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Filing # 131815434 E-Filed 08/02/2021 10:25:37 AM
IN THE CIRCUIT COURT OF THE SEVENTEENTH
JUDICIAL CIRCUIT IN AND FOR BROWARD
COUNTY, FLORIDA
GENERAL JURISDICTION DIVISION
CASE NO. CACE19021666
FREEDOM MORTGAGE CORPORATION,
Plaintiff,
VS.
ANDRE ST. STEVE KIFFIN, et al.
Defendant(s).
i
NOTICE OF FILING
Plaintiff, by and through its undersigned attorney hereby files:
o 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 2 day ofAugust, 2021.
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\Lourdes Sanchez Barcia-
Lourdes Sanchez Barcia, Esquire
Florida Bar No. 598461
CommunicationEmail:
1111111111111111111111111111111111111111111111 11111111111111111111111111111111111111111111111111111111111111111111111111111111111111
19-376234
***
FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 08/02/2021 10:25:36 AM.****
SERVICE LIST
ANDRE ST. STEVE KIFFIN
2126 N 32ND AVE
HOLLYWOOD, FL 33021
19-376234
IN THE CIRCUIT COURT OF THE SEVENTEENTH
JUDICIAL CIRCUIT IN AND FOR BROWARD
COUNTY, FLORIDA
GENERAL JURISDICTION DIVISION
CASE NO. CACE19021666
FREEDOM MORTGAGE CORPORATION,
Plaintiff,
VS.
ANDRE ST. STEVE KIFFIN, et al.
Defendant(s).
i
AFFIDAVIT AS TO TIME, EFFORT AND COSTS
STATE OF FLORIDA
COUNTY OF PALM BEACH
Affiant avers as follows:
1 I am an attorney employedby Robertson,Anschutz, Schneid, Crane & Partners, PLLC (the
"Firm"), counsel for Plaintiffin 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 compilationof 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 informationprovided by people with such first-hand knowledge.
Recording such informationis a regularpractice of the Firm's regularly conductedbusiness activities.
3 As counsel for Plaintiff in the above styled action, the followingservices 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 foreclosureaction.
, 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.
19-376234
,
Compliance with mandatory mediation administrativeorders and review and preparation of
documents associatedtherewith.
,
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 whetherservice was effectuatedproperly.
, Review of Certificatesof Military Service.
, Review Answers and Responses to the Foreclosure Complaint and prepare any necessaryresponses of
the same.
Preparation of Motion for Default and Notice of Dropping Parties.
, Miscellaneous client communication regarding the status of the foreclosureaction.
. Review and compilationo f all the documents needed to obtain Final Judgment, i.e. Motion for
SummaryJudgment and supporting affidavitsincluding the Affidavitof Indebtedness, Affidavit as to
Time, Effort and Costs, Affidavit as to the Reasonableness of Attorney's Fees, Motion for Default and
Non-militaryaffidavit; Final Judgment and Preparation of documents required for Foreclosure Sale.
, Attendance at final hearing.
19-376234
4. hourly rate charged by the Affiant's Firm for the attorneys' services rendered is $215.00
The
per hour. Notwithstanding,in the above-styled action, Affiant's Firm will receive compensationfrom Plaintiff
on the basis of a blended fee consisting of a $4,100.00 flat rate fee for standard foreclosure services, plus the
hourly rate of $215.00 per hour for resolutionof contested issues. Affiant's Firm has expended 40.10 hours of
time at a rate of $215.00 per hour for resolution of contested issues, for a total amount of $8,621.50. Plaintiff
will pay Affiant'sFirm a total of $12,721.50.
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 followingcosts in connectionwith this above-styled Foreclosure
Action.
Sunlnlons $20.00
Filing Fee Sl,973.41
Service of Process $120.00
Court Reporting $240.00
TOTAL $2,353.41
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 Time, Effort and Costs, and the facts stated in it are true on this 2 day of
Affidavit as to
August, 2021.
/S/Lourdes Sanchez Barcia
Lourdes Sanchez Barcia, Esq.
19-376234
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Filing # 131815434 E-Filed 08/02/2021 10:25:37 AM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA GENERAL JURISDICTION DIVISION CASE NO. CACE19021666 FREEDOM MORTGAGE CORPORATION, Plaintiff, VS. ANDRE ST. STEVE KIFFIN, et al. Defendant(s). i NOTICE OF FILING Plaintiff, by and through its undersigned attorney hereby files: o 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 2 day ofAugust, 2021. 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\Lourdes Sanchez Barcia- Lourdes Sanchez Barcia, Esquire Florida Bar No. 598461 CommunicationEmail: 1111111111111111111111111111111111111111111111 11111111111111111111111111111111111111111111111111111111111111111111111111111111111111 19-376234 *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 08/02/2021 10:25:36 AM.**** SERVICE LIST ANDRE ST. STEVE KIFFIN 2126 N 32ND AVE HOLLYWOOD, FL 33021 19-376234 IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA GENERAL JURISDICTION DIVISION CASE NO. CACE19021666 FREEDOM MORTGAGE CORPORATION, Plaintiff, VS. ANDRE ST. STEVE KIFFIN, et al. Defendant(s). i AFFIDAVIT AS TO TIME, EFFORT AND COSTS STATE OF FLORIDA COUNTY OF PALM BEACH Affiant avers as follows: 1 I am an attorney employedby Robertson,Anschutz, Schneid, Crane & Partners, PLLC (the "Firm"), counsel for Plaintiffin 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 compilationof 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 informationprovided by people with such first-hand knowledge. Recording such informationis a regularpractice of the Firm's regularly conductedbusiness activities. 3 As counsel for Plaintiff in the above styled action, the followingservices 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 foreclosureaction. , 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. 19-376234 , Compliance with mandatory mediation administrativeorders and review and preparation of documents associatedtherewith. , 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 whetherservice was effectuatedproperly. , Review of Certificatesof Military Service. , Review Answers and Responses to the Foreclosure Complaint and prepare any necessaryresponses of the same. Preparation of Motion for Default and Notice of Dropping Parties. , Miscellaneous client communication regarding the status of the foreclosureaction. . Review and compilationo f all the documents needed to obtain Final Judgment, i.e. Motion for SummaryJudgment and supporting affidavitsincluding the Affidavitof Indebtedness, Affidavit as to Time, Effort and Costs, Affidavit as to the Reasonableness of Attorney's Fees, Motion for Default and Non-militaryaffidavit; Final Judgment and Preparation of documents required for Foreclosure Sale. , Attendance at final hearing. 19-376234 4. hourly rate charged by the Affiant's Firm for the attorneys' services rendered is $215.00 The per hour. Notwithstanding,in the above-styled action, Affiant's Firm will receive compensationfrom Plaintiff on the basis of a blended fee consisting of a $4,100.00 flat rate fee for standard foreclosure services, plus the hourly rate of $215.00 per hour for resolutionof contested issues. Affiant's Firm has expended 40.10 hours of time at a rate of $215.00 per hour for resolution of contested issues, for a total amount of $8,621.50. Plaintiff will pay Affiant'sFirm a total of $12,721.50. 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 followingcosts in connectionwith this above-styled Foreclosure Action. Sunlnlons $20.00 Filing Fee Sl,973.41 Service of Process $120.00 Court Reporting $240.00 TOTAL $2,353.41 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 Time, Effort and Costs, and the facts stated in it are true on this 2 day of Affidavit as to August, 2021. /S/Lourdes Sanchez Barcia Lourdes Sanchez Barcia, Esq. 19-376234