Case 2:17-cv-00094-RAJ Document 139 Filed 03/29/18 Page 1 of 5

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THE HONORABLE RICHARD A. JONES

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UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON
AT SEATTLE

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ABDIQAFAR WAGAFE, et al., on behalf
of themselves and others similarly situated,
Plaintiffs,

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v.

No. 2:17-cv-00094-RAJ
DECLARATION HUGH HANDEYSIDE
IN SUPPORT OF PLAINTIFFS’
MOTION FOR SANCTIONS

DONALD TRUMP, President of the
United States, et al.,

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Defendants.

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I, Hugh Handeyside, declare as follows:

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1.

I am an attorney admitted to practice in New York and Washington, and I am

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counsel for Plaintiffs in this case. I have personal knowledge of the facts set forth herein and am

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competent to testify thereto.

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2.

I am a 2007 graduate of the University of Michigan Law School and currently a

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Senior Staff Attorney at the American Civil Liberties Union Foundation, where I engage in

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litigation and advocacy on a range of matters related to national security. Prior to joining the

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ACLU, I worked as a litigation associate at Perkins Coie LLP and Corr Cronin Michelson

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Baumgardner & Preece LLP in Seattle. I also served as a law clerk to Judge John C. Coughenour

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of the U.S. District Court for the Western District of Washington.

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DECL. OF HUGH HANDEYSIDE IN SUPPORT OF
PLAINTIFFS’ MOTION FOR SANCTIONS
(No. 2:17-cv-00094-RAJ) – 1

 Case 2:17-cv-00094-RAJ Document 139 Filed 03/29/18 Page 2 of 5

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3.

I have recorded my time contemporaneously for this matter using the Toggl

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timekeeping platform. Attached as Exhibit A to this declaration is a true and correct copy of my

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time records for the work performed on the issues for which Plaintiffs’ counsel are seeking

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attorneys’ fees associated with Plaintiffs’ motion for sanctions.

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4.

As supported by the Declaration of Carol Sobel, my hourly rate for the work

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performed is $676.85 for 2018 and $646.64 for 2017, based on my year of graduation and the

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market rates for Seattle, Washington.

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5.

Below is a chart that details the attorneys’ fees that I am seeking with Plaintiffs’

motion for sanctions, broken up by category. The total value of my work is $3,779.60.

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Cost Category
Plaintiffs’ Motion to Compel (Sept/Oct
2017)
Defendants’ Motion to Reconsider (Nov
2017)
Executive Order Discovery (Nov 2017 –
Jan 2018)

Time and Rate
1.6 Hours x $646.64 Rate
$1,034.62
0.3 Hours x $646.64 Rate
$193.99
0.7 Hours x $646.64 Rate

$452.75
Production Timeline (Dec 2017 – Jan 2018) 1.2 Hours x $676.85 Rate
Court Conferences & Follow-up (Feb –
Mar 2018)
TOTAL

$812.22
1.9 Hours x $676.85 Rate
$1286.02
$3,779.60

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I declare under penalty of perjury that the foregoing is true and correct.

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DATED this 28th day of March, 2018, at New York, NY.

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/s/ Hugh Handeyside
Hugh Handeyside

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DECL. OF HUGH HANDEYSIDE IN SUPPORT OF
PLAINTIFF’S MOTION FOR SANCTIONS
(No. 2:17-cv-00094-RAJ) – 2

 Case 2:17-cv-00094-RAJ Document 139 Filed 03/29/18 Page 3 of 5

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CERTIFICATE OF SERVICE
The undersigned certifies that on the dated indicated below, I caused service of the
foregoing DECLARATION OF HUGH HANDEYSIDE IN SUPPORT OF PLAINTIFFS’
MOTION FOR SANCTIONS via the CM/ECF system that will automatically send notice of
such filing to all counsel of record herein.
DATED this 29th day of March, 2018, at Seattle, Washington.

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By: s/ Laura K. Hennessey
Laura K. Hennessey, #47447
Attorneys for Plaintiffs
Perkins Coie LLP
1201 Third Avenue, Suite 4900
Seattle, WA 98101-3099
Telephone: 206.359.8000
Facsimile: 206.359.9000
Email: LHennessey@perkinscoie.com

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CERTIFICATE OF SERVICE
(No. 17-cv-00094 RAJ) – 1
139100138.2

Perkins Coie LLP

1201 Third Avenue, Suite 4900
Seattle, WA 98101-3099
Phone: 206.35.8000
Fax: 206.359.9000

 Case Document 139 Filed 03/29/18 Page 4 of 5

EXHIBIT A

Case 2:17-cv-00094-RAJ Document 139 Filed 03/29/18 Page 5 of 5

Detailed report
2017-09-01 - 2018-03-28
Total 05 h 53 min

CARRP selected as projects
MFS selected as tags
Date

09-27

10-10

10-19

11-14

11-29

01-24

01-25

02-05

02-07

02-26

03-12

Description

Duration

CARRP - [MFS]

10:46-11:25

Review response to motion to compel

0:39:02

CARRP - [MFS]

23:06-23:45

Review order on motion to compel; exchange correspondence on same

0:20:06

CARRP - [MFS]

13:54-14:14

Review response to motion for reconsideration

0:23:37

CARRP - [MFS]

14:40-15:03

Confer regarding court order and discovery issues

0:45:10

CARRP - [MFS]

14:31-15:16

Conference call re meet & confer, motions to compel, and case schedule

0:39:28

CARRP - [MFS]

14:45-15:25

Review research on privilege invocations; confer re same

0:28:10

CARRP - [MFS]

16:56-17:25

Review draft submission to court regarding discovery disputes

0:42:26

CARRP - [MFS]

11:32-12:14

Confer regarding case issues and discovery motions

0:37:52

CARRP - [MFS]

14:30-15:08

Review draft status report

0:17:20

CARRP - [MFS]

12:00-12:17

Review status report and draft response, exchange correspondence on same

0:20:54

CARRP - [MFS]

10:33-10:54

Review and revise draft motion to compel

0:39:16

User

Hugh Handeyside

Hugh Handeyside

Hugh Handeyside

Hugh Handeyside

Hugh Handeyside

Hugh Handeyside

Hugh Handeyside

Hugh Handeyside

Hugh Handeyside

Hugh Handeyside

Hugh Handeyside

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