On July 20, 2022 a
AFFIDAVIT RE: ATTORNEY/COUNSEL FEES
was filed
involving a dispute between
Credit Acceptance Corporation,
and
Triniya Graham,
for C40 - Contracts - Collections
in the District Court of New Haven County.
Preview
DOCKET NO. NNH-CV-22-6127248S
CREDIT ACCEPTANCE CORPORATION SUPERIOR COURT
JUDICIAL DISTRICT OF
VS, NEW HAVEN AT NEW HAVEN
TRINIYA GRAHAM DECEMBER 13, 2023
ATTORNEY'S FEE AFFIDAVIT
STATE OF CONNECTICUT )
) SS: BLOOMFIELD
COUNTY OF HARTFORD )
The undersigned, being duly sworn, deposes and says:
1 Iam over the age of eighteen (18).
2 I understand the obligation of an oath.
3 Iam the Attorney for the Plaintiff in the above-referenced matter.
4 Professional services rendered on this file to date are as follows:
DATE SERVICES HOURS
5/11/2022 Receipt and review of file
5/11/2022 Checked Pacer for bankruptcy status
Checked Defense Manpower for military status
Ran credit bureau report; review of same
Searched IDICore for identity/address confirmation
Review of town assessor’s website for property
5/13/2022 Demand letter sent to debtor
6/28/2022 Reviewed and prepared legal file
6/28/2022 Review of file; made adjustments
Drafted complaint
7/6/2022 Prepared writ, summons and finalized complaint
Prepared letter to State Marshal
7/20/2022 Receipt and review of Return of Service from State Marshal
7/20/2022 E-filed Summons, Complaint and Return of Service with Court
Paid Marshal
9/28/2022 Prepared and e-filed Motion for Change of Venue
10/12/2022 Receipt and review of notice from Court
Prepared Affidavit of Debt; sent to client
Receipt and review of signed Affidavit of Debt
11/3/2022 Prepared and e-filed Motion for Default for Failure to Appear
11/16/2022 Receipt and review of Notice from Court
11/22/2022 Prepared and e-filed Amended Summons
1/11/2023 Prepared and e-filed Motion for Default for Failure to Appear
2/23/2023 Receipt and review of notice from Court
3/10/2023 Prepared and e-filed Motion for Reconsideration
3/27/2023 Receipt and review of notice from Court
4/17/2023 Prepared Amended Summons and Complaint; sent to state marshal
for service
4/25/2023 Receipt and review of Return of Service; e-filed with the court
E-filed Amended Complaint
6/21/2023 Prepared and e-filed Motion for Default for Failure to Appear
6/29/2023 Receipt and review of notice from Court
8/31/2023 Prepared and e-filed Certificate of Closed Pleadings, Claim to
Hearing in Damages
10/6/2023 Prepared and e-filed Motion for Judgment, Bill of Costs, Military
Affidavit, Affidavit of Debt and Attorney Fees Affidavit 13
10/30/2023 Receipt and review of Notice from Court
Prepared Affidavit of Debt; sent to client
11/10/2023 Receipt and review of signed Affidavit
12/13/2023 Prepared and e-filed Proposed Order, Bill of Costs, Affidavit of
Debt, Military Affidavit and Attorneys Fee Affidavit 1.0
16.6 Hours @ $225.00/Hour = $3,735.00
5 I anticipate that additional time will be necessary in pursuing post-judgment efforts.
6. Based on the pre-judgment and post-judgment efforts necessaryy to bring this matter to
conclusion, I believe Plaintiff's request for attorney's fees in the amoun $1,265.89i fen
NS ~
pngble.
~
—)
AFFIANT--~
Walter Onacewiez, Esquire
NAJR& LEVIN; PSC
ca
Subscribed and sworn to, before me, on December 13, 2023."
Fetz
Notary Pub! .
My Comi missio Y Expires 1413072025
LA u FR ETZER
vy
ic
MY CI Sg) 1ON
ESI XPIR} YOV. 30, 2025
Document Filed Date
December 13, 2023
Case Filing Date
July 20, 2022
Category
C40 - Contracts - Collections
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DOCKET NO. NNH-CV-22-6127248S CREDIT ACCEPTANCE CORPORATION SUPERIOR COURT JUDICIAL DISTRICT OF VS, NEW HAVEN AT NEW HAVEN TRINIYA GRAHAM DECEMBER 13, 2023 ATTORNEY'S FEE AFFIDAVIT STATE OF CONNECTICUT ) ) SS: BLOOMFIELD COUNTY OF HARTFORD ) The undersigned, being duly sworn, deposes and says: 1 Iam over the age of eighteen (18). 2 I understand the obligation of an oath. 3 Iam the Attorney for the Plaintiff in the above-referenced matter. 4 Professional services rendered on this file to date are as follows: DATE SERVICES HOURS 5/11/2022 Receipt and review of file 5/11/2022 Checked Pacer for bankruptcy status Checked Defense Manpower for military status Ran credit bureau report; review of same Searched IDICore for identity/address confirmation Review of town assessor’s website for property 5/13/2022 Demand letter sent to debtor 6/28/2022 Reviewed and prepared legal file 6/28/2022 Review of file; made adjustments Drafted complaint 7/6/2022 Prepared writ, summons and finalized complaint Prepared letter to State Marshal 7/20/2022 Receipt and review of Return of Service from State Marshal 7/20/2022 E-filed Summons, Complaint and Return of Service with Court Paid Marshal 9/28/2022 Prepared and e-filed Motion for Change of Venue 10/12/2022 Receipt and review of notice from Court Prepared Affidavit of Debt; sent to client Receipt and review of signed Affidavit of Debt 11/3/2022 Prepared and e-filed Motion for Default for Failure to Appear 11/16/2022 Receipt and review of Notice from Court 11/22/2022 Prepared and e-filed Amended Summons 1/11/2023 Prepared and e-filed Motion for Default for Failure to Appear 2/23/2023 Receipt and review of notice from Court 3/10/2023 Prepared and e-filed Motion for Reconsideration 3/27/2023 Receipt and review of notice from Court 4/17/2023 Prepared Amended Summons and Complaint; sent to state marshal for service 4/25/2023 Receipt and review of Return of Service; e-filed with the court E-filed Amended Complaint 6/21/2023 Prepared and e-filed Motion for Default for Failure to Appear 6/29/2023 Receipt and review of notice from Court 8/31/2023 Prepared and e-filed Certificate of Closed Pleadings, Claim to Hearing in Damages 10/6/2023 Prepared and e-filed Motion for Judgment, Bill of Costs, Military Affidavit, Affidavit of Debt and Attorney Fees Affidavit 13 10/30/2023 Receipt and review of Notice from Court Prepared Affidavit of Debt; sent to client 11/10/2023 Receipt and review of signed Affidavit 12/13/2023 Prepared and e-filed Proposed Order, Bill of Costs, Affidavit of Debt, Military Affidavit and Attorneys Fee Affidavit 1.0 16.6 Hours @ $225.00/Hour = $3,735.00 5 I anticipate that additional time will be necessary in pursuing post-judgment efforts. 6. Based on the pre-judgment and post-judgment efforts necessaryy to bring this matter to conclusion, I believe Plaintiff's request for attorney's fees in the amoun $1,265.89i fen NS ~ pngble. ~ —) AFFIANT--~ Walter Onacewiez, Esquire NAJR& LEVIN; PSC ca Subscribed and sworn to, before me, on December 13, 2023." Fetz Notary Pub! . My Comi missio Y Expires 1413072025 LA u FR ETZER vy ic MY CI Sg) 1ON ESI XPIR} YOV. 30, 2025