Sample Petition Requesting Transfer Of Independent Section In Return For Value
MAGISTRATE LAW COURT
TO THE HONORABLE JUDGE
THE PLAINTIFFS :
ATTORNEY :
DEFENDANT :
SUBJECT : It consists of the request for the transfer of the defendant’s independent section in return for the price.
FACTS : 1- The defendant is the owner of the apartment numbered …… of the apartment building on the immovable property numbered …………, ………….. district, …………. neighborhood, ……… street, …….. island, …….. parcel.
2- The defendant has been using his apartment as a casino for about 5 months. Dozens of gambling people enter and exit the apartment every day. This situation both disturbs my clients’ family and the residents of the neighborhood.
3- Despite repeated warnings to the defendant, he has not given up this attitude. Therefore, it has become necessary to file this lawsuit.
LEGAL GROUNDS :
EVIDENCE : Land registry, management plan, ….. Notary’s notice dated …./…./…… and numbered ………, discovery and all kinds of evidence.
CONCLUSION AND REQUEST : For the reasons stated above, we respectfully request and demand that our lawsuit be accepted and that the defendant’s independent section be transferred to my clients in proportion to their land shares in return for the price in accordance with the provisions of the Condominium Law and registered to the title deed in their names and that the judicial expenses and attorney fees be decided to be taken from the defendant. …./…./…….
Plaintiffs’ Counsel
Atty…
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