Preview
Filing # 152010754 E-Filed 06/22/2022 05:15:30 PM
IN THE COUNTY COURT OF THE TWENTIETH JUDICIAL CIRCUIT
IN AND FOR CHARLOTTE COUNTY, FLORIDA
COUNTY CIVIL DIVISION
DENISE FURRY,
Plaintiff, Case No. 21000164CC
vs.
STATE FARM FLORIDA
INSURANCE COMPANY,
Defendant.
/
AFFIDAVIT OF MATTHEW R. DANAHY IN SUPPORT
OF PLAINTIFF’S CLAIM FOR ATTORNEY’S FEES
STATE OF FLORIDA
COUNTY OF HILLSBOROUGH
BEFORE ME the undersigned authority, this day personally appeared MATTHEW
R. DANAHY, who after being first duly sworn, deposes and says as follows:
1 | am an attorney in good standing licensed to practice law in the State of
Florida and have been so licensed since October 30, 1986.
2 lam A.V. rated by Martindale-Hubbell and Board Certified in Civil Trial Law
by both the Florida Bar and the National Board of Trial Advocacy.
3 | have over 35 years of experience as an attorney handling cases in civil
litigation. During that time, | have represented both insurance companies and insureds in
cases involving insurance claims and coverage issues.
4 For the past twenty (22) years, | have exclusively represented insureds
against their insurers in insurance coverage disputes and other first party claims, including
disputed water loss claims such as the claim at issue. A copy of my professional Resume
is attached as Exhibit A.
5. In addition to my litigation experience, | have also handled in excess of 60
appeals to the Florida District Courts of Appeal, Florida Supreme Court and Federal
Eleventh Circuit Court of Appeal. Most of those appeals have involved first party and
insurance matters.
6. On February 9, 2021, my law firm, Danahy & Dunnavant, P.A. (f/k/a
Danahy & Murray, P.A.) was retained by DENISE FURRY (MS. FURRY) (See Authority
to Represent attached as composite Exhibit B', and also identified as Exhibit 1 to
Plaintiffs Comprehensive Fee Motion).
7. From February 9, 2021 through the present my firm(s) and | have spent 47.6
hours doing appropriate legal work for MS. FURRY in prosecuting her case against
STATE FARM FLORIDA INSURANCE COMPANY (“STATE FARM”). Of this time, 38.2
hours is billable and 9.4 hours is non-billable and is not being claimed.
8. To date entitlement remains in dispute, as no stipulation to entitlement has
been made by State Farm. As a result, entitlement remains to be resolved by the court.
9. The 38.2 hours claimed, from February 9, 2021 through the present have a
lodestar value of $17,429.50. The time expended was kept in contemporaneous time
records which are attached along with a summary of total and claimed time. See Exhibit
c
10. My time was billed at my normal hourly rate of $700.00 for 19.2 hours of
billable legal work from February 9, 2021 through the present. This post-suit and post-
1 On June 14, 2021, Danahy & Murray, P.A. ceased operation, and representation of Plaintiff's claim was
assumed by Danahy & Dunnavant, P.A. as reflected in Plaintiffs’ Authority to Represent dated June 14,
2021.
2
appraisal payment was a “confession of judgment” and the functional equivalent of a
verdict in Plaintiffs favor. | also incurred 6.5 hours of time for which no fee is claimed.
11. My hours incurred were reasonable and necessary, and my hourly rate is
fair and reasonable based on my ability, experience and the nature of my practice
exclusively handling first party claims by insureds against their insurers.
12. Further, my hourly rate has been awarded by Florida courts, is paid by
clients who can afford to do so (including insurance companies in the appraisal process
where | serve as both an Umpire and an Appraiser) and has been stipulated to be
reasonable and paid by other insurance companies, including by Citizens Property
Insurance Company (the state’s largest insurer).
13. Erin E. Dunnavant, Esquire was an associate with the firm of Danahy &
Murray, P.A. and is a partner with Danahy & Dunnavant, P.A. Her time was billed at her
normal hourly rate of $500.00 per hour for 1.6 hours of reasonable and necessary legal
work up to the date of the payment of the appraisal award.
14, Her hourly rate was and is consistent with those rates for an attorney of her
ability and experience who exclusively handles first party claims in Charlotte County and
throughout the State of Florida. Her rate is consistent with other attorneys of her
experience who exclusively handle such claims and who are partners in a first party
litigation practice. Ms. Dunnavant's professional Resume is attached as Exhibit D.
15. Kimberly L. Armistead, Esquire was an associate with the firm of Danahy &
Murray, P.A. Her time was billed at her normal hourly rate of $450.00 per hour for 1.7
hours of reasonable and necessary legal work prior to the payment of the appraisal award,
and 2.9 hours of non-billable time for which a fee is not being claimed.
16. Her hourly rate was and is consistent with those rates for an attorney of her
ability and experience who exclusively handles first party claims in Charlotte County and
throughout the State of Florida. Her rate is consistent with other attorneys of her
experience who exclusively handle such claims. Ms. Armistead’s prior professional
Resume is attached as Exhibit E.
17. Courtney Bumgarner was a paralegal with the firm of Danahy & Murray,
P.A., and is currently a paralegal with the firm of Danahy & Dunnavant, P.A. Her time was
billed at her normal hourly rate $155.00 per hour for 13.9 hours of reasonable and
necessary legal work.
18. Her hourly rate is reasonable and consistent with those rates for a paralegal
of her ability and experience who exclusively handles first party claims in Charlotte county
and throughout Florida. A copy of Ms. Bumgarner’s professional Resume is attached as
Exhibit F.
19. Jeannine Thurlow is a paralegal with the firm of Danahy & Dunnavant, P.A.
Her time was billed at her normal hourly rate $150.00 per hour for 1.8 hours of reasonable
and necessary legal work.
20. Her hourly rate is reasonable and consistent with those rates for a
paralegal of her ability and experience who exclusively handles “first party” claims in
Charlotte county and throughout Florida. A copy of Ms. Thurlow’s professional Resume is
attached as Exhibit G.
21. My firm(s) took this case on a contingency fee basis as to both fees and
costs, and) have worked on Plaintiffs behalf since February 9, 2021 without being paid
any fees or costs for the prosecution of the claim.
22. MS. FURRY advised that, after suffering the windstorm loss and roof
damage complained of, the need to replace the roof, and the denial of her roof
replacement claim, and the coverage defenses raised, she needed to be paid for the
damage to her home. As she could not afford to pay attorney's fees or any costs needed
to prosecute her claim she required a contingency fee agreement.
23. | believe a fee enhancement multiplier of 2.0 should be used, according to
the standards set by Standard Guaranty Insurance Co. vs. Quanstrom, 555 So.2d. 828
(Fla. 1990) and State Farm Fire and Casualty Co. v. Palma, 555 So.2d 836 (Fla. 1990).
The reasons for this are more fully set forth in the Comprehensive Motion for
Determination of Attorney's Fees, Costs and Interest and Memorandum of Law in support
thereof, which reasons are incorporated herein by reference.
[SEE AVERMENT ON NEXT PAGE]
FURTHER AFFIANT SAYETH NOT. L fil huty
MATTHEW R. DANAHY L
The foregoing instrument was acknowledged before me this ygind day
of J A Ne , 2022, by MATTHEW R. DANAHY, who is personally known to me and
who took an oath.
IN WITNESS WHEREOF, my hand and seal in the State and County aforesaid
this aus day of June
* eco
Signature of Person TakiplAcknéylledgment
s HY
ve PU, VALERIE ANN VAZQUEZ
Commission # HH 062233
Valevi. Vazauer
< = Expires November 11, 2024 Name of Acknowledger (Typed, Printed or
ora Bonded Thru Budget Notary Services Stamped)
Title: Notary Public
Commission # W273
RESUME OF MATTHEW R. DANAHY
EXHIBIT A
Education:
University of Florida, Gainesville, Florida -- 1979 to 1983
Degree: Bachelor of Arts in Criminal Justice
St. Edmund Hall, Oxford University, Oxford, England — 1985
Accredited Program in Law Sponsored by Florida State University
Stetson University College of Law, Gulfport, Florida — 1983 to 1986
Degree: Juris Doctor
B. Professional Licenses, Certifications, Associations and Memberships:
Member, Florida Bar Association, Oct. 30, 1986- Present
- Trial Lawyers Section
Member, Hillsborough County Bar Association, 1986 - Present
- Chair, Professional Conduct Committee, 2007-2009
“A.V.” rated by Martindale-Hubbell legal directory and rating service, 2001 - Present
(Reflecting the highest level of skill, integrity and professional excellence)
Board Certified Civil Trial Lawyer by the Florida Bar Board of Legal Specialization and
Education, 2000- Present
- Re-Certified through 2025
Board Certified as a Civil Trial Advocate, National Board of Trial Advocacy, 2005 -
Present.
- Re-Certified through 2025
Board Certified as a Civil Pretrial Practice Advocate, National Board of Civil Pretrial
Practice Advocacy, 2012 - Present
Certified Circuit and County Court Mediator 1998 - Present.
- Re-Certified through 10/16/2022
Certified Umpire - Certified through Windstorm Insurance Network, Inc., 2005 - Present
- Advanced Umpire Training, 2009
- Re-Certified through 2023
Member, American Board of Trial Advocates (ABOTA), 2019 - Present
Member, Florida Windstorm Insurance Network, Inc. (2001-Present)
- Chair, Constitution/By-Laws Committee, 2010-2016
- Board of Directors, 2013-2016
- Fellow, 2014
6-2021
Silver Springs Moose Lodge No. 1199 v. Orman, 631 So.2d 1119, (Fla. 5 DCA 1994)
Roe v. Amica Mutual Ins. Co., 533 So.2d 279 (Fla.1988)
G. Media Appearances
October 11, 2005 — Wilkins, Frohlich Legal Hour
AM 1580, Port Charlotte, Florida
Topic: First Party Insurance/ legal issues
March 28, 2006 — Wilkins, Frohlich Legal Hour
AM 1580, Port Charlotte, Florida
Topic: First Party Insurance/ legal issues
May 23, 2006 — Wilkins, Frohlich Legal Hour
AM 1580, Port Charlotte, Florida
Topic: Preparation for the 2006 Hurricane Season
September 20, 2019 — Tampa Home Talk with Katrina Madewell
AM 1010, FM 103.1, FM 92.1. Tampa, Florida
Topic: Flood Insurance Claims
H. Court Rules Proposed and Adopted
Florida Rule of Appellate Procedure 9.130(a)(3)(c)(iv)- Proposed amendment to rule
permitting non final appeals to permit appeals from court orders requiring appraisal and
following Burnett v Clarendon Select Ins. Co., supra (see citation in reported cases)
L Boards/Community
Tampa Preparatory School, Board of Trustees, Tampa, Fl. (2011 - Present)
- Chair, Risk Management Committee (2014-2017)
- Board President (2017-2019)
-Trustee Emeritus (2021-present)
Boy Scouts of America, Troop 4, Palma Ceia Presbyterian Church, Tampa, FI.
-Assistant Scoutmaster (201 1- 2017)
6-2021
Licensed Educational Instructor, Florida Department of Financial Services, 2014
Fellow, Florida Bar Foundation - 2005
Member, Million Dollar Advocates Forum - 2005
Member, Florida Justice Association (Eagle)
-General Insurance Committee
Honored - Florida Super Lawyers Magazine (Insurance) - 2007 - 2021
Honored - Florida Trend Magazine, Florida Legal Elite - 2011, 2012, 2019
Honored - Best Lawyers in America — 2016 - 2021
Avvo.com legal rating service — Superb rating (10.0 out of 10.0).
c. Employment Experience:
June 2021 to Present - Danahy & Dunnavant P.A.,Tampa, Florida. Founding partner in
a trial practice firm exclusively representing insured individuals, partnerships and
corporations state wide in first party insurance claims, insurance coverage disputes, bad
faith litigation, and related appeals
November 2004 to June 2021 - Danahy and Murray P.A.,Tampa, Florida. Founding
partner in a trial practice firm exclusively representing insured individuals, partnerships
and corporations state wide in first party insurance claims, insurance coverage disputes,
bad faith litigation, and related appeals
May 2001 to November 2004 — Douglas L. Grose, P.A., Tampa, Florida. Attorney
exclusively representing insured’s in first party insurance claim litigation, insurance
coverage disputes, bad faith litigation, and related appeals state wide.
January 2000 to May 2001 - Rywant, Alvarez, Jones, Russo and Guyton, P.A., Tampa
and Ocala, Florida. Attorney handling cases involving insurance coverage disputes,
insurer bad faith, serious personal injury and wrongful death, and related appeals.
February 1992 to December 1999 — Shofi, Hennen and Gramovot, P.A., Tampa,
Florida, Partner in insurance defense firm handling the defense of insurance coverage
disputes, insurer bad faith, serious personal injury and wrongful death claims, premises
liability, products liability, professional malpractice (including medical and legal
malpractice claims), maritime law, and related appeals.
September 1989 to February 1992 — Rywant, Alvarez, Jones and Russo, P.A., Tampa,
Florida. Attorney practicing general insurance defense litigation and related appeals.
6-2021
December 1986 to September 1989 — Mitchell, Alley, Rywant and Vessel, P.A., Tampa,
Florida. Attorney practicing general insurance defense litigation and defending personal
injury and death suits resulting from asbestos exposure
D. Admitted to Practice by:
Florida Supreme Court (all State Courts in Florida)
U.S. District Courts — Middle District of Florida
Southern District of Florida
U.S. Circuit Court of Appeals — Eleventh Circuit
U.S. Supreme Court
Prior admission Pro Hac Vice in various foreign courts, including:
USS. District Court, Northern District, Florida
California Superior Court, Solano County, California
U.S. District Court, W. D. Kentucky
U.S. District Court, E. D, Tennessee
Illinois Circuit Court, 15" Circuit, Ogle County, Illinois
E. Lectures/Seminars:
November 3, 1999 - “Uninsured Motorist Coverage: Coverage Issues and Case Law
Update”
Florida Insurance Law Seminar,
Sponsored by Lorman Education Systems
Tampa, Florida
February 3, 2005 - “Mediation Issues and Strategies for First Party Insurance Claims”
6th Annual Windstorm Insurance Conference
Sponsored by the Windstorm Insurance Network
Tampa, Florida
March 24, 2005 - “Florida’s Valued Policy Law and Coverage Issues after Mierzwa”
F.A.P.1.A. Winter Conference
Sponsored by the Florida Association of Public Insurance Adjusters
Tallahassee, Florida
August 11, 2005 - “Overhead and Profit: Overview of Law and Industry Practice”
F.A.P.I.A. Summer Conference
Sponsored by the Florida Association of Public Insurance Adjusters
Orlando, Florida
6-2021
February 10, 2006 - “Mold: Are The New Policy Limitation Endorsements Working?”
7th Annual Windstorm Insurance Conference
Sponsored by the Windstorm Insurance Network
Orlando, Florida
August 10, 2006 - “Making Insurance Claims With The Florida Insurance Guaranty
Association (F.I.G.A.)”
F.A.P.1.A. Summer Conference
Sponsored by the Florida Association of Public Insurance Adjusters
Tampa, Florida
January 31, 2007 - “An Overview of Builder’s Risk Policies”
8th Annual Windstorm Insurance Conference
Sponsored by the Windstorm Insurance Network
Tampa, Florida
March 29, 2007 - “Florida’s Insurer of Last Resort: The Trouble With Citizens”
F.A.P.1.A. Winter Conference
Sponsored by the Florida Association of Public Adjusters
Orlando, Florida
August 10, 2007 - “Florida’s Insurer of Last Resort, Citizens Property Insurance
Corporation (Part II)”
F.A.P.L.A. Summer Conference
Sponsored by the Florida Association of Public Insurance Adjusters
Captiva Island, Florida
January 11, 2008 - “Pre-Suit Mediation of First Party Insurance Claims”
F.A.P.I.A. Winter Conference
Sponsored by the Florida Association of Public Insurance Adjusters
Orlando, Florida
March 10, 2008 - “Professionalism-Good for the Profession & Good for You”
Hillsborough County Bar Association, Professional Conduct Section
Tampa, Florida
January 12, 2010 - “He Said, She Said & All The Letters in Between (Public Adjusters &
Letter Writing 101)”
F.A.P.I.A. Winter Conference
Sponsored by the Florida Association of Public Insurance Adjusters
Tampa, Florida
January 26, 2010 - “Claims Handling Fundamentals — State Claims Handling Practices”
10th Annual Windstorm Insurance Conference
Sponsored by the Windstorm Insurance Network
Jacksonville, Florida
6-2021
June 28, 2010 - “Sinkholes — Florida’s Other Catastrophe”
F.A.P.I.A. Summer Conference
Sponsored by the Florida Association of Public Insurance Adjusters
Ft. Lauderdale, Florida
January 11, 2011 - “Avoiding the Fraudulent Policy Holder”
F.A.P.I.A. Winter Conference
Sponsored by the Florida Association of Public Insurance Adjusters
Orlando, Florida
February | & 2, 2012 - “Knowing Coverage and Policy Language”
13th Annual Windstorm Insurance Conference
Sponsored by the Windstorm Insurance Network
Orlando, Florida
May 22, 2012 - “Public Adjusting 201-Law and Policy, Knowing Coverage and Policy
Language”
F.A.P.1.A. Spring Conference
Sponsored by the Florida Association of Public Insurance Adjusters
Kissimmee, Florida
Jan 28 & 29, 2014 - “Myths and Legends in Property Adjusting”
15" Annual Windstorm Insurance Conference
Sponsored by the Windstorm Insurance Network
Orlando, Florida
November 7, 2016 - “Current Issues Involving Anti-Assignment of Benefits Endorsement
and Agreement Not to Use Public Adjusters in Lloyds of London Application”
F.A.P.I.A. Fall Conference
Sponsored by the Florida Association of Public Insurance Adjusters
Orlando, Florida
May 22, 2017 - “Timing is Everything- Documenting the Claim File”
F.A.P.1.A 25" Anniversary Conference
Sponsored by the Florida Association of Public Insurance Adjusters
Hawks Cay Resort, Duck Key, Florida
June 4, 2018 - “This Old House: Unique Considerations When Adjusting Damage to Old
and Historic Homes”
F.A.P.LA. Spring 2018 Conference
Sponsored by the Florida Association of Public Adjusters
Sanibel Harbour Resort and Spa, Ft. Myers, Florida
October 27, 2018 - “Insurance Company Delay Tactics and How to Deal With Them”
F.A.P.1.A Fall 2018 Conference
Sponsored by the Florida Association of Public Adjusters
Wyndham Grand Orlando Resort Bonnet Creek, Orlando, Florida
6-2021
October 27,2019 - “Duties After Loss — Is Everyone In Compliance?”
F.A.P.1.A. Fall 2019 Conference
Sponsored by the Florida Association of Public Adjusters
Wyndham Grand Orlando Resort Bonnet Creek, Orlando, Florida
December 7, 2020 - “Fire Claim Analysis ”
F.A.P.I.A Virtual 2020 Conference
Sponsored by the Florida Association of Public Adjusters
Webinar
Reported First Party Insurance Cases (Representative List):
Florida Peninsula Insurance Company v Newlin, 2019 Fla. App. LEXIS 9152,*1,
2019 WL 2439375 (Fla.2"¢ DCA 2019)
Hunt v State Farm Florida Ins, Co., 2013 WL 1352471 (Fla. 2" DCA 2013)
Sunshine State Ins. Co. v. Benjamin, 100 So. 3" 90 (Fla. 2" DCA 2012)
Jackson V Metropolitan Property and Casualty Insurance Co., 2007 W.L.2936213
(M.D. Fla.); 2008 W.L.58953 (M.D. Fla.); 2009 W.L.1456439 (M.D. Fla.)
Goff v. State Farm Florida Ins. Co., 999 So.2d 684 (Fla. 2" DCA 2009)
Wilson v. Federated Nat. Ins. Co., 969 So.2d 1133, (Fla. 2“ DCA 2007)
Burnett v. Clarendon Select Ins. Co., 920 So.2d 188, (Fla. 2"! DCA 2006)
Widdows v. State Farm Florida Ins. Co., 920 So.2d 149, (Fla. 5“ DCA 2006)
General Star Indemnity. Co. v. West Florida Village Inn, Inc., 874 So.2d 26, (Fla. 2"4
DCA 2004)
Lasman v. Freedom Life Ins. Co. of America, 862 So.2d 787, (Fla. 2" DCA 2003)
Infinity Ins. Co. v. Berges, 806 So.2d 504, (Fla.2"4 DCA 2001)
Dominion of Canada v. State Farm Fire and Casualty. Co., 754 So.2d 852, (Fla. 2" DCA
2000)
Fireman's Fund Ins. Co. v. Signorelli, 681 So.2d 720, (Fla. 2"! DCA 1996)
Ady v. American Honda Finance Corp., 675 So.2d 577, (Fla.1996)
Russo v. Plant City Moose Lodge No. 1668, 656 So.2d 957, (Fla. 2" DCA 1995)
Ady v. American Honda Finance Corp., 652 So.2d 415, (Fla. 2" DCA 1995)
6-2021
Exhibit B
im
DANAHY & MURRAY
901 West Swann Avenue
Tampa, Florida 33606
(813) 258-3600 (phone) (813) 258-3321 (fax)
www.danahyandmurray.com
AUTHORITY
TO REPRESENT
u ct
Me, , the undersigned Client(s) do(es)
hereby retain and employ the law firm DANAHY & MURRAY, P.A. , (the Lawyers), to represent me/us in
myh Pp damages, both contractual and extra-contractual, against
‘or any other Ins: urance Tt any 1 who is or may be liable for danfages
an rence or loss on or about arising out of a
claim or loss , upon the following terms
1, ATTORNEY'S FEE - In the event of a recovery of benefits from the ctient(s)’ insurer(s), their agents,
tepresentatives and/or others, the client(s) agree(s) to pay the attomey’s fee to the Lawyers as outlined
below:
(a) 33.3% of the gross recovery, or Court Awarded Fees, whichever is greater for any damages
recovered before or after a lawsuit is filed seeking contact damages or declaratory relief.
(b) 40% of the gross recovery, or Court Awarded Fees, whichever is greater, for any damages
recovered in a “bad faith” or extra contractual damages claim made following the resolution of
contract damages owed or after a suit for bad faith or extra-contractual damages is filed.
(b) Court Awarded Fees - If there is a Court Awarded Fee under Florida Statute §627.428, 624.155, or
any other separately determined Court awarded fee, including fees that exceeds the amount the client(s)
are obligated to pay as a contingency fee from the gross recovery, then the Lawyers will receive the amount
so awarded by the Court. This Court awarded amount is in lieu of and shall not be added to the client(s)’
obligation to pay attorney's fees on a contingency fee basis. In the event a Court awarded fee Is less than
the amount the client(s) is to pay as a contingency fee, then the difference between the Court awarded fee
and the amount to be paid pursuant to the contingency fee provisions shall remain due from the client.
Notwithstanding the percentages set forth above, if a statute, law or court rule requires a lesser fee, this
contract shall be deemed amended to conform to such statute, law, or rule.
The client(s) agree to preserve the right for the Lawyers to seek a fee award, and agree(s) that Lawyers are
entitled to collect any amount awarded by the Court or paid by the Insurer as attomey's fees. The clients
hereby assign Lawyers all rights to seek any awards of Lawyer's attomey's fees, and agree that any fee
payment or court awarded fee/judgment may be made payable directly to Lawyers.
it this ymen pon contingent fe nd ifno recovery mad
th -AWYE or atto:
2. DEF IN ROSSRi - The contingencyfee to be paid to the Lawyerswill be calculated
based on the “gross recovery” obtained in the case. “Gross Recovery” is the total amount recovered and
actually received by, on behalf of, or for the benefit of the client(s), including amount recovered as interest.
There is to be no deduction for costs or other expenses from the gross recovery in determining the amount
of contingency atto: 's fee due. Any amounts paid to client(s) by the insurance company prior to the
retention of the Lawyers is not included in the calculation of Gross Recovery.
3. ADVANCED COSTS - Client(s) understand(s) and acknowledge(s) that it will be necessary to incur
costs in the prosecution of the claim and any related litigation. Client(s) expressly authorize(s) the Lawyers
to incur and expend such costs as are reasenable and necessary. in the event of recovery, all such
advanced costs are to be paid from the gross recovery after reduction by the amount of attomey’s fees due.
OlvE"d TEEHBSSETST OL *WOad Te:9t Tte@2-8-aa4
Intl nt that no recovery i: ad,very is insufficient to full
or the ay attomey’s fees and costs, then
the client(s) shall have no further obligati o reimburse the L: for costs. Reim! ment of costs
advanced by the Lawyers are contingent upon recovery.
4. ONSENT TO SETTLEMENT AND CONTROL 0! OF LITIGATION IN - Client(s) authorize(s) the Lawyers to
bring those actions and causes of actions that they believe, in good faith, ought to be prosecute in order to
assert the claims against any offending party, as may be applicable or appropriat te. The Client(s) retain(s)
the right to ultimately decide whether a settlement should be accepted.
Client(s), acknowledge(s) that the claims do, or may, carry a right to obtain a court awarded al ttomey’s fee
based upon differing factors, including the attomeys’ hours spent prosecuting the claims. Further, a
settlement offer inclusive of the attorney's fee claim may represent substantially more in attorney's fee
payment that even client(s)’ claim on the merits, independent of attorney's fees. Client(s) agree to protect
the Lawyers right to pursue court awarded fee when making any settlement decision.
LIENTS’ RIGHT TO FIRE THE ERS Client(s) has/have the right to fire the Lawyers at any
time, even without cause or justification. [If client fires the Lawyers, Client(s) agree(s) to pay the Lawyers
the reasonable value of the Lawyers’ services and to promptly repay any costs or expenses advanced or
incurred on behaff of client in the handling of this matter.
6. LAWYERS’ RIGHT TO WITHDRAW - The client(s) will cooperate with the Lawyers as they handle this
case. ifthe Lawyers, for any reason, determine it is unfeasible for the Lawyerto continue representation,
--
the-Lawyers-may cancel ‘the ‘contract and the Client(s) will not be obligated for legal fees, unless the
cancellation is due to Client(s) failure to cooperate with the Lawyer's reasonable requests, or other good
cause, in which case the Lawyers shall be entitled to a retaining lien and/or charging lien to recover fees
and costs.
7. NATURE OF EMPLOYMENT - it is agreed and understood that this employment is limited to the First
Party legal representation as identified in paragraph 1. This representation only applies to the named
parties described on page one (1) and does not include any other legal work or advice, and specifically
does not include tax advice, financial planning or investment planning. The client(s) assume(s) the
responsibility of obtaining such tax or financial advice from other sources.
8. THE ENTIRE AGREEMENT - This Authority to Represent states the entire agreement between the
Client(s) and the Lawyers and takes the place of any prior oral or written agreements. This Agreement is
entered into and is to be performed within the State of Florida, and is to be interpreted in accordance with
Florida law. The terms of this agreement may be changed only by a separate written agreement signed and
dated by the Client(s) and the Lawyers.
This contract may be cancelled by written notification to the Lawyers at any time within three (3) business
days of the date the contract is signed, and if cancelled the client(s) shall not be obligated to pay any fees to
the Lawyers.
RECOVERY IS MADE, C! T(S) WILL NOT BE INDEBTED TO THE LAWYERS FOR ANY S'
WHATSOEVER AS ATTORNEY’S FEES
pate 2/S/A] La 2a Client
Date: Client
Date: 2121 2) CHL put Danahy + Murray
Bt-b'd Tekeasee tet OL ?WOY4d 22:97 tea2-8-834
DANAHY —_—_——
DUNNAVANT
INSURANCE CLAIM LAWYERS
901 WEST SWANN AVE. TELEPHONE (813) 906-1841 ‘WWW.DANDDLAW.COM
TAMPA, FLORIDA 33606 FACSIMILE (813) 579-1912
AUTHORITY TO REPRESENT
D ni: Furry,
We, Denise Fur the undersigned Client(s) do(es) hereby retain and employ the law firm of DANAHY &
DUNNAVANT, P.A., (the Lawyers), to represent us in our claim(s) for damages; both contractual and extra-
contractual, against State Farm Florida Ins. Co or any other person, firm or corporation who is or may be
liable for damages resulting from an occurrence or loss on or about November 11, 2020 arising from
windstorm (loss), effective June 14, 2021 and retroactive to the date of the original contract with the
predecessor firm Danahy & Murray PA, upon the following terms:
1. ATTORNEY'S FEE - In the event of a recovery of benefits from the client(s)’ insurer(s), their agents,
representatives and/or others, the client(s) agree(s) to pay the attomey's fee to the Lawyers.as outlined
below:
(a) 33 1/3% of the gross recovery, or Court Awarded Fees, whichever is greater.
(b) 40% of any claim for bad faith or extra contractual damages, or court awarded fees, whichever is
greater, in the event of a separate bad faith or extra contractual claim
Court Awarded Fees - If there is a Court Awarded Fee under Florida Statutes §627.428, §624.155,
§626.9373 or any other separately determined Court awarded fee, including fees that exceeds the amount
the client(s) are obligated to pay as a contingency fee from the gross recovery, then the Lawyers will
receive the amount so awarded by the Court. This Court awarded amount is in lieu of and shall not be
added to the client(s)' obligation to pay attorney's fees on a contingency fee basis. In the event a Court
awarded fee is less than the amount the client(s) is to pay as a contingency fee, then the difference
between the Court awarded fee and the amount to be paid pursuant to the contingency fee provisions shall
remain due from the client. Notwithstanding the percentages set forth above, if a statute, law or court rule
requires a lesser fee, this contract shall be deemed amended to conform to such statute, law, or rule.
The client(s) agree to preserve the right for the Lawyers to seek a fee award and agree(s) that Lawyers are
entitled to collect any amount awarded by the Court or paid by the Insurer as attorney's fees. The clients
hereby assign Lawyers all rights to seek any awards of Lawyer's attorney's fees and agree that any fee
payment or court awarded fee/judgment may be made payable directly to Lawyers.
ind understood this m nt i upon co lingent e ba d if no recove Is mage
he inde: ed ents will not be inde 9 the ers for attorn ey'sfe
2. DEFINTION oF cross RECOVERY - The contingency fee to be paid to the Lawyers will be calculated
based on the “gross recovery” obtained in the case. “Gross Recovery” is the total amount recovered and
actually received by, on behalf of, or for the benefit of the client(s), including amount recovered as interest.
There is to be no deduction for costs or other expenses from the gross recovery in determining the amount
of contingency attorney's fee due. Any amounts paid prior to client(s) retention of the Lawyers is not
included in the calculation of gross recovery.
3. ADVANCED COSTS - Client(s) understand(s) and acknowledge(s) that it will be necessary to incur
costs in the prosecution of the claim and any related litigation. Client(s) expressly authorize(s) the Lawyers
8
.
to incur and expend such costs as are reasonable and necessary. In the event of recovery, all such
advanced costs are to be paid from the gross recovery after reduction by the amount of attomey's fees due.
In the even recovel is had, or the ré very is insufficient to f lorney's fe s and costs, then
*
client(s) further obli tion to imburse. ers for cost: t rsement of costs
advani th ers are Int upon recov!
4. CONSENT TO SETTLEMENT AND CONTROL OF LITIGATION — Client(s) authorize(s) the Lawyers to
bring those actions and causes of actions that they believe, in good faith, ought to be prosecute in order to
assert the claims against any offending party, as may be applicable or appropriate. The Client(s) retain(s)
the right to ultimately decide whether a settlement should be accepted.
Client(s), acknowledge(s) that the claims do, or may, carry a right to obtain a court awarded attomey's fee
based upon differing factors, including the attorneys’ hours spent prosecuting the claims. Further, a
settlement offer inclusive of the attorney's fee claim may represent substantially more in attorney's fee
payment that even client(s)’ claim on the merits, independent of attorney's fees. Client(s) agree to protect
the Lawyers right to pursue court awarded fee when making any settlement decision.
5. CLIENTS’ RIGHT TO FIRE THE LAWYERS - Client(s) has/have the right to fire the Lawyers at any
time, even without cause or justification. If client fires the Lawyers, Client(s) agree(s) to pay the Lawyers
the reasonable value of the Lawyers’ services and to promptly repay any costs or expenses advanced or
incurred on behalf of client in the handling of this matter.
6. LAWYERS’ RIGHT TO WITHDRAW - The client(s) will cooperate with the Lawyers as they handle this
case. If the Lawyers, for any reason, determine it is unfeasible for the Lawyer to continue representation,
the Lawyers may cancel the contract and the Client(s) will not be obligated for legal fees, unless the
cancellation is due to Client(s) failure to cooperate with the Lawyer's reasonable requests, or other good
cause, in which case the Lawyers shall be entitled to a retaining lien and/or charging lien to recover fees
and costs.
7. NATURE OF EMPLOYMENT - It is agreed and understood that this employment is limited to the First
Party legal representation as identified in paragraph 1. This representation only applies to the named
parties described on page one (1) and does not include any other legal work or advice, and specifically
does not include tax advice, financial planning or investment planning. The client(s) assume(s) the
responsibility of obtaining such tax or financial advice from other sources.
8. THE ENTIRE AGREEMENT - This Authority to Represent states the entire agreement between the
Client(s) and the Lawyers and takes the place of any prior oral or written agreements. This Agreement is
entered into and is to be performed within the State of Florida and is to be interpreted in accordance with
Florida law. ‘Thé termsof this agreement may be changed only by a separate written agreement signed and
dated by the Client(s) and the Lawyers.
This contract may be cancelled by written notification to the Lawyers any time within three (3) business days
of the date the contract is signed, and if cancelled the client(s) shall not be obligated to pay any fees.
u IF RECOVE! LIENT(S) WILL NOT BI IDEBTED TO THE LAWYERS IR ANY SUM
WHATSOEVER AS ATTORNEY'S FEES OR COSTS
Date: a/ (2z. By: leews Jury
Client
Date: 2/ 7 | Ve By:. LO lm
Danahy & Dunnavant, PA.
Exhibit C
Summary of Claimed Time
Time |Records | from Feb 9, 2021 to Present
D&M Billable Non-billable Fees D&D Billable Non-billable |Fees
MRD 9.6) 4.1] $6,720.00 MRD 9.6) 2.4| $6,720.00
ED 0 0 $0.00 ED 1.6) 0 $800.00
KLA 1,7 29 $765.00 KLA 0 $0.00
cD 47 0 $728.50 cD 9.2) O| $1,426.00
JT 0 0 $0.00 JT 1.8) 0 $270.00
Totals 16} 7|_ $8,213.50 Totals 22.2) 2.4| $9,216.00
Totals Billable Non-billable Fees
MRD 19.2 6.5] $13,440.00 Total Time 47.6
ED 1.6 0 $800.00 Total Bill 38.2
KLA 17 2.9 $765.00 Total Non 9.4
cD 13.9 O} $2,154.50 Total Fees $17,429.50
JT 18 oO $270.00
Totals 38.2] 9.4] $17,429.50
Danahy & Murray, PA.
901 West Swann Avenue
Tampa, FL 33606
Ph:813-258-3600 Fax:813-258-3321
Denise Furry December 8, 2021
PO Box 381032
Murdock, FL
33938
File #: Furry
Attention: Inv #: Sample
RE: Furry vs State Farm
DATE DESCRIPTION HOURS AMOUNT LAWYER
Jan-12-21 Phone call with public adjuster Bill Kovacik 0.50 350.00 MRD
regarding claim and possible Civil Remedy
Notice
Prepare e-mail to public adjuster with Civil 0.10 70.00 MRD
Remedy Notice checklist
Jan-15-21 Receipt of documents for Civil Remedy Notice 0.40 280.00 MRD
from public adjuster
Phone call with public adjuster regarding 0.50 350.00 MRD
details of claim
Jan-19-21 Review and revise draft Civil Remedy Notice 0.40 280.00 MRD
of Insurer Violation and letter to potential new
client (drafted by KLA)
Jan-21-21 Call with Bill Kovacik regarding Civil 0.20 140.00 MRD
Remedy Notice of Insurer Violation
Phone call with potential new client regarding 0.60 420.00
claim / Civil Remedy Notice of Insurer
Violation
Jan-22-21 Receipt and review authorization to file Civil 0.10 70.00 MRD
Remedy Notice of Insurer Violation
Receipt and review of Proof of loss drafted by 0.10 70.00 MRD
public adjuster
Invoice #: Sample Page 2 December 8, 2021
Exchange e-mails with KLA regarding 0.10 70.00 MRD
revisions to Civil Remedy Notice of Insurer
Violation
Receipt of call from public adjuster 0.10 70.00 MRD
Feb-04-21 Send new Client documents to Denise Furry 0.20 140.00 MRD
with e-mail
DESC ONLY - Receipt of e-mail / letter from 0.10 NIC MRD
State Farm
DESC ONLY - Prepare e-mail to potential new 0.10 N/C MRD
client and public adjuster
DESC ONLY - Phone conference with 0.20 N/C MRD
potential new client and public adjuster
regarding representation
Feb-08-21 Call from potential new client to discuss 0.40 280.00 MRD
representation
Feb-09-21 Receipt of new client documents from Client 0.20 140.00 MRD
Receipt of public adjuster file materials and 0.20 140.00 MRD
review same with e-mail of 2/9
drafted complaint for breach of contract 1.20 0.00 KLA
Feb-10-21 drafted b6 notice and schedules 0.20 0.00
drafted first request for production to 0.30 0.00 KLA
defendant
drafted first interrogatories to state farm 0.40 0.00 KLA
drafted first request for admissions to state 0.40 0.00 KLA
farm
drafted antispoliation letter 0.20 0.00 KLA
drafted client complaint letter 0.10 0.00 KLA
drafted summons and civil cover sheet 0.10 0.00 KLA
final review and revisions to complaint 0.20 90.00 KLA
Invoice #: Sample Page 3 December 8, 2021
Feb-11-21 Review and revise complaint and exhibits 0.80 560.00 MRD
Review and revise discovery to State Farm 0.80 560.00 MRD
(Request for Production / RA's / Interrogs)
Review letter to adjuster and B6 Notice 0.20 140.00 MRD
Feb-12-21 Receipt of certified policy from State Farm 0.20 140.00 MRD
adjuster
Feb-15-21 Exchange e-mails with Client regarding e-mail 0.10 70.00 MRD
from State Farm she received on 2/10
Feb-17-21 Brief initial review of summons issued by 0.10 15.50 CBD
clerk
Research county court procedures in Charlotte 0.20 31.00 CBD
county to determine if service of Standing
Order in Civil Cases required for county Civil
Cases
Feb-18-21 Receipt of 2/17 email from State Farm 0.10 70.00 MRD
attorney Jay Green requesting public adjuster
respond to his 2/11 letter seeking reinspection
Prepare email in response to SF attorney 0.30 210.00 MRD
Phone conference with Bill Kovacik regarding 0.20 140.00 MRD
State Farm letter and response
Brief initial review of letter and email from 0.10 15.50 CBD
opposing counsel providing 2/11/21 letter
acknowledging dispute
Telephone call with Public Adjuster regarding 0.10 15.50 CBD
email from opposing counsel providing
2/11/21 letter acknowledging dispute
Feb-22-21 Receipt of Service of Process Fee 0.10 70.00 MRD
Preview
Filing # 152010754 E-Filed 06/22/2022 05:15:30 PM IN THE COUNTY COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA COUNTY CIVIL DIVISION DENISE FURRY, Plaintiff, Case No. 21000164CC vs. STATE FARM FLORIDA INSURANCE COMPANY, Defendant. / AFFIDAVIT OF MATTHEW R. DANAHY IN SUPPORT OF PLAINTIFF’S CLAIM FOR ATTORNEY’S FEES STATE OF FLORIDA COUNTY OF HILLSBOROUGH BEFORE ME the undersigned authority, this day personally appeared MATTHEW R. DANAHY, who after being first duly sworn, deposes and says as follows: 1 | am an attorney in good standing licensed to practice law in the State of Florida and have been so licensed since October 30, 1986. 2 lam A.V. rated by Martindale-Hubbell and Board Certified in Civil Trial Law by both the Florida Bar and the National Board of Trial Advocacy. 3 | have over 35 years of experience as an attorney handling cases in civil litigation. During that time, | have represented both insurance companies and insureds in cases involving insurance claims and coverage issues. 4 For the past twenty (22) years, | have exclusively represented insureds against their insurers in insurance coverage disputes and other first party claims, including disputed water loss claims such as the claim at issue. A copy of my professional Resume is attached as Exhibit A. 5. In addition to my litigation experience, | have also handled in excess of 60 appeals to the Florida District Courts of Appeal, Florida Supreme Court and Federal Eleventh Circuit Court of Appeal. Most of those appeals have involved first party and insurance matters. 6. On February 9, 2021, my law firm, Danahy & Dunnavant, P.A. (f/k/a Danahy & Murray, P.A.) was retained by DENISE FURRY (MS. FURRY) (See Authority to Represent attached as composite Exhibit B', and also identified as Exhibit 1 to Plaintiffs Comprehensive Fee Motion). 7. From February 9, 2021 through the present my firm(s) and | have spent 47.6 hours doing appropriate legal work for MS. FURRY in prosecuting her case against STATE FARM FLORIDA INSURANCE COMPANY (“STATE FARM”). Of this time, 38.2 hours is billable and 9.4 hours is non-billable and is not being claimed. 8. To date entitlement remains in dispute, as no stipulation to entitlement has been made by State Farm. As a result, entitlement remains to be resolved by the court. 9. The 38.2 hours claimed, from February 9, 2021 through the present have a lodestar value of $17,429.50. The time expended was kept in contemporaneous time records which are attached along with a summary of total and claimed time. See Exhibit c 10. My time was billed at my normal hourly rate of $700.00 for 19.2 hours of billable legal work from February 9, 2021 through the present. This post-suit and post- 1 On June 14, 2021, Danahy & Murray, P.A. ceased operation, and representation of Plaintiff's claim was assumed by Danahy & Dunnavant, P.A. as reflected in Plaintiffs’ Authority to Represent dated June 14, 2021. 2 appraisal payment was a “confession of judgment” and the functional equivalent of a verdict in Plaintiffs favor. | also incurred 6.5 hours of time for which no fee is claimed. 11. My hours incurred were reasonable and necessary, and my hourly rate is fair and reasonable based on my ability, experience and the nature of my practice exclusively handling first party claims by insureds against their insurers. 12. Further, my hourly rate has been awarded by Florida courts, is paid by clients who can afford to do so (including insurance companies in the appraisal process where | serve as both an Umpire and an Appraiser) and has been stipulated to be reasonable and paid by other insurance companies, including by Citizens Property Insurance Company (the state’s largest insurer). 13. Erin E. Dunnavant, Esquire was an associate with the firm of Danahy & Murray, P.A. and is a partner with Danahy & Dunnavant, P.A. Her time was billed at her normal hourly rate of $500.00 per hour for 1.6 hours of reasonable and necessary legal work up to the date of the payment of the appraisal award. 14, Her hourly rate was and is consistent with those rates for an attorney of her ability and experience who exclusively handles first party claims in Charlotte County and throughout the State of Florida. Her rate is consistent with other attorneys of her experience who exclusively handle such claims and who are partners in a first party litigation practice. Ms. Dunnavant's professional Resume is attached as Exhibit D. 15. Kimberly L. Armistead, Esquire was an associate with the firm of Danahy & Murray, P.A. Her time was billed at her normal hourly rate of $450.00 per hour for 1.7 hours of reasonable and necessary legal work prior to the payment of the appraisal award, and 2.9 hours of non-billable time for which a fee is not being claimed. 16. Her hourly rate was and is consistent with those rates for an attorney of her ability and experience who exclusively handles first party claims in Charlotte County and throughout the State of Florida. Her rate is consistent with other attorneys of her experience who exclusively handle such claims. Ms. Armistead’s prior professional Resume is attached as Exhibit E. 17. Courtney Bumgarner was a paralegal with the firm of Danahy & Murray, P.A., and is currently a paralegal with the firm of Danahy & Dunnavant, P.A. Her time was billed at her normal hourly rate $155.00 per hour for 13.9 hours of reasonable and necessary legal work. 18. Her hourly rate is reasonable and consistent with those rates for a paralegal of her ability and experience who exclusively handles first party claims in Charlotte county and throughout Florida. A copy of Ms. Bumgarner’s professional Resume is attached as Exhibit F. 19. Jeannine Thurlow is a paralegal with the firm of Danahy & Dunnavant, P.A. Her time was billed at her normal hourly rate $150.00 per hour for 1.8 hours of reasonable and necessary legal work. 20. Her hourly rate is reasonable and consistent with those rates for a paralegal of her ability and experience who exclusively handles “first party” claims in Charlotte county and throughout Florida. A copy of Ms. Thurlow’s professional Resume is attached as Exhibit G. 21. My firm(s) took this case on a contingency fee basis as to both fees and costs, and) have worked on Plaintiffs behalf since February 9, 2021 without being paid any fees or costs for the prosecution of the claim. 22. MS. FURRY advised that, after suffering the windstorm loss and roof damage complained of, the need to replace the roof, and the denial of her roof replacement claim, and the coverage defenses raised, she needed to be paid for the damage to her home. As she could not afford to pay attorney's fees or any costs needed to prosecute her claim she required a contingency fee agreement. 23. | believe a fee enhancement multiplier of 2.0 should be used, according to the standards set by Standard Guaranty Insurance Co. vs. Quanstrom, 555 So.2d. 828 (Fla. 1990) and State Farm Fire and Casualty Co. v. Palma, 555 So.2d 836 (Fla. 1990). The reasons for this are more fully set forth in the Comprehensive Motion for Determination of Attorney's Fees, Costs and Interest and Memorandum of Law in support thereof, which reasons are incorporated herein by reference. [SEE AVERMENT ON NEXT PAGE] FURTHER AFFIANT SAYETH NOT. L fil huty MATTHEW R. DANAHY L The foregoing instrument was acknowledged before me this ygind day of J A Ne , 2022, by MATTHEW R. DANAHY, who is personally known to me and who took an oath. IN WITNESS WHEREOF, my hand and seal in the State and County aforesaid this aus day of June * eco Signature of Person TakiplAcknéylledgment s HY ve PU, VALERIE ANN VAZQUEZ Commission # HH 062233 Valevi. Vazauer < = Expires November 11, 2024 Name of Acknowledger (Typed, Printed or ora Bonded Thru Budget Notary Services Stamped) Title: Notary Public Commission # W273 RESUME OF MATTHEW R. DANAHY EXHIBIT A Education: University of Florida, Gainesville, Florida -- 1979 to 1983 Degree: Bachelor of Arts in Criminal Justice St. Edmund Hall, Oxford University, Oxford, England — 1985 Accredited Program in Law Sponsored by Florida State University Stetson University College of Law, Gulfport, Florida — 1983 to 1986 Degree: Juris Doctor B. Professional Licenses, Certifications, Associations and Memberships: Member, Florida Bar Association, Oct. 30, 1986- Present - Trial Lawyers Section Member, Hillsborough County Bar Association, 1986 - Present - Chair, Professional Conduct Committee, 2007-2009 “A.V.” rated by Martindale-Hubbell legal directory and rating service, 2001 - Present (Reflecting the highest level of skill, integrity and professional excellence) Board Certified Civil Trial Lawyer by the Florida Bar Board of Legal Specialization and Education, 2000- Present - Re-Certified through 2025 Board Certified as a Civil Trial Advocate, National Board of Trial Advocacy, 2005 - Present. - Re-Certified through 2025 Board Certified as a Civil Pretrial Practice Advocate, National Board of Civil Pretrial Practice Advocacy, 2012 - Present Certified Circuit and County Court Mediator 1998 - Present. - Re-Certified through 10/16/2022 Certified Umpire - Certified through Windstorm Insurance Network, Inc., 2005 - Present - Advanced Umpire Training, 2009 - Re-Certified through 2023 Member, American Board of Trial Advocates (ABOTA), 2019 - Present Member, Florida Windstorm Insurance Network, Inc. (2001-Present) - Chair, Constitution/By-Laws Committee, 2010-2016 - Board of Directors, 2013-2016 - Fellow, 2014 6-2021 Silver Springs Moose Lodge No. 1199 v. Orman, 631 So.2d 1119, (Fla. 5 DCA 1994) Roe v. Amica Mutual Ins. Co., 533 So.2d 279 (Fla.1988) G. Media Appearances October 11, 2005 — Wilkins, Frohlich Legal Hour AM 1580, Port Charlotte, Florida Topic: First Party Insurance/ legal issues March 28, 2006 — Wilkins, Frohlich Legal Hour AM 1580, Port Charlotte, Florida Topic: First Party Insurance/ legal issues May 23, 2006 — Wilkins, Frohlich Legal Hour AM 1580, Port Charlotte, Florida Topic: Preparation for the 2006 Hurricane Season September 20, 2019 — Tampa Home Talk with Katrina Madewell AM 1010, FM 103.1, FM 92.1. Tampa, Florida Topic: Flood Insurance Claims H. Court Rules Proposed and Adopted Florida Rule of Appellate Procedure 9.130(a)(3)(c)(iv)- Proposed amendment to rule permitting non final appeals to permit appeals from court orders requiring appraisal and following Burnett v Clarendon Select Ins. Co., supra (see citation in reported cases) L Boards/Community Tampa Preparatory School, Board of Trustees, Tampa, Fl. (2011 - Present) - Chair, Risk Management Committee (2014-2017) - Board President (2017-2019) -Trustee Emeritus (2021-present) Boy Scouts of America, Troop 4, Palma Ceia Presbyterian Church, Tampa, FI. -Assistant Scoutmaster (201 1- 2017) 6-2021 Licensed Educational Instructor, Florida Department of Financial Services, 2014 Fellow, Florida Bar Foundation - 2005 Member, Million Dollar Advocates Forum - 2005 Member, Florida Justice Association (Eagle) -General Insurance Committee Honored - Florida Super Lawyers Magazine (Insurance) - 2007 - 2021 Honored - Florida Trend Magazine, Florida Legal Elite - 2011, 2012, 2019 Honored - Best Lawyers in America — 2016 - 2021 Avvo.com legal rating service — Superb rating (10.0 out of 10.0). c. Employment Experience: June 2021 to Present - Danahy & Dunnavant P.A.,Tampa, Florida. Founding partner in a trial practice firm exclusively representing insured individuals, partnerships and corporations state wide in first party insurance claims, insurance coverage disputes, bad faith litigation, and related appeals November 2004 to June 2021 - Danahy and Murray P.A.,Tampa, Florida. Founding partner in a trial practice firm exclusively representing insured individuals, partnerships and corporations state wide in first party insurance claims, insurance coverage disputes, bad faith litigation, and related appeals May 2001 to November 2004 — Douglas L. Grose, P.A., Tampa, Florida. Attorney exclusively representing insured’s in first party insurance claim litigation, insurance coverage disputes, bad faith litigation, and related appeals state wide. January 2000 to May 2001 - Rywant, Alvarez, Jones, Russo and Guyton, P.A., Tampa and Ocala, Florida. Attorney handling cases involving insurance coverage disputes, insurer bad faith, serious personal injury and wrongful death, and related appeals. February 1992 to December 1999 — Shofi, Hennen and Gramovot, P.A., Tampa, Florida, Partner in insurance defense firm handling the defense of insurance coverage disputes, insurer bad faith, serious personal injury and wrongful death claims, premises liability, products liability, professional malpractice (including medical and legal malpractice claims), maritime law, and related appeals. September 1989 to February 1992 — Rywant, Alvarez, Jones and Russo, P.A., Tampa, Florida. Attorney practicing general insurance defense litigation and related appeals. 6-2021 December 1986 to September 1989 — Mitchell, Alley, Rywant and Vessel, P.A., Tampa, Florida. Attorney practicing general insurance defense litigation and defending personal injury and death suits resulting from asbestos exposure D. Admitted to Practice by: Florida Supreme Court (all State Courts in Florida) U.S. District Courts — Middle District of Florida Southern District of Florida U.S. Circuit Court of Appeals — Eleventh Circuit U.S. Supreme Court Prior admission Pro Hac Vice in various foreign courts, including: USS. District Court, Northern District, Florida California Superior Court, Solano County, California U.S. District Court, W. D. Kentucky U.S. District Court, E. D, Tennessee Illinois Circuit Court, 15" Circuit, Ogle County, Illinois E. Lectures/Seminars: November 3, 1999 - “Uninsured Motorist Coverage: Coverage Issues and Case Law Update” Florida Insurance Law Seminar, Sponsored by Lorman Education Systems Tampa, Florida February 3, 2005 - “Mediation Issues and Strategies for First Party Insurance Claims” 6th Annual Windstorm Insurance Conference Sponsored by the Windstorm Insurance Network Tampa, Florida March 24, 2005 - “Florida’s Valued Policy Law and Coverage Issues after Mierzwa” F.A.P.1.A. Winter Conference Sponsored by the Florida Association of Public Insurance Adjusters Tallahassee, Florida August 11, 2005 - “Overhead and Profit: Overview of Law and Industry Practice” F.A.P.I.A. Summer Conference Sponsored by the Florida Association of Public Insurance Adjusters Orlando, Florida 6-2021 February 10, 2006 - “Mold: Are The New Policy Limitation Endorsements Working?” 7th Annual Windstorm Insurance Conference Sponsored by the Windstorm Insurance Network Orlando, Florida August 10, 2006 - “Making Insurance Claims With The Florida Insurance Guaranty Association (F.I.G.A.)” F.A.P.1.A. Summer Conference Sponsored by the Florida Association of Public Insurance Adjusters Tampa, Florida January 31, 2007 - “An Overview of Builder’s Risk Policies” 8th Annual Windstorm Insurance Conference Sponsored by the Windstorm Insurance Network Tampa, Florida March 29, 2007 - “Florida’s Insurer of Last Resort: The Trouble With Citizens” F.A.P.1.A. Winter Conference Sponsored by the Florida Association of Public Adjusters Orlando, Florida August 10, 2007 - “Florida’s Insurer of Last Resort, Citizens Property Insurance Corporation (Part II)” F.A.P.L.A. Summer Conference Sponsored by the Florida Association of Public Insurance Adjusters Captiva Island, Florida January 11, 2008 - “Pre-Suit Mediation of First Party Insurance Claims” F.A.P.I.A. Winter Conference Sponsored by the Florida Association of Public Insurance Adjusters Orlando, Florida March 10, 2008 - “Professionalism-Good for the Profession & Good for You” Hillsborough County Bar Association, Professional Conduct Section Tampa, Florida January 12, 2010 - “He Said, She Said & All The Letters in Between (Public Adjusters & Letter Writing 101)” F.A.P.I.A. Winter Conference Sponsored by the Florida Association of Public Insurance Adjusters Tampa, Florida January 26, 2010 - “Claims Handling Fundamentals — State Claims Handling Practices” 10th Annual Windstorm Insurance Conference Sponsored by the Windstorm Insurance Network Jacksonville, Florida 6-2021 June 28, 2010 - “Sinkholes — Florida’s Other Catastrophe” F.A.P.I.A. Summer Conference Sponsored by the Florida Association of Public Insurance Adjusters Ft. Lauderdale, Florida January 11, 2011 - “Avoiding the Fraudulent Policy Holder” F.A.P.I.A. Winter Conference Sponsored by the Florida Association of Public Insurance Adjusters Orlando, Florida February | & 2, 2012 - “Knowing Coverage and Policy Language” 13th Annual Windstorm Insurance Conference Sponsored by the Windstorm Insurance Network Orlando, Florida May 22, 2012 - “Public Adjusting 201-Law and Policy, Knowing Coverage and Policy Language” F.A.P.1.A. Spring Conference Sponsored by the Florida Association of Public Insurance Adjusters Kissimmee, Florida Jan 28 & 29, 2014 - “Myths and Legends in Property Adjusting” 15" Annual Windstorm Insurance Conference Sponsored by the Windstorm Insurance Network Orlando, Florida November 7, 2016 - “Current Issues Involving Anti-Assignment of Benefits Endorsement and Agreement Not to Use Public Adjusters in Lloyds of London Application” F.A.P.I.A. Fall Conference Sponsored by the Florida Association of Public Insurance Adjusters Orlando, Florida May 22, 2017 - “Timing is Everything- Documenting the Claim File” F.A.P.1.A 25" Anniversary Conference Sponsored by the Florida Association of Public Insurance Adjusters Hawks Cay Resort, Duck Key, Florida June 4, 2018 - “This Old House: Unique Considerations When Adjusting Damage to Old and Historic Homes” F.A.P.LA. Spring 2018 Conference Sponsored by the Florida Association of Public Adjusters Sanibel Harbour Resort and Spa, Ft. Myers, Florida October 27, 2018 - “Insurance Company Delay Tactics and How to Deal With Them” F.A.P.1.A Fall 2018 Conference Sponsored by the Florida Association of Public Adjusters Wyndham Grand Orlando Resort Bonnet Creek, Orlando, Florida 6-2021 October 27,2019 - “Duties After Loss — Is Everyone In Compliance?” F.A.P.1.A. Fall 2019 Conference Sponsored by the Florida Association of Public Adjusters Wyndham Grand Orlando Resort Bonnet Creek, Orlando, Florida December 7, 2020 - “Fire Claim Analysis ” F.A.P.I.A Virtual 2020 Conference Sponsored by the Florida Association of Public Adjusters Webinar Reported First Party Insurance Cases (Representative List): Florida Peninsula Insurance Company v Newlin, 2019 Fla. App. LEXIS 9152,*1, 2019 WL 2439375 (Fla.2"¢ DCA 2019) Hunt v State Farm Florida Ins, Co., 2013 WL 1352471 (Fla. 2" DCA 2013) Sunshine State Ins. Co. v. Benjamin, 100 So. 3" 90 (Fla. 2" DCA 2012) Jackson V Metropolitan Property and Casualty Insurance Co., 2007 W.L.2936213 (M.D. Fla.); 2008 W.L.58953 (M.D. Fla.); 2009 W.L.1456439 (M.D. Fla.) Goff v. State Farm Florida Ins. Co., 999 So.2d 684 (Fla. 2" DCA 2009) Wilson v. Federated Nat. Ins. Co., 969 So.2d 1133, (Fla. 2“ DCA 2007) Burnett v. Clarendon Select Ins. Co., 920 So.2d 188, (Fla. 2"! DCA 2006) Widdows v. State Farm Florida Ins. Co., 920 So.2d 149, (Fla. 5“ DCA 2006) General Star Indemnity. Co. v. West Florida Village Inn, Inc., 874 So.2d 26, (Fla. 2"4 DCA 2004) Lasman v. Freedom Life Ins. Co. of America, 862 So.2d 787, (Fla. 2" DCA 2003) Infinity Ins. Co. v. Berges, 806 So.2d 504, (Fla.2"4 DCA 2001) Dominion of Canada v. State Farm Fire and Casualty. Co., 754 So.2d 852, (Fla. 2" DCA 2000) Fireman's Fund Ins. Co. v. Signorelli, 681 So.2d 720, (Fla. 2"! DCA 1996) Ady v. American Honda Finance Corp., 675 So.2d 577, (Fla.1996) Russo v. Plant City Moose Lodge No. 1668, 656 So.2d 957, (Fla. 2" DCA 1995) Ady v. American Honda Finance Corp., 652 So.2d 415, (Fla. 2" DCA 1995) 6-2021 Exhibit B im DANAHY & MURRAY 901 West Swann Avenue Tampa, Florida 33606 (813) 258-3600 (phone) (813) 258-3321 (fax) www.danahyandmurray.com AUTHORITY TO REPRESENT u ct Me, , the undersigned Client(s) do(es) hereby retain and employ the law firm DANAHY & MURRAY, P.A. , (the Lawyers), to represent me/us in myh Pp damages, both contractual and extra-contractual, against ‘or any other Ins: urance Tt any 1 who is or may be liable for danfages an rence or loss on or about arising out of a claim or loss , upon the following terms 1, ATTORNEY'S FEE - In the event of a recovery of benefits from the ctient(s)’ insurer(s), their agents, tepresentatives and/or others, the client(s) agree(s) to pay the attomey’s fee to the Lawyers as outlined below: (a) 33.3% of the gross recovery, or Court Awarded Fees, whichever is greater for any damages recovered before or after a lawsuit is filed seeking contact damages or declaratory relief. (b) 40% of the gross recovery, or Court Awarded Fees, whichever is greater, for any damages recovered in a “bad faith” or extra contractual damages claim made following the resolution of contract damages owed or after a suit for bad faith or extra-contractual damages is filed. (b) Court Awarded Fees - If there is a Court Awarded Fee under Florida Statute §627.428, 624.155, or any other separately determined Court awarded fee, including fees that exceeds the amount the client(s) are obligated to pay as a contingency fee from the gross recovery, then the Lawyers will receive the amount so awarded by the Court. This Court awarded amount is in lieu of and shall not be added to the client(s)’ obligation to pay attorney's fees on a contingency fee basis. In the event a Court awarded fee Is less than the amount the client(s) is to pay as a contingency fee, then the difference between the Court awarded fee and the amount to be paid pursuant to the contingency fee provisions shall remain due from the client. Notwithstanding the percentages set forth above, if a statute, law or court rule requires a lesser fee, this contract shall be deemed amended to conform to such statute, law, or rule. The client(s) agree to preserve the right for the Lawyers to seek a fee award, and agree(s) that Lawyers are entitled to collect any amount awarded by the Court or paid by the Insurer as attomey's fees. The clients hereby assign Lawyers all rights to seek any awards of Lawyer's attomey's fees, and agree that any fee payment or court awarded fee/judgment may be made payable directly to Lawyers. it this ymen pon contingent fe nd ifno recovery mad th -AWYE or atto: 2. DEF IN ROSSRi - The contingencyfee to be paid to the Lawyerswill be calculated based on the “gross recovery” obtained in the case. “Gross Recovery” is the total amount recovered and actually received by, on behalf of, or for the benefit of the client(s), including amount recovered as interest. There is to be no deduction for costs or other expenses from the gross recovery in determining the amount of contingency atto: 's fee due. Any amounts paid to client(s) by the insurance company prior to the retention of the Lawyers is not included in the calculation of Gross Recovery. 3. ADVANCED COSTS - Client(s) understand(s) and acknowledge(s) that it will be necessary to incur costs in the prosecution of the claim and any related litigation. Client(s) expressly authorize(s) the Lawyers to incur and expend such costs as are reasenable and necessary. in the event of recovery, all such advanced costs are to be paid from the gross recovery after reduction by the amount of attomey’s fees due. OlvE"d TEEHBSSETST OL *WOad Te:9t Tte@2-8-aa4 Intl nt that no recovery i: ad,very is insufficient to full or the ay attomey’s fees and costs, then the client(s) shall have no further obligati o reimburse the L: for costs. Reim! ment of costs advanced by the Lawyers are contingent upon recovery. 4. ONSENT TO SETTLEMENT AND CONTROL 0! OF LITIGATION IN - Client(s) authorize(s) the Lawyers to bring those actions and causes of actions that they believe, in good faith, ought to be prosecute in order to assert the claims against any offending party, as may be applicable or appropriat te. The Client(s) retain(s) the right to ultimately decide whether a settlement should be accepted. Client(s), acknowledge(s) that the claims do, or may, carry a right to obtain a court awarded al ttomey’s fee based upon differing factors, including the attomeys’ hours spent prosecuting the claims. Further, a settlement offer inclusive of the attorney's fee claim may represent substantially more in attorney's fee payment that even client(s)’ claim on the merits, independent of attorney's fees. Client(s) agree to protect the Lawyers right to pursue court awarded fee when making any settlement decision. LIENTS’ RIGHT TO FIRE THE ERS Client(s) has/have the right to fire the Lawyers at any time, even without cause or justification. [If client fires the Lawyers, Client(s) agree(s) to pay the Lawyers the reasonable value of the Lawyers’ services and to promptly repay any costs or expenses advanced or incurred on behaff of client in the handling of this matter. 6. LAWYERS’ RIGHT TO WITHDRAW - The client(s) will cooperate with the Lawyers as they handle this case. ifthe Lawyers, for any reason, determine it is unfeasible for the Lawyerto continue representation, -- the-Lawyers-may cancel ‘the ‘contract and the Client(s) will not be obligated for legal fees, unless the cancellation is due to Client(s) failure to cooperate with the Lawyer's reasonable requests, or other good cause, in which case the Lawyers shall be entitled to a retaining lien and/or charging lien to recover fees and costs. 7. NATURE OF EMPLOYMENT - it is agreed and understood that this employment is limited to the First Party legal representation as identified in paragraph 1. This representation only applies to the named parties described on page one (1) and does not include any other legal work or advice, and specifically does not include tax advice, financial planning or investment planning. The client(s) assume(s) the responsibility of obtaining such tax or financial advice from other sources. 8. THE ENTIRE AGREEMENT - This Authority to Represent states the entire agreement between the Client(s) and the Lawyers and takes the place of any prior oral or written agreements. This Agreement is entered into and is to be performed within the State of Florida, and is to be interpreted in accordance with Florida law. The terms of this agreement may be changed only by a separate written agreement signed and dated by the Client(s) and the Lawyers. This contract may be cancelled by written notification to the Lawyers at any time within three (3) business days of the date the contract is signed, and if cancelled the client(s) shall not be obligated to pay any fees to the Lawyers. RECOVERY IS MADE, C! T(S) WILL NOT BE INDEBTED TO THE LAWYERS FOR ANY S' WHATSOEVER AS ATTORNEY’S FEES pate 2/S/A] La 2a Client Date: Client Date: 2121 2) CHL put Danahy + Murray Bt-b'd Tekeasee tet OL ?WOY4d 22:97 tea2-8-834 DANAHY —_—_—— DUNNAVANT INSURANCE CLAIM LAWYERS 901 WEST SWANN AVE. TELEPHONE (813) 906-1841 ‘WWW.DANDDLAW.COM TAMPA, FLORIDA 33606 FACSIMILE (813) 579-1912 AUTHORITY TO REPRESENT D ni: Furry, We, Denise Fur the undersigned Client(s) do(es) hereby retain and employ the law firm of DANAHY & DUNNAVANT, P.A., (the Lawyers), to represent us in our claim(s) for damages; both contractual and extra- contractual, against State Farm Florida Ins. Co or any other person, firm or corporation who is or may be liable for damages resulting from an occurrence or loss on or about November 11, 2020 arising from windstorm (loss), effective June 14, 2021 and retroactive to the date of the original contract with the predecessor firm Danahy & Murray PA, upon the following terms: 1. ATTORNEY'S FEE - In the event of a recovery of benefits from the client(s)’ insurer(s), their agents, representatives and/or others, the client(s) agree(s) to pay the attomey's fee to the Lawyers.as outlined below: (a) 33 1/3% of the gross recovery, or Court Awarded Fees, whichever is greater. (b) 40% of any claim for bad faith or extra contractual damages, or court awarded fees, whichever is greater, in the event of a separate bad faith or extra contractual claim Court Awarded Fees - If there is a Court Awarded Fee under Florida Statutes §627.428, §624.155, §626.9373 or any other separately determined Court awarded fee, including fees that exceeds the amount the client(s) are obligated to pay as a contingency fee from the gross recovery, then the Lawyers will receive the amount so awarded by the Court. This Court awarded amount is in lieu of and shall not be added to the client(s)' obligation to pay attorney's fees on a contingency fee basis. In the event a Court awarded fee is less than the amount the client(s) is to pay as a contingency fee, then the difference between the Court awarded fee and the amount to be paid pursuant to the contingency fee provisions shall remain due from the client. Notwithstanding the percentages set forth above, if a statute, law or court rule requires a lesser fee, this contract shall be deemed amended to conform to such statute, law, or rule. The client(s) agree to preserve the right for the Lawyers to seek a fee award and agree(s) that Lawyers are entitled to collect any amount awarded by the Court or paid by the Insurer as attorney's fees. The clients hereby assign Lawyers all rights to seek any awards of Lawyer's attorney's fees and agree that any fee payment or court awarded fee/judgment may be made payable directly to Lawyers. ind understood this m nt i upon co lingent e ba d if no recove Is mage he inde: ed ents will not be inde 9 the ers for attorn ey'sfe 2. DEFINTION oF cross RECOVERY - The contingency fee to be paid to the Lawyers will be calculated based on the “gross recovery” obtained in the case. “Gross Recovery” is the total amount recovered and actually received by, on behalf of, or for the benefit of the client(s), including amount recovered as interest. There is to be no deduction for costs or other expenses from the gross recovery in determining the amount of contingency attorney's fee due. Any amounts paid prior to client(s) retention of the Lawyers is not included in the calculation of gross recovery. 3. ADVANCED COSTS - Client(s) understand(s) and acknowledge(s) that it will be necessary to incur costs in the prosecution of the claim and any related litigation. Client(s) expressly authorize(s) the Lawyers 8 . to incur and expend such costs as are reasonable and necessary. In the event of recovery, all such advanced costs are to be paid from the gross recovery after reduction by the amount of attomey's fees due. In the even recovel is had, or the ré very is insufficient to f lorney's fe s and costs, then * client(s) further obli tion to imburse. ers for cost: t rsement of costs advani th ers are Int upon recov! 4. CONSENT TO SETTLEMENT AND CONTROL OF LITIGATION — Client(s) authorize(s) the Lawyers to bring those actions and causes of actions that they believe, in good faith, ought to be prosecute in order to assert the claims against any offending party, as may be applicable or appropriate. The Client(s) retain(s) the right to ultimately decide whether a settlement should be accepted. Client(s), acknowledge(s) that the claims do, or may, carry a right to obtain a court awarded attomey's fee based upon differing factors, including the attorneys’ hours spent prosecuting the claims. Further, a settlement offer inclusive of the attorney's fee claim may represent substantially more in attorney's fee payment that even client(s)’ claim on the merits, independent of attorney's fees. Client(s) agree to protect the Lawyers right to pursue court awarded fee when making any settlement decision. 5. CLIENTS’ RIGHT TO FIRE THE LAWYERS - Client(s) has/have the right to fire the Lawyers at any time, even without cause or justification. If client fires the Lawyers, Client(s) agree(s) to pay the Lawyers the reasonable value of the Lawyers’ services and to promptly repay any costs or expenses advanced or incurred on behalf of client in the handling of this matter. 6. LAWYERS’ RIGHT TO WITHDRAW - The client(s) will cooperate with the Lawyers as they handle this case. If the Lawyers, for any reason, determine it is unfeasible for the Lawyer to continue representation, the Lawyers may cancel the contract and the Client(s) will not be obligated for legal fees, unless the cancellation is due to Client(s) failure to cooperate with the Lawyer's reasonable requests, or other good cause, in which case the Lawyers shall be entitled to a retaining lien and/or charging lien to recover fees and costs. 7. NATURE OF EMPLOYMENT - It is agreed and understood that this employment is limited to the First Party legal representation as identified in paragraph 1. This representation only applies to the named parties described on page one (1) and does not include any other legal work or advice, and specifically does not include tax advice, financial planning or investment planning. The client(s) assume(s) the responsibility of obtaining such tax or financial advice from other sources. 8. THE ENTIRE AGREEMENT - This Authority to Represent states the entire agreement between the Client(s) and the Lawyers and takes the place of any prior oral or written agreements. This Agreement is entered into and is to be performed within the State of Florida and is to be interpreted in accordance with Florida law. ‘Thé termsof this agreement may be changed only by a separate written agreement signed and dated by the Client(s) and the Lawyers. This contract may be cancelled by written notification to the Lawyers any time within three (3) business days of the date the contract is signed, and if cancelled the client(s) shall not be obligated to pay any fees. u IF RECOVE! LIENT(S) WILL NOT BI IDEBTED TO THE LAWYERS IR ANY SUM WHATSOEVER AS ATTORNEY'S FEES OR COSTS Date: a/ (2z. By: leews Jury Client Date: 2/ 7 | Ve By:. LO lm Danahy & Dunnavant, PA. Exhibit C Summary of Claimed Time Time |Records | from Feb 9, 2021 to Present D&M Billable Non-billable Fees D&D Billable Non-billable |Fees MRD 9.6) 4.1] $6,720.00 MRD 9.6) 2.4| $6,720.00 ED 0 0 $0.00 ED 1.6) 0 $800.00 KLA 1,7 29 $765.00 KLA 0 $0.00 cD 47 0 $728.50 cD 9.2) O| $1,426.00 JT 0 0 $0.00 JT 1.8) 0 $270.00 Totals 16} 7|_ $8,213.50 Totals 22.2) 2.4| $9,216.00 Totals Billable Non-billable Fees MRD 19.2 6.5] $13,440.00 Total Time 47.6 ED 1.6 0 $800.00 Total Bill 38.2 KLA 17 2.9 $765.00 Total Non 9.4 cD 13.9 O} $2,154.50 Total Fees $17,429.50 JT 18 oO $270.00 Totals 38.2] 9.4] $17,429.50 Danahy & Murray, PA. 901 West Swann Avenue Tampa, FL 33606 Ph:813-258-3600 Fax:813-258-3321 Denise Furry December 8, 2021 PO Box 381032 Murdock, FL 33938 File #: Furry Attention: Inv #: Sample RE: Furry vs State Farm DATE DESCRIPTION HOURS AMOUNT LAWYER Jan-12-21 Phone call with public adjuster Bill Kovacik 0.50 350.00 MRD regarding claim and possible Civil Remedy Notice Prepare e-mail to public adjuster with Civil 0.10 70.00 MRD Remedy Notice checklist Jan-15-21 Receipt of documents for Civil Remedy Notice 0.40 280.00 MRD from public adjuster Phone call with public adjuster regarding 0.50 350.00 MRD details of claim Jan-19-21 Review and revise draft Civil Remedy Notice 0.40 280.00 MRD of Insurer Violation and letter to potential new client (drafted by KLA) Jan-21-21 Call with Bill Kovacik regarding Civil 0.20 140.00 MRD Remedy Notice of Insurer Violation Phone call with potential new client regarding 0.60 420.00 claim / Civil Remedy Notice of Insurer Violation Jan-22-21 Receipt and review authorization to file Civil 0.10 70.00 MRD Remedy Notice of Insurer Violation Receipt and review of Proof of loss drafted by 0.10 70.00 MRD public adjuster Invoice #: Sample Page 2 December 8, 2021 Exchange e-mails with KLA regarding 0.10 70.00 MRD revisions to Civil Remedy Notice of Insurer Violation Receipt of call from public adjuster 0.10 70.00 MRD Feb-04-21 Send new Client documents to Denise Furry 0.20 140.00 MRD with e-mail DESC ONLY - Receipt of e-mail / letter from 0.10 NIC MRD State Farm DESC ONLY - Prepare e-mail to potential new 0.10 N/C MRD client and public adjuster DESC ONLY - Phone conference with 0.20 N/C MRD potential new client and public adjuster regarding representation Feb-08-21 Call from potential new client to discuss 0.40 280.00 MRD representation Feb-09-21 Receipt of new client documents from Client 0.20 140.00 MRD Receipt of public adjuster file materials and 0.20 140.00 MRD review same with e-mail of 2/9 drafted complaint for breach of contract 1.20 0.00 KLA Feb-10-21 drafted b6 notice and schedules 0.20 0.00 drafted first request for production to 0.30 0.00 KLA defendant drafted first interrogatories to state farm 0.40 0.00 KLA drafted first request for admissions to state 0.40 0.00 KLA farm drafted antispoliation letter 0.20 0.00 KLA drafted client complaint letter 0.10 0.00 KLA drafted summons and civil cover sheet 0.10 0.00 KLA final review and revisions to complaint 0.20 90.00 KLA Invoice #: Sample Page 3 December 8, 2021 Feb-11-21 Review and revise complaint and exhibits 0.80 560.00 MRD Review and revise discovery to State Farm 0.80 560.00 MRD (Request for Production / RA's / Interrogs) Review letter to adjuster and B6 Notice 0.20 140.00 MRD Feb-12-21 Receipt of certified policy from State Farm 0.20 140.00 MRD adjuster Feb-15-21 Exchange e-mails with Client regarding e-mail 0.10 70.00 MRD from State Farm she received on 2/10 Feb-17-21 Brief initial review of summons issued by 0.10 15.50 CBD clerk Research county court procedures in Charlotte 0.20 31.00 CBD county to determine if service of Standing Order in Civil Cases required for county Civil Cases Feb-18-21 Receipt of 2/17 email from State Farm 0.10 70.00 MRD attorney Jay Green requesting public adjuster respond to his 2/11 letter seeking reinspection Prepare email in response to SF attorney 0.30 210.00 MRD Phone conference with Bill Kovacik regarding 0.20 140.00 MRD State Farm letter and response Brief initial review of letter and email from 0.10 15.50 CBD opposing counsel providing 2/11/21 letter acknowledging dispute Telephone call with Public Adjuster regarding 0.10 15.50 CBD email from opposing counsel providing 2/11/21 letter acknowledging dispute Feb-22-21 Receipt of Service of Process Fee 0.10 70.00 MRD