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Filing # 186553587 E-Filed 11/20/2023 07:44:31 PM
IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT
IN AND FOR OSCEOLA COUNTY, FLORIDA
CIVIL ACTION
WELLS FARGO BANK, N.A,
Plaintiff,
CASE NO: 2023 CA 003228 MF
vs. DIVISION: 39
RAMON CARTAGENA, et al,
Defendant(s).
AFFIDAVIT OF ATTORNEY FEES AND COSTS
STATE OF FLORIDA
COUNTY OF HILLSBOROUGH
ON THIS DATE, before me, the undersigned authority, personally appeared the below
affiant, who upon being duly sworn, deposes and says as follows:
1 Jam over the age of 21 and have personal knowledge of the matters set forth herein. Jam
an attorney with the law firm of Albertelli Law (the “Firm”) and represent our client in the above-referenced
foreclosure action. As an attorney handling the day-to-day matters of this case, I am familiar with the
services rendered and all costs and expenses incurred on behalf of our client in prosecuting this action.
2. The Firm has provided or may provide some or all of the following attorney services on a
flat fee basis, for which time records have not been kept:
a. Review documents and information received from client
b. Review title search and/or reports from the title examiner to determine list of
Defendants, potential interests, and addresses for service
c. Preparation of Lis Pendens, Complaint, Summons, Civil Cover Sheet, and other
documents necessary to effectuate service of process
d, Review of title update and/or report from title examiner
¢. Review and preparation of affidavit of military service
f. Review of service returns
& Review of Answers, Preparation of Motions to Default, and Notice of Dropping
Parties
h Preparation for Foreclosure Sale, including Notice of Sale, Proof of Publication,
and other documents necessary to effectuate foreclosure sale pursuant to a Final Judgment of Foreclosure
3 In consideration for the services listed above, amongst other duties in connection with the
prosecution of this action, the Firm has agreed to charge, and the client has agreed to pay a flat rate
attorneys’ fee. This is a standard fee within the industry for the services provided as described herein.
4 In addition to the flat fee, the Firm also charges the client for certain contested matters,
including but not limited discovery, motion practice, responsive and supplemental pleading, etc.. The Firm
charges, and the client has agreed to pay a mixture of flat rate attorneys’ fees and hourly attorneys’ fees,
depending on the nature of the work performed.
5 To date, the Firm has incurred, and the client has agreed to pay the following attorneys’
fees:
Date Description Amount
03/15/2023 Atty Fees through Referral $1,230.00
03/22/2023 Atty Fees through Title Review $410.00
04/27/2023 Atty Fees through Service Started $410.00
04/27/2023 Atty Fees through Complaint $410.00
05/31/2023 Atty Fees through Service $410.00
07/10/2023 Motion to Extend Time Prep $150.00
08/25/2023 Contested Affirmative Defenses ~ Received and Reviewed $857.50
Answer
10/06/2023 Contested Production PREP — Received and Reviewed $784.00
Request for Production
10/11/2023 Motion to Extend Time Prep $150.00
10/16/2023 Production FILED — Review responses from client $122.50
TOTAL $4,934.00
6 I am familiar with the costs that the Firm incurred on behalf of our client in this action.
These costs and expenses are as follows:
Description Amount
Complaint Filing Fee $2,007.50
Service of Process $733.00
Statutory Mail $3.12
TOTAL $2,783.62
7. Under penalties of perjury, I declare thatI have read the foregoing and that the facts stated
in it are true and correct.
FURTHER AFFIANT SAYETH NOT.
Dated this day of Navan bor 2023.
Albertelli Law
P.O. Box 23028
Tampa, FL.33623
(813). 221-4743
(813) 221-9171 facsimile
Servic. : servealaw@albertellilaw.com
. JUSTIN A, SWOSINGKE
By FLORI SAR
36533
The foregoing instrument was sworn to and4ubscribed before me by means of by physical
presence or 0 online notarization, this | day of. 2023, by
sulystin A. Swosingkt
“nolan ARE
NOTARY PUBLIC, State of
My commission expires: Notary Public State of Florida
Pamela Anne Strom
My Commission HH 437753
Expires 8/27/2027
23-003322
2023 CA 003228 MF - WELLS FARGO BANK vs. UNITED STATES OF AMERICA ACTING THROUGH SECRETARY OF VETERANS AFFAIRS
SUMMARY
Judge: ALVARO, CHAD Court Type: CIRCUIT CIVIL Case Type: HOMESTEAD RESIDENTIAL FORECLOSURE
‘Case Number: 2023 CA 003228 Uniform Case Number: 492023CA003228XXXXXX $250,001 AND UP
MF Status Date: 4113/2023 Status: OPEN
Clerk File Date: 4113/2023 Custody Location: Waive Speedy Trial:
Total Fees Due: 0.00 Agency:
Agency Report Number: Foreclosure: ACTIVE - 4/13/2023
[ PARTIES
ss a ~
TP PARTY NAME ATTORNEY
PLAINTIFF WELLS FARGO BANK CALHOUN, CHARLINE (Main Attorney)
| DEFENDANT. UNITED STATES OF AMERICA ACTING THROUGH SECRETARY OF VETERANS AFFAIRS
[DEFENDANT ‘TD BANK USA NA
DEFENDANT ‘MIDLAND FUNDING LLC
DEFENDANT EAGLE BAY OF OSCEOLA COUNTY MASTER ASSOCIATION INC MAIER, CRYSTAL MARIE
I DEFENDANT EAGLE BAY OF OSCEOLA COUNTY HOMEOWNERS ASSOCIATION INC
I DEFENDANT CARTAGENA, RAMON
DEFENDANT UNKNOWN PARTY 1
DEFENDANT UNKNOWN PARTY 2
DEFENDANT UNKNOWN PARTY 3
DEFENDANT UNKNOWN PARTY 4
oe en sone bese cv os
EVENTS
~
DATE EVENT [auoce LOCATION [RESULT
12/13/2023 8:30 AM MOTION FOR SUMMARY JUDGMENT ALVARO, CHAD. VIRTUAL HEARING
UTSTANDING AMOUNT
vn ns ss ~
‘COUNT CODE DESCRIPTION ASSESSMENT PAID WAIVED BALANCE PAYMENT PLAN / JUDGHENT. DUE DATE
MES MTG FORECLOSURE $250,001 OR MORE $1,905.00 $1,905.00 $0.00 0.00
‘Total Outstanding: [$0.00
TPOVER’ TIS PENDENS OVER PAY $5.00 $5.00 $0.00 $0.00
CVLADDOF” CIRCUIT CIVIL FILING FEE ADDTL DEFENDANTS $12.50 $12.50 $0.00 0.00
SUMCA SUMMONS CIRCUIT CIVIL $80.00 $80.00 $0.00, $0.00
Total Outstanding: [$0.00
a
DATE ECEIPT # APPLIED AMOUNT
~
4/24/2023 2023047311 $2,002.50
“CASE DOCKETS
VIEWER IMAGE | DATE ENTRY ~
Request 11/1/2023 AFFIDAVIT OF ATTORNEY'S FEES AND COSTS
Re quest | 44/1/2023, NOTICE OF FILING AFFIDAVIT OF ATTORNEY FEES AND COSTS
LRequest] 10716/2023 NOTICE OF PLAINTIFF'S RESPONSE TO DEFENDANTS REQUEST FOR PRODUCTION
[Request 19/6/2023 PLAINTIFF MOTION FOR ENLARGEMENT OF TIME TO RESPOND TO DEFENDANT DISCOVERY REQUEST
Ov 9/28/2023 AFFIDAVIT OF AMOUNT DUE AND OWING
G2 9/28/2023 NOTICE OF FILING AFFIDAVITAS TO AMOUNT DUE AND OWING
9/26/2023 MOTION FOR SUMMARY JUDGMENT SET FOR 12/13/2023 AT 8:30 AM IN VR BEFORE JUDGE: ALVARO, CHAD
Request. 9/22/2023 NOTICE OF HEARING
Request 9/7/2023 REQUEST FOR PRODUCTION OF DOCUMENTS.
Request 8/25/2023 PLAINTIFF REPLY TO DEFENDANT AFFIRMATIVE DEFENSES.
Request 8/23/2023 AFFIDAVIT OF ATTORNEY'S FEES AND COSTS AND AFFIDAVIT OF REASONABLE ATTORNEY FEES
VieweR |Imace | DATE lentey
L
[Request] 5/23/2023 NOTICE OF FILING AFFIDAVIT OF ATTORNEY FEES AND COSTS AND AFFIDAVIT OF REASONABLE ATTORNEY FEES
Request 8/22/2023 PLAINTIFF'S MOTION FOR SUMMARY JUDGMENT INCLUDINGA HEARING TO TAX ATTORNEY'S FEES AND COST
Request 8/18/2023 ORDER GRANTING DEFENDANT MOTION FOR EXTENSION OF TIME TO RESPOND TO COMPLAINT
Request. 8/17/2023 DEFENDANT ANSWER TO VERIFIED COMPLAINT TO FORECLOSE MORTGAGE AND AFFIRMATIVE DEFENSES
Request 7114/2023 DELIVERY / READ EMAIL CONFIRMATION TO ATTORNEY
G2 71712023 DEFAULT ENTERED AGAINST DEFENDANTS
Request. 7/3/2023 PLAINTIFFS RESPONSE TO DEFENDANT RAMON CARTAGENA AND UNKNOWN PARTY #1 N/K/A TOMMY CARTAGENA'S MOTION FOR ENLARGEMENT OF TIME TO
RESPOND TO COMPLAI
Request, 6/30/2023 MOTION FOR DEFAULT AND ENTRY OF DEFAULT
Request 6/30/2023 NOTICE OF DROPPING PARTY DEFENDANTS
Request 6/28/2023 AFFIDAVIT OF NON-MILITARY SERVICE
west 6/28/2023 NOTICE OF FILING AFFIDAVIT
[Request] 6/23/2023 CERTIFICATE OF MAILING
Request 6/15/2023 DEFENDANT MOTION FOR EXTENSION OF TIME TO RESPOND TO COMPLAINT
Request 6/15/2023 DESIGNATION OF E-MAIL ADDRESSES PURSUANT
TO RULE 2,516
-
Request 6/1/2023 ‘SUMMONS RETURNED, CORPORATE SERVED DATE SERVED : 05/08/2023@945AM PARTY SERVED: USA SECRETARY OF VETERANS AFFAIRS
Request, 6/1/2023 SUMMONS RETURNED, CORPORATE SERVED DATE SERVED : 05/09/2023@359PM PARTY SERVED: EAGLE BAY OF OSCEOLA COUNTY MASTER ASSOCIATION INC.
[Request| 6/1/2023 SUMMONS RETURNED, CORPORATE SERVED DATE SERVED : 05/04/2023@241PM PARTY SERVED: TD BANK USA NA.
Request 6/1/2023 ‘SUMMONS RETURNED, SUBSTITUTE SERVED. DATE SERVED: 05/27/2023@749PM PARTY SERVED: UNKNOWN PARTY
cequest 6/4/2023 ‘SUMMONS RETURNED, CORPORATE SERVED DATE SERVED : 05/09/2023@359PM PARTY SERVED: EAGLE BAY OF OSCEOLA COUNTY HOMEOWNERS ASSOCIATION INC
Request 6/1/2023 SUMMONS RETURNED, CORPORATE SERVED DATE SERVED : 05/17/2023@410PM PARTY SERVED: MIDLAND FUNDING LLC
Request. 6/1/2023 ‘SUMMONS RETURNED, INDIVIDUALLY SERVED DATE SERVED: 05/27/2023@749PM PARTY SERVED: RAMON CARTAGENA
Request 6/1/2023 ‘SUMMONS RETURNED, UNSERVED FOR UNKNOWN PARTY
au 5/19/2023 ANSWER OF DEFENDANT UNITED STATES OF AMERICA ON BEHALF OF VETERAN AFFAIRS
Request 5/11/2023 DEFENDANT EAGLE BAY OF OSCEOLA COUNTY HOMEOWNERS ASSOCIATION INC NOTICE OF APPEARANCE OF COUNSEL
B3 5/11/2023 ANSWER AND DEFENSES
Bt 5/2/2023 NOTICE OF LIS PENDENS (REC)
Request 4/24/2023 PAYMENT $2,002.50 RECEIPT #2023041311
O17 4/24/2023 SUMMONS ISSUED (EMAILED TO ATTY)
G3 4/13/2023 STANDING CASE MANAGEMENT PLAN/ORDER (STREAMLINED TRACK)
vest 4/13/2023 ‘SUMMONS TO BE ISSUED
Request 4/13/2023 SUMMONS TO BE ISSUED
Request 4/13/2023 SUMMONS TO BE ISSUED
[Request | 4743/2003 SUMMONS TO BE ISSUED
Request 4/13/2023 ‘SUMMONS TO BE ISSUED
Request. 4113/2023 ‘SUMMONS TO BE ISSUED
juest 4/13/2023 SUMMONS TO BE ISSUED
[Request] 4713/2023 SUMMONS TO BE ISSUED
B1 4/13/2023 VALUE OF REAL PROPERTY OR MORTGAGE FORECLOSURE CLAIM
Request 4/13/2023 NOTICE OF LIS PENDENS
a4 4/13/2023 MORTGAGE FORECLOSURE COMPLAINT
Request 4/43/2023 CIVIL COVER SHEET
4/13/2023 CASE FILED 04/13/2023 CASE NUMBER 2023 CA 003228 MF