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 # 124309153 E-Filed 04/05/2021 12:36:52 PM
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 TIME, EFFORT AND COSTS
STATE OF FLORIDA
COUNTY OF PALM BEACH
Affiant avers as follows:
1 Tam an attorney employed by Robertson, Anschutz, Schneid, Crane & Partners, PLLC (the
"Firm”), counsel for Plaintiff in this action.
2. Ihave 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.
19-376234
#** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 04/05/2021 12:36:51 PM.**#*
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.
19-376234
4 The hourly rate charged by the Affiant’s Firm for the attomeys’ services rendered is $225.00
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 $2,800.00 flat fee for standard foreclosure services and a $750.00
flat rate fee for Bulk Continuation, plus the hourly rate of $225.00 per hour for resolution of contested issues,
trial preparation and attendance. Affiant’s Firm has expended 37.10 hours of time at a rate of $225.00 per
hour for resolution of contested issues, preparation for and attendance at trial, for a total amount of $8,347.50.
Plaintiff will pay Affiant’s Firm a total of $11,897.50.
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 following costs in connection with this above-styled Foreclosure
Action.
Summons $20.00
Court Reporting $240.00
Filing Fees $1,973.41
Service of Process $120.00
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 Affidavit as to Time, Effort and Costs, and the facts stated in it are true on this 4 day of
April, 2021.
/S/Lourdes Sanchez Barcia
Lourdes Sanchez Barcia, Esq.
19-376234
Preview
Filing # 124309153 E-Filed 04/05/2021 12:36:52 PM 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 TIME, EFFORT AND COSTS STATE OF FLORIDA COUNTY OF PALM BEACH Affiant avers as follows: 1 Tam an attorney employed by Robertson, Anschutz, Schneid, Crane & Partners, PLLC (the "Firm”), counsel for Plaintiff in this action. 2. Ihave 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. 19-376234 #** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 04/05/2021 12:36:51 PM.**#* 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. 19-376234 4 The hourly rate charged by the Affiant’s Firm for the attomeys’ services rendered is $225.00 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 $2,800.00 flat fee for standard foreclosure services and a $750.00 flat rate fee for Bulk Continuation, plus the hourly rate of $225.00 per hour for resolution of contested issues, trial preparation and attendance. Affiant’s Firm has expended 37.10 hours of time at a rate of $225.00 per hour for resolution of contested issues, preparation for and attendance at trial, for a total amount of $8,347.50. Plaintiff will pay Affiant’s Firm a total of $11,897.50. 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 following costs in connection with this above-styled Foreclosure Action. Summons $20.00 Court Reporting $240.00 Filing Fees $1,973.41 Service of Process $120.00 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 Affidavit as to Time, Effort and Costs, and the facts stated in it are true on this 4 day of April, 2021. /S/Lourdes Sanchez Barcia Lourdes Sanchez Barcia, Esq. 19-376234