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Filing # 83924902 E-Filed 01/25/2019 03:03:14 PM
IN THE CIRCUIT COURT OF THE SECOND JUDICIAL CIRCUIT
IN AND FOR LEON COUNTY, FLORIDA
Navy Federal Credit Union, GENERAL JURISDICTION DIVISION
Plaintiff,
VS. Case No. 2018 CA 001978
Norman LaMere III; et al
Defendants.
/
NOTICE OF FILING
Plaintiff, Navy Federal Credit Union, by and through its undersigned counsel.
hereby gives notice of filing the following attached:
e Affidavit of Reasonable Attorney’s Fees and Time
Affidavit of Attorney’s Fees and Costs
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy hereof was served
electronically or via U.S. Mail on this ZS day of January, 2019 to all persons shown
on the following service list.
BROCK & SCOTT, PLLC
Attorney for Plaintiff
2001 NW 64th St, Suite 130
Ft. Lauderdale, FL 33309
Phone: (954) 618-6955, ext. 4769
Fax: (954) 618-6954
FLCourtDocs@brockandscott.com
(A
tt 4 —
Julie Anthousis, Esq
Florida Bar No. 55337
Shaib . Rios, Esq.
EL Bar No. 28316
fo. 2018 CA 00 le # 18-FO2160
MOT IU
SERVICE LIST
The following persons were served by e-mail:
Crescent Hills Homeowners Association, Inc.
c/o David J. Fredericks, Esq
1689 Mahan Center Blvd., Suite B
Tallahassee, FL 32317
DFredericks@andersongivens.com; collections@andersongivens.com
The following persons were served by U.S. mail:
Tharpe Street Holdings, Inc.
c/o Behzad Ghazvini, Registered Agent
4708 Capital Circle NW
Tallahassee, FL 32303
Norman LaMere
5340 Falling Star Rd
Tallahassee, FL 32303
Patricia LaMere
5340 Falling Star Rd
Tallahassee, FL 32303
Case No. 2018 CA 001978 2 of2 File # 18-F02160
IN THE CIRCUIT COURT OF THE SECOND JUDICIAL CIRCUIT
IN AND FOR LEON COUNTY, FLORIDA
Navy Federal Credit Union, GENERAL JURISDICTION DIVISION
Plaintiff,
VS. Case No. 2018 CA 001978
Norman LaMere II]; et al,
Defendants.
/
AFFIDAVIT OF REASONABLE ATTORNEY’S FEES AND TIME
BEFORE ME, the undersigned, personally appeared Gayle G. Conner, Esquire, who,
after being first duly sworn, deposes and says:
1 That I am an attorney licensed to practice in the State of Florida, and have been
practicing in the State of Florida since October, 2004.
That I am familiar with the fees generally charged in this community for mortgage
foreclosure proceedings.
That I have examined the working file of Brock & Scott, PLLC in connection with the
above-styled proceedings.
That I have reviewed said file in light of the criteria set forth in Rule 4-1.5 of the Florida
Bar Rules of Professional conduct and the decision of the Florida Supreme Court in
Florida Patient's Compensation Fund vs. Rowe, 472 So.2d 1145 (Fla. 1985).
That I am of the opinion, and so state that the flat fee of $4,200.00, spent by Brock &
Scott, PLLC, in connection with the above-styled proceeding, were reasonable. The
amount of hours, stated herein, do not contemplate objections to the sale being filed,
motions for re-hearing, writs of possession, bankruptcy proceedings, or proceedings for
deficiency judgments.
Case No. 2018 CA 001978 1 of 2 File # 18-F02160
6 That I am of the opinion, and so state, that $4,200.00 would be a reasonable fee to be paid
to Plaintiff's attorneys.
FURTHER YOUR AFFIANT SAYETH NOT.
Dated: ipsbey emt.
Gayle G. Conner, Esq., FL Bar No. 840521
STATE OF FLORIDA
COUNTY OF BROWARD
Sworn to or affirmed before me this CS Gay of January, 2019, by Gayle G. Conner,
Esq., who is personally known to me.
Nn Dix Ere
Notary Public
TINA ELI SE BIRGEL OO7374
1 COMMISS! JONine #29,GG2020
EXPIRES Ju
FloridaNotarySene
gory 308-0158
Case No. 2018 CA 001978 2 of 2 File # 18-F02160
IN THE CIRCUIT COURT OF THE SECOND JUDICIAL CIRCUIT
IN AND FOR LEON COUNTY, FLORIDA
Navy Federal Credit Union, GENERAL JURISDICTION DIVISION
Plaintiff,
vs. Case No. 2018 CA 001978
Norman LaMere II]; et al,
Defendants
/
AFFIDAVIT OF ATTORNEY’S FEES AND COSTS
STATE OF FLORIDA )
COUNTY OF BROWARD _ )
BEFORE ME, the undersigned authority, personally appeared Shaib Rios, Esq., who,
having made an oath or affirmation, deposes and says:
As counsel for Plaintiff in the above styled action, Affiant’s firm, Brock & Scott, PLLC.,
has provided or may provide some or all of the following attorney services on a flat fee basis, for
which time records have not been kept:
Review information received from client
Review of Initial title search or report from title examiner for list of
Defendants, their interests and possible addresses
Preparation of Lis Pendens, Complaint, Summons, Motion and Order
Appointing Process Server and Civil Cover Sheet
Review of supplemental title search or report from title examiner
Review of Certificates of Military Service
Review of Returns of Service
Review Answers of Defendants, Preparation of Motion for Default,
and Notice of Dropping Parties
Prepare for foreclosure sale
Miscellaneous telephone conversations and memoranda to client
In addition to the attorney time noted above, Affiant’s firm, Brock & Scott, PLLC., has
provided or may provide some or all of the following paralegal services on a flat fee basis, for
which time records have not been kept:
Review information received from client, set up physical file and file in
computer data base
Preparation of Lis Pendens, Complaint, Summons, Motion and Order
Page 1 of 2
Case No.: 2018 CA 001978 File No.: 18-F02160
Appointing Process Server and Civil Cover Sheet including review of
Attorney’s instructions, input to and maintenance of computer data
base and copying of packages
Preparation of Requests for Certificate of Military Service
Review and organize returns of service, notate computer tracking
program, notate legal file and. file returns of service
Organize answers or motions to dismiss and prepare replies or motions
to strike, per attorney’s instructions notate computer tracking program,
notate legal file and file documents
Prepare for foreclosure sale
Preparation of final package to client
FEE CALCULATION
FLAT FEE $3,450.00
NON-JURY TRIAL FLAT FEE $750.00
TOTAL $4,200.00
Affiant certifies that there are no reasons for either reduction or enhancement of the fee
pursuant to Florida Patient's Compensation Fund v. Rowe, 472 So. 2d 1145 (Fla.1985).
Plaintiff, either directly or through counsel, has expended the following costs in
connection with this action.
Complaint Filing — Brock & Scott, PLLC. $959.00
Service of Process — Brock & Scott, PLLC $421.75
Title Search — Brock & Scott, PLLC. $325.00
Title Update — Brock & Scott, PLLC. $75.00
TOTAL COSTS $1,780.75
FURTHER AFFIANT SAYETH NAUGHT. -
Dated: Januar) 24, QDI)
Shaib Rios, Esq., FL Bar No. 28316
Sworn to-or affirmed before me this ? Uy of January, 2019, by Shaib Rios, Esq., who
is personally known to me.
A inher Choe ‘ oO
‘Notary Public
TINA ELISE BIRGEL
74
MY COMMISSION # GG0073
EXPIRES June 29, 2020
40
Page2 of 2
Case No.: 2018 CA 001978 File No.: 18-F02160
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Filing # 83924902 E-Filed 01/25/2019 03:03:14 PM IN THE CIRCUIT COURT OF THE SECOND JUDICIAL CIRCUIT IN AND FOR LEON COUNTY, FLORIDA Navy Federal Credit Union, GENERAL JURISDICTION DIVISION Plaintiff, VS. Case No. 2018 CA 001978 Norman LaMere III; et al Defendants. / NOTICE OF FILING Plaintiff, Navy Federal Credit Union, by and through its undersigned counsel. hereby gives notice of filing the following attached: e Affidavit of Reasonable Attorney’s Fees and Time Affidavit of Attorney’s Fees and Costs CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy hereof was served electronically or via U.S. Mail on this ZS day of January, 2019 to all persons shown on the following service list. BROCK & SCOTT, PLLC Attorney for Plaintiff 2001 NW 64th St, Suite 130 Ft. Lauderdale, FL 33309 Phone: (954) 618-6955, ext. 4769 Fax: (954) 618-6954 FLCourtDocs@brockandscott.com (A tt 4 — Julie Anthousis, Esq Florida Bar No. 55337 Shaib . Rios, Esq. EL Bar No. 28316 fo. 2018 CA 00 le # 18-FO2160 MOT IU SERVICE LIST The following persons were served by e-mail: Crescent Hills Homeowners Association, Inc. c/o David J. Fredericks, Esq 1689 Mahan Center Blvd., Suite B Tallahassee, FL 32317 DFredericks@andersongivens.com; collections@andersongivens.com The following persons were served by U.S. mail: Tharpe Street Holdings, Inc. c/o Behzad Ghazvini, Registered Agent 4708 Capital Circle NW Tallahassee, FL 32303 Norman LaMere 5340 Falling Star Rd Tallahassee, FL 32303 Patricia LaMere 5340 Falling Star Rd Tallahassee, FL 32303 Case No. 2018 CA 001978 2 of2 File # 18-F02160 IN THE CIRCUIT COURT OF THE SECOND JUDICIAL CIRCUIT IN AND FOR LEON COUNTY, FLORIDA Navy Federal Credit Union, GENERAL JURISDICTION DIVISION Plaintiff, VS. Case No. 2018 CA 001978 Norman LaMere II]; et al, Defendants. / AFFIDAVIT OF REASONABLE ATTORNEY’S FEES AND TIME BEFORE ME, the undersigned, personally appeared Gayle G. Conner, Esquire, who, after being first duly sworn, deposes and says: 1 That I am an attorney licensed to practice in the State of Florida, and have been practicing in the State of Florida since October, 2004. That I am familiar with the fees generally charged in this community for mortgage foreclosure proceedings. That I have examined the working file of Brock & Scott, PLLC in connection with the above-styled proceedings. That I have reviewed said file in light of the criteria set forth in Rule 4-1.5 of the Florida Bar Rules of Professional conduct and the decision of the Florida Supreme Court in Florida Patient's Compensation Fund vs. Rowe, 472 So.2d 1145 (Fla. 1985). That I am of the opinion, and so state that the flat fee of $4,200.00, spent by Brock & Scott, PLLC, in connection with the above-styled proceeding, were reasonable. The amount of hours, stated herein, do not contemplate objections to the sale being filed, motions for re-hearing, writs of possession, bankruptcy proceedings, or proceedings for deficiency judgments. Case No. 2018 CA 001978 1 of 2 File # 18-F02160 6 That I am of the opinion, and so state, that $4,200.00 would be a reasonable fee to be paid to Plaintiff's attorneys. FURTHER YOUR AFFIANT SAYETH NOT. Dated: ipsbey emt. Gayle G. Conner, Esq., FL Bar No. 840521 STATE OF FLORIDA COUNTY OF BROWARD Sworn to or affirmed before me this CS Gay of January, 2019, by Gayle G. Conner, Esq., who is personally known to me. Nn Dix Ere Notary Public TINA ELI SE BIRGEL OO7374 1 COMMISS! JONine #29,GG2020 EXPIRES Ju FloridaNotarySene gory 308-0158 Case No. 2018 CA 001978 2 of 2 File # 18-F02160 IN THE CIRCUIT COURT OF THE SECOND JUDICIAL CIRCUIT IN AND FOR LEON COUNTY, FLORIDA Navy Federal Credit Union, GENERAL JURISDICTION DIVISION Plaintiff, vs. Case No. 2018 CA 001978 Norman LaMere II]; et al, Defendants / AFFIDAVIT OF ATTORNEY’S FEES AND COSTS STATE OF FLORIDA ) COUNTY OF BROWARD _ ) BEFORE ME, the undersigned authority, personally appeared Shaib Rios, Esq., who, having made an oath or affirmation, deposes and says: As counsel for Plaintiff in the above styled action, Affiant’s firm, Brock & Scott, PLLC., has provided or may provide some or all of the following attorney services on a flat fee basis, for which time records have not been kept: Review information received from client Review of Initial title search or report from title examiner for list of Defendants, their interests and possible addresses Preparation of Lis Pendens, Complaint, Summons, Motion and Order Appointing Process Server and Civil Cover Sheet Review of supplemental title search or report from title examiner Review of Certificates of Military Service Review of Returns of Service Review Answers of Defendants, Preparation of Motion for Default, and Notice of Dropping Parties Prepare for foreclosure sale Miscellaneous telephone conversations and memoranda to client In addition to the attorney time noted above, Affiant’s firm, Brock & Scott, PLLC., has provided or may provide some or all of the following paralegal services on a flat fee basis, for which time records have not been kept: Review information received from client, set up physical file and file in computer data base Preparation of Lis Pendens, Complaint, Summons, Motion and Order Page 1 of 2 Case No.: 2018 CA 001978 File No.: 18-F02160 Appointing Process Server and Civil Cover Sheet including review of Attorney’s instructions, input to and maintenance of computer data base and copying of packages Preparation of Requests for Certificate of Military Service Review and organize returns of service, notate computer tracking program, notate legal file and. file returns of service Organize answers or motions to dismiss and prepare replies or motions to strike, per attorney’s instructions notate computer tracking program, notate legal file and file documents Prepare for foreclosure sale Preparation of final package to client FEE CALCULATION FLAT FEE $3,450.00 NON-JURY TRIAL FLAT FEE $750.00 TOTAL $4,200.00 Affiant certifies that there are no reasons for either reduction or enhancement of the fee pursuant to Florida Patient's Compensation Fund v. Rowe, 472 So. 2d 1145 (Fla.1985). Plaintiff, either directly or through counsel, has expended the following costs in connection with this action. Complaint Filing — Brock & Scott, PLLC. $959.00 Service of Process — Brock & Scott, PLLC $421.75 Title Search — Brock & Scott, PLLC. $325.00 Title Update — Brock & Scott, PLLC. $75.00 TOTAL COSTS $1,780.75 FURTHER AFFIANT SAYETH NAUGHT. - Dated: Januar) 24, QDI) Shaib Rios, Esq., FL Bar No. 28316 Sworn to-or affirmed before me this ? Uy of January, 2019, by Shaib Rios, Esq., who is personally known to me. A inher Choe ‘ oO ‘Notary Public TINA ELISE BIRGEL 74 MY COMMISSION # GG0073 EXPIRES June 29, 2020 40 Page2 of 2 Case No.: 2018 CA 001978 File No.: 18-F02160