On June 08, 2023 a
Party Statement
was filed
involving a dispute between
Matrix Financial Services Corp,
and
Felia, Natalie M,
Hunters Ridge Homeowners Assoc,
Unknown Tenant In Possession O,
Wilson, Christopher D,
for Circuit Civil 3-C
in the District Court of Pasco County.
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Filing # 185769650 E-Filed 11/08/2023 04:16:05 PM
MATRIX FINANCIAL SERVICES IN THE CIRCUIT COURT OF THE
CORPORATION IXTH JUDICIAL CIRCUIT JUDICIAL
PLAINTIFF, IRCUIT, IN AND FOR
VS. ASCO COUNTY, FLORIDA
NATALIE M. FELIA AND CHRISTOPHER IVIL DIVISION
D. WILSON, ET AL., ‘ASE NO.: 2023CA003662CAAXWS
DEFENDANTS.
AFFIDAVIT AS TO ATTORNEY’S FEES
STATE OF FLORIDA
COUNTY OF BROWARD
Pursuant to Florida Statute § 92.525(2), Michael Fontalvo, Esq., deposes and says:
1 The Affiant is a duly qualified and licensed attorney admitted to practice in the State of
Florida.
2. The Affiant has been a practicing member of the Florida Bar since May 3, 2006.
3. The Affiant has familiarity in suits similar to this case and is further familiar with the
factors to be considered in determining the reasonableness of a fee outlined in Fla. Bar
Code Prof. Resp., D.R. 2-106 (B), the Rules Regulating The Florida Bar 4-15(b), and under
Florida Patient's Compensation Fund v. Rowe, 472 So. 2d 1145 (Fla. 1985).
Affiant has considered the following factors in determining his opinion of reasonable
attorney’s fees:
A The time and labor required, the novelty, complexity, and difficulty of the questions
involved, and the skill requisite to perform the legal service properly.
B The likelihood that the acceptance of the particular employment will preclude other
employment by the lawyer.
The fee, or rate of fee, customarily charged in the locality for legal services of
comparable or similar Nature.
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 with the client.
The experience, reputation, diligence, and ability of the lawyer or lawyers performing
the service and the skill, expertise, or efficiency of effort reflected in the actual
providing of such services whether the fee is fixed or contingent, and, if fixed as to
amount or rate, then whether the client’s ability to pay rested to any significant degree
on the outcome of the representation.
The Affiant has examined the relevant portions of the Plaintiffs attorney's file in this
proceeding, including the Affidavit of Plaintiff's Counsel as to Attorneys’ Fees.
ElectronicatfPAGG
PAbo Case # 2023CA003662CAAXWS 11/08/2023 04:16:05 PM
6. Affiant is familiar with the specific steps and requirements that the Firm must complete to
handle a foreclosure action to its conclusion. In my opinion, the flat foreclosure fee
arrangement of $4,275.00 is reasonable and customary.
FURTHER AFFIANT SAYETH NAUGHT
Dated this 8" day of November, 2023.
Under penalties of perjury, I declare that I have
read the foregoing document and that the facts
Stated in it are true.
/s/ Michael Fontalvo
Michael Fontalvo, Esq., Affiant
Florida Bar No.: 22552
23FL404-0021
Document Filed Date
November 08, 2023
Case Filing Date
June 08, 2023
Category
Circuit Civil 3-C
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Filing # 185769650 E-Filed 11/08/2023 04:16:05 PM MATRIX FINANCIAL SERVICES IN THE CIRCUIT COURT OF THE CORPORATION IXTH JUDICIAL CIRCUIT JUDICIAL PLAINTIFF, IRCUIT, IN AND FOR VS. ASCO COUNTY, FLORIDA NATALIE M. FELIA AND CHRISTOPHER IVIL DIVISION D. WILSON, ET AL., ‘ASE NO.: 2023CA003662CAAXWS DEFENDANTS. AFFIDAVIT AS TO ATTORNEY’S FEES STATE OF FLORIDA COUNTY OF BROWARD Pursuant to Florida Statute § 92.525(2), Michael Fontalvo, Esq., deposes and says: 1 The Affiant is a duly qualified and licensed attorney admitted to practice in the State of Florida. 2. The Affiant has been a practicing member of the Florida Bar since May 3, 2006. 3. The Affiant has familiarity in suits similar to this case and is further familiar with the factors to be considered in determining the reasonableness of a fee outlined in Fla. Bar Code Prof. Resp., D.R. 2-106 (B), the Rules Regulating The Florida Bar 4-15(b), and under Florida Patient's Compensation Fund v. Rowe, 472 So. 2d 1145 (Fla. 1985). Affiant has considered the following factors in determining his opinion of reasonable attorney’s fees: A The time and labor required, the novelty, complexity, and difficulty of the questions involved, and the skill requisite to perform the legal service properly. B The likelihood that the acceptance of the particular employment will preclude other employment by the lawyer. The fee, or rate of fee, customarily charged in the locality for legal services of comparable or similar Nature. 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 with the client. The experience, reputation, diligence, and ability of the lawyer or lawyers performing the service and the skill, expertise, or efficiency of effort reflected in the actual providing of such services whether the fee is fixed or contingent, and, if fixed as to amount or rate, then whether the client’s ability to pay rested to any significant degree on the outcome of the representation. The Affiant has examined the relevant portions of the Plaintiffs attorney's file in this proceeding, including the Affidavit of Plaintiff's Counsel as to Attorneys’ Fees. ElectronicatfPAGG PAbo Case # 2023CA003662CAAXWS 11/08/2023 04:16:05 PM 6. Affiant is familiar with the specific steps and requirements that the Firm must complete to handle a foreclosure action to its conclusion. In my opinion, the flat foreclosure fee arrangement of $4,275.00 is reasonable and customary. FURTHER AFFIANT SAYETH NAUGHT Dated this 8" day of November, 2023. Under penalties of perjury, I declare that I have read the foregoing document and that the facts Stated in it are true. /s/ Michael Fontalvo Michael Fontalvo, Esq., Affiant Florida Bar No.: 22552 23FL404-0021