1

EXHIBIT “B”

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

MIAMI DIVISION

Case No.: 1:20-cv-22693-MGC

DOLORES REYES, 

Plaintiff,

v.

CITY WATCH PROTECTIVE SERVICES, 

INC. and PERCY PALMA,

Defendants.

 

 

DECLARATION OF RUBEN MARTIN SAENZ AS TO ATTORNEY’S

FEES AND COSTS IN SUPPORT OF THE PARTIES’ JOINT MOTION FOR 

APPROVAL OF FLSA SETTLEMENT AND TO DISMISS CASE WITH PREJUDICE

1. My name is Ruben Martin Saenz. I am the attorney of record for Plaintiff, 

MIGLAISE ALLIANCE (“Plaintiff”). 

2. I am over the age of eighteen (18) years and fully competent to testify as to the 

matters set forth in this declaration. 

3. This declaration is based on my personal knowledge of attorney’s fees and costs to 

be charged and collected, and upon my review of the books and records of Saenz & Anderson, 

PLLC, made in the ordinary course of business and held under my supervision and control.

4. I am an owner of Saenz & Anderson, PLLC and have been a licensed and practicing 

attorney since May 2003. I practice primarily in Miami-Dade and Broward counties in the area of 

employment law, including wage and hour law. Throughout the years, I have successfully litigated, 

I believe, over one thousand cases on behalf of employees fighting injustice at the workplace.

Case 1:20-cv-22693-MGC Document 30-2 Entered on FLSD Docket 12/30/2020 Page 1 of 18
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5. I graduated from Syracuse University, College of Law in 2002. I have been a 

member of the Florida Bar since May of 2003. I am also a member of the United States District 

Court for the Southern District of Florida, the United States District Court for the Middle District 

of Florida, and the United States Court of Appeals for the 11th Circuit.

6. Since 2003, the primary focus of my practice has been employment law. 

7. Throughout my career, my practice has been in both state and federal courts. I have 

consulted, litigated and tried cases involving employees’ rights under the FLSA, Title VII, the 

Florida Civil Rights Act of 1992, Florida Whistleblower’s Act, the Florida Worker’s 

Compensation Act, the Family and Medical Leave Act of 1993 and other employee-related laws.

8. I have been selected as a Florida Rising Star by the Super Lawyers Magazine in 

2012, 2013 and 2014. I have also tried and won what I believe is the largest verdict in a religious 

discrimination case in Florida.

9. I have authored articles, chapters, and the book written in Spanish titled “My Rights 

as an Employee in the U.S., Part 1: The Basic Rights (2010).” Along with my law partner, Ilona 

Anderson, I have also coauthored the book titled “How to File for Employment Discrimination 

with the Equal Employment Opportunity Commission (the EEOC).”

10. My reputation and proven abilities have allowed me to maintain my practice 

through referrals from attorneys and from former and current satisfied clients. 

11. I have prepared (or collaborated in the preparation) and fully reviewed the motion 

for approval of settlement agreement in the instant action and I attest that the motion is wellgrounded in fact and law. 

12. The attached billing and expense records specifically indicate the activity 

performed by my law partner, Ilona Anderson, my firm associate(s), our support team, and by the 

Case 1:20-cv-22693-MGC Document 30-2 Entered on FLSD Docket 12/30/2020 Page 2 of 18
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undersigned in prosecuting the above-styled action. The referenced billing and expense records 

are attached hereto as Exhibit 1 to this declaration. 

13. Ms. Anderson and my firm’s legal team are highly experienced in litigating 

employment matters, including cases under the FLSA. 

14. I believe the number of hours spent in the instant case was reasonable and 

necessary considering the nature of this litigation and all the circumstances surrounding it. 

15. My firm routinely bills all its FLSA cases for plaintiffs at the rate of $400.00 per 

hour for the professional services that are rendered. My hourly rate of $400.00 per hour reflects 

my skill and experience in litigating employment cases and is reasonable considering the relevant 

legal marketplace. My firm’s attorneys, who helped me litigate this case under my supervision, 

also bill at the rate of $400.00 per hour or $250.00 per hour. Their relevant experience is 

highlighted in my firm’s website (https://www.saenzanderson.com/attorneys/). 

16. In specific, my associate Aron Smukler, Esq., who works under my supervision and 

control, bills at a rate of $250.00 per hour. He has experience litigating employment cases as he 

has been working for my firm first as a paralegal since August of 2018 and then as an attorney at 

law since April 16, 2020. Mr. Smukler is knowledgeable in FLSA law and has attended at least 3 

of my trials.

17. My associate Yadhira Ramirez-Toro, Esq., who works under my supervision and 

control, bills at a rate of $400.00 per hour. Mrs. Ramirez-Toro has been admitted to practice law 

in the Commonwealth of Puerto Rico since 1995 and in the State of Florida since 2015. Prior to 

joining Saenz & Anderson, PLLC, Mrs. Ramirez-Toro focused exclusively in the federal forum, 

representing officials from the executive, legislative, and judiciary branches of the Commonwealth 

of Puerto Rico and the Government itself in lawsuits before the U.S. District Court for the District 

Case 1:20-cv-22693-MGC Document 30-2 Entered on FLSD Docket 12/30/2020 Page 3 of 18
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of Puerto Rico. Mrs. Ramirez-Toro has ample experience as a trial attorney in Civil Rights cases 

and labor and employment matters, including without limitation Title VII, ADA, and FMLA.

18. Additionally, Tanesha Walls Blye, Esq., who works under my supervision and 

control, bills at a rate of $400.00 per hour. Mrs. Blye was admitted to practice law in the State of 

Florida in 2004. Prior to joining Saenz & Anderson, PLLC, Mrs. Blye owned and operated her 

own business which focused on the investigation of employment discrimination claims filed by 

government employees; practiced as an Associate Attorney; and was an Assistant Public Defender 

at the Miami-Dade County Public Defender’s Office. As a zealous advocate, Mrs. Blye has tried 

over a dozen jury trials, and successfully resolved hundreds of cases on her clients’ behalf through 

settlement negotiations, motion practice, mediation, and arbitration.

19. Based upon my experience, familiarity with rates charged by other lawyers, and 

fees awarded in similar litigation by federal district courts and state circuit courts in Florida, I 

believe that my rate of $400 per hour, and that of those attorneys associated with my firm of $400 

and $250 per hour are reasonable. I also believe that my law clerk and paralegal’s rate ($75 per 

hour) is also reasonable.

20. I am of the opinion that the work performed was done efficiently and effectively 

and that the time spent on that work was reasonable and not excessive.

21. The undersigned is seeking compensation for attorneys’ fees incurred on behalf of 

Plaintiff. However, I specifically agree to reduce my total billing invoice to the amount indicated 

in the settlement agreement and in the motion for approval of the FLSA settlement agreement 

because I believe such reduction was necessary to help my client reach a favorable settlement in 

her case. 

Case 1:20-cv-22693-MGC Document 30-2 Entered on FLSD Docket 12/30/2020 Page 4 of 18
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22. In addition, my law firm has spent $690.00 on behalf of the Plaintiff. The 

undersigned is seeking reimbursement in the amount of $690.00.

UNDER PENALTIES OF PERJURY, I DECLARE THAT I HAVE READ THE 

FOREGOING DECLARATION AND THAT THE FACTS STATED IN IT ARE TRUE.

s/R. Martin Saenz

R. MARTIN SAENZ, ESQ.

Case 1:20-cv-22693-MGC Document 30-2 Entered on FLSD Docket 12/30/2020 Page 5 of 18
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EXHIBIT “1”

(INSERT BILLING AND EXPENSE RECORDS – INVOICE – HERE) 

Case 1:20-cv-22693-MGC Document 30-2 Entered on FLSD Docket 12/30/2020 Page 6 of 18
Reyes, Dolores v. City Watch Protective Services

Time Entries

Date EE Activity Description Rate Hours Line Total

06/02/2020 YR Draft complaint $400.00 0.45 $180.00

06/03/2020 YR Telephone

conference with: client re: clarify facts for complaint $400.00 0.10 $40.00

06/03/2020 YR Receive and

Review: pictures of time sheets sent by plaintiff $400.00 0.70 $280.00

06/03/2020 YR Draft complaint $400.00 1.30 $520.00

06/03/2020 YR Telephone

conference with:

plaintiff re: pictures of time sheets received;

average hours worked per week $400.00 0.10 $40.00

06/11/2020 YR Draft complaint $400.00 3.50 $1,400.00

06/17/2020 YR Receive and

Review: text message from client re: job offer $400.00 0.10 $40.00

06/17/2020 YR Telephone

conference with:

client re: case status; conversation held with former

employer; consequences of accepting new job offer

$400.00 0.30 $120.00

06/17/2020 YR Complete draft of complaint $400.00 1.40 $560.00

06/22/2020 IDA Review file; prepare and send email to TB re: complaint. $400.00 0.20 $80.00

06/23/2020 TB Revise draft complaint. $400.00 0.50 $200.00

06/23/2020 YR Receive, review

and respond text message from client $400.00 0.10 $40.00

06/23/2020 TB Review and

Finalize Draft

Complaint. $400.00 0.40 $160.00

06/24/2020 YR Receive and

Review: revisions to draft of complaint $400.00 0.20 $80.00

06/26/2020 YR Telephone

conference with: client re: complaint $400.00 0.30 $120.00

Saenz & Anderson, PLLC

20900 NE 30th Avenue

Ste 800

Aventura, Florida 33180

United States

305-503-5131

Balance

Invoice #

Invoice Date

Payment Terms

Due Date

$16,932.50

00270

December 29, 2020

Due on Receipt

December 29, 2020

Dolores Reyes

717 NW 1st St.

Hallandale, FL 33009

Case 1:20-cv-22693-MGC Document 30-2 Entered on FLSD Docket 12/30/2020 Page 7 of 18
06/29/2020 YR

Review client's file

and docket

intake and notes of interview to clarify facts alleged

in draft of complaint $400.00 0.35 $140.00

06/29/2020 YR Edit complaint $400.00 1.15 $460.00

06/29/2020 YR Receive and

Review: draft of complaint with edits by TB $400.00 0.10 $40.00

06/29/2020 YR Telephone

conference with: TB re: final draft of complaint $400.00 0.50 $200.00

06/29/2020 YR

Prepare and send

email to co

counsel:

IDA & AS re: final version of complaint ready to be

filed $400.00 0.10 $40.00

06/30/2020 AS Draft Summonses $250.00 0.10 $25.00

06/30/2020 AS Revise and Finalize Complaint $250.00 0.10 $25.00

06/30/2020 AS Draft Civil Cover Sheet $250.00 0.10 $25.00

06/30/2020 AS File complaint $250.00 0.25 $62.50

06/30/2020 AS

Correspond with

process server re:

service of process

$250.00 0.15 $37.50

07/01/2020 RS

Review client's file

and docket of

events to determine

status of case and

analyze strategy

and next step.

$400.00 0.60 $240.00

07/01/2020 RS

Receive, review,

docket and analyze

trial and discovery

strategy based on

document reviewed

re:

Order of referral to magistrate and ordering

statement of claim. $400.00 0.40 $160.00

07/01/2020 YR Receive and

Review: ECF 4 $400.00 0.10 $40.00

07/01/2020 YR Receive and

Review: ECF 5 $400.00 0.10 $40.00

07/06/2020 YR Receive, review

and respond text message from client re: update on case $400.00 0.10 $40.00

07/06/2020 YR Receive and

Review: text message from client re: update $400.00 0.10 $40.00

07/06/2020 YR Prepare and Send text message to client $400.00 0.10 $40.00

07/08/2020 UL upload docs $75.00 0.10 $7.50

07/08/2020 UL upload docs upload - add deadlines $75.00 0.10 $7.50

07/15/2020 AS Draft statement of claim $250.00 0.50 $125.00

07/15/2020 UL upload docs $75.00 0.05 $3.75

07/15/2020 AS FInalize and FIle statement of claim $250.00 0.10 $25.00

07/21/2020 UL upload docs $75.00 0.10 $7.50

07/21/2020 UL upload docs upload - add expenses $75.00 0.05 $3.75

Case 1:20-cv-22693-MGC Document 30-2 Entered on FLSD Docket 12/30/2020 Page 8 of 18
07/27/2020 DT Conference With

Client reReach out to the client to obtain paystubs or anydocuments related to her claim. $75.00 0.15 $11.25

07/27/2020 DT Conference Conference w/ YRT re: Client docs sent $75.00 0.10 $7.50

07/27/2020 AS Review and Revise

Certificate of Interested Party and Notice of

Pendency of Action

$250.00 0.20 $50.00

07/27/2020 AS Confer with

Paralegal DT re client's documents for SOC $250.00 0.10 $25.00

07/28/2020 AS Confer with

Paralegal DT re client's documents for SOC $250.00 0.10 $25.00

07/28/2020 DT Draft & File

Convert draft to PDF for Notice & Certificate, then

file with court. $75.00 0.20 $15.00

07/29/2020 RS Receive, Review

and Docket

Defendant's Certificate of Other Affiliates/Corporate

Disclosure Statement - $400.00 0.10 $40.00

07/29/2020 UL upload docs $75.00 0.10 $7.50

07/29/2020 YR Prepare and Send email to DT, paralegal copying UL, paralegal re:

documents produced by plaintiff $400.00 0.35 $140.00

07/29/2020 DT upload Examine 30 emails containing redundant

documents, extract, and upload. $75.00 0.70 $52.50

07/29/2020 DT email Bates Stamp Documents, Send SOC, Order &

docs to OC. $75.00 0.30 $22.50

07/29/2020 DT Draft & File Draft & File Notice of Compliance for SOC $75.00 0.10 $7.50

07/29/2020 DT Review Mark Tasks Complete $75.00 0.05 $3.75

07/29/2020 DT Update Update atty information $75.00 0.10 $7.50

07/29/2020 RS

Receive, review,

docket and analyze

trial and discovery

strategy based on

document reviewed

re:

$400.00 0.50 $200.00

07/29/2020 YR Receive, review

and respond text message from client re: documents $400.00 0.10 $40.00

07/29/2020 UL upload docs upload-file $75.00 0.10 $7.50

07/29/2020 YR Receive and

Review: ECF 14 $400.00 0.10 $40.00

07/29/2020 YR Prepare and Send text message to client with update of proceedings $400.00 0.10 $40.00

07/30/2020 UL upload docs $75.00 0.10 $7.50

07/31/2020 UL upload docs $75.00 0.10 $7.50

08/03/2020 AS Receive and

Review: ECF 14 order on deadlines $250.00 0.10 $25.00

08/04/2020 UL Calendar deadlines $75.00 0.60 $45.00

08/05/2020 AS Receive and

Review: Defendant's MTD $250.00 0.30 $75.00

08/05/2020 AS Reveiw answer to complaint $250.00 0.20 $50.00

Case 1:20-cv-22693-MGC Document 30-2 Entered on FLSD Docket 12/30/2020 Page 9 of 18
08/06/2020 RS

Receive, review,

docket and analyze

trial and discovery

strategy based on

document reviewed

re:

$400.00 0.40 $160.00

08/06/2020 RS Receive, Review

and Docket

$400.00 0.40 $160.00

08/06/2020 AS Research If D can make jury demand $250.00 0.60 $150.00

08/06/2020 UL upload docs upload-add deadline $75.00 0.10 $7.50

08/06/2020 AS Draft Motion to strike Ds' jury demand $250.00 3.70 $925.00

08/06/2020 IDA Correspond with team re: strategy with regard to defendant's

jury demand. $400.00 0.10 $40.00

08/17/2020 UL upload docs $75.00 0.05 $3.75

08/19/2020 AS Confer with CoCounsel

TB re response to MTD and potential need for

extension of time

$250.00 0.10 $25.00

08/19/2020 AS Receive and

Review: Draft response to MTD $250.00 0.15 $37.50

08/19/2020 JR Draft Drafted the Plaintiff's Response in Opposition to

Defendants' Motion to Dismiss

$75.00 4.50 $337.50

08/19/2020 AS Review and Revise response to MTD $250.00 0.60 $150.00

08/19/2020 AS FInalize and FIle Response to MTD $250.00 0.15 $37.50

08/25/2020 UL upload docs $75.00 0.05 $3.75

08/25/2020 AS Review and Revise Motion to strike $250.00 0.50 $125.00

08/25/2020 AS Confer with OC re motion to strike $250.00 0.10 $25.00

08/25/2020 AS Confer with OC conferral as to motion to strike $250.00 0.10 $25.00

08/25/2020 DT rule 26 disclosures

Call to Client and everyone in the office to assist

with translation for R26. $75.00 0.30 $22.50

08/25/2020 AS Confer with CoCounsel TB re motion to strike $250.00 0.20 $50.00

08/28/2020 AS Draft election to magistrate forms $250.00 0.20 $50.00

09/09/2020 AS Phone conference

with client

case update $250.00 0.25 $62.50

09/14/2020 AS Draft initial witness list $250.00 0.45 $112.50

09/14/2020 AS Confer with

Paralegal BG re witness list $250.00 0.10 $25.00

09/14/2020 AS Finalize & Send witness list to OC $250.00 0.10 $25.00

09/15/2020 UL upload docs NOTICE of Attorney Appearance $75.00 0.05 $3.75

09/15/2020 UL upload docs PLAINTIFF’S INITIAL WITNESS LIST $75.00 0.05 $3.75

09/15/2020 UL upload docs Def witness list $75.00 0.05 $3.75

10/05/2020 AS Correspond with

Client

case update $250.00 0.15 $37.50

10/15/2020 AS Receive & Confer

discovery requests to P & confer with DT re

responses

$250.00 0.15 $37.50

Case 1:20-cv-22693-MGC Document 30-2 Entered on FLSD Docket 12/30/2020 Page 10 of 18
10/16/2020 RS Receive, Review

and Docket

Defendants' discovery requests (interrogatories and

requests for production); create tasks to respond to

discovery.

$400.00 0.40 $160.00

10/16/2020 UL upload docs

upload discovery rqts

add deadline to calendar

do letter

do envelope

scan upload

send email

$75.00 0.35 $26.25

10/19/2020 DT Deposition

Deposition: Call to Client re deposition dates, Call

to UL. $75.00 0.35 $26.25

10/19/2020 UL Deposition call with client regarding availability $75.00 0.25 $18.75

10/20/2020 DT Deposition Deposition coordination $75.00 0.15 $11.25

10/20/2020 UL Review review tasks

send email $75.00 0.25 $18.75

10/21/2020 AS Receive and

Review: notice of taking p's deposition $250.00 0.05 $12.50

10/22/2020 AS Receive and

Review: ECF No. 23 $250.00 0.05 $12.50

10/22/2020 AGT upload docs Notices $75.00 0.05 $3.75

10/26/2020 UL Deposition

upload notice

add to calendar

do letter

do envelope

scan

upload

send email

$75.00 0.20 $15.00

10/26/2020 UL Mediation

coordinate

schedule

do notice

file

send email

add to calendar

$75.00 0.35 $26.25

10/26/2020 AGT upload docs

2020-10-26 Proposed ORDER SCHEDULING

MEDIATION

NOTICE

$75.00 0.05 $3.75

10/27/2020 UL upload docs review uploads $75.00 0.05 $3.75

10/29/2020 AGT upload docs 2020-10-28 NOTICE OF MEDIATION $75.00 0.05 $3.75

10/29/2020 UL Review review calendar

send email $75.00 0.15 $11.25

10/29/2020 AS confer DT re rescheduling P's depo $250.00 0.05 $12.50

11/02/2020 DT Discovery

responses

Discovery: Call to Client w/ BG $75.00 0.15 $11.25

11/02/2020 DT Discovery Discovery: responses translation w/ BG $75.00 1.65 $123.75

11/02/2020 BG Discovery discovery meeting with client $75.00 1.30 $97.50

11/02/2020 DT rule 26 disclosures R26 Discs $75.00 0.65 $48.75

11/03/2020 DT Discovery

responses

Discovery responses: Prepare & Send Drafted

responses to AS $75.00 2.70 $202.50

Case 1:20-cv-22693-MGC Document 30-2 Entered on FLSD Docket 12/30/2020 Page 11 of 18
11/04/2020 UL upload docs

notice of mediation

do letter

do envelope

scan

upload

send email

$75.00 0.15 $11.25

11/04/2020 AS Revise and Send P's initial disclosures & documents $250.00 0.60 $150.00

11/05/2020 UL Rule 26

Conference

coordinate

send email $75.00 0.10 $7.50

11/05/2020 AGT upload docs 2020-11-04 P's Initial Disclosures $75.00 0.05 $3.75

11/05/2020 JR Discovery Drafted discovery package (RFP, ROGS, RFA) $75.00 1.00 $75.00

11/10/2020 AS confer with DT re P's discovery responses $250.00 0.10 $25.00

11/10/2020 DT Call Discovery: Call to BG re client docs & Jurat Page $75.00 0.10 $7.50

11/10/2020 DT Discovery Email to AS & BG $75.00 0.10 $7.50

11/10/2020 DT Discovery Call from BG re Discovery $75.00 0.10 $7.50

11/10/2020 BG Discovery Notary meeting with Client $75.00 0.30 $22.50

11/10/2020 AS Draft P's responses to interrogatories $250.00 1.30 $325.00

11/10/2020 AS Draft P's responses to RFP $250.00 1.10 $275.00

11/12/2020 UL Discovery

responses

upload

update

serve

$75.00 0.40 $30.00

11/12/2020 DT Coordinate Depo

Deposition coordination: review emails, update

calendar, send email to TB to confirm deponents. $75.00 0.65 $48.75

11/19/2020 AS Receive and

Review: ECF No. 26 $250.00 0.05 $12.50

11/19/2020 AGT upload docs NOTICE OF APPEARANCE $75.00 0.05 $3.75

11/19/2020 AS Receive and

Review: P's signed affidavit $250.00 0.10 $25.00

11/19/2020 UL Review review uploads $75.00 0.05 $3.75

11/20/2020 DT Coordinate Depo

Deposition: follow-up with OC for confirmation of

link and interpreter. $75.00 0.15 $11.25

11/20/2020 UL Deposition

review

add zoom link

send to client

$75.00 0.20 $15.00

11/20/2020 AS Receive and

Review: Defendants R26 ID $250.00 0.20 $50.00

11/20/2020 AS Depo Prep with P $250.00 0.30 $75.00

11/20/2020 AS confer with client & OC re scheduling/rescheduling

depositions & settlement $250.00 0.60 $150.00

11/20/2020 DT Deposition

Deposition coordination: Client cancelled depo.

Review calendar, finalize topics, Call AS, Call to

TB, Call to UL to strategize.

$75.00 1.05 $78.75

11/22/2020 AS confer with OC re rescheduling P depo & scheduling

depositions

$250.00 0.10 $25.00

11/23/2020 DT Coordinate Depo

Deposition coordination: Calls to As, confer w/ Ul,

message to TB, and Email to OC. $75.00 0.55 $41.25

Case 1:20-cv-22693-MGC Document 30-2 Entered on FLSD Docket 12/30/2020 Page 12 of 18
11/23/2020 DT Coordinate Depo

Deposition coordination: Send msg to TB and

update calendar. $75.00 0.10 $7.50

11/23/2020 AS confer with Plaintiff, OC, & DT re rescheduling deposition

& depositions

$250.00 0.60 $150.00

11/23/2020 DT email Deposition Coordination: Confer w/ UL Email AS. $75.00 0.10 $7.50

11/23/2020 AGT upload docs 2020-11-20 D's Rule 26 Initial Disclosures $75.00 0.05 $3.75

11/23/2020 AS confer topics for Corp Rep deposition $250.00 0.10 $25.00

11/23/2020 AS Confer with OC re depositions and settlement $250.00 0.30 $75.00

11/24/2020 AS confer DT re P's deposition $250.00 0.05 $12.50

11/24/2020 AS Revise and Serve discovery requests to Defendants $250.00 1.20 $300.00

11/24/2020 UL Deposition

coordinate

check availability

send email

$75.00 0.50 $37.50

11/25/2020 UL Deposition

coordinate

do notices

send email

$75.00 0.65 $48.75

11/25/2020 UL upload docs

discovery rqts

add deadline

$75.00 0.10 $7.50

11/25/2020 AGT upload docs Defendant's RESPONSE to [6] Statement of Claim $75.00 0.05 $3.75

11/25/2020 AS Receive and

Review: ECF No. 27 $250.00 0.20 $50.00

11/30/2020 AS Receive and

Review: notices of taking depositions & objections $250.00 0.20 $50.00

11/30/2020 AS Confer with OC re payment of cancellation invoice $250.00 0.10 $25.00

11/30/2020 UL Deposition

coordinate

send email $75.00 0.10 $7.50

11/30/2020 DT Coordinate Depo Deposition coordination: Email to OC $75.00 0.10 $7.50

11/30/2020 AS Correspond with OC, Thor & IA re interpreter invoice & payment $250.00 0.15 $37.50

11/30/2020 AS Revise notice of taking CR deposition $250.00 0.15 $37.50

12/01/2020 UL Deposition

upload notice

add to calendar

do letter

do envelope

send email

$75.00 0.25 $18.75

12/01/2020 UL Deposition

do notices

add to calendar

send email

$75.00 0.25 $18.75

12/02/2020 AS Correspond IA re cancellation payment $250.00 0.05 $12.50

12/03/2020 UL Review

case review

reconfirm depos mediation appointments deadlines

send email

$75.00 0.60 $45.00

12/04/2020 UL Deposition add and send zoom links $75.00 0.15 $11.25

12/06/2020 TB Depo Prep

Review file and draft questions to prepare to take

the deposition of Plaintiff's Corporate

Representative.

$400.00 3.10 $1,240.00

12/07/2020 AS Correspond with OC & client re settlement $250.00 1.50 $375.00

Case 1:20-cv-22693-MGC Document 30-2 Entered on FLSD Docket 12/30/2020 Page 13 of 18
12/07/2020 TB Correspond with

OC

regarding non-monetary terms of settlement via

email and telephone. $400.00 0.40 $160.00

12/07/2020 TB Telephone

conference with:

Attorney Aron Smukler regarding settlement

negotiations. $400.00 0.30 $120.00

12/07/2020 TB Depo Prep

Continue to draft questions for deposition of

Defendants' corporate representative. $400.00 0.50 $200.00

12/07/2020 AS Draft settlement agreement $250.00 0.60 $150.00

12/07/2020 UL Draft

notice of cancellation

send email

upload

$75.00 0.40 $30.00

12/07/2020 UL Draft notice of settlement $75.00 0.15 $11.25

12/07/2020 UL Deposition respond email $75.00 0.05 $3.75

12/08/2020 AGT upload docs 2020-12-08 US Legal Cancellation Notice. $50.00 0.05 $2.50

12/08/2020 AS Receive and

Review: notice of settlement $250.00 0.10 $25.00

12/08/2020 UL File

notice of settlement

add deadline

clear calendar

$75.00 0.10 $7.50

12/09/2020 UL Deposition

cancellation fee waived

respond to emails

$75.00 0.20 $15.00

12/09/2020 UL upload docs $75.00 0.05 $3.75

12/11/2020 AS Revise and Send settlement agreement to OC $250.00 0.50 $125.00

12/15/2020 AS Correspond with

OC re settlement agreement $250.00 0.10 $25.00

12/16/2020 AS Correspond with

OC re settlement agreement $250.00 0.10 $25.00

12/17/2020 AS Review and Confer

D's revisions to settlement agreement & confer

with OC re same

$250.00 0.35 $87.50

12/18/2020 UL settlement

upload settlement agreement

prepare doc for esignature

call client

$75.00 0.10 $7.50

12/21/2020 AS Correspond with

OC settlement agreement $250.00 0.10 $25.00

12/21/2020 TB Review, Revise,

and Confer with client regarding settlement agreement. $400.00 0.90 $360.00

12/23/2020 AS Confer with OC re executing SA $250.00 0.10 $25.00

12/23/2020 AGT upload docs

Administrative Order Closing Case and Requiring

parties to submit a settlement Agreement $50.00 0.05 $2.50

12/28/2020 AS Correspond with

OC re executed settlement agreement $250.00 0.10 $25.00

12/28/2020 AS Receive and

Review: ECF No. 29 $250.00 0.10 $25.00

12/29/2020 AS Draft joint motion for approval and exhibits $250.00 1.50 $375.00

12/29/2020 RS Review and revise joint motion for approval of settlement

agreement with attachments and declaration. $400.00 0.40 $160.00

Totals: 70.35 $16,242.50

Case 1:20-cv-22693-MGC Document 30-2 Entered on FLSD Docket 12/30/2020 Page 14 of 18
Expenses

Date EE Activity Description Cost Quantity Line Total

06/30/2020 AS File complaint $400.00 1.0 $400.00

07/02/2020 UL Service of Process

on Defendant(s) City Watch $40.00 1.0 $40.00

07/21/2020 UL Service of Process

on Defendant(s) Percy Palma $120.00 1.0 $120.00

11/25/2020 TAG Interpreting Spanish Interpreting Service $130.00 1.0 $130.00

Non-billable Expenses:

06/30/2020 AS

Flat fee for copying

and postage per

retainer agreement

$100.00 1.0 $100.00

Expense Total: $690.00

Time Entry Sub-Total:

Expense Sub-Total:

Sub-Total:

Total:

Amount Paid:

$16,242.50

$690.00

$16,932.50

$16,932.50

$0.00

Balance Due: $16,932.50

Case 1:20-cv-22693-MGC Document 30-2 Entered on FLSD Docket 12/30/2020 Page 15 of 18
Lindsay Legal Services, Inc

7105 SW 8th Street

Suite 307

Miami, FL 33144

Phone: (305) 273-0317

INVOICE Invoice #RLA-2020001583

7/2/2020

R. Martin Saenz, Esq

Saenz & Anderson, PLLC

20900 Ne 30th Ave

Ste 800

Miami, FL 33180

Please enclose a copy of this invoice with your payment.

Page 1 / 1

Copyright © 1992-2020 Database Services, Inc. - Process Server's Toolbox V8.1c

Case Number: 20-CV-22693-MGC

Plaintiff:

DOLORES REYES

Defendant:

CITY WATCH PROTECTIVE SERVICES, INC. and PERCY PALMA

Received: 6/30/2020 Served: 7/1/2020 3:10 pm CORPORATE

To be served on: CITY WATCH PROETECTIVESERVICES, INC. C/O AMIT, ADI, ESQ.

ITEMIZED LISTING

Line Item Quantity Price Amount

Service Fee Broward 1.00 40.00 40.00

TOTAL CHARGED: $40.00

BALANCE DUE: $40.00

Case 1:20-cv-22693-MGC Document 30-2 Entered on FLSD Docket 12/30/2020 Page 16 of 18
Lindsay Legal Services, Inc

7105 SW 8th Street

Suite 307

Miami, FL 33144

Phone: (305) 273-0317

INVOICE Invoice #RLA-2020001584

7/21/2020

R. Martin Saenz, Esq

Saenz & Anderson, PLLC

20900 Ne 30th Ave

Ste 800

Miami, FL 33180

Please enclose a copy of this invoice with your payment.

Page 1 / 1

Copyright © 1992-2020 Database Services, Inc. - Process Server's Toolbox V8.1c

Case Number: 20-CV-22693-MGC

Plaintiff:

DOLORES REYES

Defendant:

CITY WATCH PROTECTIVE SERVICES, INC. and PERCY PALMA

Received: 6/30/2020 Served: 7/21/2020 2:23 pm INDIVIDUAL/PERSONAL

To be served on: PERCY PALMA

ITEMIZED LISTING

Line Item Quantity Price Amount

Service Fee Local 1.00 35.00 35.00

Skip Trace 1.00 50.00 50.00

2nd Add: 18651 SW 104th St, Miami, Fl. 33196 1.00 35.00 35.00

TOTAL CHARGED: $120.00

BALANCE DUE: $120.00

Case 1:20-cv-22693-MGC Document 30-2 Entered on FLSD Docket 12/30/2020 Page 17 of 18
INVOICE

Mykola Tyshchenko, Interpreter: Spanish, Russian, Ukrainian, Bulgarian. Also

covering Portuguese, Creole, Mandarin, Romanian and other languages

through my associates.

Mykola Tyshchenko

6705 SW 113th Avenue

Miami, Florida 33173

United States

Phone: (786) 263 0000

Mobile: (305) 793 0619

BILL TO

Adi Amit, P.A.

101 Northeast 3rd Avenue

Suite 300

Fort Lauderdale, 33301

(954) 533-5922

adi@defenderofbusiness.com

Invoice Number: 3316415

Invoice Date: November 25, 2020

Payment Due: December 10, 2020

Amount Due (USD): $130.00

Services Hours Rate Amount

Spanish Interpreting Service

Case No.: 1:20-cv-22693-MGC

DOLORES REYES,

Plaintiff,

v.

CITY WATCH PROTECTIVE SERVICES,

INC. and PERCY PALMA,

Defendants.

NAME(S): DOLORES REYES

DATE: Monday, November 23, 2020 at 10:00 a.m.

SAME DAY CANCELATION

2 $130.00 $260.00

Discount in Consideration

Discount in consideration of the circumstances.

1 ($130.00) ($130.00)

Total: $130.00

Amount Due (USD): $130.00

Notes / Terms

Thank you for your business!

Please make check to Mykola Tyshchenko, 6705 SW 113th Ave, Miami, FL 33173. Any unpaid amount of this invoice after the

due date, shall accrue interest at the rate of 5% per month. Overdue invoices shall be subject to penalty fee, cost of collection,

and attorney’s fees. Should you have any questions, please contact me at: nt.interpreter@gmail.com. Thank you!

Mykola Tyshchenko, Interpreter: Spanish, Russian, Ukrainian, Bulgarian. Also covering Portuguese, Creole, Mandarin,

Romanian and other languages through my associates.

Case 1:20-cv-22693-MGC Document 30-2 Entered on FLSD Docket 12/30/2020 Page 18 of 18