Sample Adversary Complaint to Determine Validity of Liens

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This sample adversary complaint to determine validity, priority and extent of liens is pursuant to Federal Rule of Bankruptcy Procedure 7001, and also includes a request for a declaratory judgment pursuant to Federal Rule of Civil Procedure 57. The sample is used when a party disputes that another party has any valid lien against their real property, although the sample could be modified for use in a case involving personal property. The author is a freelance paralegal who has worked in California and Federal litigation since 1995 and has used this sample for many years. Note that the author is NOT an attorney and no guarantee or warranty is provided.