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<br />04/25/2005 MaN 15: 45 FAX 954385~A.~ KRONENGOLD - DANZ <br />IJ <br /> <br />I4J 003/029 <br /> <br /><\ <br />'0 <br /> <br />CASE NO. 04-12891-CA-31 <br /> <br />Court's Order of Taking as to Parcel No.1, dated March 24. 2005. In support of its motion, <br /> <br />Vanguard states as follows: <br /> <br />1. An Order of Taking as to Parcel No.1 was entered March 24, 2005. <br /> <br />2. Pursuant to section 73.091, Florida Statutes (2001), Petitioner is responsible for <br /> <br />expert witness fees and costs of those consultants retained by Vanguard. as well as court costs <br /> <br />incurred in these proceedings. <br /> <br />3, In order to defend these proceedings and protect the interests of Respondents herein, <br /> <br />Vanguard has incurred costs as follows: <br /> <br />a. Appraisal fee in the amount of$23,637.50; and, <br /> <br />b. Court costs in the amount of $4,072.24. <br /> <br />4. In addition to the foregoing costs, Vanguard is entitled to an award of reasonable <br /> <br />attorneys' fees incurred in connection with these proceedings, pursuant to section 73.092(2). Florida <br /> <br />Statutes, as set forth in Exhibit A. <br /> <br />5. Vanguard anticipates that additional attorneys' fees and costs will be incurred in light <br /> <br />of the appeal filed by Respondent RK Associates No.1, Inc., Case No. 3D05-811 pending in the <br /> <br />Third District Court of Appeal. <br /> <br />6. Accordingly, Vanguard requests this Court to determine, .fix, assess and award in <br /> <br />favor of Vallguard, and against Petitioner, Vanguard's costs, fees and expenses incurred in <br /> <br />connection with these proceedings. <br /> <br />2 <br />