Iv. [§ 6.16] Partition of Land

• Jurisdiction: Maryland

IV. [§ 6.16] PARTITION OF LAND

John Smith owns an undivided one-half interest, as tenant in common with George Harris, of a 100-acre parcel of land located in Montgomery County, Maryland. The property is improved only by a small log cabin, which Harris built with his own hands and which the two individuals used for weekend excursions. Smith now desires to construct a residential development on the parcel, but Harris desires that the land remain virtually unimproved. As a result, Smith brings this action to partition the land.

COMPLAINT

Partition of Land

John Smith (hereinafter "Smith"), Plaintiff, by his attorneys, Finn P. Doyle and Doyle & Doyle, P.A., sues George Harris (hereinafter "Harris"), Defendant, and states:
1. Plaintiff and Defendant are owners as tenants in common of a 100-acre parcel of real property located in Montgomery County, Maryland, pursuant to a deed (hereinafter "Deed") recorded in the Land Records of Montgomery County at Liber 101, Folio 27 (hereinafter "Property").
2. A copy of the above referenced Deed is attached hereto as Exhibit A, and the Deed contains a correct legal description of the Property.
3. Plaintiff and Defendant each have an undivided one-half interest in fee simple in the Property.
4. There are no liens or encumbrances appearing of record on the Property, and Plaintiff has no knowledge of any parties who claim an interest in the Property, or who will be materially affected by the action other than Plaintiff and Defendant.
5. Plaintiff has obtained a title report from

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