Case 1:17-cv TCB Document 46-3 Filed 01/30/18 Page 1 of 44 EXHIBIT C DECLARATION OF EZRA D. ROSENBERG

Transcription

1 Case 1:17-cv TCB Document 46-3 Filed 01/30/18 Page 1 of 44 EXHIBIT C DECLARATION OF EZRA D. ROSENBERG

2 Case 1:17-cv TCB Document 46-3 Filed 01/30/18 Page 2 of 44 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION GEORGIA STATE CONFERENCE OF * THE NAACP, et al., * DRAFT * Plaintiffs, * * CA No. 1:17cv01427-TCB v. * * STATE OF GEORGIA and * BRIAN KEMP, in his official capacity * as Secretary of State for the State of * Georgia, * * Defendants. * DECLARATION OF EZRA D. ROSENBERG 1. My name is Ezra D. Rosenberg. I am over the age of twenty-one (21) years of age and am fully competent to execute this Declaration. I have knowledge of the facts recited here, which are true and correct, and are based on my personal knowledge and my review of the records of the Lawyers Committee for Civil Rights Under Law (hereinafter, Lawyers Committee ). 2. I make this Declaration in support of the Special Motion for Attorneys Fees and Expenses filed by Plaintiffs in this action. 3. The Lawyers Committee is a nonpartisan, nonprofit organization, formed in 1963 at the request of President John F. Kennedy to enlist the private bar s 1

3 Case 1:17-cv TCB Document 46-3 Filed 01/30/18 Page 3 of 44 leadership and resources in combating racial discrimination and the resulting inequality of opportunity. The principal mission of the Lawyers Committee is to secure equal justice for all through the rule of law, targeting in particular the inequities confronting African Americans and other racial and ethnic minorities, including, but not limited to, in the field of voting rights. 4. I am Co-Director of the Voting Rights Project of the Lawyers Committee and co-lead counsel for plaintiffs in this action with Ira Feinberg, Esq., a partner in the New York City office of Hogan Lovells, and with Bryan Sells, local Georgia barred counsel. 5. As co-lead counsel, I am responsible for supervising the handling of this matter by the Lawyers Committee attorneys and staff, formulating and directing the case strategy, and implementing the strategy for all aspects of the case. 6. I have personal knowledge of the work of the Lawyers Committees attorneys and support staff for Plaintiffs on this lawsuit from its pre-suit investigation and through the present. Legal Background and Experience 7. I joined the Lawyers Committee in November 2014 as Special Senior Counsel in the Legal Mobilization Project before being named Co-Director of the Voting Rights Project in July

4 Case 1:17-cv TCB Document 46-3 Filed 01/30/18 Page 4 of Prior to joining the Lawyers Committee, I was a partner at Dechert LLP, where I served several terms on the firm s Policy Committee, as a Deputy Chair of the firm, and as co-chair of Dechert s Product Liability and Mass Torts Group. I have been recognized for my litigation work in New Jersey and nationwide by numerous publications, including Chambers, The Legal 500 United States, Benchmark Litigation, and, in 2014, was named as one of the top 500 lawyers in the nation by Lawdragon. 9. At Dechert, I was actively involved in pro bono representations, including several significant cases with the Lawyers Committee. I served as one of the lead counsel challenging Texas s photo ID voting law, served as co-lead trial and lead coordinating counsel in both the Section 2 and Section 5 cases (tried in 2014 and 2012 respectively); served as co-lead trial counsel in a school desegregation case tried in Pitt County, North Carolina in 2013; and supervised the advantageous settlements of a minority profiling case in New Jersey and of a prison conditions case in Passaic County, New Jersey. In 2014, I successfully argued an appeal on behalf of the NJ-ACLU before the New Jersey Supreme Court, dealing with the admissibility of a defendant s rap lyrics in his attempted murder trial, helping to persuade the court to adopt stringent standards before admitting such evidence. In 3

5 Case 1:17-cv TCB Document 46-3 Filed 01/30/18 Page 5 of , I was named to The National Law Journal s Pro Bono Hot List for my role in significant public interest cases of national importance. 10. I began my career with the New Jersey Department of the Public Advocate, focusing on special project criminal appeals, arguing several times before the New Jersey Supreme Court, including a landmark case that set the standard for judicial review of prosecutorial denials of pretrial intervention, and a series of cases which established protections against discovery by the prosecution of investigative and expert reports criminal defendants did not intend to use at trial. I joined the Lands & Natural Resources Division of the United States Department of Justice in 1979, where, as a Senior Trial Attorney, I handled a variety of cases relating to the nation s lands, including the defense of surface mining regulations and a pre-chadha one House veto case under the Wilderness Act. 11. I graduated from the University of Pennsylvania, B.A., Cum laude, in 1971 and from New York University School of Law, J.D., 1974, Cum laude, where I received the Founders Day Award and was admitted to the Order of the Coif. I am a past President of the Mercer County, NJ, Bar Association and have received numerous awards during my career, including the Department of Justice Award for Meritorious Service in 1982, the New Jersey Commission on Professionalism 4

6 Case 1:17-cv TCB Document 46-3 Filed 01/30/18 Page 6 of 44 Professional Lawyer of the Year Award in 1997, the American Jewish Congress Learned Hand Award in 2011, the Mercer County Bar Association s Michael J. Nizolek Award for Service to the Bar in 2014, the Lawyers Committee s Brooke R. Burdette Award for Best New Board Member in 2014, the ACLU of NJ s Legal Leadership Award in 2015, and a Joint Resolution of the New Jersey Legislature in 2015, honoring my pro bono service. 12. I am familiar with the legal work that the Lawyers Committee staff performed on behalf of Plaintiffs in connection with all aspects of this litigation. Based on my experience and knowledge of that representation, I believe that the work performed was reasonable and appropriate. 13. The work I personally performed in connection with the litigation included overseeing the initial pre-suit investigation, developing litigation strategy and oversight, supervising the Lawyers Committee s attorneys and other staff working on the matter, and reviewing and revising pleadings and other key documents during the course of the litigation. 14. Due to the complexity of the case and the need to quickly complete the pretrial investigation and commence litigation due to the impending special runoff election in June 2017, the staffing of this litigation by the Lawyers Committee included myself, one senior attorney, Julie Houk, and one junior attorney, John 5

7 Case 1:17-cv TCB Document 46-3 Filed 01/30/18 Page 7 of 44 Powers. I am familiar with the background and experience of the Lawyers Committee staff members who worked on this litigation. Timekeepers, Their Experience, and Their Roles 15. Julie Houk joined the Lawyers Committee in May 2014 as a Senior Special Counsel in the Voting Rights Project. Ms. Houk graduated from Marquette University in 1979 where she received a B.A. degree with double majors in journalism and political science. Ms. Houk also received an M.A. degree in political science from Marquette University in 1981 and was inducted into Alpha Sigma Nu, the honor society of Jesuit universities, the same year. Ms. Houk obtained her J.D. from the Golden Gate University School of Law in 1984, where she served as a writer on the Law Review and was a lecturer in the school s legal writing and research seminar for first year law students. Ms. Houk was admitted to the State Bar of California in December Ms. Houk is also admitted to practice law in the District of Columbia, Massachusetts, New Hampshire and Illinois (voluntarily registered as inactive in Illinois). She is also admitted to practice before the United States District Courts for the Northern, Eastern, Central and Southern Districts of California and the United States Court of Appeals for the Ninth Circuit. 6

8 Case 1:17-cv TCB Document 46-3 Filed 01/30/18 Page 8 of Before joining the Lawyers Committee, Ms. Houk was a litigation attorney with a firm in Berkeley, California for almost 28 years where her practice focused primarily upon civil rights litigation in California federal and state courts. Ms. Houk was one of the lead plaintiffs attorneys in a landmark civil rights action, Allen v. City of Oakland (also known as the Oakland Riders litigation), which resulted in a $10.9 million dollar damage settlement for 119 individual plaintiffs who had been victimized by a group of rogue officers and which led to the entry of a consent order in 2003, mandating significant reforms in the Oakland Police Department which is still ongoing today. While practicing in California, Ms. Houk also argued significant civil rights cases before the United States Court of Appeals for the Ninth Circuit, including, Estate of Amaro v. City of Oakland, 653 F. 3d 808 (9 th Circuit 2011) and Smith v. City of Oakland, 379 Fed.Appx. 647 (9 th Cir. 2010). 17. Since joining the Lawyers Committee, Ms. Houk has led investigations and played a senior role in important voting rights litigation in Georgia, including in GA NAACP v. Kemp (also known as the exact match voter registration litigation), which resulted in the restoration of thousands of previously cancelled voter registration applicants to pending status and led to reforms of the Secretary of State s voter registration verification process. Ms. Houk also played a senior role in GA Coalition for the Peoples Agenda v. Deal, in which the plaintiffs obtained a 7

9 Case 1:17-cv TCB Document 46-3 Filed 01/30/18 Page 9 of 44 preliminary injunction extending the voter registration deadline for Chatham County residents in the aftermath of Hurricane Matthew. Ms. Houk also played a lead role in GA NAACP v. Hancock County Board of Elections and Registration, which involved systemic, discriminatory purges of the Hancock County voter rolls and resulted in the restoration of improperly purged voters to the Hancock County voter registration list and a settlement requiring the defendants to undertake reforms to prevent a recurrence of the unlawful purges. 18. Ms. Houk has also made presentations on the subject of voting rights at continuing legal education seminars and other events, including at the Georgia State Bar convention, the National NAACP and Georgia NAACP annual conventions and at civic engagement events in Georgia, South Carolina and Michigan. Ms. Houk has also participated in the drafting of amicus briefs filed by the Lawyers Committee in the Supreme Court on important voting rights issues. 19. Ms. Houk was the principal attorney assigned to the initial factual investigation of this matter shortly after the Lawyers Committee was contacted by local partners in March 2017 with concerns that Georgia s voter registration scheme in federal run-off elections violated Section 8 of the National Voter Registration Act of 1993 (hereinafter, NVRA ). Because a potential special runoff election in Georgia s Sixth Congressional District would be impacted by this 8

10 Case 1:17-cv TCB Document 46-3 Filed 01/30/18 Page 10 of 44 voter registration scheme in June 2017, Ms. Houk had to quickly commence an investigation of the matter in order to determine whether emergency litigation would need to be filed. 20. Ms. Houk continued to work on all aspects of the case throughout its duration, including extensive work in overall case strategy and development. Ms. Houk was the primary contact for the individual and organizational Plaintiffs and spent considerable time with the clients developing the facts of the case, identifying witnesses and obtaining relevant documents and material from the clients, witnesses and other sources. She also communicated with the Defendants counsel; drafted and revised pleadings; and appeared at multiple telephone conferences with the litigation team and with opposing counsel. Ms. Houk also prepared for and appeared at the hearing of the Plaintiffs motion for a preliminary injunction and participated in the settlement negotiations which led to the filing of the Consent Order to settle the merits of the case. Ms. Houk also participated in efforts to settle the fee and cost claim and, failing that, worked on the filings related to the motion to recover Plaintiffs fees and expenses. 21. John Powers joined the Lawyers Committee in September 2015 as an associate counsel in the Voting Rights Project. Before joining the Lawyers Committee, he worked for eight years in the Voting Section at the Department of 9

11 Case 1:17-cv TCB Document 46-3 Filed 01/30/18 Page 11 of 44 Justice. Prior to the Shelby County decision, Mr. Powers reviewed submissions for preclearance under Section 5 of the Voting Rights Act. More recently, he was part of DOJ litigation teams challenging the Texas voter ID and North Carolina omnibus election laws in federal district court. While at DOJ, Mr. Powers received the AAG Distinguished Service Award and other awards for his work. He was admitted to practice law in Maryland in 2013 and in the District of Columbia in Mr. Powers obtained his J.D. from the Georgetown University Law Center in He served as Executive Articles Editor for the Georgetown Journal of Law and Modern Critical Race Perspectives. He has been published in that journal, as well as The Georgetown Law Journal and the Harvard Journal on Racial and Ethnic Justice. Mr. Powers earned his B.A. in History from Haverford College, and attended Mansfield College at Oxford University for a year. Mr. Powers assisted in the initial investigation of this matter; conducted legal research; assisted in the drafting of the complaint and motion for a preliminary injunction; and continued to work on the matter during the course of the litigation. 10

12 Case 1:17-cv TCB Document 46-3 Filed 01/30/18 Page 12 of 44 The Lawyers Committee s Representation of Plaintiffs and How the Work for Plaintiffs Was Recorded, Edited and Summarized 23. The Lawyers Committee was engaged to represent the individual and organizational plaintiffs on a pro bono basis, with the understanding that, it would retain the right to petition the court for recovery of its fees and costs in the event the plaintiffs prevailed in their claims. 24. In connection with its representation of the plaintiffs, the Lawyers Committee signed written retainer agreements with the plaintiffs and a co-counsel agreements with Hogan Lovells and Bryan Sells, setting forth the terms of the engagement for their representation of the plaintiffs in this matter. In the co-counsel Agreement, the Lawyers Committee agreed that its staff would keep contemporaneous records of the time spent on the matter, which would include sufficient specificity to identify the date, amount of time spent, and the work accomplished by each timekeeper on this matter. 25. Thus, in accordance with the co-counsel Agreement, and as part of the Lawyers Committee s normal business practice, the assigned attorneys tracked the time they worked on this matter. As is normal and customary for Lawyers 11

13 Case 1:17-cv TCB Document 46-3 Filed 01/30/18 Page 13 of 44 Committee staff, the attorneys working on this matter entered their time into a computer program designed to track the time that staff devoted to the case. 26. A chart compiling the time incurred by each Lawyers Committee staff member on this action for which we are seeking payment are attached and incorporated herein by reference as Exhibit 1. The chart is a summary based upon the electronic time keeping records of the Lawyers Committee s personnel, which were prepared in the regular and ordinary course of business. It is the practice of the Lawyers Committee staff to prepare and keep such records; the records were made and kept by individuals with personal knowledge of the entries; and the entries were made at or about the date reflected in the chart. 27. I have personally reviewed the entries. In the reasonable exercise of billing judgment, the Lawyers Committee is not seeking payment of certain billing entries denoted with N/C, meaning No Charge, which may have been for time spent on certain tasks which was excessive, duplicative, redundant, inefficient, not directly related to the case, not sufficiently detailed, or which in the exercise of my reasonable billing judgment, the Lawyers Committee has agreed not to seek recovery for one reason or another. 28. As shown in the chart attached at Exhibit 1, the Lawyers Committee seeks reimbursement for the time of its attorneys and staff spent working on this 12

14 Case 1:17-cv TCB Document 46-3 Filed 01/30/18 Page 14 of 44 case at the following hourly rates: (1) Ezra Rosenberg, Co-Director, $650; (2) Julie Houk, Senior Special Counsel, $550; and, (4) John Powers, Counsel $400. Attached hereto as Exhibit 2 is a chart itemizing each of the expenses incurred and paid by the Lawyers Committee in connection with, and in furtherance of, this litigation and the redacted backup records related to said expenses. This chart is a summary based upon both the electronic records maintained by the Lawyers Committee to keep track of expenses for its clients. The electronic records were prepared in the regular and ordinary course of business; it is the practice of the Lawyers Committee to prepare and keep such records; the records were made and kept by individuals with personal knowledge of the entries; and the entries were made at or about the date reflected in the chart. Hourly Rates Charged by the Lawyers Committee Compared to Market Rates 29. In connection with this submission, I reviewed hourly rate information available from the online billing rates database of the Fulton County Daily Report, The data available included rates for certain attorneys from mid-size to larger firms from 2006 through In some instances, rates were available for attorneys up to 2012, or earlier. The data 13

15 Case 1:17-cv TCB Document 46-3 Filed 01/30/18 Page 15 of 44 that I reviewed indicated hourly billing rates for law firm partners ranging between $300-$950/hour and $285-$470 for associates. 30. I also reviewed a number of cases in the United States District Court for the Northern District of Georgia, Atlanta Division, in which Courts have made attorneys fee awards in recent years. These cases included: Andrews v. Autoliv Japan Ltd., Civ. No. 1:14-CV-3432-WSD (N.D. Ga. July 28, 2017) (finding that the customary hourly rates of attorneys with Atlanta s Alston and Bird of $715 and $575, which were billed at a 15% voluntary reduction in that litigation, were reasonable rates for a partner and senior associate in the Atlanta metro legal market); Griffin v. General Mills, 157 F.Supp.3d (N.D. Ga. 2016)(finding that $650/hour for a senior partner and $455/hour for an associate in an Erisa case were reasonable rates in the Atlanta market); In re Application of: Anna Aleksandrovna Sergeeva, Civil Action No. 1:13-CV-3437-LMM, DOC (N.D. Ga. October 20, 2015)(a partner with Atlanta s Bondurant Mixson & Elmore, LLP averred in an affidavit that the firm s 2015 hourly rates for partners litigating the case ranged from $610 (13 years experience) to $885 (40+ years experience); and its hourly rates for associates ranged from $295 (1 year associate) to $395 (4 year associate); Purchasing Power, LLC, v. Bluestem Brands, Inc., 2016 WL , *2 (N.D. GA. April 6, 2016), reversed on other grounds, 851 F.3d 1218 (11 th Cir. 14

16 Case 1:17-cv TCB Document 46-3 Filed 01/30/18 Page 16 of )(finding hourly rates in 2016 of $650 for partners, $350 for associates and $225 for paraprofessionals to be consistent with those charged by competent and experienced counsel for litigation of this type in the Atlanta metropolitan area. ); W.A. Griffin, M.D., v. General Mills, Inc., 157 F.Supp.3d 1350, (N.D. GA. 2016)(finding hourly rates in 2016 of $650 for a partner with 35 years experience, $455 for an associate, and $170 for a paralegal to be reasonable); Newpoint Media Group, LLC v. Mitchell Media Group, LLC, 2017 WL (N.D. Ga. April 14, 2017)(finding senior associate and associate hourly rates of $545; $345 and $325 were reasonable rates in the Atlanta market). 31. Based on my education, experience, and review of the Northern District of Georgia case law and Fulton County Daily Report rate survey, it is my opinion that the hourly rates assigned to the Lawyers Committee s staff in Exhibit 1 are reasonable and appropriate under the circumstances, particularly in light of the voluntary reductions the Lawyers Committee has agreed to apply in the exercise of billing judgment. The Lawyers Committee s Attorneys Fees 32. The total value of legal fees performed by the Lawyers Committee s staff in this matter from inception through January 12, 2018, less the aforementioned line item ( N/C ) reductions in the exercise of billing judgment, is 15

17 Case 1:17-cv TCB Document 46-3 Filed 01/30/18 Page 17 of 44 in the amount of $87,879. This encompasses hours of work performed in this matter through January 11, The number of hours billed and fees requested by the Lawyers Committee attorneys can be generally broken down by tasks and phases of litigation, as follows: LCCRUL investigation and client engagement Phase 1 Phase 2 Phase of Case Pre-suit factual investigation, initial legal research and client engagement Case Initiation (including preparation of complaint, motion for preliminary injunction, supporting declarations and memorandum of law) Reply Brief (in support of motion for preliminary injunction) Number of Amount Hours 50.1 $25, $27, $8,955 Phase 3 Oral Argument $6,809 Phase 4 Phase 5 Post-injunction Handling of Litigation Settlement Discussions (including negotiation of consent decree and consideration of Rule 68 offer of judgment) 12.8 $7, $2,530 16

18 Case 1:17-cv TCB Document 46-3 Filed 01/30/18 Page 18 of 44 Phase 6 Preparation of Attorneys Fee Motion (including legal research on attorneys fee issues) 17.5 $9,415 Totals $87, Based upon my education and experience, it is my professional opinion that the work performed and the amount of attorneys fees sought by the Lawyers Committee in this application are reasonable in light of the issues presented in this case, the complexity of the case, including that it was a case of first impression in Georgia and in the 11 th Circuit, the defendants refusal to resolve the case before the commencement of litigation in response to Plaintiffs pre-litigation NVRA notice letter, and the successful results achieved under the circumstances. 34. The Lawyers Committee s staff worked in a manner in which responsibilities were divided according to the relative skill sets of the lawyers involved. As Co-Director of the Voting Rights Project at the Lawyers Committee, my role is similar to that as a senior partner in a private firm. I am responsible for developing and implementing strategy, assigning and supervising staff and reviewing pleadings and evidence. As a senior special counsel in the Voting Rights Project, Ms. Houk s role is similar to that as partner or very senior associate 17

19 Case 1:17-cv TCB Document 46-3 Filed 01/30/18 Page 19 of 44 in a private firm. Mr. Powers, as a counsel in the Voting Rights Project, has a role that is similar to that of a 4-5 year associate in a private firm. Based upon the relative roles of the Lawyers Committee staff, the time spent on the litigation and on tasks was divided to prevent unnecessary duplication and to ensure that the matter proceeded in an efficient, but thoughtful and competent fashion. The division of labor on the case in this way is reflected in the hours billed on the case and the dollar amount of the fees being claimed by the Lawyers Committee attorneys. The Lawyers Committee s Litigation Expenses 35. In addition to its attorneys fees, the Lawyers Committee seeks to recover its expenses of litigation incurred and paid in this matter, in the amount of $2, These litigation expenses included the pro hac vice admission fees that local co-counsel, Bryan Sells, advanced on behalf of the Lawyers Committee s attorneys and which we reimbursed to him, travel expenses incurred in connection with the May 4, 2017 hearing on the emergency motion for a preliminary injunction and Westlaw legal research charges. 37. It is the Lawyers Committee s standard practice to account for these types of expenses separate from the hourly rates recorded for the legal work 18

20 Case 1:17-cv TCB Document 46-3 Filed 01/30/18 Page 20 of 44 performed. Based on my experience, this practice is consistent with the typical practice in all Georgia markets including the United States District Court for the Northern District of Georgia. Total Amount Sought for Attorneys Fees and Related Litigation Expenses Incurred Through January 11, The total amount of attorneys fees and litigation expenses sought by the Lawyers Committee in this matter for work performed, and expenses incurred, through January 11, 2018, is $90, This amount is comprised of $87,879 in attorneys fees and $2, in litigation expenses. Plaintiffs will supplement this amount to include any attorneys fees and costs incurred after January 11, Based on my experience with other litigation matters and my personal knowledge of the facts and circumstances of this litigation, the total amount requested is reasonable and appropriate under the circumstances. 40. Pursuant to 28 U.S.C. 1746, I declare under penalty of perjury on this day of January 30, 2018 that the foregoing is true and correct. FURTHER AFFIANT SAYETH NOT. /s/ Ezra D. Rosenberg Ezra D. Rosenberg, Esq. Lawyers Committee for Civil Rights Under Law Plaintiffs Counsel 19

21 Case 1:17-cv TCB Document 46-3 Filed 01/30/18 Page 21 of 44 EXHIBIT 1

22 Case 1:17-cv TCB Document 46-3 Filed 01/30/18 Page 22 of 44 LAWYERS' COMMITTEE FOR CIVIL RIGHTS UNDER LAW BILLING SUMMARY FOR GA NAACP V. GA/KEMP (Federal Runoff Election NVRA Claim) Staff Bill Date Time Rate Charge Tasks Houk, Julie 3/20/ $ Rev. John P's re legal research on Section 8 (.2) Powers, John 3/20/ $400 Researched Georgia statutory and constitutional provisions related to the voter registration deadline for federal runoff elections; conducted legal research on Section 8 of the NVRA, in particular whether OCGA conflicted with it with respect ot the voter registration deadline for runoff elections for federal office; researched precedent both under the NVRA and UOCAVA; drafted summarizing that legal research; circulated by to Julie, Ezra, and Jon (3.5) (Deduct for ) Houk, Julie 3/27/ $550 Rev. s from/to Ezra re triggering event for NVRA notice and John P's re drafting notice letter (.2)(N/C); rev. s from clients (.2); to/from client re NVRA notice letter (.4); rev. from John P. and NVRA notice letter draft (.4)(N/C); rev. and Jon's revisions to NVRA notice letter dr aft (.2)(N/C)); to/from client re continuing efforts to reg. voters in 6th 550 Congressional district (.4) Powers, John 3/27/ $400 Drafted NVRA notice letter. Had discussion with Julie regarding the investigation, outreach to local GA groups, and who should be included as signatories. Circulated draft NVRA notice letter by . Reviewed edits to NVRA notice letter from Jon G and made revisions. Circulated revised draft by with Julie Ezra and Jon (3.7)(Deduct 1/2 for internal conferences and 920 )(total Billed: Houk, Julie 3/28/ $550 s from/to Aunna re early voting in 6th Congressional District race (.2); s to/from John re registration by race in 6th Congressional district and percentage of unregistered POC in the 0 district (.2) (N/C) Powers, John 3/28/ $400 s to/from Julie re registration by race in 6th Congressional district and percentage of unregistered POC in the district; discussed drafting the complaint and the requisite components; looked for complaints in past NVRA litigation; talked with intern Nadav Karasov about the 40 investigation and sent him relevant documents (.7 N/C) Houk, Julie 3/29/ $550 Draft and forward retainer agreements to clients (1.5)(N/C); s to/from clients re NVRA notice 1650 letter (.5); work on draft of TRO/PI motion (2.5) Powers, John 3/29/ $400 Talked with Julie regarding the draft notice letter, in particular re: the proper registration deadline and ProGeorgia signing on to join the litigation. Made edits to the NVRA notice letter and 280 circulated the revised draft by . (.7) Houk, Julie 3/30/ $550 Rev. status of retainers and approval by clients re NVRA notice letter; discussion w/john P. re the same; review news reports re status of special election and possibility that there will be no 1925 runoff (.4)(N/C); continue work on TRO/PI motion and legal research re the same (3.5). Powers, John 3/30/ $400 Discussion with Julie re: status of retainers and approval by clients to move forward with the NVRA notice letter. Made final edits to the NVRA notice letter and circulated by to the internal team. After talking with Julie, sent the NVRA notice letter to Brian Kemp, Ryan Germany, Cris Correia, Russ Willard. Researched the voting age population in GA CD 6. Found data and circulated with Julie and Ezra. Continued looking for templates to use for drafting the complaint 1560 by looking at past NVRA cases and looking at complaints (4.2)(.3 N/C) from/to client re service of NVRA notice letter (.2); s from/to John re status of individual plaintiffs (.2); continue work on draft of TRO/PI motion; legal research re the same (2.5) Houk, Julie 3/31/ $ Houk, Julie 4/3/ $ Continue legal research and drafting of PI motion (1.5)

23 Case 1:17-cv TCB Document 46-3 Filed 01/30/18 Page 23 of 44 LAWYERS' COMMITTEE FOR CIVIL RIGHTS UNDER LAW BILLING SUMMARY FOR GA NAACP V. GA/KEMP (Federal Runoff Election NVRA Claim) Powers, John 4/3/ $400 Discussion w/ Julie re copying Kristen/Nikki w/ NVRA notice letter and strategy; begin putting the framework together for the complaint, building out styling of the case, identifying counsel, etc.(.5 0 N/C) Houk, Julie 4/4/ $550 s to/from clients re scheduling call re status and participate in call; rev, and download 0 retainer agreement from client (1)(N/C) Powers, John 4/4/ $ Begin drafting the complaint Rosenberg, Ezra 4/4/ $650 Attention to issues relating to possible filing of suit 325 Houk, Julie 4/6/ $550 Work on draft of PI motion, legal research on preemption issue; draft and edit section on preemption; research history of Art. 2, Sec. 2, para. 2 of GA Constitution relative to NVRA's 1375 adoption and effective date; same re GA (a) (2.5) Houk, Julie 4/7/ $550 to/from client re retainer agreement; download retainer and print for file (.2)(N/C); review 1100 absentee voter stats online (.2(N/C)); continue legal research and editing of TRO/PI motion (2) Powers, John 4/9/ $ Continued drafting the complaint Houk, Julie 4/10/ $550 s and calls to schedule conference w/clients re PI/TRO motion (.4); rev. retainer agreements received from clients and download to network (.2)(N/C); discussion re engagement 330 of local counsel and re the same (.2) Powers, John 4/10/ $400 discussion w/ Julie re engaging Bryan Sells as co-local counsel and ; continue drafting the 400 complaint (1.5)(Deduct.5 for internal discussion) Houk, Julie 4/11/ $550 Continue work on PI/TRO motion, including calls w/clients re declarations, review and edit same (2.5); revise and edit. draft of complaint to include Ezra's revisions and comments (1); rev. information from client re registration status of applicants and eligible couple unable to register 2200 (.5) Powers, John 4/11/ $400 Complete drafting the complaint; circulate a draft with Julie and Ezra by (5)(Deduct 1 for 1600 internal discussion and ) Rosenberg, Ezra 4/11/ $650 Review and revise complaint; s to and from prospective pro bono counsel; confer with J 650 Houk and J Powers re local counsel retention. Houk, Julie 4/12/ $550 Rev. from John P. and revised draft of Complaint (.3); rev. from client re voter registration efforts before/after March 20 (.2); rev. and memo from John P. re history of runoff elections in GA (.2); rev. edits to client decl. draft from John P. and revise/edit draft 110 accordingly (.2) (Deduct.7 for internal s) Powers, John 4/12/ $400 Reviewed edits by Julie and Ezra; completed revised draft of complaint and circulated via ; prepared and memo discussing the history of runoff elections in GA; reviewed Nse Decl. 600 draft, redlined some edits, and circulated via (2)(Deduct.5 for internal s) Houk, Julie 4/13/ $ Continue work on PI motion and declarations of plaintiffs in support thereon (2.5) Powers, John 4/13/ $400 0 Meet with Julie, Ezra, and Jon G re next steps (.2 N/C) Rosenberg, Ezra 4/13/ $650 Meet with J Houk and J Powers and J Greenbaum re next steps; revise approval memo; review 975 draft complaint; s to Hogan Lovells re retention Houk, Julie 4/14/ $550 Prep for and phone conference w/hogan Lovells team re complaint and PI/TRO motion status (.5)(N/C); continue work on memo of law, motion and declarations for PI/TRO motion and 825 proposed order re the same (1.5)

24 Case 1:17-cv TCB Document 46-3 Filed 01/30/18 Page 24 of 44 LAWYERS' COMMITTEE FOR CIVIL RIGHTS UNDER LAW BILLING SUMMARY FOR GA NAACP V. GA/KEMP (Federal Runoff Election NVRA Claim) Speak to Bryan Sells about the possibility of him joining the case as co-counsel; phone conference with Hogan Lovells team re: same, as well as complaint and PI/TRO motion status; assemble retainers, co-counsel agreement, and draft complaint; draft welcoming Bryan Powers, John 4/14/ $400 0 Sells to Hogan Lovells and the rest of the litigation team (2.5 N/C) Rosenberg, Ezra 4/14/ $ Review and revise complaint; multi calls and s with co-counsel; participate in call with all cocounsel Houk, Julie 4/15/ $ Continue work on PI/TRO memo of law and circulate to team for review and comments (2) Houk, Julie 4/16/ $550 Continue work on PI motion draft and declarations. including revisions suggested by co-counsel; 825 s from/to co-counsel re the same; legal research (1.5) Rosenberg, Ezra 4/16/ $650 Review draft pleadings and discuss with team 650 Houk, Julie 4/17/ $550 Continue work on PI motion and declarations (2); from/to client pre and post March 20th voter reg. efforts and TC re the same (.6); rev. file and s to/from Cris Correia re no remedial action and notice period (.2); s from/to T. Weymouth re retainer agreements and follow up re the same with clients (.4)(N/C); s from/to client. re declaration; revise and edit and 1815 circulate (.5) Rosenberg, Ezra 4/17/ $650 Continued attention to finalizing pleadings 975 Houk, Julie 4/18/ $550 Continue work on PI motion and declarations; retainer agreements, including revise documents to reflect decision to include additional plaintiff org; draft retainer agreement (1.5)(.5 N/C); follow-up 275 with clients re declarations and retainer agreement (.5) Powers, John 4/18/ $400 Confer with Ezra and Julie regarding the pleadings; edited and revised co-counsel agreement in light of feedback received from co-counsel; circulated revised co-counsel agreement with the team by ; revised the complaint based on feedback received from Bryan Sells, and 440 circulated a revised version of the complaint with co-counsel (.6 N/C) Rosenberg, Ezra 4/18/ $650 Confer with J Houk and J Powers re pleadings; multi s to and from co-counsel re thereto 1040 Houk, Julie 4/19/ $550 Continue work on complaint, motion and declarations for filing; (2.8); finalize retainer agreement re new client and discussion w/client re status (.5); finalize all documents for filing, draft summons 2090 and civil cover sheet (.5) Powers, John 4/19/ $400 Made additional revisions to the complaint based on feedback received from the Hogan Lovells team, and circulated a revised version of the complaint with co-counsel; reviewed draft TRO/PI motion, made edits to the section related ot relief, and sent the revised draft to Julie; drafted a proposed order and circulated that with co-counsel; made additional last-second changes to the 0 complaint and sent the final version to Bryan (3.5)(N/C to avoid duplication) Rosenberg, Ezra 4/19/ $650 Final review and comment on papers; multi s to and from J Houk and I Feinberg re thereto 1950 Houk, Julie 4/20/ $550 0 Rev. local rules re PHV, draft phv apps for myself and Ezra (1.6)(N/C.8); finalize all documents and transmit to Bryan Sells for filing (.2)(N/C); review ecf notifications re filing and assignment (.2) (N/C)

25 Case 1:17-cv TCB Document 46-3 Filed 01/30/18 Page 25 of 44 LAWYERS' COMMITTEE FOR CIVIL RIGHTS UNDER LAW BILLING SUMMARY FOR GA NAACP V. GA/KEMP (Federal Runoff Election NVRA Claim) Powers, John 4/20/ $400 Reviewed latest draft of the TRO/PI motion memorandum of law, made several changes, including to citations and the table of authorities, and circulated a revised draft with Julie and Ezra; assisted with finalizing documents; reviewed and exchanged numerous s with cocounsel; prepared pro hac vice application for myself and Ezra and sent to Bryan Sells (3.7) ( N/C) Rosenberg, Ezra 4/20/ $650 s to and from team re filing of papers and last changes; confer with I Feinberg re next steps; hold press conference and prepare for press conference in preparation for filing; further 650 discussions with J Houk re next steps (3.0 N/C) Houk, Julie 4/21/ $550 Rev. from potential new client; confer with team re the same and TC w/potential client (.5(N/C)); research futility issue re NVRA notice for new clients (1.8); TC w/potential new client (.8); rev. from Bryan Sells re Judge Batten's instructions to counsel and rev. instructions (.3)(N/C); from/to Ezra re request by coalition members (.2)(N/C); rev. notices of appearance filed by Cris Correia and Josiah Heidt (.2); from/to Paul Wiley re potential new client's standing (.2)(N/C); provide info. to Hogan team re potential new client for conflicts ck 1540 (.2)(N/C) Powers, John 4/21/ $400 Reviewed Judge Batten's standing order; reviewed media coverage of the case; reviewed and 0 exchanged s with co-counsel (1.0 N/C) Rosenberg, Ezra 4/21/ $650 Discuss next steps with J Houk; deal with press calls re new case (2.0 N/C) 0 Houk, Julie 4/22/ $550 s and discussions w/potential new client and draft retainer agreement re the same (1.2)(N/C 385 for.5) Houk, Julie 4/23/ $550 from/to Ira re presentation of testimony at hearing on PI motion (.2); TC and s w/new client (.2); from/to Bryan Sells re certificate of interested parties; revise and edit certificate re the same (.2); draft declaration of client and circulate it to team; rev. from Bryan Sells re the same (1); rev. from Jonathan Abram re the same (.1)(N/C); rev. from Bryan Sells re constitutional claim; legal research re durational residency cases and respond re the same (1.5); rev. Ira's w/additional revisions to client declaration (.2)(N/C); send draft of declaration to client for review; rev. in response (.2); rev. from potential clients who 2035 recently purchased a home in Tucker, GA; TC to potential clients (.4) Powers, John 4/23/ $400 Reviewed s between co-counsel regarding the possibility of adding other claims; drafted lengthy recommending that we not add more claims, identifying legal and strategic bases, 0 etc. (.5 N/C) Houk, Julie 4/24/ $550 Discussion re timing of amending complaint to add new client; review Judge Batten's order re the briefing schedule (.2)(N/C); rev. from Bryan Sells re defendants' arguments re PI motion and review information from reporter re defendants' likely position (.2);(N/C) discussion w/client re potential additional individual plaintiffs and discussion w/ potential plaintiffs re the same for conflicts (.5) ;interview another potential new plaintiff and circulate notes of interview to team; 935 to potential additional client re the same (1.2)

26 Case 1:17-cv TCB Document 46-3 Filed 01/30/18 Page 26 of 44 LAWYERS' COMMITTEE FOR CIVIL RIGHTS UNDER LAW BILLING SUMMARY FOR GA NAACP V. GA/KEMP (Federal Runoff Election NVRA Claim) Houk, Julie 4/24/ $550 Additional legal research re futility issue re NVRA notice for new potential plaintiffs and potential, additional constitutional claims (1.5); rev. s from/to Bryan and Ira re constitutional claims and state office closures (.3)(N/C); s from/to new client re declaration and related issues (.2); rev. from new client w/signed retainer agreement and download to file (.2)(N/C); rev. ECF notice re filing of certificate of interested parties (.2(N/C)); work on first amended complaint and amended certificate of interested parties (2.5); rev. from Ira F. re new client's declaration, revise declaration and confer with client for her approval (.5); TC w/potential new clients and circulate re the same (.5); to/from new client re status update (.4); revise 3300 complaint per Ira's (.4); Powers, John 4/24/ $400 0 Conducted research of Judge Batten's opinions in other voting cases (.5 N/C) Rosenberg, Ezra 4/24/ $650 Attend to issues relating to press re new case (.5 NC); review schedule for hearing; multi s 325 to and from team re amendment of complaint issues (.5) Powers, John 4/25/ $400 Conducted legal research into whether the NVRA can preempt state-imposed qualifications on voter eligibility; drafted memo citing case law supporting preemption, which I circulated with cocounsel by (3.5) 1400 Rosenberg, Ezra 4/25/ $650 Confer with I Feinberg re next steps; confer at length with J Houk re thereto; multi s to and 910 from team re amendment of complaint and supplementation of motion Houk, Julie 4/26/ $550 Update org, client's counsel re status of case (.2); rev. from Ezra re inquiry from voting org 110 re case and respond (.5)(N/C) Powers, John 4/26/ $400 0 Discussion with Javeria Jamil of AAAJ-Atlanta regarding the status of the case (N/C) Houk, Julie 4/27/ $550 Rev. ecf notice re granting of consent motion re client's declaration and discussion w/team re the same (.5)(N/C); to client re status of briefing schedule and hearing (.2); from/to voting org re query about CD 6 voter reg (.2)(N/C); from/to client re status of updated registration 220 address (.2) Houk, Julie 4/28/ $550 Prep. and attend phone conf. re status and planning for argument (.8); legal research re whether states other than GA have similar scheme (1); make travel arrangements (.5)(N/C); contact 1265 clients to coordinate attendance at the hearing (.5) Powers, John 4/28/ $400 Reviewed defendants' response to TRO/PI motion; prepared for and participated in conference 480 call with co-counsel discussing their response and strategizing re: next steps (1.2) Rosenberg, Ezra 4/28/ $650 Conference call with co-counsel re briefing issues; review brief submitted by State; call with Ira 1625 Feinberg re oral argument. Houk, Julie 4/30/ $550 s from/to Bryan Sells re logistics for hearing (.2)(N/C); from/to Ira F. re client's reply 330 declaration and revise and edit declaration (.6) Rosenberg, Ezra 4/30/ $650 Review and edit draft reply brief; multi- s to and from plaintiff counsel team re thereto 650 Houk, Julie 5/1/ $ from Ezra re client's reply declaration (.2)(N/C); from/to Bryan Sells re order to bring laptops and phones into courtroom and review draft order re the same (.36(N/C)); from/to client re status of registration (.4); to/from client re revised declaration and defendants' response/declarations (.5); s from/to Ira re plaintiffs' reply brief and review reply brief; rev. edits to reply brief from John P. (.5); from/to Ezra re report's interest in interviewing clients; TC w /client re the same (.4)(N/C); rev. from Ira w/additional revisions to client reply declaration; rev. revisions w/client. and finalize declaration (.8); rev. additional edits to reply brief from Jonathan A and Emily G (.4)(N/C); rev. Ezra's edits (.3)

27 Case 1:17-cv TCB Document 46-3 Filed 01/30/18 Page 27 of 44 LAWYERS' COMMITTEE FOR CIVIL RIGHTS UNDER LAW BILLING SUMMARY FOR GA NAACP V. GA/KEMP (Federal Runoff Election NVRA Claim) Powers, John 5/1/ $400 Read the draft reply brief. Put together redline revisions to this section of the brief. Circulate the 1200 redline draft. (6)(N/C for 1/2)(billed 3) Rosenberg, Ezra 5/1/ $650 further review and edit of draft reply; s to and from co-counsel re thereto and in preparation 845 for argument Houk, Julie 5/2/ $550 Finalize reply declaration, review voter list training and include link to supplemental voter list training (.6); review additional edits to the reply brief from Jonathan A (.2)(N/C); rev. from client re info she received about 2006 voter ID case and TC w/client re the same (.6)(N/C); s from/to Bryan S. re logistics for efiling brief and declaration/exhibits; finalize declaration and exhibits for filing (.2)(N/C); research and finalize travel plans for trip to/from Atl for argument (.4)(N/C); rev. additional drafts of the reply brief with edits by John, Ezra and Ira (.5); rev. ecf 880 notices re filing of reply and reply declaration (.2)(N/C); final review of reply brief for filing (.5) Powers, John 5/2/ $400 Reviewed burden section of the draft reply brief. Put together redline revisions to the burden section of the brief. Circulate the redline draft. Review subsequent drafts circulated by cocounsel. Confer with Ezra nd Julie about the draft. (2.7)(N/C for 1.2)(Billed 1.5) 600 Rosenberg, Ezra 5/2/ $650 final review and editing of reply brief; multi- s to and from co-counsel team re thereto; confer 1300 at length with team in preparation for argument Houk, Julie 5/3/ $550 Prep. for oral argument, rev. motion papers and response; outline burden argument (2.5); TC's and s w/clients re hearing and meeting locations (.5); travel to Atlanta and hotel from DC (4.8)(Travel billed at 1/2 (2.4 billed); review defendants' sur-reply and meeting with co-counsel re the same (1.5)(N/C for 1/2 - billed,75); TC w/client re sur-reply and Harvey II declaration (1); research re supplemental list and process for voters who register and are not on express polls (.5); Powers, John 5/3/ $400 Draft a press release in anticipation of the plaintiffs winning at the hearing. Draft quotes for cocounsel and send s back and forth with them. Edit draft press release based on feedback. 0 (2.0 N/C) Rosenberg, Ezra 5/3/ $650 review defendants' surreply; s to J Houk re thereto 650 Houk, Julie 5/4/ $550 Prepare for oral argument of motion for PI (2)(NC for 1/2)(billed 1); prep clients for potential testimony and travel to court (1.2)(N/C for 1/2 -billed.6); appear for argument (.8); rev. order post argument and discuss w/co-counsel and clients (.4); travel to airport and to DC (4.5)(travel billed at 1/2 - billed 2.13) Powers, John 5/4/ $400 Review Judge Batten's ruling. Discuss it with co-counsel. Circulate s with co-counsel and plaintiffs. Talk with Julie about the hearing and strategize regarding next steps. Phone call with voting rights litigators discussing Judge Batten's ruling g in the Georgia runoff registration cutoff 0 case. (2.0 N/C) Rosenberg, Ezra 5/4/ $650 Review court's opinion; confer at length with J Houk re hearing; s to and from I Feinberg re 325 thereto; (multi s and calls re press releases for hearing and other media contacts (1.5 N/C) Houk, Julie 5/5/ $550 s from/to Hogan Lovells and co-counsel re monitoring and verification of registrations post March 20 (.4); from/to Cris Correia re request for extension to answer and internal 330 discussion re same(.2) Rosenberg, Ezra 5/5/ $ s to and from co-counsel re next steps; analyze issues relating to follow-up; attention to media requests(.5 N/C)

28 Case 1:17-cv TCB Document 46-3 Filed 01/30/18 Page 28 of 44 LAWYERS' COMMITTEE FOR CIVIL RIGHTS UNDER LAW BILLING SUMMARY FOR GA NAACP V. GA/KEMP (Federal Runoff Election NVRA Claim) Houk, Julie 5/7/ $550 to clients and team re scheduling discussion re verifying applicants are being processed 275 onto voter rolls (.3);rev. s from clients in response (.2); Houk, Julie 5/8/ $550 TC w/reporter re counties giving wrong info re voter registration; follow up with clients and counties; TC w/reporter re the same (.2)(N/C); to Maxine Daniels and DeKalb county 275 counsel re erroneous information on DeKalb website and s in response (.5) Powers, John 5/8/ $400 Prepared for and participated in phone conference with co-counsel regarding verification/monitoring of processing of voter registrations by Fulton Cobb and DeKalb Counties 200 (.5) Rosenberg, Participate in call with co-counsel re monitoring issues (.5) Ezra 5/8/ $ Houk, Julie 5/9/ $ s and reviews of information re registration data and updates from clients re progress (.5) Rosenberg, Attention to various media issues (1.0 N/C) Ezra 5/9/ $650 0 Houk, Julie 5/11/ $550 Organize and host discussion re status of registration and issues pertinent to case w/clients and 825 litigation team (1.5) Powers, John 5/11/ $400 0 Participate in call re monitoring; followup discussions with Julie and Ezra (.5)(N/C) Rosenberg, Participate in call re monitoring; followup discussions with J Houk and J Powers Ezra 5/11/ $ Houk, Julie 5/12/ $ Rev. status of registering new voters; TC w/client re the same (.5) Houk, Julie 5/14/ $550 Review article re registration post court order and circulate to co-counsel; rev. responses re the 275 same (.4)(N/C); discussion/ s re permanent relief (.5) Houk, Julie 5/17/ $550 Rev from Cris Correia w/ alpha voter file; share with clients; call clients re the same; 550 planning and strategy re the same (1) Houk, Julie 5/23/ $550 Rev. new alpha voter files from Cris Correia and discussions re the same (.6); review from client re new registrants against (.4); TC w/client re applicants not on active list (.4); rev from Bryan Sells re alpha voter files from Cris Correia (.2)(N/C) Houk, Julie 6/2/ $ Update org. client counsel re status (.3) Participate in call with Phi Nguyen of AAAJ-Atlanta updating her on the status of the case; review Powers, John 6/2/ $ data re: registration in CD 6 (.7) Houk, Julie 6/5/ $ from/to Cris Correia re updated registration stats for GA 6th Congressional District (.2) Houk, Julie 6/6/ $ Discussion and s from/to Cris Correia re updated registration reports (.2) Houk, Julie 6/8/ $ Rev. new alpha voter file from AG and circulate to clients and team (.4) Houk, Julie 6/14/ $550 Rev. McDonald's early vote analysis for 6th Cong. district and forward to team and client 0 (.4)(N/C) Houk, Julie 6/19/ $550 Rev. GA SC decision on sovereign immunity under GA law (.3); rev. ecf notice re Cris C leave of absence (.2); from/to Ira F. re next steps re litigation, Rule 26(f) conf., prelimin. report and 495 initial disclosures (.4) Houk, Julie 6/21/ $550 Rev. from Cris Correia re scheduling call and confer with co-counsel re scheduling and 110 rev. from Cris Correia re waiving Bryan's personal appearance (.2)

29 Case 1:17-cv TCB Document 46-3 Filed 01/30/18 Page 29 of 44 LAWYERS' COMMITTEE FOR CIVIL RIGHTS UNDER LAW BILLING SUMMARY FOR GA NAACP V. GA/KEMP (Federal Runoff Election NVRA Claim) Houk, Julie 6/28/ $550 Prep. draft of jt. preliminary statement and attend phone conf. re jt. preliminary statement and settlement discussions (1.8); from Bryan S re revisions to jt. preliminary statement (.2)(N/C); additional edits to jt. preliminary statement (.4); additional s re jt. preliminary statement draft (.2)(N/C); rev. from Ira Feinberg re jt. prel. stmt (.1)(N/C); from Ira re 1320 prepping memo re call with Cris C and draft memo re the same and circulate (.2) Powers, John 6/28/ $ Prepared for and participated in the Rule 26(f) conference Houk, Julie 6/29/ $550 0 Rev. ecf notice re joint motion for extension on Runoff registration case (.2)(N/C) Houk, Julie 8/6/ $550 to/from Ira re attorneys' fee and cost demand (.2); coordinate call regarding attorneys' fee 110 and cost demand (.2)(N/C) Houk, Julie 8/7/ $550 Rev. s re coordinating call with AG re fee/cost demand and call w/cris Correia re the same (.5); to accounting re need for hours and costs for settlement demand (.1)(N/C); review and 275 circulate draft of consent order internally for review (.2)(N/C) Powers, John 8/7/ $400 Review draft consent decree proposed by opposing counsel; take notes on the draft and potential 280 proposed changes, list of questions (.7) Houk, Julie 8/8/ $550 Rev. and information from Bryan S. re Atlanta hourly rates and additional info for attorneys' fee and cost demand (.5)(N/C); rev. itemization of attorneys' hours and costs for fee and cost 385 demand (.7) Houk, Julie 8/9/ $ from/to Lula re fee summary and costs for demand (.2)(N/C) Houk, Julie 8/10/ $550 Internal discussion re status (.5)(N/C); phone conf. w/defendants' counsel and prep. for same re settlement (.7); rev. from P. Wiley re Az. case on the issue of the 30 days or lesser period provided by state law issue (.5); discussion w/co-counsel re merits settlement discussion and the timing issue when deadline on a weekend (.4); rev. revisions by co-counsel to consent order and s re the same (.4)(N/C); revise and edit draft and circulate to team (.5); rev. from Ira re research on the issue regarding the timing of the close of registration when last day falls on a weekend (.4); rev. John P's times sheet for settlement demand and add to excel sheet (.4)(N/C); 1375 rev. additional s re issues relating to draft consent order (.2(N/C)) Powers, John 8/10/ $400 Discuss draft consent decree with co-counsel; review edits suggested by co-counsel; make my own edits to draft consent decree; consolidate and send our side's proposed edits to consent 600 decree to opposing counsel; participate in phone call concerning the consent decree (1.5) Houk, Julie 8/13/ $ from Ira F. re settlement agreement language and state's position (.2) Houk, Julie 8/14/ $550 0 rev. s re the status of the settlement discussions (.4)(N/C) Houk, Julie 8/15/ $550 Approve draft consent motion re extension on initial disclosures and joint prelimn. statement and 165 review ECF confirmation of filing re the same (.3) Powers, John 9/8/ $400 Participated in a portion of the call with co-counsel discussing attorneys' fees and costs demand 200 (1)(.5 N/C) Houk, Julie 9/11/ $550 Rev. billing summaries and draft letter to AG's office with settlement demand (.5); s to/from 275 team re the same (.3)(N/C) Powers, John 9/14/ $400 Prepared for and participated in conference call with co-counsel to discuss strategy going forward 240 with respect to attorney's fees - e.g., reviewed our offer to the other side Houk, Julie 9/15/ $550 Discussion re attorneys' fees and obtaining further extension on filing of jt. statement and initial 165 disclosures(.6) (.3(N/C) Powers, John 9/15/ $400 Prepared for and participated in a phone conference with Cris Correia, Julie Houk, and cocounsel regarding attorney's fees and settlement (.6)( N/C)

30 Case 1:17-cv TCB Document 46-3 Filed 01/30/18 Page 30 of 44 LAWYERS' COMMITTEE FOR CIVIL RIGHTS UNDER LAW BILLING SUMMARY FOR GA NAACP V. GA/KEMP (Federal Runoff Election NVRA Claim) Houk, Julie 9/18/ $ Rev. and download court order re extension (.2) Houk, Julie 9/26/ $550 0 Rev. from Ira re status and deadline (.1)(N/C) Houk, Julie 9/27/ $550 Rev. L.R. 54.2, edit proposed Consent Decree draft on issue of attorneys' fee and cost claim; circulate internally for approval and to defendants/ counsel (.5); rev. proposed reductions to billing summaries and update excel sheet to include more recent billing for purposes of the fee 440 motion (.3) Houk, Julie 9/28/ $550 Prep. For an attend phone conf. re Consent Order issues re recovery of fees and planning re fee application and Text related issues; to Cris Correia w/revised draft (.3); rev. and edit chart re 605 recoverable fees for motion (.8) Houk, Julie 10/9/ $ Revise and edit Consent Order and same to Cris Correia Houk, Julie 10/13/ $550 Rev. Rule 68 offer from def. initial legal research re the same; rev. current demand and 275 team re the same Houk, Julie 10/22/ $550 Discussion w/team re whether to accept Rule 68 offer and results of research re whether it is 330 valid on an NVRA fee claim Houk, Julie 11/11/ $ Rev. and edit chart for lodestar claim re motion for fees and expenses Houk, Julie 11/12/ $ Legal research and work on draft of phase one motion for fees and expenses Houk, Julie 11/13/ $ Finalize draft of phase one fee motion and declaration; same to team Houk, Julie 12/6/ $ Rev. updated Rule 68 offer from defendants, and discuss same w/team Houk, Julie 12/11/ $ and discussion w/cris Correia re updated Rule 68 and counter-offer Discussion and re Bill Custer will agree to review rates and time for possible decl. in Houk, Julie 12/27/ $ support of fee motion Houk, Julie 1/3/ $ Rev. draft of Bryan S.' fee decl. and billing summary Houk, Julie 1/8/ $ Work on phase 2 of fee motion, including updated billing summary and declarations Houk, Julie 1/9/ $550 Cont. work on fee motion phase 2; rev. report by law fellow re updated rev. of ND of GA fee 660 awards Houk, Julie 1/10/ $550 TC w/bill Custer re fee motion and information re rates in N.D. GA (.2); rev. draft of Ira's fee 275 declaration and updated billing summary for Hogan Lovells (.3) Houk, Julie 1/11/ $ Cont. work on phase 2 of fee motion and drafts of declaration for LCCRUL and Bill Custer Total Hours/Lodestar EXHIBIT 1

31 Case 1:17-cv TCB Document 46-3 Filed 01/30/18 Page 31 of 44 EXHIBIT 2

32 Case 1:17-cv TCB Document 46-3 Filed 01/30/18 Page 32 of 44 Lawyers' Committee Under Law Liigation Expenses GA NAACP v. GA/Kemp (Runoff Voter Registration NVRA Matter) Airfare Lodging Rental Car Parking 6.00 Parking Pro Hac Ck to Bryan S Westlaw Westlaw Westlaw 1, Total Costs 2, EXHIBIT 2

33 Case 1:17-cv TCB Document 46-3 Filed 01/30/18 Page 33 of 44 5/2/2017 The Law Office of Bryan L. Sells, LLC Mail - Pay.gov Payment Confirmation: GAND CM ECF Bryan Sells <bryan@bryansellslaw.com> Pay.gov Payment Confirmation: GAND CM ECF 7 messages paygovadmin@mail.doc.twai.gov <paygovadmin@mail.doc.twai.gov> To: "bryan@bryansellslaw.com" <bryan@bryansellslaw.com> Thu, Apr 20, 2017 at 5:31 PM Your payment has been submitted to Pay.gov and the details are below. If you have any questions or you wish to cancel this payment, please contact Kathy Sewell at (404) Application Name: GAND CM ECF Pay.gov Tracking ID: 26203BGA Agency Tracking ID: 113E Transaction Type: Sale Transaction Date: Apr 20, :31:48 PM Account Holder Name: Bryan L Sells Transaction Amount: $ Card Type: A 1/3

34 5/2/2017 The Law Office of Bryan L. Sells, LLC Mail - Pay.gov Payment Confirmation: GAND CM ECF Card Number: * Case 1:17-cv TCB Document 46-3 Filed 01/30/18 Page 34 of 44 THIS IS AN AUTOMATED MESSAGE. PLEASE DO NOT REPLY. paygovadmin@mail.doc.twai.gov <paygovadmin@mail.doc.twai.gov> To: "bryan@bryansellslaw.com" <bryan@bryansellslaw.com> Thu, Apr 20, 2017 at 5:40 PM Your payment has been submitted to Pay.gov and the details are below. If you have any questions or you wish to cancel this payment, please contact Kathy Sewell at (404) Application Name: GAND CM ECF Pay.gov Tracking ID: 26203E5N Agency Tracking ID: 113E Transaction Type: Sale Transaction Date: Apr 20, :40:42 PM Account Holder Name: Bryan L Sells Transaction Amount: $ Card Type: Card Number: * THIS IS AN AUTOMATED MESSAGE. PLEASE DO NOT REPLY. paygovadmin@mail.doc.twai.gov <paygovadmin@mail.doc.twai.gov> To: "bryan@bryansellslaw.com" <bryan@bryansellslaw.com> Thu, Apr 20, 2017 at 5:50 PM Your payment has been submitted to Pay.gov and the details are below. If you have any questions or you wish to cancel this payment, please contact Kathy Sewell at (404) Application Name: GAND CM ECF Pay.gov Tracking ID: 26203EOH Agency Tracking ID: 113E Transaction Type: Sale Transaction Date: Apr 20, :50:43 PM Account Holder Name: Bryan L Sells Transaction Amount: $ Card Type: Card Number: THIS IS AN AUTOMATED MESSAGE. PLEASE DO NOT REPLY. PM 2/3

35 Case 1:17-cv TCB Document 46-3 Filed 01/30/18 Page 35 of 44 THIS IS AN AUTOMATED MESSAGE. PLEASE DO NOT REPLY. Thu, Apr 20, 2017 at 6:26 PM /mail.google.com/mail/u/2/?ui=2&ik=d05cf0ed21&view=pt&q=after%3a2017%2f4%2f19%20before%3a2017%2f4%2f22%20payment&qs=true&search=q 3/3

36 1 of 1 6/2/17, 1:24 PM Case 1:17-cv TCB Document 46-3 Filed 01/30/18 Page 36 of 44 Transaction Details Prepared for Julie M Houk Account Number DATE DESCRIPTION CARD MEMBER AMOUNT MAY LANIER PARKING - ATLANTA, GA JULIE M HOUK $10.00 Doing business as: LANIER PARKING 140 MARITTTA STREET ATLANTA GA UNITED STATES OF AMERICA (THE) Transaction Details Description LANIER GA STA Additional Information: Reference: Category: Transportation - Parking Charges

37 1 of 1 6/2/17, 1:26 PM Case 1:17-cv TCB Document 46-3 Filed 01/30/18 Page 37 of 44 Transaction Details Prepared for Julie M Houk Account Number DATE DESCRIPTION CARD MEMBER AMOUNT MAY LAZ PARKING ATLANTA, GA JULIE M HOUK $6.00 Doing business as: LAZ PARKING 675 PONCE DE LEON AVE NE ATLANTA GA UNITED STATES OF AMERICA (THE) Transaction Details Description PARKING FEES Additional Information: Reference: Category: Transportation - Parking Charges

38 Case 1:17-cv TCB Document 46-3 Filed 01/30/18 Page 38 of 44

39 of 5 6/2/17, 1:34 PM Congrats On Your SkyMiles Award Trip Case 1:17-cv TCB Document 46-3 Filed 01/30/18 Page 39 of 44 any lithium battery powered self-balancing personal transportation devices on board its aircraft. These items are prohibited as both carry-on and checked baggage. Spare batteries for other devices, fuel cells, and e-cigarettes are permitted in carry-on baggage only. If your carry-on bag contains these items and is gate checked, they must be removed and carried in the cabin. Further information and specific guidelines regarding restricted items can be found here. Passenger Info NAME JULIE HOUK SkyMiles # Silver FLIGHT DELTA AIR LINES INC 2503 DELTA AIR LINES INC 2909 SEAT 05C 05A If you purchased a Trip Extra, please visit My Trips to access a receipt of your purchase. Miles + Cash Flight Receipt Ticket #: Place of Issue: Delta.com Ticket Issue Date: 28APR17 Ticket Expiration Date: 28APR18 METHOD OF PAYMENT AX* $ USD MILES SkyMiles # Miles Redeemed 97,500 Miles CHARGES Cash Portion $ USD (17,500 Miles) Air Transportation Charges Base Fare $0.00 USD Taxes, Fees and Charges United States - September 11th Security Fee(Passenger Civil Aviation Security Service Fee) (AY) Total Charges TOTAL TICKET VALUE $11.20 USD $ USD 115,000 Miles and $11.20 USD VALID ON DL/SM OAL/PNLTY FOR CHGS Changes to outbound Award Travel must be made 72 hours prior to the departure time of the currently-ticketed outbound flight. Changes to return Award Travel must be made at least 72 hours prior to the departure time of the

40 Case 1:17-cv TCB Document 46-3 Filed 01/30/18 Page 40 of 44

41 Case 1:17-cv TCB Document 46-3 Filed 01/30/18 Page 41 of 44

42 Case 1:17-cv TCB Document 46-3 Filed 01/30/18 Page 42 of 44

43 Case 1:17-cv TCB Document 46-3 Filed 01/30/18 Page 43 of 44

44 Case 1:17-cv TCB Document 46-3 Filed 01/30/18 Page 44 of 44