Ii. [§ 6.6] Quiet Title

• Jurisdiction: Maryland

II. [§ 6.6] QUIET TITLE

John Smith owns a gasoline station located on Taylor Street in Chevy Chase, Maryland. George Harris owns an adjacent parcel of land that is used as a shopping center. In his use of the shopping center property, George Harris has repeatedly asked Smith for permission to use a 20-foot strip of Smith's property as a means of ingress and egress for the shopping center. Smith has flatly refused to permit Harris to use his land for this purpose. Recently, however, Harris has claimed that he has superior title to this property and has made plans to put an entranceway across Smith's land. As a result, Smith brought this action to quiet title to his land.

VERIFIED COMPLAINT

Quiet Title

John Smith (hereinafter "Smith"), Plaintiff, by his attorneys, Tom P. Moreno and Moreno & Moreno, P.A., sues George Harris (hereinafter "Harris"), Defendant, and states:
1. Smith is a resident of Montgomery County, Maryland.
2. Harris is a resident of Montgomery County, Maryland.
3. The real property that is the subject of this suit is located in Montgomery County, Maryland.
4. Jurisdiction and venue are proper in the Circuit Court for Montgomery County pursuant to § 14-108 of the Real Property Article of the Maryland Code.
5. Smith is the owner of certain real property, used as a gasoline service station, located on Taylor Street in Montgomery County, Maryland, as is more particularly described by a deed recorded in the land records for Montgomery County at Liber 101, Folio 27 (hereinafter "the Station Property"). A copy of the deed to the Station Property is attached hereto and incorporated as Exhibit A.
6. Harris is the owner of an adjacent parcel of land used as a shopping center, as is more particularly described by a deed recorded in the land records for Montgomery County at Liber 47, Folio 290 (hereinafter "the Shopping Center Property"). A copy of the deed to the Shopping Center Property is attached hereto and incorporated as Exhibit B.
7. Harris has

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