UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

MIAMI DIVISION

CASE NO. 19-17549-BKC-RAM

CHAPTER 13

DOMINIQUE C. LALLEMAND

Debtor.

______________________/

APPLICATION FOR FEES BY ATTORNEY FOR DEBTOR

Pursuant to Court Order, the undersigned files this Application for Fees by

Attorney for the Debtors in the above case and state:

1. The rate normally charged by the undersigned and is considered

reasonable in the community in a matter such as this, is $500.00 per hour.

2. The Law Offices of Brooks, Frank & De La Guardia, Jr. have expended 

(23.80) hours at the rate of $500.00 per hour from May 27, 2019. A delineation of the

time expended is as follows:

Date Description Hours

05-27-19 Initial Consultation with Client and opening of File 1.00

06-06-19 Prepared Case for filing and filed Case 1.00

06-06-19 Prepared and Filed Means Test 1.00

06-07-19 Received and reviewed Notice of Incomplete Filings Due 0.10

06-07-19 Consultation to review all Schedules and Income and Expenditures 1.00

06-07-19 Prepared and filed Schedules I, J and Declaration 0.80

06-07-19 Prepared and filed Chapter 13 Plan 1.00

06-10-19 Received and reviewed Trustee's Notice of Required Documents 0.10

06-10-19 Received and reviewed Notice of Commencement 0.10

06-17-19 Received and Reviewed Notice of Appearance and Request for Service

filed by Creditor JGAR Financial, LLC

0.10

06-18-19 Received and Reviewed Notice of Appearance and Request for Service

filed by Creditor W ells Fargo Bank

0.10

06-19-19 Prepared and Filed Certification of Compliance and Request for

Confirmation

0.10

06-19-19 Received and Reviewed Objection to Confirmation of Chapter 13 Plan

filed by Creditor W ells Fargo Bank

0.40

06-27-19 Received and Reviewed Request for Notice Filed by Creditor Miami

Dade County Tax Collector

0.10

06-27-19 Prepared and Filed First Amended Chapter 13 Plan 0.70

Case 19-17549-RAM Doc 73-1 Filed 09/19/19 Page 1 of 4
06-27-19 Received and Reviewed Objection to Confirmation Filed by Creditor

JGAR Financial, LLC

0.40

07-03-19 Received and Reviewed Trustee’s Notice of Deficiency for Confirmation 0.10

07-11-19 Prepared for 341 Meeting of Creditors 0.50

07-12-19 Attended 341 Meeting of Creditors 0.50

07-15-19 Received and Reviewed Statement Adjourning Meeting of Creditors 0.10

07-15-19 Received and Reviewed Trustee’s Notice of Deficiency for Confirmation 0.10

07-15-19 Prepared and Filed Second Amended Chapter 13 Plan 0.70

07-15-19 Received and Reviewed Trustees Objection to Claimed Exemptions 0.10

07-16-19 Prepared and Filed Third Amended Chapter 13 Plan 0.20

07-16-19 Prepared and Filed Motion to Determine that Claims Filed have No

Interests in property held by Tenants of the Entireties

0.80

07-23-19 Received and Reviewed Objection to Confirmation of Chapter 13 Plan

Filed by Creditor JGAR Financial, LLC

0.30

07-26-19 Received and Reviewed Motion for relief from Stay Filed by Creditor

JGAR Financial, LLC

0.40

07-26-19 Received and Reviewed Response to Motion to Determine that Claims

Filed have No Interests in property held by Tenants of the Entireties

0.40

08-01-19 Prepared for 341 Meeting of Creditors 0.50

08-01-19 Attended 341 Meeting of Creditors 0.50

08-02-19 Received and Reviewed Trustee’s Notice of Deficiency for Confirmation 0.10

08-02-19 Consultation with Debtor to Amend Schedules 0.40

08-02-19 Prepared and Filed Amended Schedule C and Declaration 0.30

08-06-19 Received and reviewed Trustee’s Objection to Debtors Claimed

Exemptions

0.20

08-07-19 Received and Reviewed Trustee’s Notice of Deficiency for Confirmation 0.10

08-08-19 Prepared and Filed Fourth Amended Chapter 13 Plan 0.30

08-08-19 Consultation with Debtor to review income and expenses and Prepared

and Filed Amended Schedules I, J and Declaration

0.60

08-09-19 Prepared and Filed Fifth Amended Chapter 13 Plan 0.40

08-12-19 Pre-hearing with Trustee regarding Confirmation Hearing 0.10

08-12-19 Reviewed file for Confirmation Hearing 0.20

08-12-19 Called Client regarding Confirmation Hearing 0.20

08-13-19 Attended Confirmation Hearing 0.40

08-13-19 Prepared for and Attended Hearing on Objection to Debtor’s Claimed

Exemptions Filed by Creditor JGAR Financial, LLC and prepared for and

attended hearing on Objection to Debtor’s Claimed Exemptions filed by

Trustee

0.70

08-13-19 Prepared for and Attended Hearing on Motion for Relief from Stay 0.50

08-13-19 Prepared for and Attended Hearing on Motion for Determination that

Claims Filed have No Interests in Property Held by Tenants of the

Entirety

0.50

08-21-19 Received and reviewed Order Continuing Confirmation 0.10

08-27-19 Received and Reviewed Order Continuing Motion for relief from Stay

Filed by Creditor JGAR Financial

0.10

08-30-2019 Researched and prepared Debtor’s Motion for Rehearing on Order on

Objection to Exemptions 2.00

09-16-19 Pre-hearing with Trustee regarding Confirmation Hearing 0.10

09-16-19 Reviewed file for Confirmation Hearing 0.20

09-16-19 Called Client regarding Confirmation Hearing 0.20

09-17-19 Attended Confirmation Hearing 0.40

Case 19-17549-RAM Doc 73-1 Filed 09/19/19 Page 2 of 4
09-17-19 Prepared for and Attended Hearing on Objection to Debtor’s Claimed

Exemptions Filed by Creditor JGAR Financial, LLC, prepared for and

attended hearing on Objection to Debtor’s Claimed Exemptions filed by

Trustee

0.50

09-17-19 Prepared for and Attended Hearing on Motion for Relief from Stay filed

by Creditor JGAR Financial, LLC

0.50

Prepared and filed Application for Fees and review of file. 1.00

Attendance at Hearing on Application for Fees. 0.50

Total Hours.................................................. 23.80

23.80 hours x $500.00 = $ 11,900.00

The total fee requested is $10,000.00. The Debtors’ attorney has received

$2,500.00 in fees. The total amount of work performed pre-Confirmation is (23.80)

hours at $500.00 an hour = $11,900.00. The undersigned submits that the amount of

$10,000.00 for all of the work that has been performed and all of the future work to be

performed is reasonable pursuant to the standard set forth In re: Norman vs. Housing

Authority of Montgomery, 836 F. 2nd 1299 (11th Cir. 1988) and 11 U.S.C. Section 330.

There are no charges in this Application for Fees for secretarial or typing time and no

charges have been added for travel time to and from the Courthouse for any of the

hearings.

WHEREFORE, the Debtor requests to be awarded fees in the amount of

$10,000.00.

CERTIFICATE OF SERVICE 

I HEREBY CERTIFY that 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 Rule

2090-1(A) and that a true and correct copy of this Notice of Hearing and the Application for Fees by Attorney for

Debtors was sent by e-mail to Nancy K. Neidich, Trustee at e2c8f01@ch13herkert.com and all others set forth in NEF

on September 19, 2019, and this Motion and an upcoming Notice of Hearing will be served on a separate Certificate

of Service via email to those set forth above and by regular mail to: Dominque C. Lallemand, Debtor, 265 Grapetree

Drive, Unit 127, Key Biscayne, FL 33149.

LAW OFFICES OF MICHAEL J. BROOKS, MICHAEL A. FRANK

& RODOLFO H. DE LA GUARDIA, JR.

Attorneys for the Debtors

Suite 620 • Union Planters Bank Building

10 Northwest LeJeune Road

Miami, FL 33126-5431

Telephone (305) 443-4217

Facsimile (305) 443-3219

By /s/ Michael A. Frank 

 Michael A. Frank

Case 19-17549-RAM Doc 73-1 Filed 09/19/19 Page 3 of 4
 Florida Bar No. 339075

Case 19-17549-RAM Doc 73-1 Filed 09/19/19 Page 4 of 4