Quiet Title Motion Drafting

I have an active quiet-title action on a piece of real estate. The defendant could not be located, service was completed by newspaper publication, and the court has set a judgment-with-prejudice hearing. I now need a motion—complete with supporting memorandum and proposed order—that asks the court to determine ownership and permanently clear the title.

You’ll draw on the existing docket (case already filed) and craft a persuasive filing that tracks the relevant state quiet-title statutes, cites controlling case law, and walks the judge from the publication service through to the requested relief. I will supply the complaint, affidavit of due diligence, proof of publication, and any prior minute orders so you can weave the facts into a cohesive argument.

Deliverables
• Draft motion in editable Word format
• Supporting memorandum of points and authorities
• Proposed order for the judge’s signature
• Proof-of-service form ready for filing

Acceptance criteria: motion follows local court formatting rules, references all exhibits by correct docket number, and clearly requests entry of judgment quieting title in my favor with prejudice.

Please be comfortable using standard legal-research tools and citation format; a quick turnaround is appreciated so I can file ahead of the scheduled hearing date.