THE SEMRAD LAW FIRM 

Attorneys & Counselors at Law 

2332 Galiano, 2nd Floor 

Coral Gables, FL 33134 

(786) 706-8014

Thank you for selecting The Semrad Law Firm LLC (the “Firm”) as legal counsel. It is our policy 

to confirm in writing the terms of our engagement, including the scope of our representation 

and how we will charge for our legal services. Those terms are set forth below. 

1. Scope of Representation. The Firm will be representing you in all aspects of your

Bankruptcy case filed under Chapter 7 of the United Stated Bankruptcy Code except for

any adversary proceedings that may be filed against you. The scope of this

representation does not include any other civil or criminal proceedings.

2. Conditional Representation. The Firm has agreed to represent you on the condition that

you will enter into and sign an agreement after the filing of your bankruptcy case to pay

the Firm for services rendered after the filing of your case. If you refuse to enter into

and sign the agreement within ten (10) days after the filing of your case, the Firm will

file a motion to withdraw from representing you.

3. Prepetition Fees.

a. Before the case is filed, the Firm agrees to:

i. Personally counsel you regarding the advisability of filing either a Chapter

13 or a Chapter 7 case, discuss both procedures as well as nonbankruptcy options, and answer your questions;

ii. Personally explain to you that the Firm is being engaged to represent you

on all matters arising in the case, as required by Local Bankruptcy Rule,

and explain how and when the attorney’s fees are determined and paid;

iii. Personally review with you and sign the completed petition, statements,

and schedules;

iv. Timely prepare and file your petition, statements, and schedules,

v. Advise you on which creditors you will need to continue to pay, such as

housing or vehicle payments that you intend to retain.

b. The fee for services provided before the case is filed is $0.00.

c. The Firm may also incur costs for such items as credit reports and tax transcripts

for which it will not seek reimbursement.

4. Post-Petition Fees.

a. After the case is filed, the Firm agrees to:

i. Advise you of the requirement to attend the meeting of creditors and

notify you of the date, time, and place of the meeting;

Document Ref: WETZR-ZCEPB-N2UVR-UVZFY Page 1 of 4

Exhibit A

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Cheryl Brown 

ii. Advise you of the requirement to attend a debtor education course and

provide a certificate of completion to the Firm;

iii. Send notice of your case filing to creditors;

iv. Correspond with creditors regarding any matters necessary for the

administration of your case, including to cease payroll garnishments,

unfreeze bank accounts, or recover property that was improperly seized

by a creditor;

v. Timely submit to the Chapter 7 trustee properly documented proof of

income, tax records as well as any other necessary documentation;

vi. Provide you with knowledgeable legal representation at the meeting of

creditors as well as any continued or rescheduled meetings in time for

check-in and examination;

vii. Timely prepare and file the notice of completion of the debtor education

course;

viii. If the Firm will be employing another attorney to attend the meeting of

creditors, personally explain to you, in advance, the role and identity of

the other attorneys and provide that attorney with your file in sufficient

time to review it and properly represent you at the meeting;

ix. Timely negotiate with the Trustee regarding any property or actions that

the Trustee may pursue that could be adverse to your interests;

x. Timely prepare, file, and serve any necessary statements, amended

statements, amended schedules and any change of address, in

accordance with information provided by you;

xi. Monitor all incoming case information, including but not limited to,

Reaffirmation agreements, notice of audits by the US Trustee,

correspondence from you or any interested parties;

xii. Review and negotiate, if necessary, any reaffirmation agreements and

personally explain the terms of said agreements to you;

xiii. Be available to respond to your questions throughout the term of the

case;

xiv. Review and timely respond, if necessary, to Trustee motions to dismiss

the case;

xv. Review and timely respond, if necessary, to motions for relief from stay;

xvi. Prepare, file, and serve all appropriate motions to avoid liens;

xvii. Prepare, file, and serve all appropriate motion to redeem;

xviii. Send In Re Mendiola letters to previously undisclosed creditors; and

xix. Provide any other legal services necessary for the administration of the

case.

b. The fee for services provide after the case is filed is $1,362.00.

c. The firm will have no right to payment of the fee listed in section 4(b) unless you

sign an agreement after the filing of your bankruptcy case to pay the Firm for

services rendered after the filing of your case.

Document Ref: WETZR-ZCEPB-N2UVR-UVZFY Page 2 of 4

Case 20-23632-LMI Doc 19-1 Filed 02/19/21 Page 2 of 5
Cheryl Brown 

d. After the case is filed, the Bankruptcy Court will require payment of filing fees in 

the amount of $338.00. In order to pay this, you have two (2) options (please 

circle one): 

i. Pay the costs directly to the bankruptcy court either all at once, or apply 

to pay these costs in installments; or 

ii. Request that the Firm pay the costs on your behalf for which it will seek 

reimbursement from you; 

5. Retainers and Payments to the Firm. 

a. The fee being charged to you is a flat fee for services rendered during the 

Chapter 7 case and will be applied without the need for the Firm to keep 

detailed time records for the specific services performed. 

b. Any funds paid to the Firm shall immediately become property of the Firm and 

will be deposited into the operating account of the Firm and will be used for 

general expenses of the firm. 

c. While it is ordinarily your option to deposit funds with an attorney that shall 

remain your property as security for future services, the Firm does not represent 

clients under such a security retainer because bankruptcy cases require many 

disparate tasks and functions for the attorneys and support staff; some of which 

require legal expertise while others may only be ministerial in nature. The 

benefit to you is the firm’s commitment to perform any and all work necessary 

to represent you in this Chapter 7 bankruptcy. 

6. Right to Hire New Counsel. You always have the right at any time to terminate the 

Firm’s representation and hire new counsel. Should you refuse to sign an agreement 

after the filing of your bankruptcy case to pay the Firm for services rendered after the 

filing of your case, and the Firm moves to withdraw from representing you, you are 

strongly encouraged to hire new counsel. 

7. Conflict Waiver. There is an inherent conflict wherever attorneys represent debtors in 

bankruptcy for a fee. The Firm is working to alleviate financial issues, while at the same 

time charging a fee. There have also previously been cases that questioned whether 

asking you to sign an agreement after the filing of your bankruptcy case to pay the Firm 

for services rendered after the filing of your case presents a possible additional conflict 

of interest. The Firm may only represent you if that representation will not be 

materially limited by the Firm’s own interests. We believe our ability to represent you 

will not be affected by your ongoing obligation to pay our post-petition fee. By signing 

this agreement, you are waiving this conflict and are allowing us to represent you. You 

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Cheryl Brown 

do not have to waive this conflict of interest and can instead choose for the Firm not to 

represent you. You also have the right to consult separate counsel to discuss whether 

you should waive this conflict. 

8. Merger. This agreement constitutes the entire agreement between you and the Firm. 

Any previous discussions or agreements are not valid or enforceable unless contained in 

this document. 

Very truly Yours, 

________________________________ 

Haidan Huang, The Semrad Law Firm 

CONFIRMED: 

________________________________ 

Cheryl Brown 

_________________________ 

Date 

 

{signature:attorney}

{signature:debtor}

12/14/2020

Document Ref: WETZR-ZCEPB-N2UVR-UVZFY Page 4 of 4

Case 20-23632-LMI Doc 19-1 Filed 02/19/21 Page 4 of 5
Signature Certificate

Document Ref.: WETZR-ZCEPB-N2UVR-UVZFY

Document signed by:

Haidan Huang

Verified E-mail:

dhuang@semradlaw.com

IP: 174.228.133.68 Date: 15 Dec 2020 01:42:47 UTC

Cheryl Brown

Verified E-mail:

brownc2002@gmail.com

IP: 98.242.148.108 Date: 15 Dec 2020 03:31:19 UTC

Document completed by all parties on:

15 Dec 2020 03:31:19 UTC

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