Saud A. H. Khokhar provides legal researching, writings and preparing pleadings, petitions, applications, motions, briefs, appeals and discovery services for attorneys and law firms for presentation in City Courts, Supreme Courts, Appellate Courts, Federal Courts, Bankruptcy Courts, U.S. Circuit Court of Appeals, and Federal and State Administrative Agencies, involving matters related to real estate; foreclosure of mortgages and mechanic’s liens; contested matrimonial; chapter 7, Chapter 13, and Chapter 11 bankruptcies including adversary proceedings; wills and estates; immigration and naturalization; collection; landlord and tenant matters; breach of contract; breach of the implied covenant of good faith and fair dealing; unjust enrichment; violation of the Unfair Competition Law; declaratory relief under state and federal law; racketeering in violation of 18 U.S.C. § 1962; civil conspiracy; joint venture/joint enterprise; antitrust in violation of New York State Law; and securities violations.
Saud also provides real estate acquisition and brokerage services including financing for Purchase, Refinance, Cash-out Refinance, at a very competitive rates with variety of different payment programs for Commercial Loans, Real Estate Loans, SRO Loans No Documents Loan, Stated Income Loans, SBA Loans, Investment Property Loans, Multi-Family (5) Plus Units, Mixed-Use, Motels/Hotels, Office + Retail, Senior Housing, etc. Geography: Nationwide
Saud is graduate of the Pace University, New York City, and was named to the Pi Gamma Mu – International Honor Society in Social Sciences. Saud also earned a Certificate in Internet Technology Programming from Baruch College. Saud is also a graduate of REALTOR® Institute, and Scott. Shield Commercial Real Estate Academy. Saud is a licensed real estate broker (New York), Licensed Mortgage Broker – NYS Department of Financial Services – Third-Party Loan Provider (NMLS#140381), Licensed Insurance Broker and Life and Health Agent and Notary Public. Saud is a REALTOR® and certified by the National Association of Realtor as an e-PRO® (Electronic Marketing Specialist), BPOR (Broker Price Opinion Resources Specialist), CIPS® (Certified International Property Specialist), GRI (Graduate REALTOR Institute), RSPS (Resort and Second Home Property Specialist, SFR® (Short Sale and Foreclosure Resources Specialist, SRES® (Senior Real Estate Specialist).
Experience:
Saud has over 35 years of experience in legal researching, writing and preparing pleadings, petitions, applications, motions, appeals, briefs, and discovery for presentation in Civil Courts, Family Courts, Supreme Courts, Appellate Courts, Court of Appeals of the State of New York, United States Citizenship and Homeland Security (Immigration and Naturalization Service), Administrative Agencies, and Federal Courts including Federal Bankruptcy Courts involving complex litigation involving matters related to real estate; contempt of court; foreclosure of mortgages and mechanic’s liens; contested matrimonial; chapter 7, Chapter 13, and Chapter 11 bankruptcies including adversary proceedings; wills and estates; immigration and naturalization; collection; landlord and tenant matters; breach of contract; breach of the implied covenant of good faith and fair dealing; unjust enrichment; violation of the Unfair Competition Law; declaratory relief under state and federal law; racketeering in violation of 18 U.S.C. § 1962; civil conspiracy; joint venture/joint enterprise; antitrust in violation of New York State Law; and securities violations.
Saud also has experience in Federal Litigation practice and defense of patent, copy right and trade mark infringements cases commenced by such famous names as E.T., Michael Jackson, Adidas, Gremlin, Seiko, Cabbage Patch Kids, Menudo, etc. In fact, at present Saud is a Plaintiff in a law suit his partner and he has brought pro se entitled Craig Gottlieb and Saud A.H, Khokha vs. Alphabet Inc., Google LLC, Larry Page, Sergey Brin, Eric E. Schmidt and Patrick Pichette, originally filed in 2016 in the United States District Court for the Eastern District of New York, and now pending in the U.S. District Court, Norther District of California, asserting causes of action for: (1) violation of California Civil Code § 1671(b); (2) breach of contract; (3) breach of the implied covenant of good faith and fair dealing; (4) unjust enrichment; (5) violation of the Unfair Competition Law, California Business and Professions Code § 17200 et seq.; (6) declaratory relief under state and federal law; (7) racketeering in violation of 18 U.S.C. § 1962; (8) civil conspiracy; (9) joint venture/joint enterprise; (10) antitrust in violation of New York state law; and (11) various securities violations, seeking multimillion dollars compensatory damages.
Further, Saud also has over 35 years of combined experience in Real Estate, International Business, Insurance, Import & Export, E-Commerce and Financing. Saud is the primary drafter of appeals and briefs, opposition papers and applications in representative cases involving:
Deficiency Judgment under Real Property Actions and Proceedings Law § 1371 Mariani v. J.K.I.F. Management, Inc., 1993, 158 Misc.2d 938, 602 N.Y.S.2d 84;
1992 Law (ch.216, section 27[b]) Arbisser v. Gelbelman, A.D. 2d Dept., June 23, 1997, N.Y.L.J. June 30, 1997, p.33, col.6.;
Blue Grey Development, Inc. v. Rainer Realty Corp.,269 A.D.2d 553, 703 N.Y.S.2d 753, N.Y.A.D. 2 Dept. 2000, affirming the lower court’s decision with costs in a mechanic’s lien foreclosure matter, by holding that once the plaintiff made a prima facie showing of its entitlement to summary judgment by demonstrating that it had performed work and provided materials for the subject premises and had not been paid, the burden shifted to the defendant to produce evidentiary proof in admissible form sufficient to establish the existence of material issues of fact which required a trial of the action;
In re Gjokaj, 728 N.Y.S.2d 724, 2001 N.Y. App. Div. 2nd Dept. involving Probate and Estates;
NYCTL 1996-1 Commercial, REO, LLP, v. El Pequeno Restaurant Food Corp., 2003,765 N.Y.S.2d 465, N.Y.L.J. October 2, 2003, p.20, col. 1., involving Landlord & Tenant Law, and Strict Foreclosure action under Real Property Action and Proceedings Law §1352 or a Re-Foreclosure action under Real Property Action and Proceedings Law Section §1353;
Arbisser v. Gelbelman, 286 A.D.2d 693, 730 N.Y.S.2d 157, Appellate Div, 2nd Dept., holding that (1) the statute of limitations in foreclosure Action accrued when mortgagee’s predecessor in interest brought prior foreclosure action, (2) mortgagor did not suffer any damages as a result of alleged fraud; Choudhary v. Eat Buffet Restaurant, 24 A.D.3d 493, 808 N.Y.S.2d 239, 2005, reversing the lower court decision and holding that fact issue as to whether owners created or exacerbated a hazardous condition on premises by attempting to clear walkway adjacent to premises while snowstorm was in progress precluded summary judgment;
Hilf v. Gebelman, 286 A.D.2d 693, 730 N.Y.S.2d 157, 2001 NY Slip Op. 07088, N.Y.A.D. 2 Dept. involving denying a foreclosure action reinstating to the active status since the Court already determined, the action was withdrawn (see Arbisser v Gelbelman, 286 AD2d 693, 694 [2001]). Therefore, it may not be restored to “active status” and the motion for that relief was properly denied.
Faisal v. Mayronne, 22 A.D.3d 63, 801 n.Y.S.2d 920, 2005 N.Y. Slip Op. 07658, N.Y.A.D. 2 Dept., October 17, 2005, involving vacating and setting aside jury verdict;
Weiss, et al., v. Feldbrand, 50 A.D.3d 673, 854 N.Y.S.2d 740, 2008, involving specific performance of a contract for the sale of real property holding that genuine issues of material fact existed as to whether purchasers were ready, willing, and able to perform, as was argued; The Supreme Court, Appellate Division, held that genuine issues of material fact existed as to whether purchasers were ready, willing, and able to perform;
Czernicki v. Lawniczaki, 50 A.D. 3d 1121, 904 N.Y.S.2d 127, 2010, A.D. 2 Dept. modifying the lower court decision, and holding that: The Supreme Court, Appellate Division, held that: (1) parties entered into an oral agreement to purchase, own, and operate the apartment building as partners, creating a partnership at will, and (2) parties’ course of conduct in connection with their prior purchase of another property was credible evidence of copartner’s obligation to reimburse partner for one half of the down payment and closing costs incurred in partnership’s purchase of the apartment building; (3) copartner was required to pay partner interest at rate of eight percent per annum; and (4) copartner did not forfeit all interest in the apartment building by failing to timely reimburse partner for his share of down payment and closing costs;
338 West 46th Street Realty LLC v. Leonardi, 32 Misc.3d 131(A), 930 N.Y.S.2d 177, N.Y. Sup. App. Term, 2011. 32 Misc.3d 131(A), 930 N.Y.S.2d 177, 2011 N.Y., WL 2749612, modifying the lower court decision and directing that the tenants, who were granted legal fees as a prevailing party in a landlord and tenant holdover summary proceedings, were not entitled to be reimbursed for the portion of their legal fees incurred in connection with the satellite DHCR proceeding instituted by landlord. The Appellate Term ruled that the agency proceeding was neither a “lawsuit” nor an “action or special proceeding” within the meaning of the lease attorney fee provision or RPL § 234;
Morton v. 338 West 46th Street Realty LLC, N.Y. 2014 Slip op. 24248, 45 Misc. 3d 544; N.Y.L.J., September 10, 2014, in this case Tenants claimed rent history fraud and in their summary judgment motion sought the Court to look beyond four-year statutory period and the court denied their motion and ruled that Court may look beyond four-year look back period to see if landlord engaged in fraud;
Plaia v Safonte, 45 AD3d 747. Mortgage Loan Acceleration: The Statute of Limitations, in the absence of an acceleration, runs from the date each payment is due (as it is considered a separate cause of action for each installment) or from the time the mortgagee is entitled to demand full payment;
Lauria v Usak-Lauria, 65 AD3d 1017 [2009]. An Interim Legal Fees in Matrimonial Matter: An award of an interim counsel fee in light of the disparity in the parties’ relative financial positions and the husband’s conduct, which resulted in unnecessary motion practice.;
Gottlieb v. Gottlieb, 101 AD3d 678, 679 [2012]. Appellate Division reversed the lower court’s Decision and Order insofar as appealed from, on the law, and that branch of the defendant’s motion which was for an award of an attorney’s fee was denied in its entirety. The Appellate Division ruled that: The court rules imposing certain requirements upon attorneys who represent clients in domestic relations matters (see 22 NYCRR part 1400) were designed to address abuses in the practice of matrimonial law and to protect the public. Substantial compliance with those rules is required, and such a showing must be made on a prima facie basis as part of the moving party’s papers and counsel for the defendant failed to establish, prima facie, substantial compliance with 22 NYCRR 1400.2 and 1400.3. Accordingly, the Supreme Court should have denied that branch of the defendant’s motion which was for an award of an attorney’s fee;
Khokhar v. Beschastnikh, et al., 48 Misc 3d 1214(A); 2015 NY Slip Op 51116(U); N.Y.L.J., August 6, 2015, Plaintiff pro se Khokhar’s Motion for Good Cause Shown for Extension to Serve Defendants was granted;
Suspended Scaffold v. Great American Construction Corp.;
In Re: Blair Ventures, LLC, vs. Famous Restoration, Inc., 581 B.R. 728; N.Y.L.J. December 11, 2017, United State District Court, S.D. of New York, involving Contempt Sanction;
Craig Gottlieb and Saud A.H, Khokhar vs. Alphabet Inc., Google LLC, Larry Page, Sergey Brin, Eric E. Schmidt and Patrick Pichette, U.S. District Court, Norther District of California, involving 28 U.S.C. § 1331 Cause: 28 U.S.C. § 1331, for: (1) violation of California Civil Code § 1671(b); (2) breach of contract; (3) breach of the implied covenant of good faith and fair dealing; (4) unjust enrichment; (5) violation of the Unfair Competition Law, California Business and Professions Code § 17200 et seq.; (6) declaratory relief under state and federal law; (7) racketeering in violation of 18 U.S.C. § 1962; (8) civil conspiracy; (9) joint venture/joint enterprise; (10) antitrust in violation of New York state law; and (11) various securities violations, seeking multimillion dollars compensatory damages.
Credentials:
Certificates and Licenses: United Nation Conference on Trade & Development, Generalized System of Preference Awarded: 1974 New York State Department of State, Real Estate Broker Awarded: 2003 New York State Department of State, Real Estate Sales Person Awarded: 1989 New York State Insurance Department, Insurance Broker Awarded: 2002 New York State Insurance Department, Life and Health Agent Awarded: 2002 New Jersey Department of Banking & Insurance, Insurance Broker Awarded: 2002 New Jersey Department of Banking & Insurance, Life and Health Agent Awarded: 2002 National Association of Security Dealers, NASD Series 6 & 63 Awarded: 2002 New York State Banking Department, Mortgage Broker Awarded: 2005 to 9-2020, New York State Department of State, Notary Public Awarded: 1998 New York City Department of Consumer Affairs, Process Server Awarded: 1996-2019, Baruch College, Internet Technology Programming Awarded: 2000 SEMINARS AND NON-TRADITIONAL FORMAT COURSES SPONSORED BY THE NATIONAL LAW FOUNDATION AND BY THE NEW YORK STATE BAR ASSOCIATION (1991-2003) Bankruptcy Reform Act of 1994; Bankruptcy Law and Litigation for New York Practitioners; Bankruptcy Litigation for Non-Bankruptcies Attorney; Immigration Law Update; New Developments, Procedures, and Regulations; Modern Tactics, Strategies and Techniques in Trial of Personal Injuries; Insurance Litigations: Practice and Procedures in the Nineties; Worker’s Compensation Law; A Practical Guide to Estate Administration in New York; Administration of Decedents’ Estates and Related Surrogate’s Court Proceedings; Serious Injury Threshold Under the No-Fault law: What You Need To Know; Developments in New York Civil Practice and Tort Law 6/03 Update; Disclosure in New York State Courts; Expert Testimony in New York Courts; The Basic Guide to Handling New York Residential Real Estate Transactions; Ethics and Professionalism for New York State Attorneys and Multijurisdictional Update; fees for New York Attorneys: Ethically Making sure you are Paid; Elderly law in New York after the 2005 Deficit Reduction Act; Ethics: Trap, Snares and Pitfalls at a Glance; The Dynasty Trust: Creating the Gift that Keeps in Giving; Advising the Purchaser or Seller of a Business; Advanced Real Estate Practice; Update on the landlord and Tenant Practice; Ethics in the Wake of New Rules of Professional Conduct; Dealing with Residential Foreclosures; Mortgage Foreclosures and Workouts; Got Title? A Practical Guide to a Successful Quiet Title Action in New York Supreme Court; MERS and Securitization in Foreclosure Litigation; Understanding Today’s Foreclosure Defense Part 2: Lender Vulnerabilities; Commercial Collections Litigation; Asset Protection Planning: What Every Practitioner Should Know; Consumer Credit: A Consumer’s Legal Rights; An Attorney’s Guide to Loan Modifications under the Home Affordable Modification Program; Due Diligence in a Business Acquisition, etc. LIBERTY MORTGAGE BANKING Melville, NY (1990) Completed the Mortgage Processing and Underwriting Course THE AMERICAN REAL ESTATE SCHOOL Hauppauge, NY (1988) Completed Real Estate Salesperson’s Course, 45 Hours
Education and Honors:
Pace University, New York City, Bachelor of Arts Degree Awarded: 1996
Honors: Membership in Pi Gamma Mu – International Honor Society in Social Sciences
Baruch College – City University of New York, Certificate in Internet Technology Programming
Awarded: 1996 Saud is also a licensed real estate broker (New York), Registered Mortgage Broker – NYS Department of Financial Services – Third-Party Loan Provider From 2005 to 9-2020 under NMLS ID#140381, Mortgage Loan Officer ID #148213), Licensed Insurance Broker and Life and Health Agent (New York and New Jersey), Licensed Process Server, and Notary Public. Saud is a REALTOR® and certified by the National Association of Realtor as: BPOR® (Broker Price Opinion Resources Specialist), CIPS® (Certified International Property Specialist, an e-PRO® (Electronic Marketing Specialist), SFR® (Short Sale and Foreclosure Resources Specialist, SRES® (Senior Real Estate Specialist).
Licenses:
Licensed Real Estate Broker, Licensed Mortgage Broker – New York State Department of Financial Service – Third Party Loan Providers from 2005 to 9-2020 under NMLS ID#140381, Mortgage Loan Officer ID #148213, Licensed Insurance Broker and Life and Health Agent (New York & New Jersey), and Notary Public
Should you have a specific requirement, please contact:
Saud A.H. Khokhar, REALTOR®, AHWD,BPOR, CIPS®, e-PRO®, GRI, PSA, RENE, RSPS, SFR, SRES®
Senior Paralegal, Licensed Real Estate Broker, Licensed Insurance Broker & Life and Health Agent (New York & New Jersey), Commercial Loans and Financing
Tel: 718.768.1474
E-Mail: SK@SaudKhokhar.com – www.SaudKhokhar.com
www.MallRoad.com™