UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

James Messerschmidt,

 Plaintiff, Case No: 0:22-cv-61614-AHS 

v.

Gazeta Brazilian News Corporation,

Defendant.

___________________________________/

DECLARATION OF CRAIG B. SANDERS

CRAIG B. SANDERS, pursuant to 28 U.S.C. § 1746, hereby declares under 

penalty of perjury, as follows:

1. I am a member of the law firm of Sanders Law Group, attorneys for

Plaintiff James Messerschmidt (“Plaintiff”), and submit this Declaration in support 

of Plaintiff’s Motion for a Default Judgment. As counsel to Plaintiff since the 

beginning of this action, I have personal knowledge as to the facts set forth herein.

2. I respectfully submit this Declaration in support of Plaintiff’s Motion 

for a Default Judgment against Defendant, Gazeta Brazilian News Corporation

(“Defendant” or “Gazeta”), pursuant to Fed. R. Civ. P. 55(b)(2) and Local Rule 7.1

and the Court’s inherent power, granting Plaintiff’s default judgment against 

Defendant. 

3. In support of the portion of the motion which asks the Court to fix an 

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award of fees and damages, I submit the following. By way of background, I 

received my Juris Doctor (J.D.) from the University of Pennsylvania Law School in 

1993 and am a founding partner in the law firms of Sanders Law, PLLC, and Sanders 

Law Group. I was admitted to practice of law in Florida in 1993 and New York in 

1994. In addition to New York and Florida, I am currently admitted to practice law 

in the states of California, Utah, Colorado, Maryland, Washington and New Jersey. 

In addition to the above-listed state admissions, I am admitted to practice law in the 

Federal Courts of New Jersey, California (all four Districts), Colorado, Florida (all 

three Districts), Illinois (all three Districts as a lead trial attorney), Indiana (both 

Districts), Maryland, New York (all four Districts), Texas (all four Districts), Utah, 

Wisconsin (both Districts), New Jersey and the District of Columbia. I am also 

admitted to the Second, Third, Fifth, Ninth, and Tenth Circuit Courts of Appeals and 

have argued appeals in each of these Circuits. I am also admitted to practice before 

the United States Supreme Court. I am in good standing in the above-referenced 

Courts and have never been disciplined by any bar. During the course of my twentynine (29) year professional career, I have focused on Federal Litigation, primarily 

involving civil litigation matters and have personally filed and litigated hundreds of 

copyright cases. My current billable hourly rate is $700 per hour for work in the 

district.

4. My hourly rate of $700/hr. for the prosecution of copyright 

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infringement matters is well within the range of hourly billing for similarly 

experienced attorneys according with the Report of the Economic Survey (2017) for 

the American Intellectual Property Law Association (Exhibit 2). 

5. Jaymie Sabilia-Heffert is an associate with the firm. Ms. Sabilia-Heffert 

received her Juris Doctor from Touro Law School in 2015 and was admitted to 

practice in the Courts of the State of New York in 2016. She was admitted to practice 

in the United States District Court for the Southern District of New York in 2018 

and the Northern District of New York in 2019. During the course of her seven-year 

professional career, Ms. Sabilia-Heffert has focused her practice primarily on 

litigation involving civil matters in both State and Federal Courts. Ms. SabiliaHeffert’s current hourly rate is $450.00 per hour. 

6. As part of my responsibilities at Sanders Law Group, I maintain the 

firm’s billing records, and I supervise the firm’s billing procedures and policies, both 

for our paying clients, as well as for our work in fee-shifting cases. 

7. Concerning the billing records attached to this Declaration, I have 

reviewed the billing records of the firm to identify time entries that may be 

duplicative (or deemed excessive) and subtracted these amounts or events. It is my 

belief that the entries on the billing records attached hereto as Exhibit 1 are 

reasonable for the successful prosecution of this case.

8. In addition to the time entries, Plaintiff incurred and seeks 

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reimbursement for costs in the amount of $477.00 which includes a $402.00 filing 

fee which Plaintiff requests this Court take judicial notice, and a $75.00 service of 

process fee from Gotcha Legal Services, Inc.

9. For the foregoing reasons, as well as those set forth in all the papers 

heretofore submitted, I respectfully request that the Court award attorney’s fees and 

costs as detailed in the attached billing records. 

10. No part of the Judgment sought has been paid. 

Dated: January 20, 2023

SANDERS LAW GROUP

By: /s/ Craig B. Sanders

Craig B. Sanders, Esq. (Fla. Bar 985686)

333 Earle Ovington Blvd., Suite 402

Uniondale, NY 11553

Tel: (516) 203-7600

Email: csanders@sanderslaw.group 

Our File No: 125646

Attorneys for Plaintiff

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