UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

MIAMI DIVISION

www.flsb.uscourts.gov

In re: 

HECTOR Y. FAGUNDO SERRANO,

Debtor.

__________________________________/

Case No. 19-23676-AJC

Chapter 7

SUMMARY OF FIRST AND FINAL APPLICATION FOR ALLOWANCE 

AND PAYMENT OF COMPENSATION AND REIMBURSEMENT OF 

EXPENSES TO DUNN LAW, P.A., AS COUNSEL TO MARCIA T. DUNN, 

CHAPTER 7 TRUSTEE FOR THE ESTATE OF HECTOR Y. FAGUNDO SERRANO

Name of Applicant: Michael P. Dunn, Esq. and Dunn 

Law, P.A.

Role of Applicant: Counsel to Marcia T. Dunn as Chapter 

7 Trustee

Name of Certifying Professional: Michael P. Dunn, Esq.

Date Case Filed (Petition Date): October 11, 2019

Date of Application for Employment: December 2, 2019 [D.E. 17]

Date of Order Approving Employment: December 4, 2019 [D.E. 18]

Date of This Application: July 30, 2020

Dates of Services Covered in This Application: December 2, 2019 through July 30, 2020 

Total Funds Recovered for the Benefit of the Estate $7,100.00

Fees

Gross Fees Requested Under This Application: $4,707.00

Voluntary Fee Reduction: ($2,307.00)

Net Fees Requested Under This Application: $2,400.00

Expenses

Total Reimbursement of Expenses Requested This 

Application

$63.50

Net Award Requested: $2,463.50

Case 19-23676-AJC Doc 40 Filed 07/30/20 Page 1 of 22
2

UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

MIAMI DIVISION

www.flsb.uscourts.gov

In re:

HECTOR Y. FAGUNDO SERRANO,

Debtor.

__________________________________/

Case No. 19-23676-AJC

Chapter 7

FIRST AND FINAL APPLICATION FOR ALLOWANCE AND PAYMENT 

OF COMPENSATION AND REIMBURSEMENT OF EXPENSES TO DUNN 

LAW, P.A., AS COUNSEL TO MARCIA T. DUNN, CHAPTER 7 TRUSTEE

FOR THE ESTATE OF HECTOR Y. FAGUNDO SERRANO

Michael P. Dunn, Esq. and Dunn Law, P.A. (the “Applicant”) as counsel to Marcia T. 

Dunn, Chapter 7 Trustee (the “Trustee”) for the bankruptcy estate of HECTOR Y. FAGUNDO 

SERRANO, applies for final compensation of fees for services rendered and reimbursement of 

costs incurred in this Chapter 7 proceeding (the “Application”). This Application is filed 

pursuant to 11 U.S.C. § 330 and Bankruptcy Rule 2016(a) and meets all of the requirements set 

forth in the Guidelines on Fee Applications for Professionals in the Southern District of Florida

(the “Guidelines”) incorporated in Local Rule 2016-1(B)(1). 

In accordance with the Guidelines, the following exhibits are annexed to this Application:

Exhibits “1-A” and “1-B” – Summaries of Professional and Paraprofessional Time

Exhibit “2” – Summary of Requested Reimbursement of Expenses

Exhibit “3” – Applicant’s complete time records, in chronological order, by category 

code, for the time period covered by this Application. The requested fees are itemized to the

tenth of an hour. 

BACKGROUND

On October 11, 2019, (the “Petition Date”), HECTOR Y. FAGUNDO SERRANO (the 

Case 19-23676-AJC Doc 40 Filed 07/30/20 Page 2 of 22
3

“Debtor”) commenced the instant bankruptcy case with the filing of a voluntary petition under 

Chapter 7, Title 11 of the United States Bankruptcy Code.

Marcia T. Dunn is the duly appointed Chapter 7 Trustee of the Debtor’s bankruptcy 

estate (the “Estate”).

On November 14, 2019, the Debtor’s § 341 Meeting of Creditors (the “341 Meeting”) 

was held and concluded.

On November 15, 2019, the Trustee file a Report of No Distribution [D.E. 11], and on 

November 21, 2019, the Report of No Distribution was withdrawn by the Trustee [D.E. 16].

On December 4, 2019, upon application by the Trustee [D.E. 17], this Court entered an 

Order Granting Ex-Parte Application for Approval of Employment of Michael P. Dunn and 

Dunn Law, P.A. as Counsel to Marcia T. Dunn, Chapter 7 Trustee [D.E. 18]. 

The Applicant submits this Application, pursuant to 11 U.S.C. §§ 328, 330, 331 and

503(b), Fed.R.Bankr.P. 2016 and the Guidelines.

The Applicant requests an award of legal fees and the reimbursement of expenses 

incurred by the Applicant for services rendered, as counsel to the Trustee, in the amount of 

$4,770.50 comprised of (a) $4,707.00 for services rendered during the period of December 2, 

2019 through July 30, 2020 (the “Application Period”); and (b) $63.50 as reimbursement for the

actual and necessary expenses incurred by the Applicant during the Application Period.

This request is the Applicant’s first and final application to the Court for compensation 

and reimbursement of expenses for services rendered as counsel to the Trustee. As a result of 

total recoveries made to date, the Applicant is making this request for compensation and submits 

that funds are available to pay the fees requested herein. No understanding exists between the 

Applicant and any other person for the sharing of compensation sought by this Applicant, except 

among the partners and associates of the Applicant.

Case 19-23676-AJC Doc 40 Filed 07/30/20 Page 3 of 22
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The Applicant has expended a total of 18.10 hours during the Application Period in 

rendering necessary and beneficial legal services to the Trustee. Exhibits “1-A” and “1-B”

contain a list of the Applicant’s professionals and paraprofessionals who have provided services 

to the Trustee during the Application Period, the hourly rate charged by each and a summary of 

time expended by each as well as a summary of professional and paraprofessional time by 

activity code as required by, and in compliance with, the Guidelines. Exhibit “2” contains a 

summary of the Applicant’s total actual and necessary out-of-pocket expenses and 

disbursements, on behalf of the Trustee, for which the Applicant seeks reimbursement in 

accordance with 11 U.S.C. § 330(a)(2), the Bankruptcy Rules and the Guidelines. The expenses 

and disbursement summarized in Exhibit “2” are those which the Applicant typically would 

invoice to its non-bankruptcy clients.

The majority of work in this case was performed by Michael P. Dunn, Joel S. Knee, 

Barry S. Turner and their paralegal and legal support staff. Exhibit “3” contains: (i) a daily 

description of the services rendered and the hours expended by the attorney and 

paraprofessionals of the Applicant who performed services in this case on behalf of the Trustee;

and (ii) a detailed schedule listing of the expenses and disbursements for which the Applicant 

seeks reimbursement. The Applicant has prepared Exhibit “3” based on, among other things, 

contemporaneous daily time records maintained by the Applicant's attorneys and 

paraprofessionals who rendered services in this case.

Applicant believes that the requested fees and costs, which total $4,770.50 are

reasonable1considering the twelve (12) factors enumerated in Johnson v. Georgia Highway 

Express, Inc., 488 F.2d 714 (5th Cir. 1974), made applicable to bankruptcy proceedings by In re 

1 However, for the Benefit of the Estate, Applicant takes a voluntary reduction of $2,307.00 in fees for a total fee request of 

$2,400.00, plus full reimbursement of costs. 

Case 19-23676-AJC Doc 40 Filed 07/30/20 Page 4 of 22
5

First Colonial Corp., 544 F.2d 1291 (5th Cir. 1977).

INDEXING OF TASKS BY ACTIVITY / CATEGORY CODES

As set forth in the exhibits to this Application, the Applicant has organized its time 

records by activity category codes in accordance with the Guidelines. Accordingly, each of the 

time entries of the attorneys and paraprofessionals of the Applicant have been indexed into the 

categories listed below.

Case Administration: Coordination and compliance activities, including, but not limited 

to: correspondence with the Trustee; general creditor inquiries; and other tasks not 

otherwise indexed by activity code.

Asset Analysis & Recovery: Identification and review of potential assets including

causes of action and non-litigation recoveries.

Fee/Employment Application: Preparation of employment and fee applications for self; 

motions to establish interim procedures.

SUMMARY OF SERVICES PERFORMED

The following is a Summary of Services Performed on behalf of the Trustee in

connection with this case:

Case Administration. During the Application Period, the Applicant assisted and 

counseled the Trustee with regards to matters concerning all aspects of the administration of this 

case and conducted numerous conferences with the Trustee, and other parties-in-interest with 

regards to the general status of the Chapter 7 case. Applicant participated in discussions, 

collaborated with various parties, and reviewed documents and information concerning the prepetition activities of the Debtor to ascertain the financial position and obligations of the Debtor.

Applicant has expended 3.6 hours totaling $582.50 in fees under this Application in the 

routine management and monitoring of this case as well as ministerial functions such as the

preparation and filing of certificates of service.

Case 19-23676-AJC Doc 40 Filed 07/30/20 Page 5 of 22
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Asset Analysis and Recovery. The Debtor had a pre-petition personal injury claim (the

“Claim”), and as a result of the bankruptcy filing, the Claim became property of the Estate and

the Trustee asserted the Estate’s right to the Claim.

Upon the retention of the Applicant as counsel to the Trustee in December 2019,

Applicant assisted special counsel with the prosecution of the Claim, in addition to reviewing, 

analyzing, and negotiating a consensual resolution between all involved parties.

Pursuant to the settlement reached between the parties, the defendant agreed to pay the 

Trustee a gross sum of $7,100.00, as full settlement of the Claim. The settlement is more fully 

set forth in the Motion to Approve Stipulation to Compromise Controversy [D.E. 36]. 

Applicant has expended 10.5 hours totaling $2,997.00 in fees under this Application with 

respect to Asset Analysis and Recovery.

Fee/Employment Application. Applicant assisted with the preparation and filing of 

retention application, declaration and order on behalf of: (i) the Applicant, as counsel to the 

Trustee; and (ii) Justin Weinstein, Esquire and Weinstein Legal, as special counsel to the 

Trustee.

Applicant has expended 4.5 hours totaling $1,215.00 in fees under this Application in the 

preparation, review and filing of retention pleadings upon internal conflict check, and in the 

preparation and review of this Application.

EVALUATION OF SERVICES RENDERED

This Application has presented the nature and extent of the professional services the 

Applicant has rendered in connection with its representation of the Trustee for which the 

Applicant seeks compensation. The recitals set forth in the daily dairies attached hereto

constitute only a summary of the time spent. 

Case 19-23676-AJC Doc 40 Filed 07/30/20 Page 6 of 22
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Under the Bankruptcy Code, the applicable legal standard for determining reasonable 

compensation is set forth in 11 U.S.C. § 330, which states that reasonable compensation shall be 

based on the nature, the extent, and the value of such services, the time spent on such services,

and the cost of comparable services other than in a case under Title 11 of the United States Code, 

and reimbursement for actual, necessary expenses incurred. 

In American Benefit Life Ins. Co. v. Baddock (In re First Colonial Corp.), 544 F.2d 1291

(5th Cir.), cert denied, 431 U.S. 904 (1977), the court enumerates twelve factors a bankruptcy 

court should evaluate in awarding fees. First Colonial remains applicable in the Eleventh Circuit

to the determination of reasonableness of fees to be awarded under the Bankruptcy Code. Grant 

v. George Schumann Tire & Battery Company, 908 F.2d 874 (11th Cir. 1990); Collier on 

Bankruptcy & 330.05[2][a] at 330-33 through 330-37 (L. King 15th ed. 1991); See also Bonner 

v. City of Prichard, 661 F.2d 1206, 1209 (11th Cir. 1981). The twelve factors are:

(1) The time and labor required;

(2) The novelty and difficulty of the questions presented;

(3) The skill required to perform the legal services properly;

(4) The preclusion from other employment by the attorney due to acceptance of the case;

(5) The customary fee for similar work in the community;

(6) Whether the fee is fixed or contingent;

(7) The time limitations imposed by the client or circumstances;

(8) The amount involved and results obtained;

(9) The experience, reputation and ability of the attorneys;

(10) The undesirability of the case;

(11) The nature and length of the professional relationship with the client; and

Case 19-23676-AJC Doc 40 Filed 07/30/20 Page 7 of 22
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(12) Awards in similar cases.

First Colonial, 544 F.2d at 1298-99.

Based on the standards set forth in 11 U.S.C. § 330 and First Colonial, the Applicant 

believes that the fair and reasonable value of its services rendered during the period covered by 

this Application is the total amount of $2,400.00 (which includes a voluntary reduction of 

$2,307.00),, plus expenses of $63.50. Dunn Law, P.A. respectfully requests that it be granted all 

fees and expenses requested herein based on the nature and results of its representation of the 

Trustee, the time invested in this case, and the necessity and reasonableness of the fees and 

expenses incurred.

The Time and Labor Required

The foregoing summary, together with the exhibits attached hereto, details the time, 

nature and extent of the professional services of the Applicant rendered for the benefit of the 

Estate during the period covered by this Application. The total number of hours expended (18.1) 

reveals the time devoted to this matter by the Applicant which have arisen in this case during the 

period covered by this Application. Exhibit “1” reflects the time actually expended by the 

Applicant. 

The Novelty and Difficulty of the Services Rendered

The issues which have arisen in this case during the period encompassed by this 

Application presented matters that required the services and skill of an experienced bankruptcy 

attorney. The Applicant spent considerable time reviewing or drafting discovery, pleadings and 

documents.

Case 19-23676-AJC Doc 40 Filed 07/30/20 Page 8 of 22
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Skill Requisite to Perform Services Properly

In rendering services to the Trustee, the Applicant demonstrated substantial legal skill 

and expertise in the areas of bankruptcy, commercial law, Debtors-creditor rights, secured 

transactions, and negotiation.

The Preclusion of Other Employment by Applicant Due to Acceptance of Case

The Applicant devoted substantial time in the representation of the Chapter 7 Trustee as 

more fully appears on Exhibit “3.” The Applicant is aware of no other specific employment 

which was precluded as a result of its accepting this case, but had the Applicant not accepted this 

employment, the time spent in the case would have been spent on other matters which would pay 

an hourly compensation on a current basis.

The Customary Fee

The hourly rate charged by the Applicant as set forth in Exhibits “1” and “2” ranges 

from $400 to $425 per hour for the attorneys and $175 to $215 per hour for the 

paraprofessionals, throughout the Application Period, which is customary for professionals and 

paraprofessionals in the Southern District of Florida of similar skill and experience.

Whether Fee is Fixed or Contingent

The Applicant's compensation in this matter is subject to approval of the Court and 

therefore contingent. The Court should consider this factor, which militates in favor of a fee 

award in the amount requested. The amount requested is consistent with the fee which the 

Applicant would charge its clients in other non-contingent, bankruptcy and commercial cases.

Time Limitations Imposed By Client or Other Circumstances

The services performed by the Applicant were performed under time constraints imposed 

by the Chapter 7 Trustee. Therefore, time had to be expended within short periods of time to 

Case 19-23676-AJC Doc 40 Filed 07/30/20 Page 9 of 22
10

produce pleadings, review documents and perform research in connection with the examination 

of the Debtors, and to prepare settlement documents predicated upon the Chapter 7 Trustee’s 

proposed actions to resolve the issues in this Estate. The circumstances of this case occasionally 

imposed serious time constraints on the Applicant due to the necessity for rapid resolution of 

significant issues.

The Experience, Reputation, and Ability of Applicant

The Applicant is well-known and the attorney working on this case is experienced in 

matters of this kind. Undersigned counsel has significant bankruptcy experience and has 

appeared numerous times before this Court on other matters. The Applicant’s reputation and 

abilities are well known to this Court. The Applicant enjoys a fine reputation and has 

demonstrated substantial ability in the fields of bankruptcy, litigation, and creditors’ rights.

Undesirability of the Case

The representation of the Chapter 7 Trustee and of this case was in no way undesirable. 

The Applicant is privileged and honored to have the opportunity to represent the Trustee and to 

appear before the Court in this case.

Nature and Length of Professional Relationship with Client

The Applicant has represented the Trustee in many other bankruptcy cases and matters 

wholly unrelated to the Debtor or this case.

Awards in Similar Cases

The amount requested by the Applicant is reasonable in terms of awards in cases of 

similar magnitude and complexity. The compensation which the Applicant requests comports 

with the mandate of the Bankruptcy Code, which directs that services be evaluated in light of 

comparable services performed in non-bankruptcy cases in the community. The fees incurred by 

Case 19-23676-AJC Doc 40 Filed 07/30/20 Page 10 of 22
11

the Applicant ($4,707) reflect an average hourly rate of $260 for 18.1 hours of service. 

Considering the results obtained during the periods covered by this Application, this rate is

appropriate.

CONCLUSION

WHEREFORE, the Applicant respectfully requests the Court to enter an order (i) 

awarding the Applicant the sum of $2,400.00 as compensation for services rendered, and $63.50

as reimbursement for actual and necessary expenses incurred during the course of Applicant’s 

representation of the Trustee during the Application Period; (ii) authorizing and directing the 

Trustee to pay the Applicant the aggregate sum of $2,463.50 upon entry of an Order awarding

the fees requested in this Application; (iii) granting such further relief the Court deems just and

proper.

Dated: July 30, 2020 Respectfully submitted,

DUNN LAW, P.A.

Counsel for Marcia T. Dunn, Chapter 7 Trustee

66 West Flagler Street, Suite 400

Miami, Florida 33130

Phone: (786) 433-3866 | | Fax: (786) 260-0269

michael.dunn@dunnlawpa.com 

By: /s/ Michael P. Dunn d

 Michael P. Dunn, Esq.

 Florida. Bar No. 100705

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on July 30, 2020, a true and correct copy of the foregoing 

was served via the Court’s CM/ECF electronic transmission system to all interested parties who 

are currently on the list to receive e-mail notice and service for this case. 

By: /s/ Michael P. Dunn d

 Michael P. Dunn, Esq.

 Florida. Bar No. 100705

Case 19-23676-AJC Doc 40 Filed 07/30/20 Page 11 of 22
12

EXHIBIT 1-A

Summary of Professional and Paraprofessional Time

Name of Paraprofessional Total Hours Hourly Rate* Total Fees

Michael P. Dunn, Esq. 3.4 $400-425 $1,422.50

Barry S. Tuner, Esq. 0.6 $425 $255.00

Joel S. Knee, Esq. 1.8 $425 $765.00

Maria D. Zucker, Paralegal 6.3 $215 $1,354.50

Rosa Basnueva, Legal Assistant 6.0 $175 $910.00

TOTALS 18.1 Hours ($260/Blended) $4,707.00

EXHIBIT 1-B

Summary of Professional and Paraprofessional Time By Activity Code Category

ACTIVITY CODE CATEGORY: FEE/EMPLOYMENT APPLICATIONS

Name of Professional/Para Total Fees Total Hours Hourly Rate

Michael P. Dunn, Esq. $505.00 1.2 $400-425

Barry S. Turner, Esq. $255.00 0.6 $425

Rosa Basnueva, Legal Assistant $455.00 2.7 $175

TOTALS $1,215.00 4.5

ACTIVITY CODE CATEGORY: ASSET ANALYSIS & RECOVERY

Name of Professional/Para Total Fees Total Hours Hourly Rate

Michael P. Dunn, Esq. $790.00 1.9 $400-425

Joel S. Knee, Esq. $765.00 1.8 $425

Maria D. Zucker, Paralegal $1,354.50 6.3 $215

TOTALS $2,909.50 10.0

ACTIVITY CODE CATEGORY: CASE ADMINISTRATION

Name of Paraprofessional Total Fees Total Hours Hourly Rate

Michael P. Dunn, Esq. $127.50 0.3 $400-425

Rosa Basnueva, Legal Assistant $455.00 3.3 $175

TOTAL $582.50 3.6

*Rates subject to annual change

Case 19-23676-AJC Doc 40 Filed 07/30/20 Page 12 of 22
13

EXHIBIT 2

Summary of Requested Reimbursement of Expenses

Filing Fees and Electronic Court Filing Charges $0.00

Process Service Fees $0.00

Witness Fees $0.00

Court Reporter Fees and Transcripts $0.00

Certification of Pleading Documents $0.00

Photocopies (In-House) 63 pages @ $0.15 $9.45

Photocopies/Mailing (Outsourced) $36.00

Postage $18.05

Overnight Delivery Charges $0.00

Outside Courier/Messenger Services $0.00

Long Distance Calls $0.00

Facsimile Transmissions $0.00

Computerized Legal Research $0.00

Out of District Travel $0.00

Other Permissible Expenses $0.00

TOTAL EXPENSE REIMBURSEMENT $63.50

Case 19-23676-AJC Doc 40 Filed 07/30/20 Page 13 of 22
14

CERTIFICATION

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

current “Guidelines on Fee Applications for Professionals in the Southern District of Florida” 

(the “Guidelines”).

2. I have read the 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 and expenses sought are billed at rates and in accordance with the

practices customarily employed by the Applicant and generally accepted by the Applicant’s 

clients.

4. In seeking reimbursement for the expenditures, the Applicant is seeking

reimbursement only for the actual expenditure and has not marked up the actual cost to provide a 

profit or to recover the amortized cost of investment in staff time or equipment or capital outlay 

(except to the extent that the Applicant has elected to charge for in-house photocopies and 

outgoing facsimile transmissions at the maximum rates permitted by the Guidelines).

5. In seeking reimbursement for any service provided by a third party, the Applicant

is seeking reimbursement only for the amount actually paid by the Applicant to the third party.

6. There are no variances in the Application with the provisions of the Guidelines.

/s/ Michael P. Dunn

Michael P. Dunn, Esq.

Florida Bar No. 100705

Case 19-23676-AJC Doc 40 Filed 07/30/20 Page 14 of 22
Dunn Law PA

66 West Flagler Street

Suite 400

MIami, 33130

Date: 7/30/2020

Case No.: 19-23676-AJC

Matter: Serrano, Hector Y. Fagundo

Time Entries

Time Entries Billed By Rate Hours Sub

Manage data/files

12/2/2019

Receipt and review of email from Trustee regarding new asset case;

create case e-file folder; create billing matter; revise asset analysis

chart with initial case information; review petition schedule D; calendar

all necessary deadlines.

RB $175.00 0.50 $87.50

Draft/revise

12/2/2019

Draft, revise firm employment application; circulate same for execution.

RB $175.00 0.40 $70.00

Review / Revise

12/2/2019

Review and revise employment application; execute employment

affidavit.

MPD $400.00 0.20 $80.00

Review / Revise

12/2/2019

Review, revise, Application to Employ Dunn Law as Counsel to Chapter

7 Trustee.

RB $175.00 0.20 $35.00

Communicate (other outside counsel)

12/3/2019

Email to Justin Weinstein, Esq regarding personal injury claim of

Debtor, and his possible representation of the Trustee as special

counsel.

JSK $425.00 0.70 $297.50

Review/analyze

12/3/2019

Review Trustee's initial case analysis; additional review and analysis of

Debtor's schedules and case filing, including review of recent auto

accident report.

MDZ $215.00 2.00 $430.00

Invoice #1813044Page 1 of 6 

Case 19-23676-AJC Doc 40 Filed 07/30/20 Page 15 of 22
Time Entries Billed By Rate Hours Sub

Drafted

12/3/2019

Drafted objection to exemptions, email to R. Basnueva regarding filing

JSK $425.00 1.10 $467.50

Certificate of Service

12/4/2019

Review Order Granting Application to Employ Dunn Law as Trustee's

Counsel [ECF No. 18]; Draft,Certificate of Service for same.

RB $175.00 0.30 $52.50

Review

12/4/2019

Review case status and trustee's objection deadlines.

RB $0.00 0.10 $0.00

Review / Revise

12/4/2019

Review, revise, Trustee's Objection to Claimed Exemptions and Motion

for Turnover.

RB $175.00 0.30 $52.50

Certificate of Service

12/4/2019

Review Notice of Hearing [ECF No. 21]; Draft Certificate of Service for

same.

RB $175.00 0.30 $52.50

Communicate (other external)

12/11/2019

Follow up email to Justin Weinstein, PI attorney for Debtor.

MDZ $215.00 0.20 $43.00

Correspondence

12/12/2019

review correspondence with PI counsel regarding case update

MPD $400.00 0.10 $40.00

Review

12/18/2019

Review response from PI counsel regarding Debtor's auto accident

claim.

MDZ $215.00 0.20 $43.00

Research

12/18/2019

Review Debtor's bank statements, and email Debtor's counsel seeking

additional documents and information.

MDZ $215.00 0.70 $150.50

Review/analyze

12/18/2019

Brief review of schedules filed by Esther Serrano in relation to those

filed by Hector Serrano, particularly in relation to joint vehicle

ownership.

MDZ $215.00 0.50 $107.50

Communicate (other external)

12/19/2019

Email from Debtor's counsel regarding documents and information

requested.

MDZ $215.00 0.10 $21.50

Review/analyze

12/19/2019

Review savings account statements and 2017 Chevy Malibu info

received from Debtor's counsel.

MDZ $215.00 0.30 $64.50

Drafted

12/30/2019

Drafted proposed agreed ex-parte order on Trustee’s Objection to

Debtor’s Claimed Exemptions and Valuation of Scheduled Property,

and Motion for Turnover of Non-Exempt Assets.

MDZ $215.00 0.50 $107.50

Invoice #1813044

Page 2 of 6 

Case 19-23676-AJC Doc 40 Filed 07/30/20 Page 16 of 22
Time Entries Billed By Rate Hours Sub

Correspondence

12/30/2019

Review file and schedules; review and reply to emails with Debtor's

counsel regarding objection to exemption and motion for turnover;

review revise proposed agreed order; emails exchanged with debtor's

counsel regarding same

MPD $400.00 0.60 $240.00

Communicate (in firm)

1/6/2020

Confer with MPD regarding hearing on Trustee's Objection to Claimed

Exemptions.

RB $0.00 0.10 $0.00

Certificate of Service

1/6/2020

Review Order on Trustee's (1) Objection to Debtor's Claimed

Exemptions and Valuation of Scheduled Property, and (2) Motion for

Turnover of Non-Exempt Assets [ECF No. 23]; Draft Certificate of

Service for same.

RB $175.00 0.30 $52.50

Communicate (in firm)

1/6/2020

Email to MPD and MDZ regarding upcoming 727 deadline.

RB $0.00 0.10 $0.00

Communicate (in firm)

1/6/2020

Review deadline to object to discharge and employment of P.I. counsel.

MDZ $215.00 0.20 $43.00

Drafted

1/7/2020

Drafted application to employ special counsel, proposed order and

affidavit of special counsel; emailed same to MPD for approval.

RB $175.00 1.00 $175.00

Communicate (in firm)

1/8/2020

Email to MPD regarding trustee's deadline to object to debtor's

discharge.

RB $0.00 0.10 $0.00

Draft/revise

1/13/2020

Review revise retention application for special personal injury counsel

MPD $425.00 0.40 $170.00

Communicate (other outside counsel)

1/14/2020

Email to special counsel with copy of employment affidavit for

execution.

RB $175.00 0.10 $17.50

Review / Revise

1/14/2020

Review and revise affidavit of special counsel.

RB $175.00 0.10 $17.50

Emails

1/14/2020

Emails exchanged with special counsel regarding revised employment

affidavit.

RB $175.00 0.10 $17.50

Review / Revise

1/17/2020

Review, revise Trustee's Application to Employ Special Counsel.

RB $175.00 0.20 $35.00

Certificate of Service

1/17/2020

Review Notice of Hearing of Trustee's Application to Employ Special

Counsel [ECF No. 27]; Draft, Certificate of Service for same.

RB $175.00 0.20 $35.00

Invoice #1813044

Page 3 of 6 

Case 19-23676-AJC Doc 40 Filed 07/30/20 Page 17 of 22
Time Entries Billed By Rate Hours Sub

Emails

1/17/2020

Emails exchanged with office of special counsel regarding employment.

RB $0.00 0.10 $0.00

Hearing Preparation

2/10/2020

Prepared hearing binder for hearing on Application to Employ Special

Counsel

BT $425.00 0.60 $255.00

Hearing Preparation

2/10/2020

Prepared hearing binder for hearing on Trustee's Application to Employ

Special Counsel.

RB $175.00 0.10 $17.50

Review / Revise

2/11/2020

Review, and revise Order Granting Trustee's Application to Employ

Special Counsel.

RB $175.00 0.10 $17.50

Plan and prepare for

2/11/2020

Prepare for and attend hearing on application to employ special counsel

MPD $425.00 0.60 $255.00

Correspondence

2/17/2020

Correspondence with special counsel regarding retention as SC and

demand to defendant

MPD $425.00 0.20 $85.00

Certificate of Service

2/17/2020

Review Order Granting Trustee's Application to Employ Special Counsel

[ECF No. 31]; Draft Certificate of Service for same.

RB $175.00 0.20 $35.00

Review/analyze

2/18/2020

Review documents responsive to Trustee's Rule 2004 Examination

Duces Tecum, and email with Debtor's counsel for missing items.

MDZ $215.00 0.80 $172.00

Correspondence

3/5/2020

Correspondence regarding PI claim and case administration

MPD $425.00 0.20 $85.00

Communicate (other external)

3/18/2020

Re-review documents produced by Debtor, and email to Debtor's

counsel seeking bank statements through year-end 2019 (no bank

statements as of Petition Date provided).

MDZ $215.00 0.20 $43.00

Review

4/9/2020

Review email from PI Counsel on status of claim and potential

settlement.

MDZ $215.00 0.10 $21.50

Correspondence

4/9/2020

Emails exchanged with personal injury counsel regarding settlement

and process; discuss same and claims issues with MZ

MPD $425.00 0.30 $127.50

Review

4/9/2020

Review schedules and amendments, and email Debtor's counsel for

confirmation that all medical claims are scheduled and extend offer for

Debtor to purchase the PI claim from the Estate.

MDZ $215.00 0.20 $43.00

Invoice #1813044

Page 4 of 6 

Case 19-23676-AJC Doc 40 Filed 07/30/20 Page 18 of 22
Time Entries Billed By Rate Hours Sub

Correspondence

4/9/2020

Additional correspondence with PI counsel; internal correspondence

with MZ and RB regarding information from debtor

MPD $425.00 0.20 $85.00

Correspondence

4/10/2020

correspondence with special counsel regaridng administering PI claim

and settlement

MPD $425.00 0.10 $42.50

Correspondence

4/13/2020

Correspondence with debtor's counsel regarding case issues.

MPD $425.00 0.10 $42.50

Communicate (other external)

4/15/2020

Telephone call with Debtor's counsel regarding Debtor's rejection to

purchase personal injury claim from the Estate.

MDZ $215.00 0.20 $43.00

Communicate (in firm)

4/15/2020

Discuss setting claim bar date with respect to pending settlement of PI

claim.

MDZ $215.00 0.10 $21.50

Correspondence

4/21/2020

Correspondence with PI counsel regarding settlement

MPD $425.00 0.20 $85.00

Communicate (in firm)

5/6/2020

Case status review with MDZ regarding preparation of personal injury

settlement motion.

RB $0.00 0.10 $0.00

Emails

5/6/2020

Emails exchanged with MPD regarding preparation of 9019 motion.

RB $0.00 0.10 $0.00

Draft/Review/Revise

5/7/2020

Draft, review and revise motion and proposed for settlement of personal

injury claim; emailed same to MPD for approval.

RB $175.00 0.50 $87.50

Review / Revise

5/12/2020

Review, and revise Motion to Approve Settlement and Compromise of

Personal Injury Claim.

RB $175.00 0.20 $35.00

Review / Revise

6/3/2020

Review, and revise Order Granting trustee's Motion to Approve

Settlement of Personal Injury Claim.

RB $175.00 0.10 $17.50

Emails

6/3/2020

Emails exchanged with special counsel regarding status of case.

RB $0.00 0.10 $0.00

Correspondence

6/3/2020

Review order on approval of PI settlement; correspondence with PI

counsel regarding same

MPD $425.00 0.20 $85.00

Time Entries

Total

18.10 $4,707.00

Invoice #1813044

Page 5 of 6 

Case 19-23676-AJC Doc 40 Filed 07/30/20 Page 19 of 22
Total (USD) $4,707.00

Paid $0.00

Balance $4,707.00

Timekeeper Totals

Name Rate Hours Total

RB $151.67 6.00 $910.00

MPD $418.38 3.40 $1,422.50

MDZ $215.00 6.30 $1,354.50

BT $425.00 0.60 $255.00

JSK $425.00 1.80 $765.00

Invoice #1813044

Page 6 of 6 

Case 19-23676-AJC Doc 40 Filed 07/30/20 Page 20 of 22
Dunn Law PA

66 West Flagler Street

Suite 400

MIami, 33130

Date: 7/30/2020

Case No.: 19-23676-AJC

Matter: Serrano, Hector Y. Fagundo

Expenses

Expense Price Qty Sub

Copying

12/2/2019

Application to Employ Dunn Law as Counsel to Chapter 7 Trustee.

$0.15 12.00 $1.80

Postage

12/2/2019

Application to Employ Dunn Law as Counsel to Chapter 7 Trustee.

$0.65 1.00 $0.65

Copying

12/4/2019

Order Granting Application to Employ Dunn Law as Trustee's Counsel [ECF No. 18].

$0.15 4.00 $0.60

Postage

12/4/2019

Order Granting Application to Employ Dunn Law as Trustee's Counsel [ECF No. 18].

$0.50 1.00 $0.50

Copying

12/4/2019

Trustee's Objection to Claimed Exemptions and Motion for Turnover and Notice of Hearing.

$0.15 5.00 $0.75

Postage

12/4/2019

Trustee's Objection to Claimed Exemptions and Motion for Turnover and Notice of Hearing.

$0.50 0.50 $0.25

Copying

1/6/2020

Order on Trustee's (1) Objection to Debtor's Claimed Exemptions and Valuation of Scheduled

Property, and (2) Motion for Turnover of Non-Exempt Assets [ECF No. 23].

$0.15 3.00 $0.45

Postage

1/6/2020

Order on Trustee's (1) Objection to Debtor's Claimed Exemptions and Valuation of Scheduled

Property, and (2) Motion for Turnover of Non-Exempt Assets [ECF No. 23].

$0.50 1.00 $0.50

Invoice #1813045Page 1 of 2 

Case 19-23676-AJC Doc 40 Filed 07/30/20 Page 21 of 22
Expense Price Qty Sub

Copying

1/17/2020

Trustee's Application to Employ Special Counsel.

$0.15 15.00 $2.25

Postage

1/17/2020

Trustee's Application to Employ Special Counsel.

$0.65 1.00 $0.65

Copying

2/10/2020

Hearing binder documents for hearing on Trustee's Application to Employ Special Counsel.

$0.15 20.00 $3.00

Copying

2/17/2020

Order Granting Trustee's Application to Employ Special Counsel [ECF No. 31].

$0.15 4.00 $0.60

Postage

2/17/2020

Order Granting Trustee's Application to Employ Special Counsel [ECF No. 31].

$0.50 1.00 $0.50

Outside printing

5/12/2020

Motion to Approve Settlement of Personal Injury Claim.

$31.50 1.00 $31.50

Postage

5/12/2020

Motion to Approve Settlement of Personal Injury Claim.

$7.50 1.00 $7.50

Outside printing

6/3/2020

Order Granting Trustee's Motion To Approve Settlement and Compromise of Personal Injury

Claim [ECF No. 37].

$4.50 1.00 $4.50

Postage

6/3/2020

Order Granting Trustee's Motion To Approve Settlement and Compromise of Personal Injury

Claim [ECF No. 37].

$7.50 1.00 $7.50

Expenses Total: 72.50 $63.50

Total (USD) $63.50

Paid $0.00

Balance $63.50

Invoice #1813045

Page 2 of 2 

Case 19-23676-AJC Doc 40 Filed 07/30/20 Page 22 of 22