23-3-62 Form 1 Petition to establish title against all the world

IN THE SUPERIOR COURT OF [NAME OF COUNTY]

STATE OF GEORGIA
[Name of plaintiff],

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Plaintiff
v.
[Name of defendant],
and all persons unknown who claim or might
claim adversely to plaintiff's title to [brief
description of land],
Defendants

CIVIL ACTION
NO. [number of case]

PETITION TO ESTABLISH TITLE AGAINST

ALL THE WORLD
Plaintiff files this Petition to establish title against all the world and shows the following:

1.
The land to which plaintiff seeks to establish his title is all that tract or parcel of land
lying and being in Land Lot [designation of lot] of the [name of district] District of [name
of county], Georgia, and is more particularly described in Exhibit [designation of exhibit]
which is attached hereto.
2.
The interest of plaintiff in said land is [specification of interest].
3.
Said interest of plaintiff is based upon [description of written instrument], a copy of
which is attached hereto as Exhibit [designation of exhibit]. (The interest may be based
upon written instruments or adverse possession or both.)
4.
Attached hereto as Exhibit [designation of exhibit] is a list of all adverse claims or
possible adverse claims of which plaintiff has actual or constructive notice. (Include in

Exhibit [designation of exhibit] the names and addresses, so far as is known, of any
possible adverse claimants.)
5.
(If the proceeding is brought to remove a particular cloud or clouds, include a statement
as to the grounds upon which it is sought to remove such cloud or clouds.)
6.
Attached hereto as Exhibit [designation of exhibit] is a list of the names and addresses,
so far as is known, of the owners of lands adjoining the land which is the subject of this
proceeding. (Not required by O.C.G.A. 23-3-62 but may be required by special master
under O.C.G.A. 23-3-64.)
7.
Attached hereto as Exhibit [designation of exhibit] is an abstract of title to the land
which is the subject of this proceeding. (Not required by O.C.G.A. 23-3-62 but may be
required by special master under O.C.G.A. 23-3-64.)
8.
Attached hereto as Exhibit [designation of exhibit] is a plat of survey of the land which
is the subject of this proceeding.
9.
(Also attach copy of the immediate instrument or instruments of record or otherwise
known to plaintiff, if any, upon which any person might base an interest in said land
adverse to plaintiff.)
10.
As required by O.C.G.A. 23-3-62, a notice of lis pendens is being filed
contemporaneously with this petition.
11.
Plaintiff cannot immediately or effectually maintain or protect his rights by any other
course other than the filing of this petition and is without an adequate remedy at law, and
unless a Court of Equity intervenes, plaintiff will suffer irreparable damage.
WHEREFORE, plaintiff prays for the following:

(a) That the court take jurisdiction of this matter as an action in rem requiring the
appointment of a special master pursuant to O.C.G.A. 23-3-61 et seq.
(b) That the court appoint such special master and that this proceeding be referred to
said special master by proper order pursuant to said Code sections.
(c) That, subject to the right of appeal, plaintiff have a judgment establishing his title in
said lands against all the world and that all clouds to plaintiff's title to said land be
removed.
(d) That plaintiff have other such and further relief as may be legal, just and proper.

_______________
[Name of attorney]
Attorney for Plaintiff
[Address of attorney]
[Telephone number of attorney]
[State bar number of attorney]
[Verification]
[Attachments of exhibits]