UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF NEW YORK

-----------------------------------x
INDEX NOS. 23-22095, 23-11805

NOTICE OF MOTION FOR CONTEMPT OF

IN THE MATTERS OF COURT AGAINST MICAH LOPEZ, LAWYERS
FUND FOR CLIENT PROTECTION, MICHAEL
KNIGHT, ATTORNEY REMI SHEA

RAHUL MANCHANDA,
MANCHANDA LAW OFFICE PLLC
.(.;

CJ
-----------------------------------x C>
'
PLEASE TAKE NOTICE that upon the annexed affirmation of Ra!1ul Manchanda duly
affirmed the 30th day of March 2025, the annexed Memo~a1ictum of Law and
Exhibits, and all of the Pleadings and Proceedings heretofor~ had herein,
the Undersigned will move this Honorable Court at U.S. SDNY Bankruptcy
Court, 300 Quarropas Street White Plains, NY 10601-4150 on April 9, 2025 at
2:00 PM or at a mutually agreeable time and place for an order holding the
above referenced indi victuals in Civil and Criminal Contempt of Court
pursuant to U.S. Federal Bankruptcy Law for willful violations of the Stay
pursuant to 111 U.S.C. § 362, and the following:

1. On the grounds that as per the attached, even though these individuals
know that a Stay exists, but anyway they still continue to willfully
fail to comply with this Honorable Bankruptcy Court through the
Automatic Stay pursuant to 111 U.S.C. § 362 and Protection of this
Honorable Court by continuing to engage in collections, threats,
intimidation, harassment, defamation, extortion, lawsuits, enabling,
encouraging, aiding, abetting, facilitating (Attorney Remi Shea,
Lawyers Fund for Client Protection, Michael Knight), blackmail, and
otherwise violating federal bankruptcy protection, the stay, and the
orders of this federal court;

2. On the grounds that even though they have repeatedly received written
and electronic Notice of Chapter 7 Bankruptcy Filings for cases 23-
22095 and 23-11805, they continue to engage in threatening, harassing,
intimidating, litigating, suing, enabling, encouraging, collecting, and
otherwise violating federal bankruptcy protection and the stay;

3. On the grounds that nothing less than sanctions, penalties, fines, and
incarceration will persuade them to comply with this Honorable Court's
Automatic Stay and Protection from continuing to engage in threatening,
harassing, intimidating, litigating, suing, enabling, encouraging,
collecting, and otherwise violating federal bankruptcy protection and
the stay;
4. On the grounds that if they are not forced to comply with this
Honorable Court's Automatic Stay and Protection from continuing to
engage in threatening, harassing, intimidating, litigating, suing,
enabling, encouraging, collecting, and otherwise violating federal
bankruptcy protection and the stay, then they will have reduced federal
bankruptcy protection to a shambles;

5. On the grounds that their willful and intentional noncompliance with

the Automatic Stay and Protection prohibiting their continuing to
engage in threatening, harassing, intimidating, litigating, suing,
enabling, encouraging, collecting, and otherwise violating federal
bankruptcy protection and the stay, and otherwise aggressive disregard
for federal bankruptcy protection of this Honorable Court will have
defeated, impaired, impeded and prejudiced Debtor's rights;

6. And even though we have complied with SDNY Bankruptcy Judge Sean Lane's
verbal and written instructions to first notify these people in writing
and/or verbally of our intent to seek this court's intervention,
especially the trustees who literally do not even return Debtor's
countless emails and requests to warn the co-contemnors, they do
nothing, thus necessitating emergency action by Debtor.

7. And for such other further relief as this Honorable Court deems just
and proper, including contempt, costs, penalties, fines, incarceration,
and sanctions against them for willful violations of U.S. Federal
Bankruptcy Law, willful violations of the Stay pursuant to 111 U.S.C.
§ 362, and in light of the information contained herein.

Dated: March 30, 2025

New York, NY Rahul Manchanda (Pro Se)
270 Victory Boulevard
New Rochelle, New York 10804
Tel: (646) 645-0993
UNITED STATES BANKRUPTCY COURT
SOUTHERN DISTRICT OF NEW YORK
-----------------------------------x
)
)
)
IN THE MATTER OF ) INDEX NOS. 23-22095, 23-11805
)
)
RAHUL MANCHANDA, ) AFFIRMATION IN SUPPORT OF
MANCHANDA LAW OFFICE PLLC ) MOTION FOR CONTEMPT
)
)
-----------------------------------x
STATE OF NEW YORK }
:ss
COUNTY OF WESTCHESTER }

RAHUL MANCHANDA affirms the following to be true under penalty of perjury:

1. I make this Affirmation in support of this Motion for Contempt of

Court against the above referenced individuals in all respects based
upon my personal knowledge of the facts and experiences that I relate
herein, based upon information and belief, and based on the contents
of the file.

2. On the grounds that as per the attached, even though these individuals
know that a Stay exists, but anyway they still continue to willfully
fail to comply with this Honorable Bankruptcy Court through the
Automatic Stay pursuant to 111 U.S.C. § 362 and Protection of this
Honorable Court by continuing to engage in collections, threats,
intimidation, harassment, defamation, extortion, lawsuits, enabling,
encouraging, aiding, abetting, facilitating (Attorney Remi Shea,
Lawyers Fund for Client Protection, Michael Knight), blackmail, and
otherwise violating federal bankruptcy protection, the stay, and the
orders of this federal court;

2. On the grounds that even though they have repeatedly received written
and electronic Notice of Chapter 7 Bankruptcy Filings for cases 23-
22095 and 23-11805, they continue to engage in threatening, harassing,
intimidating, litigating, suing, enabling, encouraging, collecting,
and otherwise violating federal bankruptcy protection and the stay;

3. On the grounds that nothing less than sanctions, penalties, fines, and
incarceration will persuade them to comply with this Honorable Court's
Automatic Stay and Protection from continuing to engage in
threatening, harassing, intimidating, litigating, suing, enabling,
encouraging, collecting, and otherwise violating federal bankruptcy
 protection and the stay;

4. On the grounds that if they are not forced to comply with this
Honorable Court's Automatic Stay and Protection from continuing to
engage in threatening, harassing, intimidating, litigating, suing,
enabling, encouraging, collecting, and otherwise violating federal
bankruptcy protection and the stay, then they will have reduced
federal bankruptcy protection to a shambles;

5. On the grounds that their willful and intentional noncompliance with

the Automatic Stay and Protection prohibiting their continuing to
engage in threatening, harassing, intimidating, litigating, suing,
enabling, encouraging, collecting, and otherwise violating federal
bankruptcy protection and the stay, and otherwise aggressive disregard
for federal bankruptcy protection of this Honorable Court will have
defeated, impaired, impeded and prejudiced Debtor's rights;

6. And even though we have complied with SONY Bankruptcy Judge Sean
Lane's verbal and written instructions to first notify these people
in writing and/or verbally of our intent to seek this court's
intervention, especially the trustees who literally do not even return
Debtor's countless emails and requests to warn the co-contemnors, they
do nothing, thus necessitating emergency action by Debtor.

7. And for such other further relief as this Honorable Court deems just
and proper, including contempt, costs, penalties, fines,
incarceration, and sanctions against them for willful violations of
U.S. Federal Bankruptcy Law, willful violations of the Stay pursuant
to 111 U.S.C. § 362, and in light of the information contained herein.

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 Contemnors for violation of
U.S. Federal Bankruptcy Law, willful violations of the Stay pursuant to 111
U.S.C. § 362, and in light of the information contained herein.

Dated: March 30, 2025

New York, NY Rahul Manchanda (Pro Se)
270 Victory Boulevard
New Rochelle, New York 10804
Tel: (646) 645-0993
 CERTIFICATE OF SERVICE

On March 30, 2025, I, Rahul Manchanda, served a copy of this Motion for
Contempt of Court and any attached pages to the above referenced
individuals as follows: Micah Lopez located at 16 Brevoort Road, Chappaqua,
New York 10514, Michael Knight and Lawyers Fund for Client Protection
located at 119 Washington Avenue, Albany, New York 122210, Attorney Remi
Shea located at NYS Unified Court System, 27 MADISON AVE, NEW YORK, NY
10010-2201 via Electronic and/or U.S. Mail and/or Facsimile.

By: Rahul Manchanda (Pro Se)

Manchanda Law Office PLLC
270 Victory Boulevard
New Rochelle, New York 10804
Tel: (646) 645-0993
 ua1m n l!:JUlUSl, Micah Lopez, Response Letter Plus Exhibits

Subject: Claim# 2501052, Micah Lopez, Response Letter Plus Exhibits

From: Rahul Manchanda Gmail Account <[email protected]>
Date: 3/29/2025, 7:50 PM
To: [email protected]
CC: [email protected], FBI IC <[email protected]>, "[email protected]" <[email protected]>,
"Wenzler,Robert" <[email protected]>, "Pena, Jose" <[email protected]>,
[email protected], "[email protected]" <[email protected]>,
GUARDAutomatedDeliverySystem <[email protected]>, [email protected], Keith Grunberg-
Daniels <[email protected]>, "Buckle, Jake" <[email protected]>,
[email protected], [email protected], [email protected],
[email protected], ICEOPRlntake <[email protected]>, [email protected], CRCLCompliance
<[email protected]>, [email protected]
BCC: [email protected], [email protected]

March 29, 2025

VIA FACSIMILE AND U.S. MAIL

Michael J. Knight
The Lawyers Fund for Client Protection of the State of New York
119 Washington Avenue
Albany, New York 122210
Fax: {518) 434-5641

RE: Claim # 2501052, Micah Lopez, Response Letter Plus Exhibits

Dear Michael J. Knight:

As per the below and the attached, and in response to former client Micah Lopez's characteristically
misleading, if not perjurious, "Claim for Reimbursement," we respond as follows:

1. The only dishonest person here is Micah Lopez, who used and abused our law firm and staff over
a period of weeks and months on his illegal alien girlfriend and then refused to pay us as per contract.

2. We were also forced to contact the police when he started threatening, extorting and harassing
us for money.

3. Our law firm duly provided legal, research, investigation, consultation, advisory services in
connection with his exploited "girlfriend" who he refused to marry in a quick and timely fashion,
choosing instead to torture and keep her sexually enslaved instead of filing her immigration papers -
even though we quickly provided him with legal and equitable solutions as per the attached, he fired
us and demanded his duly earned retainer fee back.

4. Micah Lopez is a con-artist and violent sexual predator, which we were able to determine and

1 of3 3/30/2025, 9:56 A~

 ua1m ff Z~UlU52, Micah Lopez, Response Letter Plus Exhibits

surmise after providing this loser with months of free consultations until he finally retained/paid us.

5. As indicated above, it is our observation that Micah Lopez preferred keeping his 11 girlfriend 11 in
immigration limbo and indentured sexual servitude rather than filing her immigration papers, so that
he could continue to keep her in fear and sexual slavery, and when our law firm team questioned why
he was delaying/refusing to file such an easy case, he fired us.

6. We are now in the process of filing a motion for contempt of court in bankruptcy court against
Micah Lopez because he was already named as a Creditor therein, he did not file a motion to remove
or lift the automatic bankruptcy stay, including Attorney Grievance Committee 1st Department Staff
Attorney Remi Shea who he names in his legal fee lawsuit/complaint with the Lawyers Fund for Client
Protection as aiding, abetting, counseling, encouraging, and advising him to violate this automatic
bankruptcy stay in violation of 11 U.S.C. § 362.

7. Micah Lopez makes many false statements - we have no outstanding judgments against us that
we need to pay after 25 years of law firm business.

8. As indicated above we are taking Remi Shea to bankruptcy court for contempt for encouraging
him to violate the automatic stay.

9. Once again, Micah Lopez' own words herein are a major red flag - after months of working with
and advising this con-artist on how easy it was to fix her illegal immigrant situation, we could not
understand why he delayed, ignored, refused to follow our legal advice, and instead chose to keep his
"girlfriend" in immigration limbo and illegal alien status.

10. After multiple conversations with Micah Lopez, the police and other law enforcement agencies,
we came to the conclusion that the reason that he did not file her immigration papers, and that his
"girlfriend" STILL does not have legal immigration status more than 2 years after we last dealt with
him and he supposedly has another immigration lawyer, is that he is purposefully refusing to file her
papers and deliberately keeping her in a dependent, exploitative, sexual slavery situation, and that
this was one of the main reasons our legal services were terminated.

11. Client secrets are one thing:, but when the client tries to gaslight and project his criminality on to
his lawyers, we have a right to def.end ourselves per the law and the Ethics Codes.

Respectfully submitted,

Rahul Manchanda (Pro Se)

270 Victory Boulevard
New Rochelle, NY 10804
Tel: (646) 645-0993
[email protected]

2 of3 3/30/2025, 9:56 All

 L1a1m # L501U52, Micah Lopez, Response Letter Plus Exhibits

cc: AMGuard Professional Liability Insurance Company, Micah Lopez, 16 Brevoort Road, Chappaqua,
New York 10514, New Rochelle Police Department, FBI NYC Field Office, DHS/ICE, Lockton Affinity

Kind regards,

Rahul Manchanda
Licensed Real Estate Broker
Manchanda Real Estate Broker New York LLC
125 Park Avenue, 25th Floor
New York, New York 10017
Tel: (212) 968-8600
Fax: (212) 968-8601
Mob: (646) 645-0993
Email: rahul.manchanda.new,[email protected]
Web: www.manchanda-realestate.com

~~. Virus-free.www.norton.com

- Attachments:---------------------------------

Claim # 2501052, Micah Lopez, Response Letter Plus Exhibits.pdf 562 KB

3 of3 3/30/2025, 9:56 A~

 Rahul Manchanda (Pro Se)
270 Victory Boulevard
New Rochelle, NY 10804
Tel: (646) 645-0993
Email: [email protected]

March 29, 2025

VIA FACSIMILE AND U.S. MAIL

Michael J. Knight
The Lawyers Fund for Client Protection of the State of New York
119 Washington Avenue
Albany, New York 122210
Fax: (518) 434-5641

Re: Claim# 2501052, Micah Lopez, Response Letter

Dear Michael J. Knight:

In response to Micah Lopez's characteristically misleading, if not

perjurious, "Claim for Reimbursement," we respond as follows:

1. The only dishonest person here is Micah Lopez, who used and

abused our law firm and staff over a period of weeks and

months on his illegal alien girlfriend and then refused to pay

us as per contract.

2. We were also forced to contact the police when he started

threatening, extorting and harassing us for money.

3. Our law firm duly provided legal, research, investigation,

consultation, advisory services in connection with his

 exploited "girlfriend" who he refused to marry in a quick and

timely fashion, choosing instead to torture and keep her

sexually enslaved instead of filing her immigration papers -

even though we quickly provided him with legal and equitable

solutions as per the attached, he fired us and demanded his

duly earned retainer fee back.

4. Micah Lopez is a con-artist and violent sexual predator, which

we were able to determine and surmise after providing this

loser with months of free consultations until he finally

retained/paid us.

5. As indicated above, it is our observation that Micah Lopez

preferred keeping his "girlfriend" in immigration limbo and

indentured sexual servitude rather than filing her immigration

papers, so that he could continue to keep her in fear and

sexual slavery, and when our law firm team questioned why he

was delaying/refusing to file such an easy case, he fired us.

6. We are now in the process of filing a motion for contempt of

court in bankruptcy court against Micah Lopez because he was

already named as a Creditor therein, he did not file a motion

to remove or lift the automatic bankruptcy stay, including

Attorney Grievance Committee 1 st Department Staff Attorney Remi

Shea who he names in his legal fee lawsuit/complaint with the

 Lawyers Fund for Client Protection as aiding, abetting,

counseling, encouraging, and advising him to violate this

automatic bankruptcy stay in violation of 11 U.S.C. § 362.

7. Micah Lopez makes many false statements we have no

outstanding judgments against us that we need to pay after 25

years of law firm business.

8. As indicated above we are taking Remi Shea to court for

contempt for encouraging him to violate the automatic stay.

9. Once again, Micah Lopez' own words herein are a major red flag

- after months of working with and advising this con-artist on

how easy it was to fix her illegal immigrant situation, we

could not understand why he delayed, ignored, refused to

follow our legal advice, and instead chose to keep his

"girlfriend" in immigration limbo and illegal alien status.

10. After multiple conversations with Micah Lopez, the police and

other law enforcement agencies, we came to the conclusion that

the reason that he did not file her immigration papers, and

that his "girlfriend" STILL does not have legal immigration

status more than 2 years after we last dealt with him and he

supposedly has another immigration lawyer, is that he is

purposefully refusing to file her papers and deliberately

 keeping her in a dependent, exploitative, sexual slavery

situation, and this was one of the main reasons our legal

services were terminated.

11. Client secrets are one thing, but when the client tries to

gaslight and project his criminality on to his lawyers, we

have a right to defend ourselves per the law and the Ethics

Codes.

Respectfully submitted,

Rahul Manchanda (Pro Se)

270 Victory Boulevard
New Rochelle, NY 10804
Tel: ( 646) 645-0993
~i!~-•--~,~l~
cc: AMGuard Professional Liability Insurance Company
Micah Lopez, 16 Brevoort Road, Chappaqua, New York 10514
To: Mr. Rahul Manchanda, Esq.
From: Brian Hamid and Richa Bhandari, Esq.
Date: 08/25/2023
Memorandum of Law for Micah Lopez

INTRODUCTION

Mr. Lopez and his girlfriend were retained on August 81h, 2023, after paying the retainer of $5000.00. The
Agreement that she signed states that "The hourly time charges for the firm attorneys and support staff
will be billed against the retainer fee. Senior attorneys bill at $500 USD per hour, Junior Attorneys at
$350 an hour, Senior Paralegals bill at $250 an hour and Law Clerks bill at $150 an hour. Furthermore
"upon exhaustion of the retainer fee the firm may request an additional retainer or replenishment fee".
Mr. Lopez's girlfriend's immigration status is in jeopardy. Through analysis of the facts, we can conclude
there is a strong case to file an 1-601 hardship waiver, 42B Cancellation of Removal, and an I-589.

Mr. Lopez's girlfriend's 2 previous attorneys failed to meet their ethical responsibility in filing these
documents so complaints should also be filed against them with the New York State Bar Association.

RULE OF LAW

1-601 Hardship Waiver - In order to apply for this waiver, the applicant must submit evidence that their
denial of admission to the United States would cause extreme hardship to their sponsoring U.S. legal
citizen or permanent resident. Evidence ofhardship can include Evidence establishing a family
relationship or familial ties to the United States, impact of separation or relocation, which can include
financial impact, health conditions and quality of health treatment or significant strain on quality of life,
social conditions, economic conditions.

42B Cancellation of Removal application - The qualifications for this application are as follows: the
individual must have maintained continuous physical presence in the United States for ten (10) years or
more, and you have been a person of good moral char- acter as defined in section lOl(f) of the INA
during such period; 2. You have not been convicted of an offense covered under sections 212(a)(2),
237(a)(2), or 237(a)(3) of the INA. Your removal would result in exceptional and extremely unusual
hardship to your United States citizen or lawful permanent resident spouse, parent, or child, and you are
deserving of a favorable exercise of discretion on your application.

I-589 Asylum for changed circumstances - This application is used to apply for asylum in the United
States and for withholding of removal (formerly called "withholding of deportation"). This application
may also be used to apply for protection under the Convention Against Torture (CAT).

DISCUSSION

Mr. Lopez's girlfriend has an 8-year-old son who is a US Citizen. From this we can ascertain she has been
residing in the United States for at least 7 years. Because of this she meets the standard to apply for the
I-601 Hardship waiver. If Mr. Lopez's girlfriend has continued residing in the U.S and been a "lawful"
citizen for the past 7 years she would then also be eligible for the 42B Cancellation of Removal
application. If Mr. Lopez's girlfriend returned to her country of origin she would face certain persecution,
this would make her eligible to file for the 1-589 Asylum for changed circumstances. As a victim of
human trafficking, she would also qualify for a T-Visa non-migrant status. An assessment by our Forensic
Expert Dr. George Ramos will show the effects her history of trauma has had on her life.

Mr. Lopez's girlfriend's 2 previous attorneys failed to meet their ethical responsibility in filing these
documents so complaints should be filed against them.

CONCLUSION

Based on aforementioned facts and rule oflaw it is advisable to pursue this case. Ifwe can provide
evidence and supporting documentation for the 1-601, 42B and 1-589 applications we will surely receive
an approval.
 t '.

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[email protected] ,..3
TO: Mr. Rabal Maacllanda
FROM: Ridla Bhandari

DATE: 88/21/2023

RE: Memorandum of law - Mr. Micala Lopa

Lawyen responsibilities/ is it inefl'eetive assistance of CHnsel to dints who an
uarespoasivelwaveriag/unresponsive/disrespeetfal/terminate lerVicet ri&•t after retaialag

This Meme will discuss the attoraey's respoaslbllldes ud dMin when die dieat ha &iped
reuiaer or paid fall/substa■tial part of the retainer fee alld then have terminated serviees.

Mr. Lopez and his girlfriend were retained on August 8th. 2023, after paying the retainer of
$5000.00. The Agreement that she signed s ~ that "'The hourly time charges for the firm
attorneys and support staff will be billed against the retainer fee. Senior attorneys bill at SSOO USD
per hour. Junior Attorneys at $350 an hour. Senior Paralegals bill at S250 an hour and Law Clerks
bill at S 150 an hour. Furthennore "upon exhaustion of the retainer fee the firm may n:quest an
additional retainer or replenishment fee".
Mr. Lopez hired the finn 's girlfriend's immigration status is injeopa:nty. Throughanalysis oftbe
~ we concluded there is a strong case to file an 1-60 I hardship waiver, 428 Cancellation of
Removal. and an 1-589. Mr. 1..opez•s girlfriend's 2 previous attorneys failed to meet their c:drical
responsibility in filing these documents so complaints should also be filed against them with the
New York State Bar Association.
Mr. Lopez•s girlfriend bas an 8-year-old son who is a US Citizen. From this we can ascertain she
has been residing in the United States for at least 7 years. Because of this she meets the standaid
to apply for the 1-601 Hardship waiver. If Mr. Lopez's girlfriend has cootinued 1'esufi,W ia the U.S
and been a 'iawful" citizen for the past 7 years she would then also be eligible for the 42B
Cancellation of Removal application. If Mr. Lopez's girlftiend returned to her country of origin
she would face certain persecution, this would make her eligible to file for the 1-589 Asylum for
changed circumstances. As a victim of human trafficking. she would also qualify for a T-Visa non-
migrant status. An assessment by our forensic Expert Dr. George Ramos will show the effects her
history of trauma has had on her life. Mr. Lopez's girlfriend's 2 previous attorneys failed to meet
their ethical responsibility in filing these documents so complaints should be filed against than.
Rule of Law
RULE 1.3 - DILIGENCE
(a) A lawyer shall act with reasonable diligence and promptness in representing a client.
(b) A lawyer shall not neglect a le~l matter entrusted to the lawyer.
( c) A lawyer shall not intentionally fail to carry out a contract of employment entered into with a
client for professional services. but the lawyer may withdraw as permitted under these Rules
Fee dispute

RULE l.5 - FEES AND DIVISION OF FEES

{a) A lawyer shall not make an agreement for. charge, or collect an excessive or illegal fee or
ex.pense. A fee is excessive when. after a review of the fac~ a reasonable lawyer would be left
with a definite and finn conviction that the fee is excessive.
b) A lawyer shall communicate to a client the scope of their presentation and the basis or rate of
the fee and expenses for which the client wiJl be l'CSfX)nsibk. This infonnation shall be
communicated to the client before or within a reasonable time after commencement of the
representation and shall be in writing where required by statute or court rule. This provision shall
not apply when the lawyer will charge a regularly represented client on the same basis or rate and
perfonn services that are of the same general kind u previously rendered to and paid for by the
client. Any changes in the scope of the representation or the basis or rate of the fee or expenses
shall also be commtmicated to the client

Discussion
Matter of Lozada. 19 I&N Dec. 637 (BIA 1988)
1. The motion must be supported by an affidavit by the respondent attesting to the relevant facts.
The affidavit should include a statement of the agreement between the respondent 8J'ld the artomey
with respect to the representation.
2. Befote the respondent files the motion. he or she must inform counsel of the allegations and
give counsel the opportunity to respond. Any response should he included with the motion.
3. The motion should reflect whether a complaint has been filed with appropriate disciplinary
authorities regarding such representation, and if not. why not.
Under the Lozada principle the client would not be able to prove that there was inefficient
usiscance of counsel. The client retained the firm for his girlfriend case - to file an 1-601 hardship
waiver. 42B Cancellation of Removal. and an l-589 asylum case. This limits the scope of the
representation that the tinn had to provide the client Even after the retention the client did not
provide any documents or information on which the firm could have assessed the urgency. or any
deadline related to the case.
It is true that the attorney has a responsibility to the retained clients to look for his int~ it" there
are any deadlines or any statutory time limit on any appeal or c::ausc of w:tion.. However. the f"rnn
cannot be sued under Lozada for following reasons:

a. Here the scope of the representation was limited to case to file an 1-601 hardship waiver.
428 Cancellation of Removal. and an l-589 asylum appli<:ation. To move forward with the
asylum application lot of documentary evidence and other relevant documents are n:quired
 to process the application. The client tiJl date. not provide any relevant documents or
infonnation that would help us with his case.
b. Th client must write a letter or complaint to the finn with detail allegation against the firm.
Explaining how the finn lacked in handling the client case. Client also has to give
opportunity to the fum to respond to these claims and refute them.
c. After this the client must file before proper disciplinary board against the alleged lawyer.
explaining the situation foe the claim.
It would be difficult for the client to prove the principles of Lozada, that we failed in providing
adequate services. The client has not fulfilled his responsibility that he owes the firm.

Strickland v. Washington. 466 U.S. 668 (1984)

The appropriate standard for ineffective. assistance of counsel requires both that the defense
attorney was objectively deficient and that there was a reasonable prot.bi.lity that a competent
attorney would have led to a different outcome.

Under the Strickland case client would not be able to prove that the finn was in any way in
providing deficient services or any other competent lawyer would have been able to get better
outcome. Since the client has not provided any further details regarding this case nor there is any
advaJK:emcnt on the case or any case strategy the client would not be able to satisfy the test under
Strickland.

Conclusion

Based on research and analysis of case laws and relevant rules of professional responsibilities
under both ABA and NY CPR. It can be said that the firm must outline the work it would be doing
on behalf of the client and what the finn expects from the client.
 1he J.avvyers' Fund for Oient Protection
d the State of New 'lbrk
119 Washi'1900 Avenue• Albany, New \tJrk 12210
Telephone: 518/434-1935 • 800/442-FUND • Fax: 518/434-5641
www.nylawfund.org

Boanl oll'nlsteel
Cric A. Seift'.
C1wim,n
~J.e..,ne, March 24, 2025
~ A., lk:flacosa
Stuart M. (Alhcn
f"afN l. Gadi"J
Gary S. ClftDlbag Rahul D. Manchanda
Lisa L HU!minson
125 Park Avenue, 25th Fl.
New York, NY 10017

Re: Claim #2501052, Micah Lopez

Dear Hr. Manchanda:

I enclose a copy of an application for reimbursement

with our Fund by Micah Lopez.
The only
The claim alleges dishonest conduct by you in the dishonest persoi
practice of law, resulting in a loss to Mr. Lopez in the here is Micah
amount of $5,300. Lopez, who use<
and abused our
The Trustees have directed me to forward this claim law firm and
to you and to extend to you the opportunity to respond tGt.affovera
the allegations made therein within 20 days following periodofweeks
receipt of this letter. You may admit or deny the & months on hi
allegations, offer an explanation, and submit any evidendN,gtial~n
in support of your position. You may also request a girlfriendand
hearing. then refused to
pay us asper
Your failure to respond may result in the Trustees contract. We
finding that you engaged in dishonest conduct, based upoifere also forced
the allegations contained in the claim and the support int\<> contact the
police when he
documentation supplied by the claimant. started
threatening.
In addition, the fund will be legally subrogated to extortingand
the claimant's rights if an award is made. harassing us for
money.
I hope very much that you can cooperate with us in
resolving this claim.
Very truly yours,

MJK/jk
!!:a~~7ti
Executive Director
Enclosures
 The Lawyers' Fund for Client Protection
of the State of Nevi/ York
MAR 12 2025 ...
APPI.lCATION FOR REIMBURSEMENT
...
. - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - ~ l d Y - M . . . . , _ - - . ..•
Instructions:
You must answer every question in this application. Incomplete applications will be
returned. If space is inadequate, attach additional pages.
You must provide us with: copies of all evidence that proves your loss, such as cancelled checks, receipts,
letters, closing statements, disciplinary and criminal complaints, etc.
Mail the completed application and supporting documentation to: 1be Lawyers' Fund for Client
Protection, 119 Washington Avenue, AJbany, New Yock 12210.

1. Your Name and.Address: J Mr. D Mrs. D Miss D Ms. Age(s) _._ j j

Name: Mie,o.h Ul~

Address: /fr._/)tC!YoOrf ffe-· I OS t</
Home Tet~l~~ Y Social Security or Federal Tax ID#: 01-/ -JZ.-/ 11{'
Business Telephone> 9/<-l-1<)'J ~ 5~ t Occupation and Employer: CM)e,r/ TJ
M._a,x )'.
2. Name, ~ ~ tdeJ?hone pwnber of the attorney who has dishonestly t.aken your money or property:
~ Oif~ .
1~ J,wk Nt•
/11.t..~ v flt NY 100 I 1-
3. What legal serv1ces did you ask this attorney to perform for you?

: " • ~ O u ~ ~ d u l ~ d e d t, ~ t i o ~ ~ u ~ o ' : ~ ~ , v i ; e ~ n c~on~:i'±Oh

v0--S"- "girlfriend'' who he refused to marry in a quick and timely fashion, choosing instead to torture and keep her enslaved instead of
filing her immigration papers - even though we provided him legal and equitable solutions as per the attached he fired us and
4. Hoyj~~e~rJ ;g{r ~r~t~tt~~r} 5 3 OQ
5. Was your agreement with the attorney in writing? Yes_L No_ _ . If Yes, attach a copy of the
agreement.

6. Did your loss involve: rl3 money □ other property? Specify:

 • u,urt Rules do notpennit atlomeys who help~ process claims with the FwuJ to d,arge •"'
(ea for that setrJia; e,i:aptwitb the permission of the &,,d's Boanl of Tm,tee.s.

• Sho,Jd ym, receiue an awatd. f,o,,,. the F,md, the facts relating to yo,R' ioss become II p,J.,licna,,d.

• The Flmd's Rsplalions am be fou,ul, 1Zt 22 NYCRR 7200.

I (We) verify and affirm, under penalty of perjury, that the information provided in this application is true.

Sipat,no~
 W\\S
is ~ ~ tv\h l ~ ~ M'IIWltq t!Att{.t,-, ~VJ.- ho!- /YJ lhL - t>.1,-J "1-tv
ls . ','h II pu,,dr1 ~ t!ats YJb.}- vv~ rer ~~ -,., 1u-.,,w
Jf 1w po ii-,}, wl ~.J.I.?.,{ w-1-t-fA Mr. M~~ .
Jtlir"h~ \'V~ c:,µ;e ~ Wl l'-V/.y CJ>nri,i-Jd hl#,
t1v-. M.2.hd,~2
1 SHI} r,-ot/t...;r, j
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1/17 CJIY-1/hthJ de>tS hN- ~~
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c.o*:ttf- ~" o..--fftitn'j.
i,llf't tt,(}- Wt U,.,, . /wt,_i". ~off'.~;with~..i~~Oflho~easyitwas
Once ain, Micah Lopez' words herein are a ma1or red flag - atter n~~ndela ed i nored, refused to follow our legal advice and ms~ad
to fix ~r illegal immigrant situation, we ~oul~ not unde~stand ~y 1 status {ft;r ~ulti .le conve.rsations with Micah Lopez, ~e ,P<?hc~ an~,
chose t; keep his "girlfriend" ~n immigratmnhmbo ~~.~~1b.~: ~: reasoi~ he did not &le her immigration papers, and that ~IS S!-rlfn~nd
other law enforcement age?c1~ we ~ame to 1:1e con d: l 2 rears after we last dealt with him and he supposedly h:15 another unm1gration
.STILL does not h~ve legal t~igra:10:1 !t~tufil:~;~ p~;:s ~d deliberately keeping her in a dependent, explo1t~tivlsext
1av.rye:, ls that h~ JS purpose . y re ~smo o I. our le al services were terminated. Client secrets are one thing, 1:t en e en
s~ti tries to
situation
gaslight andandproject
this washisone of the.mam
criminality reaS?.5
on to hts awyers,gwe have
T an·ght to defend ourselves per the law and the Ethics Codes.
 .. .

lhe ~Fund for Client Protection •• NY~-

• oftheStalltofNMYoltc . ALBANY • •• ·•~ USPOSTAGE..... Pm11v10WES
~ T19Washf~AWlrUt • Albany,~Yatc 1U10
24 MAR 20 t.> ~ •• • I t ~ l!liY I
•
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ZIP 1221 0
02 7H
--000.89°
$
11. • • 0006203039 MAR 2~ 2025

Rahul o. Manchanda
125 Park Avenue, 25th Fl.
New York, NY 10017
1...1111•••11,, ....111•••1...111

10017-555025 ,fJllfll,fulf,t1n/ll,fpl,fJmllJ•1llllffl/tl,',l1tffl1ff1llt