On July 03, 2007 a
Party Statement
was filed
involving a dispute between
Indymac Bank Fsb,
and
Any And All Unknown Parties Claiming By Through Un,
Decicco Nichols, Linda A,
Nichols, Robert W,
Tenant #1,
Tenant #2,
Tenant #3,
Tenant #4,
for MORTGAGE FORECLOSURE - CIRCUIT (SOUTH COUNTY)
in the District Court of Sarasota County.
Preview
we"
IN THE CIRCUIT COURT OF THE TWELFTH JUDICIAL CIRCUIT
IN AND FOR SARASOTA COUNTY, FLORIDA
CIVIL ACTION
INDYMAC BANK, F.S.B.,
Plaintiff,
CASENO.® 2007 CA 007757 SC
VS. DIVISION H
LINDA A. DECICCO-NICHOLS A/K/A LINDA A. NICHOLS, et
al,
Defendant(s).
NOTICE OF FILING
Plaintiff, INDYMAC BANK, F.S.B., gives Notice of Filing of the following:
1. Affidavit of Reasonable Attorney Fees
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by U.S. Mail to all
parties listed on the attached service list on this \S day of August, 2008.
Default Law Group, P.L.
Florida
Wda/Bar No. 26139
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DOC_ID: M003106 2 =. DD
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FILE_ NUMBER: F0/7021616
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IN THE CIRCUIT COURT OF THE TWELFTH JUDICIAL CIRCUIT
IN AND FOR SARASOTA COUNTY, FLORIDA
CIVIL ACTION
INDYMAC BANK, F.S.B.,
Plaintiff, .
CASE NO.: 2007 CA 007757 SC
VS. DIVISION: H
LINDA A. DECIGCO-NICHOLS A/K/A LINDA
A. NICHOLS, et al,
Defendant(s).
, /
AFFIDAVIT AS TO REASONABLE ATTORNEYS FEES
STATE OF FLORIDA S
COUNTY OF HILLSBOROUGH S
BEFORE ME, the undersigned authority, personally appeared Erin Collins Cullaro, who upon first being duly
sworn on oath, deposes and says:
1. I am an attorney at law duly authorized to practice in the State of Florida.
2. I have been active in the practice of law in Florida since September 22, 1995, and I am personally
familiar with the fees usually allowed Plaintiffs for the services of their attorneys in suits of the kind and nature in which
this affidavit is to be filed.
3. I] am familiar with Rule 4-1.5(b) of the Rules Regulating the Florida Bar, and have taken into
consideration the factors set forth in such Rule for the determination of reasonable attorney's fees.
4. I am also familiar with and have considered the dictates of the Florida Supreme Court in the case of
Florida Patient's Compensation Fund vs. Rowe, 472 So.2d 1145 (Fla 1985) for the determination of reasonable
attorney's fees.
5. In arriving at my opinion of the value of reasonable attorney's fees in this action, J have utilized and
considered the following criteria:
a. The time and labor required, the novelty, complexity and difficulty of the questions involved, and the
skill requisite to perform the legal services properly.
b. The likelihood that the acceptance of the particular employment will preclude other employment by
the lawyer.
c. The fee or rate of fee customarily charged in the locality for services of a comparable or similar
nature.
FILE_NUMBER: F07021616 DOC_ID: M002300
MO
|
Iwr
Au
The amount involved and the results obtained.
The time limitations imposed by the client or by the circumstances.
The nature and length of the professional relationship with the client.
The experience, reputation and ability of the lawyer or lawyers performing the services.
x go m o
Whether the fee is fixed or contingent.
6. Echevarria, Codilis & Stawiarski does not keep records of its time while it represents the Plaintiff
pursuant to a flat fee arrangement; therefore, I have reviewed no specific time keeping records.
7. It is my opinion that a review of the actual foreclosure file of Echevarria, Codilis & Stawiarski in this
case would be unnecessary and futile event. In my opinion, the specific steps and requirements for filing and
litigating a mortgage foreclosure action in the State of Florida dictate that under no circumstance could the fee
charged by Echevarria, Codilis & Stawiarski be unreasonable; therefore, I have not reviewed the actual file in this
Case.
8. Based upon my review as set forth, it is my opinion that a reasonable attorney's fee and paralegal fee
is $1,450.00.
FURTHER AFFIANT SAYETH NAUGHT.
mae day of
lly known to me.
fopeg S ent was subscribed 4
, 2007, by Erin
INDYMAC-FNMA-B-rhamig- F07021616
NOTARY PUBLIC. v TATE OF FLOR.
T
g, Lisa L. Cullarc
AS EY Commission 4 “DD57754
“nnw’ Expires: JULY 2
BONDED THRU ATLANTIC BONDING 10 wiew7
Service List
LINDA A. DECICCO-NICHOLS A/K/A LINDA A. NICHOLS
3106 Seattle Avenue
North Port FL 34286
LINDA A. DECICCO-NICHOLS A/K/A LINDA A. NICHOLS
c/o L. Murray Fitzhugh
2167 S Tamiami Trail
Venice, FL 34293
ROBERT W. NICHOLS
3106 Seattle Avenue
North Port, FL 34286
Category
MORTGAGE FORECLOSURE - CIRCUIT (SOUTH COUNTY)
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Preview
we" IN THE CIRCUIT COURT OF THE TWELFTH JUDICIAL CIRCUIT IN AND FOR SARASOTA COUNTY, FLORIDA CIVIL ACTION INDYMAC BANK, F.S.B., Plaintiff, CASENO.® 2007 CA 007757 SC VS. DIVISION H LINDA A. DECICCO-NICHOLS A/K/A LINDA A. NICHOLS, et al, Defendant(s). NOTICE OF FILING Plaintiff, INDYMAC BANK, F.S.B., gives Notice of Filing of the following: 1. Affidavit of Reasonable Attorney Fees I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by U.S. Mail to all parties listed on the attached service list on this \S day of August, 2008. Default Law Group, P.L. Florida Wda/Bar No. 26139 ¢gN. Sadlak Der a3 eh 4 Boe OS re on iM ma ES co OC Hoo Ya > o> a Som §™ © “SG mW ICS = IE iT S05 om © LS = © DOC_ID: M003106 2 =. DD ~J i) FILE_ NUMBER: F0/7021616 nn mu II yinee, as . 2h IN THE CIRCUIT COURT OF THE TWELFTH JUDICIAL CIRCUIT IN AND FOR SARASOTA COUNTY, FLORIDA CIVIL ACTION INDYMAC BANK, F.S.B., Plaintiff, . CASE NO.: 2007 CA 007757 SC VS. DIVISION: H LINDA A. DECIGCO-NICHOLS A/K/A LINDA A. NICHOLS, et al, Defendant(s). , / AFFIDAVIT AS TO REASONABLE ATTORNEYS FEES STATE OF FLORIDA S COUNTY OF HILLSBOROUGH S BEFORE ME, the undersigned authority, personally appeared Erin Collins Cullaro, who upon first being duly sworn on oath, deposes and says: 1. I am an attorney at law duly authorized to practice in the State of Florida. 2. I have been active in the practice of law in Florida since September 22, 1995, and I am personally familiar with the fees usually allowed Plaintiffs for the services of their attorneys in suits of the kind and nature in which this affidavit is to be filed. 3. I] am familiar with Rule 4-1.5(b) of the Rules Regulating the Florida Bar, and have taken into consideration the factors set forth in such Rule for the determination of reasonable attorney's fees. 4. I am also familiar with and have considered the dictates of the Florida Supreme Court in the case of Florida Patient's Compensation Fund vs. Rowe, 472 So.2d 1145 (Fla 1985) for the determination of reasonable attorney's fees. 5. In arriving at my opinion of the value of reasonable attorney's fees in this action, J have utilized and considered the following criteria: a. The time and labor required, the novelty, complexity and difficulty of the questions involved, and the skill requisite to perform the legal services properly. b. The likelihood that the acceptance of the particular employment will preclude other employment by the lawyer. c. The fee or rate of fee customarily charged in the locality for services of a comparable or similar nature. FILE_NUMBER: F07021616 DOC_ID: M002300 MO | Iwr Au The amount involved and the results obtained. The time limitations imposed by the client or by the circumstances. The nature and length of the professional relationship with the client. The experience, reputation and ability of the lawyer or lawyers performing the services. x go m o Whether the fee is fixed or contingent. 6. Echevarria, Codilis & Stawiarski does not keep records of its time while it represents the Plaintiff pursuant to a flat fee arrangement; therefore, I have reviewed no specific time keeping records. 7. It is my opinion that a review of the actual foreclosure file of Echevarria, Codilis & Stawiarski in this case would be unnecessary and futile event. In my opinion, the specific steps and requirements for filing and litigating a mortgage foreclosure action in the State of Florida dictate that under no circumstance could the fee charged by Echevarria, Codilis & Stawiarski be unreasonable; therefore, I have not reviewed the actual file in this Case. 8. Based upon my review as set forth, it is my opinion that a reasonable attorney's fee and paralegal fee is $1,450.00. FURTHER AFFIANT SAYETH NAUGHT. mae day of lly known to me. fopeg S ent was subscribed 4 , 2007, by Erin INDYMAC-FNMA-B-rhamig- F07021616 NOTARY PUBLIC. v TATE OF FLOR. T g, Lisa L. Cullarc AS EY Commission 4 “DD57754 “nnw’ Expires: JULY 2 BONDED THRU ATLANTIC BONDING 10 wiew7 Service List LINDA A. DECICCO-NICHOLS A/K/A LINDA A. NICHOLS 3106 Seattle Avenue North Port FL 34286 LINDA A. DECICCO-NICHOLS A/K/A LINDA A. NICHOLS c/o L. Murray Fitzhugh 2167 S Tamiami Trail Venice, FL 34293 ROBERT W. NICHOLS 3106 Seattle Avenue North Port, FL 34286