Saud has over 25 years of experience in legal researching, writing and preparing pleadings, petitions, applications, motions, appeals, and discovery for presentation in Civil Courts, Supreme Courts, Appelalte Divisions, Court of Appeals of the State of New York, United States Citizenship and Homeland Security (Immigration and Natrulaization Service), Administrative Agencies, and Federal Courts including Federal Bankruptcy Courts. Further Saud has extensive experience in Real Estate, Mortgage, Insurance, International Business, and E-Commerce.

Saud is the primary drafter of appeals and opposition papers 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 mortaggee'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 holdind 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;

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.

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.

An Interm Legal Fees i n 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.

Saud also has experience in Federal Litigation practice and defense of patent, copy right and trade mark infringements cases. Saud aided attorney involved in Immigration and Federal Litigation practice and defense of patent, copyright and trade mark infringements cases commenced by such famous names as E.T., Michael Jackson, Adidas, Gremlin, Seiko, Cabbage Patch Kids, Menudo, etc. Further, Saud also has over 25 years of combined experience in Real Estate, International Business, Insurance, Import & Export, E-Commerce and Financing.

Should you have a specific requirement, please contact:

Saud A.H. Khokhar, REALTOR®, e-PRO®, SFR®, SRES®