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Matthew E. Ladd, P.A.

, 4649 Ponce De Leon Blvd, Coral Gables, FL 33134


O: 305-665-3978 C: 305-984-4649
MLLawMiami.com

CIVIL ATTORNEY / CLIENT AGREEMENT AND CONTRACT FOR EMPLOYMENT

The following document is an Attorney/Client Agreement and Contract for Employment between Attorney
Matthew E. Ladd, Esq. as an agent of Matthew E. Ladd, P.A., 4649 Ponce De Leon Blvd., Suite 301, Coral
Gables, FL 33146, Telephone No. (305) 665-3978 (hereinafter referred to as the Law Firm), and

Name: Gannon Billie Billie (hereinafter referred to as Client);


Phone: (205) 406-8055
Address:

Email: gannonbillie.official@hotmail.com

in contemplation of and preparation of the following herein described as the limited scope of work:

SCOPE

1. Demand Letter to Ivenette Guzman regarding $80,000 demand for default on promissory note

As compensation for the services of the Law Firm, the firm shall charges $1,000 as an initial
retainer which includes attorney services prior to filing suit and limited to the drafting of the
demand letter. The drafting of any settlement agreements or review of other documents are not
included. The services related to the demand including the oral negotiating a payment
plan. Thereafter, the discounted rate of $500 will apply for each hour over the initial included
hours until the matter is concluded with either a settlement, judgment, or dismissal. The discounted
rate reflects a deviation from the firm’s standard default rate of $565/ hr.

Client and firm have agreed to the discounted $___ per hour for any services beyond the initial included
hours after being advised that the time has expired unless and until the parties reach an alternative flat-fee
agreement.

CLIENT UNDERSTANDS THAT CLIENT IS RESPONSIBLE FOR ANY COSTS. Should the court
allow the recovery of reasonable attorney’s fees against the opposing side, and the court awards such fees,
fees will be calculated at the firms default regular rate of $565 per hour and will not reflect the discount
being offered to the Client.

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The Law Firm will be responsible for the handling of this matter and will assign such attorneys and
paralegals as required from time to time. We expect to perform the legal services necessary to present the
matter at mediation, trial or both. We anticipate the need, should suit be filed, to depose any of the witnesses
and perhaps other fact witnesses. A complete exchange of documents may lead to further discovery, and
we expect considerable conflict in our efforts to secure discovery, particularly if the litigation proceeds to
the bad faith stage when an insurer is involved.

Periodic statements for in-house charges and out-of-pocket expenses (hereinafter "costs") are due upon
receipt. You agree to be ultimately responsible for costs we deem appropriate for the handling of your
matter. Such costs typically include long-distance telephone calls, courier services, photocopies, taxes,
outside Miami-Dade County travel expenses (including all meals and lodging while out of town),
investigations, computer-assisted legal research deposition expenses, court costs (e.g., filing fees,
service of process, subpoena costs, witness fees, etc.), and the fees and expenses of experts, which we deem
appropriate for the proper handling of this matter. These costs will be billed to you approximately monthly
or as incurred. In the event that such bills are not paid within 30 days of the billing date, interest will
accrue at the rate of 1% per month on the unpaid balance.

All monies paid under the agreement are NON-REFUNDABLE unless specific costs were collected. This
means that there will be no refunds for any reason unless an escrow agreement is made in writing. This is
an hourly contract. The initial payment represents equal parts fee and retainer. A flat fee is charged for
services to be rendered for the initial retainer and fee for the initial hours. The initial hours are a minimum
fee due and is non-refundable. Fees are calculated based upon hours spent or to be spent on a case and time
records are not kept unless a specific time is allotted for a flat-fee. The fee you are paying is based upon
the novelty, complexity, and difficulty of the issues involved in your case. The fee you are paying is also
based on the experience, reputation, diligence, skill, expertise, efficiency of effort reflected in providing
legal services, and the ability of this law firm.

The Client agrees if they do not adhere to the payment schedule under this agreement or otherwise default,
the Law Firm has the unconditional right to withdraw as counsel of record in the above-referenced
case. Time is of the essence for all payments required herein. The fact that the Law Firm may allow the
existence of past due outstanding invoices, or accept late payments, shall not be construed as a waiver of
this or any other provision.

This agreement does not include any appellate, collateral, or post-trial proceedings, or post-plea
proceedings including violations of probation. Should such proceedings become necessary a separate
agreement and rate will be required. The services provided for in this agreement are limited to the
proceedings associated with the trial court in which the actions have been filed. Representation in any
appellate court, whether it is for an appeal, a writ of prohibition or mandamus, or any other purpose
whatsoever, is not included in this agreement.

PAYMENT SHALL BE MADE BEFORE FILING OF ANY DOCUMENTS. Should it be determined that
additional time is required beyond that which was initially paid-for, or any additional litigation above that
which has been stated herein, such additional services shall be charged at the firm’s default rate unless
otherwise agreed-to. Client acknowledges the firm’s default rate of $565 per hour. In the event that the
above charge(s) is/are dismissed and subsequently re-filed, or a new or second trial is required for any
reason, including a mistrial, additional fees will be required. The above fee is exclusively for representation
at the trial level of the specific case and charges referred to herein.

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Client further agrees and understands that this fee is a retainer for services only, and does not cover the
various costs of the proceeding, such as depositions, filing fees, service of subpoenas, expert witness fees,
copying or photographing costs, postage, long distance phone calls, private investigator fees, medical
records costs, and other costs which the Law Firm deems necessary to proper preparation of the case. Such
costs must and will be paid by Client as accrued. Some services include incidental costs of delivery and
postage. In the event such a service is rendered, if costs are included such inclusion of costs in the initial
fee will be specified in the scope of services above.

Client agrees that the Law Firm cannot and does not promise any specific result, judgment, or verdict and
that no such representation has been made to Client. Said fee is not contingent upon the outcome or
disposition of the case. No promises or guarantees have been made nor are any promises or guarantees
lawful. No representations have been made to the Client concerning estimates of the time required to
complete this matter. The Law Firm has the right to use the services of other attorneys as it deems
desirable. No representations have been made to the Client concerning the probability of success as to their
case.

In the event of default under this agreement, all monies owed become due and payable immediately to Law
Firm and Client hereby agrees to pay all costs and attorney’s fees accrued by the Law Firm in its effort to
collect the unpaid balance. Interest is to be paid at the highest rate allowable by Florida law on the unpaid
balance due the first day following the last payment received, or, if no payment, from the date of this
agreement. This contract is enforceable only in Miami-Dade County, FL in a competent court of that
jurisdiction. Client and Law Firm stipulate that Miami-Dade County is to be the venue of any legal
action. Should any challenge related to the effective assistance of counsel including malpractice,
misconduct, or otherwise, all costs, attorney’s fees, and charges associated with defendant such allegations
shall be owed by client should such allegations be deemed unfounded.

Client further agrees that in the event of default, the Law Firm shall be immediately entitled to withdraw
from the matter with said withdrawal not preventing the Law Firm from collecting the entire agreed fee. As
part of this agreement, the Client has agreed to pay fees on a timely basis, as specified in this written
retainer. In the event this engagement was the result of another attorney’s referral, the firm is authorize and
the client expressly consents to a referral fee and/or co-counsel participation fee paid to the referring
attorney. This agreement constitutes the complete understanding between the parties. Should any portion
of this agreement become invalidated, the remainder of the agreement shall be unaffected.

GENERAL CIVIL MATTERS

We agree to make no compromise or settlement in this matter without your approval as to the specific
settlement or compromise. We agree to notify you whenever an offer of settlement or compromise is
received by us and to inform you of the amount of that offer and our recommendation as to the
acceptability thereof. Likewise, you agree to make no compromise or settlement in this matter without our
advice and knowledge. You agree to notify us whenever an offer of settlement or compromise is received
by you and to inform us of the amount or terms of any such offer. You acknowledge and recognize that
the lawsuit we are here contemplating. While based on what we take to be strong evidence, is not risk-free,
since our adversary process inherently contains a risk of loss.

While many of the risks in this litigation are being assumed by the firm pursuant to
this Agreement, you should be aware that the possibility of exposure exists in the context of
potential cost and attorneys' fee judgments against you, both under the normal procedures for taxing costs
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and the provisions of the Offer of Judgment statute, F.S. §768.79, which can expose you to payment of
the opposition's fees if your recovery does not achieve 75% of a tendered offer. These liabilities can attach,
of course, only if you lose the case, either outright or by failing to exceed the 75%.

You agree to give us a lien on the claims or causes of action on any sum recovered by way of settlement,
and on any judgment that may be recovered thereon to the extent of the sums herein provided as our fees
and other fees, charges and expenses incurred. If is further agreed that we shall have all general, possessory
or retaining liens and all special or charging liens available under law. Such a lien should not be necessary
in this case unless a conflict of interest arises that requires us to withdraw. Should such an unforeseen event
occur, we would naturally consult with you extensively on the choice of substitute counsel, but we would
ultimately be governed by the Florida Rules of Professional Conduct.

We agree to assert a diligent effort to assure that you are informed at all times as to the status of the matter
and as to the courses of action which are being followed or are being recommended by us. Copies of all
materials sent or received by us pertaining to the matter will be provided to you at your request and at your
expense.

TERMINATION

The relationship established by this letter is subject to termination only as follows:

1. We reserve the right to withdraw from this matter for any just reason as permitted or required under
the Florida Rules of Professional Conduct or as permitted by the Rules of Courts of the State of
Florida. Notification of withdrawal shall be made in writing to you. In the event of such withdrawal, you
agree to promptly pay us for all costs incurred pursuant to this letter prior to the date of such withdrawal.

2. You reserve the right to terminate our representation for cause if we fail to honor this
agreement. Notification of the termination shall be made in writing to us. In the event of any such
termination by you, we waive any further rights to compensation relative to the representation except
to the extent of the fees we have invested in the matter at our normal hourly rates as of the date of
termination, less any damages suffered by you as a result of the cause for discharge.

3. You further reserve the right to terminate the representation without cause and to notify us in writing of
any such termination. In the event of any such termination, the firm shall be entitled to the fees and costs
invested in the case as of the date of termination.

In the event of a discharge, the firm shall be entitled to a fee only if you recover damages in the matter
which is the subject of this Agreement. If the discharge is for reason 3, the basis of fee calculation shall be
the contingent fee percentages set forth above. If the discharge is for reason 1, the firm may be entitled to
payment of attorneys’ fees in the event of an eventual successful recovery, though any entitlement to such
fees would depend upon the reason for our withdrawal.

PRIVACY NOTICE

You have requested legal services from us which may require us to obtain certain non-public personal
information about you and/or your employees. As attorneys, we are bound by strict rules of client
confidence, which serve to protect the privacy of all your information. We scrupulously adhere to those

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professional requirements and will continue to do so. However, under recently enacted federal law, we are
also required to give you specific information about the manner
in which we collect such information, the manner in which we provide this
information to others (if we do), and the manner in which we protect the security of that
information.

In the course of our professional relationship, we may receive non-public, personal information from you,
from other professionals rendering services to you and from people, including witnesses, with whom
we have contact about you during this representation.

All such information is kept strictly confidential. We do not make this information available to any other
person or entity except as necessary to provide the specific legal service you have requested or otherwise
required by law, such as during the discovery process in this matter. We maintain this information in our
records, which are archived after the matter, is closed.

As we have always done, we will continue to maintain physical, electronic and procedural safeguards to
ensure that your records, whether in an active file or in an archived file, will remain confidential and private
to the extent that our documents are secured through our use of Microsoft 365 and Windows Defender. No
other services are retained regarding security of the electronic services. You are welcome to provide all
confidential information through U.S. Mail.

If you have any concern that your information is not being properly safeguarded or has been released
without your approval, please notify me in writing, at this address. We will respond to your complaint or
inquiry within 10 days. If this matter involves a contingency arrangement wherein the attorney has agreed
to accept payment as a percentage of any recovery or upon client being entitled to recover attorneys fees as
a prevailing party or otherwise entitled, client consents to such a continency agreement. In the event of a
personal injury matter, a Statement of Client Rights will be provided.

ENTIRE AGREEMENT

This letter contains the entire agreement between you and Law Office of Matthew E. Ladd, P.A. regarding
this matter and the fees and costs to be paid relative thereto. This letter shall not be modified except by
written agreement signed by you and our firm. This Agreement shall be binding upon you and us and the
respective heirs, executors, legal representatives and successors of each.

THIS IS A BINDING CONTRACT BETWEEN YOU AND THE LAW OFFICE OF MATTHEW E.
LADD, P.A., PLEASE READ IT CAREFULLY BEFORE SIGNING. IF THERE IS ANYTHING YOU
DO NOT UNDERSTAND, PLEASE ASK. WE ENCOURAGE YOU TO HAVE THIS
AGREEMENT REVIEWED BY ANO'IHER ATTORNEY OF YOUR CHOICE.

Client declares and agrees with the aforementioned Law Firm that Client is not securing legal representation
for the purpose of furthering any present, future, or continuing fraudulent, criminal, or illegal activity. The
Law Firm declares and agrees with the client that, as a condition for the continuing representation of him,
the Client was advised to cease any unlawful activities in violation of state or federal, civil, or criminal law.

Client has indicated that the funds with which he/she is making payment for legal services, as set forth
below, have not been derived from any unlawful activity. The Law Firm and Client expressly agree that
this instrument and its contents are confidential and that it is being entered into with the expectation that it
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is protected by the Sixth and Fourteenth Amendments to the United States Constitution as well as the
attorney/client privilege. The Law Firm declares and agrees to keep the Client’s identity and the nature of
the amount of fees paid by him/her confidential, in order to place him/her in the most favorable position in
the event that criminal or quasi-criminal charges are brought against him/her or against his/her property.

STATEMENT OF CLIENT'S RIGHTS

Before you, the prospective client, arrange a contingency fee agreement with a lawyer, you should
understand this statement of your rights as a client. This agreement is not a part of the actual contract
between you and your lawyer, but as a prospective client, you should be aware of these rights:

1. There is no legal requirement that a lawyer charge a client a set fee or a percentage of
money recovered in a case. You, the client, have the right to talk with your lawyer about the proposed fee
and to bargain about the rate or percentage as in any other contract. If you do not reach an agreement with
one lawyer you may talk with other lawyers.

2. Any contingency fee contract must be in writing and you have three business days to
reconsider the contract. You may cancel the contract without any reason if you notify your lawyer in writing
within those three business days of signing the contract. If you withdrew from the contract within the first
three business days, you do not owe the lawyer a fee although you may be responsible for the lawyer's
actual costs during that time. If your lawyer begins to represent you, your lawyer may not withdraw from
your case without giving you notice, delivery of necessary papers to you and allowing you time to employ
another lawyer. Often your lawyer must obtain court approval before withdrawing from a case. If you
discharge your attorney you will be responsible for a fee for work the lawyer has done.

3. Before hiring a lawyer, you, the client, have the right to know about the lawyer's education,
training and experience. If you ask, the lawyer should tell you specifically about his or her actual experience
dealing with cases similar to yours. If you ask, the lawyer should provide information about special training
or knowledge and give you this information in writing if you request it.

4. Before signing a contingency fee contract with you, a lawyer must advise you whether he
or she intends to handle your case alone or whether other lawyers will be helping with the case. If your
lawyer intends to refer your case to other lawyers, he or she should tell you what kind of fee-sharing
arrangement will be made with other lawyers. If lawyers from different law firms will represent you, at
least one lawyer from each firm must sign the contingency fee contract.

5. If your lawyer intends to refer your case to another lawyer or counsel with other lawyers,
your lawyer should tell you about that at the beginning. If your lawyer takes the case and later decides to
refer it to another lawyer or to associate with other lawyers, you should sign a new contract to which
includes the new lawyers. You, the client, also have the right to consult with each lawyer working on your
case and each lawyer is legally responsible to represent your interests and is legally responsible for the acts
of the other lawyers involved in the case.

6. You, the client, have the right to know in advance, how you will need to pay the expenses
and legal fees at the end of the case. If you pay a deposit in advance for costs, you may ask reasonable
questions about how the money will be or has been spent and how much of it remains unspent. Your lawyer
should give a reasonable estimate about future necessary costs. If your lawyer agrees to lend or advance

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you money to prepare or research the case, you have the right to know periodically how much money is
spent to prepare the case. If you pay the expenses, you have the right to decide how much to spend. Your
lawyer should also inform you whether the fee will be based on the gross amount recovered or on the
amount recovered minus the costs.

7. You, the client, have the right to be told by your lawyer about possible adverse
consequences if you lose the case. Those adverse consequences might include money which you might
have to pay to your lawyer for costs and liability you might have for attorney's fees to the other side.

8. You, the client, have the right to receive and approve a closing statement at the end of the
case before you pay any money. The statement must list all of the financial details of the entire case,
including the amount recovered, all expenses, and a precise statement of your lawyer's fee. Until you
approve the closing statement, you need not pay any money to anyone, including your lawyer. You should
have the right to have every lawyer or law firm working on your case, sign the closing statement.

9. You, the client, have the right to ask your lawyer at reasonable intervals how the case is
progressing and to have these questions answered to the best of your lawyer's ability.

10. You, the client, have the right to make the final decision regarding the settlement of a case.
Your lawyer must notify you of all offers of settlement before and after trial. Offers during the trial must
be immediately communicated and you should consult with your lawyer regarding whether to accept a
settlement. However, you must make the final decision to accept or reject a settlement offer.

11. If, at any time, you the client, believe that your lawyer has charged an excessive or illegal
fee, you have the right to report the matter to the Florida Bar, the agency that oversees the practice and
behavior of all lawyers in Florida. For information on how to reach The Florida Bar, call 1-800-342-8060,
or contact the local bar association. Any disagreement between you and your lawyer about a fee can be
taken to court and you may wish to hire another lawyer to help you resolve this disagreement. Usually fee
disputes must be handled in a separate lawsuit.

We look forward to helping you resolve your matter. Please feel free to call us at 305-665-3978.

Sincerely,

/s/Matthew E. Ladd, Esq

Matthew E. Ladd, Esq. for Matthew E. Ladd, P.A.

APPROVED AND ACCEPTED:


1/12/2024

Client: ______________________________
ID YEhfGh563spnKVS9yn7Tt3P1 Date: _____________________

You can submit your payment by Credit Card, E-Check, and even set up a payment plan. Click this
link to access LawPay and enter the amount specified on the first page:

https://secure.lawpay.com/pages/matthew-e-ladd-pa/misc

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We appreciate your business!
Please call if you have any questions!

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eSignature Details

Signer ID: YEhfGh563spnKVS9yn7Tt3P1


Signed by: Gannon Billie
Sent to email: gannonbillie.official@hotmail.com
IP Address: 205.185.222.232
Signed at: Jan 12 2024, 5:38 pm EST

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