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IN THE CIRCUIT COURT OF THE TWELFTH JUDICIAL CIRCUIT
IN AND FOR SARASOTA COUNTY, FLORIDA
CIVIL ACTION
INDYMAC BANK, E.S.B.,
Plaintiff, CASE NO.: 2007-CA-008060-SC
VS. DIVISION: C
SLAVICA STOJANOVIC, et al,
Defendant(s).
/
NOTICE OF FILING
Plaintiff, INDYMAC BANK, F:S.B., gives Notice of Filing of Affidavit as to Reasonable Attorneys Fees.
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by U.S. Mail to all
parties listed on the attached service list on this A\ day of May, 2009.
Florida Default Law Group, P.L.
P.O. Box 25018
Tampa, Florida 33622-5018
(813) 251-4766
Julie Anthousis
Florida Bar No, 55337
ANAC A
10246432
Filed for Record 05/22/2009 10:21 AM - Karen E. Rushing, Clerk of the Circuit Court - Sarasota County, FL - 2007 CA 008060 SC Dkt-52045254 Page 1 of 4IN THE CIRCUIT COURT OF THE TWELFTH JUDICIAL CIRCUIT
IN AND FOR SARASOTA COUNTY, FLORIDA
CIVIL ACTION
INDY MAC BANK, F.S.B.,
Plaintiff,
CASE NO.: 2007-CA-008060-SC
vs. DIVISION: H
SLAVICA STOJANOVIC, et al,
Defendant(s).
/
AFFIDAVIT AS TO REASONABLE ATTORNEYS FEES
STATE OF FLORIDA S
COUNTY OF HILLSBOROUGH Ss
BEFORE ME, the undersigned authority, personally appeared Erin Collins Cullaro, who upon first being duly
sworn on oath, deposes and says:
1. 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 I 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 reasonabie
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.
c. 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.
FILE NUMBER: F07022547 DOC_ID: M002300
Filed for Record 05/22/2009 10:21 AM - Karen E. Rushing, Clerk of the Circuit Court - Sarasota County, FL - 2007 CA 008060 SC Dkt-52045254 Page 2 of 4f & é .. S&
|
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.
x ga rho
Whether the fee is fixed or contingent.
6. Echevarria, Codilis & Stawiarski 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 Echevarria, Codilis & Stawiarski 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 Echevarria, Codilis & Stawiarski 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 SAYETH NAUGHT.
RIN SOLLINSCULLARO
The Oi trument was subscribed 4 dn to before me this day of
, 2007, by Erin q \llaro whe pegsenally known to me.
ZA
NOTARY PUBLIC, State of Florida
My Commission Expires:
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Filed for Record 05/22/2009 10:21 AM - Karen E. Rushing, Clerk of the Circuit Court - Sarasota County, FL - 2007 CA 008060 SC Dkt-52045254 Page 3 of 4Service List
SLAVICA STOJANOVIC
2989 Sarletto St
North Port, FL 34287
MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INCORPORATED, AS NOMINEE FOR GMAC
MORTGAGE, LLC
3300 SW 34th Ave., Suite 101
Ocala, FL 34474
Filed for Record 05/22/2009 10:21 AM - Karen E. Rushing, Clerk of the Circuit Court - Sarasota County, FL - 2007 CA 008060 SC Dkt-52045254 Page 4 of 4
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IN THE CIRCUIT COURT OF THE TWELFTH JUDICIAL CIRCUIT IN AND FOR SARASOTA COUNTY, FLORIDA CIVIL ACTION INDYMAC BANK, E.S.B., Plaintiff, CASE NO.: 2007-CA-008060-SC VS. DIVISION: C SLAVICA STOJANOVIC, et al, Defendant(s). / NOTICE OF FILING Plaintiff, INDYMAC BANK, F:S.B., gives Notice of Filing of Affidavit as to Reasonable Attorneys Fees. I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by U.S. Mail to all parties listed on the attached service list on this A\ day of May, 2009. Florida Default Law Group, P.L. P.O. Box 25018 Tampa, Florida 33622-5018 (813) 251-4766 Julie Anthousis Florida Bar No, 55337 ANAC A 10246432 Filed for Record 05/22/2009 10:21 AM - Karen E. Rushing, Clerk of the Circuit Court - Sarasota County, FL - 2007 CA 008060 SC Dkt-52045254 Page 1 of 4IN THE CIRCUIT COURT OF THE TWELFTH JUDICIAL CIRCUIT IN AND FOR SARASOTA COUNTY, FLORIDA CIVIL ACTION INDY MAC BANK, F.S.B., Plaintiff, CASE NO.: 2007-CA-008060-SC vs. DIVISION: H SLAVICA STOJANOVIC, et al, Defendant(s). / AFFIDAVIT AS TO REASONABLE ATTORNEYS FEES STATE OF FLORIDA S COUNTY OF HILLSBOROUGH Ss BEFORE ME, the undersigned authority, personally appeared Erin Collins Cullaro, who upon first being duly sworn on oath, deposes and says: 1. 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 I 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 reasonabie 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. c. 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. FILE NUMBER: F07022547 DOC_ID: M002300 Filed for Record 05/22/2009 10:21 AM - Karen E. Rushing, Clerk of the Circuit Court - Sarasota County, FL - 2007 CA 008060 SC Dkt-52045254 Page 2 of 4f & é .. S& | 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. x ga rho Whether the fee is fixed or contingent. 6. Echevarria, Codilis & Stawiarski 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 Echevarria, Codilis & Stawiarski 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 Echevarria, Codilis & Stawiarski 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 SAYETH NAUGHT. RIN SOLLINSCULLARO The Oi trument was subscribed 4 dn to before me this day of , 2007, by Erin q \llaro whe pegsenally known to me. ZA NOTARY PUBLIC, State of Florida My Commission Expires: INDYMAC-CONV-R-ejayska- F07022547 ee pn vi “ches aS , ys : " a 4 sT'1? . ¢ 3 ‘ “57° 3 Dv . gs WO woe ‘, Le . Shey OP © 0. y Fey he EO TSH yuo i =a F Sait ge ™ Pog yy stk ge Filed for Record 05/22/2009 10:21 AM - Karen E. Rushing, Clerk of the Circuit Court - Sarasota County, FL - 2007 CA 008060 SC Dkt-52045254 Page 3 of 4Service List SLAVICA STOJANOVIC 2989 Sarletto St North Port, FL 34287 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INCORPORATED, AS NOMINEE FOR GMAC MORTGAGE, LLC 3300 SW 34th Ave., Suite 101 Ocala, FL 34474 Filed for Record 05/22/2009 10:21 AM - Karen E. Rushing, Clerk of the Circuit Court - Sarasota County, FL - 2007 CA 008060 SC Dkt-52045254 Page 4 of 4