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DECLARATION OF JEFFREY T. EVEN DETAILING REQUEST FOR ATTORNEYS' FEES

DECLARATION OF JEFFREY T. EVEN DETAILING REQUEST FOR ATTORNEYS' FEES

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Published by Helen Tansey
AG Even's Declaration of Attorney Fee's
AG Even's Declaration of Attorney Fee's

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Categories:Types, Business/Law
Published by: Helen Tansey on Jan 07, 2013
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01/28/2014

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1
NO. 87837-4
SUPREME COURT OF THE STATE OF WASHINGTON
LINDA JORDAN,Appellant,v.SAM REED, Secretary of State of theState of Washington,Respondent.DECLARATION OFJEFFREY T. EVENDETAILING REQUESTFOR ATTORNEYS'FEESI, JEFFREY T. EVEN, declare as follows:1.
 
I am over eighteen years of age and competent to testify. Iam an attorney licensed to practice law in Washington. I am currentlyemployed by the Attorney General of Washington, and my title is DeputySolicitor General. I serve as counsel for Respondent Secretary of StateSam Reed in this action. I submit this Declaration pursuant toRAP 18.1(d), and the Order of this Court entered on December 5, 2012,
awarding reasonable attorneys’ fees in favor of the Respondent pursuant to
RAP 18.9.2.
 
As detailed below, Respondent seeks an order settingreasonable attorney fees in this matter at $12,675, payable by Ms. Jordanto the State of Washington.
 
2
3.
 
During the time period of September 7, 2012, through andincluding October 16, 2012, I devoted a total of 27 hours to the defense of this appeal. The time period begins after this appeal commenced, and
ends before I began work on Respondent’s Motion For Attorney’s Fees,
and therefore does not include any time devoted to that motion. Tasksperformed in those 27 hours principally consisted of preparing pleadingsrelated to the motion practice in this matter, as well as the review of pleadings and discussions of the case with Deputy Solicitor GeneralAllyson Zipp and with representatives of the client at the Office of theSecretary of State.
Exhibit A
 
to this Declaration is a table describing thelegal services provided on this appeal in greater detail.4.
 
After October 16, 2012, I devoted an additional 17.4 hours
to the tasks related to Respondent’s Motion for Attorney’s Fees
. Thesehours are also detailed in
Exhibit A
. In requesting fees, respondent
sought fees in the amount incurred up to the date of the motion, plus “suchadditional amount as may be incurred before dismissal of this action.”
Respondent
’s Motion for Attorney’s Fees at 2. I note that the motion alsoalluded to requesting additional fees “other than related to this motion.”
 Id.
 
at 10. For this reason, I separately note this block of time. The Court’sorder simply granted “reasonable attorney fees.” Order (Dec. 5, 2
012).
 
3
5.
 
I also devoted an additional 1.4 hours related toMs.
Jordan’s attempt to file requests for admissions
, because I drafted amotion to strike that attempted discovery pleading. I did not file themotion, because the Cou
rt rejected Ms. Jordan’s pleading
sua sponte
.These hours are also detailed on
Exhibit A.
 6.
 
My hours compensable pursuant to this Court’s order of 
December 5, 2012, accordingly total 45.8 hours.7.
 
I was assisted in this matter by my colleague, DeputySolicitor General Allyson Zipp, who devoted a total of 7 hours to thedefense of this appeal between the dates of September 7, 2012, throughand including October 16, 2012. A true and correct copy of a declarationshe previously filed in this matter is attached as
Exhibit B
 
for ease of reference. Ms. Zipp has since left the employment of the Office of theAttorney General.8.
 
The Office of the Attorney General has developed aschedule of litigation recovery rates, to be used when seeking the recovery
of attorney’s f 
ees from opposing parties. A true and correct copy of thatschedule is attached as
Exhibit C
. The fee schedule sets hourly ratesbased upon years of experience as an Attorney. I was admitted to theWashington bar in 1991, after earlier being admitted to the bars of California and Montana in 1987 and 1988 respectively. Accordingly,

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