Cancellation Of Land Share Allocated To Common Land
TO THE HONORABLE JUDGE
THE PLAINTIFFS :…….
ATTORNEYS :…….
DEFENDANT :…….
SUBJECT : Cancellation of Land Share Allocated to Common Area
EXPLANATIONS : My clients have filed a lawsuit on ……. and ……. Province, ……. District, ……. …. numbered independent sections on the main real estate registered to the title deed in the ……. parcel, ……. plot, ……. block, ……. parcel.
According to the Management Plan, a land share was allocated to the terrace, which is one of the common areas of the main real estate, and registered to the title deed in favor of the defendant.
The necessity of filing this lawsuit has arisen in order to cancel this share, which was registered to the title deed unfairly in favor of the defendant, and to ensure that it is registered to the title deed in the name of my clients in proportion to their shares.
REASONS : Condominium Law and Related Legislation
EVIDENCE : Land Registry, Management Plan
CONCLUSION OF THE REQUEST: For the reasons stated above, we respectfully request and demand that the land share registered to the title deed in favor of the defendant be canceled and that this share be registered to the title deed in the name of my clients in proportion to their shares, that the title deed be corrected in this way, that the costs of the proceedings be charged to the defendant, and that the counterparty attorney fee be awarded on our behalf as Attorneys in accordance with the 164/last paragraph of the Attorneyship Law No. 1136 amended by Law No. 4667. …….
PLAINTIFFS' COUNSEL
