COMPLAINT FOR QUIET TITLE

January 4, 2024

XXXXX
Plaintiffs, pro se

SUPERIOR COURT OF THE STATE OF XXXX
COUNTY OF XXXX, CENTRAL DISTRICT

XXXX;

Plaintiffs,

v.

XXXX, LLC, and
XXXXX.
Defendants

Case No.: _____________
[Unlimited Jurisdiction Case]
COMPLAINT FOR QUIET TITLE

COME NOW, plaintiffs XXXX and XXXX
(“Plaintiffs”), based on personal knowledge and on information and belief allege as follows:

INTRODUCTION

1. This action seeks: to quiet title to the subject property.
THE REAL PROPERTY

2. The subject of this action is certain real property in the City of XXXX, County
of XXXX, State of XXXX (hereinafter the “subject property”), described as follows:
Lot 5 IN Block “G” of Arlington, in the City of XXX, County of XXXX
State of XXXX, according to the map thereof number XXX, filed in the Office
of the County Recorder of XXX. COMMOLY
XXXX

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COMPLAINT
PARTIES

3. Plaintiff XXXX (“XXXX”) is an indivdual residing in
the County of XXXX.
4. Plaintiff XXXX(“XXXX”) is an indivdual residing in the County
of San Diego.
5. Defendant XXXt Services, LLC is a Limited Liability Company conducting
business in the County of XXXX, State of XXX.
6. At all relevant times, Defendant XXXXs was a managing member at
Land Grant Services, LLC. He directs, formulates, controls and has knowledge of, and approves
the acts and practices of XXX Services, LLC. Defendant Hutchings is sued individually
and in his capacity as Managing Member.
7. Whenever reference is made in this Complaint to any act of Defendants, that
allegation shall mean that each Defendant acted individually and jointly with the other
Defendants. Accordingly, wherever appearing in this complaint, each and every reference to
Defendants and to any of them, is intended to be and shall be a reference to all Defendants
hereto, and to each of them (“Defendants”).
8. At all relevant times, each Defendant committed the acts, caused others to commit
the acts, ratified the acts, or permitted others to commit the acts alleged in this Complaint.
9. Defendants have engaged in a conspiracy, common enterprise, and common
course of conduct, the purpose of which is and was to engage in the violations of law alleged in
this Complaint. The conspiracy, common enterprise, and common course of conduct continues to
the present.
10. The violations of law alleged in this Complaint occurred in XXXX County and
elsewhere throughout XXXX.

JURISDICTION AND VENUE

11. Jurisdiction, venue, and sub-venue in the above-entitled court are proper as the
basis for this action as a dispute related to real property located in XXXX County, State of

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COMPLAINT

XXXXX. Further, a substantial portion of the wrongs complained of herein, including the
Defendants’ participation in the wrongful acts occurred in this County, and Defendants have
engaged in numerous activities that had an effect in this County.
12. Plaintiff reserves the right to assert additional violations of law as documents and
information related to the transaction(s) are produced in the course of discovery in this action.

FACTUAL ALLEGATIONS

13. Plaintiffs are victims of a foreclosure rescue scam where the Defendants acquire a
grant deed to homes in foreclosure by representing to the grantor that the conveyance is
necessary for Defendants to place the property in a “land grant.” Defendants represented that the
land grant would ensure the grantors ownership rights over their land and protect it against loss
through foreclosure.
14. Plaintiffs have been the beneficial owners of the subject property, which they had
purchased on mortgage.
15. On or about XXXX, the Plaintiffs entered a Grant Deed, in which they
granted the real property to the Defendants. The Defendants had promised the Plaintiffs that they
would avoid foreclosure by deeding the subject property to the Defendant through an alleged
federal land grant.
16. Defendants operate as an equity purchaser .XXXX Civil Code section 1695.1
subdivision (a) defines an equity purchaser as any person who accepts title to any residence in
foreclosure unless title is acquired pursuant to specified exceptions.
17. Defendants also operate as a mortgage foreclosure consultant. In pertinent part,
California Civil Code section 2945.1, subdivision (a) defines a foreclosure consultant as “any
person who makes any solicitation, representation, or offer to any [home] owner to perform for
compensation or who, for compensation, performs any service which the person in any manner
represents will in any manner do [among others] any of the following: (1) Stop or postpone the
foreclosure sale . . . . (8) Save the owner’s residence from foreclosure.”

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COMPLAINT

18. On or about XXXX, an investigation was done and Defendants were charged
with Violations of Business and Professions Code Section 17500 (untrue or misleading
representations), and Violations of Business and Professions Code Section 17200 (Unfair
Competition) 1 .
19. On or about XXXXX, a judgment was issued against the Defendants.
The jury convicted William Jeffrey Hutchings of one count of conspiracy to commit grand theft
(Pen. Code, §182, subd. (a)(1)); 65 counts of grand thef (§ 487, subd. (a)); 41 counts of deceitful
practices by a mortgage foreclosure consultant (Civ. Code, § 2945.4); and 56 counts of rent
skimming (Civ. Code, §§ 890, 892). The jury also found *2 true the special allegations that
Hutchings took funds and property of another with the value exceeding $100,000 (§ 1203.045,
subd. (a)), the aggregate losses from all the charges exceeded $150,000 (§ 12022.6, subd. (a)(2)),
and the charges involved a taking in excess of $500,000, through a pattern of fraud and
embezzlement (§ 186.11, subd. (a)(2)). The court sentenced Hutchings to prison for a term of 46
years, consisting of a two-year base term for the conspiracy conviction, plus 63 consecutive
eight-month terms for his grand theft convictions and two years for the section 186.11,
subdivision (a)(2) enhancement.
20. Hutchings appealed the Trial Court’s decision but the Court of Appeal upheld the
Trial Court’s judgment.
21. On or about or about March 24, 2021, Francisco made a complaint 2 regarding
XXXX (hereinafter “Hutchings”) to the office of the District Attorney, County of
San Diego (hereinafter “D.A’s office”). In the complaint, Francisco stated and provided evidence
that upon release from prison, XXXX his intent to sell the subject property,
which he obtained by fraud through his federal land grant services scam for which he was
convicted.

1 People v. XXXX, D057451 (Cal. Ct. XXXX).
2 Complaint No .XXXX

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COMPLAINT

22. On or about XXXXX, the D.A.’s office sent Francisco a letter regarding
the XXXX complaint against Hutchings. The D.A.’s office stated that the office attempted to
reach out about the status of the matter, to no avail, and that they were closing the file until there
was any further developments in the case.
23. The Plaintiffs also received a letter from a realtor, XXXX who stated that
she noticed that the Defendant Land Grant Services, LLC is still on the title of the subject
property. XXXX stated that in the past, she helped a property owner get her title cleared so she
could sell her home. She further stated that she obtained the services of a notary to get the title
back into the property owner’s name. And that after that, she put out the property on the market
and sold it for a huge profit for the property owner. Stella then asked Plaintiffs to contact her if
they needed her assistance on the matter.
24. At the time of filing this Complaint, the Plaintiffs are still on the mortgage and are
current with their lender, XXX Servicing. Further, the Plaintiffs intend to refinance the loan,
but are unable to due to Title. Meantime, the subject property has a lot of equity now and the
borrowers want to protect their interest.

FIRST CAUSE OF ACTION
Quiet Title to Real Property
(Against All Defendants)

25. Plaintiffs incorporate by reference and re-alleges each and every allegation
contained in this complaint, as though fully set forth herein.
26. That Plaintiffs are seeking a quiet title action against the claims of Defendants and
each of them in the subject property, as more specifically described hereinabove.
27. Plaintiffs are the owners of the subject property, as more specifically described
hereinabove, and seek to remove certain false ownership interests clouding plaintiffs’ title by
Defendant Land Grant Services, LLC and Defendant XXXX, and any other entity, as
more specifically described herein. Plaintiffs are not challenging any mortgage encumbrances of

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COMPLAINT

record, for the subject property, and neither contest nor reaffirm the same by the way of this
action.
28. That the claims of Defendants, and each of them, are without any right, title,
ownership or interest whatsoever and that Defendants, and each of them, have no right, title or
interest in the subject property, and that any alleged title interests, if any, obtained by the within
Defendants and each of them, was obtained by wrongful acts. Defendants have no right, title or
any interest whatsoever in the subject property.
29. Defendants have asserted an adverse claim against Plaintiffs with respect to the
subject property.
30. Plaintiffs seek to quiet title in the subject property as of the date of this lawsuit to
each Defendant, and that each such Defendant has no such right, title, estate, lien, or interest in
the subject property or any part of it, adverse to Plaintiffs, or at all, and that the claims of all
Defendants herein are without any right, title, ownership or interest whatsoever.
31. By virtue of the foregoing facts, Plaintiffs are entitled to a judicial declaration that
Plaintiffs are the 100% owner of the Subject Property.
PRAYER FOR RELIEF
WHEREFORE, Plaintiffs pray for judgment as follows:
1. For a court judgment and order declaring the equitable rights of the parties herein;
2. For a court judgment and order declaring that Plaintiffs have quiet title in Lot 5
IN Block “G” of Arlington, in the City of San Diego, County of San Diego, State
of California, according to the map thereof number 1638, filed in the Office of the
County Recorder of San Diego County, XXXXX. COMMOLY KNOWN
AS: XXXX, CA 92113 as to each Defendant, and that
each Defendant has no right, title, estate, lien or interest in the subject property or
any part of it, adverse to Plaintiff, or at all;

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COMPLAINT
3. For attorney’s fees, if allowed by law;
4. For costs of suit; and
5. For such other and further relief as the court may deem just and proper.

Dated: ___________

Respectfully submitted,

___________________________________
XXXX

___________________________________
XXXX

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COMPLAINT

CERTIFICATE OF SERVICE

I certify that a copy of this Complaint for Quiet Title was served on [ENTER DATE] to the
Defendants in this action at the following address:

XXXX

XXXX
[ENTER ADDRESS]

Dated: ______________

___________________________________
XXXX

___________________________________
XXXX

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