LAWSUIT OF SUCCESSION

VILLAGE: ________________

MUNICIPALITY: _______________

STATUS: _________________

JUDGMENT: _________________

C. MAGISTRATE OF THE UNITARY COURT

AGRARIAN DISTRICT ___________

PRESENT

___________________, in my own right and in my capacity as legitimate wife of the deceased

ejidatario __________, whose correct name is ______________; indicating as domicile to hear and
receive all types of notifications and agreements the property occupied by the offices of the
Procuraduría Agraria, located at _________________ in this City of __________, State of
____________, authorizing for such purposes the CC. Lics. EN Derecho ___________________
and __________________, with professional license numbers ___________ and __________,
respectively, public servants of said Institution before which I have requested their advice and
professional services, in order to continue in all its proceedings and instances the lawsuit that with
this writing I am initiating, in terms described by articles 135 and 136, section I, of the Agrarian Law
in force, as well as numeral 305 of the supplementary Federal Code in force.I have requested your
advice and professional services, in order to continue in all its proceedings and instances the
lawsuit that with this writing I am initiating, in the terms described in articles 135 and 136, section I,
of the Agrarian Law in force, as well as numeral 305 of the supplementary Federal Code of Civil
Procedures; before you, I respectfully appear and expose:

By means of the present document and based on the provisions of Section I of Article 18 of the
Agrarian Law in force and 18, Section VII, of the Organic Law of the Agrarian Courts, I come to
promote asuccession trial to the estate of the deceased ejidatario ______________, whose
correct name was _____________, requesting from this H. Unitary Agrarian Tribunal, be notified of
the filing of the present case to the authorities of the ejido of ___________, Municipality of
__________, State of __________, through the Ejidal Commissariat represented by the CC.
______________ and ______________, in their capacity as President, Secretary and Treasurer,
respectively, who may be notified at the ejido offices located in the center of the aforementioned
town, demanding the following:
 BENEFITS

A.- That the transfer of the Agrarian Rights recognized by my wife ________________, whose
correct name was ______________, who was a legally recognized ejidatario of the ejido of
___________, Municipality of ___________, in the State of ____________, be made in favor of the
undersigned, with respect to the Certificate of Agrarian Rights number ____________, issued in
favor of the author of the succession on the day ______________, in compliance with the resolution
issued by the extinct Mixed Agrarian Commission of the State of ___________, on the date
______________.mero __________, issued in favor of the author of the succession on
_________________, in compliance with the resolution issued by the extinct Mixed Agrarian
Commission of the State of _____________, dated ______________.

B.- As a consequence of the foregoing provision, the National Agrarian Registry is ordered to
cancel the Certificate referred to in the foregoing provision and instead issue in favor of the
undersigned the document that protects me as legal ejidataria with respect to the agrarian rights
that corresponded to the author of the succession for the reasons and rationale that I will indicate
below.

I base the present document on the following facts and legal considerations:

FACTS

1.- My deceased husband _______________, whose correct name was _______________, was a
legally recognized ejidatario of the ejido of __________, Municipality of ____________, in the state
of ___________, with respect to the Certificate of Agrarian Rights number ___________, issued in
favor of the author of the succession.n on __________________; in compliance with the resolution
issued by the extinct Mixed Agrarian Commission of the State of ___________, dated
_______________, situation that is evidenced by the certificate of agrarian rights attached hereto.
(ANNEX ONE)

2.- I hereby inform you that the undersigned contracted a civil marriage with the author of the
succession, as evidenced by the Marriage Certificate issued by the C. Officer of the Civil Registry of
the Municipality of ___________, State of ___________, and in said union we procreated two
children named _________________ and ________________, surnamed _______________, as
evidenced by the birth certificates attached hereto. (ANNEX TWO TO FOUR)

It is the case that on the date _______________, my husband died, as evidenced by the
corresponding Death Certificate issued by the Civil Registry Officer of the Municipality of
____________, State of _________, on ________________. (ANNEX FIVE)
4.- I inform your honor, that my husband did NOT make a designation of successors before the
National Agrarian Registry, nor by any other means, having knowledge of the above because I
requested, before said registry body, information regarding the agrarian rights that belonged to my
husband and that motivate this matter, informing me on the date , by means of the registration of
agrarian rights in the ejido.I am aware of the above because I requested, before said registry body,
information regarding the agrarian rights that belonged to my husband and that motivate the present
matter, informing me on ________________, by means of the registration certificate of agrarian
rights in ejido, the above. (ANNEX SIX)

5.- Likewise, I hereby inform you that the ejido of reference has no objection whatsoever to the
undersigned being the legal successor of the agrarian rights that in life corresponded to my
deceased husband, since the facts contained in this document are true.

On the other hand, I hereby inform your Honor that the Ejido in question has not been verified
through the Program for the Certification of Ejido Rights, in terms of Article 56 of the Agrarian Law,
and for this reason there are no parcel certificates in our nucleus.

RIGHTS

The provisions of Articles 1, 2, 18, section I, and 163 of the Agrarian Law in force, as well as the
provisions of Article 18, section VII, of the Organic Law of the Agrarian Courts, are applicable to the
merits of the case.

The procedure is governed by the provisions of articles 167, 181, 185, 186, 187, 189 and other
relative and applicable articles of the Agrarian Law in force, as well as the provisions of articles 303,
322, 323 and 324 of the supplementary Federal Code of Civil Procedures.

In order to prove the above, I hereby offer, as of this moment, the following means of evidence:

TESTS

1.-PUBLIC DOCUMENTATION, consisting of the Certificate of Registration of Individual Agrarian

Rights in Ejido, issued by the Delegate of the National Agrarian Registry, on __________________.
PUBLIC DOCUMENTATION, consisting of the certified copy of the marriage certificate executed
between the author of the succession and the undersigned, issued by the C. Civil Registry Officer of
the Municipality of _____________, State of ____________.

PUBLIC DOCUMENTARY, consisting of the birth certificates of the children that we procreated, the
author of the succession and the undersigned, during the marriage, whose names are
_______________ and ______________.

PUBLIC DOCUMENTARY, consisting of the death certificate of my husband ______________,

whose correct name was ______________, issued by the C. Civil Registry Officer of ___________,
Municipality of ____________, State of ____________.

PUBLIC DOCUMENTATION, consisting of a certified copy of the birth certificate issued in favor of
the undersigned by C. Civil Registry Officer of the Municipality of ____________, in the state of
______________.

PUBLIC DOCUMENTATION, consisting of the Certificate of Agrarian Rights number

____________, issued in favor of the author of the succession the _______________.

7.-CONFESSIONAL, in charge of the Ejidal Commissariat of the town ___________, Municipality

__________, of the State of ____________, through its representatives CC. _________________,
_________________ and ________________, in their capacity as President, Treasurer and
Secretary, respectively, in order to prove the facts mentioned in paragraphs 1, 2, 3, 4, and 5, of my
written complaint.

8.-INSTRUMENTAL OF ACTIONS, consisting of everything that is acted upon in the present matter
and that benefits my interests.

9.-LEGAL AND HUMAN PRESUMED EVIDENCE, which is offered in the terms of the previous
evidence.

In view of the foregoing and for the foregoing reasons;TO YOU, C. JUDGE, I kindly request you:
FIRST: I am deemed to have been presented with the written statement of account, formulating the
benefits that have been described in the respective chapter.

SECOND: To set a date and time for the Hearing of Law to take place, prior notice to be given to
the members of the Ejidal Commissariat of the aforementioned town, so that they may appear
before this Tribunal to state their rights in relation to the present matter.

THIRD: To consider as offered and admitted the evidence attached to the present writ of claim for
the legal effects that may be applicable.

FOURTH: After the legal procedures, to issue the sentence of merit, in which I declare myself as
ejidataria by succession with respect to the agrarian rights that in life belonged to my deceased
husband _________________, whose correct name was ______________.

FIFTH: Prior to the legal procedures, I request the National Agrarian Registry to register the
corresponding agrarian rights in my name and to issue me the corresponding certificate.

SIXTH: Authorize the return of my original documents that I exhibited as evidence in this matter.

SEVENTH: To have the domicile indicated and the professionals mentioned as authorized for the
effects specified in the initial document of the claim.

PROTEST ACCORDING TO LAW

In the City of _________, State of Mexico on the ___day of _________of_______.

(SIGNATURE )