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File: 06-BC-DT-2074
-- --- ~2 Plf~: r3
IN THE CIRCUIT COURTFORBALTIMORECITY,MARYLAND ' ! 1"',,, ­
C V1
CIVIL DIVISION TAX F'O·I~-(}C~I~'.9N
.IL. ,-u:::>URE

Kona Properties, LLC

Plaintiff
Civil Action No, 24-C-06-011912
VS. FR

TAXSALE--­

Defendants
.:-:-cc---';:=c: _
'"..:..~--

PLAINTIFF'S AMENDED AFFIDAVIT FOR ATTORNEY'S FEES AND

EXPENSES FOR THE PROPERTY KNOWN AS 1515 Mckean Avenue

Re: Property Owner: Turner, Charles L

Baltimore City County Tax Accl No,: 15-08-0020-052
Address: 1515 Mckean Avenue
Case Number; 24-C-06-011912
Plaintiff: Kona Properties, LLC
---------::-::-­ --~-------T-'~~AmOUl-lt-i
I. Taxes, Liens and Interest ___ ~ ___ ~ _______
Tax Sale Lien Amount
_____________________;:_;::_ ' _ _ _7_10_,_57-1
Interest on Tax Sale Lien Amount calculated through September 30, 2008
with a PE!_ diem()fO.~~ thereafter. ______ 305.91
~-----~---1'--~-'::;-~- --­
Subsequent Taxes and Interest Figure
provided by
City to
'--------- --~----- Defendant
Estimated Total amount due to Baltimore City, plus any subsequent
taxes that may have accrued on the property - Any redeeming party
must verify the current amount due for taxes and other municipal bills
with the Baltimore City Tax Office, as the City is the only authority that 1,016.48
may levy real property taxes, and the City is the ouly authority that can
advise as to the exact amount d~e and p,.::a:Lya=b:.::le::.:._ _~~_____~'---~_ __
 ----- -~ ---
II. Attorney's Fees -~-

Presumptively valid flat fee for all billable I

legal activities through filing of Complaint 1,300.00

Court approved amount for prosecuting case

to the point of being "ready" to file Affidavit 200.00 i

of Comnliance
Total due for attorney's fees $1,500.00
------------------------,-~-~,-=,----------- ;"--;;- -- -,~---- "-
A.' Stiite the nurnber of years that you have Anthony J. De Laurentis: 38 yeaKli
practiced law: _ _ ; John K. Reiff: 12 years -
:i2t,cr~-',,,," ~~"~=~'~';!¥~"_;;=;';~~~~~~~""-"'~i~!-~~~·Reiq:~:y'e~s. --~;; --=~ --- : --~~; ,. '_'-';,
~~===""..,:~B!;l-,-~"Jl~-~'C~~~9xill~y~~l¥lti.em:-e in me arelwL....l.:rhe.attomeys.hay~secuted~thousands_ --_.. --- - - ­
-~""""'"
-~ -- -,..... tax foreclOsures: ,- ~-~ ',-,- ____c o ' of tax siileforedosUre actionsiirroughout I

~the state of Maryland since 1985. i

I C. Has an affidaVit of comphance been filed? I m Yyes I

rD Vlt 0 fC omprlance has not been -

If anaffida' es;
filed, then has everything been done so that
!
~

I
the case is ready for an iUfidavit of -
comnliance to be filed? I
E. How many Defendants have been served? 21
F. Describe any service problems:
f-------­
No service problems.
G. Descril:ie the date and length of any Two hearings on 7/14/08 and 9/2/08 in
hearings and describe the purposes. regards to the Motions filed by Ms. Vicki
Valentine and the Motions to Set
Redemption Amounts.
H. Describe any reason why the fixed fee No reason.
should be increased (or decreased) and
attach aDpropriate documentation. I

9/212008
 ., ...'. 'I The Plaintiffhas already paid attorney's
;~ Jiles 0[$1,500 and will pay an additional
_ .. ...... $2,000 in attorney's fees if a judgment
foreclosing the right of redemption is
obtained. . . .
~~-:...._ _.~ _redemption..c::~-::~
:=---' -- ----., - ..-.
The original Plaiutiff, a national investor
0:C;;",;."",,,:,:~~:::,== ,~.,i;jjj'"~~-';~K•.2~."-'-f"":'~~cc-'-;;,:::=;~,Cfu,,,.-::..
. ..
decision to divest itself ofits Maryland
J. State whether the attorney or the attorney's
spouse, parents, children or siblings have any
ownership interest in the plaiutiff or will
benefit financially, directly or indirectly, in
any way other than through the payment of
attorney's fees.
~~- -----I,from-tbe-Iaw-finn,-~---L--
Plaintiff s current retaiuer agreement with
the law fmu is that ari-ittiomey's feeof ... ._==
$1,500 will be paid, unless the Plaintiff is ., ..
awarded a judgment, in which case
Plaintiff will pay an additional $2,000 ... ­
attorney's fee for a total 0[$3,500 per
judgment. The retainer agreement also
provides that Plaintiff will pay all out-of­
pocket expenses, which are due and
payable upon redemption or issuance of a
judgment foreclosing the right of
...,-.,,_. ~-.==::.=_: .
=fn'tiiX··liens;:h-airecently made11t)Usfness~ ;=;L'-;;::;:"~
.
nOlumgs; arid'isinl1ie~process'ol·- ~ ­
liquidating its Baltimore City portfolio.
This decision precipitated the assigmnent
of the underlying lien in this matter.
The original Plaintiff has not purchased
any tax liens in the State of Maryland
since 2007.
The substitute Plaintiff includes two
members. John Re.iff, who is a member of
the law finn, has a fifty percent (50%)
ownership interest in the substitute
Plaintiff. The remaining fifty percent
(50%) ownership inlerest in Ihe Plaintiff is
vested in De Laurentis & Associates,
LLC, a Maryland Limited Liability
Company that is wholly owned by two
separate tmsts, the beneficiaries of which
are the adult children of Anthony J. De
Laurentis. The SUbstitute Plaintiffis I
active and in good standing and is in the
business of purchasing, renovating,
renting and selling real property primarily
in Baltimore City. The substitute Plaintiff
IS completely separate and mdependent
 • K. State any other facts that need to be taken No other fuets.
._... into accoiiiiC:-'- .. . - ­
III. Expenses 1,046.74
A. List all expenses and attach r~=ipts _

. -·:--_--.::w~h.ere indicated:

1. Title Search and Title Update (by Service 325.00

Investigations, LLC) (Receipts attached)
2. Order ofPublication (by the Daily Record) 250.00
(Receint attached)
3. Filing Fee 125.00
: 4. Posting Fee (by Service Investigations, 40.00
. .-~-.--~-- i LLC)·c-C---CC:=::C=='.·C:=·-~-···---·'· - ----.---
-
-~~'--~,
----­
- .. ~~--- ---~--.

. . . . '(ReceipTroiPrivateP~Ostmga'tiachedi- . .

Description of defendants served, and the

method of service: .

Defendant Baltimore City was substitute

served by serving Iris Darby at the

Defendant '.I' address ofrecord. on 3/15/07.

Defendant Charles McKean was substitute

served by serving Edward Valentine, the

Defendant '.I' son- in- law, at the property

address that is the subject ofthis case on

3/15/07.

7. Judgment reports (by Property Insight, 12.00

LLC)
(Receipt attached showing that 1 judgment
: reports was obtained.) _ _ _ _ _ _ _ _-l-_ _ _ _ _ _ _ _ _ _ _ _ _---J
I 8. Postage 85.34 !

. (1 mailing at $9.05. 12 mailings at $6.28 each

for a total of$75.36. 1 mailing at $0.92.)
1---.--,------- . - - - - - - - + - - - - - - - - - - - - - - , , - : - : - , : - 1
9. Copies 79.00
(State the number of copies, 790 @ at $0.10
I per page) (Receipt attached)
: 10. Court Courier Costs (by Service 5.00
--r:~~~;ta::~h~~2Iivery incl--ud.:.e:.:d·~fi~ft~ee-n--·f---··--···
lliI;ngs in other cases). _ _ _ _ _ _ _ _ _ _--'

91212008
 11. Substantial Repair Order Fee (paid to 0.00
B<!1tiriioreCiljHousirig) ~.. -- I
Recei t attached}~_,-,-~ ~---C:':':----+--::cc:---=:---'-"-c;;-"--"::';:"--;::-=.---";::-::-::l
12. Other (Specify) ~. _._ Vacant Property Inspection (by 0.0
Plaintiff has included the cost of its Vacant _ Service Investigations, LLC)
Property Inspection that specifically led to the ~ (Recei t attached '

issuance of Baltimore City Housing's - Accurint™ name searches and --- 0.01

Certificate of Substantial Repair. The Vacant summary reports (Receipt

PropertY Inspection was conducted by and attached) i
i
billed for by Service Investigations, LLC. Bankruptcy searches 0.40
(at $0.08 per search)
.___.___ ~ ____ ~_ !'!<Jintiffhas~lso included the costs of itsc-' -' . ~--~.--~--.-----~--- ----' .---~
-
-~-.-~.~~~

".----.~ Acturint™ name searches-and sumiliary -.~~- .­

_\- _rep~~s in the ~t!ached itemized state;nent of .
addItIOnal fees and expenses. Accunnt™ c.
IDfu~"-"'W'i"C:;;""",,3 ~c,~~ges

~l?)~I<li'eacIi·~ame·~.~~$i.50f()r - J:IT'~L;'.;o;'·nr£_=::~r.i:~=.~iiiii'2~12h""=:~:'§I{",g2~
hi

each summary report, and $8.50 per i

cbrilpreherisrVeleport -lli:thi'S'Case, Pia-"'miii~tJ1II~;;::-'"i-'"",===!!!!-~==""",~-;:::-~"'C"''';'''='='"'I~=~''''''l'l'l

paid fOf_ name searche(s), _- summary
report(s), and __ comprehensive report(s).
, Plaintiff has attached copies of the reports as
- receipts. ­
f-:c:c:..:;:£.:.::"---,--.,-.,--.---,----,----+-=----:----:c:---::--:-----~-: . _ - - j
B. For each of the expenses where work was The vendor used by the law finn for many
performed by a third party, state whether the
attorney of thc attorney's spouse, parents,
children or siblings have any ownership
interest in the third party or will benefit
financially, directly or indirectly, in any way
from the payment.
of the expenses listed below is Service - ­
Investigations, LLC, an entity fonned for
the specific purpose ofperforming the
unique due diligence requirements
demanded by tax sale practitioners. The
three principal attorneys from De
Laurentis, Reiff & ruer, LLC own
Service Investigations, LLC. However,
the service company employs an
independent manager, and all process
servers and investigators are independent
contractors. The expenses charged for all
service ofprocess related activities are
based on current market rates.

None ofthe attorneys, nor any attorney's

spouse, parents, children or siblings have
any ownership interest in Property Insight, ,
LLC, Accurint™, Baltimore City :
Housing, nor the Daily Record, nor will I
---.----.--~ ­ --.--------~.----.-- -.---._-----.l\-b
Li~~~t::;~~~l~;:=:.1ndireetly,]----
 -
-----------

. ...

C. State the amount that the plaintiff paid in Plaintiff will pay the entirety ofthe law
"expenses~$O,-and the' additional amounuhlit finn'soliCofpOcket expenses incurred in .
is payable by the plaintiff if the property is . this matter, regardless of the Court's
not redeemed ($1,046.74). If the redemption Order establishing a redemption amount.
amount set by the Courfisless thatieqtiested,
will the plaintiff pay the balance of the
amount requested? Yes.. If the plaintiff will
pay less than the requested amount, please
explain.

IV• Were figures requested before a Yes

,·.ecce·· .petition to redeem,was filed? ..... -- , ,. -------"
- -- -- - - - - - - -
---" .. - ."- .._­ ...... _."_."­
A. If yes; then Wha!waSthe date ofthe . ".-'- April 18, 2007

,. , - -.----- ----------- --­

request?

-_., -- .. _-,- . -. -. . B. What was the date of the response?

. . . April 18, 2007
--~.

----=..:....---.:-'-'---.--. --.~-~:::::: --.". .c;',

C waS the'same'iliforniaifon,iric1uuinga ,:N:o;!.he Court'sopinioii had not yet been
_""''''''''' -.­..!?9PX of reeeil!ts and the amoun...tP.aid or issued. ~~ ... ~
- - .- ...
payiiblebyihe plailitiff; t!:iiit is being providea­ ,. ,. . ...'.

with this affidavit, excluding any updates,

provided to the redeeming party prior to the
filing ofthe petition to redeem? Yes or no. If
not, in what ways is the information provided
to the Court different from the information
that wasp.rovided to the redeeming party?
,

The total redemption amount requested is $2,546.74 for attorney's fees and
expenses, in addition to the estimated taxes of $1,016.48 due to be paid directly to
Baltimore City, through September 30, 2008 plus a per diem of $0.35, plus any
subsequent taxes and Interest due from the date of the tax sale through the date of
redemption, to be paid directly to Baltimore City.'

I solemnly swear or affirm under the penalties of perjury and upon personal
knowledge that the contents of the foregoing paper are true.

An on J. De Laurenti

J0 . Reiff, Esq.

John E. Reid, Esq.

De Laurentis, Reiff & Turer, LL.C.

9891 Broken Land Parkway

~JlUillma,Maryland 21046
(443) 539-2003
 CERTIFICATE OF SERVICE

.. ·.---.~Plaintiffhereby certifies that on September 2, 2008, a copy ofthe foregoing .

. Affidavit for-Attomey's Fees and Expenses, was sent by first-class mail, to:~

Vicki Tumer- Valentine

1515 McKean Avenue

Baltimore, MD 21217

Charles L. Turner '

:-15 15McKeail Avenue- .

md .

Baltimore City, Maryland

Servc: George Nilson, City Solicitor
100 North Holliday Street, Room 101
Baltimore, MD 21202