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Filing # 142180862 E-Filed 01/18/2022 04:09:30 PM
IN THE CIRCUIT COURT OF THE NINTH
JUDICIAL CIRCUIT IN AND FOR OSCEOLA
COUNTY, FLORIDA
GENERAL JURISDICTION DIVISION
CASE NO. 2018-CA-003041-MF
HOMEBRIDGE FINANCIAL SERVICES,
INC.,
Plaintiff,
vs.
MICHAEL R. PARKEY AND MARK D.
PARKEY, et al.
Defendant(s).
___________________________________/
NOTICE OF FILING
Plaintiff, by and through its undersigned attorney hereby files:
● Affidavit as to Time, Effort, and Costs
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished to the
parties listed on the attached service list via Mail and/or E-mail in accordance with the corresponding
addresses listed therein on this 18 day of January, 2022.
ROBERTSON, ANSCHUTZ, SCHNEID, CRANE &
PARTNERS, PLLC
Attorney for Plaintiff
6409 Congress Ave., Suite 100
Boca Raton, FL 33487
Telephone: 561-241-6901
Facsimile: 561-997-6909
Service Email: flmail@raslg.com
By: _\S\Scott Brown_
Scott Brown, Esquire
Florida Bar No. 88187
Communication Email: sbrown@raslg.com
PAGE 1
20-060827 - StC
SERVICE LIST
LAW OFFICES OF LEGENDRE & LEGENDRE, PLLC
ANTHONY N. LEGENDRE II, ESQUIRE
ATTORNEY FOR MICHAEL R. PARKEY
C/O LAW OFFICES OF LEGENDRE & LEGENDRE, PLLC
P.O. BOX 948599
MAITLAND, FL 32794
PRIMARY EMAIL: ANTHONYLEGENDRE@LIVE.COM
SECONDARY EMAIL: ANTHONY@LAW-LEGENDS.COM
LAW OFFICES OF LEGENDRE & LEGENDRE, PLLC
ANTHONY N. LEGENDRE II, ESQUIRE
ATTORNEY FOR MARK D. PARKEY
C/O LAW OFFICES OF LEGENDRE & LEGENDRE, PLLC
P.O. BOX 948599
MAITLAND, FL 32794
PRIMARY EMAIL: ANTHONYLEGENDRE@LIVE.COM
SECONDARY EMAIL: ANTHONY@LAW-LEGENDS.COM
UNKNOWN PARTY #1 N/K/A CHRISTINE DEVORE
1355 JAN LAN BLVD
SAINT CLOUD, FL 34772
PAGE 2
20-060827 - StC
IN THE CIRCUIT COURT OF THE NINTH
JUDICIAL CIRCUIT IN AND FOR OSCEOLA
COUNTY, FLORIDA
GENERAL JURISDICTION DIVISION
CASE NO. 2018-CA-003041-MF
HOMEBRIDGE FINANCIAL SERVICES,
INC.,
Plaintiff,
vs.
MICHAEL R. PARKEY AND MARK D.
PARKEY, et al.
Defendant(s).
___________________________________/
AFFIDAVIT AS TO TIME, EFFORT AND COSTS
STATE OF FLORIDA
COUNTY OF PALM BEACH
Affiant avers as follows:
1. I am an attorney employed by Robertson, Anschutz, Schneid, Crane & Partners, PLLC
(the "Firm”), counsel for Plaintiff in this action.
2. I have personal knowledge of the facts contained in this affidavit including the Firm’s
method of recording attorney fees and costs. The attorney fees and costs described below are kept in the
Firm’s billing ledger, which is a compilation of data maintained in the Firm’s electronic accounting
system. The entries in those records are made at the time the fees are incurred and the costs are advanced
either by people with first-hand knowledge of those events or from information provided by people with
such first-hand knowledge. Recording such information is a regular practice of the Firm’s regularly
conducted business activities.
3. As counsel for Plaintiff in the above styled action, the following services are the typical
services provided by the Firm on a flat fee basis, for which time records have not been kept, and on
hourly fees. The services include the following:
Review payment and transaction history and other documents from Plaintiff. Open file and
prepare for the filing of the foreclosure action.
Review of initial tile search and title examiner’s report to determine all of the possible interests
connected with the property.
Review all of the documents required for the filing of the Lis Pendens and Complaint.
20-060827 - StC
PAGE 1
Compliance with mandatory mediation administrative orders and review and preparation of
documents associated therewith.
Preparation for and attendance at mandatory mediation session.
Preparation of Lis Pendens, Complaint, Summons, Motion and Order Appointing Process Server,
and Civil Cover Sheet.
Review of supplemental title search or report from title examiner.
Review of Returns of Service and determination as to whether service was effectuated properly.
Review of Certificates of Military Service.
Review Answers and Responses to the Foreclosure Complaint and prepare any necessary
responses of the same.
Preparation of Motion for Default and Notice of Dropping Parties.
Miscellaneous client communication regarding the status of the foreclosure action.
Review and compilation of all the documents needed to obtain Final Judgment, i.e. Motion for
Summary Judgment and supporting affidavits including the Affidavit of Indebtedness, Affidavit
as to Time, Effort and Costs, Affidavit as to the Reasonableness of Attorney’s Fees, Motion for
Default and Non-military affidavit; Final Judgment and Preparation of documents required for
Foreclosure Sale.
Attendance at final hearing.
20-060827 - StC
PAGE 2
4. The hourly rate charged by the Affiant’s Firm for the attorneys’ services rendered is
$215.00 per hour. Notwithstanding, in the above-styled action, Affiant’s Firm will receive compensation
from Plaintiff on the basis of a blended fee consisting of a $1,230.00 flat fee for standard foreclosure
services, plus the hourly rate of $215.00 per hour for resolution of contested issues, trial preparation and
attendance. Affiant’s Firm has expended 89.60 hours of time at a rate of $215.00 per hour for resolution
of contested issues, preparation for and attendance at trial, for a total amount of $19,264.00. Plaintiff
will pay Affiant’s Firm a total of $20,494.00.
5. Affiant certifies that there are no reasons for either reduction or enhancement of the fee
pursuant to Florida Patient’s Compensation Fund v. Rowe, 472 So. 2d 1145 (Fla.1985).
6. Plaintiff has incurred the following costs in connection with this above-styled
Foreclosure Action.
Court Reporting $315.00
Mediation Cost $200.00
TOTAL $515.00
VERIFICATION
Under the penalties of perjury, and pursuant to Fla.Stat. §92.525(1)(b) and (2), I declare that I
have read the foregoing Affidavit as to Time, Effort and Costs, and the facts stated in it are true on this
18 day of January, 2022.
/S/Scott Brown
Scott Brown, Esq.
20-060827 - StC
PAGE 3
Preview
Filing # 142180862 E-Filed 01/18/2022 04:09:30 PM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR OSCEOLA COUNTY, FLORIDA GENERAL JURISDICTION DIVISION CASE NO. 2018-CA-003041-MF HOMEBRIDGE FINANCIAL SERVICES, INC., Plaintiff, vs. MICHAEL R. PARKEY AND MARK D. PARKEY, et al. Defendant(s). ___________________________________/ NOTICE OF FILING Plaintiff, by and through its undersigned attorney hereby files: ● Affidavit as to Time, Effort, and Costs CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished to the parties listed on the attached service list via Mail and/or E-mail in accordance with the corresponding addresses listed therein on this 18 day of January, 2022. ROBERTSON, ANSCHUTZ, SCHNEID, CRANE & PARTNERS, PLLC Attorney for Plaintiff 6409 Congress Ave., Suite 100 Boca Raton, FL 33487 Telephone: 561-241-6901 Facsimile: 561-997-6909 Service Email: flmail@raslg.com By: _\S\Scott Brown_ Scott Brown, Esquire Florida Bar No. 88187 Communication Email: sbrown@raslg.com PAGE 1 20-060827 - StC SERVICE LIST LAW OFFICES OF LEGENDRE & LEGENDRE, PLLC ANTHONY N. LEGENDRE II, ESQUIRE ATTORNEY FOR MICHAEL R. PARKEY C/O LAW OFFICES OF LEGENDRE & LEGENDRE, PLLC P.O. BOX 948599 MAITLAND, FL 32794 PRIMARY EMAIL: ANTHONYLEGENDRE@LIVE.COM SECONDARY EMAIL: ANTHONY@LAW-LEGENDS.COM LAW OFFICES OF LEGENDRE & LEGENDRE, PLLC ANTHONY N. LEGENDRE II, ESQUIRE ATTORNEY FOR MARK D. PARKEY C/O LAW OFFICES OF LEGENDRE & LEGENDRE, PLLC P.O. BOX 948599 MAITLAND, FL 32794 PRIMARY EMAIL: ANTHONYLEGENDRE@LIVE.COM SECONDARY EMAIL: ANTHONY@LAW-LEGENDS.COM UNKNOWN PARTY #1 N/K/A CHRISTINE DEVORE 1355 JAN LAN BLVD SAINT CLOUD, FL 34772 PAGE 2 20-060827 - StC IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR OSCEOLA COUNTY, FLORIDA GENERAL JURISDICTION DIVISION CASE NO. 2018-CA-003041-MF HOMEBRIDGE FINANCIAL SERVICES, INC., Plaintiff, vs. MICHAEL R. PARKEY AND MARK D. PARKEY, et al. Defendant(s). ___________________________________/ AFFIDAVIT AS TO TIME, EFFORT AND COSTS STATE OF FLORIDA COUNTY OF PALM BEACH Affiant avers as follows: 1. I am an attorney employed by Robertson, Anschutz, Schneid, Crane & Partners, PLLC (the "Firm”), counsel for Plaintiff in this action. 2. I have personal knowledge of the facts contained in this affidavit including the Firm’s method of recording attorney fees and costs. The attorney fees and costs described below are kept in the Firm’s billing ledger, which is a compilation of data maintained in the Firm’s electronic accounting system. The entries in those records are made at the time the fees are incurred and the costs are advanced either by people with first-hand knowledge of those events or from information provided by people with such first-hand knowledge. Recording such information is a regular practice of the Firm’s regularly conducted business activities. 3. As counsel for Plaintiff in the above styled action, the following services are the typical services provided by the Firm on a flat fee basis, for which time records have not been kept, and on hourly fees. The services include the following: Review payment and transaction history and other documents from Plaintiff. Open file and prepare for the filing of the foreclosure action. Review of initial tile search and title examiner’s report to determine all of the possible interests connected with the property. Review all of the documents required for the filing of the Lis Pendens and Complaint. 20-060827 - StC PAGE 1 Compliance with mandatory mediation administrative orders and review and preparation of documents associated therewith. Preparation for and attendance at mandatory mediation session. Preparation of Lis Pendens, Complaint, Summons, Motion and Order Appointing Process Server, and Civil Cover Sheet. Review of supplemental title search or report from title examiner. Review of Returns of Service and determination as to whether service was effectuated properly. Review of Certificates of Military Service. Review Answers and Responses to the Foreclosure Complaint and prepare any necessary responses of the same. Preparation of Motion for Default and Notice of Dropping Parties. Miscellaneous client communication regarding the status of the foreclosure action. Review and compilation of all the documents needed to obtain Final Judgment, i.e. Motion for Summary Judgment and supporting affidavits including the Affidavit of Indebtedness, Affidavit as to Time, Effort and Costs, Affidavit as to the Reasonableness of Attorney’s Fees, Motion for Default and Non-military affidavit; Final Judgment and Preparation of documents required for Foreclosure Sale. Attendance at final hearing. 20-060827 - StC PAGE 2 4. The hourly rate charged by the Affiant’s Firm for the attorneys’ services rendered is $215.00 per hour. Notwithstanding, in the above-styled action, Affiant’s Firm will receive compensation from Plaintiff on the basis of a blended fee consisting of a $1,230.00 flat fee for standard foreclosure services, plus the hourly rate of $215.00 per hour for resolution of contested issues, trial preparation and attendance. Affiant’s Firm has expended 89.60 hours of time at a rate of $215.00 per hour for resolution of contested issues, preparation for and attendance at trial, for a total amount of $19,264.00. Plaintiff will pay Affiant’s Firm a total of $20,494.00. 5. Affiant certifies that there are no reasons for either reduction or enhancement of the fee pursuant to Florida Patient’s Compensation Fund v. Rowe, 472 So. 2d 1145 (Fla.1985). 6. Plaintiff has incurred the following costs in connection with this above-styled Foreclosure Action. Court Reporting $315.00 Mediation Cost $200.00 TOTAL $515.00 VERIFICATION Under the penalties of perjury, and pursuant to Fla.Stat. §92.525(1)(b) and (2), I declare that I have read the foregoing Affidavit as to Time, Effort and Costs, and the facts stated in it are true on this 18 day of January, 2022. /S/Scott Brown Scott Brown, Esq. 20-060827 - StC PAGE 3