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 OBJECTION TO SUPPLEMENTAL NOTICE OF POST-PETITION FEES, 

EXPENSES AND CHARGES FILED BY FACE BANK INTERNATIONAL 

CORPORATION

Debtor requests that this matter be set for hearing on June 16, 2020 at 9:00 a.m. along 

with other related matters in this case. 

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

counsel files this 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. 

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

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. The Debtor objects to the NPPF filed by Face Bank and requests that the Court review 

Face Bank’s supplemental NPPF and award an attorney’s fees that is reasonable and just. 

 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 5th day of June 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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