Case 2:17-cv-00094-RAJ Document 141 Filed 03/29/18 Page 1 of 6 1 THE HONORABLE RICHARD A. JONES 2 3 4 5 6 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON AT SEATTLE 7 8 9 10 ABDIQAFAR WAGAFE, et al., on behalf of themselves and others similarly situated, Plaintiffs, 11 12 13 v. No. 2:17-cv-00094-RAJ DECLARATION OF MATT ADAMS IN SUPPORT OF PLAINTIFFS’ MOTION FOR SANCTIONS DONALD TRUMP, President of the United States, et al., 14 Defendants. 15 16 17 I, Matt Adams, hereby declare as follows: 1. I am one of the attorneys for Plaintiffs in this case. I have personal knowledge of 18 the facts set forth herein and am competent to testify thereto. I submit this declaration in support 19 of Plaintiffs’ Motion for Sanctions. 20 2. I am an attorney at law, admitted to practice in Washington State since 21 November, 1998. I graduated from Berkeley Law School in May of 1998. I have worked at 22 Northwest Immigrant Rights Project as a staff attorney since I graduated in 1998. I am currently 23 the legal director for Northwest Immigrant Rights Project. During these last twenty years I have 24 worked exclusively in representing clients on matters relating to the Immigration and Nationality 25 Act. My experience is set forth in my declaration in support of Plaintiffs’ motion for class 26 certification, see Dkt. No. 31. DECL. OF MATT ADAMS IN SUPPORT OF PLAINTIFFS’ MOTION FOR SANCTIONS (No. 2:17-cv-00094-RAJ) – 1 Case 2:17-cv-00094-RAJ Document 141 Filed 03/29/18 Page 2 of 6 1 3. I have recorded my time contemporaneously for all matters in this case. Attached 2 as Exhibit A to this declaration is a true and correct copy of my timesheet for the work 3 performed on the issues for which we are seeking attorneys’ fees with Plaintiffs’ motion for 4 sanction. 5 4. As supported by the Declaration of Carol Sobel, the hourly market rate of work 6 performed was $779.74 per hour in 2017 and $815.62 in 2018. See Declaration of Carol Sobel. 7 These rates are within the range of reasonable and customary rates charged by lawyers with 8 similar credentials, experience, expertise, and resources at comparable firms. See id. 9 10 5. Included below is a chart summarizing my time records and hourly rates, labeled by the categories of work involved. The total value of my work is $17,986.43. 11 2017 12 13 14 15 16 17 18 19 20 21 22 Category 1 Plaintiffs’ Motion to Compel Cost Category #2 Defendants’ Motion to Reconsider Cost Category #3 Executive Order Discovery 24 6.3 Hours x $779.74 Rate 1.5. Hours x $815.62 Rate $4912.36 1.6 Hours x $779.74 Rate $1,223.43 0 Hours $1.247.58 0 Hours Cost Category #4 Production Timeline 0 Hours Cost Category #5 Court Conferences & Follow-up 0 Hours 23 TOTAL 2018 0 Hours 2.9 Hours x $815.62 Rate $2,365.30 10.1 Hours x $815.62 Rate 7.9 Hours $8,237.76 14.5 Hours $6159.94 $11826.49 25 26 DECL. OF MATT ADAMS IN SUPPORT OF PLAINTIFF’S MOTION FOR SANCTIONS (No. 2:17-cv-00094-RAJ) – 2 TOTAL HOURS 7.8 TOTAL AMOUNT $6,135.79 1.6 $1247.58 0 $0 2.9 $2,365.30 10.1 $8,237.76 23.4 $17,986.43 Case 2:17-cv-00094-RAJ Document 141 Filed 03/29/18 Page 3 of 6 1 I declare under penalty of perjury that the foregoing is true and correct. Executed this 27th day 2 of March, 2018, at Seattle, Washington. 3 s/Matt Adams Matt Adams Northwest Immigrant Rights Project 615 Second Ave., Ste. 400 Seattle, WA 98104 Tel: (206) 957-8611 Email: matt@nwirp.org 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 DECL. OF MATT ADAMS IN SUPPORT OF PLAINTIFF’S MOTION FOR SANCTIONS (No. 2:17-cv-00094-RAJ) – 3 Case 2:17-cv-00094-RAJ Document 141 Filed 03/29/18 Page 4 of 6 1 2 3 4 5 6 CERTIFICATE OF SERVICE The undersigned certifies that on the dated indicated below, I caused service of the foregoing DECLARATION OF MATT ADAMS 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. 7 8 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 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 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 141 Filed 03/29/18 Page 5 of 6 EXHIBIT A D 44532 44554 44570 44576 44605 54500 44621 44800 44799 45470 47048 48403 49401 50376 50375 50798 53367 53372 53368 Date of Service 09/27/2017 10/04/2017 10/12/2017 10/18/2017 11/01/2017 11/08/2017 11/08/2017 01/10/2018 01/10/2018 01/24/2018 02/08/2018 02/19/2018 02/25/2018 03/01/2018 03/01/2018 03/05/2018 03/11/2018 03/16/2018 03/16/2018 Time Spent 1.6 0.5 2.4 0.8 1 1.2 0.4 0.2 0.7 0.6 4 0.4 0.3 1.5 0.7 1.2 0.5 1.2 0.3 Caseworker Matt Adams Matt Adams Matt Adams Matt Adams Matt Adams Matt Adams Matt Adams Matt Adams Matt Adams Matt Adams Matt Adams Matt Adams Matt Adams Matt Adams Matt Adams Matt Adams Matt Adams Matt Adams Matt Adams Funding Code 23 NWIRP - general 23 NWIRP - general 23 NWIRP - general 23 NWIRP - general 23 NWIRP - general 23 NWIRP - general 23 NWIRP - general 23 NWIRP - general 23 NWIRP - general 23 NWIRP - general 23 NWIRP - general 23 NWIRP - general 23 NWIRP - general 23 NWIRP - general 23 NWIRP - general 23 NWIRP - general 23 NWIRP - general 23 NWIRP - general 23 NWIRP - general Activity Type Case Activity Case Activity Case Activity Case Activity Case Activity Case Activity Case Activity Case Activity Case Activity Case Activity Case Activity Case Activity Case Activity Case Activity Case Activity Case Activity Case Activity Case Activity Case Activity Activity Details editing motion to compel team call responding to discovery disputes review opp to mx to compel, edit draft reply pcw/ team follow up re discovery, mx to compel pc w/ team prep on meet and confer, review discovery editing respnse to mx to reconsider pc response for meet and confer review court order on MTC pc re meet & confer pc re prep for meet & confer, motion to compel hearing re discovery requests edit discovery requests editing response to gvt status report reviewing D's motion and supporting exhibits, feedback meet and confer with Defendants' counsel editing response to Ds' mx for protective order editing email responses to OIL editing deliberative process mx edit motion re overlength