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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

MIAMI DIVISION

Case No.: 1:22-cv-23223-GAYLES

Venus Concept USA Inc., a 

Delaware Corporation,

Plaintiff,

v.

Exotic V’s Beauty Bar and Spa, a California 

company, and Victoria Naborne, 

an individual,

Defendants.

/

DECLARATION OF VINCENT F. ALEXANDER, ESQ. IN SUPPORT OF 

PLAINTIFF’S REQUEST FOR ATTORNEYS’ FEES AND COSTS

I, Vincent F. Alexander, Esq., pursuant to 28 U.S.C. § 1746, submit this Declaration in 

Support of Plaintiff’s Request for Attorneys’ Fees and Costs (“Declaration”), and declare as 

follows to the best of my knowledge, information, and belief: 

1. I am over the age of 18 and am fully competent to make this declaration in support 

of Plaintiff Venus Concept USA, Inc.’s (“Plaintiff” or “Venus”) request for attorneys’ fees and 

costs. This declaration is based on my own personal knowledge unless otherwise indicated. If 

called to testify, I could and would do so competently on the matters stated herein. I am authorized 

to make this Declaration on behalf of Venus and Lewis Brisbois Bisgaard & Smith, LLP

(“LBBS”).

2. I am a partner with LBBS. I, my associate David Robbins, along with LBBS 

paralegals under my supervision, including Christina Freeman and Gary Lipscomb, represented

Venus in the above-captioned matter. I have been a member in good standing of the State Bar of 

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Florida since 2009 and am also admitted to practice before the Eleventh Circuit Court of Appeals, 

the United States District Courts for the Southern, Middle, and Northern Districts of Florida, the 

United States District Court for the District of Colorado, and the United States District Court for 

the Southern District of Texas. My practice focuses on complex commercial litigation matters, and 

I have successfully tried cases throughout the country as lead counsel in numerous state and federal 

courts.

3. LBBS diligently investigated, prosecuted, and dedicated resources to the claims in 

this matter. The work performed by LBBS included, without limitation, the following:

a. review of relevant documents; 

b. drafting and sending demand letters;

c. researching and drafting complaint against Defendants;

d. obtaining defaults against Defendants; and

e. drafting a motion for default final judgment and related documents against 

Defendants.

4. In my experience, these tasks are typical of this sort of litigation and were necessary 

to the successful prosecution and resolution of the claims.

5. Copies of LBBS’s time entries containing the reasonable attorneys’ fees and costs

incurred in this matter and summary of expenses are attached hereto as Composite Exhibit 1.

1

These detailed time records consist of contemporaneous logs, with separate entries for the hours 

spent on specific tasks, indicating who performed the work and giving a description of the task.

1

Information protected by the attorney-client privilege and/or the work product doctrine has 

been redacted from certain entries in the invoices.

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These records of LBBS are kept in the normal course of business for the purpose of billing clients,

and I have reviewed same in respect to the preparation of this Declaration.

6. The reasonable rates charged by LBBS in this matter were based upon the 

experience and skill required in performing the work by each attorneys and were discounted from 

LBBS’s normal and customary rates. LBBS charged a blended flat rate of $360.00 per hour for all 

attorneys and a blended flat rate of $160.00 per hour for all paralegals.

7. The chart below reflects the reasonable hours billed on this matter by LBBS staff:

Timekeeper Position Hourly Rate Total Hours Total Amount

Vincent F. Alexander Partner $360.00 7.6 $2,736.00

David Robbins Associate $360.00 18.4 $6,624.00

Christina Freeman Paralegal $160.00 9.3 $1,488.00

Gary Lipscomb Paralegal $160.00 6.4 $1,024.00 

Total 41.7 $11,872.00

8. Based on my experience, the hourly rates charged by LBBS in this matter are on 

par or below the rates sought by other attorneys handling similar litigation matters. 

9. LBBS took measures to litigate this case efficiently and to avoid duplication of 

efforts.

10. LBBS also incurred on behalf of Venus the following ordinary and necessary costs 

as follows:

Costs and Expenses Amount

Filing Fee & Issuance of Summonses $817.04

Service of Process $5,099.80

Total $5,916.84

11. I have reviewed these costs to ensure that they were not excessive or unnecessary.

12. The worked performed by LBBS was essential to Venus obtaining a favorable 

result.

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I declare under penalty of perjury that the foregoing is true and correct.

Executed this 2

nd day of June, 2023 /s/ Vincent F. Alexander

 Vincent F. Alexander

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