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Filing # 130206550 E-Filed 07/07/2021 04:11:38 PM
IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT
CHARLOTTE COUNTY, FLORIDA
BABCOCK PROPERTY HOLDINGS, L.L.C.,
Plaintiff,
Case No. 19-CA-877
BANROC CORP; LEND -MORE, LLC; Judge Geoffrey H. Gentile
SOUTHWEST STRUCTURAL, INC; Complex Civil Litigation Action
FERGUSON ENTERPRISES, LLC alk/ a
Ferguson Enterprises, Inc.; HONC INDUSTRIES,
INC; TIJD Holdings, LLC d/b/a Gates
Construction; DRAKE READY MIX, INC;
UNKNOWN TENANTS AND POSSESSORS
Defendants.
LEND MORE, LLC,
Plaintiff,
BANROC CORP.;
SOUTHWEST
STRUCTURAL, INC;
CHANNEL MARK
CONSTRUCTION, INC.; O’NEILL
STRUCTURAL CONCRETE, INC.; FERGUSON
ENTERPRISES, INC; HONC INDUSTRIES,
INC; RAYMOND BUILDING SUPPLY, LLC;
SCOTT RYAN BUILDERS LLC; et al,
Defendants.
STIPULATION FOR ENTRY OF FINAL JUDGMENT ON ATTORNEY'S FEES AND
COSTS
COMES NOW the Defendant, SOUTHWEST STRUCTURAL, INC, and Defendant,
BANROC CORP., by and through their undersigned counsel and hereby agree and stipulate to the
following:
1 That the Defendant, SOUTHWEST STRUCTURAL, INC., was the prevailing party at the
Hearing held June 8, 2021, and as such Fla. Stat. 713 et al. requires fees and costs to be
assessed in favor of the prevailing party.
Parties agree that the Affidavits attached, Exhibit “A” and Exhibit “B” are reasonable and
Page 1 of 2
necessary time charged in the matter by SOUTHWEST STRUCTURAL, INC’s counsel and
that the hourly rate is reasonable.
Furthermore, the costs set forth in the affidavit are taxable against BANROC CORP.
Stipulated that the court shall outline an Order awarding Southwest Structural fees in the
amount of $15,263.00 and costs in the amount of $2,297.05, for a total amount of
$17,560.05,
B
Nabil Jj
Attorn
oh, Esq. ¥
for Banroc Corp.
ISR
Mieale Ka {yAa, Esl.
Attorney for ayes Esk Structural.
Florida Bar No.: 1012159 Florida Bar No: 472433
3411 Tamiami Trial N. 2077 First Street
Suite 100 Suite 201
Naples, Florida 34103 Fort Myers, Florida 33901
Page 2 of 2
IN THE CIRCUEE COURT OF THE TWENTIETH JUDICIAL CIRCUIT
CHARLOTTE COUNTY, FLORIDA
BABCOCK PROPERTY HOLDINGS, LLC,
Plaintiff,
¥. Case No. 19-CA-877
BANROC CORP; LEND MORE, LLC; Judge Geoffrey H. Gentile
SOUTHWEST STRUCTURAL, INC; Complex Civil Litigation Action
FERGUSON ENTERPRISES, LLC a/k/a
Fergusou Enterprises, Inc; HONC INDUSTRIES,
INC; TID Holdings, LLC d/b/a Gates
Construction; DRAKE READY MEX, INC;
UNKNOWN TENANTS AND POSSESSORS:
Defendants.
AND
aan
LEND MORE, LLC,
Plaintiff,
BANROC CORP. SOUTHWEST
STRUCTURAL,
INC; CHANNEL MARK.
CONSTRUCTION, INC.; O’NEILL
STRUCTURAL CONCRETE, INC.;
FERGUSON ENTERPRISES, INC; HONC
INDUSTRIES, INC; RAYMOND BUILDING
SUPPLY, LLC; SCOTT RYAN BUILDERS
LLG; etal,
Defendants.
ED. VIT ONABLE, % ES
STATE OF FLORIDA )
COUNTY OF LEB }
BEFORE ME, the undersigned authority, this day personally appeared
Mark Anderson, Esq.. who,
after being duly sworn, deposits and says as follows:
1 My name is Anderson,
Mark an attoruey with offices in Lee County, Florida,
2. J have been licensed to practice law in the State of Florida since_2603. I am. personally
familiar
with the fees chargedby attorneys in the State of Florida for civil action for damages
3. have considered the fees charged in light of my knowledge ofatiorney’s services required
in this type of case as well as fees charged generally therefore by attorneys in the State of Florida and in
this county. I have also considered the following:
@ The time and labor required:
EXHIBIT
® The novelty and difficulty of the questions involved and the skill requisite to
perform the services properly:
© ‘The likelihood that the acceptance of the particular employment will preclude other
employment by the person:
@ ‘The fee customarily charged in the locality for similar services:
© The amount invelved and the results obtained:
@ ‘The fine limitation imposed by the circumstances;
® ‘The nature and length of the professional relationship with this case; and
& The experience, diligence, and ability of the person performing the services.
4, Lam familiar with the Florida Supreme Court Decision of Florida Patients Fund v. Rowe,
472 So 2d 1145 (Fla. 1985), with respect to attorney's fees.
5. it is, therefore, my considered opinion as a practicing attomey in the State of Florida,
knowledgeable in the subject by training and experience, that a reasonable attorney’s fees
and costs in this cause is $17.560.05.
Wek ded
# Mark Anderson, Esq. 7
Florida Bar No;0631922
SWORN TO AND SUBSCRIBED before me this aa day of. Wh Wf , 2021
By Mark Anderson, who is personally known to me and who did take an oath.
petra
c(h
= % {Ox COMMISSION Z GG 178040
EXPIRES:
January 26, 2022
‘Borelstt
Thee Notary Patio
ae
Notary Public
My Commission expires:
. ~
IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT
CHARLOTTE COUNTY, FLORIDA
BABCOCK PROPERTY HOLDINGS, L.L.C.,
Plaintiff,
Case No, 19-CA-877
BANROC CORP; LEND MORE, LLC; Judge Geoffrey H. Gentile
SOUTHWEST STRUCTURAL, INC; Complex Civil Litigation Action
FERGUSON ENTERPRISES, LLC a/k/ a
Ferguson Enterprises, Inc.; HONC INDUSTRIES,
INC; TJD
Holdings, LLC d/b/a Gates
Construction; DRAKE READY MIX, INC;
UNKNOWN TENANTS AND POSSESSORS
Defendants.
LEND MORE, LLC,
Plaintiff,
BANROC SOUTHWEST
CORP.;
STRUCTURAL, INC;
CHANNEL MARK
CONSTRUCTION, INC.; O’NEILL
STRUCTURAL CONCRETE, INC.; FERGUSON
ENTERPRISES, INC; HONC INDUSTRIES,
INC; RAYMOND BUILDING SUPPLY, LLC;
SCOTT RYAN BUILDERS LLC; et al,
Defendants.
AFFIDAVIT OF FEES AND COSTS
STATE OF FLORIDA)
COUNTY OF LEE )
BEFORE ME, the undersigned authority, personally appeared MICHAEL F. KAYUSA,
who, after being first duly sworn, deposes and says:
1 My name is Michael F. Kayusa, and I am the attorney for Defendant,
SOUTHWEST STRUCTURAL, INC.
The attached is a list of fees and costs expended in the above captioned cause, to
wit. See Exhibit “A”.
FURTHER AFFIANT SAYETH NOT.
MICHAEL P/KAYUSA
EXHIBIT
Bh
SWORN TO AND SUBSCRIBED before me this AT “aay of June,
2021
By Michael F. Kayusa, who is personally known to me and who did take an oath.
Notary Peli
My Commission expires:
®
Notary Public State of Florida
Jessica
K Looper
icons Ss 267820
| — —— ST SSS
6/29/2021 MICHAEL F, KAYUSA
1:11 PM Slip Listing Page
4
Selection Criteria
Clie.Selection Include: SOUTHWEST STRUCTURAL*7055
Slip. Transaction Type Time
Slip.Classification Open
Rate Info - identifies rate source and level
Slip ID Attorey Units Rate Slip Value
Dates and Time Activity DNB Time Rate Info
Posting Status Client Bill Status
Description
76451 TIME KAYUSA - $250.00 0.16 250.00 40.00
7/15/2019 Other 0.00 c@i
Billed G:43260 6/17/2021 SOUTHWEST STRUCT
Office conference with Cody regarding three (3) liens.
76452 TIME KAYUSA - $250.00 4.25 250.00 313.00
7116/2019 Other 0.00 c@!
Billed G:43260 6/17/2021 SOUTHWEST STRUCT
Research property deed; Review documents;
Prepare lien.
76453 TIME KAYUSA - $250.00 0.08 250.00 20.00
7712019 Other 0,00 c@1
Billed G:43260 6/17/2021 SOUTHWEST STRUCT
Office conference with client regarding reviewing and
signing liens.
76454 TIME KAYUSA - $250.00 0,50 250.00 125.00
7/17/2019 Other 0.00 c@i
Billed G:43260 6/17/2021 SOUTHWEST STRUCT
Preparation of letter and all certified mail receipts to
all parties for lien.
76455 TIME KAYUSA - $250.00 0.10 250.00 25.00
7117/2019 Other 0.00 c@i
Billed G:43260 6/17/2021 SOUTHWEST STRUCT
Open new file,
76456 TIME KAYUSA - $250.00 0.05 250.00 13.00
7/22/2019 Other 0.00 c@1
Billed G:43260 6/17/2021 SOUTHWEST STRUCT
Certified mail receipt regarding lien on Pine Lily
signed for July 19, 2019; Copy of same sent to
client.
EXHIBIT
PA
6/29/2021 MICHAEL F. KAYUSA
4:11 PM Slip Listing Page 2
Slip ID Attorney Units Rate Slip Value
Dates and Time Activity DNB Time Rate Info
Posting Status Client Bill Status
Description
76457 TIME KAYUSA - $250.00 0.25 250.00 63.00
9/10/2019 Other 0.00 c@1
Billed G:43260 6/17/2021 SOUTHWEST STRUCT
Office conference with Cody.
76458 TIME KAYUSA - $250.00 2.00 250.00 500.00
9/16/2019 0.00 c@1
Billed G:43260 6/17/2021 SOUTHWEST STRUCT
Prepare Answer and Counter Claim; File with Court.
76459 TIME KAYUSA - $250.00 0.75 250.00 188.00
9/17/2019 Other 0.00 c@1
Billed G:43260 6/17/2021 SOUTHWEST STRUCT
Preparation of Notice of Filing Exhibits to Cross
Claim; Assemble Exhibits.
76460 TIME KAYUSA - $250.00 0.25 250.00 63.00
9/19/2019 Other 0.00 c@1
Billed G:43260 6/17/2021 SOUTHWEST STRUCT
Receive and review Plaintiffs notice of filing recorded
notice of lis pendens.
76461 TIME KAYUSA - $250.00 0.50 250.00 125.00
9/19/2019 Other 0.00 c@1
Billed G:43260 6/17/2021 SOUTHWEST STRUCT
Preparation of Lis Pendens.
76530 TIME KAYUSA - $250.00 4.00 250.00 250.00
9/20/2019 Other 0.00 c@1
Billed G:43260 6/17/2021 SOUTHWEST STRUCT
Office conference with client regarding new
complaint from Lend More.
76531 TIME KAYUSA - $250.00 0.50 250.00 125.00
9/20/2019 Other 0.00 c@1
Billed G:43260 6/17/2021 SOUTHWEST STRUCT
Receive and review complaint from Lend More.
76462 TIME KAYUSA - $250.00 0.50 250.00 125.00
9/27/2019 Other 0.00 c@1
Billed G:43260 6/17/2021 SOUTHWEST STRUCT
Preparation of letter to all parties; Certified to all
parties with enclosed Lis Pendens.
76463 TIME KAYUSA - $250.00 0.25 250.00 63.00
9/30/2019 Other 0.00 c@1
Billed G:43260 6/17/2021 SOUTHWEST STRUCT
Preparation of Notice of Filing; Notice of Lis
Pendens; File with the Clerk and forward to client.
6/29/2021 MICHAEL F. KAYUSA
4:11 PM Slip Listing Page 3
Slip ID Attomey Units Rate Slip Vatue
Dates and Time Activity DNB Time Rate Info
Posting Status Client Bill Status
Description
76532 TIME KAYUSA - $250.00 0.00 250.00 0.00
9/30/2019 Other 0.00 c@i
Billed G:43260 6/17/2021 SOUTHWEST STRUCT No Charge
Receive and review Town of Fort Myers Answer and
Affirmative Defenses to Lend More.
76533 TIME KAYUSA - $250.00 1.50 250.00 375.00
10/3/2019 Other 0.00 c@1
Billed G:43260 6/17/2021 SOUTHWEST STRUCT
Preparation of Answer and Affirmative Defenses
and Cross Claim to Lend More.
76534 TIME KAYUSA - $250.00 1.00 250.00 250.00
10/4/2019 Other 0.00 c@1
Billed G:43260 6/17/2021 SOUTHWEST STRUCT
Finalize Answer and Cross Claim and additional
exhibits.
76535 TIME KAYUSA - $250.00 0.50 250.00 125.00
10/7/2019 Other 0.00 c@1
Billed G:43260 6/17/2021 SOUTHWEST STRUCT
Recelve and review Banroc's Motion to Dismiss
Lend More's Complaint.
76536 TIME KAYUSA - $250.00 0.50 250.00 125.00
10/14/2019 Other 0.00 c@1
Billed G:43260 6/17/2021 SOUTHWEST STRUCT
Receive and review Plaintiffs response to our
Affirmative Defenses and Cross Claim; Prepare
reply to Plaintiffs response to our Affirmative
Defense and cross claim.
76537 TIME KAYUSA - $250.00 0.25 250.00 $3.00
10/14/2019 Other 0.00 c@1
Billed G:43260 6/17/2021 SOUTHWEST STRUCT
Receive and review Lend More's reply to Fergusons
Affirmative Defense and Honc's Affirmative Defense.
76464 TIME KAYUSA - $250.00 4.00 250.00 250.00
10/17/2019 Other 0.00 c@i
Billed G:43260 6/17/2021 SOUTHWEST STRUCT
Receive and review Babcock's amended complaint
and exhibits (over 700 pages).
76465 TIME KAYUSA - $250.00 0.25 250.00 63.00
11/6/2019 Other 0.00 c@1
Billed G:43260 6/17/2021 SOUTHWEST STRUCT
Correspondence with opposing counsel regarding
answer and affirmative defenses.
6/29/2021 MICHAEL F. KAYUSA
4:11 PM Slip Listing Page 4
SlipID Attomey Units Rate Slip Value
Dates and Time Activity DNB Time Rate Info
Posting Status Client Bill Status
Description
76538 TIME KAYUSA - $250.00 0.25 250.00 63.00
11/21/2019 Other 0.00 c@1
Billed G:43260 6/17/2021 SOUTHWEST STRUCT
Receive and review discovery from Hone to Banroc
and Lend More.
76466 TIME KAYUSA - $250.00 0.50 250.00 125.00
12/2/2019 Other 0.00 c@1
Billed G:43260 6/17/2021 SOUTHWEST STRUCT
Telephone conference with opposing counsel
regarding status of matter; Telephone conference
with client regarding same.
76467 TIME KAYUSA - $250.00 0.75 250.00 188.00
12/17/2019 Other 0.00 c@t
Billed G:43260 6/17/2021 SOUTHWEST STRUCT
Preparation of three (3) summons for Banroc, Hone
and Furguson.
76468 TIME KAYUSA - $250.00 0.75 250.00 188.00
12/26/2019 Other 0.00 c@i
Billed G:43260 6/17/2021 SOUTHWEST STRUCT
Prepare and file three (3) summons; Prepare
acceptance of service; Forward executed
summonses to process server with cross-claim.
76469 TIME KAYUSA - $250.00 1.00 250.00 250.00
1/21/2020 Other 0.00 c@1
Billed G:43260 6/17/2021 SOUTHWEST STRUCT
Hearing on Motion to Dissolve Lis Pendens and
Motion to Dismiss Amended Complaint with Judicial
Assistant.
76470 TIME KAYUSA - $250.00 0.25 250.00 63.00
2/10/2020 Other 0.00 c@1
Billed G:43260 6/17/2021 SOUTHWEST STRUCT
Telephone conference with Nabil Joseph regarding
possible setilement with all matters.
76471 TIME KAYUSA - $250.00 0.25 250.00 63.00
3/4/2020 Other 0.00 c@1
Billed G:43260 6/17/2021 SOUTHWEST STRUCT
Review documents - Case Management Plan and
Order.
76472 TIME KAYUSA - $250.00 0.25 250.00 63.00
3/12/2020 Other 0.00 c@i
Billed G:43260 6/17/2021 SOUTHWEST STRUCT
Multiple emails between parties with respect to
6/29/2021 MICHAEL F. KAYUSA
4:11 PM Slip Listing Page 5
Slip 1D Attomey Units Rate Slip Value
Dates and Time Activity DNB Time Rate Info
Posting Status Client Bill Status
Description
having case changed to complex matter, Review
documents - Stipulation Order regarding having
case heard as complex matter.
76473 TIME KAYUSA - $250.00 0.25 250.00 63.00
3/13/2020 Other 0.00 c@1
Billed G:43260 6/17/2021 SOUTHWEST STRUCT
Conference with all parties regarding complex case,
deadlines and joining Lendmore and Babcock
matters.
76539 TIME KAYUSA - $250. 00 0.25 250.00 63.00
3/16/2020 Other 0.00 c@t
Billed G:43260 8/17/2021 SOUTHWEST STRUCT
Receive and review various emails regarding Lend
More.
76474 TIME KAYUSA - $250.00 0.25 250.00 63.00
3/17/2020 Other 0.00 c@1
Billed G:43260 6/17/2021 SOUTHWEST STRUCT
Review documents - Stipulated Motion to Declare
Action Complex.
76475 TIME KAYUSA - $250.00 0.50 250.00 125.00
3/17/2020 Other 0.00 c@1
Billed G:43260 6/17/2021 SOUTHWEST STRUCT
Telephone conference with Court Call regarding
scheduling telephonic hearing.
76540 TIME KAYUSA - $250.00 0.25 250.00 63.00
3/17/2020 Other 0.00 c@1
Billed G:43260 6/17/2021 SOUTHWEST STRUCT
Receive and review email regarding March 19th
hearing.
76541 TIME KAYUSA - $250.00 0.25 250.00 63.00
3/18/2020 Other 0.00 c@1
illed G:43260 6/17/2021 SOUTHWEST STRUCT
Receive and review Notice of Dropping Party.
76542 TIME KAYUSA - $250.00 0.25 250.00 63.00
4/1/2020 Other 0.00 c@1
illed G:43260 6/17/2021 SOUTHWEST STRUCT
Receive and review report and recommendations of
general magistrate on case management
conference.
6/29/2021 MICHAEL F. KAYUSA
4:11 PM Slip Listing Page 6
Slip ID Attomey Units Rate Slip Value
Dates and Time Activity DNB Time Rate Info
Posting Status Client Bill Status
Description
76476 TIME KAYUSA ~ $250.00 0.25 250.00 63.00
5/11/2020 Other 0.00 c@1
Billed G:43260 6/17/2021 SOUTHWEST STRUCT
Receive and review court ordered initial case
management conference's joint statement.
76477 TIME KAYUSA - $250.00 0.50 250.00 125.00
5/13/2020 Other 0.00 c@1
Billed G:43260 6/17/2021 SOUTHWEST STRUCT
Various telephone conferences with all counsel on
matter to determine new court deadline; Receive
and review proposed joint statement with proposed
order on new deadlines.
76543 TIME KAYUSA - $250.00 0.25 250.00 63.00
5/18/2020 Other 0.00 c@i
Billed G:43260 6/17/2021 SOUTHWEST STRUCT
Receive and review court ordered initial case
management conference with Judge Porter; Notice
of Appearance from Murphy regarding Honc; Email
to Judge from opposing counsel Murphy regarding
not being available to attend case management
conference because of conflict.
76544 TIME KAYUSA - $250.00 0.25 250.00 $3,00
§/19/2020 Other 0.00 c@1
Billed G:43260 6/17/2021 SOUTHWEST STRUCT
Receive and review proposed joint statement in
compliance with complex rule.
76545 TIME KAYUSA - $250.00 0.25 250.00 63.00
5/26/2020 ther 0.00 c@1
Billed G:43260 6/17/2021 SOUTHWEST STRUCT
Agreed to joint statement in compliance with
complex rule submitted to Judge.
76546 TIME KAYUSA - $250.00 0.25 250.00 63.00
5/26/2020 Other 0.00 c@1
Billed G:43260 6/17/2021 SOUTHWEST STRUCT
Receive and review Lend More's dropping party -
Ferguson Enterprises.
76478 TIME KAYUSA - $250.00 0.25 250.00 63.00
6/1/2020 Other 0.00 c@1
Billed G:43260 6/17/2021 SOUTHWEST STRUCT
Attend hearing on initial case management
conference with Judge Porter.
6/29/2021 MICHAEL F. KAYUSA
4:11PM Slip Listing Page 7
Slip ID Attorney Units Rate Slip Value
Dates and Time Activity DNB Time Rate Info
Posting Status Client Bill Status
Description
76479 TIME KAYUSA - $250.00 0.75 250.00 188.00
6/2/2020 Other 0.00 c@i
Billed G:43260 6/17/2021 SOUTHWEST STRUCT
Receive and review agreed case management plan
and order, Calendar all deadlines.
76547 TIME KAYUSA - $250.00 0.25 250.00 63.00
6/15/2020 Other 0.00 c@1
Billed G:43260 6/17/2021 SOUTHWEST STRUCT
Attend Initial Case Management Conference via
zoom,
76480 TIME KAYUSA - $250.00 0.25 250.00 63.00
6/29/2020 Other 0.00 c@1
Billed G:43260 6/17/2021 SOUTHWEST STRUCT
Calendar all deadlines up to and until trial.
76548 TIME KAYUSA - $250.00 0.25 250.00 63.00
6/29/2020 Other 0.00 c@t
Billed G:43260 6/17/2021 SOUTHWEST STRUCT
Calendar all deadlines up to trial.
76481 TIME KAYUSA - $250.00 0.10 250.00 25.00
9/14/2020 Other 0.00 c@i
Billed G:43260 6/17/2021 SOUTHWEST STRUCT
Telephone conference with client regarding status of
case.
76549 TIME KAYUSA - $250.00 0.10 250.00 25.00
9/14/2020 Other 0.00 c@1
Billed G:43260 6/17/2021 SOUTHWEST STRUCT
Telephone conference with client regarding status of
case.
76482 TIME KAYUSA - $250.00 0.25 250.00 63.00
10/19/2020 Other 0.00 c@1
Billed G:43260 6/17/2021 SOUTHWEST STRUCT
Review documents - Stipulation and Order
Substitution of counsel.
76550 TIME KAYUSA - $250.00 0.25 250.00 63.00
10/19/2020 Other 0.00 c@i
Billed G:43260 6/17/2021 SOUTHWEST STRUCT
Review documents - Stipulation and Order for
Substitution of Counsel.
76483 TIME KAYUSA - $250.00 0.25 250.00 63.00
10/23/2020 Other 0.00 c@1
Billed G:43260 6/17/2021 SOUTHWEST STRUCT
6/29/2021 MICHAEL F. KAYUSA
1:11 PM Slip Listing Page 8
Slip ID Attomey Units Rate Slip Value
Dates and Time Activity DNB Time Rate Info
Posting Status Client
Description
Bill Status
Review documents - Order Granting Substitution of
Counsel,
76551 IME KAYUSA - $250.00 0.25 250.00 63.00
10/23/2020 Other 0.00 c@i
Billed G:43260 6/17/2021 SOUTHWEST STRUCT
Review document - Order Granting Substitution of
Counsel.
76552 TIME KAYUSA - $250.00 0.25 250.00 63.00
12/3/2020
Billed G:43260
Other 0.00 c@1
6/17/2021 SOUTHWEST STRUCT
Correspondence to Judicial Assistant for Judge
Gentile regarding Case Management Conference.
76484 TIME KAYUSA - $250.00 0.25 250.00 63.00
12/7/2020 Other 0.00 c@1
Billed G:43260 6/17/2021 SOUTHWEST STRUCT
Attend Case Management Conference.
76553 TIME KAYUSA - $250.00 0.25 250.00 63.00
12/7/2020 Other 0.00 c@1
Billed G:43260 6/17/2024 SOUTHWEST STRUCT
Attend Case Management Conference.
76554, TIME KAYUSA - $250.00 0.25 250.00 63.00
12/10/2020 Other 0.00 c@i
Billed G:43260 6/17/2021 SOUTHWEST STRUCT
Receive and review Order regarding Case
Management Conference; Forward to client.
76485 TIME KAYUSA - $250.00 0.25 250.00 63.00
12/15/2020 Other
Billed
0.00 c@i
G:43260 6/17/2021 SOUTHWEST STRUCT
Receive and review correspondence from opposing
counsel regarding amended complaint; Respond to
same.
76555 TIME KAYUSA - $250.00 0.25 250.00 63.00
12/16/2020 Other 0.00 c@i
Billed G:43260 6/17/2021 SOUTHWEST STRUCT
Receive and review Agreed Order on Defendant's
Motion to Dismiss.
76486 TIME KAYUSA - $250.00 0.25 250.00 63.00
12/17/2020 Other 0.00 c@1
Billed G:43260 6/17/2021 SOUTHWEST STRUCT
Receive and review correspondence from opposing
counsel regarding Motion for Leave to Amend;
6/29/2021 MICHAEL F, KAYUSA.
4:11 PM Slip Listing Page 9
Slip ID Attomey Units Rate Slip Value
Dates and Time Activity DNB Time Rate Info
Posting Status Client Bill Status
Description
Respond to same.
76487 TIME KAYUSA - $250.00 0.25 250.00 63.00
12/17/2020 0.00 c@i
Billed G:43260 6/17/2021 SOUTHWEST STRUCT
Correspondence to opposing counsel regarding
providing consent for motion to file.
76488 TIME KAYUSA - $250.00 0.25 250.00 63.00
12/22/2020 Other 0.00 c@1
Billed G:43260 6/17/2021 SOUTHWEST STRUCT
Receive and review correspondence from opposing
counsel regarding amended complaint; Receive and
review correspondence from opposing counsel
regarding answers to interrogatories.
76556 TIME KAYUSA - $250.00 0.25 250.00 63.00
4/11/2021 Other 0.00 c@1
Billed G:43260 6/17/2021 SOUTHWEST STRUCT
Receive and review amended complaint; Receive
and review amended notice of Lis Pendens.
76489 TIME KAYUSA - $250.00 0.25 250.00 63.00
1/14/2021 Other 0.00 Cc@1
Billed G:43260 6/17/2021 SOUTHWEST STRUCT
Receive and review Notice of Hearing; Calendar and
forward to client.
76557 TIME KAYUSA - $250.00 0.50 250.00 125.00
1/14/2021 Other 0.00 c@1
Billed G:43260 6/17/2021 SOUTHWEST STRUCT
Telephone conference with Attomey for Banroc
regarding upcoming events.
76558 TIME KAYUSA - $250.00 3.00 250.00 750.00
1/28/2021 Other 0.00 c@i
Billed G:43260 6/17/2021 SOUTHWEST STRUCT
Attend Deposition of Banroc's corporate
representative,
76559 TIME KAYUSA - $250.00 0.25 250.00 63.00
2/17/2021 Other 0.00 c@1
Billed G:43260 6/17/2021 SOUTHWEST STRUCT
Receive and review Motion to Consolidate from
opposing counsel.
76490 TIME KAYUSA - $250.00 0.25 250.00 63.00
3/1/2021 Other 0.00 c@1
Billed G:43260 6/17/2021 SOUTHWEST STRUCT
6/29/2021 MICHAEL F. KAYUSA
4:11 PM Slip Listing Page 10
Slip ID Attomey Units Rate Slip Value
Dates and Time Activity DNB Time Rate Info
Posting Status Client Bill Status
Description
Receive and review Defendant's Witness List;
Forward to client.
76560 TIME KAYUSA - $250.00 0.25 250.00 63.00
3/1/2021 Other 0.00 c@i
Billed G:43260 6/17/2021 SOUTHWEST STRUCT
Review documents - Defendant's Witness List;
Forward to client.
76491 TIME KAYUSA - $250,00 0.25 250.00 63.00
3/3/2021 Other 0.00 c@1
Billed G:43260 6/17/2021 SOUTHWEST STRUCT
Prepare our Disclosure of Fact Witnesses; Forward
to client; File with court.
76561 TIME KAYUSA - $250.00 0.25 250.00 63.00
3/3/2021 Other 0.00 c@1
Billed G:43260 6/17/2021 SOUTHWEST STRUCT
Prepare our Disclosure of Fact Witnesses; Forward
to client; File with Court.
76492 TIME KAYUSA - $250.00 0.25 250.00 63.00
3/8/2021 Other 0.00 c@i
Billed G:43260 6/17/2021 SOUTHWEST STRUCT
Receive and review correspondence from opposing
counsel regarding incomplete response to Banroc,
76493 TIME KAYUSA - $250.00 0.25 250.00 63.00
3/12/2021 Other 0.00 c@i
Billed G:43260 6/17/2021 SOUTHWEST STRUCT
Receive and review correspondence regarding
Mediation Deadline and Extension.
76494 TIME KAYUSA - $250.00 1.00 250.00 250.00
3/15/2021 Other 0.00 c@1
Billed G:43260 6/17/2021 SOUTHWEST STRUCT
Prepare Expert Witness List; File with Court and
forward to client.
76495, TIME KAYUSA - $250.00 0.25 250.00 63.00
3/17/2021 Other 0.00 c@1
Billed G:43260 6/17/2021 SOUTHWEST STRUCT
Correspondence with client confirming receipt of
requested documents.
76496 TIME KAYUSA - $250.00 0.25 250.00 63.00
3/17/2021 Other 0.00 c@1
Billed G:43260 6/17/2021 SOUTHWEST STRUCT
Correspondence with Court Reporter to obtain
——_-
6/29/2021 MICHAEL F. KAYUSA
4:11 PM Slip Listing Page 1
Slip ID Attomey Units Rate Slip Value
Dates and Time Activity DNB Time Rate Info
Posting Status Client Bill Status
Description
deposition transcript of Roland Bandinal.
76497 TIME KAYUSA - $250.00 0.25 250.00 63.00
3/19/2021 Other 0.00 c@1
Billed G:43260 6/17/2021 SOUTHWEST STRUCT
Correspondence with opposing counsel regarding
Motion for Summary Judgement.
76498 TIME KAYUSA - $250.00 2.00 250.00 500.00
3/22/2021 Other 0.00 Cc@i
Billed G:43260 6/17/2021 SOUTHWEST STRUCT
Preparation of Motion for Summary Judgement.
76499 TIME KAYUSA - $250.00 0.25 250.00 63,00
3/22/2021 Other 0.00 c@1
Billed G:43260 6/17/2021 SOUTHWEST STRUCT
Receive and review Notice of Hearing; Calendar and
forward to client;
76500 TIME KAYUSA - $250.00 0.25 250.00 63.00
3/22/2021 Other 0.00 c@i
Billed G:43260 6/17/2021 SOUTHWEST STRUCT
Receive and review Notice of Hearing on Banroc's
Motion to Dismiss.
76501 TIME KAYUSA - $250.00 1.00 250.00 250.00
3/24/2021 Other 0.00 c@1
Billed G:43260 6/17/2021 SOUTHWEST STRUCT
Preparation of Affidavit of Cody Griffith.
76502 TIME KAYUSA - $250.00 0.25 250.00 63.00
3/29/2021 Other 0.00 c@1
Billed G:43260 6/17/2021 SOUTHWEST STRUCT
Receive and review Notice of Voluntary Dismissal
as to Furguson Enterprises.
76503 TIME KAYUSA - $250.00 0.50 250.00 125.00
3/30/2021 Other 0.00 c@i
Billed G:43260 6/17/2021 SOUTHWEST STRUCT
Receive and review Proposed Order Consolidating
Case submitted to Judge Gentile.
76504 TIME KAYUSA - $250.00 0.50 250,00 125.00
3/31/2021 Other 0.00 c@t
Billed G:43260 6/17/2021 SOUTHWEST STRUCT
Obtain dates from the Judges calendar for hearing
on our motion for summary judgement;
Correspondence with all counsel regarding dates to
coordinate hearing.
ee
6/29/2021 MICHAEL F. KAYUSA
41:11 PM Slip Listing Page 12
Slip ID Attorney Units Rate Slip Value
Dates and Time Activity DNB Time Rate Info
Posting Status Client Bill Status
Description
76505 TIME KAYUSA - $250.00 0.25 250.00
Preview
Filing # 130206550 E-Filed 07/07/2021 04:11:38 PM IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT CHARLOTTE COUNTY, FLORIDA BABCOCK PROPERTY HOLDINGS, L.L.C., Plaintiff, Case No. 19-CA-877 BANROC CORP; LEND -MORE, LLC; Judge Geoffrey H. Gentile SOUTHWEST STRUCTURAL, INC; Complex Civil Litigation Action FERGUSON ENTERPRISES, LLC alk/ a Ferguson Enterprises, Inc.; HONC INDUSTRIES, INC; TIJD Holdings, LLC d/b/a Gates Construction; DRAKE READY MIX, INC; UNKNOWN TENANTS AND POSSESSORS Defendants. LEND MORE, LLC, Plaintiff, BANROC CORP.; SOUTHWEST STRUCTURAL, INC; CHANNEL MARK CONSTRUCTION, INC.; O’NEILL STRUCTURAL CONCRETE, INC.; FERGUSON ENTERPRISES, INC; HONC INDUSTRIES, INC; RAYMOND BUILDING SUPPLY, LLC; SCOTT RYAN BUILDERS LLC; et al, Defendants. STIPULATION FOR ENTRY OF FINAL JUDGMENT ON ATTORNEY'S FEES AND COSTS COMES NOW the Defendant, SOUTHWEST STRUCTURAL, INC, and Defendant, BANROC CORP., by and through their undersigned counsel and hereby agree and stipulate to the following: 1 That the Defendant, SOUTHWEST STRUCTURAL, INC., was the prevailing party at the Hearing held June 8, 2021, and as such Fla. Stat. 713 et al. requires fees and costs to be assessed in favor of the prevailing party. Parties agree that the Affidavits attached, Exhibit “A” and Exhibit “B” are reasonable and Page 1 of 2 necessary time charged in the matter by SOUTHWEST STRUCTURAL, INC’s counsel and that the hourly rate is reasonable. Furthermore, the costs set forth in the affidavit are taxable against BANROC CORP. Stipulated that the court shall outline an Order awarding Southwest Structural fees in the amount of $15,263.00 and costs in the amount of $2,297.05, for a total amount of $17,560.05, B Nabil Jj Attorn oh, Esq. ¥ for Banroc Corp. ISR Mieale Ka {yAa, Esl. Attorney for ayes Esk Structural. Florida Bar No.: 1012159 Florida Bar No: 472433 3411 Tamiami Trial N. 2077 First Street Suite 100 Suite 201 Naples, Florida 34103 Fort Myers, Florida 33901 Page 2 of 2 IN THE CIRCUEE COURT OF THE TWENTIETH JUDICIAL CIRCUIT CHARLOTTE COUNTY, FLORIDA BABCOCK PROPERTY HOLDINGS, LLC, Plaintiff, ¥. Case No. 19-CA-877 BANROC CORP; LEND MORE, LLC; Judge Geoffrey H. Gentile SOUTHWEST STRUCTURAL, INC; Complex Civil Litigation Action FERGUSON ENTERPRISES, LLC a/k/a Fergusou Enterprises, Inc; HONC INDUSTRIES, INC; TID Holdings, LLC d/b/a Gates Construction; DRAKE READY MEX, INC; UNKNOWN TENANTS AND POSSESSORS: Defendants. AND aan LEND MORE, LLC, Plaintiff, BANROC CORP. SOUTHWEST STRUCTURAL, INC; CHANNEL MARK. CONSTRUCTION, INC.; O’NEILL STRUCTURAL CONCRETE, INC.; FERGUSON ENTERPRISES, INC; HONC INDUSTRIES, INC; RAYMOND BUILDING SUPPLY, LLC; SCOTT RYAN BUILDERS LLG; etal, Defendants. ED. VIT ONABLE, % ES STATE OF FLORIDA ) COUNTY OF LEB } BEFORE ME, the undersigned authority, this day personally appeared Mark Anderson, Esq.. who, after being duly sworn, deposits and says as follows: 1 My name is Anderson, Mark an attoruey with offices in Lee County, Florida, 2. J have been licensed to practice law in the State of Florida since_2603. I am. personally familiar with the fees chargedby attorneys in the State of Florida for civil action for damages 3. have considered the fees charged in light of my knowledge ofatiorney’s services required in this type of case as well as fees charged generally therefore by attorneys in the State of Florida and in this county. I have also considered the following: @ The time and labor required: EXHIBIT ® The novelty and difficulty of the questions involved and the skill requisite to perform the services properly: © ‘The likelihood that the acceptance of the particular employment will preclude other employment by the person: @ ‘The fee customarily charged in the locality for similar services: © The amount invelved and the results obtained: @ ‘The fine limitation imposed by the circumstances; ® ‘The nature and length of the professional relationship with this case; and & The experience, diligence, and ability of the person performing the services. 4, Lam familiar with the Florida Supreme Court Decision of Florida Patients Fund v. Rowe, 472 So 2d 1145 (Fla. 1985), with respect to attorney's fees. 5. it is, therefore, my considered opinion as a practicing attomey in the State of Florida, knowledgeable in the subject by training and experience, that a reasonable attorney’s fees and costs in this cause is $17.560.05. Wek ded # Mark Anderson, Esq. 7 Florida Bar No;0631922 SWORN TO AND SUBSCRIBED before me this aa day of. Wh Wf , 2021 By Mark Anderson, who is personally known to me and who did take an oath. petra c(h = % {Ox COMMISSION Z GG 178040 EXPIRES: January 26, 2022 ‘Borelstt Thee Notary Patio ae Notary Public My Commission expires: . ~ IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT CHARLOTTE COUNTY, FLORIDA BABCOCK PROPERTY HOLDINGS, L.L.C., Plaintiff, Case No, 19-CA-877 BANROC CORP; LEND MORE, LLC; Judge Geoffrey H. Gentile SOUTHWEST STRUCTURAL, INC; Complex Civil Litigation Action FERGUSON ENTERPRISES, LLC a/k/ a Ferguson Enterprises, Inc.; HONC INDUSTRIES, INC; TJD Holdings, LLC d/b/a Gates Construction; DRAKE READY MIX, INC; UNKNOWN TENANTS AND POSSESSORS Defendants. LEND MORE, LLC, Plaintiff, BANROC SOUTHWEST CORP.; STRUCTURAL, INC; CHANNEL MARK CONSTRUCTION, INC.; O’NEILL STRUCTURAL CONCRETE, INC.; FERGUSON ENTERPRISES, INC; HONC INDUSTRIES, INC; RAYMOND BUILDING SUPPLY, LLC; SCOTT RYAN BUILDERS LLC; et al, Defendants. AFFIDAVIT OF FEES AND COSTS STATE OF FLORIDA) COUNTY OF LEE ) BEFORE ME, the undersigned authority, personally appeared MICHAEL F. KAYUSA, who, after being first duly sworn, deposes and says: 1 My name is Michael F. Kayusa, and I am the attorney for Defendant, SOUTHWEST STRUCTURAL, INC. The attached is a list of fees and costs expended in the above captioned cause, to wit. See Exhibit “A”. FURTHER AFFIANT SAYETH NOT. MICHAEL P/KAYUSA EXHIBIT Bh SWORN TO AND SUBSCRIBED before me this AT “aay of June, 2021 By Michael F. Kayusa, who is personally known to me and who did take an oath. Notary Peli My Commission expires: ® Notary Public State of Florida Jessica K Looper icons Ss 267820 | — —— ST SSS 6/29/2021 MICHAEL F, KAYUSA 1:11 PM Slip Listing Page 4 Selection Criteria Clie.Selection Include: SOUTHWEST STRUCTURAL*7055 Slip. Transaction Type Time Slip.Classification Open Rate Info - identifies rate source and level Slip ID Attorey Units Rate Slip Value Dates and Time Activity DNB Time Rate Info Posting Status Client Bill Status Description 76451 TIME KAYUSA - $250.00 0.16 250.00 40.00 7/15/2019 Other 0.00 c@i Billed G:43260 6/17/2021 SOUTHWEST STRUCT Office conference with Cody regarding three (3) liens. 76452 TIME KAYUSA - $250.00 4.25 250.00 313.00 7116/2019 Other 0.00 c@! Billed G:43260 6/17/2021 SOUTHWEST STRUCT Research property deed; Review documents; Prepare lien. 76453 TIME KAYUSA - $250.00 0.08 250.00 20.00 7712019 Other 0,00 c@1 Billed G:43260 6/17/2021 SOUTHWEST STRUCT Office conference with client regarding reviewing and signing liens. 76454 TIME KAYUSA - $250.00 0,50 250.00 125.00 7/17/2019 Other 0.00 c@i Billed G:43260 6/17/2021 SOUTHWEST STRUCT Preparation of letter and all certified mail receipts to all parties for lien. 76455 TIME KAYUSA - $250.00 0.10 250.00 25.00 7117/2019 Other 0.00 c@i Billed G:43260 6/17/2021 SOUTHWEST STRUCT Open new file, 76456 TIME KAYUSA - $250.00 0.05 250.00 13.00 7/22/2019 Other 0.00 c@1 Billed G:43260 6/17/2021 SOUTHWEST STRUCT Certified mail receipt regarding lien on Pine Lily signed for July 19, 2019; Copy of same sent to client. EXHIBIT PA 6/29/2021 MICHAEL F. KAYUSA 4:11 PM Slip Listing Page 2 Slip ID Attorney Units Rate Slip Value Dates and Time Activity DNB Time Rate Info Posting Status Client Bill Status Description 76457 TIME KAYUSA - $250.00 0.25 250.00 63.00 9/10/2019 Other 0.00 c@1 Billed G:43260 6/17/2021 SOUTHWEST STRUCT Office conference with Cody. 76458 TIME KAYUSA - $250.00 2.00 250.00 500.00 9/16/2019 0.00 c@1 Billed G:43260 6/17/2021 SOUTHWEST STRUCT Prepare Answer and Counter Claim; File with Court. 76459 TIME KAYUSA - $250.00 0.75 250.00 188.00 9/17/2019 Other 0.00 c@1 Billed G:43260 6/17/2021 SOUTHWEST STRUCT Preparation of Notice of Filing Exhibits to Cross Claim; Assemble Exhibits. 76460 TIME KAYUSA - $250.00 0.25 250.00 63.00 9/19/2019 Other 0.00 c@1 Billed G:43260 6/17/2021 SOUTHWEST STRUCT Receive and review Plaintiffs notice of filing recorded notice of lis pendens. 76461 TIME KAYUSA - $250.00 0.50 250.00 125.00 9/19/2019 Other 0.00 c@1 Billed G:43260 6/17/2021 SOUTHWEST STRUCT Preparation of Lis Pendens. 76530 TIME KAYUSA - $250.00 4.00 250.00 250.00 9/20/2019 Other 0.00 c@1 Billed G:43260 6/17/2021 SOUTHWEST STRUCT Office conference with client regarding new complaint from Lend More. 76531 TIME KAYUSA - $250.00 0.50 250.00 125.00 9/20/2019 Other 0.00 c@1 Billed G:43260 6/17/2021 SOUTHWEST STRUCT Receive and review complaint from Lend More. 76462 TIME KAYUSA - $250.00 0.50 250.00 125.00 9/27/2019 Other 0.00 c@1 Billed G:43260 6/17/2021 SOUTHWEST STRUCT Preparation of letter to all parties; Certified to all parties with enclosed Lis Pendens. 76463 TIME KAYUSA - $250.00 0.25 250.00 63.00 9/30/2019 Other 0.00 c@1 Billed G:43260 6/17/2021 SOUTHWEST STRUCT Preparation of Notice of Filing; Notice of Lis Pendens; File with the Clerk and forward to client. 6/29/2021 MICHAEL F. KAYUSA 4:11 PM Slip Listing Page 3 Slip ID Attomey Units Rate Slip Vatue Dates and Time Activity DNB Time Rate Info Posting Status Client Bill Status Description 76532 TIME KAYUSA - $250.00 0.00 250.00 0.00 9/30/2019 Other 0.00 c@i Billed G:43260 6/17/2021 SOUTHWEST STRUCT No Charge Receive and review Town of Fort Myers Answer and Affirmative Defenses to Lend More. 76533 TIME KAYUSA - $250.00 1.50 250.00 375.00 10/3/2019 Other 0.00 c@1 Billed G:43260 6/17/2021 SOUTHWEST STRUCT Preparation of Answer and Affirmative Defenses and Cross Claim to Lend More. 76534 TIME KAYUSA - $250.00 1.00 250.00 250.00 10/4/2019 Other 0.00 c@1 Billed G:43260 6/17/2021 SOUTHWEST STRUCT Finalize Answer and Cross Claim and additional exhibits. 76535 TIME KAYUSA - $250.00 0.50 250.00 125.00 10/7/2019 Other 0.00 c@1 Billed G:43260 6/17/2021 SOUTHWEST STRUCT Recelve and review Banroc's Motion to Dismiss Lend More's Complaint. 76536 TIME KAYUSA - $250.00 0.50 250.00 125.00 10/14/2019 Other 0.00 c@1 Billed G:43260 6/17/2021 SOUTHWEST STRUCT Receive and review Plaintiffs response to our Affirmative Defenses and Cross Claim; Prepare reply to Plaintiffs response to our Affirmative Defense and cross claim. 76537 TIME KAYUSA - $250.00 0.25 250.00 $3.00 10/14/2019 Other 0.00 c@1 Billed G:43260 6/17/2021 SOUTHWEST STRUCT Receive and review Lend More's reply to Fergusons Affirmative Defense and Honc's Affirmative Defense. 76464 TIME KAYUSA - $250.00 4.00 250.00 250.00 10/17/2019 Other 0.00 c@i Billed G:43260 6/17/2021 SOUTHWEST STRUCT Receive and review Babcock's amended complaint and exhibits (over 700 pages). 76465 TIME KAYUSA - $250.00 0.25 250.00 63.00 11/6/2019 Other 0.00 c@1 Billed G:43260 6/17/2021 SOUTHWEST STRUCT Correspondence with opposing counsel regarding answer and affirmative defenses. 6/29/2021 MICHAEL F. KAYUSA 4:11 PM Slip Listing Page 4 SlipID Attomey Units Rate Slip Value Dates and Time Activity DNB Time Rate Info Posting Status Client Bill Status Description 76538 TIME KAYUSA - $250.00 0.25 250.00 63.00 11/21/2019 Other 0.00 c@1 Billed G:43260 6/17/2021 SOUTHWEST STRUCT Receive and review discovery from Hone to Banroc and Lend More. 76466 TIME KAYUSA - $250.00 0.50 250.00 125.00 12/2/2019 Other 0.00 c@1 Billed G:43260 6/17/2021 SOUTHWEST STRUCT Telephone conference with opposing counsel regarding status of matter; Telephone conference with client regarding same. 76467 TIME KAYUSA - $250.00 0.75 250.00 188.00 12/17/2019 Other 0.00 c@t Billed G:43260 6/17/2021 SOUTHWEST STRUCT Preparation of three (3) summons for Banroc, Hone and Furguson. 76468 TIME KAYUSA - $250.00 0.75 250.00 188.00 12/26/2019 Other 0.00 c@i Billed G:43260 6/17/2021 SOUTHWEST STRUCT Prepare and file three (3) summons; Prepare acceptance of service; Forward executed summonses to process server with cross-claim. 76469 TIME KAYUSA - $250.00 1.00 250.00 250.00 1/21/2020 Other 0.00 c@1 Billed G:43260 6/17/2021 SOUTHWEST STRUCT Hearing on Motion to Dissolve Lis Pendens and Motion to Dismiss Amended Complaint with Judicial Assistant. 76470 TIME KAYUSA - $250.00 0.25 250.00 63.00 2/10/2020 Other 0.00 c@1 Billed G:43260 6/17/2021 SOUTHWEST STRUCT Telephone conference with Nabil Joseph regarding possible setilement with all matters. 76471 TIME KAYUSA - $250.00 0.25 250.00 63.00 3/4/2020 Other 0.00 c@1 Billed G:43260 6/17/2021 SOUTHWEST STRUCT Review documents - Case Management Plan and Order. 76472 TIME KAYUSA - $250.00 0.25 250.00 63.00 3/12/2020 Other 0.00 c@i Billed G:43260 6/17/2021 SOUTHWEST STRUCT Multiple emails between parties with respect to 6/29/2021 MICHAEL F. KAYUSA 4:11 PM Slip Listing Page 5 Slip 1D Attomey Units Rate Slip Value Dates and Time Activity DNB Time Rate Info Posting Status Client Bill Status Description having case changed to complex matter, Review documents - Stipulation Order regarding having case heard as complex matter. 76473 TIME KAYUSA - $250.00 0.25 250.00 63.00 3/13/2020 Other 0.00 c@1 Billed G:43260 6/17/2021 SOUTHWEST STRUCT Conference with all parties regarding complex case, deadlines and joining Lendmore and Babcock matters. 76539 TIME KAYUSA - $250. 00 0.25 250.00 63.00 3/16/2020 Other 0.00 c@t Billed G:43260 8/17/2021 SOUTHWEST STRUCT Receive and review various emails regarding Lend More. 76474 TIME KAYUSA - $250.00 0.25 250.00 63.00 3/17/2020 Other 0.00 c@1 Billed G:43260 6/17/2021 SOUTHWEST STRUCT Review documents - Stipulated Motion to Declare Action Complex. 76475 TIME KAYUSA - $250.00 0.50 250.00 125.00 3/17/2020 Other 0.00 c@1 Billed G:43260 6/17/2021 SOUTHWEST STRUCT Telephone conference with Court Call regarding scheduling telephonic hearing. 76540 TIME KAYUSA - $250.00 0.25 250.00 63.00 3/17/2020 Other 0.00 c@1 Billed G:43260 6/17/2021 SOUTHWEST STRUCT Receive and review email regarding March 19th hearing. 76541 TIME KAYUSA - $250.00 0.25 250.00 63.00 3/18/2020 Other 0.00 c@1 illed G:43260 6/17/2021 SOUTHWEST STRUCT Receive and review Notice of Dropping Party. 76542 TIME KAYUSA - $250.00 0.25 250.00 63.00 4/1/2020 Other 0.00 c@1 illed G:43260 6/17/2021 SOUTHWEST STRUCT Receive and review report and recommendations of general magistrate on case management conference. 6/29/2021 MICHAEL F. KAYUSA 4:11 PM Slip Listing Page 6 Slip ID Attomey Units Rate Slip Value Dates and Time Activity DNB Time Rate Info Posting Status Client Bill Status Description 76476 TIME KAYUSA ~ $250.00 0.25 250.00 63.00 5/11/2020 Other 0.00 c@1 Billed G:43260 6/17/2021 SOUTHWEST STRUCT Receive and review court ordered initial case management conference's joint statement. 76477 TIME KAYUSA - $250.00 0.50 250.00 125.00 5/13/2020 Other 0.00 c@1 Billed G:43260 6/17/2021 SOUTHWEST STRUCT Various telephone conferences with all counsel on matter to determine new court deadline; Receive and review proposed joint statement with proposed order on new deadlines. 76543 TIME KAYUSA - $250.00 0.25 250.00 63.00 5/18/2020 Other 0.00 c@i Billed G:43260 6/17/2021 SOUTHWEST STRUCT Receive and review court ordered initial case management conference with Judge Porter; Notice of Appearance from Murphy regarding Honc; Email to Judge from opposing counsel Murphy regarding not being available to attend case management conference because of conflict. 76544 TIME KAYUSA - $250.00 0.25 250.00 $3,00 §/19/2020 Other 0.00 c@1 Billed G:43260 6/17/2021 SOUTHWEST STRUCT Receive and review proposed joint statement in compliance with complex rule. 76545 TIME KAYUSA - $250.00 0.25 250.00 63.00 5/26/2020 ther 0.00 c@1 Billed G:43260 6/17/2021 SOUTHWEST STRUCT Agreed to joint statement in compliance with complex rule submitted to Judge. 76546 TIME KAYUSA - $250.00 0.25 250.00 63.00 5/26/2020 Other 0.00 c@1 Billed G:43260 6/17/2021 SOUTHWEST STRUCT Receive and review Lend More's dropping party - Ferguson Enterprises. 76478 TIME KAYUSA - $250.00 0.25 250.00 63.00 6/1/2020 Other 0.00 c@1 Billed G:43260 6/17/2021 SOUTHWEST STRUCT Attend hearing on initial case management conference with Judge Porter. 6/29/2021 MICHAEL F. KAYUSA 4:11PM Slip Listing Page 7 Slip ID Attorney Units Rate Slip Value Dates and Time Activity DNB Time Rate Info Posting Status Client Bill Status Description 76479 TIME KAYUSA - $250.00 0.75 250.00 188.00 6/2/2020 Other 0.00 c@i Billed G:43260 6/17/2021 SOUTHWEST STRUCT Receive and review agreed case management plan and order, Calendar all deadlines. 76547 TIME KAYUSA - $250.00 0.25 250.00 63.00 6/15/2020 Other 0.00 c@1 Billed G:43260 6/17/2021 SOUTHWEST STRUCT Attend Initial Case Management Conference via zoom, 76480 TIME KAYUSA - $250.00 0.25 250.00 63.00 6/29/2020 Other 0.00 c@1 Billed G:43260 6/17/2021 SOUTHWEST STRUCT Calendar all deadlines up to and until trial. 76548 TIME KAYUSA - $250.00 0.25 250.00 63.00 6/29/2020 Other 0.00 c@t Billed G:43260 6/17/2021 SOUTHWEST STRUCT Calendar all deadlines up to trial. 76481 TIME KAYUSA - $250.00 0.10 250.00 25.00 9/14/2020 Other 0.00 c@i Billed G:43260 6/17/2021 SOUTHWEST STRUCT Telephone conference with client regarding status of case. 76549 TIME KAYUSA - $250.00 0.10 250.00 25.00 9/14/2020 Other 0.00 c@1 Billed G:43260 6/17/2021 SOUTHWEST STRUCT Telephone conference with client regarding status of case. 76482 TIME KAYUSA - $250.00 0.25 250.00 63.00 10/19/2020 Other 0.00 c@1 Billed G:43260 6/17/2021 SOUTHWEST STRUCT Review documents - Stipulation and Order Substitution of counsel. 76550 TIME KAYUSA - $250.00 0.25 250.00 63.00 10/19/2020 Other 0.00 c@i Billed G:43260 6/17/2021 SOUTHWEST STRUCT Review documents - Stipulation and Order for Substitution of Counsel. 76483 TIME KAYUSA - $250.00 0.25 250.00 63.00 10/23/2020 Other 0.00 c@1 Billed G:43260 6/17/2021 SOUTHWEST STRUCT 6/29/2021 MICHAEL F. KAYUSA 1:11 PM Slip Listing Page 8 Slip ID Attomey Units Rate Slip Value Dates and Time Activity DNB Time Rate Info Posting Status Client Description Bill Status Review documents - Order Granting Substitution of Counsel, 76551 IME KAYUSA - $250.00 0.25 250.00 63.00 10/23/2020 Other 0.00 c@i Billed G:43260 6/17/2021 SOUTHWEST STRUCT Review document - Order Granting Substitution of Counsel. 76552 TIME KAYUSA - $250.00 0.25 250.00 63.00 12/3/2020 Billed G:43260 Other 0.00 c@1 6/17/2021 SOUTHWEST STRUCT Correspondence to Judicial Assistant for Judge Gentile regarding Case Management Conference. 76484 TIME KAYUSA - $250.00 0.25 250.00 63.00 12/7/2020 Other 0.00 c@1 Billed G:43260 6/17/2021 SOUTHWEST STRUCT Attend Case Management Conference. 76553 TIME KAYUSA - $250.00 0.25 250.00 63.00 12/7/2020 Other 0.00 c@1 Billed G:43260 6/17/2024 SOUTHWEST STRUCT Attend Case Management Conference. 76554, TIME KAYUSA - $250.00 0.25 250.00 63.00 12/10/2020 Other 0.00 c@i Billed G:43260 6/17/2021 SOUTHWEST STRUCT Receive and review Order regarding Case Management Conference; Forward to client. 76485 TIME KAYUSA - $250.00 0.25 250.00 63.00 12/15/2020 Other Billed 0.00 c@i G:43260 6/17/2021 SOUTHWEST STRUCT Receive and review correspondence from opposing counsel regarding amended complaint; Respond to same. 76555 TIME KAYUSA - $250.00 0.25 250.00 63.00 12/16/2020 Other 0.00 c@i Billed G:43260 6/17/2021 SOUTHWEST STRUCT Receive and review Agreed Order on Defendant's Motion to Dismiss. 76486 TIME KAYUSA - $250.00 0.25 250.00 63.00 12/17/2020 Other 0.00 c@1 Billed G:43260 6/17/2021 SOUTHWEST STRUCT Receive and review correspondence from opposing counsel regarding Motion for Leave to Amend; 6/29/2021 MICHAEL F, KAYUSA. 4:11 PM Slip Listing Page 9 Slip ID Attomey Units Rate Slip Value Dates and Time Activity DNB Time Rate Info Posting Status Client Bill Status Description Respond to same. 76487 TIME KAYUSA - $250.00 0.25 250.00 63.00 12/17/2020 0.00 c@i Billed G:43260 6/17/2021 SOUTHWEST STRUCT Correspondence to opposing counsel regarding providing consent for motion to file. 76488 TIME KAYUSA - $250.00 0.25 250.00 63.00 12/22/2020 Other 0.00 c@1 Billed G:43260 6/17/2021 SOUTHWEST STRUCT Receive and review correspondence from opposing counsel regarding amended complaint; Receive and review correspondence from opposing counsel regarding answers to interrogatories. 76556 TIME KAYUSA - $250.00 0.25 250.00 63.00 4/11/2021 Other 0.00 c@1 Billed G:43260 6/17/2021 SOUTHWEST STRUCT Receive and review amended complaint; Receive and review amended notice of Lis Pendens. 76489 TIME KAYUSA - $250.00 0.25 250.00 63.00 1/14/2021 Other 0.00 Cc@1 Billed G:43260 6/17/2021 SOUTHWEST STRUCT Receive and review Notice of Hearing; Calendar and forward to client. 76557 TIME KAYUSA - $250.00 0.50 250.00 125.00 1/14/2021 Other 0.00 c@1 Billed G:43260 6/17/2021 SOUTHWEST STRUCT Telephone conference with Attomey for Banroc regarding upcoming events. 76558 TIME KAYUSA - $250.00 3.00 250.00 750.00 1/28/2021 Other 0.00 c@i Billed G:43260 6/17/2021 SOUTHWEST STRUCT Attend Deposition of Banroc's corporate representative, 76559 TIME KAYUSA - $250.00 0.25 250.00 63.00 2/17/2021 Other 0.00 c@1 Billed G:43260 6/17/2021 SOUTHWEST STRUCT Receive and review Motion to Consolidate from opposing counsel. 76490 TIME KAYUSA - $250.00 0.25 250.00 63.00 3/1/2021 Other 0.00 c@1 Billed G:43260 6/17/2021 SOUTHWEST STRUCT 6/29/2021 MICHAEL F. KAYUSA 4:11 PM Slip Listing Page 10 Slip ID Attomey Units Rate Slip Value Dates and Time Activity DNB Time Rate Info Posting Status Client Bill Status Description Receive and review Defendant's Witness List; Forward to client. 76560 TIME KAYUSA - $250.00 0.25 250.00 63.00 3/1/2021 Other 0.00 c@i Billed G:43260 6/17/2021 SOUTHWEST STRUCT Review documents - Defendant's Witness List; Forward to client. 76491 TIME KAYUSA - $250,00 0.25 250.00 63.00 3/3/2021 Other 0.00 c@1 Billed G:43260 6/17/2021 SOUTHWEST STRUCT Prepare our Disclosure of Fact Witnesses; Forward to client; File with court. 76561 TIME KAYUSA - $250.00 0.25 250.00 63.00 3/3/2021 Other 0.00 c@1 Billed G:43260 6/17/2021 SOUTHWEST STRUCT Prepare our Disclosure of Fact Witnesses; Forward to client; File with Court. 76492 TIME KAYUSA - $250.00 0.25 250.00 63.00 3/8/2021 Other 0.00 c@i Billed G:43260 6/17/2021 SOUTHWEST STRUCT Receive and review correspondence from opposing counsel regarding incomplete response to Banroc, 76493 TIME KAYUSA - $250.00 0.25 250.00 63.00 3/12/2021 Other 0.00 c@i Billed G:43260 6/17/2021 SOUTHWEST STRUCT Receive and review correspondence regarding Mediation Deadline and Extension. 76494 TIME KAYUSA - $250.00 1.00 250.00 250.00 3/15/2021 Other 0.00 c@1 Billed G:43260 6/17/2021 SOUTHWEST STRUCT Prepare Expert Witness List; File with Court and forward to client. 76495, TIME KAYUSA - $250.00 0.25 250.00 63.00 3/17/2021 Other 0.00 c@1 Billed G:43260 6/17/2021 SOUTHWEST STRUCT Correspondence with client confirming receipt of requested documents. 76496 TIME KAYUSA - $250.00 0.25 250.00 63.00 3/17/2021 Other 0.00 c@1 Billed G:43260 6/17/2021 SOUTHWEST STRUCT Correspondence with Court Reporter to obtain ——_- 6/29/2021 MICHAEL F. KAYUSA 4:11 PM Slip Listing Page 1 Slip ID Attomey Units Rate Slip Value Dates and Time Activity DNB Time Rate Info Posting Status Client Bill Status Description deposition transcript of Roland Bandinal. 76497 TIME KAYUSA - $250.00 0.25 250.00 63.00 3/19/2021 Other 0.00 c@1 Billed G:43260 6/17/2021 SOUTHWEST STRUCT Correspondence with opposing counsel regarding Motion for Summary Judgement. 76498 TIME KAYUSA - $250.00 2.00 250.00 500.00 3/22/2021 Other 0.00 Cc@i Billed G:43260 6/17/2021 SOUTHWEST STRUCT Preparation of Motion for Summary Judgement. 76499 TIME KAYUSA - $250.00 0.25 250.00 63,00 3/22/2021 Other 0.00 c@1 Billed G:43260 6/17/2021 SOUTHWEST STRUCT Receive and review Notice of Hearing; Calendar and forward to client; 76500 TIME KAYUSA - $250.00 0.25 250.00 63.00 3/22/2021 Other 0.00 c@i Billed G:43260 6/17/2021 SOUTHWEST STRUCT Receive and review Notice of Hearing on Banroc's Motion to Dismiss. 76501 TIME KAYUSA - $250.00 1.00 250.00 250.00 3/24/2021 Other 0.00 c@1 Billed G:43260 6/17/2021 SOUTHWEST STRUCT Preparation of Affidavit of Cody Griffith. 76502 TIME KAYUSA - $250.00 0.25 250.00 63.00 3/29/2021 Other 0.00 c@1 Billed G:43260 6/17/2021 SOUTHWEST STRUCT Receive and review Notice of Voluntary Dismissal as to Furguson Enterprises. 76503 TIME KAYUSA - $250.00 0.50 250.00 125.00 3/30/2021 Other 0.00 c@i Billed G:43260 6/17/2021 SOUTHWEST STRUCT Receive and review Proposed Order Consolidating Case submitted to Judge Gentile. 76504 TIME KAYUSA - $250.00 0.50 250,00 125.00 3/31/2021 Other 0.00 c@t Billed G:43260 6/17/2021 SOUTHWEST STRUCT Obtain dates from the Judges calendar for hearing on our motion for summary judgement; Correspondence with all counsel regarding dates to coordinate hearing. ee 6/29/2021 MICHAEL F. KAYUSA 41:11 PM Slip Listing Page 12 Slip ID Attorney Units Rate Slip Value Dates and Time Activity DNB Time Rate Info Posting Status Client Bill Status Description 76505 TIME KAYUSA - $250.00 0.25 250.00