Plaintiff, ELIZABETH HERNANDEZ-CARO (hereinafter referred to as Plaintiff) is and at all times mentioned herein was, an individual, residing in the County of San Bernardino, State of California. 2. Defendant ROBERT ROLDAN, (hereinafter referred to as Defendant) upon information and belief, is now, and at all times mentioned herein was, an individual residing in the County of San Bernardino, State of California. 3. The true names and capacities whether individual, corporate, associate or otherwise of claims DOES 1-5, inclusive, and each of them, are unknown to Plaintiff, who therefore sues these defendants by such fictitious names. Plaintiff will seek leave of Court to amend the Complaint to show such Defendants' true names and capacities…show more content… After Plaintiff CARO purchased the property, Defendant ROLDAN consistently pressured Plaintiff CARO to be a part of the purchase. He argued that he was entitled to being a part of the deed because of a past loan he had given Plaintiff totaling less than $2,000. Plaintiff CARO did not need Defendant ROLDAN's credit score nor his loan to qualify for the purchase of the Subject Property. 10. Plaintiff CARO decided to appease Defendant ROLDAN by mistakenly including him on the title of the Grant Deed and the Mortgage on the Subject Property. Attached as Exhibit "B" to the complaint is a true and correct copy of the Grant Deed. Plaintiff CARO feared that if she did not appease Defendant ROLDAN he would harm her and her children. Since Defendant ROLDAN never contributed to the actual purchase, Plaintiff CARO believed that she was able to remove him from the title of the Subject Property at a later date. 11. Plaintiff CARO has never received any form of legal education and did not seek the advice of a licensed attorney before placing ROLDAN's name on the Grant Deed. CARO was unaware of the power she gave ROLDAN when she placed his name on the Grant Deed as it does not reflect the true nature of…show more content… On October 24, 2017, the Victorville court issued a permanent restraining order in favor of Plaintiff CARO and her children. The restraining order is in effect until October 20, 2020. The judge included a move-out order in the restraining order. Attached as Exhibit "C" is a true and correct copy of the October 24, 2017, restraining order in San Bernardino Superior Court, case number FAMVS1703119. 14. As a result of her abusive relationship with Defendant ROLDAN, Plaintiff CARO has sought the help of a professional therapist to help her deal with her Post-Traumatic Stress Disorder, anxiety, and depression. Plaintiff Caro has been receiving outpatient rehabilitation for the last two years. 15. Since this incident Plaintiff CARO has separated from Defendant ROLDAN. Defendant ROLDAN no longer resides at the Subject Property as a result of the restraining order. Plaintiff's mistake in adding Defendant to the grant deed is preventing her from refinancing, conveying, or otherwise enjoying the property. Defendant ROLDAN demands 50% of the equity in the property, despite Plaintiff CARO being the sole person who pays for the mortgage, taxes, utilities, upkeep and maintenance of the property. Plaintiff brings this action to protect real property that belongs to
