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Attorney General, hereby oppose Plaintiffs’ motion for attorneys’ fees and costs (Docs. 69, 70,

and 71) for the following reasons:

Argument

On January 29, 2015, this Court entered a final order granting judgment on the pleadings

and permanent injunction in favor of Plaintiffs. (Doc. 65.) Based upon the Tenth Circuit Court of

Appeals decisions in Kitchen v. Herbert , 755 F. 3d 1193 (10th Cir. 2014) and Bishop v. Smith, 760

F.3d 1070 (10th Cir. 2014) this Court held that laws prohibiting same-sex marriage and laws failing

to recognize the validity of same-sex marriages are unconstitutional. Plaintiffs have submitted a

fee petition under 42 U.S.C. § 1988. “In any fee request under 1988(b), a claimant must prove

two elements: (1) that the claimant was the ‘prevailing party’ in the proceeding; and (2) that the

claimant’s fee request is “reasonable.’” Robinson v. City of Edmond , 160 F.3d 1275, 1280 (10th

Cir. 1998). The State Defendants agree that Plaintiffs are the prevailing party and are entitled their

reasonable fees and expenses. However, the State Defendants have many concerns about

Plaintiffs’ attorneys’ billings and oppose their fees and expenses for several reasons:

1)

Many of the hours Plaintiffs’ attorneys billed and submitted to this Court are duplicative

and excessive — five to seven attorneys typically reviewed and/or edited every pleading;

2) Plaintiffs’ counsel is requesting fees for time spent subpoenaing Governor Mead for the

preliminary injunction hearing — an action that this Court stated was unnecessary to the

legal issues of the case;

3) Many hours relate to work on pleadings that were never filed;

4) The time spent on simple tasks such as preparing pro hac vice motions was excessive;

5) Plaintiffs’ attorneys billed for time spent working on the State case;

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6) Plaintiffs’ attorneys billed for time spent working on pleadings even though they had

already been filed; and

7) Many hours relate to Plaintiffs’ attorneys’ preparation and travel time to the preliminary

injunction hearing even though those attorneys did not participate in the hearing.

Plaintiffs’ attorneys billed hourly rates ranging from $140 to $325, with at least 4 attorneys

billing $300/hour or more.1 The State Defendants are willing to accept these hourly rates, however,

if Plaintiffs’ attorneys are going to charge these rates based upon their expertise and experience

(See Affidavits in Docs. 70-1, 70-2, 70-3, and 70-4), they should not charge and recover fees for

the duplicative, excessive work and supervision that is pervasive in these billings.

Plaintiffs’ counsels’ fee request includes fees from four law firms, nine attorneys, and one

paralegal totaling 371.6 hours and $92,728.07. (Docs. 70-1, 70-2, 70-3, and 70-4.) The fee request

can be summarized as follows:

Name Firm Hourly rate Total hours Total fee

ThomasStoever

Arnold & Porter LLP $325 35 $11,375

James Lyman Arnold & Porter LLP $262.40 101.6 $26,659.84Rebecca Golz(paralegal)

Arnold & Porter LLP $133.25 23.3 $3,104.73

QusairMohamedbhai

RathodMohamedbhai LLC

$300 21.9 $6,570

ArashJahanian

RathodMohamedbhai LLC

$200 70.7 $14,140

Aaron Belzer RathodMohamedbhai LLC

$140 13.5 $1,890

Tracy Zubrod Zubrod Law Office,PC

$220 38.3 $8,426

ShannonMinter

National Center forLesbian Rights

$325 19.8 $6,435

ChristopherStoll

National Center forLesbian Rights

$300 42.6 $12,780

1 The 2013 Wyoming State Bar survey results indicate that only 4.4% of Wyoming attorneys charge morethan $300 an hour. (See Doc. 70-5, pp. 3, 19.)


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Amy Whelan National Center forLesbian Rights

$275 4.9 $1,347.50

Total 371.6 $92,728.072

In addition, Plaintiffs’ attorneys seek to recover costs of $5,125.97. (Docs. 70-1, p. 23; 70-

2, p. 22; and 70-3, p. 24.) Plaintiffs’ counsel suggests that these fees and costs were reasonably

incurred by each attorney for a case that substantially lasted only two weeks — the complaint was

filed October 7, 2014, the Court granted the preliminary injunction (Doc. 44) on October 17, and

the State Defendants filed their notice that they would not appeal (Doc. 47) on October 21. The

only remaining issue was the form of the final order granting a permanent injunction. After the

parties filed competing motions for judgment on the pleadings (Docs. 54 and 56), the Court granted

a permanent injunction (Doc. 65) on January 29, 2015.

The Court adopted the State Defendants’ proposed order in all material respects. The Court

rejected the Plaintiffs’ proposed order requesting the Court force the State Defendants to “ensure

that county clerks and other officials within their control fulfill their obligations under the law .”

The Court explained that it was “not convinced State Defendants have the authority to control

county clerks because county clerks are separately elected officials. The Court finds Plaintiffs’

request in this regard is inappropriate and cannot be granted.” (Internal citation omitted) (Doc.

65.)

“To determine a reasonable attorneys fee, the district court must arrive at a ‘lodestar’ figure

by multiplying the hours plaintiffs’ counsel reasonably spent on the litigation by a reasonable

hourly rate.” Case v. Unified School Dist. No. 233, Johnson Cnty., Kan., 157 F.3d 1243, 1249

(10th Cir. 1998) (quoting Jane L. v. Bangerter, 61 F.3d 1505, 1509 (10th Cir.1995)). “[T]he fee

applicant bears the burden of establishing entitlement to an award and documenting the appropriate

2 In Plaintiffs’ fee chart on page 5 of their memorandum (Doc. 70), Plaintiffs’ counsel indicates that th etotal is $92,728.12.


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hours expended and hourly rates.” Case, 157 F.3d at 1249 (quoting Mares v. Credit Bureau of

Raton, 801 F.2d 1197, 1201 (10th Cir. 1986)); Hensley v. Eckerhart, 461 U.S. 424, 437 (1933).

“Once the district court has adequate time records before it, it must then ensure that the winning

attorneys have exercised ‘billing judgment.’” Id. at 1250 (quoting Copeland v. Marshall, 641 F.2d

880, 891 (D.C.Cir.1980). “Billing judgment consists of winnowing the hours actually expended

down to the hours reasonably expended. Hours that an attorney would not properly bill to his or

her client cannot reasonably be billed to the adverse party, making certain time presumptively

unreasonable.” See id. at 1250.

Based upon a review of Plaintiffs’ counsels’ billing statements, the State Defendants have

identified several areas that appear to be unreasonable because Plaintiffs’ attorneys failed to

exercise the appropriate and necessary billing judgment.3 For the convenience of the Court, the

State Defendants have attached and will cite to the Plaintiffs’ attorneys’ affidavits and billing

statements. (Docs. 70-1, 70-2, 70-3, and 70-4, attached as Exhibit A.)

I. Shannon Minter’s and Christopher Stoll’s time should be disallowed because it is

duplicative, unnecessary, excessive, and unreasonable.

“The district court may reduce the reasonable hours awarded if ‘the number [of

compensable hours] claimed by counsel include[s] hours that were unnecessary, irrelevant and

duplicative.’ ” Case, 157 F.3d at 1250 (quoting Carter v. Sedgwick Cnty., Kan., 36 F.3d 952, 956

(10th Cir.1994)). Upon review of Plaintiffs’ invoices, all of Minter ’s and Stoll’s time is

duplicative, unnecessary, excessive, and unreasonable. Stoll’s and Minter ’s work consisted

entirely of: 1) reviewing, revising, or editing documents drafted by one of the other seven attorneys

3 The State Defendants have tried to be precise with its calculations in this filing, however, it was a difficulttask because Plaintiffs’ attorneys commingled multiple tasks on individual billing entries.


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on the case; and 2) conferring with co-counsel or each other about the case. In most instances,

Stoll and Minter were the fifth and sixth attorneys to review a particular document.

For instance, the billing records indicate that Lyman drafted the complaint on October 6

and 7, 2014, (Doc. 70-1, p. 16) however, five other attorneys, including Stoll and Minter, billed

for and are requesting payment for reviewing and/or editing the complaint even though the

complaint is nearly identical to the complaint Plaintiffs’ attorneys filed about seven months earlier

in State district court (Courage v. Wyoming, et al .)(State Complaint attached as Exhibit B). (Docs

70-1, p. 16; 70-2, pp. 18-19; 70-3, p. 17; and 70-4, p. 5.) Similarly, Lyman drafted the motion for

preliminary injunction from October 6-8, 2014, (Doc. 70-1, p. 16) and six other attorneys,

including Stoll and Minter, researched, reviewed, or edited the motion. (Docs 70-1, p. 16; 70-2,

pp. 18-19; 70-3, p. 17; and 70-4, p. 5.) Minter’s and Stoll’s time does not appear to be essential

or necessary to the litigation especially considering the expertise and quality of the other attorneys

representing Plaintiffs. (See Affidavits attached to Docs. 70-1, 70-2, 70-3, and 70-4.) In making

the request for payment of their fees, Minter and Stoll failed to winnow the hours actually

expended down to the hours reasonably expended. Case, 157 F.3d at 1250. Minter’s and Stoll’s

billing statements do not reflect hours reasonably expended.

Further, many of Minter ’s and Stoll’s time entries are identical or nearly identical. For

example:

10/6/2014 - Confer with client and co-counsel re Supreme Court certiorari denials,communications with state officials, and potential federal litigation (Minter - 1.6 hrs)(Doc.70-2, p. 18);

10/6/2014 - Confer with client and co-counsel re Supreme Court certiorari denials and potential federal litigation (Stoll - 1.6 hrs)(Doc. 70-2, p. 19);

10/7/2014 - Confer with co-counsel re filing of complaint, pro hac vice motions and casestrategy (Minter - 1.4 hrs)(Doc. 70-2, p. 18);


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10/7/2014 - Confer with co-counsel re filing of complaint pro hac vice motions and re casestrategy (Stoll - 1.4 hrs)(Doc. 70-2, p. 19);

10/8/2014 - Confer with client and co-counsel re preliminary injunction and hearing(Minter - 1.5 hrs)(Doc. 70-2, p. 18);

10/8/2014 - Confer with client and co-counsel re motion for preliminary injunction andscheduling of hearing (Stoll - 1.5 hrs)(Doc. 70-2, p. 19);

10/9/2014 - Confer with co-counsel re preliminary injunction oral argument (Minter - .7hrs)(Doc. 70-2, p. 18);

10/9/2014 - Confer with co-counsel re hearing on motion for preliminary injunction (Stoll- .7 hrs)(Doc. 70-2, p. 19);

10/14/2014 – Review proposed order of proof; confer with co-counsel re same (Minter - .6

hrs)(Doc. 70-2, p. 18);

10/14/2014 – Review proposed order of proof; confer with co-counsel re same. (Stoll - .8hrs)(Doc. 70-2, p. 19);

10/14/2014 – Confer with co-counsel re oral argument (Minter – 1.2 hrs)(Doc. 70-2, p. 18);

10/14/2014 – Confer with co-counsel re preparation for hearing (Stoll – 1.2 hrs)(Doc. 70-2, p. 19);

10/15/2014 – Confer with co-counsel re preparation for hearing (Minter – 1.3 hrs)(Doc.

70-2, p. 18); and

10/15/2014 – Confer with co-counsel re preparation for hearing (Stoll – 1.3 hrs)(Doc. 70-2, p. 19).

These types of billing entries are consistent throughout Minter ’s and Stoll’s billing statements. Not

only did Minter and Stoll duplicate the other attorneys’ work, they consistently duplicated each

other’s work.

In addition, Stoll billed 20.1 hours (between October 9 and 16) and $1,606.53 in travel

costs related to his preparation, traveling to, and attending the preliminary injunction hearing.4

4 Minter also billed 3.5 hours relating to preparation for the hearing which he did not attend. (Doc. 70-2, p. 18.)


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(Doc. 70-2, pp. 19, 22.) However, Stoll did not participate in the hearing, he simply observed.

(See attached Hearing Transcript, Exhibit C.) Again, these fees and costs are unnecessary,

excessive, and unreasonable. If more attorneys are present at a hearing than needed, compensation

for excess time should be denied. See Case, 157 F.3d at 1250. At the preliminary injunction

hearing, although at least six of Plaintiffs’ attorneys were present, only three participated in the

one-hour hearing. All of Stoll’s time and expenses associated with the preliminary injunction

hearing is excessive, duplicative, and unnecessary.

The State Defendants request that Minter ’s and Stoll’s 62.4 hours be disallowed because

they are duplicative, unnecessary, excessive, and unreasonable. Case, 157 F.3d at 1250. Those

hours do not represent appropriate billing judgment.

II. All the fees and costs associated with the subpoena to Governor Mead are

unnecessary and unreasonable.

Plaintiffs seek recovery for approximately 26 hours of time totaling approximately $5,200

and $180 in service fees in relation to the subpoena for Governor Mead to testify at the preliminary

injunction hearing and responding to the State Defendants’ motion to quash.5 (Docs. 70-1, p. 16;

70-3, pp. 17-18, 24; and 70-4, p. 6.) In granting the motion to quash, this Court stated that “[t]here

is no legitimate evidentiary need for the testimony of Governor Mead for this court’s resolution of

the issues before it. Rather, it appears Plaintiffs’ counsel has engaged in a political stunt, which

simply detracts from the merits of the serious legal issues before this court.” (Doc. 25.) In a

footnote the Court explained that: “[t]he typical practice in serving subpoenas upon parties

5

Twenty-six hours is an estimate because on several of the billing entries relating to the subpoena,Plaintiffs’ counsel also commingled other tasks. For instance, on October 9, 2014, Mohamedbhai spent 2.8hours on “strategize re subpoena; prepare clients for hearing[]” and on the same day, Jahanian spent 3.3hours on “[p]repare subpoena; confer re pro hac vice motions; draft motion for summary judgment.” (Doc.70-3, p. 17.) It is impossible for the State Defendants to know the exact time Plaintiffs’ counsel spent onthe subpoena. For this reason, the entire 26 hours should be disallowed —Plaintiffs’ counsel have not mettheir burden to show that the hours billed and requested are reasonable.


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represented by counsel is to advise in advance opposing counsel of the intent to serve his or her

client with a subpoena, and seek to have counsel accept service on behalf of their client to minimize

costs and difficulties in service. That initially was not done in this case. For no good reason.” Id .

The time and expenses relating to the subpoena were unnecessary to the legal issues of the

case because there was “no legitimate evidentiary need for the testimony of Governor Mead.” Id.

(See Case, 157 F.3d at 150 , See also Carter, 36 F.3d at 956 ). Plaintiffs should not be allowed to

recover the 26 hours and $180 in service costs relating to the subpoena.

III. Time spent on pro hac vice motions was excessive.

Plaintiffs’ attorneys request approximately 27 hours of time associated with drafting,

reviewing, and discussing pro hac vice motions.6 (Docs. 70-1, pp. 16-17; 70-2, pp. 18-19; 70-3,

pp. 17-19; and 70-4, pp. 5, 7.) Pro hac vice motions are essentially pro forma filings that can be

easily created and duplicated. (See Docs. 8, 12, 29, and 30.) Twenty-seven hours is excessive for

this simple, basic task.

Further, time spent becoming admitted in a specific jurisdiction is not appropriate to be

billed to the client, but is simply a matter of personal qualification for an attorney. “While

admission to the bar of the court of appeals is certainly a prerequisite to defending an appeal in

that forum, an attorney’s professional licensing and bar admissions are matters of personal

qualification for the attorney himself to pursue, apart from the time expended in defense of a

particular appeal.” Parker v. CitiMortgage, Inc., 987 F.Supp.2d 1224, 1232 (D.Utah 2013). The

same logic is applicable here. Clearly, the pro hac vice motions were necessary for the out-of-

6 As previously noted, not all of the 27 hours is associated solely with the pro hac vice motions becauseother tasks were combined in the billing descriptions. However, it is impossible for the State Defendantsto know the exact time Plaintiffs’ counsel spent on tasks relating solely to the pro hac vice motions. Forthis reason, the entire 27 hours should be disallowed.


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state attorneys to practice before this Court, but they are personal bar admission matters that are

separate from time expended litigating the case. As such, these hours should be disallowed.

IV. All work performed drafting, reviewing, or editing documents after service or

filing should be disallowed.

On four separate instances, for a total of 5.5 hours, Plaintiffs’ attorneys billed fees for time

spent working on pleadings that had already been served or filed. On October 8, 2014, Stoever

billed 3 hours for “[r]evisions to federal complaint and preliminary motion[.]” (Doc. 70-1, p. 16.)

However, the federal complaint was filed one day earlier on October 7, 2014, and the complaint

was never amended.7 (Doc. 1.) Further, on October 9, 2014, Stoever billed 1 hour for “[r]evisions

to preliminary motion.” (Doc. 70-1, p. 16.) The preliminary injunction motion was filed one day

earlier on October 8, 2014. (Doc. 7.) On October 10, 2014, Mohamedbhai billed .6 hours to:

“[c]ontinue strategizing re subpoena[]”, however, the subpoena was served the previous day on

October 9, 2014. (Docs. 70-3, p. 18; 18, and 25.) Last, on December 2, 2014, Golz billed .9 hours

to “file and serve plaintiffs’ motion for judgment on the pleadings [,]” however, that motion was

filed on November 24, a week earlier. (Docs. 70-1, p. 21; 56.) These 5.5 hours are unreasonable

and unnecessary. See Case, 157 F.3d at 1250. They further call into question the accuracy of

Plaintiffs’ counsels’ billing statements.

V. Work on pleadings that were never filed should be disallowed.

Jahanian seeks recovery for 5.9 hours for researching and drafting a motion for summary

judgment that was never filed. (Doc. 70-3, pp. 17-18.) Belzer also requests recovery for 3 hours

for research on a summary judgment motion. Id. at p. 18. Hours that an attorney would not

properly bill to his or her client cannot reasonably be billed to the adverse party. See Case, 157

7 Again, Stoever’s entry combines multiple tasks and it is impossible to know how much of the 3 hourswas spent on revising the complaint and how much was spent on the motion.


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F.3d at 1250. It is not reasonable or proper to bill a client for work on a motion that was never

filed. As such, these 8.9 hours are unreasonable, excessive, and should be disallowed.

VI. Plaintiffs’ counsels’ preparation time, travel time, and attendance at the preliminary

injunction hearing was excessive.

Approximately 130 hours was billed by seven different attorneys in preparation for, travel

to, and attendance at, the preliminary injunction hearing. If more attorneys assist in a matter than

are needed, compensation should be denied for any excess time. Case, 157 F.3d at 1250. Four of

those seven attorneys either observed or did not attend the hearing at all. Specifically, Lyman

spent 46.2 hours preparing for and attending the preliminary injunction hearing. (Doc. 70-1, pp.

16-18.) However, Lyman did not participate in the hearing. (See Transcript, Exhibit C.) None of

Lyman’s 46.2 hours describe preparing witnesses or any other task that a hearing non-participant

attorney would reasonably be expected to assist with leading up to a hearing.

As part of those 130 billed hours, Minter and Stoll combined to bill approximately 23 hours

in preparation for, travel to, and attendance at, the preliminary injunction hearing without

participating in the hearing or preparing any witness. (Doc. 70-2, pp. 18-19.) Last, Mohamedbhai

billed approximately 7 hours8 for what appears to be his preparation for the hearing. (Doc. 70-3,

pp. 18-19.) For instance, on October 14, he “[f]inalized pro hac vice motion; review and revise

reply to State Defendants’ response to preliminary injunction motion; prepare for hearing[]” and

on October 16 he “[c]ontinue[d] preparing for hearing; participate in hearing.”9 Id. at p. 19.

8 Mohamedbhai’s time is hard to calculate as he combines many tasks together on billing entries.

9

Mohamedbhai also spent an additional 2.6 hours preparing for the hearing but his billing entry alsodescribes “[p]repar[ing] clients for hearing[]” which seems reasonable to the State Defendants. (Doc. 70-3, p. 19.)


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However, although Mohamedbhai attended the hearing, he did not participate in the hearing and

this time should be reduced. (See Exhibit C.)

The State Defendants contend that the 76 hours billed by Minter, Stoll, Lyman, and

Mohamedbhai relating to attending or preparing for the hearing were excessive, unnecessary, and

duplicative. The hearing lasted approximately one hour and three different Plaintiffs’ attorneys

participated in the hearing. (Exhibit C.) Those three participating attorneys’ (Stoever, Jahanian,

and Zubrod) preparation, travel, and participation time totaled approximately 53 hours and may be

reasonable, although three attorneys participating in the hearing could be excessive. (Doc. 70-1,

pp. 17-18; 70-3, p. 19; and 70-4, pp. 5-8.)

This court should reduce the number of hours expended by Lyman, Stoll, Minter, and

Mohamedbhai, who simply observed the hearing without participation. “[T]he fee applicant bears

the burden of establishing entitlement to an award and documenting the appropriate hours

expended and hourly rates.” Case, 157 F.3d at 1249.

VII. Time spent on the fee petition is excessive.

The State Defendants do not contest that collecting reasonable fees for drafting a fee

petition is permissible. “An award of reasonable attorneys’ fees may include compensation for

work performed in preparing and presenting the fee application.” Mares v. Credit Bureau of Raton,

801 F.2d 1197, 1205 (10th Cir. 1986); and See Glass v. Pfeffer, 849 F.2d 1261, 1266 n. 3 (10th

Cir.1988); Hernandez v. George, 793 F.2d 264, 269 (10th Cir.1986). That being said, Plaintiffs

are requesting about 44 hours of time devoted solely to their fee petition. (Docs. 70-3, pp. 21-22;

70-2, pp. 18-21.) Further, a new attorney, Amy Whelan, who had no involvement in litigating the

case, billed 4.9 hours, all of which were devoted solely to the fee petition. (Doc. 70-2, p. 21.)

Courts have refused to award attorneys’ fees for conducting research and drafting motions


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Page 13 of 20

pertaining to attorney fee recovery because the time submitted for post-trial work was excessive.

See Case, 157 F.3d at 1254. Forty-four hours is excessive.

In comparison, according to the billing statements, Plaintiffs’ counsel billed approximately

60 hours for the two major court filings, the complaint and the preliminary injunction motion.

(Docs. 70-1, p. 16; 70-2, pp. 18-19; 70-3, p. 17; and 70-4, pp. 5-6.) As such, counsel for Plaintiffs’

attorneys billed nearly as much time for the post judgment attorneys’ fee motion as they did for

the complaint and preliminary injunction motion, which is excessive and unreasonable for such a

simple, non-complex filing. Plaintiffs’ counsels’ time should be reduced because 44 hours is

excessive and unreasonable.

The State Defendants believe some of Jahanian’s time spent drafting and revising the fee

petition in the amount of 19.5 hours is reasonable.10 The other time spent by Jahanian and the

other attorneys is duplicative and excessive. In fact, a substantial portion of the time spent on the

fee petition is limited to “confer[ing] re fee petition.” Based upon the billing statements, it appears

that Plaintiffs’ counsel spent at least 5 hours simply conferring on the fee petition. (Doc. 70-3, pp.

21-22.)

VIII. Other duplicative work is unreasonable and excessive.

The duplicative work of Minter and Stoll has already been discussed; however, there are

other examples of duplicative, excessive billing in Plaintiffs’ counsels’ fee request. In addition to

Minter and Stoll, Plaintiffs’ counsel requests attorney’s fees for approximately 18 hours of

reviews, revisions, and edits of the complaint and preliminary injunction motion by four different

attorneys in addition to approximately 31 hours Lyman billed to draft the documents. (Doc. 70-1,

p. 16; 70-3, pp. 17; 70-4, p. 5.) Five attorneys working on one document is excessive and

10 This figure includes Jahanian’s time on December 4, 5, 15, 2014, and February 24, and 25, 2015. (Doc.70-3, pp. 21-22.)


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Page 14 of 20

duplicative and should be reduced. See Case, 157 F.3d at 1250. The State Defendants believe that

billing for reviewing and revising a pleading by one attorney is reasonable at times, given the

nature of the case and the documents being drafted.

Further, four attorneys (not including Minter and Stoll) and a legal assistant billed around

5 hours to review this Court’s order granting preliminary injunction. (Docs. 70-1, p. 18; 70-2, pp.

18-19; 70-3, pp. 19-20; and 70-4, p. 5.) It is excessive and unreasonable for four attorneys and a

legal assistant to bill to review the Court’s order. We think it is reasonable for the attorney that

performed the majority of the work on the pleadings to bill and recover for his time to review the

Court’s order.

Duplicative and excessive billings are pervasive throughout Plaintiffs’ counsels’ billings.

It is excess and inappropriate for at least four to five attorneys (not including Stoll and Minter) to

bill for reviewing party filings and orders of the Court. Plaintiffs’ attorneys have not met their

burden of proving why it is reasonable for every attorney on the case to bill for and seek fees for

reviewing relatively straightforward pleadings and orders. Because there are nine different

attorney billings with entries that contain multiple tasks, State Defendants have had a hard time

parsing out the exact number of hours each attorney dedicated for duplicative work such as

reviewing and revising pleadings and reviewing orders. The State Defendants do not wish to imply

that all time spent reviewing or editing a court filing is duplicative; however, when five

experienced, well trained attorneys and a legal assistant are all reviewing various court filings, a

portion of that time is excessive and duplicative and should be reduced to a reasonable number of

hours.


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IX. Billing for work on the State same sex marriage case is not appropriate.

Plaintiffs’ attorneys seek 5.2 hours of time spent working on the prior case they filed in

State district court, Courage v. Mead, et al . Those charges are:

10/15/2014

11/11/2014

review transcript of statecourt case regarding issueof state’s request for stayof case (Doc. 70-4, pp. 6-7.)

[redacted] regardingstate’s motions in federaland state cases. (Doc. 70-1, p. 19.)

Zubrod

Lyman11

0.60

1.80

11/13/2014 Attend to calls withdefendants’ counselregarding upcomingstatus conference. Id. at20.

Lyman 0.60

11/14/2014 Prepare for and attendstatus hearing in Couragev. Wyoming case. Id. at p. 20.

Lyman 0.50

1/5/2015 Work on filings withWyoming District Court. Id. at p. 21.

Stoever 1.00

1/30/2015 Legal Assistant Servicesfor T. Stoever: reviewstate court file regardingstatus of case and nextsteps before JudgeCampbell. Id . at p. 22.

Golz 0.70

These charges are not in connection with this case and should not be included in Plaintiffs’

fee request.

11 Lyman’s billings indicate he worked on motions in the state case along with motions in the federal case.It is impossible for the State Defendants to parse out the exact amount of time he spent on the state case.


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X. Plaintiffs’ reasonable fees and costs should be split between both defendants, Debra

K. Lathrop, Laramie County Clerk and the State Defendants

This case involves a situation where the Plaintiffs were the prevailing party against multiple

defendants. The Attorneys’ Fees Database treatise discusses this type of situation.

Where a plaintiff prevails against multiple defendants and obtains an awardof attorney’s fees, a question may arise as to the allocation of liability for the feeaward among the defendants. Initially, the allocation of a fee award is a mattercommitted to the District Court’s discretion, and a court’s determination will not be disturbed unless there is an abuse of discretion.

There are a number of possible methods of allocating a fee award. Wherethe defendants are joint tortfeasors or are otherwise jointly responsible for actionsthat produced an indivisible injury, it may be appropriate to hold each defendant

jointly and severally liable for the entire fee award. An alternative method in a caseinvolving roughly equal wrongdoers is to divide the fees equally among thedefendants.

Where the claims against the defendants are separate and distinct or whereculpability is significantly unequal, a court may choose among other methods ofallocating the fee award. One approach is to apportion the attorney’s fees in accordwith each defendant’s relative degree of culpability or in the same proportions asthe jury assessed damages. Alternatively, a court may apportion the fees accordingto the relative amounts of time spent by the plaintiff in preparing the case againsteach defendant. When one defendant is solely or largely responsible for a singleclaim within an action, a court may choose to hold that defendant liable for all ofthe attorney’s fees related to that claim. Finally, a court may decide it is appropriateto combine two or more of the above approaches in allocating the fee award.

1 Attorneys’ Fees § 10:27 (3d ed.)(internal citations omitted).

The State Defendants assert that the recoverable fees and costs should be equally divided

between the Laramie County Clerk and the State Defendants. Most of the substantive work on the

case was applicable against both the Laramie County Clerk and the State of Wyoming, including

the complaint, preliminary injunction motion and hearing, and the motion for judgment on the

pleadings. Further, Plaintiffs essentially raised two claims in this case. One claim was brought

against the Laramie County Clerk demanding her to issue marriage certificates for same sex

couples and the other claim was brought against the State Defendants demanding that the State


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Page 17 of 20

recognize valid same sex marriages entered in other states for the purpose of receiving spousal

benefits.

In addition, a considerable amount of work, around 15 to 17 hours, was performed and

billed by Plaintiffs’ attorneys directly in response to the county and its filings. (Docs. 70-1, pp.

17, 19; 70-2, pp. 18-19; 70-3, pp. 18, 20; and 70-4, pp. 5-9.) Based on the evenly divided claims

and joint work on this case, the easiest and fairest allocation of fees and expenses is to evenly

divide them between Laramie County and the State of Wyoming.

XI. The costs incurred by Plaintiffs’ attorneys are excessive.

Plaintiffs’ counsel requests costs in the total amount of $5,125.97. (Docs. 70-1, p. 23; 70-

2, pp. 21, 22; and 70-3, p. 24.) The costs include: 1) Stoll’s travel costs ($1,606.53) to travel from

San Francisco to Casper for the preliminary injunction hearing; 2) Mohamedbhai’s travels costs

from Denver to Casper for the preliminary injunction hearing, processing costs to serve a subpoena

on Governor Mead, and miscellaneous mailing costs totaling $743.72; and 3) Lyman’s and

Stoever’s travel costs to Casper for the preliminary injunction hearing and miscellaneous other

costs (filing fees, copying and Westlaw research) totaling $2,775.72.

As explained earlier, Stoll did not participate in the hearing and his travel costs should not

be allowed. Mohamedbhai also did not participate in the hearing and his travel costs totaling

$480.57 should not be allowed. Further, as described earlier, Mohamedbhai’s processing fees of

$180 to serve the subpoena on Governor Mead should be disallowed. Lyman’s travel costs of

$122.7712 should not be allowed because he did not participate in the hearing. Last, Arnold and

Porter’s $1,100 in filing fees should be reduced. It appears that $700 of the filing fees relate to

12 In Arnold and Porter’s billing statements, Lyman’s and Stoever’s travel costs are not separated. TheState Defendant’s took the total cost amounts under the headings “hotel” and “travel meals” and reducedthose by one half to account for Lyman’s travel costs. (Doc. 70-1, p. 23.)


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pro hac vice admission which, as described earlier, should not be the responsibility of the

defendants. Based upon these reasonable and necessary reductions, the State Defendants believe

Plaintiffs’ attorneys are entitled to $2,036.10 in costs.

Conclusion

In sum, in order to identify the appropriate lodestar fee award, the Court must determine

the appropriate number of hours at the appropriate rate. Case, 157 F.3d at 1249. The State

Defendants are willing to accept the hourly rates submitted by Plaintiffs’ counsel; however, the

State Defendants object to the number of hours billed in this case. For the convenience of the

Court, the chart below reflects the fees that the State Defendants believe are fair and reasonable

and that reflects proper and appropriate billing judgment.

Name Firm Hourly

rate

Total

hours

billed

Recommended

allowed hours

Total fees

billed

Recommended

allowed fees

ThomasStoever

Arnold & PorterLLP

$325 35 30 $11,375 $9,750

James Lyman Arnold & PorterLLP

$262.40 101.6 54.5 $26,659.84 $14,300.80

Rebecca Golz

(paralegal)

Arnold & Porter

LLP

$133.25 23.3 5.8 $3,104.73 $772.85

QusairMohamedbhai

RathodMohamedbhaiLLC

$300 21.9 4 $6,570 $1,200

ArashJahanian

RathodMohamedbhaiLLC

$200 70.7 45.1 $14,140 $9,020

Aaron Belzer RathodMohamedbhaiLLC

$140 13.5 1.7 $1,890 $238

Tracy Zubrod Zubrod LawOffice, PC

$220 38.3 31.9 $8,426 $7,018

ShannonMinter

National Centerfor Lesbian Rights

$325 19.8 0 $6,435 0

ChristopherStoll

National Centerfor Lesbian Rights

$300 42.6 0 $12,780 0

Amy Whelan National Centerfor Lesbian Rights

$275 4.9 0 $1,347.50 0

Total 371.6 173 $92,728.07 $42,299.65


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Page 19 of 20

As the chart reveals, the State Defendants believe that Plaintiffs’ counsel is entitled to a

total of 173 hours of work on the case for a total of $42,299.65. Further, Plaintiffs’ counsel should

only be entitled to costs in the amount $2,036.10. The State Defendants believe this represents a

fair, reasonable, and appropriate amount of fees and costs. Last, the State Defendants believe that

these amounts should be split evenly between the County and the State Defendants.

Dated this 12th day of March, 2015.

OFFICE OF THE ATTORNEY GENERAL

/s/ Jared S. Crecelius Peter K. Michael, (Wyo. Bar. No. 5-2309)Attorney General of WyomingMartin L. Hardsocg (Wyo. Bar No. 6-2919)Deputy Attorney GeneralRyan T. Schelhaas (Wyo. Bar No. 6-3321)Senior Assistant Attorney GeneralMichael M. Robinson (Wyo. Bar. No. 6-2658)Senior Assistant Attorney GeneralJared S. Crecelius (Wyo. Bar No. 6-4118)Senior Assistant Attorney GeneralAttorneys for State Defendants123 State CapitolCheyenne, WY 82002(307) 777-7876(307) 777-3687 fax [email protected] [email protected] [email protected] [email protected] [email protected]


mailto:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]

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Page 20 of 20

I certify that on this 12th day of March, 2015, I electronically filed the foregoing with theCM/ECF system which sent notice to the following:

Tracy L. Zubrod Thomas W. Stoever, [email protected] [email protected]

Qusair Mohamedbhai Shannon P. [email protected] Christopher F. Stoll

[email protected] Mark T. [email protected] Bernard P. Haggerty

[email protected]

/s/ Jared S. Crecelius

Jared S. Crecelius


mailto:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]

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UNITED STATES DISTRICT COURTDISTRICT OF WYOMING

)

Plaintiffs, ))Anne Marie Guzzo and Bonnie Robinson; )Ivan Williams and Charles Killion; )Brie Barth and Shelly Montgomery; )Carl Oleson and Rob Johnston; and )Wyoming Equality, )

)v. ) Case No. 14-cv-00200-SWS

)Defendants, )

)Matthew H. Mead, in his official capacity )as the Governor of Wyoming; Dean Fausset, in his official )capacity as Director of the Wyoming Department of )Administration and Information; Dave Urquidez, in his )official capacity as Administrator of the State of Wyoming )Human Resources Division; and Debra K. Lathrop, in her )official capacity as Laramie County Clerk, ) _____________________________________________________________________________

DECLARATION OF THOMAS W. STOEVER, JR. IN SUPPORT OF PLAINTIFFS’

MOTION FOR REASONABLE ATTORNEYS’ FEES AND EXPENSES

__________________________________________________________________

I, Thomas W. Stoever, Jr., hereby declare and state as follows:

1. I am a member in good standing of the Colorado State Bar. I am also a member

in good standing of the State Bars of California and Florida. I am a partner at the international

law firm of Arnold & Porter LLP. I have been asked to make this Declaration in Support of

Plaintiffs’ Motion for Reasonable Attorneys’ Fees and Expenses. I have personal knowledge of

the matters stated in this Declaration and could and would confidently testify to these facts.

2. I attended the Boalt Hall School of Law at the University of California, Berkeley,

and graduated in 1990. After graduation from law school, I worked at the law firm of Covington

2

Case 2:14-cv-00200-SWS Document 70-1 Filed 02/26/15 Page 2 of 23Case 2:14-cv-00200-SWS Document 72-1 Filed 03/12/15 Page 1 of 85

EXHIBIT A

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& Burling in Washington, D.C. In 1994, I moved from Covington & Burling to Arnold &

Porter’s office in Denver, Colorado. Arnold & Porter has offices in several locations around the

country and around the world, including, but not limited to, Washington, D.C., New York, San

Francisco, and London. The firm’s work runs the gamut from corporate and transactional

matters to litigation.

3. I have extensive experience litigating complex, multi-jurisdictional cases. This

has included environmental matters, antitrust matters, and mass tort cases. My experience has

included all phases of litigation, including motions practice, discovery, trials, and appeals. I

have handled cases in jurisdictions around the country, including, but not limited to, Colorado,

Florida, California, Texas, New York, Arizona, Utah, Montana, and Wyoming. I have argued

numerous appeals including, but not limited to, two en banc arguments before the Federal Circuit

Court of Appeals and an appearance in the United States Supreme Court (See Attachment 1).

4. In addition to my professional experience, I am an active member of the Colorado

Bar Association, the American Bar Association, and the Faculty of Federal Advocates in the

District of Colorado. Over the years I have made several CLE presentations to peers and

colleagues regarding various aspects of litigation, legal ethics, and trial practice. I have also

served on the Board of Directors of several local, national, and international nonprofit

organizations.

5. L. James Lyman was an associate at Arnold & Porter. Mr. Lyman received his

law degree from the University of Colorado School of Law in 2007 (Order of the Coif). Mr.

Lyman was editor of the University of Colorado Law Review. After graduation he clerked for

the Honorable Lewis T. Babcock on the United States District Court for the District of Colorado.

Mr. Lyman practiced before the state and federal courts of Colorado, the Court of Appeals for

3


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the Tenth Circuit, the Court of Federal Claims, and the Court of Appeals for the Federal Circuit.

Mr. Lyman’s practice included representing clients in all phases of litigation (See Attachment 2).

In December 2014, Mr. Lyman left Arnold & Porter to become a trial attorney with the

Securities and Exchange Commission.

6. Arnold & Porter was retained in this litigation by the Plaintiffs to challenge

Wyoming’s laws prohibiting the issuance of marriage licenses to same-gender couples and

prohibiting recognition of valid marriages of same-gender couples entered into in other

jurisdictions. The individual plaintiffs in this action did not have the resources to retain private

legal counsel and could not financially afford paying the attorneys’ fees and expenses necessary

to proceed with this action. Arnold & Porter is therefore representing Plaintiffs pro bono.

Plaintiffs have agreed that any awarded attorneys’ fees and costs will belong and be paid to their

counsel.

7. After the Supreme Court struck down the Federal Defense of Marriage Act in

Windsor v. United States, 570 U.S. 12 (2013), I was approached by representatives from the

National Center for Lesbian Rights about the possibility of representing same-gender couples.

Beginning in early 2014, Mr. Lyman and I began to research and prepare a complaint for

injunctive relief to be filed in the Wyoming state courts. That complaint was filed on March 5,

2014. The Governor and the Laramie County Clerk were named as defendants. In addition to

filing a complaint, we filed a motion for summary judgment arguing that Wyoming’s

constitution prohibited the application of Wyoming’s statute defining marriage as a union

between one man and one woman. At the Governor’s request, a hearing on that motion for

summary judgment was delayed so the parties could take discovery.

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8. While that discovery was ongoing, the Supreme Court denied certiorari in Kitchen

v. Herbert . Immediately after the Supreme Court’s denial of certiorari, Mr. Lyman and I

prepared and filed a complaint in federal court. That complaint was filed on October 7, 2014.

The next day we filed a motion for preliminary injunction.

9. I managed the process of researching and drafting the complaint, the motion for

preliminary injunction, and supporting papers. I took the lead at the hearing on the motion for

preliminary injunction. Two days after the hearing, the Court granted our motion and the

Governor chose not to appeal.

10. I served as lead counsel for Plaintiffs in this litigation. I was ultimately

responsible for making all strategy calls and deploying the team’s legal and other resources for

research, drafting, etc. I was also ultimately responsible for responding to the questions and

concerns of our clients and making sure they were fully informed regarding the status of the

litigation.

11. Plaintiff’s counsel litigated this case efficiently and without duplication of effort.

I brought my experience working with multiple law firms representing a single client (i.e., the

virtual firm model) to bear on this litigation.

12. This complex and groundbreaking litigation was expedited over a very short

period. As noted above, Plaintiffs’ motion for a preliminary injunction was filed almost

immediately after the filing of the complaint. A hearing was requested and scheduled shortly

thereafter. The time from filing a complaint to issuance of a preliminary injunction was just ten

days.

13. The Governor of Wyoming increased the workload for Plaintiffs’ counsel by

insisting on taking this matter to a hearing. As noted in the Court’s order issuing a preliminary

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injunction, Kitchen v. Herbert was the law of the Tenth Circuit. The Court was obliged to follow

that law. And, most importantly, the Governor never argued to the contrary or put on any

evidence suggesting that the burden of a preliminary injunction would outweigh the benefit. The

Governor could have significantly reduced the fees and expenses accrued by Plaintiffs’ counsel

by agreeing to a preliminary injunction.

14. Moreover, the Governor had no fewer than four lawyers working on his

opposition to the motion for preliminary injunction. In addition, there were four lawyers present

at the preliminary injunction hearing. The Governor’s staffing decisions in this case are a further

reflection of its significance and complexity. The Court should consider the Governor’s staffing

when evaluating the reasonableness of the fee petition submitted by Plaintiffs’ counsel.

15. Despite the demands and challenges, the efforts of Plaintiffs’ counsel produced an

excellent result. Plaintiffs prevailed on all claims in their complaint and helped to established

marriage equality in the Equality State. The lives of the Plaintiffs and thousands of other

families and individuals in Wyoming have been forever altered as a result of the Court’s decision

in this case, recognizing their fundamental rights to due process and equal protection under the

U.S. Constitution.

16. Attorneys and legal assistants at Arnold & Porter maintained detailed time

records. Those records are attached. In addition to myself and Mr. Lyman, Rebecca Golz, a

legal assistant at the firm, has billed time to this matter. These billing records reflect only the

time billed since the Supreme Court’s denial of certiorari in the Kitchen v. Herbert case. None

of the time spent on research, drafting the complaint filed in state court, preparing the motion for

summary judgment filed in state court, or appearing in that venue are part of Arnold & Porter’s

fee petition in this case. All of that time provided a foundation for the work done in federal

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court. Put another way, we would have spent more time researching, drafting, and preparing to

argue in federal court, had we not done the work in state court.

17. Arnold & Porter is requesting to be compensated for 159.90 hours at an aggregate

rate of $257 per hour, which we believe is reasonable within the legal community given the

background, experience, and skill of the lawyers involved. Further, this rate is reasonable given

the exceptionally rare congruence and complexity, risk, and time demands of this case, as well as

the degree of success achieved.

18. This hourly rate is based upon comparable rates typically billed by Wyoming

firms in commercial cases, and what other attorneys with similar skill, reputation, and experience

charge for similar work. In commercial cases, my usual hourly billable rate is $795.00 an hour,

Mr. Lyman’s billable rate was $640.00 per hour, and Ms. Golz’ billable rate is $325.00 per hour.

However, in this case, we have adjusted my hourly billable rate to $325.00, Mr. Lyman’s billable

rate to $262.40, and Ms. Golz’ billable rate to $133.25.

19. Arnold & Porter is seeking a total award in fees of $41,139.62 (See Attachment 3).

Please note this figure does not include the time spent preparing our fee petition. In the event

Defendants dispute Plaintiffs’ fee petition, Plaintiffs’ counsel will submit supplemental time

records, at the appropriate time, for any time incurred after February 1, 2015. These are expenses

that we typically charge to fee-paying clients.

20. In addition to fees, Arnold & Porter seeks to recover $2,775.72 in expenses. This

includes $659.39 for online research; $133.05 for copying; $1,100.00 for filing fees; and,

$628.14 for travel from Denver to Casper for the hearing on the motion for preliminary

injunction.

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

Executed in Denver, Colorado on this 26th day of February, 2015.

Respectfully submitted,

s/ Thomas W. Stoever, Jr.Thomas W. Stoever, Jr.

8


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ATTACHMENT 1


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arnoldporter.com

Thomas W. Stoever, Jr. Partner

Tom Stoever is a partner in Arnold & PorterLLP's Denver office and represents clients incomplex litigation-including environmentalmatters, antitrust cases, consumer classactions, product liability, and commercialcases.

Environmental

Mr. Stoever has represented individuals and corporations inenvironmental litigation in both state and federal courts. He hasdefended clients in Superfund and regulatory actions, citizen suitsunder the Endangered Species Act, Clean Water Act cases, NationalEnvironmental Policy Act (NEPA) litigation, toxic tort cases, andnatural resource damage claims. Mr. Stoever has, in addition,negotiated on behalf of his clients with federal and state agencies fora variety of permits for use of public lands. He has also representedclients in environmental insurance coverage litigation.

Ant i t rust

Mr. Stoever has represented corporations and standard-settingbodies in large, multiparty antitrust matters brought under federaland state competition statutes.

Product Liabi l i ty and Con sum er Class Act ions

Mr. Stoever has represented pharmaceutical manufacturers,consumer product makers, and technology companies inmultijurisdictional product liability and consumer class actionlitigation, managing cases from initiation through discovery and trialin jurisdictions around the country, including several jurisdictionsconsidered particularly hostile for corporate defendants. He has

represented clients at trial and managed large "virtual law firms"comprised of attorneys from firms around the country.

Pro Bono

Mr. Stoever's pro bono practice has focused on litigating claims onbehalf of veterans seeking benefits from the US government. He hasrepresented former service men and women in matters before the

Contact [email protected]

tel: +1 303.863.2328

fax: +1 303.832.0428

Suite 4400370 Seventeenth Street

Denver, CO 80202-1370

Areas of PracticeProduct Liabi lity Litigation

Environmental

Litigation

Legislative and Public Policy

Nanotechnology

Antitrust/Competition

Information Securi ty, ElectronicSurveillance and ComputerCrime

Consumer Products

Political Law, Government Ethics,and Lobbying Compliance

Energy

EducationJD, University of California,

Berkeley School of Law (BoaltHall), 1990

MA, Johns Hopkins School of Advanced International Studies ,1984

BA, Johns Hopkins University,1983

AdmissionsCalifornia

Colorado

Supreme Court of the UnitedStates

Various Federal Courts

Florida


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Thomas W. Stoever, Jr.

Arnold & Porter LLP 2

US Court of Veterans Appeals and the US Court of Appeals for the Federal Circuit, including two enbanc arguments before that court. He was recognized for his work on the Henderson v. Shinseki in the2011 Annual Report for the Veterans Consortium’s Pro Bono Program.

Mr. Stoever also represents a class of landowners in southern Colorado in litigation to obtain theirancestral rights to access large tracts of private land for grazing and timber.

Representative Matters

Representation of the owners of a large power plant in toxic tort litigation brought by neighborsalleging groundwater contamination by coal combustion by-products.

Representation of a consumer product manufacturer in a citizen suit brought pursuant to theEndangered Species Act.

Representation of a transportation company in the negotiation of an Incidental Take Permit andHabitat Conservation Plan under the Endangered Species Act.

Representation of Visa in antitrust litigation brought by American Express, Discover, and a

purported class of merchants.

Representation of a large resort company in permitting for ski areas on National Forest land.

Representation of Wyeth in the diet drug litigation. Responsible for overseeing all aspects ofthousands of cases in 17 states, Mr. Stoever developed and implemented strategies for fact andexpert discovery, the generation of scientific testimony, and the formation and staffing of teamsto prepare and try cases.

Representation of Philip Morris in its litigation with state attorneys general, health insurers, andconsumers in individual and class actions.

Representation of a standard-setting organization in antitrust litigation brought by a

manufacturer.

Representation of clients in large commercial litigation and arbitration.

Representation of investors in an Employee Retirement Income Security Act (ERISA) classaction.

Articles

Thomas W. Stoever, Jr. "Caution! Forest Plan Revisions Ahead" Ski Area Management, July 1,1996

Presentations

Thomas W. Stoever, Jr. "Presentation: Multi-jurisdictional Practice: A Trap for In-houseCounsel," Association of Corporate Counsel, Colorado Chapter, January 2006

Thomas W. Stoever, Jr. "Presentation: Ethical Issues for In-house Counsel in the Wake ofSarbanes Oxley," Association of Corporate Counsel, Colorado Chapter, December 2004

Advisories


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Thomas W. Stoever, Jr.

Arnold & Porter LLP 3

"Reefer Madness - New Treasury Guidance for Banks Providing Financial Services to MarijuanaSellers" Mar. 2014

Multimedia

Daphne O'Connor, Jessica Mayer, Maurice A. Leiter and Thomas W. Stoever, Jr.. "Setting theGoals, Building the Team, Managing the Budget" July 19, 2012.


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ATTACHMENT 2


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arnoldporter.com

L. James Lyman Alumni

James Lyman assists clients at all stages of litigation, including pleading, discovery, trial,and appeal. James' litigation experienceincludes internal investigations and complexmotions practice in matters involving bothstate and federal government agencies,

including matters arising under the False Claims Act and Anti-Kickback Act. James has represented clients in class actions,arbitrations, and other complex litigation matters involving breach of

contract, breach of fiduciary duty, theft of intellectual property, civilfraud, and product liability.

James is an Associate of the American Arbitration Association'sInternational Center for Dispute Resolution Young and InternationalGroup and presents a Continuing Legal Education seminar addressing forum selection clauses and arbitration clauses entitled:"Making it Stick: Choosing a Forum and Staying There."

James served as a judicial clerk for the Honorable Lewis T. Babcockof the United States District Court for the District of Colorado from2007 though 2009. While in law school, James was an editor of the

University of Colorado Law Review. He is the author of "CoalbedMethane: Crafting a Right to Sell from an Obligation to Vent." 78 U.Colo. L. Rev. 613 (2007).

Contact Information

[email protected]

tel: +1 303.863.2381

fax: +1 303.832.0428

Suite 4400370 Seventeenth Street

Denver, CO 80202-1370

Areas of Practice

Litigation

Education

JD, Order of the Coif, Universityof Colorado School of Law, 2007

BA in Communications, summacum laude, University of Colorado, 2004

Admissions

Colorado

US District Court for the Districtof Colorado

US Court of Appeals for theTenth Circuit

US Court of Federal Claims

US Court of Appeals for the

Federal Circuit


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ATTACHMENT 3


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List of Fee and Disbursement Entries

Arnold & Porter LLP

From Transaction Date: 10/6/2014 to Transaction Date: 2/10/2015

National Center for Lesbian Rights

e

Timekeeper (Category)Tran Date Description

Hourly

Rate

Base

Time/Unit Value

Billed

T im e/ Un it Am ou nt Bi ll Nu m Pr eb ill Nu mPrint

Flag

Wyoming Marriage Equality Action

10/06/14

draft

federal complaint and motion for preliminary injunction;

10.90 6,976.00 10.90 0 2713661 Y4261 Lyman, L. James 0.00

10/07/14 Legal Assistant Services for J. Lyman:prepare draft summonses, praecipe for

summons and pro hac vice motion for Guzzo case in federal court.

2.50 812.50 2.50 0 2713661 Y7153 Golz, Rebecca A. 0.00

10/07/14 Draft and revise federal complaint andprepare for filing;

draft

motion for preliminary injunction.

11.40 7,296.00 11.40 0 2713661 Y4261 Lyman, L. James 0.00

10/08/14 Revisions to federal complaint and

preliminary motion;

3.00 2,385.00 3.00 0 2713661 Y4387 Stoever, Thomas W. 0.00

10/08/14 Draft and revise preliminary injunctionmotion;

8.50 5,440.00 8.50 0 2713661 Y4261 Lyman, L. James 0.00

10/08/14 Legal Assistant Services for J. Lyman:

circulate affidavits for reference indraft motion for preliminary injunction;finalize file and serve pro hac vice

motion and motion for preliminaryinjunction.

2.90 942.50 2.90 0 2713661 Y7153 Golz, Rebecca A. 0.00

10/09/14 Revisions to preliminary motion. 1.00 795.00 1.00 0 2713661 Y4387 Stoever, Thomas W. 0.00

10/09/14 Prepare for upcoming

preliminary injunction hearing;

6.30 4,032.00 6.30 0 2713661 Y4261 Lyman, L. James 0.00

10/09/14 Legal Assistant Services for J. Lyman:prepare, file and serve pro hac vice

motion for T. Stoever; preparesubpoena to appear for hearing;prepare waiver and acceptance of

service of subpoena to appear athearing; prepare and submit ECF

registration form.

3.70 1,202.50 3.70 0 2713661 Y7153 Golz, Rebecca A. 0.00

Page: 1


262.40 2,860.16

262.40

262.40

262.40

133.25

133.25

133.25

325.00

325.00

333.13

2,991.36

975.00

2,230.40

386.43

325.00

1,653.12

493.03

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Arnold & Porter LLP



e


Hourly

Rate

Base

Time/Unit Value

Billed


Flag

10/10/14 Legal Assistant Services for J. Lyman:prepare draft pro hac vice motions for

co-counsel.

1.10 357.50 1.10 0 2713661 Y7153 Golz, Rebecca A. 0.00

10/10/14 Prepare for hearing next week in

Casper.


10/10/14 Research and prepare reply to countyresponse in opposition to preliminary

injunction.

3.30 2,112.00 3.30 0 2713661 Y4261 Lyman, L. James 0.00

10/12/14 Revise reply to county response to

motion for preliminary injunction;

.

3.30 2,112.00 3.30 0 2713661 Y4261 Lyman, L. James 0.00

10/13/14 Prepare for preliminary hearing on

Thursday in Casper.


10/13/14prepare for hearing;

research relating to hearing onpreliminary injunction motion.

7.60 4,864.00 7.60 0 2713661 Y4261 Lyman, L. James 0.00

10/14/14 prepare for

upcoming hearing;

10.50 6,720.00 10.50 0 2713661 Y4261 Lyman, L. James 0.00

10/14/14 Prepare for preliminary hearing in

Casper on October 16; revisions topleadings


Page: 2


262.40

262.40

262.40

262.40

133.25

325.00

325.00

325.00

146.58

650.00

865.92

865.92

1,300.00

1,994.24

2,755.20

1,625.00

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Arnold & Porter LLP



e


Hourly

Rate

Base

Time/Unit Value

Billed


Flag


revisedcase files with recent court filings;prepared package to court clerk

.

5.00 1,625.00 5.00 0 2713661 Y7153 Golz, Rebecca A. 0.00

10/15/14 Prepare for hearing on motion for preliminary injunction;


10/15/14 R evise reply in support of motion for

preliminary injunction and prepare for filing; travel to Casper for hearing;

12.00 7,680.00 12.00 0 2713661 Y4261 Lyman, L. James 0.00

10/16/14 Prepare for and argue motion for

preliminary injunction in Casper,Wyoming.


10/16/14 Legal Assistant Services for T.

Stoever: file and serve notice of attorney appearance.

0.50 162.50 0.50 0 2713661 Y7153 Golz, Rebecca A. 0.00

10/16/14 Prepare for and attend hearing onmotion for preliminary injunction;

return travel for hearing.

9.80 6,272.00 9.80 0 2713661 Y4261 Lyman, L. James 0.00

10/17/14

regarding order on motionfor preliminary injunction.

1.40 896.00 1.40 0 2713661 Y4261 Lyman, L. James 0.00

10/17/14 Legal Assistant Services for J. Lyman:review and circulate court order

granting preliminary injunction andtemporary stay of federal case.

0.60 195.00 0.60 0 2713661 Y7153 Golz, Rebecca A. 0.00

Page: 3


262.40

262.40

262.40

133.25

133.25

133.25

325.00

325.00

666.25

1,625.00

3,148.80

2,600.00

66.63

2,571.52

367.36

79.95

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Arnold & Porter LLP



e


Hourly

Rate

Base

Time/Unit Value

Billed


Flag

10/20/14 Attend to calls withopposing counsel regarding entry of

injunction; review state providedmarriage forms and communicationswith county for compliance with

injunction.

2.70 1,728.00 2.70 0 2713661 Y4261 Lyman, L. James 0.00

10/20/14 Correspond with AG's office;correspond with team and clients.

1.00 795.00 1.00 0 2713661 Y4387 Stoever, Thomas W. 0.00


review and update case files withrecent court filings.

0.30 97.50 0.30 0 2713661 Y7153 Golz, Rebecca A. 0.00

10/21/14 calls and emails with

county regarding licenses.

1.60 1,024.00 1.60 0 2713661 Y4261 Lyman, L. James 0.00

10/22/14 Discussion with state regardingstipulation; .

0.40 256.00 0.40 0 2713661 Y4261 Lyman, L. James 0.00

10/23/14 discussions with

county regarding stipulation for permanent injunction.

1.00 640.00 1.00 0 2713661 Y4261 Lyman, L. James 0.00

10/24/14 Revisions to joint stipulation for udgment;

.


10/24/14 Review county answer to complaint in

Guzzo v. Mead; attend to issuesrelating to final settlement of Guzzo v.Mead.

2.20 1,408.00 2.20 0 2713661 Y4261 Lyman, L. James 0.00

10/30/14 Prepare for and attend to call with

state regarding stipulation.

0.70 448.00 0.70 0 2713661 Y4261 Lyman, L. James 0.00

11/05/14 Legal Assistant Services for J. Lyman:prepare and circulate

draft stipulation for permanent injunction.

1.10 357.50 1.10 0 2713661 Y7153 Golz, Rebecca A. 0.00

11/05/14 Work on redrafting the stipulated

udgment.



circulate recent filing from statedefendants regarding pending

deadlines in state court; circulaterecent filing from state defendantsregarding request for judgment on

pleadings in federal court.

0.20 65.00 0.20 0 2713661 Y7153 Golz, Rebecca A. 0.00

11/11/14regarding state's motions

in federal and state cases.

1.80 1,152.00 1.80 0 2713661 Y4261 Lyman, L. James 0.00

Page: 4


262.40

262.40

262.40

262.40

262.40

262.40

262.40

133.25

133.25

133.25

325.00

325.00

325.00

708.48

325.00

39.98

419.84

104.96

262.40

325.00

577.28

183.68

146.58

325.00

26.65

472.32

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Arnold & Porter LLP



e


Hourly

Rate

Base

Time/Unit Value

Billed


Flag

11/13/14 Attend to calls with defendants'

counsel regarding upcoming statusconference.

0.60 384.00 0.60 0 2713661 Y4261 Lyman, L. James 0.00

11/14/14 Revisions to various pleadings; 1.00 795.00 1.00 0 2713661 Y4387 Stoever, Thomas W. 0.00

11/14/14 Prepare for and attend status hearingin Courage v. Wyoming case.

0.50 320.00 0.50 0 2713661 Y4261 Lyman, L. James 0.00


file and serve response to statedefendants' motion for judgment.

0.80 260.00 0.80 0 2713661 Y7153 Golz, Rebecca A. 0.00

11/17/14draft

stipulation; draft response to state

motion for judgment.

2.20 1,408.00 2.20 0 2713661 Y4261 Lyman, L. James 0.00

11/19/14 Draft motion for judgment onpleadings.


11/21/14 Revise motion for judgment on the

pleadings in federal case and draftproposed order.

0.90 576.00 0.90 0 2713661 Y4261 Lyman, L. James 0.00

11/24/14 Legal Assistant Services for T.Stoever: file and serve plaintiffs'

motion for judgment on the pleadings.

1.20 390.00 1.20 0 2713661 Y7153 Golz, Rebecca A. 0.00

11/24/14 Draft proposed order and finalize

motion for judgment for filing.

2.00 1,280.00 2.00 0 2713661 Y4261 Lyman, L. James 0.00

Page: 5


262.40

262.40

262.40

262.40

262.40

133.25

133.25

325.00

325.00

157.44

325.00

131.20

106.60

577.28

325.00

236.16

159.90

524.80

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Arnold & Porter LLP



e


Hourly

Rate

Base

Time/Unit Value

Billed


Flag

12/02/14 Legal Assistant Services for T.Stoever: file and serve plaintiffs'

motion for judgment on the pleadings.

0.90 292.50 0.90 0 2713661 Y7153 Golz, Rebecca A. 0.00

12/08/14 Review state's opposition to judgmenton pleadings and draft reply regarding

same.


12/12/14 Legal Assistant Services for T.

Stoever: assemble exhibits, finalize,file and serve plaintiffs' reply to motionfor judgment on pleadings.

1.70 552.50 1.70 0 2713661 Y7153 Golz, Rebecca A. 0.00

01/05/15 W ork on filings with W yoming District

Court.

1.00 835.00 0 0 Y4387 Stoever, Thomas W. 0.00

Page: 6


133.25

133.25

325.00

325.00

119.93

325.00

226.53

325.00

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Arnold & Porter LLP



e


Hourly

Rate

Base

Time/Unit Value

Billed


Flag

01/29/15 Legal Assistant Services for T.Stoever: circulate court order granting

udgment on pleadings and permanentinjunction as to WY state laws.

0.10 34.00 0 0 Y7153 Golz, Rebecca A. 0.00

01/30/15 Legal Assistant Services for T.Stoever: review state court file

regarding status of case and nextsteps before Judge Campbell.

0.70 238.00 0 0 Y7153 Golz, Rebecca A. 0.00


Page: 7

133.25

133.25

13.33

93.28

Fees Base Fees Billed

Time Value Time Value

159.90 41,139.62

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Arnold & Porter LLP


eTimekeeper (Category)

Tran Date DescriptionHourly

Rate

Base

Time/Unit Value

Billed

T im e/ Un it Am ou nt Bi ll Nu m Pr eb ill Nu mPrintFlag

port Total

Number of Entries Billed ValueDisbursement Category

Westlaw Research 12 579.02147

Other Computer Research 3 80.371501

Travel Expenses 1 62.37151Hotel 2 178.731511

Travel Meals 2 76.80152

Local Transportation 1 310.24153

Duplicating 62 129.60160

Air Delivery Services 7 59.34172

Filing Fees 7 1,100.00187

Color copies 1 3.75194

Depositions & Transcript (original) 1 195.50202

Page: 10


Page: 8

Number of Entries

Disb Base Disb Billed

Unit Value Unit Value

869.00 2,775.72 869.00 2,775.72

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Tracy L. ZubrodZUBROD LAW OFFICE, PC219 East 18th StreetCheyenne, WY 82001Telephone: (307) 778-2557

Facsimile: (307) 778-8225Email: [email protected]

L. James Lyman*Thomas W. Stoever, Jr.ARNOLD & PORTER LLP370 Seventeenth Street, Suite 4400Denver, Colorado 80202-1370Telephone: (303) 863-1000Facsimile: (303) 832-0428Email: [email protected]

Qusair MohamedbhaiRATHOD MOHAMEDBHAI LLC1518 Blake StreetDenver, Colorado 80202Telephone: (303) 578-4400Facsimile: (303) 578-4401Email: [email protected]

Shannon P. Minter*Christopher F. Stoll* NATIONAL CENTER FORLESBIAN RIGHTS870 Market Street, Suite 370San Francisco, CA 94102Telephone: (415) 365-1335Facsimile: (415) 392-8442Email: [email protected]

Attorneys for Plaintiffs

*Admission Pro Hac Vice


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1

U NITED STATES DISTRICT COURT DISTRICT OF WYOMING

Anne Marie Guzzo and Bonnie Robinson; IvanWilliams and Charles Killion; Brie Barth and ShellyMontgomery; Carl Oleson and Rob Johnston; andWyoming Equality,

Plaintiff(s),

v. Case Number: 2:14-cv-00200-SWS

Matthew H. Mead, in his official capacity as theGovernor of Wyoming; Dean Fausset, in his official

capacity as Director of the Wyoming Department ofAdministration and Information; Dave Urquidez, in hisofficial capacity as Administrator of the State ofWyoming Human Resources Division; and Debra K.Lathrop, in her official capacity as Laramie CountyCl

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