Legal Question in Landlord & Tenant Law in California

You MAY be able to demurr if there is public record of you not owning the building at the relevant time. The trouble with a demurrer is that it only addresses the sufficiency of the pleading itself. So everything in it is assumed to be true for purposes of a demurrer. Only defects in the allegations themselves can usually be reached by demurrer. However, the court MAY take judicial notice of certain things. Public records are one such thing. So if, for example, you once owned the building and you sold it, you can ask for judicial notice of a certified copy of the recorded deed from the County Recorder. You are not likely, however, to get a judge to take judicial notice of an entire chain of title showing you were never on it. You would have to file an answer and then a motion for summary judgment to present that level of factual evidence. The place to start in any case is with a letter to the attorney who filed the complaint telling him you don't own the property and asking what proof he needs of that fact in order to dismiss you. Very few attorneys have any interest in wasting their time and their client's money chasing someone who they will never win against.