This sample motion to expunge a Lis Pendens for California is made pursuant to Code of Civil Procedure section 405.30 on the grounds that the complaint does not state a real property claim as required by California law, and on the further grounds that the Lis Pendens was not properly served in accordance with California law. The sample motion also requests attorney fees and costs pursuant to Code of Civil Procedure section 405.38. The sample is 14 pages and includes brief instructions, a memorandum of points and authorities with citations to case law and statutory authority, sample declaration and proof of service by mail.