1

UNITED STATES BANKRUTPCY COURT

SOUTHERN DISTRICT OF FLORIDA

In re: 

Mario L Sorroche Moreno, Case No. 19-17620-RAM

Debtor(s) Chapter 13

_________________________/

UPDATED FEE AFFIDAVIT AND ACTUAL DAMAGES

I hereby certify under penalty of perjury the following is a true and accurate 

representation of time and resources spent in relation to the case sub judice.

DATE STAFF DESCRIPTION TIME PRICE/

HOUR

SUB TOTAL

7/3/2019 RS Client came to speak to RS 

because the creditor repoed his 

car. RS reviewed petition and 

facts about what transpired. 

Conferenced with JG

0.7 425 $297.50

7/3/2019 JAG Conference with RS and client 0.7 125 $87.50

7/3/2019 JAG Left message with staff member 

Sarah to tell her boss Sergio to 

call back ASAP

0.1 125 $12.50

7/3/2019 JAG Staff called back to inform us to 

contact Attorney Paul Wilson

0.1 125 $12.50

7/3/2019 RS RS spoke to Wilson about the 

facts and case law

0.3 425 $127.50

7/3/2019 RS Client discussion about previous 

conversation

0.2 425 $85.00

7/3/2019 RS RS sent email to JB 0.1 425 $42.50

7/5/2019 JAB Reviewed email from JG (JB 

returned from vacation)

0.1 425 $42.50

7/5/2019 JAB Reviewed email from RS; 

conference

0.2 425 $85.00

7/5/2019 RS Conference with JB 0.2 425 $85.00

7/5/2019 JAB Client came to the office and 

spoke with JB afterhours

0.2 425 $85.00

7/8/2019 JAB Reviewed registration records 

that client dropped off as well as 

the case itself

0.3 425 $127.50

7/8/2019 JAB Phone call and email with 

Attorney Wilson

0.3 425 $127.50

7/8/2019 JAB Drafted and filed emergency 

motion; left voicemail requesting 

hearing with Ms. Jackie Antillon. 

0.7 425 $297.50

7/8/2019 JAB Debtor called and advised that 

the Creditor will not return any 

of the other personal items in the 

vehicle except for the documents 

and will charge him $150 for it.

0.1 425 $42.50

7/11/2019 JAB Preparation for hearing, review 

of case file, and notes; 

Conference with JG; 

0.5 425 $212.50

Case 19-17620-RAM Doc 52 Filed 09/19/19 Page 1 of 4
2

Printing/ECF COST: $3.75

7/11/2019 JAG Conference with JB 0.2 125 $25.00

7/11/2019 JAB Phone call with client regarding 

case status and regarding 

recovery of missing items 

including insulin medicine; rereviewed notes from earlier

0.4 425 $170.00

7/11/2019 JAB Reviewed Creditor response and 

email; along with case law and 

code section stated

0.7 425 $297.50

7/12/2019 JAB Court hearing with parking 

(COST: $11.00); Reviewed 

signed Court Order

0.6 425 $255.00

7/15/2019 JAB Reviewed and sent Insurance to 

the Creditor

0.2 425 $85.00

7/16/2019 JAB Sent follow up urgent email to 

the Creditor with Insurance again

0.1 425 $42.50

7/17/2019 JAB Received a response from 

Creditor's attorney and 

responded; Called client to pick 

up belongings

0.2 425 $85.00

7/17/2019 JAB Debtor called to inform of 

$98.25 for title; withheld return 

of truck pending title; sent email 

to Creditor's attorney; Creditor 

called mistaken about when 

truck could be returned

0.3 425 $127.50

7/23/2019 JAB Client called to inform that he 

began to work on Friday, but was 

out of work on Tuesday, 

Wednesday, and Thursday

0.1 425 $42.50

7/29/2019 JAB Preparation for hearing, review 

of case file, and notes; 

Conference with JG; 

Printing/ECF COST: $6.00

0.5 425 $212.50

7/29/2019 JAG Conference with JB 0.2 125 $25.00

7/29/2019 JAB Prepared Fees and expenses 

incurred due to the repossession 

of the truck per court order

0.4 425 $170.00

7/30/2019 JAB Court hearing with parking 

(COST: $11.00) [Projected 

Time]

0.5 425 $212.50

8/1/2019 JAB Review of EHO; communicate 

with Jen, schedule deadlines; 

advise the client of the EH in 

October

0.5 425 $212.50

8/1/2019 JAG Conference for EH 0.2 125 $25.00

8/7/2019 JAB Forwarded email from Sergio to 

Wilson advising not to contact 

me directly; reached out to 

Wilson to discuss settlement.

0.2 425 $85.00

8/19/2019 JAB Review of another direct email 

from Sergio.

0.1 425 $42.50

8/19/2019 SSS Took phone call from Sergio 0.1 125 $12.50

8/19/2019 JAB Preparation, uploading and 1.3 425 $552.50

Case 19-17620-RAM Doc 52 Filed 09/19/19 Page 2 of 4
3

sending Discovery Documents at 

ECF 40; advised Wilson that 

Sergio emailed and that he called 

Ms. Sanchez a disgusting person 

and that she should get another 

job.

8/21/2019 JAB Review of call history with SSS 0.3 425 $127.50

8/21/2019 SSS Review of call history with JAB 0.3 125 $37.50

9/3/2019 JAB Review of court docket and 

emails to see if there was a 

response that was due yesterday

0.1 425 $42.50

9/3/2019 JAB Notice of filing discovery good 

faith letter; extending deadlines 

for responses. ECF43; emailed 

creditor

0.3 425 $127.50

9/6/2019 JAB Expedited Motion to Compel 

Responses ECF44; obtain 

hearing and send COS; email to 

creditor [.9 No Charge N/C 

because reached an agreed order 

for this specific motion]

0 425 0

9/9/2019 JAB Coordinated expedited hearing 

with chambers; six emails 

to/from Wilson [from 9/9/2019 -

9/13/2013] [0.7 N/C]

0 425 0

9/10/2019 JAB Reviewed and responded to 

Wilson's email for an agreed 

order. [0.2 N/C]

0 425 0

9/16/2019 JAB Agreed Order on Motion to 

Compel 48; and COS; emailed 

Wilson [0.4 N/C]

0 425 0

9/17/2019 JAB Conference with JG 0.2 425 $85.00

9/17/2019 JAG Conference with JB 0.2 125 $25.00

9/17/2019 JAB Client called to speak about the 

EH and progression of case

0.2 425 $85.00

9/17/2019 JAB Prepared and filed 2004 Exam; 

Witness and mileage fee; sent 

cert. (Cost: $54.00 + $6.85)

0.6 425 $255.00

9/19/2019 JAB Review of court audio; 

Researching, drafting, uploading 

and serving Motion for 

Contempt; SJ; Memo; Entry of 

order

5.2 425 $2,210.00

9/19/2019 JAB Prepared Updated Fees and 

expenses incurred

0.6 425 $37.50

JAB Preparation for hearing, review 

of case file, and notes; 

Conference with JG; 

Printing/ECF COST: $6.00 

[Projected Time]

0.5 425 $212.50

JAG Conference with JB [Projected 

Time]

0.3 125 $37.50

JAB Court hearing with parking 

(COST: $11.00) [Projected 

Time]

0.5 425 $212.50

Case 19-17620-RAM Doc 52 Filed 09/19/19 Page 3 of 4
4

10/02/2019 JAB 2004 Exam (Projected Cost: 

$200) [Projected Time = 2 

Hours; not req. if court rules SJ]

0 425 $0.00

Total Time Spent 20.9 $8,162.50

TOTAL COSTS 

TOTAL FEES and COSTS $8,162.50 $309.60 $8,472.10

In addition, Mr. Sorroche had the following damages that occurred as a direct 

result after the Truck was taken on July 3, 2019 through the date of return on July 18, 

2019 in the late afternoon. 

Mario Sorroche Moreno Lost Income and Expenses

Date Description Amount

7/2/2019 Truck was taken

7/8/2019 Cost to retrieve items $150.00

7/15/2019 Placed insurance on vehicle 

and emailed Creditor's 

attorney

7/17/2019 Average lost earnings of $300 

per day; (7/17/2019 -

7/18/2019; 2 days)

$600.00

7/17/2019 Transfer title fee paid by the 

Debtor

$98.25

Total $848.25

I HEREBY CERTIFY that I am admitted to the Bar of the United States District Court 

for the Southern District of Fla. and I am in compliance with the additional qualifications 

to practice in this Court set forth in Local Rule 2090-1(A) and that this was sent via 

CM/ECF to Paul Wilson, Esq. and to Nancy Neidich, Trustee on September 19, 2019. 

Respectfully Submitted: 

ROBERT SANCHEZ, P.A. 

Attorney for Debtor

355 W 49th Street

Hialeah, FL 33012

Tel. 305-687-8008

By: _/s/ Jose A. Blanco___________________

 Jose A. Blanco, Esq., FBN#0062449

Case 19-17620-RAM Doc 52 Filed 09/19/19 Page 4 of 4