On July 11, 2007 a
Party Statement
was filed
involving a dispute between
Deutsche Bank National Trust Company As Trustee Un,
and
Any And All Unknown Parties Claiming By Through Un,
Harwell, B Jason,
Hill, Tom Clay,
Tenant #1,
Tenant #2,
Tenant #3,
Tenant #4,
The Unknown Spouse Of B Jason Harwell,
for MORTGAGE FORECLOSURE - CIRCUIT
in the District Court of Sarasota County.
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IN THE CIRCUIT COURT OF THE TWELFTH JUDICIAL CIRCUIT
IN AND FOR SARASOTA COUNTY, FLORIDA
CIVIL ACTION
DEUTSCHE BANK NATIONAL TRUST COMPANY
AS TRUSTEE UNDER THE POOLING AND
SERVICING AGREEMENT SERIES
ITF INABS
2005-A,
Plaintiff,
CASE NO. 2007-CA-008059-NC
VS. DIVISION C
2 8 2
B JASON HARWELL , et al Pos 7
Defendant(s). $> 2K 3" > “
/ POF —
ON ' oO
oe OO pry LO 3
NOTICE OF FILING oh,
aft O) rm
Plaintiff, DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE UNDERTHEPORYING?
Q
AND SERVICING AGREEMENT SERIES ITF INABS 2005-A, gives Notice of Filing of Afidavi Re TID
Reasonable Attorney Fees.
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by the U.S. Mail this
day of October, 2007, to all parties on the attached service list
Florida Default Law Group, P.L.
P.O. Box 25018 4
Tampa, Florida 33622-5018
(813) 251-4¥Q6. -
By:
ANDREA D. PIDALA
FLORIDA BAR NO. 0022848
E. TYLER SAMSING
FLORIDA BAR NO. 0028380
FILE_NUMBER: F07022552
DOC_ID: M003100
i
jiliehaon /
LIN THE CIRCUIT COURT OF THE TWELFTH JUDICIAL CIRCUIT
IN AND FOR SARASOTA COUNTY, FLORIDA
CIVIL ACTION
DEUTSCHE BANK NATIONAL TRUST
COMPANY AS TRUSTEE UNDER THE
POOLING AND SERVICING AGREEMENT
SERIES ITF INABS 2005-A,
Plaintiff,
CASE NO.: 2007-CA-008059-NC
vs. DIVISION: C
B JASON HARWELL, et al,
Defendant(s).
/
AFFIDAVIT AS TO REASONABLE ATTORNEYS FEES
STATE OF FLORIDA S
COUNTY OF HILLSBOROUGH S
BEFORE ME, the undersigned authority, personally appeared Erin Collins Cullaro, who upon first being duly
sworn on oath, deposes and says:
I. I am an attorney at law duly authorized to practice in the State of Florida.
2. I have been active in the practice of law in Florida since September 22, 1995, and ] am personally
familiar with the fees usually allowed Plaintiffs for the services of their attorneys in suits of the kind and nature in which
this affidavit is to be filed.
3. 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.
4. I am 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.
5. In arriving at my opinion of the value of reasonable attorney's fees in this action, I have utilized and
considered the following criteria:
a. The time and labor required, the novelty, complexity and difficulty of the questions involved, and the
skill requisite to perform the legal services properly.
b. The likelihood that the acceptance of the particular employment will preclude other employment by
the lawyer.
FILE_NUMBER: F07022552 DOC_ID: M002300
| vn
|
INNc. The fee or rate of fee customarily charged in the locality for services of a comparable or similar
nature.
d. The amount involved and the results obtained.
The time limitations imposed by the client or by the circumstances.
The nature and length of the professional relationship with the client.
The experience, reputation and ability of the lawyer or lawyers performing the services.
sg mm o
Whether the fee is fixed or contingent.
6. Florida Default Law Group, P.L. does not keep records of its time while it represents the Plaintiff
pursuant to a flat fee arrangement; therefore, I have reviewed no specific time keeping records.
7. It is my opinion that a review of the actual foreclosure file of Florida Default Law Group, P.L. in this
case would be unnecessary and futile event. In my opinion, the specific steps and requirements for filing and
litigating a mortgage foreclosure action in the State of Florida dictate that under no circumstance could the fee
charged by Florida Default Law Group, P.L. be unreasonable; therefore, I have not reviewed the actual file in this
case.
8. Based upon my review as set forth, it is my opinion that a reasonable attorney's fee and paralegal fee
is $1,450.00.
FURTHER AFFIANT SA} UGHT.
a
ERJNYSOLLINS CULLARO
going instrument was subscrifed and swork to before-tye this FS day of
2007, by Brin Collins Cullarg~* osha RHnally known to me.
OFA POBEIC, State of Florida
My (Aartnission Expires:
INDYMAC-CONV-R-ejayska- F07022552Service List
B JASON HARWELL
8345 Bluffview Way
Colorado Springs, CO 80919
THE UNKNOWN SPOUSE OF B JASON HARWELL N/K/A CHRISTINE HARWELL
8345 Bluffview Way
Colorado Springs, CO 80919
TOM CLAY HILL
58 County Road 17
Kremmling, CO 80459-9630
Document Filed Date
October 09, 2007
Case Filing Date
July 11, 2007
Category
MORTGAGE FORECLOSURE - CIRCUIT
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IN THE CIRCUIT COURT OF THE TWELFTH JUDICIAL CIRCUIT IN AND FOR SARASOTA COUNTY, FLORIDA CIVIL ACTION DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE UNDER THE POOLING AND SERVICING AGREEMENT SERIES ITF INABS 2005-A, Plaintiff, CASE NO. 2007-CA-008059-NC VS. DIVISION C 2 8 2 B JASON HARWELL , et al Pos 7 Defendant(s). $> 2K 3" > “ / POF — ON ' oO oe OO pry LO 3 NOTICE OF FILING oh, aft O) rm Plaintiff, DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE UNDERTHEPORYING? Q AND SERVICING AGREEMENT SERIES ITF INABS 2005-A, gives Notice of Filing of Afidavi Re TID Reasonable Attorney Fees. I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by the U.S. Mail this day of October, 2007, to all parties on the attached service list Florida Default Law Group, P.L. P.O. Box 25018 4 Tampa, Florida 33622-5018 (813) 251-4¥Q6. - By: ANDREA D. PIDALA FLORIDA BAR NO. 0022848 E. TYLER SAMSING FLORIDA BAR NO. 0028380 FILE_NUMBER: F07022552 DOC_ID: M003100 i jiliehaon / LIN THE CIRCUIT COURT OF THE TWELFTH JUDICIAL CIRCUIT IN AND FOR SARASOTA COUNTY, FLORIDA CIVIL ACTION DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE UNDER THE POOLING AND SERVICING AGREEMENT SERIES ITF INABS 2005-A, Plaintiff, CASE NO.: 2007-CA-008059-NC vs. DIVISION: C B JASON HARWELL, et al, Defendant(s). / AFFIDAVIT AS TO REASONABLE ATTORNEYS FEES STATE OF FLORIDA S COUNTY OF HILLSBOROUGH S BEFORE ME, the undersigned authority, personally appeared Erin Collins Cullaro, who upon first being duly sworn on oath, deposes and says: I. I am an attorney at law duly authorized to practice in the State of Florida. 2. I have been active in the practice of law in Florida since September 22, 1995, and ] am personally familiar with the fees usually allowed Plaintiffs for the services of their attorneys in suits of the kind and nature in which this affidavit is to be filed. 3. 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. 4. I am 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. 5. In arriving at my opinion of the value of reasonable attorney's fees in this action, I have utilized and considered the following criteria: a. The time and labor required, the novelty, complexity and difficulty of the questions involved, and the skill requisite to perform the legal services properly. b. The likelihood that the acceptance of the particular employment will preclude other employment by the lawyer. FILE_NUMBER: F07022552 DOC_ID: M002300 | vn | INNc. The fee or rate of fee customarily charged in the locality for services of a comparable or similar nature. d. The amount involved and the results obtained. The time limitations imposed by the client or by the circumstances. The nature and length of the professional relationship with the client. The experience, reputation and ability of the lawyer or lawyers performing the services. sg mm o Whether the fee is fixed or contingent. 6. Florida Default Law Group, P.L. does not keep records of its time while it represents the Plaintiff pursuant to a flat fee arrangement; therefore, I have reviewed no specific time keeping records. 7. It is my opinion that a review of the actual foreclosure file of Florida Default Law Group, P.L. in this case would be unnecessary and futile event. In my opinion, the specific steps and requirements for filing and litigating a mortgage foreclosure action in the State of Florida dictate that under no circumstance could the fee charged by Florida Default Law Group, P.L. be unreasonable; therefore, I have not reviewed the actual file in this case. 8. Based upon my review as set forth, it is my opinion that a reasonable attorney's fee and paralegal fee is $1,450.00. FURTHER AFFIANT SA} UGHT. a ERJNYSOLLINS CULLARO going instrument was subscrifed and swork to before-tye this FS day of 2007, by Brin Collins Cullarg~* osha RHnally known to me. OFA POBEIC, State of Florida My (Aartnission Expires: INDYMAC-CONV-R-ejayska- F07022552Service List B JASON HARWELL 8345 Bluffview Way Colorado Springs, CO 80919 THE UNKNOWN SPOUSE OF B JASON HARWELL N/K/A CHRISTINE HARWELL 8345 Bluffview Way Colorado Springs, CO 80919 TOM CLAY HILL 58 County Road 17 Kremmling, CO 80459-9630