of the same is attached
27   hereto as Exhibit 1 (the "Plaintiffs Trustee's Deed").
28          9.       The foreclosure went forward pursuant to the terms of a Deed of Trust recorded against


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                                   VERIFIED COMPLAINT FOR QUIET TITLE