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 # 103671146 E-Filed 02/21/2020 07:47:12 AM
IN THE CIRCUIT COURT OF THE SEVENTEENTH
JUDICIAL CIRCUIT IN AND FOR BROWARD.
COUNTY, FLORIDA
GENERAL JURISDICTION DIVISION
CASE NO. CACE-19-021666
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 lam an attorney employed by Robertson, Anschutz & Schneid, P.L. (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:
e Review payment and transaction history and other documents from Plaintiff. Open file and
prepare for the filing of the foreclosure action.
e Review of initial tile search and title examiner’s report to determine all of the possible interests
connected with the property.
19-376234
#** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 02/21/2020 07:47:12 AM.*##*
Review all of the documents required for the filing of the Lis Pendens and Complaint.
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 attorneys’ services rendered is
$175.00 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, plus the hourly rate of $175.00 per hour for resolution of contested issues, trial preparation and
attendance. Affiant’s Firm has expended 10.00 hours of time at a rate of $175.00 per hour for resolution
of contested issues, preparation for and attendance at trial, for a total amount of $1,750.00. Plaintiff will
pay Affiant’s Firm a total of $4,550.00.
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.
Filing Fees $1,973.41
Service of Process $120.00
Summons $20.00
TOTAL $2,113.41
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
20 day of February, 2020.
/S/James Beralus
James Beralus, Esq.
19-376234