Sample Petition Requesting Transfer of Independent Section in Return for Value
Magistrate Law Court
Your Honor
DEFENDANTS
ATTORNEY :
DEFENDANT
SUBJECT : It consists of the request for the transfer of the independent section belonging to the defendant for a price.
FACTS : 1- The defendant is the owner of the apartment numbered …… of the apartment building located on the immovable property numbered …………, ………….. district, ………… neighborhood, ……… street, …….. island, …….. parcel.
2- The defendant has been using his apartment as a casino for about 5 months. Dozens of gamblers enter and exit the apartment every day. This situation disturbs both my clients’ family and the residents of the neighborhood.
3- Despite repeated warnings to the defendant, he has not given up this behavior. Therefore, it has become mandatory to file this lawsuit.
LEGAL GROUNDS
EVIDENCE : Title deed, management plan, ….. …./…./…… date and ……… numbered notary letter. Discovery and all kinds of evidence.
CONCLUSION AND DEMAND : For the reasons stated above, we respectfully request and demand the acceptance of our lawsuit and the transfer of the independent section belonging to the defendant to my clients in proportion to their land shares in return for the price in accordance with the condominium provisions. It has been decided that it is registered in their name in the law and title deed and that the costs of the proceedings and attorney’s fees shall be charged to the defendant. …./…./…….
Plaintiffs’ Attorneys
Lawyer
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