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Seeking NY-savvy paralegal to finalize pro se court filings for Westchester Supreme divorce case.
Deliverables – Step 1: Immediate Filing for April 11, 2025 Documents to Review, Finalize & Format for NY Supreme Court Filing: 1. Affirmation in Support of Termination of Counsel • With notary block • Structured to meet NY Supreme standards • Includes brief malpractice history 2. Affidavit in Support of Poor Person Status • Conforms with CPLR § 1101 • Includes statement of income, SSI 3. Request to Waive Filing Fees • Follows CPLR § 1102 Here is a full professional breakdown you can give to the paralegal, clearly outlining the step-by-step scope of work, background, and what you need help with — including the legal strategy and goals. ⸻ PROJECT FRAMEWORK FOR PARALEGAL ASSISTANCE Client: Anthony Cacace Jurisdiction: New York State Supreme Court – Westchester County Case: Divorce – ⸻ STEP 1: URGENT RESPONSE TO ORDER TO SHOW CAUSE (Hearing – April 11, 2025) Background Summary: • I’m currently pro se due to my attorney (Samuel Manrique) filing a motion to withdraw • I’m not opposing the withdrawal, but I need to make a record showing the damage caused by my representation and request relief due to disability and financial hardship Deliverables Needed: 1. Affirmation in Support of Termination of Counsel • Clearly state I’m not opposing, but document misconduct: • Told me to answer a contempt motion on my own • Failed to respond to motions • Did not submit required disclosures • Poor communication 2. Affidavit of Poor Person Status (CPLR § 1101) • Disability, SSI only income • No assets or employment 3. Request to Waive Filing Fees (CPLR § 1102) • Based on indigence 4. Request for Virtual Appearance • Due to disability, transportation issues • In process of receiving home health aide 5. Hardship Statement • Loss of business, forced relocation, vehicle repossessions, debt default 6. Proof of Service • On Plaintiff’s counsel and former attorney 7. Cover Letter to the Court • Summarizes submission professionally 8. Exhibit Index • References SSI letter, repossession notices, lease agreements, emails, and financial hardship ⸻ STEP 2: RESTORE TO DISCOVERY PHASE AND PROTECT MARITAL ASSET Litigation Goals: • Vacate or postpone inquest hearing (May 13, 2025) • Request full discovery from opposing party • Request exclusive use and control of the marital residence • Present all facts and evidence showing I’ve pivoted the property into a real business (100% occupancy, leases, Airbnb transition) Future Motions to Prepare: 1. Motion to Vacate Inquest / Restore Case to Discovery Phase • Based on attorney’s negligence, missed filings, and outstanding discovery • Improper to proceed to inquest without full exchange of financials 2. Formal Discovery Demand (CPLR § 3120) • Demand financial disclosures from Plaintiff: • 401(k)s, stock accounts, joint accounts with relatives, car sale docs, power of attorney used at closing, life/health insurance, income, tax returns 3. Motion for Exclusive Use and Control of Marital Residence • I occupy and maintain the home • Operate a legal rental business from it • Ex-wife tampered with guests and security • Filed leases with current tenants 4. Formal Response to Contempt Motion • Refute false claim that ex-wife was locked out of Airbnb • Clarify business ownership (60% mine) • Show Airbnb was never profitable under her control • Business pivoted to month-to-month leases for sustainability ⸻ Additional Context for Legal Strategy • Former attorney’s failures put me at risk for contempt and inquest • Opposing counsel is controlling the narrative — this must be corrected • I am acting in good faith, not seeking delays — I’ve turned this into a functioning business • Property is occupied under valid lease agreements, including one I signed as owner-operator • Need legal help making filings court-compliant, strong, and professional ⸻ Let me know if you’d like this exported as a Word or PDF file to send directly to the paralegal. This is a solid foundation for them to step in and help fast.
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