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MOTION FOR ATTORNEY'S FEES AND COSTS
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                                                             STATE OF FLORIDA
DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION
DIVISION OF FLORIDA LAND SALES, CONDOMINIUMS AND MOBILE HOMES

IN RE: PETITION FOR ARBITRATION

MANUELBLANCO,
          Petitioner,
V.                                                                                                        Case No.00-1960
THE VILLAGE OF KINGS CREEK
CONDOMINIUM ASSOCIATION, INC.,
         Respondent.
__________________________________________________________/

                                 MOTION FOR ATTORNEY'S FEES AND COSTS

Respondent, THE VILLAGE OF KINGS CREEK CONDOMINIUM ASSOCIATION, INC., ("ASSOCIATION"), a Florida not-for-profit corporation, by and through undersigned counsel, and pursuant to Chapter 718, Florida Statutes (2000) and Chapter 61 B-45, Florida Administrative Code, hereby moves for an award of attorney's fees and costs against Petitioner MANUEL BLANCO ("BLANCO") and states:

                     1.         ASSOCIATION was required to file an answer to the instant arbitration proceeding after BLANCO made a demand for a copy of minutes of a Board of Directors meeting.
                     2.         On March 8, 2001 after an evidentiary hearing, the Arbitrator entered a Final Order of Dismissal dismissing BLANCO's Petition and denying him any relief sought.
BLANCO'S Motion for Rehearing was also denied.

                     3. ASSOCIATION put BLANCO on notice in the Answer filed in this Arbitration that it would be requesting an award of attorneys fees and costs in connection with this proceeding.

                     4. Pursuant to the Arbitrator’s Final Order, ASSOCIATION is the prevailing party as to all issues in the Arbitration proceeding.  Helen Mar Condominium Association, Inc. V. Marshall, Fees Case No. 98-5146 (Final Order on Attorney's Fees/Draper/February 5, 1999); (A party is a prevailing party if it succeeds on a significant issue in the arbitration and achieves some of the benefit sought in bringing the action); Southport Condominium Association, Inc.  V. Ricci, Fees Case No. 97-0337F (Final Order on Attorney's Fees/Draper/September 30, 1997) (association is the prevailing party where it obtained order requiring compliance with parking rules).

                    5. Florida Statute 718.1255(4)(f) provides in relevant part:

                        The prevailing party in an arbitration proceeding shall be awarded the costs of the
                        arbitration and reasonable attorney's fees in an amount determined by the
                        arbitrator.

The award of attorney's fees is mandatory since this case was filed after October 1, 1997.  Carriage Houses of Fairfield Association, Inc., v. Oft, Fees Case No. 98-4752 (Final Order on Attorney's Fees/Draper/September 24, 1998).

                    6. ASSOCIATION seeks an award of attorney's fees and costs pursuant to §718.303, Florida Statutes, as well as The Declaration of Condominium which provides that a prevailing party is entitled to its attorney's fees and costs. (See Exhibit "A".)

                     7. The Affidavits of ASSOCIATION’s counsel are attached hereto as Exhibits "B" and "C".  The Affidavits set forth a specific description of the time expended and hourly rates charged.
WHEREFORE, for the aforementioned reasons, ASSOCIATION requests an award of attorney’s fees and costs against BLANCO.

                                               CERTIFICATE OF SERVICE

                  I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished by mail to: Manuel Blanco, 7915 Camino Real, Unit N-302, Miami, Florida 33143 on this 11th. day of April, 2001 and sent via FEDEX to Patricia Draper, Department of Business and Professional Regulation, Arbitration Section, 1940 North Monroe Street, Tallahassee, Florida, 32399-1029.

                                                                Respectfully submitted,
                                                                PHILLIPS, EISINGER, KOSS,
                                                                ROTHSTEIN & ROSENFELDT, P.A.
                                                                4000 Hollywood Boulevard
                                                                Suite 265-South
                                                                Hollywood, Florida 33021
                                                                Telephone: (954) 894-8000
                                                                Facsimile:  (954) 894-8015
 

                                                                 BY:     SIGNATURE      
                                                                 Jeremy A. Koss, Esquire
                                                                 Fla. Bar No. 612900



According to attached:
                                               AFFIDAVIT OF JEREMY A.KOSS, ESQUIRE
                                          IN SUPPORT OF MTION FOR ATTORNEYS' FEES
the BILLABLE GRAND TOTAL will be $ 2363.50