…… HONORABLE JUDGE
PLAINTIFF: ……
ATTORNEY: ……
DEFENDANT: ……
SUBJECT: Regarding Our Request for Correction of the Division of the Land Parcel
EXPLANATIONS: My client resides at the address …….., located in the ……. State, ……. County, ……. Neighborhood, ……., and is the owner of the independent unit numbered ……. The property is registered in the land registry under the name ……., with parcel number …….
The land share of the independent unit owned by my client was. Incorrectly calculated and recorded in the land registry in this manner. This error also applies to the land shares of the other independent units.
The incorrect calculation of the land shares of my client and the other independent units is causing problems in the payment of common expenses. The failure to distinguish between my client’s and the other independent units’ land shares is causing problems in the payment of common expenses.
It was necessary to file this lawsuit to resolve these issues.
GROUNDS: Condominium Law and Relevant Legislation
EVIDENCE: Land Registry, Management Plan
AS A RESULT OF THE CLAIM: We respectfully request that the court rule in our favor based on the reasons presented, order the defendant to bear the litigation costs, and determine the opposing party’s attorney’s fees in our favor pursuant to Article 164 of the Attorney’s Act No. 1136 (as last amended by Article 4667).
ATTORNEY FOR THE PLAINTIFF