Fill and Sign the Pretrial Memorandum Requesting Reimbursement of Real Estate Upkeep Costs for Redeemed Property Louisiana Form

______________ : ______ JUDICIAL DISTRICT COURT VS : PARISH OF ______ , LOUISIANA THE UNOPENED SUCCESSION OF ______________ : DOCKET NO. ______ _________________________________________________________________ _ PRETRIAL MEMORANDUM MAY IT PLEASE THE COURT: This matter comes before the Court for trial on ______ ___ , 20 ___ , before the Honorable ______________ , as a ______ fixing. FACTS: ______________ acquired a tract of land located in the City of ______________ at Sheriff's Sale for non-payment of State property taxes. (Attached is a copy of the Tax Deed). Subsequent thereto, the subject property was redeemed from ______________ for the sum of $ ______ , which represents the unpaid taxes for the years ____ , ____ , ____ and ____ , plus any applicable interest thereon. (Attached is a copy of said redemption). Prior to the aforementioned redemption, ______________ spent in excess of ______________ and ___ /l00 ($ ______ ) Dollars for the maintenance and upkeep of the subject property. LAW: Louisiana Revised Statute 47:2222.l provides the following: A. In addition to the payments required under R.S. 47:2222, the purchaser of any real estate sold to pay taxes due thereon at a tax collector's sale by the city of Shreveport, by the city of Monroe, or by the city of New Orleans shall be entitled to receive from the owner or agent of such real estate the cost of any repairs, rehabilitation, maintenance removal, or demolition made or done thereon by said purchaser to the extent not otherwise included in the value of improvements for which payment is required under R.S. 47:2222, when required by an order of either the property standards board or the city council of the city of Shreveport, the city of Monroe, or the city of New Orleans, for the purpose of enforcing a property standards ordinance. The reimbursement for costs set forth in this Section shall be limited to the minimum amount reasonably necessary to comply with the order of such board or city council and the property standards ordinance. B. To prove the cost of repairs, rehabilitation, maintenance, removal, or demolition made or done on such real estate, the purchaser of the real estate thus sold shall provide written receipts for the payment of said costs from the persons who performed the work or from whom the materials were purchased. In the event the owner of the real estate contests the validity of such documentation, appraisers shall be appointed and shall proceed in the manner set forth in R.S. 47:2223 to determine the cost of said repairs, rehabilitaiton, maintenance, removal, or demolition. The governing authority of the city of Shreveport, the governing authority of the city of Monroe, and the governing authority of the city of New Orleans shall each respectively enact such procedures, rules and regulations as may be necessary for the implementation of this Section. Your plaintiff will provide the Court with written receipts reflecting the amount that has been expended on the subject property. CONCLUSION: It is respectfully suggested that the plaintiff will prove its case by a preponderance of the evidence, and that this Court should award Judgment in favor of plaintiff and against defendant in an amount in excess of ______________ and ___ /l00 ($ ______ ) Dollars. Respectfully submitted, _____________________________ ______________ ______________ ______ , Louisiana ______ ( ___ ) ______ La. Bar Roll No. ______ ATTORNEY FOR PLAINTIFF * * * C E R T I F I C A T E I HEREBY CERTIFY that a copy of the above and foregoing Pretrial Memorandum has been served upon ______________ , Attorney at Law, ______________ , ______________ , Louisiana ______ , attorney for defendant, by placing a copy of same in the United States Mail, postage prepaid and properly addressed. ______________ , Louisiana, this _____ day of ___________, 20 ___ . ______________________________ __ ______________