For Challenging Obama Identity Fraud; Overbilled Nearly $10,000
Excerpt via the Motion to Modify:
Ms. Jordan details in her prior affidavit her unsuccessful efforts to obtain legal counsel and that an award of over $12,000 against her “would be an extreme financial hardship for me and it does seem unreasonable.” Jordan Declaration Objection 6. She makes little more than $500 per month caring for a senior citizen. Her husband is a school teacher. Although the court has previously determined her legal arguments were not well taken there is no claim she acted in bad faith or will malicious intent. Any award against her should be compensatory, not punitive.
A. Actual attorney fees charged the agency must be beginning point of analysis
Attorney fee awards are generally calculated by the lodestar method wherein the court first determines the reasonable number of hours spent to secure the result, excluding wasteful or duplicative hours. Mahler v. Szucs, 135 Wn.2d 398, 434, 957 P.2d 632 (1998). The court then determines the reasonableness of counsel’s hourly rate at the time he rendered the services and multiplies the two to arrive at a total award. Ibid. at 434
That is not, however, what happened here. Although the original motion requested reimbursement of fees actually incurred by the Secretary of State; nowhere does the declaration detailing the request claim the requested fees were actually incurred by the Secretary. To the contrary, the requested hourly rate is not even claimed to be the actual hourly rate. Rather it is a fictitious one derived from an internal document prepared by the AG’s Operations Committee purported to approximate a “reasonable market rate” in the private sector without regard to the actual rate charged the agency. See Even Declaration December 10, ex. C
Noting the failure to disclose the actual attorney fees billed the agency, your undersigned called Mr. Even who acknowledged his fee request was not based on the actual amount billed. He stated the agency was billed $525.03 for Ms. Zipp’s 7 hours and $2,887.37 for his 45.8 hours, for a total of $3,412.40, not the $12,675 awarded by the clerk. He also said other services not documented in his declaration were billed at $87.33 and $420.66 to the agency and $32.78 was not billed by error. [...]
B. Number of hours unreasonable
An award of nearly $13,000 to successfully defend a claimed frivolous suit is on its face unreasonable. [...]
MOTION TO MODIFY CONTINUED BELOW OR HERE: http://www.scribd.com/doc/124407022
PREVIOUS REPORTS: http://obamareleaseyourrecords.blogspot.com/search?q=Linda+Jordan
LINDA'S DEFENSE PAGE: http://www.ObamaForgeries.com
Jordan v Reed - Appellant Motion to Modify - Washington State Supreme Court - Obama Challenge Sanction Appe... by ObamaRelease YourRecords
WATCH SHERIFF OBAMA INVESTIGATION PRESS CONFERENCE HERE: CLICK HERE.
-ARTICLE II ELIGIBILITY FACTS HERE: http://www.art2superpac.com/issues.html
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