Special Tax Collector of the Internal Revenue Service, Southern Coast Office: Diogenes Villacis Crespo, representing the rights of the TOSQUINI S.A. company, RUC # 0992541164001, owner of the 7 land lots located in the Playas canton that the SRI pretends to auction according to regulation N° RLS-COAPRPC13-01526; within the illegal enforcement proceeding N° RLS-003855-2012 in which the entity I represent has been wrongly linked, say:

Before the publication made in El Telegrafo newspaper, calling for the public auction of the 7 real assets located in the Playas canton, with registration numbers 1282, 1943, 1944, 1946, 1947, 1948 y 1949, according to regulation N° RLS-COAPRPC13-01526), I appear before you and I file a PETITION TO ANNUL that calling for the following reasons:

1.- The aforementioned collection proceeding has been suspended since the date that was filed the exception document against this execution. As enforced by articles 214 and 246 of the Tax Code.

2.- The same collection proceeding is also suspended by the filing of the Direct Action number 09502-2013-0087
which is substantiated by the National Court of Justice for Cassation.

3.- It is also suspended by the segregation actions of domain presented before you a few days ago.

4.- Additionally, it has been presented, complaint proceedings against the Special Tax Collector, Economist Juan Miguel Aviles Murillo, for the violation of due process, actions that continue against the entity I represent.

The suspension of the execution proceeding, necessarily suspends its managerial competencies, therefore, at the moment of the calling of the auction, it was exercised a physical act resulting in the annulation on everything carried out.

For the grounds given, bear to abstain from the auction calling and to know what to expect within the current legal system.

It is justice.


Diogenes Villacis Crespo                                                               Dr. Jorge Zavala Egas.

Legal Representative

Tosquini S.A.