plea MODEL FOR ROUTE INHIBITORY
COMPETITION RAISES QUESTION OF INHIBITORY
VIA Honor :
........................, lawyer, registered in the respective registration folio ............. , the book .........., with existing security, Street address for service constitute ........ ........... n º......-
of this city of ................, to VS and I stand respectfully say
I.) PERSONALITY:
That as I credit the a public mandate that accompany original and copy, I gripped the street Mr. ........................, domiciled ....... No city of .........., and whose other identification data held by the aforementioned aims and are reproduced here in honor of the soon .-
II. ) SUBJECT:
express That following intrusion my client, I come to appear before VS and raise the issue of RESTRAINING COMPETITION FOR VIA (art. 6 of the CPCC), which then determined and founded .-
III.) FOUNDATION.
FACTS
As emerges from the official notice accompanied to receive my instituting on the same date ....../......../......., has been sued ............................................... .........................................
................................................ .................................................. ......................................... by Mr. ................................ in this cause is to .............................................. ........................................
................................................ .................................................. .................................................. LACK
.........- :
is the case that under no circumstances can the court hear this case because ............ .................................................. .................................................. Atento
.............................- reserve the provinces regarding the regulation adjective (art. 104 SC) and rule "locus regit actum", I note to VS ..................................... .................................................. ....
..............................................-
IV.) DEMONSTRATION:
also evident to Your Excellency that I have not expressly agreed to any extension of competition, nor have tacitly consented, since this is the first action I perform in relation to the cause and has not held the possibility of filing a plea .-
V.) TEST:
INSTRUMENTAL: Atento
grounds accompanied the card received notification .........................................-
VI.) RIGHT:
Fundo this pose on the provisions in arts. 4, 6, sig. and conc. the CPCCSF-
VII.) COMPETITION:
VS Competition to hear this pose appears to have chosen this part of the road "INHIBITORY" that empowers the fact that it judges from different provinces and jurisdiction to hear the main .-
VIII.) Reference:
the foregoing to apply VS:
a) I have filed with established legal residence and invoke the character that I agree on the participation rightfully belongs.
b) it has made this competition issues plenteo VIA INHIBITORY .-
c) Free trade (Law 22,172) to the Court ................... ................................................ conunicándole the promotion of this pose, with copies of this letter, and requesting a stay of proceedings .-
d) Run VS view the prosecutor (art. 7 of CPCC and 139, inc. 7, of Act 10,160.). -
e) Timely VS declare their competence to intervene in the case, asking the judge to disqualify himself from further acting in the same understanding and inviting where appropriate, to settle the race before the Superior .-
VS Provide
under
JUSTICE FOR BEING. -
0 comments:
Post a Comment