INTRODUCTION
Defendant Pal Viczian (“Defendant”) demurs to Plaintiff Judith Tuzson Paal’s entire First Amended Complaint (“FAC”).
Defendant also demurs to the 1st through 7th causes of action in the FAC:
Cancellation of Deed and Quiet Title
Undue Influence
Rescission
Elder Abuse – Welfare & Institutions Code § 15610.30(a)(1)
Conversion
Injunctive Relief
Declaratory Relief
Additionally, Defendant moves to strike the FAC.
ALLEGATIONS
Plaintiff owned real property at 247 Roycroft Avenue in Long Beach, California. The case concerns a joint tenancy grant deed recorded on March 7, 2016, which purports that Plaintiff, for valuable consideration, conveyed a joint tenancy between herself and Defendant. Plaintiff alleges Defendant is not related to her but acted as a “personal chauffer” to Plaintiff and her husband. After the death of Plaintiff’s husband, Defendant continued to act as “a purported chauffer, friend and confidant” to Plaintiff.
The complaint alleges Plaintiff is over
Hearing Date
January 30, 2020
Type
Quiet Title (General Jurisdiction)
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INTRODUCTION
Defendant Pal Viczian (“Defendant”) demurs to Plaintiff Judith Tuzson Paal’s entire First Amended Complaint (“FAC”).
Defendant also demurs to the 1st through 7th causes of action in the FAC:
Cancellation of Deed and Quiet Title
Undue Influence
Rescission
Elder Abuse – Welfare & Institutions Code § 15610.30(a)(1)
Conversion
Injunctive Relief
Declaratory Relief
Additionally, Defendant moves to strike the FAC.
ALLEGATIONS
Plaintiff owned real property at 247 Roycroft Avenue in Long Beach, California. The case concerns a joint tenancy grant deed recorded on March 7, 2016, which purports that Plaintiff, for valuable consideration, conveyed a joint tenancy between herself and Defendant. Plaintiff alleges Defendant is not related to her but acted as a “personal chauffer” to Plaintiff and her husband. After the death of Plaintiff’s husband, Defendant continued to act as “a purported chauffer, friend and confidant” to Plaintiff.
The complaint alleges Plaintiff is over