UD Xpert:--I Help Tenants Resist--Commrcl Spclst//4 Low as $81.82//Hr. (New York-Smart & Jersey-Tough, from Suffern, NY since 2010.)

license info: AAS Degree in Paralegal Studies (Made Dean's List), from SUNY // Rockland Community College, Spring 2002.
Lawyer-Quality Paralegal-Service
John Sovak, Owner
Suffern, NY 10901
(201) 934-3306

(I conduct my business almost exclusively in the afternoon and evenings)
- ((when most of the Demand is), from around 2 or 3 in the afternoon until)
- (about 10 or 11 in the late evening. If you call me in the morning, you are
- (all-but-certain to be leaving me a voice mail. I apologize for any inconvenience.)


I have recently developed extensive-Expertise in Tenant Defense in California Unlawful Detainer (Eviction) Cases.

Now this really only applies to Holdover Tenants (CCP § 1161(1)). --- Although the Vast Majority of UD Defendants are there because of Non-Payment Claims under CCP § 1161(2), and such Non-Payment Defendants have only one real Defense, that of the Warranty of Habitability (Tenantability in CA UD parlance), this is NOT TRUE of Holdover UD Defendants.

If you cannot Pay your Rent, you will have a very difficult time in the UD Part. --- If you can and are Paying your Rent, however, then you have a Fighting Chance. --- I know ALL of the Defenses available to Holdover Defendants and will be very happy to put these Skills to-work for you.

If you can and are Paying your Rent, you have a fighting chance of keeping your Leasehold.


There is a scene in the movie "Alien" (1979), starring Sigourney Weaver, Tom Skerritt, Yaphet Kotto and John Hurt (who steals the show in the scene with the Alien bursting through his abdomen), where the Alien has ripped the Robot, named Ash, into pieces, and so Ripley (Sigourney Weaver) has to wire his head up in order to be able to speak with him.

When Ripley asks Ash's disembodied-head about the Alien, the head responds that the Alien is "Extremely Hostile and Aggressive."

Well, that is the description that applies to my Litigation Style.

I won't ever break any Rule or Law, but within the scope of the Law and the Rules, I am very happy to promise you the maximum Hostility and Aggression permitted.

I am also happy to tell you that I sometimes have had a Customer ask me to dial-back the aggression, but I have never been asked to increase it. Not once. Not ever.

At the close of the scene with Ash's speaking head, Ripley incinerates the head with a flame-thrower.

I love that scene.

Full-Range Litigation-Support, to Consumers and Attorneys Alike

I provide all of the services required to prepare for, File and pursue any Litigation.

Pre-Litigation Planning

If you are worried about evidence disappearing unless you collect it before it gets a chance to, then you certainly should collect that evidence.

There are other benefits from creating a full Litigation Plan, but this step is not required, only advisable.

Pleadings Commence Litigation: -- The Summons and Complaint, Answers and even Replies

Pleadings are the means by which Litigation is Commenced. Usually this is by way of Summons and Complaint, but it can also be by Notice of Petition and Petition.

Answers are required in all matters, or else you Default in your own Defense, and can expect to have a Default Judgment entered against you.

Replies are essentially Answers Served and Filed by the Plaintiff in Reply Counterclaims or Cross-Claims stated in the Defendant's Answer.


Motions are requests for an Order.

One of the most important types of Motions is the Motion for Summary Judgment. Motions for Summary Judgment are the primary means of ending Litigation without Trial, and sometimes even without Discovery.

Some other types of Motions are for:

--------------------------- Vacating of Default Judgments;

--------------------------- Changes of Venue;

--------------------------- in Limine (to limit evidence admissible at Trial);

--------------------------- Recusal or Disqualification of Counsel or Judge;

--------------------------- To Strike Defenses or Answers;

-------------------------- To Overturn Verdicts Rendered by Juries (for a Directed Verdict);

-------------------------- For Reconsideration of a Prior Judicial Decision;

-------------------------- For Designation as a Poor Person for Purpose of Judicial Fees and Costs;

-------------------------- For Summary Judgment (Yes, I'm Being Redundant Here, but this one is that important);

-------------------------- This List is Just off the Top of my Head, there are More!


Discovery is the process whereby all of the evidence is produced and examined in order to measure it against the various standards for, first, a Motion for Summary Judgment, and then to win at Trial.

There are basically three (3) types of Discovery:

------------------------------------------------------- Demands for Documents, Records and other things;

------------------------------------------------------- Written Questions
-------------------------------------------------------- (formally-known-as "Interrogatories"); and

------------------------------------------------------- Verbal Questioning in Person
-------------------------------------------------------- (f-k-a "Deposition under Oral Examination").

Trial Preparation: the Trial Memorandum

The most essential document of Trial Preparation is the Trial Memorandum. The Trial Memorandum follows a prescribed format and describes all of the legal points that the Plaintiff must prove, the evidence to be offered to attempt to prove each factual allegation and the legal arguments supporting its admissibility and probity.


Before Appealing, you may well wish to ask the Trial Court for Orders granting Reconsideration of a previous Judicial Decision, or to overturn a Jury Verdict.


Every Litigant is entitled to one Appeal under the Due Process Clauses of the Fifth and Fourteenth Amendments to the Constitution of the United States, and under similar clauses of the several state constitutions.

In the State of New Jersey, this Court is known as the Appellate Division. All Litigants have a right to their initial Appeal, as of right, to the Appellate Division.

Appeals to the Supreme Court of New Jersey are not guaranteed to be accepted by the Court.

Hourly Rate Pricing, Terms and Conditions

My Hourly Rate for ALL Premium Work: -- Administrative, Appellate, Criminal, Intellectual-Property and Legal Malpractice; -- is $115.00 per Hour. --- The 11-for-10 deal still applies, and it lowers the effective Hourly Rate to $104.55 per Hour (= $1150 // 11), once you purchase and use 10 full Hours.

For ALL Non-Premium Work Work, the Hourly Rate is $90.00 per Hour. --- For Customers who purchase and use 10 or more hours, I offer a 10% Time-Bonus, or 11 Hours for the price of 10 (= $900 // 11), thereby lowering the effective Hourly Rate to $81.82 per Hour.

All work is prepaid, and no work is performed prior to payment.

All payments purchase a specified number of hours of legal work. --- The amount of time purchased is equal to the amount of the payment divided by the applicable rate.

There is no converting of Hourly Rate Work Assignments into Fixed-Price Projects.


I have listed this detailed summary of the Litigation Process to let you know that I know what I am talking about when it comes to Litigation and to help you understand what it involves.

I am experienced in each and all of these areas of the Litigation Process, and I promise to give you my very best effort to obtain success in your matter.

Thank you very much for your consideration.

Lawyer-Quality Paralegal-Service
John Sovak, Owner
Suffern, NY 10901
(201) 934-3306

post id: 7758649309


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