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HomeMy Public PortalAbout10-8016 Payment to Burnadette Norris Weeks Sponsored by: Commissioner R. Tydus Resolution No. 10-8 01 6 A RESOLUTION OF THE CITY COMMISSION OF THE CITY OF OPA-LOCKA, FLORIDA, AUTHORIZING THE CITY MANAGER TO MAKE PAYMENT TO BURNADETTE NORRIS-WEEKS,P.A.FOR LITIGATION LEGAL SERVICES RENDERED TO THE CITY OF OPA-LOCKA, PAYABLE FROM ACCOUNT NO. 28-514390; PROVIDING FOR INCORPORATION OF RECITALS; PROVIDING FOR AN EFFECTIVE DATE WHEREAS,Burnadette Norris-Weeks,P.A.previously serviced as the City Attorney for the City of Opa-locka,having been hired in June of 2008,and having resigned in December, 2009;and WHEREAS, Burnadette Norris-Weeks, P.A., is requesting authorization from the City Commission of the City of Opa-locka("City Commission")for the City Manager to make payment to Burnadette Norris-Weeks, P.A., for litigation legal services rendered as City Attorney from the time of hiring up until its resignation of December 9, 2009; and WHEREAS, at the time of hiring the video recorded record of the hiring will reflect that litigation services were not a part of the hiring terms for the firm. NOW,THEREFORE,BE IT DULY RESOLVED BY THE CITY COMMISSION OF THE CITY OF OPA-LOCKA,FLORIDA: Section 1. The recitals to the preamble herein are incorporated by reference. Section 2. The City Commission of the City of Opa-locka hereby authorizes the City Manager to make payment to the law firm of Burnadette Norris-Weeks, P.A., for litigation legal services rendered on behalf of the City of Opa-locka in the amount of$37,647.50,per the attached, Exhibit "A",payable from Account No. 28-514390. Section 3. This resolution shall take effect immediately upon adoption. Resolution No. 1 0—8 01 6 PASSED AND ADOPTED this 10 day of FEBRUARY , 2010. YO P, Attest to: Approved as o form and legal if iency: / A I hVO airs EBOR -• S. IRBY JO1S `� :�. GELLER, ESQUIRE CITY C ERK INT RI CITY ATTORNEY Moved by: JOHNSON Second by: TYDUS Commission Vote: 3-2 Commissioner Holmes: NO Commissioner Johnson: NO Commissioner Tydus: YES Vice-Mayor Taylor: YES Mayor Kelley: YES T A Law Office of Burnadette Norris-Weeks, P.A. 401 N. Avenue of the Arts Fort Lauderdale, Florida 33311 Client City of Opa-locka Professional Services Rendered Number Date(s) Description of Litigation Case Number Amount Billed 1 10/30/09-11/4/08 Dora Industries v. Randoplh Aiken 09-557 $ 869.50 Raymond Walls and Edward 2 10/22/09-11/23/09 Blackman v. Deborah Sheffield Irby 09-764353 CA01 2,571.50 09-6935 CC 05- 3 07/10/09-11/30/09 City v. James Randle 02 1,591.00 4 11/06/08-10/02/09 Darleen Browne v. City 09-6936 CC05-06 888.00 5 10/08/09-11/24/09 City v. GFM Operations, Inc 09-75359 1,498.50 Evelyn Runicman a/k/a Evelyn 6 08/14/09-12/09/09 Rosen v. City 07-41425 851.00 7 08/04/09-09/30/09 Jennifer Garcia Matter(No Charge) N/A 0.00 8 06/17/09-08/03/09 City v. Bellsouth 09-48376CA 20 3,052.50 9 09/16/08-03/09/09 James Wright v. City 08-62478 3,145.00 10 12/08/09-12/09/09 Tran Construction v. City N/A 869.50 11 03/12/09/03/13/09 City v. Brownstein (No Charge) N/A 0.00 08-23259 12 10/23/08-01/27/09 Leal v. City (Federal Court 1,702.00 13 04/01/09-06/18/09 Nikeya Hill/Natalie Buissereth v. City 09-CV20662 3,959.00 14 09/2/2008 Tamika Miller v. City(No Charge) N/A 0.00 15 09/23/08-12/03/09 Foreclosure Cases Various 16,650.00 Total $ 37,647.50 Law Office of Burnadette Norris-Weeks, P.A. 401 N. Avenue of the Arts • Fort Lauderdale, Florida 33311 Phone (954) 768-9770•Fax (954) 768-9790 INVOICE CLIENT: CITY OF OPA-LOCKA, FLORIDA MATTERS: (Litigation) Dora Industries v. Randolph Aiken, City of Opa-locka, et.al (Case No.: 09-557) 11/4/09 Preparation and Attendance at Pre-Trial Conference (Re: Dora Industries v. Randolph Aiken, City of Opa-locka, City Manager, Bryan Finnie); Preparation Notice of Dropping Party Defendants; Telephone Conferences with Eli Finkelberg; Status Report of B. Finnie 2.6 11/02/09 Telephone conference with Eli Finkelberg; Telephone conference with asst. to Finkelberg RE: litigation matter; Preparation/Draft of Notice of Dropping Party Defendants (Re:Dora Industries v. Randolph Aiken, City of Opa-Locka, City Manager, Bryan Finnie) .7 10/30/09 Telephone Conference with Eli Finkelberg, Dora Industries; Meeting with Randolph Aiken (Re: Dora Industries v. Randolph Aiken, City of Opa-locka, City Manager, Bryan Finnie); Case No.: 09-557(60) 1.4 Total Professional Services Billed: $869.50 VKL 4.7 Raymond Walls and Edward Blackman v. Deborah Sheffield Irby Case 09-76453 CA 01 11/23/09 Response to Complaint for Public Records; Preparation of letter to Plaintiff's attorney; Travel for filing; Review with Defendant and update 3.6 11/20/09 Communication with Joshua Entin. Esq. RE: records issues .2 11/17/09 Telephone conference with law office RE: records issues .1 11/13/09 Review of Public Records Compiled by City Staff and telephone conference with Plaintiff's Counsel; Review of letter from Joshua Entin 3.5 11/12/09 Preparation of letter to Jushua Entin .4 11/9/09 Review of letter from Jushua Entin, Esq. .1 11/5/09 Telephone conference with Joshua Entin RE: Public Records issues Preparation of letter to Entin RE: Deposit issues .6 10/30/09 Preparation of letter to Joshua Entin; Telephone conference to Joshua M. Entin, Esquire RE: Public Records Request; Communication with Defendant Clerk; Review of recent case law RE: Public Records matters 1.8 10/29/09 Telephone conference with Sharlene Boyd (Re: Public Records Request (Re: Edward Blackman and Raymond Walls v. Deborah Irby- Case No.: 09-76453 (CA 01); Telephone conference with Assistant Chief Cason, Captain Jorge' Amaya and Sharlene Boyd (Re: Public Records Request Review of documents and discussion with Police Chief Smith RE: receipt issues from City Clerk 2.1 10/22/09 Receipt and Review of Complaint and back-up and Response to Request for information Re: Edward Blackman; Review of factual issues 1.5 Time Reduced in System: Total Professional Services Billed: $2,571.50 VKL 6.9 BNW 7.0 City of Opa-locka v. James Randle-Case No.:09-6935 CC 05-02 11/30/09 Telephone conference with James Randle (Re: Settlement Negotiations) Case No.:09-6935 CC 05-02 .5 10/16/09 Meeting with James Randle Re: City of Opa-locka v. James Randle-Review Settlement Agreement 1.0 • 10/15/09 Preparation/Draft of Settlement Agreement (Re: City of Opa-locka v. James Randle) 1.5 10/02/09 Telephone conference with James Randle Re: Settlement Negotiations; Preparation and Draft of Correspondence to James Randle (Re: Settlement Offer); Second Telephone conference with James Randle Re: Negotiations .5 10/01/09 Telephone conference with James Randle Re: Settlement Negotiations .1 08/27/09 Telephone conference with James Randle .3 08/20/09 Telephone conference with Neil Flaxman, Esq. Re: James Randle .4 08/14/09 Meeting with Former Employee, Police Officer, James Randle Re: City of Opa-Locka v. James Randle-Negotiating a Settlement-Case No.: 09-6935 CC 05-02) .9 08/13/09 Telephone conference with Neil Flaxman, Esq. Re: City of Opa-Locka v. James Randle Settlement; Meeting with Human Resources Specialist II, Cassandra Joseph Re: Signing Bonus-James Randle; Telephone conference with Randle; Meeting with Human Resources Director, Sharlene Boyd (Re: Review of Termination letter James Randle) 1.6 08/07/09 Telephone conference with Former Employee, Police Officer, James Randle Re: City of Opa-Locka v. James Randle-Negotiating a Settlement-Case No.: 09-6935 CC 05-02) .4 08/06/09 Telephone conference with James Randle Re: City of Opa-Locka v. James Randle- Case No.: 09-6935CC 05-02); Meeting with Carol/Finance (Re: James Randle- Proof of Bonus Paid); Meeting with Human Resources Director, Sharlene Boyd Re: James Randle- Proof of Bonus Paid 1.3 7/31/09 Telephone conference with Clerk of Court, Miami-Dade County Courthouse Re: Motion Calendar- Notice of Hearing-James Randle; Telephone Conference with Judge Ronald Friedman's Office (Re: James Randle) Complaint Preparation and filing .6 7/17/08 Receipt and Review of Complaint of Hostile Work Environment from former Officer James Randle N/C 07/10/09 Preparation of Notice of Hearing on Motion to Dismiss (Re: City of Opa-locka v. James Randle) N/C Total Professional Services Billed: $1,591.00 VKL 5.6 BNW 3.0 Darleen Browne v. City of Opa-locka Case No.: 09-6938 (CC05-06 10/02/09 Telephone conference with Miami-Dade Clerk of Courts (Re: Darleen Browne .3 09/04/09 Preparation and Draft of Correspondence to Clerk of Court (Re: .2 Motion for Default-Darleen Browne) 09/03/09 Preparation and Draft of Affidavit of Non-Military Status/Research + filing 1.0 09/03/09 Telephone conference with Department of Defense (Re: Darleen Browne) .3 07/10/09 Preparation of Motion for Default (Re: City of Opa-Locka v. Darleen Browne) and filing .8 11/20/08 Final Preparation of Complaint (Re: City of Opa-Locka v. Darleen Browne; research of service issues with staff 2.0 11/06/08 Initial Preparation & Draft of Complaint -- City of Opa-locka v. Darleen Browne .2 Total Professional Services Billed: $888.00 VKL 4.8 City of Opa-locka v. GFM Operations, Inc. Case # 09-75359 11/24/09 Review of Motion for Extension of Time from James Greason; Delivery of Motion to for Default Clerk of Court; Office call for verified service 1.5 11/23/09 Preparation of Motion for Default and filing 1.0 11/18/09 Research of court file for Default Motion .4 10/08/09 Preparation of Complaint Re: City of Opa-locka v. GFM Operations; 3.6 Review of supporting documents from Finance Department 10/08/09 Preparation/Draft Summons and Civil Cover Sheet (Re: City of Opa- Locka v. GMF Operations, Inc.) .4 10/08/09 Meeting with Finance Staff regarding outstanding amounts and verification .5 10/08/09 Receipt and Review Correspondence to Scott Miller, Opa-locka/Hialeah (Re: Delinquent Occupational License Fees); Litigation preparation for Complaint .7 Total Professional Services Billed: $1,498.50 BNW 8.1 Evelyn Runciman a/k/a Evelyn Rosen v. City of Opa-Locka et al. Case 07-41425 12/9/09 Review of letter from Fran Zion Esq. RE: Hearing and notice .2 10/29/09 Telephone conference with Plaintiff's counsel RE: City position .3 10/26/09 Review of Plaintiff's Motion for Summary Judgment .8 10/2/09 Telephone conference with Terry Sonn RE: Quiet Title Action and conference with B. Finnie RE: possible settlement issues; .5 10/1/09 Review of Miami-Dade County Property-public records .4 9/18/09 Meeting Re: Quiet Title issues and discussions with Interim City Manager B. Finnie and O. Spanner .6 9/8/09 Telephone conference with Joe Geller RE: file and discussions .2 09/04/09 Receipt and Review of File (Re: Evelyn Rosen v. City of Opa-locka) .7 08/20/09 Telephone conference with Tony Palumbo Re: Property Folio No.: 08 .4 2122000 0350-1736 Ali Baba Avenue 8/18/09 Telephone Conference with Plaintiff's counsel RE: Title issues .3 08/14/09 Telephone conference with Tony Palumbo (Re: Quiet Title Action) .2 Total Professional Services Billed: $851.00 BNW 4.6 Jennifer Garcia Matter— No Charge 09/30/09 Meeting with Human Resources Director, Sharlene Boyd (Re: Unemployment Hearing —Jennifer Garcia) 1.0 09/30/09 Attendance at Unemployment Hearing (Re: Jennifer Garcia) 1.0 08/03/09 Research in Preparation of Unemployment Appeals Hearing (Re: Jennifer Garcia) .7 08/03/09 Preparation for Unemployment Appeals Hearing (Re: Jennifer Garcia) 1.0 08/04/09 Meeting with Human Resources Director, Sharlene Boyd (Re: Unemployment Appeals Hearing- Former Employee, Jennifer Garcia) 1.0 08/04/09 Attendance at Unemployment Appeals Hearing (Re: Former Employee- Jennifer Garcia) 1.2 Total Professional Services Billed: $NO CHARGE City of Opa-locka vs. Bellsouth Case# 09-48376CA 20 08/03/09 Receipt and Review of Notice of Mediation (Re: City of Opa-locka v. Bell South) Telephone conference with opposing counsel .7 7/31/09 Preparation and Attendance at Mediation 7.8 7/30/09 Meeting with City Manager and city staff in preparation for mediation 1.0 7/28/09 Meeting with finance department staff RE: calculations and cost estimates .8 6/25/09 Preparation of complaint completion and filing issues; Communication RE: mediation with opposing counsel 4.3 6/19/09 Information gathering; Meetings with city staff for collection of documents and review of all communications from D. Abia .8 6/17/09 Preparation of Draft of Complaint 1.1 Total Professional Services Billed: $3,052.50 VKL 10.5 BNW 6.0 James Wright v. City of Opa-locka Case #08-62478 3/9/09 Communication with opposing counsel RE: Settlement Agreement .7 2/13/09 Review of letter and telephone conference with opposing counsel .8 2/11/09 Review of letter from opposing counsel RE: settlement; Communication 1.4 with Interim City Manager RE: settlement issues 2/2/09 Review of Order of Referral to Mediation from Court; update to Interim City Manager .2 1/8/09 Review of correspondence from opposing counsel Diaz and follow-up; Conference call; Meeting for discussion of potential settlement issues 1.6 1/7/09 Review of letter from opposing counsel RE: scheduling of deposition; Review of Defendant's reply to affirmative defenses and response 1.4 12/30/08 Final Preparation of Answer and Affirmative Defenses; Staff communication 2.2 12/26/08 Preparation of Answer and Affirmative Defenses (Re: James Wright) 3.5 12/19/08 Research Affirmative Defenses (Re: Answer, James Wright); Research of Legal standing and employee file matters 2.0 12/14/08 Review of First Amended Complaint .9 11/18/08 Review of letter from opposing counsel Diaz and telephone conference with Diaz .7 11/13/08 Telephone conference with Richard Diaz, Esquire Re: (Wright v. City of Opa-Locka); Review of e-mail from Wright and leave time issues 1.6 10/20/08 Receipt and Review of Complaint 9/16/08 Receipt & Review of Release (Re: James Wright) N/C 9/16/08 Preparation & Draft of Release and Settlement Agreement (Re: James Wright) N/C No Charge Executive Session — Removed Total Professional Services Billed: $3,145.00 VKL 4.0 BNW 13.0 Tran Construction Inc. v. City of Opa-locka 12/9/09 Preparation and Emergency Court Hearing with Judge and Opposing Counsel; Telephone conference with opposing counsel; Preparation of proposed Order for Court 2.8 12/8/09 Review of Plaintiff's Verified Motion for Temporary Injunction; Review of Verified Complaint for Relief; Review of Various Attachments and Exhibits; Telephone conference with opposing Counsel; Meeting with City Manager and Staff in Preparation 1.9 Total Professional Services Billed: $869.50 BNW 4.7 City of Opa-locka v. Brownstein 03/12/09 Receipt and Review of Executed Contract (Re: City of Opa-Locka v. Norman and Marjorie Brownstein) N/C 03/13/09 Meeting with Assistant Finance Director, Faye Douglas (Re: City of Opa-Locka v. Norman and Marjorie Brownstein) Preparation and Draft of correspondence to Michael S. Tobin,Esq. (Re: Executed Contract-Norman and Marjorie Brownstein) N/C Total Professional Services Billed: $NO CHARGE Leal v. City of Opa-locka Case No: 08-23259 (Federal Court ) 1/27/09 Review of letter and Settlement Agreement from Eddy Marban 1.5 1/23/09 Preparation of General Agreement Terms for Opposing counsel .8 12/11/09 Telephone conference with Plaintiff's Counsel RE: potential settlement of pending and contract leave cases 1.2 12/10/08 Attendance at Federal Court Hearing for Scheduling Conference; Meeting with opposing Counsel Marban 2.3 11/25/08 Review of various back-up documents from HR RE: officers and leave .6 11/20/08 Telephone conference with Human Resources Director, Sharlene Boyd Re: Roberto Leal; Final Preparation of Complaint 1.3 11/13/08 Receipt and Review of Timesheets .4 11/06/08 Review/Research Documents in support of Complaint .5 10/20/09 Review of Memorandum from Jannie Beverly RE: Leal with back-up .4 10/23/08 Receipt and Review of correspondence from Roberto Leal (Re: Overtime pay); Preparation for Complaint filing .2 Total Professional Services Billed: $1,702.00 VKL 3.0 BNW 6.2 Nikeya Hill/ Natalie Buissereth v. City of Opa-Locka- Case No. 09-CV-20662 06/18/09 Receipt and Review of Order Re:Stipulation of Dismissal of Complaint Re: Nikeya Hill/Natalie Buissereth v. City of Opa-Locka .3 5/29/09 Tele-Conference with Jennifer Daley, Esq.,The Amlong Firm, P.A.; Meeting with Finance, Carol (Re: Nikeya Hill and Natalie Buissereth payment); Receipt and Review of Executed Settlement Agreement (Re: Nikeya Hill); Receipt and Review of Executed Settlement Agreement (Re: Natalie Buissereth); Receipt and Review of Joint Stipulation of Dismissal (Hill, Buissereth v. City of Opa-Locka); Meeting with City Manager 4.1 5/28/09 Receipt and Review of Court Order; Receipt and Review of Plaintiff's Response to Court Order; Two Telephone conferences with Jennifer Daley, Esq., The Amlong Firm, P.A. 1.2 5/27/09 Various telephone conferences with Jennifer Daley, Esq. RE: Settlement issues .7 05/21/09 Telephone conference with Jennifer Daley, Esq., The Amlong Firm, P.A., Meeting with Human Resources Director, Sharlene Boyd (Re: Tax Withholdings/ Settlement Agreements for Nikeya Hill and Natalie Buissereth) .5 05/21/09 Telephone conference with Jennifer Daley, Esq., The Amlong Firm, P.A. (Re: Nikeya Hill and Natalie Buissereth) .4 05/15/09 Tele-Conference with Jennifer Daley, Esq., The Amlong Firm, P.A. (Re: Nikeya Hill and Natalie Buissereth); Meeting with Commissioner Holmes at request Re: Nikeya Hill and Natalie Buissereth .7 05/14/09 Telephone Conference with Jennifer Daley, Esq., The Amlong Firm, P.A. (Re: Counter-offer/Settlement-Nikeya Hill and Natalie Buissereth) .5 05/08/09 Review Public Records Request from The Amlong Firm, P.A.; Meeting with Human Resources Director, Sharlene Boyd Re: Public Records Request; Review of Complaint in Preparation of Response/Answer Re: Nikeya Hill; Research Case law in Preparation of Response/Answer (Re: Natalie Buissereth) 1.5 05/07/09 Receipt and Review of Public Records Request from the Amlong Firm, P.A. Re: Nikeya Hill and Natalie Buissereth v. City of Opa-Locka; Receipt and Review of Correspondence from Jennifer Daley, Esq., The Amlong Firm, P.A. (Re: Nikeya Hill nd Natalie Buissereth); Meeting with City Manager, Bryan Finnie Re: Sexual Harassment Cases (Hill and Buissereth; Telephone conference with Jennifer Daley, Esq. Re: Counter-offer/Nikeya Hill and Natalie Buissereth; legal research 4.5 05/01/09 Research Sexual Harassment Affirmative Defenses (Re: Nikeya Hill/Natalie Buissereth v. City of Opa-locka); Telephone conference with Jennifer Daley, Esq., The Amlong Firm, P.A. (Re: Demand/Nikeya Hill and Natalie Buissereth) .5 04/16/09 Tele-Conference with Jennifer Daley, Esquire/The Amlong Firm Nikeya Hill/Natalie Buissereth v. City of Opa-Locka .4 04/10/09 Research Sexual Harassment Issues (Nikeya Hill/Natalie Buissereth v. City of Opa-Locka) 2.5 04/01/09 Receipt and Review of Complaint Nikeya Hill/Natalie Buissereth v. City of Opa-Locka; Research Sexual Harassment Affirmative Defenses ( Re: Nikeya Hill/Natalie Buissereth v. City of Opa-locka) 3.6 Total Professional Services Billed: Executive Session Not Charged $3,959.00 VKL 21.4 Tamika Miller v. City of Opa-locka (NO CHARGE) 9/02/08 Research current law on Sexual Harassment and Retaliation law (Re: Update on Employment Issues- Re: Tamika Miller v. City of Opa-Locka N/C 9/02/08 Receipt and Review of File Materials in preparation of Mediation N/C 9/03/08 Telephone conference with City Manager, Jannie Beverly N/C Re: Pre-Mediation Strategy- Tamika Miller v. City of Opa- Locka) 9/03/08 Meeting with Director, MDCEOB, Marcus Regalado N/C (Re: Motion to Dismiss Bosque Charge of Discrimination) 9/03/08 Attendance at Mediation (Re: Tamika Miller v. City of Opa-Locka) N/C Travel time to and from Office of Miami Dade County Equal Opportunity Board; Meeting with City Manager, Jannie Beverly Re: Pre-Mediation Strategy 9/02/08 Receipt and Review of File Materials in preparation of Mediation; N/C 9/02/08 Research current law on Sexual Harassment and Retaliation law RE: update on change in law Total Professional Services Billed: $NO CHARGE Foreclosure Cases 12/3/2009 Review of file & Complaint; Preparation of Answer RE: Bank of Coral Gables v. Tierra Garden Apartments 1.2 12/3/2009 Review of file & Complaint; Preparation of Answer RE: Bank of New York v. Candido Cardona 0.9 12/3/2009 Review of file & Complaint; Preparation of Answer RE: One West Bank v. Eneida R. Martinez 0.8 12/3/2009 Review of file & Complaint; Preparation of Answer RE: Us National Bank Ass'n v. Pedro Hernandez 0.9 12/3/2009 Review of file & Complaint; Preparation of Answer RE: US National Bank Ass'n v. Marckson Louis 0.9 11/24/2009 Review of file & Complaint; Preparation of Answer RE: JP Morgan Chase Bank v. Pedro P. Hernandez 1.0 11/20/2009 Review of file & Complaint; Preparation of Answer RE: Bank of America v. Stanley Bien-Aime 0.8 11/20/2009 Review of file & Complaint; Preparation of Answer RE: Bank of New York Mellon v. Zonia Oliveros 1.0 11/20/2009 Review of file & Complaint; Preparation of Answer RE: Bank of New York Mellon v. Eric Smith 1.0 11/20/2009 Review of file & Complaint; Preparation of Answer RE: Deutsche Bank National Trust v. Hattie Burmon 0.8 11/20/2009 Review of file & Complaint; Preparation of Answer RE: JP Morgan Chase Bank v. Iris Doreus 0.9 11/20/2009 Review of file & Complaint; Preparation of Answer RE: JP Morgan Chase Bank v. Magda Hernandez 0.9 10/30/2009 Receipt and Review of Ex Parte Motion for Summary Judgement RE: Deutsch Bank v. Reinaldo Acosta 0.4 10/25/2009 Review of file & Complaint; Preparation of Answer RE: US National Bank Ass'n v. Merline Escarment 1.0 10/16/2009 Receipt and Review of Response of Summons & Complaint RE: Bank of New York Mellon v. Candido Cardona 0.4 10/16/2009 Receipt and Review of Response of Summons & Complaint RE: US Bank National Association v. Pedro Hernandez 0.4 10/15/2009 Receipt and Review Order Granting Default RE: Countrywide Home Loans Servicing LP v. Jaime Herrera 0.3 10/15/2009 Receipt and Review of Order Granting Default RE: The Bank of New York v. Benjamin Cartegena 0.2 10/15/2009 Receipt and Review of Notice of Hearing RE: Bank of America v. Pedro Hernandez 0.2 10/15/2009 Receipt and Review of Response to Request for Production RE: Chase Home Finance v. Pedro Hernandez 0.7 10/1/2009 Receipt and Review of Motion and Correspondence RE: JP Morgan Chase Bank v. Golden Quest Investment Group 0.5 10/1/2009 Receipt and Review Affidavit of Indebtedness RE: Deutsche Bank National Trust Co. v. Louisa Bazemore 0.3 10/1/2009 Receipt and Review of Notice of Cancellation of Hearing RE: CitiMortgage, Inc. v. Ana Lil Remond-Rodriguez 0.2 9/24/2009 TeleConference with Attorney Curtis Turner (David Stern's office) RE: Aurora Loan Services v. Ricardo Alvarez 0.2 9/22/2009 Review of file & Complaint; Preparation of Answer RE: BAC Home Loans v. Carlos A. Fernandez 0.8 9/22/2009 Review of file & Complaint; Preparation of Answer RE: Countrywide Home Loans v. Jaime Herrera 0.9 9/22/2009 Review of file & Complaint; Preparation of Answer RE: HSBC Bank USA v. Pedro A. Hernandez 0.8 9/22/2009 Review of file & Complaint; Preparation of Answer RE: JP Morgan Chase Bank v. Anthony A. Hodge 0.9 9/22/2009 Review of file & Complaint; Preparation of Answer RE: One West Bank v. Salema Hernandez 1.0 9/3/2009 Receipt and Review of Motion for Summary Judgment RE: Deutsch Bank National Trust Company v. James Lewis 0.2 9/3/2009 Receipt and Review of Answer to Complaint &Affirmative Defenses RE: Indymac Bank v. Ana Rodriguez 0.4 8/28/2009 Receipt and Review Motion for Judges Default RE: Bank of New York v. Noemi Colon 0.3 8/28/2009 Receipt and Review of Complaint with Summons RE: Bank of New York v. Zonia Oliveros, Angel Alvarez 0.4 8/28/2009 Receipt and Review of Complaint with Summons RE: J.P. Morgan Chase v. Iris Doreus 0.2 8/28/2009 Receipt and Review Notice of Cancellation RE: Citi Mortgage, Inc. v. Jose A. Diaz 0.2 8/21/2009 Review of file & Complaint; Preparation of Answer RE: lndymac Federal Bank v. Omar Rodriguez 0.8 8/20/2009 Review of file & Complaint; Preparation of Answer RE: Deutsche Bank National Trust v. Louisa Bazemore 0.8 8/20/2009 Receipt and Review of Notice of Hearing (Re: Citi-Mortgage v. Jose Diaz 0.2 8/20/2009 Receipt and Review Notice of Filing Plaintiff's Affidavit of Attorney Fees RE: Bank of New York v. Noemi Colon 0.4 7/31/2009 Receipt and Review Notice RE: HSBC Mortgage Corp, USA v. Gladys Ochoa 0.2 7/31/2009 Receipt and Review of Complaint and Correspondence RE: Countrywide Home Loans Servicing, LP v. Jaime Herrera 0.4 7/31/2009 Receipt and Review Notice of Dropping Defendants RE: U.S. Bank National Association v. 1940, LLC 0.2 7/31/2009 Receipt and Review of Motion for Default RE: Park National Bank v. East Opa-Locka Warehouse, Inc. 0.2 7/17/2009 Receipt and Review of Notice of Voluntary Dismissal RE: The Bank of New York v. Marlene Arroliga 0.2 7/2/2009 Receipt and Review Order Denying Defendant's Motion to Stay RE: Park National Bank v. East Opa-Locka 0.3 7/2/2009 Receipt and Review Order of Default RE: JP Morgan Chase Bank NA v. Lourdes Del Pino 0.2 6/5/2009 Review of file & Complaint; Preparation of Answer RE: CitiMortgage v. Ana Lil Remond-Rodriguez 0.9 6/5/2009 Review of file & Complaint; Preparation of Answer RE: Jose M. Garcia, as Trustee v. Don Saunders 0.9 5/29/2009 Receipt and Review of Plaintiff's Notice of Hearing RE: Park National Bank v. East Opa-locka Warehouse 0.2 5/29/2009 Receipt and Review of Notice of Hearing & Summary Judgment Motion RE: HSBC Mortgage v. Wilfredo Gonzalez 0.2 5/29/2009 Receipt and Review of Notice of Hearing & Summary Judgment Motion RE: HSBC Mortgage v. Wilfredo Gonzalez 0.6 5/14/2009 Review and Receipt of Non-Military Affidavit RE; Chase Home Finance v. Radcliffe Jackson 0.3 5/14/2009 Receipt and Review of Plaintiff's Notice of Filing Non-Military Affidavit RE: Colonial Bank v. Golden Quest 0.3 5/14/2009 Receipt and Review of Plaintiff's Motion for Default RE: Colonial Bank v. Golden Quest Investment Group 0.3 5/6/2009 Review of file & Complaint; Preparation of Answer Chase Home Finance v. Radcliffe Jackson 0.9 5/5/2009- Review of file & Complaint; Preparation of Answer RE: Aurora Loan Services LLC v. Ricardo K. Alvarez 0.9 5/5/2009 Review of file & Complaint; Preparation of Answer RE: Bank of New York v. Marlene C. Arroliga 1.2 5/5/2009 Review of file & Complaint; Preparation of Answer RE: Bank of America v. Olga Benavides 1.0 5/5/2009 Review of file & Complaint; Preparation of Answer RE: Bank of America v. Pedro Fidel Hernandez 1.0 5/5/2009 Review of file & Complaint; Preparation of Answer RE: CitiMortgage v. Jose A. Diaz 0.8 5/5/2009 Review of file & Complaint; Preparation of Answer RE: Countrywide Home Loans v. Misael Morejon 0.8 5/5/2009 Review of file & Complaint; Preparation of Answer RE: Countrywide Home Loans v. Jaime R. Ramirez 0.9 5/5/2009 Review of file & Complaint; Preparation of Answer RE: Deutsch Bank National Trust v. Radcliffe Jackson 0.8 5/5/2009 Review of file & Complaint; Preparation of Answer RE: Indymac Federal Bank v. Ana Rodriguez 0.8 5/5/2009 Review of file & Complaint; Preparation of Answer RE: Park National Bank v. East Opa-locka Warehouse 0.8 5/5/2009 Review of file & Complaint; Preparation of Answer RE: Regions Bank v. Reinaldo A. Carrillo 0.9 5/5/2009 Review of file & Complaint; Preparation of Answer RE: US National Bank Ass'n v. Carla E. Scott 0.8 4/30/2009 Receipt and Review of Motion for Summary Judgment RE: LPP Mortgage v. Twidlin Brown 0.4 3/30/2009 Review of file & Complaint; Preparation of Answer RE: National City Bank v. Lucio Morales 1.2 3/18/2009 Review of file & Complaint; Preparation of Answer RE: Regions Bank v. Golden Quest Investment Group 1.2 3/18/2009 Review of file & Complaint; Preparation of Answer RE: US Bank National Ass'n v. 1940, LLC 0.8 3/13/2009 Review of file & Complaint; Preparation of Answer RE: Bank of America v. Anthony Atkins 0.9 3/13/2009 Review of file & Complaint; Preparation of Answer RE: Bank of New York v. Noemi Colon 0.9 3/13/2009 Review of file & Complaint; Preparation of Answer RE: Indymac Bank v. Leonardo Diaz 0.9 3/13/2009 Review of file & Complaint; Preparation of Answer RE: Nationstar Mortgage v. Keyla Hechevarria 1.2 3/13/2009 Receipt and Review of Order Granting Default RE: Countrywide Home Loans v. Joseph Macker 0.2 3/13/2009 Receipt and Review of Order Granting Default RE: Chase Home Finance v. Jose Gonzalez 0.2 2/20/2009 Receipt and Review of Motion for Summary Judgement RE: JP Morgan Chase Bank v. Golden Quest Investment Group 0.5 2/2/2009 Review of file & Complaint; Preparation of Answer RE: Chase Home Finance v. Pedro Hernandez 0.8 2/2/2009 Review of file & Complaint; Preparation of Answer RE: Countrywide Home Loans v. Edwin Morales 0.8 2/2/2009 Review of file & Complaint; RE: Countrywide Home Loans v. Jaime R. Ramirez 0.3 2/2/2009 Review of file & Complaint; Preparation of Answer RE: Deutsch Bank National Trust v. Reinaldo Acosta 0.9 2/2/2009 Review of file & Complaint; Preparation of Answer RE: HSBC Mortgage v. Wilfredo Gonzales 0.9 2/2/2009 Review of file & Complaint; Preparation of Answer RE: Park National Bank v. East Opa-locka Warehouse 0.9 2/2/2009 Review of file & Complaint; Preparation of Answer RE: Wachovia Bank v. Alberto Torna 0.8 1/20/2009 Review of file & Complaint; RE: Chase Home Finance v. Jose Gonzalez 0.6 1/16/2009 Review of file & Complaint; Preparation of Answer RE: Bank of New York v. Altagracia Navarro 0.8 1/16/2009 Review of file & Complaint; Preparation of Answer RE: CitiFinancial, Inc. v. Wayne Colston 0.8 1/16/2009 Review of file & Complaint; Preparation of Answer RE: Deutsch Bank National Trust v. James Lewis 1.0 1/16/2009 Review of file & Complaint; Preparation of Answer RE: HSBC Mortgage v. Gladys Ochoa 0.9 1/16/2009 Review of file & Complaint; Preparation of Answer RE: Nationstar Mortgage v. Gary Lee Harrell 1.2 1/12/2009 Review of file & Complaint; Preparation of Answer RE: Wachovia Bank v. Radcliffe Jackson 0.8 1/12/2009 Review of file & Complaint; Preparation of Answer RE: Wells Fargo Financial System Florida v. Latoya Reid 0.9 1/8/2009 Receipt and Review of Motion for Extension of Time RE; Deutsch Bank National Trust v. Carlos Fernandez 0.2 12/22/2008 Review of file & Complaint; Preparation of Answer RE: Colonial Bank v. Golden Quest Investment Group 1.2 12/22/2008 Review of file & Complaint; Preparation of Answer RE: D. Wolf as Trustee of D. Wolf Trust v. Anterro Graham 0.9 12/22/2008 Review of file & Complaint; Preparation of Answer RE: CitiGroup Global v. Pedro Llamosa 1.0 12/18/2008 Review of file & Complaint; Preparation of Answer RE: CitiMortgage v. Adalberto Perez 0.9 12/18/2008 Review of file & Complaint; Preparation of Answer RE: Deutsche Bank National Trust v. Fernando Diaz 0.9 12/18/2008 Review of file & Complaint; Preparation of Answer RE: JP Morgan Chase Bank v. Lourdes Del Pino 1.0 11/20/2008 Review of file & Complaint; Preparation of Answer RE:Bank of New York v. John Williams 1.2 11/20/2008 Review of file & Complaint; Preparation of Answer RE: Chase Home Finance v. Hannah Lall 0.8 11/20/2008 Review of file & Complaint; Preparation of Answer RE: LaSalle Bank National Ass'n v. Alberto Hernandez 0.9 11/20/2008 Review of file & Complaint; Preparation of Answer RE: US National Bank Ass'n v. William Arias Rodriguez 0.9 11/17/2008 Review of file & Complaint; Preparation of Answer RE: Indymac Bank v. Luis F. Perez 0.9 11/17/2008 Review of file & Complaint; Preparation of Answer RE: LPP Mortgage v. Twidlin Brown 1.0 11/17/2008 Review of file & Complaint; Preparation of Answer RE: US National Bank Ass'n v. Margot Hernandez 0.8 10/27/2008 Review of file & Complaint; Preparation of Answer RE: US National Bank Ass'n v. William Rodriguez 0.8 10/22/2008 Review of file & Complaint; Preparation of Answer RE: Countrywide Home Loans v. Joseph Macker 1.0 10/22/2008 Review of file & Complaint; Preparation of Answer RE: Indymac Bank v. Maria Diaz 0.8 10/22/2008 Review of file & Complaint; Preparation of Answer RE: National City Mortgage v. Latoya Reid 0.8 10/22/2008 Review of file & Complaint; Preparation of Answer RE: HSBC Bank USA v. Juan Mejia 1.0 10/21/2008 Review of file & Complaint; Preparation of Answer RE: Bank of New York v. Benjamin Cartegena 1.0 10/21/2008 Review of file & Complaint; Preparation of Answer Chase Home Finance v. Olivia Viveros 0.8 10/21/2008 Review of file & Complaint; Preparation of Answer RE: Deutsch Bank National Trust v. Marta Loran 0.8 10/21/2008 Review of file & Complaint; Preparation of Answer RE: Deutsch Bank National Trust v. Marie Francoise Louis 0.9 10/21/2008 Review of file & Complaint; Preparation of Answer RE: US National Bank Ass'n v. Michael Egbebike 0.8 10/14/2008 Review of file & Complaint; T/c with Plaintiffs Counsel RE: Citi Financial Mortgage v. Javier Llera 0.5 10/6/2008 Review of file & Complaint; Preparation of Answer RE: Deutsch Bank National Trust v. Nancy Morales 0.8 10/6/2008 Review of file & Complaint; Preparation of Answer RE: US National Bank Ass'n v. Antoinette Britt 0.8 10/6/2008 Review of file & Complaint; Preparation of Answer RE: Washington Mutual Bank v. Sligo Villa Apartments 0.9 10/6/2008 Review of file & Complaint; Preparation of Answer RE: Wells Fargo Bank v. Pedro Hernandez 1.0 10/2/2008 Review of file & Complaint; RE: Deutsch Bank National Trust v. Rufino Jimenez 0.3 9/24/2008 Review of file & Complaint; RE: LaSalle Bank National Ass'n v. Guillermo Lopez 0.5 9/24/2008 Review of file & Complaint; RE: US National Bank Ass'n v. Carlos M. Fernandez 0.5 9/24/2008 Review of file & Complaint; Preparation of Answer RE: US National Bank Ass'n v. Reinaldo Lopez 0.4 9/24/2008 Review of file & Complaint; RE: Washington Mutual Bank v. Golden Quest Investment 0.6 9/23/2008 Review of file & Complaint; RE: Deutsch Bank National Trust v. Alphonso Knight 0.4 Sub-Total Professional Services: $16,650.00 TOTAL LITIGATION FEES DUE: $37,647.50 TOTAL COSTS$2,684.00 (WAIVED) NOT INCLUDED IN BILLING