On May 11, 132 a
Party Statement
was filed
involving a dispute between
Florida Opportunity Real Estate Investment, Llc,
and
All Unknown Parties Claiming Interests By, Through, Under Or Against A Named Defendant To This Action, Or Having Or Claiming To Have Any Right, Title Or Interest In The Property Hereein Described,
Milan, Wilfredo,
Reigosa, Lisette,
Unknown Tenant #1,
Unknown Tenant #2,
for Non-Homestead Residential Foreclosure 50,001 - 250,000
in the District Court of Charlotte County.
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Filing # 71525000 E-Filed 05/01/2018 04:20:04 PM
IN THE CIRCUIT COURT OF THE 20TH JUDICIAL CIRCUIT
IN AND FOR CHARLOTTE COUNTY, FLORIDA
CIVIL DIVISION
FLORIDA OPPORTUNITY REAL
ESTATE INVESTMENT, LLC, CASE NO: 17000587CA
Plaintiff,
vs.
WILFREDO MILAN; LISSETTE
REIGOSA, et al.,
Defendant(s).
/
AFFIDAVIT AS TO REASONABLE ATTORNEY’S FEES
STATE OF FLORIDA )
COUNTY OF BROWARD }
1, Omar Saleh, the undersigned, do hereby state on oath as follows:
1am an ajtorney licensed to practice in Florida, and have been admitted to the practice of
law in the State of Florida since September 20, 2011.
Tam personally familiar with the procedure of mortgage foreclosures in Florida, and with
the fees usually charged by attorneys in conducting such suits.
I am personally familiar with the law firm of Tripp Scott, P.A. and how the Firm
processes its foreclosure files. I am further familiar with the fee agreement the Firm has with its
clients regarding foreclosure files.
Tam familiar with Rule 4-1.5(b) of the Rules Regulating the Florida Bar, and have taken
into account the factors set forth in such Rule for the determination of reasonable attorney’s fees.
Lam familiar with and have considered the dictates of the Florida Supreme Court in the
case of Florida Patient's Compensation Fund v. Rowe, 472 So.2d 1145 (1985) for the
determination of reasonable attorneys fees.
In arriving at my opinion of the value of reasonable attorney’s fees in this matter, | have
considered the following criteria:
“TS# 17-029998 CASE NO. 17000587CA,
AFF OF REASONABLE ATTY FEES Page 1of2a. 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 acceptance of the particular employment will preclude other
employment for the lawyer.
c. The fee or rate of fee customarily charged in the locality for services of a
comparable or similar nature, including the aspect of discounted fees.
d. ‘The amount involved and result to be obtained.
e. ‘The time limitations imposed by the client or the circumstances,
f. The nature and length of professional relationship with the client.
g. ‘The experience, reputation and ability of the lawyers performing the services.
h. Whether the fee is fixed or contingent.
Tripp Scott, P.A. has reached a fee agreement with their client wherein the Firm is paid
based on a flat fee for uncontested foreclosures and an hourly rate for responding to any issue
that may be raiséd by a Defendant. The Firm is paid a flat fee of $2,520.00 for an uncontested
foreclosure, To the extent an issue is raised that must be replied to, the Firm is paid at a flat fee
of $215 per hour for a response to the issue.
T have examined the attorney’s file in this proceeding, including the Affidavit of
Plaintiff's Counsel as to Attorney’s Fees. | am familiar with the specific steps and requirements
that the Firm must complete to handle a foreclosure to its conclusion. This knowledge, together
with my understanding of the flat fee agreement and the hourly rate agreement, leads me to the
opinion that a fee of $8,916.25 is reasonable.
Date: Af) 1g
THIS CONCLUDES THIS AFFIDAVIT
Omar Saleh, AFFIANT _
SWORN TO AND SUBSCRIBED before me this /3 fay of Cpr. £ :
2018, by Omar Saleh who is personally known to me.
Ned x ude VAAL
Notary/Public, State of
SABIAN M. KHAN
Notary Public - State of F;
Commission # FF 218!
it lame: SAIS pau Mt isan
‘TS# 17-029998 CASE NO. 17000587CA
AFF OF REASONABLE ATTY FEES. Page 2 of 2
Document Filed Date
May 01, 2018
Case Filing Date
May 11, 132
Category
Non-Homestead Residential Foreclosure 50,001 - 250,000
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Filing # 71525000 E-Filed 05/01/2018 04:20:04 PM IN THE CIRCUIT COURT OF THE 20TH JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA CIVIL DIVISION FLORIDA OPPORTUNITY REAL ESTATE INVESTMENT, LLC, CASE NO: 17000587CA Plaintiff, vs. WILFREDO MILAN; LISSETTE REIGOSA, et al., Defendant(s). / AFFIDAVIT AS TO REASONABLE ATTORNEY’S FEES STATE OF FLORIDA ) COUNTY OF BROWARD } 1, Omar Saleh, the undersigned, do hereby state on oath as follows: 1am an ajtorney licensed to practice in Florida, and have been admitted to the practice of law in the State of Florida since September 20, 2011. Tam personally familiar with the procedure of mortgage foreclosures in Florida, and with the fees usually charged by attorneys in conducting such suits. I am personally familiar with the law firm of Tripp Scott, P.A. and how the Firm processes its foreclosure files. I am further familiar with the fee agreement the Firm has with its clients regarding foreclosure files. Tam familiar with Rule 4-1.5(b) of the Rules Regulating the Florida Bar, and have taken into account the factors set forth in such Rule for the determination of reasonable attorney’s fees. Lam familiar with and have considered the dictates of the Florida Supreme Court in the case of Florida Patient's Compensation Fund v. Rowe, 472 So.2d 1145 (1985) for the determination of reasonable attorneys fees. In arriving at my opinion of the value of reasonable attorney’s fees in this matter, | have considered the following criteria: “TS# 17-029998 CASE NO. 17000587CA, AFF OF REASONABLE ATTY FEES Page 1of2a. 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 acceptance of the particular employment will preclude other employment for the lawyer. c. The fee or rate of fee customarily charged in the locality for services of a comparable or similar nature, including the aspect of discounted fees. d. ‘The amount involved and result to be obtained. e. ‘The time limitations imposed by the client or the circumstances, f. The nature and length of professional relationship with the client. g. ‘The experience, reputation and ability of the lawyers performing the services. h. Whether the fee is fixed or contingent. Tripp Scott, P.A. has reached a fee agreement with their client wherein the Firm is paid based on a flat fee for uncontested foreclosures and an hourly rate for responding to any issue that may be raiséd by a Defendant. The Firm is paid a flat fee of $2,520.00 for an uncontested foreclosure, To the extent an issue is raised that must be replied to, the Firm is paid at a flat fee of $215 per hour for a response to the issue. T have examined the attorney’s file in this proceeding, including the Affidavit of Plaintiff's Counsel as to Attorney’s Fees. | am familiar with the specific steps and requirements that the Firm must complete to handle a foreclosure to its conclusion. This knowledge, together with my understanding of the flat fee agreement and the hourly rate agreement, leads me to the opinion that a fee of $8,916.25 is reasonable. Date: Af) 1g THIS CONCLUDES THIS AFFIDAVIT Omar Saleh, AFFIANT _ SWORN TO AND SUBSCRIBED before me this /3 fay of Cpr. £ : 2018, by Omar Saleh who is personally known to me. Ned x ude VAAL Notary/Public, State of SABIAN M. KHAN Notary Public - State of F; Commission # FF 218! it lame: SAIS pau Mt isan ‘TS# 17-029998 CASE NO. 17000587CA AFF OF REASONABLE ATTY FEES. Page 2 of 2