TO THE PRESIDENT OF THE COURT
PETITIONERS:
ATTORNEYS:
DEFENDANT:
SUBJECT: Cancellation of the Allotment Share of Land Allocated to a Common Area
EXPLANATIONS: My clients are the owners of the independent units numbered … located in parcel … on the main immovable property registered in the land registry, located at ……. pafta, ……. ada, ……. address, in ……. District, ……. Municipality, ……. Province. The defendant is the owner of the independent unit numbered … on the same immovable property.
The defendant’s independent unit ../../…. causes disturbance and damage to my clients.
Verbal warnings made to the defendant to correct this intolerable behavior have been unsuccessful. A warning letter dated and numbered ….. was issued. Despite this warning, the defendant continued his/her activity.
For these reasons, it has become necessary to file this lawsuit on behalf of my clients for the transfer of ownership of the independent unit belonging to the defendant.
H. REASONS: Condominium Law and Related Legislation
EVIDENCE: Land Registry, Warning, Witness Statements
RESULT OF THE CLAIM: On behalf of my clients, we respectfully request that the defendant pay the price of the independent section belonging to the defendant for the reasons stated, that the costs of the proceedings be transferred to the defendant, and that the opposing party’s attorney’s fees be determined as attorney’s fees in accordance with the last paragraph of Article 164 of the Attorney’s Law No. 1136, amended by Law No. 4667. Thank you. …….
ATTORNEY AT LAW