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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, oc 6B om
Plaintiff, Sinise SB
CASE NO. 2007-CA-008059-NC Go &
VS. DIVISION C Satie FE
C30 @ 2
B JASON HARWELL , et al, Som .
Defendant(s). Bes AP os
<2 = o> S
aS rp
NOTICE OF FILING “7S Oo
Plaintiff, DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE UNDER THE POOLING
AND SERVICING AGREEMENT SERIES ITF INABS 2005-A, gives Notice of Filing of Amended Affidavit of
Amended Affidavit of Plaintiff's Counsel as to Attorney's Fees and Costs.
Florida Default Law Group, P.L.
P.O. Box 25018
Tampa, Florida 33622-5018
(813) 251-4766
FEOKIDA BAR NO. 26139
DOC_ID: M003108
“TT
FILE_ NUMBER: F07022552
wit inf
vCiiliaenaenIN 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).
/
AMENDED AFFIDAVIT OF PLAINTIFF'S COUNSEL AS TO
ATTORNEY'S FEES AND COSTS
ON THIS DATE, before me, the undersigned authority, personally appeared Jonathan W. Mesker, who upon
being duly sworn, deposes and says as follows:
l. I am over the age of 21 and have personal knowledge of the matters set forth herein. I am an
attorney with the law firm of Florida Default Law Group, P.L. and represent our client in the above referenced
foreclosure action. As an attorney with this firm, I am familiar with the services rendered and all costs and expenses
incurred on behalf of our client in prosecuting this action.
2. This action is an uncontested residential mortgage foreclosure. In uncontested foreclosure actions,
the attorney and paralegals will perform, at a minimum, the following legal services:
A. Review Complaint, Summonses, Lis Pendens and Civil Cover Sheet;
B. Review returns of service and prepare motions for default, where applicable;
C. Where filed, review Answers and other pleadings;
D. Review loan documents and correspondence;
E. Review the motion for summary judgment, affidavit of indebtedness, affidavit in support of
Plaintiff's claim for fees and costs, affidavit in support of reasonableness of attorney's fees, notice of
FILE_NUMBER: F07022552 DOC_ID: M005402
CT INI ahearing, proposed final judgment, proposed notice of sale and final disposition form.
F. in the event this matter proceeds to sale, additional time will be incurred in preparing the bid and
ensuring that all requirements have been met to proceed to sale.
3. For all legal services performed in this uncontested residential foreclosure, Florida Default Law
Group, P.L. has agreed to charge, and this client has agreed to pay, a flat rate of $1,200.00. This represents our fee
agreement for prosecuting this type of loan in an uncontested residential foreclosure action. In the event the matter
becomes contested, Florida Default Law Group, P.L. has agreed to charge, and this client has agreed to pay, an
hourly fee up to $175.00 per hour for services related to the contested issues. In no event does Florida Default Law
Group, P.L. seek to recover attorney's fees greater than the amount billed to and paid by this client.
4, Florida Default Law Group, P.L. does not create any specific timekeeping records reflecting the
amount of time spent on an uncontested residential foreclosure due to this flat fee agreement and the administrative
costs that would result. The flat fee agreement was determined by taking into account many factors including, but
not limited to, the following: the time and labor reasonable expended by lawyers in the community handling
uncontested residential foreclosures; the complexity of the foreclosure action, the experience of Florida Default Law
Group, P.L. in handling these types of matters; the industry standard for this type of loan, which is the discounted
amount that this firm and our client have agreed to as a reasonable flat fee for each individual foreclosure action
given that our client will refer this firm similar type actions in the future; and current market conditions.
5. I am also familiar with the costs and expenses that Florida Default Law Group, P.L. incurred on
behalf of our client in this action. These costs and expenses are as follows:
COSTS:
A. Title Charges: $325.00
Title Search Fee $175.00
Title Examination Fee $150.00
B. Filing Fee 263.00
C. Investigation/Service of Process 570.00
(see attached invoice)
D. Publication Notice of Sale 220.00
TOTAL $1,378.006. The title search and exam cost includes amounts paid to third parties for data and information reviewed
for title purposes. New House Title, L.L.C is the title company utilized to perform the title work on this foreclosure
action. The owners of Florida Default Law Group, P.L. own New House Title, L.L.C.
FURTHER AFFIANT SAYETH NOT.
! i
DATED this | day of “Yy , 2008.
Florida Default Law Group, P.L.
P.O. Box 25018
W. Mésker
Florida Bar No. 805971
The forego}
instrument was sworn to and subscribed before me _ this LY day of
2008, by Jonathan W. Mesker, who is personally
aunbltides,
¢
a
=
ST, SHERI L. SATTERWHITE
a= MY COMMISSION # DD 506117
Bi
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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, oc 6B om Plaintiff, Sinise SB CASE NO. 2007-CA-008059-NC Go & VS. DIVISION C Satie FE C30 @ 2 B JASON HARWELL , et al, Som . Defendant(s). Bes AP os <2 = o> S aS rp NOTICE OF FILING “7S Oo Plaintiff, DEUTSCHE BANK NATIONAL TRUST COMPANY AS TRUSTEE UNDER THE POOLING AND SERVICING AGREEMENT SERIES ITF INABS 2005-A, gives Notice of Filing of Amended Affidavit of Amended Affidavit of Plaintiff's Counsel as to Attorney's Fees and Costs. Florida Default Law Group, P.L. P.O. Box 25018 Tampa, Florida 33622-5018 (813) 251-4766 FEOKIDA BAR NO. 26139 DOC_ID: M003108 “TT FILE_ NUMBER: F07022552 wit inf vCiiliaenaenIN 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). / AMENDED AFFIDAVIT OF PLAINTIFF'S COUNSEL AS TO ATTORNEY'S FEES AND COSTS ON THIS DATE, before me, the undersigned authority, personally appeared Jonathan W. Mesker, who upon being duly sworn, deposes and says as follows: l. I am over the age of 21 and have personal knowledge of the matters set forth herein. I am an attorney with the law firm of Florida Default Law Group, P.L. and represent our client in the above referenced foreclosure action. As an attorney with this firm, I am familiar with the services rendered and all costs and expenses incurred on behalf of our client in prosecuting this action. 2. This action is an uncontested residential mortgage foreclosure. In uncontested foreclosure actions, the attorney and paralegals will perform, at a minimum, the following legal services: A. Review Complaint, Summonses, Lis Pendens and Civil Cover Sheet; B. Review returns of service and prepare motions for default, where applicable; C. Where filed, review Answers and other pleadings; D. Review loan documents and correspondence; E. Review the motion for summary judgment, affidavit of indebtedness, affidavit in support of Plaintiff's claim for fees and costs, affidavit in support of reasonableness of attorney's fees, notice of FILE_NUMBER: F07022552 DOC_ID: M005402 CT INI ahearing, proposed final judgment, proposed notice of sale and final disposition form. F. in the event this matter proceeds to sale, additional time will be incurred in preparing the bid and ensuring that all requirements have been met to proceed to sale. 3. For all legal services performed in this uncontested residential foreclosure, Florida Default Law Group, P.L. has agreed to charge, and this client has agreed to pay, a flat rate of $1,200.00. This represents our fee agreement for prosecuting this type of loan in an uncontested residential foreclosure action. In the event the matter becomes contested, Florida Default Law Group, P.L. has agreed to charge, and this client has agreed to pay, an hourly fee up to $175.00 per hour for services related to the contested issues. In no event does Florida Default Law Group, P.L. seek to recover attorney's fees greater than the amount billed to and paid by this client. 4, Florida Default Law Group, P.L. does not create any specific timekeeping records reflecting the amount of time spent on an uncontested residential foreclosure due to this flat fee agreement and the administrative costs that would result. The flat fee agreement was determined by taking into account many factors including, but not limited to, the following: the time and labor reasonable expended by lawyers in the community handling uncontested residential foreclosures; the complexity of the foreclosure action, the experience of Florida Default Law Group, P.L. in handling these types of matters; the industry standard for this type of loan, which is the discounted amount that this firm and our client have agreed to as a reasonable flat fee for each individual foreclosure action given that our client will refer this firm similar type actions in the future; and current market conditions. 5. I am also familiar with the costs and expenses that Florida Default Law Group, P.L. incurred on behalf of our client in this action. These costs and expenses are as follows: COSTS: A. Title Charges: $325.00 Title Search Fee $175.00 Title Examination Fee $150.00 B. Filing Fee 263.00 C. Investigation/Service of Process 570.00 (see attached invoice) D. Publication Notice of Sale 220.00 TOTAL $1,378.006. The title search and exam cost includes amounts paid to third parties for data and information reviewed for title purposes. New House Title, L.L.C is the title company utilized to perform the title work on this foreclosure action. The owners of Florida Default Law Group, P.L. own New House Title, L.L.C. FURTHER AFFIANT SAYETH NOT. ! i DATED this | day of “Yy , 2008. Florida Default Law Group, P.L. P.O. Box 25018 W. Mésker Florida Bar No. 805971 The forego} instrument was sworn to and subscribed before me _ this LY day of 2008, by Jonathan W. Mesker, who is personally aunbltides, ¢ a = ST, SHERI L. SATTERWHITE a= MY COMMISSION # DD 506117 Bi