In Kirkeby v. Superior Court (2004) 33 Cal.4th 642, the California Supreme Court was asked to decide whether a fraudulent conveyance claim affects title to or the right to possess real property thereby supporting the recording of a lis pendens. (Kirkeby, supra, 33 Cal.4th at p. 645.) The Supreme Court concluded that it does. (Ibid.) The plaintiff filed a complaint alleging 27 causes of action, including a fraudulent conveyance cause of action, and recorded a lis pendens. (Kirkeby, supra, 33 Cal.4th at p. 646.) The complaint requested that the alleged fraudulent transfers be voided to the extent necessary to satisfy the other claims set forth in the plaintiff's complaint. (Ibid.) That remedy was the plaintiff's only interest in the property. The trial court granted a motion to expunge the lis pendens and the appellate court affirmed, finding that the basis of the complaint was to recover money and had nothing to do with real property. (Id. at pp. 646-647.) The Supreme Court reversed: "A fraudulent conveyance claim requesting relief pursuant to Civil Code section 3439.07, subdivision (a)(1), if successful, may result in the voiding of a transfer of title of specific real property. By definition, the voiding of a transfer of real property will affect title to or possession of real property. Therefore, a fraudulent conveyance action seeking avoidance of a transfer under subdivision (a)(1) of Civil Code section 3439.07 clearly 'affects title to, or the right to possession of' (Code Civ. Proc., 405.4) real property and is therefore a real property claim for the purposes of the lis pendens statutes." (Kirkeby, supra, 33 Cal.4th at p. 649.) The Supreme Court explained: " 'A lis pendens is a recorded document giving constructive notice that an action has been filed affecting title or right to possession of the real property described in the notice.' A lis pendens may be filed by any party in an action who asserts a 'real property claim.' (Code Civ. Proc., 405.20.) Section 405.4 defines a '"Real property claim"' as 'the cause or causes of action in a pleading which would, if meritorious, affect (a) title to, or the right to possession of, specific real property ... .' 'If the pleading filed by the claimant does not properly plead a real property claim, the lis pendens must be expunged upon motion under CCP 405.31.' " (Kirkeby, supra, at p. 647.) In Kirkeby, there were 26 other claims that did not involve the real property. Yet, because the UFTA specifically allows the remedy of "avoidance of the transfer or obligation to the extent necessary to satisfy the creditor's claim" (Civ. Code, 3439.07, subd. (a)(1)), the Kirkeby court held that a fraudulent conveyance claim seeking avoidance of a transfer "is therefore a real property claim for the purposes of the lis pendens statutes." (Kirkeby, supra, at p. 649.)