.TO THE HONORABLE COURT
PLAINTIFF :…….
ATTORNEY :…….
Defendant: …….
Subject: Request to Prevent the Defendant’s Actions of Making Changes to the Independent Unit Without the Approval of the Condominium Owners’ Association and to Restore It to Its Original State.
EXPLANATIONS: My client is the owner of the independent units numbered …. located on the main property registered in the land registry at ……. address, ……. Province, ……. District, ……. Neighborhood, ……. sheet, ……. block, ……. parcel. The defendant is the owner of the independent unit numbered … on the same property.
The defendant altered the exterior appearance of the main property without obtaining the approval of the other co-owners’ committee, painting the balcony railings and interior walls of the balcony in a different color.
This action, taken without the approval of the Condominium Owners’ Association, constitutes an infringement of the rights of the other condominium owners, making it necessary to file this lawsuit.
REASONS: Condominium Ownership Law and Related Legislation
EVIDENCE: Land Registry Record, Decision Book, Inspection and Expert Examination
REQUESTED OUTCOME: To prevent the defendant’s infringement, to issue a warning to the defendant to restore the situation to its original state, to impose the litigation costs on the defendant, and that the attorney’s fees of the opposing party be awarded to us as attorneys in accordance with the last paragraph of Article 164 of the Attorney Law No. 1136, as amended by Law No. 4667. …….
PLAINTIFF’S ATTORNEY
