2:14-cv-00200 #70

Case 2:14-cv-00200-SWS Document 70 Filed 02/26/15 Page 1 of 13
Tracy L. Zubrod
ZUBROD LAW OFFICE, PC
219 East 18th Street
Cheyenne, WY 82001
Telephone: (307) 778-2557
Facsimile: (307) 778-8225
Email: zubrod@aol.com
Thomas W. Stoever, Jr.
ARNOLD & PORTER LLP
370 Seventeenth Street, Suite 4400
Denver, Colorado 80202-1370
Telephone: (303) 863-1000
Facsimile: (303) 832-0428
Email: thomas.stoever@aporter.com
Qusair Mohamedbhai
Arash Jahanian
RATHOD MOHAMEDBHAI LLC
2701 Lawrence Street, Suite 100
Denver, CO 80205
Telephone: (303) 578-4400
Facsimile: (303) 578-4401
Email: qm@rmlawyers.com
Shannon P. Minter
Christopher F. Stoll
NATIONAL CENTER FOR
LESBIAN RIGHTS
870 Market Street, Suite 370
San Francisco, CA 94102
Telephone: (415) 365-1335
Facsimile: (415) 392-8442
Email: sminter@nclrights.org
Attorneys for Plaintiffs
UNITED STATES DISTRICT COURT

DISTRICT OF WYOMING
)
)
)
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,
)
______________________________________________________________________________
Plaintiffs,
MEMORANUDUM IN SUPPORT OF
PLAINTIFFS MOTION FOR ATTORNEYS FEES AND COSTS
______________________________________________________________________________
INTRODUCTION
On January 29, 2015, the Court awarded Plaintiffs the permanent declaratory and
injunctive relief they had sought when they first availed themselves of the federal courts three
and a half months prior. The Court declared that to deny Plaintiffs the right to marry and remain
married violated the U.S. Constitutions Due Process and Equal Protection Clauses, and it
enjoined Defendants from carrying out and enforcing the laws and practices that violated these
rights. As prevailing parties in this civil rights action, Plaintiffs are entitled to reasonable fees
and costs under 42 U.S.C. 1988. Plaintiffs quickly achieved a high level of success in this case
involving significant constitutional issues. Plaintiffs counsel worked efficiently and without
duplication, have not submitted hours for their underlying work done on the related state case,
and have reduced their rates to reflect this legal market. Accordingly, the fees and costs that
Plaintiffs ask the State Defendants to pay are reasonable.
ARGUMENT
In an action brought under 42 U.S.C. 1983, the court, in its discretion, may allow the
prevailing party . . . a reasonable attorneys fee as part of the costs . . . . 42 U.S.C. 1988(b).
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 claimants fee request is reasonable.
Robinson v. City of Edmond, 160 F.3d 1275, 1980 (10th Cir. 1998). The prevailing party in a
1983 lawsuit is entitled to reasonable attorneys fees unless special circumstances would render
such an award unjust. Hensley v. Eckerhart, 461 U.S. 424, 429 (1983). Where a plaintiff has
obtained excellent results, his attorney should recover a fully compensatory fee. Id. at 435.
Plaintiffs are prevailing parties who are making a reasonable request.1
I.
Plaintiffs Are the Prevailing Parties in This Case

First, Plaintiffs are the prevailing parties in this case. Under [the Supreme Courts]
generous formulation of the term, plaintiffs may be considered prevailing parties for attorneys
fees purposes if they succeed on any significant issue in litigation which achieves some of the
benefit the parties sought in bringing suit. Farrar v. Hobby, 506 U.S. 103, 109 (1992) (internal
quotations omitted). The Supreme Court has repeatedly held that an injunction or declaratory
Plaintiffs counsel will file a supplemental application for additional fees incurred in
connection with any other work necessary to secure reasonable attorneys fees and costs in this
matter. See, e.g., Hernandez v. George, 793 F.2d 264, 269 (10th Cir. 1986) ([T]his court
generally allows recovery of fees for attorneys work in seeking attorneys fees . . . . [W]ork in
resolving the fee issue furthers the purpose behind the fee authorization in 1988 which is to
encourage attorneys . . . in vindicating federal civil rights policies.) (citations omitted).
1
judgment, like a damages award, will usually satisfy that test. Id. (citing Rhodes v. Stewart, 488
U.S. 1, 4 (1988) (per curiam)). Plaintiffs are the prevailing parties in this action because they
obtained an enforceable judgment against Defendants for injunctive and declaratory relief. On
January 29, 2014, the Court issued judgment with declaratory and injunctive relief in favor of
Plaintiffs and against Defendants on all of Plaintiffs claims. Doc. 65 at 2.
II.
Plaintiffs Are Entitled to Full Award of their Requested Fees

Second, the fees that Plaintiffs have submitted in this case are reasonable. A court will
generally determine what fee is reasonable by first calculating the lodestarthe total number of
hours reasonably expended multiplied by a reasonable hourly rateand then adjust the lodestar
upward or downward to account for the particularities of the suit and its outcome. Phelps v.
Hamilton, 120 F.3d 1126, 1131 (10th Cir. 1997) (citing Hensley, 461 U.S. at 43334). Plaintiffs
are requesting the lodestar, without any upward adjustment.
A.
Summary of Plaintiffs Counsels Hours and Rates
Plaintiffs are requesting that the State Defendants pay a total attorney fee of $92,728.12.
The breakdown by law firm is as follows: Arnold & Porter LLP $41,139.62, National Center for
Lesbian Rights $20,562.50, Rathod Mohamedbhai LLC $22,600.00, and Zubrod Law Office, PC
$8,426.00. These amounts are supported by the attached declarations of counsel, curricula vitae,
and time sheets including specific descriptions and time spent on tasks performed. Ex. 1,
Declaration of Thomas Stoever with Attached Bios and Billing Statements; Ex. 2, Declaration of
Shannon Minter with Attached Resumes and Billing Statements; Ex. 3, Declaration of Qusair
Mohamedbhai with Attached Bios and Billing Statements; Ex. 4, Declaration of Tracy Zubrod
with Attached Billing Statement; Ex. 5, Declaration of Bruce Moats with Attached Wyoming Bar
Survey. The summary of the fees requested is as follows:
Employee
Thomas Stoever
Shannon Minter
Christopher Stoll
Qusair Mohamedbhai
Amy Whelan
James Lyman
Tracy Zubrod
Arash Jahanian
Aaron Belzer
Rebecca Golz (paralegal)
Firm
Arnold & Porter LLP
National Center for Lesbian Rights
Rathod Mohamedbhai LLC
Arnold & Porter LLP
Zubrod Law Office, PC
Arnold & Porter LLP
TOTAL
Rate
$325
$325
$300
$300
$275
$262.40
$220
$200
$140
$133.25
Hours
35
19.8
42.6
21.9
4.9
101.6
38.3
70.7
13.5
23.3
371.6
Total Fee
$11,375
$6,435.00
$12,780.00
$6,570.00
$1,347.50
$26,659.84
$8,426.00
$14,140.00
$1,890.00
$3,104.73
$92,728.12
B. Plaintiffs Hours Are Reasonable

The first step in calculating fee awards is to determine the number of hours reasonably
spent by counsel for the party seeking the fees. Ramos v. Lamm, 713 F.2d 546, 553 (10th Cir.
1983). Evaluation of the reasonableness of a prevailing partys attorneys hours involves a
number of factors, several of which are analyzed in detail below. See Robinson, 106 F.3d at
1281; Ramos, 713 F.2d at 554.
1. Plaintiffs Counsel Are Entitled to a Fully Compensatory Fee
[T]he most critical factor in determining the reasonableness of a fee award is the
degree of success obtained. Farrar v. Hobby, 506 U.S. 103, 114 (1992) (quoting Hensley, 461
U.S. at 436). The Supreme Court has guided: [T]he district court should focus on the
significance of the overall relief obtained by the Plaintiffs in relation to the hours reasonably
expended on the litigation. Riverside v. Rivera, 477 U.S. 561, 569 (1986) (quoting Hensley,
461 U.S. at 435 (alterations in original)). Here, the Court has awarded Plaintiffs all the relief
they have sought in their complaint, namely, declarations that Defendants failure to grant and
recognize their marriages violated the Equal Protection and Due Process Clauses of the U.S.
Constitution, and injunctive relief prohibiting Defendants from continuing and enforcing these
discriminatory practices. See Compl. (Doc. 1) at 21; J. (Doc. 65) at 2-3. Along the way,
5
Plaintiffs prevailed in their motion for preliminary injunction and motion for judgment on the
pleadings. See Doc. 44, 65. Accordingly, the reasonableness of the hours expended by
Plaintiffs counsel is reflected in the high level of success they have achieved.
2. The Importance of This Case Necessitated the Hours and Fees Incurred
Another factor supporting the reasonableness of Plaintiffs hours is the overall public
interest served by Plaintiffs victory in this litigation. See, e.g., Ex. 1, Stover Decl. 15; Ex. 4,
Zubrod Decl. 14. The significance of the relief obtained is evident [p]articularly in civil rights
cases such as this . . . . Joseph A. by Wolfe v. New Mexico Dept of Human Servs., 28 F.3d
1056, 1060 (10th Cir. 1994). After all, [u]nlike most private tort litigants, a civil rights plaintiff
seeks to vindicate important civil and constitutional rights that cannot be valued solely in
monetary terms. Rivera, 477 U.S. at 574. Potential liability for full fee awards can deter
violations of the civil rights laws, especially in situations where the fee award represents a
significant portion of a defendants financial exposure. Ramos, 713 F.2d at 552. This case
affects the fundamental constitutional rights of many Wyoming citizens. As reflected in the
judgment of this Court, those who wish to marry a person of the same sex have a fundamental
right to do so, and that fundamental right is protected by the Due Process and Equal Protection
Clauses of the United States Constitution. Doc. 65 at 2.
3. Plaintiffs Expedited These Proceedings as Much as Possible, Achieving
Complete Success in a Very Short Timeframe
[W]hen examining an attorneys fee claim, the district court should examine the hours
spent on each task to determine the reasonableness of the hours reported. Shaw v. AAA Engg
& Drafting, Inc., 213 F.3d 538, 542 (10th Cir. 2000) (internal citation omitted). Plaintiffs
counsels work on this case was extremely efficient and streamlined. Plaintiffs achieved
complete success in a case of significant constitutional magnitude in only three and a half
months. During the evidentiary hearing on Plaintiffs motion for preliminary injunction, which
lasted approximately one hour, Plaintiffs made their presentation in the most expeditious manner
possible. See Doc. 43. The only live testimony presented was that of Defendant Lathrop, and
Plaintiffs presented their testimony through affidavits already submitted to the Court rather than
testifying live. Once the Court granted a preliminary injunction in favor of Plaintiffs, the only
issue that required the Courts determination was the form of the judgment.
4. Plaintiffs Counsel Diligently Minimized Attorney Time
Another factor the court should examine in determining the reasonableness of hours
expended is the potential for duplication of services. Ramos, 713 F.2d at 554. As shown in the
attached affidavits and curricula vitae, each of the Plaintiffs attorneys has unique skills, which
created an efficient and complementary legal team. Each attorney played a specific role. Arnold
& Porter took the lead, with the bulk of hours worked by associate James Lyman, and in large
part tasked out the other attorneys. See Ex. 2, Minter Decl. 14-5; Ex. 3, Mohamedbhai Decl.
15; Ex. 4, Zubrod Decl. 11. For the most part, the National Center for Lesbian Rights
provided expertise in marriage equality cases, Ms. Zubrod served as local counsel, and Rathod
Mohamedbhai added expertise in civil rights litigation, including in Wyoming. Moreover,
because NCLR litigated Kitchen v. Herbert, 755 F.3d 1193 (10th Cir. 2014), and other marriage
cases around the country, Plaintiffs attorneys were able to efficiently use legal research and
briefing from those cases where relevant and applicable, thereby reducing the overall hours
dedicated to the case. Ex. 2, Minter Decl. 13.
5. Plaintiffs Counsel Have Exercised Billing Judgment to Exclude Unnecessary
Hours Related to the Parallel State Court Proceeding
In evaluating a fee request, [t]he district court must determine not just the actual hours
expended by counsel, but which of those hours were reasonably expended in the litigation.
Ramos, 713 F.2d at 553. In exercising billing judgment, [t]he prevailing party must make a
good-faith effort to exclude from a fee request hours that are excessive, redundant, and
otherwise unnecessary. Jane L. v. Bangerter, 61 F.3d 1505, 1510 (10th Cir. 1995) (quoting
Hensley, 461 U.S. at 434). Most significantly, though much of the work underlying this case
was done in connection with the related state court case, Courage v. Wyoming, et al., Plaintiffs
counsel have not submitted any of those fees. See Ex. 1, Stoever Decl. 16; Ex. 3,
Mohamedbhai Decl. 18. The Supreme Court has held that fees may be granted for some of
the services performed before a lawsuit is formally commenced by the filing of the complaint . .
. . if they are both useful and of a type ordinarily necessary to advance the litigation in
question. Ray Haluch Gravel Co. v. Cent. Pension Fund of Int'l Union of Operating Engineers
& Participating Employers, 134 S. Ct. 773, 783 (2014) (quoting Webb v. Dyer County Board of
Education, 471 U.S. 234, 243 (1985)). Other federal courts have applied the majority opinion
in Webb . . . to allow for partial fee awards for work done in proceedings ancillary to a 1983
action. Schneider v. Colegio de Abogados de Puerto Rico, 187 F.3d 30, 46 n. 29 (1st Cir. 1999)
(listing cases). Courage involved essentially identical parties and similar legal theories.
Plaintiffs briefed the merits of their position in a motion for summary judgment, and the parties
engaged in discovery. The affidavits that this Court considered in granting Plaintiffs motion for
preliminary injunction had been gathered in connection with the motion for summary judgment
in the Courage litigation. Accordingly, there is a significant amount of work that advanced this
litigation that Plaintiffs have not submitted as recoverable fees.
6. The State Defendants Unreasonable Opposition to Plaintiffs Position
Necessitated the Hours Plaintiffs Counsel Spent on This Case
The Supreme Court has . . . recognized that part of an attorneys calculus of the amount
of time reasonably necessary for a case is the vigor which the opponents bring to the dispute.
Robinson, 160 F.3d at 1284. A client cannot escape the consequences of tactics that undeniably
drive up the costs of litigation, even if such tactics amount to no more than aggressive
advocacy. Latham v. First Marine Ins. Co., 16 F. Appx 834, 839 (10th Cir. 2001); see also
Robinson, 160 F.3d at 1284 (The government cannot litigate tenaciously and then be heard to
complain about the time necessarily spent by the Plaintiffs in response. (internal citations and
quotations omitted)).
Standing on its own, the State Defendants refusal to concede the blatant
unconstitutionality of their laws and practices in the face of binding law is enough to warrant a
significant fee award. See, e.g., Ramos, 713 F.2d at 556 ([H]ad the state defendants not decided
to stonewall on all issues, . . . this case would have a different posture.). Rather, they defended
an untenable position with no fewer than four attorneys. See Ex. 1, Stoever Decl. 14; Ex. 3,
Mohamedbhai Decl. 17. In opposing Plaintiffs motion for preliminary injunction, the State
Defendants conceded that Plaintiffs may ultimately succeed on the merits before this Court in
the present case, but took the position of disagreeing with the binding Tenth Circuit decisions in
Kitchen and Bishop. Doc. 26 at 6. They conceded that Plaintiffs suffered irreparable
constitutional harm as a matter of law, yet contended that they had a right to continue defending
and enforcing unconstitutional laws and practices. They advanced the delay tactic of asking the
Court a reasonable opportunity to evaluate and respond to Plaintiffs newly raised allegations.
Id. at 7. The Court rejected these unjustified yet persistent defenses, and, as the State Defendants
predicted, Plaintiffs prevailed on all issues. Furthermore, rather than stipulating to a judgment
that was supported by the law and facts of this case, Defendants filed their own motion for
judgment on the pleadings, based on positions that were once again rejected by the Court. Thus,
in contrast to Defendant Lathrop, who cooperated with Plaintiffs and assisted the minimization
of fees incurred, the State Defendants unnecessarily prolonged this case and should have to pay
Plaintiffs fees and costs as a result.
C. Plaintiffs Counsels Rates Are Reasonable
Plaintiffs have submitted rates for their attorneys that are reasonable and reflective of the
legal market in which this Court sits. The first step in setting a rate of compensation for the
hours reasonably expended is to determine what lawyers of comparable skill and experience
practicing in the area in which the litigation occurs would charge for their time. Ramos, 713
F.2d at 555; see also Jane L., 61 F.3d at 1510 (Hourly rates must reflect the prevailing market
rates in the relevant community. (quoting Blum v. Stenson, 465 U.S. 886, 895 (1984)). In
addition, [t]he hourly rate should be based on the lawyers skill and experience in civil rights or
analogous litigation. Ramos, 713 F.2d at 555. The rates for Plaintiffs counsel are supported by
the declaration of Bruce Moats, an 18-year Wyoming civil rights and constitutional lawyer, who
relies on his extensive experience as well as survey results of the Wyoming State Bar. Ex. 5.
Although Plaintiffs counsel could request San Francisco and Denver billing rates for this
case based on their expertise and experience, see, e.g., Reazin v. Blue Cross and Blue Shield of
Kan., Inc., 899 F.2d 951, 983 (10th Cir. 1990) (affirming district courts award of higher rates
for out-of-state counsel based on their expertise and experience); Rocky Mtn. Christian Church v.
Bd. of Cnty. Commrs of Boulder Cnty., No. 06-CV-00554, 2010 WL 3703224, at *5 (D. Colo.
Sept. 13, 2010) (awarding higher hourly rates for attorney with specialized knowledge and
skills in the areas of constitutional law.), they seek rates consistent with those in the Wyoming
legal market as an exercise of billing judgment. Plaintiffs counsel have appropriately reduced
their out-of-market rates: Mr. Stoever from $795 to $325, Mr. Lyman from $640 to 262.40, and
Ms. Golz from $325 to $133.25, Ex. 1, Stoever Decl. 18; Mr. Minter from $675 to $325, Mr.
10
Stoll from $650 to $300, and Mrs. Whelan from $500 to $275, Ex. 2, Minter Decl. 18; Mr.
Mohamedbhai from $450 to $300, Mr. Jahanian from $325 to $200, and Mr. Belzer from $175 to
$140. Ex. 3, Mohamedbhai Decl. 7-9. Ms. Zubrod, who practices in Cheyenne, has
submitted her regular rate of $220. Ex. 4, Zubrod Decl. 10. Accordingly, Plaintiffs counsels
rates are exceeding reasonable.
III.
Plaintiffs Are Entitled to Recovery of Their Costs

Plaintiffs are also entitled to an award of expenses that would normally be billed to fee-
paying clients, pursuant to 42 U.S.C. 1988(b) and Federal Rule of Civil Procedure 54(d). As
detailed in the declarations of counsel, Plaintiffs incurred and are entitled to total costs of
$5,125.97 in this litigation. All of those costs were necessary to the litigation, including the
travel expenses associated with the preliminary injunction hearing. See Bee v. Greaves, 910 F.2d
686, 690 (10th Cir. 1990) (attorneys reasonable travel expenses should be awarded if normally
billed to private clients); Ginest v. Bd. of Cnty. Commrs of Carbon Cnty., Wyo., 423 F.Supp.2d
1237, 1240-42 (D. Wyo. 2006) (awarding out-of-state counsel reasonable hours and expenses
associated with travel to Wyoming). A Bill of Costs is being filed concurrently for statutory
costs, which comprise $1,651.45 out of the $5,125.97 in total recoverable costs.
IV.
Plaintiffs Are Entitled to Interest on the Judgment

Plaintiffs request that the Court order that the prevailing interest rate apply to any award
from the date of the Courts order awarding reasonable attorneys fees and costs. See Dill v. City
of Edmond, 72 F. Appx 753, 758 (10th Cir. 2003).
V.
Plaintiffs Have Consulted with Counsel for All Defendants

Pursuant to Local Rule 54.3(a), Plaintiffs state that they have consulted with counsel for
the State Defendants on multiple occasions in an attempt to reach an agreement regarding
11
attorneys fees and costs. At the request of State Defendants counsel, Plaintiffs counsel sent
their invoices on February 11, 2015. Plaintiffs obtained a two-week extension to file this motion
so that the parties could continue to negotiate. After numerous failed attempts at communication
since the extension was granted, the State Defendants counsel advised Plaintiffs counsel on
February 24 and 25, 2015 that due to their schedules they had not the opportunity to review the
invoices, and that Plaintiffs should file this Motion. The parties will continue to attempt to reach
a resolution. On February 26, 2015, counsel for Defendant Lathrop indicated that she takes no
position on the relief requested in this Motion.
DATED: February 26, 2015.
Respectfully submitted,
s/ Arash Jahanian
Arash Jahanian
Qusair Mohamedbhai
Denver, CO 80205
Telephone: (303) 578-4400
Facsimile: (303) 578-4401
Email: aj@rmlawyers.com
ARNOLD & PORTER LLP
Telephone: (303) 863-1000
Facsimile: (303) 832-0428
Tracy L. Zubrod
Cheyenne, WY 82001
Telephone: (307) 778-2557
Facsimile: (307) 778-8225
12
Shannon P. Minter
NATIONAL CENTER FOR
LESBIAN RIGHTS
Telephone: (415) 365-1335
Facsimile: (415) 392-8442
CERTIFICATE OF SERVICE
This is to certify that a copy of the foregoing has been filed with the Clerk of Court on
this 26th day of February, 2015 and served upon the following:
Peter K. Michael,
Attorney General of Wyoming
Martin L. Hardsocg,
Deputy Attorney General
James C. Kaste,
Deputy Attorney General
Jared S. Crecelius,
Senior Assistant Attorney General
Ryan T. Schelhaas,
Michael M. Robinson,
123 State Capitol Building
Cheyenne, WY 82002
Mark Towne Voss

Bernard P Haggerty
310 W. 19th Street, Suite 320
Cheyenne, WY 82001
Attorneys for the Laramie County Clerk
Attorneys for the State Defendants
s/ Arash Jahanian
Arash Jahanian
13
Case 2:14-cv-00200-SWS Document 70-1 Filed 02/26/15 Page 1 of 23
Tracy L. Zubrod
Cheyenne, WY 82001
Telephone: (307) 778-2557
Facsimile: (307) 778-8225
ARNOLD & PORTER LLP
Telephone: (303) 863-1000
Facsimile: (303) 832-0428
Qusair Mohamedbhai
Arash Jahanian
Denver, CO 80205
Telephone: (303) 578-4400
Facsimile: (303) 578-4401
Shannon P. Minter
NATIONAL CENTER FOR
LESBIAN RIGHTS
Telephone: (415) 365-1335
Facsimile: (415) 392-8442

DISTRICT OF WYOMING
)
)
)
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
)
)
)
official capacity as Administrator of the State of Wyoming
)
Human Resources Division; and Debra K. Lathrop, in her
)
official capacity as Laramie County Clerk,
)
_____________________________________________________________________________
Plaintiffs,
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
& Burling in Washington, D.C. In 1994, I moved from Covington & Burling to Arnold &
Porters 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 firms 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
the Tenth Circuit, the Court of Federal Claims, and the Court of Appeals for the Federal Circuit.
Mr. Lymans 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
Wyomings 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 Wyomings
constitution prohibited the application of Wyomings statute defining marriage as a union
between one man and one woman. At the Governors request, a hearing on that motion for
summary judgment was delayed so the parties could take discovery.
8.
While that discovery was ongoing, the Supreme Court denied certiorari in Kitchen
v. Herbert. Immediately after the Supreme Courts 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 teams 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.
Plaintiffs 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 Courts order issuing a preliminary
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 Governors staffing decisions in this case are a further
reflection of its significance and complexity. The Court should consider the Governors 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 Courts 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 Courts 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 & Porters
fee petition in this case. All of that time provided a foundation for the work done in federal
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. Lymans 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. Lymans 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.
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.
ATTACHMENT 1

Partner
Tom Stoever is a partner in Arnold & Porter
LLP's Denver office and represents clients in
complex litigation-including environmental
matters, antitrust cases, consumer class
actions, product liability, and commercial
cases.
Environmental
Mr. Stoever has represented individuals and corporations in
environmental litigation in both state and federal courts. He has
defended clients in Superfund and regulatory actions, citizen suits
under the Endangered Species Act, Clean Water Act cases, National
Environmental Policy Act (NEPA) litigation, toxic tort cases, and
natural resource damage claims. Mr. Stoever has, in addition,
negotiated on behalf of his clients with federal and state agencies for
a variety of permits for use of public lands. He has also represented
clients in environmental insurance coverage litigation.
Antitrust
Mr. Stoever has represented corporations and standard-setting
bodies in large, multiparty antitrust matters brought under federal
and state competition statutes.
Product Liability and Consumer Class Actions
Mr. Stoever has represented pharmaceutical manufacturers,
consumer product makers, and technology companies in
multijurisdictional product liability and consumer class action
litigation, managing cases from initiation through discovery and trial
in jurisdictions around the country, including several jurisdictions
considered 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 on
behalf of veterans seeking benefits from the US government. He has
represented former service men and women in matters before the
arnoldporter.com
Contact Information
Thomas.Stoever@aporter.com
tel: +1 303.863.2328
fax: +1 303.832.0428
Suite 4400
370 Seventeenth Street
Denver, CO 80202-1370
Areas of Practice
Product Liability Litigation
Environmental
Litigation
Legislative and Public Policy
Nanotechnology
Antitrust/Competition
Information Security, Electronic
Surveillance and Computer
Crime
Consumer Products
Political Law, Government Ethics,
and Lobbying Compliance
Energy
Education
JD, University of California,
Berkeley School of Law (Boalt
Hall), 1990
MA, Johns Hopkins School of
Advanced International Studies,
1984
BA, Johns Hopkins University,
1983
Admissions
California
Colorado
Supreme Court of the United
States
Various Federal Courts
Florida
US Court of Veterans Appeals and the US Court of Appeals for the Federal Circuit, including two en
banc arguments before that court. He was recognized for his work on the Henderson v. Shinseki in the
2011 Annual Report for the Veterans Consortiums Pro Bono Program.
Mr. Stoever also represents a class of landowners in southern Colorado in litigation to obtain their
ancestral 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 neighbors
alleging groundwater contamination by coal combustion by-products.
Representation of a consumer product manufacturer in a citizen suit brought pursuant to the

Endangered Species Act.
Representation of a transportation company in the negotiation of an Incidental Take Permit and

Habitat 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 of
thousands of cases in 17 states, Mr. Stoever developed and implemented strategies for fact and
expert discovery, the generation of scientific testimony, and the formation and staffing of teams
to prepare and try cases.
Representation of Philip Morris in its litigation with state attorneys general, health insurers, and
consumers 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) class

action.
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-house

Counsel," Association of Corporate Counsel, Colorado Chapter, January 2006
Thomas W. Stoever, Jr. "Presentation: Ethical Issues for In-house Counsel in the Wake of
Sarbanes Oxley," Association of Corporate Counsel, Colorado Chapter, December 2004
Advisories

Arnold & Porter LLP 2
"Reefer Madness - New Treasury Guidance for Banks Providing Financial Services to Marijuana
Sellers" Mar. 2014
Multimedia
Daphne O'Connor, Jessica Mayer, Maurice A. Leiter and Thomas W. Stoever, Jr.. "Setting the
Goals, Building the Team, Managing the Budget" July 19, 2012.

Arnold & Porter LLP 3
ATTACHMENT 2
L. James Lyman
Alumni
James Lyman assists clients at all stages of
litigation, including pleading, discovery, trial,
and appeal. James' litigation experience
includes internal investigations and complex
motions practice in matters involving both
state and federal government agencies,
including matters arising under the False Claims Act and AntiKickback 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, civil
fraud, and product liability.
James is an Associate of the American Arbitration Association's
International Center for Dispute Resolution Young and International
Group 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. Babcock
of the United States District Court for the District of Colorado from
2007 though 2009. While in law school, James was an editor of the
University of Colorado Law Review. He is the author of "Coalbed
Methane: Crafting a Right to Sell from an Obligation to Vent." 78 U.
Colo. L. Rev. 613 (2007).
arnoldporter.com
Contact Information
James.Lyman@APORTER.COM
tel: +1 303.863.2381
fax: +1 303.832.0428
Suite 4400
370 Seventeenth Street
Denver, CO 80202-1370
Areas of Practice
Litigation
Education
JD, Order of the Coif, University
of Colorado School of Law, 2007
BA in Communications, summa
cum laude, University of
Colorado, 2004
Admissions
Colorado
US District Court for the District
of Colorado
US Court of Appeals for the
Tenth Circuit
US Court of Federal Claims
US Court of Appeals for the
Federal Circuit
ATTACHMENT 3
Arnold & Porter LLP
List of Fee and Disbursement

Entries
Case 2:14-cv-00200-SWS
Document
70-1 Filed 02/26/15 Page 16 of 23
From Transaction Date: 10/6/2014 to Transaction Date: 2/10/2015
0091738

Base
Control
Group Line
Timekeeper (Category)
00004
32419968
Tran Date
Description
Billed
Hourly
Rate
Time/Unit
Value
Time/Unit
0.00
262.40
10.90
6,976.00
2,860.16
10.90
Prebill Num
Print
Flag
2713661
Amount Bill Num
Wyoming Marriage Equality Action

4261
Lyman, L. James
10/06/14
draft
federal complaint and motion for
preliminary injunction;
32422624
7153
Golz, Rebecca A.
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.
0.00
133.25
2.50
333.13
812.50
2.50
2713661
32419969
4261
Lyman, L. James
10/07/14
Draft and revise federal complaint and

prepare for filing;
0.00
262.40
11.40
2,991.36
7,296.00
11.40
2713661
draft
motion for preliminary injunction.
34932976
4387
Stoever, Thomas W.
10/08/14
Revisions to federal complaint and

preliminary motion;
0.00
325.00
3.00
975.00
2,385.00
3.00
2713661
32427295
4261
Lyman, L. James
10/08/14
Draft and revise preliminary injunction

motion;
0.00
262.40
8.50
5,440.00
2,230.40
8.50
2713661
32422585
7153
Golz, Rebecca A.
10/08/14
133.25
0.00
2.90
386.43
942.50
2.90
2713661
34932984
4387
Stoever, Thomas W.
10/09/14

circulate affidavits for reference in
draft motion for preliminary injunction;
finalize file and serve pro hac vice
motion and motion for preliminary
injunction.
Revisions to preliminary motion.
0.00
325.00
1.00
325.00
795.00
1.00
2713661
32427297
4261
Lyman, L. James
10/09/14
Prepare
for upcoming
preliminary injunction hearing;
0.00
262.40
6.30
1,653.12
4,032.00
6.30
2713661
32422503
7153
Golz, Rebecca A.
10/09/14

prepare, file and serve pro hac vice
motion for T. Stoever; prepare
subpoena to appear for hearing;
prepare waiver and acceptance of
service of subpoena to appear at
hearing; prepare and submit ECF
registration form.
0.00
133.25
3.70
1,202.50
493.03
3.70
2713661
Page: 1
0091738
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Group Line
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Entries
Document
70-1 Filed 02/26/15 Page 17 of 23

Base
Prebill Num
Print
Flag
2713661
2.00
2713661
2,112.00
865.92
3.30
2713661
3.30
865.92
2,112.00
3.30
2713661
0.00
325.00
4.00
1,300.00
3,180.00
4.00
2713661
0.00
262.40
7.60
1,994.24
4,864.00
7.60
2713661
262.40
0.00
10.50
2,755.20
6,720.00
10.50
2713661
0.00
325.00
5.00
1,625.00
3,975.00
5.00
2713661
Description
prepare draft pro hac vice motions for
co-counsel.
Prepare for hearing next week in
Casper.
0.00
133.25
1.10
146.58
357.50
1.10
0.00
325.00
2.00
650.00
1,590.00
Research and prepare reply to county

response in opposition to preliminary
injunction.
Revise reply to county response to
motion for preliminary injunction;
0.00
262.40
3.30
0.00
262.40
7153
Golz, Rebecca A.
10/10/14
34933062
4387
Stoever, Thomas W.
10/10/14
32427345
4261
Lyman, L. James
10/10/14
32427303
4261
Lyman, L. James
10/12/14
Time/Unit
Value
Time/Unit
Amount Bill Num
34933179
4387
Stoever, Thomas W.
10/13/14
34930515
4261
Lyman, L. James
10/13/14
34934614
Billed
Tran Date
34934578
34938704
Hourly
Rate
Prepare for preliminary hearing on

Thursday in Casper.
prepare for hearing;
research relating to hearing on

preliminary injunction motion.
4261
Lyman, L. James
10/14/14
prepare for
upcoming hearing;
4387
Stoever, Thomas W.
10/14/14
Prepare for preliminary hearing in

Casper on October 16; revisions to
pleadings
Page: 2
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Arnold & Porter LLP

Entries
Document
70-1 Filed 02/26/15 Page 18 of 23

Base
7153
Golz, Rebecca A.
Billed
Tran Date
Description
Hourly
Rate
10/15/14
0.00
133.25
5.00
1,625.00
666.25
5.00
Time/Unit
Value
Time/Unit
Prebill Num
Print
Flag
2713661
Amount Bill Num
revised
case files with recent court filings;
prepared package to court clerk
.
34949615
4387
Stoever, Thomas W.
10/15/14
Prepare for hearing on motion for

325.00
0.00
5.00
1,625.00
3,975.00
5.00
2713661
34938705
4261
Lyman, L. James
10/15/14
Revise reply in support of motion for

preliminary injunction and prepare for
filing; travel to Casper for hearing;
0.00
262.40
12.00
7,680.00
3,148.80
12.00
2713661
34949624
4387
Stoever, Thomas W.
10/16/14
0.00
325.00
8.00
2,600.00
6,360.00
8.00
2713661
34943790
7153
Golz, Rebecca A.
10/16/14
0.00
133.25
0.50
162.50
66.63
0.50
2713661
34943401
4261
Lyman, L. James
10/16/14
Prepare for and argue motion for

preliminary injunction in Casper,
Wyoming.
Legal Assistant Services for T.
Stoever: file and serve notice of
attorney appearance.
Prepare for and attend hearing on
motion for preliminary injunction;
return travel for hearing.
0.00
262.40
9.80
6,272.00
2,571.52
9.80
2713661
34943992
4261
Lyman, L. James
10/17/14
262.40
0.00
1.40
367.36
896.00
1.40
2713661
0.00
133.25
0.60
195.00
79.95
0.60
2713661
34943899
7153
Golz, Rebecca A.
10/17/14
regarding order on motion

for preliminary injunction.
review and circulate court order
granting preliminary injunction and
temporary stay of federal case.
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Entries
Document
70-1 Filed 02/26/15 Page 19 of 23

Base
Hourly
Rate
Billed
Prebill Num
Print
Flag
2713661
1.00
2713661
97.50
39.98
0.30
2713661
1.60
419.84
1,024.00
1.60
2713661
Tran Date
Description
Time/Unit
Value
Time/Unit
Attend to calls with

opposing counsel regarding entry of
injunction; review state provided
marriage forms and communications
with county for compliance with
injunction.
Correspond with AG's office;
correspond with team and clients.
0.00
262.40
2.70
1,728.00
708.48
2.70
0.00
325.00
1.00
325.00
795.00

review and update case files with
recent court filings.
0.00
133.25
0.30
0.00
262.40
Amount Bill Num
34949784
4261
Lyman, L. James
10/20/14
34949340
4387
Stoever, Thomas W.
10/20/14
34955083
7153
Golz, Rebecca A.
10/21/14
34949597
4261
Lyman, L. James
10/21/14
34954769
4261
Lyman, L. James
10/22/14
Discussion with state regarding

stipulation;
.
0.00
262.40
0.40
256.00
104.96
0.40
2713661
34954985
4261
Lyman, L. James
10/23/14
0.00
262.40
1.00
640.00
262.40
1.00
2713661
34960609
4387
Stoever, Thomas W.
10/24/14
0.00
325.00
1.00
325.00
795.00
1.00
2713661
34964967
4261
Lyman, L. James
10/24/14
discussions with
county regarding stipulation for
permanent injunction.
Revisions to joint stipulation for
judgment;
.
Review county answer to complaint in
Guzzo v. Mead; attend to issues
relating to final settlement of Guzzo v.
Mead.
0.00
262.40
2.20
577.28
1,408.00
2.20
2713661
34974698
4261
Lyman, L. James
10/30/14
Prepare for and attend to call with

state regarding stipulation.
0.00
262.40
0.70
183.68
448.00
0.70
2713661
35006526
7153
Golz, Rebecca A.
11/05/14

prepare and circulate
133.25
0.00
1.10
146.58
357.50
1.10
2713661
calls and emails with

county regarding licenses.
draft stipulation for

permanent injunction.
35015463
4387
Stoever, Thomas W.
11/05/14
Work on redrafting the stipulated

judgment.
325.00
0.00
1.00
325.00
795.00
1.00
2713661
35011524
7153
Golz, Rebecca A.
11/10/14

circulate recent filing from state
defendants regarding pending
deadlines in state court; circulate
recent filing from state defendants
regarding request for judgment on
pleadings in federal court.
0.00
133.25
0.20
26.65
65.00
0.20
2713661
35014261
4261
Lyman, L. James
11/11/14
262.40
0.00
1.80
472.32
1,152.00
1.80
2713661
regarding state's motions

in federal and state cases.
Page: 4
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Entries
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70-1 Filed 02/26/15 Page 20 of 23

Base
Hourly
Rate
Time/Unit
Billed
Value
Prebill Num
Print
Flag
2713661
1.00
2713661
Tran Date
Description
Time/Unit
Attend to calls with defendants'

counsel regarding upcoming status
conference.
Revisions to various pleadings;
262.40
0.00
0.60
157.44
384.00
0.60
0.00
325.00
1.00
325.00
795.00
Amount Bill Num
35027711
4261
Lyman, L. James
11/13/14
35034749
4387
Stoever, Thomas W.
11/14/14
35027715
4261
Lyman, L. James
11/14/14
Prepare for and attend status hearing

in Courage v. Wyoming case.
0.00
262.40
0.50
131.20
320.00
0.50
2713661
35031576
7153
Golz, Rebecca A.
11/17/14

file and serve response to state
defendants' motion for judgment.
0.00
133.25
0.80
260.00
106.60
0.80
2713661
35040033
4261
Lyman, L. James
11/17/14
0.00
262.40
2.20
577.28
1,408.00
2.20
2713661
draft
stipulation; draft response to state
motion for judgment.
35034793
4387
Stoever, Thomas W.
11/19/14
Draft motion for judgment on

pleadings.
0.00
325.00
1.00
325.00
795.00
1.00
2713661
35040232
4261
Lyman, L. James
11/21/14
262.40
0.00
0.90
236.16
576.00
0.90
2713661
35044275
7153
Golz, Rebecca A.
11/24/14
0.00
133.25
1.20
159.90
390.00
1.20
2713661
35060622
4261
Lyman, L. James
11/24/14
Revise motion for judgment on the

pleadings in federal case and draft
proposed order.
Stoever: file and serve plaintiffs'
motion for judgment on the pleadings.
Draft proposed order and finalize
motion for judgment for filing.
0.00
262.40
2.00
1,280.00
524.80
2.00
2713661
Page: 5
0091738
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Entries
Document
70-1 Filed 02/26/15 Page 21 of 23

Base
Tran Date
Description
Hourly
Rate
Time/Unit
Billed
Value
Time/Unit
Amount Bill Num
Prebill Num
Print
Flag
35075048
7153
Golz, Rebecca A.
12/02/14

Stoever: file and serve plaintiffs'
motion for judgment on the pleadings.
0.00
133.25
0.90
292.50
119.93
0.90
2713661
35085129
4387
Stoever, Thomas W.
12/08/14
Review state's opposition to judgment

on pleadings and draft reply regarding
same.
0.00
325.00
1.00
325.00
795.00
1.00
2713661
35134560
7153
Golz, Rebecca A.
12/12/14

Stoever: assemble exhibits, finalize,
file and serve plaintiffs' reply to motion
for judgment on pleadings.
0.00
133.25
1.70
226.53
552.50
1.70
2713661
35151411
4387
Stoever, Thomas W.
01/05/15
Work on filings with Wyoming District

Court.
325.00
0.00
1.00
325.00
835.00
Page: 6
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Entries
Document
70-1 Filed 02/26/15 Page 22 of 23

Base
Tran Date
Description
Hourly
Rate
Time/Unit
Billed
Value
Time/Unit
Amount Bill Num
Prebill Num
Print
Flag
35201421
7153
Golz, Rebecca A.
01/29/15

Stoever: circulate court order granting
judgment on pleadings and permanent
injunction as to WY state laws.
0.00
133.25
0.10
34.00
13.33
35213797
7153
Golz, Rebecca A.
01/30/15

Stoever: review state court file
regarding status of case and next
steps before Judge Campbell.
133.25
0.00
0.70
93.28
238.00
Fees Base
Page: 7
Fees Billed
Time
Value
159.90
41,139.62
Time
Value
Arnold & Porter LLP

Entries
Document
70-1 Filed 02/26/15 Page 23 of 23
Base
Control
Group Line
Tran Date
Hourly
Rate
Description
Time/Unit
Billed
Value
Time/Unit
Amount Bill Num
Prebill Num
Report Total
Disbursement Category
Numberof
of Entries
Entries
Number
Billed Value
147
Westlaw Research
12
579.02
1501
Other Computer Research
80.37
151
Travel Expenses
62.37
1511
Hotel
178.73
152
Travel Meals
76.80
153
Local Transportation
310.24
160
Duplicating
62
129.60
172
Air Delivery Services
59.34
187
Filing Fees
1,100.00
194
Color copies
3.75
202
Depositions & Transcript (original)
195.50
Disb Base
Page:
Page: 10
8
Disb Billed
Unit
Value
Unit
Value
869.00
2,775.72
869.00
2,775.72
Print
Flag
Tracy L. Zubrod
Cheyenne, WY 82001
Telephone: (307) 778-2557
Facsimile: (307) 778-8225
L. James Lyman*
ARNOLD & PORTER LLP
Telephone: (303) 863-1000
Facsimile: (303) 832-0428
Email: james.lyman@aporter.com
Qusair Mohamedbhai
1518 Blake Street
Denver, Colorado 80202
Telephone: (303) 578-4400
Facsimile: (303) 578-4401
Shannon P. Minter*
Christopher F. Stoll*
NATIONAL CENTER FOR
LESBIAN RIGHTS
Telephone: (415) 365-1335
Facsimile: (415) 392-8442
*Admission Pro Hac Vice

DISTRICT OF WYOMING
Anne Marie Guzzo and Bonnie Robinson; Ivan

Williams and Charles Killion; Brie Barth and Shelly
Montgomery; Carl Oleson and Rob Johnston; and
Wyoming Equality,
Plaintiff(s),
v.
Case Number: 2:14-cv-00200-SWS
Matthew H. Mead, in his official capacity as the

Governor of Wyoming; Dean Fausset, in his official
official capacity as Administrator of the State of
Wyoming Human Resources Division; and Debra K.
Lathrop, in her official capacity as Laramie County
Clerk,
Defendant(s).
DECLARATION OF SHANNON P. MINTER IN SUPPORT OF PLAINTIFFS MOTION
FOR ATTORNEYS FEES AND EXPENSES
I, Shannon P. Minter, hereby declare and state as follows:
1.
I am an attorney admitted pro hac vice before this Court and represent the Plaintiffs
in this action. I am a member in good standing of the California State Bar and am admitted to
practice law in California state and federal courts, several U.S. Courts of Appeals, and the Supreme
Court of the United States. I have personal knowledge of the matters stated in this Declaration
and could and would competently testify to these facts.
2.
This Declaration is filed concurrently with Plaintiffs Motion for Reasonable
Attorneys Fees and Expenses.
3.
I am a 1993 graduate of Cornell University School of Law, and have been a licensed
attorney since that year. Since 2000, I have been the Legal Director of the National Center for
Lesbian Rights (NCLR), which is a national legal organization committed to advancing the civil
and human rights of lesbian, gay, bisexual, and transgender people and their families. In particular,
NCLR is committed to litigating precedent-setting cases at the trial and appellate court levels
throughout the country. A more complete recitation of my experience and background in civil
rights cases is included below and in my curriculum vitae, a copy of which is attached hereto as
Exhibit A.
MY MOST RELEVANT GENERAL BACKGROUND
4.
NCLR maintains a diverse legal practice and I have litigated a variety of complex
cases in state and federal courts during my twenty-one year tenure at the organization. For
instance, I have litigated complex child custody, adoption, youth, immigration, employment
discrimination, and civil rights matters. I have also argued cases before trial and appellate courts,
including state supreme courts and federal circuit courts of appeal.
5.
I am an expert on legal matters involving lesbian, gay, bisexual, and transgender
(LGBT) people and frequently teach or lecture regarding these topics. For example, I have taught
courses on LGBT legal issues at Berkeley, Stanford, Santa Clara, American University
Washington College of Law, and several other laws schools.
6.
I have authored several treatises and publications on legal issues related to the
LGBT community, including in the areas of family law, constitutional rights, employment
discrimination, and immigration / asylum, and frequently lecture around the country and abroad
regarding LGBT civil and human rights. For example, in September of 2013, I traveled to El
Salvador to meet with various governmental agencies about hate violence against LGBT people at
the request of the U.S. Department of State.
7.
I also have extensive experience litigating challenges to state laws that prohibit
marriages by same-sex couples or recognition of valid marriages of same-sex couples performed

in other jurisdictions. NCLR was lead counsel for same-sex couples in In re Marriage Cases, 43
Cal.4th 757, 76 Cal.Rptr.3d 683, 183 P.3d 384 (2008), representing fifteen (15) same-sex couples
in the case that made California the second state in the country to allow same-sex couples to
marry. I argued the case on behalf of the couples before the California Supreme Court, which
ruled in May 2008 that the California Constitutions guarantees of due process and equal protection
prohibited the state from barring same-sex couples from marriage. The decision was also the first
ruling by a state supreme court that laws that discriminate on the basis of sexual orientation are
subject to strict scrutiny under the equal protection guarantee of a state constitution. The decision
followed more than four years of litigation in the California courts, including briefing and
argument by NCLR and its co-counsel in the San Francisco Superior Court and California Court
of Appeal. I was substantially involved in the briefing and strategy for the case throughout the
process, as was Senior Staff Attorney Christopher Stoll, who was then a partner at Heller Ehrman
LLP, one of the law firms that worked with NCLR on the case, and Constitutional Litigation
Director David Codell, who had his own firm at that time.
8.
NCLR was also lead counsel in Strauss v. Horton, 46 Cal. 4th 364, 207 P.3d 48
(Cal. 2009). I argued that case before the California Supreme Court, which held that the marriages
of same-sex couples who legally married in California before the enactment of Proposition 8 were
valid.
9.
In 2012, NCLR litigated Port v. Cowan, 426 Md. 435, 44 A.3d 970 (Md. 2012). I
argued that case before the Maryland Court of Appeals, the highest state court in that state, which
held that Maryland must recognize the marriages of same-sex couples who validly married in other
jurisdictions.
10.
In 2011 through 2013, NCLR also successfully litigated Cozen OConnor, P.C. v.
Tobits, et al., No. 110045, 2013 WL 3878688 (E.D. Penn. Jul. 29, 2013) in the Eastern District
of Pennsylvania establishing the validity of a marriage of a same-sex couple. In that case, Jennifer
Tobits lost her wife to a four-year battle with cancer. When she sought distribution of her wifes
employee pension plan, the employer refused to distribute the funds based on the federal Defense
of Marriage Act. Relying on the U.S. Supreme Courts decision in United States v. Windsor, the
federal judge ruled that Jennifer was a legal spouse entitled to her wifes pension plan.
11.
NCLR also represented same-sex couples in Griego v. Oliver, a lawsuit challenging
New Mexicos failure to issue marriage licenses to same-sex couples. In that case, we secured a
unanimous decision from the New Mexico Supreme Court ruling that the New Mexico
Constitution requires the state to allow same-sex couples to marry and to recognize the valid
marriages of same-sex couples performed outside the state.
12.
In 2013, NCLR served as amicus counsel for the Leadership Conference on Civil
and Human Rights, the American Association of University Women, the Hispanic National Bar
Association, the Japanese American Citizens League, the League of United Latin American
Citizens, the Mexican American Legal Defense and Educational Fund, the Southern Poverty Law
Center and other civil rights organizations in United States v. Windsor, 133 S. Ct. 2675 (2013).
13.
I, along with Christopher Stoll, Amy Whelan, and other NCLR legal staff, also
served or are serving as Plaintiffs counsel in multiple marriage cases around the country, including
in Utah, Idaho, Florida, Tennessee, South Dakota, North Dakota, and Alabama. We prevailed on
dispositive motions and/or motions for preliminary injunctive relief in Utah, Idaho, Florida,
Tennessee, South Dakota, and Alabama and have a summary judgment motion pending in North
Dakota. In addition, on behalf of our Utah and Idaho clients, we prevailed in appeals before the
Ninth and Tenth Circuits, where we had primary responsibility for drafting all briefs. Presently,
we represent the plaintiffs in a challenge to Tennessees refusal to recognize the lawful marriages
of same-sex couples entered into in other jurisdictions, in which the Supreme Court of the United
States has granted a writ of certiorari and requested briefing and argument on the merits. Because
of our extensive experience and expertise litigating these cases, we have also provided legal
assistance and research to numerous other attorneys around the country who are litigating marriage
cases in both state and federal courts.
SUMMARY OF THE LITIGATION AND THE
EXCELLENT RESULTS OBTAINED
14.
NCLR was retained in this litigation, along with co-counsel, on a fully contingent
basis to challenge Wyomings laws prohibiting the issuance of marriage licenses to same-sex
couples and prohibiting recognition of valid marriages of same-sex couples entered in other
jurisdictions. The attorneys at Arnold & Porter served as lead counsel, and NCLR, Ms. Zubrod,
Mr. Mohamedbhai, and Mr. Jahanian were actively involved in strategy, drafting of key briefs and
documents, and decision making for the case. All counsel worked hard to divide tasks so that their
effort was not duplicative. Plaintiffs counsel conducted much of their business during telephone
conferences and through email, which served as a cost-effective means to divide tasks between the
attorneys and staff while eliminating the need for expensive travel by NCLR and co-counsel.
15.
Plaintiffs counsel litigated this case efficiently and without unnecessary
duplication of effort. Our co-counsel at Arnold & Porter took primary responsibility for preparing
5
initial drafts of many of the pleadings and briefs, including the briefing regarding the dispositive
motions, which were reviewed and edited by co-counsel. Because of NCLRs long experience
with the important constitutional issues involved in this case, we provided co-counsel with
guidance on all substantive briefs and oral argument and contributed significantly to the overall
strategy in the case.
12.
The majority of the work in this case, including drafting and filing the complaint,
motions, oppositions, replies, and the oral argument, occurred within the month of October 2014.
13.
Plaintiffs counsel litigated this case efficiently by using legal research and briefing
from NCLRs other marriage cases around the country, where it was relevant and applicable. This
reduced the number of required hours significantly, making this motion extremely reasonable.
14.
Based on my extensive litigation experience, the results obtained in this case are
excellent. Plaintiffs prevailed on all of their claims, including that Wyomings laws violate their
rights to due process and equal protection of the laws, and also secured all of the relief requested.
BILLING RATES, RECORDS, REDUCTIONS, AND CHARTS
15.
As a non-profit litigation firm, NCLR does not charge our clients for legal services.
We do, however, seek reasonable attorneys fees and expenses in cases where there are fee-shifting
statutes and our clients are the prevailing parties. NCLR and our co-counsel have incurred all
costs in this matter and Plaintiffs have agreed that any awarded attorneys fees and costs shall
belong to and be paid to Plaintiffs counsel.
16.
Attached hereto as Exhibit B is a true and accurate transcription of NCLRs time
and expenses in this case from the beginning of the case through February 25, 2015. That time
reflects our work on the following major categories of work: (1) review and editing of the
complaint; (2) preparation of Plaintiffs successful motion for preliminary injunction, including
supporting affidavits and evidence and preparation for the hearing on that motion; and (3)
preparation of the motion for judgment on the pleadings; (4) work moving for reasonable
attorneys fees and costs in this case.
17.
I have been assisted in this case by NCLRs Senior Staff Attorney, Christopher F.
Stoll. Amy Whelan, another Senior Staff Attorney, also worked on the attorneys fees motion.
Mr. Stolls and Ms. Whelans resumes are attached hereto as Exhibit C.
18.
The current billing rates we seek in this case are as follows: $325 per hour for
myself, $300 per hour for Christopher Stoll, who has 20 years of litigation experience in complex
civil and constitutional cases, and $275 per hour for Amy Whelan, who has 14 years of litigation
experience in complex civil and constitutional cases. As the supporting declaration of Bruce T.
Moats shows, these rates are consistent with those charged in the Wyoming market for attorneys
with similar, extensive experience litigating complex constitutional cases. Our requested rates are
also reasonable because we could seek San Francisco billing rates for this case based on our
extensive expertise and experience, as well as Plaintiffs inability to find local counsel that
specialize in constitutional matters. See e.g. Reazin v. Blue Cross and Blue Shield of Kansas, Inc.,
899 F.2d 951, 983 (10th Cir. 1990) (affirming district courts award of higher rates for out-of-state
counsel based on their expertise and experience); Rocky Mountain Christian Church v. Bd. of
County Comrs of Boulder County, No. 06-CV-00554, 2010 WL 3703224, at *5 (D. Colo. Sept.
13, 2010) (awarding higher hourly rates for attorney with specialized knowledge and skills in the
areas of constitutional law.); Swisher v. U.S., 262 F.Supp.2d 1203, 1213-14 (D. Kan. 2003)
(awarding non-local hourly rates where Plaintiff was unable to find local counsel and where legal
issues were not routinely litigated in the court). My rate in the San Francisco market is $675 per
hour, Chris Stolls rate is $650 per hour and Amy Whelans is $500 per hour.
19.
NCLR and our co-counsel performed work efficiently, effectively, with extreme
diligence, and without unnecessary duplication. Based on my experience litigating complex civil
rights cases, I believe the hours recorded by NCLR staff on this case to be extremely conservative.
We have nevertheless made billing judgment reductions for the purpose of eliminating any
possible duplication, overstaffing or overwork. For instance, we did not record significant
amounts of time we spent communicating about strategy and emailing with co-counsel about
various litigation-related issues and strategy. Also, we do not seek fees for the two paralegals in
our office who worked on this case. Finally, we are not requesting any of the time our attorneys
or legal staff spent on the related Courage v. Wyoming litigation in state court.
20.
Following the exercise of the billing judgment reductions described above, NCLRs
total claimed lodestar for merits work and fees-for-fees work through February 25, 2015 is
$20,562.50. We also seek $1,606.53 in travel expenses, for a total request of $22,169.03. See
Exhibit B. Travel expenses are typically charged to fee-paying clients and all of these expenses,
which were incurred by one attorney to attend the hearing on the motion for preliminary injunction
/ temporary restraining order, were necessary to the litigation. Chris Stoll was the only NCLR
attorney who traveled to Wyoming for the hearing, which was essential to Plaintiffs success. Mr.
Stoll assisted our co-counsel before and during the hearing by offering his knowledge and insights
concerning legal arguments, presentation of evidence, and overall strategy based on his experience
with dozens of similar hearings and trials in marriage equality cases around the country.
I declare under penalty of perjury that the foregoing is true and correct.
Executed in Washington, D.C. on this 26th day of February 2015.
Shannon P. Minter (pro hac vice)

Attorney for Plaintiffs
8
EXHIBIT A
SHANNON PRICE MINTER

Legal Director
EDUCATION AND BAR ADMISSIONS
Cornell Law School, J.D., 1993
Honors: Magna Cum Laude, Order of the Coif, Graduation Address
Activities: Symposium Editor, CORNELL INTERNATIONAL LAW JOURNAL
Cornell University, Ph.D. program, English & American Literature, 1984-88
Honors: Mellon Fellow, Andrew White Fellow
University of Texas at Austin, B.A., 1983
Honors: Phi Beta Kappa
Bar Admissions: California (1993); admitted to CA state and federal courts, several U.S.
Courts of Appeals, and U.S. Supreme Court
EXPERIENCE
Legal Director, 2000-present; Senior Staff Attorney, 1996-1999
Legal director of national civil rights organization with offices in California and Washington,
D.C. with nationwide impact litigation and policy practice.
Litigation: Serve as lead counsel in state and federal impact cases, including child
custody, adoption, youth, immigration, employment discrimination, and other areas.
Supervise legal team of 13 in-house counsel and manage co-counsel relationships with
other legal organizations and law firms. Coordinate national network of 40 to 45 family
law and estate planning attorneys and legal scholars who develop new legal strategies for
protecting same-sex couples and their children.
Legislation: Draft local, state, and federal anti-discrimination and family recognition bills
and regulations affecting gay, lesbian, bisexual, and transgender people.
Policy advocacy: Develop and implement national and state policy initiatives relating to
LGBT parents, students, youth, immigrants, elders, and prisoners. Examples include:
testimony as expert on gender identity discrimination before House Committee on
Education and Labor (June, 2008); development with Child Welfare League of America
of best practice guidelines for serving LGBT youth in foster care and juvenile justice
settings (2006); development of model safe school policies for San Francisco and Los
Angeles Unified school districts (2004).
National Association of Public Interest Law Fellow, 1993-1995

Created national legal and public policy advocacy program to address abuse of gay, lesbian,
bisexual and transgender youth in mental health system.
American University Washington College of Law
Visiting Professor, Constitutional Law Summer Program, 2011-present
Whittier Law School
Visiting Professor, Transgender Rights, Summer 2010
Santa Clara Law School
Lecturer, Gender, Sexuality, and the Law, Spring 2004
University of San Francisco School of Law
Adjunct Professor of Law, Sexual Orientation and the Law, Fall 2003
University of California, Berkeley School of Law (Boalt Hall)
Adjunct Professor of Law, Gender, Sexuality and the Law, Spring 2003
Golden Gate School of Law
Adjunct Professor of Law, Sexual Orientation and the Law, Spring 2003
Stanford Law School
Adjunct Professor of Law, Gender, Sexuality, and the Law, Spring 2001
The Schomberg Library African-American Fiction and Periodicals Project
Editorial Assistant to Henry Louis Gates, Jr., 1988-1990
Responsible for identifying and preserving fiction and book reviews published in nineteenth
and early twentieth century African-American owned or edited newspapers in the U.S.
SAMPLE PUBLICATIONS
LESBIAN, GAY, BISEXUAL AND TRANSGENDER FAMILY LAW. Coauthored with Courtney G.
Joslin (West Publishing 2012).
TRANSGENDER RIGHTS. Co-edited with Paisley Currah and Richard M. Juang (Minnesota
University Press 2006).
The Great Divorce: The Separation of Equality and Democracy in Contemporary Marriage
Litigation, 19 UNIV. OF SOUTHERN CALIF. REV. OF L. & SOCIAL JUSTICE 89 (2010)
Representing Transsexual Clients, in SEXUAL ORIENTATION AND THE LAW (West Publishing
2012).
Same-Sex Marriage and Its Implications for Employee Benefits, 9 EMPLOYEE RIGHTS AND
EMPLOYMENT POLICY JOURNAL 499 (2005).
Unprincipled Exclusions: The Struggle to Achieve Judicial and Legislative Equality for
Transgender People, (with Paisley Currah) 7 WILLIAM & MARY JOURNAL OF WOMEN AND
2
THE LAW 37 (2000). Published in Elizabeth

REGULATING SEXUALITY (Routledge 2005).
Bernstein and Laurie Schaeffer, eds.,
Preface, SOCIAL SERVICES WITH TRANSGENDERED YOUTH, Gary Mallon, ed. (2000).
Beyond Second-Parent Adoption: The Uniform Parentage Act and Intended Parents, (with
Kate Kendell) 2 GEORGETOWN JOURNAL OF GENDER AND THE LAW 29 (2000).
Do Transsexuals Dream of Gay Rights? Getting Real About Transgender Inclusion in the Gay
Rights Movement, 17 NEW YORK LAW SCHOOL JOURNAL OF HUMAN RIGHTS 589 (2000).
TRANSGENDER EQUALITY. Coauthored with Paisley Currah (National Gay & Lesbian Task
Force 2000).
Lesbians and Gay Men as Adoptive Parents: A Child Welfare Perspective, in ADOPTION
FACTBOOK III (National Council for Adoption, 1999).
Diagnosis and Treatment of Gender Identity Disorder in Children, in Matthew Rottnek, ed.,
SISSIES AND TOMBOYS: GENDER NONCONFORMITY AND HOMOSEXUAL CHILDHOOD (NYU
Press 1999).
Lesbians and Political Asylum: Sexual Orientation, Gender, and Lesbian Human Rights, in A
RESOURCE GUIDE FOR ATTORNEYS REPRESENTING LESBIANS AND GAY MEN IN ASYLUM
CASES (International Gay and Lesbian Human Rights Commission 1996).
Lesbian Rights in the United States, in Rachel Rosenbloom, ed., UNSPOKEN RULES: SEXUAL
ORIENTATION AND WOMEN'S HUMAN RIGHTS (Cassell 1996).
Sodomy and Public Morality Offenses Under U.S. Immigration Law: Penalizing Lesbian and
Gay Identity, 26 CORNELL INTERNATIONAL LAW JOURNAL 771 (1993).
SELECTED PRESENTATIONS
Keynote: Realizing the Dream of Equality for All, New Mexico Bar Association, May 1,
2013
Winning Cases, Losing Children: The Human Impact of Litigation in LGBT Impact Cases,
Roundtable Discussion, Law & Society Conference, San Francisco, June 3, 2011.
LGBT Legal Issues in Utah, State Judges Annual Judicial Conference, Homestead, Utah,
May 5, 2011
Plenary, What the LGBT and Disability Rights Movements Can Learn from One Another,
Jacobus tenBroek Disability Law Symposium, Bridging the Gap between the Disability Rights
Movement and Other Civil Rights Movements, April 14, 2011
Panel, How Does it Get Better? New Directions in LGBT Equality, "Gay Rights as Human
Rights" Conference at the Harvard Kennedy School, April 15, 2011
The Relevance of Martin Luther King To LGBT Advocacy, Martin Luther King Memorial,
3
DePaul University College of Law, January 17, 2011

Keynote, Gay Rights, Democracy, and the United States Supreme Court, Minnesota
Lavender Bar Association, January 29, 2011
Keynote, Do Transsexuals Dream of Gay Rights?, Harvard Kennedy School, Carr Center for
Human Rights Policy, Nicholas Papadopoulos Lecture, April 23, 2010
Keynote, The Heart of Democracy: Marriage Equality for Same-Sex Couples, Conference:
Controlling Sexuality through Violence, Harassment and Intrusion: Implications and Prospects
for Fundamental Human Rights, Tanner Humanities Center, University of Utah, February 26,
2010
Keynote, The Legal and Political Implications of Proposition 8, Til Ballot Initiative Do Us
Part: Marriage Equality, Religion, and Civil Rights, American University Washington
College of Law, March 19, 2009
The Future of Marriage Equality in California, The Global Arc of Justice: Sexual Orientation
Law around the World, UCLA School of Law, March 14, 2009
Keynote, Why Gender Theory Should Not Determine Transgender Advocacy, Trans
Rhetorics Conference, Cornell University, March 7, 2009
The Struggle To Achieve Equality for Same-Sex Couples, Conference: Race, Class,
Ethnicity and Gender, University of North Carolina Law School, February 21, 2009
Keynote, The Concepts of Dignity and Privacy in Transgender Advocacy, Symposium:
Transgender Lives and the Law, Temple Law School, November 8, 2008
The Case Against Proposition 8, Levin Center for Public Service and Public Interest Law
Award, Stanford Law School, November 10, 2008
Relationship Recognition for Same-Sex Couples in California, Symposium: When Change
Comes Home: Legal Repercussions and Comparative Perspectives on Changing Structures of
American Households, Santa Clara Law School, February 15, 2008
Legal & Policy Issues Affecting Transgender Students, Faculty, and Staff, Conference:
Legal Issues in Higher Education, Vermont Law School, October 16, 2007
Gay Marriage in California: Legal and Political Prospects, Debate sponsored by the
Federalist Society, the American Constitution Society, the Pew Forum on Religion & Public
Life, and the USC Annenberg Knight Chair in Media and Religion, Los Angeles, California,
February 28, 2007
Plenary speaker, The Role of Ethics in Public Interest Law, University of Maryland Law
School, October 18, 2006
4
Do Transsexual Athletes Have A Right To Compete?, Sports Law Symposium, Marquette

Law School, October 6, 2006
The Evolution of Transgender Rights Nationally and Globally, Symposium: Transgender
Civil Rights Issues, Hastings Law School, July 21, 2006
Speaker, Panel on the Marriage Debate, The Charles R. Williams Project on Sexual Orientation
and Public Policy, UCLA School of Law, April 21, 2006
The Struggle to Achieve Marriage Equality for Same-Sex Couples, Cornell Law School,
November 16, 2005
The Salience of Gender-Based Humiliation in Human Rights Abuses Against Transgender
Prisoners in the United States and So-Called Enemy Combatants Abroad, Conference: Race,
Class, Gender, and Ethnicity, University of North Carolina Law School, February 18, 2005
Speaker, Panel on the California Frontier: Litigating Exclusions to Gay and Lesbian Adoption
and Marriage, Conference: Gay and Lesbian Adoption: Past, Present and Future, New York
Law School, September 21, 2005
The Current State of Gender Identity and Sexual Orientation Law, Conference: Progress and
Promise in Sexual Orientation and Gender Identity Law, Pace Law School, April 21, 2003
SELECTED HONORS AND AWARDS
Distinguished Service Award, GayLaw D.C. Bar Association, 2010

One of California Lawyers of the Year, California Lawyer Magazine, 2009
One of Nations Top 8 Lawyers of the Year, Lawyers USA, 2009
One of Californias 100 Top Lawyers, Daily Journal, 2008
National Public Service Award, Stanford Law School, 2008
Exemplary Public Service Award, Cornell Law School, 2008
Award of Excellence, University of San Francisco Public Interest Law Foundation, 2008
Community Service Award, Elections Committee of the County of Orange, 2008
Advocacy Award, Bay Area Municipal Elections Committee, 2008
Dan Bradley Award, National Lesbian and Gay Law Association, 2008
Legal Advocacy Award, San Francisco State University National Sexuality Resource
Center, 2008
Visionary Award, Alice B. Toklas LGBT Democratic Club, 2008
Community Service Award, Long Beach Lambda Democratic Club, 2008
Award, International Foundation for Gender Education, 2008
Community Advocacy Award, Gender Spectrum, 2007
Unity Award, Bay Area Lawyers for Individual Freedom, 2006
Leadership for a Changing World Award, Ford Foundation, 2005
Justice Award, Equality California, 2005
Advocacy Award, San Francisco Bar Association, 2004
Honorary Doctorate, City University of New York Law School, 2004
Anderson Foundation Prize, National Gay & Lesbian Task Force, 2003
5
National Service Award, Gay/Lesbian/Bisexual Transgender Bar Association of

Washington, D.C., 2002
COMMUNITY AND PROFESSIONAL SERVICE

American Bar Association Commission on Sexual Orientation and Gender Identity, 20072009
Transgender Law and Policy Institute, Board of Directors, 2000-present
International Gay & Lesbian Human Rights Commission, Advisory Board, 2003-present
Council for Global Equality, 2008-present
Faith in America, Board of Directors, 2009-present
Aids Relief Fund for China, 2010-present
Gender Spectrum, 2010-present
EXHIBIT B

Guzzo v. Mead - 2:14-cv-00200-SWS
Shannon P. Minter Time
DATE
10/6/2014
DESCRIPTION
HOURS
BILLED
Confer with client and co-counsel re Supreme Court certiorari denials,

communications with state officials, and potential federal litigation
Edit draft complaint
Confer with co-counsel re filing of complaint, pro hac vice motions and case
strategy
Edit motion for preliminary injunction
Confer with client and co-counsel re preliminary injunction and hearing
1.6
0.7
0.2
0.3
1
10/14/2014
10/14/2014
Confer with co-counsel re preliminary injunction oral argument

Review county response to motion for preliminary injunction
Review state's opposition to preliminary injunction motion
Confer with clients and co-counsel re preparation for preliminary injunction
hearing
Review draft reply brief re preliminary injunction; confer with co-counsel re
same
Review proposed order of proof; confer with co-counsel re same
Confer with co-counsel re oral argument
10/15/2014
Confer with co-counsel re preparation for hearing
1.3
10/17/2014
10/20/2014
Review ruling on motion for PI; conferences with co-counsel re same

Conferences with co-counsel re filing of notices of non-appeal and effective
date of preliminary injunction
Review state notice of non-appeal and order lifting temporary stay
Review Prop Stip for Permanent injunction; conferences with co-counsel re
same
Review defendant's changes to stip; confer with co-counsel re same
Confer with co-counsel re draft stip
Review state's motion for judgment on the pleadings
Confer with co-counsel re response to motion for jjdmt on the pleadings
Edited draft motion for judgment on the pleadings
Review state response to motion for jdmt on the pleadings
Edited draft reply re motion for jdmt on the pleadings; confer with co-counsel
re same
Review order granting jdmt on the pleadings and permanent inj.
reviewed draft Minter decl ISO fee motion; revised same
Totals
1.3
1.8
10/7/2014
10/7/2014
10/8/2014
10/8/2014
10/9/2014
10/10/2014
10/13/2014
10/13/2014
10/14/2014
10/21/2014
10/23/2014
11/4/2014
11/5/2014
11/10/2014
11/11/2014
11/21/2014
12/8/2014
12/11/2014
1/29/2015
2/25/2015
0.5
1.4
1.3
1.5
0.3
0.6
1.2
0.2
1
0.6
0.8
0.2
0.8
0.2
0.2
0.4
0.2
0.2
19.8

Christopher F. Stoll Time
DATE
DESCRIPTION
HOURS
BILLED
10/6/2014
Confer with client and co-counsel re Supreme Court certiorari denials and
potential federal litigation.
1.6
10/7/2014
10/7/2014
Review draft complaint.

Confer with co-counsel re filing of complaint and pro hac vice motions and
re case strategy.
Review and revise motion for preliminary injunction.
Confer with client and co-counsel re motion for preliminary injunction and
scheduling of hearing.
Confer with co-counsel re hearing on motion for preliminary injunction.
0.8
1.4
10/8/2014
10/8/2014
10/9/2014
2.3
1.5
0.7
10/10/2014 Review county response to motion for preliminary injunction.

10/13/2014 Review state's opposition to preliminary injunction motion.
10/13/2014 Confer with clients and co-counsel re preparation for preliminary
injunction hearing; legal research re same.
10/14/2014 Review draft reply brief in support of motion for preliminary injunction;
confer with co-counsel re same.
10/14/2014 Review proposed order of proof; confer with co-counsel re same.
10/14/2014 Confer with co-counsel re preparation for hearing.
10/14/2014 Travel to Casper, WY, for hearing on motion for preliminary injunction.
0.3
0.4
2.3
10/15/2014 Confer with co-counsel re preparation for hearing.

10/16/2014 Attend hearing on motion for preliminary injunction; confer with cocounsel re preparation for same.
10/16/2014 Travel from Casper to San Francisco.
10/17/2014 Review ruling on motion for preliminary injunction; conferences with cocounsel re effective date of injunction.
10/20/2014 Conferences with co-counsel re filing of notices of non-appeal and effective
date of preliminary injunction; review correspondence from defendants re
same.
10/21/2014 Review state notice of non-appeal and order lifting temporary stay;
conferences re client applications for marriage licenses.
10/23/2014 Review proposed stipulation for permanent injunction; conferences with
co-counsel re same.
11/4/2014 Review defendant's proposed changes to stipulation; confer with cocounsel re same.
11/5/2014 Confer with co-counsel re draft stipulation.
11/10/2014 Review state's motion for judgment on the pleadings; confer with cocounsel re same.
11/11/2014 Confer with co-counsel re response to motion for judgment on the
pleadings.
1.3
3.8
0.5
0.8
1.2
5.3
5.5
1.3
2.2
1.2
1
0.6
0.8
0.7
0.8

Christopher F. Stoll Time
DATE
DESCRIPTION
HOURS
BILLED
11/21/2014 Review draft motion for judgment on the pleadings.

12/8/2014 Review state response to motion for judgment on the pleadings.
12/11/2014 Review draft reply in support of motion for judgment on the pleadings;
confer with co-counsel re same.
1/29/2015 Review order granting judgment on the pleadings and permanent
injunction.
2/6/2015
Conferences with co-counsel re motion for attorneys' fees and costs;
review time entries.
2/9/2015
Conferences with co-counsel re motion for attorneys' fees and disussions
with state defendants.
2/10/2015 Conference with co-counsel re motion for attorneys' fees.
2/19/2015 Conference with co-counsel re negotiations with state and motion for
attorneys' fees.
2/24/2015 Review and revise declaration in support of motion for attorneys' fees;
conferences with co-counsel re same.
2/25/2015 Review and revise supporting documents for motion for attorneys' fees;
conferences with co-counsel re same.
Totals
0.3
0.2
0.4
0.2
0.4
0.2
0.3
0.3
1.2
0.8
42.6

Amy Whelan Time
DATE
DESCRIPTION
HOURS
BILLED
2/3/2015
2/9/2015
2/9/2015
2/24/2015
2/24/2015
2/25/2015
2/25/2015
2/25/2015
LR re fee motion and bill of costs deadlines; email to team re same

Prep of S. Minter Decl ISO fee motion
emails with CS and SM re draft Minter fees decl
revised Minter decl ISO fee motion
Legal research re awards of out-of-market rates based on experience and
unavailability of local counsel; email to team re same
emails with team re reasonable hourly rates
LR re market rates for Wyoming district; email to CS re same
revised Minter decl ISO fee motion re hourly rates; revised exhibits for same;
email to SM re same
Totals
0.4
1
0.2
0.3
1.5
0.2
0.6
0.7
4.9

NCLR Expenses- 2014
DATE
DESCRIPTION
Actual
Expenses
10/14/2014
10/14/2014
10/14/2014
10/14/2014
10/17/2014
C. Stoll taxi to SF airport for Hearing on PI / TRO

C. Stoll roundtrip airfare SF to WY for Hearing on PI / TRO
C. Stoll car rental for Hearing on PI / TRO
C. Stoll 2 nights hotel for Hearing on PI / TRO
C. Stoll taxi from SFO for Hearing on PI / TRO
$
62.08
$ 1,070.70
$ 152.00
$ 268.90
$
52.85
Total
$ 1,606.53
EXHIBIT C
CHRISTOPHER F. STOLL
Senior Staff Attorney
Harvard Law School, Cambridge, Massachusetts, J.D. magna cum laude, 1994
Harvard Law Review, Supreme Court Editor, 1992-94
DePauw University, Greencastle, Indiana, B.A. summa cum laude, 1991
Political Science/Russian Area Studies
Bar Admissions: California (1995); admitted to CA state and federal courts, several U.S.
Courts of Appeals, and U.S. Supreme Court
LEGAL EXPERIENCE
National Center for Lesbian Rights, San Francisco, California
Senior Staff Attorney, 2008-present
Oversee NCLRs general litigation, policy, and public education work.
Supervise and manage legal team members on complex civil cases around the
country.
Litigate numerous marriage equality cases, including in Florida, Idaho,
Tennessee, New Mexico, Utah, and Wyoming.
Litigate a variety of employment, discrimination, Title IX, First Amendment,
family law, and complex constitutional cases around the country.
Heller Ehrman LLP, San Francisco, California
Shareholder, 2003-2008, Associate, 1995-2002
Broad-based complex civil litigation practice with focus on insurance law,

intellectual property, and consumer class action matters. First and second
chair trial and appellate experience in state and federal courts in California
and nationally. (List of representative litigation matters attached.)
Supervised case teams and personally handled all aspects of civil litigation,
including legal research and writing, discovery, depositions, oral argument,
trial, appeal, alternative dispute resolution and settlement. Prepared case
budgets and advised clients on litigation strategy.
Managed staffing of more than 30 litigation associates and senior counsel as

Staffing Partner for the San Francisco office of large national law firm.
Monitored and balanced attorney workload. Drafted and delivered
performance reviews. Mentored, counseled, and trained junior attorneys.
United States Court of Appeals for the Ninth Circuit, San Francisco, California
Law Clerk to the Honorable James R. Browning, 1994-95
MEMBERSHIPS & HONORS
State Bar of California, American Bar Association, San Francisco Bar Association, Bay
Area Lawyers for Individual Freedom, Northern California SuperLawyers
COMMUNITY INVOLVEMENT
Board of Directors, Community United Against Violence, 1999-2006
Board of Directors, Positive Resource Center 1996-1999
REPRESENTATIVE LITIGATION ENGAGEMENTS, 2008-present
Kitchen v. Herbert (United States Court of Appeals, Tenth Circuit). Represent three same-sex
couples in a federal lawsuit challenging Utahs laws prohibiting same-sex couples from marrying
and refusing to respect the legal marriages of same-sex couples who married in other states.
Tanco v. Haslam (United States Court of Appeals, Sixth Circuit). Represent three legally married
same-sex couples challenging Tennessee laws that prevent the state from respecting their legal
marriages.
Pickup v. Brown (United States Court of Appeals, Ninth Circuit). Participated as amicus curiae
in case defending California state law that prohibits state-licensed therapists from trying to
change the sexual orientation or gender expression of a patient under 18 years old.
King v. Christie (United States District Court, District of New Jersey). Represent intervenor in
case defending New Jersey state law that prohibits state-licensed therapists from trying to change
the sexual orientation or gender expression of a patient under 18 years old.
Christian Legal Society v. Martinez (Supreme Court of the United States). Represented student
organization at Hastings College of the Law as intervener in First Amendment case challenging
Hastings Policy on Nondiscrimination. Prevailed before the U.S. Supreme Court.
Doe v. Anoka-Hennepin School District No. 11 and E.R. (United States District Court, District of
Minnesota). Represented students in lawsuit against the school district and school officials for
failure to stop daily harassment and bullying by their peers because of their actual or perceived
sexual orientation or gender expression. Obtained favorable lawsuit for plaintiff students.
Howe v. Haslam (Court of Appeals for Tennessee, Middle Section). Represent plaintiffs in
constitutional challenge of Tennessee law precluding localities from passing anti-discrimination
ordinances. Currently on appeal.
REPRESENTATIVE LITIGATION ENGAGEMENTS, 1995-2008

Insurance Recovery
Underwriters at Lloyds, London v. TransUnion LLC (Circuit Court of Cook County, Illinois).
First chair role representing national consumer credit reporting agency in litigation seeking errors
and omissions insurance coverage for consumer class actions relating to alleged privacy
violations.
Acuity v. Symantec Corporation et al. (Supreme Court of Wisconsin). First chair role
representing Symantec Corporation in suit seeking CGL advertising injury insurance coverage
for trademark and copyright infringement actions brought by Symantec relating to alleged piracy
of Symantecs commercial software products. Obtained favorable summary judgment, Court of
Appeals and Wisconsin Supreme Court decisions resulting in full coverage for claim.
PMI Mortgage Insurance Co. v. American International Specialty Lines Insurance Co. (United
States Court of Appeals, Ninth Circuit). Represented policyholder in litigation seeking errors
and omissions insurance coverage for settlement of nationwide consumer class action claims.
Drafted successful partial summary judgment motions, obtained judgment at trial for full policy
limits, and wrote successful appeal brief resulting in affirmance of the judgment.
Hewlett-Packard Co. v. Factory Mutual Ins. Co. (United States District Court, Southern District
of New York). Represented HP in suit seeking first-party property and business interruption
insurance coverage for property damage arising out of sabotage by a former HP employee.
PG&E v. Lexington Ins. Co. et al. (Superior Court of California, City & County of San
Francisco). Represented PG&E in litigation seeking CGL insurance coverage for environmental
liabilities arising out of historical manufactured gas plant operations.
Scheidt v. Metropolitan Life Ins. Co. (Superior Court of California, County of Marin).
Represented policyholder in successful litigation challenging denial of life insurance benefits.
Class Actions and Representative Plaintiff Actions
Philip Morris Incorporated. (Various matters.) Represented Philip Morris Incorporated in
actions brought by governmental entities and private plaintiffs seeking recoupment of medical
costs arising out of tobacco-related illnesses. Drafted successful oppositions to class certification
and successful appeal briefs affirming dismissal of challenges to Master Settlement Agreement
between states and tobacco companies.
Semler v. First Colony Life Ins. Co. et al. (Superior Court of California, City & County of San
Francisco). Represented plaintiff in successful litigation under California Business and
Professions Code challenging life insurers practice of charging premiums for periods of time in
which no insurance is provided. Obtained injunction following court trial against Guardian Life
Insurance Company of America. Argued successful summary judgment motions.
Intellectual Property Litigation

Chan v. Symantec Corporation (United States District Court, Northern District of California)
Defended Symantec Corporation in patent litigation relating to the LiveUpdate feature and
Internet hyperlinks contained in certain Symantec CD-ROM software products. Drafted
Markman brief and obtained favorable claim construction ruling. Worked with experts and
consultants in preparing opinions relating to claim construction, infringement and invalidity
issues.
ActivCard v. VASCO (United States District Court, District of Delaware). Represented
ActivCard in patent litigation relating to encryption technology.
Pro Bono
In re Marriage Cases (Supreme Court of California). Representation of plaintiffs in one of
several consolidated cases challenging on constitutional grounds Californias statutory exclusion
of same-sex couples from civil marriage.
Smith v. Knoller et al. (Superior Court of California, City and County of San Francisco).
Representation of plaintiff in civil wrongful death action arising from dog attack.
AMY WHELAN
Senior Staff Attorney
Northeastern University School Of Law, Boston, MA: Juris Doctor, May 2001
Princeton University, Princeton, NJ: Bachelor of Arts, June 1996
Senior Thesis: Gay Marriage: A Social Contract and Utilitarianism Analysis
Princeton Project 55 Fellowship (now Princeton AlumniCorps) at Disability Rights Advocates
Bar Admissions: California (2001); admitted to CA state and federal courts, several U.S. Courts
of Appeals, and U.S. Supreme Court
LEGAL EXPERIENCE
National Center for Lesbian Rights San Francisco, CA
Feb. 2011present
Senior Staff Attorney: Oversee NCLRs general litigation, policy, and public education work.
Supervise and manage legal team members in complex civil cases around the country. Litigate
numerous marriage equality cases, including in Florida, Idaho, Tennessee, Utah, and Wyoming,
as well as employment, discrimination, Title IX, First Amendment, family law, and complex
constitutional matters around the country.
Rosen Bien Galvan & Grunfeld, LLP San Francisco, CA
2001Jan. 2011
Associate: General and complex civil litigation firm, with an emphasis on civil rights, prisoners
rights, employment, and attorneys fees cases at the trial court and appellate levels. Perform all
litigation-related tasks for diverse cases and hire and manage paralegals and law student interns.
Highlights:
Member of 2008-2009 trial team in Coleman/Plata v. Schwarzenegger before federal
three-judge court and then U.S. Supreme Court, holding that California must reduce
prison overcrowding in order to meet the medical and mental health needs of prisoners.
Litigated post-judgment issues in Coleman v. Schwarzenegger, a class action lawsuit

under the 8th Amendment regarding mental healthcare in Californias state prison
system.
Litigated post-judgment issues and acted as a monitor in Armstrong v. Schwarzenegger,

a class action lawsuit under the ADA, the Rehabilitation Act and the 8th Amendment
regarding disability accommodations and access in Californias state prison system.
Represented a federal public defender in her administrative grievance process

regarding the federal governments discriminatory denial of healthcare benefits to her
same-sex partner. Obtained retroactive and ongoing benefits.
Responsible for all matters of civil discovery including taking and defending
depositions, developing expert testimony, propounding and responding to written
discovery and drafting and arguing motions.
Hired, managed and supervised paralegal staff and law student interns.
Legal Action Center, New York, NY

Fall 2000
Legal Intern: Conducted legal research and provided direct legal services to ex-offenders and
people with HIV experiencing discrimination in employment, housing, and public benefits.
American Civil Liberties Union of Northern California, San Francisco, CA
Spring 2000
Legal Intern: Conducted research regarding an array of constitutional and civil rights issues,
including a legal challenge to a Juvenile Crime voter initiative, a public school prohibition of
extracurricular activities on Jewish holidays in violation of the Establishment Clause, and the
Racial Justice Programs Driving While Black/Brown campaign.
San Francisco Human Rights Commission, San Francisco, CA
Fall 1999
Legal Intern: Advised and educated city contractors regarding compliance with San Franciscos
Nondiscrimination in Contracts ordinance.
Investigated and prosecuted complaints of
discrimination based on sexual orientation, gender identity, and HIV status.
Disability Rights Advocates, Oakland, CA
August 1996August 1998
Princeton Project 55 Fellow: Assisted attorneys representing persons with disabilities in class
action employment and public accommodations cases. Participated in a United Way Schools
Project to educate superintendents in more than fourteen school districts about the legal
requirements for physical and programmatic access for students with disabilities. Participated on
the trial team for a case of first impression against Macys for failure to provide physical access to
persons with disabilities.
SAMPLE PUBLICATIONS & PRESENTATIONS
Amy Whelan & Gay C. Grunfeld, No Time to Waste-Californias Rules for Claims against Public
Entities, The Recorder, winter 2009 Supplement at 6-7.
Sid Wolinsky & Amy Whelan, Federal Law and the Accommodation of Students with LD: The
Lawyers Look at the BU Decision (Guckenberger v. Boston University), Journal of Learning
Disabilities, Volume 32, Number 4, July/August 1999 at 286-291.
Amy Whelan, Presenter at National Lawyers Guild 2009 Disability Rights Seminar (The Changing
Face of Disability Rights Law), panel on Institutions: Prisons, Adult Homes & Integration of
Children.
Presenter at ACLU of Southern California 2010 Brown Bag Lunch Series, Prisoners Rights:
Mississippis Super-Max and California Prison Overcrowding Litigation.
Presenter at National Lawyers Guild 2010 Far West Regional Conference, panel on Prisoner
Overcrowding in California State Prisons.
Presenter at 6th Annual KBA CLE on LGBT Issues, First Amendment Issues as They Relate to the
Community, October 7, 2011.
2
David Coon, Heather Gray, and Amy Whelan, Presenters at 14th Annual Updates on Dementia
Conference, LGBT Aging Research and Practice: Updates and Implications for Care Panel, May
6 2012.
Amy Whelan & Julie Nice, Panelists at 2012 Summer Brown Bag Lectures In Public Interest Law,
The Season For Gay Rights? A Discussion of Emerging Constitutional Law, July 24 2012.
Cameo Speaker, Pacific Coast Labor & Employment Conference, April 26 2013.
EXHIBIT 1
QUSAIR MOHAMEDBHAI
wk. (303) 578-4400

fax (303) 578-4401
qm@rmlawyers.com
PROFESSIONAL BACKGROUND
Qusair is a partner at RATHOD | MOHAMEDBHAI LLC. His practice is
exclusively in the areas of plaintiffs employment discrimination and
constitutional civil rights litigation. He advocates for the rights of employees in
the workplace, and for the civil rights of all individuals against governmental
and institutional abuses of power.
AWARDS
Colorado Trial Lawyers Association Case of the Year (2014); Super Lawyer Plaintiffs Employment Law
(2014-2015); Super Lawyer Rising Star Civil Rights / First Amendment (2011 - 2013); National Lawyers
Guild First Amendment Defender Democratic National Convention (2008).
PROFESSIONAL ASSOCIATIONS AND MEMBERSHIPS
University of Denver Sturm College of Law - Adjunct Faculty (2014); Plaintiff Employment Lawyers
Association Board Member (2014); Colorado Trial Lawyers Association Co-Chair Employment Law
Section (2010-present); National Institute for Trial Advocacy Faculty (2012); Civil Rights Education &
Enforcement Center, Litigation Committee (2013-present); General Counsel, Colorado Muslim Society
(2010Present); Servicios de la Raza Board Member (2011-Present); Colorado Bar Association (2004Present); Wyoming Bar Association (2004-Present); Denver Bar Association (2004Present), South Asian
Bar Association (2010-Present); The National Association for the Advancement of Colored People (2011Present); Islamic Society of North America, Arbitrator (2011-Present).
EDUCATION & BAR ADMISSIONS
Qusair graduated from the University of Wyoming School Of Law, Laramie, Wyoming in 2003. He received
his undergraduate degree in Biological Sciences from the University of Alberta, Edmonton, Alberta in 2000.
Qusair is admitted to practice law in Colorado, Wyoming, the United States District Court, District of
Colorado, and Tenth Circuit Court of Appeals.
PUBLICATIONS
The Colorado Anti-Discrimination Act, Chapter Update, Practitioners Guide to Employment Law, Colorado
Bar Association (January 2015); Municipal Liability: Strategies, Critiques, and a Pathway Toward Effective
Enforcement of Civil Rights (Denver University Law Review, Volume 91, Issue 3); Religious Minorities
Need Not Apply: Legal Implications of Faith-Based Employment Advertising, 43 The Colorado Lawyer 27
(April 2014); Ramadan at Guantanamo Bay, Front Range Muslim Newspaper (October 2011); Colorado
Muslims Support Libyan Students, Front Range Muslim Newspaper (June 2011); Peter T. King and the
Radicalization in the American Muslim Community, Front Range Muslim Newspaper (April 2011); and The
Rights of Muslims in the Workplace, Front Range Muslim Newspaper (December 2010).
ACADEMIC LECTURING
Remedies For Sexual Violence: What All Attorneys Need To Know CLE, CWBA (January 2015); Harassment
and Discrimination in the Workplace CLE, Sterling Education Services, Cheyenne, Wyoming (September
2014); Taking a CCRD Probable Cause Finding to the ALJ CLE, PELA (August 2014); Employment Law
for the Personal Injury and Medical Malpractice Attorney: Issue Spotting and Avoiding Pitfall CLE, CTLA,
(August 2014); Workplace Privacy CLE, Colorado Bar Association (March 2014); Workplace
Discrimination CLE, Program Chair, Colorado Bar Association (January 2014), Nuts and Bolts of the CADA
Remedies Bill CLE, Colorado Trial Lawyers Association (December 2013); Stock Options: Pitfalls and
Considerations to your Employment Practice CLE, Colorado Bar Association, (October 2013); The EEOCs
Systemic Initiative, Ogletree Deakins Annual Employment Law Seminar (October 2013); Go F*ck Yourself
Defending Your Case with the First Amendment CLE, Colorado Public Defenders Office Annual Conference
(September 2013); Hanging Your Own Shingle CLE, Colorado Bar Association (August 2013 & 2012);
Employment Law Discovery & Evidentiary Issues CLE, Colorado Trial Lawyers Association (August 2013);
Stereotyping in Employment Discrimination CLE, Colorado Bar Association (April 2013); Summer Trial
Institute, Faculty, University of Wyoming School of Law (2011-2013); Employment Issues in Workers
Compensation Cases CLE, Colorado Bar Association (March 2013); 1983 is Not the Introduction to an
Orwell Novel CLE; Colorado Criminal Defense Bar (December 2012); Civil Rights for the Criminal Defense
Attorney -Colorado Public Defenders Adams County Office (September 2012); Colorado Progressive
Coalition: Understanding Civil Rights (September 2012); Building Your Case With the Bill of Rights Federal Practice Series CLE (September 2012); See the Forest and the Trees When Evaluating an
Employment Discrimination Case CLE, Wyoming Bar Association Annual State Bar/Judicial Conference
(September 2012); Successfully Navigating the Criminal Justice System as Plaintiffs Employment Attorneys:
Representing the Victim/Witness of a Crime CLE, Plaintiffs Employment Law Association Annual Retreat
(August 2012); Religious Rights in the Workplace CLE, Colorado Bar Association (May 2012); Civil Rights
for the Criminal Defense Attorney, Colorado Public Defenders Denver Office (May 2012); National Institute
for Trial Advocacy, Faculty: Trial Skills (April 2012);10 Dos and Donts of Starting a law Firm, Colorado
Bar Association CLE (March 2012); Constitutional Litigation - University of Denver Law School (October
2012); Employment Discrimination, Guest Speaker, Denver Islamic Society (June 2011); Muslims and Law
Enforcement, Guest Speaker, Colorado Muslim Society (December 2010); First Amendment in Employment
CLE, Sterling Education Services, Cheyenne, Wyoming (November 2010); Panelist, First Amendment and
Academic Freedom, University of Wyoming, Laramie, Wyoming (April 2010).
REPRESENTATIVE CASES
Robert Dienes v. CVNA, 2014cv02132 (Disability Discrimination); Shelli Robins v. Adams 14 School District, 2014cv01794-WYD-KMT (Gender Discrimination)(2014); Wilson v. Pauling Management Co et al.,
2013-cv-035298 (Employment Discrimination); Hart v. VK Investment Group, LLC, 13-cv-02301 (Housing
Discrimination); Blair v. Resort Management Group, 13-cv-01298 (Employment Gender Discrimination);
Carpenter v. CenturyLink, 2013-cv-032401 (Wrongful Discharge); Hunter v. City and County of Denver et
al., 2012-cv-5623 (Prisoner Civil Rights); Morgan et al v. Colorado Department of Corrections et al., 12-cv0936 (Prisoner Civil Rights); Ortega et al. v. City and County of Denver, et al., 11-cv-02394 (Police
Brutality and Governmental Liability); Perry v. Red Peak et al., 11-cv-01900-WYD-CBS (Housing
Discrimination); Blake v. 23 LTD et al., 11-cv-8197 (Employment Gender Discrimination and Retaliation;
Shroff v. City and County of Denver et al., 604 F.3d 1179 (10th Cir. 2010) (False Arrest and Violation of
Bodily Integrity against Denver Police Officer); Martinez et al v. City and County of Denver et al, 11-cv00102-MSK -KLM (Home Invasion and Excessive Force Against Denver Police Officers); Rehberg v. City
of Pueblo et al, 10-cv-00261-LTB-KLM (Excessive Force and Unlawful Entry against Pueblo Police
Officers); Moore v. City and County of Denver et al,10-cv-00651-JLK -MJW (Excessive Force and False
Arrest against Denver Police Officers); Hardy v. Procter & Gamble Company; 10-cv-01867-MSK -MEH
(Disability Discrimination in Employment); Graber v. City & County of Denver et al, 09-cv-01029-JLKMJW (Excessive Force and False Arrest against Denver Police Officers); Duran v. City & County of Denver
et al, No. 10-cv-01569-REB-KMT (Excessive Force against Denver City Jail and Denver Deputy Sheriff);
Alpers v. Town of Erie,10-cv-01105-WDM-CBS (Excessive Force against Erie Police Department and K-9);
Kreck v. City & County of Denver, 10-cv-01474-LTB-MEH (First Amendment Retaliation Against Denver
Police Officer); Ayers v. University of Wyoming; 10-cv-00079-WFD (First Amendment Retaliation); Hall,
Aragon, Jordan, Appleberry, & Arnall v. Adams County, No. 09-cv-02836-WYD-BNB (Sexual Harassment,
Retaliation, and/or First Amendment Retaliation against Adams County Coroners Office); Trujillo v. City of
Lakewood, No. 08-cv-00149-WDM-CBS (Excessive Force against Lakewood Police Officers and K-9;
Chavez et al v. Fitzsimons Community Federal Credit Union, 07-cv-01529 (Race Discrimination in
Employment); McGuire-Mann v. Naked Juice Company, 2008 Arbitration, (Sexual Harassment in
2
Employment); Echegaray v. Rygiels Obstetrics, 2007cv3693 (Pregnancy Discrimination in Employment);

Churchill v. University of Colorado, 2006CV11473 (First Amendment Retaliation in Employment); and
O'Neil v. West Cheyenne Fire Prot. Dist., 05-cv-02173-RPM (Excessive Force and Unlawful Entry).
Pro Bono: Kahn Family (2013); John Copeland (2013); Occupy Denver Legal Training (2012);
Proposition 8 / Gay Rights Representation of Protestors (2009); Democratic National Convention
Representation of Protestors (2008); Columbus Day Representation of Protestors (2007).
EXHIBIT 2
ARASH JAHANIAN
wk (303) 578-4400
fax (303) 578-4401
aj@rmlawyers.com
1518 Blake Street

PROFESSIONAL BACKGROUND
Arash Jahanian is an attorney at Rathod | Mohamedbhai LLC. His practice
includes advocating for the civil rights of employees in the workplace and
individuals suffering governmental and institutional abuses of power. Prior to
joining Rathod Mohamedbhai, Arash was an associate in Crowell & Moring
LLPs Washington, DC office and a judicial clerk for the Honorable Wiley Y.
Daniel, Chief Judge of the United States District Court for the District of
Colorado.
PRIOR EXPERIENCE
While at Crowell & Moring, Arash worked in the Labor & Employment and Litigation practice groups. His
Labor & Employment practice was focused on litigating employment discrimination claims and wage-and-hour
claims under the Fair Labor Standards Act (FLSA). His practice in the Litigation group focused on education
civil rights law and on bringing claims against foreign governments on behalf of victims of state-sponsored
terrorism. Through his pro bono practice, Arash helped victims of an immigration raid gain recourse for
constitutional civil rights violations by federal officers.
From 2003 to 2005, Arash taught in Chicago Public Schools as a Teach For America corps member. Dedicated
to closing the achievement gap in underprivileged schools, Arash taught math, language arts, and Spanish. He
also coached boys softball and led after-school tutoring programs.
EDUCATION
Arash graduated Cum Laude from Georgetown University Law Center, Washington, D.C. in 2008. He served as
Articles Editor for the Georgetown Journal of Gender and the Law and participated in the Center for Applied
Legal Studies, Georgetowns political asylum clinic. He also helped to found the Georgetown Journal of Law &
Modern Critical Race Perspectives, for which he served as Symposium Chair during the journals inaugural
year. Arash received his undergraduate degree, with Highest Honors, in Psychology and Journalism and Mass
Communication from the University of North Carolina at Chapel Hill in 2003.
REPRESENTATIVE CASES
Dienes v. Colorado Visiting Nurse Association, 14-cv-3132 (Disability Discrimination (2014)
Courage, et al. v. State of Wyoming, et al., Civil Action No. 182-262 (Marriage Equality) (2014)
Robins v. Adams County School District 14, 14-cv-01794-WYD-KMT (Gender Discrimination) (2014);
Carpenter v. CenturyLink, Inc. et al., 2013cv32401 (Retaliation in Employment) (2013)
Blair v. Resort Management Group, LLC Hunter v. City and County of Denver et al., 13-cv-01298WJM-CBS (Sexual Harassment) (2013)
Hunter v. City and County of Denver et al., 12-cv-02682-JLK (Prisoner Civil Rights) (2012)
Morgan et al. v. Colorado Department of Corrections et al., 12-cv-00936-RM-KMT (Prisoner Civil
Rights) (2012)
Ortega et al. v. City and County of Denver et al., 11-cv-02394-WJM-CBS (Police Brutality) (2011)
HONORS AND AWARDS
Super Lawyer Rising Star
PROFESSIONAL ASSOCIATIONS AND MEMBERSHIPS
Denver GLBT Commission, Commissioner
Colorado GLBT Bar Association, Board Member, Programming Committee Co-Chair

Arash Jahanian
One Colorado, Strategic Assessment Group

Colorado Bar Association, Civil Rights Committee
Plaintiffs Employment Lawyers Association
Colorado Trial Lawyers Association
Denver Bar Association
South Asian Bar Association
Asian Pacific American Bar Association of Colorado
PUBLICATIONS
Religious Minorities Need Not Apply: Legal Implications of Faith-Based Employment Advertising,
The Colorado Lawyer, Co-Authors: Matthew J. Cron, Arash Jahanian, Qusair Mohamedbhai, and
Siddhartha H. Rathod, 2014
Municipal Liability: Strategies, Critiques, and a Pathway Forward Toward Effective Enforcement of
Civil Rights, University of Denver Law Review, Volume 91, Issue 3, Co- Authors: Matthew J. Cron,
Arash Jahanian, Qusair Mohamedbhai, and Siddhartha H. Rathod, 2014
True Endorsement: A Critical Race Approach to Bans on Same-Sex Marriage, Georgetown Journal of
Gender & the Law, 2008
The Foreign Sovereign Immunities Act: 2010 Year In Review, Co-Authors and Editors: Laurel Pyke
Malson, Katherine Nesbitt, Aryeh S. Portnoy, Lisa Savitt, Birgit Kurtz, David Bell, Arash Jahanian,
Jonathan Anastasia, Elizabeth Carter, Melanie Natasha Henry, Nicholas Fromherz, Julia Franklin, and
Dalal Hasan, 2011
The Foreign Sovereign Immunities Act: 2009 Year in Review, Co-Authors and Editors: Laurel Pyke
Malson, Katherine J. Nesbitt, Aryeh S. Portnoy, Birgit Kurtz, John Murino, Joshua Dermott, Beth
Goldman, Arash Jahanian, Marguerite Walter, Howard Yuan, Lisa Savitt, and David Bell, 2010
LANGUAGES
Spanish
Farsi
BAR ADMISSIONS
Colorado
New York
District of Columbia
U.S. District Court for the District of Colorado
U.S. District Court for the District of Maryland
EXHIBIT 3
February 26, 2015

Guzzo, et al.
Client Code: 0080
RE:
Rathod Mohamedbhai LLC Time Entry Report for Guzzo, et al. v. Matthew H.
Mead, et al., Civil Action No. 182-262 (D. Wyo.)
Tuesday, October 7, 2014 to Thursday, February 26, 2015
DATE
ATTORNEY /
STAFF
DESCRIPTION
RATE
TIME
TOTAL
(6 min)
Jahanian
Review and revise draft

Complaint; research
affidavit requirements
for preliminary
injunction motion.
200
3.50
$700.00
Belzer
Research affidavit
requirements for
Preliminary Injunction
Motion.
140
$280.00
Jahanian
Continue researching
affidavit requirements
for preliminary
injunction motion; revise
motion.
200
1.00
$200.00
Wednesday, October 08,

2014
Belzer
Research affidavit
requirements for
preliminary injunction
motion.
140
3.00
$420.00
Thursday, October 09,

2014
Strategize re subpoena;
prepare clients for
Mohamedbhai hearing.
300
2.80
$840.00

2014
Prepare subpoena;
confer re pro hac vice
motions; draft motion
for summary judgment.
200
3.30
$660.00
Tuesday, October 07, 2014

2014
Jahanian
2701 LAWRENCE ST., SUITE 100 DENVER, CO 80205 303.578.4400 (t) 303.578.4401 (f) www.RMLawyers.com

Guzzo, et al.
Client Code: 0080
Page 2 of 6
DATE
ATTORNEY /
STAFF
DESCRIPTION
RATE
TIME
(6
min)
TOTAL

2014
Belzer
Research requirements
for and prepare
subpoena.
140
1.9
$266.00
Friday, October 10, 2014
Continue strategizing re
Mohamedbhai subpoena.
300
0.60
$180.00
Jahanian
Confer with Attorney

General's Office re
subpoena; continue
drafting motion for
summary judgment.
200
2.60
$520.00
Belzer
Conduct research for

summary judgment
motion.
140
3.00
$420.00
Sunday, October 12, 2014
Review draft reply to

Defendant Lathrop's
response to motion for
confer re hearing
Mohamedbhai testimony.
300
1.00
$300.00
Monday, October 13, 2014
Confer re motion to
quash subpoena and
reply to State
Defendants' response to
Mohamedbhai motion.
300
0.70
$210.00
Jahanian
Draft response to
motion to quash
subpoena; draft reply to
State Defendants'
response to preliminary
injunction motion.
200
8.20
$1,640.00
Belzer
Conduct research for

draft response to motion
to quash.
140
1.90
$266.00

Guzzo, et al.
Client Code: 0080
Page 3 of 6
DATE
ATTORNEY /
STAFF
DESCRIPTION
RATE
TIME
(6
min)
TOTAL
Finalize pro hac vice

motion; review and
revise reply to State
motion; prepare for
300
3.00
$900.00
Finalize pro hac vice

motions; continue
drafting reply to State
motion; prepare for
hearing.
200
6.20
$1,240.00
Conduct legal research

re recent denials of stay
in marriage equality
cases.
140
1.70
$238.00
300
2.60
$780.00
200
6.00
$1,200.00
Jahanian
Tuesday, October 14, 2014 Belzer

2014
Prepare clients for

hearing; continue
Mohamedbhai preparing for hearing.
Prepare clients for
hearing; prepare for
standing argument.

2014
Jahanian

2014
Continue preparing for

hearing; participate in
300
3.00
$900.00

2014
Jahanian
Continue preparing for

hearing; participate in
hearing including
standing argument.
200
3.00
$600.00
Review Court's
Order; confer re next
Mohamedbhai steps.
300
0.50
$150.00

Guzzo, et al.
Client Code: 0080
Page 4 of 6
DATE
ATTORNEY /
STAFF
DESCRIPTION
RATE
TIME
(6
min)
TOTAL
Jahanian
Review Court's
Order; confer re next
steps.
Jahanian
Confer and strategize re

lifting of stay.

2014
Review and confer re

draft stipulated
Mohamedbhai jungment.
300
0.20
$60.00

2014
Jahanian
Review and confer re

draft stipulated
judgment.
200
0.40
$80.00
Jahanian
Review and revise draft

stipulated judgment;
review Defendant
Lathrop's Answer to
Complaint.
200
0.40
$80.00
Jahanian
Review draft stipulated

judgment.
200
0.20
$40.00
Jahanian
Continue reviewing,
revise draft stipulated
judgment.
200
0.50
$100.00
Friday, November 07,

2014
Jahanian
Review Defendants'
Answer to Complaint.
200
0.20
$40.00
Monday, November 10,

2014
Review, confer re
Defendants' motion for
judgment on the
Mohamedbhai pleadings.
300
0.20
$60.00
Monday, November 10,

2014
Jahanian
Review, confer re
Defendants' Motion for
Judgment on the
Pleadings.
200
0.50
$100.00
Jahanian
Review Preliminary
Injunction Hearing
Transcript.
200
0.40
$80.00

Tuesday, November 04,
2014
Wednesday, November
05, 2014
Tuesday, November 18,

2014
200
0.50
$100.00
200
0.20
$40.00

Guzzo, et al.
Client Code: 0080
Page 5 of 6
DATE
ATTORNEY /
STAFF
Tuesday, January 13, 2015

Wednesday, January 14,
2015
Wednesday, February 04,
2015
2015
Friday, February 06, 2015
Monday, February 09,
2015
Monday, February 09,
2015
2015

2015
Thursday, February 19,
2015
RATE
TIME
(6
min)
TOTAL
Review and revise Draft

Motion for Judgment on
the Pleadings.
200
0.40
$80.00
Prepare Fee Petition.

Revise Fee Petition.
200
200
2.60
0.60
$520.00
$120.00
Confer re and revise

Reply in Support of
Motion for Judgment on
the Pleadings.
200
3.40
$680.00
Mohamedbhai Review fee petition.
300
0.20
$60.00
Jahanian
Revise Fee Petition.
200
1.00
$200.00
Jahanian
Draft and file Notice of

Change of Address.
200
0.50
$100.00
Jahanian
Review and revise

motion for oral
argument.
200
0.10
$20.00
Mohamedbhai Confer re fee petition.
300
0.30
$90.00
Jahanian
Confer re fee petition.
Jahanian
200
300
200
0.30
0.40
0.40
$60.00
$120.00
$80.00
Confer with opposing

Mohamedbhai counsel re fees.
300
0.20
$60.00
Jahanian
200
0.20
$40.00
300
0.30
$90.00
200
1.20
$240.00
300
0.10
$30.00
Friday, November 21,

2014
Jahanian
Thursday, December 04,
2014
Jahanian
Friday, December 05, 2014 Jahanian
Thursday, December 11,

2014
Monday, December 15,
2014
Monday, December 15,
2014
DESCRIPTION
Jahanian
Jahanian
Confer with co-counsel

and opposing counsel re
fee petition; draft and
file motion for
extension.

Guzzo, et al.
Client Code: 0080
Page 6 of 6
DATE
ATTORNEY /
STAFF
DESCRIPTION
RATE
TIME
(6
min)
TOTAL

2015
Jahanian
200
0.40
$80.00


Mohamedbhai counsel re fees.
Jahanian
300
200
0.10
0.20
$30.00
$40.00
Tuesday, February 24,

2015

counsel re fees; confer
Mohamedbhai re appropriate fees.
300
1.20
$360.00
200
7.20
$1,440.00
Tuesday, February 24,

2015
Jahanian

2015
Revise affidavit in
Mohamedbhai support of fee petition.
300
0.50
$150.00

2015
Jahanian
Continue revising Fee

Petition and affidavit in
support.
200
8.10
$1,620.00

2015
Revise fee petition and

Mohamedbhai affidavit in support.
300
4.00
$1,200.00
200
7.00
$1,400.00

2015
Jahanian
Revise Fee Petition; draft

affidavit in support.
Continue revising and

file Fee Petition and
exhibits.
TOTAL FEES
104.10 $22,600.00
EXHIBIT 4
February 26, 2015

Guzzo, et al.
Client Code: 0080
RE:
DATE
10/9/2014
10/10/2014
10/14/2014
10/14/2014
10/15/2014
10/15/2014
10/15/2014
10/15/2014
10/15/2014
10/16/2014
10/16/2014
10/20/2014
12/17/2014
Rathod Mohamedbhai LLC Cost Report for Guzzo, et al.

October 9, 2014 to December 17, 2014
PAYEE
Process Service of Wyoming, Inc.
Process Service of Wyoming, Inc.
FedEx
FedEx
FedEx
Qusair Mohamedbhai
0404 - MOTEL 6 CASPER
Wendy's
hotels.com (Motel 6)
Qusair Mohamedbhai
Sanfords Grub and Pub Casper
FedEx
RM
TOTAL
AMOUNT
100.00
80.00
5.91
1.60
16.52
155.12
3.14
3.57
142.52
155.12
21.10
16.52
42.60
$743.72
DESCRIPTION
Service of Subpoena
Service of Subpoena
Mailing
Mailing
Mailing
277 miles x $0.56 (Denver-Casper)
Internet
Food before hearing
Lodging for hearing
277 miles x $0.56(Casper-Denver)
Food after hearing
Mailing
Total Printing (284 pages x .15)
2701 LAWRENCE ST., SUITE 100 DENVER, CO 80205 303.578.4400 (t) 303.578.4401 (f) www.RMLawyers.com
2013 Wyoming State Bar Member Survey Results

Total Distribution = 1,641 (All In-State Active)
Total Respondents = 453
Response Rate = 28%
DEMOGRAPHICS
1. In which judicial district do you live?
Rating
Percent
First Judicial District
35.6%
Second Judicial District
11.6%
Third Judicial District
8.2%
Fourth Judicial District
6.2%
Fifth Judicial District
8.2%
Sixth Judicial District
7.8%
Seventh Judicial District
11.6%
Eighth Judicial District
2.9%
Ninth Judicial District
7.8%
Answered Question
Skipped Question
Rating
Total
160
52
37
28
37
35
52
13
35
449
4
BAR STAFF & LEADERSHIP

2. Please rate your experience with the members of the Wyoming State Bar staff.
Executive Director,
Sleeter Dover
Deputy Executive Director,
Sharon Wilkinson
Mark Gifford,
Bar Counsel
Brandi Robinson,
Assistant to Bar Counsel
Marie Ellis,
CLE Director
Nancy Shore,
Admissions Director
Cathy Duncil,
Lawyer Referral Coordinator
Ashlee Rawlinson,
Administrative Assistant
Excellent
Good
Average
Fair
Poor
N/A
38.4% (165)
Rating
Average
3.57
Rating
Count
430
23.7% (102)
19.3% (83)
13.0% (56)
2.8% (12)
2.8% (12)
51.6% (223)
25.5% (110)
3.9% (17)
1.9% (8)
0.5% (2)
16.7% (72)
2.24
432
37.7% (162)
17.9% (77)
4.7% (20)
2.8% (12)
3.3% (14)
33.7% (145)
3.17
430
12.0% (50)
11.8% (49)
3.4% (14)
0.7% (3)
1.0% (4)
71.2% (297)
4.81
417
51.6% (223)
28.2% (122)
6.0% (26)
2.5% (11)
0.5% (2)
11.1% (48)
2.05
432
14.7% (62)
11.2% (47)
4.0% (17)
1.2% (5)
3.8% (16)
65.1% (274)
4.63
421
18.2% (77)
11.1% (47)
2.6% (11)
0.0% (0)
0.0% (0)
68.1% (288)
4.57
423
13.0% (55)
10.2% (43)
2.1% (9)
0.2% (1)
0.0% (0)
74.4% (314)
4.87
422
Answered Question
Skipped Question
437
16
Comments:
I have had experiences with the WY State Bar that have me left me with the impression that this entity is not here to assist the attorneys in the
state. Especially when it comes to registering CLE credits.
Have not had much experience with bar staff
have not had contact with several, therefore "N/A"
Don't know most of these folks
Sharon is the best!
Ms. Ellis appears to be tepid at best in responding to questions.
I have not had much direct communication with the office.
2
I am pleased the WSB is hiring a full time bar counsel, in the past it seemed serious misconduct by practicing attorneys got little attention, with
the excuse being bar counsel was overwhelmed.
good staff
all contacts have been by email
Always responsive and helpful
GREAT STAFF!
Both Sharon and Marie to yeoman's work for the Bar and their work is always incredibly detailed and well done
I put N/A for individuals I have never dealt with.
The hurdles to have out-of-state MCLE counted are excessive
great improvement over prior bar counsel and her assistant. will miss Mark but Jim will do great job. Current staff much friendlier than in past.
will miss Sleeter!
Have had positive experiences with everyone!
contact limited, so tough to draw conclusions.
i don't know the n/a folks
Great staff at the bar...
sharon is the best
I called Gifford with some questions re an ethics issue. I left numerous voice mails, even one with his assistant. I NEVER received a return call.
There are some staff at the WSB who should not be working there.
Sleeter never greeted lawyers or acted like he cared who we were. Very disappointing.
The Bar staff are always responsive to questions. They do a great job.
Nancy Shore could be a little nicer to potential bar admittees. She was very unpleasant and brusque with me on several occasions.
Sharon represents the Wyoming STate Bar in a way that makes everyone proud.
3. Do you know who the elected Bar Commissioner is that represents your Judicial District?
Rating
Percent
Yes
59.0%
No
41.0%
Answered Question
Skipped Question
Rating
Total
255
177
432
21

4. Please rate the effectiveness of your Bar Commissioners communication with you regarding the following:
Upcoming Board of Officers &

Commissioners meetings
Annual meeting of your
judicial district (mandated by
Article III, Section 4(b) of the
Bylaws of the Wyoming State
Bar)
Activities at the
Wyoming State Bar
Follow-up on meetings
Excellent
Good
Average
Fair
Poor
19.5% (49)
Rating
Average
2.77
Rating
Count
251
20.3% (51)
29.5% (74)
22.7% (57)
8.0% (20)
22.6% (57)
31.3% (79)
23.4% (59)
6.3% (16)
16.3% (41)
2.62
252
21.4% (44)
33.7% (85)
21.0% (53)
7.5% (19)
16.3% (41)
2.63
252
18.0% (44)
30.2% (74)
23.7% (58)
9.4% (23)
18.8% (46)
2.81
Answered Question
Skipped Question
245
254
199

BAR SERVICES & ACTIVITIES
5. Please rate the following sections of the Wyoming Lawyer:
You Need to Know (news,

notes and other items of
interest)
From the President
From the Executive Director
Office of Bar Counsel
My Perspective
(individual authors
perspective
on a chosen topic)
Feature Articles
Ethically Speaking by
John M. Burman
Court Summaries
Law School News
Information Connection
(various articles provided
by law librarians)
Article Discipline
Classified Advertising
Always
Read
28.8% (117)
Usually
Read
43.8% (178)
Sometimes
Read
23.9% (97)
Never Read
16.5% (68)
14.4% (59)
30.2% (124)
10.2% (42)
30.2% (124)
28.4% (116)
39.2% (161)
34.1% (140)
14.2% (58)
29.8% (124)
2.0% (8)
Unaware
1.5% (6)
Rating
Average
2.03
Rating
Count
406
42.6% (175)
44.7% (183)
26.3% (108)
51.0% (209)
10.0% (41)
11.7% (48)
3.6% (15)
3.7% (15)
0.7% (3)
0.7% (3)
0.7% (3)
1.0% (4)
2.48
2.56
2.06
2.51
411
409
411
410
45.3% (185)
33.7% (140)
39.2% (160)
30.3% (126)
1.0% (4)
5.8% (24)
0.2% (1)
0.5% (2)
2.28
2.13
408
416
36.1% (149)
9.1% (37)
8.1% (33)
38.0% (157)
26.0% (106)
24.1% (98)
20.6% (85)
44.1% (180)
52.1% (212)
4.8% (20)
19.1% (78)
13.5% (55)
0.5% (2)
1.7% (7)
2.2% (9)
1.96
2.78
2.78
413
408
407
57.5% (238)
16.5% (67)
29.2% (121)
24.9% (101)
11.8% (49)
42.7% (173)
1.2% (5)
14.8% (60)
0.2% (1)
1.57
1.0% (4)
2.59
Answered Question
Skipped Question
414
405
417
36
6. What else would you like to see in the Wyoming Lawyer?
letters/comments from readers

Nothing
It seems to me the lawyers who lack, and could use more, support are sole or small office practitioners- maybe more in the way of practical
material. The WL does a pretty good job but this would be an area of possible expansion.
I don't have any suggestions
Plain color pages that are easieer to read then the multi-colored bit.
5
new technology
More on keeping the Access to Justice program active and productive.
Indian Child Welfare Act requirements in child custody proceedings!
More practice-based articles.
Changing or evolving trends in case law -- fro example, changes to judicial views regarding damages and collateral source as pertains to medicaid,
workers' comp and whether the measure of damages should be amount billed or paid.
More articles about problems encountered by Wyoming lawyers.
Substantive content Judicial perspective
Orders adopting changes to court rules. Important statutory changes that affect the practice of law.
More emphasis on nuts and bolts of practicing law
I always look forward to getting the Wyoming Lawyer.
Reports on and access to significant or unusual topic District Court decisions. Including the decision letter, findings of fact, conclusions of law,
orders and forms of judgment would be very helpful..
I would like to see the results of the meeting wherein by a 5to 2 vote the committe voted to reinstate preemt. for judges. Two no votes were by
judges. Found NO abuse.
A "featured lawyer" article. Maybe highlighting an attorney's achievements or service.
Report on activities to educate public about non lawyer legal advice
I think we have an excellent magazine, I wouldn't change a thing.
Significant U.S. Supreme Court case summaries.
The technology things in the last issue were really great. Maybe an ongoing tech update, or new things.
More articles about the way people are accomplishing the same task in different Courts. Legislative updates. Overviews of different areas of the
law
Profiles of Wyoming attorneys
A list of the CLEs that are available and where they are taking place.
Discussions, articles of new ideas in the practice of law.
Crossword puzzle
actually helpful information.
Some cartoons if they are really good.
More stories on attorney and Bar community service and philanthopy.
From the Bench; Comments or articles from Judges every month on Bench/Bar relations, civility.decorum and strong hints on how they have in
the past or might in the future rule on discovery and other lawyer disputes. These articles might encourage more cooperative behavior and help
reduce the cost of legal services.
Just a well done benefit of being a Wyoming lawyer and often flag articles and go back and re-read them.
6
I would like to see an CLE offered in the WY lawyer that is counted for a live credit. There could be an article to read with a quiz afterwards to
send in to be graded. You could earn 1 CLE per quiz you submit to the CLE office. (Example, California does this and charges on $15 per CLE- it's a
great way to get CLE each month)
more articles written by attys on specific issues
A forum on electronic discovery, problems and suggestions.
4/26/2013 10:14 AMView Responses
More practice tips for solos.
Monthly treasurer's report and summary of the commissioner's meetings.
More information on community service matters that members of the Bar are involved in. I think this would encourage even more involvement
as well as making known the positive contributions of our membership to their communities.
Fewer stock photos of smiling young lawyers, more photos of real Wyoming lawyers
Life-style activities outside of law practice.
More guest articles from attorneys with expertise in specific areas.
More interactive electronic formatting, hyperlinks, and links to free legal research sites.
I would like to see more verdict results for civil trials in Wyoming published. Seems as though this information should be easily obtained from the
various Circuit and District court clerks with a bit of cooperation.
Instead of having columns by exec dir and bar pres -- their comments should be crafted into news stories. They would get much more review that
way.
More useful articles, not just "here's what we are doing at the bar, look at us!"
more profiles on attorneys in non-traditional roles, profiles on judges
articles on implications of the law and cutting edge advancements of science
Spotlights on attorneys in the bar
An announcement that I will no longer be required to subscribe to the Wyoming Lawyer and the Wyoming Law Review, and that my bar due will
be reduced as a result.
Many of the articles are "fluff pieces." Something with real substance would be better. Please skip the trips down memory lane and feature
stories on lawyers. These are boring.
CLE topic with online quiz for . to 1 hr of cle per publication
It is an impressive, well put together publication. Sharon has done an amazing job.
Nothing comes to mind right now.

7. An enhanced digital edition of the Wyoming Lawyer is available on the Bars website at www.wyomingbar.org. Have you taken advantage of this
feature to find a past article?
Rating
Percent
Yes
31.3%
No
68.7%
Answered Question
Skipped Question
Rating
Total
131
287
418
35
8. Please rate the following Wyoming State Bar member benefits:
Wyoming State Bar Legal

Directory
Wyoming Lawyer magazine
Casemaker
LawPay
Live Well Solutions
Use of Wyoming State Bar
meeting rooms
Listserves
Wyoming Law Review
Excellent
Good
Average
Fair
Poor
Unaware
69.9% (293)
23.9% (100)
4.1% (17)
0.7% (3)
0.2% (1)
37.5% (156)
27.9% (112)
3.6% (14)
3.6% (14)
8.6% (33)
51.4% (214)
27.2% (109)
10.4% (40)
14.4% (56)
14.9% (57)
8.2% (34)
13.0% (52)
11.2% (43)
11.6% (45)
9.4% (36)
1.7% (7)
4.0% (16)
2.3% (9)
8.0% (31)
2.9% (11)
7.0% (27)
19.1% (77)
13.7% (53)
38.9% (157)
13.4% (52)
22.8% (92)
4.6% (18)
6.9% (28)
1.2% (5)
Rating
Average
1.41
Rating
Count
419
0.5% (2)
1.7% (7)
4.2% (16)
5.1% (20)
2.9% (11)
0.7% (3)
26.2% (105)
68.3% (263)
57.3% (223)
61.3% (234)
1.78
3.03
4.98
4.69
4.60
416
401
385
389
382
3.4% (13)
2.2% (9)
58.0% (225)
4.58
10.1% (41)
2.65
Answered Question
Skipped Question
388
404
419
34

9. In the space provided, please describe other services you would like the Wyoming State Bar to provide its members.
Do we have an attorney insurance plan?

Health insurance (NOT)
maybe a little more in the way of a referral network
I don't have any suggestions.
online digest of articles, rules, guidelines about problems with electronic discovery
Solo Practitioner medical insurance, for those of us without employees.
Stay with Core services ie; admission, disciplinary action, fee arbitration. Limit the non-core functions like live-well solutions as there are plenty
of other resources for these and no need for the Bar to provide these as an integrated Bar. Some might perceive a need for the Bar to become a
lender to its members but having our own Credit Union should not be a function of the Wyoming Bar.
Group health insurance through a reputable company that won't go belly up.
The bar directory in a digital format. Support to get filing with the courts online. Try to encourage this to happen faster. To eliminate the politics
from the assessment of ethical issues. Who u r has a great deal to do with how the bar treats u.
Training for legal staff, more free CLE
Good and affordable health insurance still remains an issue where all enrollees are considered the group, and not individual firms or enrollees. I
also wonder if the Bar should investigate to find out whether there is a well respected investment firm out there that if endorsed by the State Bar
would lower service charges to members/firms who established their retirement plans through them. I also wonder if discounted rates might be
obtained from a cell phone provider such as Verizon, etc. as benefits to Bar members and firms. I am thinking of ways to assist firms in cutting
costs while also potentially increasing the benefits available to attorneys and to our staff.
Some services for attorneys who don't practice or those that aren't in private practice would be nice. Sometimes it seems the Bar forgets that
there are a large group of us that aren't in private practice and a group of us that don't practice.
Not other services, but improve the communication with and outreach to members with current services
What listserves?
Make training on using Casemaker more readily available.
Discounts on hotels and car rentals
More information on the availablity and comparative cost of legal malprcatice insurance.
More assistance and reduced rate CLE for sole and small firm practitioners.
Insurance coverage for solo attorneys
Work with Wyoming Supreme Court committee to substantially expand use of mandatory standard form discovery to reduce the cost of
litigation.
The bar has become a lap dog for dictatorship by The Supreme Court.
ipad app for Wyoming lawyer and law review would be helpful.
The way the Judge/Admin. Assistant/Clerk of Court listings (particularly for traveling judges) are presented in the Legal Directory, could be
reorganized for clarity. The District Attorney listings should also be included in the section for clarity.
9
I would opt out of receiving the Wyo Law Review to save paper and view it online instead.
I would like the option to receive the Law Review online ONLY, rather than a hard copy.
More active committees
Provide more free CLEs
Discussion and advisory opinions of ethical questions posited so that the inquiring attorney(s) may avoid activity in the Bar Court.
Solo practitioner reduced insurance and increased assistance
New laes and their effects
paid sabaticals
I'd like the list serves to be available for more functions. Like, when someone in the bar is supporting or hosting a non-CLE event, it would be
great to use the list serve to circulate the news.
I think there is a lack of good CLE in this state for the number of hours we are supposed to receive per year, as well as 10 of them having to be
"live". I think the bar should provide more teleconferences or webcasts that are low cost and should allow attorneys to get the majority of their
CLE as a "self-study" credit, because the program locations are so far and wide in this state. Living in Teton County, I haven't seen one live
program in the last 5 months that I could attend conveniently.
Enough services are provided. Further expansion is not warranted.
Where unaware is marked it is because it is geographically unusable or inapplicable to our practice.
keep doing what you are doing
Regular lists of upcoming CLE seminars
Solo insurance
CLEs on any rules changes at various locations around the State.
Can the State Bar Directory be made available in electronic form compatible with Outlook-Contacts so it could be loaded as a separate Contacts
List. This would save a huge amount of time for mailings, phone calls and emails.
Perhaps another run at group health insurance, losing that was a big loss for the little guys out there.
Health insurance would have been nice, but that didn't work so well. Why couldn't a group plan with a major carrier work?
I'd like to see the State Bar encourage the use of the List Serves. And, if possible, I think they should be expanded to be topical, as well as by
district.
More support for improvement projects
Attorney mentoring, solo practitioner mentoring programs, more free ethics CLE hosted at the Wyoming Bar Association or other location.
The health insurance experiment was disappointing. This is still a need.
Discounts on Legal Malpractice insurance
It would be interesting to know how many hours of CLE which members collect are actually relevant to their legal work. CLE programs on a wide
range of topics should be made available on line and the 5-hour limit removed, so that attys could focus on relevant programs instead of sitting
through hours of talk about something not relevant.
More free CLEs
10
You left the State Bar Convention off the list... by far one of the best services you offer! The quality & diversity of CLE is unparalleled
For lawyers who are willing to share the information, include cell phone numbers in the directory.
Free cle's.
Social events
Programming outside of Cheyenne and Casper.
More low-cost or free CLE would be appreciated. It would also help if the CLE rules were amended to allow 100% of the hours to be earned
through home study / self study like many other states (e.g., Colorado). It is too expensive to take a full day away from the office, travel, stay in a
motel and pay hundreds of dollars for 4 or 5 hours of CLE. The bar convention is also far too expensive and I haven't attended it in years because
of the add on costs for meals and other useless items.
Cannot think of any right now.
ATTORNEY DISCIPLINE
10. Please indicate the extent to which you agree or disagree with each of the following statements regarding Wyomings disciplinary system.
The disciplinary system is

effective.
The disciplinary process is fair
to lawyers.
The disciplinary process is fair
to the public.
Disciplinary sanctions are
consistent.
Strongly
Agree
16.9% (70)
Agree
54.2% (224)
Disagree
11.4% (47)
Strongly
Disagree
4.6% (19)
Unaware
12.8% (53)
Rating
Average
2.42
Rating
Count
413
13.8% (57)
52.2% (216)
11.1% (46)
6.5% (27)
16.4% (68)
2.60
414
15.5% (64)
52.5% (216)
9.2% (38)
4.6% (19)
18.6% (77)
2.59
414
8.7% (36)
39.4% (163)
13.3% (55)
10.9% (45)
27.8% (115)
3.10
414
Answered Question
Skipped Question
11
415
38

JUDICIARY
11. What do you think of the judicial discipline system?
Rating
Percent
Effective
29.0%
Ineffective
23.9%
Dont Know
47.1%
Answered Question
Skipped Question
Rating
Total
120
99
195
414
39
12. What is the best method for the Wyoming State Bar to improve communications between the members of the Bench and the Bar?
Rating
Percent
49.3%
51.7%
35.0%
35.0%
Offer more opportunities for informal communication

More seminars involving judges on panels and as speakers
More opportunities for social interaction
Communication is already adequate.
Other (see below)
Answered Question
Skipped Question
Rating
Total
186
195
132
132
33
377
76
Other:
Articles in the Wyoming Lawyer on what issues they see and what they would like to see.
set up roundtable discussion; no one with more power than others; all ideas given fair consideration
The issue is a lack of the bar's ability to communicate with judges. The WRCP have been modified to assist the court but none of the changes
assist the attorneys.
I don't know how you improve this. I think it is adequate, but certainly not perfect.
Annual meeting needs to be more affordable and topical
GET LESS POMPOUS ARROGANT JUDGES
remind lawyers and judges that we are, and should act like we are, equals when not in a proceeding.
Good Bench Bar working committee in District Court.
12
The judge's bench book is helpful, if it is completed completely and updated

Require courts to notify local counsel of decisions in their cases rather than relying on counsel to constantly check court mail boxes
I do not know.
lawyers cant turn in judges. lawyers pay the price
Offer anything on west side of the state
perhaps occasional articles in Wyo Lawyer
don't know
consistency in rulings
Electronic communications enhancement
the bar already is too invasive.
eliminate elitest bench members
Lack of consistent quality in Judicial Appointmnts. Many, including our current are excellent. In the past, our's were pitifully inadequate.
improve format of Wyoming Lawyer. current version is hard to read
The role of Judge, by its very nature requires a separation between the judge and lawyers appearing before the judge.
ad hoc committees with a specific goal in mind that consists of lawyers and judges.
There needs to be an effective way for bar members to grieve a judge in which the lawyer is protected from retribution by the judge.
Have a formal discussion process each year
It seems impossible to remove the fear factor from communications with Judges particularly for younger members. This is complicated by the
attitudes of some judges that relations with attorneys are best viewed in an "us vs. them" context.
I think communications are good now, and about as effective as they can realistically be.
sponsoring regular meetings of the family law bar
the ability to request judicial monitoring without risking judicial retaliation
Have judges from more populated districts share their experiences with less populated districts -- and not just to Teton County
don't hide things like the ABA report on the disciplinary system
More "view from the bench" articles in the Wyoming Lawyer (maybe a standing column?)
constant update of bench book
13

13. Are you in favor of the Bar continuing the Judicial Advisory Poll?
Rating
Percent
Yes
93.9%
No
6.1%
Answered Question
Skipped Question
Rating
Total
385
25
410
43
14. Is courtroom security adequate in the courthouses in which you practice?

Rating
Percent
Yes
83.4%
No
16.6%
Answered Question
Skipped Question
Rating
Total
337
67
404
49
15. Have you used the Wyoming Supreme Courts electronic filing system?
Rating
Percent
Yes
47.1%
No
52.9%
Answered Question
Skipped Question
14
Rating
Total
195
219
414
39

16. Please rate the Supreme Courts electronic filing system.
Excellent
Good
Average
Fair
Poor
Comments (see below)
Rating
Percent
21.1%
52.1%
18.0%
6.2%
2.6%
Answered Question
Skipped Question
Rating
Total
41
101
35
12
5
18
194
259
Comments:
I think it is a waste of paper to have to follow up with the six copies.

Difficult to use and finicky
Filings should be credited to the calendar day on which they are posted. I am not aware of any reason for the 5:00 pm cut-off for calendar date
filings. Another suggestion is to provide a note explaining how to open linked documents within a case file. Last, would be to actually include the
document or a Otherwise, the electronic service shows up as "Notice of Filing". It should read "Electronic Service" or "Notice of Service" or
maybe "YOU HAVE BEEN SERVED!" The last one is a bit of a joke but very effectively communicates the message.
It is more difficult and less intuitive that CM/ECF. The State Courts around the state need to have an electronic filing system.
I don't understand the point of e-filing when paper filing 6 copies of all documents is required and remains jurisdicitonal.
could be a bit more user friendly, especially for those who do not appear consistently.
Service rules need to be streamlined: serve only by e-filing
Since hard copies also have it be provided it seems to be additional work.
My staff uses it.
What is the point of an electronic filing system when paper filing is also required?
I expect that I am like most Wyoming lawyers and filing only 3 or 4 times a year makes each filing a new experience.
Because you still have to file paper copies.
seems like there are too many steps, and I don't understand why I still have to file a paper copy
Needs to extend the filing deadline past 5:00 p.m.
Why oh why have we not broadened its use to the District Courts? This is way past due.
It is still way behind the federal filing system.
The requirement to provide paper copies by mail is silly. Let's go to a pure e-file system like federal courts.
15
It is better than the federal system
17. When state courts develop electronic filing, what functions would you like to see? (check all that apply)
Rating
Percent
91.2%
72.1%
53.7%
58.5%
Rating
Total
343
271
202
220
Answered Question
Skipped Question
37
376
77
Electronic notices and services

Extension of hours of operation
Public access
Access from mobile devices such as
tablets and smartphones
Other (see below)
ECONOMICS & OFFICE PRACTICE

18. If you charge on an hourly basis, what is your usual hourly rate?
Less than $75

$76 - $100
$101 - 125
$126 150
$151 - $200
$201 - $300
More than $300
Not applicable
Rating
Percent
0.0%
1.2%
4.0%
10.4%
21.7%
22.7%
4.4%
35.6%
Answered Question
Skipped Question
16
Rating
Total
0
5
16
42
88
92
18
144
405
48

19. What is the starting salary for associates in your law firm or organization?
Less than $40,000

$40,001 - $60,000
$60,001 - $80,000
$80,001 - $100,000
$100,001 or more
Rating
Percent
13.8%
59.0%
20.5%
4.9%
1.9%
Answered Question
Skipped Question
Rating
Total
37
158
55
13
5
268
185
20. In your office, what percent of your firms gross income goes to cover overhead expenses to maintain your office on a monthly basis? (Please include
rent, equipment, regular monthly payables and support staff salaries, but not salaries for partners and associates.)
Up to 30%
31 40%
41 45%
46 50%
51 60%
More than 60%
Dont know
Not applicable
Rating
Percent
13.9%
12.6%
9.8%
6.3%
6.6%
3.3%
14.1%
33.3%
Answered Question
Skipped Question
17
Rating
Total
55
50
39
25
26
13
56
132
396
57

21. In your office, which of the following is the highest-cost item other than salaries?
Rating
Percent
Rent
24.6%
Benefits
21.8%
Technology
10.6%
Legal Research
0.8%
Dont know
18.5%
Not applicable
23.8%
Answered Question
Skipped Question
Rating
Total
97
86
42
3
73
94
395
58
22. How much do you spend per month on legal research?
Less than $500

$500 - $1,000
$1,001 - $1,500
$1,501 - $2,000
$2,001 - $2,500
$2,501 - $3,000
$3,001 - $3,500
$3,501 - $4,000
$4,001 - $4,500
$4,501 - $5,000
More than $5,000
Nothing; I utilize Casemaker
Do not know
Rating
Percent
26.5%
10.9%
3.3%
1.5%
1.5%
0.5%
0.3%
0.0%
0.0%
0.0%
0.8%
22.0%
32.8%
Answered Question
Skipped Question
18
Rating
Total
105
43
13
6
6
2
1
0
0
0
3
87
130
396
57

23. In 2012, what was your personal net income or earnings from the practice of law? (If you are in private practice, please give a pre-tax estimate of
your personal income.)
Rating
Percent
Less than $40,000
13.7%
$40,001 - $60,000
13.7%
$60,001 - $80,000
19.0%
$80,001 - $100,000
16.4%
$100,001 - $125,000
13.5%
$125,001 - $150,000
7.1%
$150,001 - $200,000
7.1%
More than $200,000
9.5%
Answered Question
Skipped Question
Rating
Total
52
52
72
62
51
27
27
36
379
74
24. Do you keep time records?

Rating
Percent
Always
51.7%
Usually, except in fixed fee or contingency cases
17.6%
Sometimes
5.1%
Never
3.2%
Not applicable
22.3%
Answered Question
Skipped Question
19
Rating
Total
211
72
21
13
91
408
45

25. Do you discuss your fees and how you determine them in your first interview with a client?
Rating
Percent
Always
50.0%
Usually
13.8%
Sometimes
1.2%
Rarely
1.0%
Not applicable
34.0%
Answered Question
Skipped Question
Rating
Total
203
56
5
4
138
406
47
26. Do you use written fee agreements with your clients?

Rating
Percent
Always
33.7%
Usually
20.9%
Sometimes
6.4%
Rarely
4.2%
Not applicable
34.7%
Answered Question
Skipped Question
20
Rating
Total
137
85
26
17
141
406
47

27. What one area of law constitutes the largest portion of your practice?
Rating
Percent
5.4%
5.1%
6.4%
0.5%
9.4%
8.6%
8.6%
2.9%
4.0%
9.4%
0.8%
7.2%
0.8%
5.1%
1.6%
0.8%
5.9%
9.7%
1.3%
2.7%
2.4%
0.8%
0.5%
Tort/Plaintiff
Tort/Defense
Business Law
Employment Law
Family Law
Criminal Prosecution
Criminal Defense
Domestic Relations
Real Estate Law
Estate Planning/Probate
Insurance
Litigation
Tax Law
Oil & Gas
Bankruptcy
Banking Law
Administrative Law
Government Law
Judicial Functions
Environmental Law
Workers Compensation
Mediation
Collections
Other (see below)
Answered Question
Skipped Question
Other:
hard to say
Juvenile
All
Juvenile law
21
Rating
Total
20
19
24
2
35
32
32
11
15
35
3
27
3
19
6
3
22
36
5
10
9
3
2
10
373
80
Appellate
varies
Administrative Law
Education Law
mixture of transactional and litigation
Child Support
TECHNOLOGY
28. What section of the Bars website do you find most useful?
Rating
Percent
50.3%
7.3%
My Bar Page
Online Membership
Directory
Casemaker
27.8%
CLE Section
12.9%
Bookstore
0.0%
Job Bank
1.8%
Other (see below)
Answered Question
Skipped Question
Other:
My Bar Page is also great. Would love to see online CLE submission.
totally unhelpful
This applies to #2 - Cannot submit out-of-state
22
Rating
Total
199
29
110
51
0
7
7
396
57

29. Have you submitted your CLE hours online at www.wyomingbar.org?
Rating
Percent
Yes
85.3%
No
14.7%
Answered Question
Skipped Question
Rating
Total
348
60
408
45
30. Please rate the online CLE submission system.

Rating
Percent
Excellent
49.6%
Good
41.9%
Average
6.6%
Fair
0.6%
Poor
0.9%
Unaware
0.6%
Answered Question
Skipped Question
Rating
Total
174
147
23
2
3
2
351
102
31. Please share any recommendations for improving the online CLE submission system.
None- it just took me time to get into it. But, don't make it the exclusive way to do things... wait til I'm dead.
I don't have any suggestions for the Bar Office. My only frustration is when a sponsor doesn't ask for pre-approval and/or doesn't understand
how to calculate the hours. The Bar Office has beenexcellent about reviewing programs, and very broad with the definition of what might be
helpful to my practice.
not require routine information
Require less routine information.
I file C.L.E. by FAX, after downloding form. Not sure if this what you mean by "on line submission." Anyway, I don't know how to electroniclly
"sign."
Works very well.
I find uploading attachments to be a challenge.
23
confirmation of submission would be very helpful

It would be handy to be able to file the submission for CLE approval online. Also, the submission page columns are "Date" , "Title" , "Location"
and sorted alphabetically by title. It think it would be easier to find the CLE if they were sorted "Date", "Location" , "Title" and sorted by location
and then title secondary. Otherwise, the system is very simple and effective.
The annual reports are very confusing and hard to understand as far as carry-over hours.
CLE has become an officious process.
I've been impressed with how easy it is!
Maybe allow for sharing reports with other states in which the attorney is licensed.
Check w/ West Legal Ed Center and include their course offerings for online submission. Only about 1 out of 5 are currently available for
submission.
Not sure how it could be accomplished but create some mechanism for online submissions for credit for classes not yet approved by Bar but
likely to be approved.
difficult to identify worthwhile CLE courses
perfect already.
the search options to find the specific CLE attended can be difficult
An email saying when credit has been approved, not when the application has been received, would be helpful.
Send e-mail notices to members prior to the deadline if we do not have enough credits for that year.
To submit CLE for courses not listed on the calendar requires multiple steps. It would be helpful to have an earlier link to submit such CLE
requests.
None at this time.
The part where you have to search for the Cle you're applying for is annoying. I've had trouble finding the right Cle to apply for because the name
was not recognized.
24

32. Please indicate your reason for NOT utilizing the online CLE system (check all that apply)
Rating
Percent
18.4%
10.3%
17.2%
60.9%
I am unaware of this option

The system is too complicated.
I dont know how the system works
I prefer to submit the
paper CLE application
Other (see below)
Answered Question
Skipped Question
Rating
Total
16
9
15
53
15
87
366
Other:
I think I have the system figured out but found it difficult- got good help from Mary.
Sometimes it is easier to get the paperwork at the CLE than to submit electronically
I file C.L.E. by FAX, after downloding form. Not sure if this what you mean by "on line submission." Anyway, I don't know how to electroniclly
"sign."
Faxing is faster
When CLE not previously approved
It never works like the instructions indicate
if the seminar is not listed I usually send in paper
My CLE meetings are not included
What ever is convent.
Have not had a reason to use yet, but I will
Out of state CLE cannot be submitted unless pre-approved.
sometimes it is easier to do form when available
Habit
I just haven't done it yet.
Went to many programs that were not Wyo so had to get approved which meant submitting the agenda etc
25

33. Do you take advantage of Casemaker, the online legal research library available through the Wyoming State Bar?
Rating
Percent
Yes
47.8%
No
52.2%
Answered Question
Skipped Question
Rating
Total
194
212
406
47
34. How often do you utilize Casemaker?

Rating
Percent
A few times per week
20.6%
Weekly
22.7%
A few times per month
26.3%
Monthly
11.3%
Rarely
19.1%
Answered Question
Skipped Question
Rating
Total
40
44
51
22
37
194
259
35. I use Casemaker:

Rating
Percent
Exclusively
46.1%
In conjunction with other legal research providers
53.9%
Answered Question
Skipped Question
26
Rating
Total
89
104
193
260

36. Have you taken advantage of the free Casemaker training opportunities?
Rating
Percent
Yes
46.6%
No (please explain)
53.4%
Answered Question
Skipped Question
Rating
Total
89
102
191
262
Comments:
I find it really simple to use.

The trainings require agreeing to receive spam from the Company about allits other products.
scheduling conflicts
not aware of them
It is easy to use
By taking the free course, you must agree to receive spam from Casemaker concerning paid upgrades.
I am tech savvy enough that I have not felt the need to train. I am sure the training opportunities are valuable for those who need it, I just don't
need it.
37. Was the training helpful?

Rating
Percent
Yes
92.2%
No (please explain)
7.8%
Answered Question
Skipped Question
Comments:
I guess.
Helpful, but basic and limited
27
Rating
Total
83
7
90
363

38. If you do not utilize Casemaker, what is the main reason? (check all that apply)
Rating
Percent
0.0%
80.7%
16.0%
11.2%
Too expensive
Utilize other legal research tools
Not user friendly
Not aware it was available
Other (see below)
Answered Question
Skipped Question
Other:
just haven't tried - - yet.

use Westlaw and haven't had time to learn new system
Not as easy to use as other options.
minimal legal research
Had Westlaw in previous office; will use Casemaker in current office
have other readily available resources
Never learned how to use it
I do use Casemaker?
Don't do much legal research.
It does not get the results that I obtain with Westlaw
I have Westlaw provided by my employer
Never have taken the time to learn it
No research
it is too limited.
not applicable
No keynotes like Westlaw; fee to Keycite/Shephardize
Not very effective
no need yet
I am not adept but plan to try it soon.
Haven't had the need as of yet.
My practice does not involve significant amounts of legal research anymore
28
Rating
Total
0
151
30
21
40
187
266
don't have the skills.

Little if any practice in Wyoming - just office here.
I do use Casemaker.
Most of my research is delegated.
Never got around to it.
Just accustomed to Westlaw and haven't made the switch
Have no used it.
don't know how
as a state employee I have access to Westlaw
sometimes I am looking for a resource that my firm has access to in our westlaw subscription that is not available in casemaker
have not taken time to learn it
Other options are available to me.
Have other option
I haven't taken the time to learn it and I'm not sure how it compares to Westlaw, which I've always used.
I generally don't need a lot of research
It sucks compared to westlaw.
I don't practice
We've tried Casemaker before. The search functions are unreliable and miss important precedent. We simply cannot trust the results.
PUBLIC SERVICE & CHARITABLE WORK

39. How many hours per week do you devote to non-law-related community service?
Rating
Percent
None
15.5%
5 hours or less
56.9%
6 10 hours
21.6%
11 20 hours
3.8%
21 or more hours
2.3%
Answered Question
Skipped Question
29
Rating
Total
62
227
86
15
9
399
54

40. On average, how many hours per month do you devote to pro bono clients or clients accepted at a substantially reduced rate? (Please do not include
hours spent on cases billed but not collected.)
Rating
Percent
34.1%
20.5%
8.7%
3.1%
5 hours or less
6 10 hours
11 20 hours
21 or more hours
I make cash donations to Legal Services or to the Bar Foundation
in lieu of doing pro bono legal work
4.7%
I do not accept pro bono cases and do not donate cash in lieu of
pro bono work.
28.9%
Answered Question
Skipped Question
41. In the last two years, how many hours have you spent in direct representation of a pro bono client?
Rating
Percent
None
41.3%
1 5 hours
9.9%
6 10 hours
8.1%
11 20 hours
8.6%
21 -30 hours
8.6%
More than 30 hours
23.5%
Answered Question
Skipped Question
30
Rating
Total
158
38
31
33
33
90
383
70
Rating
Total
130
78
33
12
18
110
381
72

42. In regard to the direct representation cases, how did you learn of the case?
Rating
Percent
12.6%
Through a formal program (i.e.

Wyoming State Bar, Legal Aid of
Wyoming)
Direct contact from the public
87.4%
Other (see below)
Answered Question
Skipped Question
Other:
Also through ServeWyoming.

Attorney referrals
Involvement with non-profits needing legal work
working with non profits I support
client came in
sometimes direct from client calling for assistance
I am the attorney for a local non-profit organization
friend
family, friends
Personal referrals and requests to help
through our not for profit pro bono organization
I'm a public defender. I'm appointed by the court.
From client family
both
Personal referral
Casper College Paralegal Program
referred by clients/friends
referrals from attorneys
I am unaware.
31
Rating
Total
25
174
19
199
254

43. What is the average number of hours of law-related volunteer work (not pro bono) that you perform in an average month (e.g. Law Day, Mock Trial,
Bar committee/board service, etc.)?
Rating
Percent
None
42.6%
1 5 hours
43.7%
6 10 hours
8.4%
11 20 hours
4.2%
21 30 hours
0.5%
More than 30 hours
0.5%
Answered Question
Skipped Question
Rating
Total
162
166
32
16
2
2
380
73
44. What would make pro bono service more appealing to you?
Rating
Percent
37.1%
52.3%
15.2%
11.0%
6.8%
38.0%
Reimbursement for expenses

CLE
Mentoring with an experienced attorney
Easy cases
Public recognition
Requiring pro bono recipients to be
more vested in their case by requiring
some financial commitment
Other (please specify)
Answered Question
Skipped Question
Rating
Total
88
124
36
26
16
90
52
Comments:
We are going the way of health care. More clients have an expectation that they are "entitled" to my services. No "pro bono" representation
begins as a hand out... client understands that I expect compensation.. how charity manifests itself depends on the circumstances and we do see
lots of $20 per month payments and significant "writing off" for those who show character. Others just don't get to come back.
areas that I am competent in
32
It's a huge issue. I don't have any good suggestions.

It doesn't work well for a government attorney in general.
Pro bono is mostly a luxury for salaried attorneys.
I've found that most pro bono clients don't take their issues "seriously," and can be difficult to contact and remain in communication with.
it's appealing now - I do it on a case-by-case basis for people I know
Clients that communicate as promised.
NA
malpractice insurance for attorneys doing pro bono work
time
Malpractice insurance for representation
Not applicable due to my work with a gov't organization
I am prohibited by statute to do pro bono
It might not be logistically feasible but I would be willing to take additional pro bono work if it would guarantee some time with an experienced
attorney who is willing to discuss how to proceed with the case.
I work for local government.
Cases for which I have expertise
Client's needs
Protection from claims by Some insurance like program.
Most pro bono recipients have cases involving domestic or criminal matters which are areas I choose not to work in. If the pro bono client
needed help in my area and had a meritorious claim I would be more willing to take the case.
My kids growing up & not spending so much time with them & other volunteer organizations. There is only so much time. My family must come
first outside of work. Volunteer organizations are much more important to me and help more people than pro bono.
Encourage my employer to allow it
More available time
not so much "easy" as within my area of practice so I do not need to go outside my comfort zone and conduct a lot of research to do it.
prosecutors can't engage in the pro bono work due to not being allowed to practice outside of the prosecution role.
more time
I used to give alot of time to bar activities but other non-profit boards consume too much time.
i am employed by the government and not allowed to practice outside of my employment
If I didn't need to earn a living.
not applicable
just did a lot , should be no recognition for it.
None
allow govt attys to do pro-bono
33
I undertake pro bono cases when I am confronted with a need and it is in my area of practice. I don't need any help finding pro bono
opportunities.
A Powerball win.
Cases within the scope of my expertise
Too long is practice and too busy
Better screening by referring organizations
Given the nature of my practice (business and real estate transactions and litigation, there are few pro bono opportunities. I am very
uncomfortable going into practice areas that I am not proficient. Consequently, I would probably do more pro bono if I could easily turn to a
proficient practicioner for guidance.
It must fit time and financial wise
Nothing.
If you do it for recognition you probably shouldn't do it.
Nothing. Pro Bono is an accepted duty of members of this profession. It should be enough to know that doing this sort of work is the right thing.
Think of it as "paying it forward".
This is just something that is done
Not in private practice
The law facilitates the rich getting richer and the poor getting crushed.
As a state attorney, we are required by statute to only represent govt clients.
Judges should be understanding of the time demands as well
Not interested.
opportunity
i no longer work full-time. if I were were return to a full practice I would resume more pro bono work
Less risk to the attorney
34

45. What do you believe are the most critical challenges preventing attorneys from doing pro bono work? (check all that apply)
Rating
Percent
26.2%
Employers not allowing employees to

take on pro bono cases
Solo practitioners unable to afford
66.1%
doing pro bono work
Distance and time
31.2%
New attorney not having enough
19.3%
experience
Other (please specify)
Answered Question
Skipped Question
Rating
Total
79
199
94
58
61
301
152
Comments:
liability
attorney not having experience (new is not the test0
Many attorneys don't know what to expect from pro bono cases so they avoid them
Clients are not vested and usually make unreasonable requests and demands
time
It doesn't work well for government attorneys without an outside practice.
sometimes too busy with demanding clients
clients - they should be working instead of using the system for their whining
I don't know
These cases often take more time than an "identical" fee generating case because of the very nature of the clients and the way they do business.
After a time, attorneys learn not to take too many of them because they can consume the time needed to generate a living.
Pro bono clients, other than people chosen by me, are unrealistic and ungrateful
malpractice insurance!
lack of understanding of need for pro bono work
INVOLUNTARY PRO BONO WORK BECAUSE PEOPLE DONT PAY
I am prohibited by statute to do pro bono
an incentive to provide pro bono and a bridge between the demand and the supply. the entire pro bono demand must be organized and
cataloged so practitioners can maximize the effectiveness of each hour spent supplying the demand.
35
Difficulty matching skills and experience with indigents' legal needs

Greed
Pro Bon clients are very demanding and aggressive if not handled with kid gloves. They have no sense of burden or cost of endless demands.
Pro bono clients who think they are entitled and are too demanding
Time. Family. Volunteering.
The need to make a living.
Not being competent in areas in which pro bono services are most often requested.
Honestly, I am not a strong believer in pro bono work. I have always paid my own way despite some very serious setbacks; the rest of society can
also.
administrative costs for solo practitioners
I work for state government. If I had an experienced attorney willing to help me navigate a pro bono case, I would gladly do it. However, I have
not found someone willing.
In addition to the time, the expense including fees, filings, document prodution, staff's time, etc, that one must also cover. If it was just a time
issue, I believe more attorneys would participate.
pro bono matters are usually outside my areas of expertise
inability to pre-determine how much time a case will take
Not enough time
can always do it.
There should be no reason. We should all do it.
Attorneys do not know the people that need pro bono services well enough to perceive the need -- too much of a social gulf
Balancing pro bono work with other work
Risk of hopeless/endless/costly entanglements.
Too busy with billable commitments
Lack of cases within the scope of attorney's expertise
Pro bono clients are often more difficult to communicate with and not as responsive as paying clients because they don't have a vested interest
in not wasting time.
See #2
No more time in the day to do anything more than what I am already doing.
too busy
I think Wyoming lawyers do significant pro bono work without seeking recognition for it.
greed
Time
Old attorney not having enough experience in the area where the demand is.
Screening of cases for pro bono work
36
Selfishness
Not being paid is a big hurdle.
Most pro bono clients that are not personally know to me are unreasonable because they have no financial incentive to be reasonable
Most pro bono clients that are not personally know to me are unreasonable because they have no financial incentive to be reasonable
my area of expertise, estate planning, not often compatible with pro bono clients
Lazy
On occasion, the client is needy and ungrateful. This is precisely why it should be done. No one else will help these folks because they are so
difficult. It is not always fun but the reward is knowing that you did the right thing.
The costs associated with a pro bono case are extremely high and the clients are usually difficult.
Conflicts with current clients
conflicts of interest
shortage of attorneys means less pro bono time available
Not allowed to practice law.
In my experience, pro bono clients are demanding and wasteful of legal time - they have no appreciation because they have no investment.
Fears of taking on a case for an unhappy client who will grieve on the other end of the representation
Government job prevents participation
Clients who lack a financial commitment don't understand that time is money.
37

46. What do you believe are the most critical challenges facing the legal profession in Wyoming? (Rank the top five challenges by using 1 5, with 1
being the most critical.)
Access to the legal system for

all citizens
The use of the Internet and
related technology
Loss of professionalism and
civility among lawyers
The practice of law by nonlawyers
Loss of confidence in the legal
system by the public
Loss of job satisfaction among
attorneys
1st
28.4% (104)
2nd
19.7% (72)
3rd
22.1% (81)
4th
13.9% (51)
5th
15.8% (58)
Rating
Average
2.69
Rating
Count
366
11.6% (40)
21.7% (75)
29.6% (102)
20.0% (69)
17.1% (59)
3.09
345
23.5% (86)
23.5% (86)
25.7% (94)
17.5% (64)
9.8% (36)
2.67
366
16.2% (53)
21.3% (70)
24.4% 980)
19.8% (65)
18.3% (60)
3.03
328
23.2% (84)
30.9% (112)
27.9% (101)
11.6% (42)
6.4% (23)
2.47
362
24.9% (90)
34.0% (123)
20.7% (75)
12.4% (45)
8.0% (29)
2.45
362
Other (see below)

Answered Question
Skipped Question
16
386
67
Comments:
Uncomplicating things- citizens once had a clear understanding of what was "right" and what was "wrong" - the language of the law must not be
foreign to the ears of those who are to obey- L. Hand
The unfairness of the criminal justice system.
To many attornrys
These are all related to one another!
Need electronic court filing in state court!!!
the most critical ones seem interrelated
GETTING RID 0F THE POLITICAL JUDICIAL SELECTION PROCESS
Many who aren't civil, do not realize it. When confronted with it, they are defensive. Kinda like trying to tell a tired misbehaving kid he's sleepy.
He denies it & fights sleep.
The civility issue is only a problem in the family law arena.
lack of funding for the WY legal aid program
Inconsistency in rulings; lack of predictability
38
47.
Stunning cost of resolution of disputes due to the obsession with advocacy rather than justice or sensible resolution of disputes.
It isn't just the use of technology, it's the lack of technology. Other business sectors are way ahead of the law by having useful apps and faster
methods to mine and use data.
docket delays in District Court; judges need to manage their dockets more effectively; this is my number one complaint
attacks on the civil justice system
of these five...
What do you think the top priorities of the Wyoming State Bar should be? (Rank the top five priorities using 1st as the top priority.)
1
44.6% (168)
2
22.0% (83)
3
16.7% (63)
4
7.2% (27)
5
9.5% 936)
Rating
Average
2.15
13.8% (45)
29.4% (96)
24.5% (80)
20.8% (68)
11.6% (38)
2.87
327
7.5% (23)
13.3% (41)
31.5% (97)
23.7% (73)
24.0% (74)
3.44
308
42.2% (151)
29.9% (107)
13.4% (48)
10.1% (36)
4.5% (16)
2.05
358
6.3% (18)
13.5% (39)
31.3% (90)
28.8% (83)
20.1% (58)
3.43
288
10.8% (36)
23.2% (77)
35.5% (118)
19.6% (65)
10.8% (36)
2.96
332
23.0% (79)
32.3% (111)
24.1% (83)
14.2% (49)
6.4% (22)
2.49
344
43.5% (160)
30.4% (112)
16.3% (60)
6.3% (23)
3.5% (13)
1.96
Other (see below)
Answered Question
Skipped Question
st
Offering Continuing Legal

Education
Helping attorneys adapt to
changing technology
Certifying or recognizing
practice specialties
Reviewing and examining
new admittees
Identifying new markets for
legal services
Helping attorneys respond to
changing needs of legal
consumers
Educating the public about
the legal profession
Reviewing ethical complaints
nd
rd
th
th
Rating
Count
377
368
19
386
67
Comments:
Establishing and appointing qualified and fair judges to the bench. The syetm is stacked with former prosecutors that have no interest in
protecting the rights of the average citizen.
39
I believe the most important is to address the issues in Question 1 above this. Making the law serve people, bringing back its honor and
advocating for it to be affordble and accessible. Outreach and communication to the public and lawmakers.
police unauthorized practice of law
IMPROVING THE JUDICIAL SELECTION PROCESS
The system for rates charged for CLE is woefully antiquated. Why should judges or government lawyers receive reduced rates while sole and
small firm practitioners be charged more? Makes no sense, since judges and government lawyers now make, on average, much higher incomes
with far more generous benefit packages.
Assisting the Court with online filing
3) Devote some time to discipline for non-lawyers (ie CPAs, Broker/Dealers) practicing law. 4) Rewrite the required ad disclaimer so it doesn't
require lawyers to inform the public that lawyers are generally incompetent and they may be better off just not seeking legal advice for their
legal issues (Doctors and Accountants aren't required to tell prospective patients/clients that they may be incompetent)
Educate public about the peril of non lawyer legal advice
I don't think we need certification
Assist attorneys when assistance is asked for; to aid attorneys so they do not commit malpractice.
Since the Bar feels a full time disciplinarian is necessary, they should get ahead of the curve by providing a full time member advisor.
Civility and by Court control of overzealous advocacy reduce the cost of legal services.
lack of professionalisn and civility of bench & between attorneys
Explore alternatives for malpractice insurance with ALPS -- they have a monopoly in Wyoming -- I have never had a claim, but our premium just
increased 30% in one year
I disagree with the move to the uniform bar exam. Further this decision was not adequately announced, disclosed and addressed by bar
members at large. Lastly it has the potential to alter the pracitce in Wyo by encourging/allowing large out of state firms to enter the state to
"cherry pick" cases and clients. The CLE supplement is a weak and ineffective way to address Wyoming law and practices.
I would have included Review and Examine new admittees but the court took that away
Ethical issues should be handled by the Supreme Court
The ethical complaint process should be moved to the Supreme Court. Because of political pressures, the Bar is not the agency that should
handle such complaints. It's time to do a partial dis-integration of the Bar, somewhat like Nebraska.
Acknowledging and meeting the needs of attorneys who don't practice, and find non traditional employment
40
EXHIBIT INDEX
Civil Action No. 14-cv-00200-SWS (D. Wyo.)
Anne Marie Guzzo, et al. v. Matthew H. Mead, et al.
Memorandum in Support of Plaintiffs Motion for Attorneys Fees and Costs
February 26, 2015
Exhibit 1.
Declaration of Thomas Stoever

Attachment 1, Thomas Stoever Bio
Attachment 2, L. James Lyman Bio
Attachment 3, Billing Statements
Exhibit 2.
Declaration of Shannon Minter

Exhibit A, Shannon Minter Resume
Exhibit B, Billing Statements
Exhibit C, Christopher Stoll and Amy Whelan Resumes
Exhibit 3.
Declaration of Qusair Mohamedbhai

Exhibit 1, Qusair Mohamedbhai Bio
Exhibit 2, Arash Jahanian Bio
Exhibit 3, Time Entries
Exhibit 4, Costs
Exhibit 4.
Declaration of Tracy Zubrod, with Billing Statement Attached
Exhibit 5.
Declaration of Bruce Moats, with 2013 Wyoming State Bar Member

Survey Results Attached

2:14-cv-00200 #70

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Case 2:14-cv-00200-SWS Document 70 Filed 02/26/15 Page 1 of 13

Case 2:14-cv-00200-SWS Document 70 Filed 02/26/15 Page 2 of 13

UNITED STATES DISTRICT COURT

Case 2:14-cv-00200-SWS Document 70 Filed 02/26/15 Page 3 of 13

Plaintiffs Are the Prevailing Parties in This Case

Case 2:14-cv-00200-SWS Document 70 Filed 02/26/15 Page 4 of 13

Plaintiffs Are Entitled to Full Award of their Requested Fees

Summary of Plaintiffs Counsels Hours and Rates

Case 2:14-cv-00200-SWS Document 70 Filed 02/26/15 Page 5 of 13

B. Plaintiffs Hours Are Reasonable

Case 2:14-cv-00200-SWS Document 70 Filed 02/26/15 Page 6 of 13

Case 2:14-cv-00200-SWS Document 70 Filed 02/26/15 Page 7 of 13

Case 2:14-cv-00200-SWS Document 70 Filed 02/26/15 Page 8 of 13

Case 2:14-cv-00200-SWS Document 70 Filed 02/26/15 Page 9 of 13

Case 2:14-cv-00200-SWS Document 70 Filed 02/26/15 Page 10 of 13

Case 2:14-cv-00200-SWS Document 70 Filed 02/26/15 Page 11 of 13

Plaintiffs Are Entitled to Recovery of Their Costs

Plaintiffs Are Entitled to Interest on the Judgment

Plaintiffs Have Consulted with Counsel for All Defendants

the State Defendants on multiple occasions in an attempt to reach an agreement regarding

Case 2:14-cv-00200-SWS Document 70 Filed 02/26/15 Page 12 of 13

Case 2:14-cv-00200-SWS Document 70 Filed 02/26/15 Page 13 of 13

Mark Towne Voss

Attorneys for the State Defendants

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

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

UNITED STATES DISTRICT COURT

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

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

Case 2:14-cv-00200-SWS Document 70-1 Filed 02/26/15 Page 3 of 23

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

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

Case 2:14-cv-00200-SWS Document 70-1 Filed 02/26/15 Page 4 of 23

Case 2:14-cv-00200-SWS Document 70-1 Filed 02/26/15 Page 5 of 23

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

The Governor of Wyoming increased the workload for Plaintiffs counsel by

Case 2:14-cv-00200-SWS Document 70-1 Filed 02/26/15 Page 6 of 23

Case 2:14-cv-00200-SWS Document 70-1 Filed 02/26/15 Page 7 of 23

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

Case 2:14-cv-00200-SWS Document 70-1 Filed 02/26/15 Page 8 of 23

Case 2:14-cv-00200-SWS Document 70-1 Filed 02/26/15 Page 9 of 23

Case 2:14-cv-00200-SWS Document 70-1 Filed 02/26/15 Page 10 of 23

Thomas W. Stoever, Jr.

Case 2:14-cv-00200-SWS Document 70-1 Filed 02/26/15 Page 11 of 23

Representation of a consumer product manufacturer in a citizen suit brought pursuant to the

Representation of a transportation company in the negotiation of an Incidental Take Permit and

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

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

Representation of clients in large commercial litigation and arbitration.

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

Thomas W. Stoever, Jr. "Presentation: Multi-jurisdictional Practice: A Trap for In-house

Thomas W. Stoever, Jr.

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

Thomas W. Stoever, Jr.

Case 2:14-cv-00200-SWS Document 70-1 Filed 02/26/15 Page 13 of 23

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

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

Arnold & Porter LLP

List of Fee and Disbursement

National Center for Lesbian Rights

Amount Bill Num

Wyoming Marriage Equality Action

Legal Assistant Services for J. Lyman: