On April 28, 2023 a
Party Statement
was filed
involving a dispute between
Us Bank Trust National Associa,
and
Town Of White Springs Florida,
Unknown Spouse Of Bernard L Wi,
Unknown Spouse Of Ruby T Willi,
Unknown Tenant 1,
Unknown Tenant 2,
Williams, Bernard L,
Williams, Ruby T,
for Circuit Civil 3-C
in the District Court of Hamilton County.
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Filing “gigdihigdiy E-Filed 12/12/2023 11:30:19 AM
IN THE CIRCUIT COURT OF THE THIRD JUDICIAL CIRCUIT
EN AND FOR HAMILTON COUNTY FLORIDA
U.S. BANK TRUST NATI JNAL CIRCUIT CIVIL DIVISION
AS OCIATION, AS TR POR LB-
DWELLING SERIES V TRUS CASE NO.: 2023-CA-000041
Plaintiff,
Vv
RUBY T. WILLIAMS, et al
Defendant.
AFFIDAVIT AS TO REASONABLE ATTORNEY’S FEES
BEFORE ME, the undersigned authority, personally appeared Drew Beinhaker,
being duly sworn, deposes and says:
ey PeInnaner. Esq... who
i Fam an attorney licensed to practice inthe State of Florida and I have practic
ed law
in Broward County, Florida for more than fifteen (15) years.
3{ have reviewed the Affidavit of Attorney's Fees and Costs of Plaintiff's counsel.
HOWARD 1 AW, prepared for this tion. | have also reviewed the nature of the action, the
amount of work involved resulting in the services rendered to date and
still to be performed and,
the years of experience of counsel assigned to this litigation, togethe
r with the ave rage rates in the
community for same. Additionally, | have conferred as needed with PI aintiff
s counsel regarding
the services rendered.
3 In light of the foregoing, and sy pecifically taking into consideration the
factors set
forth in Rule 4-1.5 of the Rules Regul ating the Florida Bar and
the criteria discussed by the Florida
Supreme Court in Morita Putient’s Compensation Fund y.
1 ena Rowe, 472 So.2d 1145 (Fla.
1985), including without limitation the time spent by Ph
aintil’s counsel in th ction, itis my
opinion that the total fee of $4,750.00 is a re nable attorney’s fee for the services rendered and
presently anticipated to be rendered in thi tion by Plaintiff's counsel with respect to time
devoted to routine, non-contested portions of this action and
$5,220.00, which consists of 17.40
hours at a rate of $300.00 per hour, is a reasonable attorn
ey fee for the services rendered to the
time devoted to non outine and/or contested portions of tt his action,
making the resulting total fee
of $9,978.00 a reasonable attorney's fee for the services of Plaint
iffs counsel in this action..
4 { have evaluated the factors checked bel ow in determining my opinion of a
reasonable attorney's fee as stated above:
x
ae a, The time and labor required, the novel ty, complexi
ty and difficulty of the
questions involved, and the skill req uisite to
perform the legal service
properly.
Electronically Filed Hamilton Case # 23000041CAAXMX 12/12/2023 11:30:19 AM
CASE NO. 2023-CA-000041
wathx b The likelihood that the acceptance of the particular employment will
preclude other employment by the lawyer.
he f ind/or rate of fee, customarily charged in this locality for legal
sof a comparable or a similar nature.
d The significance of. or amount involved in. the subject matter of the
representation. the responsibility involved in the representation, and the
results obtained.
The time limitations imposed by the client or by the circumstances and, as
between attorney and client. any additional or special time demands or
requests of the attorney by the client
The nature and length of the professional relationship between said counsel
and the client
x
£h. 8 The experience. reputation, diligence and ability of Plaintiff's attorney and
the skill, expertise. of efficiency of effort reflected in the actual providing
of such services.
x h The fact that the fee is fixed and not contingent and the fact that the client’s
ability to pay did not rest io any significant degree on the outcome of the
representation
FURTHER AFT ANT SAYETH NAUGHI
eo
Dr Beinhaker
lorida Bar N 1635 38
STATE OF FLORIDA
COUNTY OF BROWARD }ss.
The foregoing instrument was acknow ledged before me by means of O]
phy al presence
or (2 online notarization, this _ day of December, 2023 by Drew Beinhalager. Sq.. who is
personally known to me or who has produced as identification
NO AR PUBLIC IDA
aR
HAWANTIE SHAMKARRAN
we: Commission
# HH 405404
Expires August 7, 2027
Me ae ne
Printed Name
CASE NO.: 2023-CA-000041
CERTIFICATE OF SERVICE
1 HEREBY CERTIFY thai a true and correct copy of the foregoing was furnished via
U.S. Mail or E-Mail to those parties listed below on this 12th — day of DEC v MBER 2023:
John Lara, F'sq.. Kyle & Kyle L AWW
E-Mail: jo Ky . rebecca. bonnett@kyleandkylelaw.com
Counsel for Di endant. Rub Williams
Town of White Springs, Florida
c/o of any officer or person authorized to accept service
10363 Bridge St
White Springs, PL 32096
Unknown Tenant 4) N/K/A Nicole Williams
16797 Mills Street
White Springs. FL 32096
HOWARD LAW
4755 Technology Way. Suite # 104
Boca Raton, FL 33431
Telephone: (954) 893-7874
Service: Pleadings’
sec JowardLaw.com
oa COM
By iS} uy ,. Macias
Anya E. Macias, Esq.
Florida Bar No.: 0458600
Anya@ HowardLaw.com
3
Document Filed Date
December 12, 2023
Case Filing Date
April 28, 2023
Category
Circuit Civil 3-C
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Filing “gigdihigdiy E-Filed 12/12/2023 11:30:19 AM IN THE CIRCUIT COURT OF THE THIRD JUDICIAL CIRCUIT EN AND FOR HAMILTON COUNTY FLORIDA U.S. BANK TRUST NATI JNAL CIRCUIT CIVIL DIVISION AS OCIATION, AS TR POR LB- DWELLING SERIES V TRUS CASE NO.: 2023-CA-000041 Plaintiff, Vv RUBY T. WILLIAMS, et al Defendant. AFFIDAVIT AS TO REASONABLE ATTORNEY’S FEES BEFORE ME, the undersigned authority, personally appeared Drew Beinhaker, being duly sworn, deposes and says: ey PeInnaner. Esq... who i Fam an attorney licensed to practice inthe State of Florida and I have practic ed law in Broward County, Florida for more than fifteen (15) years. 3{ have reviewed the Affidavit of Attorney's Fees and Costs of Plaintiff's counsel. HOWARD 1 AW, prepared for this tion. | have also reviewed the nature of the action, the amount of work involved resulting in the services rendered to date and still to be performed and, the years of experience of counsel assigned to this litigation, togethe r with the ave rage rates in the community for same. Additionally, | have conferred as needed with PI aintiff s counsel regarding the services rendered. 3 In light of the foregoing, and sy pecifically taking into consideration the factors set forth in Rule 4-1.5 of the Rules Regul ating the Florida Bar and the criteria discussed by the Florida Supreme Court in Morita Putient’s Compensation Fund y. 1 ena Rowe, 472 So.2d 1145 (Fla. 1985), including without limitation the time spent by Ph aintil’s counsel in th ction, itis my opinion that the total fee of $4,750.00 is a re nable attorney’s fee for the services rendered and presently anticipated to be rendered in thi tion by Plaintiff's counsel with respect to time devoted to routine, non-contested portions of this action and $5,220.00, which consists of 17.40 hours at a rate of $300.00 per hour, is a reasonable attorn ey fee for the services rendered to the time devoted to non outine and/or contested portions of tt his action, making the resulting total fee of $9,978.00 a reasonable attorney's fee for the services of Plaint iffs counsel in this action.. 4 { have evaluated the factors checked bel ow in determining my opinion of a reasonable attorney's fee as stated above: x ae a, The time and labor required, the novel ty, complexi ty and difficulty of the questions involved, and the skill req uisite to perform the legal service properly. Electronically Filed Hamilton Case # 23000041CAAXMX 12/12/2023 11:30:19 AM CASE NO. 2023-CA-000041 wathx b The likelihood that the acceptance of the particular employment will preclude other employment by the lawyer. he f ind/or rate of fee, customarily charged in this locality for legal sof a comparable or a similar nature. d The significance of. or amount involved in. the subject matter of the representation. the responsibility involved in the representation, and the results obtained. The time limitations imposed by the client or by the circumstances and, as between attorney and client. any additional or special time demands or requests of the attorney by the client The nature and length of the professional relationship between said counsel and the client x £h. 8 The experience. reputation, diligence and ability of Plaintiff's attorney and the skill, expertise. of efficiency of effort reflected in the actual providing of such services. x h The fact that the fee is fixed and not contingent and the fact that the client’s ability to pay did not rest io any significant degree on the outcome of the representation FURTHER AFT ANT SAYETH NAUGHI eo Dr Beinhaker lorida Bar N 1635 38 STATE OF FLORIDA COUNTY OF BROWARD }ss. The foregoing instrument was acknow ledged before me by means of O] phy al presence or (2 online notarization, this _ day of December, 2023 by Drew Beinhalager. Sq.. who is personally known to me or who has produced as identification NO AR PUBLIC IDA aR HAWANTIE SHAMKARRAN we: Commission # HH 405404 Expires August 7, 2027 Me ae ne Printed Name CASE NO.: 2023-CA-000041 CERTIFICATE OF SERVICE 1 HEREBY CERTIFY thai a true and correct copy of the foregoing was furnished via U.S. Mail or E-Mail to those parties listed below on this 12th — day of DEC v MBER 2023: John Lara, F'sq.. Kyle & Kyle L AWW E-Mail: jo Ky . rebecca. bonnett@kyleandkylelaw.com Counsel for Di endant. Rub Williams Town of White Springs, Florida c/o of any officer or person authorized to accept service 10363 Bridge St White Springs, PL 32096 Unknown Tenant 4) N/K/A Nicole Williams 16797 Mills Street White Springs. FL 32096 HOWARD LAW 4755 Technology Way. Suite # 104 Boca Raton, FL 33431 Telephone: (954) 893-7874 Service: Pleadings’ sec JowardLaw.com oa COM By iS} uy ,. Macias Anya E. Macias, Esq. Florida Bar No.: 0458600 Anya@ HowardLaw.com 3