[1] Pursuant to court order, the Applicant files its final fee application; however the applicant reserves the right to additional fees and 

expenses incurred subsequent to this fee application. 

UNITED STATE DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

PALM BEACH DIVISION

IN RE: CASE NO.: 19-18585-MAM

Chapter 11

MERIDIAN MARINA & YACHT CLUB

OF PALM CITY, LLC 

Debtor.

___________________________________/

CORRECTED

FINAL [1] FEE APPLICATION OF COUNSEL FOR 

SECURED CREDITOR MARTIN COUNTY MARINE HOLDINGS, LLC

1. Name of Applicant: Paul J. Lane Esq.

2. Role of Applicant: Attorney for Secured Creditor

3. Name of Certifying Professional: Paul J. Lane, Esq.

4. Date case filed: June 27, 2019

5. Date of Retention Order: NA

6. Total Amount of Compensation Sought during case: $14,925.00

Paul J. Lane, Esq. counsel to the Secured Creditor, MARTIN COUNTY MARINE 

HOLDINGS, LLC, applies for an award of compensation for fees for services rendered and costs 

incurred in this Chapter 11 proceeding to the Secured Creditor pursuant to 11 U.S.C. §506(b) and 

meets all of the requirements set forth in the Guidelines incorporated in Local Rule 2016(B). The 

exhibits attached to this application, pursuant to the Guidelines, are:

Exhibit "1"- The Applicant's complete time records in chronological order for the time period 

covered by this application.

Case 19-18585-MAM Doc 189 Filed 09/03/20 Page 1 of 6
WORK PERFORMED - BREAKDOWN BY CATEGORY

All work was performed to protect the secured creditor’s claim

THE TIME AND LABOR REQUIRED: See attached Exhibit "1”.

THE NOVELTY AND DIFFICULTY OF THE SERVICES RENDERED: The 

undersigned is counsel for the secured creditor, MARTIN COUNTY MARINE HOLDINGS, 

LLC, and was counsel in the foreclosure action that resulted in the Final Judgment which is the 

primary basis for this bankruptcy action, which action was filed just days before the scheduled sale 

date. The undersigned was also counsel in the prior foreclosure action by this secured creditor, 

which also resulted in a bankruptcy action to prevent that sale from going forward. The debtor in 

this action used diverse and complex strategies to stall collection actions and the undersigned has 

unique knowledge of the debtor’s history and actions, having been involved in proceedings 

concerning the property herein, and this debtor since 2010. As corporate counsel for the secured 

creditor, the undersigned provided consultation to bankruptcy counsel representing the secured 

creditor, and such consultation was necessary to protect the secured creditor’s claims.

THE SKILL REQUISITE TO PERFORM THE SERVICES PROPERLY: Experience in 

collection of judgments obtained in foreclosure.

THE CUSTOMARY FEE: The hourly rates sought by Applicant in connection with this 

case are lower than the customary hourly rates charged by other experienced practitioners in the 

Southern District of Florida and are within the hourly rates customarily awarded by this Court in 

similar cases.

WHETHER THE FEE IS FIXED OR CONTINGENT: Applicant was employed on an 

hourly basis, and the fee is not fixed or contingent.

THE EXPERIENCE, REPUTATION, AND ABILITY OF THE PROFESSIONAL: The 

undersigned is a member in good standing with the Florida Bar, has been actively engaged in the 

practice of law for over 40 years and has had over 32 years prior experience in representing parties

in similar matters to that herein. 

THE NATURE AND LENGTH OF THE PROFESSIONAL RELATIONSHIP OF THE

CLIENT: Applicant has been counsel for this client for over ten years.

AWARDS IN SIMILAR CASES: The award sought by the Applicant in connection with 

this case is consistent with the fees sought and awarded in similar Chapter 11 cases in the Southern

District of Florida.

SHARING OF COMPENSATION: There is no agreement between the Applicant or any 

other person for the sharing of any compensation which may be awarded in connection with this 

case.

Case 19-18585-MAM Doc 189 Filed 09/03/20 Page 2 of 6
WHEREFORE, the applicant seeks an award of fees in the amount of $14,925.00.

Dated: September 1, 2020

I am admitted to the Bar of the United States District Court for the Southern District of Florida 

and I am in compliance with the additional qualifications to practice in this Court set forth in Local 

Rules 2090-1(A) and 9011-4(A)(1). 

PAUL J. LANE, ESQ. P.A.

By: /s/ Paul J. Lane

Paul J. Lane

Florida Bar No. 292842

7880 N. university Dr. Suite 200

Tamarac, Fl. 33321

Tel: (954) 718-2996

Cell Phone: (954) 682-4211

Fax: (866) 721-2053

Attorney for Martin County Marine Holdings, 

LLC

CERTIFICATION

1. I am the professional in this case for compliance with the Guidelines for Fee

Applications for Professionals in the Southern District of Florida in Bankruptcy Cases (the 

"Guidelines").

2. I have read the Applicant's application for compensation and reimbursement of 

expenses (the "Application"). The application complies with the Guidelines, and the fees and

expenses sought fall within the Guidelines, except as specifically noted in this certification and 

described in the application.

3. The fees are billed at rates and in accordance with practices customarily employed 

by the Applicant and generally accepted by the Applicant's clients.

4. The following are the variances with the provisions of the Guidelines, the date of 

each court order approving the variance, and the justification for the variance: None.

Case 19-18585-MAM Doc 189 Filed 09/03/20 Page 3 of 6
CERTIFICATE OF SERVICE

I hereby certify that on September 2, 2020 I electronically filed the foregoing with the 

Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this 

day on all counsel of record identified on the Service List via transmission of Notices of Electronic 

Filing generated by CM/ECF furnished and via U. S. Mail to the attached mailing list.

By: /s/ Paul J. Lane

Paul J. Lane

Florida Bar No. 292842

Case 19-18585-MAM Doc 189 Filed 09/03/20 Page 4 of 6
EXHIBIT "1" Post Filing Legal Fees - Paul J. Lane, Esq. - Case No. 19-18585-MAM

Date Services performed

12/27/18 Prepare order transferring note from prior foreclosure 0.50

01/03/19 Prepare order filing promissory note 0.50

03/04/19 Review and consult on Motion to Extend Sale Date 1.00

03/04/19 Review tax bill 2018-2019 0.25

03/07/19 Review Purchase Agrt with Windward Marina Group 1.00

03/12/19 Review Motion to Intervene and consultation 1.25

03/18/19 Review and consult on proposed and agreed order to extend sale 2.00

06/11/19 Prepare and publish Notice of Sale 1.00

06/23/19 Review Affidavit of Publication 0.25

06/28/19 Review Suggestion of Bankruptcy 0.25

06/28/19 Review Bankruptcy Petition 1.25

07/02/19 Meet with Bankruptcy counsel and review engagement letter 1.50

07/02/19 Review proposed interim budget and order 0.50

08/15/20 Review appraisal 1.00

10/15/19 Consult with BKC counsel on Objection to Extension of Exclusivity 0.50

10/22/19 Conference call with client 1.00

10/24/19 Review claims list 0.50

12/09/19 Review Motion for Authority to Sell and Contract for Sale 2.50

12/12/19 Prepare notes for BKC Counsel on Limited Objection to Sale 2.50

01/10/20 Attend hearing on Motion to Sell 1.00

01/20/20 Review proposed order to sell and consult 1.50

03/03/20 Consult on document request 2.00

03/17/20 Hearing on Order to Show Cause 1.00

03/25/20 Review Order 0.50

03/27/20 Prepare confidentiality agreement 1.00

04/21/20 Review Amended Plan disclosure and Non-disclosure docs 1.00

06/01/20 Review request for proof of funds 0.50

06/05/20 Review Order on Plan 0.50

06/15/20 Review insurance disclosure 1.00

07/02/20 Prepare explanation of lack of insurance 1.50

07/15/20 Review Motion re: exclusivity 1.50

07/16/20 Review closing checklist from MDP 2.00

07/27/20 Review Environmental report 1.00

07/27/20 Review Amended Motion to Sell 1.00

07/28/20 Hearing on Order to Show Cause 1.00

07/29/20 Review Insurance Quote and comments 1.00

07/29/20 Review revised Ch 11 Plan 1.00

08/11/20 Hearing on Motion to Terminate Exclusivity 0.50

08/13/20 Review 3rd Amended Disclosure 1.50

08/14/20 Prepare Payoff through 8/17/20 2.00

08/20/20 Consultation with Bankruptcy counsel and clients 0.50

08/21/20 Review and notes on Objection to Sale 1.00

08/24/20 Consultation with Bankruptcy counsel and clients 0.50

08/25/20 Consultation with Bankruptcy counsel and clients 1.00

Case 19-18585-MAM Doc 189 Filed 09/03/20 Page 5 of 6
Page 2

EXHIBIT "1" Post Filing Legal Fees - Paul J. Lane, Esq. - Case No. 19-18585-MAM

08/25/20 Hearing on Order for Sale 2.00

08/26/20 Consultation and review of Order for Sale 1.50

Total Hours as of August 26, 2020 - post judgment 49.75

Hourly Rate 300.00

Fee 14,925.00

Case 19-18585-MAM Doc 189 Filed 09/03/20 Page 6 of 6