……. TO THE HONOURABLE JUDGE
THE PLAINTIFF :…….
ATTORNEYS :…….
DEFENDANT :…….
SUBJECT : Cancellation of Land Share Allocated to Common Area
EXPLANATIONS :
My clients have filed a lawsuit on ……. and ……. Province, ……. District, ……. …. numbered independent sections on the immovable property registered to the title deed at ……., ……. plot, ……. island, ……. parcel. The defendant is the owner of the independent section numbered … on the same immovable.
Defendant has been operating the independent section as ……. since …/…/…. and has been disturbing and harming my clients.
The verbal warnings made to the defendant to correct these behaviours, which have become unbearable, were ineffective, whereupon a notice dated …/../…. and numbered ….. was issued to him from ……… Notary Public. Despite this notice, the defendant continued to operate the independent section as ………..
For these reasons, it has become necessary to file this lawsuit for the transfer of the ownership of the defendant’s independent section in the name of my clients.
CAUSES : Condominium Law and Related Legislation
EVIDENCE : Land Registry, Notice, Witness Statements
CONCLUSION OF THE REQUEST :
For the reasons stated above, we respectfully request and demand that the defendant’s independent section be transferred in the name of my clients in proportion to their shares provided that its value is paid, that the defendant be charged with the costs of the proceedings, and that the counterparty attorney fee be decided on our behalf as a lawyer in accordance with the 164/last paragraph of the Attorneyship Law No. 1136 amended by Law No. 4667. …….
PLAINTIFFS’ COUNSEL
…….
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