BRING SPECIAL ITEM PRIOR STATEMENT.
Mr. Judge:
..................., lawyer, attorney of the defendant in cars images: "....... ...C / ........S /.........." Expte. N ยบ ......../......, VS respectfully to appear and say:
I) SUBJECT:
That I have been served on demand, and as an article prior and special delivery respect of such act, I come to file plea (inc. 1 of art. 139 of CPCC).
II) RATIONALE:
As emerges from the terms of the demand is already established, is intended ........................ ..................................
................................................ .................................................. ..................................................
............- Thus, VS is physically incompetent to understand in this case, because under the provisions of art. ...... of Law 10,160, ............................................. .................................................. .............
................................................ .................................................. ..................................................
..............- For the purposes of the provisions of art. 2, para. 2, ap. b. of Law 10,160, VS manifest has not been expressly agreed prorogation
.- This legislation is absolutely incompetent ratione VS materiare and not having brokered an informal statement on the matter, should be the exception in this act interpose. -
to argue this:
The procedural bar is articulated on the basis of timely filed within ...... days of running the transfer of claim (art. 140 of CPCC) as appears from the official notice that accompanied, but the latter party has at no time consented to the jurisdiction of VS-
III) TEST:
I propose to my effects test:
....................................... .................................................. ..................................................
........................- IV) REQUEST:
the foregoing, VS request:
a) Please be filed with this plea, which was shall transfer to the plaintiff, suspended the processing of principal.
b) Take the proof offered VS.
c) Ruling, VS declare itself incompetent to hear the case, imposing the costs to the plaintiffs and ordered the removal of these proceedings.
Provide
under VS. JUSTICE FOR BEING
.-
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