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Filing # 137853911 E-Filed 11/03/2021 04:46:28 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 OF ATTORNEY FEES AND COSTS,
Plaintiff, PENTAGON FEDERAL CREDIT UNION, by and through undersigned counsel, hereby
gives Notice of Filing the following items:
1.) AFFIDAVIT OF ATTORNEY FEES AND COSTS
CERTIFICATE OF SERVICE
I 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 2 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: 2021-11-02 16:25:17
By:
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).
/
AFFIDAVIT OF ATTORNEY FEES AND COSTS
STATE OF FLORIDA
COUNTY OF PALM BEACH}
Before me this day personally appeared New R. scola FGtho, being first duly
sworn deposes and states: FBN 44927
1 Jam an attorney with ALDRIDGE PITE, LLP which has a fee agreement entitling it to attorney’s fees and
reimbursement of costs related to representing the Plaintiff in this action.
2. As the attorney for Plaintiff in this action, I have full knowledge of the proceedings herein and the
attorney’s fees and costs expended by or on behalf of the Plaintiff.
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.
Iam 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.
Foreclosure Fees
Therefore, A ffiant requests the sum of $4,100.00 on behalf of the Plaintiff for the flat rate attorney’s fee
for prosecution of this action.
Additional Fees
The A ffiant requests additional fees in the sum of $1,725.00 for services performed by ALDRIDGE PITE,
LLP, for the handling of this action on behalf of the Plaintiff as it relates to the following:
A flat rate of $75.00 for services rendered relating to the Certificate Fee
A flat rate of $350.00 for services rendered relating to the Motion to Appoint Guardian Ad Litem.
A flat rate of $350.00 for services rendered relating hearing on 5/26/2021 on Motion to Appoint
Guardian Ad Litem.
A flat rate of $350.00 for services rendered relating to the Amended Complaint
1634-014B
A flat rate of $350.00 for services rendered relating to the Motion for Leave to Amend
A flat rate of $250.00 for services rendered relating to the Fee for Completion of Amended Service.
TOTAL ATTORNEYS’ FEES $5,825.00
The costs expended by the Plaintiff in this action are as follows:
First Class Mail $0.50
Full Title Report $250.00
Complaint Filing $400.00
eFiling Service Fee $5.00
Lis Pendens $5.00
Summons $20.00
Title Report Update $45.00
Service of Process $522.25
First Class Mail $1.40
FedEx Mail $13.61
Publication for Service $145.00
First Class Mail $1.42
First Class Mail $2.13
First Class Mail $0.51
First Class Mail $1.40
Guardian Ad Litem $550.00
Service of Process $226.30
Fee paid to court for Sale $140.00
TOTAL COSTS: $2,329.52
ALDRIDGE PITE, LLP
Attomey for Plaintiff
1615 South Congress Avenue
Suite 200
Delray Beach, FL 33445
Telephone: 561-392-6391
“Ce
Facsimile; 56 12 -6965 -
Andrew R. Scol ar
FB
poNe
FBN 44927
tifa pee
Primary E-Mail:ServjceMail@aldridgepite.com
Date:
STATE OF FLORIDA
COUNTY OF PALM BEACH }
SUBSCRIBED AND SWORN before me this Zz’ day of , 2021,
(
Aacren
Re Sealand
‘affiant). The undersigned notary public specifies that affiant’s signature
t the affiant personally appeared before the notary public at the time of
PENA D personally known.
<\ PRYExpires UY, hu,
\ Waa, My
My Commission Expires =
FS 9° sacs i OF Public
fate of Florida
Jessica Mendez
1634-014B My Sommssion #
iB, HH 144418 XE
“ARCineof Fu
aisws
we -
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Filing # 137853911 E-Filed 11/03/2021 04:46:28 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 OF ATTORNEY FEES AND COSTS, Plaintiff, PENTAGON FEDERAL CREDIT UNION, by and through undersigned counsel, hereby gives Notice of Filing the following items: 1.) AFFIDAVIT OF ATTORNEY FEES AND COSTS CERTIFICATE OF SERVICE I 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 2 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: 2021-11-02 16:25:17 By: 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). / AFFIDAVIT OF ATTORNEY FEES AND COSTS STATE OF FLORIDA COUNTY OF PALM BEACH} Before me this day personally appeared New R. scola FGtho, being first duly sworn deposes and states: FBN 44927 1 Jam an attorney with ALDRIDGE PITE, LLP which has a fee agreement entitling it to attorney’s fees and reimbursement of costs related to representing the Plaintiff in this action. 2. As the attorney for Plaintiff in this action, I have full knowledge of the proceedings herein and the attorney’s fees and costs expended by or on behalf of the Plaintiff. 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. Iam 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. Foreclosure Fees Therefore, A ffiant requests the sum of $4,100.00 on behalf of the Plaintiff for the flat rate attorney’s fee for prosecution of this action. Additional Fees The A ffiant requests additional fees in the sum of $1,725.00 for services performed by ALDRIDGE PITE, LLP, for the handling of this action on behalf of the Plaintiff as it relates to the following: A flat rate of $75.00 for services rendered relating to the Certificate Fee A flat rate of $350.00 for services rendered relating to the Motion to Appoint Guardian Ad Litem. A flat rate of $350.00 for services rendered relating hearing on 5/26/2021 on Motion to Appoint Guardian Ad Litem. A flat rate of $350.00 for services rendered relating to the Amended Complaint 1634-014B A flat rate of $350.00 for services rendered relating to the Motion for Leave to Amend A flat rate of $250.00 for services rendered relating to the Fee for Completion of Amended Service. TOTAL ATTORNEYS’ FEES $5,825.00 The costs expended by the Plaintiff in this action are as follows: First Class Mail $0.50 Full Title Report $250.00 Complaint Filing $400.00 eFiling Service Fee $5.00 Lis Pendens $5.00 Summons $20.00 Title Report Update $45.00 Service of Process $522.25 First Class Mail $1.40 FedEx Mail $13.61 Publication for Service $145.00 First Class Mail $1.42 First Class Mail $2.13 First Class Mail $0.51 First Class Mail $1.40 Guardian Ad Litem $550.00 Service of Process $226.30 Fee paid to court for Sale $140.00 TOTAL COSTS: $2,329.52 ALDRIDGE PITE, LLP Attomey for Plaintiff 1615 South Congress Avenue Suite 200 Delray Beach, FL 33445 Telephone: 561-392-6391 “Ce Facsimile; 56 12 -6965 - Andrew R. Scol ar FB poNe FBN 44927 tifa pee Primary E-Mail:ServjceMail@aldridgepite.com Date: STATE OF FLORIDA COUNTY OF PALM BEACH } SUBSCRIBED AND SWORN before me this Zz’ day of , 2021, ( Aacren Re Sealand ‘affiant). The undersigned notary public specifies that affiant’s signature t the affiant personally appeared before the notary public at the time of PENA D personally known. <\ PRYExpires UY, hu, \ Waa, My My Commission Expires = FS 9° sacs i OF Public fate of Florida Jessica Mendez 1634-014B My Sommssion # iB, HH 144418 XE “ARCineof Fu aisws we -