demand for undue payment
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ScribdTranslationsMARIANO SERRANO CRUZ
VS
LUIS ANGEL SANCHEZ MEJÍA.
ORDINARY CIVIL TRIAL
C. JUEZ DE LO CIVIL EN TURNO.
Mariano Serrano Cruz, in my own right, stating my address to hear and receive
All kinds of notifications and documents, located at Blamaceda Street number 13; neighborhood
Star Hill; Iztapalapa Municipality; C.P. 09860; in Mexico City, authorizing
indistinctly for such purposes and under the terms of Article 112, fraction IV, of the
Code of Civil Procedure, to Lic. Erika Dennis García Tovar who practices the
profession of a law degree under professional license number
121222965, issued by the General Directorate of Professions, before you with the due
I respectfully appear to present:
That through this document, in the Ordinary Civil Route and in the exercise of the action of payment
for the improper, I come to demand Mr. Luis Angel Sanchez Mejía through his
legal representative, who can be notified at their address, located on the street
Fresno Maz. 10, lot. 28; Agrarian Council Hall, in Mexico City as follows:
Benefit.
a) The payment of the amount of $320,000.00 (THREE HUNDRED TWENTY THOUSAND PESOS
00/100, M.N.), for the concept of undue payment that Mr. Mariano Serrano Cruz
I carry out the demand against the defendant.
FACTS
FIRST.- On January 12, two thousand twenty-two, I addressed the defendant.
to request a loan of $640,000.00 (six hundred forty thousand pesos 00/100, M.N.),
balance that would be paid in amounts of $213,333.33 over a period of three
months in the final days of these, leaving as the due date to pay the total balance the day
April 30, 2022.
The assertion made in this fact is supported by the payment receipts that the defendant gave him.
delivered to Mr. Mariano Serrano Cruz.
Second.- dated April 13th of the year two thousand twenty-two, the defendant mentions to you
to Mr. Mariano Serrano Cruz who made an incorrect payment, as in the month
in April I delivered the amount of $113,333.33.
Third.- Mr. Mariano Serrano Cruz makes the payment that the defendant requested from him for
concept of erroneous payment.
Cuarto.- El C. Mariano se percato de el error que el demandado cometió al cobrarle la
amount of $100,000 since it is mentioned in the receipt that was given to the actor,
signature from both parties that the payment had been made correctly.
The previous facts, from the first to the fourth, are known to Mr. Mara Delhi.
Cisneros Dominguez and Diego Humberto Acosta Rodriguez
Law.
Regarding the substance, the provisions contained in articles 1883 apply.
1887 and 1889 of the Federal Civil Code.
The procedure to be followed is regulated by articles 255, 256 and the following.
other related provisions of the Civil Procedure Code for the Federal District.
For the reasons stated,
TO YOU C. JUDGE, I respectfully ask you to please:
FIRST.- Consider me presented with this writing, documents, and copies that
I accompany, suing Mr. Luis Sanchez Angel Mejía through his
legal representative, the compliance and payment of all and each of the benefits
mentioned in the preamble of this document.
SECOND.- To admit the claim in the proposed manner and form, ordering that it be
place the defendant at their home, so that within the legal term, they produce their
response.
THIRD.- At the appropriate time and after the legal procedures, issue a final ruling, in
the one that declares the admissibility of the action I intend and condemns the defendant to
compliance with each and every one of the benefits that I claim from you, therefore
to correspond according to law and be of justice.
PROTEST IS NECESSARY
Mexico City, May 1, 2022.
SIGNATURE
