TO THE HONORABLE COURT
PLAINTIFF: …….
ATTORNEY: …….
DEFENDANT: …….
SUBJECT: Cancellation of the Business Project
EXPLANATION: My client is the owner of the independent unit numbered …. located on the immovable property registered in the land registry at the address of ……. Province, ……. District, ……. Neighborhood, ……. Block, ……. Parcel, ……. Parcel.
Despite my client’s objection to the operating project at the Condominium General Assembly held on ../../…. , this objection was rejected.
It has become necessary to file this lawsuit for the cancellation of this operating project, which is contrary to the law and the Management Plan.
REASONS: Condominium Law and Related Legislation
EVIDENCE: Land Registry Record, Decision Book, Management Project,
SOLUTION:
For the reasons stated above, the management project, which is contrary to the law and the management plan, should be canceled, the litigation costs should be borne by the defendant, and the payment of the opposing party’s attorney’s fees to us in accordance with the last paragraph of Article 164 of the Attorney’s Act No. 1136, as amended by Law No. 4667.
PLAINTIFF’S ATTORNEY