Page 1 of 3

LF-69 (rev. 12/01/09)

UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

www.flsb.uscourts.gov

In re: Marco Barrios Case No.: 20-19836-AJCMaria Barrios Chapter 13

 Debtor(s) /

APPLICATION FOR COMPENSATION FOR PROFESSIONAL SERVICES

OR REIMBURSEMENT OF EXPENSES BY ATTORNEY FOR CHAPTER 13 DEBTOR

Applicant, Robert Sanchez, Esq. and the Law Offices of Robert Sanchez, was 

retained by the debtor to serve in this bankruptcy case as attorney for debtor. A copy 

of the retainer agreement is attached as Exhibit “A”. Pursuant to Local Rule 2016-

1(B)(2) and the “Chapter 13 Fee Guidelines”, applicant hereby requests the court to 

approve compensation and reimbursement of expenses as follows:

Total Fees Requested: $ 7,000.00 

Total Expenses to be Reimbursed: $ 100.00 

Amount Received To-Date: $ 1,470.00 

(exclusive of filing fees)

Amount to be Paid through Plan: $ 5,630.00 

1. The amount requested, if allowed, will be paid in full after 14 monthly

payments under the plan.

2. A detailed itemization of the services rendered to date and corresponding 

time entries is attached as Exhibit “B” for the pre-confirmation period from February 17, 

2020 to March 23, 2021.

3. Applicant estimates that an additional n/a hours will be required to 

be expended in providing legal services on behalf of the debtor(s) described below:

 n/a.

4. The following is a short statement of any unusual, troublesome or unique 

Case 20-19836-AJC Doc 75 Filed 02/23/21 Page 1 of 3
Page 2 of 3

LF-69 (rev. 12/01/09)

aspects of this case which resulted in or will result in more than the usual amount of 

time being expended and more than the usual amount of costs being incurred:

 Debtor and counsel had detailed conversations regarding the various trustee’s 

deficiency for confirmation requests. The consultations required more than the usual 

time compared to other similarly situated clients and plan changes were requested. This 

resulted in a few confirmation hearing continuances. 

A Secured Creditor was successfully stripped down from $9,057.18 to $3,000.00 with a 

reduced interest rate from 11.39% to 5.25%. This was done through an agreed order 

after several negotiation discussions. 

The IRS also filed a proof of claim that was objected to. Several creditors filed stale 

claims that were later withdrawn through the undersigned’s efforts. The ones that did 

not comply were objected to and set for hearing. 

The most complicating factor was that the Debtors thought they were current on their 

mortgage and were treating said mortgage outside and directly and initially disputed the 

claim arrearage amount. In the end, the plan was converted a to cure and maintain plan 

to provide for the cure of said arrears in full. This also resulted in having the 

undersigned to vacate the wage deduction order that was previously entered. 

Fees were voluntarily reduced by over $1,000.00 for this pre-confirmation period. 

There are no charges in this Application for Fees for secretarial or typing time and no 

charges have been added for travel time to and from the Courthouse for any of the 

hearings.

5. The source of compensation previously paid to applicant was the initial 

retainer paid by the Debtors.

6. Applicant has not shared or agreed to share any compensation received in 

connection with the bankruptcy case with any person or entity other than a member or 

regular associate of applicant’s firm. (If such a sharing arrangement exists, it should be 

disclosed in this paragraph.)

Case 20-19836-AJC Doc 75 Filed 02/23/21 Page 2 of 3
Page 3 of 3

LF-69 (rev. 12/01/09)

WHEREFORE, Robert Sanchez, Esq. of Robert Sanchez, P.A. respectfully 

requests that this court enter an order awarding the attorney's fees requested in this 

application and for any other relief deemed just and proper in the circumstances.

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). 

DATED: February 23, 2021

Respectfully Submitted: 

ROBERT SANCHEZ, P.A. 

355 W 49th Street

Hialeah, FL 33012

Tel. 305-687-8008

By:__/s/ Robert Sanchez, Esq.____

Robert Sanchez, Esq., FBN#0442161

Attorney for Debtor

cc: Debtor(s), Marco Barrios, Maria Barrios 

466 E 56th Street,

Hialeah, FL 33013-1344

Chapter 13 Trustee Via CM/ECF

Nancy K. Neidich

PO Box 279806

Miramar, FL 33027

Assistant US Trustee Via CM/ECF

51 SW 1st Avenue, #1204

Miami, FL 33130

Case 20-19836-AJC Doc 75 Filed 02/23/21 Page 3 of 3