……. TO THE HONOURABLE JUDGE
THE PLAINTIFF :…….
ATTORNEY :…….
DEFENDANT :…….
SUBJECT : Our Request for the Prevention of the Behaviour of the Defendant Who Made Changes in the Independent Section Without Obtaining the Approval of the Board of Condominium Owners and for the Conversion of the Independent Section to its Former Condition.
EXPLANATIONS :
My client is located at ……. and ……. Province, ……. District, ……. Neighbourhood, ……. plot, ……. island, ……. parcel, …. numbered independent sections on the main immovable registered to the title deed. The defendant is the owner of the independent section numbered … in the same immovable.
The defendant painted the balcony bars and balcony interior paints in a different colour by making changes in a way to disrupt the external appearance of the main property without obtaining the approval of the other Condominium Owners’ Board.
Since this behaviour without the approval of the Board of Condominium Owners is an infringement of the rights of the other condominium owners, it has become necessary to file this lawsuit.
CAUSES : Condominium Law and Related Legislation
EVIDENCE : Land Registry, Decision Book, Discovery and Expert Examination
CONCLUSION OF THE REQUEST : For the reasons stated above. We respectfully request and demand that the encroachment made by the defendant be prevented. That the defendant be warned to restore the situation. That the costs of the proceedings be charged to the defendant. And that the counterparty attorney fee be decided on our behalf as a lawyer in accordance with the 164/last paragraph of the Law No. 1136 on Attorneyship Law amended by Law No. 4667. …….
ATTORNEY FOR THE PLAINTIFF
…….
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