TO THE HONORABLE COURT
PLAINTIFF: …….
ATTORNEY: …….
DEFENDANT: …….
SUBJECT: Cancellation of the Operating Project
EXPLANATIONS: My client is the owner of the independent unit numbered …. located on the real estate registered in the land registry of ……. Province, ……. District, ……. Neighborhood, ……. block, ……. plot, ……. parcel.
Despite my client’s objection to the operating project at the Condominium Owners’ Meeting 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, Operating Project,
CONCLUSION:
We respectfully request that the court rule to cancel the business project, which is contrary to the law and the management plan for the reasons stated above, to impose the costs of the proceedings on the defendant, and to award the attorney’s fees of the opposing party 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
