UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

WEST PALM BEACH DIVISION

CASE NO.: 9:20-cv-81307

AFFORDABLE AERIAL PHOTOGRAPHY, 

INC.,

Plaintiff,

v.

PALM BEACH REAL ESTATE, INC. AND 

TARA EDEN PEARL,

Defendants.

DECLARATION OF JOEL B. ROTHMAN IN SUPPORT OF MOTION FOR FINAL

DEFAULT

I, Joel B. Rothman, declare and say:

1. I am an attorney duly licensed to practice before this Court, and I am counsel for 

Plaintiff AFFORDABLE AERIAL PHOTOGRAPHY, INC. (“AAP”) in the above-captioned 

matter. I make this Declaration, which is filed in support of Plaintiff’s Motion for Entry of a

Final Judgment of Default and Incorporated Memorandum of Law, and I could and would testify 

competently to the matters set forth herein.

2. On August 12, 2020, AAP filed its Complaint against Defendants PALM BEACH 

REAL ESTATE, INC. AND TARA EDEN PEARL (“PBRE AND PEARL”) [ECF 1].

3. AAP has incurred $488.10.00 in costs in pursuit of this case.

4. This figure includes $80.00 for process service, $400 in filing fees, and $8.10 for 

priority mail.

5. In addition to these costs, AAP has incurred $3387.50 in attorney’s fees.

Case 9:20-cv-81307-RKA Document 12-2 Entered on FLSD Docket 10/15/2020 Page 1 of 10
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6. Attached as Exhibit 1 is our invoice that details the work done by SRIPLAW in 

connection with this matter.

7. Though the matter was uncontested, considerable time was spent investigating the 

factual circumstances of the matter, drafting the notice letter to PBRE and Pearl, drafting the 

Complaint in this matter, obtaining the Default, and drafting the Motion for entering Default 

Judgment, and corresponding Declarations.

8. My billing rate is $475 per hour and I expended 0.1 hours on this matter.

9. Attorney Jason S. Weiss’ billing rate for 2019 was $375 and he expended 0.2 

hours. Attorney Weiss’ billing rate for 2020 is $425 per hour and he expended 0.2 hours on this 

matter.

10. Attorney Craig A. Wirth has a billing rate of $350 per hour and expended 1.0 

hour on this matter. 

11. Attorney Meir Teitelbaum’s billing rate was $250 for 2019 and he expended 1.0 

hours. Attorney Teitelbaum’s billing rate for 2020 is $300 per hour and he expended 5.3 hours 

on this matter.

12. Paralegal Jamie C. James has a billing rate of $200 per hour and expended 4.4 

hours on this matter

13. Paralegal Michael R. Mulvaney has a billing rate of $200 per hour and expended 

0.3 hours on this matter.

14. Investigator Kimberly Abajian has a billing rate of $200 per hour and expended 

0.1 hour on this matter.

Case 9:20-cv-81307-RKA Document 12-2 Entered on FLSD Docket 10/15/2020 Page 2 of 10
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15. Legal assistant Lia M. DiNuzzo had a billing rate of $125 per hour in 2019 and 

expended 0.1 hours. Ms. DiNuzzo’s billing rate is $175 for 2020 and she expended 0.1 hours on 

this matter.

16. Following the lodestar method of multiplying the per hour billing rate times the 

number of hours expended on the matter, the total amount of attorney’s fees are $3,387.50.

17. These fees are reasonable because they reflect the market rate for services of 

similar quality and nature in the local area. 

I declare under perjury under the laws of the United States of America that the foregoing 

is true and correct.

Executed on October 15, 2020 at Boca Raton, Florida.

JOEL B. ROTHMAN

Case 9:20-cv-81307-RKA Document 12-2 Entered on FLSD Docket 10/15/2020 Page 3 of 10
Exhibit 

1

Case 9:20-cv-81307-RKA Document 12-2 Entered on FLSD Docket 10/15/2020 Page 4 of 10
Affordable Aerial Photography, Inc.

1938 Gray Falcon Circle SW

Vero Beach, FL 32962

00022-0060 - Affordable Aerial Photography, Inc. v.

Palm Beach Real Estate

Copyright Infringement FLORIDA

Fees

Date Description Staff Rate Hours Total

09/20/2019 Services provided on 9/20/2019

- Matter review (0.10 hrs)

JSW $425.00 0.10 $42.50

10/01/2019 Services provided on 10/1/2019

- 2019.07.22. Demand Letter to PBRE

(1) edited and reviewed (0.10 hrs)

- Copyright - Follow-Up Demand Letter

- Image NOT removed created (0.10

hrs)

- 1 email sent/reviewed regarding

Affordable Aerial Photography, Inc. v.

Palm Beach Real Estate, Inc. (0.10 hrs)

- 2019.10.01. Follow up Demand Letter

to PBRE edited (0.10 hrs)

JCJ $200.00 0.40 $80.00

10/18/2019 Services provided on 10/18/2019

- Matter review (0.10 hrs)

JCJ $200.00 0.10 $20.00

SRIPLAW, P.A.

21301 Powerline Road

Suite 100

Boca Raton, FL 33433

561.404.4350

Invoice

Invoice Number 35123

Invoice Date 10/15/2020

Payment Due On 10/30/2020

Amount Due $3,875.60

Invoice No.: 35123 Page 1/6

Case 9:20-cv-81307-RKA Document 12-2 Entered on FLSD Docket 10/15/2020 Page 5 of 10
11/01/2019 Services provided on 11/1/2019

- 3 emails sent/reviewed regarding

Affordable Aerial Photography, Inc. v.

Palm Beach Real Estate, Inc. ; Case No.:

(0.10 hrs)

JSW $425.00 0.10 $42.50

11/01/2019 Services provided on 11/1/2019

- 2 emails sent/reviewed regarding

Affordable Aerial Photography, Inc. v.

Palm Beach Real Estate, Inc. ; Case No.:

(0.10 hrs)

- Matter review (0.10 hrs)

JCJ $200.00 0.20 $40.00

11/21/2019 Services provided on 11/21/2019

- Matter review (0.10 hrs)

LMD $125.00 0.10 $12.50

12/06/2019 Services provided on 12/6/2019

- 2019.07.22. Demand Letter to PBRE

reviewed (0.10 hrs)

- Copyright Complaint with CMI

Removal created (0.60 hrs)

MT $250.00 0.70 $175.00

12/09/2019 Services provided on 12/9/2019

- Demand Letter reviewed (0.10 hrs)

MT $250.00 0.10 $25.00

12/11/2019 Services provided on 12/11/2019

- Matter review (0.10 hrs)

- Exhibit 2 - Infringement edited (0.10

hrs)

- JBR Summons created (0.10 hrs)

- Exhibit 3 - Demand Letters edited

(0.10 hrs)

- Copyright Complaint with CMI

Removal edited (0.70 hrs)

- 2019.10.01. Follow up Demand Letter

to PBRE reviewed (0.10 hrs)

- FLSD Civil Cover Sheet created (0.10

hrs)

- COI-CDS created (0.10 hrs)

- Exhibit 1 - Registrations edited (0.10

hrs)

- Affordable Aerial Photography, Inc. -

Intellectual Property Litigation - Palm

Beach Real Estate, Inc. - Copyright

Infringement

FLORIDA (0.10 hrs)

JCJ $200.00 1.60 $320.00

03/16/2020 Services provided on 3/16/2020

- 2019.07.22. Demand Letter to PBRE

reviewed (0.10 hrs)

MT $250.00 0.10 $25.00

05/05/2020 Services provided on 5/5/2020

- Matter review (0.10 hrs)

KAA $200.00 0.10 $20.00

05/19/2020 Services provided on 5/19/2020

- 2019.10.01. Follow up Demand Letter

to PBRE reviewed (0.10 hrs)

MT $250.00 0.10 $25.00

Invoice No.: 35123 Page 2/6

Case 9:20-cv-81307-RKA Document 12-2 Entered on FLSD Docket 10/15/2020 Page 6 of 10
06/15/2020 Services provided on 6/15/2020

- Matter review (0.10 hrs)

JCJ $200.00 0.10 $20.00

07/16/2020 Services provided on 7/16/2020

- 1 email sent/reviewed regarding

Complaint and Supporting Docs -

Affordable Aerial Photography, Inc. v.

Palm Beach Real Estate, Inc. (0.10 hrs)

CAW $350.00 0.10 $35.00

07/16/2020 Services provided on 7/16/2020

- 2 emails sent/reviewed regarding

Complaint and Supporting Docs -

Affordable Aerial Photography, Inc. v.

Palm Beach Real Estate, Inc. (0.20 hrs)

JSW $375.00 0.20 $75.00

07/20/2020 Services provided on 7/20/2020

- 1 email sent/reviewed regarding

Complaint and Supporting Docs -

Affordable Aerial Photography, Inc. v.

Palm Beach Real Estate, Inc. (0.20 hrs)

CAW $350.00 0.20 $70.00

07/20/2020 Services provided on 7/20/2020

- 1 email sent/reviewed regarding

Complaint and Supporting Docs -

Affordable Aerial Photography, Inc. v.

Palm Beach Real Estate, Inc. (0.10 hrs)

JBR $475.00 0.10 $47.50

07/29/2020 Services provided on 7/29/2020

- Matter review (0.10 hrs)

JCJ $200.00 0.10 $20.00

08/04/2020 Services provided on 8/4/2020

- Exhibit 3 - Demand Letters edited

(0.10 hrs)

- Copyright Complaint with CMI

Removal edited (0.30 hrs)

- Exhibit 2 - Infringement edited (0.10

hrs)

- Exhibit 1 - Registrations edited (0.10

hrs)

- Matter review (0.10 hrs)

JCJ $200.00 0.70 $140.00

08/12/2020 Finalize and file Complaint with the

United States District Court for the

Southern District of Florida.

- Copyright Complaint with CMI

Removal edited (0.10 hrs)

- FLSD Civil Cover Sheet edited (0.10

hrs)

- JBR Summons edited (0.10 hrs)

- JBR Summons - 2nd Def created (0.10

hrs)

- Case Expense Checklist created, then

edited (0.10 hrs)

- COI-CDS edited (0.10 hrs)

- 1 message sent/reviewed (0.10 hrs)

- Matter admin (0.10 hrs)

JCJ $200.00 0.80 $160.00

08/14/2020 Services provided on 8/14/2020

- 1 internal message sent/reviewed

(0.10 hrs)

LMD $175.00 0.10 $17.50

Invoice No.: 35123 Page 3/6

Case 9:20-cv-81307-RKA Document 12-2 Entered on FLSD Docket 10/15/2020 Page 7 of 10
08/18/2020 Services provided on 8/18/2020

- Email attachment reviewed - DE

0006. ORDER re- Proof of Service.

Signed by Judge Roy K. Altman on

8172020. See attached document for

fu (2020.08.17) (0.10 hrs)

JCJ $200.00 0.10 $20.00

08/24/2020 Services provided on 8/24/2020

- 1 email sent/reviewed regarding

Affordable Aerial Photography, Inc. v.

Palm Beach Real Estate, Inc. & Pearl

Case No. 9:20-cv-81307 (0.10 hrs)

- Matter admin (0.10 hrs)

JCJ $200.00 0.20 $40.00

08/28/2020 File executed affidavits of service with

the court

Service filed against both defendants

MRM $200.00 0.30 $60.00

09/21/2020 Services provided on 9/21/2020

- Matter admin (0.10 hrs)

JCJ $200.00 0.10 $20.00

10/05/2020 Services provided on 10/5/2020

- 1 email sent/reviewed regarding

Draft for Entry of Clerk's Default -

Affordable Aerial Photography, Inc. v.

Palm Beach Real Estate, Inc. & Pearl

Case No. 9:20-cv-81307 (0.10 hrs)

CAW $350.00 0.10 $35.00

10/08/2020 Services provided on 10/8/2020

- 4 emails sent/reviewed regarding

New filing in Affordable Aerial

Photography, Inc. v. Palm Beach Real

Estate, Inc. et al: ORDER ON DEFAULT

FINAL JUDGMENT (flsd-9:2020-cv81307) (0.3hs)

CAW $350.00 0.30 $105.00

10/15/2020 Discussed and drafted affidavit with

client

MT $300.00 0.50 $150.00

10/15/2020 Drafted declaration of JBR MT $300.00 0.30 $90.00

10/15/2020 Drafted motion for Final Default

Judgment

MT $300.00 4.00 $1,200.00

10/15/2020 Drafted proposed order for Final

Default Judgment

MT $300.00 0.50 $150.00

10/15/2020 Reviewed docs drafted by M

Teitelbaum prior to filing

CAW $350.00 0.30 $105.00

$3,387.50

Expenses

Date Description Cost Qty Total

07/22/2019 Disbursement to courier for shipment of

documents

$8.10 1.00 $8.10

Invoice No.: 35123 Page 4/6

Case 9:20-cv-81307-RKA Document 12-2 Entered on FLSD Docket 10/15/2020 Page 8 of 10
Subtotal $3,875.60

Total $3,875.60

Total Balance Due $3,875.60

08/12/2020 Disbursement to the United States District

Court for the filing fee of new Complaint.

$400.00 1.00 $400.00

08/28/2020 Disbursement for fee for service of process of

Summons and Complaint.

Majestic Process Invoice No. SR 2020 - 45

dated August 26, 2020

$80.00 1.00 $80.00

$488.10

Invoice No.: 35123 Page 5/6

Case 9:20-cv-81307-RKA Document 12-2 Entered on FLSD Docket 10/15/2020 Page 9 of 10
Professional Fee Summary

Name Hours Rate Total

JBR 0.10 $475.00 $47.50

JSW 0.20 $425.00 $85.00

0.20 $375.00 $75.00

CAW 1.00 $350.00 $350.00

MT 5.30 $300.00 $1,590.00

1.00 $250.00 $250.00

JCJ 4.40 $200.00 $880.00

KAA 0.10 $200.00 $20.00

MRM 0.30 $200.00 $60.00

LMD 0.10 $175.00 $17.50

0.10 $125.00 $12.50

Total 12.80 $3,387.50

Invoice No.: 35123 Page 6/6

Case 9:20-cv-81307-RKA Document 12-2 Entered on FLSD Docket 10/15/2020 Page 10 of 10