On August 22, 2014 a
Party Statement
was filed
involving a dispute between
First Lido Condominium, Inc. A Florida Not-For-Profit Corporation,
and
Bank Of America Na,
Garrison, Clo Ann,
Secretary Of Housing And Urban Development,
Unknown Tenant In Possession, Tenant,
for CONDOMINIUM - CIRCUIT 2010
in the District Court of Sarasota County.
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IN THE CIRCUIT COURT OF THE TWELFTH JUDICIAL CIRCUIT
IN AND FOR SARASOTA COUNTY, FLORIDA
FIRST LIDO CONDOMINIUM, INC.,
a Florida not-for-profit corporation,
Plaintiff,
VS. CASE NO. 2014-CA-004931-NC
CLO-ANN GARRISON; and
BANK OF AMERICA, NA, FILED IN OPEN COURT
Defendants. ON Mae. 3 2015 ,
ee
AFFIDAVIT OF REASONABLE ATTORNEY'S FEES
STATE OF FLORIDA
COUNTY OF SARASOTA
BEFORE ME, the undersigned authority, personally appeared DANIJEL E. SCOTT,
being well known to me, deposes and says as follows:
]. That I am an attorney at law and have been actively engaged in the practice of law
for many years.
2. I have examined the above-captioned file of counsel for Plaintiff and find that
said counsel has diligently applied themselves to the attention of matters usual and necessary
under the circumstances regarding discovery compliance by Defendant, including a Motion to
Compel Discovery and for Sanctions.
3. I am also familiar from my experience with the attorney's fees customarily
charged by attorneys in the Sarasota and Manatee County area for legal services rendered in
cases such as this.
4. I have examined the attorney's work product, as well as the time spent by the
attorney on behalf of the Plaintiff in connection with the Motion to Compel. I have also
carefully considered all factors stated in Rule 4.1-5 of the Rules Regulating the Florida Bar,
Filed 03/04/2015 10:19 AM - Karen E. Rushing, Clerk of the Circuit Court, Sarasota County, FLincluding the time and labor required; the novelty and difficulty of the legal and factual
questions; the skill requisite to perform the legal services properly; the fee customarily charged
in this circuit for similar legal services; the amount incurred and the result obtained to date; the
experience, reputation and ability of the lawyers performing the services; the nature of the fee;
the relevant time limitations imposed; and the other employment opportunities precluded by the
attorney as a result of accepting this particular employment. In view of those factors, I have
formed the opinion that a reasonable fee for the legal services relating to Plaintiff's Motion to
Compel, including an estimated 1.0 hour for preparation, attendance at the hearing and
©
communication with the client in this matter is $ bo b ( )°= based upon ote YO hours
reasonably expended in this matter.
5. Affiant states that the hourly rate of $275.00 per hour represents a reasonable
hourly rate, and said rate is at or below hourly rates customarily charged in Sarasota for similar
legal services.
FURTHER AFFIANT SAITH NOT.
Daniel E. Scott? Esquire
2033 Main Street, Suite 408
Sarasota, Florida 34237
(941) 366-6301
The foregoing instrument was sworn to and subscribed before me by Daniel E. Scott,
p
Esquire who is personally known to me on this 3f day of March, 2015.
My Commission Expires:
Nogary Pubfic
Fenn sabe TW aw
Print Name
w:\first lido\garrison, clo-ann (unit 304) fc (pat)\affidavit of reasonable fees.doc
2
Filed 03/04/2015 10:19 AM - Karen E. Rushing, Clerk of the Circuit Court, Sarasota County, FL
Document Filed Date
March 04, 2015
Case Filing Date
August 22, 2014
Category
CONDOMINIUM - CIRCUIT 2010
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IN THE CIRCUIT COURT OF THE TWELFTH JUDICIAL CIRCUIT IN AND FOR SARASOTA COUNTY, FLORIDA FIRST LIDO CONDOMINIUM, INC., a Florida not-for-profit corporation, Plaintiff, VS. CASE NO. 2014-CA-004931-NC CLO-ANN GARRISON; and BANK OF AMERICA, NA, FILED IN OPEN COURT Defendants. ON Mae. 3 2015 , ee AFFIDAVIT OF REASONABLE ATTORNEY'S FEES STATE OF FLORIDA COUNTY OF SARASOTA BEFORE ME, the undersigned authority, personally appeared DANIJEL E. SCOTT, being well known to me, deposes and says as follows: ]. That I am an attorney at law and have been actively engaged in the practice of law for many years. 2. I have examined the above-captioned file of counsel for Plaintiff and find that said counsel has diligently applied themselves to the attention of matters usual and necessary under the circumstances regarding discovery compliance by Defendant, including a Motion to Compel Discovery and for Sanctions. 3. I am also familiar from my experience with the attorney's fees customarily charged by attorneys in the Sarasota and Manatee County area for legal services rendered in cases such as this. 4. I have examined the attorney's work product, as well as the time spent by the attorney on behalf of the Plaintiff in connection with the Motion to Compel. I have also carefully considered all factors stated in Rule 4.1-5 of the Rules Regulating the Florida Bar, Filed 03/04/2015 10:19 AM - Karen E. Rushing, Clerk of the Circuit Court, Sarasota County, FLincluding the time and labor required; the novelty and difficulty of the legal and factual questions; the skill requisite to perform the legal services properly; the fee customarily charged in this circuit for similar legal services; the amount incurred and the result obtained to date; the experience, reputation and ability of the lawyers performing the services; the nature of the fee; the relevant time limitations imposed; and the other employment opportunities precluded by the attorney as a result of accepting this particular employment. In view of those factors, I have formed the opinion that a reasonable fee for the legal services relating to Plaintiff's Motion to Compel, including an estimated 1.0 hour for preparation, attendance at the hearing and © communication with the client in this matter is $ bo b ( )°= based upon ote YO hours reasonably expended in this matter. 5. Affiant states that the hourly rate of $275.00 per hour represents a reasonable hourly rate, and said rate is at or below hourly rates customarily charged in Sarasota for similar legal services. FURTHER AFFIANT SAITH NOT. Daniel E. Scott? Esquire 2033 Main Street, Suite 408 Sarasota, Florida 34237 (941) 366-6301 The foregoing instrument was sworn to and subscribed before me by Daniel E. Scott, p Esquire who is personally known to me on this 3f day of March, 2015. My Commission Expires: Nogary Pubfic Fenn sabe TW aw Print Name w:\first lido\garrison, clo-ann (unit 304) fc (pat)\affidavit of reasonable fees.doc 2 Filed 03/04/2015 10:19 AM - Karen E. Rushing, Clerk of the Circuit Court, Sarasota County, FL