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.
Preview
Filing # 125910509 E-Filed 04/30/2021 09:24:57 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).
/
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 am an attorney licensed to practice law in the State of Florida and I have practiced law in
Florida since 1985, 1 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 Tam familiar with the amounts charged by attorneys for services rendered in such cases and
$225.00 per hour is a reasonable rate.
4 In my opinion, based on the circumstances of this case, a flat fee of $2,800.00, fees in the
amount of $750.00 Bulk Continuation, and contested fees in the amount of $8,347.50, for a total amount of
$11,897.50 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 determining my
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).
The time and labor required, the novelty, complexity and difficulty of the questions involved, and
the skill requisite to perform the legal service properly.
The likelihood that the acceptance of the particular employment will preclude other employment
by the lawyer.
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 04/30/2021 09:24:57 AM.**##*
The significance of, or amount involved in, the subject matter of the representation, the
responsibility involved in the representation, and the results obtained.
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.
The nature and length of the professional relationship between said counsel and the client.
The experience, reputation and ability of Plaintiff's attorney.
The fact that the fee is fixed and not contingent.
6. Ihave no interest in the outcome of this litigation nor am I associated with or an employee of
the Plaintiff or the Defendant, or of the attorneys of either.
FURTHER AFFIANT SAYETH NAUGHT.
An
Nathan Schwartz, Esquire
STATE OF FLORIDA
COUNTY OF PALM BEACH
The foregoing instrument was acknowledged before me this2] day of April 2021, by Nathan Schwartz who
is personally known to me or has produced as identification, and who
did
(Seal) Duwi Neem.
DIANNE DICKENSON Signature of Notary Public
265
MY COMMISSIONGG 285 Print, Type/Stamp Name of Notary
EXPIRES: January
1, 2023
Bonded Thru Notary Public Under
19-376234
Category
Real Prop Non-Homestead Res Fore =/>$250,000
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Filing # 125910509 E-Filed 04/30/2021 09:24:57 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). / 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 am an attorney licensed to practice law in the State of Florida and I have practiced law in Florida since 1985, 1 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 Tam familiar with the amounts charged by attorneys for services rendered in such cases and $225.00 per hour is a reasonable rate. 4 In my opinion, based on the circumstances of this case, a flat fee of $2,800.00, fees in the amount of $750.00 Bulk Continuation, and contested fees in the amount of $8,347.50, for a total amount of $11,897.50 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 determining my 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). The time and labor required, the novelty, complexity and difficulty of the questions involved, and the skill requisite to perform the legal service properly. The likelihood that the acceptance of the particular employment will preclude other employment by the lawyer. 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 04/30/2021 09:24:57 AM.**##* The significance of, or amount involved in, the subject matter of the representation, the responsibility involved in the representation, and the results obtained. 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. The nature and length of the professional relationship between said counsel and the client. The experience, reputation and ability of Plaintiff's attorney. The fact that the fee is fixed and not contingent. 6. Ihave no interest in the outcome of this litigation nor am I associated with or an employee of the Plaintiff or the Defendant, or of the attorneys of either. FURTHER AFFIANT SAYETH NAUGHT. An Nathan Schwartz, Esquire STATE OF FLORIDA COUNTY OF PALM BEACH The foregoing instrument was acknowledged before me this2] day of April 2021, by Nathan Schwartz who is personally known to me or has produced as identification, and who did (Seal) Duwi Neem. DIANNE DICKENSON Signature of Notary Public 265 MY COMMISSIONGG 285 Print, Type/Stamp Name of Notary EXPIRES: January 1, 2023 Bonded Thru Notary Public Under 19-376234