Bank of America v. Falabella

CourtSuperior Court of Maine
DecidedJanuary 25, 2016
DocketCUMre-13-492
StatusUnpublished

This text of Bank of America v. Falabella (Bank of America v. Falabella) is published on Counsel Stack Legal Research, covering Superior Court of Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bank of America v. Falabella, (Me. Super. Ct. 2016).

Opinion

STATE OF MAINE SUPERIOR COURT CUMBERLAND, SS . CIVIL ACTION DOCKET NO . CUMSC-RE-13-492 STATE OF MAINE Cumberland ss Clerks Office BANK OF AMERJCA, N .A. ) JAN '}) 8 2016 Plaintiff, ) RECF ·v--o V. JI t:. ORDER ON DEFENDANTS ' MOTION ) FOR ATTORNEY'S FEES AND DOUGLAS H. FALABELLA and ) MOTION FOR SANCTIONS LORI L. FALABELLA ) ) Defendants. )

Before the court are Defendants Douglas and Lori Falabella's motion for attorney 's fees

and their motion for sanctions. For the following reasons, Defendants' motion for attorney's fees

is granted in part and denied in part, and Defendants ' motion for sanctions is denied.

I. BACKGROUND

Plaintiff filed this action for foreclosure in August 2013. (Comp 1. 1.) Defendants sought

referral to the Foreclosure Diversion Program. (Pl. Objct. to Def. Mot. Att'y Fees 1 1.) The first

mediation session was held in January 2014, but a resolution was not reached. (1/13/14 Med.

Report 1.) At this mediation session, Defendants indicated that they wished to apply for a

modification, and a deadline for Defendants to submit materials required for this application was

set for February 20, 2014 . (Id. at 2.) On March 14, 2014, Plaintiff moved to terminate mediation

because it had not received the materials. (Pl. Mot. Terminate Med. 1.) On April 1, 2014,

Defendants submitted some of the required materials. (Pl. Obj ct. to Def. Mot. Att'y Fees 18.) A

second mediation session occurred on April 4, 2014, Defendants were given an extension of 30

days to provide the remaining materials, which they did on or about April 29, 2014. (4/4/ 14 Med. Report 1; Def. Mot. Refer to Med. 1.) Plaintiff declined Defendants' application for a

modification on May 9, 2014. (Pl. 2d Mot. Terminate Med., 6, Ex. A.)

Neither party filed a request for additional mediation sessions by the June 4, 2014,

deadline, and the clerk restored the case to the civil docket. On July 11, 2014, Defendants

requested a return to mediation, stating that they had not been aware that their application was

denied. (Def. Mot. Refer to Med. 1.) The court returned the matter to the Foreclosure Di version

Program in late August 2014. (8/28/14 Order 1.) Plaintiff then filed a second motion to

terminate mediation on the basis that it had provided Defendants with a letter in May 2014 that

informed them their application for a modification had been denied. (Pl. 2d Mot. Terminate

Med. 1.) The court granted the motion to terminate and returned the case to the civil docket in

late October 2014. (10/28/14 Order 1.)

In March 2015, Plaintiff filed a motion to dismiss its complaint because it did not wish to

prosecute this action until it further reviewed the impact of Bank ofAm., NA. v. Greenleaf, 2014

ME 89, 96 A.3d 700, and CitiMortgage, Inc. v. Chartier, 2015 ME 17, 111 A.3d 39, on this case.

(Pl. Mot. Dismiss,, 2-3 .) The court granted dismissal without prejudice. (5/5/15 Order 1.)

On May 4, 2015, Defendants filed a motion for attorney's fees . (Def. Mot. Atty's Fees

1.) Plaintiff filed an objection to Defendants' motion on May 21, 2015. (Pl. Objct. to Def. Mot.

Atty ' s Fees 1.) Defendants then filed a motion for sanctions on May 29, 2015, arguing that

Plaintiff impermissibly included matters that allegedly occurred in the qiediation sessions in its

objection. (Def. Mot. Sane. 1.) Plaintiff filed an objection to the motion for sanctions on June

22, 2015 . (Pl. Objct. to Def. Mot. Sane. 1.)

2 II. ANALYSIS

A. Motion for Attorney's Fees

Defendants seek $10,855.46 in attorney's fees . (Def. Mot. Atty's Fees 1.) Defendants '

attorney, James Levis, Jr., asserts that he spent a total of 33.30 hours working on this case, at a

rate of $325.00 per hour. (Def. Mot. Atty's Fees 5; Levis Aff. 1 5.) Plaintiff argues that

Defendants' delays unnecessarily increased their attorney ' s fees, that one of Mr. Levis ' s charges

was in error, and that the amounts charged for "trial preparation" in December 2014 are

excessive. (Pl. Objct. to Def. Mot. Atty's Fees 1120-23, 26.)

The statute governing attorney's fees in foreclosure actions provides:

If the mortgagee does not prevail, or upon evidence that the action was not brought in good faith, the court may order the mortgagee to pay the mortgagor's reasonable court costs and attorney's fees incurred in defending against the foreclosure or any proceeding within the foreclosure action and deny in full or in part the award of attorney ' s fees and costs to the mortgagee.

14 M.R.S . § 6101 (2014) . The determination of attorney's fees is within the court's discretion.

Town of Freeport v. Ocean Farms of Maine, Inc., 633 A.2d 396, 399 (Me. 1993).

Plaintiff does not argue that Defendants should recover no fees . (Pl. Objct. to Def. Mot.

Atty' s Fees 1 18.) Plaintiff only argues that fairness requires some of the requested fees be

deducted from the award. (Id.) First, Plaintiff argues that it is unreasonable for Plaintiff to pay

additional fees incurred as a result of Defendants ' delays. (Id. 1 20.) During the pendency of

this foreclosure action, Defendants submitted documents late and mistakenly requested a return

to mediation. (Id. 11 21, 26.) According to Defendants ' motion for attorney ' s fees , Mr. Levis

charged Defendants $130.00 for receiving Plaintiffs motion to terminate on March 17, 2014.

(Def. Mot. Atty's Fees 3.) On April 4, 2014, Mr. Levis charged of $455 .00 Defendants for

attending the April 4 mediation session. (Id. at 4.) On July 10, 2015 , Mr. Levis also charged

3 Defendants $65 .00 for filing of their motion to refer the action back to mediation. (Id. at 5.)

Defendants would not have incurred these charges if not for Defendants' late submissions and

mistaken request to return this action to mediation. Therefore, it is not reasonable to include

these charges in Defendants ' award for attorney's fees .

Second, Plaintiff argues that Mr. Levis ' s $877.50 charge on April 9, 2014, for 2.7 hours

of work titled "initial review of pleadings; prepared draft Answer" was in error and should not be

awarded. (Pl. Objct. to Def. Mot. Arty ' s Fees ~ 22; Def. Mot. Arty's Fees 4.) According to

Defendants ' motion, Mr. Levis had already recorded 1.4 hours of work on December 13 , 2013,

for filing an answer to the complaint. (Def. Mot. Arty's Fees 3.) Mr. Levis did, in fact, file

Defendants ' answer on December 13 , 2013. (Ans. 1.) The December 13, 2013 , entry and the

April 9, 2014, entry are irreconcilable. It is unlikely that Mr. Levis reviewed pleadings and

prepared an answer in April 201 4. The only reasonable inference is that the April 9, 2014, entry

was in error. Therefore, it is reasonable to deduct $877.50 from Defendants' award of attorney's

fees.

Finally, Plaintiff argues that Mr. Levis ' s charges for trial preparation in December 2014

are excessive in light of the fact that a trial date had not yet been set. (Pl. Objct. to Def. Mot.

Arty ' s Fees~ 23.) On December 16, 2014, Mr. Levis recorded 4.5 hours of work, at a charge of

$1 ,462.50, for trial preparation and preparation of the witness and exhibit list. (Def. Mot. Arty 's

Fees 5.) On December 22, 2014, Mr.

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Related

Town of Freeport v. Ocean Farms of Maine, Inc.
633 A.2d 396 (Supreme Judicial Court of Maine, 1993)
Bayview Loan Servicing, LLC v. John H. Bartlett
2014 ME 37 (Supreme Judicial Court of Maine, 2014)
Bank of American, N.A. v. Scott A. Greenleaf
2014 ME 89 (Supreme Judicial Court of Maine, 2014)
Citimortgage, Inc. v. Ronald Chartier
2015 ME 17 (Supreme Judicial Court of Maine, 2015)

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Bank of America v. Falabella, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bank-of-america-v-falabella-mesuperct-2016.