On October 18, 2019 a
Party Statement
was filed
involving a dispute between
Freedom Mortgage Corporation,
and
Kiffin, Andre St Steve,
for Real Prop Non-Homestead Res Fore =/>$250,000
in the District Court of Broward County.
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Filing # 132706774 E-Filed 08/16/2021 07:42:59 AM
IN THE CIRCUIT COURT OF THE SEVENTEENTH
JUDICIAL CIRCUIT IN AND FOR BROWARD
COUNTY, FLORIDA
GENERAL JURISDICTION DIVISION
CASE NO. CACE 19021666
FREEDOM MORTGAGE CORPORATION,
Plaintiff,
VS.
ANDRE ST. STEVE KIFFIN, et al.
Defendant(s).
AFFIDAVIT AS TO REASONABLE ATTORNEYS FEES
STATE OF FLORIDA
COUNTY OF PALM BEACH
BEFORE ME, the undersigned authority,personally appeared Nathan Schwartz, Esq., who being duly
sworn, deposes and says:
1. I attorney licensed to practice law in the State of Florida and I have practiced law in
am an
Florida since 1985. i am personally familiar with the fees usually awarded to plaintiffs in foreclosure suits of
the kind and nature in which this affidavit is filed.
2. I have reviewed, or have had the opportunity to review, the file of counsel for Plaintiff in this
action.
3. I am familiar with the amounts charged by attorneys for services rendered in such cases and
$215.00 per hour is a reasonable rate.
4. opinion, based on the circumstances ofthis case, a flat fee of $4,100.00, and contested
In my
fees in the amount of $8,621.50, for a total amount of $12,721.50 to be billed by Plaintiff's Attorney's Law
Firm is reasonable.
5. In arriving at my opinion I have evaluated the factors identified below in determiningmy
opinion of a reasonable attorney's fee as stated above, pursuant to R. Regulating Fla.Bar 4-1.5(b) and under
Florida Patients Compensation Fund v. Rowe 472 So.2nd 1145 (Fla. 1985).
a. The time and labor required, the novelty, complexity and difficulty of the questions involved, and
the skill requisite to perform the legal service properly.
b. The likelihoodthat the acceptance ofthe particular employment will preclude other employment
by the lawyer.
c. The fee, or rate of fee, customarily charged in this locality for legal services of a comparable or a
similar nature.
19-376234
***
FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 08/16/2021 07:42:59 AM.****
d. The significance of, or amount involved in, the subject matter of the representation, the
responsibility involved in the representation, and the results obtained.
e. The time limitations imposed by the client or by the circumstances and, as between attorney and
client, any additional or special time demands or requests of the attorney by the client.
f. The nature and length of the professionalrelationship between said counsel and the client.
g. The experience,reputation and ability of Plaintiff's attorney.
h. The fact that the fee is fixed and not contingent.
6. I have no interest in the outcome of this litigation nor am I associated with or an employee of
the Plainti ff or the Defendant, or of the attorneys of either.
FURTHER AFFIANT SAYETH NAUGHT. -1
Nathan Sch4rtz>Wsquire
STATE OF FLORIDA
COUNTY OF PALM BEACH
Mgwt
The foregoing instrument was acknowledged before me this 12,day of#B# 2021, by Nathan Schwartz who is
fersonallknownto me or has produced as identification, and who
did take an oath.
(Seal) PD.mhi #i&
Signature ofNotary Public
., IG*tiz'. DIANNE DICKENSON
Print, Type/Stamp Name of Notary
,?-*,.-,-**
i/AE#.*-0E
I ":28>f> BondedThT Notary Pb-lic Undelwrit??,?
19-376234
Preview
Filing # 132706774 E-Filed 08/16/2021 07:42:59 AM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA GENERAL JURISDICTION DIVISION CASE NO. CACE 19021666 FREEDOM MORTGAGE CORPORATION, Plaintiff, VS. ANDRE ST. STEVE KIFFIN, et al. Defendant(s). AFFIDAVIT AS TO REASONABLE ATTORNEYS FEES STATE OF FLORIDA COUNTY OF PALM BEACH BEFORE ME, the undersigned authority,personally appeared Nathan Schwartz, Esq., who being duly sworn, deposes and says: 1. I attorney licensed to practice law in the State of Florida and I have practiced law in am an Florida since 1985. i am personally familiar with the fees usually awarded to plaintiffs in foreclosure suits of the kind and nature in which this affidavit is filed. 2. I have reviewed, or have had the opportunity to review, the file of counsel for Plaintiff in this action. 3. I am familiar with the amounts charged by attorneys for services rendered in such cases and $215.00 per hour is a reasonable rate. 4. opinion, based on the circumstances ofthis case, a flat fee of $4,100.00, and contested In my fees in the amount of $8,621.50, for a total amount of $12,721.50 to be billed by Plaintiff's Attorney's Law Firm is reasonable. 5. In arriving at my opinion I have evaluated the factors identified below in determiningmy opinion of a reasonable attorney's fee as stated above, pursuant to R. Regulating Fla.Bar 4-1.5(b) and under Florida Patients Compensation Fund v. Rowe 472 So.2nd 1145 (Fla. 1985). a. The time and labor required, the novelty, complexity and difficulty of the questions involved, and the skill requisite to perform the legal service properly. b. The likelihoodthat the acceptance ofthe particular employment will preclude other employment by the lawyer. c. The fee, or rate of fee, customarily charged in this locality for legal services of a comparable or a similar nature. 19-376234 *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 08/16/2021 07:42:59 AM.**** d. The significance of, or amount involved in, the subject matter of the representation, the responsibility involved in the representation, and the results obtained. e. The time limitations imposed by the client or by the circumstances and, as between attorney and client, any additional or special time demands or requests of the attorney by the client. f. The nature and length of the professionalrelationship between said counsel and the client. g. The experience,reputation and ability of Plaintiff's attorney. h. The fact that the fee is fixed and not contingent. 6. I have no interest in the outcome of this litigation nor am I associated with or an employee of the Plainti ff or the Defendant, or of the attorneys of either. FURTHER AFFIANT SAYETH NAUGHT. -1 Nathan Sch4rtz>Wsquire STATE OF FLORIDA COUNTY OF PALM BEACH Mgwt The foregoing instrument was acknowledged before me this 12,day of#B# 2021, by Nathan Schwartz who is fersonallknownto me or has produced as identification, and who did take an oath. (Seal) PD.mhi #i& Signature ofNotary Public ., IG*tiz'. DIANNE DICKENSON Print, Type/Stamp Name of Notary ,?-*,.-,-** i/AE#.*-0E I ":28>f> BondedThT Notary Pb-lic Undelwrit??,? 19-376234