1 Kevin I. Shenkman (SBN 223315) Mary R. Hughes (SBN 222662) 2Andrea A. Alarcon (SBN 319536) SHENKMAN & HUGHES 328905 Wight Road Malibu, California 90265 4Telephone: (310) 457- 0970 R. Rex Parris (SBN 96567) 5Ellery S. Gordon (SBN 316655) PARRIS LAW FIRM 643364 10th Street West Lancaster, California 93534 7Telephone: (661) 949-2595 8Milton C. Grimes (SBN 59437) LAW OFFICES OF MILTON C. GRIMES 93774 West 54th Street Los Angeles, California 90043 10Telephone: (323) 295-3023

11Robert Rubin (SBN 85084) LAW OFFICE OF ROBERT RUBIN 12237 Princeton Avenue Mill Valley, CA 94941 13Telephone: (415) 298-4857

14Attorneys for Plaintiffs SUPERIOR COURT OF THE STATE OF CALIFORNIA 15 COUNTY OF SAN BERNARDINO 16 PICO NEIGHBORHOOD Case No.: BC616804 17ASSOCIATION and MARIA LOYA, 18 Plaintiffs, DECLARATION OF KEVIN SHENKMAN 19 IN SUPPORT OF PLAINTIFFS' MOTION v. FOR AWARD OF ATTORNEYS' FEES 20CITY OF SANTA MONICA, and AND EXPENSES DOES 1 through 100, inclusive, 21 Defendants. Date: August 28, 2019 22 Time: 8:30 a.m. Dept.: SSC-9 23 1 24

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SHENKMAN DECLARATION 1 I, Kevin I. Shenkman, declare as follows:

2 1. I am an attorney duly licensed to practice law before all courts of the State of

3California and I am a principal of Shenkman & Hughes PC, attorneys of record for Plaintiffs

4in the above -captioned case. The facts set forth in this declaration are within my personal knowledge and, if called as a witness, I could and would competently testify as follows: 5

6 Shenkman & Hushes Attorneys 7 2. I have been primarily responsible for the handling of the above -captioned case 8 since its inception, and I have been involved in all aspects of this case. My partner, Mary R. 9 Hughes, has also worked on this matter, as have John L. Jones II and Andrea Alarcon,as 10 well as attorneys and professionals with the Parris Law Firm, Law Offices of Milton C. 11 Grimes and Law Office of Robert Rubin. 12 3. I graduated from Rice University in 1999 and completedmy J.D. at Columbia 13 University School of Law in 2002. I was admitted to the California Bar in 2002, and began 14 working at Hennigan, Bennett & Dorman LLP (now McKool Smith Hennigan),where I 15 worked on a wide variety of complex litigation until 2008. In 2011,I founded the law firm 16of Shenkman & Hughes along with Mary R. Hughes, whomI had known from my time at 17Gibson Dunn & Crutcher LLP. 18 4. Mary R. Hughes graduated from California State UniversityNorthridge in 191999 and completed her J.D. at the University of SouthernCalifornia Gould Law School. 20She was admitted to the California Bar in 2002, andbegan working at Gibson, Dunn & 21Crutcher LLP, where she worked until 2010. In 2011,Ms. Hughes co-founded the law firm 22of Shenkman & Hughes.

23 5. John L. Jones II graduated from Creighton Universityin 1996 and completed

24his J.D. at Yale Law School in 2001. Followinga short career in investment banking, he began working at Hennigan, Bennett & Dorman 25 LLP (now McKool Smith Hennigan) in 2002, where he remained until 2008. While 26 at Hennigan Bennett & Dorman LLP, and since

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SHENKMAN DECLARATION 1 his time at that firm, he has worked on complex litigationand bankruptcy matters, including

2 the notable bankruptcies of Hawaiian Airlines and BrobeckPhleger & Harrison LLP.

3 6. Andrea Alarcon graduated from Georgetown Universityin2000 and

4 completed her J.D. at Loyola Law School in 2009. Ms. Alarcon hashad an extensive career

5 in government and public service, before joining Shenkman &Hughes PC. For example,

6 Ms. Alarcon served as Director of the Los Angeles office of AttorneyGeneral Bill Lockyer

7 and Assistant to Attorney General Jerry Brown, and served as Presidentof the Los Angeles

8 Board of Public Works (the only Latina to serve in that role in the City of LosAngeles'

9 history), responsible for an annual budget of $1.8 billion. Important to the instant case,Ms.

10 Alarcon has also been involved in the Latino civil rights movement and politics for her

11 entire life.

12 7. True and correct copies of condensed resumes for Ms. Hughes and I, and the

13 resumes for Mr. Jones and Ms. Alarcon are collectively attached hereto as Exhibit A.

14 8. Ms. Hughes, Mr. Jones and I were also primarily responsible for the handling

15 of the first and second cases brought pursuant to the California Voting Rights Act to proceed

16 to trial - Jauregui v. City of Palmdale, Los Angeles Superior Court Case No. BC483039 and

17 Garrett v. City of Highland, San Bernardino Superior Court Case No. CIVDS1410696. We

18 prevailed in both of those cases. Following our trial victory in Jauregui v. City of Palmdale,

19 we also prevailed in both the intermediate appellate court and the California Supreme Court 20 - Jauregui v. City of Palmdale (2014) 226 Cal. App.4m 781 (review denied, en banc, Aug.

21 20, 2014)

22 9. For our successes in Jauregui v. City of Palmdale, subsequent cases brought 23 pursuant the California Voting Rights Act, and efforts to end unfair at -large elections 24 throughout California, I have been featured, sometimes along with the other attorneys of 25 Shenkman & Hughes PC, in various media, such as the Los Angeles Times, New York 26 Times, Wall Street Journal, ABC, CBS, PBS, NPR, Los Angeles Daily Journal, Dr. Drew 27 Show and Breitbart News (claiming that we were ending democracy in California).I am 28 frequently invited to speak to audiences of attorneys and non -attorneys concerning voting

SHENKMAN DECLARATION 1 rights and elections. For example, I have been the keynote speaker at Los Angeles County Bar Association events for young lawyers, and the annual conference of theCalifornia 3 Latino School Board Association. 4

5 Our Work On This Case 6 10. Even before filing suit, we worked with two renowned experts, David Ely and 7 J. Morgan Kousser, to study Santa Monica's elections to determine whether those elections 8 were characterized by racially polarized voting - the key element in a CVRA case. At the 9 same time, we engaged with civic leaders in Santa Monica and immersed ourselves in Santa 10 Monica's politics, city council actions, and historical discrimination to develop a better 11 sense of the unique circumstances in Santa Monica concerning race and elections. 12 Particularly because of Santa Monica's unique reputation and demographics, we also 13 worked with those same experts to evaluate the likely effectiveness of any remedial changes 14 to Santa Monica's election system.And, we also investigated the unique history and 15 controversy surrounding Santa Monica's adoption and maintenance (at various times) of its 16 at -large election system, to evaluate whether an Equal Protection claim might also be 17 justified. 18 11. While many political subdivisions, since our victory in Jauregui v. City of 19 Palmdale, had chosen to adopt district elections upon receiving notice that their at -large 20 elections violate the CVRA, we expected that Santa Monica would not likely change its 21 election system without a court battle.In fact, early in our pre -filing investigation, I met 22 with then -councilman Tony Vazquez, who had led the effort to adopt district elections for 23 Santa Monica's council in the late 1980s and early 1990s. Mr. Vazquez emphasized the 24 continuing power of those who had clung to the at -large election system in Santa Monica in 25 the past, and doubted that we would be successful in any effort to convince other council 26 members to adopt a fairdistrict -based election system. Indeed, Santa Monica is 27 exceptionally wealthy, enabling its council to carry ona scorched -earth approach to 28 defending its at -large elections, as some of its council members have noted in rationalizing

SHENKMAN DECLARATION 1 their expensive fight against the CVRA. A true and correct copy of aJuly 12, 2018 opinion -

2 editorial in the Los Angeles Times authored by Santa Monica's mayor and mayor pro -tern,

3 touting Santa Monica's financial resources that enabled it to vigorously litigate(and appeal)

4 the instant case, is attached as Exhibit B. Prior to filing the instant case, while wedid not

5 fully comprehend the extreme lengths to which Defendant's council members would go to

6 maintain the at -large system by which they were elected, we understood that they would

7 fight, and so a robust and complete pre -filing investigation would be necessary.

8 12. Satisfied that our preliminary investigation justifiedfurther action, on

9 December 15, 2015 we wrote to Defendant, notifying Defendant that its at -large elections

10 were unlawful and requesting that Defendant contact us todiscuss changing its at -large

11 system of electing its city council. A true and correct copy of my December 15, 2015

12 correspondence to Defendant is attached hereto as Exhibit C. There is no question that

13 Defendant's city council took notice of our December 15, 2015 letter - not only did I speak

14 personally with the then -city attorney, Marsha Moutrie, when I personally delivered the

15 letter along with several Pico Neighborhood activists (Ms. Moutrie actually communicated

16 her personal support for our efforts), but the letter was also the subject of a closed session

17 meeting of Defendant's city council in January 2016. A true and correct copy of the relevant

18 page of Defendant's city council meeting agenda for its January 12, 2016 meeting is

19 attached hereto as Exhibit D. 20 13. We waited for four months- well past the requested response date in the 21 December 15, 2015 letter- but received no substantive response from Defendant or its 22 attorneys. On April 12, 2016 Plaintiffs filed the above -captioned case. 23 14. Defendant quickly sprang into action to retaliate against me personally for 24 filing the above -captioned case on behalf of our clients. At that time, I was one of three 25 members of the Malibu Unification Negotiation Committee appointed by the City of Malibu 26 to negotiate fmancial terms for the establishment of an independent Malibu unified school 27 district. My counterparts from Santa Monica on that committee walked away from those 28 negotiations at Defendant's direction, demanded that we dismiss the above -captioned case,

SHENKMAN DECLARATION 1 and even forced the cancellation of the Committee's next scheduled publicly -noticed Brown

2 Act meeting. This all caused me a great deal of distress, particularly because several of my

3 neighbors blamed me for harming the years -long effort to establish a Malibu school district

4 - an effort onwhich I had spent significant time and resources.Ultimately, I decided,

5 consistent with my ethical obligations to our various clients, to resign from the Malibu

6 Unification Negotiation Committee, and make clear that we would never abandon our clients

7 or our fight for minority voting rights.My resignation letter was published by local

8 newspapers, and a true and correct copy of that letter is attached as Exhibit E. The Santa

9 Monica members of that committee returned to negotiate financial terms, and that committee

10 completed its work without me, but the damage to our relationships with our neighbors and

11 community, caused by that episode, persist.

12 15. Defendant's city attorney office has been involved in this case from its 13 inception, and Defendant also retained the very large and very expensive law firm- Gibson 14 Dunn & Crutcher LLP -a few weeks after the case was filed. My partner, Ms. Hughes, 15 worked as an associate at Gibson Dunn & Crutcher LLP for nearly 8years, and I also 16 worked at that firm for a short time, so we understood that Defendant's retention of that firm 17 meant that it planned to spare no expense in its defense of its racially discriminatory at -large 18 election system. We also understand, from our experience at Gibson Dunn & Crutcher LLP, 19 what it takes to prevail over that firm, particularly recognizing thatwe could never match the 20 financial resources and manpower that firm brings to bear. 21 16. The litigation that followed over the next threeyears has been extensive and 22 contentious.That litigation, culminating in a judgment fmding that Defendant'sat -large 23 election system not only violates the CVRA but alsowas adopted and maintained for a 24 discriminatory purpose, and thus violates the Equal Protection Clause, included,among 25 other things: 26 An expert -intensive six -week trial;

27 Three writ petitions; 28 A petition for review to the California Supreme Court;

SHENKMAN DECLARATION A summary judgment motion;

2 Two pleading challenges;

3 Twenty-four (24) depositions of fact witnesses;

4 Eight (8) depositions of expert witnesses; and

5 Thirty-one (31) discovery motions

6 Furthermore, particularly because of Defendant's publicity campaign orchestrated by its

7 significant in-house public relations department, we also needed to press Plaintiffs' case in

8 the court of public opinion and rally support among community leaders, activists and

9 residents in Santa Monica. Similarly, because of Defendant's efforts to lobby the California

10 Legislature to amend the CVRA in ways that would exculpate Defendant, we also needed to

11 press Plaintiffs' case with legislative leaders and Democratic Party officials.

12 17. Throughout the three-year litigation, Plaintiffs attempted to convince Defendant

13 that an amicable resolution through settlement would be superior, for all parties concerned, to

14 a disputed resolution by the court.In fact, Plaintiffs even convinced renowned mediator,

15 Jeffrey Krivis, to mediate the case for free. Though Defendant agreed to participate in that

16 free mediation, and then asked for a second day of free mediation (which was held a few

17 weeks after the first day of mediation), Defendant obstinately insisted at every stage that it

18 would never agree to any structural changes to its discriminatory at -large election system.

19 Rather, Defendant's city attorney bluntly explained Defendant's rationale for refusing any 20 change to its election system, remarking that she "just do[es]n't see any merit in this case."

21 Even during the six -week trial, Defendant's counsel inquired several times whether Plaintiffs 22 were ready to dismiss their case, and eschewed my invitations to discuss settlement. Rather,

23 Defendant complained that somehow Plaintiffs' actions were improper because they were 24 aimed at coercing Defendant to settle.For example, in opposing Plaintiffs' efforts to 25 question Defendant's city council members about their campaign finances, Defendant argued 26 that Plaintiffs' counsel "used the deposition to attempt to pressure Mr. O'Day to settle the 27 case" and "broached the improper topic of settlement" with Ms. Davis. A true and correct

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SHENKMAN DECLARATION 1 copy of the relevant pages from Defendant's Opposition to Plaintiffs'motion to compel the

2 subsequent depositions of Gleam Davis and Terry O'Day is attached hereto as Exhibit F.

3 18. To be sure, though the facts and law certainly support this Court's findings,

4 decision and Judgment, this case was no "sure thing."In fact, Defendant's counsel was

5 interviewed by Law.com on the eve of trial, and proclaimed: "We feel really good about our

6 case on the merits here." Defendant's counsel went evenfurther, stating: "The reality is that

7 if Santa Monica fails the CVRA test, then no city could pass."Notably, in that same

8 interview Defendant's counsel stated that CVRA cases are "so costly and time-consuming."

9 A true and correct copy of the August 1,2018Law.com article, titled "In Rare California

10 Voting Rights Trial, Gibson Dunn Steps Up for Santa Monica," is attached hereto as Exhibit

11 G.Defendant and its counsel were not the only ones to doubt whether Plaintiffs would

12 prevail in this case - prior to filing this case, I invited the law firm of Goldstein Borgen

13 Dardarian & Ho LLP as well as the Mexican American Legal Defense and Education Fund

14 ("MALDEF") to join us on this case but they both declined.Fortunately, other political

15 subdivisions have learned from Defendant's miscalculation; since this Court decided in favor

16 of Plaintiffs, many other political subdivisions in California have eliminated their potentially

17 dilutive at -large election systems, without the need for any lawsuit, as demonstrated by, for

18 example, the recent reporting of the Marin Independent Journal (a true and correct copy of

19 which is attached as Exhibit H).

20

21 Billing Rates

22 19. Shenkman & Hughes PC charges our hourly -paying clients$815per hour for

23 my time,$740per hour for Ms. Hughes' time, and $615 per hour for Ms. Alarcon's time. 24 Mr. Jones no longer works for Shenkman & Hughes PC, but in his years with Shenkman & 25 Hughes PC, Mr. Jones' billing rate was always the same as that of Ms. Hughes (which is 26 $740per hour). We have, in some instances, charged a blended rate for our services.In 27 those instances where we determine a blended rate is appropriate, that blended rate is$715 28 per hour.

SHENKMAN DECLARATION 1 20. In 2014, our firm's attorney rate (at that time, for Ms. Hughes, Mr. Jones and 2 myself) was $550 per hour, and that rate was approved by the Los Angeles Superior Court 3 for our work in Jauregui v. City of Palmdale.Since that time, in response to significant 4 demand for my services and the services of other Shenkman & Hughes' attorneys, we have 5 increased our respective rates several times, to the current rates stated above. Those rate 6 increases have not resulted in any decrease in demand for our services; if anything, the 7 demand for our services has continued to increase well beyond our capacity. 8 21. In addition to gauging the demand for our services, we arrived at our rates by 9 surveying the rates charged by attorneys with comparable education, skill, experience and 10 past results.Our rates are generally consistent with the billing rates suggested by the 11 Updated Laffey Matrix for attorneys with our respective experience. The Updated Laffey 12 Matrix suggests an hourly rate of: $685 for Ms. Alarcon - higher than her current rate of 13 $615; and $742 for Ms. Hughes - slightly higher than her current rate of $740. While my 14

15 hourly rate of $815 is slightly higher than that suggested by the Updated Laffey Matrix

16 ($740), I believe my exceptional experience and results warrant a rate greater than that

17 suggested by the Updated Laffey Matrix.Specifically, very few attorneys with less than

18 twenty years of experience have been lead counsel in the sort of notable trial victories as

19 Jauregui v. City of Palmdale and Garrett v. City of Highland as well as a rare trial of a 20 certified class action, and no other attorneys of any experience -level can claim greater 21 experience with the CVRA. Even Breitbart, while criticizing our work and the CVRA more 22 generally, conceded that I am "one of the most prolific and successful civil rights lawyers of 23 his generation." A true and correct copy of the Updated Laffey Matrix is attached as 24 Exhibit I. 25 22. The demand for my services, as well as other attorneys with Shenkman & 26 Hughes PC, has increased dramatically, particularly over the last seven years.I believe that 27 significant increase in demand for our services is the result of, among other things, three 28 recent notable victories our firm has achieved.First, as discussed above, in 2013 we

SHENKMAN DECLARATION 1 prevailed in the first -ever trial of a case brought under the CVRA, and prevailed in the

2 appeal of that same case in 2014. Second, later in 2014, we prevailed in a rare trial of a 3 certified class action, wherein the jury awarded the class of approximately 2500 consumers 4 we represented more than $4.3 million, including punitive damages.Third, as discussed 5 above, in January 2016 we prevailed in the second -ever trial of a case brought under the 6 CVRA. 7 23. The hourly rates of the attorneys at Shenkman & Hughes PC are also modest 8 in comparison to the rates charged by Defendant's attorneys - Gibson Dunn & Crutcher LLP 9 - overwhom we prevailed in this case. For example, filings in other cases reveal both the 10 historic rates of the particular Gibson Dunn & Crutcher attorneys who worked on this case, 11 as well as the rate of annual increase in their rates: in 2009 Marcellus McRae's billing rate 12 was $785 per hour; William Thomson's rate increased from $665 per hour in 2011 to 13 $864.50 per hour in 2014; Kahn Scolnick's rate increased from $641.25 per hour in 2012 to 14

15 $764.75 in 2014; and Tiaunia Henry's (f/lea Tiaunia Bedell) rate increased from $508.25 in

16 2011 to $631.75 in 2013. This indicates an annual rate increase of 9.5% - 12%, reflecting

17 both the increase in the prices for legal services generally and the increased skill and

18 expertise attorneys gain through additional years of practice. A true and correct copy of the

19 relevant pages of court filings showing the historic rates of Mr. McRae, Mr. Thomson, Mr. 20 Scolnick and Ms. Henry are collectively attached hereto as Exhibit J. A court filing in

21 another case also reveals Gibson Dunn & Crutcher LLP's blended rates for 2018 for non- 22 bankruptcy attorneys and paralegals: $1,117 per hour for partners; $870 per hour for 23 "counsel"; $710 per hour for associates; and $399 per hour for paralegals. That same court 24 filing also reveals the 2019 hourly rates of particular Gibson Dunn & Crutcher attorneys 25 along with their respective dates of admission to practice law. Based on that court filing, if 26 Ms. Hughes, Mr. Jones and I were at Gibson Dunn & Crutcher LLP (where both Ms. 27 Hughes and I worked at one point in our respective careers), our billing rate would be 28 approximately $1,275 per hour. If Ms. Alarcon were at Gibson Dunn & Crutcher LLP, her

SHENKMAN DECLARATION 1 billing rate would be approximately $900 per hour. A true and correct copy of relevant 2 pages of the court filing showing the blended rates charged byGibson Dunn & Crutcher in 3 2018 as well as the specific rates of various Gibson Dunn & Crutcher attorneys and 4 paralegals in 2018 and 2019 is attached hereto as Exhibit K. 5 Billing Records 6 24. The attorneys with Shenkman & Hughes PC maintain contemporaneous time 7 records. Attached hereto as Exhibit L is a true and correct copy of the contemporaneous 8 records of time reasonably spent by Shenkman & Hughes PC's attorneys in this case.I 9 personally reviewed the time records of each Shenkman & Hughes PC attorney, and 10 exercised my billing judgment in deleting approximately 240 hours of time that did not 11 appear reasonably necessary or reflected small amounts of time for minor tasks. In total, after 12 those reductions, Shenkman & Hughes PC attorneys spent 7786.3 hours pursuing this case. 13 25. To assist the evaluation of our billings, particularly due to the volume of billing 14 entries, I have also categorized the time by task. Attached hereto as Exhibit M is a true and 15 correct copy of the summary "time -and -task" chart that I prepared from the contemporaneous 16 time records. 17 26. Particularly in light of the anticipated complexity of this case and my 18 recognition that Defendant would put up a significant fight, I invited several firms to join 19 Shenkman & Hughes in pursuit of this case.I asked Milton Grimes to join us as co -counsel 20 due to his exceptional trial experience and understanding of racial issues and how to present 21 sensitive racial issues at trial.I asked Rex Parris and his firm to join us as co -counsel 22 similarly due to their exceptional trial experience. Finally, I asked Robert Rubin to join us as 23 co -counsel due to his experience and knowledge in the field of voting rights. Each of these 24 firms has been involved in this case since April 2016 when the original Complaint was filed. 25 Though my colleagues at Shenkman & Hughes and I did the majority of the work on this 26 case, the contributions of these three other firms proved to be invaluable at various points in 27 this case; without them it would have been nearly impossible to compete with the resources 28

SHENKMAN DECLARATION 1 and manpower of Defendant's counsel, both Defendant's in-house city attorneysand outside

2 counsel at Gibson Dunn & Crutcher LLP.

3 27. While the involvement of multiple law firms was essential to the litigation and 4 trial of this case, it also posed challenges in avoiding the duplication of work. Even with

5 these other law firms, we could never match the combined resources and manpowerof

6 Gibson Dunn & Crutcher LLP and Defendant with its well -staffed city attorney's office, so

7 we needed to be efficient in the way that we litigatedand tried this case; we did not have the

8 luxury of duplicating each other's work. Though some duplication of work was inevitable,

9 and even occasionally desirable in limited circumstances, we minimized any duplication of

10 work by implementing a clear system for allocating work. Specifically, I was responsible for

11 allocating and coordinating all work by all attorneys, as well as overall case strategy. While

12 attorneys at firms other than Shenkman & Hughes necessarily kept abreast of the events, facts

13 and law of the case, so that they had at least a basic understanding of the case to allow them

14 to do their work when called upon, those other attorneys handled only work, issues and

15 matters as I directed. My allocation of work was principally guided by the unique strengths

16 of each attorney. For instance, Mr. Paths and Mr. Grimes are accomplished and skilled trial

17 attorneys; and Mr. Rubin has decades of experience in voting rights. Additionally, Mr. Parris

18 has experience in municipal government, having served as Mayor of Lancaster for over a 19 decade, and Mr. Grimes has first-hand experience in the civil rights movement- both 20 important in this case.I took these strengths (and others) into account in assigning various 21 tasks, issues and work to each co -counsel firm as well as among the attorneys within 22 Shenkman & Hughes. Oftentimes work in this case required the involvement ofmore than 23 one attorney or firm, and I have always found that it is beneficial to the ultimate work product 24 to have attorneys discuss issues with one another, however, by maintaining responsibility for 25 the allocation of all work in the first instance, I was able to minimize duplication of efforts in 26 this case. 27 28. While the amount of work required of plaintiffs' attorneys is often greater than 28 that of defendants' attorneys, particularly because plaintiffs generally bear the burden of

SHENKMAN DECLARATION 1 proof, the number of hours expended, and the amount of attorneys'fees incurred, by a non -

2 prevailing party can sometimes be informative of the reasonableness of the prevailingparties'

3 fees.For the sake of comparison, the defendant in Jauregui v. Palmdale revealed, in

4 opposing the plaintiffs' first fees motion, that its counsel had worked approximately 2850

5 hours through the entry of judgment; and the court found 4363.9 hours expendedby

6 plaintiffs' counsel to be reasonable.

7 29. In order to make the comparison in this case, I directed Marci Hilsinger, a

8 paralegal at the Parris Law Firm, to submit a California Public Records Act ("CPRA")

9 request to Defendant for: the aggregate total amount of money paid by Defendant to Gibson

10 Dunn & Crutcher LLP by producing all warrants approved by its city council for payments to

11 Gibson Dunn & Crutcher LLP; and the billing rates charged by each of Defendant's attorneys

12 in this case by producing the agreement approved by Defendant's city council for legal

13 services by Gibson Dunn & Crutcher LLP.Defendant refused to provide any of this

14 information, and asserted that it would not provide any information at all. A true and correct

15 copy of Defendant's response to the CPRA request is attached hereto as Exhibit N.

16 30. We are not the only ones who have sought to uncover this information

17 concerning Defendant's expenditure of public funds on lawyers to defend its council

18 members' self -interested decision to cling to the racially discriminatory at -large election 19 system.As the Santa Monica Lookout reported on March 5, 2019, that newspaper also 20 requested the same information, and that request was similarly refused by Defendant. A true 21 and correct copy of the March 5, 2019 article in the Santa Monica Lookout, titled "City 22 Officials Won't Reveal Cost of Voting Rights Lawsuit Until Case is Closed" is attached 23 hereto as Exhibit 0. 24

25 Fee Awards in Other CVRA Cases 26 31. Based on being plaintiff's counsel in a significant portion of the CVRA 27 litigation to date, as well as developing relationships with nearly all other attorneys who have 28

SHENKMAN DECLARATION worked on any CVRA litigation at all, I am familiar with the conduct and fees awards in nearly all CVRA cases.

3 32. In Jauregui v. City of Palmdale, following an eight -day trial and an appeal of 4 the preliminary injunction issued in that case, the court ultimately awarded Plaintiffs' counsel

5 over $4.6 million. In Sanchez v. City of Modesto, the defendant paid $3 million -a case in

6 which the trial court granted the defendant's motion for judgment on the pleadings less than a

7 year after the complaint was filed, but was then reversed by an intermediate appellate court,

8 and the case settled with no further litigation activity. Notably, Defendant's counsel (before

9 he retired), George Brown, represented the plaintiff in Sanchez v. City of Modesto.In

10 Yumori-Kaku v. City of Santa Clara, the court recently awarded more than $3.1 million in

11 fees after one year of litigation culminating in a five-day trial.

12 33. None of those cases was even remotely as lengthy, hard-fought and extensive as

13 the instant case. Up until this case, Jauregui v. City of Palmdale was the hardest -fought 14 CVRA case. Jauregui required an 8 -day trial approximately one year after the case was filed;

15 the trial of this case lasted six weeks and began more than two years after the case was filed. 16 For comparison, in Jauregui there were six (6) fact witness depositions, all but one of which 17 lasted less than three hours; in this case there were twenty-four (24) fact witness depositions. 18 In Jauregui, there were two (2) discovery motions; in this case there were thirty-one (31) 19 discovery motions. I have been involved in the litigation of multi -million dollarcases since 20 being admitted to practice law in 2002, and even a multi -billion dollarcase that reached the 21 U.S. Supreme Court (MGM Studios, Inc. v. Grokster, Ltd. (2005) 545 U.S. 913);none of 22 those cases have been as hard-fought, extensive, and physically and emotionally taxingas 23 this case. 24

25 Expenses

26 34. In the course of litigating the above -captioned case, Shenkman & Hughes PC 27 incurred significant expenses- the majority of which were expert witness fees. Through a 28 query of our firm's accounting system, I was able to retrieve a summary of the expenses,

SHENKMAN DECLARATION 1 excluding expert witness fees, incurred in connection with the above -captioned case.

2 Attached hereto, collectively, as Exhibit P is a true and correct copy of that summary,

3 organized by expense type (e.g. travel, filing and messenger fees, and meals).

4 35. The majority of the expenses incurred in this case were for expert witnesses /

5 consultants. Specifically, expert demographer David Ely with Compass Demographics, Inc.,

6 Caltech Professor J. Morgan Kousser, an expert on racially polarized voting, history and

7 elections, survey expert Jonathan Brown and Loyola Law School professor Justin Levitt were

8 invaluable in the development and trial of this case.Their invoices totaled $97,482.76;

9 $394,712.50; $30,250.00 and $90,155.00, respectively, for work through the entry of

10 judgment on February 13, 2019. True and correct copies of their invoices for the work they

11 performed on this case are attached collectively as Exhibit Q. Note that while Professor

12 Levitt's invoice is for $91,430, a small portion of that invoice is for work after entry of

13 judgment, and so Plaintiffs seek reimbursement of only $90,155 for Professor Levitt's work

14 at this time.

15 36. In total, other than small items for which Shenkman & Hughes does not track

16 and therefore does not seek to recover, Shenkman & Hughes incurred a total of $633,221.04

17 in expenses in pursuit of this case.

18

19 I declare under penalty of perjury under the laws of the State of California that the 20 foregoing is true and correct.

21 Executed this 3rd day of June 2019, at Malibu, California. 22

23 24 Kevin I. Shenkman 25

26

27 28

SHENKMAN DECLARATION EXHIBIT A KEVIN I. SHENKMAN

28905 Wight Road, Malibu, California 90265 (310) 457-0970 [email protected]

EXPERIENCE Shenlunan & Hughes PC, Malibu, California Principal, June 2011 - present

Lead attorney on first and second California Voting Rights Act cases to be decided at trial - prevailed in both, including on appeal - and successfully settled over a dozen other voting rights cases

Lead attorney on rare jury trial of a certified consumer class action, obtaining judgment in excess of $6 million including punitive damages, and successfully settled numerous other class action cases.

Frequent invited speaker regarding voting rights and elections on radio, television and professional conferences.

Zuber & Taillieu, LLP, Los Angeles, California Senior Counsel, 2010-2011 Associate, 2009

McKool Smith Hennigan, LLP, Los Angeles, California (f/k/a Hennigan Bennett & Dorman, LLP) Associate, 2002-2008 Gibson, Dunn & Crutcher, LLP, Los Angeles, California Summer Associate, Summer 2001

Morgan & Finnegan, LLP, New York, New York Summer Associate, Summer 2000 Clerk, September 2000- May 2001

Gifford Krass Groh Sprinkle Anderson & Citkowski, Birmingham, Michigan Summer Associate, Summer 2000 Clerk, Summer 1999

Ford Global Technologies, Inc., Dearborn, Michigan Intern - Summer 1998

47th District Court, Farmington, Michigan Clerk - Summer 1996 and Summer 1997

EDUCATION Columbia University School of Law, New York, New York Juris Doctor, May 2002

Columbia Business Law Review Rice University, Houston, Texas Bachelor of Science, Mechanical Engineering, May 1999

Dean's List

MISCELLANEOUS Admitted to California State Bar since 2002

Admitted to the Patent Bar since 2000 MARY RUTH HUGHES

28905 Wight Road, Malibu, California 90265 (310) 457-0970 [email protected]

PROFILE Accomplished attorney with over sixteen years of experience in a broad range of legal matters, including all aspects of litigation, including trial preparation, motion practice, expert reports, depositions and discovery, complex public company mergers, private equity acquisitions and divestitures, joint ventures, capital market transactions, SEC reporting, financing, general corporate advice and contract negotiation.

EXPERIENCE Shenkman & Hughes PC, Malibu, California Principal, April 2010 - present

Handle all aspects of class action and voting rights litigation, including trial, appeal, class certification, dispositive motions, settlement negotiation, and obtaining court approval of settlements

Handle all legal matters for a wide variety of clients, including in the software development, construction, real estate and stem cell research industries. Gibson, Dunn & Crutcher, LLP, Los Angeles, California Associate, October 2002 - April 2010 Summer Associate, Summer 2001

Handle all aspects of business transactions from inception through closing.

Draft and negotiate merger agreements, stock purchase agreements, note purchase agreements, stockholders agreements, ancillary transaction documents, operating agreements (such as international distribution agreements and supplier agreements).

Experience with partnership and limited liability company agreements and private equity investments, including leveraged buyout and co -investment relations.

Successfully consummate a wide variety of corporate transactions, from a $35 million acquisition to a $19 billion merger of equals, including buy -side and sell- side representation of both operating companies and financial buyers.

Part of litigation team on complex antitrust matters with over $1 billion in dispute, taking and defending depositions, drafting and opposing motions, and overall litigation strategy. Hymes & Company, CPA, Tarzana, California Accountant, 1997-1999

Bookkeeping and business management for entertainment and manufacturing clients.

Prepare tax returns and unaudited financial statements.

EDUCATION University of Southern California, Los Angeles, California Juris Doctor, May 2002

Order of the Coif (top 10%)

Southern California Law Review California State University Northridge, Northridge, California Bachelor of Science, Accountancy, December 1998

Dean's List (all semesters)

MISCELLANEOUS Admitted to California State Bar since 2002

Passed CPA exam in 1998 (among top 125 scores)

California licensed real estate broker JOHN LORENZO JONES II

28905Wight Road, Malibu, California90265 (310) 457-0970 jjones®sheniunanhughes.com

EDUCATION YALE LAW SCHOOL New Haven, CT Juris Doctor April 2001 Honors: Earl Warren Scholar, John M. Olin Fellow, Business Plan Competition(Yale School of Management) - 1st Place Activities: Co -Chair, Black Law Students' Association; Legal Services Clinic; TemporaryRestraining Order (TRO) Project

CREIGHTON UNIVERSITY Omaha, NE Bachelor of Science in Mathematics, Computer Science, and Philosophy, cum laude May1996 Honors: University Distinguished Scholar (4 years), Theta Bould Foundation Scholarship,Phi Sigma Tau Honors Activities: Board Member, United Way of the Midlands; Captain, Debate Team

EXPERIENCE

Shenkman & Hughes PC Malibu, CA Counsel 2012-2017

Worked on all aspects of voting rights litigation from preliminary statistical analysis to trial to appeals.

Represent clients in connection with business and commercial litigation.

Lim, Ruger & Kim, LLP Los Angeles, CA Associate, Litigation Group 2008-2012

Represent clients in connection with business and commercial litigation and bankruptcy matters. Engaged in all aspects of litigation in state and federal courts.

Drafted and argued motions and other pleadings in state and federal courts, including motions for summary judgment, relief from stay, demurrers, discovery motions, and non-dischargeability actions. Litigated breach of contract disputes, conducted depositions, participated in mediations, negotiated settlements, and counseled clients.

Hennigan, Bennett & Dorman LLP Los Angeles, CA Associate, Business Reorganization & Bankruptcy Group 2002-2008

Represent creditors, debtors, trustees, and other parties in interest in corporate bankruptcy and out -of -court restructurings, including first day filings, negotiating and adjudicating claims, litigating adversary proceedings and related appeals.

Represented chapter 11 trustee in connection with soliciting investments in chapter 11 debtor. Assisted in preparation of joint plan of reorganization and disclosure statement, as well as related term sheets and agreements.

Represented chapter 7 trustee in connection with the sale of equity and limited partnership interests in investment portfolio.

Oversee junior attorneys and staff; work with and manage outside counsel and consultants.

Representative matters include: Hawaiian Airlines, Inc. (chapter 11 trustee, reorganized debtor), Brobeck, Phleger & Harrison LLP (chapter 7 trustee), NorthPoint Communications, Inc. (chapter 7 trustee, ad hoc committee of bondholders).

Dresdner Kleinwort Wasserstein, Inc. New York, NY Associate, Financial Restructuring Group 2000-2002

Worked on financial restructuring assignments representing debtors and creditors. Responsibilities included performing valuation and claims analysis, completing due diligence, negotiating with creditor groups and developing strategic alternatives. Participated in a buy -side transaction in the food and beverage industry. Modeled financial scenarios including pro -forma acquisition and divestiture analysis. Responsible for executing management presentations and assisting with bidding strategy.

Primary day-to-day contact and coordinator in a sell -side transaction. Drafted offering memorandum, performed valuation, and negotiated confidentiality agreements and purchase terms with potential buyers.

Developed financial models to value public and private entities.

Cravath Swaine & Moore LLP New York, NY and Hong Kong Summer Associate Summer 1999

Drafted prospectus and conducted due diligence for the $500MM secondary equity offering by Neptune Orient Lines.

Drafted prospective IPO filing for the China National Offshore Oil Corporation.

Howard Rice Nemerovski Canady Falk & Rabkin San Francisco, CA Summer Associate Summer 1998

Developed appellate strategy for patent infringement suit to the Federal Circuit Court of Appeals.

Drafted motion in limine to exclude spoliated evidence and expert testimony.

Los Alamos National Laboratory Los Alamos, NM Graduate Research Assistant 1996-1997

Designed software and algorithms to collect GPS satellite data, performed data analysis of energetic particle data.

Conducted a study of potential causes of false trigger rates of W -Sensors.

Personal Member of California and New York State Bars; enjoy reading, mountain biking, Asian culture, and philosophy ANDREA ALARCON 28905 Wight Road Office (310) 457-0970 Malibu, CA 90265 [email protected]

EDUCATION LOYOLA LAW SCHOOL, Los Angeles, CA Juris Doctorate, May 2009 Law Study Abroad: Universidad para la Paz, Costa Rica, Intl. HumanRights & Environmental Law, Summer 2007

GEORGETOWN UNIVERSITY, Washington, D.C. Graduate Business Administration Certificate, May 2001 Bachelor of Arts, Double Major: American Government and English Literature, Minor:Theology, December 2000

EXPERIENCE SHENKMAN & HUGHES PC, September 2017 - Current Associate Counsel for plaintiffs in 6 -week trial re: Pico Neighborhood Association, et al. v.City of Santa Monica - assertingviolations of the California Voting Rights Act (CVRA) and the Equal Protections Clause of the California Constitution; Contributed to trialstrategy development and preparation of witnesses andevidencefortrial;Managefirm'sportfolioof CVRA mattersinjurisdictionsstatewide; Conduct historical research on municipalities; Compile election results, census data and related information; Draft complaints, motions, declarations, mediation briefs & other pleadings; Propound & respond to discovery; Appearances in Bankruptcy, Employment, Corporate & Civil matters; Managed execution of Writ of Possession from property seizure to auction; Participate in mediation sessions; Maintain positive client relations.

LAW OFFICES OF MILTON C. GRIMES, February 2017 - September 2017 As the firm's sole employee, drafted all pleadings, legal & client correspondence, memoranda, discovery documents and mediation demand letters in areas of law including: civil rights, criminal law, election law and employment law; Contributed to legal strategy and development; Gathered facts and obtained evidence through thorough document review and client interviews; Maintained close client contact regarding case progress and strategy; Created deposition outlines for key witnesses; Conducted all client consultations; Researched case -specific issues of medical standards of care and law enforcement protocol.

GABRIELSALOMONS, LLP, September 2016 -January 2017 A small general practice law firm with a primary focus on civil, corporate defense; Propounded and responded to discovery; Transactional corporate work, i.e. establish business entities, drafting corporate documents including By -Laws & Articles of Incorporation; Other areas of practice include: Estate Planning/Wills & Trusts drafting trusts, living wills, powers of attorney, advance directives, etc. and Family Law dealing with dissolutions, community property division, alimony/child support using DissoMaster, child custody and domestic violence related issues; Conduct Legal Research; Communicate with clients & court departments; Manage office accounting and support staff.

LAW OFFICES OF PETER M. HART, February 2016 - June 2016 A plaintiffs' employment law firm with a primary focus on wage and hour violations, class actions and PAGA representative actions; Drafted and prepared discovery requests & responses, pleadings and other client communications; Assisted in development of deposition strategy and line of questioning; Conducted legal research and drafted related memoranda; Created a class action client questionnaire used to collect and compile facts via live client interviews.

ALARCON STRATEGIES, Owner and Public Policy Consultant, February 2013- 2017 Established a public policy consultant firm offering strategic advice and public policy development to businesses and CBOs; Worked with affiliated labor organizations to negotiate Collective Bargaining Agreements and settle/resolve labor disputes; Create and foster positive partnerships for clients with residents, community organizations, businesses and other stakeholders in municipalities throughout California. Significant interface with City, County and State elected officials. LOS ANGELES BOARD OF PUBLIC WORKS President / Commissioner, Sept. 2009 - Jan. 2013 Served as the President of the Los Angeles Board of Public Works, the City's onlyfull-time, appointed policy making body. Alarcon was the youngest and only second Latina in the City's history to servein this esteemed position. The Board is an executive team composed of five -members, appointed by the Mayorof Los Angeles and confirmed by City Council to 5 -year terms. As General Managers, the Board of Public WorksCommissioners are the chief administrators of the Department of Public Works, the City's third largest municipal agencywhich consists of more than 5,500 employees and has an annual budget of more than $1.8 billion. The Board meetsin public forum three times per week and, during its open meetings, receives bids for and awards 85% of theCity's construction contracts, develops and implements departmental policy initiatives, and protectsresidents' due process through hearings for property assessments, above ground facility and cell tower proposals, treeremovals and construction subcontractor substitutions. The Board oversees 5 Bureaus: the Bureau of Engineering. responsiblefor the design, construction, renovation and operation of public facilities and infrastructure ranging from the City's wastewater treatment plants, bridges, libraries, police / fire department buildings, and other publicfacilities; the Bureau of Sanitation: responsible for citywide curbside waste collection, wastewater management, hazardous wastecollection and watershed protection; the Bureau of Street Services: responsible for pavement/maintenance of the City's7,000 miles of streets, its urban forest of over 700,000 street trees, its 11,000 mile sidewalk network, and enforcement of municipal codes for illegal dumping, illegal sign postings, illegal sidewalk vending and other encroachments in the public right of way; the Bureau of Street Lighting: installed and maintained the LED Street Lighting network; and, the Bureau of Contract Administration: processed contractor bids, contract awards and managed City's Project Labor Agreement (PLA).

CALIFORNIA ATTORNEYS GENERAL BILL LOCKYER / JERRY BROWN Director, Los Angeles Executive Office for AG Bill Lockyer, Jan. 2004 -Jan. 2008; Assistant for AG Jerry Brown, Jan. 2008-Sept. 2009 Managed Southern CA executive operations; Crafted a legislative package - "CORE" Collaborative Opportunities for Rehabilitation and Enforcement - to provide funding for offender rehabilitation through collaborative efforts between law enforcement and community -based organizations; Served as AG liaison on matters of violence against women through advocacy with the AG's Task Force on Criminal Justice Response to Domestic Violence, the LA County Domestic Violence Council, the LA City Domestic Violence Task Force and the Inter -Agency Council on Abuse & Neglect (ICAN); Led the AG's Anti -Gang Violence Initiative including the development of a statewide directory of gang interventionist and community resources; Reviewed policy proposals; Coordinated AG press conferences, special events, hearings, interviews, meetings, community events; Designated staffing for the AG's Southern CA schedule of events; Tracked priority litigation & legislation; Conducted legal research, drafted and analyzed legal memoranda, reviewed/revised voter initiatives' "Title and Summary"; and, briefed AG for Southern CA events; Supervised executive personnel.

GOVERNOR GRAY DAVIS COMMITTEE / CALIFORNIANS AGAINST THE GOVERNORS RECALL Deputy Political Director, Sept. 2003 - Oct. 2003 (Los Angeles, CA) Contributed to campaign strategic development, particularly related to Hispanic and women voters, spearheading several targeted mobilization efforts including Women Against the Recall, Latinas Against the Recall, Teachers Against the Recall, etc.; Convened private meetings with Governor Davis, press conferences and public/private events; Coordinated campaign advertising specific to Spanish language media, including radio and television spot buys to promote our Get Out the Vote (GOTV) efforts; Served as direct liaison and direct point of contact to local, state, county and national elected officials; Developed a network of surrogate speakers against the recall.

TAXPAYERS AGAINST THE GOVERNORS RECALL Director of Operations, June 2003 - Sept. 2003 (Sacramento, CA) Developed and managed operating budget; Processed financial contributions; Authorized disbursements for all expenditures; Managed payroll; Contributed to campaign strategic planning; Facilitation of Press conferences; Political outreach to legislators and other elected officials. WOMEN ADVANCING THE VALLEY THROUGH EDUCATION, ECONOMICS AND EMPOWERMENT Executive Director & Grant Writer, Sept. 2001 - May 2003 Alarcon served as the managing officer of the largest transitional housing shelter for victims of Domestic Violence in the United States; directed a staff of over 30 employees including licensed clinicians, case managers, child development and administrative personnel; Managed an annual budget of over $500k in government funding, including the administration of four sizeable government contracts provided by Housing & Urban Development (HUD), the Los Angeles Homeless Services Authority (LAHSA) and the LA Community Development Department (CDD); Filed monthly invoices and annual reports; Interfaced with City, County and State Elected Officials; Applied for and Received License for on -site Child Development Center - closed escrow with the CA Division of Housing & Community Development on a $1 million development project to construct the center; and, restructured the programmatic design into a phased system to allow clients gradual progression towards self-sufficiency. UNITED STATES DEPARTMENT OF JUSTICE Hate Crimes Policy Analyst, June 1999 - Sept. 1999 Completed preliminary research on criminal hate activity at institutions of higher learning, convened focus groups; Developed and conducted a telephone survey of over 100 college & university Chiefs of Police to assess their preparedness to respond to hate related incidents. With the information compiled, authored a 23 -page federal document entitled, "Responding to Hate Crimes and Bias Motivated Incidents on College and University Campuses," which was published and distributed by the US DOJ. Interfaced with members of the US Senate, US House of Representatives and Presidential Executive personnel.

LEADERSHIP '98 - P.A.C. CREATED BY VICE PRESIDENT AL GORE / GORE 2000 Assistant to Regional Director of the Western US, Oct. 1998 - Jan. 1999 Assisted in the coordination of political events and fundraisers in Western states; Prepared Vice President's briefing materials; Maintained a database of detailed biographical information on elected officials, dignitaries, and donors.

APPOINTMENTS LOS ANGELES CITY BOARD OF TAXICAB COMMISSIONERS Commissioner, Dec. 2008 - Sept. 2009 Served, by unanimous City Council approval, on the Board of Taxicab Commissioners which advises the General Manager of the LA Department of Transportation on issues pertaining to all privately owned taxicab franchises in the City; Contributed to formulation of the Franchise Request for Proposals and voted to determine and fmally approve taxicab franchise applications; Reviewed appeals by taxi drivers who were issued citations for violations of the Taxi Rules and Regulations pursuant to the LA Administrative Code and other related ordinances.

LOS ANGELES CITY BOARD OF TRANSPORTATION COMMISSIONERS Commissioner, March 2006-Dec. 2008 Served, by unanimous City Council approval, on the governing body for the LA Department of Transportation; Provided oversight of the Special Parking Revenue Fund, the 5' largest revenue source for the City's general fund; Contributed to development & implementation of the City's Parking Master Plan, including policy directives for Preferential Parking Districts, valet/curbside parking, off-street parking facilities & on -street parking zones; Determined parking rate increases; Approved appropriations for citywide transportation development projects; Made finaldeterminationsfor LA DOT personnelactionappeals; Approved Ambulatory Vehicle & Operator Permits.

INTERNSHIPS LOS ANGELES CITY COUNCILMEMBER HAL BERNSON 12" City Council District, February - June 1997

CALIFORNIA ASSEMBLYMEMBER / DEMOCRATIC MAJORITY LEADER RICHARD KATZ 39" State Assembly District, January - June 1996

LOS ANGELES CITY COUNCILMEMBER RICHARD ALARCON Th City Council District, June - September 1994 PAST ORGANIZATIONAL AFFILIATIONS CALIFORNIA DEMOCRATIC PARTY, Executive Board Member & Appointed Delegate LOS ANGELES COUNTY DEMOCRATIC PARTY CENTRAL COMMITTEE, Appointed Delegate LA CITY HISPANIC HERITAGE MONTH MAYORAL COORDINATING COMMITTEE, Chair COMISION FEMENIL DEL SAN FERNANDO VALLEY, Board Secretary COMMUNITY HOUSING MANAGEMENT SERVICES, Board Member CALIFORNIA YOUNG DEMOCRATS, Member DEMOCRATIC PARTY OF THE SAN FERNANDO VALLEY, Member AG'S TASK FORCE ON CRIMINAL JUSTICE RESPONSE TO DOMESTIC VIOLENCE, Liaison LOS ANGELES COUNTY DOMESTIC VIOLENCE COUNCIL, Member LA CITY DOMESTIC VIOLENCE TASK FORCE, Member INTER -AGENCY COUNCIL ON ABUSE AND NEGLECT (ICAN), Member

HONORS / GUEST SPEAKER LA Sustainability Collaborative Award for Leadership: 2012 Hispanas Organized for Political Equality (H.O.P.E.) Conference Speaker: 2012 City of Los Angeles Certificate of Recognition by Eric Garcetti: 2012 Weingart Foundation "Women Building LA" Award: 2011 National Hispana Leadership Institute (N.H.L.I.) Speaker: 2011 Hispanic Heritage Month City of Los Angeles Certificate of Appreciation: 2011 Latina Lawyers Bar Association Award: 2009 LAUSD Board of Education "Extraordinary American Woman" Award: 2006 Georgetown University Second Honors: 2000 Georgetown University Dean's List: 1997-2000 Patrick Healy Honors Fellowship: 1999-2000 Us Department of Justice Certificate of Appreciation: 1999 Georgetown Center for Minority Educational Affairs Certificate for Leadership Service: 1999 Georgetown Young Scholars Certificate for Outstanding Leadership: 1999 California State Assembly Certificate of Recognition: 1997 US House of Representatives Certificate of Special Congressional Recognition: 1997 City of Los Angeles Certificate of Commendation: 1997 Presidential Academic Award for Educational Excellence: 1997

PUBLICATIONS UNITED STATES DEPARTMENT OF JUSTICE, 1999, Washington, DC. "Responding to Hate Crimes and Bias Motivated Incidents on College and University Campuses" EXHIBIT B 12 FREE WEEKS ] LOG IN iI71 TOPICS SALE ENDS 6/3

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OP-ED OP-ED OPINION Santa Monica shouldn't have to change its local elections

By TED WINTERER and GLEAM DAVIS tr r. JUL 12, 2018 I 4:05 AM

Santa Monica Mayor Ted Winterer. (Los Angeles Times) The city of Santa Monica received a letter from a Malibu law firm in late 2015 claiming that its at -large election system - in which all voters choose the whole city council - discriminated against Latino residents. We were both on the City Council at the time and found it surprising, not least because the then -mayor was Mexican American.

Still, the letter threatened a lawsuit under the California Voting Rights Act if the council did not immediately agree to change to district -based elections. It turns out Santa Monica wasn't alone. Dozens of cities have received similar demand letters - many from the same lawyer - and many have altered their election systems in response.

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ADVERTISEMENT Santa Monica, however, has decided to fight this lawsuit. Why? Because making electoral changes based on lawsuits instead of the will of voters diminishes rather than enhances voting rights. Equally important, the facts in Santa Monica and the experience of cities elsewhere show that carving the city into districts will not meaningfully enhance local Latino political representation.

The Pico neighborhood is the focus of the California Voting Rights Act lawsuit, but the 13% of Santa Monica voters who are Latino live in every part the city. Under our existing at -large election system, Latino candidates have won seats on all of the city's governing bodies, including two currently serving on the seven -member City Council. As the Los Angeles Times reported, in this kind of racially integrated landscape, a change to district -based elections is unlikely to increase Latino representation.

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By Sunrise Springs \,%-if If the California legislature believes that district -based voting is the only system that works, it should mandate the switch statewide.

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GrassrootsLab, a consulting firm that specializes in local government politics, studied the electoral outcomes in 22 cities that switched to district elections because of a California Voting Rights Act legal threat. Only seven of the 22 cities saw any increase in Latino elected officials. Indeed, some people are trying to make the case that district elections create their own set of problems. The former mayor of Poway, for instance, in October filed a federal lawsuit arguing that forcing district elections ultimately violates the constitutional rights of other voters.

Santa Monica voters have twice rejected proposals to move to district -based elections, in 1975 and 2002. A district system may work well in larger cities like Los Angeles, but dividing up our 8.3 -square -mile community will pit neighborhood against neighborhood, increasing balkanization and encouraging legislative deal - making to serve the interests of individual districts rather than the city as a whole.

A united Santa Monica has been able to tackle large issues, including crime, homelessness, affordable housing, mobility, economic growth, educational opportunity and community well-being. We work hard to accomplish a lot, in part because council members are accountable to every Santa Monica voter every two years. With district elections, residents would be represented by only one council member, who would face election only once every four years.

Other California cities believed just as strongly in their at -large election systems. They nonetheless switched to district elections out of fear of overwhelming legal costs. In addition to paying their own lawyers, cities that lose such cases have to pay the plaintiffs attorney's fees, according to the state law. In Palmdale, where one of the first high -profile cases was settled in 2015, the attorney fees hit $4.5 million. ADVERTISEMENT

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We are fighting this lawsuit because we believe it lacks merit. But other cities without our financial resources haven't had that choice. Instead, decisions affecting the heart of the democratic process were driven as much by fear of legal costs as by desire to ensure that everybody's vote counts. This cannot be what the state legislature intended when it passed the California Voting Rights Act in 2001.

If Santa Monica voters believe that district -based voting will best serve our city, we can go to the ballot box to make that choice. If the California legislature believes that district -based voting is the only system that works, it should mandate the switch statewide. But if state lawmakers believe that Californians should have a choice as to how they elect their local representatives, the California Voting Rights Act should be amended to follow the federal Voting Rights Act, which ensures that court -mandated districting and payment of attorneys' fees occurs only when a district -based system is truly needed to make sure minority votes count.

Ted Winterer has served on the Santa Monica City Council since2012and is currently mayor. Gleam Davis has been on the council since 2009 and is mayor pro tem.

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A digest of essential news, insight and analysis from L.A. Times editors. EXHIBIT C 28905 Wight Road SHENKMAN & HUGHES Malibu, California 90265 (310) 457-0970 ATTORNEYS MALIBU. CALIFORNIA [email protected]

VIA EMAIL

December 15, 2015

Mayor Tony Vazquez [email protected] Mayor Pro Tern Ted Winterer [email protected] Councilmember Kevin McKeown [email protected] Councilmember Gleam Davis [email protected] Councilmember Sue Himmelrich [email protected] Councilmember Pam O'Connor pam.oconnor®smgov.net Councilmember Terry O'Day [email protected] City Manager - Rick Cole [email protected] City of Santa Monica 1685 Main St., Rm. 209 Santa Monica, CA 90401

Re: Violation of the California Voting Rights Act and Intentional Discrimination in the 1946 Adoption of At -Large Elections for the Santa Monica City Council

We write to you at the request of several Latino residents of the Pico Neighborhood of Santa Monica.

The City of Santa Monica ("Santa Monica") relies upon an at -large election system for electing candidates to its City Council. It also appears that voting within Santa Monica is racially polarized, resulting in minority vote dilution, and therefore Santa Monica's at - large elections are violative of the California Voting Rights Act of 2001 ("CVRA").

Moreover, Santa Monica's current at -large election system is the result of intentional discrimination against Santa Monica's minority residents in 1946. At that time, the at - large election system was adopted specifically to prevent the ethnic minority residents of September 2015 Page 2 of 4

Santa Monica, residing principally in the southern portion of Santa Monica, from achieving representation on the Santa Monica City Council.

Santa Monica's At -Large Elections Violate the CVRA

The CVRA states in relevant part:

14027. An at -large method of election may not be imposed or applied in a manner that impairs the ability of a protected class to electcandidates of its choice or its ability to influence the outcome of an election, as a result of the dilution or the abridgment of the rights of voters who are members of a protected class, as defined pursuant to Section 14026.

14028. (a) A violation of Section 14027 is established if it is shown that racially polarized voting occurs in elections for members of the governing body of the political subdivision or in elections incorporating other electoral choices by the voters of the political subdivision....

While Santa Monica is a charter city, and charter cities are granted certain autonomy over the manner and method of their elections, it is now well settled that the CVRA preempts any conflicting charter provision regarding at -large elections. Specifically, in a case that the undersigned counsel successfully argued, the Court of Appeals found that the CVRA is equally applicable to charter cities, and controls over conflicting charter provisions, because it is narrowly tailored to addressing matters of statewide concern - the right to vote, equal protection, and the integrity of the electoral process.Jauregui v. City of Palmdale (2014) 226 Cal. App. 4th 781, 798-804, review denied en banc (Aug. 20, 2014).

Based on our analysis, Santa Monica's at -large system dilutes the ability of minority residents - particularly Latinos (a "protected class") - to elect candidates of their choice or otherwise influence the outcome of Santa Monica's council elections.

The key to determining whether an at -large election violates the CVRA, is determining whether there is racially polarized voting. See Cal. Elec. Code §14028 ("A violation of Section 14027 is established if it is shown that racially polarized voting occurs in elections ..." Racially polarized voting is "voting in which there is a difference...in the choice of candidates or other electoral choices that are preferred by voters in a protected class, and in the choice of candidates and electoral choices that are preferred by voters in the rest of the electorate." Id. § 14026(e). Racially polarized voting shall be determined from examining results of elections in which "one candidate is a member of a protected class or elections involving ballot measures, or other electoral choices that affect the rights and privileges of a protected class." Id. § 14208(b).

Our research shows that in the history of the Santa Monica city council, spanning more than a hundred years, only one Latino has ever been elected to the city council, and there September 2015 Page 3 of 4

has never been a Latino resident of the Pico Neighborhood, where Latinos are concentrated, elected to the Santa Monica city council. Latino residents of the Pico Neighborhood have run in several recent elections for the Santa Monica city council, and though they have been preferred by both voters in the Pico Neighborhood and by Latino voters generally, they have all lost due to the costly and discriminatory at -large system by which Santa Monica elects its city council.

Though not necessary to establish a violation of the CVRA, a history of discrimination, and the deleterious effects of that past discrimination on the protected class and its ability to elect candidates of its choice, are also relevant. Id. § 14208(e). Though Santa Monica is regarded by many to be one of the more progressive cities in the State, as explained more fully below, that was not true historically. Rather, Santa Monica has a disturbing history of racial discrimination that is masked by its more recent progressive image. In fact, whatever their intention, even recent decisions of the Santa Monica city council have had a deleterious impact on the Pico Neighborhood where Latinos are concentrated, for example the decisions to de -fund the Pico Youth and Family Center and to burden the Pico Neighborhood with the maintenance facility for the light rail that is planned to terminate near the much more affluent area around the 3rd St. Promenade. For Latinos residing in the Pico Neighborhood, the lack of representation, or prospect of representation, on the Santa Monica city council has led to the general neglect of their community. As revealed by documents recently released in connection with an employment case against Santa Monica, even employment decisions are made by the Santa Monica city council, and so not having appropriate representation on the city council has resulted in a lack of concern for the Latino community of the Pico Neighborhood from Santa Monica's administration as well as its city council.

As you may be aware, in 2012, we sued the City of Palmdale for violating the CVRA. After an eight -day trial, we prevailed. We then prevailed in successive appeals, and writ petitions, and the trial court's judgment was affirmed in June 2015. After spending millions of dollars, district -based elections are now ultimately being imposed upon the Palmdale city council, with districts that combine all incumbents into one of the four districts. Moreover, in addition to the estimated $2.5 million paid by the City of Palmdale to its attorneys, the City of Palmdale was required to pay us more than $4.6 million for our efforts.

Given the historical lack of Latino representation, and particularly from the Pico neigborhood, on the city council in the context of racially polarized elections, we urge Santa Monica to voluntarily change its at -large system of electing council members. Otherwise, on behalf of residents within the jurisdiction, we will be forced to seek judicial relief.

Santa Monica's At -Large Elections Are the Result of Intentional Discrimination in 1946

Even if Santa Monica's at -large election system could withstand a challenge based on the September 2015 Page 4 of 4

CVRA (it cannot), it would still fall as it was adopted with the purpose of discriminating against Santa Monica's ethnic minority population residing in the southern portion of the city. That fact alone - that the 1946 adoption of at -large elections was generally motivated by a desire to disenfranchise ethnic minorities - makes the at -large election system unconstitutional today. See, e.g., Hunter v. Underwood, 471 US 222 (1985) (invalidating a suffrage provision of the 1901 Alabama Constitution Convention even though it was adopted 84 years earlier).

This should come as no surprise to Santa Monica. In 1992, the Santa Monica city attorney retained renowned discrimination expert, Dr. J. Morgan Kousser, to evaluate whether the at -large election system was adopted with a discriminatory intent. Dr. Kousser investigated the matter, and prepared a detailed report, concluding that the 1946 adoption of at -large elections for the city council was likely motivated by a desire to keep ethnic minorities, concentrated in the southern portion of the city, from achieving electoral success and gaining representation on Santa Monica's city council. A copy of Dr. Kousser's report is attached for your convenience.

Despite Dr. Kousser's conclusions, solicited by the Santa Monica city attorney, Santa Monica has not taken the necessary actions to correct this historic wrong. Rather, the at - large election system has accomplished exactly what it was intended to do - disenfranchise the minority residents living in the less -wealthy neighborhoods in the southern portion of Santa Monica, namely the Pico Neighborhood. While district -based elections would ensure that the Latino residents of the Pico Neighborhood enjoyed fair and equal representation in their local government, Santa Monica's current at -large system has prevented residents of the Pico Neighborhood from being elected to the city council, despite strong support from Latinos and the Pico Neighborhood.

Please advise us no later than January 11, 2016 as to whether you would like to discuss a voluntary change to your current at -large system.

We look forward to your response.

Very truly yours,

Raeuew T. Sdeokoget* EXHIBIT D AGENDAS

CITY OF SANTA MONICA

REGULAR AND SPECIAL JOINT MEETING

Clyor CITY HALL COUNCIL CHAMBERS Santa Monica"' 1685 MAIN STREET, ROOM 213

TUESDAY JANUARY 12, 2016

MEETING BEGINS AT 5:30 PM

CALL TO ORDER PLEDGE OF ALLEGIANCE ROLL CALL

(Please note that Agenda Items may be reordered during the Council meeting at the discretion of the City Council.)

1. CLOSED SESSIONS

1.A. Conference with Legal Counsel - Anticipated Litigation: Anticipate significant exposure to litigation pursuant to Government Code Section 54956.9 (d)(2) - 2 cases - 1) Part 16 re leasing policy, landing fees and loans 2) Voting Rights Act

1.B. Conference with Legal Counsel - Potential Litigation: Consideration of whether to initiate litigation pursuant to Government Code Section 54956.9 (d)(4) - 1605 Ocean Front Walk

1.C. Public Employee Evaluation: Title of Employee: City Manager

1.D. Conference with Legal Counsel - Existing Litigation - Litigation has been initiated formally pursuant to Government Code Section 54956.9 (d)(1): National Business Aircraft Association, et al. v. City of Santa Monica, FAA Docket No. 16-14-04

1.E. Conference with Legal Counsel - Existing Litigation - Litigation has been initiated formally pursuant to Government Code Section 54956.9 (d)(1): Mahgerefteh v. City of Santa Monica, Los Angeles Superior Court Case Number BC 541 384

The following is the order of business for items to be heard no earlier than 6:30 p.m.

2. SPECIAL AGENDA ITEMS

City of Santa Monica Generated: 1/26/2016 3:34 PM Page 3 EXHIBIT E April 18. 2016

fuWhom It May Concern:

It is with great trepidation that I lime decided to resign from the Malibu 1. Indication Negotiation Committee. For sacral years. I have worked tirelessly on two causes about which I care deeply: 1) noting rights: and 2) local control for Malibu schools. Now. due to retaliation !Or my pursuit of toting rights for the Latino community of Santa Monica. I am litrced to step away from my role in pursuit of a separate Malibu school district.

Last week. after reeei% Mg no response from the City of Santa Monica !Or !bur months. my law first. along with three others. filed a lawsuit on behalf of Latino voters against the City lOr % iolating the CalilOrnia Voting Rights Act, just as we have successfully done against the cities of Palmdale. Highland. Garden (irove and Fullerton. In addition to iolating the CatilOrnia Voting Rights Act. Santa Monica's at -large election sy stein is also unlawful because it was intended to prevent minority communities from electing candidates of their choice a fact that was reported to the City by its own consultant more than 20 years ago.

;milli': to defend its election system in a court of law. the City of Santa Monica instead sought to retaliate against me in an unrelated matterthe Santa Monica negotiators on the Malibu llnification Negotiation Committee were instructed to walk away from the important work of that Committee in response to our lawsuit.they took that action even though the %oting rights of Latinos in city council elections have absolutely nothing to do with the financial terms of splitting the Santa Monica -Malibu l'nilied School District.

Retaliation for our pursuit of minority \ ming rights is nothing new for us. In the course of our successful CalifOrnia Voting Rights Act case against the ('its of Palmdale. for example. my family and I endured death threats. our phones were tapped. and my co - counsel. Rex Parris. who happens to be the Mayor of Lancaster. is still facing political retribution from those who purported to be his friends. None of that deterred us from winning Palmdale's African American and Latino residents their voting rights: it only served to strengthen our resoke. likewise. the retaliation we have so far endured from the City of Santa Monica only proves to us why our case is needed.

I ha% c tOund that the best way to deal with this sort of retaliation is to eliminate the potential lig desperate opponents to retaliate. Here. that means stepping down from my role on the Malibu Unilication Negotiation Committee.

While I believe that I am uniquely qualified to serve on that committee, as demonstrated by my successes in bringing the Santa Monica team to the negotiation table. and negotiating the sensitive agreement go%crning the pay meat of consultants. the retaliatory actions by the Santa Monica negotiators have caused my in% olvement to become a distraction to the real issues that the Committee is charged with resolving. April 18.2016 Page 2 of 2

I hope that %%hoc\ er replaces me on the Committee ill bring the same passion for creating a separate Malibu school district that respects all of its distinct communities. protecting the interests of those most in need, and putting an end to the indilThrenee about poisoning our children +ith PCBs. among other things. Santa Monica and Malibu are both. respectivel). among the \%ealthiest communities in the +orld. With those resources. our schools should he. and could he. so much better than the are. for all of our students.

Sincere!).

KEVIN SHENKMAN. Father of 4 daughters in SMMUSD EXHIBIT F 1 CITY OF SANTA MONICA LANE DILG, SBN 277220 2 City Attorney [email protected] 3 SUSAN COLA, SBN 178360 Deputy City Attorney 4 [email protected] 1685 Main Street, Room 310 5 Santa Monica, CA 90401 Telephone: 310.458-8336 6 GIBSON, DUNN & CRUTCHER LLP 7 THEODORE J. BOUTROUS JR., SBN 132099 [email protected] 8 MARCELLUS MCRAE, SBN 140308 [email protected] 9 WILLIAM E. THOMSON, SBN 187912 [email protected] 10 KAHN SCOLNICK, SBN 228686 [email protected] 11 TIAUNIA HENRY, SBN 254323 333 South Grand Avenue 12 Los Angeles, CA 90071-3197 Telephone: 213.229.7000 13 Facsimile: 213.229.7520

14 Attorneys for Defendant CITY OF SANTA MONICA 15 SUPERIOR COURT OF THE STATE OF CALIFORNIA 16 FOR THE COUNTY OF LOS ANGELES 17 PICO NEIGHBORHOOD ASSOCIATION CASE NO. BC 616804 (filed Apr. 12, 2016) 18 and MARIA LOYA, CITY OF SANTA MONICA'S OPPOSITION 19 Plaintiffs, TO PLAINTIFFS' MOTION TO COMPEL SUBSEQUENT DEPOSITIONS OF TERRY 20 v. O'DAY AND GLEAM DAVIS

21 CITY OF SANTA MONICA and DOES 1- HON. YVETTE M. PALAZUELOS, DEP'T 28 100, Discovery Referee: HON. LUIS A. CARDENAS 22 Defendants. Action Filed:April 12, 2016 23 Trial Date: July 30, 2018

24 Hearing Date:January 22, 2018 at 11:00 a.m.

25

26

27

28

Gibson, Dunn & CITY OF SANTA MONICA'S OPPOSITION TO PLAINTIFFS' MOTION TO COMPEL SUBSEQUENT DEPOSI- Clincher LIP TIONS OF TERRY O'DAY AND GLEAM DAVIS 1 political action committees-all of which is publicly available information-and Mr. O'Day's opin-

2 ion on whether the campaign contribution laws are fair. (O'Day Depo. at 56:6-20, 156:11-157:9.)

3 Additionally, Plaintiffs' counsel used the deposition to attempt to pressure Mr. O'Day to settle the

4 case by referring to the expense of litigation and purporting to identify other cities that have lost

5 CVRA cases. (O'Day Depo. at 113:5-17.) Plaintiffs' counsel also pursued an improper line of ques-

6 tioning concerning the presence or absence of methane gas in Gandara Park (formerly Stewart Park).

7 (O'Day Depo. at 104:7-105:21; 107:19-25.) Having asked all their questions, Plaintiffs ended the

8 deposition without reserving time or the right to recall Mr. O'Day. (O'Day Depo. at 164:11-13.)

9 Similarly, Ms. Davis appeared for her deposition in Lancaster, California, on October 6, 2016,

10 made herself available for a full seven -hour deposition, and duly answered Plaintiffs' counsel's ques-

11 tions for the full amount of time Plaintiffs' counsel desired to depose her. As with Mr. O'Day, Plain-

12 tiffs' counsel spent a significant amount of the deposition asking Ms. Davis about tangential topics

13 like the presence or absence of methane gas in Gandara Park (formerly Stewart Park) (Gleam Davis

14 Depo. at 20:1-21:23) and they again broached the improper topic of settlement to avoid incurring ad-

15 ditional defense costs (Gleam Davis Depo. at 102:4-103:10). Upon stating, "I don't have any more

16 questions," Plaintiffs' counsel concluded Ms. Davis' deposition without reserving time or the right to

17 recall Ms. Davis. (Davis Depo. at 130:18-20.)

18 Meanwhile, while Plaintiffs were actively pursuing discovery from the City, they have contin-

19 ued to refuse to provide substantive responses to the City's discovery requests. Since October

20 2016shortly after Mr. O'Day and Ms. Davis were deposed-the City has been diligently working

21 to obtain proper responses to its written discovery propounded on Plaintiffs on August 9, 2016. Due

22 to Plaintiffs' assertion of baseless and improper objections and refusal to produce responsive docu-

23 ments, subsequent delay in providing supplemental responses and a document production, and refusal

24 to provide second supplemental responses to the City's written discovery absent a court order, Judge

25 Palazuelos continued the trial date to July 30, 2018.

26 In August 2017, the FPPC issued a Stipulation, Decision, and Order, fining the Huntley Hotel

27 for illegal campaign contributions to various candidates and committees in Santa Monica's 2012 and

28

3 Gibson, Dunn & CITY OF SANTA MONICA'S OPPOSITION TO PLAINTIFFS' MOTION TO COMPEL SUBSEQUENT DEPOSI- Crutches LLP TIONS OF TERRY O'DAY AND GLEAM DAVIS EXHIBIT G In Rare California Voting Rights Trial, Gibson Dunn Steps Up for Santa Monica Said Gibson Dunn's Kahn Scolnick: "The reality is that if Santa Monica fails the CVRA test, then no city could pass, because Santa Monica is doing really well in terms of full representation and success of minority candidates."

By Ross Todd August 01, 2018 at 09:20 AM

1 'Rift&stielt-11110.11r,II ^ %al °NC I tilt _II 41

Santa Monica, California. (Photo: oneinchpunch/Shutterstock.coin)

At the Stanley Mosk Courthouse in Los Angeles Wednesday, proceedings are set to get underway in a rare California Voting Rights Act case to make it all the way to trial. The 2001 law, designed with an eye toward making it easier for voters to challenge local voting procedures that dilute the voting power of minorities, has come under fire of late from critics who claim the law does more to line the pockets of plaintiffs lawyers than it does to boost the prospects of minority political candidates. Count the team at Gibson, Dunn & Crutcher, which represents the city of Santa Monica in a CVRA lawsuit, among those critics. The firm has signed on to represent the city in a lawsuit which claims that its citywide election system, instituted in 1946, was designed to prevent Latino voters from picking the candidates of their choice. The trial is set to play out in Superior Court Judge Yvette M. Palazuelos' courtroom over the next four to six weeks.

The Recorder spoke with Gibson Dunn partners Ted Boutrous and Kahn Scolnick, two members of Santa Monica's defense team. The following has been edited for length and clarity.

How did this case come to you?

Boutrous: It's really interesting. This statute, the California Voting Rights Act of 2001, has not really been litigated much. It was enacted to make it easier for plaintiffs to succeed on a claim that at -large elections dilute minority voting power and it has a very good purpose to it. But starting about eight or nine years ago, it started to become more of a plaintiffs lawyer fee -generating machine rather than a statute that's actually making elections fair. And this same group of plaintiffs lawyers has been sending letters to cities and school districts making these demands. And the statute has a fee -shifting provision that also allows attorney fees plus experts' fees.

Most of the governmental units, rather than face expensive litigation and potential fees, have just been changing their system. Santa Monica strongly believes in a fair voting system and at the same time believes its system is fair and complies with the law. It decided that it's going to fight this because it believes that it's in the right. The city interviewed a number of law firms and we sat down with them and they chose us to represent them. It's great in the sense that they strongly believe in the purpose of the statute and here it's being misused.

Scolnick: Only a couple have gone to trial. Even in one that was disputed, it wasn't about liability. It was about a remedy. So, they're almost never decided on the merits. It's so costly and time-consuming. You need experts. So, how will you attempt to make the case that at -large voting isn't dilutive on minority voting in Santa Monica-or is the burden on plaintiffs to show that it actually is?

Scolnick: The burden is on the plaintiffs to show that it actually is. But we can actually show, and I believe it is undisputed, that there is no vote dilution. And the way we do that is because of the demographics in Santa Monica.

The Latino population is pretty small in the city. It's only about 13 percent of the citizen, voting age population of the city and it's dispersed throughout the city. The Voting Rights Act claims were meant for these areas in the South where there are these large minority populations that aren't able to elect a candidate even if you had districts where they would be a majority of the district. That's just not what Santa Monica looks like.

Both sides agree, the best you could possibly do, even if you ignore all the constitutional requirements about how you draw a district, is around a 30 percent district. That basic, demographic fact shows that they're not going to do any better in a district. In fact, they would do worse. They wouldn't have the ability to elect the candidate of their choice in their district. And then two-thirds of the city's Latinos would be living outside that district. In other words, you'd be splintering and in the language of the Voting Rights Act, you'd be "cracking and packing" Latinos, diluting their voting power by putting them in districts. Whereas now, where everyone gets to vote three or four candidates every election, Latinos have consistently been able to elect their candidates.

Who are you up against on the plaintiffs' side?

Scolnick: Kevin Shenkmen [of Malibu's Shenkman & Hughes]. is certainly the front man. There's a team of law firms. It started right after the law was enacted in 2001. The person who drafted it was the original lawyers, Joaquin Avila, who is longtime civil rights lawyers in California.

We represented several plaintiffs suing under the California Voting Rights Act early on and so, as Ted mentioned, it was 10 years ago or so that it went from this good -purposed and well-intentioned statute. Kevin Shenkmen and Robert Paris, who has his own personal injury shop in Lancaster, they somehow got affiliated with the group of civil rights lawyer [including Robert Rubin] and they began driving the train and littering the state up and down with demand letters and warning letters-dozens and dozens of cities and municipalities and school boards across the state of California.

Our big point is that it's doing so without being litigated and doing so without any proof that you're actually helping.I think the L.A. Times reported that as a result of all these changes in district elections, there hasn't really been any increase in minority representation.

Boutrous: The other thing you see is they send these letters out, they go into these municipalities without doing any real study about whether the provisions of the statute would require some change. It's a little like we've seen before in California with some of the environmental regulations or public accommodations where it becomes a cottage industry that's separate from the purpose of the statute. It's high irony that Santa Monica is the target of this lawsuit. It's a great client to work with both in terms of the results of their elections-if you go outside the city council, again it's very diverse.

Scolnick: The school board, the college board, the rent control board...it's super -representative. Latino candidates do better than white candidates on those boards. Look it's Santa Monica, it prides itself on inclusiveness and diversity, which is part of the reason why it's fighting this suit. It believes it's doing the right thing. The voters in Santa Monica have twice rejected district elections. It's a small city geographically. So they think that dividing the city up is going to result in balkanization and horse trading and everybody looking out for themselves and not really looking out for the city. If you hear the city council members tell it, they strongly believe that they represent everyone in the city.

So, what's the trial going to look like?

Boutrous: If the issues that are relevant to the statute are focused on, it should be experts talking about the composition of the citizenry and the results of elections. But I believe the reason it's projected to be so long is because the plaintiffs want to put on all this extraneous information about the elected officials.

Scolnick: That's right. Normally in these cases is that you have a demographer and you have a political scientist and they can put in statistical evidence about how Latinos and others voted. I think the strategy on the other side is to make this a referendum on every racist thing that's happened in California since 1800, and I'm not even exaggerating. I think the link that's missing in the plaintiffs' case is that all these things that have happened in California that are bad really have nothing to do with at -large elections. The evidentiary scope is going to be pretty broad. We're going to talk about methane gas in city parks. We're going to talk about after -school programs. We're going to talk about all these things with no real connection to the trial.

Boutrous: That's the plaintiffs' strategy to just go back and focus on problems in California that were really problems around the country. But that really doesn't have anything to do with the issues that were presented by the case. We feel really good about our case on the merits here. It will be very interesting to see their approach. They're disconnected from the purpose of the statute and we're going to try to show that. The judge isI think going to give them wide latitude. It should be interesting.

Hopefully, we can clarify what the law actually means. I think that's one of the reasons Santa Monica feels it would be a benefit to everyone to have some clarity on what the law actually means. Plaintiffs have taken the position that there's basically strict liability-that if they can come in and say there's racially polarized voting without showing (1) that districts could solve a problem, or (2) without showing that there's been any harm or effect that's actually legally redressable. We think that's just wrong.

Scolnick: The reality is that if Santa Monica fails the CVRA test, then no city could pass, because Santa Monica is doing really well in terms of full representation and success of minority candidates. That's why I think this case is so important. Who is on the trial team?

Boutrous: Marcellus McRae, who tried the Vergara case with me is the lead trial lawyer, and Michelle Maryott, who tried the Grubhub case with me, will have a

significant role. I will have a role at trial, but since there are important constitutional issues involved, I'm also involved in more on the broader strategy. Kahn and senior associate Tiaunia Henry will also be part of the team. EXHIBIT H NEWS LOCAL NEWS More Novato agencies move to district elections

Water comes up to the bottom of a pedestrian bridge at Stafford Lake in Novato earlier this month. (Alan Dep/Marin Independent Journal)

By WILL HOUSTON I [email protected] PUBLISHED: April 26, 2019 at 2:02 pm I UPDATED: April 26. 2019 at 6:12 pm The specter of a voting rights lawsuit has kicked off a wave of Novato government agencies transitioning to district -based elections.

The North Marin Water District was the latest Novato government body to begin the switch from at -large to by -district elections this week. On Wednesday, the Novato Fire Protection District board is set to consider whether it too wants to make the switch.

"Essentially, we feel that the public interest is better served by our board to consider a proposal to transition to a district -based election system," Novato fire Chief Bill Tyler said Friday.

Earlier this month, the Novato Sanitary District Board of Directors also voted to begin the same process. Preceding them was the Novato Unified School District and the Novato City Council.

"Now that there are three local agencies that are ahead of us we're hoping we can have some implementation efficiencies and learning what they have been having to go through and try to have some common messaging out to our customers," said Drew McIntyre, the water district's general manager.

Each agency has a tight deadline of 90 days to draw and adopt its own district maps. This series of election overhauls stems from a letter sent to the Novato City Council in February by Malibu attorney Kevin Shenkman, who demanded the city switch to district elections or face a lawsuit. Reached Friday, Shenkman said he's generally pleased that his letter has had such a widespread effect.

"That's been the case statewide in a more general sense," he said. "Locally in and around Novato, it's good to see political subdivisions taking proactive steps rather than waiting for someone to allege a violation."

The city's at -large elections, Shenkman argues, violate the California Voting Rights Act by diluting the voting power of protected classes of voters, such as Latinos.

"The California Voting Rights Act has been the law since Jan. 1, 2003 and I'm glad to see that jurisdictions are finally getting around to bringing their elections into compliance," Shenkman said.

While Novato agencies have chosen to comply, they don't all agree with Shenkman's claims.

"We don't believe that our current at -large elections are not compliant with the California Voting Rights Act," McIntyre said, but added that "any attempt to defend against a demand letter would be costly with little chance of success."

Still, others such as the sanitary district say the change falls in line with their values.

"The district has a commitment to diversity and inclusion," said Sandeep Karkal, sanitary district general manager and chief engineer.

The financial risk of not complying with Shenkman's demands has proven to be high for other cities. Those cities that have resisted Shenkman's demands in recent years have found themselves on the losing end and paying multi -million - dollar settlements. By going along with Shenkman's demands, the city of Novato is set to limit its payout to Shenkman to $30,000.

For the sanitary and water districts, choosing to proactively make the switch helps them avoid the $30,000 payment altogether. The process will still come at a cost, though. The North Marin Water District anticipates paying about $75,000 to hoici a series of public meetings arid for its hired demographer.

While sharing resources would have been helpful, Tyler said it would be difficult to do so given that each agency has its own jurisdictional boundaries. "Unfortunately it wasn't something we could all do together," Tyler said.

Tags:district elections,election,elections,newsletter, NMWD, North Marin Water District

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Years Out of Law School *

Paralegal/ Adjustmt Law Year Factor** Clerk 1-3 4-7 8-10 11-19 20 +

6/01/18- 5/31/19 1.0350 $202 $371 $455 $658 $742 $894

6/01/17- 5/31/18 1.0463 $196 $359 $440 $636 $717 $864

6/01/16- 5/31/17 1.0369 $187 $343 $421 $608 $685 $826

6/01/15- 5/31/16 1.0089 $180 $331 $406 $586 $661 $796

6/01/14- 5/31/15 1.0235 $179 $328 $402 $581 $655 $789

6/01/13- 5/31/14 1.0244 $175 $320 $393 $567 $640 $771

6/01/12-5/31/13 1.0258 $170 $312 $383 $554 $625 $753 Owl 6/01/11-5/31/12 1.0352 $166 $305 $374 $540 $609 $734 6/01/10- 5/31/11 1.0337 $161 $294 $361 $522 $589 $709

6/01/09- 5/31/10 1.0220 $155 $285 $349 $505 $569 $686

6/01/08- 5/31/09 1.0399 $152 $279 $342 $494 $557 $671

6/01/07-5/31/08 1.0516 $146 $268 $329 $475 $536 $645

6/01/06-5/31/07 1.0256 $139 $255 $313 $452 $509 $614

6/1/05-5/31/06 1.0427 $136 $249 $305 $441 $497 $598

6/1/04-5/31/05 1.0455 $130 $239 $293 $423 $476 $574

6/1/03-6/1/04 1.0507 $124 $228 $280 $405 $456 $549

6/1/02-5/31/03 1.0727 $118 $217 $267 $385 $434' $522

6/1/01-5/31/02 1.0407 $110 $203 $249 $359 $404 $487

6/1/00-5/31/01 1.0529 $106 $195 $239 $345 $388 $468

6/1/99-5/31/00 1.0491 $101 $185 $227 $328 $369 $444

6/1/98-5/31/99 1.0439 $96 $176 $216 $312 $352 $424

6/1/97-5/31/98 1.0419 $92 $169 $207 $299 $337 $406

6/1/96-5/31/97 1.0396 $88 $162 $198 $287 $323 $389

6/1/95-5/31/96 1.032 $85 $155 $191 $276 $311 $375

6/1/94-5/31/95 1.0237 $82 $151 $185 $267 $301 $363 EXHIBIT J Case 2:07-cv-00380-PA-FFM Document 311-3Filed 09/18/17 Page 208 of 347 Page ID #:5204 '61 ) I "t:itAit 1 GIBSON, DUNN & CRUTCHER LLP Wayne Barsky (SBN 116731) 2 Marcellus A. McRae (SBN 140308) Meghan Blanco (SBN 238171) 3 Michael Anthony Brown (SBN 243848) FILED Carol A. Fabrizio (SBN 258187) LOS ANGELES SUPERIOR COURT 4 Kristy S. Grant (SBN 260016) 333 South Grand Avenue 5 Los Angeles, California 9007]-3197 APR 0 g 2009 Tel: (213) 229-7000 Fax: (213) 229-6604 6 [email protected] [email protected] JOHN1CLAAK , CLERK 7 [email protected] [email protected] BY JA TAYLOR, DEPUTY 8 Attorneys for PLAINTIFFS Esperanza Rogel, 9 Gerardo Espinoza, Oscar Leon, Marcos Martinez, Jaime Torres, and California ACORN, Los 10 Angeles Chapter

11 Additional counsel listed on following page.

12 SUPERIOR COURT OF THE STATE OF CALIFORNIA

13 COUNTY OF LOS ANGELES - CENTRAL DISTRICT 14

15 ESPERANZA ROGEL, et al., )Case No. BS106592 ) 16 PLAINTIFFS, ) DECLARATION OF WAYNE BARSKY IN ) SUPPORT OF PLAINTIFFS' MOTION FOR 17 v. ) ORDER AWARDING ATTORNEYS' FEES

18 ) REDEVELOPMENT AGENCY OF THE CITY)Hearing Date: May 1, 2009 19 OF LYNWOOD, )Hearing Time: 9:00 a.m. )Hearing Place: Dept: 20 20 Defendant )Judge: Hon. Kevin C. Brazile ) 21 )(Filed Concurrently: Plaintiffs' Motion for Award of Attorneys Fees; Memorandum of 22 ) )Points and Authorities in Support thereof; 23 )Supporting Declarations of Wayne Barsky, )Marcellus McRae, Meghan Blanco, Michael A. 24 )Brown, Kristy S. Grant, Carol A. Fabrizio, Rebecca F. Thornton, Carol A. Sobel, Theresa 25 Traber, Shashi Hanuman, Michael Rawson, 26 Deborah Collins, Craig Castellanet, Karen R. Growdon, and Cynthia Merrill) 27 Complaint Filed: December 21, 2006 28

Glascri, Durri Calk:hen-1LP DECLARATION OF WAYNE BARSKY IN SUPPORT OF PLAINTIFFS' MOTION FOR ORDER AWARDING ATTORNEYS' FEES Case 2:07-cv-00380-PA-FFM Document 311-3Filed 09/18/17 Page 223 of 347 Page ID #:5219

1 certain time entries that were mis-entered into our computer system, and which should have been

2 charged to other clients; these time entries were removed entirely from the attached billing records.

3 21. As of March 18, 2009, Gibson Dunn incurred $1,304,645.50 in legal fees and

4 $38,810.34 in costs and out-of-pocket expenses in connection with its prosecution of Plaintiffs'

5 action. At my direction, however, we have excluded from our lodestar figure numerous attorney

6 (and non -attorney) hours and costs incurred in an effort to seek recovery only for non -duplicative and

7 particularly relevant work. Toward that end, we have: (a) deducted all time, regardless of task, of

8 attorneys who worked less than 10 total hours on the case; (b) deducted numerous hours for drafts of

9 discovery that were not ultimately used; (c) reduced or eliminated attorneys' time entries for

10 depositions and hearings where more than one attorney was present; (d) reduced all time charge for

11 reviewing and summarizing deposition transcripts; and, (e) reduced time charged for an attorney's

12 general background work when the time invested in activities were disproportionate to the time spent

13 substantively working on the case.

14 22. As noted in Plaintiffs' Motion for Award of Attorneys Fees, 1 calculated the Fees

15 Charged using the firm's actual 2009 rates. The following charts detail the 2009 rates of each Gibson

16 Dunn attorney who worked on this matter, the total charges actually incurred by those attorneys on

17 this matter through March 17, 2009, and the total amount the firm has included in its lodestar figure.

18 Total Attorney Fees Actually Incurred & Charged

o< .1" 19 ex 4 -:,.. tk -." 4 , 1- C 1 -----,,,, _s 1 -14, _41 ,15,--- l'' l' 4 1.0,0- ,),, .:. ' 20 Vr 44 c4,,,,.,..es Y ' 4'' .4. '4"uaF-%t -,F. 4, If.1: , Wayne M. 13arsky $905 76.75 $69,458.75 75.15 $68,010.75 21 Partner, JD 1983 22 Marcellus A. McRae $785 339.90 $266,821.50 338.7 $265,879.50 23 t Partner, JD 1988

24 Daniel M. Kolkey $840 0.3 $252 0.3 $0 Partner, JD 1977 25 Danielle A. Katzir $525 0.4 $210 0 $0 26 Associate, .1D 2004 27 Michael Anthony $495 746.9 $369,715.50 738.77 $365,691.15 28 Brown

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IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE

In re: Chapter 11

BROOKSTONE HOLDINGS CORP., et al.,'Case No. 18-11780 (BLS)

Debtors. JointlyAdministered

Ref. Docket No. 1127

SUPPLEMENT TO SECOND INTERIM FEE APPLICATION OF GIBSON, DUNN & CRUTCHER LLP

Gibson, Dunn & Crutcher LLP ("Gibson Dunn" or the "Firm"), counsel to Brookstone

Holdings Corp. and its affiliated debtors and debtors -in -possession in the above -captioned chapter 11 cases (collectively, the "Debtors"), hereby supplements the Second Interim Fee

Application of Gibson, Dunn & Crutcher LLP [Docket No. 1127 (the "Second Interim

Application") for the period from November 1, 2018 through January 31, 2019 (the "Application

Period") by attaching, as Exhibits A through E hereto, certain schedules requested by the Appendix

B Guidelines for Reviewing Applications for Compensation and Reimbursement of Expenses Filed

Under United States Code by Attorneys in Larger Chapter 11 Cases (the "UST Guidelines"). In addition, Gibson Dunn respectfully states as follows to address the questions set forth under section

C.5 of the UST Guidelines:

UST Guidelines C.5(b): Did you agree to any variation from, or alternatives to, your standard

or customary billing rates, fees or terms for services pertaining to

1 The Debtors, along with the last four digits of each Debtor's tax identification number, are: Brookstone Holdings Corp. (4638), Brookstone, Inc. (2895), Brookstone Company, Inc. (3478), Brookstone Retail Puerto Rico, Inc. (5552), Brookstone International Holdings, Inc. (8382), Brookstone Purchasing, Inc. (2514), Brookstone Stores, Inc. (2513), Big Blue Audio LLC (N/A), Brookstone Holdings, Inc. (2515), and Brookstone Properties, Inc. (2517). The Debtors' corporate headquarters and the mailing address for each Debtor is One Innovation Way, Merrimack, NH 03054.

103207145.1 Case 18 -11780 -BLS Doc 1129 Filed 03/18/19 Page 6 of 20

Gibson Dunn's hourly rates for bankruptcy services are comparable to the hourly rates charged in complex chapter 11 cases by comparably skilled bankruptcy attorneys. In addition, Gibson Dunn's hourly rates for bankruptcy services are comparable to the rates charged by Gibson Dunn, and by comparably skilled practitioners in other firms, for complex corporate and litigation matters, whether in court or otherwise, regardless of whether a fee application is required. By way of example, Gibson Dunn's blended hourly rates for attorneys and paraprofessionals for all Bankruptcy and Corporate Restructuring matters of Gibson Dunn for the prior calendar year were as set forth below. Gibson Dunn believes that the services performed for the Debtors are comparable to the services performed by the firm for all Bankruptcy and Corporate Restructuring matters during the prior calendar year. Also included below is blended hourly rate information for all sections of Gibson Dunn for which Gibson Dunn represented a client in a matter other than an in -court bankruptcy proceeding during the prior calendar year.'

Category of Blended Hourly Rate Timekeeper Billed Billed Billed Firm -wide non- Firm -wide This Application bankruptcy and bankruptcy and November 1, 2018 restructuring practicerestructuring matters through areas for preceding for preceding January 31, 2019 ($) calendar year2 ($) calendar year3 ($)

Partner 1,117 1,071 1021 Counsel 870 896 935 Associate 710 685 805 Paralegal 399 427 429 Aggregated: 820 835 896

While Gibson Dunn used reasonable efforts to separate Bankruptcy and Restructuring matters from other practice group matters, it is possible that there is some overlap between these practice groups and the billings reported herein. 2 This column reflects the blended rates charged by the firm for all matters excluding Bankruptcy and Corporate restructuring matters during the prior calendar year. 3 This column reflects the blended rates charge by the firm for all Bankruptcy and Corporate Restructuring matters during the prior calendar year.

2 103207145.1 Case 18 -11780 -BLS Doc 1129 Filed 03/18/19 Page 8 of 20

Total Billed 2018 2019 Hours for FeesBilled in , Hourly Hourly this the Date of Billing Billing Application Application. Title Depa issioilipRate (8) Rate (8) Period Period (SIM i Karlan,Mitchell Partner Litigation 1980 1415 1495 12.00 17,500.00 2. Feldman, David Partner Corporate 1994 1260 1345 2.20 2,772.00 3. Rosenauer, David Partner Tax 1993 1260 1345 10.60 13,356.00 4. Winter, Graham Partner Corporate 1990 1260 1345 0.60 756.00 s. Williams, Matt Partner Bankruptcy 1999 1215 1285 49.70 61,176.50 6. Collins, Michael Partner Litigation 2005 1205 1265 2.60 3,157.00 7. Hoffman, Matthew Partner Corporate 2003 1155 1195 3.50 4,042.50 s. Kelsey, Matthew K. Partner Bankruptcy 2004 1085 1115 133.20 145,419.00 9. Leroy, Carrie Partner Litigation 2000 1025 1075 4.20 4,305.00 io. Martorana, Keith Partner Bankruptcy 2008 935 1095 331.40 325,523.00 ii.Vojtisek, John -Paul Of CounselCorporate 2006 935 995 26.50 24,843.50 12. Fortney, Jonathan Associate Litigation 2010 925 975 24.50 23,447.50 13. Goldstein, Jason Associate Bankruptcy 2013 885 945 400.90 362,788.50 H.Weiner, Genevieve Associate Bankruptcy 2007 875 915 28.30 25,138.50 is.Riddick, Tarana Associate Litigation 2015 815 895 30.40 27,208.00 16. Bouslog, Matthew Associate Bankruptcy 2011 840 900 1.00 840.00 17. Solow, Ryan Associate Corporate 2011 840 900 0.30 252.00 18. Cassidy, Dylan S. Associate Corporate 2016 755 850 173.10 135,526.00 19. Park, Jean Associate Corporate 2014 720 815 3.00 2,160.00 20. Schmeltz, Brittany Associate Corporate 2016 595 695 2.30 1,368.50 21. Bernstein, Andrew Associate Corporate 2016 615 725 16.30 11,080.50 22. Hammond, Tyler A. Associate Corporate 545 625 85.00 48,373.00 23. Ogowewo, Imole Paralegal Corporate 495 515 0.50 247.50 24. Kann, Stephanie Paralegal Corporate 470 490 4.80 2,256.00 25. Amponsah, Duke Paralegal Bankruptcy 440 460 17.20 7,634.00 26. Santos, Pamela Paralegal Bankruptcy 420 435 61.30 26,049.00

103207145.1 Case 18 -11780 -BLS Doc 1129 Filed 03/18/19 Page 9 of 20

Total Billed 2018 2019 Hours for Fees Billed in Hourly Hourly this the Date of Billing Billing Application Application fiE. Name Title DepartmentAdmission Rate ($) Rate ($) Period Period ($) 27. Yang, Eric Paralegal Corporate 395 0.20 79.00

Total 1,425.60 I 1,277,298.50

*NY State Bar number pending; not currently licensed to practice in the State of New York.

2 103207145.1 Case 18 -11780 -BLS Doc 1129 Filed 03/18/19 Page 14 of 20

POSITION OF PROFESSIONAL; NUMBER OF YEARS IN THAT POSITION; PROFESSIONAL YEAR OBTAINING LICENSE TO PRACTICE, IF APPLICABLE

Karlan, Mitchell Partner since 1989.Joined the firm as an Associate in 1984. Member of the D.C. Bar since 2005; NY bar since 1980. Primary practice area: General Commercial Litigation Feldman, David Partner. Joined firm as a Partner in 2008. Member of NY Bar since 1994. Primarypracticearea:BusinessRestructuring& Reorganization Rosenauer, David Partner. Joined firm as an Associate in 1987. Member of NY Bar since 1993. Primary practice area: Tax Winter, Graham Partner. Joined firm as a Partner in 2011. Licensed to practice law in Hong Kong since 2016; United Kingdom since 1990. Primary practice area: Capital Markets; Mergers and Acquisitions; Private Equity; Securities Regulation and Corporate Governance Williams, Matt Partner. Joined the firm as a Partner in 2008. Member of NY Bar since 1999. Primarypracticearea:BusinessRestructuringand Reorganization Collins, Michael Partner since 2007. Joined firm as an Associate in 2000. Member of D.C. Bar since 2004. Primary practice area: Executive Compensation and Employee Benefits Hoffman, Matthew Partner since 2012. Joined Firm as an Associate in 2003. Member of CA Bar since 2003. Primary practice area: Insurance Kelsey, Matthew K. Partner since 2013. Joined Firm as an Of Counsel in 2008. Member of NY Bar since 2004. Primarypracticearea: BusinessRestructuring & Reorganization Leroy, Carrie Partner since 2018Joined Firm as a Partner in 2018. Member of CA Bar since 2000. Primary practice area: Intellectual Property Martorana, Keith Of Counsel.Joined the firm as an Associate in 2008. Member of the NY and NJ Bars since 2008. Vojtisek, John -Paul Of Counsel.Joined the firm as an Associate in 2005. Member of the NY Bar since 2006. Fortney, Jonathan Associate.Joined the Firm as an Associate in 2009. Member of NY Bar since 2010.

4 103207145.1 Case 18 -11780 -BLS Doc 1129 Filed 03/18/19 Page 15 of 20

POSITION OF PROFESSIONAL; PROFESSIONAL NUMBER OF YEARS IN THAT POSITION; YEAR OBTAINING LICENSE TO PRACTICE, IF APPLICABLE

Goldstein, Jason Associate. Joined the firm as an Associatein 2016. Member of the NY Bar since 2013. Weiner, Genevieve Associate. Joined the Firm as an Associate in 2007. Member of CA Bar since 2007. Riddick, Tarana Associate. Joined the Firm as an Associate in 2014. Member of NY Bar since 2015. Bouslog, Matthew Associate. Joined firm as an Associate in 2012. Member of CA Bar since 2011. Solow, Ryan Associate. Joined the firm as an Associate in 2015. Member of CA Bar since 2015; IL Bar since 2011. Cassidy, Dylan S. Associate. Joined the Firm as an Associate in 2015. Member of NY Bar since 2016. Park, Jean Associate. Joined the firm as an Associate in 2014. Member of CA Bar since 2014. Schmeltz, Brittany Associate. Joined the firm as an associate in 2016. Member of CA Bar since 2016. Bernstein, Andrew Associate. Joined the firm as an Associate in 2018. Member of NY Bar since 2018. Hammond, Tyler A.* Associate. Joined the Firm as an Associate in 2018. *NY State Bar number pending; not currently licensed to practice in the State of New York. Ogowewo, Imole Paralegal Kann, Stephanie Paralegal Amponsah, Duke Paralegal Santos, Pamela Paralegal Yang, Eric Paralegal

5 103207145.1 EXHIBIT L Client ID: Pico Neighborhood Assn, et al. Matter ID: City of Santa Monica 01-01-2015 - 02-13-2019 Attorney Time Detail Date Attorney Task Hours 6/25/15 KIS Discussion with C. Foster re: 0. de Ia Torre, Pico Youth Center, 3.4 and desire to bring district elections to Santa Monica; quick research regarding CVRA applicablility. 6/26/15 KIS Telephone conversation with 0. de la Torre; further research 4.9 issues raised by 0. de Ia Torre. 6/30/15 KIS Travel to/from and meet with 0. de Ia Torre and M. Loya 5.9 regarding potential case against City of Santa Monica under the California Voting Rights Act of 2001. 7/1/15 KIS Discuss potential case against Santa Monica with M. Kousser, 3.5 particularly M. Kousser's previous work for Santa Monica; review M. Kousser's report from 1992. 7/2/15 MRH Review both current and historic demographics of Santa 5.7 Monica; pull key data from US Census 7/3/15 MRH Review election history of Santa Monica; gather historical 7.4 election data from Los Angeles County Registrar 7/5/15 MRH Prepare memorandum comparing Santa Monica demographics 10.8 and voting patterns to benchmark political subdivisions, including summary spreadsheet of historical elections and demographics of Santa Monica. 7/6/15 MRH Continue work on memorandum comparing Santa Monica 6.3 demographics and voting patterns to benchmark political subdivisions, including summary spreadsheet of historical elections and demographics of Santa Monica. 7/7/15 MRH Travel to/from Caltech and meet with M. Kousser regarding 8.1 past work on Santa Monica and potential case against Santa Monica. 7/8/15 KIS Review summary memorandum on potential Santa Monica 4.0 case and meet with M. Hughes to discuss. 7/8/15 MRH Meeting with K. Shenkman regarding potential Santa Monica 2.0 case. 7/9/15 KIS Discuss intentional discrimination law and demographic 2.5 concentration with M. Hughes. 7/9/15 MRH Research regarding intentional discrimination and 9.1 neighborhood level demographics of Santa Monica, discuss same with K. Shenkman. 7/10/15 MRH Travel to/from Compass Demographics and meet with D. Ely 7.5 regarding potential case against Santa Monica. 7/13/15 MRH Travel to/from Caltech and meet with M. Kousser regarding 9.3 intentional discrimination and potential case against Santa Monica. 7/14/15 MRH Travel to/from Caltech and meet with M. Kousser regarding 6.8 potential Equal Protection case against Santa Monica, and interplay between CVRA and intentional discrimination case 7/20/15 MRH Research regarding intentional discrimination and issue of 7.3 federal question and potential for California Constitution claim. 7/21/15 MRH Research regarding intentional discrimination and available 5.9 legal avenues to address same. 7/22/15 MRH Research equal protection claims and drafting firm 9.0 memorandum. 7/23/15 MRH Research avenues of addressing intentional discrimination, 7.5 elements of applicable claims, and drafting firm memorandum. 7/24/15 MRH Draft firm memorandum regarding issues in potential CVRA 10.2 and Equal Protection case against Santa Monica; discuss same with K. Shenkman 7/24/15 KIS Review firm memorandum and discuss with M. Hughes 4.4 7/25/15 MRH Gather data and information regarding elections of Santa 7.7 Monica and statewide propositions; discuss with experts. 7/27/15 MRH Travel to/from and meet with D. Ely at Compass Demographics 7.5 to work on Santa Monica potential case and potential impact thereof. 7/27/15 JU Research regarding financial and health disparities in Santa 8.2 Monica, city council decisions, racial appeals in Santa Monica campaigns, discuss with K. Shenkman. 7/28/15 MRH Gather data and information on exogenous elections of Santa 7.0 Monica. 7/28/15 JU Research regarding comparative literacy rates and educational 9.4 outcomes in Santa Monica and historical decisions of Santa Monica city council relating to education, focusing on north - south divide and racial segregation in schools and effect of intradistrict and interdistrict transfers; discuss same with K. Shenkman 7/28/15 KIS Discuss education issues in Santa Monica with J. Jones. 1.5 7/29/15 MRH Travel to/from Caltech and meet with M. Kousser regarding 7.9 potential case against Santa Monica; compile initial ecological regression and ecological inference results 7/30/15 KIS Call with 0. de la Torre and M. Loya regarding progress and 0.7 potential case. 8/3/15 MRH Travel to/from Caltech and meet with M. Kousser regarding 6.5 potential case against Santa Monica 8/5/15 MRH Travel to/from Caltech and meet with M. Kousser regarding 7.1 potential case against Santa Monica 8/13/15 MRH Travel to/from Compass Demographics abd work with D. Ely to 8.3 develop election data sets for RPV analyses. 8/17/15 MRH Work with Compass Demographics to prepare HPA analysis, 6.9 and creation of maps of elections by precinct. 8/20/15 MRH Work with Compass Demographics to prepare HPA analysis, 7.4 and creation of maps of endogenous and exogenous elections by precinct. 8/21/15 MRH Run rough regression analyses on key elections; discuss same 7.5 with K. Shenkman. 8/25/15 MRH Discuss potential additional exogenous elections for further 7.9 analysis with K. Shenkman, M. Kousser and D. Ely; gather information regarding exogenous elections; discuss with experts and K. Shenkman. 8/26/15 MRH Compile research and findings and prepare summary firm 5.8 memorandum and recommendations. 8/27/15 MRH Compile research and findings, further legal research 6.0 concerning potential case against Santa Monica, and prepare summary firm memorandum and recommendations. 8/28/15 MRH Revise, finalize firm memorandum re potential Santa Monica 3.6 case; discuss same with K. Shenkman 8/28/15 KIS Review summary firm memorandum regarding Santa Monica 4.5 and discuss with M. Hughes. 8/30/15 KIS Review firm memorandum and Kousser 1992 report; draft and 5.2 circulate demand letter and respond to comments. 9/4/15 KIS Travel to/from and meet with Pico Neighborhood activists 5.5 regarding potential case and district election outreach campaign. 9/7/15 JU Research campaign spending, sources of funds financing 7.5 campaigns, endorsements tied to electoral success in Santa Monica 9/8/15 JU Investigate history of discrimination in Santa Monica, 8.6 representation in local government, boards and commissions, and historical and recent decisions of Santa Monica city council. 9/9/15 JU Investigate history of discrimination in Santa Monica and 5.3 compile theses on the subject. 9/9/15 KIS Travel to/from and meet with 0. de la Torre and M. Loya 4.0 regarding district election public campaign and organizing effort 9/10/15 JU Research racial appeals in Santa Monica elections 6.4 (endogenous and exogenous), racial issues in local politics both recent and historic 9/11/15 JU Continue research on 14028(e) factors; compile research 8.9 materials and prepare summary firm memorandum on 14028(e) factors 9/14/15 JU Draft summary firm memorandum on 14028e factors 4.0 9/29/15 KIS Travel to/from and meet with 0. de la Torre re: Santa Monica 3.6 campaign and potential case and outreach to Latino leaders. 10/2/15 KIS Discuss potential case and tour Santa Monica's Pico 5.0 Neighborhood with M. Grimes 10/15/15 KIS Review firm memoranda in preparation for meeting with Santa6.3 Monica activists; meet with 0. de la Torre and Pico Youth Center staff. 10/16/15 KIS Meet with M. Loya and 0. de la Torre about Santa Monica case 3.8 and public campaign 10/16/15 MRH Travel to/from and meet with 0. de la Torre and M. Loya to 3.8 discuss initial findings and potential case. 10/19/15 MRH Work on materials for Santa Monica outreach campaign for 5.1 district elections 10/20/15 MRH Work on powerpoint and FAQs for outreach campaign for 5.5 district elections 10/26/15 MRH Revise powerpoint and FAQs for outreach campaign for district 4.6 elections, discuss with 0. de la Torre 10/30/15 KIS Travel to/from and meet with 0. de la Torre and M. Loya to 4.9 prepare materials for community activist workshop. 10/30/15 MRH Work with M. Loya and 0. de la Torre in advance of rollout 4.9 meeting. 11/3/15 KIS Travel to/from and participate in community activist workshop 4.5 on district elections and history in Santa Monica to discuss CVRA and process. 11/3/15 MRH Santa Monica district election campaign rollout meeting 4.5 11/9/15 JU Research regarding procedural path of Santa Monica to 6.8 change its election system voluntarily through political process and/or through court intervention in light of city charter, review applicable Government Code and Elections Code sections; discuss with K. Shenkman. 11/10/15 JU Research federal voting rights cases outside California to 8.0 develop potential paths for voluntary changes to election system of Santa Monica despite city charter 11/11/15 JU Research FVRA preclearance and effect cases for election 7.7 changes in context of settlements not effected through consent decrees or judgments, to develop potential paths for voluntary election change in Santa Monica. 11/12/15 JU Research charter status and contents of jurisdictions making 8.1 electoral changes in response to allegations of voting rights and election law violations in and outside of California and discuss with K. Shenkman for applicability to Santa Monica. 11/13/15 JU Research availability of voluntary election change in Santa 9.8 Monica in light of charter and Jauregui decision; draft summary firm memorandum regarding same. 11/17/15 KIS Travel to/from and meet with T. Vazquez and 0. de la Torre, 5.0 and then meet with 0. de la Torre and Pico Center staff thereafter 11/25/15 KIS Review report re police misconduct of SMPD against 0. de la 2.0 Torre; discuss same with 0. de la Torre 12/13/15 KIS Draft press release for Santa Monica rollout 1.0 12/14/15 KIS Revise press release, discussions with 0. de la Torre and M. 1.2 Loya re same. 12/15/15 KIS Rally in support of adopting district elections at SM city hall, 3.7 deliver demand, discuss with SM Daily Press, discuss with SM City Attorney M. Moutrie 12/20/15 KIS Deal with M. Feinstein opposition; discuss situation with CfER 2.5 and FairVote leadership. 12/28/15 KIS Evaluate correspondence from M. Moutrie saying city will 0.8 address the demand letter at Jan 12 meeting; discuss with 0. de la Torre re next steps. 1/4/16 KIS Travel to/from and meet with 0. de la Torre and M. Loya 6.8 regarding Santa Monica, efforts to obtain districts, and potential case. 1/12/16 KIS Meet with 0 de la Torre and attend city council meeting 4.7 therafter 1/15/16 KIS Correspondence with T. Vazquez re support for district 0.4 elections and other issues 1/23/16 KIS Call with T. Vazquez and follow up thereafter 1.9 2/4/16 MRH Identify potential experts regarding discrimination and 5.5 disparities in Santa Monica; research background of same; discuss potential engagement by phone. 2/5/16 MRH Identify potential experts regarding discrimination and 4.8 disparities in Santa Monica; research background of same; discuss potential engagement by phone. 2/12/16 JU Gather initial research on Santa Monica and racially -polarized 3.2 voting analysis; begin synthesizing research; for preparation of firm summary memorandum. 2/13/16 JU Research and drafting firm summary memorandum for 5.7 potential Santa Monica CVRA case. 2/14/16 JU Revise and finalize S&H firm summary memorandum regarding4.4 potential Santa Monica CVRA case; circulate and discuss same 2/17/16 MRH Travel to/from and meet with potential 14028(e) experts 6.6 2/22/16 MRH Work w/ D. Ely on potential remedies in light of potential 5.9 challenge based on lack of majority -minority district 2/24/16 MRH Research potential for single -member and multi -member 5.6 districts and combination of remedies 2/26/16 MRH Continue research regarding potential remedies and elections 6.8 systems employed in South Dakota and New Hampshire, draft firm memorandum concerning same. 2/29/16 MRH Continue research regarding remedies and charter city 6.4 authority to enact remedies inconsistent with charter, continue drafting firm memorandum concerning same. 3/1/16 MRH Further research and complete firm summary memorandum 6.3 concerning flexibility and availability of combination remedies inconsistent and consistent with charter enactments. 3/4/16 KIS Discuss potential case with Pico Neighborhood activists and 4.9 breakout groups regarding district election campaign 3/7/16 KIS Discuss potential CVRA case against Santa Monica and 3.0 provisions of Santa Monica city charter with AMPS leaders. 3/8/16 KIS Research regarding Education Code, county committee 4.5 authority on election changes, and effect of Santa Monica charter and potential effect thereon of case against City of Santa Monica 3/9/16 KIS Further discussion with AMPS leaders regarding involvement / 1.7 support of potential case against City of Santa Monica 3/9/16 MRH Discuss AMPS role with K. Shenkman, research regarding 2.8 Education Code and potential impact of finding of CVRA violation and/or Equal Protection violation. 3/10/16 MRH Research regarding potential effect of court findings on 5.7 charter provisions on county committee authority under Ed Code 5019; begin drafting memorandum re same. 3/11/16 MRH Further research and finalize firm memorandum regarding 6.0 potential impact of CVRA/Equal Protection declaration concerning Santa Monica city charter on county committee authority 3/14/16 MRH Research regarding standing of Pico Neighborhood Association 6.2 and AMPS, based on membership and interests. 3/15/16 MRH Discussion with 0. de la Torre concerning Pico Neighborhood 3.9 Association membership and interests; further research regarding standing of Pico Neighborhood Association and AMPS, based on membership and interests. 3/17/16 MRH Research regarding standing of AMPS and Pico Neighborhood 2.6 Association; draft firm memorandum regarding same. 3/18/16 MRH Research regarding standing of AMPS and Pico Neighborhood 4.5 Association; draft firm memorandum regarding same. 3/20/16 KIS Review memorandum concerning organizations' standing; 1.0 discussion with AMPS leadership regarding same and potential involvement in case. 3/23/16 KIS Research equal protection claim and potential for removal 2.4 based on federal question. 3/24/16 KIS Research regarding standards under equal protection clauses 3.5 in US and Cal Constitutions; discuss same with M. Hughes. 3/25/16 KIS Research regarding relative standards under federal and 4.8 California constitutions for equal protection claims and similar claims under other provisions of federal and state constitutions 3/26/16 KIS Research regarding relative standards under federal and 6.0 California constitutions for equal protection claims and similar claims under other provisions of federal and state constitutions 3/28/16 KIS Research and begin drafting firm memorandum regarding 4.3 relative standards under federal and California constitutions for equal protection claims and similar claims under other provisions of federal and state constitutions 3/29/16 KIS Research concerning desirability of asserting equal protection 5.1 claim under US and/or California constitutions; drafting memorandum on same. 3/31/16 KIS Further research, drafting, revising memorandum regarding 5.9 relative standards under US and Cal Constitutions and availability of removal based on claims, defenses and allegations asserted 4/1/16 KIS Revise memorandum on equal protection claim and potential 3.3 removal; circulate same and discuss with M. Hughes 4/2/16 KIS Drafting complaint and reviewing demographic and election 2.9 information and firm memoranda for the same; discuss same 4/3/16 KIS Drafting complaint and reviewing demographic and election 4.6 information for the same, coordinate with Pico activists on press and organizational effort. 4/5/16 MRH Finalizing complaint for filing, draft summons and civil case 1.1 coversheet 4/6/16 KIS Review complaint; discuss with R. Rubin and concerns re 0.9 removal 4/7/16 KIS Work with Pico Neighborhood activists and AMPS leadership 2.0 on publicity and organizational effort to coincide with complaint filing. 4/8/16 KIS Work with Pico Neighborhood activists and AMPS leadership 0.8 on publicity and organizational effort to coincide with complaint filing, call with R. Rubin re: same 4/11/16 KIS Draft, revise, finalize press release regarding case filing and 1.8 coordinate rollout with Pico Neighborhood activists. 4/13/16 MRH Research regarding Judge Palazuelos to determine whether to 2.4 file 170.6 challenge, and discuss experiences with Palazuelos with attorneys appearing in her courtroom previously. 4/13/16 KIS Discuss case with local press. 1.3 4/14/16 KIS Deal with retaliation by Santa Monica for case filing; 3.5 discussions with 0. de la Torre, M. Sweetmore and C. Foster among others regarding same. 4/15/16 KIS Further deal with retaliation by Santa Monica related to MUNC 6.6 walkout from negotiations, discuss same with press, conference call with AMPS leadership; discuss same and potential impact on SMMUSD with its attorney (M. Foster). 4/16/16 KIS Travel to/from and meet with L. Rosenthal, C. Foster, M. 4.5 Sweetmore and R. Israel regarding MUNC walkout retaliation and AMPS role 4/17/16 KIS Discussions with AMPS leadership, Malibu city staff, Pico 6.9 Neighborhood activists etc. regarding MUNC situation and AMPS continued role; field press inquiries; draft resignation letter and formulate press strategy for same. 4/18/16 KIS Revise MUNC resignation letter; deal with aftermath of 5.9 resignation letter; field press inquiries regarding same and voting rights case generally, call with R. Rubin regarding interplay between case and school district 4/19/16 KIS Discussions with local press, AMPS leadership and Pico 4.4 Neighborhood activists regarding resignation and response to Santa Monica retaliation; draft correspondence re: same. 4/20/16 KIS Correspondence and discussions with M. Moutrie, T. Larmore, 4.5 S. Peak and C. Foster regarding Santa Monica's response to lawsuit and aftermath of retaliation 4/21/16 KIS Research regarding historical elections and draft first set of 5.3 discovery requests to Santa Monica 4/22/16 KIS Draft first set of discovery requests to Santa Monica 2.5 4/25/16 MRH Research regarding ethical obligations due to split in interests 7.3 between AMPS and Pico plaintiffs 4/26/16 MRH Research regarding ethical obligations due to split in interests 6.4 between AMPS and Pico plaintiffs, and impact of various alternatives on NM ability to represent Santa Monica. 4/27/16 MRH Further research regarding ethical obligations due to AMPS 6.8 desire to withdraw from case and potential for maintaining conflict for NM. 4/28/16 MRH Further research regarding ethical obligations re AMPS-PNA 7.0 split and impact on NM conflict; drafting firm memorandum regarding same. 5/2/16 KIS Evaluate letter from T. Larmore regarding intention to return 0.7 to MUNC task because of K. Shenkman resignation; discuss same and course of action re AMPS with M. Sweetmore. 5/3/16 MRH Continue research regarding course of action in light of AMPS 7.2 request; investigate Santa Monica's process of retaining counsel; complete firm memorandum regarding ethical and suggested course of action. 5/9/16 KIS Discussion with R. Simon regarding airport dispute and 3.8 potential for collaboration; investigate same thereafter. 5/11/16 KIS Travel to/from and meet with R. Simon and N. Rubin regarding2.9 potential collaboration and politics of airport and Santa Monica more generally. 5/18/16 KIS Evaluate Santa Monica's Answer; research for potential 2.2 demurrer to answer; discuss with M. Hughes. 5/19/16 MRH Research regarding potential demurrer to answer, propriety of4.9 amending answer and need for leave of court, and whether pleading challenge to answer can prevent amendment of answer. 5/24/16 KIS Call with J. Shachtner re discovery, retaliation, and case 1.5 generally; investigate contentions of J. Shachtner; draft correspondence regarding deposition dates 5/26/16 KIS Correspondence with J. Shachtner re discovery, retaliation, 1.9 and case generally 5/28/16 KIS Evaluate amended answer, compare for inconsistency; 4.0 research regarding sham pleadings and potential action. 1.0 6/1/16 KIS Evaluate deficient discovery responses from Defendant 6/3/16 KIS Drafting meet and confer letters in response to deficient 2.5 discovery responses. 6/6/16 KIS Research and drafting meet and confer letters in response to 3.1 deficient discovery responses. 6/7/16 KIS Review supplementary discovery responses from Defendant; 3.8 discuss with M. Hughes. 6/10/16 KIS Drafting meet and confer letters in response to Defendant's 5.9 supplemental discovery responses; research propriety of supplementing RFA responses in inconsistent manner and appropriate action in response thereto. 6/17/16 KIS Evaluate SMDP article regarding Pico Neighborhood political 4.8 organization and Sanders -Clinton primary results; investigate precinct level results and 0. de la Torre involvement in Sanders campaign. 6/20/16 KIS Review discovery responses and drafting meet and confer 4.7 letters 6/21/16 KIS Review discovery responses and drafting meet and confer 2.6 letters 6/22/16 KIS Review documents produced by Defendant 4.1 6/23/16 KIS Review documents produced by Defendant; prepare summary 5.6 of council actions and consideration 6/24/16 KIS Review documents produced by Defendant; prepare summary; 6.8 investigate council and political action following 1992 meeting 6/24/16 MRH Document review and preparing spreadsheets for historical 7.0 elections. 6/27/16 MRH Document review and preparing spreadsheets for historical 5.2 elections. 6/28/16 KIS Review discovery responses and drafting meet and confer 3.9 letters; finalize meet and confer letter regarding special interrogatories 6/28/16 MRH Document review and preparing spreadsheets for historical 5.9 elections. 6/29/16 KIS Review discovery responses and drafting meet and confer 4.5 letters; finalize meet and confer letters regarding first and second sets of requests for production of documents and form interrogatories 7/8/16 KIS Evaluate correspondence regarding counsel change; discuss 0.4 with M. Hughes 7/8/16 MRH Investigate Gibson Dunn experience in CVRA cases; review 5.3 previously obtained briefs by Gibson attorneys on CVRA case; discuss with K. Shenkman 7/11/16 KIS Review discovery requests and responses; prepare for and 3.3 participate in conference call with Defendant's new counsel; discuss case strategy with R. Rubin thereafter 7/11/16 MRH Evaluate options with respect to AMPS in light of new counsel 1.0 identification and discuss same with K. Shenkman 7/12/16 KIS Discussions with AMPS leadership, and separately with Pico 1.2 Neighborhood plaintiffs, regarding plan to remove AMPS from case. 7/13/16 KIS Draft meet and confer letter regarding document production. 1.5 7/14/16 MRH Investigate T. Vazquez history 3.8 7/15/16 KIS Review documents produced and responses to document 2.7 requests and revise meet and confer letter accordingly. 7/15/16 MRH Investigate T. Vazquez and M. Leon -Vazquez 5.5 7/18/16 MRH Investigate council members and actions in late 1980s and 6.9 early 1990s 7/19/16 MRH Investigate council members and actions in late 1980s and 6.6 early 1990s 7/20/16 KIS Draft request for dismissal and discuss with AMPS leadership 1.0 and M. Delrahim. 7/21/16 KIS Evaluate correspondence from Defendant's counsel along with 3.2 draft CMS and supplemental discovery responses and supplemental document production. 7/22/16 MRH Review supplemental documents produced by Defendant and 7.0 work on historical election spreadsheets. 7/25/16 KIS Review Defendant's draft CMS, draft correspondence 1.2 regarding same, and draft Plaintiffs' CMS 7/28/16 KIS Attempt to review supplemental document production,n and 0.3 correspondence with Defendant's counsel re same. 7/29/16 KIS Evaluate Defendant's CMS and draft correspondence 1.0 regarding impropriety of same (purporting to be a joint CMS) 7/30/16 KIS Review supplemental discovery responses and begin drafting 5.6 correspondence regarding continued deficiencies in responses. 7/31/16 KIS Evaluate RFA responses and research regarding standard and 4.1 procedure for denying a previously admitted RFA. 8/1/16 KIS Review supplemental document production, and drafting 3.0 correspondence regarding continued deficiencies in supplemental discovery responses and need for deposition dates. 8/2/16 KIS Review correspondence from Defendant's counsel, revised 1.4 Defendant's CMS, and further supplemental interrogatory responses 8/3/16 KIS Travel to/from and meet with M. Grimes, J. Karton and I. 3.4 Jackson to develop case story. 8/5/16 MRH Review correspondence regarding deposition availability and 4.8 investigation in preparation for depositions of council members 8/5/16 KIS Evaluate correspondence regarding depositions and discuss 0.6 same and deposition preparation with M. Hughes. 8/6/16 MRH Investigation for upcoming depositions of council members 7.3 8/8/16 KIS Travel to/from and meet with 0. de la Torre and R. Rubin 3.5 8/9/16 KIS Travel to/from and attend meeting with M. Hughes, 0. de Ia 5.4 Torre and M. Grimes re case generally and council member depositions 8/9/16 KIS Call with R. Rubin regarding CMC and Defendant's counsel 0.5 8/9/16 MRH Meet with K. Shenkman, Oscar De La Torre and Milton Grimes 5.4 regarding deposition investigation and preparation and general story / theme. 8/10/16 KIS Travel to/from and attend CMC and debrief co -counsel and 5.0 clients thereafter. 8/11/16 KIS Travel to/from and attend meeting with 0. de Ia Torre 3.8 regarding case and upcoming depositions 8/12/16 KIS Evaluate Defendant's discovery requests and discuss with J. 1.8 Douglass 8/16/16 KIS Drafting responses to Defendant's discovery requests. 3.5 8/19/16 KIS Drafting responses to Defendant's discovery requests. 5.1 8/22/16 MRH Investigation and preparing deposition outlines for Santa 7.5 Monica council members. 8/24/16 MRH Investigation and preparing deposition outlines for Santa 6.9 Monica council members. 8/25/16 MRH Investigation and preparing deposition outlines for Santa 7.3 Monica council members. 8/29/16 MRH Investigation and preparing deposition outlines for Santa 7.4 Monica council members. 9/2/16 KIS Travel to/from and meet with Pico Neighborhood Association 4.2 Board re case update and outlook. 9/6/16 KIS Correspondence with Defendant's counsel regarding 3.8 deposition scheduling and location; research regarding location of depositions. 9/7/16 KIS Research regarding location of depositions and "good cause" 6.9 for ordering location be different than the default of the CCP; discuss with R. Parris; call with Defendant's counsel regarding location and scheduling of T. Vazquez deposition and depositions going forward. 9/9/16 KIS Draft and revise responses to Defendant's first set of discovery 3.1 requests. 9/11/16 KIS Revise and finalize responses to Defendant's discovery 2.6 requests. 9/12/16 KIS Review materials for T. Vazquez deposition prepared by M. 3.4 Hughes and discuss same with M. Hughes 9/12/16 MRH Investigation for T. Vazquez and T. O'Day depositions and 8.3 discuss with K. Shenkman 9/13/16 KIS Investigate further for T. Vazquez deposition and prepare for 7.2 same 9/15/16 KIS Investigation and prepare for deposition of T. Vazquez 4.7 9/16/16 KIS Investigation and preparation for T. Vazquez deposition; 6.5 review, deal with and draft response to correspondence from Defendant's counsel regarding the same 9/19/16 KIS Prepare for deposition of T. Vazquez 7.8 9/20/16 KIS Prepare for, travel to/from and take deposition of T. Vazquez. 11.3 9/20/16 MRH Investigation for T. O'Day deposition. 4.9 9/21/16 KIS Discuss findings on T. O'Day with M. Hughes and continue 5.3 preparation for T. O'Day deposition; deal with Defendant's counsel's continued nonsense regarding the scheduling and location of depositions of council members 9/22/16 KIS Continue investigation of T. O'Day actions and issues; prepare 7.4 notes outline of T. O'Day findings and discuss same with R. Parris 9/23/16 KIS Debriefing re T. O'Day deposition and continue to deal with 2.0 Defendant's counsel's nonsense regarding deposition scheduling and location. 9/26/16 KIS Evaluate Defendant's further supplemental responses to form 1.2 interrogatories; discuss further action regarding same. 9/27/16 KIS Research regarding potential actions to compel deposition 5.0 attendance and location and potential for sanctions for Defendant's cancellation of deposition. 9/28/16 KIS Correspondence back and forth with Defendant's counsel 8.5 regarding their continued insistence on ignoring the CCP command about deposition location and their refusal to schedule depositions; further research regarding same and begin drafting motion to compel completion of T. Vazquez deposition. 9/29/16 KIS More correspondence back and forth with Defendant's 7.9 counsel regarding their continued insistence on ignoring the CCP command about deposition location and their refusal to schedule depositions; drafting motion to compel completion of T. Vazquez deposition, call with R. Rubin re: same. 9/30/16 KIS Evaluate correspondence from Defendant's counsel purporting4.8 to be meet and confer regarding Plaintiffs' discovery responses; research regarding sufficiency of meet and confer; review discovery responses to respond to Defendant's letter 10/1/16 KIS Review investigation findings re G. Davis from M. Hughes and 9.2 discuss same with M. Hughes; further investigate for G. Davis deposition; research regarding voter perception of ethnicity to guide G. Davis deposition questioning. 10/2/16 KIS Further investigate for G. Davis deposition and prepare 8.6 deposition outline; further research regarding voter perception of ethnicity in identifying minority candidates; discuss with M. Grimes. 10/3/16 KIS Review discovery responses referenced in Defendant's letter; 4.5 research sufficiency of same; drafting responsive letter 10/4/16 KIS Further research regarding sufficiency of discovery responses 7.0 and impropriety of certain of Defendant's discovery requests, and draft letter responding to Defendant's purported meet and confer letter 10/5/16 KIS Further investigation for G. Davis deposition; discuss same 5.6 with M. Grimes to prepare for deposition. 10/6/16 KIS Travel to/from and attend deposition of G. Davis. 9.7 10/7/16 KIS Continue to deal with T. Vazquez deposition scheduling and 2.9 continued dispute regarding deposition location and draft correspondence re same. 10/10/16 KIS Travel to/from and meet with Parris firm team regarding 6.8 depositions and case generally, and conference call with Defendant's counsel regarding scheduling of T. Vazquez deposition and location. 10/10/16 MRH Meeting with Parris attorneys and staff to coordinate tasks 6.5 and strategy for case. 10/11/16 KIS Evaluate correspondence from Defendant's counsel regarding 3.0 Plaintiffs' discovery responses and review referenced discovery responses. 10/12/16 MRH Review and summarize deposition transcript of T. Vazquez, 5.6 and discuss deposition with K. Shenkman 10/12/16 KIS Discuss first day of deposition of T. Vazquez with M. Hughes 4.7 and further investigate and prepare for second day of T. Vazquez deposition. 10/13/16 MRH Investigation for McKeown deposition 5.8 10/14/16 MRH Continue investigation for McKeown deposition, discuss with 7.9 K. Shenkman and 0. de la Torre (separately), and drafting deposition outline 10/16/16 KIS Review correspondence from Defendant's counsel regarding 2.6 discovery responses, research regarding sufficiency of meet and confer and draft correspondence re same. 10/17/16 KIS Draft supplemental responses to Defendant's discovery 4.3 requests where appropriate 10/20/16 KIS Draft supplemental responses to Defendant's discovery 4.9 requests where appropriate, call with R. Rubin regarding timing and disclosure of expert opinions 10/23/16 KIS Draft supplemental responses to Defendant's discovery 2.2 requests where appropriate 10/24/16 KIS Read and summarize transcript of O'Day deposition and 4.8 discuss with R. Parris. 10/25/16 KIS Research and drafting opposition papers to Defendant's ex 9.4 parte application to advance hearings on 8 motions to compel further responses. 10/26/16 KIS Finalize ex parte opposition papers, travel to/from and attend 8.8 ex parte hearing, debrief co -counsel thereafter, and review motion to compel at issue in ex parte. 10/27/16 KIS Research regarding discovery referee appointment and costs 6.0 allocation, discuss potential discovery referees with R. Parris, correspondence with Defendant's counsel re same, evaluate 8 motions to compel purportedly necessitating discovery referee appointment 10/28/16 KIS Further research regarding appointment of discovery referee 8.3 and costs therefor and lengthy discussion with Defendant's counsel regarding discovery referee and discovery disputes; draft correspondence memorializing conversation with Defendant's counsel 10/31/16 KIS Correspondence and further lengthy conversation with 7.4 Defendant's counsel regarding discovery referee and discovery disputes, and research in advance of conversation. 11/1/16 KIS Prepare for, travel to/from and attend continued ex parte 4.9 hearing regarding discovery referee, discuss same with R. Parris, and correspondence thereafter regarding same. 11/2/16 KIS Travel to/from and meet with M. Grimes, M. Hughes, F. Juarez 7.1 and 0. de la Torre, call with R. Rubin thereafter regarding discrimination expert 11/2/16 MRH Meeting at Grimes office with potential local discrimination 6.0 expert. 11/3/16 KIS Prepare for and participate in lengthy conference with 3.8 Defendant's counsel regarding discovery disputes etc., and begin drafting memorializing correspondence on same. 11/4/16 KIS Drafting supplemental responses to discovery requests 4.3 consistent with conversations with Defendant's counsel. 11/7/16 KIS Investigation in preparation of T. Vazquez continuing 4.2 deposition. 11/8/16 KIS Research and drafting supplemental responses to discovery 5.3 requests, and draft correspondence memorializing November 3 conference with Defendant's counsel. 11/10/16 KIS Preparation for T. Vazquez deposition, investigate 2016 5.9 campaign and precinct totals for same. 11/11/16 KIS Evaluate correspondence from Defendant's counsel regarding 4.0 discovery disputes, research and working on supplemental responses consistent with discussions and letter. 11/14/16 KIS Further investigation and preparation for T. Vazquez 7.3 continuing deposition, including review of previous deposition transcript and available videos of T. Vazquez 11/15/16 KIS Prepare for, travel to/from and take deposition of T. Vazquez; 9.5 meet with Parris team thereafter 11/16/16 KIS Call with R. Rubin regarding discovery 0.3 11/23/16 KIS Correspondence with Defendant's counsel regarding discovery 1.0 referee etc. 11/27/16 KIS Drafting supplemental discovery responses (RFAs and form 5.5 interrogatories) in light of discussions with Defendant's counsel and research concerning expert discovery timing and impact on RFAs 11/28/16 KIS Research and drafting opposition papers for Defendant's ex 7.1 parte application regarding discovery referee. 11/29/16 KIS Prepare for, travel to/from and attend ex parte hearing 6.7 regarding discovery referee and Defendant's continuing gripes; work with Defendant's counsel on discovery referee stipulation and correspondence regarding the same thereafter. 11/30/16 KIS Travel to/from and meet with 0. de la Torre and Centinela 5.2 Valley USD constituents regarding T. Vazquez and M. Leon - Vazquez transgressions; further deal with discovery referee stipulation and confer with R. Parris re same. 12/1/16 KIS Drafting supplemental discovery responses (RFAs and form 6.3 interrogatories) in light of discussions with Defendant's counsel and research concerning expert discovery timing and impact on RFAs 12/2/16 KIS Drafting supplemental responses to document requests in 5.4 light of discussions with Defendant's counsel and research concerning expert discovery timing and good cause requirement for motions to compel responses to RFPs 12/3/16 MRH Read and summarize transcript of second deposition of T. 4.9 Vazquez, discuss with K. Shenkman. 12/4/16 KIS Coordinate with R. Parris regarding list of potential discovery 1.1 referees and address stipulation regarding same. 12/4/16 MRH Investigate potential discovery referees and pull available 5.8 decisions of each to compile proclivities on discovery issues and voting rights where available. 12/5/16 KIS Discuss document request responses and production and 3.5 implications thereof with 0. de la Torre and M. Loya; drafting supplemental responses to document requests in light of discussions with Defendant's counsel and research concerning expert discovery timing and good cause requirement for motions to compel responses to RFPs 12/5/16 MRH Further investigate potential discovery referees and complete 2.9 chart comparing discovery referee candidates. 12/8/16 KIS Call with R. Rubin regarding experts 0.5 12/9/16 MRH Document review and preparation for production and work 6.2 with clients to gather documents. 12/10/16 MRH Gathering documents, review and preparation for production 5.7 12/11/16 KIS Coordinate preparation of discovery referee info for list to 0.8 court, and review drafts of same. 12/13/16 KIS Travel to/from and meet with 0. de la Torre regarding case 4.3 generally, document production, etc. 12/14/16 KIS Travel to/from and meet with Pico Neighborhood Assn board 4.0 12/15/16 KIS Investigation for McKeown deposition, discuss with R. Parris 4.9 12/15/16 MRH Prepare deposition outline with K. Shenkman for McKeown 6.0 deposition and discuss McKeown actions with Santa Monica residents. 12/16/16 KIS Travel to/from and attend deposition of K. McKeown and 10.9 debriefing and discussion with R. Parris and M. Cussimonio thereafter regarding case preparation. 12/18/16 KIS Review discovery requests and responses and correspondence 2.8 regarding same to identify scope of continued disputes, and discuss with R. Rubin 12/19/16 KIS Travel to/from and meet with 0. de la Torre and M. Loya 7.8 regarding case generally, discovery and logistics and gathering of documents for production, call with M. Hughes, R. Parris and R. Rubin, and draft correspondence regarding remaining discovery disputes and path forward for resolution of same. 12/19/16 MRH Meeting with PNA clients and conference with K. Shenkman, R. 5.2 Parris and R. Rubin. 12/20/16 MRH Document review and preparation for production, discuss 5.3 same with K. Shenkman 12/21/16 KIS Prepare for and further discussion with Defendant's counsel 4.6 regarding discovery responses, production etc., and drafting supplemental discovery responses in light of continuing discussions. 12/24/16 KIS Call with R. Rubin and R. Parris regarding experts 0.4 12/27/16 MRH Draft and revise supplemental responses to document 5.3 requests in light of discussion with K. Shenkman regarding conversations with Defendant's counsel and review of documents available to produce. 12/29/16 KIS Evaluate motion for judgment on the pleadings and discuss 3.6 same with M. Hughes. 12/29/16 MRH Read Defendant's motion for judgment on the pleadings, quick 4.8 research raised by motion, discuss with K. Shenkman. 12/30/16 KIS Research for opposition to motion for judgment on the 5.9 pleadings, call with R. Rubin re: same 12/31/16 KIS Research for opposition to motion for judgment on the 5.5 pleadings and develop outline for opposition 1/1/17 KIS Further research for opposition to motion for judgment on the 4.9 pleadings 1/2/17 KIS Research and drafting opposition to motion for judgment on 7.0 the pleadings 1/3/17 KIS Research and drafting opposition to motion for judgment on 8.5 the pleadings, call with R. Rubin re: same 1/4/17 KIS Research and drafting opposition to motion for judgment on 9.3 the pleadings 1/5/17 KIS Research and drafting opposition to motion for judgment on 9.6 the pleadings 1/6/17 KIS Research and drafting opposition to motion for judgment on 7.5 the pleadings 1/7/17 MRH Discuss motion for judgment on the pleadings with K. 3.2 Shenkman; revise opposition 1/7/17 KIS Revise opposition to motion for judgment on the pleadings 7.7 and draft ancillary documents; further research for final points. 1/8/17 KIS Revise opposition to motion for judgment on the pleadings 5.0 and draft supporting documents; further research for final points. 1/9/17 MRH Revise opposition to motion for judgment on the pleadings 2.2 1/10/17 KIS Finalize opposition papers to motion for judgment on the 2.7 pleadings and coordinate filing. 1/11/17 KIS Call with R. Rubin regarding experts 0.4 1/11/17 MRH Review additional documents at clients' home gathered by 3.4 clients for document production 1/12/17 KIS Coordinate production of documents. 0.6 1/12/17 KIS Conference with potential survey experts 0.7 1/15/17 KIS Coordinate production of documents. 0.5 1/17/17 KIS Draft supplemental responses to special interrogatories 1.3 consistent with discussions with Defendant's counsel 1/18/17 KIS Travel to/from clients' home for document production, review 5.5 documents to be produced and coordinate same. 1/19/17 KIS Travel to/from and meet with PNA board. 3.5 1/24/17 KIS Evaluate Defendant's reply in support of motion for judgment 4.6 on the pleadings; discuss same with R. Rubin; research cases cited therein and issues raised by reply. 1/25/17 KIS Travel to/from and meet with 0. de la Torre and S. Duron 3.9 1/30/17 KIS Coordinate with M. Kousser on case and needed analysis 0.7 1/30/17 KIS Call with R. Rubin re: upcoming hearing 0.7 2/1/17 KIS Research and prepare for hearing on motion for judgment on 2.0 the pleadings 2/2/17 KIS Prepare for hearing on motion for judgment on the pleadings, 3.6 discuss with R. Rubin. 2/3/17 KIS Prepare for, travel to/from and attend hearing on motion for 5.2 judgment on the pleadings; deal with press thereafter. 2/10/17 KIS Evaluate correspondence from Defendant's counsel to 4.9 discovery referee's assistant regarding supplementing Defendant's motions to compel, research ability to supplement motions to compel after 45 -day deadline has passed, draft correspondence regarding same. 2/20/17 KIS Review case materials and drafting FAC to address issues in 3.5 court's ruling on motion for judgment on the pleadings 2/21/17 KIS Draft FAC, call with R. Rubin re: same 3.9 2/22/17 KIS Discuss FAC with co -counsel and clients, and revise 2.3 accordingly. 2/24/17 KIS Travel to/from and attend PNA event to discuss case generally 4.0 and expected path going forward. 3/4/17 KIS Evaluate planning commission reports for statements 4.2 concerning Pico Neighborhood disparities, distinctions and history 3/5/17 MRH Pull commission reports and city council minutes and review 9.0 for helpful items of discrimination against minorities and the Pico Neighborhood 3/6/17 MRH Investigate process associated with location of the 10 freeway; 7.6 evaluate commission reports and city council minutes and review for helpful items of discrimination against minorities and the Pico Neighborhood. 3/6/17 KIS Travel to/from and meet with T. Crane. 3.3 3/7/17 KIS Call with R. Parris re: depositions 0.4 3/13/17 KIS Travel to/from and speak at N.E. Neighbors meeting to provide 3.8 information and update on case. 3/14/17 KIS Travel to/from and meet with A. Gonzalez regarding T. 5.4 Vazquez and case generally fitting into Southwest Voter Registration Education Project campaign. 3/16/17 KIS Review correspondence from Defendant's counsel regarding 0.3 demurrer and discuss with M. Hughes. 3/20/17 KIS Coordinate retention of survey expert 0.6 3/21/17 KIS Pull CVRA complaints filed by G. Brown in Sanchez v Modesto 6.1 and Rey v Madera USD to compare level of specificity with FAC, research regarding level of specificity in voting rights complaints generally, and discuss course of action re need for amendment with R. Rubin. 3/22/17 KIS Prepare for and participate in conference with Defendant's 2.0 counsel regarding anticipated demurrer. 3/23/17 KIS Evaluate correspondence from Defendant's counsel regarding 4.9 anticipated demurrer; draft correspondence in response; and research for same. 3/24/17 KIS Evaluate letter brief submitted by Defendant 0.5 3/29/17 KIS Call with R. Rubin regarding upcoming conference with 0.5 discovery referee 3/31/17 KIS Prepare for and participate in telephonic conference with 4.0 Judge Bostrom; confer with co -counsel re same. 4/1/17 KIS Evaluate demurrer to FAC, discuss with M. Hughes 2.8 4/1/17 MRH Review Defendant's demurrer to Plaintiffs' FAC and research 3.8 compiled on specificity of voting rights complaints and discuss with K. Shenkman. 4/3/17 KIS Research for opposition to demurrer to FAC 5.2 4/4/17 KIS Call with R. Rubin regarding demurrer 0.5 4/6/17 KIS Research for opposition to demurrer to FAC and discussion 6.0 with J. Levitt re same and case generally 4/7/17 KIS Research for opposition to demurrer to FAC and case generally 5.7 consistent with discussion with J. Levitt 4/10/17 KIS Research for opposition to demurrer to FAC and case generally 7,8 consistent with discussion with J. Levitt and summarize research in firm memorandum, call with R. Rubin re: same 4/11/17 KIS Evaluate submissions to discovery referee by Defendant; 9.6 research and draft responsive letter brief 4/12/17 KIS Research and drafting letter brief to discovery referee 9.3 4/12/17 KIS Travel to/from and meet with F. Guerra, A. Alarcon and B. 3.5 Gilbert regarding survey expert and case generally 4/13/17 KIS Travel to/from and meet with J. Levitt regarding demurrer and 6.5 case generally and potential for J. Levitt as expert witness 4/14/17 MRH Discuss letter brief and discovery responses with K. Shenkman, 1.5 revise letter to Bostrom accordingly 4/14/17 KIS Revise letter brief to discovery referee and discuss same with 0.7 M. Hughes. 4/17/17 KIS Call with R. Rubin regarding demurrer 0.4 4/18/17 KIS Research and investigate issues identified in discussion with J. 7.0 Levitt for demurrer and case generally. 4/19/17 KIS Research and investigate issues identified in discussion with J. 7.7 Levitt for demurrer and case generally. 4/21/17 KIS Research and investigate issues identified in discussion with J. 7.2 Levitt for demurrer and case generally, conference with M. Fahey and R. Rubin re: same 4/25/17 KIS Research and drafting opposition to demurrer to FAC 8.3 4/26/17 KIS Research and drafting opposition to demurrer to FAC 6.9 4/29/17 KIS Research and drafting opposition to demurrer to FAC 8.2 5/1/17 KIS Research and drafting opposition to demurrer to FAC 7.3 5/2/17 KIS Research and drafting opposition to demurrer to FAC 7.6 5/4/17 KIS Research and drafting opposition to demurrer to FAC and 6.2 associated papers 5/5/17 KIS Research and drafting opposition to demurrer to FAC and 6.6 associated papers, call with M. Fahey and R. Rubin re: same 5/7/17 KIS Research and drafting opposition to demurrer to FAC and 5.0 associated papers 5/8/17 KIS Revising opposition to demurrer to FAC; discuss same with M. 3.8 Hughes and J. Levitt 5/8/17 MRH Review and revise opposition to demurrer and discuss with K. 3.7 Shenkman 5/9/17 KIS Revise and finalize papers in opposition to demurrer for filing. 2.9 5/10/17 KIS Correspondence about discovery referee scheduling and 0.4 Defendant claiming prejudice by scheduling. 5/11/17 KIS Call with M. Kousser and direct tasks on ER analysis 1.5 5/13/17 KIS Research and drafting letter briefs requested by discovery 7.4 referee in opposition to Defendant's various motions to compel 5/14/17 KIS Research and drafting 8 letter briefs requested by discovery 6.9 referee in opposition to Defendant's various motions to compel 5/15/17 KIS Research and drafting letter briefs requested by discovery 5.5 referee in opposition to Defendant's various motions to compel 5/16/17 MRH Revise opposition briefs for discovery referee and discuss with 2.0 K. Shenkman 5/16/17 KIS Revise letter briefs consistent with discussion with M. Hughes. 0.8 5/17/17 KIS Revise and finalize 8 letter briefs to discovery referee 2.1 regarding Defendant's motions to compel 5/20/17 KIS Evaluate Defendant's reply papers in support of its demurrer, 4.5 research cases cited therein. 5/23/17 MRH Draft further requests for production of documents 2.3 5/23/17 KIS Evaluate Defendant's letter briefs to discovery referee and 2.5 deal with some issues identified as still in dispute and draft correspondence re same. 5/24/17 KIS Prepare for, travel to/from and attend discovery referee 6.8 hearing at Judicate West, and deal with aftermath. 5/25/17 KIS Investigate S. Himmelrich actions and issues in preparation for 5.3 deposition 5/26/17 KIS Investigation for S. Himmelrich deposition, discuss with Santa 4.9 Monica constituents 5/28/17 KIS Research and preparation for S. Himmelrich deposition 6.5 5/29/17 KIS Further investigation and discussion with SM constituents re S. 7.1 Himmelrich; draft deposition outline. 5/30/17 KIS Prepare for, travel to/from and take deposition of S. 6.7 Himmelrich. 6/1/17 KIS Call with R. Rubin re: upcoming hearing 0.5 6/2/17 KIS Travel to/from and meet with D. Parker and CDP officials 4.5 regarding Santa Monica case, party resolutions and political support 6/2/17 MRH Meeting with Cal. Dem. Party. 4.5 6/4/17 KIS Review demurrer papers, research open issues and prepare for 3.9 demurrer hearing. 6/5/17 KIS Travel to/from (Santa Monica) and participate in Voice of 4.3 America filming for story on Santa Monica voting rights case 6/5/17 KIS Travel to/from and meet with R. Rubin to prepare for 3.5 demurrer hearing. 6/6/17 KIS Prepare for, travel to/from and attend hearing on demurrer; 5.4 discuss with co -counsel and press thereafter. 6/7/17 KIS Meeting with PNA Board to update on case and coordinate 3.8 organizational effort. 6/8/17 KIS Travel to/from and meet with D. Ely and J. Jones regarding 5.8 case tasks and demographic presentation 6/8/17 JU Meeting with K. Shenkman and D. Ely 4.0 6/9/17 KIS Evaluate Defendant's draft stipulation concerning case 1.5 schedule, draft correspondence in response to same, and coordinate with R. Parris re same. 6/12/17 KIS Travel to/from (downtown) and participate in Voice of 4.9 America filming for story on Santa Monica voting rights case 6/12/17 JU Research regarding expert witness conflict issue. 6.0 6/13/17 JU Research regarding expert witness conflict issue. 6.7 6/14/17 JU Research and drafting firm memorandum regarding expert 8.3 witness conflict issue. 6/15/17 JU Research and drafting firm memorandum regarding expert 9.6 witness conflict issue. 6/20/17 KIS Correspondence back and forth and conference call with 1.1 Defendant's counsel regarding case schedule in advance of status conference. 6/21/17 KIS Prepare for, travel to/from and attend status conference 4.7 regarding case schedule. 6/21/17 JU Work with D. Ely on case showing two worlds in one city. 5.3 6/22/17 JU Work with D. Ely on case showing two worlds in one city. 5.9 6/23/17 JU Work with D. Ely on case showing two worlds in one city. 4.8 6/26/17 KIS Handle scheduling mess regarding conference with discovery 0.7 referee and draft correspondence re same, call with R. Rubin re: same. 6/27/17 JU Work with D. Ely on case showing two worlds in one city. 5.5 6/28/17 KIS Review Defendant's answer to FAC and discuss with co- 1.0 counsel possibility of demurrer to answer. 6/28/17 MRH Evaluate Defendant's responses to third set of document 1.5 requests and compare with notes of investigation. 7/3/17 JU Work with D. Ely on case showing story of election effect on 6.0 Pico Neighborhood. 7/5/17 JU Work with D. Ely on case showing two worlds in one city. 3.3 7/6/17 KIS Travel to/from and speak at NOMA meeting regarding case 3.8 status and contentions. 7/10/17 JU Work with D. Ely on case showing effect of election method on 7.2 not only outcome but also impact on Pico Neighborhood and people of color 7/11/17 JU Work with D. Ely on case showing effect of election method on 6.1 not only outcome but also impact on Pico Neighborhood and people of color 7/12/17 KIS Prepare for and participate in conference with discovery 3.2 referee, research issue of discovery referee authority in response to concern expressed by discovery referee 7/13/17 KIS Evaluate Defendant's submission regarding authority of 4.6 discovery referee, research same issues, send correspondence to discovery referee in light of research 7/14/17 MRH Read and summarize transcript of deposition of S. Himmelrich 5.3 7/14/17 KIS Review correspondence from Defendant's counsel alleging 4.0 violation of ethical obligations; confer with M. Grimes regarding allegations; research applicable ethical obligations; draft response. 7/17/17 JU Discuss allegations by Defendant's counsel with K. Shenkman; 6.6 research ethical obligations raised by correspondence from G. Brown. 7/18/17 JU Further research regarding ethical obligations in light of 7.0 allegations by Defendant's counsel. 7/19/17 JU Further research on ethical issues raised by Defendant's 8.1 counsel's allegations; draft memorandum re same; discuss suggested course of action with K. Shenkman. 7/19/17 KIS Discuss ethics issue with J. Jones. 0.4 7/21/17 KIS Research for oppositions to motions to compel further 6.3 responses to special interrogatories, and review responses and supplements for same. 7/24/17 KIS Research and drafting oppositions to motions to compel 4.0 further responses to special interrogatories to Loya and PNA 7/25/17 KIS Travel to/from and meet with D. Ely, A. Gonzalez and A. 5.9 Alarcon regarding T. Vazquez and case generally. 7/26/17 KIS Research and drafting oppositions to motions to compel 7.2 further responses to special interrogatories 7/27/17 KIS Research and drafting oppositions to motions to compel 7.5 further responses to special interrogatories to Loya and PNA and associated papers. 7/28/17 KIS Research and drafting oppositions to motions to compel 8.4 further responses to special interrogatories to Loya and PNA and associated papers 7/31/17 MRH Revise opposition papers in response to MTCs special 2.0 interrogatories 7/31/17 KIS Revise oppositions to motions to compel further responses to 7.3 special interrogatories; drafting ancillary papers including separate statements 8/1/17 KIS Revise oppositions to motions to compel further responses to 6.5 special interrogatories; drafting ancillary papers for same. 8/2/17 KIS Finalize papers in opposition to motions to compel further 3.8 responses to special interrogatories (Loya and PNA) and coordinate submission to discovery referee. 8/4/17 JU Speak to Santa Monica residents regarding P. O'Connor and 7.0 investigate leads. 8/7/17 JU Further investigation for O'Connor deposition and discuss with 5.8 K. Shenkman 8/8/17 KIS Evaluate Defendant's writ petition, discuss with J. Bickford, M. 2.9 Hughes, M. Fahey and R. Rubin 8/8/17 MRH Read Santa Monica petition for writ of mandamus and discuss 2.0 potential response with K. Shenkman 8/9/17 KIS Research issues in writ petition and formulate outline for 6.5 delighted letter 8/10/17 KIS Review findings of O'Connor investigation for deposition and 1.0 discuss with R. Parris. 8/11/17 KIS Meet with 0. de la Torre regarding O'Connor deposition, travel 1.8 to/from O'Connor deposition (until learning that she walked out), 8/12/17 KIS Research and drafting correspondence to discovery referee 4.9 regarding O'Connor walking out of deposition. 8/13/17 KIS Research and drafting delighted letter in opposition to writ 5.6 petition. 8/13/17 MRH Review and revise preliminary opposition to writ petition. 0.6 8/14/17 KIS Travel to/from and meet with 0. de Ia Torre and M. Loya 4.6 regarding case and next depositions and continuing public efforts 8/15/17 KIS Read O'Connor deposition transcript and discuss motion to 1.3 compel with R. Parris and J. Douglass 8/16/17 KIS Research, review and revise motion to compel deposition of P. 4.8 O'Connor, review correspondence regarding O'Connor walk out and discuss same with R. Parris and J. Douglass. 8/18/17 KIS Travel to/from and meet with 0. de Ia Torre and E. Sanchez in 8.9 Oceanside regarding public outreach on voting rights and district elections and coordinating SoCal efforts. 8/21/17 KIS Conference call with Defendant's counsel regarding O'Connor 1.8 deposition walkout; discuss with R. Parris before and after call. 8/22/17 KIS Research and drafting opposition to motion to compel further 7.2 responses to RFAs, call with R. Rubin re: same 8/23/17 KIS Review order denying Defendant's writ petition and discuss 1.4 same with local press. 8/24/17 KIS Prepare for and participate in conference call with discovery 1.1 referee regarding O'Connor walkout 8/24/17 KIS Travel to/from and meet with T. Crane and P. Brock regarding 3.6 case, local support and current/former council members. 8/25/17 KIS Travel to/from and attend discovery referee hearing regarding 5.3 motion to compel further responses to special interrogatories directed to M. Loya and PNA, discussion with M. Grimes thereafter. 8/26/17 KIS Research and drafting opposition to motion to compel further 5.9 responses to RFAs and form interrogatory 17.1 8/27/17 KIS Research and drafting opposition to motion to compel further 6.4 responses to RFAs and associated papers 8/28/17 MRH Review PNA membership documents, discuss with 0. de la 4.8 Torre and draft declaration to resolve issues concerning discovery requests to PNA. 8/28/17 KIS Research and drafting opposition to motion to compel further 6.0 responses to RFAs and associated papers 8/29/17 MRH Revise opposition to MTC RFAs. 2.5 8/29/17 KIS Revise papers in opposition to motion to compel further 6.7 responses to RFAs, and research/deal with Defendant's belated withdrawal of a portion of that motion. 8/30/17 KIS Revise and finalize all papers for opposition to motion to 4.6 compel further RFA responses. 8/30/17 KIS Work on survey script 1.4 8/31/17 AAA Review and revise survey script 0.5 9/1/17 KIS Evaluate Defendant's motion for protective order and 1.9 opposition to motion to compel deposition of P. O'Connor, and discuss same with J. Douglass. 9/1/17 AAA Research SM commissioners and draft summary memo 2.8 9/5/17 KIS Evaluate rulings of discovery referee, discuss same with R. 1.5 Parris, compare correspondence from Defendant's counsel to determine action regarding de la Torre declaration. 9/6/17 KIS Evaluate Defendant's petition for review from Cal. Supreme 2.3 Court and discuss same and responsive course of action with M. Hughes and J. Bickford 9/6/17 MRH Read petition for review of denial of writ petition and discuss 1.8 with K. Shenkman 9/6/17 AAA Review First Amended Complaint, Rulings of the Discovery 5.7 Referees, Special Interrogatories and Responses; Initiate Draft for Supplemental Responses to SM's Special Interrogatories per Referee Rulings; Initiate Draft of Special Interrogatories, Set One from PNA to SM. 9/7/17 KIS Research for answer to petition for review, and research 6.0 timing of petition and completeness of submission. 9/7/17 AM Call with KS to discuss PNA's Special Interrogatories to SM and 1.4 begin drafting 9/8/17 KIS Review Defendant's papers and discovery referee ruling to 3.5 determine scope of remaining disputes and draft correspondence regarding same and call with Defendant's counsel re same; review Defendant's reply in support of its motions to compel RFA responses. 9/8/17 AM Research Santa Monica electoral history and incorporate 3.7 election information into draft of PNA's Special Interrogatories to SM 9/9/17 KIS Research, review and revise opposition to motion for 3.9 protective order and reply in support of motion to compel deposition of P. O'Connor 9/10/17 KIS Research, review and revise opposition to motion for 4.7 protective order and reply in support of motion to compel deposition of P. O'Connor 9/10/17 AAA Finalize draft of special interrogatories from PNA to SM (187 3.6 Special Interrogatories). 9/11/17 KIS Draft supplemental responses to special interrogatories 6.9 consistent with discovery referee ruling, and draft additional interrogatories based on view expressed in discovery referee ruling. 9/11/17 AAA Review special interrogatory responses from K. Shenkman 0.5 9/12/17 KIS Research and drafting answer to petition for review 8.5 9/12/17 AAA Continue preparing draft supplemental responses; draft 3.5 additional SROGs re: city atty's legal advice to CM's & Charter Review Commission. 9/13/17 KIS Research and drafting answer to petition for review 7.9 9/14/17 KIS Research and drafting answer to petition for review 8.0 9/14/17 AAA Research and confirm historical candidates' ethnicities. 1.8 9/17/17 KIS Review Defendant's reply brief in support of motions to 3.8 compel RFA responses, research issue therein, and prepare for hearing on same. 9/18/17 KIS Prepare for, travel to/from and attend hearing with discovery 7.0 referee regarding RFAs and form intrerrogatory 17.1, research regarding mootness of discovery motions thereafter in response to issue that arose at hearing. 9/19/17 KIS Research and drafting opposition to motion to compel RFP 7.8 responses. 9/19/17 AAA Finish draft supplemental responses 3.2 9/20/17 KIS Research and drafting opposition to motion to compel RFP 7.1 responses. 9/21/17 KIS Review Defendant's reply in support of motion for protective 0.8 order and discuss with R. Parris. 9/22/17 MRH Discuss petition for review with K. Shenkman and work on 2.2 organization. 9/22/17 KIS Research and drafting answer to petition for review; discuss 7.6 with M. Hughes. 9/23/17 MRH Research and drafting sections of opposition to MTC further 6.5 responses to document requests 9/23/17 KIS Research and drafting opposition to motion to compel RFP 7.0 responses. 9/24/17 MRH Research and draft letter brief regarding entitlement to a 5.8 ruling on submitted motions to compel. 9/24/17 MRH Work on opposition to petition for review to Cal. S. Ct. 4.6 9/24/17 KIS Research and drafting opposition to motion to compel RFP 6.2 responses. 9/25/17 KIS Travel to/from and attend hearing with discovery referee on 5.3 O'Connor deposition motions, meeting re case generally and O'Connor thereafter with R. Parris et al. 9/25/17 AM Draft supplemental responses to RFAs and form rogs 3.1 9/25/17 MRH Research and draft letter brief regarding entitlement to a 3.3 ruling on submitted motions to compel. 9/25/17 MRH Work on opposition to petition for review to Cal. S. Ct. 4.3 9/26/17 MRH Revise opposition to petition for review. 2.0 9/26/17 KIS Revise answer to petition for review and gather exhibits for 5.6 same. 9/27/17 KIS Revise and finalize Answer to petition for review to the Cal. 4.7 Supreme Court 9/28/17 KIS Research and drafting opposition and ancillary papers in 6.6 response to motion to compel RFP responses. 9/28/17 MRH Revise opposition to MTC further responses to RFPs, discuss 2.5 with K. Shenkman 9/29/17 MRH Finalize papers in opposition to Defendant's motion to compel 3.9 further responses to document requests. 9/30/17 KIS Travel to/from and meet with M. Bailer and L. Ho regarding 13.8 Santa Monica and Santa Clara cases and coordination of same. 10/3/17 KIS Draft further supplemental responses to special 5.4 interrogatories consistent with discovery referee ruling, and draft supplemental responses to form interrogatories consistent with discussions and likely rulings of discovery referee, and draft supplemental responses to RFAs consistent with discovery referee rulings. 10/6/17 KIS Evaluate Defendant's reply brief in support of its motions to 1.1 compel RFP responses, and Defendant's letter brief regarding withdrawal of a portion of its motion to compel RFA responses. 10/8/17 KIS Prepare for discovery referee hearing on Defendant's motions 2.7 to compel RFP responses. 10/9/17 KIS Prepare for, travel to/from and attend hearing on Defendant's 5.0 motions to compel RFP responses. 10/11/17 MRH Review Defendant's reply in support of its petition for review, 1.2 discuss with K. Shenkman 10/11/17 KIS Evaluate Defendant's reply in support of petition for review to 2.1 Cal. Supreme Court, discuss same with M. Hughes, research cases cited therein. 10/12/17 KIS Evaluate discovery referee ruling on motions re O'Connor 2.5 deposition walkout; field inquiries from local Santa Monica press and LA Times and regarding same and case generally. 10/16/17 MRH Research and investigate disparities and disparate treatment 7.4 of Pico Neighborhood and minority residents. 10/17/17 MRH Research and investigate disparities and disparate treatment 8.2 of Pico Neighborhood and minority residents. 10/17/17 KIS Evaluate discovery referee amended ruling re RFAs and direct 3.5 corresponding action, and discovery referee directive concerning additional briefing; initial research for additional briefing. 10/18/17 MRH Research and investigate disparities and disparate treatment 5.5 of Pico Neighborhood and minority residents. 10/19/17 MRH Research and investigate disparities and disparate treatment 6.3 of Pico Neighborhood and minority residents; prepare guide and summary of wellbeing report 10/21/17 KIS Evaluate order denying petition for review, discuss same with 1.0 local press. 10/23/17 KIS Investigate campaign contribution violations in light of 5.0 reporting re FPPC fine; research ability to take second depositions; direct M. Cussimonio re same. 10/23/17 KIS Calls with R. Rubin regarding settlement potential and 1.1 possibilities. 10/24/17 KIS Evaluate correspondence from Defendant's counsel regarding 3.9 depositions, discuss with R. Parris, and research issue identified therein. 10/27/17 KIS Travel to/from and meet with Mr. and Mrs. Holbrook 8.7 regarding case generally and 1992 decision; investigate council member corruption issues identified at meeting. 10/28/17 KIS Investigate council member finances. 4.8 10/29/17 KIS Travel to/from and meet with P. Brock and C. Matthews 4.4 regarding case, council members and local effort 10/30/17 KIS Travel to/from and meet with PNA board regarding case, 3.9 council member revelations and path forward. 11/1/17 KIS Research regarding legal standard for leave to take second 5.7 depositions, and formulate argument for same 11/2/17 KIS Research and drafting letter to discovery referee re seeking 4.8 subsequent depositions of T. O'Day and G. Davis in light of FPPC fines. 11/6/17 KIS Draft additional interrogatory 0.3 11/7/17 KIS Further research regarding propriety of subsequent 6.1 depositions and relevancy of campaign spending, contributions and fundraising to RPV analysis and 14028(e) factors; discuss same with J. Douglass. 11/7/17 KIS Call with M. Kousser regarding ER and El results and RPV 1.4 analysis. 11/7/17 AAA Coordinate with M. Kousser and research regarding intent, 2.0 correspondence with Santa Monica Historical Museum 11/10/17 AAA Coordinate with Santa Monica Historical Museum to get 0.8 materials. 11/14/17 KIS Assist LA County DA with investigation of Santa Monica 2.4 corruption uncovered in investigation and depositions, as requested. 11/15/17 AAA Research at the Santa Monica Library directed by M. Kousser 9.5 11/16/17 KIS Travel to/from and attend N.E. Neighbors meeting to provide 5.5 community with update on case and support organizing efforts; respond to inquiries of local press regarding statements concerning council corruption. 11/16/17 AAA Research at the Santa Monica Library directed by M. Kousser 8.7 11/17/17 KIS Evaluate Defendant's supplemental brief in support of its 3.0 motion to compel further responses to RFPs; initial research for supplemental opposition; discuss with M. Hughes. 11/17/17 MRH Read supplemental papers submitted by Defendant regarding 1.8 discovery motion and discuss with K. Shenkman 11/20/17 KIS Research, draft and revise supplemental papers in opposition 7.5 to motion to compel further responses to RFPs 11/21/17 MRH Review and revise supplemental opposition to MTC responses 2.0 to document requests. 11/21/17 KIS Revise supplemental papers in opposition to motion to compel 4.5 further responses to RFPs 11/22/17 KIS Evaluate correspondence from K. Scolnick regarding discovery 3.3 responses and discovery referee rulings; compare responses with direction from discovery referee to determine appropriate reaction. 11/28/17 KIS Review discovery referee rulings and supplemental responses 2.8 in preparation for conference with Defendants' counsel, and participate in conference. 11/29/17 AAA Review research from Santa Monica library and historical 5.5 museum and draft outline summary for M. Kousser 11/30/17 KIS Review Defendant's supplemental reply in support of motion 2.9 to compel further responses to RFPs, research new issues and evidence raised in supplemental reply, and back -and -forth about submitting a surreply and/or having a further hearing. 12/2/17 KIS Travel to/from and meet with A. Gonzalez regarding T. 5.3 Vazquez and his place in case narrative. 12/4/17 KIS Research and drafting motion to compel subsequent 4.6 depositions of G. Davis and T. O'Day. 12/5/17 KIS Research and drafting motion to compel subsequent 4.9 depositions of G. Davis and T. O'Day. 12/6/17 KIS Research and drafting motion to compel and associated 6.0 papers seeking subsequent depositions of G. Davis and T. O'Day. 12/8/17 KIS Revise and finalize motion to compel subsequent depositions 1.8 of G. Davis and T. O'Day and associated papers. 12/11/17 KIS Prepare for and participate in telephonic hearing with 2.6 discovery referee regarding Defendant's motion to compel further responses to RFPs 12/11/17 AAA Research at Santa Monica Library regarding charter 7.0 commissions. 12/12/17 KIS Review Defendant's responses to discovery requests and 2.0 discuss same with J. Douglass for preparation of meet -and - confer letter. 12/12/17 AAA Review research and draft memorandum for M. Kousser 4.5 regarding charter commissions 12/13/17 KIS Call with M. Kousser regarding ER and El results and RPV 1.3 analysis. 12/14/17 KIS Review and revise meet -and -confer letter 1.8 12/15/17 KIS Evaluate notice regarding change in counsel for Defendant; 2.6 discuss same with M. Hughes and R. Rubin, and investigate new counsel. 12/15/17 AAA Appointment at SM History Museum for research on SM 6.8 12/18/17 KIS Research regarding assertion of Fifth Amendment in civil 5.0 action by party -affiliated witness and consequences in California and federal cases. 12/19/17 KIS Evaluate correspondence from Defendant's counsel regarding 3.0 discovery disputes and unavailability to meet and confer; research regarding 45 -day deadline on motion to compel and failure to participate in meet and confer process and coordinate with M. Cussimonio regarding relevant dates. 12/20/17 KIS Research regarding effect of prior order on 45 -day deadline, 4.2 direct co -counsel on approach in light of research and Defendant's tact. 12/20/17 KIS Research regarding Fifth Amendment and further investigation 5.7 regarding T. Vazquez and Santa Monica government corruption; draft correspondence requesting subsequent deposition of T. Vazquez and explaining basis therefor. 12/22/17 KIS Evaluate correspondence from K. Scolnick; research Rule 5-100 4.3 issue raised in K. Scolnick's letter. 12/23/17 KIS Research and drafting motion for subsequent deposition of T. 5.6 Vazquez 12/25/17 KIS Research and drafting motion for subsequent deposition of T. 1.2 Vazquez 12/26/17 KIS Research and drafting motion for subsequent deposition of T. 3.9 Vazquez 12/27/17 KIS Research and drafting motion for subsequent deposition of T. 4.7 Vazquez 12/28/17 KIS Research, drafting and revising motion to compel further 6.0 responses to special interrogatories 12/28/17 AAA Research at SM Library for M. Kousser 5.7 12/29/17 AAA Research at SM Library for M. Kousser 5.4 12/29/17 KIS Research, drafting and revising motion to compel further 6.4 responses to special interrogatories and associated papers 1/2/18 KIS Travel to/from and meet with 0. de la Torre and M. Loya 4.0 regarding case generally, settlement idea, and how to pursue resolution. 1/2/18 KIS Research and drafting motion for subsequent deposition of T. 5.2 Vazquez 1/3/18 MRH Revise and finalize MTC subsequent deposition of T. Vazquez. 3.7 1/4/18 KIS Revise and finalize motion to compel further responses to 5.6 special interrogatories and associated papers 1/5/18 KIS Research regarding inclusion of multi -member districts and 6.5 differing election structures within a jurisdiction as remedy for voting rights violation. 1/6/18 KIS Travel to/from and meet with J. Newman regarding effort to 4.4 legislate away Santa Monica CVRA case. 1/8/18 KIS Research regarding RPV in individual elections for reply to 4.8 anticipated opposition to motion to compel special interrogatory responses. 1/9/18 KIS Evaluate Defendant's opposition to motion for subsequent 2.1 depositions of G. Davis and T. O'Day and formulate reply; correspondence regarding discovery motion briefing and scheduling. 1/10/18 KIS Research and drafting reply in support of subsequent 6.0 depositions of O'Day and Davis. 1/11/18 KIS Research and drafting reply in support of subsequent 7.7 depositions of O'Day and Davis. 1/12/18 KIS Research and drafting reply in support of subsequent 5.4 depositions of O'Day and Davis. 1/15/18 MRH Review moving and opposition papers regarding subsequent 3.8 depositions of council members, discuss with K. Shenkman and revise reply 1/15/18 KIS Revising reply in support of subsequent depositions of O'Day 4.0 and Davis. 1/15/18 KIS Correspondence with M. Barreto and LatinoDecisions team, 1.2 and talk to A. Gonzalez about problems with Barreto et al. 1/16/18 KIS Finalize reply papers for motion seeking subsequent 3.2 depositions of O'Day and Davis. 1/16/18 AAA Follow up regarding CPRA request and coordinate with K. 0.9 Shenkman and M. Kousser 1/17/18 KIS Interview with potential polling expert, and follow up with 2.4 scope and survey outline. 1/18/18 KIS Research regarding legality of potential settlement proposal; 6.6 discuss same with clients and affected constituents. 1/19/18 KIS Research regarding legality of potential settlement proposals 7.5 and confer with experts regarding likely remedial effectiveness; lobby clients and affected constituents for support for same. 1/22/18 KIS Prepare for, travel to/from and attend discovery referee 5.0 hearing regarding motion for subsequent depositions of O'Day and Davis. 1/23/18 MRH Read discovery oppositions submitted by Defendant and 1.9 discuss responses with K. Shenkman 1/23/18 KIS Evaluate Defendant's oppositions to motions to compel 4.9 subsequent deposition of T. Vazquez and further responses to special interrogatories, and initial research for reply; discuss with M. Hughes. 1/24/18 KIS Research and drafting reply in support of motion for 6.8 subsequent deposition of T. Vazquez; conference with E. Gordon regarding reply in support of motion to compel special interrogatory responses. 1/25/18 KIS Research and drafting reply in support of motion for 6.0 subsequent deposition of T. Vazquez 1/26/18 KIS Travel to/from and meet with Pico Neighborhood activists 4.1 including most of PNA board. 1/26/18 KIS Review draft survey text and discuss with J. Brown 1.0 1/27/18 KIS Research and drafting reply in support of motion for 5.7 subsequent deposition of T. Vazquez 1/28/18 MRH Review moving and opposition papers, discuss with K. 3.0 Shenkman and revise reply regarding T. Vazquez deposition 1/28/18 KIS Research, drafting and revising reply in support of motion for 5.9 subsequent deposition of T. Vazquez 1/29/18 MRH Review and revise reply in support of MTC special 5.1 interrogatories. 1/29/18 KIS Revise replies in support motions to compel T. Vazquez 4.5 deposition and further responses to interrogatories 1/29/18 KIS Call with R. Rubin regarding settlement possibilities 0.5 1/30/18 KIS Finalize replies in support of discovery motions - 5.2 interrogatories and T. Vazquez deposition - and deal with dispute over subpoena of M. Leon -Vazquez. 1/31/18 KIS Prepare for and participate in conference with Defendant's 0.9 counsel regarding deposition and subpoena of M. Leon - Vazquez 2/1/18 MRH Calls with Santa Monica activists regarding T. Winterer 4.3 business dealings etc., and summarize for K. Shenkman for deposition. 2/1/18 KIS Investigation / preparation for T. Winterer deposition. 6.1 2/2/18 KIS Prepare for, travel to/from and attend discovery referee 6.5 hearing on Defendant's motion to compel further responses to special interrogatories, and review rulings from discovery referee concerning document requests. 2/3/18 KIS Travel to/from and meet with G. Ramos and 0. de la Torre 5.4 regarding council member misconduct and campaign finance. 2/5/18 MRH Research regarding mediation privilege and confidentiality, 6.2 and applicability to non -participating members of a governing board; discuss with K. Shenkman 2/5/18 KIS Research regarding availability of multi -member district 7.4 remedies and applicability of equal protection to remedies that treat different districts differently in light of Bush v Gore 2/6/18 KIS Prepare for, travel to/from and attend discovery referee 6.0 hearing regarding subsequent T. Vazquez deposition and Plaintiff's motion to compel further responses to interrogatories. 2/7/18 KIS Investigation / preparation for T. Winterer deposition. 5.9 2/8/18 MRH Research and drafting mediation brief. 9.3 2/8/18 KIS Correspondence and call with K. Scolnick regarding mediation 4.8 and stand -down agreement; research sufficiency of Defendant's proposal regarding same; discussion with J. Krivis regarding mediation scheduling. 2/8/18 AAA Review video obtained from CPRA request 2.2 2/9/18 AAA Finish watching council meeting video and draft time linked 5.3 summary 2/9/18 MRH Research and drafting mediation brief. 8.9 2/9/18 KIS Travel to/from and meet with G. Ramos, 0. de la Torre, A. 4.0 Elmahrek and B. Oreskes regarding campaign finance and council member dealings. 2/10/18 MRH Research and drafting mediation brief. 8.4 2/10/18 KIS Work on mediation brief with M. Hughes, and research 9.5 remedies for potential violation of mediation confidentiality to determine appropriate level of detail to provide to Defendant's counsel in advance of mediation. 2/11/18 MRH Research and drafting mediation brief. 7.8 2/11/18 KIS Work on mediation brief with M. Hughes, and correspondence5.5 with K. Scolnick regarding sneak preview of settlement offer 2/12/18 MRH Research and drafting mediation brief. 7.1 2/12/18 AAA Compile research regarding SM commissioners and send to K. 0.6 Shenkman. 2/12/18 KIS Revise mediation brief and discuss with M. Hughes. 4.7 2/13/18 MRH Revise and finalize mediation brief. 2.8 2/13/18 KIS Travel to/from and meet with R. Tahvildaran-Jesswein 2.5 regarding SMRR and case generally. 2/13/18 KIS Call with R. Rubin regarding settlement authority 0.5 2/14/18 KIS Conversations with clients, co -counsel and interested parties 2.6 to secure buy -in for mediation strategy. 2/15/18 KIS Discussions with clients and co -counsel regarding mediation 3.3 and likely effectiveness of various remedies and range of proposals acceptable to clients. 2/16/18 KIS Prepare for, travel to/from and attend mediation; meeting 8.5 with clients and co -counsel thereafter. 2/16/18 AM Mediation and team meeting 7.1 2/19/18 KIS Evaluate motion for protective order / quash subpoena to 5.0 prevent deposition of M. Leon -Vazquez; research for opposition. 2/20/18 KIS Research and drafting opposition to M. Leon -Vazquez motion 6.6 2/21/18 KIS Research and drafting opposition to M. Leon -Vazquez motion 7.3 2/22/18 KIS Research and drafting opposition to M. Leon -Vazquez motion; 7.1 evaluate second amended ruling from discovery referee regarding RFAs 2/23/18 MRH Revise and finalize opposition to motion for protective order 2.4 regarding M. Leon -Vazquez. 2/23/18 KIS Travel to/from and meet with PNA board regarding mediation, 4.5 settlement and case prospects. 2/25/18 KIS Revise outline and prepare for deposition of T. Winterer 6.3 2/26/18 KIS Prepare for, travel to/from and take deposition of T. Winterer. 10.2 2/27/18 KIS Research propriety of seeking clarification through informal 4.4 means, and draft correspondence to discovery referee regarding amended rulings 2/28/18 KIS Evaluate Defendant's reply in support of its motion to prevent 1.8 deposition of M. Leon -Vazquez, and deal with press aftermath of Defendant's use of article in its reply. 3/1/18 KIS Evaluate correspondence from K. Scolnick evidencing 5.2 Defendant's purpose to use mediation as discovery tool; research regarding what K. Scolnick terms a "coalition theory" in response. 3/2/18 KIS Research regarding what K. Scolnick terms a "coalition 7.0 theory," sufficiency of pleadings to put Defendant on notice, and propriety of Defendant using mediation as a discovery tool. 3/3/18 KIS Research regarding what K. Scolnick terms a "coalition 3.6 theory," sufficiency of pleadings to put Defendant on notice, and propriety of Defendant using mediation as a discovery tool; draft correspondence to K. Scolnick regarding same. 3/5/18 KIS Prepare for discovery referee hearing and discuss with M. 3.5 Grimes. 3/6/18 KIS Prepare for, travel to/from and attend discovery referee 6.9 hearing regarding M. Leon -Vazquez deposition, and discussion with J. Levitt thereafter. 3/7/18 KIS Call with J. Krivis regarding potential second day of mediation 1.1 and handling of discovery in the interim; direct team in light of discussion. 3/8/18 KIS Evaluate discovery referee ruling and direct action in light of 0.9 ruling, and correspondence regarding depositions. 3/8/18 AM Contact M. Quinones -Perez and follow up correspondence 1.2 3/9/18 MRH Discuss discovery referee ruling and Defendant's intent to 5.7 challenge ruling; research regarding procedure for confirming / objecting and authority of discovery referee under CCP. 3/10/18 MRH Research regarding discovery referee authority and procedure 5.0 for turning referee rulings into court orders based on authority for referee appointment and stipulation; discuss with K. Shenkman. 3/10/18 KIS Travel to/from (Santa Clarita) and meet with M. Grimes and R. 3.9 Parris regarding work allocation and case tasks and strategy 3/12/18 KIS Evaluate discovery referee ruling on T. Vazquez subsequent 2.9 deposition, draft correspondence in light of same and research in order to get prompt depositions. 3/13/18 KIS Prepare for second mediation; calls with clients and other 2.8 interested parties regarding settlement authority 3/14/18 KIS Further research regarding available remedies and precedent 6.6 therefor in advance of second mediation, discussion with J. Levitt re same and L. Dilg. 3/15/18 KIS Prepare for, travel to/from and attend second day of 7.4 mediation; team meeting with all counsel thereafter. 3/15/18 AAA Mediation and team meeting 5.0 3/16/18 AAA Contact M. Perez and M. Quinones -Perez to obtain 1.0 cooperation 3/16/18 KIS Work with D. Ely, M. Kousser and J. Levitt on respective 9.8 opinions and reports in light of Defendant's refusal to engage in settlement discussions. 3/19/18 MRH Review correspondence from K. Scolnick; research discovery 4.1 referee authority and procedure in light of issues raised therein; discuss course of action with K. Shenkman 3/19/18 KIS Work with D. Ely and M. Kousser on respective opinions and 9.2 reports in light of Defendant's refusal to engage in settlement discussions. 3/20/18 MRH Work on demographics and election recreation report with D. 6.5 Ely. 3/21/18 MRH Read and summarize T. Winterer deposition transcript for 6.8 team and separate summary for press. 3/21/18 KIS Travel to/from and meet with M. Grimes and W. Ouchi 5.4 regarding work allocation and case generally. 3/22/18 KIS Review correspondence from H. Galloway regarding 1.9 deposition notices and objections, and direct action in response; deal with deposition scheduling and objection issues; draft correspondence regarding same. 3/23/18 AAA Analysis of SM commissioners, current and historical 1.0 3/26/18 AAA Analysis of SM commissioners, current and historical 4.4 3/26/18 KIS Investigation for R. Cole deposition. 7.7 3/26/18 KIS Finalize survey script and discuss sampling with 1. Brown 0.8 3/27/18 MRH Research and drafting ex parte application to confirm 5.3 discovery referee rulings. 3/27/18 KIS Investigate R. Cole role in Pasadena district election campaign, 6.9 political career and actions in Santa Monica; begin preparing outline for R. Cole deposition. 3/28/18 MRH Research and drafting ex parte application to confirm 4.9 discovery referee rulings. 3/28/18 AAA Analysis of SM commissioners, current and historical and 3.7 prepare spreadsheet 3/28/18 KIS Calls with Santa Monica activists concerning R. Cole and 4.8 potential deposition inquiries; preparing outline for deposition and coordinate with W. Ouchi 3/28/18 KIS Call with R. Rubin regarding MSJ 0.3 3/29/18 MRH Read summary judgment papers and discuss with K. Shenkman 3.4 3/29/18 KIS Travel to/from and meet with K. Scolnick and T. Henry 4.9 regarding deposition scheduling and court review of discovery referee rulings in advance of depositions; quick review of MSJ and discuss with M. Hughes and A. Alarcon. 3/30/18 MRH Review discovery referee rulings regarding subsequent 6.8 depositions of T. Vazquez, G. Davis and T. O'Day, and motion to quash deposition subpoena to M. Leon -Vazquez; research and drafting ex parte application to confirm discovery referee rulings. 3/30/18 AAA Revise commissioner study and spreadsheet 1.7 3/30/18 KIS Prepare for, travel to/from and take deposition of R. Cole. 9.9 3/31/18 KIS Evaluate MSJ and associated papers, circulate to experts and 4.5 co -counsel; discuss same and allocation of work for opposition. 3/31/18 MRH Revise ex parte application to confirm discovery referee 3.1 rulings in light of Defendant's counsel's indication they would not comply with objection deadline. 4/1/18 MRH Research issues identified in Defendant's summary judgment 7.0 motion, discuss with K. Shenkman 4/1/18 KIS Review MSJ papers; pull cases and research for opposition; 7.3 coordinate with M. Hughes and R. Rubin. 4/2/18 MRH Research for opposition to MSJ 5.8 4/2/18 AAA Research at SM Library for M. Kousser 9.2 4/2/18 KIS Review and revise ex parte papers to confirm discovery 3.4 referee ruling, correspondence regarding same 4/3/18 AAA Research regarding communications to discovery referee by 4.1 non-parties in response to S. Martini email. 4/3/18 MRH Research for opposition to MSJ 4.8 4/3/18 KIS Prepare for, travel to/from and attend hearing on ex parte 5.9 application to confirm discovery referee rulings. 4/4/18 AAA Research regarding right to distribute discovery materials and 2.6 deposition transcripts absent a court order to the contrary and appropriate response to communication to discovery referee by S. Martini email. 4/4/18 AAA Research at SM Library for M. Kousser, focusing on Prop 3 and 8.5 1975 4/4/18 MRH Research for opposition to MSJ 6.2 4/4/18 KIS Research and work with D. Ely and M. Kousser for opposition 7.8 to MSJ 4/4/18 KIS Correspondence regarding yesterday's ex parte hearing and 0.6 order; evaluate timing and enforcement potential of order. 4/5/18 MRH Research for opposition to MSJ and draft issue memoranda 7.0 4/5/18 AAA Research at SM Library for M. Kousser, focusing on 1975, 9.9 1990, 1991 and 1992, and compile documents for M. Kousser 4/5/18 KIS Research and work with D. Ely and M. Kousser for opposition 9.2 to MSJ 4/5/18 KIS Travel to/from and meet with M. Grimes and W. Ouchi to 4.4 allocate work and case strategy generally 4/6/18 MRH Research for opposition to MSJ and draft issue memoranda 7.4 4/6/18 KIS Work on materials that will be necessary for summary 8.3 judgment opposition, meet with M. Grimes and talk with J. Levitt (separately) to coordinate same. 4/6/18 KIS Evaluate Defendant's objection to discovery referee ruling 2.9 regarding M. Leon -Vazquez deposition; communicate with press regarding Defendant's complaint that we communicate with the press. 4/7/18 KIS Call with R. Rubin regarding MSJ 0.3 4/9/18 MRH Research for opposition to MSJ and draft issue memoranda 6.5 4/9/18 AAA Compile research regarding intent analysis for M. Kousser and 4.8 K. Shenkman 4/9/18 KIS Research and work with D. Ely and M. Kousser for opposition 8.4 to MSJ 4/10/18 MRH Research, draft and revise opposition to ex parte application. 6.7 4/10/18 KIS Research and drafting opposition to ex parte application for 7.9 reconsideration. 4/10/18 KIS Call with J. Levitt regarding MSJ opposition. 0.6 4/11/18 MRH Research for opposition to MSJ and draft issue memoranda 7.6 and outline opposition sections. 4/11/18 KIS Prepare for, travel to/from and attend hearing on ex parte 6.2 application for reconsideration of court's confirmation of discovery referee rulings. 4/11/18 KIS Call with M. Kousser regarding ER and El results and RPV 0.5 analysis and needed work on intent and impact analysis 4/12/18 MRH Research for opposition to MSJ and draft issue memoranda 7.8 4/12/18 KIS Research regarding timing of MSJ and consequences of late 8.3 filing or improper service and work on opposition to MSJ 4/12/18 AAA Research at SM Library, focusing on 2002 and election method 7.1 proposition 4/13/18 AAA Research at SM Library, focusing on 2002 and election method 8.9 proposition; compile research for M. Kousser and K. Shenkman; meet with potential witness regarding ballot proposition 4/13/18 MRH Research for opposition to MSJ and draft issue memoranda 7.5 4/13/18 KIS Research regarding timing of MSJ and consequences of late 6.9 filing or improper service and procedure for addressing same without waiving defect. 4/14/18 KIS Research and drafting motions in limine 5.5 4/15/18 KIS Research and drafting motions in limine 6.3 4/16/18 MRH Discuss potential motions in limine with K. Shenkman and 6.8 research for same. 4/16/18 AAA Compile and prepare materials for meeting, meet with K. 6.7 Shenkman and M. Kousser 4/16/18 KIS Travel to/from and meet with M. Kousser and A. Alarcon 7.0 regarding intent case 4/16/18 KIS Research and drafting response to Defendants objection to 6.4 discovery referee ruling regarding M. Leon -Vazquez deposition. 4/17/18 MRH Research for potential motions in limine 7.4 4/17/18 KIS Research and drafting response to Defendant's objection to 5.5 discovery referee ruling regarding M. Leon -Vazquez deposition. 4/17/18 KIS Prepare sample responses to interrogatories and RFAs to PNA 2.1 and M. Loya, and discuss same with E. Gordon. 4/17/18 AM Contact potential witness regarding T. Vazquez funding. 0.2 4/17/18 AM Review M. Kousser 1992 report and cross-reference to recent 1.7 research and materials 4/18/18 MRH Research for potential motions in limine; draft memorandum 8.9 summarizing potential motions in limine. 4/18/18 KIS Research and drafting response to Defendant's objection to 3.9 discovery referee ruling regarding M. Leon -Vazquez deposition. 4/19/18 MRH Research for potential motions in limine; draft memorandum 6.6 summarizing potential motions in limine. 4/19/18 AM Research regarding 1946 SM and freeholders 2.2 4/19/18 KIS Research and drafting response to Defendant's objection to 4.3 discovery referee ruling regarding M. Leon -Vazquez deposition and associated papers. 4/20/18 MRH Revise and finalize response papers regarding M. Leon- 2.8 Vazquez deposition. 4/20/18 AAA Research at SM Library, focusing on 1946 charter and source 9.7 materials. 4/20/18 KIS Revise response to objection to discovery referee ruling. 2.4 4/21/18 KIS Investigate P. O'Connor votes, campaigns and finances; talk 7.3 with constituents re same. 4/22/18 KIS Further investigate P. O'Connor for deposition; draft outline 7.9 for deposition. 4/23/18 KIS Travel to/from and attend deposition of P. O'Connor, and case 10.8 meeting thereafter. 4/23/18 AAA Review and organize research documents from SM Library for 3.6 M. Kousser and K. Shenkman 4/24/18 MRH Work with D. Ely on report for MSJ opposition. 7.1 4/24/18 KIS Research and drafting opposition to MS1 6.9 4/24/18 KIS Evaluate survey results and crosstabs and discuss with J. 2.9 Brown 4/25/18 MRH Work with M. Kousser on report for MS1 opposition. 8.7 4/25/18 KIS Research and drafting opposition to MSJ 7.5 4/26/18 MRH Work with M. Kousser on report for MSJ opposition. 8.3 4/26/18 KIS Research and drafting opposition to MSJ 7.4 4/27/18 MRH Work with M. Kousser on report for MS1 opposition. 8.0 4/27/18 KIS Read and summarize transcript of O'Connor deposition, 5.9 communicate with press regarding O'Connor business 4/30/18 KIS Travel to/from and meet with A. Sanchez, D. Ely and A. Alarcon 3.7 in Sherman Oaks regarding Vazquez shakedown of labor unions and case generally. 4/30/18 AAA Meeting with D. Ely, K. Shenkman and A. Sanchez 2.5 5/1/18 KIS Evaluate correspondence from K. Scolnick regarding M. Leon- 3.8 Vazquez deposition, discovery referee ruling and Defendant's objection; research and draft correspondence in response. 5/2/18 KIS Deposition preparation with 0. de la Torre and M. Loya 6.6 5/3/18 KIS Research and drafting ex parte application to confirm 5.2 discovery referee ruling / advance hearing date for objection regarding discovery referee ruling regarding M. Leon -Vazquez deposition. 5/4/18 MRH Read Defendant's motion to stay, discuss with K. Shenkman 4.6 and begin formulating response. 5/4/18 KIS Deposition preparation with 0. de la Torre 4.9 5/4/18 KIS Evaluate Defendant's motion to stay deposition of M. Leon- 3.5 Vazquez; discuss response with M. Hughes. 5/5/18 KIS Research and drafting ex parte application to confirm 4.8 discovery referee ruling / advance hearing date for objection regarding discovery referee ruling regarding M. Leon -Vazquez deposition. 5/6/18 MRH Research and drafting opposition to motion to stay M. Leon- 6.1 Vazquez deposition. 5/6/18 KIS Research and drafting opposition papers to MSJ, coordinate 9.6 with M. Kousser re same and report 5/7/18 MRH Research and drafting opposition to motion to stay M. Leon- 4.2 Vazquez deposition. 5/7/18 KIS Research and drafting ex parte application to confirm 3.8 discovery referee ruling / advance hearing date for objection regarding discovery referee ruling regarding M. Leon -Vazquez deposition. 5/8/18 MRH Research and drafting opposition to motion to stay M. Leon- 5.1 Vazquez deposition. 5/8/18 KIS Deposition preparation with 0. de la Torre 4.5 5/9/18 MRH Work with D. Ely on report for MSJ opposition, review P. 6.7 Morrison declaration and determine whether deposition is warranted. 5/9/18 KIS Travel to/from and defend deposition of 0. de la Torre, 11.7 meeting with 0. de la Torre thereafter. 5/10/18 KIS Research and drafting ex parte application to confirm 5.4 discovery referee ruling / advance hearing date for objection regarding discovery referee ruling regarding M. Leon -Vazquez deposition. 5/10/18 KIS Correspondence with Defendant's counsel regarding 1.0 deposition scheduling and ex parte. 5/11/18 MRH Research for MSJ opposition 6.6 5/11/18 KIS Prepare for and travel to hearing on ex parte application 4.0 regarding discovery referee ruling and objection thereto 5/11/18 KIS Defend PMK deposition of PNA, and travel from. 6.7 5/12/18 MRH Work with M. Kousser on report for MS.1 opposition. 9.2 5/12/18 KIS Research and drafting opposition to MSJ and supporting 9.0 papers. 5/13/18 MRH Research and drafting separate statement response for 8.4 opposition to MSJ. 5/13/18 KIS Research and drafting opposition to MSJ, discuss same with J. 8.3 Levitt. 5/14/18 MRH Research and drafting opposition and separate statement 7.5 response for opposition to MSJ. 5/14/18 KIS Research and drafting opposition to MSJ, coordinate with D. 8.9 Ely to get necessary information and analysis to J. Levitt. 5/14/18 KIS Deposition preparation with M. Loya, and back -and -forth with 7.9 Defendant's counsel regarding various deposition and discovery matters. 5/15/18 MRH Research and drafting opposition and separate statement 7.0 response for opposition to MSJ. 5/15/18 KIS Travel to/from and defend deposition of M. Loya, meeting 10.9 with 0. de la Torre and M. Loya and call with J. Levitt thereafter 5/16/18 MRH Work on MSJ opposition papers 7.7 5/16/18 KIS Research and drafting opposition to MSJ and supporting 10.4 declarations; call with S. Ferias regarding experiences in San Juan Capistrano and willingness to submit declaration. 5/17/18 MRH Discuss experts with K. Shenkman and desirability of 1.0 requesting exchange; draft expert witness exchange demand. 5/17/18 AAA Work with M. Kousser and D. Ely on their respective reports 5.5 5/18/18 AAA Research for M. Kousser at SM Library 4.8 5/18/18 MRH Work on MSJ opposition declarations. 10.3 5/20/18 KIS Travel to/from and participate in tour of Santa Monica for trial 7.1 preparation 5/21/18 MRH Work on MS.1 opposition papers 5.9 5/21/18 KIS Work with M. Kousser on his report and put together source 6.2 materials for report. 5/21/18 KIS Research and drafting opposition to MS.1 4.4 5/22/18 MRH Work on MSJ opposition papers 5.7 5/22/18 AM Research at SM Library for M. Kousser 7.2 5/22/18 KIS Research and drafting opposition to MSJ and discuss same 6.5 with J. Levitt and R. Rubin 5/22/18 KIS Deal with various discovery issues and correspondence 0.9 regarding same. 5/23/18 MRH Work on MSJ opposition papers 8.3 5/23/18 AAA Research at SM Library for M. Kousser 9.7 5/23/18 KIS Prepare for, travel to/from and attend hearing on Defendant's 10.3 objection to discovery referee ruling, prepare opposition documents for continued hearing thereafter. 5/23/18 KIS Deal with various discovery issues and correspondence 2.6 regarding same; draft exemplary responses to RFPs regarding expert survey. 5/23/18 KIS Work on summary judgment opposition and discuss with J. 1.0 Levitt. 5/24/18 MRH Work on MSJ opposition papers 9.5 5/24/18 AAA Research at SM Library for M. Kousser 8.3 5/24/18 KIS Research and drafting opposition to MSJ 10.6 5/24/18 KIS Deal with various discovery issues and correspondence 1.3 regarding same; draft exemplary responses to RFPs regarding expert survey. 5/25/18 MRH Work on MSJ opposition papers 7.8 5/25/18 AM Conference call with R. Martinez; research Prop. 14, Caucasian 6.8 clauses in SM and newspaper evidence of racist attitudes in SM 5/25/18 KIS Call with R. Martinez for guidance on equal protection case. 1.5 5/25/18 KIS Research and drafting opposition to MS1 7.0 5/25/18 KIS Deal with various discovery issues and correspondence 1.0 regarding same; draft exemplary responses to RFPs regarding expert survey. 5/26/18 MRH Work on MSJ opposition papers 6.9 5/26/18 AAA Research at SM Library for M. Kousser 5.3 5/26/18 KIS Review FPPC issue and press coverage and G. Davis deposition 4.9 transcript and summary; prepare outline; call regarding questioning for deposition. 5/26/18 KIS Research and drafting opposition to MSJ 6.4 5/27/18 MRH Work on MSJ opposition papers 9.2 5/27/18 KIS Research and drafting opposition to MSJ 10.5 5/28/18 MRH Work on MSJ opposition papers 5.6 5/28/18 AAA Research at SM Library for M. Kousser 5.5 5/28/18 KIS Research and drafting opposition to MSJ 11.2 5/29/18 MRH Work on MSJ opposition papers 5.8 5/29/18 AAA Work on report with M. Kousser 11.4 5/29/18 KIS Revise opposition to MSJ and associated papers. 7.4 5/29/18 KIS Review FPPC issue and press coverage and G. Davis deposition 3.5 transcript and summary; prepare outline; call regarding questioning for deposition. 5/30/18 MRH Work on MSJ opposition papers 10.5 5/30/18 AAA Work on Kousser report and MSJ opposition. 15.1 5/30/18 KIS Revise and finalize opposition to MSJ and associated papers 16.2 and discuss with co -counsel 5/31/18 KIS Prepare for, travel to/from and attend hearing on Defendant's 5.0 motion to reverse discovery referee ruling regarding M. Leon - Vazquez. 5/31/18 KIS Finalize and transmit (consistent with order of the court at 4.9 hearing earlier in the day) opposition to motion for summary judgment. 6/1/18 MRH Work on motions in limine. 7.2 6/1/18 KIS Correspondence and deal with continuing deposition issues. 0.8 6/1/18 KIS Evaluate Defendant's motion for sanctions, confer with clients 3.9 regarding same, address briefing schedule 6/2/18 MRH Work on motions in limine 5.3 6/2/18 KIS Research and drafting opposition to motion for sanctions. 7.6 6/3/18 KIS Research and drafting opposition to motion for sanctions and 8.2 associated papers. 6/4/18 MRH Research and drafting motions to compel: 1) deposition of M. 5.4 Quinones -Perez, and 2) production of documents re P. O'Connor 6/4/18 KIS Research regarding necessity of providing editable version of 0.4 separate statement and timing for doing so. 6/4/18 KIS Research and drafting opposition to motion for sanctions and 6.1 associated papers. 6/5/18 MRH Research regarding depositions of MSJ opposition expert 2.5 declarants and timing thereof, discuss with K. Shenkman to determine response to T. Henry. 6/5/18 KIS Deposition preparation with 0. de Ia Torre and gather 5.9 documents for production at deposition 6/5/18 KIS Research and drafting opposition to sanctions motion. 4.4 6/6/18 MRH Work on motions to compel deposition of M. Quinones -Perez 3.9 and document production from Kaplan Chen Kaplan. 6/6/18 KIS Travel to/from and defend deposition of PNA PMK (vol. 2) 7.0 6/7/18 MRH Research and draft objections to reply papers on MSJ 4.3 6/7/18 KIS Santa Monica tour with photographer, M. Grimes and 0. de Ia 7.1 Torre for opening 6/7/18 KIS Review Defendant's reply papers re MSJ; research and draft 3.8 objection to reply separate statement and reply declaration of P. Morrison, and draft notice of errata 6/8/18 MRH Research and drafting trial brief; discuss with K. Shenkman 6.3 6/8/18 KIS Formulate rough outline for trial brief and discuss allocation 2.9 with M. Hughes 6/8/18 KIS Revise and finalize notice of errata, and objections to reply 1.5 papers on Si motion. 6/8/18 KIS Review, revise and finalize motion to compel deposition of M. 3.5 Quinones -Perez and motion to compel production of documents from Kaplan Chen Kaplan. 6/9/18 MRH Work on opposition to motion for sanctions. 4.0 6/9/18 KIS Research and drafting opposition to sanctions motion. 8.2 6/10/18 MRH Work on opposition to motion for sanctions. 3.8 6/10/18 KIS Research and drafting opposition to sanctions motion. 6.6 6/11/18 MRH Work on opposition to motion for sanctions. 4.7 6/11/18 KIS Research and drafting opposition to sanctions motion. 7.5 6/11/18 KIS Drafting expert witness exchange documents, discuss with 6.3 experts, and reviewing same from Defendant; deal with Defendant's gripe about timing and manner of exchange 6/11/18 KIS Travel to/from and speak at N.E. Neighbors meeting regarding 4.0 case generally. 6/12/18 MRH Research regarding need for subpoenas for non-profit board 2.2 members of a party litigant. 6/12/18 MRH Research and drafting trial brief 6.4 6/12/18 KIS Review MSJ papers and prepare for hearing. 5.0 6/12/18 KIS Research and drafting opposition to motion for sanctions. 3.9 6/12/18 KIS Deal with deposition notices and scheduling of PNA board 0.7 members; discuss with M. Hughes. 6/12/18 KIS Investigate Defendant's experts and prepare for expert 2.0 depositions 6/12/18 KIS Research regarding discovery referee authority to control 1.5 schedule; correspondence regarding motion scheduling. 6/13/18 MRH Review and revise papers in opposition to motion for 3.3 sanctions. 6/13/18 AAA Review summary judgment papers and prepare for hearing. 1.8 6/13/18 KIS Revise and finalize opposition and supporting papers on 2.0 sanctions motion. 6/13/18 KIS Research and drafting section of trial brief. 4.9 6/13/18 KIS Evaluate Defendant's response to objections to reply papers, 4.4 and prepare for MSJ hearing. 6/14/18 MRH Research and drafting trial brief 5.6 6/14/18 AA Summary judgment hearing and conference with co -counsel. 5.0 6/14/18 KIS Prepare for, travel to/from hearing on MSJ; meeting with J. 13.6 Levitt thereafter; talk with local press, clients and community activists thereafter; research regarding 473 motions and waiver of untimely MSJ. 6/14/18 KIS Prepare E. Gordon for deposition of T. O'Day. 0.9 6/14/18 KIS Correspondence regarding scheduling of motion re M. 0.3 Quinones -Perez 6/15/18 MRH Review Defendant's "motion to reject Plaintiffs' argument"; 4.5 research for opposition; discuss with K. Shenkman 6/15/18 AAA Review Defendant's 473 motion and discuss with K. Shenkman 0.8 6/15/18 KIS Correspondence regarding scheduling of motion re M. 2.4 Quinones -Perez; research regarding timing and service on non- party witness represented by counsel who has made an appearance 6/15/18 KIS Research and drafting opposition to Defendant's (sorta) 473 5.8 motion 6/15/18 KIS Research regarding expert discovery timing 0.9 6/16/18 MRH Research and drafting section of opposition to Defendant's 6.8 "motion to reject Plaintiffs' argument" 6/16/18 KIS Research and drafting opposition to Defendant's (sorta) 473 10.7 motion 6/16/18 KIS Research regarding demand for electronic files created by 2.5 attorney, in response to informal demand from K. Scolnick. 6/17/18 AAA Research regarding Defendant's 473 motion and excusable 2.9 neglect standard, discuss with K. Shenkman 6/17/18 MRH Research and drafting opposition to Defendant's "motion to 7.4 reject Plaintiffs' argument" 6/17/18 KIS Research, draft, revise opposition to Defendant's (sorta) 473 6.3 motion 6/17/18 KIS Deposition preparation with B. Onofre 4.9 6/17/18 KIS Correspondence regarding deposition locations of B. Onofre 0.2 and M. Leon -Vazquez 6/18/18 MRH Revise and finalize opposition to Defendant's "motion to reject3.5 Plaintiffs' argument"; review Adler declaration regarding failure to timely file 473 motion and discuss with K. Shenkman. 6/18/18 KIS Revise opposition to Defendant's (sorta) 473 motion and 5.8 file/deliver personally at the request of the court; review amusing Adler declaration about how he couldn't walk 3 blocks to deliver 473 motion so it was not timely filed. 6/18/18 KIS Deposition preparation with B. Onofre 1.8 6/18/18 KIS Correspondence regarding deposition locations of B. Onofre 0.3 and M. Leon -Vazquez 6/18/18 KIS Deal with expert deposition scheduling. 0.7 6/19/18 MRH Work on trial brief 2.5 6/19/18 AAA Compile and summarize cases regarding 473 and Si timing for 6.8 hearing; attend hearing on Defendant's 473 motion. 6/19/18 KIS Prepare for, travel to/from and attend hearing on Defendant's 8.9 (sorta) 473 motion and deposition of B. Onofre. 6/19/18 KIS Travel to/from and speak at Mid -City Neighborhood Assn 3.6 meeting. 6/19/18 KIS Investigate Defendant's experts and prepare for expert 3.2 depositions 6/20/18 MRH Work on trial brief 6.7 6/20/18 KIS Evaluate Defendant's reply in support of motion for sanctions 3.5 and prepare for hearing. 6/20/18 KIS Investigate Defendant's experts and prepare for expert 4.1 depositions. 6/20/18 KIS Investigate and review materials on Vazquezes and prepare for 3.3 deposition of T. Vazquez and M. Leon -Vazquez 6/21/18 MRH Work on motions in limine 4.0 6/21/18 MRH Review Defendant's reply in support of motion for sanctions; 2.5 research prompted by reply; discuss with K. Shenkman 6/21/18 MRH Research regarding timing and scope of supplemental expert 4.7 designations and discuss with K. Shenkman 6/21/18 KIS Evaluate reply in support of sanctions motion; discuss with M. 3.8 Hughes for hearing preparation 6/21/18 KIS Review materials on Vazquezes and prepare for deposition of 2.3 T. Vazquez and M. Leon -Vazquez 6/21/18 KIS Investigate Defendant's experts and prepare for expert 3.6 depositions. 6/21/18 KIS Work on trial brief 2.0 6/21/18 KIS Evaluate "supplemental" expert designation; research 4.1 regarding propriety of supplementation of expert designation; discuss with M. Hughes. 6/22/18 MRH Review motion to compel further responses to thousands of 2.6 discovery requests, and associated documents; discuss with K. Shenkman. 6/22/18 MRH Investigate supplemental expert of Defendant 6.5 6/22/18 KIS Evaluate motion to compel filed by Defendant on last set of 3.0 discovery; discuss with E. Gordon and M. Hughes (separately); correspondence regarding briefing and hearing schedule. 6/22/18 KIS Work on trial brief 2.8 6/22/18 KIS Investigate Defendant's experts and prepare for expert 3.1 depositions. 6/22/18 KIS review materials on Vazquezes and prepare for deposition of 3.2 T. Vazquez. 6/22/18 KIS Deal with / correspondence regarding T. Vazquez refusal to 0.9 appear for court -ordered deposition; draft and serve deposition notices for R. Miller and A. Sanchez to address T. Vazquez refusal to be deposed. 6/22/18 KIS Evaluate KCK opposition to motion to compel documents and 1.0 discuss with E. Gordon. 6/23/18 MRH Research regarding exclusion of late -designated experts and 7.2 scope of testimony if not excluded altogether. 6/23/18 KIS Investigate Defendant's experts and prepare for expert 8.5 depositions. 6/23/18 KIS Work on trial brief 1.7 6/24/18 MRH Research regarding exclusion of late -designated experts and 7.6 scope of testimony if not excluded altogether; draft motion outline. 6/24/18 KIS Investigate Defendant's experts and prepare for expert 8.8 depositions. 6/24/18 KIS Work on trial brief 1.1 6/24/18 KIS Deal with deposition and discovery motion scheduling, 1.5 correspondence regarding same. 6/25/18 MRH Investigate Defendant's experts, review prior opinions, 9.3 testimony and reports. 6/25/18 KIS Travel to/from deposition (no-show) of T. Vazquez; meeting 8.9 with Parris lawyers and staff regarding pretrial tasks. 6/25/18 KIS Deposition preparation with J. Blake 1.2 6/25/18 KIS Review and revise reply in support of motion to compel 4.1 documents from KCK 6/25/18 KIS Correspondence back and forth regarding scheduling of 1.0 Defendant's motion to compel its thousands of discovery requests, and the untimeliness of its motion. 6/25/18 KIS Evaluate Defendant's responses to discovery requests. 1.9 6/26/18 MRH Review expert documents and prepare for production 4.3 6/26/18 MRH Investigate Defendant's experts and supplemental expert 5.0 6/26/18 KIS Work on trial brief 5.4 6/26/18 KIS Deposition preparation with M. Kousser 5.9 6/26/18 KIS Correspondence regardingi Schloss deposition untimeliness; 3.7 research regarding consequences of untimeliness and procedure for addressing same; and discuss need for motion for protective order with D. Williams 6/27/18 MRH Work on trial brief 7.0 6/27/18 AM Preparing trial exhibits 3.8 6/27/18 MRH Review expert documents and prepare for production. 3.6 6/27/18 KIS Deposition preparation with G. de Baca 1.6 6/27/18 KIS Investigate M. Leon -Vazquez and prepare for her deposition. 4.5 6/27/18 KIS Work on trial brief 4.7 6/27/18 KIS Correspondence with discovery referee regarding scheduling 0.9 and availability of arguments on motion to compel. 6/28/18 MRH Research and drafting motion for sanctions for T. Vazquez 8.9 failure to appear for court -ordered deposition 6/28/18 MRH Review expert documents and prepare for production. 2.6 6/28/18 KIS Prepare for, travel to/from and attend discovery referee 6.2 hearing on motion for sanctions and motion to compel documents from KCK 6/28/18 KIS Correspondence concerning disputes regarding Schloss, 2.0 Sanchez and Miller depositions, and research same. 6/28/18 KIS Investigate M. Leon -Vazquez and prepare for her deposition; 3.9 discuss with M. Grimes 6/29/18 MRH Research and drafting motion for sanctions for T. Vazquez 8.5 failure to appear for court -ordered deposition 6/29/18 AAA Preparing trial exhibits 5.7 6/29/18 KIS Prepare for, travel to/from and attend/take deposition of M. 10.8 Leon -Vazquez 6/29/18 KIS Evaluate opposition to motion to compel deposition of M. 1.4 Quinones -Perez; discuss with E. Gordon. 6/29/18 KIS Call with J. Levitt in preparation for deposition. 0.5 6/30/18 MRH Research and drafting motion for sanctions for T. Vazquez 5.7 failure to appear for court -ordered deposition 6/30/18 MRH Review documents produced by Defendant on June 29 6.0 6/30/18 KIS Evaluate correspondence from C. Villegas to discovery referee; 4.3 research authority of discovery referee over third -parties in response thereto and discuss with E. Gordon how to proceed. 6/30/18 KIS Deposition preparation with C. McLeod 4.9 6/30/18 KIS Research and drafting part of motion to quash deposition 3.5 subpoena of J. Schloss 7/1/18 MRH Review documents produced by Defendant on June 29 5.0 7/1/18 MRH Research and drafting motion for sanctions for T. Vazquez 5.8 failure to appear for court -ordered deposition 7/1/18 KIS Work with R. Holbrook friends and family to get declaration, 2.2 revise declaration accordingly. 7/1/18 KIS Research and drafting motion to strike Lichtman designation 8.4 7/1/18 KIS Review, research and revise motion to quash J. Schloss 1.9 subpoena. 7/2/18 MRH Review documents produced by Defendant on June 29 5.7 7/2/18 MRH Research and drafting motion for sanctions for T. Vazquez 4.2 failure to appear for court -ordered deposition 7/2/18 KIS Deposition preparation with J. Brown 3.0 7/2/18 KIS Travel to/from SM and procure signature on R. Holbrook 2.0 statement. 7/2/18 KIS Work on trial brief. 3.8 7/2/18 KIS Research and drafting motion to strike Lichtman designation 4.4 7/2/18 KIS Work on reply in support of motion to compel deposition of 1.7 M. Quinones -Perez and discuss same with E. Gordon 7/3/18 MRH Review documents produced by Defendant on June 29 5.9 7/3/18 MRH Research regarding effect of motion to quash on pending 2.8 scheduled deposition and need (or lack thereof) to specifically seek a stay of the deposition. 7/3/18 MRH Research and drafting motion for sanctions for T. Vazquez 3.6 failure to appear for court -ordered deposition 7/3/18 AAA Gather evidence for M. Kousser and prepare exhibits. 2.1 7/3/18 KIS Travel to/from and meet with D. Ely, T. Crane and M. Grimes 6.6 regarding remedial map etc.; review P. Morrison report with D. Ely and prepare outline of P. Morrison deposition. 7/3/18 KIS Research and drafting motion to strike Lichtman designation 3.8 7/3/18 KIS Review writ petition challenging denial of MSJ, formulate 3.1 response 7/3/18 KIS Deal with C. Villegas refusal to attend scheduled discovery 0.3 referee hearing. 7/3/18 KIS Review and revise reply in support of motion to compel 2.1 deposition of M. Quinones -Perez 7/4/18 MRH Review documents produced by Defendant on June 29 4.5 7/4/18 KIS Research and drafting motion to strike Lichtman designation 2.9 7/4/18 KIS Research and drafting delighted letter in response to writ 4.2 petition challenging denial of MSJ 7/4/18 KIS Review Morrison documents and prepare for his deposition. 5.7 7/5/18 MRH Meeting with D. Ely and M. Grimes 6.4 7/5/18 MRH Review, revise motion to strike supplemental expert 2.3 designation 7/5/18 KIS Prepare for, travel to/from and attend hearing with discovery 7.5 referee regarding M. Quinones -Perez motion and other matters such as Kousser deposition and Lichtman deposition / improper designation; and attend/defend deposition of J. Brown. 7/5/18 KIS Travel to/from and meet with D. Ely and M. Grimes to prepare 4.5 Ely testimony 7/5/18 KIS Research and drafting delighted letter in opposition to writ 3.3 petition 7/5/18 KIS Call with R. Rubin re: trial and witnesses 0.8 7/5/18 KIS Investigate Defendant's experts and prepare for depositions. 2.9 7/6/18 MRH Research and drafting ex parte to shorten time on T. Vazquez 6.8 sanctions motion. 7/6/18 MRH Research and drafting opposition to motion to compel 4.5 responses to Defendant's last set of thousands of discovery requests. 7/6/18 AAA Preparing trial exhibits 3.3 7/6/18 KIS Investigate Defendant's experts and prepare for depositions; 2.5 review Lewis documents 7/6/18 KIS Research and revise ex parte applications regarding Lichtman 3.0 and Vazquez, discuss with R. Parris 7/6/18 KIS Research and drafting opposition to ex parte to exclude 9.6 Kousser testimony; correspondence with K. Scolnick to figure out what basis for excluding Kousser might be. 7/7/18 MRH Research and drafting section of ex parte opposition regarding 5.9 Kousser discriminatory intent analysis. 7/7/18 MRH Review documents produced by Defendant on June 29 4.8 7/7/18 AAA Preparing trial exhibits 5.0 7/7/18 KIS Investigate Defendant's experts and prepare for depositions. 4.6 7/7/18 KIS Research and drafting opposition to ex parte to exclude 8.4 Kousser testimony. 7/8/18 MRH Research, draft and revise opposition to motion to compel 2.8 responses to Defendant's last set of thousands of discovery requests. 7/8/18 MRH Research and revise opposition to Kousser ex parte application 3.9 7/8/18 MRH Review documents produced by Defendant on June 29 2.7 7/8/18 AM Preparing trial exhibits 6.2 7/8/18 KIS Investigate Defendant's experts and prepare for depositions. 3.5 7/8/18 KIS Revise and finalize delighted letter in opposition to writ 1.0 petition regarding denial of MSJ 7/8/18 KIS Research and drafting opposition to ex parte to exclude 7.2 Kousser testimony. 7/9/18 MRH Revise and finalize opposition to motion to compel responses 3.3 to Defendant's last set of thousands of discovery requests. 7/9/18 MRH Review documents produced by Defendant on June 29 4.0 7/9/18 MRH Prepare M. Kousser for deposition 5.4 7/9/18 AAA Preparing trial exhibits 6.9 7/9/18 KIS Prepare for, travel to and attend hearing on various ex parte 4.7 applications regarding Lichtman, Vazquez and Kousser. 7/9/18 KIS Prepare for, travel to/from, attend/take deposition of P. 10.2 Morrison. 7/10/18 MRH Review and revise motions in limine, discuss with K. Shenkman 3.5 advisability of multiple motions in limine 7/10/18 MRH Review documents produced by Defendant on June 29 2.9 7/10/18 AAA Final review of exhibits, work with M. Cussimonio to prepare 4.8 for trial. 7/10/18 KIS Revise and finalize motion in limine regarding exogenous and 2.8 all -white elections, discuss other motions in limine with M. Hughes and potential for raising issues in other manners. 7/10/18 KIS Prepare for Lewis deposition, discuss with J. Levitt. 7.1 7/10/18 KIS Call with R. Rubin re: trial 0.6 7/10/18 KIS Deposition preparation with D. Ely 3.5 7/11/18 MRH Research and drafting opposition to motion to exclude Kousser8.5 testimony 7/11/18 MRH Read Defendant's reply in support of its writ petition and 0.8 discuss with K. Shenkman. 7/11/18 KIS Evaluate Defendant's reply to delighted letter regarding writ 1.2 petition, discuss with M. Hughes, and research regarding propriety of reply. 7/11/18 KIS Prepare for, travel to/from and take deposition of Jeffrey 11.0 Lewis, call with R. Rubin re: same thereafter 7/11/18 KIS Research and drafting opposition to motion to exclude Kousser4.0 testimony 7/12/18 M RH Research and drafting oppositions to motions in limine 7.2 7/12/18 KIS Prepare for, travel to/from and attend hearing with discovery 9.0 referee on Lichtman motion; attend/defend deposition of D. Ely 7/12/18 KIS Research and drafting oppositions to motions in limine, 4.1 including Kousser motion 7/12/18 KIS Deposition preparation with M. Kousser 3.0 7/12/18 KIS Short call with J. Levitt to ensure preparation for deposition. 0.3 7/12/18 KIS Evaluate 2DCA order denying Defendant's writ petition; send 0.2 to local press 7/13/18 MRH Research and drafting oppositions to motions in limine 11.9 7/13/18 KIS Research and drafting oppositions to motions in limine, 4.3 including Kousser motion; personally file Kousser opposition 7/13/18 KIS Travel to/from and attend Levitt deposition. 6.0 7/13/18 KIS Deposition preparation with M. Kousser 2.9 7/13/18 KIS Evaluate Defendant's replies in support of its sanctions motion4.4 and motion to compel further responses to its thousands of discovery requests and prepare outline of argument for hearing. 7/14/18 MRH Research and drafting oppositions to motions in limine 8.9 7/14/18 KIS Research and drafting oppositions to motions in limine 3.5 7/14/18 KIS Travel to/from and attend/defend Kousser deposition. 9.7 7/14/18 KIS Investigate and prepare for deposition of A. Lichtman; review 3.3 documents produced by Lichtman 7/14/18 KIS Evaluate discovery referee ruling and discuss strategy in 0.3 response with M. Hughes. 7/15/18 MRH Research and drafting oppositions to motions in limine 9.8 7/15/18 KIS Research and drafting oppositions to motions in limine 8.5 7/15/18 KIS Investigate and prepare for deposition of A. Lichtman; review 6.4 documents produced by Lichtman 7/16/18 MRH Revise and finalize oppositions to motions in limine 3.5 7/16/18 KIS Revise and research oppositions to motions in limine, discuss 4.3 with J. Levitt 7/16/18 KIS Review discovery referee rulings regarding KCK documents 0.4 and Lichtman designation, and coordinate with E. Gordon to get and review documents. 7/16/18 KIS Prepare for, travel to/from and attend/take deposition of A. 10.9 Lichtman 7/16/18 KIS Trial prep and work on witness list and exhibit list 5.5 7/17/18 MRH Work on trial brief and trial preparation 11.4 7/17/18 KIS Prepare for, travel to/from and attend discovery referee 7.2 hearing on Defendant's motion to compel final discovery request responses, Plaintiffs' motion for sanctions for T. Vazquez no-show, and scope of Lichtman testimony. 7/1.7/18 KIS Evaluate reply in support of Defendant's motion to exclude 3.4 Kousser intent testimony; discuss with M. Kousser and deposition preparation with M. Kousser for second day of deposition 7/17/18 KIS Trial prep and work on witness list and exhibit list 5.0 7/18/18 MRH Work on trial brief and trial preparation 5.7 7/18/18 MRH Research and drafting letter brief regarding scope of Lichtman 6.1 testimony 7/18/18 KIS Review motions in limine and other papers and prepare for 4.5 final status conference. 7/18/18 KIS Calls with M. Kousser regarding deposition 0.6 7/19/18 MRH Work on trial brief and trial preparation 12.1 7/19/18 KIS Prepare for, travel to/from and attend final status conference, 8.3 meeting with team thereafter. 7/19/18 KIS Trial prep 3.9 7/19/18 KIS Research and drafting letter brief regarding scope of Lichtman 5.8 testimony 7/20/18 MRH Work on trial brief and trial preparation 10.6 7/20/18 KIS Research, draft, revise letter brief regarding scope of Lichtman 5.9 testimony 7/20/18 KIS Trial prep 7.7 7/20/18 KIS Review discovery referee ruling regarding M. Quiniones-Perez 0.2 and coordinate with E. Gordon to secure deposition attendance. 7/21/18 MRH Work on trial brief and trial preparation 10.6 7/21/18 KIS Prepare and deliver letter brief regarding scope of Lichtman 4.5 testimony 7/21/18 KIS Trial prep 9.8 7/22/18 MRH Work on trial brief and trial preparation 8.4 7/22/18 KIS Trial prep (read depositions and prepare witness outlines) and 11.2 revise trial brief, discuss with J. Levitt 7/23/18 MRH Work on trial brief and trial preparation 9.8 7/23/18 AAA Review 1992 council video; prepare transcript of key portions 7.9 and timestamps of suggested clips for trial 7/23/18 KIS Trial prep (read depositions, prepare witness outlines, prepare 12.6 opening) 7/23/18 KIS Evaluate discovery referee rulings on various issues/motions 0.9 and coordinate appropriate response. 7/24/18 MRH Work on trial brief and trial preparation 7.6 7/24/18 AAA Finish preparing 1992 video guidance and meet with M. 11.9 Kousser and K. Shenkman 7/24/18 KIS Trial prep (read depositions, prepare witness outlines, prepare 5.0 opening, revise witness list and exhibit list), discuss with J. Levitt. 7/24/18 KIS Travel to/from and meet with M. Kousser and A. Alarcon for 9.4 trial prep 7/24/18 KIS Deal with compliance of third parties regarding discovery 0.7 referee rulings. 7/25/18 MRH Trial preparation including beginning investigation of 12.3 Defendant's witnesses 7/25/18 AAA Research for M. Kousser and K. Shenkman regarding T. 7.7 Vazquez recent stance on minority contracting, historical pictures of Pico Neighborhood and city council members, charter advertisements and endorsements and minority leaders in 1940s SM. 7/25/18 KIS Trial prep (prepare video presentation, read depositions, 13.1 prepare witness outlines, prepare opening, revise witness list and exhibit list) 7/26/18 MRH Trial preparation including investigation of Defendant's 13.0 witnesses 7/26/18 KIS Trial prep (read depositions, prepare witness outlines, prepare 14.1 opening) 7/27/18 MRH Work on trial brief and trial preparation 10.5 7/27/18 KIS Trial prep (read depositions, prepare witness outlines, prepare 13.8 opening) 7/28/18 MRH Revise trial brief and discuss with K. Shenkman, and other trial 11.6 preparation 7/28/18 KIS Trial prep (read depositions, prepare witness outlines, prepare 12.2 opening) 7/28/18 KIS Revise and finalize trial brief, discuss with J. Levitt 3.3 7/28/18 AAA Review R. Cole deposition, summarize and prepare outline for 8.6 trial 7/29/18 KIS Prepare for, travel to/from and meeting with trial team at 14.6 Grimes office for trial and opening rehearsal; and trial prep upon return (read depositions, prepare witness outlines, discuss with witnesses, prepare opening) 7/29/18 AAA Trial opening prep meeting; research regarding hazards in Pico 13.3 Neighborhood; draft outline of opening with stats. 7/29/18 MRH Work on trial preparation; meeting with co -counsel to present 12.5 and critique opening statement. 7/30/18 MRH Trial preparation including reading depositions, investigating 10.9 Defendant's witnesses and preparing witness outlines. 7/30/18 AAA Work on hazardous use portion of opening with M. Grimes; 13.6 land use and zoning research at SM library and discuss with K. Shenkman 7/30/18 KIS Trial prep (read depositions, prepare witness outlines, prepare 13.3 opening) 7/31/18 MRH Review Defendant's trial brief and "glossary of terms" and 2.0 discuss with K. Shenkman 7/31/18 MRH Trial preparation including reading depositions, investigating 9.8 Defendant's witnesses and preparing witness outlines. 7/31/18 AM Draft Kousser 1940s testimony outline; miscellaneous trial 16.3 prep 7/31/18 KIS Trial prep (read depositions, prepare witness outlines, prepare 11.5 opening) 7/31/18 KIS Evaluate Defendant's trial brief and purported glossary; 2.4 discuss response to glossary with M. Hughes and A. Alarcon. 8/1/18 KIS Trial 15.8 8/1/18 MRH Trial support from office, including review motion to exclude S. 12.6 Farias, S. Hoffbauer and J. Carrillo and research and draft opposition, and deal with purportedly inadvertent production by Defendant 8/1/18 AAA Trial 10.2 8/2/18 KIS Trial 17.4 8/2/18 MRH Trial support from office, including research and draft 11.5 opposition to motion to exclude S. Farias, S. Hoffbauer and J. Carrillo, and review documents produced by LACDP, Schloss and SMMUSD in response to Defendant's trial subpoena 8/2/18 AAA Trial 13.8 8/3/18 KIS Trial 12.9 8/3/18 MRH Trial support from office, including revise and finalize 10.9 opposition to motion to exclude S. Farias, S. Hoffbauer and J. Carrillo, and research issue of purportedly inadvertent production and ethical obligations in response. 8/3/18 AAA Trial 11.6 8/4/18 KIS Trial prep, discuss with J. Levitt, and deal with admissibility of 13.1 Holbrook statement and emails and preparing M. Loya for court questioning 8/4/18 MRH Trial preparation including research and drafting opposition to 12.0 motion to exclude Holbrook statement 8/4/18 AM Trial prep and draft responses to discovery requests consistent 12.5 with discovery referee ruling 8/5/18 KIS Trial prep and deal with M. Loya email issue and preparing M. 11.7 Lava for court questioning 8/5/18 KIS Review and revise responses to discovery requests specified by1.9 discovery referee. 8/5/18 MRH Trial preparation including research and drafting opposition to 12.2 motion to exclude Holbrook statement 8/5/18 AAA Trial prep and draft responses to discovery requests consistent 13.3 with discovery referee ruling 8/6/18 KIS Trial 18.2 8/6/18 MRH Trial support from office including research and drafting 11.1 opposition to motion to exclude Holbrook statement 8/6/18 AM Trial 11.9 8/7/18 KIS Trial and prepare for continuing deposition of T. Vazquez 17.9 8/7/18 MRH Trial support from office, including research and revising 10.8 opposition to motion to exclude Holbrook statement 8/7/18 AAA Trial 14.8 8/8/18 KIS Trial and prepare for continuing deposition of T. Vazquez 17.8 8/8/18 MRH Trial support from office, including investigate Defendant's 13.5 witnesses and preparing witness outlines 8/8/18 AAA Trial 13.2 8/9/18 KIS Trial and deposition of T. Vazquez 19.5 8/9/18 MRH Trial support from office, including investigate Defendant's 12.4 witnesses and preparing witness outlines 8/9/18 AAA Trial 14.4 8/10/18 KIS Trial and work on response to "glossary" 15.7 8/10/18 MRH Trial support from office, including investigate Defendant's 12.2 witnesses and preparing witness outlines 8/10/18 AAA Trial 9.6 8/11/18 KIS Trial prep and research and drafting motion regarding K. 12.9 McDonald report, and deal with Defendant's attempt and correspondence to create discovery dispute. 8/11/18 MRH Trial preparation and work on motion concerning Defendant's 9.5 failure to disclose expert report 8/11/18 AAA Trial prep 5.6 8/12/18 KIS Trial prep and research and drafting motion regarding K. 11.6 McDonald report and correspondence with K. Scolnick regarding Defendant's attempt to create discovery disputes to distract from trial 8/12/18 MRH Trial preparation and work on motion concerning Defendant's 10.6 failure to disclose expert report 8/12/18 AAA Trial prep 6.3 8/13/18 KIS Trial and review/revise opposition to motion to quash 18.0 deposition subpoena. 8/13/18 MRH Trial support from office, including dealing with additional 12.6 email production 8/13/18 AM Trial 15.2 8/14/18 KIS Trial prep and address and coordinate opposition to motion 13.7 for sanctions including working with K. Scolnick and M. Loya to search for emails. 8/14/18 MRH Trial preparation, including investigate Defendant's witnesses 9.1 and preparing witness outlines and work on opposition to sanctions motion 8/14/18 AAA Trial prep 7.9 8/15/18 KIS Trial 16.2 8/15/18 MRH Trial support from office, including investigate Defendant's 12.0 witnesses and preparing witness outlines 8/15/18 AAA Trial 12.3 8/16/18 KIS Trial 18.9 8/16/18 MRH Trial support from office, including work on opposition to 11.5 sanctions motion. 8/16/18 AAA Trial 14.0 8/17/18 KIS Trial 12.3 8/17/18 MRH Trial support from office, including work on reply in support of 9.3 K. McDonald motion 8/17/18 AAA Trial 11.5 8/18/18 KIS Trial prep and work on deposition designations 13.8 8/18/18 MRH Trial preparation, including reading depositions and 11.7 summaries and preparing designations and working on reply regarding K. McDonald report not disclosed by Defendant. 8/18/18 AAA Trial prep 4.6 8/19/18 KIS Trial prep and work on deposition designations and reply in 14.6 support of motion to strike answer for failure to disclose report finding racially polarized voting. 8/19/18 MRH Trial preparation, including reading depositions and 10.5 summaries and preparing designations. 8/19/18 AAA Trial prep 2.8 8/20/18 KIS Trial 17.9 8/20/18 KIS Evaluate SMCCD's reply in support of motion to quash 0.4 subpoena 8/20/18 MRH Trial support from office, including reading depositions and 12.6 summaries and preparing designations. 8/20/18 AAA Trial 15.6 8/21/18 KIS Trial 15.5 8/21/18 MRH Trial support from office, including reading depositions and 10.9 summaries and preparing designations. 8/21/18 MA Trial support 4.5 8/22/18 KIS Trial 19.1 8/22/18 MRH Trial support from office, including investigate Defendant's 11.8 witnesses and preparing witness outlines 8/22/18 AAA Trial 13.0 8/23/18 KIS Trial 16.3 8/23/18 KIS Work on opposition to motion for sanctions and coordinate 2.0 with E. Gordon. 8/23/18 MRH Trial support from office, including work on response to 13.5 Defendant's purported glossary of terms 8/23/18 AAA Trial 14.8 8/24/18 KIS Trial 17.4 8/24/18 MRH Trial support from office, including investigate Defendant's 13.1 witnesses and preparing witness outlines 8/24/18 AAA Trial 10.2 8/25/18 KIS Trial prep and work on response to "glossary" 10.3 8/25/18 MRH Trial preparation, including investigate Defendant's witnesses 7.8 and preparing witness outlines 8/25/18 AAA Trial prep 2.5 8/26/18 KIS Trial preparation, including video review of deposition clips 12.2 and review papers on motion to quash subpoena of M. Quinones -Perez for hearing on same 8/26/18 MRH Trial preparation 8.4 8/26/18 AAA Trial prep 3.8 8/27/18 KIS Trial prep, including reading and watching deposition portions, 11.9 discussion with J. Levitt and preparing cross exam bulletpoints, and correspondence with K. Scolnick regarding rule of completeness and what deposition clips to play. 8/27/18 MRH Trial preparation 6.8 8/27/18 AAA Trial prep 4.6 8/28/18 KIS Trial 15.5 8/28/18 MRH Trial preparation, including investigating Defendant's potential 6.5 witnesses and develop cross exams. 8/28/18 AAA Trial 13.4 8/29/18 KIS Trial 17.3 8/29/18 MRH Trial preparation, including investigating Defendant's potential 9.9 witnesses and develop cross exams. 8/29/18 AAA Trial 13.1 8/30/18 KIS Trial 19.0 8/30/18 MRH Trial preparation, including investigating Defendant's potential 7.6 witnesses and develop cross exams. 8/30/18 AAA Trial 12.9 8/31/18 KIS Coordinate co -counsel preparation for trial. 2.9 8/31/18 MRH Trial preparation, focusing on 4 witnesses identified by 10.2 Defendant's counsel in email. 8/31/18 MA Trial prep 1.0 9/1/18 KIS Coordinate co -counsel preparation for trial and work on 3.3 witness outline 9/1/18 MRH Trial preparation, including investigating Defendant's potential 5.9 witnesses and develop cross exams. 9/1/18 AM Trial prep and preparing cross exams 6.2 9/2/18 KIS Coordinate co -counsel preparation for trial and prepare 4.6 witness cross exam 9/2/18 MRH Trial preparation, including investigating Defendant's potential 7.0 witnesses and develop cross exams. 9/2/18 AM Trial prep and preparing cross exams 7.0 9/3/18 KIS Trial prep and coordinate with co -counsel regarding cross 9.8 exams 9/3/18 MRH Trial preparation, including revising response to Defendant's 7.6 "glossary" 9/3/18 AAA Trial prep and preparing cross exams 10.9 9/4/18 KIS Trial and revise and finalize response to Defendant's "glossary 15.9 of terms," deal with Lichtman scope and exhibits outside of what was ready for deposition questioning 9/4/18 MRH Trial support from office, including investigation of 8.9 Defendant's potential witnesses and preparing witness cross examination outlines 9/4/18 AM Trial 14.9 9/5/18 KIS Trial 16.6 9/5/18 MRH Trial support from office, including investigation of 9.5 Defendant's potential witnesses and preparing witness cross examination outlines 9/5/18 AAA Trial 12.8 9/6/18 KIS Trial 13.3 9/6/18 MRH Trial support from office, including investigation of 6.8 Defendant's potential witnesses and preparing witness cross examination outlines 9/6/18 AAA Trial prep and preparing cross exams 6.5 9/7/18 KIS Trial prep, including dealing with Lichtman issue 10.9 9/7/18 MRH Trial preparation including investigation of Defendant's 7.0 potential witnesses and preparing witness cross examination outlines 9/7/18 AAA Trial prep and preparing cross exams 6.3 9/8/18 KIS Trial prep, including dealing with Lichtman issue 11.5 9/8/18 MRH Trial preparation, including investigation of Defendant's 5.5 potential witnesses and preparing witness cross examination outlines 9/8/18 AM Trial prep and preparing cross exams 6.0 9/9/18 KIS Trial prep, including dealing with Lichtman issue 10.6 9/9/18 MRH Trial preparation, including investigation of Defendant's 5.2 potential witnesses and preparing witness cross examination outlines 9/9/18 AAA Trial prep and preparing cross exams 7.3 9/10/18 KIS Trial and review papers regarding sanctions motion in 15.5 preparation for hearing 9/10/18 MRH Trial support from office 4.7 9/10/18 AM Trial 11.7 9/11/18 KIS Trial and research and draft response regarding Lichtman's 11.1 testimony and documents outside the scope of deposition 9/11/18 MRH Trial support from office, including research and drafting 6.0 response regarding Lichtman testimony and documents 9/11/18 AAA Trial and discuss preparation of closing brief 9.7 9/12/18 KIS Research and drafting closing brief. 8.6 9/12/18 MRH Research, draft and revise response regarding Lichtman 4.1 testimony and documents beyond his designation and what he was prepared to discuss at deposition. 9/12/18 AAA Research for closing brief and prepare for exhibit admission 3.0 hearing. 9/13/18 KIS Review exhibits, travel to/from and attend conference to 5.6 address admission of trial exhibits, debrief with A. Alarcon and M. Cussimonio to address trial exhibit issues. 9/13/18 KIS Travel to/from and meet with M. Kousser and A. Gonzalez for 4.9 trial debrief and thoughts on closing. 9/13/18 MRH Research and organize closing brief and proposed verdict 4.0 form. 9/13/18 AAA Court conference re: trial exhibits, conference with K. 6.7 Shenkman thereafter and research for closing brief. 9/14/18 KIS Research and drafting closing brief. 7.5 9/14/18 MRH Work on closing brief 5.8 9/14/18 AAA Research for closing brief 4.1 9/15/18 KIS Research and drafting closing brief. 8.2 9/15/18 MRH Work on closing brief 7.1 9/15/18 AAA Research for closing brief 5.0 9/16/18 KIS Research and drafting closing brief and verdict form, review 10.7 trial transcripts and exhibits 9/16/18 MRH Work on closing brief 6.4 9/16/18 AAA Review trial transcript for use in closing brief 7.1 9/17/18 KIS Research and drafting closing brief and verdict form, review 11.2 trial transcripts and exhibits 9/17/18 MRH Work on closing brief 6.9 9/17/18 AAA Review trial transcript for use in closing brief 4.4 9/18/18 KIS Research and drafting closing brief and verdict form, review 9.5 trial transcripts and exhibits 9/18/18 MRH Drafting closing brief and verdict form 4.9 9/18/18 AAA Review trial transcripts for inserts in closing brief 3.7 9/19/18 KIS Research and drafting closing brief. 10.8 9/19/18 MRH Revise portions of closing brief 5.9 9/19/18 AAA Review trial transcripts for inserts in closing brief 14.3 9/20/18 KIS Research and drafting closing brief, adding evidentiary support 11.5 9/20/18 MRH Work on closing brief 6.2 9/20/18 AAA Insert trial transcript and trial exhibit citations in closing brief 11.6 and revise intent section 9/21/18 KIS Research and drafting closing brief, adding evidentiary support 7.4 9/21/18 MRH Review and revise closing brief 3.2 9/21/18 AAA Find trial transcript and exhibits for citation in closing brief and 5.5 verdict form 9/22/18 KIS Revise closing brief, add evidentiary support 6.2 9/22/18 MRH Revise closing brief 1.5 9/22/18 AAA Find trial transcript and exhibits for citation in closing brief and 3.5 verdict form 9/23/18 KIS Revise closing brief, add evidentiary support 5.5 9/23/18 MRH Research and revise closing brief and verdict form 4.9 9/23/18 AM Find trial transcript and exhibits for citation in closing brief and4.0 verdict form 9/24/18 KIS Revise closing brief, add evidentiary support 7.2 9/24/18 MRH Revise closing brief and verdict form 2.4 9/24/18 AAA Revise closing brief and verdict form with evidence support 4.7 and deal with trial exhibit admission issue. 9/25/18 KIS Revise and finalize closing brief and verdict form 3.8 9/25/18 MRH Revise and finalize closing brief 1.0 10/10/18 KIS Investigate problem with closing brief corresponding to 1.7 admitted exhibits; research ability to introduce RFA response after conclusion of evidence at trial. 10/11/18 KIS Deal with difference between closing brief, proposed verdict 2.1 form and admitted exhibits, and draft notice of errata and corrected closing documents accordingly 10/15/18 KIS Evaluate Defendant's closing brief and verdict form, discuss 3.6 with M. Hughes and begin formulating response 10/15/18 KIS Travel to/from and meet with PNA board 3.5 10/15/18 MRH Review closing statement and proposed verdict form filed by 4.5 Defendant and discuss same with K. Shenkman; research issues raised in Defendant's closing and verdict form. 10/16/18 KIS Research and drafting reply closing brief 8.5 10/16/18 MRH Research and drafting response to Defendant's closing 6.7 statement. 10/17/18 KIS Research and drafting reply closing brief 9.2 10/17/18 AAA Review correspondence from T. Henry and review trial notes 1.8 to determine admission of exhibits 10/17/18 KIS Review correspondence from T. Henry regarding exhibits and 0.7 coordinate with A. Alarcon and M. Cussimonio 10/17/18 MRH Research and drafting response to Defendant's closing 5.5 statement. 10/18/18 KIS Research and drafting reply closing brief 7.3 10/18/18 MRH Research and drafting response to Defendant's closing 5.8 statement. 10/18/18 AAA Review trial transcripts for response to T. Henry regarding 7.4 admission of exhibits 10/19/18 KIS Research and drafting reply closing brief, discuss with J. Levitt 8.3 10/19/18 KIS Deal with inquiries from press and public regarding allegations 2.5 of PAL sex abuse and discussion of same at depositions of Winterer, Cole, et al. in advance of revelations of rampant sex abuse of Latino children in the Pico Neighborhood; draft statement concerning same. 10/19/18 MRH Research and drafting response to Defendant's closing 4.0 statement. 10/20/18 KIS Research and drafting reply closing brief 9.3 10/20/18 MRH Research and drafting response to Defendant's closing 2.6 statement. 10/21/18 KIS Research and drafting reply closing brief 8.7 10/21/18 MRH Research and drafting response to Defendant's closing 4.4 statement. 10/22/18 KIS Research and drafting reply closing brief 10.4 10/22/18 MRH Research and drafting response to Defendant's closing 4.8 statement. 10/23/18 KIS Research and drafting reply closing brief 7.8 10/23/18 MRH Research and drafting response to Defendant's closing 5.9 statement. 10/23/18 AAA Work on rebuttal closing brief and find trial citations 9.1 10/24/18 KIS Research and revising reply closing brief 5.0 10/24/18 MRH Revise response to Defendant's closing statement and discuss 2.3 with K. Shenkman 10/24/18 MA Work on rebuttal closing brief and find trial citations 5.8 10/25/18 KIS Revise and finalize reply closing brief 3.0 10/25/18 MRH Revise response to Defendant's closing statement. 1.2 10/25/18 AAA Review T. Henry objections to exhibit binders and coordinate 1.3 with K. Shenkman and M. Cussimonio 10/26/18 KIS Investigate, research and drafting response to objections to 2.0 exhibit binders 10/26/18 AAA Review trial transcripts for exhibit admissions to deal with 10.5 Defendant's objections; draft sections for response to objections 10/27/18 KIS Investigate, research and drafting response to objections to 3.1 exhibit binders 10/27/18 AAA Work on response to objection to exhibit binders and 6.5 declaration 10/28/18 KIS Investigate, research and drafting response to objections to 3.6 exhibit binders 10/28/18 AAA Revise and coordinate response to objection to trial exhibit 1.7 binders and call with E. Gordon 10/29/18 KIS Draft, revise and finalize response to objections to exhibit 2.5 binders and associated papers. 10/29/18 AAA Review transcripts for citations requested by K. Shenkman. 3.2 10/30/18 KIS Travel to/from and speak at N.E. Neighbors meeting 3.9 11/9/18 AAA Monitor LASC Electronic filing system for ruling throughout the 1.0 day; Email Exchange w team. 11/10/18 KIS Deal with press and clients and community activists regarding 1.8 unavailability of court decision on case and story about monetary sanctions 11/13/18 KIS Evaluate court tentative decision, deal with press regarding 3.7 same, communicate with co -counsel and experts regarding ruling. 11/13/18 MRH Review court decision; discuss timing of remedies briefing with5.2 K. Shenkman; research and drafting ex parte application to modify briefing schedule as an impossibility. 11/13/18 AAA Speak with K. Shenkman re ruling and briefing schedule; 2.0 review ruling; call Dept. 28 regarding briefing schedule and receipt of ruling; conduct press search; Email team re SM Press Statement. 11/14/18 KIS Correspondence with K. Scolnick and coordinate with E. 0.6 Gordon regarding briefing schedule and stipulation, avoiding need for ex parte application. 11/14/18 KIS Research and drafting remedies brief 7.3 11/14/18 MRH Research and drafting opening remedies brief 4.5 11/15/18 KIS Correspondence with K. Scolnick regarding effect of court 0.3 decision on 2018 election. 11/15/18 KIS Evaluate request for statement of decision, discuss with M. 3.8 Hughes, and research regarding level of harassment by Defendant's request for statement of decision 11/15/18 MRH Research regarding inquisition through request for statement 4.9 of decision. 11/15/18 KIS Travel to/from and meet with G. Morena and 0. de la Torre 3.0 11/15/18 KIS Travel to/from and participate in local cable news story 3.3 regarding Plaintiffs' victory. 11/15/18 KIS Begin formulating remedies brief and strategy, discuss with J. 1.5 Levitt. 11/16/18 KIS Research and drafting remedies brief 7.6 11/16/18 MRH Research and drafting opening remedies brief 5.8 11/17/18 KIS Research and drafting remedies brief and associated papers 6.9 11/17/18 MRH Research for opening remedies brief 4.1 11/18/18 KIS Research and drafting remedies brief and associated papers 9.2 11/18/18 MRH Research and revise opening remedies brief 3.7 11/19/18 KIS Revise and finalize remedies brief and associated papers, 3.8 discuss with J. Levitt; discuss path to stop certification of 2018 election 11/19/18 KIS Explain to local press Defendant's request for statement of 0.6 decision, and how it is not newsworthy 11/19/18 MRH Research regarding procedure for expedited injunction, 3.4 discuss with K. Shenkman. 11/19/18 AAA Read and suggest revisions to remedies brief and associated 1.3 declarations 11/20/18 KIS Research and drafting TRO / OSC application to prohibit 7.1 certification of 2018 election, discuss with R. Rubin 11/20/18 MRH Research for TRO and preliminary injunction motion regarding 3.6 certification of 2018 election. 11/21/18 KIS Research and drafting TRO / OSC application to prohibit 4.9 certification of 2018 election. 11/21/18 MRH Research for TRO and preliminary injunction motion regarding 3.0 certification of 2018 election. 11/23/18 KIS Research and drafting TRO / OSC application to prohibit 8.5 certification of 2018 election. 11/23/18 MRH Research for TRO and preliminary injunction motion regarding 5.1 certification of 2018 election. 11/24/18 KIS Research and drafting TRO / OSC application to prohibit 6.2 certification of 2018 election. 11/24/18 MRH Research and drafting section of TRO and preliminary 2.9 injunction motion regarding certification of 2018 election. 11/25/18 KIS Research, draft and revise objection to request for statement 6.5 of decision; coordinate with E. Gordon regarding same. 11/25/18 MRH Revise TRO and preliminary injunction motion. 2.5 11/26/18 KIS Research and revise objection to request for statement of 3.9 decision 11/26/18 MRH Revise and finalize TRO and preliminary injunction motion 1.8 11/26/18 AAA Review ex parte application and declarations and suggest 1.4 edits. 11/27/18 KIS Prepare for, travel to/from and attend hearing on TRO / OSC 5.8 application to prohibit certification of 2018 election 11/27/18 KIS Travel to/from and attend rally at city council meeting and city 5.1 council meeting, then meet with clients and local activists. 11/27/18 AAA Hearing on ex parte application of stop certification of election 4.9 11/30/18 KIS Evaluate order directing Plaintiffs to prepare proposed 6.6 statement of decision and proposed judgment, and Defendant's remedies brief, discuss with M. Hughes and R. Rubin, and begin formulating reply regarding remedies. 11/30/18 MRH Review Defendant's remedies brief, discuss with K. Shenkman, 5.2 research issues raised in Defendant's brief. 12/1/18 KIS Research and drafting reply remedies brief 6.5 12/1/18 MRH Work on response to Defendant's brief and failure to actually 4.4 propose a remedy 12/2/18 KIS Research and drafting reply remedies brief 8.1 12/2/18 MRH Work on response to Defendant's brief and failure to actually 5.3 propose a remedy 12/3/18 KIS Research and drafting reply remedies brief 7.6 12/3/18 MRH Work on response to Defendant's brief and failure to actually 4.9 propose a remedy 12/4/18 KIS Revise and finalize reply remedies brief, discuss with R. Rubin 6.6 12/4/18 MRH Revise response to Defendant's brief and failure to actually 2.8 propose a remedy 12/7/18 KIS Prepare for, travel to/from and attend hearing on selection of 5.5 appropriate remedies, conference with co -counsel thereafter. 12/7/18 AAA Hearing on appropriate remedies and team meeting. 4.8 12/14/18 KIS Evaluate remedies order and decision, respond to press 2.9 inquiries re: same, discuss response with A. Alarcon. 12/14/18 AAA Review court tentative decision and discuss response to court 0.4 tentative decision on remedies with K. Shenkman. 12/15/18 KIS Research and drafting ex parte for clarification. 2.6 12/15/18 MRH Work on ex parte application in response to remedies ruling 3.5 12/16/18 KIS Research and drafting ex parte for clarification. 1.9 12/17/18 KIS Research and drafting ex parte for clarification, discuss with R. 4.0 Parris. 12/17/18 MRH Revise ex parte application for clarification of remedies ruling 2.2 12/18/18 KIS Revise and finalize ex parte for clarification and draft 4.9 associated papers, incorporate revisions from colleagues; correspondence with K. Scolnick regarding same. 12/18/18 MRH Revise ex parte application for clarification. 1.6 12/18/18 AAA Review and revise ex parte application 0.8 12/19/18 KIS Prepare for, travel to/from ex parte application hearing and 3.7 confer with G. Cardona regarding rescheduling and potential agreement on seeking clarification and draft correspondence re: same. 12/19/18 AAA Travel to/from ex parte application hearing 2.8 12/20/18 KIS Drafting proposed statement of decision and proposed 5.4 judgment. 12/21/18 KIS Drafting proposed statement of decision and proposed 6.3 judgment. 12/22/18 KIS Drafting proposed statement of decision and proposed 7.5 judgment. 12/23/18 KIS Drafting proposed statement of decision and proposed 5.2 judgment. 12/24/18 KIS Revise ex parte application and associated papers accounting 2.2 for date change and additional relief necessitated by date change, and correspondence with opposing counsel regarding same. 12/24/18 KIS Drafting proposed statement of decision and proposed 4.9 judgment. 12/26/18 KIS Drafting proposed statement of decision and proposed 6.5 judgment. 12/26/18 MRH Review and revise proposed statement of decision and 3.7 proposed judgment 12/27/18 MRH Review and revise proposed statement of decision and 3.0 proposed judgment 12/27/18 AAA Review and revise draft proposed judgment 0.6 12/29/18 AAA Review and suggest revisions to draft proposed statement of 1.4 decision 12/29/18 KIS Compiling revisions and further research and drafting 5.0 proposed statement of decision and proposed judgment 12/30/18 KIS Compiling revisions and further research and drafting 4.5 proposed statement of decision and proposed judgment 12/31/18 KIS Revise and finalize ex parte for clarification papers. 1.8 12/31/18 KIS Compiling revisions and further research and drafting 5.3 proposed statement of decision and proposed judgment 1/1/19 KIS Review remedies briefing and case law and applicable sections 4.7 of Elections Code to prepare for hearing on ex parte application for clarification; review mandatory e -filing rules to determine applicability to 1-2-19 ex parte and coordinate filing. 1/1/19 MRH Revise proposed statement of decision. 3.6 1/2/19 KIS Prepare for, travel to/from and attend hearing on ex parte for 8.2 clarification, debrief clients and then debrief M. Hughes and R. Rubin, respond to press inquiries re: same 1/2/19 KIS Draft and revise proposed statement of decision and proposed4.9 judgment based on court's direction and suggestions of colleagues. 1/2/19 MRH Debrief with K. Shenkman regarding hearing on ex parte 2.5 application for clarification and further work on proposed statement of decision and proposed judgment in accordance with court's instruction. 1/2/19 MA Review previous remedies briefing and ex parte application; 5.2 travel to/from and attend hearing on ex parte application for clarification. 1/3/19 KIS Research, revise and finalize proposed statement of decision 4.8 and proposed judgment consistent with court's direction, and draft notice of lodging 1/3/19 MRH Review and revise proposed statement of decision and 1.9 proposed judgment. 1/7/19 KIS Prepare materials for neighborhood / civic organization 5.9 meetings; travel to/from and speak at N.E. Neighbors meeting and Apartment Owners' group meeting. 1/8/19 KIS Travel to/from and meet with PNA board 4.0 1/12/19 KIS Travel to/from and speak at Neighborhood Council meeting. 4.5 1/18/19 KIS Evaluate objections to proposed statement of decision and 4.9 proposed judgment, coordinate with D. Ely regarding district boundary descriptions in judgment 1/18/19 MRH Review Defendant's objections to proposed statement of 3.5 decision and proposed judgment. 1/21/19 KIS Evaluate objections to proposed statement of decision and 2.0 proposed judgment; discuss appropriate response with M. Hughes. 1/24/19 KIS Draft responses to Defendant's objections to proposed 4.4 statement of decision and proposed judgment, and corrected proposed judgment. 1/31/19 AAA Address case reassignment with Dept. 28/9; draft declaration 2.9 as directed by clerk; discuss with K. Shenkman EXHIBIT M -0 5: w 7r) Vir,-0 a -., CD "5 V v, - -0(4. 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I-) la 1.0 I-1 V I-1 1-k Fh rn !Al $0 D.J :.'I 01 00 4:. NI la Fa Ch V EXHIBIT N Office of the City Attorney Rebecca Katsura City Hall [email protected] 1685 Main Street PO Box 2200 Santa Monica, California 90407-2200

City of Santa Monica.

April 18, 2019

VIA E-MAIL

Marci Cussimonio Paralegal, PARRIS Lawyers 43364 10th Street West Lancaster, California 93534 Phone: 661-429-3399 Email: [email protected]

Re:Public Records Act Request

Dear Ms. Cussimonio:

The City of Santa Monica (the "City") received your Public Records Act ("Act") request, dated April 10, 2019. Our response to your request is below.

Request No. 1: "All warrants for payments to Gibson Dunn & Crutcher, LLP since January 1, 2016."

Response to Request No. 1: Your request does not seek any records that are non- exempt. See discussion below.

Discussion re: Request No. 1: In accordance with the Act, records that constitute attorney -client privileged communications and attorney work product are exempt from disclosure. (Gov. Code, § 6254, subd. (k); Evid. Code, § 1040.) The attorney -client privilege covers confidential communications between an attorney and his or her client. The attorney work product rule creates for attorneys the absolute privilege against disclosure of writings containing the attorney's impressions, conclusions, opinions, or legal theories. (Code Civ. Proc., § 2018; Gov. Code, § 6254, subd. (k).)

The attorney -client privilege protects the confidentiality of "everything in an invoice" from an attorney, including "the amount of aggregate fees," when a "legal matter remains pending and active." Los Angeles County Board of Supervisors v. Superior Court (2016) 2 Ca1.5th 282, 297 ("Los Angeles County"). As the Court of Appeals explained on remand, the Supreme Court's ruling in this case "teaches that invoices related to pending or ongoing litigation are privileged and are not subject to PRA disclosure." County of Los Angeles Board of Supervisors v. Superior Court (2017) 12 Cal.App.5th 1264, 1274.

tel:310 458-8336 . fax: 310 395-6727 Marci Cussimonio April 18, 2019 Re: April 10 PRA Request Page 2

Here, the litigation regarding the claims raised in Pico Neighborhood Association and Maria Loya v. City of Santa Monica, Case No. BC616804, Los Angeles County Superior Court, remains pending and ongoing as the trial court's decision has been appealed by the City. See City of Santa Monica v. Pico Neighborhood Association; Maria Loya, Case No. B295935, California Court of Appeal, Second Appellate District, Division8.1 Moreover, the law firm as to which you request records, Gibson, Dunn & Crutcher, remains the City's counsel in connection with the pending appeal. Accordingly, the records you request in your Request No. 1, which relate to payments in response to invoices from Gibson Dunn & Crutcher, remain subject to attorney -client privilege and, as a result, are exempt from production under the Act.

Request No. 2: "All council meeting minutes/agendas referencing a warrant, payment or contract with Gibson Dunn & Crutcher, LLP."

Response to Request No. 2: Your request appears to specify the same date range for this request, that is, from January 1, 2016. During this time, the City retained Gibson Dunn & Crutcher only in connection with the California Voting Rights Act case filed in April 2016, Pico Neighborhood Association and Maria Loya v. City of Santa Monica, Case No. BC616804, Los Angeles County Superior Court. As discussed below, litigation in this matter remains pending. The matter has been on the Council's closed session agenda on numerous occasions since January 1, 2016, including: January 12, 2016; April 26, 2016; May 10, 2016; May 24, 2016; June 14, 2016; June 28, 2016; September 27, 2016; October 25, 2016; December 6, 2016; February 14, 2017; February 28, 2017; April 18, 2017; June 13, 2017; July 10, 2017; October 10, 2017; October 24, 2017; November 28, 2017; December 12, 2017; January 9, 2018; January 23, 2018; February 13, 2018; February 27, 2018; March 6, 2018; March 27, 2018; April 10, 2018; April 24, 2018; May 8, 2018; May 22, 2018; June 12, 2018; June 26, 2018; July 24, 2018; August 14, 2018; August 28, 2018; September 11, 2018; October 9, 2018; October 23, 2018; November 13, 2018; November 27, 2018; December 18, 2018; January 8, 2019; January 22, 2019; February 12, 2019; February 21, 2019; February 26, 2019; March 5, 2019; and March 26, 2019. Neither the agenda nor the minutes for any of these meetings references a warrant, payment, or contract with Gibson Dunn & Crutcher LLP. Accordingly, the City has not identified any documents responsive to your request. For your information, the agendas and minutes for City Council meetings conducted between January 1, 2016 and the present are available online at: https://www.smgov.net/departments/clerk/agendas.aspx.

1 Community members and others who wish to stay apprised of events in the pending litigation can find relevant non -privileged information and pleadings online at: https://www.santamonica. gov/Election-Litigation-PNA-V-Santa-Monica. Marci Cussimonio April 18, 2019 Re: April 10 PRA Request Page 3

This completes the City's written response to your request dated April 10, 2019.

Sincerely,

Rebecca Katsura Public Records Coordinator EXHIBIT 0 4111111pr ROQUE & Santa Monica MARK Co. REAL TTTTTT LOOKOUT (310)828-7525 Traditional Reporting for A Digital Age 2802 Santa Monica Blvd. Santa Monica, CA 90404 rogue-mark.com

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City Officials Won't Reveal Cost of Voting Rights Lawsuit Until Case is Closed

By Jorge Casuso

March 5, 2019 -- Santa Monica taxpayers will have to wait until the voting rights lawsuit ends to learn what the City has spent fighting the nearly three -year -old case.

Last week, City officials declined to provide The Lookout with the total fees paid to Gibson Dunn & Crutcher, the law firm hired to defend the City.

In response to the Lookout's request, City officials on Thursday cited attorney client privilegesin the ongoing litigation.

"The legal fees paid to Gibson Dunn as part of the CVRA lawsuit is privileged information until the case is resolved," the City responded.

The Lookout's request was made after the City Council last month voted to appeal a Superior Court ruling that found Santa Monica's at -large election system discriminates against Latino voters("Santa Monica Council Votes to Appeal Voting Rights Ruling,"February21, 2019).

The Council's unanimous vote fueled public speculation about the legal fees paid to the high-powered Los Angeles firm to fight the lawsuit filed by local Latino activists.

At the February 21 public hearing, most of the speakers who testified urged the City to drop what they view as a losing battle, saying taxpayer money could be better used. But the total legal fees incurred by the City related to the lawsuit filed in April 2016 remains unclear("Santa Monica Facing Lawsuit Over At -Large Council Elections,"April 13, 2016).

In 2017, total fees to Gibson, Dunn and Crutcher were nearly $5 million, although the price tag included other legal matters, finance officials said at the time (" City of Santa Monica Enters Second Year of Fight Against Voting Rights Lawsuit," April 19, 2018).

Community activists have speculated in public meetings and on social media that the City's legal bill has reached $20 million.

Gibson Dunn Legal Fees

Founded in Los Angeles in 1890, the firm has more than 1,300 attorneys in 20 offices worldwide and has argued more than 100 cases before the U.S. Supreme Court, according to the firm's site.

Its clients have included Apple, Inc., Facebook founder Mark Zuckerberg, Chevron and CNN reporter Jim Acosta in the station's press pass case against the White House.

Gibson Dunn is routinely ranked among the U.S. law firms with the highest billing rates, according to the National Law Journal (NLJ).

In 2015, the last readily available data the Lookout found, the firm's partner Theodore Olson "had the highest rate the NLJ could find in public records" at $1,800 an hour.

The three runners up had an hourly rate of $1,250("Billing Rates Rise. Discounts Abound,"January5, 2015).

Gibson Dunn's rates have made headlines.

Four years ago, Albany County asked a federal judge to throw out the $7 million legal bill Gibson Dunn and the firm DerOhannesian & DerOhannesian submitted in a voting rights lawsuit, according to a report in Albany's Times Union.

"In one instance cited by the county, five Gibson Dunn lawyers billed $38,255 for 63.55 hours of work in connection with the deposition of County Legislature Majority Leader Frank Commission, which lasted less than two hours," the article said.

The bill filed with the court was 900 pages long, according to the Times Union ("Albany County disputes $7111 bill,"July 8, 2015).

In a 2012 case filed against Chevron by a group of Ecuadoran villagers, the oil company said the legal fees included 36,837 hours billed by its lawyers at Gibson, Dunn & Crutcher, according to a 2014 report in Reuters.

"Randy Mastro, the lead lawyer for Chevron, most recently billed at a rate of $1,140 an hour," the 2014 article said.("Chevron seeks $32 million in legal fees in Ecuador case."March 19, 2014). Court Rules on Disclosure of Legal Fees

The City has legal precedent in refusing the Lookout's request, legal experts said.

"The courts have ruled on the issue," said Fredric Woocher, an LA attorney who specializes in campaign finance law. "The amount of fees a City has paid could give information about its legal strategies," he said.

Woocher cited a ruling in a case filed by the ACLU after the LA County Board of Supervisors refused to produce invoices for law firms defending the County in police brutality cases.

In the October 11, 2017 ruling, the Second District held that a government entity is not required to disclose any invoices in pending litigation under the Public Records Act (PRA).

The County argued the the PRA made exceptions based on attorney -client privilege and work product. The Second District, on remand from the California Supreme Court, agreed.

Maria Loya, the lead plaintiff in Santa Monica's voting rights lawsuit, criticized the City's refusal to provide the information.

"It's very suspicious to me they don't want to share that amount," Loya said. "That means to me it's a very large amount."

Santa Monica taxpayers, she said, should be told what the City is spending as the Council prepares to approve a new fiscal budget in June.

"How can we have a budget discussion when we don't know what they're spending on the lawsuit," she said.

"It's upsetting because at the same time they're spending millions, they're telling people there's no money to fix the streets or hire another park ranger.

"So much for the transparency and the accountability that the City Council talks about," she said.

...itiaLOOKOUT copyrightCopyright 1999-2019 surfsantamonica.com. All Rights Reserved.EMAIL Disclosures EXHIBIT P Meal Expenses

Pico Neighborhood Assn. v. Santa Monica

Date Statement Description Debit 9/9/2015mao's Kitchen - Venice, CA $(33.89) 10/16/2015 Inn of the Seventh Ray - Topanga, CA $ (48.97) 10/30/2015Veggie Grill - Santa Monica, CA $(22.57) 11/3/2015Houston's - Santa Monica, CA $(83.08) 11/4/2015 Spruzzo's - Malibu, CA $(81.98) 114/2016 Mao's Kitchen - Venice, CA $(58.05) 8/9/2016Simply Wholesome - Los Angeles, CA $(12.21) 10/10/2016Panera - Lancaster, CA $ (29.05) 10/27/2016Duck Dive - Malibu, CA $(83.40) 11/30/2016DEBIT CARD #4202 11/29 OLIVE GARDEN #00 MANHATTAN BCHCA $(35.00) 12/23/2016 DEBIT CARD #4202 12/22 CORAL BEACH CANT MALIBU CA $ (34.70) DEBIT CARD #4202 01/18 LARES RESTAURANT SANTA MONICA 01/19/2017 CA $ (82.90) 02/01/2017DEBIT CARD #4202 01/31 SATDHA SANTA MONICA CA $ (57.17) 03/14/2017DEBIT CARD #4202 03/13 THE PENINSULA BE BEVERLY HILLSCA $ (112.43) 03/24/2017DEBIT CARD #0561 03/23 SPRUZZO RESTAURA MALIBU CA $ (121.80) 04/06/2017DEBIT CARD #0561 04/06 THE SUNSET RESTA MALIBU CA $(24.07) 05/18/2017DEBIT CARD #4202 05/16 OLLO MALIBU CA $(24.00) 06/08/2017DEBIT CARD #4202 06/07 COLONIAL KITCHEN SAN MARINO CA $(50.00) 07/21/2017DEBIT CARD #4202 07/20 NEPTUNES NET SEA MALIBU CA $(19.70) 07/25/2017DEBIT CARD #4202 07/24 SALATHAI THAI CU SAN GABRIEL CA $ (66.37) 07/28/2017DEBIT CARD #4202 07/27 ANDERSON MOULDIN CULVER CITY CA $(51.92) DEBIT CARD #4202 08/11 CAMPOS FAMOUS BU SANTA MONICA 08/14/2017 CA $(23.60) 08/18/2017DEBIT CARD #4202 08/18 RIM TALAY THAI C OCEANSIDE CA $ (103.52) 08/25/2017DEBIT CARD #4202 08/24 CHOLADA THAI BEA MALIBU CA $(61.02) 09/30/2017DEBIT CARD #4202 09/29 GOLDEN LOTUS VEG OAKLAND CA $(53.68) 10/27/2017DEBIT CARD #4202 10/26 FROMIN'S RESTAUR SANTA MONICA CA $(45.91) 10/30/2017DEBIT CARD #4202 10/27 HILLSTONE (310) LOS ANGELES CA $ (104.20) 12/02/2017DEBIT CARD #4202 12/01 COMMERCE CASINO COMMERCE CA $(20.00) 01/02/2018DEBIT CARD #4202 12/31 MAOS KITCHEN VENICE CA $(32.38) 01/06/2018DEBIT CARD #4202 01/05 STARBUCKS STORE YORBA LINDA CA $ (8.50) 02/03/2018DEBIT CARD #4202 02/02 PRESSED JUICERY EL SEGUNDO CA $ (18.05) 02/09/2018DEBIT CARD #4202 02/08 VEGGIE GRILL PES EL SEGUNDO CA $ (2.74) 02/09/2018DEBIT CARD #4202 02/08 SAMOSA HOUSE 310-4967389 CA $(12.53) 02/13/2018DEBIT CARD #4202 02/13 COFFEE BEAN STOR MALIBU CA $ (7.43) 02/16/2018DEBIT CARD #4202 02/16 KUNG PAO CHINA B SHERMAN OAKS CA $(56.14) 02/27/2018DEBIT CARD #4202 02/26 RUBIO'S #215 LANCASTER CA $(17.17) 03/12/2018DEBIT CARD #4202 03/09 DUCK DIVE GASTRO MALIBU CA $ (15.64) 03/31/2018DEBIT CARD #4202 03/30 RUBIO'S #215 LANCASTER CA $(16.17) 04/06/2018DEBIT CARD #4202 04/05 BA COLBURN58 LOS ANGELES CA $(18.94) 04/30/2018DEBIT CARD #4202 04/27 KUNG PAO CHINA B SHERMAN OAKS CA $ (42.00) 05/09/2018DEBIT CARD #4202 05/08 MAOS KITCHEN VENICE CA $(31.28) 05/10/2018DEBIT CARD #4202 05/09 BA COLBURN51 LOS ANGELES CA $ (12.24) 05/12/2018DEBIT CARD #4202 05/12 OCHO MEXICAN GRI LOS ANGELES CA $(43.10) 06/07/2018DEBIT CARD #4202 06/07 MAOS KITCHEN VENICE CA $(24.00) 06/14/2018DEBIT CARD #4202 06/14 LOCAL LOS ANGELES CA $(36.00) 06/30/2018DEBIT CARD #4202 06/29 PANERA BREAD #20 LANCASTER CA $(23.49) 07/05/2018DEBIT CARD #4202 07/03 STUFF I EAT INC INGLEWOOD CA $ (53.29) 07/13/2018DEBIT CARD #4202 07/13 OCHO MEXICAN GRI LOS ANGELES CA $(32.00) 08/02/2018DEBIT CARD #4202 08/02 SQ *PANORAMA CAF LOS ANGELES CA $(19.33) 08/10/2018DEBIT CARD #4202 08/09 AU LAC PLANT BAS LOS ANGELES CA $ (61.47) 08/10/2018DEBIT CARD #4202 08/09 GRAND CAFE LOS ANGELES CA $ (106.79) 08/18/2018DEBIT CARD #4202 08/17 AU LAC PLANT BAS LOS ANGELES CA $(71.32) 08/18/2018DEBIT CARD #4202 08/16 AU LAC PLANT BAS LOS ANGELES CA $(88.46) 08/27/2018DEBIT CARD #4202 08/24 KENDALLS BRASSER LOS ANGELES CA $ (218.61) 10/11/2018DEBIT CARD #4202 10/11 CORAL BEACH CANT MALIBU CA $(34.57) 10/15/2018DEBIT CARD #4202 10/14 MAOS KITCHEN VENICE CA $(32.88) 11/28/2018DEBIT CARD #4202 11/27 CASA MARTIN SANTA MONICA CA $ (173.19) 01/08/2019DEBIT CARD #4202 01/07 MAOS KITCHEN VENICE CA $(18.88)

Total -2873.78 PNA v. Santa Monica

Mileage and Parking -

Date and Attorney Parking Mileage 6/30/15 - 25.71 SHENKMAN 7/7/15 - Hughes 61.17 7/10/15 - Hughes 67.24 7/13/15 - Hughes 61.17 7/14/15 - Hughes 61.17 7/27/15 - Hughes 67.24 7/29/15 - Hughes 61.17 8/3/15 - Hughes 61.17 8/5/15 - Hughes 61.17 8/13/15 - Hughes 67.24 9/4/15 -SHENKMAN 25.71 9/9/15 - SHENKMAN 28.59 9/14/15 - 25.71 SHENKMAN 9/29/15 - 25.71 SHENKMAN 10/15/15 - 25.71 SHENKMAN 10/16/15 - 21.66 SHENKMAN 10/30/15 - 25.71 SHENKMAN 11/3/15 - 25.71 SHENKMAN 11/17/15 - 25.71 SHENKMAN 12/15/15 - 25.71 SHENKMAN 1/4/16 - SHENKMAN 25.59 1/12/16 - 10.00 25.71 SHENKMAN 1/13/16 - Hughes 61.17 1/15/16 - Hughes 67.24 1/19/16 - Hughes 61.17 1/26/16 - Hughes 67.24 1/28/16 - Hughes 61.17 1/29/16 - Hughes 61.17 2/5/16 - Hughes 61.17 2/8/16 - Hughes 67.24 2/18/16 - Hughes 61.17 2/23/16 - Hughes 67.24 2/24/16 - Hughes 61.17 2/25/16 - Hughes 61.17 3/7/16 - Hughes 67.24 5/11/16 - Shenkman 14.28 5/12/16- 25.71 SHENKMAN 6/3/16 - SHENKMAN 25.71 7/1/16 -SHENKMAN 25.71 8/9/16 -SHENKMAN 32.61 8/10/16- 18.00 38.08 SHENKMAN 8/11/16- 25.71 SHENKMAN 9/2/1.6 - SHENKMAN 25.71 9/20/16 - 104.36 SHENKMAN 10/6/16 - 104.36 SHENKMAN 10/10/16- 104.36 SHENKMAN 10/20/16- 25.71 SHENKMAN 11/1/16 - 18.00 38.08 SHENKMAN 11/2/16 - 32.61 SHENKMAN 11/15/16 - 25.71 SHENKMAN 11/29/16 - 18.00 38.08 SHENKMAN 11/30/16 - 43.79 SHENKMAN 12/13/16- 1.00 25.71 SHENKMAN 12/14/16- 1.00 25.71 SHENKMAN 12/16/16- 104.36 SHENKMAN 12/19/16- 25.71 SHENKMAN 1/10/17 - Hughes 25.71 1/11/17 - Hughes 25.71 1/12/17 - Hughes 25.71 1/13/17- 25.71 SHENKMAN 1/19/17 - 25.71 SHENKMAN 2/1/17 -SHENKMAN 25.71 2/3/17-SHENKMAN 18.00 38.08 2/24/17 - SHENKMAN 25.71 3/6/17 - SHENKMAN 25.71 3/13/17 - SHENKMAN 25.71 3/14/17 - 34.03 SHENKMAN 4/13/17 - SHENKMAN 38.08 5/24/17 -Shenkman 32.00 46.17 5/30/17 - 32.61 SHENKMAN 6/2/17 - SHENKMAN 18.00 38.08 6/5/17 - SHENKMAN 25.71 6/6/17 - SHENKMAN 25.71 6/7/17-SHENKMAN 18.00 38.08 6/8/17 -SHENKMAN 67.24 6/8/17 - ALARCON 67.24 6/12/17 - SHENKMAN 18.00 38.08 6/21/17 - SHENKMAN 18.00 38.08 7/6/17 - SHENKMAN 25.71 7/25/17 - SHENKMAN 67.24 7/25/17 - ALARCON 67.24 7/28/17- 32.61 SHENKMAN 8/11/17 - 104.36 SHENKMAN 8/14/17 - 25.71 SHENKMAN 8/18/17 - 138.04 SHENKMAN 8/24/17 - SHENKMAN 16.07 8/25/17 - SHENKMAN 18.00 38.08 9/18/17 - SHENKMAN 18.00 38.08 9/25/17 - SHENKMAN 18.00 38.08 9/30/17 - 461.72 SHENKMAN 10/9/17 - SHENKMAN 18.00 38.08 10/16/17 - Hughes 61.17 10/27/17- 25.71 SHENKMAN 10/30/17- 25.71 SHENKMAN 11/15/17 -Alarcon 14.00 21.42 11/16/17 - 25.71 SHENKMAN 12/2/17 - SHENKMAN 48.91 12/11/17 -Alarcon 14.00 21.42 12/15/17 - Alarcon 14.00 21.42 12/28/17 -Alarcon 14.00 21.42 12/29/17 -Alarcon 14.00 21.42 1/2/18 -SHENKMAN 28.59 1/6/18 - SHENKMAN 79.37 1/22/18 - SHENKMAN 18.00 38.08 1/26/18 - SHENKMAN 25.71 2/2/18 - SHENKMAN 18.00 38.08 2/3/18 -SHENKMAN 41.53 2/6/18 - SHENKMAN 18.00 38.08 2/9/18 -SHENKMAN 41.53 2/13/18- 9.52 SHENKMAN 2/16/18 - SHENKMAN 18.45 34.63 2/16/18 - Alarcon 18.45 4.88 2/23/18- 1.50 25.71 SHENKMAN 2/26/18 - 104.36 SHENKMAN 3/6/18 - SHENKMAN 18.00 38.08 3/15/18 - SHENKMAN 18.45 34.63 3/30/18 - 104.36 SHENKMAN 4/4/18 - Hughes 61.17 4/4/18 -Alarcon 14.00 21.42 4/5/18- Hughes 67.24 4/5/18 -Alarcon 14.00 21.42 4/6/18 - SHENKMAN 18.00 38.08 4/11/18 - SHENKMAN 18.00 38.08 4/12/18 -Alarcon 14.00 21.42 4/16/18 -Shenkman 61.17 4/16/18 -Alarcon 27.37 4/19/18 - Hughes 61.17 4/20/18 - Hughes 67.24 4/20/18 -Alarcon 14.00 21.42 4/23/18 - 104.36 SHENKMAN 4/30/18 - SHENKMAN 35.83 4/30/18 -ALARCON 4.88 5/8/18 - Hughes 61.17 5/9/18-SHENKMAN 18.00 38.08 5/10/18- 18.00 38.08 SHENKMAN 5/11/18- 18.00 38.08 SHENKMAN 5/12/18 - 18.00 38.08 SHENKMAN 5/15/18- 18.00 38.08 SHENKMAN 5/17/18 - Hughes 61.17 5/18/18 - Alarcon 14.00 21.42 5/21/18 -Alarcon 14.00 21.42 5/22/18 - Hughes 61.17 5/22/18 -Alarcon 14.00 21.42 5/23/18 -Alarcon 14.00 21.42 5/24/18 -Alarcon 14.00 21.42 5/30/18 - 104.36 SHENKMAN 5/31/18 - 18.00 38.08 SHENKMAN 6/6/18-SHENKMAN 18.00 38.08 6/7/18 -SHENKMAN 28.59 6/11/18 - 25.71 SHENKMAN 6/14/18- 18.00 64.38 SHENKMAN 6/14/18 -ALARCON 18 22.85 6/18/18 -Shenkman 18.00 38.08 6/19/18- 18.00 38.08 SHENKMAN 6/19/18 - 25.71 SHENKMAN 6/19/18 -ALARCON 18 22.85 6/25/18 - 104.36 SHENKMAN 6/28/18 - 18.00 38.08 SHENKMAN 6/29/18- 104.36 SHENKMAN 7/2/18 -SHENKMAN 25.71 7/3/18 -SHENKMAN 32.61 7/5/18-SHENKMAN 18.00 44.03 7/9/18 - shenkman 18.00 114.24 7/9/18 - ALARCON 18 22.85 7/11/18 - 104.36 SHENKMAN 7/12/18 - 18.00 38.08 SHENKMAN 7/13/18 - 18.00 38.08 SHENKMAN 7/14/18 - 18.00 38.08 SHENKMAN 7/16/18 - 104.36 SHENKMAN 7/17/18 - 18.00 38.08 SHENKMAN 7/19/18 - 18.00 38.08 SHENKMAN 7/19/18 -ALARCON 18 22.85 7/21/18 - Shenknnan 81.16 7/22/18 - 32.61 SHENKMAN 7/22/18 - ALARCON 24.28 7/23/18 - Hughes 61.17 7/24/18 - Hughes 61.17 7/25/18 - Hughes 61.17 7/25/18 -Alarcon 14.00 21.42 7/27/18 - Hughes 61.17 7/28/18 - 32.61 SHENKMAN 7/28/18 - ALARCON 24.28 7/30/18 - Hughes 61.17 8/1/18 - SHENKMAN 18 38.08 8/1/18 - ALARCON 18 22.85 8/2/18 - SHENKMAN 18 38.08 8/2/18 - ALARCON 18 22.85 8/3/18 - SHENKMAN 18 38.08 8/3/18 - ALARCON 18 22.85 8/6/18 - SHENKMAN 18 38.08 8/6/18 - ALARCON 18 22.85 8/7/18 - SHENKMAN 18 38.08 8/7/18 - ALARCON 18 22.85 8/8/18 - SHENKMAN 18 38.08 8/8/18 - ALARCON 18 22.85 8/9/18 - SHENKMAN 18 38.08 8/9/18 - ALARCON 18 22.85 8/10/18 - 18 38.08 SHENKMAN 8/10/18 - ALARCON 18 22.85 8/13/18 - 18 38.08 SHENKMAN 8/13/18 - ALARCON 18 22.85 8/15/18 - 18 38.08 SHENKMAN 8/15/18-ALARCON 18 22.85 8/16/18 - 18 38.08 SHENKMAN 8/16/18 - ALARCON 18 22.85 8/17/18 - 18 38.08 SHENKMAN 8/17/18 - ALARCON 18 22.85 8/20/18 - 18 38.08 SHENKMAN 8/20/18 - ALARCON 18 22.85 8/21/18 - 18 38.08 SHENKMAN 8/21/18 - ALARCON 18 22.85 8/22/18 - 18 38.08 SHENKMAN 8/22/18 - ALARCON 18 22.85 8/23/18 - 18 38.08 SHENKMAN 8/23/18 - ALARCON 18 22.85 8/24/18 - 18 38.08 SHENKMAN 8/24/18-ALARCON 18 22.85 8/28/18 - 18 38.08 SHENKMAN 8/28/18 - ALARCON 18 22.85 8/29/18 - 18 38.08 SHENKMAN 8/29/18-ALARCON 18 22.85 8/30/18 - 18 38.08 SHENKMAN 8/30/18 - ALARCON 18 22.85 9/4/18 - SHENKMAN 18 38.08 9/4/18 - ALARCON 18 22.85 9/5/18 - SHENKMAN 18 38.08 9/5/18 - ALARCON 18 22.85 9/6/18 - SHENKMAN 18 38.08 9/6/18 - ALARCON 18 22.85 9/10/18 - 18 38.08 SHENKMAN 9/10/18 - ALARCON 18 22.85 9/11/18 -SHENKMAN 18 38.08 9/11/18 - ALARCON 18 22.85 9/13/18 - SHENKMAN 18 38.08 9/13/18 - ALARCON 18 22.85 9/25/18 - 18 38.08 SHENKMAN 10/15/18 - 28.59 SHENKMAN 10/30/18 - 25.71 SHENKMAN 11/27/18 - 25.71 SHENKMAN 11/27/18 - 20 38.08 SHENKMAN 11/27/18 - ALARCON 20 22.85 12/3/18 - 25.71 SHENKMAN 12/7/18 - SHENKMAN 20 38.08 12/7/18 -ALARCON 20 22.85 12/19/18 - 20 38.08 SHENKMAN 12/19/18 - ALARCON 20 38.08 1/2/19 - ALARCON 20 38.08 1/2/19 - SHENKMAN 20 38.08 1/3/19 - SHENKMAN 20 38.08 1/7/19 -SHENKMAN 25.71 1/8/19 - SHENKMAN 25.71 1/12/19 - 25.71 SHENKMAN 2/1/19-SHENKMAN 25.71 2/21/19 - 25.71 SHENKMAN 3/4/19 - SHENKMAN 20 38.08 3/4/18 - ALARCON 20 22.85

Total $12,915.40

Court and Messenger Fees

Date Type Amount 4/12/16 Complaint filing fee 435 4/12/16 Messenger 70 4/13/16 Messenger 50 7/21/16 Messenger 70 1/10/17 Messenger 70 2/23/17 Messenger 70 5/9/17 Messenger 70 3/29/18 Messenger 70 5/2/18 Messenger 70 5/11/18 Motion fee 60 5/31/18 Messenger 70 6/8/18 Messenger 70 7/9/18 Motion fees 120 7/12/18 Messenger 70 7/24/18 Messenger 70 9/25/18 Messenger 70 10/25/18 Messenger 70 11/14/18 Messenger 70 11/19/18 Messenger 70 11/27/18 Motion fee 60 12/4/18 Messenger 70 1/2/19 Motion fee and e -filing fee 73.40 1/25/19 Messenger 70

Total $1988.40

Postage, Copying and Printing -

Date Type Amount Mar. 16 Postage, copying and printing 61.62 Apr. 16 Postage, copying and printing 66.55 May 16 Postage, copying and printing 29.58 Jun. 16 Postage, copying and printing 39.43 Jul. 16 Postage, copying and printing 46.83 Aug. 16 Postage, copying and printing 34.50 Sep. 16 Postage, copying and printing 54.22 Oct. 16 Postage, copying and printing 78.38 Nov. 16 Postage, copying and printing 48.31 Dec. 16 Postage, copying and printing 71.97 Jan. 17 Postage, copying and printing 47.32 Feb. 17 Postage, copying and printing 20.70 Mar. 17 Postage, copying and printing 35.49 Apr. 17 Postage, copying and printing 33.52 May 17 Postage, copying and printing 52.74 Jun. 17 Postage, copying and printing 48.80 Jul. 17 Postage, copying and printing 57.18 Aug. 17 Postage, copying and printing 70.98 Sep. 17 Postage, copying and printing 108.94 Oct. 17 Postage, copying and printing 51.26 Nov. 17 Postage, copying and printing 49.79 Dec. 17 Postage, copying and printing 65.07 Jan. 18 Postage, copying and printing 93.16 Feb. 18 Postage, copying and printing 81.33 Mar. 18 Postage, copying and printing 100.56 Apr. 18 Postage, copying and printing 146.89 May 18 Postage, copying and printing 180.90 Jun. 18 Postage, copying and printing 245.48 Jul. 18 Postage, copying and printing 261.25 Aug. 18 Postage, copying and printing 170.55 Sep. 18 Postage, copying and printing 141.47 Oct. 18 Postage, copying and printing 98.09 Nov. 18 Postage, copying and printing 60.63 Dec. 18 Postage, copying and printing 54.22 Jan. 19 Postage, copying and printing 35.49

Total $2843.20 EXHIBIT Q SEXTANT STRATEGIES & RESEARCH

INVOICE

Law Offices of Kevin Shenkman

28905 Wight Rd.

Malibu, CA 90265

JOB SSR1066

LIVE TELEPHONE VOTER SURVEY

400 Registered Voters - City of Santa Monica, CA

PDI sample

Field 4/11-16, 2018

TOTAL SURVEY COST $17,250.00

TOTAL DUE UPON RECEIPT $17,250.00

Please Remit Payment to

Sextant Strategies & Research

3020 Lansbury Avenue

Claremont, CA 91711

Questions? - contact Jonathan Brown (909) 973-5567 or [email protected] SEXTANT STRATEGIES & RESEARCH

INVOICE

August 8, 2018

Jonathan Brown - expert testimony in Pico Neighborhood Association and Maria Loya v. City of Santa Monica

July 2, 2018 Preparation for deposition 5.0 hours $ 2500.00 July 3, 2018 Preparation for deposition 3.5 hours $1750.00 July 5, 2018 Preparation prior to deposition 1.5 hours $ 750.00

TOTAL $5,000.00

Please Remit Payment to

Sextant Strategies & Research 3020 Lansbury Avenue Claremont, CA 91711

Questions? - contact Jonathan Brown (909) 973-5567 or [email protected] SEXTANT STRATEGIES & RESEARCH

INVOICE

September 13, 2018

Jonathan Brown - expert testimony in Pico Neighborhood Association and Maria Loya v. City of Santa Monica

August 2, 2018 Review deposition transcript 1.5 hours $ 750.00 August 3, 2018 Preparation for testimony 1.5 hours $ 750.00 August 3, 2018 Present all day (not called) 5.5 hours $2,750.00 August 6, 2018 Present until 3:30 (testified) 6.5 hours $3,750.00

TOTAL $8,000.00

Please Remit Payment to

Sextant Strategies & Research 3020 Lansbury Avenue Claremont, CA 91711

Questions? - contact Jonathan Brown (909) 973-5567 or [email protected] ul O

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David Ely 6575 N Vista Street DATE: March 10, 2019 San Gabriel, CA 91775 INVOICE # 190407A Phone (626) 285-3074 Email [email protected] FOR: PNA V Santa Monica BILL TO: CVRA analysis Kevin Shenkman Shenkman & Hughes 28905 Wight Road Malibu, CA 90265

DESCRIPTION QUANTITY RATE AMOUNT

CVRA - Database,Analysis,Mapping and Testimony 324.50 $300 $ 97,350.00

Political Data Inc. $ 132.76

TOTAL $ 97,482.76

Please make checks payable to Compass Demographics Inc. (EIN 90-0877169) For questions regarding the services covered by this invoice, please contact Dave Ely at (626) 285-3074.

THANK YOU FOR YOUR BUSINESS! Date Task Hours 7/10/2015 Meet with M. Hughes 4.5 7/12/2015 Initial Database Geography 5.75 7/13/2015 Geographic data review and testing 5.5 7/14/2015 Election Data processing 2.5 7/15/2015 Election Data processing 2.75 7/26/2015 Election Data review and testing 3 7/27/2015 Meet with M. Hughes 5 7/28/2015 Election Data processing 6 7/30/2015 Election Data processing 3.25 8/1/2015 Election Data processing 3.75 8/4/2015 Election Data processing 3 8/9/2015 Election Data processing 2.5 8/12/2015 Election Data review and testing 6.75 8/13/2015 Meet with M. Hughes 5.5 2/22/2016 Preliminary review of remedy effectiveness 5 7/1/2016 Census Geographic data 6.75 7/18/2016 Census Demographic data processing 2.25 8/17/2016 Census Demographic data processing 2.5 8/30/2016 Election data processing 4 12/6/2016 Geo and Election Data update 6.25 12/21/2016 Election Data review and testing 2.5 2/11/2017 Election Data processing 5.75 2/12/2017 Election Data review and testing 3 2/21/2017 Election Data review and testing 1.5 5/5/2017 Historical Census research 3 5/23/2017 Candidate address preliminary analysis 3.25 6/8/2017 Meeting with K. Shenkman and J. Jones 4 6/21/2017 Meeting with J. Jones 5.25 6/22/2017 Meeting with J. Jones 6 6/23/2017 Meeting with J. Jones 4.75 6/27/2017 Meeting with J. Jones 5.5 7/3/2017 Meeting with J. Jones 6 7/5/2017 Meeting with J. Jones 3.25 7/10/2017 Meeting with J. Jones 7.25 7/11/2017 Meeting with J. Jones 6 7/24/2017 Geographic data supplement 1.5 7/25/2017 Meet with K. Shenkman, A. Alarcon and A. Gonzalez 4 7/26/2017 Geographic data review and testing 6.25 10/16/2017 Election Data update 3 12/29/2017 Demographic data update and merge 6.75 1/5/2018 Election Data update 5.5 2/12/2018 Geographic analysis 5.25 2/13/2018 Geographic analysis 2.5 3/16/2018 Work with K. Shenkman on case and report 3 3/19/2018 Work with K. Shenkman on case and report 2 3/20/2018 Election recreations 4 4/4/2018 SJ opposition, review and analysis 2.75 4/5/2018 SJ opposition, review and analysis 4.5 4/9/2018 SJ opposition, review and analysis 3.5 4/24/2018 SJ opposition, review and analysis 4.75 4/27/2018 SJ opposition, review and analysis 5 4/30/2018 Meet with K. Shenkman, A. Alarcon and A. Sanchez 3.5 5/3/2018 SJ opposition, review and analysis 3.25 5/9/2018 Meet with M. Hughes 4.25 5/14/2018 SJ opposition, review and analysis 3.75 5/17/2018 SJ opposition, review and analysis 3.5 5/22/2018 SJ opposition, review and analysis 3 5/27/2018 SJ opposition, review and analysis 5.5 5/29/2018 SJ opposition, review and analysis 6.25 5/30/2018 SJ opposition, review and analysis 2.5 6/12/2018 Defendant expert review 1.75 7/3/2018 Meet with M. Grimes, K. Shenkman and T. Crane 6.5 7/5/2018 Meet with M. Grimes, M. Hughes and K. Shenkman 4 7/9/2018 Depo prep, analysis and review 2.75 7/10/2018 Depo prep, analysis and review 6 7/12/2018 Deposition travel 2.25 7/13/2018 Declaration prep, analysis and review 6.5 7/23/2018 Declaration prep, analysis and review 2 7/27/2018 Declaration prep, analysis and review 6 7/30/2018 Declaration prep, analysis and review 4 7/31/2018 Declaration prep, analysis and review 5.5 8/1/2018 Trial Prep 4.5 8/2/2018 Trial Prep and Testimony 5.75 8/3/2018 Trial Prep and Testimony 9 8/6/2018 Consult for Morrison crossexam 3 12/3/2018 Remedy Brief 3.75 1/18/2019 Remedy review 2.5

Total 324.5 @$300/hr $ 97,350.00