Notice of Motion For Impleader of Former of Counsel Attorneys Robert Androsiglio, Luis Ricardo Trujillo, and Anthony Motta Filed
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Rahul ManchandaNotice of Motion For Impleader of Former of Counsel Attorneys Robert Androsiglio, Luis Ricardo Trujillo, and Anthony Motta Filed
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Rahul ManchandaUNITED STATES BANKRUPTCY COURT
SOUTHERN DISTRICT OF NEW YORK
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IN THE MATTER OF I ,;, . ) -}NDEX NO.
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0 -t..oVERSARY
RAHUL MANCBANDA s.o. f )
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) ROBERT ANDROSIGLIO, LUIS RICARDO
) TRUJILLO, AND ANTHONY MOTTA
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PLEASE TAKE NOTICE that upon the annexed affirmation of Rahul Manchanda duly
affirmed the 7th day of August 2024, the annexed Memorandum of Law and
Exhibits, and all the Pleadings and Proceedings heretofore had herein, the
Undersigned will move this Honorable Court at US SDNY Bankruptcy Court, 300
Quarropas Street White Plains, NY 10601-4150 on August 15, 2024 at 10 AM or
at a mutually agreeable time and place for an order impleading former Of
Counsel Attorneys Robert Androsiglio, Luis Ricardo Trujillo, and Anthony
Motta for any and all real or possible liability stemming from their actions
as my lawyers on the underlying New York County Supreme Court case index no
152538/2019, since Debt6r did zero work on said case, and the documented
billable hours recorded show that the above referenced lawyers did 100% of
the relevant legal work on said case, pursuant FRCP § 14 and Rule 7002
dealing with Third Party Practice, Federal Rules of Bankruptcy Procedure§
7014:
Even assuming that the attached Order of Judge Dakota Ramseur violated the
automatic bankruptcy stay as per the Motion for Contempt submitted to the
court yesterday August 6, 2024 for a return date of August 15, 2024, even
though she knew that a Stay exists, that SDNY Federal Bankruptcy Judge Sean
Lane has declared this Senderoff case now in an Adversary Proceeding brought
by his lawyers, into a "sine die" status, but anyway Judge Dakota Ramseur
still continues to willfully fail to comply with this Honorable Bankruptcy
Court of the Automatic Stay pursuant to 111 U.S.C. § 362 and protection of
this Honorable Court by continuing to engage in proceedings in her lower
court case index no 152538/2019, issuing orders and judgments when no one
is either present or litigating, all the while threatening, harassing,
intimidating, litigating, ordering, and otherwise violating federal and
bankruptcy law protection, and the stay and the orders of this federal
court, Debtor hereby impleads pursuant to FRBP § 7014, FRCP § 14, and Rule
7002 the above named Of Counsel lawyers who did all relevant legal work
according to billable hour records, while Debtor did zero work on that case.
Dated: August 7, 2024
New York, NY Rahul Manchanda, Esq.
Manchanda Law Office PLLC
2 70 Victory Boulevard
New Rochelle, New York 10804
Tel ;. (21 2 ) 968-8600
Fax : ( 212 ) 9 6 8 - 8 6 0 1
UNITED STATES BANKRUPTCY COURT
SOUTHERN DISTRICT OF NEW YORK
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)
)
)
IN THE MATTER OF ) INDEX NO. 23-22095
) ADVERSARY PROCEEDING 23-07008
)
RAHUL MANCBANDA ) AFFIRMATION IN SUPPORT FOR
) MOTION TO IMPLEAD FORMER
) OF COUNSEL ATTORNEYS ROBERT
) ANDROSIGLIO, LUIS RICARDO
-----------------------------------x TRUJILLO, AND ANTHONY MOTTA
STATE OF NEW YORK }
:ss
COUNTY OF WESTCHESTER }
RABUL MANCBANDA, an Attorney duly licensed to practice law in the State of
New York, affirms the following to be true under penalty of perjury:
1. I make this Affirmation in support of this Motion for Impleader of my
former Of Counsel Attorneys Robert Androsiglio, Luis Ricardo Trujillo,
Anthony Motta pursuant to FRBP § 7014, FRCP § 14, and Rule 7002 for
any and all real or possible liability stemming from their actions as
my lawyers on the underlying New York County Supreme Court case index
no 152538/2019,
2. since undersigned Debtor did zero work on said case,
3. the documented billable hours recorded show that the above referenced
lawyers did 100% of the relevant legal work on said case,
4. pursuant FRCP § 14 and Rule 7002 dealing with Third Party Practice,
and Federal Rules of Bankruptcy Procedure§ 7014;
5. Even assuming that the attached Order in New York County Supreme Court
case index no 152538/2019 of Judge Dakota Ramseur violated the
automatic bankruptcy stay, as per the Motion for Contempt submitted
to the court yesterday, August 6, 2024 with a return date of August
15, 2024 at 10:00 AM,
6. even though Judge Dakota Ramseur knew that a Stay exists,
7. that SDNY Federal Bankruptcy Judge Sean Lane declared that this
Senderoff case now is in an Adversary Proceeding in a "sine die"
status,
8. but anyway Judge Dakota Ramseur still continues to willfully fail to
comply with this Honorable Bankruptcy Court of the Automatic Stay
pursuant to 111 U.S.C. § 362 and protection of this Honorable Court,
by continuing to engage in proceeding in her lower court case, issuing
orders and judgments when no one is either present or litigating, all
the while threatening, harassing, intimidating, litigating, ordering,
and otherwise violating federal bankruptcy protection, the stay, and
orders of this federal court,
9. Also wherein Judge Dakota Ramseur wilfully ignores the multiple
written findings, rulings, opinions, orders, and judgments, after a
full trial, with extensive exhibits, depositions, pleadings, over many
weeks and months presided over by former New York County Supreme Court
Appellate Division, First Department Judge Rosalyn Richter in case
index nos 1336 .2021 and 2023-05258, that there is absolutely no
evidence or proof that Debtor Rahul Manchanda defamed or otherwise
wrote anything about Douglas Senderoff or anyone else that they
mention on the internet,
9. Debtor hereby formally impleads former Of Counsel Attorneys Robert
Androsiglio, Luis Ricardo Trujillo, and Anthony Motta pursuant to FRBP
§ 7014, FRCP § 14, and Rule 7002, since Debtor did zero work on the
below case index no 152538/2019, while the impleaded Of Counsel
lawyers named above did 100% of all relevant legal work according to
documented and fully paid for billable hour records.
WHEREFORE, it is respectfully requested that this Motion be granted in all
respects together with such other and further relief as this Honorable
Court deems to be just and proper, including contempt, costs, penalties,
fines, incarceration, and sanctions against Defendants and Third Party
Defendants, in light of the information contained herein.
Dated: August 7, 2024
New York, NY Rahul Manchanda, Esq.
CERTIFICATE OF SERVICE
On August 7, 2024, I, Rahul Manchanda, served a copy of this Notice of
Motion for Impleader of Debtor's former Of Counsel Attorneys Robert
Androsiglio, Luis Ricardo Trujillo, and Anthony Motta at their last known
addresses, and any attached pages to New York County Supreme Court Judge
Dakota Ramseur, 60 Centre Street, New York NY 10007, all via U.S. and
Electronic Mail.
By: Rahul Manchanda, Esq.
Manchanda Law Office PLLC
270 Victory Boulevard
New Rochelle, New York 10804
Tel: (212) 968-8600
Fax: (212) 968-8601
NYSCEF Alert: New York - Torts - Other - Upload of Order/Judgment 152538/2019 (Douglas Senderoff MD v. Rahul Manchanda Esq.)
Subject: NYSCEF Alert: New York - Torts - Other - Upload of Order/Judgment 152538/2019 (Douglas
Senderoff MD v. Rahul Manchanda Esq.)
From: [email protected]
Date: 8/5/2024, 3:30 PM
To: [email protected], [email protected], [email protected],
[email protected], [email protected], [email protected], [email protected],
[email protected]
New York County Supreme Court
UPLOAD OF ORDER/JUDGMENT
Document: 192 - DECISION + ORDER ON MOTION
The document referred to in this notification is an order or judgment that has been
uploaded to NYSCEF but has not been entered. You may access the order/judgment by
clicking the document type link (above).
Unless otherwise directed by the court, receipt of this notification does not constitute service
of the referenced order/judgment upon any party. See e-filing rules regarding service of an
order/judgment with notice of entry 202.5-b(hl(i}.
NYSCEF will send out an additional e-mail notification upon entry in the office of the County
Clerk.
Case Information
Index#: 152538/2019
Caption: Douglas Senderoff MD v. Rahul Manchanda Esq.
eFiling Status: Full Participation Recorded
Assigned Case Judge: Dakota D. Ramseur
E-mail Service Notifications Sent
Name Email Address
LUIS TRUJILLO Jr. [email protected]
ROBERT ANDROSIGUO [email protected]
Anthony Motta [email protected]
1 of2 8/7/2024, 6:26 A~
NYSCEF Alert: New York - Torts - Other - Upload of Order/Judgment 152538/2019 (Douglas Senderoff MD v. Rahul Manchanda Esq.)
DAVID UN [email protected]
RAHUL MANCHANDA [email protected]
NOnCE: This e-mail is intended only for the named recipient and for the purposes of the New York State Courts
E-Filing System. If you are neither the intended recipient nor a person designated to receive messages on behalf
of the intended recipient, notify the sender immediately.
If you are unsure of the contents or origin of this email, it is advised to NOT dick on any links
provided. Instead, log into your NYSCEF account to access the documents refetTed to in this email.
Thank you.
'
Hon. Milton A. Tingling, New York County Clerk and Clerk of the Supreme Court
•
' Phone: 646-386-5956
.
Website: http://www.nycourts.gov/courts/ljd/supctmanh/county_clerk_operations.shtml
2 of2 8/7/2024, 6:26 Ar.
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INDEX NO. 152538/2019
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