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Filing # 157689999 E-Filed 09/19/2022 02:52:20 PM
IN THE CIRCUIT COURT OF THE NINTH
JUDICIAL CIRCUIT IN AND FOR OSCEOLA
COUNTY, FLORIDA
GENERAL JURISDICTION DIVISION
CASE NO. 2018 CA 001349 MF
CITIBANK N.A. AS TRUSTEE FOR CWABS
INC. ASSET-BACKED CERTIFICATES
SERIES 2007-,
Plaintiff,
vs.
MAURICE WARD, et al.
Defendant(s).
___________________________________/
NOTICE OF FILING
Plaintiff, by and through its undersigned attorney hereby files:
● Affidavit as to Time, Effort, and Costs
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished to the
parties listed on the attached service list via Mail and/or E-mail in accordance with the corresponding
addresses listed therein on this 19 day of September, 2022.
ROBERTSON, ANSCHUTZ, SCHNEID, CRANE &
PARTNERS, PLLC
Attorney for Plaintiff
6409 Congress Ave., Suite 100
Boca Raton, FL 33487
Telephone: 561-241-6901
Facsimile: 561-997-6909
Service Email: flmail@raslg.com
By: _\S\Vanessa D. Sloat-Rogers_
Vanessa D. Sloat-Rogers, Esquire
Florida Bar No. 353530
Communication Email: vrogers@raslg.com
18-139076 - SuB
SERVICE LIST
LAW OFFICES OF LEGENDRE & LEGENDRE, PLLC
ANTHONY N. LEGENDRE, II, ESQ.
ATTORNEY FOR MAURICE WARD
C/O LAW OFFICES OF LEGENDRE & LEGENDRE, PLLC
P.O. BOX 948599
MAITLAND, FL 32794
PRIMARY EMAIL: ANTHONYLEGENDRE@LIVE.COM
SECONDARY EMAIL: ANTHONY@LAW-LEGENDS.COM
LAW OFFICES OF LEGENDRE & LEGENDRE, PLLC
ANTHONY N. LEGENDRE, II, ESQ.
ATTORNEY FOR SILVIA WARD
C/O LAW OFFICES OF LEGENDRE & LEGENDRE, PLLC
P.O. BOX 948599
MAITLAND, FL 32794
PRIMARY EMAIL: ANTHONYLEGENDRE@LIVE.COM
SECONDARY EMAIL: ANTHONY@LAW-LEGENDS.COM
ASSOCIATION OF POINCIANA VILLAGES, INC.
C/O MARK MALDONADO 401 WALNUT ST
POINCIANA, FL 34759
POINCIANA VILLAGE ONE ASSOCIATION, INC.
C/O MARK MALDONADO 401 WALNUT ST
POINCIANA, FL 34759
18-139076 - SuB
IN THE CIRCUIT COURT OF THE NINTH
JUDICIAL CIRCUIT IN AND FOR OSCEOLA
COUNTY, FLORIDA
GENERAL JURISDICTION DIVISION
CASE NO. 2018 CA 001349 MF
CITIBANK N.A. AS TRUSTEE FOR
CWABS INC. ASSET-BACKED
CERTIFICATES SERIES 2007-,
Plaintiff,
vs.
MAURICE WARD, et al.
Defendant(s).
___________________________________/
AFFIDAVIT AS TO TIME, EFFORT AND COSTS
STATE OF FLORIDA
COUNTY OF PALM BEACH
Affiant avers as follows:
1. I am an attorney employed by Robertson, Anschutz, Schneid, Crane & Partners,
PLLC (the "Firm”), counsel for Plaintiff in this action.
2. I have personal knowledge of the facts contained in this affidavit including the
Firm’s method of recording attorney fees and costs. The attorney fees and costs described below
are kept in the Firm’s billing ledger, which is a compilation of data maintained in the Firm’s
electronic accounting system. The entries in those records are made at the time the fees are
incurred and the costs are advanced either by people with first-hand knowledge of those events or
from information provided by people with such first-hand knowledge. Recording such
information is a regular practice of the Firm’s regularly conducted business activities.
3. As counsel for Plaintiff in the above styled action, the following services are the
typical services provided by the Firm on a flat fee basis, for which time records have not been
kept, and on hourly fees. The services include the following:
Review payment and transaction history and other documents from Plaintiff. Open file
and prepare for the filing of the foreclosure action.
18-139076 - SuB
Review of initial title search and title examiner’s report to determine all of the possible
interests connected with the property.
Review all of the documents required for the filing of the Lis Pendens and Complaint.
Compliance with mandatory mediation administrative orders and review and preparation
of documents associated therewith.
Preparation for and attendance at mandatory mediation session.
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 Returns of Service and determination as to whether service was effectuated
properly.
Review of Certificates of Military Service.
Review Answers and Responses to the Foreclosure Complaint and prepare any necessary
responses of the same.
Preparation of Motion for Default and Notice of Dropping Parties.
Miscellaneous client communication regarding the status of the foreclosure action.
Review and compilation of all the documents needed to obtain Final Judgment, i.e.
Motion for Summary Judgment and supporting affidavits including the Affidavit of
Indebtedness, Affidavit as to Time, Effort and Costs, Affidavit as to the Reasonableness
of Attorney’s Fees, Motion for Default and Non-military affidavit; Final Judgment and
Preparation of documents required for Foreclosure Sale.
Attendance at final hearing.
18-139076 - SuB
4. The hourly rate charged by the Affiant’s Firm for the attorneys’ services rendered
is $215.00 - $300.00 per hour. Notwithstanding, in the above-styled action, Affiant’s Firm will
receive compensation from Plaintiff on the basis of a blended fee consisting of a $5,525.00 flat
fee for standard foreclosure services, and a fee in the amount of $250.00 for Attendance at Court,
plus the hourly rate of $215.00 - $300.00 per hour for resolution of contested issues, trial
preparation and attendance. Affiant’s Firm has expended 78.40 – 9.00 hours of time at a rate of
$215.00 - $300.00 per hour for resolution of contested issues, preparation for and attendance at
trial, for a total amount of $16,856.00 - $2,700.00. Plaintiff will pay Affiant’s Firm a total of
$25,331.00.
5. 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).
6. Plaintiff has incurred the following costs in connection with this above-styled
Foreclosure Action.
Filing Fee $1,973.39
Summons $40.00
Lis Pendens $9.00
Mediation $350.00
Title Update $50.00
Service of Process $260.00
Court Reporting $590.00
Loan Modification Recording $207.24
Document Retrieval $92.00
TOTAL $3,571.63
VERIFICATION
Under the penalties of perjury, and pursuant to Fla.Stat. §92.525(1)(b) and (2), I declare
that I have read the foregoing Affidavit as to Time, Effort and Costs, and the facts stated in it are
true on this 19 day of September, 2022.
/S/Vanessa D. Sloat-Rogers
Vanessa D. Sloat-Rogers, Esq.
18-139076 - SuB
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Filing # 157689999 E-Filed 09/19/2022 02:52:20 PM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR OSCEOLA COUNTY, FLORIDA GENERAL JURISDICTION DIVISION CASE NO. 2018 CA 001349 MF CITIBANK N.A. AS TRUSTEE FOR CWABS INC. ASSET-BACKED CERTIFICATES SERIES 2007-, Plaintiff, vs. MAURICE WARD, et al. Defendant(s). ___________________________________/ NOTICE OF FILING Plaintiff, by and through its undersigned attorney hereby files: ● Affidavit as to Time, Effort, and Costs CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished to the parties listed on the attached service list via Mail and/or E-mail in accordance with the corresponding addresses listed therein on this 19 day of September, 2022. ROBERTSON, ANSCHUTZ, SCHNEID, CRANE & PARTNERS, PLLC Attorney for Plaintiff 6409 Congress Ave., Suite 100 Boca Raton, FL 33487 Telephone: 561-241-6901 Facsimile: 561-997-6909 Service Email: flmail@raslg.com By: _\S\Vanessa D. Sloat-Rogers_ Vanessa D. Sloat-Rogers, Esquire Florida Bar No. 353530 Communication Email: vrogers@raslg.com 18-139076 - SuB SERVICE LIST LAW OFFICES OF LEGENDRE & LEGENDRE, PLLC ANTHONY N. LEGENDRE, II, ESQ. ATTORNEY FOR MAURICE WARD C/O LAW OFFICES OF LEGENDRE & LEGENDRE, PLLC P.O. BOX 948599 MAITLAND, FL 32794 PRIMARY EMAIL: ANTHONYLEGENDRE@LIVE.COM SECONDARY EMAIL: ANTHONY@LAW-LEGENDS.COM LAW OFFICES OF LEGENDRE & LEGENDRE, PLLC ANTHONY N. LEGENDRE, II, ESQ. ATTORNEY FOR SILVIA WARD C/O LAW OFFICES OF LEGENDRE & LEGENDRE, PLLC P.O. BOX 948599 MAITLAND, FL 32794 PRIMARY EMAIL: ANTHONYLEGENDRE@LIVE.COM SECONDARY EMAIL: ANTHONY@LAW-LEGENDS.COM ASSOCIATION OF POINCIANA VILLAGES, INC. C/O MARK MALDONADO 401 WALNUT ST POINCIANA, FL 34759 POINCIANA VILLAGE ONE ASSOCIATION, INC. C/O MARK MALDONADO 401 WALNUT ST POINCIANA, FL 34759 18-139076 - SuB IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR OSCEOLA COUNTY, FLORIDA GENERAL JURISDICTION DIVISION CASE NO. 2018 CA 001349 MF CITIBANK N.A. AS TRUSTEE FOR CWABS INC. ASSET-BACKED CERTIFICATES SERIES 2007-, Plaintiff, vs. MAURICE WARD, et al. Defendant(s). ___________________________________/ AFFIDAVIT AS TO TIME, EFFORT AND COSTS STATE OF FLORIDA COUNTY OF PALM BEACH Affiant avers as follows: 1. I am an attorney employed by Robertson, Anschutz, Schneid, Crane & Partners, PLLC (the "Firm”), counsel for Plaintiff in this action. 2. I have personal knowledge of the facts contained in this affidavit including the Firm’s method of recording attorney fees and costs. The attorney fees and costs described below are kept in the Firm’s billing ledger, which is a compilation of data maintained in the Firm’s electronic accounting system. The entries in those records are made at the time the fees are incurred and the costs are advanced either by people with first-hand knowledge of those events or from information provided by people with such first-hand knowledge. Recording such information is a regular practice of the Firm’s regularly conducted business activities. 3. As counsel for Plaintiff in the above styled action, the following services are the typical services provided by the Firm on a flat fee basis, for which time records have not been kept, and on hourly fees. The services include the following: Review payment and transaction history and other documents from Plaintiff. Open file and prepare for the filing of the foreclosure action. 18-139076 - SuB Review of initial title search and title examiner’s report to determine all of the possible interests connected with the property. Review all of the documents required for the filing of the Lis Pendens and Complaint. Compliance with mandatory mediation administrative orders and review and preparation of documents associated therewith. Preparation for and attendance at mandatory mediation session. 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 Returns of Service and determination as to whether service was effectuated properly. Review of Certificates of Military Service. Review Answers and Responses to the Foreclosure Complaint and prepare any necessary responses of the same. Preparation of Motion for Default and Notice of Dropping Parties. Miscellaneous client communication regarding the status of the foreclosure action. Review and compilation of all the documents needed to obtain Final Judgment, i.e. Motion for Summary Judgment and supporting affidavits including the Affidavit of Indebtedness, Affidavit as to Time, Effort and Costs, Affidavit as to the Reasonableness of Attorney’s Fees, Motion for Default and Non-military affidavit; Final Judgment and Preparation of documents required for Foreclosure Sale. Attendance at final hearing. 18-139076 - SuB 4. The hourly rate charged by the Affiant’s Firm for the attorneys’ services rendered is $215.00 - $300.00 per hour. Notwithstanding, in the above-styled action, Affiant’s Firm will receive compensation from Plaintiff on the basis of a blended fee consisting of a $5,525.00 flat fee for standard foreclosure services, and a fee in the amount of $250.00 for Attendance at Court, plus the hourly rate of $215.00 - $300.00 per hour for resolution of contested issues, trial preparation and attendance. Affiant’s Firm has expended 78.40 – 9.00 hours of time at a rate of $215.00 - $300.00 per hour for resolution of contested issues, preparation for and attendance at trial, for a total amount of $16,856.00 - $2,700.00. Plaintiff will pay Affiant’s Firm a total of $25,331.00. 5. 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). 6. Plaintiff has incurred the following costs in connection with this above-styled Foreclosure Action. Filing Fee $1,973.39 Summons $40.00 Lis Pendens $9.00 Mediation $350.00 Title Update $50.00 Service of Process $260.00 Court Reporting $590.00 Loan Modification Recording $207.24 Document Retrieval $92.00 TOTAL $3,571.63 VERIFICATION Under the penalties of perjury, and pursuant to Fla.Stat. §92.525(1)(b) and (2), I declare that I have read the foregoing Affidavit as to Time, Effort and Costs, and the facts stated in it are true on this 19 day of September, 2022. /S/Vanessa D. Sloat-Rogers Vanessa D. Sloat-Rogers, Esq. 18-139076 - SuB