Professional Paralegal Services
Saud A.H. Khokhar provides low cost legal researching, writing and preparing pleadings, petitions, applications, motions, appeals and discovery services under attorney supervision for presentation in Civil Courts, Supreme Courts, Appelalte Divisions, United States Citizenship and Homeland Security (Formerly Immigration and Naturalization Service), Administrative Agencies, and Federal Courts including Federal Bankruptcy Courts 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, etc.
Saud is the primary drafter of appeals, 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;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); N.Y.L.J., August 6, 2015, Plaintiff pro se Khokhar’s Motion for Good Cause Shown for Extension to Serve Defendants was granted.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. Further, Saud also has over 25 years of combined experience in Real Estate, International Business, Insurance, Import & Export, E-Commerce and Financing.
Saud is graduate of Pace University, New York City, with a Bachelor of Arts Degree awarded in 1996 and as a Pace scholar was named to the Pi Gamma Mu – International Honor Society in Social Sciences. Saud also earned a Certificate in Internet Technology Programming from the Baruch College – City University of New York. Saud is also a Graduate of REALTOR® Institute. Saud is also a licensed real estate broker (New York), Registered Mortgage Broker – NYS Department of Financial Services – Third-Party Loan Provider (NMLS ID#14038, NMLS Mortgage Loan Officer ID #148213), Licensed Insurance Broker and Life and Health Agent (New York and New Jersey), Licensed and Bonded Process Server, and Notary Public. Saud is also 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); RSPS (Resort and Second Home Property Specialist); SFR® (Short Sale and Foreclosure Resources Specialist), SRES® (Senior Real Estate Specialist).
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
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