AFFIDAVIT OF MOISES SEVERINO
- My name is Moises Severino and I am the age of 18 years and
otherwise competent to testify. I have personal knowledge of the facts herein. I am one of several paralegals/law clerks employed by The Burns Law Firm, LLC.
- I have seen and read a number of Objections by Trustee Branigan to fee
applications submitted by The Burns Law Firm, LLC. An allegation is that the paralegals/law clerks perform clerical duties at $295.00 per hour. I believe this is misplaced by Mr. Branigan as to what work the paralegals/ law clerks perform.
- I came to work for The Burns Law Firm, LLC in June, 2019 as part of a
County program where gifted and selected students are placed in law firms known as Lawlinks. I was then hired part time after my Summer work program, and full time after I finished high school. I am attending college this Fall. I have a 4.3 GPA from High School and have already finished Prince George’s County Community College. I am skilled at paralegal/law clerk work and I expect to be attending law school among other options.
- My job and the job of other paralegals at The Burns Law Firm, LLC is
different from paralegals at other law firms. I know this because I keep in touch with a number of paralegals/ law clerks working in this area at other law firms whom I met in my Lawlinks program.
My training, the expectations made of me by Mr. Burns in particular but the entire law firm structure is harder and anything but clerical. I am expected to write motions; demand letters, assess and analyze pleadings. I am required to communicate with clients on the substance of their cases related to upcoming events, and Mr. Burns frequently requires me to review my work in the context of growth oriented mentoring.
Mr. Burns accompanied me to a mock hearing before the Bankruptcy Court where I was expected after two brief training sessions to conduct a direct examination of a witness on a reaffirmation agreement under 11 U.S.C. § 524.
- The work that I bill for daily is contemporaneous on my time expended on
legal tasks. If there is something clerical, which is either too brief to record or is in the nature of a secretarial duty that does not involve substance on the legal merits of the case, I typically do not bill for that as it is not within the scope of activities I am asked to track. There are a lot of clients at The Burns Law Firm, LLC and there is a lot of necessary work required to attend to their needs and ensure that their cases are successful. I know that most of the cases we handle result in successful results because of the work that is performed to make sure the cases are moving in the right direction with all legal issues under control. That is not easy clerical work that I perform.
- We work days and occasionally holidays and Mr. Burns and Ms.
Rashbaum, the attorneys, are very attentive to supervision and making sure the job is done right. I, as a paralegal/ law clerk, work very hard because that is the nature of the tasks which must be performed, on time, and correct. Mr. Burns runs a litigation law firm, and he is very strict in timing, quality, and what he sees as performance goals for all the paralegals / law clerks.