THE SEMRAD LAW FIRM 

Attorneys & Counselors at Law 

2332 Galiano, 2nd Floor 

Coral Gables, FL 33134 

(786) 706-8014

RECITALS 

WHEREAS, The Semrad Law Firm LLC (the “Firm”) previously agreed to represent Cheryl Brown, 

the “Client” or “Clients”) conditioned on the Client(s) entering into this agreement after the 

filing of a Chapter 7 Bankruptcy case to pay the Firm for services rendered after the filing of the 

case. 

WHEREAS, the Client(s) has filed a Chapter 7 Bankruptcy, Case #20-23632 (THE “Case”). 

WHEREAS, the Firm will forebear from requesting to withdraw from representing Client(s) so 

long as Client(s) signs this agreement within ten (10) days of the filing of the Case. 

WHEREAS, the Client(s) has been advised that in the event Client(s) refuses to sign this 

agreement, Client(s) will owe no money to the Firm for any services rendered in this Case and 

the Firm must continue to represent Client(s) in all aspects of this case until permitted by the 

Bankruptcy Court to withdraw from representation. 

WHEREAS, The Client(s) has been advised that in the event Client(s) refuses to sign this 

agreement, Client(s) may hire another attorney apart from the Firm to represent Client(s) in the 

Case. 

WHEREAS, The Client(s) has been advised that Client(s) may consult another attorney apart 

from the Firm as to whether Client(s) should enter into this agreement. 

NOW, THEREFORE, in consideration of the promises and forbearances made herein, the 

sufficiency of which is hereby expressly acknowledged, the Parties agree to the following: 

1. Scope of Representation. The Firm will be representing the Client(s) in all aspects of the

Case except for any adversary proceedings that may be filed against the Client(s). The

scope of this representation does not include any other civil or criminal proceedings.

2. Fees.

a. The Firm agrees to provide the following Services:

i. Advise Client(s) of the requirement to attend the meeting of creditors

and notify Client(s) of the date, time, and place of the meeting;

ii. Advise Client(s) of the requirement to attend a debtor education course

and provide a certificate of completion to the Firm;

iii. Send notice of the Case filing to creditors;

Document Ref: KK4RV-SPBNY-4QJJM-J8VQG Page 1 of 3

 Exhibit B

Case 20-23632-LMI Doc 19-2 Filed 02/19/21 Page 1 of 4
iv. Correspond with creditors regarding any matters necessary for the

administration of the 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 knowledgeable legal representation at the meeting of creditors

as well as any continued or rescheduled meetings in time for check-in

and the actual 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 Client(s), in advance, the role and identity

of the other attorneys and provide that attorney with the Case file in

sufficient time to review it and properly represent Client(s) at the

meeting;

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

the Trustee may pursue that may be adverse to Client(s) 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 Client(s);

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

Reaffirmation agreements, notice of audits by the US Trustee,

correspondence from Client(s) or any interested parties;

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

personally explain the terms of said agreements to Client(s);

xiii. Be available to respond to Client(s)’ 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; and

xx. Provide post discharge services such as a review of Client(s)’ credit report

and advising Client(s) regarding possible discharge violations that may

have occurred.

b. The fee for services provide after the case is filed is $1,700.

3. Retainers and Payments to the Firm.

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Case 20-23632-LMI Doc 19-2 Filed 02/19/21 Page 2 of 4
 

a. The fee being charged is a flat fee for services rendered during the 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 an option to deposit funds with an attorney that shall 

remain property of the Client(s) 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 Client(s) is the firm’s commitment to perform any and all 

work necessary to represent Client(s) in this Case. 

4. Right to Hire New Counsel. Client(s) has the right at any time to terminate the Firm’s 

representation and hire new counsel. Should Client(s) refuse to sign an agreement after 

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

the Case, and the Firm moves to withdraw from representation, Client(s) is strongly 

encouraged to hire new counsel. 

5. 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 

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. 

Date: ___________________ 

Signed: _____________________________ 

 Cheryl Brown 

_____________________________________ 

Haidan Huang, The Semrad Law Firm LLC 

12/15/2020

{signature:debtor}

{signature:attorney}

Document Ref: KK4RV-SPBNY-4QJJM-J8VQG Page 3 of 3

Case 20-23632-LMI Doc 19-2 Filed 02/19/21 Page 3 of 4
Signature Certificate

Document Ref.: KK4RV-SPBNY-4QJJM-J8VQG

Document signed by:

Haidan Huang

Verified E-mail:

dhuang@semradlaw.com

IP: 4.7.43.134 Date: 15 Dec 2020 19:56:04 UTC

Cheryl Brown

Verified E-mail:

brownc2002@gmail.com

IP: 98.242.148.108 Date: 17 Dec 2020 01:34:47 UTC

Document completed by all parties on:

17 Dec 2020 01:34:47 UTC

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