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August 14, 2018

X
X

Re: NOTICE OF PENDING LITIGATION AND ADVERSE CLAIM

Dear X:

On behalf of my client, X, I am writing to inform you of the pending


litigation and my client’s adverse claim over a certain parcel of land covered by
Transfer Certificate of Title No. X, situated at X.

It has come to my client’s attention that certain individuals may have


offered to sell you the said property or a portion thereof. However, please be
advised that there is a pending civil action for X relating to the said property.
The case is designated as Civil Case No. X and is currently being heard by the
Municipal Circuit Trial Court of X. It is my client’s position that certain
individuals have unlawfully entered and fenced the said property to the
prejudice of my client and his co-owners.

My client claims ownership over the said property by virtue of a Deed of


Absolute Sale executed by and between him, his co-owners, and the former
owners of the said property, X. A copy of the Deed of Absolute Sale is hereto
attached as Annex “A”; a copy of TCT No. X is hereto attached as Annex “B”;
and a copy of the Sketch Plan relating to TCT No. X is hereto attached as Annex
“C”.

My client expects to prevail in Civil Case No. X. Should you indeed


purchase the said property and my client eventually prevails in the said case,
please note that my client intends take any and all legal means to preserve his
rights over the said property. This includes contesting any sale, conveyance or
encumbrance which may prejudice his rights. Finally, please be advised that
this letter and your response (or lack thereof) may be presented in court if my
client is compelled to take legal action against you.

Thank you very much for your time. If you have any questions or
concerns, please feel free to contact me using the information stated below.

Sincerely,

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