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Washington AG makes strong case for sanctions

The Attorney General of Washington State filed a brief with the Supreme Court of the State of Washington, making a strong case that sanctions in the amount of $12,675 assessed by the court in the matter of the appeal in Jordan v. Reed were reasonable and proper, and that the Court should reject Jordan’s request for a reduction in fees.

The AG makes several points:

  1. Sanctions are meant to be a deterrent against future misconduct.
  2. Jordan had been warned by the trial court and the Attorney General that her appeal was frivolous.
  3. Plaintiff Jordan herself, through multiple filings, multiplied the effort that was required of the State to deal with her appeal.
  4. Market rates are the established method of calculating attorneys’ fees in Washington State.

After reading so much incompetent rambling in birther lawsuit filings, it is always refreshing to read a clear, concise well-argued brief well-founded in the law.

I bear Linda Jordan no ill will and no doubt she engaged in her reckless pursuit of a frivolous appeal partly encouraged by a long list of birthers who got away with the same thing. Still she was warned, and for birthers as well as everyone else, actions have consequences.

Read the brief:

 

Jordan v Reed/Wyman – Answer To Motion To Modify Attorney Fees – WA Obama Ballot Challenge – 2/20/2013 by ObamaRelease YourRecords

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47 Responses to Washington AG makes strong case for sanctions

  1. avatar
    Arthur February 25, 2013 at 7:59 am #

    Here’s the Supreme Court of Washington State’s response to Linda Jordan’s appeal for reduced attorney’s fees.

    http://www.scribd.com/doc/127072591/Jordan-v-Reed-Wyman-Answer-To-Motion-To-Modify-Attorney-Fees-WA-Obama-Ballot-Challenge-2-20-2013

  2. avatar
    misha marinsky February 25, 2013 at 9:34 am #

    Bovril: The BEST likely outcome for her now is simply the 13K in costs plus the ex-judges fee, a more likely result is INCREASED costs plus the ex-judges fees.

    Jordan claims she raised “approximately $8,600 for Linda’s defense.”

    https://secure.piryx.com/donate/ZSBbZAAV/Linda-Jordan/defensefund

  3. avatar
    Dr. Conspiracy February 25, 2013 at 10:06 am #

    Thanks for the tip.

    Arthur: response to Linda Jordan’s appeal for reduced attorney’s fees.

  4. avatar
    alg February 25, 2013 at 10:17 am #

    Shouldn’t be a surprise. I know Mr. Even to be a thorough and diligent attorney. Also, being personal friends with both the former and newly elected Washington Secretary of State, I know that their mutual commitment to due process, fairness and careful financial management. wouldn’t accept anything less than a proper and accurate accounting of expenses incurred.

  5. avatar
    Rickey February 25, 2013 at 10:48 am #

    I am happy to see that the brief clears up any and all questions about whether it was appropriate to charge “market rate” for the attorney fees. The salaries of Mr. Even and his associate are irrelevant in this context.

  6. avatar
    The Magic M February 25, 2013 at 11:50 am #

    Isn’t Linda barred from claiming “my appeal was so frivolous, it shouldn’t have been much work” when she has repeatedly claimed her appeal was not frivolous? Isn’t that venire contra factum proprium or something?

    I once sued a guy for breach of contract (he refused to hand over the car I had bought from him); in his emails, he repeatedly claimed the car was worth more than 10,000 EUR more than what the price was, yet in court he claimed he owed no damages because the car was not worth one cent more. The court slapped him severely for that, but then again, German civil law is certainly different from US law.

  7. avatar
    john February 25, 2013 at 1:25 pm #

    The lawyer makes the case that Jordan should be sanctioned to curtail future behavior. The lawyer’s argument is unconvincing. First, Jordan is NOT a lawyer so her legal expertise and zelousness makes it unlikely Jordan will continue further. The lawyer then tries to say that her case is frivilous because the court found that all the cases in 2008 were dismissed and Jordan should have known about them. Again, this just of the many many remarks the lawyer uses from the decision that are highly predijuced and biased. Further, the judge’s remarks are not supported by the evidence. This was the 2012 election and not the 2008 election. Jordan’s complaint makes no references to any cases from 2008 and Jordan is NOT a lawyer so due dilligence is necessarly expected. While Jordan was certainly aware of the ballot challenges from 2012, given her complaint and the evidence, there is no reason to conclude that Jordan knew about any of the cases from 2008. The lawyer’s argument is unconvincing.

  8. avatar
    justlw February 25, 2013 at 2:43 pm #

    john: her legal expertise and zelousness makes it unlikely Jordan will continue further.

    AHHHAHAHAHAHAHAHA!

    Oh, I’m sorry; you were serious there? The entire history of birfer behavior lays behind us as a counterargument.

  9. avatar
    US Citizen February 25, 2013 at 3:16 pm #

    john: The lawyer makes the case that Jordan should be sanctioned to curtail future behavior.

    John, “future behavior” applies to all lawyers and plaintiffs, not just Jordan.

  10. avatar
    Dave B. February 25, 2013 at 3:38 pm #

    Well of course it is, to you.

    john: The lawyer’s argument is unconvincing.

  11. avatar
    Graham Shevlin February 25, 2013 at 3:57 pm #

    John, your cry-fest over Linda Jordan is not at all convincing either. If Jordan wants to act as her own lawyer, she has to take on all of the responsibilities that come with being a lawyer. She can’t have it both ways, by not bothering to to research all of the previous cases of this type, ignoring messages and warnings from the court, and then begging and pleading when she gets sanctioned for (a) not understanding the previous cases and what they meant for her filings, and (b) ignoring a clear written warning from the court that further appeals would be regarded as frivolous and treated accordingly.
    In short, Jordan did not do her homework, and then refused to listen to the messages from the court. She should pay the sanctions, for no other reason than that they function as a fine on her for her own stupidity.

  12. avatar
    donna February 25, 2013 at 4:04 pm #

    Graham Shevlin:

    and then she got a birther judge, who was not re-elected, to represent her

    from the right: Washington State Responds To Linda Jordan’s Motion To Modify
    Sanctions: Attorney General Admits They’re Trying To Stop Linda Jordan
    From Challenging Obama’s Felony Identity Document Fraud

    “In short the say ‘a substantial sanction is necessary’ in order to silence those that challenge Obama’s identity document fraud.”

    http://obamareleaseyourrecords.blogspot.com/2013/02/wa-ag-admits-theyre-trying-to-silence-linda-jordan.html

    seriously??? “FACT” to them is a 4-letter curse word beginning with “F”

  13. avatar
    Rickey February 25, 2013 at 4:15 pm #

    john:
    The lawyer makes the case that Jordan should be sanctioned to curtail future behavior.The lawyer’s argument is unconvincing.First, Jordan is NOT a lawyer so her legal expertise and zelousness makes it unlikely Jordan will continue further. The lawyer then tries to say that her case is frivilous because the court found that all the cases in 2008 were dismissed and Jordan should have known about them. Again, this just of the many many remarks the lawyer uses from the decision that are highly predijuced and biased.Further, the judge’s remarks are not supported by the evidence. This was the 2012 election and not the 2008 election. Jordan’s complaint makes no references to any cases from 2008 and Jordan is NOT a lawyer so due dilligence is necessarly expected.While Jordan was certainly aware of the ballot challenges from 2012, given her complaint and the evidence, there is no reason to conclude that Jordan knew about any of the cases from 2008.The lawyer’s argument is unconvincing.

    Well, John, as usual your arguments are ludicrous. Other have already pointed that sanctions are designed to deter everyone from filing baseless lawsuits, not just the person who is being sanctioned.

    Jordan was not sanctioned for FILING her lawsuit, She was sanctioned for filing a frivolous APPEAL after the lawsuit was dismissed. When she filed her appeal, she certainly knew about the pre-2012 lawsuits because Judge McPhee’s order cites several of them! His Order also points out that under Washington law the Secretary of State had no duty (or even the right) to rule on Obama’s eligibility.

    The only way that Jordan could not have known about these things is if she failed to read Judge McPhee’s Order. You can read it yourself – you might actually learn something.

    http://www.scribd.com/doc/104357987/Linda-Jordan-v-WA-SOS-Sam-Reed-Obama-Ballot-Challenge-Judge-s-Decision-Forged-Birth-Certificate-Social-Security-Number-8-29-2012

  14. avatar
    john February 25, 2013 at 4:25 pm #

    I wonder if the lawyer intends to seek legal costs by filing this motion against Jordan? His response only calls for the original value of $12,000+. The lawyer didn’t ask for any more in his response. Could Jordan use that to her advantage? The response motion by the lawyer seems to indicate that Jordan’s motion is frivilous. If this true, then the lawyer should get legal costs of filing that motion accessed to Jordan. However, It unknown if the lawyer intends to seek costs. If not, then Jordan can argue that the lawyer is greedy and is acting bad faith. The lawyer wants to be greedy on something frivilous but doesn’t want to greedy on something else that is frivilous. In for a penny, in for a pound. Will lawyer stipulate that Jordan’s motion to modify is frivilous and then quickly move on response that lawyer has failed to ask for attorney fees and therefore is greedy?

  15. avatar
    Dr. Conspiracy February 25, 2013 at 4:48 pm #

    I presume that the statute doesn’t allow for him to collect additional costs. Given that everything in the case is settled law and the Washington Supreme Court has already determined that the appeal was frivolous, Jordan was and will remain toast. If anything, this request for the Court to amend its order is further evidence that sanctions are needed to restrain Jordan’s frivolous filings.

    john: I wonder if the lawyer intends to seek legal costs by filing this motion against Jordan? His response only calls for the original value of $12,000+. The lawyer didn’t ask for any more in his response. Could Jordan use that to her advantage?

  16. avatar
    john February 25, 2013 at 5:07 pm #

    “The only way that Jordan could not have known about these things is if she failed to read Judge McPhee’s Order. You can read it yourself – you might actually learn something.”

    Wrong! The judge ruled that Jordan knew about the challenges denied or dismissed in 2008 – a legal conclusion NOT supported by the record. The lawyer cites erroronous conclusions of the law.

    The judge’s decision was completely frivilous. It was based on extreme predujice and bias as to lack any real legal credibility. In addition, the judge makes conclusions in his decision like the lawyer cites that are completely unsupported by any facts or the record.

  17. avatar
    Joey February 25, 2013 at 6:42 pm #

    John wants to use the “but I’m not a lawyer” defense for Linda Jordan. That almost NEVER works for pro se plaintiffs and it often pisses judges off. That’s a good way to end up with an additional sanction.

  18. avatar
    bgansel9 February 25, 2013 at 6:42 pm #

    john:
    The lawyer makes the case that Jordan should be sanctioned to curtail future behavior.The lawyer’s argument is unconvincing.First, Jordan is NOT a lawyer so her legal expertise and zelousness makes it unlikely Jordan will continue further. The lawyer then tries to say that her case is frivilous because the court found that all the cases in 2008 were dismissed and Jordan should have known about them. Again, this just of the many many remarks the lawyer uses from the decision that are highly predijuced and biased.Further, the judge’s remarks are not supported by the evidence. This was the 2012 election and not the 2008 election. Jordan’s complaint makes no references to any cases from 2008 and Jordan is NOT a lawyer so due dilligence is necessarly expected.While Jordan was certainly aware of the ballot challenges from 2012, given her complaint and the evidence, there is no reason to conclude that Jordan knew about any of the cases from 2008.The lawyer’s argument is unconvincing.

    And where did you receive your JD, may I ask? What state did you take and pass the bar in? (Armchair idiots are not qualified to judge legal maneuvers without a law degree. Where is yours?)

  19. avatar
    jayHG February 25, 2013 at 7:31 pm #

    john:
    I wonder if the lawyer intends to seek legal costs by filing this motion against Jordan? His response only calls for the original value of $12,000+. The lawyer didn’t ask for any more in his response. Could Jordan use that to her advantage? The response motion by the lawyer seems to indicate that Jordan’s motion is frivilous. If this true, then the lawyer should get legal costs of filing that motion accessed to Jordan. However, It unknown if the lawyer intends to seek costs.If not, then Jordan can argue that the lawyer is greedy and is acting bad faith. The lawyer wants to be greedy on something frivilous but doesn’t want to greedy on something else that is frivilous.In for a penny, in for a pound.Will lawyer stipulate that Jordan’s motion to modify is frivilous and then quickly move on response that lawyer has failed to ask for attorney fees and therefore is greedy?

    What the hell are you babbling about…..?

  20. avatar
    Andrew Vrba, PmG February 25, 2013 at 7:45 pm #

    John, she messed with the bull, here comes the horns.
    The moral of the story: Don’t abuse the American legal system, or you’ll end up footing the bill.

  21. avatar
    Horus February 25, 2013 at 8:33 pm #

    john:
    I wonder if the lawyer intends to seek legal costs by filing this motion against Jordan? His response only calls for the original value of $12,000+. The lawyer didn’t ask for any more in his response. Could Jordan use that to her advantage? The response motion by the lawyer seems to indicate that Jordan’s motion is frivilous. If this true, then the lawyer should get legal costs of filing that motion accessed to Jordan. However, It unknown if the lawyer intends to seek costs.If not, then Jordan can argue that the lawyer is greedy and is acting bad faith. The lawyer wants to be greedy on something frivilous but doesn’t want to greedy on something else that is frivilous.In for a penny, in for a pound.Will lawyer stipulate that Jordan’s motion to modify is frivilous and then quickly move on response that lawyer has failed to ask for attorney fees and therefore is greedy?

    In john’s world lawyers are greedy, but billionaire oil barons are not.

  22. avatar
    Rickey February 25, 2013 at 8:40 pm #

    john:

    Wrong!The judge ruled that Jordan knew about the challenges denied or dismissed in 2008 – a legal conclusion NOT supported by the record.The lawyer cites erroronous conclusions of the law.

    The judge’s decision was completely frivilous. It was based on extreme predujice and bias as to lack any real legal credibility. In addition, the judge makes conclusions in his decision like the lawyer cites that are completely unsupported by any facts or the record.

    I see that your reading comprehension deficit has kicked in again. Let me try to simplify this for you.

    1. Judge McPhee did not sanction Linda Jordan for filing her lawsuit, notwithstanding his comment (undoubtedly accurate) that she “cannot be unaware of” the earlier similar lawsuits which had been filed and dismissed. Judge McPhee did not dismiss her lawsuit because of whatever knowledge she had or did not have about prior lawsuits. He dismissed the lawsuit because his Court had no jurisdiction, because Jordan had submitted no admissible evidence to support her claims, and Washington law does not require (or even permit) the Secretary of State to investigate the qualifications of Presidential candidates.

    2. Even if Linda Jordan did not know about the prior birther lawsuits when she filed her lawsuit, she certainly knew about them when she received Judge McPhee’s Order dated August 29, 2012. In the Order the judge specifically cites the Ankeny case, the Robinson case, the Keyes case, and the Rhodes case. He also refers to a “series of lawsuits” filed by the “self styled…leader of the birther movement.”

    3. Linda Jordan was sanctioned for filing a frivolous appeal, not for filing a frivolous lawsuit. You seem to be incapable of grasping that distinction. When she filed her appeal, she clearly knew about the many prior birther lawsuits which had been filed and dismissed. Judge McPhee told her that the law did not require or even allow the Secretary of State to investigate a Presidential candidate’s eligibility. He also told her that her “evidence” was admissible. That is why her appeal was ruled to be frivolous.

    In passing, it is also worth noting that in her appeal Jordan never denied Judge McPhee’s statement that she “cannot be unaware” of the prior birther lawsuits. You’re trying to make an argument which even she is not willing to make. Read her appeal and tell me where she claims that she was unaware of the prior lawsuits.

    http://www.scribd.com/doc/106321251/Obama-Ballot-Challenge-Appealed-to-WA-Supreme-Court

  23. avatar
    john February 25, 2013 at 11:27 pm #

    I can see why the lawyer went out of his way to threaten Jordan with sanctions and is coming after her. Jordan presented some pretty damning information about the behavior of the judge (who was so biased and predijuce as to lack credibility) and the opposing counsel that if proven true, both parties would be in big big trouble. Unfortunately, Jordan is not an attorney and did not possess to litigation experience to fight the lawyers’ motions that appeal was frivilous.

  24. avatar
    John Reilly February 26, 2013 at 1:03 am #

    The only admissible evidence I have seen Birthers offer is Pres. Obama’s birth certificate.

    John seems to have missed that little fact.

  25. avatar
    misha marinsky February 26, 2013 at 2:35 am #

    bgansel9: And where did you receive your JD, may I ask?

    The same place Orly Taitz did: At the bottom of a Cracker Jack box.

  26. avatar
    The Magic M February 26, 2013 at 4:34 am #

    john: However, It unknown if the lawyer intends to seek costs. If not, then Jordan can argue that the lawyer is greedy and is acting bad faith. The lawyer wants to be greedy on something frivilous but doesn’t want to greedy on something else that is frivilous. In for a penny, in for a pound. Will lawyer stipulate that Jordan’s motion to modify is frivilous and then quickly move on response that lawyer has failed to ask for attorney fees and therefore is greedy?

    Oh john, are you playing Catch-22 again? If the lawyer seeks costs, it is wrong, and if he doesn’t, it proves he wasn’t entitled to seeking costs in the first place, so he’s wrong as well?

  27. avatar
    Dr Kenneth Noisewater February 26, 2013 at 8:27 am #

    john: First, Jordan is NOT a lawyer so her legal expertise and zelousness makes it unlikely Jordan will continue further.

    If Jordan is not a lawyer she should have thought about this before she pursued this case.

  28. avatar
    Bob February 26, 2013 at 9:21 am #

    Washington AG Linda Jordan makes strong case for sanctions

  29. avatar
    donna February 26, 2013 at 9:51 am #

    if jordan is not a lawyer, she should have conferred with them BEFORE this began and when she lost (as she would have been told she would), she should have packed up her bag of toys and gone home

  30. avatar
    Daniel February 26, 2013 at 10:52 am #

    John, how long have you been coming here? How many of your predictions have come true (hint: none)?

    Do you enjoy being publicly wrong, John?

  31. avatar
    Rickey February 26, 2013 at 1:22 pm #

    john:
    I can see why the lawyer went out of his way to threaten Jordan with sanctions and is coming after her. Jordan presented some pretty damning information about the behavior of the judge (who was so biased and predijuce as to lack credibility) and the opposing counsel that if proven true, both parties would be in big big trouble. Unfortunately, Jordan is not an attorney and did not possess to litigation experience to fight the lawyers’ motions that appeal was frivilous.

    Silly John.

    Linda Jordan has a lawyer now, and her lawyer has conceded that her appeal was frivolous (by the way, you should take this opportunity to learn how to spell “frivolous”). In fact, her lawyer is arguing that her appeal was so egregiously frivolous that it should not have taken the AG’s office much time to defeat it.

  32. avatar
    Rickey February 26, 2013 at 1:27 pm #

    In my comment at 8:40 p.m. last night I meant to say:

    He also told her that her “evidence” was inadmissible.

  33. avatar
    john February 26, 2013 at 1:27 pm #

    How did Linda Jordan receive the letter from the attorney telling her not to appeal? Jordan probably should have destroyed to letter when she got it. Without proof of receipt or service of the letter, the attorney case is greatly weakened.

  34. avatar
    Dave B. February 26, 2013 at 1:36 pm #

    The only “pretty damning information” Linda Jordan has presented is about her own illegal use of E-Verify’s Self Check service.

    john: Jordan presented some pretty damning information about the behavior of the judge (who was so biased and predijuce as to lack credibility) and the opposing counsel that if proven true, both parties would be in big big trouble.

  35. avatar
    gorefan February 26, 2013 at 7:30 pm #

    john: Jordan probably should have destroyed to letter when she got it.

    She did just the opposite, she published it on a number of websites.

  36. avatar
    Bob February 26, 2013 at 9:30 pm #

    john: Without proof of receipt or service of the letter, the attorney case is greatly weakened.

    You’re wrong about that. Our USPS is dependable enough to assume that correspondence entered into the system has been delivered or returned. People cannot claim that they didn’t receive something and just ignore whatever it is they don’t want to deal with.

    What a childish solution you came up with.

  37. avatar
    Rickey February 26, 2013 at 10:27 pm #

    john:
    How did Linda Jordan receive the letter from the attorney telling her not to appeal? Jordan probably should have destroyed to letter when she got it.Without proof of receipt or service of the letter, the attorney case is greatly weakened.

    So you are suggesting that she should have destroyed the letter and then commit perjury by swearing that she never received it? You would be okay with that?

  38. avatar
    Graham Shevlin February 26, 2013 at 10:43 pm #

    John, you are disobeying the First Law Of Holes. RIght now you are in a hole of your own digging, having started at the top of the thread with your usual whining and special pleading on behalf of a person who did not understand what she was getting into, and is now suffering the consequences from sticking her head in the sand and listening only to the voice in her head. Now you’re suggesting that it would have been a good idea for Linda Jordan to pretend that she never received any letters from the court.
    Have you any idea how irredeemably idiotic that last suggestion makes you look?

  39. avatar
    JD Reed February 26, 2013 at 10:55 pm #

    john:
    Jordan presented some pretty damning information about the behavior of the judge …

    Precisely what?

  40. avatar
    alg February 27, 2013 at 12:46 am #

    john:
    Jordan presented some pretty damning information about the behavior of the judge

    John, I have known and worked with Judge McPhee for many years and know him to be an outstanding jurist, well regarded in Washington State. I have even served on one of his juries. He is thoughtful, well-prepared, dispassionate and objective.

    It shouldn’t surprise anyone that Jordan, perpetually on the losing end of her birther litigation, would lash out and try to blame him for following the law.

  41. avatar
    Bonsall Obot February 27, 2013 at 1:47 am #

    John is even more delusional than Orly, but at least she’s fleecing the rubes; John is an uncompensated stooge.

    Please proceed, John. You’re the most amusing troll we have.

  42. avatar
    The Magic M February 27, 2013 at 4:21 am #

    Bob: People cannot claim that they didn’t receive something and just ignore whatever it is they don’t want to deal with.

    It’s another common crank behaviour. The German law forum I co-moderate is full of people trying to get their pet method of evading service “checked” and “made bullet-proof”.
    (E.g. one guy had a letterbox in front of his house that looked kinda wrecked and a “pretty” one on the side entry and claimed that service to the former was invalid because it was “obviously not used” and that somehow the postman had to know there was another on the side of the house…)

  43. avatar
    realist February 27, 2013 at 8:39 am #

    john:
    .Without proof of receipt or service of the letter, the attorney case is greatly weakened.

    No, it’s not. The frivolous appeal/sanctions justified would not be altered or weakened even if they’d never written the letter. It was proper for them to do, but not required.

  44. avatar
    G February 28, 2013 at 2:53 am #

    Irredeemably idiotic suggestions have been John’s MO for years now…

    I thought he claimed he was going to give this nonsense up after his “last ditch” effort with the electoral college certification process…

    …but nope, John is just irredeemably idiotic and can’t move on…

    Graham Shevlin: Have you any idea how irredeemably idiotic that last suggestion makes you look?

  45. avatar
    Rickey February 28, 2013 at 12:06 pm #

    G:
    Irredeemably idiotic suggestions have been John’s MO for years now…

    I thought he claimed he was going to give this nonsense up after his “last ditch” effort with the electoral college certification process…

    …but nope, John is just irredeemably idiotic and can’t move on…

    Didn’t Orly say after the election that she was going to stop filing birther lawsuits?

    .I agree with you, they can’t move on. They have too much of an emotional investment in this, and unfortunately Orly has the financial resources to continue what she is doing.

    What might stop her are severe sanctions in the Mississippi case (possibly Grinols, as well).`We shall see.

  46. avatar
    Graham Shevlin February 28, 2013 at 4:31 pm #

    I have noticed that partisan opponents of Obama are unable to give up sniping and protesting…I had at least 2 Facebook friends who said “election over, back to normal stuff” last Fall, but no, they are still posting snark and snipery about the POTUS at every opportunity. They are still unable to accept that Their Guy Lost.

  47. avatar
    donna March 4, 2013 at 10:18 am #

    Jordan v Reed – Appellant Reply to Motion to Modify/DoS – WA Obama Ballot Challenge – 2/28/2013

    “The Attorney General acknowledges he sought and obtained an award of attorney fees in the amount of $12,675 without disclosing fees actually billed the client for the hours claimed in his declaration were $3,412.40”

    “The issue here is whether an award of reasonable attorney fees is compensatory or punitive. The AG prefers the later, at least when the government is the recipient rather than the party which must pay.”

    “Appellant does not dispute that the rate the AG actually bills the Secretary (about $65 per hour) is reasonable nor that it is appropriate to multiply that rate times the reasonable hours necessarily expended to dismiss an alleged frivolous appeal; however the government is entitled to compensation, not a penalty or overreaching windfall”

    “Your undersigned knows of no precedent to support a nearly $13,000 award where actual attorneys fees for documented time were less than $3,500, before adjustments down.”

    http://www.scribd.com/doc/128274665/Jordan-v-Reed-Appellant-Reply-to-Motion-to-Modify-DoS-WA-Obama-Ballot-Challenge-2-28-2013