Exhibit,Appendix: Law Office Of Ronald V. De Caprio, Ronald V De Caprio Dba v. Jocelyn Archimedes

On October 23, 2018 a Exhibit,Appendix was filed involving a dispute between Law Office Of Ronald V. De Caprio, Ronald V De Caprio Dba, and Jocelyn Archimedes, for Other Matters - Contract - Other in the District Court of Rockland County.

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FILED: ROCKLAND COUNTY CLERK 01/04/2019 01:19 PM INDEX NO. 036289/2018
NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 01/04/2019

EXHIBIT A
FILED: ROCKLAND COUNTY CLERK 01/04/2019 01:19 PM INDEX NO. 036289/2018
NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 01/04/2019

Jocelyn Archimedes
38 Heritage Apt. E
Drive,
New City, New York 10956

PERSONAL & CONFIDENTIAL
FILED: ROCKLAND COUNTY CLERK 01/04/2019 01:19 PM INDEX NO. 036289/2018
NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 01/04/2019

Jocelyn Archimedes
38 Heritage Apt. H
Drive,
New City, New York 10956

PERSONAL & CONFIDENTIAL
FILED: ROCKLAND COUNTY CLERK 01/04/2019 01:19 PM INDEX NO. 036289/2018
NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 01/04/2019

NYSCEF -hóckland County Suprerne Court

Confirmation Notice

This isan automated response for Supreme Court cases. The NYSCEF site has received your
electronically filed documents for the fó||cwiñg case.

Index Number NOT assigned

Ronald V. De Caprio - v.- Jocelyn Archimedes

Assigned Judge: None Recorded

Documents Received on 10/23i2018 10:05 AM

Doc # Document Type Motion #

1 SUMMONS + COMPLAINT

Does not contain an SSN or CPI as defined in 202.5(e) or 206.5(e)
2 COMPLAINT

Does not contain an SSN or CPI as defined in 202.5(e) or 206.5(e)
3 EXHIBIT(S) A

Does not cchtaiñ an SSN or CPI as defined in202.5(e) or 206.5(e)
4 EXHIBIT(S) B

Does not contain an SSN or CPI as defined in202.5(e) or 206.5(e)
5 EXHIBIT(S) C
Does not cõñtain an SSN or CPI as defined in202.5(e) or 206.5(e)
6 EXHIBIT(S) D

Does not cGñtain an SSN or CPI as defined in 202.5(e) or 206.5(e)
7 EXHIBIT(S) E

Does not contain an SSN or CPI as defined in202.5(e) or 206.5(e)

Filing user

Name: Ronald Vincent Decaprio

Phone #: E-mail Address: rvd@decapriolaw.com

Fax #: Work Address: 65 W RAMAPO RD
GARNERVILLE, NY 10923

E-mail Notifications

An e-mail ñctificaticñ regardiñg this filinghas been sent to the following address(es) on

10/23/2018 10:05 AM:

Paul Piperato,Rockland County Clerk - Piperatp@co.rock!end-ny us
Phone: 845-638-5094 Fax: 845-638-5073 Website:http//www.rock½±=± :!erkcom

NYSCEF Resource Center - EFile@nycourts.gov
Phone: (646) 386-3033 Fax: (212) 401-9146 Website: www.nycourts.gcviefile

Page 1 of 2
FILED: ROCKLAND COUNTY CLERK 01/04/2019 01:19 PM INDEX NO. 036289/2018
NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 01/04/2019
SUPREME COURT OF TH. TATE OF NEW YORK
COUNTY OF ROCKLAND
--------------------------------x
Ronald V. De Caprio dba Law Office of Ronald V. De
Caprio

Plaintiff/Petitioner,
-against- 03628W2018
Index No.

Jocelyn Archimedes

Defendant/Respondent.
--------------------------------x

NOTICE OF ELECTRONIC FILING

You have received this Notice because:

• The whose name is listed has filed this case the
Plaintiff/Petitioner, above, using
New York State Courts e-filing system, and
• You are a Defendant/Respondent (a in this case.
party)
(CPLR § 2111, Uniform Rule § 202.5-bb)

If you are represented by an attorney: give this Notice to your attorney. (Attorneys: see
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"Information for pg. 2).

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Page 1 of 2 EFM-1
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NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 01/04/2019
Information for Attorneyd

An attorney representing a party who is served with this notice must either:

1) immediately record his or her representation within the e-filed matter on the NYSCEF
site https://iapps.courts.state.ny.us/nyscef/HomePage; or

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Exemptions from mandatory e-filing are limited to attorneys who certify in good faith that

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Dated: 10/23/2018

RONALD VINCENT DECAPRIO 65 W RAMAPO RD
Name Address

Law Office of Ronald V. De Caprio
GARNERVILLE, NY 10923
Firm Name

845-354-3212

Phone

rvd@decapriolaw.com

E-Mail

To: Jocelyn Archimedes

38 Heritage Drive, Apt. H

New City, New York 10956

11/20/17

Index No. Page 2 of 2 EFM-1
FILED: ROCKLAND COUNTY CLERK 01/04/2019 01:19 PM INDEX NO. 036289/2018
NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 01/04/2019

SUPREME COURT : STATE OF NEW YORK
COUNTY OF ROCKLAND
------------------------------ --------------------x
Ronald V. De Caprio, Esq. Index No.Oh‡L AOW>
dba Law Office of Ronald V. De Caprio File Date: NO\%5\ ACC6
Plaintiff, RJI Date:

- against- Summons

Jocelyn Archimedes,

Defendant. Hon.
----------- ------------ ---------x

To the above named Defendant:

You are hereby summoned to answer the complaint in this action and to serve a copy of
your answer, or, if the complaiñt is not served with this summons, to serve a notice of

appearance, on the Plaintiff within 20 days after the service of this summons, exclusive of the

day of service (or within 30 days after the service is completc if thissummons is not personally
delivered to you within the State of New York); and in case of your failure to appear or answer,
judgment will be taken against you by default for the relief demanded in the complaint.

Dated: Garnerville, New York
October 23, 2018

Yours, etc.

Ronald V. De Caprio, Esq.
Law Office of Ronald V. De Caprio
65 West Ramapo Road

Garnerville,..Ne
845-354-3212

Plaintiff Pro Se

-.'schim:d:3\Pleadings\Summons.doc
R:\Clients\2007\l000\Law
Firm Receivables\I000.11.10
FILED: ROCKLAND COUNTY CLERK 01/04/2019 01:19 PM INDEX NO. 036289/2018
NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 01/04/2019

SUPREME COURT : STATE OF NEW YORK
COUNTY OF ROCKLAND
----x
Ronald V. De Caprio, Esq. Index No. Cha¾\h%
dba Law Office of Ronald V. De Caprio File Date: l¾'a3h%\S1
RJI Date:

Plaintiff,

- against- Verified Complaint

Jocelyn Archimedes,

Defendant. Hon.
______..____________- x

("Plaintiff"
Plaintiff Ronald V. De Caprio, Esq. or "Mr. De Caprio"), as and for his

("Defendant"
complaint against individual Defendant Jocelyn Arelinnedes or "Ms.

Archimedes"), alleges as follows:

1. Plaintiff is an attorney-at-law, operating as a sole proprietorship, in good standing

before the Courts of the State of New York, with offices for the transaction of business located at

65 West Ramapo Road, Garnerville, New York, Town of Haverstraw, County of Rockland.

2. Ms. Archimedes is an individual residing at 38 Heritage Drive, Apt. H, New City,

New York, County of Rockland.

3. On May 26, 2009, Ms. Archimedes hired Mr. De Caprio to take over her Chapter 13

voluntary bankruptcy case that was filed in the United States Bankruptcy Court, Southern District

of New York, by Shmuel Klein, Esq. A written "Agreement for Chapter 13 Bankruptcy

Services"
executed at the time Mr. De Caprio commenced his representation of Ms. Airliiniedes

is attached hereto at Exhibit A.

R:\Clients\2007\1000\Law - Archimedec\PleadingsWerified
Firm Receivables\l000.11.10 Complaintdoc
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NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 01/04/2019

4. Subsequent to being retained, Ms. Archimedes also retained Mr. De Caprio to

represent Ms. Archimedes in connection with a mortgage foreclosure proceeding entitled

Municipal Credit Union v. Jocelyn Archimedes et al..Index No. 2009-002184 ("Foreclosure

Action").

5. Mr. De Caprio performed significant legal services on behalf of Ms. Archimedes

(Exhibits B and C).

Archimedes'
6. On October 12, 2012, Ms. bankruptcy case was dismissed because Ms.

Archimedes could no longer maintain her obligations under the United States Bankruptcy Code

(Exhibit D).

7. On or about August 15, 2012, a Judgment of Foreclosure and Sale was filed in the

Foreclosure Action (Exhibit E).

8. Mr. De Caprio last met with Ms. Archimedes on November 20, 2012, to discuss Ms.

Archimedes'
options, going forward (Exhibit B).

9. Mr. De Caprio charged Ms. Archimedes a retainer fee of $1,000.00 at the

Archimedes'
commencement of this representation on Ms. behalf, and billed Ms. Archimedes for

Archimedes'
the services Mr. De Caprio thereafter performed on Ms. behalf (Exhibits A and B).

10. Ms. Archimedes paid the initialretainer fee to Mr. DeCaprio (Exhibits A, B and C).

11. As of December 1, 2012, Ms. Archimedes stillowed Mr. De Caprio a principal

Archimedes'
balance of no less than $2,961.34 for the services Mr. De Caprio performed on Ms.

behalf (Exhibits B and C).

12. Mr. De Caprio has attempted to recover the $2,961.34 balance from Ms. Archimedes

on numerous occasions, either verbally or in writing.

Firm Recei=b!=
R:\Clients\2007\l000\Law 1000.11.10 - &chimedes\PleadingsWerified
Complaint.doc
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13. To date, Ms. Archimedes has not paid this sum, or any sum, to Mr. De Caprio.

14. Mr. De Caprio has not performed legal services for Ms. Archimedes since November

2012, more than five (5) years ago, and as a matter of law, Mr. De Caprio is not required to

arbitrate this fee dispute with Ms. Archimedes because Mr. De Caprio has not provided legal

services to Ms. Archimedes for more than five (5) years, and this dispute has existed for more

than five (5) years.

15. Mr. De Caprio has been damaged in the principal amount of no less than $2,961.34,

plus interest, because Ms. Archimedes has refused to pay Mr. De Caprio for the legal services

provided to Ms. Archimedes by Mr. De Caprio.

16. The written retainer agreement between Ms. Archimedes and Mr. De Caprio allows

Mr. De Caprio to recover interest on any and allpast due balances due and owing to Mr. De

Caprio at a rate of nine (9%) per annum (Exhibit A), and Mr. De Caprio is seeking the recovery

of interest on this written fee agreement that Ms. Archimedes has breached, together with interest

thereon.

As and For a First Cause of Action - Breach of Contract

17. Mr. De Caprio repeats, reiterates, and re-alleges each and every allegation contained

"1" "16"
in numbered paragraphs through of the complaint as if fully set forth at length herein.

18. Although demand has been made for payment, Ms. Archimedes is refusing and

continues to refuse to make payment and is in breach of contract with Mr. De Caprio.

Archimedes'
19. By reason of Ms. breach of contract, Mr. De Caprio has been damaged

in the principal amount of no less than $2,961.34, together with interest thereon.

R:\Clients\2007\l000\Law
Firm Receiveb!es\1000.11.10 - Archimedes\Pleadings\Verified
Complaint.doc
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NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 01/04/2019

As and For a Second Cause of Action - Reasesable Value

20. Mr. De Caprio repeats, reiterates and re-alleges each and every allegation contaiñcd

"1" "19"
in numbered paragraphs through of the complaiñt as if fully set forth at length herein.

21. The reasoñãble value of Mr. De Caprio's services for which Ms. Archimedes has

refused to pay is no less than $2,961.34.

Archimedes'
22. By reason of Ms. conduct, Mr. De Caprio has been damaged in the

principal amount of no less than $2,961.34, which amount is the reasonable value of Mr. De

Caprio's services for which Ms. Archimedes has refused to make payment.

As and For a Third Cause of Action - Unjust Enrichment

23. Mr. De Caprio repeats, reiterates and re-alleges each and every allegation contained

"1" "22"
in numbered paragraphs through of the complaint as if fully set forth at length herein.

24. Ms. Archimedes received the legal services Mr. De Caprio performed pursuant to

Archimedes'
their written fee agreement and Ms. failure to pay money for these services

constitutes an unjust enrichment to Ms. Archimedes.

Archimedes'
25. As a result of Ms. unjust enrichment of Mr. De Caprio's legal services,

Mr. De Caprio has been damaged in the principal amount of no less than $2,961.34, together

with interest thereon.

As and For a Fourth Cause of Action - Account Stated

26. Mr. De Caprio repeats, reiterates and re-alleges each and every allegation contained

"1" "25"
in numbered paragraphs through of the complaint as if set forth at length herein.

Archimedes'
27. Ms. account has been outstanding despite the invoices Mr. De Caprio

has sent to Ms. Archimedes, and Ms. Archimedes has not disputed the amounts due and has

failed to pay on an account stated.

4
-
R:\Clients\2007unnnu Firm Receiv±k:M000.11.10- A= Picadings\Verified Cemsaintdoc
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Archimedes'
28. As a result of Ms. failure to pay her account stated, Ms. Archimedes has

damaged Mr. De Caprio in the principal amount of no less than $2,961.34, together with interest

thereon.

Conclusion

Wherefore, Plaintiff demands judgment on the First,Second, Third and Fourth causes of

action in a principal amount of no less than $2,961.34, together with interest thereon, and for

such other and further costs and disbursements of this action, and any further relief this Court

deems just and proper.

Dated: Garnerville, New York

October 23, 2018

tc.

Ronald V. De Caprio, Esq.

Law Office of Ronald V. De Caprio

65 West Ramapo Road

Garnerville, New York 10923

845-354-3212

Firm Receivab!es\l000.11.10 - Archimedes\Pleadings\Verified
R:\Clients\2007\l000\Law Complaint.doc
FILED: ROCKLAND COUNTY CLERK 01/04/2019 01:19 PM INDEX NO. 036289/2018
NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 01/04/2019

SUPREME COURT : STATE OF NEW YORK
COUNTY OF ROCKLAND
-- ----- ----------------------------x
Ronald V. De Caprio, Esq. Index No. t>3toA%Q ova
dba Law Office of Ronald V. De Caprio File Date: \c 3 wrg
Plaintiff, RJI Date:

- against- Individual Verification

Jocelyn Archimedes,

Defendant. Hon.

STATE OF NEW YORK )

) ss:

COUNTY OF ROCKLAND )

Ronald V. De Caprio, being duly sworn, deposes and says that he isthe Plaintiff in this

action, that he has read the attached Verified C-pl9int and all the contents thereof are true to

his knowledge, except as to matters therein stated to be alleged on information and belief, and

that, as to those matters, he believes them to be true.

Ronald V. De Caprio

Law Office of Ronald V. De Caprio

Plaintiff Pro Se

Firm Receivab!es\l000.11.10-
R:\C!i=:92007\l000\Law Archimedes\Pleadings\VerifiedCompkintdoc
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STATE OF NEW YORK )

) ss:

COUNTY OF ROCKLAND )

23rd
On the day of October 2018, before me, the undersigned, a notary public in and for

the State of New York personally appeared Ronald V. De Caprio, personally known to me or

proved to me on the basis of satisfactory evidence to be the individual whose name is subscribed

to the within instrument and acknowledged to me that he executed the same in his capacity in

that by his signature on the instrument the individual or the person upon behalf of which the

individual acted, executed the instrument.

Sworn to before me this
23rd
day of October 2018

NOT
4ARY PUB
O wy

KlMBERLY A. MclNTYRE
Notary Public,.State ofNew York
No. 01MC6172911
Qualifiedin Rockland County
Commission Expires Aug. 20, 20tq

Firm Receivables 1000.11.10 - Archimedc3\Ficadings\Verified
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NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 01/04/2019

EXHIBIT A
FILED: ROCKLAND COUNTY CLERK 01/04/2019 01:19 PM INDEX NO. 036289/2018
NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 01/04/2019

OO AGREEMENT
FOR CHAPTER 13 BANKRUPTCY SERVICES

Practice Area: Bankruptcy Law

Effective Date: May 26, 2009

This Agreement is made between Jocelyn Archimedes, residing at 87 Ridge
"Client"
Road, New City, New York 10956, County of Rockland (the or "Debtor"); and
Ronald V. De Caprio, Esq., 65 West Ramapo Road, Garnerville, New York 10923,

County of Rockland ("the Attorney").

BANKRUPTCY SERVICES

---
Type of Case

Client retains Attorney to provide continuing legal representation to the Client in
a Chapter 13 case pending before the United States Bankruptcy Court, Southern
District of New York, entitled In re: Jocelyn Archimedes, Case No. 07-23075 (RDD). .

Responsible Attorney

Attorney"
The "Responsible will be the attorney who will have primary
responsibility for handling the services, although other attomeys may participate in the
representation.

The representation may compose more than one filedependent on the

circumstances, and in the sole discretion of the Attorney. Regardless of the number of
files the Attorney opens for the representation, all files related to the same subject
matter are considered one transaction and constitute one representation.

Included Services

Contingent upon being paid for the services, as specified below, the Attorney
shall provide the following legal services to the Client:

RA.doc
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a. Analysis of the Client's financial situation, and rendering advice to the Client in

deterrnining whether to file a petition for bankruptcy relief based upon the documents
and data you supply, and available alternatives to bankruptcy;

b. Preparation of petition, schedules, statement of financial affairs, means
testing forms, Chapter 13 Plan, and other documents required at the commencement of
the bankruptcy case;

c. informing mortgage lenders (through schedules), foreclosing law firms and
referees of the commencement of a Chapter 13 case;

d. Representation at the initial Section 341 meeting of the creditors. An
additional fee will be charged to the Client, at the hourly rate of $250.00, in the event the

Attorney attends a second, and any further, 341 meetings;

e. Representation in regard to reaffirmation agreements;

f. Representation in regard to redemption agreements;

g. Motion(s) to extend plan payments;

h. Pre-confirmation modifications to the Chapter 13 Plan;

i. Representation at the initialconfirmation hearing, and at a first,adjourned,
confirmation hearing;

j. Representation in regard to satisfying mandatory requirements, but excluding
any and all representation resulting from either a motion made, contested matter

commenced, or adversary proceeding commenced, to either lift
the automatic stay,
dismiss or convert a Chapter 13 case due to the Client's failure to satisfy a mandatory
requirement; but

k. Client acknowledges and understands that there are mandatory requirements
under the United States Bankruptcy Code, as amended on October 17, 2005, which will
arise during the course of the Client's pending bankruptcy case, in the calendar years
the câieñdar year in which the Client's case was filed - of
following bankruptcy by way
example, ifthe case was filed in 2006, there will mandatory requirements pertaining to
the Client's schedules and tax returns in the and calendars years - and
2007, ensuing
that the Attorney's representation of the Client does not extend to future calendar years.

Payment of Fees for included Services

The Client agrees that the Attorney shall be paid a retainer fee of $1,000.00 for
the aforesaid services, and that this amount shall be paid in fullto the Attorney before
the Attorney begins the legal representation on behalf of the Client.

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Additional Services

The United States Bankruptcy Code permits the United States Trustee, Panel

Trustee, creditors, and in some instances, the United States Bankruptcy Judge, to
commence any number of contested matters or adversary proceedings during the
course of a bankruptcy case. The Attorney cannot predict those which may or may not

arise, even though the attorney has conducted a reasonable inquiry of the Client's
background. The Attorney is not retained under the flatfee, to represent the Client as to

contested matters or adversary proceedings, due to the fact that the Attorney cannot
control whether another person may commence a contested matter or adversary
proceeding.

The Attorney may provide the following additicñãi representation to the Client
contingent upon firstbeing paid a separate retainer for the representation:

a. Responses to demands made by the United States Trustee;

b. Appearances at depositions scheduled pursuant to Federal Rule of

Bankruptcy Procedure 2004;

c. Assistance in responding to document production demanded pursuant to
Federal Rule of Bankruptcy Procedure 2004;

d. Assistance in delivering documentation requested by creditors, such as tax

returns;

e. Amendments made to Client's petition, schedules and statements;

f. Activity, adversary proceedings and contested matters, including, but not
limited to those:

1. Pertaining to the voidance of liens on household goods;

2. Pertaining to relief from the automatic stay;

3. Pertaining to the reinstatement of the automatic stay;

4. Pertaining to the value, extent and validity of property interests in real
and personal property;

5. Pertaining to the sale of either personal property or real property;

6. Pertaining to the retention of professionals, i.e. special counsel,

accountants, appraisers, auctioneers, liquidators, real estate brokers, etc.;

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7. Pertaining to the validity, extent and enforceability of leases for the use

and of residential real leases for the use and of non-
occupancy property, occupancy
residential real property; leases pertaining to personal property;

8. Pertaining to objections to the Client's discharge, or seeking a
revocation of the Client's discharge;

9. Pertaining to an objection to the dischargeability of a debt;

10. Pertaining to preferences, fraudulent transfers or conveyances, and
the recovery of exempt property;

11. Pertaining to tax issues;

12. Pertaining to abuse issues;

13. Pertaining to the dismissal or conversion of the case from one chapter
of the Bankruptcy Code to another chapter of the Bankruptcy Code;

14. Pertaining to objections made to claims filed by creditors and parties
in interest;

15. Representation at a second, or any further, adjoumed confirmation

hearing;

16. Pertaining to the approval of a compromise or settlement of disputes,
contested matters, adversary proceedings or other issues that have arisen in the

bankruptcy case;

17. Pertaining to post-confirmation modifications to a Chapter 13 Plan;

g. Post-filing activity, communication and conduct with a vehicle lienor or lessor

pertaining to the production of evidence of insurance coverage for a vehicle in which
you may possess an interest;

h. Post-filing activity, communication and conduct with a vehicle lienor or lessor

pertaining to the physical disposition of a vehicle in which you may possess an interest;

i. Post-filing activity, communicatioñ and conduct with a vehicle lienor or lessor

pertaining to post-petition payments;

j. Post-filing activity, communication and conduct with a mortgage lender or

property lessor pertaining to post-petition payments;

k. Post-Confirmation mandatory requirements under the United States

Bankruptcy Code; and

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NYSCEF DOC. NO. 10

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Document Filed Date

January 04, 2019

Case Filing Date

October 23, 2018

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Exhibit,Appendix: Law Office Of Ronald V. De Caprio, Ronald V De Caprio Dba v. Jocelyn Archimedes

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