UNITED STATES BANKRUPTCY OURT 

SOUTHERN DISTRICT OF FLORIDA

www.flsb.uscourts.gov

In Re:

CAROLINA MOLINA Case No.: 19-23739-RAM

 Chapter 13

 Debtor(s) / 

DEBTOR’S SUPPLEMENTAL OBJECTION TO SUPPLEMENTAL NOTICE OF POSTPETITION FEES, EXPENSES AND CHARGES FILED BY FACE BANK 

INTERNATIONAL CORPORATION

 COMES NOW, the Debtor, CAROLINA MOLINA, by and through undersigned 

counsel files this Supplemental Objection to Supplemental Notice of Post-Petition Fees, 

Expenses, and Charges filed by Face Bank International Corporation and in support thereof 

states as follows: 

 1. Face Bank International Corporation (“Face Bank”) holds the mortgage on the 

Debtor’s homestead property. The Debtor has filed a First Modified Plan which cures and 

maintains the mortgage. The hearing on the Motion to Approve the First Modified Plan is 

scheduled for June 16, 2020. 

 2. Face Bank International Corporation filed a Notice of Post-Petition Mortgage Fees, 

Expenses, and Charges [Doc under Claim No. 3] (“NPPF”). The document states that Face Bank 

has incurred attorney’s fees of $32,551.91 and attaches an addendum with six (6) dates but with 

no time itemization or any other detail evidencing how this fee amount was reached. 

 3. On May 29, 2020, Face Bank filed a supplemental NPPF. Suddenly, the attorneys fees 

allegedly owed to Face Bank was reduced to $28,782.88. 

 4. Face Bank has now attached an itemization of their attorney’s fees. A review of the 

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itemization will reveal excessive time entries for simple tasks, multiple entries for the same 

tasks, and charges for administrative tasks such as calendaring deadlines or saving documents. 

 5. On June 16, 2020, the Court conducted a preliminary hearing on the Debtor’s 

Objection to Face Bank’s Supplemental Notice of Post-Petition Fees and directed the Debtor to 

file a supplemental response by July 1, 2020. 

 6. The Debtor has a general objection to all time entries which relate to “correspondence” 

that is billed in excess of .1 hours. Additionally, the Debtor has a general objection to all time 

entries which refer to “inter-office conference” and are billed at more than .2 hours. There are a 

plethora of time entries relating to “correspondence” and “inter-office conference” which are 

billed at an excessive rate and the time entry should be reduced by this Court. 

 7. The Debtor has a general objection to all time entries which cover the same period and 

the same tasks which are billed by bankruptcy counsel and by state court counsel. Bankruptcy 

counsel was retained for this matter – why is state court counsel involved with bankruptcy 

related matters? This Court should strike all duplicative time entires. 

 8. Additionally, the Debtor takes issue with the specific time entries detailed below – 

each entry is referred to by the page number in which it is found on the Amended Notice of PostPetition Fees, followed by the date of entry: 

Page / Date Explanation for Objection 

p. 6 / 11-19-2019 

p. 24 / 11-19-2019 

Duplicative time entries for state court counsel and bankruptcy

counsel on the same tasks. Why is state court counsel involved 

when bankruptcy counsel has been retained? 

p. 6-8 

11/20/2019 through 

12/05/2019 

Excessive time entries for preparation of a 4 page stay relief motion 

and 2-page objection to confirmation totals 11.7 hours and 

$3,568.50. 

p. 24 – 25 Excessive time entries - another 1.6 hours of time billed totaling 

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12/03/2019 through 

12/04/2019 

$420.00 for state court counsel review of the 4 page stay relief 

motion and 2 page objection to confirmation. 

p. 8 / 12/05/2019 

Excessive time entries - 2.9 hours billed totaling $884.50 to prepare 

and attend a 341 meeting. 

p. 9 / 12/06/2019 

Excessive time entries - .2 hours billed to review and calendar a 

notice of hearing. 

p. 9 / 12/06/2019 through 

12/30/2019 

p. 32-33 12/06/2019 

through 12/30/2019 

Duplicative time entries for state court counsel and bankruptcy

counsel on the same tasks. Why is state court counsel involved 

when bankruptcy counsel has been retained? State court counsel 

billing totals $1,052.00 for this time period. 

p. 9 / 12/30/2019 through 

01/03/2020 

Excessive time entries - a total of 5.4 hours billed totaling 

$1,647.00 to prepare proof of claim with a 2-page addendum. 

p. 12 / 01/09/2020 through 

01/13/2020 

Excessive time entries - a total of 1.5 hours billed totaling $457.50 

to confirm continuation of stay relief and confirmation hearings. 

p. 12 / 01/13/2020 Excessive time entries - .5 hours billed to review mediators. 

p. 12 / 01/16/2020 

Excessive time entries - .2 hours billed to review and calendar a 

notice of hearing. 

p. 12 / 01/17/2020 through 

01/28/2020 

Excessive time entries – a total of 2.6 hours totaling $793.00 for the 

Creditor to register to the MMM portal. 

p. 27 / 01/17/2020 through 

01/28/2020 

Duplicative and excessive time entries from state court counseling 

totaling $500.00 dealing with getting the Creditor to register to the 

MMM portal. 

p. 18 / 03/10/2020 

Excessive time entries – 2.8 hours billed totalling $854.00 for

preparation and attendance of confirmation hearing. 

 9. The Debtor objects to the supplemental NPPF filed by Face Bank and requests that the 

Court review Face Bank’s supplemental NPPF, review the Debtor’s objections as detailed 

above,and award an attorney’s fees that is reasonable and just. 

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 WHEREFORE, the Debtor, CAROLINA MOLINA, respectfully requests that this 

Court grant the relief sought by the Debtor and grant such other relief as this Court may deem 

just and equitable under the circumstances. 

CERTIFICATE OF SERVICE 

I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via 

CM/ECF to the following parties this 1st day of July 2020. 

 Nancy K. Neidich, Chapter 13 Trustee 

 Office of the United States Trustee 

 Face Bank International Corporation, c/o Leyza F. Blanco, Esq. 

 

CERTIFICATE PURSUANT TO

LOCAL RULE 9011‐4(B)

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). 

KINGCADE & GARCIA, P.A 

Counsel for the Debtor 

Kingcade Building 

1370 Coral Way ▪ Miami, Florida 33145-2960 

WWW.MIAMIBANKRUPTCY.COM

Telephone: 305-285-9100 ▪ Facsimile: 305-285-9542 

/s/ Timothy S. Kingcade, Esq. 

x Timothy S. Kingcade, Esq., FBN 082309 

□ Jessica L. McMaken, Esq., FBN 580163 

 

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