Application For Transfer Of Condominium Ownership
TO THE HONORABLE COURT
PLAINTIFFS: …….
THEIR ATTORNEYS: …….
DEFENDANT: …….
SUBJECT: Cancellation of the Allotment Share of the Common Land
EXPLANATIONS: My clients are the owners of independent units numbered … located on the immovable property registered in the land registry at ……. address, ……. Province, ……. District, ……. Neighborhood, ……. sheet, ……. block, ……. parcel. The defendant is the owner of independent unit numbered … on the same immovable property.
The defendant has been operating their independent unit as a ……. since ../../…. and is disturbing and causing harm to my clients.
Verbal warnings to the defendant to rectify his unacceptable behavior were unsuccessful, and a formal notice dated ../../…. and numbered ….. was issued to him by the ……… Notary Public. Despite this formal notice, the defendant continued to operate his independent section as ……….
For these reasons, it has become necessary to file this lawsuit for the transfer of ownership of the defendant’s independent section to my clients.
REASONS: Condominium Law and Related Legislation
EVIDENCE: Title Deed, Warning Letter, Witness Statements
CONCLUSION: For the reasons stated, the defendant’s independent unit shall be transferred to my clients in proportion to their shares, provided that its value is paid, and the costs of the proceedings shall be borne by the defendant. We respectfully request that the court rule that the opposing party’s attorney’s fees 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