Preview
FILED
3/25/2024 10:40 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Miranda Lynch DEPUTY
NO DC24-01562
RICARDO SANCHEZ, Indv. IN THE DISTRICT COURT
and d/b/a Sanchez Solutions,
Plaintiff,
vs
DALLAS COUNTY, TEXAS
TIDES ON LARGA OWNER, LLC.
d/b/a Tides on Larga
Apartments,
Defendant. 101 JUDICIAL DISTRICT
ATTORNEY'S FEE AFFIDAVIT
THE STATE OF TEXAS )
)
COUNTY OF DALLAS )
Before me, the undersigned authority, on this day personally
appeared the undersigned affiant, who, being by me duly sworn, on
oath stated:
1 "My name is Timothy Gerard Pletta and I have personal
knowledge of the facts set out in this Affidavit which are true and
correct. I am Tm: ing this Affidavit in support of a Judgment, in
Cause Number DC24-01562, entitled, Ricardo Sanchez, Indv. and d/b/a
Sanchez Solutions ("Sanchez Solutions") Vv Tides on Larga Owner,
LLC. d/b/a Tides on Larga Apartments ("Tides on Larga Apartments")
which is currently pending in the Dallas District Court, 1lolst
Judicial District, Dallas County, Texas.
2 "Tt am at least eighteen years of age, of sound mind,
capable of ma. bie ng this affidavit, and fully competent to testify to
the matters stated herein, and I have personal knowledge of each of
ATTORNEY'S FEE AFFIDAVIT Page 1
those matters stated.
3 "T am a duly licensed attorney in the State of Texas and
I practice in the Courts of this county since 1992. During this
time, I have appeared as attorney of record in cases similar to
this one in which attorney fees have been awarded by the Court. I
am also familiar with the attorney fees customarily awarded by the
Courts of this county.
4 "Because of Defendant's failure to pay monies owed to
Plaintiff, after presentment, and after default, attorney's fees
and costs or court were incurred and I have performed more than
17.6 hours of work on this case at $575.00 per hour, including
doing or causing to be done:
a (a) Client interview, review file and review unpaid account,
discuss past due balance, work provided and reasons for
demand and nonpayment, attempts to collect debt, receive
additi onal e-mail from client, discuss whether to file
suit or send written demand letter (Larga II);
(b) Review Attorney's Fee Contract, Review with Client;
({c) Follow up telephone conferences with client and its
agents regrading account and attempts to collect and
information necessary for attorney (Larga II);
(e) Investigate and Confirm
Real PropertyDallas County
Records and Legal Entity Information,
as evidenced by and
the deed records recorded in Dallas county, Texas,
Defendant owns the real property and the business made
the basis of this suit. See Recorded Deed Records and
Recorded Liens on File;
(£) Velephone conference with client, status update and
explain steps in litigation process, review client's e-
mails and applicable credits after suit was filed noting
no credits prior to filing suit and current balance due.
Request current account statement and review account;
{g) Review Applicable Statutes and Case Law; Prepare and
revise Plaintiff's Original Petition, Exhibits and
Account.
ATTORNEY'S FEE AFFIDAVIT Page 2
0.3 (h) Prepare and E-File Plaintiff's Original Petition;
1.3 (i) Telephone Conference with Client; Review Petition; Status
Update; Prepare & revise correspondence and Notice of
Suit to Tides on Larga Apartments, forward correspondence
and copy of Original Petition to Tides en Larga
Apartments;
0.2 (3) Conferences with Process Server = Request Citation to
Proceed to Issue; Affidavit of Service and Filing Return;
3 (k) Review Legal Description; Prepare and Revise Lis Pendens,
Appear at Dallas County Clerk and Record Notice; Forward
Notice of Recorded Instrument Lo Tides on Larga
Apartments;
0.3 (1) Review Court's File and executed and file date of Return
ana A. Gavit of Service, make docket entry of 2/12/24;
Note Default Date 3/4/2024; DWOP Setting 4/5/2024;
0.2 (m) Review File; Request Invoices for Taxable Court Costs;
3.8 (1) Prepare and Revise Plaintiff's Settlement Letter dated
July 27, 2023, Including Dismissal and Release Documents;
Calculate Interest (total principal claim) $37,716.50 x
18% x 3 months == $8,669.29 {total interest) (See: Texas
Prompt Pay Act §28.004);
0.9 (g) Prepare and revise e-mails with Tides on Larga Apartments
to resolve claim; update client as to status;
3.4 (n) Review Court's File; Prepare and Revise Plaintiff's
Motion for Default Judgment; Correspondence to Court,
supporting Affidavits, and Final Summary Judgment,
forward same to client; Review executed Affidavit and
invoices for unpaid account; Re-Calculate Pre-Judgment
Interest (tetal principal claim) $37,716.50 x 18% x 5
months = $9,966.70 {total interest) (Sea: Prompt Pay Act
§28.004);
0.5 {0} Telephon conference with client, status update and steps
in defau udgment process and confirm account balance,
review e-mails from client and executed affidavit;
0.4 {p) Review executed affidavit and invoices for unpaid
account; file Plaintiff's Motion for Default Judgment.
5 “Due to the nature of this case, which includes: (a) its
principal claim of $37,716.50 and total interest claim of $9,966.70
or a total c m of $47,683.20; {b) credits in the sum of §0.00
received after and as a Ces of cle filling and notice oc tie
ATTORNEY'S FEE AFFIDAVIT Page 3
lawsuit with notice of Plaintiff's Original Petition, leaving a
balance due and owing of $37,716.50; (c) the inherent or potential
risk this judgment can not be collected and/or relating to
defendant's real property, management company and/or its
accounting; (d} the lack of any response after notice of filing
suit; {e) the potential for other claims and/or lawsuit(s) which
may exist against this property for unpaid amounts and/or invoices;
(£) the time constraints imposed by the client; (g) the nature and
length of the professional relationship with the client; (h) the
amount of time and labor spent on the file and the amount in
controversy; (i) the legal skills required; (j) the fee and market
rate customarily charged for similar legal services; (k) the
experience, reputation and ability of the attorney performing the
services; {1} the responsibility imposed upon the attorney for the
amounts herein and urgency of the matter; {m) and plaintiff's
contingency fee contract arrangement; pursuant to 38.001, 38.003,
38.004 Civil Practice and Remedies Code, 28.005 (b) Texas Prompt
Payment Act and/or 36.25 Texas Business and Commerce Code, the
court may award costs and reasonable attorney's fees as the court
determines equitable and just. Prompt Pay Act § 28.005(a) (b).
Based upon the above, it is my opinion under the circumstances an
hourly rate of $575.00 per hour is reasonable and necessary and a
reasonable market rate; and therefore, a reasonable, necessary,
usual and customary fees in this cause totals $10,000.00, with an
additional war d of
a war $2,500.00, relating to providing notice of and
attending, if necessary, a hearing and taxable court costs of not
less than $946.00.
ATTORNEY’S FEE AFFIDAVIT Page 4
6 “With an additional award of $7,500.00 as attorney's fees
in the event of an appeal to the First District Court of Appeals
and $10,000.00 in the event a petition for review is filed at the
Supreme Court of ‘Texas, with all post judgment attorney's fees
contingent upon plaintiff being successful at each level.
FURTHER AFFIANT SAITH NOT."
—_—_-
Timothy
SWORN TO AND SUBSCRIBED BEFORE ME this olay of March, 2024.
My commission expires: a
— Go to www.irs.gov/FormW for instructions and the latest information.
send to the IRS,
Internat Revensie Service
‘your Inagmng tax relum). Napogis requ PETER This line blank.
An =
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2 TAO ae ame Vf cillerent from above
(CF OFT) ‘asthy 6 PLECTA
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&8 fottowiny ven boxes, certain antities, not individuals; see
ingtructions on page 2):
iIndividuat/so'e propristoror (1 cecrperation C1] § Corporation D) Partnership CT trusvrestate
ingle-member LU Exempt payee cude (if any)
CO Limited tianitity campany, Enter the tax classification (C=C corporation, S=$ corporation, P:Partnership) *
Nota: Check the sppropriete bax in the line above lor the tax classttication of the singla-member owner, Og not check Fxemption from FATCA reporting
= LLG [f the LLC Is classified as a single-member LLC that is ded from the owner unless {he over af tha LLC is code (if any)
another LUC that Is not disrogarded from the owner farU. S. federal tax purpos Otherwise, a single-membar LUC that —
fs disregarded {rom the owner should check the appropriate box for the tax classification of its owner.
Other (sae instructions) + {Aopen to accounts mantaned outwce hr US)
Ai Ter's name and address (optional)
#1,
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Taxpayer Identification Number {TIN}
line 1 to avoid Social ity numbor
Enter your TIN in the appropriate box. The TIN provided must match the name glven on
backup withholding. For individuals, this is generally your social security number (SSN). However, for a
resident alien, sole proprietor, or disregarded entity, see the Instructions for Part |, later. For other
entities, it is your emptoyer identification number (FIN). Ii you do not have a number, see How to get a
TIN, later. or
Note: If the account Is In more than one name, see the instructions for line +. Also see What Name and
[Employer Wentification number |
Number Ta Give the Requester for guidelines on whose number to enter. 2
Certification
Under penalties of perjury, | certify that:
1. The number shown on this form is my correct taxpayer identification number (or | am wailing for a numberto be issued to me); and
have not bean notified by the Internal Revenue
2.1 am not subject to backup withholding be! use: (a) | am exempt from backup withholding, or {o)or | dividends,
Service (IRS) that | am subj to baci up witl hholding as a result of a failure ta report ail interest or (c) the IRS has notified me that | am
no longer subject to backup withholding;
3. 1am a U.S. citizen of other U.S. person (defined below}; and
4, The FATCA cadeys} entered on this form () any) indicating that | am exempt from FATGA reporting is correct.
Certification instructions. You must orgss 0 1 item 2 above if you have been notifiad by the IRS that you are currently subject to backup withholding because
mortgage interest paid,
you have failsd to report ail interest and, ividends on your tax ratum, For real estate transactions, item 2 does not apply. Fer (IRA),
ncellalion of debt, contributions to an individual retirement arrangemept \d generally, payments
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acquisition or abandonment o} fg
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foroperty
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other than interest and dividend ren es ed gorsgn the certification, but you must promde your correct TIN. Sey the7. Insfuctions for Part i, later.
Sign
Here
Signature of
U.S. parson oor 9f | CY
* Form 1099-DIV (dividends, inclu:
Genera! Instructi ohs funds)
Section references are to the Internal Rev a ode unless otherwise + Form 1099-MISC (various types of income, prizes, awards, or gross
noted. proceeds)
Future developments. For the latest Information about devolopments + Form 1099-8 (stock or mutual fund sales and certain other
related to Form W-9 ani instructions, such as legislation enacted transactlons by brokers)
after they were published, go to www. irs. ‘Forms. + Form 1099-S {proceeds from real estata transactions)
Purpose of Form * Form 1099-K (merchant card and third parly network transactions)
An individual or entity (Form W-9 requester) who is required to file an + Form 1098 (home mortgage interest), 1098-E (student loan Interest},
information return with the IRS must obtain your correct taxpayer 1098-T (tuition)
identification number (TIN) which may be your social security number * Form 1099-C (canceled deb!)
(SSN), individual taxpayer identi ification
a it number {ITN}, adoption + Form 1089-A (acquisition or abandonment of secured property)
taxpayer identification number { |. or employer identification number Use Form W-9 only if you are a U.S. person (including a resident
{EIN}, te report on an informatio! return the amount aid to you, ar other
amount repertable on an information return. Exam s of Information alien}, to provide your correct TIN.
returns include, but are not limited to, the following. it you do not return Farm W-9 to the sequester with a TIN, you might
+ Form 1099-INT (interest eamed or paid) be subject to backup withholding. See What is backup withholding,
tater.
Cat, No, 10231X Form W-8 (Rev. 10-2018)
NVOICE
Sanchez Solutions
2736 Rolinda Dr
Date 08/11/2023
Dallas, Texas 75211
Invaice:# 271,
469-209-2670
Bus Dato Upon Receipt
Bill To
Tides On Lara
3330 Webb Chapel Ext
Dallas, Texas 75220
214-351-5205
item Quantity Unit Price Total
3303 HVAC 1 $4,300.00 84,800.00
Install new full HVAC system fram R22 to 410. In and outside system.
This acl ies alltabar and materials.
* Sub Total $4,300.00
Sales Tex 8.25% $384.76
Amount Due $4,654.75
Sanchez Solutions
2 738
736Rolinda Dr Dallas, Texas 75211
aay i Sanchezsolutionsag@gmail.cam 469-209-2670
Invoice
INV273
Date ‘Oct 10, 2022 Bill to:
Tides On Larga
3330 Webb Chapet Ext Dallas, Texas 75220
largamanager@robinsongroupre.com
# Item Price Qty Totat
at Unit #8110 Full Paint Of Unit And $580.60 $580.00
a
= S
Subtotal $580.00
Tax (8.26%) $47.85
GRAND TOTAL $627.85
Paid $0.00
DUE $627.85
Payment address Is
1251 Moulin Rouge #136
Dallas, Texas 75214
Sanchez Solutions
2738 Rolinda Dr Dallas, Texas 75211
an Sanchezsalutions33@gmail.com ! 469-209-2570
ce
Invoice
INV307
Date Oct 26, 2022 Bill to:
Tides On Larga
3330 Webb Chapel Ext Dallas, Texas 75220
largamanager@sobinsongroupra.com
# Item Price aty Total
o1 Unit # 2209 Full Paint $340, Paint & $1,440.00 1 $1,440.00
Materials $350, (1) 4x8 Sheetrock
Repair On Ceiling W/ Tape & Bed
And Acoustic $750
aaa eee . ae ——— .
Subtotai $1,440.00
Tax (8.25%) $118.60
GRAND TOTAL $1,558.80
Paid $0.00
DUE $1,558.80
Payment address is
1251 Moulin Rouge #436
Dalias, Texas 75211
Sanchez Solutions
2736 Aolinda Dr Dallas, Texas 75211
coats i ie Sanchezsolutions39@amail com : 469-209-2670
Invoice
INV310
Date Oct 26, 2022 Bill to:
Tides On Larga.
3330 Webb Chapel! Ext Dailas, Texas 75220
targamenager @rovinsongroupre.com
# item Price aty Total
o1 Unit #2208 Resurfacing Of Kitchan $445.00 1 $446.00
Counter & Bar $125, Resurface
Bathroom Counter $50, Resurface
Tub & Tile $176, Stripping $40,
Resurlace Fireplace $60
— i ——— es a
Subtotal 3445.00
Tax (8.25%) $36.75
GRAND TOTAL $481.71
Paid $0.00
DUE $481.71
Payment address is
1251 Moulin Rouge #436
Dallas. Texas 75217
Sanchez Solutions
736 Ronda Or Callas, Texas 75211
eat ee Sanchezsolutions39® gmail.com * 469-209-2670
Invoice
INV311
Date Oct 26, 2022 il to:
Tides On Larga
3330 Webb Chapel! Ext Gallas, Texas 75220
largamanager@robinsongroupre.com
a Rem Price Qty Total
oO Unit #2209 Make Ready (labor) 570.00 1 $570.00
$340 , Trashout $150,
Housekeeping $80
= 7
Subtotal $570.00
Tax (8.25%) $47.03
GRAND TOTAL $617.02
Paid $0.00
DUE $617.02
Payment address is
1251 Moulin Rouge #136
Dallas, Texas 75241
Sanchez Solutions
2736 Rolinda Dr Dallas, Texas 75211
Rie Bait Sanchezsclutions39@gmail.com : $68-209-2670
Invoice
INV313
Date Oct 26, 2022 Bilt to:
Tides On Larga
3230 Webb Chapel Ext Datins, Texas 75220
largamanager@ robinsongroupre.com
@ item Price ary Totat
ot Unit #2209 Materials For $1,078.00 1 $1,079.00
Makersady (t) Ventahood $80, (2)
Backsplash $100, (3) Dome Lights.
$90 (1) Vanity Light $45, (2) Towel
Bars $60, Shower Rot $15, (25)
Light Switch Covers $32, (1) Ceiling
Fan With Light $120, Repair
Cabinet Doars & Drawers in Kitchen
$300, (2) 24x72 Mini Blinds $120(1)
32x60 Mini Blind $50. 24 in Closet
rerSer = =
Sublotat $1,079.00
Tax (8.25%) $89.02
GRAND TOTAL $1,168.02
Paid $0.00
QUE $1,168.02
Payment address is
1251 Moulin Rouge #136
Dallas, Texas 75217
Sanchez Solutions
2736 Rolinda Or Dallas, Texas 75211
cont Sanchezsolutions39
@gmail com» 469-269-2670
Invoice
INV314
Date Oct 26, 2022 Bill to:
Tides On Larga
3330 Webb Chapel Ext Dallas, Texas 75220
largamanager@robinsongroupre.com
# Stem Price aty Total
1 Unit #2209 Install 558 Sq Ft O1 Vinyl $1,476.00 1 $1,475.00
Plank Materiais Plus Glue $775,
Labor For Install $700
This Includes labor and matenats
= enon - ae ee eee
Subtotal $1,476.00
ax (8.25%) $121.69
GRAND TOTAL $1,596.69
Paid $0.00
DUE $1,596.69
Payment address is
1251 Moulin Rouge #136
Dallas, Texas 75211
Sanchez Solutions
2736 Rofinda Or Dallas, Texas 75211
ce San ezsdlLtions39@gmail.com | 469-209-2670
Invoice
INV315
Date Oct 26, 2022 Bill to:
Tides On Large
3330 Webb Chapel Ext Dallas, Texas 75220
largamanager@rabinsongroupre.com
# Item Price aly Total
a1 Unit #6301 Fuil Paint $340, Paint $1.315.00 1 $1,515.00
$50,
And Materials $350, Trashout $50,
Housekeeping $80, Resurfacing
Kitchen Counter & Bar $125,
Resurface Tub & Tile $170,
Stripping $40, Resurface Bathroom
Counter $50, Resuriace Fireplace
$60, (3) a pecaee 2x2 $250
ae = a
Subtotal $1,515.00
Tax (8.25%) $124.99
GRAND TOTAL $1,639.99
Paid 30.06
DUE $1,639.99
Payment address is
1251 Moulin Rouge #136
Dallas, Texas 75214
Sanchez Solutions
2736 Rolinda Dr Oalias, Texas 75211
cra rales, Sanchezsolutions39@gmail.com
. 469-208-2670
Invoice
INV317
Date Oct 26, 2022 Gill to:
Tides On Larga
8330 Webb Chapel Ext Dallas, Texas 75220
largamanagar@robinsongraupra.com
# tem Price aty Total
01 Unit #6301 Makeraady Labor $350, $327.00 1 $827.00
(3) Dome Lights $90, (1) 3 Bulb
Vanity Light $45, (2) Towel Holders
‘$60, (1) Shower Rod $25, (2)
Smoke Alarms $28, (25) Light
Switch Covers $32, Repair Kitchen
Cabinets & Drawers $200
Subtotal $827.00
Tax (B.25%) $68.23
GRAND TOTAL $895.23
Paid $0.00
DUE $895.23
Payment address is
1251 Moulin Rouge #136
Dallas, Texas 75211
Sanchez Solutions
2736 Rotinda Dr Dallas, Texas 75211
ba oo Ee Sanchezsolulions3$@gmail com » 462-209-2670
Invoice
INV318
Date Oct 26, 2022 Bill to:
Tides On Larga
3330 Webb Chapel Ext Dallas, Texas 75220
largamanager@rabinsongroupra.com
# item Price ay Total
ot Unit #6301 Install 528 Sq Ft Vinyl $1,344.04 1 $1,344.04
Plank $686.04, Material. glue $658
Subtotal $1,344.04
Tax (8.25%) $110.88
GRAND TOTAL $1,454.92
Paid $0.00
DUE $1,454.92
Payment address is
1251 Moulin Rouge #136
Dallas, Texas 75211
Sanchez Solutions
2736 Aolinda Or Dallas, Texas 75214
Sa Sanchezsolutions39@qmail com . 469-209-2670
Invoice
INV313
Date Oct 26, 2022 Bill to:
Tides On Larga
3330 Webb Chapel Ext Dallas, Texas 75220
largamanager@rabinsongroupre.com
# tem Price Qty Total
|
ot Unit # 8307 Resurfses Tub & Tile $230.00 t $230.00
5170, Resurface Fireplace $60
Subtotai $230.00
Tax (8.25%) $18.98
GRAND TOTAL $248.98
Paid $0.00
DUE $248.98
Payment address is
1251 Moulin Rouge #435
Dallas, Texas 75211
Sanchez Solutions
2736 Rolinda Dr Dallas, Texas 75211
bots Sere Sanchezsolutios39@gmail.com 469-709-2870
=
Invoice
INV320
Date Oct 26, 2022 Bill to:
Tides On Larga
3330 Wabb Chape! Ext Dallas, Texas 75220
largamanager@ robinsongroupre.com
# tem Price Qty Total
o1 Unit #6212 Resurtace Tub & Tile $230.00 1 $290.00
$170, Resuriace Fiepiace $60
Subtotal $230.00
Tax (8.25%) $18.98
GRAND TOTAL $248.98
Paid $0.00
DUE $248.98
Payment address is
4251 Moulin Rouge #136
Dallas, Texas 75211
Sanchez Solutions
2736 Rolinda Dr Oallas. Texas 75211
aan ee Sanchezsolutions39 gmail.com } 469-209-2670
Invoice
INV322
Date Oct 26, 2022 Bili to:
Tidas On Larga
8330 Webb Chapel Exl Daflas, Texas 75220
largamanager @robinsongroupra.com
# Item Price ary Total
a1 Unit #2104 Resurface Tub & Tile a
$230.00 230,00
$170, Resuriace Fireplace $60
-
Subtotal $230.00
Tax (8.25%) $18.98
GRAND TOTAL $248.98
Paid $0.00
DUE $248.98
Payment adcress is
1251 Moulin Rouge #136
Dallas, Texas 75211
Sanchez Solutions
2736 Rolinda Dr Dallas. Texas 75211
Scat flies Sanchezsolutions39@ gmail.com | 469-209-7670
‘2
CY \2 2)
Invoice
INV323
Date Oot 26, 2022 Bill to:
Tides On Largo
3330 Wabb Chapel Ext Dallas, Texas 75220
larqamanager@robinsongraupre.com
# Item Price Qty Total
——
oF Unit # 7202 Resurface Tub & Tile $230.00 1 $230.00
$170 , Resurface Firaplace $60
Subtotal $230.00
Tax (6.26%) $18.98
Preview
FILED 3/25/2024 10:40 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Miranda Lynch DEPUTY NO DC24-01562 RICARDO SANCHEZ, Indv. IN THE DISTRICT COURT and d/b/a Sanchez Solutions, Plaintiff, vs DALLAS COUNTY, TEXAS TIDES ON LARGA OWNER, LLC. d/b/a Tides on Larga Apartments, Defendant. 101 JUDICIAL DISTRICT ATTORNEY'S FEE AFFIDAVIT THE STATE OF TEXAS ) ) COUNTY OF DALLAS ) Before me, the undersigned authority, on this day personally appeared the undersigned affiant, who, being by me duly sworn, on oath stated: 1 "My name is Timothy Gerard Pletta and I have personal knowledge of the facts set out in this Affidavit which are true and correct. I am Tm: ing this Affidavit in support of a Judgment, in Cause Number DC24-01562, entitled, Ricardo Sanchez, Indv. and d/b/a Sanchez Solutions ("Sanchez Solutions") Vv Tides on Larga Owner, LLC. d/b/a Tides on Larga Apartments ("Tides on Larga Apartments") which is currently pending in the Dallas District Court, 1lolst Judicial District, Dallas County, Texas. 2 "Tt am at least eighteen years of age, of sound mind, capable of ma. bie ng this affidavit, and fully competent to testify to the matters stated herein, and I have personal knowledge of each of ATTORNEY'S FEE AFFIDAVIT Page 1 those matters stated. 3 "T am a duly licensed attorney in the State of Texas and I practice in the Courts of this county since 1992. During this time, I have appeared as attorney of record in cases similar to this one in which attorney fees have been awarded by the Court. I am also familiar with the attorney fees customarily awarded by the Courts of this county. 4 "Because of Defendant's failure to pay monies owed to Plaintiff, after presentment, and after default, attorney's fees and costs or court were incurred and I have performed more than 17.6 hours of work on this case at $575.00 per hour, including doing or causing to be done: a (a) Client interview, review file and review unpaid account, discuss past due balance, work provided and reasons for demand and nonpayment, attempts to collect debt, receive additi onal e-mail from client, discuss whether to file suit or send written demand letter (Larga II); (b) Review Attorney's Fee Contract, Review with Client; ({c) Follow up telephone conferences with client and its agents regrading account and attempts to collect and information necessary for attorney (Larga II); (e) Investigate and Confirm Real PropertyDallas County Records and Legal Entity Information, as evidenced by and the deed records recorded in Dallas county, Texas, Defendant owns the real property and the business made the basis of this suit. See Recorded Deed Records and Recorded Liens on File; (£) Velephone conference with client, status update and explain steps in litigation process, review client's e- mails and applicable credits after suit was filed noting no credits prior to filing suit and current balance due. Request current account statement and review account; {g) Review Applicable Statutes and Case Law; Prepare and revise Plaintiff's Original Petition, Exhibits and Account. ATTORNEY'S FEE AFFIDAVIT Page 2 0.3 (h) Prepare and E-File Plaintiff's Original Petition; 1.3 (i) Telephone Conference with Client; Review Petition; Status Update; Prepare & revise correspondence and Notice of Suit to Tides on Larga Apartments, forward correspondence and copy of Original Petition to Tides en Larga Apartments; 0.2 (3) Conferences with Process Server = Request Citation to Proceed to Issue; Affidavit of Service and Filing Return; 3 (k) Review Legal Description; Prepare and Revise Lis Pendens, Appear at Dallas County Clerk and Record Notice; Forward Notice of Recorded Instrument Lo Tides on Larga Apartments; 0.3 (1) Review Court's File and executed and file date of Return ana A. Gavit of Service, make docket entry of 2/12/24; Note Default Date 3/4/2024; DWOP Setting 4/5/2024; 0.2 (m) Review File; Request Invoices for Taxable Court Costs; 3.8 (1) Prepare and Revise Plaintiff's Settlement Letter dated July 27, 2023, Including Dismissal and Release Documents; Calculate Interest (total principal claim) $37,716.50 x 18% x 3 months == $8,669.29 {total interest) (See: Texas Prompt Pay Act §28.004); 0.9 (g) Prepare and revise e-mails with Tides on Larga Apartments to resolve claim; update client as to status; 3.4 (n) Review Court's File; Prepare and Revise Plaintiff's Motion for Default Judgment; Correspondence to Court, supporting Affidavits, and Final Summary Judgment, forward same to client; Review executed Affidavit and invoices for unpaid account; Re-Calculate Pre-Judgment Interest (tetal principal claim) $37,716.50 x 18% x 5 months = $9,966.70 {total interest) (Sea: Prompt Pay Act §28.004); 0.5 {0} Telephon conference with client, status update and steps in defau udgment process and confirm account balance, review e-mails from client and executed affidavit; 0.4 {p) Review executed affidavit and invoices for unpaid account; file Plaintiff's Motion for Default Judgment. 5 “Due to the nature of this case, which includes: (a) its principal claim of $37,716.50 and total interest claim of $9,966.70 or a total c m of $47,683.20; {b) credits in the sum of §0.00 received after and as a Ces of cle filling and notice oc tie ATTORNEY'S FEE AFFIDAVIT Page 3 lawsuit with notice of Plaintiff's Original Petition, leaving a balance due and owing of $37,716.50; (c) the inherent or potential risk this judgment can not be collected and/or relating to defendant's real property, management company and/or its accounting; (d} the lack of any response after notice of filing suit; {e) the potential for other claims and/or lawsuit(s) which may exist against this property for unpaid amounts and/or invoices; (£) the time constraints imposed by the client; (g) the nature and length of the professional relationship with the client; (h) the amount of time and labor spent on the file and the amount in controversy; (i) the legal skills required; (j) the fee and market rate customarily charged for similar legal services; (k) the experience, reputation and ability of the attorney performing the services; {1} the responsibility imposed upon the attorney for the amounts herein and urgency of the matter; {m) and plaintiff's contingency fee contract arrangement; pursuant to 38.001, 38.003, 38.004 Civil Practice and Remedies Code, 28.005 (b) Texas Prompt Payment Act and/or 36.25 Texas Business and Commerce Code, the court may award costs and reasonable attorney's fees as the court determines equitable and just. Prompt Pay Act § 28.005(a) (b). Based upon the above, it is my opinion under the circumstances an hourly rate of $575.00 per hour is reasonable and necessary and a reasonable market rate; and therefore, a reasonable, necessary, usual and customary fees in this cause totals $10,000.00, with an additional war d of a war $2,500.00, relating to providing notice of and attending, if necessary, a hearing and taxable court costs of not less than $946.00. ATTORNEY’S FEE AFFIDAVIT Page 4 6 “With an additional award of $7,500.00 as attorney's fees in the event of an appeal to the First District Court of Appeals and $10,000.00 in the event a petition for review is filed at the Supreme Court of ‘Texas, with all post judgment attorney's fees contingent upon plaintiff being successful at each level. FURTHER AFFIANT SAITH NOT." —_—_- Timothy SWORN TO AND SUBSCRIBED BEFORE ME this olay of March, 2024. My commission expires: a — Go to www.irs.gov/FormW for instructions and the latest information. send to the IRS, Internat Revensie Service ‘your Inagmng tax relum). Napogis requ PETER This line blank. An = Mo 2 TAO ae ame Vf cillerent from above (CF OFT) ‘asthy 6 PLECTA 4 Exemptions (codes apply only to & | 9 Check appr te box for federal tax classification of the person whose name is entered ote) ‘Chack only one of the &8 fottowiny ven boxes, certain antities, not individuals; see ingtructions on page 2): iIndividuat/so'e propristoror (1 cecrperation C1] § Corporation D) Partnership CT trusvrestate ingle-member LU Exempt payee cude (if any) CO Limited tianitity campany, Enter the tax classification (C=C corporation, S=$ corporation, P:Partnership) * Nota: Check the sppropriete bax in the line above lor the tax classttication of the singla-member owner, Og not check Fxemption from FATCA reporting = LLG [f the LLC Is classified as a single-member LLC that is ded from the owner unless {he over af tha LLC is code (if any) another LUC that Is not disrogarded from the owner farU. S. federal tax purpos Otherwise, a single-membar LUC that — fs disregarded {rom the owner should check the appropriate box for the tax classification of its owner. Other (sae instructions) + {Aopen to accounts mantaned outwce hr US) Ai Ter's name and address (optional) #1, 6 Cw, © St. a4 sec 7 Ustaccount Kimier(s} here " oi IX 2s! G Taxpayer Identification Number {TIN} line 1 to avoid Social ity numbor Enter your TIN in the appropriate box. The TIN provided must match the name glven on backup withholding. For individuals, this is generally your social security number (SSN). However, for a resident alien, sole proprietor, or disregarded entity, see the Instructions for Part |, later. For other entities, it is your emptoyer identification number (FIN). Ii you do not have a number, see How to get a TIN, later. or Note: If the account Is In more than one name, see the instructions for line +. Also see What Name and [Employer Wentification number | Number Ta Give the Requester for guidelines on whose number to enter. 2 Certification Under penalties of perjury, | certify that: 1. The number shown on this form is my correct taxpayer identification number (or | am wailing for a numberto be issued to me); and have not bean notified by the Internal Revenue 2.1 am not subject to backup withholding be! use: (a) | am exempt from backup withholding, or {o)or | dividends, Service (IRS) that | am subj to baci up witl hholding as a result of a failure ta report ail interest or (c) the IRS has notified me that | am no longer subject to backup withholding; 3. 1am a U.S. citizen of other U.S. person (defined below}; and 4, The FATCA cadeys} entered on this form () any) indicating that | am exempt from FATGA reporting is correct. Certification instructions. You must orgss 0 1 item 2 above if you have been notifiad by the IRS that you are currently subject to backup withholding because mortgage interest paid, you have failsd to report ail interest and, ividends on your tax ratum, For real estate transactions, item 2 does not apply. Fer (IRA), ncellalion of debt, contributions to an individual retirement arrangemept \d generally, payments i acquisition or abandonment o} fg fe foroperty rude b\e (yo other than interest and dividend ren es ed gorsgn the certification, but you must promde your correct TIN. Sey the7. Insfuctions for Part i, later. Sign Here Signature of U.S. parson oor 9f | CY * Form 1099-DIV (dividends, inclu: Genera! Instructi ohs funds) Section references are to the Internal Rev a ode unless otherwise + Form 1099-MISC (various types of income, prizes, awards, or gross noted. proceeds) Future developments. For the latest Information about devolopments + Form 1099-8 (stock or mutual fund sales and certain other related to Form W-9 ani instructions, such as legislation enacted transactlons by brokers) after they were published, go to www. irs. ‘Forms. + Form 1099-S {proceeds from real estata transactions) Purpose of Form * Form 1099-K (merchant card and third parly network transactions) An individual or entity (Form W-9 requester) who is required to file an + Form 1098 (home mortgage interest), 1098-E (student loan Interest}, information return with the IRS must obtain your correct taxpayer 1098-T (tuition) identification number (TIN) which may be your social security number * Form 1099-C (canceled deb!) (SSN), individual taxpayer identi ification a it number {ITN}, adoption + Form 1089-A (acquisition or abandonment of secured property) taxpayer identification number { |. or employer identification number Use Form W-9 only if you are a U.S. person (including a resident {EIN}, te report on an informatio! return the amount aid to you, ar other amount repertable on an information return. Exam s of Information alien}, to provide your correct TIN. returns include, but are not limited to, the following. it you do not return Farm W-9 to the sequester with a TIN, you might + Form 1099-INT (interest eamed or paid) be subject to backup withholding. See What is backup withholding, tater. Cat, No, 10231X Form W-8 (Rev. 10-2018) NVOICE Sanchez Solutions 2736 Rolinda Dr Date 08/11/2023 Dallas, Texas 75211 Invaice:# 271, 469-209-2670 Bus Dato Upon Receipt Bill To Tides On Lara 3330 Webb Chapel Ext Dallas, Texas 75220 214-351-5205 item Quantity Unit Price Total 3303 HVAC 1 $4,300.00 84,800.00 Install new full HVAC system fram R22 to 410. In and outside system. This acl ies alltabar and materials. * Sub Total $4,300.00 Sales Tex 8.25% $384.76 Amount Due $4,654.75 Sanchez Solutions 2 738 736Rolinda Dr Dallas, Texas 75211 aay i Sanchezsolutionsag@gmail.cam 469-209-2670 Invoice INV273 Date ‘Oct 10, 2022 Bill to: Tides On Larga 3330 Webb Chapet Ext Dallas, Texas 75220 largamanager@robinsongroupre.com # Item Price Qty Totat at Unit #8110 Full Paint Of Unit And $580.60 $580.00 a = S Subtotal $580.00 Tax (8.26%) $47.85 GRAND TOTAL $627.85 Paid $0.00 DUE $627.85 Payment address Is 1251 Moulin Rouge #136 Dallas, Texas 75214 Sanchez Solutions 2738 Rolinda Dr Dallas, Texas 75211 an Sanchezsalutions33@gmail.com ! 469-209-2570 ce Invoice INV307 Date Oct 26, 2022 Bill to: Tides On Larga 3330 Webb Chapel Ext Dallas, Texas 75220 largamanager@sobinsongroupra.com # Item Price aty Total o1 Unit # 2209 Full Paint $340, Paint & $1,440.00 1 $1,440.00 Materials $350, (1) 4x8 Sheetrock Repair On Ceiling W/ Tape & Bed And Acoustic $750 aaa eee . ae ——— . Subtotai $1,440.00 Tax (8.25%) $118.60 GRAND TOTAL $1,558.80 Paid $0.00 DUE $1,558.80 Payment address is 1251 Moulin Rouge #436 Dalias, Texas 75211 Sanchez Solutions 2736 Aolinda Dr Dallas, Texas 75211 coats i ie Sanchezsolutions39@amail com : 469-209-2670 Invoice INV310 Date Oct 26, 2022 Bill to: Tides On Larga. 3330 Webb Chapel! Ext Dailas, Texas 75220 targamenager @rovinsongroupre.com # item Price aty Total o1 Unit #2208 Resurfacing Of Kitchan $445.00 1 $446.00 Counter & Bar $125, Resurface Bathroom Counter $50, Resurface Tub & Tile $176, Stripping $40, Resurlace Fireplace $60 — i ——— es a Subtotal 3445.00 Tax (8.25%) $36.75 GRAND TOTAL $481.71 Paid $0.00 DUE $481.71 Payment address is 1251 Moulin Rouge #436 Dallas. Texas 75217 Sanchez Solutions 736 Ronda Or Callas, Texas 75211 eat ee Sanchezsolutions39® gmail.com * 469-209-2670 Invoice INV311 Date Oct 26, 2022 il to: Tides On Larga 3330 Webb Chapel! Ext Gallas, Texas 75220 largamanager@robinsongroupre.com a Rem Price Qty Total oO Unit #2209 Make Ready (labor) 570.00 1 $570.00 $340 , Trashout $150, Housekeeping $80 = 7 Subtotal $570.00 Tax (8.25%) $47.03 GRAND TOTAL $617.02 Paid $0.00 DUE $617.02 Payment address is 1251 Moulin Rouge #136 Dallas, Texas 75241 Sanchez Solutions 2736 Rolinda Dr Dallas, Texas 75211 Rie Bait Sanchezsclutions39@gmail.com : $68-209-2670 Invoice INV313 Date Oct 26, 2022 Bilt to: Tides On Larga 3230 Webb Chapel Ext Datins, Texas 75220 largamanager@ robinsongroupre.com @ item Price ary Totat ot Unit #2209 Materials For $1,078.00 1 $1,079.00 Makersady (t) Ventahood $80, (2) Backsplash $100, (3) Dome Lights. $90 (1) Vanity Light $45, (2) Towel Bars $60, Shower Rot $15, (25) Light Switch Covers $32, (1) Ceiling Fan With Light $120, Repair Cabinet Doars & Drawers in Kitchen $300, (2) 24x72 Mini Blinds $120(1) 32x60 Mini Blind $50. 24 in Closet rerSer = = Sublotat $1,079.00 Tax (8.25%) $89.02 GRAND TOTAL $1,168.02 Paid $0.00 QUE $1,168.02 Payment address is 1251 Moulin Rouge #136 Dallas, Texas 75217 Sanchez Solutions 2736 Rolinda Or Dallas, Texas 75211 cont Sanchezsolutions39 @gmail com» 469-269-2670 Invoice INV314 Date Oct 26, 2022 Bill to: Tides On Larga 3330 Webb Chapel Ext Dallas, Texas 75220 largamanager@robinsongroupre.com # Stem Price aty Total 1 Unit #2209 Install 558 Sq Ft O1 Vinyl $1,476.00 1 $1,475.00 Plank Materiais Plus Glue $775, Labor For Install $700 This Includes labor and matenats = enon - ae ee eee Subtotal $1,476.00 ax (8.25%) $121.69 GRAND TOTAL $1,596.69 Paid $0.00 DUE $1,596.69 Payment address is 1251 Moulin Rouge #136 Dallas, Texas 75211 Sanchez Solutions 2736 Rofinda Or Dallas, Texas 75211 ce San ezsdlLtions39@gmail.com | 469-209-2670 Invoice INV315 Date Oct 26, 2022 Bill to: Tides On Large 3330 Webb Chapel Ext Dallas, Texas 75220 largamanager@rabinsongroupre.com # Item Price aly Total a1 Unit #6301 Fuil Paint $340, Paint $1.315.00 1 $1,515.00 $50, And Materials $350, Trashout $50, Housekeeping $80, Resurfacing Kitchen Counter & Bar $125, Resurface Tub & Tile $170, Stripping $40, Resurface Bathroom Counter $50, Resuriace Fireplace $60, (3) a pecaee 2x2 $250 ae = a Subtotal $1,515.00 Tax (8.25%) $124.99 GRAND TOTAL $1,639.99 Paid 30.06 DUE $1,639.99 Payment address is 1251 Moulin Rouge #136 Dallas, Texas 75214 Sanchez Solutions 2736 Rolinda Dr Oalias, Texas 75211 cra rales, Sanchezsolutions39@gmail.com . 469-208-2670 Invoice INV317 Date Oct 26, 2022 Gill to: Tides On Larga 8330 Webb Chapel Ext Dallas, Texas 75220 largamanagar@robinsongraupra.com # tem Price aty Total 01 Unit #6301 Makeraady Labor $350, $327.00 1 $827.00 (3) Dome Lights $90, (1) 3 Bulb Vanity Light $45, (2) Towel Holders ‘$60, (1) Shower Rod $25, (2) Smoke Alarms $28, (25) Light Switch Covers $32, Repair Kitchen Cabinets & Drawers $200 Subtotal $827.00 Tax (B.25%) $68.23 GRAND TOTAL $895.23 Paid $0.00 DUE $895.23 Payment address is 1251 Moulin Rouge #136 Dallas, Texas 75211 Sanchez Solutions 2736 Rotinda Dr Dallas, Texas 75211 ba oo Ee Sanchezsolulions3$@gmail com » 462-209-2670 Invoice INV318 Date Oct 26, 2022 Bill to: Tides On Larga 3330 Webb Chapel Ext Dallas, Texas 75220 largamanager@rabinsongroupra.com # item Price ay Total ot Unit #6301 Install 528 Sq Ft Vinyl $1,344.04 1 $1,344.04 Plank $686.04, Material. glue $658 Subtotal $1,344.04 Tax (8.25%) $110.88 GRAND TOTAL $1,454.92 Paid $0.00 DUE $1,454.92 Payment address is 1251 Moulin Rouge #136 Dallas, Texas 75211 Sanchez Solutions 2736 Aolinda Or Dallas, Texas 75214 Sa Sanchezsolutions39@qmail com . 469-209-2670 Invoice INV313 Date Oct 26, 2022 Bill to: Tides On Larga 3330 Webb Chapel Ext Dallas, Texas 75220 largamanager@rabinsongroupre.com # tem Price Qty Total | ot Unit # 8307 Resurfses Tub & Tile $230.00 t $230.00 5170, Resurface Fireplace $60 Subtotai $230.00 Tax (8.25%) $18.98 GRAND TOTAL $248.98 Paid $0.00 DUE $248.98 Payment address is 1251 Moulin Rouge #435 Dallas, Texas 75211 Sanchez Solutions 2736 Rolinda Dr Dallas, Texas 75211 bots Sere Sanchezsolutios39@gmail.com 469-709-2870 = Invoice INV320 Date Oct 26, 2022 Bill to: Tides On Larga 3330 Wabb Chape! Ext Dallas, Texas 75220 largamanager@ robinsongroupre.com # tem Price Qty Total o1 Unit #6212 Resurtace Tub & Tile $230.00 1 $290.00 $170, Resuriace Fiepiace $60 Subtotal $230.00 Tax (8.25%) $18.98 GRAND TOTAL $248.98 Paid $0.00 DUE $248.98 Payment address is 4251 Moulin Rouge #136 Dallas, Texas 75211 Sanchez Solutions 2736 Rolinda Dr Oallas. Texas 75211 aan ee Sanchezsolutions39 gmail.com } 469-209-2670 Invoice INV322 Date Oct 26, 2022 Bili to: Tidas On Larga 8330 Webb Chapel Exl Daflas, Texas 75220 largamanager @robinsongroupra.com # Item Price ary Total a1 Unit #2104 Resurface Tub & Tile a $230.00 230,00 $170, Resuriace Fireplace $60 - Subtotal $230.00 Tax (8.25%) $18.98 GRAND TOTAL $248.98 Paid $0.00 DUE $248.98 Payment adcress is 1251 Moulin Rouge #136 Dallas, Texas 75211 Sanchez Solutions 2736 Rolinda Dr Dallas. Texas 75211 Scat flies Sanchezsolutions39@ gmail.com | 469-209-7670 ‘2 CY \2 2) Invoice INV323 Date Oot 26, 2022 Bill to: Tides On Largo 3330 Wabb Chapel Ext Dallas, Texas 75220 larqamanager@robinsongraupre.com # Item Price Qty Total —— oF Unit # 7202 Resurface Tub & Tile $230.00 1 $230.00 $170 , Resurface Firaplace $60 Subtotal $230.00 Tax (6.26%) $18.98