Application For Transfer Of Condominium Ownership
TO THE HONORABLE COURT
PLAINTIFFS: …….
ATTORNEYS: …….
DEFENDANT: …….
SUBJECT: Cancellation of the Allotment of Land to a Common Area
EXPLANATIONS: My clients are the owners of the independent units numbered …. located on the real estate registered in the land registry at the address ……. in the province of ……. , district of ……. , neighborhood of ……. , sheet ……. , block ……. , parcel ……. . The defendant is the owner of the independent unit numbered … on the same real estate.
The defendant has been operating their independent unit as ……. since ../../…. and has been disturbing and causing harm to my clients.
Verbal warnings were made to the defendant to correct his unacceptable behavior, but these warnings were unsuccessful, and as a result, a formal notice was issued to him by the ……… Notary Public on ../../…. with the reference number ….. Despite this formal notice, the defendant continued to operate his independent unit as ……….
For these reasons, it has become necessary to file this lawsuit to transfer the ownership of the defendant’s independent unit to my clients.
REASONS: Condominium Law and Related Legislation
EVIDENCE: Title Deed, Warning Letter, Witness Statements
CONCLUSION: For the reasons stated above, we request that the defendant’s independent unit be transferred to my clients in proportion to their shares, with the defendant paying the court costs, 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. …….
PLAINTIFFS’ ATTORNEY
