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Filing# 138916281 E-Filed 11/19/2021 03:42:40 PM
IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT
IN AND FOR CHARLOTTE COUNTY, FLORIDA
PENTAGON FEDERAL CREDIT UNION, CASE NO.: 20000862CA
Plaintiff,
VS.
UNKNOWN HEIRS, BENEFICIARIES,
DEVISEES, SURVIVING SPOUSE, GRANTEES,
ASSIGNEE, LIENORS, CREDITORS,
TRUSTEES, AND ALL OTHER PARTIES
CLAIMING AN INTEREST BY THROUGH
UNDER OR AGAINST THE ESTATE OF SAIMA
M. KELLEY, DECEASED; et al.,
Defendant(s).
/
NOTICE OF FILING AFFIDAVIT IN SUPPORT OF PLAINTIFF’S ATTORNEY’S FEES
Plaintiff, PENTAGON FEDERAL CREDIT UNION, by and through undersigned counsel, hereby
gives Notice of Filing the following items:
1.) AFFIDAVIT IN SUPPORT OF PLAINTIFF’S ATTORNEY’S FEES
CERTIFICATE OF SERVICE
1 HEREBY CERTIFY that a true and correct copy of the foregoing was provided via E-Mail or
Regular U.S. Mail to the parties listed on the service list on this 19 _ day of _ November 2021.
ALDRIDGE PITE, LLP
Attorney for Plaintiff
1615 South Congress Avenue
Suite 200
Delray Beach, FL 33445
Telephone: 561-392-6391
Facsimile: 561-392-6965
Digitally signed by
Zachary Ullman
Date: 2021-11-19 08:40:
By: 1
FBN: 106751
Primary E-Mail:ServiceMail@aldridgepite.com
Secondary E-Mail: edubreucq@aldridgepite.com
1634-014B
SERVICE LIS’
UNKNOWN HEIRS, BENEFICIARIES, DEVISEES, SURVIVING SPOUSE, GRANTEES, ASSIGNEE,
LIENORS, CREDITORS, TRUSTEES, AND ALL OTHER PARTIES CLAIMING AN INTEREST BY
THROUGH UNDER OR AGAINST THE ESTATE OF SAIMA M. KELLEY, DECEASED
1050 Yarmouth Street
Port Charlotte, FL 33952
Unknown tenant #1 N/K/A Aaron Kelley
1050 Yarmouth Street
Port Charlotte, FL 33952
Jennifer Day a/k/a Jennifer Kelley
3023 Daffodil Terrace
Punta Gorda, FL 33983
1634-014B
IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN
AND FOR CHARLOTTE COUNTY, FLORIDA
PENTAGON FEDERAL CREDIT UNION, CASE NO.: 20000862CA
Plaintiff,
VS.
UNKNOWN HEIRS, BENEFICIARIES,
DEVISEES, SURVIVING SPOUSE, GRANTEES,
ASSIGNEE, LIENORS, CREDITORS,
TRUSTEES, AND ALL OTHER PARTIES
CLAIMING AN INTEREST BY THROUGH
UNDER OR AGAINST THE ESTATE OF SAIMA.
M. KELLEY, DECEASED; et al.,
Defendant(s).
/
SUPPORTING AFFIDAVIT AS TO ATTORNEY’S FEES
STATE OF FLORIDA
COUNTY OF PALM BEACH
BEFORE ME, the undersigned authority, duly authorized to administer, personally appeared Jodi
Michelle Fox, who after being first duly acknowledge says as follows:
1 Tam an attorney licensed to practice law in the State of Florida, a member in good standing of The
Florida Bar. I have been practicing law in the State of Florida since (PAYana lam admitted to
practice in the State of Florida.
Thave experience in foreclosures of mortgages and notes and am familiar with the reasonable and
customary attorney’s fees charged and allowed by the Court for attorney’s fees in such actions.
lam not affiliated with ALDRIDGE PITE, LLP, and have no interest in the outcome of this matter.
Based upon my experience in handling similar actions, I believe the sum of $5,825.00 would be a
reasonable attorney’s fee to be allowed Plaintiffs attorney for the uncontested cases, as well as
hourly fees when responsive pleadings are filed, due to the amount of time expended in the
prosecution of the lawsuit.
1634-014B
5 Iam also familiar with and have considered the dictates of the Florida Supreme Court in the case
of Florida Patient's Compensation Fund v. Rowe, 472 So.2d 1145 (Fla. 1985) for the determination
of reasonable attorney’s fees.
6. Ihave reviewed the docket in this matter. Based upon my experience in handling similar actions
I believe
$4,100.00 Flat Rate Fee on behalf of Plaintiff for the prosecution of this action.
$1,725.00 Additional Attorney Fees for the prosecution of this action
The combined total of $5,825.00 is a reasonable attorney’s fee to be awarded to the Plaintiff's
counsel for the prosecution of this action.
FURTHER AFFIANT SAYETH NAUGHT.
Jodi Michelle Fox
FBN: 24872
Date: tf fuel uf.
STATE OF FLORIDA
COUNTY OF PALM BEACH
Sworn to and qubsoribed
Jodi M. Fox
before me this IR day of
, who is personally known to me,
Nwonloey, 262), by
lotary Public
My Commission Expires
State of Florida
eli,
Kin,
Sy PU
mit
WM 44anie
ae OF FYawe
we
1634-014B
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Filing# 138916281 E-Filed 11/19/2021 03:42:40 PM IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA PENTAGON FEDERAL CREDIT UNION, CASE NO.: 20000862CA Plaintiff, VS. UNKNOWN HEIRS, BENEFICIARIES, DEVISEES, SURVIVING SPOUSE, GRANTEES, ASSIGNEE, LIENORS, CREDITORS, TRUSTEES, AND ALL OTHER PARTIES CLAIMING AN INTEREST BY THROUGH UNDER OR AGAINST THE ESTATE OF SAIMA M. KELLEY, DECEASED; et al., Defendant(s). / NOTICE OF FILING AFFIDAVIT IN SUPPORT OF PLAINTIFF’S ATTORNEY’S FEES Plaintiff, PENTAGON FEDERAL CREDIT UNION, by and through undersigned counsel, hereby gives Notice of Filing the following items: 1.) AFFIDAVIT IN SUPPORT OF PLAINTIFF’S ATTORNEY’S FEES CERTIFICATE OF SERVICE 1 HEREBY CERTIFY that a true and correct copy of the foregoing was provided via E-Mail or Regular U.S. Mail to the parties listed on the service list on this 19 _ day of _ November 2021. ALDRIDGE PITE, LLP Attorney for Plaintiff 1615 South Congress Avenue Suite 200 Delray Beach, FL 33445 Telephone: 561-392-6391 Facsimile: 561-392-6965 Digitally signed by Zachary Ullman Date: 2021-11-19 08:40: By: 1 FBN: 106751 Primary E-Mail:ServiceMail@aldridgepite.com Secondary E-Mail: edubreucq@aldridgepite.com 1634-014B SERVICE LIS’ UNKNOWN HEIRS, BENEFICIARIES, DEVISEES, SURVIVING SPOUSE, GRANTEES, ASSIGNEE, LIENORS, CREDITORS, TRUSTEES, AND ALL OTHER PARTIES CLAIMING AN INTEREST BY THROUGH UNDER OR AGAINST THE ESTATE OF SAIMA M. KELLEY, DECEASED 1050 Yarmouth Street Port Charlotte, FL 33952 Unknown tenant #1 N/K/A Aaron Kelley 1050 Yarmouth Street Port Charlotte, FL 33952 Jennifer Day a/k/a Jennifer Kelley 3023 Daffodil Terrace Punta Gorda, FL 33983 1634-014B IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA PENTAGON FEDERAL CREDIT UNION, CASE NO.: 20000862CA Plaintiff, VS. UNKNOWN HEIRS, BENEFICIARIES, DEVISEES, SURVIVING SPOUSE, GRANTEES, ASSIGNEE, LIENORS, CREDITORS, TRUSTEES, AND ALL OTHER PARTIES CLAIMING AN INTEREST BY THROUGH UNDER OR AGAINST THE ESTATE OF SAIMA. M. KELLEY, DECEASED; et al., Defendant(s). / SUPPORTING AFFIDAVIT AS TO ATTORNEY’S FEES STATE OF FLORIDA COUNTY OF PALM BEACH BEFORE ME, the undersigned authority, duly authorized to administer, personally appeared Jodi Michelle Fox, who after being first duly acknowledge says as follows: 1 Tam an attorney licensed to practice law in the State of Florida, a member in good standing of The Florida Bar. I have been practicing law in the State of Florida since (PAYana lam admitted to practice in the State of Florida. Thave experience in foreclosures of mortgages and notes and am familiar with the reasonable and customary attorney’s fees charged and allowed by the Court for attorney’s fees in such actions. lam not affiliated with ALDRIDGE PITE, LLP, and have no interest in the outcome of this matter. Based upon my experience in handling similar actions, I believe the sum of $5,825.00 would be a reasonable attorney’s fee to be allowed Plaintiffs attorney for the uncontested cases, as well as hourly fees when responsive pleadings are filed, due to the amount of time expended in the prosecution of the lawsuit. 1634-014B 5 Iam also familiar with and have considered the dictates of the Florida Supreme Court in the case of Florida Patient's Compensation Fund v. Rowe, 472 So.2d 1145 (Fla. 1985) for the determination of reasonable attorney’s fees. 6. Ihave reviewed the docket in this matter. Based upon my experience in handling similar actions I believe $4,100.00 Flat Rate Fee on behalf of Plaintiff for the prosecution of this action. $1,725.00 Additional Attorney Fees for the prosecution of this action The combined total of $5,825.00 is a reasonable attorney’s fee to be awarded to the Plaintiff's counsel for the prosecution of this action. FURTHER AFFIANT SAYETH NAUGHT. Jodi Michelle Fox FBN: 24872 Date: tf fuel uf. STATE OF FLORIDA COUNTY OF PALM BEACH Sworn to and qubsoribed Jodi M. Fox before me this IR day of , who is personally known to me, Nwonloey, 262), by lotary Public My Commission Expires State of Florida eli, Kin, Sy PU mit WM 44anie ae OF FYawe we 1634-014B