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Case 5:11-cv-00360-OLG-JES-XR Document 873-2 Filed 08/23/13 Page 1 of 17 IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS SAN ANTONIO DIVISION SHANNON PEREZ, et al., Plaintiffs, v. CIVIL ACTION NO. 11-CA-360-OLG-JES-XR STATE OF TEXAS, et al., [Lead Case] Defendants. MEXICAN AMERICAN LEGISLATIVE CAUCUS, TEXAS HOUSE OF REPRESENTATIVES, Plaintiffs, CIVIL ACTION NO. v. SA-11-CA-361-OLG-JES-XR [Consolidated Case] STATE OF TEXAS, et al., Defendants. TEXAS LATINO REDISTRICTING TASK FORCE, et al., Plaintiffs, CIVIL ACTION NO. v. SA-11-CA-490-OLG-JES-XR [Consolidated Case] RICK PERRY, Defendant. MARGARITA V. QUESADA, et al., Plaintiffs, v. CIVIL ACTION NO. SA-11-CA-592-OLG-JES-XR RICK PERRY, et al., [Consolidated Case] Defendants. EDDIE RODRIGUEZ, et al., Plaintiffs, v. CIVIL ACTION NO. SA-11-CA-635-OLG-JES-XR RICK PERRY, et al., [Consolidated Case] Defendants. 1

Case 5:11-cv-00360-OLG-JES-XR Document 873-2 Filed 08/23/13 Page 2 of 17 DECLARATION OF MANUEL G. ESCOBAR, JR. Pursuant to 28 U.S.C. 1746, I, Luis Roberto Vera, Jr., declare that: 1. I am one of the attorneys who appear on the pleadings and assisted Mr. Vera in representing Plaintiffs League of United Latin American Citizens (LULAC) et al, (hereafter Plaintiffs ) in the above-captioned case. I make this Declaration in support of the Plaintiffs motion for an award of attorneys fees and expenses. 2. I received a degree from the University of California Berkley School of Law in 1981 and graduated from Yale University in 1976. I am a member of the State Bar of Texas. I am also a member of the bar of the United States Courts of Appeals for the Fifth Circuit and the United States District Court for the Southern District of Texas and the United States District Court for the Western District of Texas. 3. Following my graduation from law school, from 1981 until the present I have served as a trial attorney in both state and federal court and in 2010 I was appointed as the National Legal Advisor to the League of United Latin American Citizens (hereinafter LULAC). LULAC is the largest and oldest Latino advocacy and civil rights organization in the United States and the commonwealth of Puerto Rico. For the entire length of this litigation and during my service at LULAC I assisted Mr. Vera with research, writing of memorandum, edits of legal documents, and participated in the trial before the three judge court in San Antonio in this case. I also participated with Mr. Vera in negotiations, meetings and briefings with the Voting rights Section of the Department of Justice Civil Rights Division in Washington DC exclusively on this case 4. My private practice is both as a trial attorney and appeals in both state and federal court. My hourly rate on this case for assisting Mr. Vera is $175.00 per hour, which is belw my hourly rate when I am the lead attorney in a case. Given the complexity and novelty of the 2

Case 5:11-cv-00360-OLG-JES-XR Document 873-2 Filed 08/23/13 Page 3 of 17 issues, and the high visibility and importance of the case and my thirty two years experience as a trial attorney, that rate is very reasonable. 6. I have reviewed the summary of hours that Mr. Vera expended in this case that was attached to his Declaration and that summary is true and accurate. However I have chosen to limit my reikmbursement to only 40 hours despite the fact thjat I contributed well beyond 100 hours over the past three years in this case. I limit it to that time period wherein the triakl consumed most of my time together with Mr. Vera. This time breaks down as follows; 9-6-2011 Trial preparation. Trial. 10 9-7-2011 Trial preparation. Trial. Work on offer of proof declaration. 10 9-8-2011 Trial preparation. Trial. 10 9-9-2011 Trial preparation. Trial. 10 9-10-2011 Trial. Trial preparation. Plaintiffs counsel on division of labor. 10 9-12-2011 Trial preparation. Trial. Review exhibits and witness outlines. 9 9-13-2011 Trial preparation. Trial. 10 9-14-2011 Trial preparation. Trial. 8 9-15-2011 Trial preparation. Trial. 8 9-16-2011 Trial preparation. Trial. Post trial meeting, debrief and make 6 Assign task for joint post trial brief 7. These activities in the case are maintained as business records in my law office. The hours expended were necessary in rendering legal services to the LULAC Plaintiffs in this case. I also have reviewed the listing of expenses included within Mr. Vera s Declaration and time sheets. Those expenses were out of pocket expenses necessarily incurred by LULAC to conduct the litigation in this case, and are of the type normally billed by me (and other law firms) to feepaying clients. 3

Case 5:11-cv-00360-OLG-JES-XR Document 873-2 Filed 08/23/13 Page 4 of 17 8. Counsel for the LULAC Plaintiffs has exercised reasonable billing judgment in this case. For example, I have excluded over 100 hours for which I could be compensated. Moreover, although at least one other attorneys worked on this case to assis LULAC, there are no excessive, redundant, or unnecessary hours included in the time detailed in this request for an award of attorneys fees, in fact only a modest billing of 40 hours are assessed for me, Manuel Escobar and Mr. Vera has elected not to bill for the services of attorney Justin Fisher. Total Due Manuel Escobar = $175.00 @ 40 hours = $7,000.00 9. I declare under penalty of perjury that the foregoing is true and correct. Dated: August 23, 2013 /s/ kkmauiel G. Escobar, Jr Manuel G. Escobar, jr. CEERTIFICATE OF SERVICE This certifies that a true and correct copy of the foregoing is being sent to all parties in this case by facsimile transmission amnd each party will also receive a copy through the electronic filing system utilized by the federal courts. August 23, 2013 /s/ Manuel G. Escobar Jr. 4

Case 5:11-cv-00360-OLG-JES-XR Document 873-2 Filed 08/23/13 Page 5 of 17 EXHIBIT A 010-2013 Redistricting League of United Latin American Citizens, (LULAC) U.S. Congress and TX House of Representatives TIME RECORS FOR Luis Roberto Vera, Jr. DATE ACTIVITY TIME 1-25-2010 initial meetings with LULAC leadership and LULAC Texas Board of Directors regarding strategy for legislative redistricting. (NC) 1-30-2010 Confer with George Korbel regarding availability as (NC) expert for LULAC and for preparation of Gingles maps for legislatures consideration. 2-1-2010 Continuous meetings with legislature representatives, LULAC 60 (NC) Leadership and LULAC members advocating for fair redistricting. to Advocacy. Meetings. with State House members and State Senate members regarding population growth, areas for new congressional districts and house districts realignment. Conferences with George Korbel regarding meeting with legislature member and testimony before the State house and State senate 8-30-2010 redistricting committees. 9-09-2010 Phone conference with DOJ, Voting Rights Section regarding (NC) Texas plans. Review population analysis done by Korbel, begin review of legislative council web cite. 9-10-2010 Weekly meetings with George Korbel. Go over status 45 (NC) to of preparations. Prepare LULAC members and leadership 6-1-2011 for redistricting facts and talking points. Begin formulating Complaint. 6-15-2011 Weekly meetings with George Korbel regarding Gingles plans, 90 to Exhibit and request from other Plaintiffs for assistance in drawing 2-15-2012 Gingles plans. Review and confer with George Korbel as each plan is drawn for exhibit at trial and for Interim plans hearing and to make sure other Plaintiffs plans do not conflict with L(ULAC. See, Korbel declaration and time log. 5-16-2011 Confer with George Korbel, Begin outline of possible 4 expert tasks during trial. 5-25-2011 Review of historical redistricting efforts, potential issues 7 for this case litigation. Meeting with possible community supporters on redistricting, Judge David Saucedo, Cong. Ciro Rodriguez, 5

Case 5:11-cv-00360-OLG-JES-XR Document 873-2 Filed 08/23/13 Page 6 of 17 former Dallas City Councilman and State Rep. Domingo Garcia. Meet with Bexar County elections administrator Jackie Callanen regarding redistricting litigation and 2012 elections and possible testimony at trial. 6-1-2011 Review complaints filed by Perez, MALC and begin 4.9 writing LULAC Complaint. Confer with George Korbel regarding meeting in DC with DOJ. 6-6-2011 Confer with George Korbel to finalize LULAC Complaint. 2 6-8-2011 Original Complaint finalized sent to George Korbel, Manuel Escobar and Justin Fisher for review and editing. 4 6-10-2011 Finalize edits and corrections to complaint and file as Plaintiff-Intevener to MALC Complaint. 6 Notify LULAC leadership and prepare for meeting with LULAC board for briefing on Complaint and goals. Confer with and meet with LULAC representatives. 6-13-2011 Review analysis of population distribution, growth in Texas. 3 Compare to current districts and project possible gains. 6-15-2011 Review committee plans, review impact on minority voters. 4 Review reports, election analysis. Confer with George korbel Develop comparison charts. 6-16-2011 Continue review of plans, compare minority districts in current 6 plan and plans offered by other Plaintiffs. 6-16-2011 Review Larios, review data on different scales for measuring 5 use of population for partisan and racial advantage. 6-22-2011 Prepare for hearing. Review pleadings, cases, outline arguments. 4 6-27-2011 Work on report to the court. Research legal issues, review Del 7 Rio, Mayfield, 1404a, draft report, confer with other with other Plaintiffs counsel and Korbel. 6-28-2011 Work on report to court for hearing, research and draft report 12 Continue to work and confer with other Plaintiff counsel for presentation to court and prepare for trial. Review emails. 6-29-2011 Finalize report to court. Develop evidence presentation 9 Confer with other plaintiff counsel and begin review of expert reports 6

Case 5:11-cv-00360-OLG-JES-XR Document 873-2 Filed 08/23/13 Page 7 of 17 6-30-2011 Work on joint response to motion to dismiss. 6 7-1-2011 Prepare for hearing. Confer with Korbel and other Plaintiffs 8 Counsel and participate in hearing. Meet with client and discuss status and hearing results. Work with staff on trial preparation, review list of potential exhibits, review redistricting plans partial map exhibits, individual district exhibits, charts etc. 7-2-2011 Continue with trial prep. Review file, pleadings, review motion 10 to dismiss outline claims, review and pull new cases, review and begin to put together First amended complaint. 7-5-2011 Review file. Check pacer for status of related cases. Trial prep: 8 review redistricting maps, charts, detail differences between different maps and district make-up. 7-6-2011 Review court s orders, review file, work on review of Def s 9 filings, review material sent to experts, Review scheduling order. Confer with other Plaintiffs counsel. 7-7-2011 Work on response to Def s motion to dismiss. Read cases 8 cited. Review Lopez and shep. Trial prep: review ct s orders Begin review for response to Def s motion. 7-8-2011 Legal research on motion to dismiss continued. Begin to draft 10 Of response distinguish cases cited by Defs. Review 1983 Issues and cases. Review standing cases, review LULAC case On judges and voters standing in Section 2 case. Review standard For organizational standing, e.g. Hunt. Review and update files. Meeting with potential George Korbel and discuss with Kother Plaintiffs counsel. 7-9-2011 Work with other counsel on jo8int response to motion to dismiss. 6 7-10-2011 Continue work on joint response to motion to dismiss, modify draft, edit s necessary 4 7-11-2011 Trial Preparation. Work on pleadings file. Review rules. Review 8 With Korbel, Tueber, Perez, Latino Task force filings, 7-12-2011 Trial preparation, work with Korbel on expert reports, 6 Identify all potential witnesses potential witnesses. 7-13-2011 Trial preparation. Work on amended complaint. Work on 10 7

Case 5:11-cv-00360-OLG-JES-XR Document 873-2 Filed 08/23/13 Page 8 of 17 Disclosures and other pleadings. Review pleadings filed by other parties. Review Georgia v. Ashcroft. Work on research on whole county line rule. Confer with Richards and Korbel. 7-14-2011 Trial preparation. Draft exhibit list; prepare for litigation 9 7-16-2011 Trial preparation. Staff meeting with MG. Go over C plans, Chapa 12 analysis, work on disclosures supp. Work on amended complaint, review exhibit list, modify and add more exhibits, review Gingles districts, review finalize motion to dismiss. 7-17-2011 Prepare for hearing on venue with other Plaintiffs counsel. 5 7-18-2011 Trial Preparation. Discuss possible testimony with County 9 Judge David Saucedo (Maverick County), Bexar County Elections Administrator Jackie Callanen, Cong. Ciro Rodriguez And former Dallas City Councilman and State Rep. Domingo Garcia. 7-19-2011 Continue trial preparation by conferring with potential 4 witnesses. 7-20-2011 Trial preparation. Work on discovery issues and confer 3 With other plaintiffs counsel 7-21-2011 Trial preparation. Work with George to to establish 4 Gingles I, kwork on joint reports to court. 7-20-2011 Finalize amended complaint. Confer with Korbel and work 9 on expert aff d drafts. 7-21-11 Work on amended complaint. Work with other Plaintiffs counsel on issues of standing, timing and venue. 6 7-22-11 Took time off to 7-25-2011. 7-26-2011 Review pending motions. Finalize Amended 8 Complaint and send to Manuel Escobar and Justin Fisher for review and edits 7-27-2011 Filed Amended Complaint, review other Amended pleadings, organize files, confer with other Plaintiffs counsel, 11 Review plans for House, and Congress. Review disclosures. Review emails, meet with Judge David Saucedo 8

Case 5:11-cv-00360-OLG-JES-XR Document 873-2 Filed 08/23/13 Page 9 of 17 and other LULAC witnesses. Review documents in response; review and modify written response to request for production; work with Korbel to finalize and organize document response and trial exhibits. 7-28-2011 Trial preparation. Review and modify response to production req. 4 Review documents. 7-29-2011 Review recent filings on motions, responses etc. 3 8-4-2011 Review files. Review expert reports, confer with other Plaintiffs 4 Counsel and George Korbel. Legal research, Review all answers to Interrogatories from all parties. 8-5-2011 Trial preparation. Continue work with George Korbel 3 8-9-2011 Work on joint reply to motion to stay. Research and 7 review questions put forth by court. Work on joint Draft response, finalize for filing by joint Plaintiffs. Begin revie of various depositions. 8-14-2011 Trial preparation. Review expert reports, Discuss various 7 Expert reports with George Korbel.. 8-15-2011 Trial preparation. Review filings and continue review of 3 expert reports filed by parties. Meeting w/ George Korbel. 8-16-2011 Review intervention papers and set meeting with DOJ. 2 8-17-2011 Confer with Jackie Callanan regarding material for testimony, 4 Contn8ue work with George Korbel and other P s counsel. 8-18-2011 Confer with other P s counsel regarding State s motion 7 for summary judgment, and motion to dismiss. Discuss joint response duties. 8-19-2011 Begin LULAC input on joint response to motions. 9 Prepare for joint meeting of all Plaintiffs counsel. Outline LULAC case and suggested order of presentation. Offer our proposed witness and exhibit list. 8-20-2011 Joint meeting of all plaintiffs counsel with LULAC expert 6 George Korbel present and post meeting thereafter. 8-22-2011 Trial preparation. Work on response to motion to dismiss and 5 Review draft of response. Work with George on Gingles plans. 9

Case 5:11-cv-00360-OLG-JES-XR Document 873-2 Filed 08/23/13 Page 10 of 17 8-23-2011 Trial preparation. Finalize joint response to State s motion. 4 8-24-2011 Trial Preparation. Continue conference by phone with LULAC 5 Witnesses and LULAC documents for trial 8-25-2011 Trial less than two weeks. Begin inalize everything, 4 Trial notebooks, exhibit notebooks for Court 8-26-2011 Confer with other Plaintiffs counsel, continue final prep 4 8-27-2011 Trial Preparation. Witness prep, LULAC concentration Dallas / Ft. worth (CD, Nueces (CD 27), Maverick Cty and South Bexar Cty (CD 23), I-35 Corridor (CD 23, 25, 35) 9 Confer with NAACP and Southern coalition supporting each Plans. George Korbel continues working with each for Alternative Gingles plans 8-28-2011 Trial preparation. Pretrial orders, state reply to response. 6 Continue organizing presentation to trial court. 8-29-2011 Trial preparation. Order color copies of maps, b/w of 5 data sheets, Start preparing George Korbel for testimony and cross by other Plaintiffs counsel 8-30-2011 Trial preparation. Witness preparation. 4 Confer with other Plaintiffs counsel 8-31-2011 Last day off until after trial 9-1-2011 Prepare for and attend pretrial hearing, post trial meeting with other Plaintiffs counsel. Finalize order of 4 court presentation. LULAC to follow MALC, LTF. 9-3-2011 Trial preparation, countdown 3 days. Have staff bind all 6 Notebooks, check for accuracy, Final prep face to face with witnesses 9-4-2011 Work on witness outlines, confer with other p s counsel 9 Confer with George Korbel as to other Plaintiff positions, Finalize opening statement. 9-5-2011 Trial preparation, countdown 1 day. Last prep with witnesses 12 Last review exhibits, final court notebooks trial notebook readied 10

Case 5:11-cv-00360-OLG-JES-XR Document 873-2 Filed 08/23/13 Page 11 of 17 9-6-2011 Trial preparation. Trial. 10 9-7-2011 Trial preparation. Trial. Work on offer of proof declaration. 10 9-8-2011 Trial preparation. Trial. 10 9-9-2011 Trial preparation. Trial. 10 9-10-2011 Trial. Trial preparation. Plaintiffs counsel on division of labor. 10 9-12-2011 Trial preparation. Trial. Review exhibits and witness outlines. 9 9-13-2011 Trial preparation. Trial. 10 9-14-2011 Trial preparation. Trial. 8 9-15-2011 Trial preparation. Trial. 8 9-16-2011 Trial preparation. Trial. Post trial meeting, debrief and make 6 Assign task for joint post trial brief 9-18-2011 Conference call on status and strategy with other Plaintiffs 2 9-19-2011 Work on LULAC portion joint advisory to court. 5 9-20-2011 The entire day on reading trial transcripts 7 9-21-2011 Continnue work on LULAC portion of post trial brief. 4 9-22-2011 Work on post trial brief. Review exhibits and trial transcript 6 9-23-2011 work on post trial brief. Review exhibits. Review transcript. 5 Confer with P s other counsel re Ct s advisory and tro motion. 9-25-2011 off today 9-26-2011 Confer with other P s counsel on status. review election code; 5 Review doj statements. Work with George Korbel for possible interim plan. 9-27-2011 Review recrd and TRO motion filed buy MALC 2 9-28-2011 Review State s response to TRO motion and Confer with 2 P s other counsel. 9-29-2011 Meet with Jackie Callanan, BX Cty elections Admn. 2 11

Case 5:11-cv-00360-OLG-JES-XR Document 873-2 Filed 08/23/13 Page 12 of 17 9-30-2011 Confer with George Korbel meet with Judge David Saucedo 3 10-1-2011 Work on other cases to 10-5-2011 10-6-2011 Joint conference with other p s counsel on post trial brief. 3 Work on LULAC portion of brief. 10-7-2011 Continue working on post trial brief with other P s counsel 4 10-10-11 Review filings and work on plan for submission as possible 5 interim plan. Confer with Gerry hebert, Quesada plaintiffs 10-11-2011 Review filings by Stae with George Korbel 1 10-12-2011 Review filings by other P s NC 10-13-2011 Confer with George Korbel on interim plan for LULAC and 2 other P s 10-14-2011 Review latest filings NC 10-16-2011 Continue work with George Korbel on remedy interim plans 2 10-21-2011 Review State response to post trial and MALC response NC 10-23-2011 Review of all Plans offered by other P s with George Korbel 6 10-24-2011 Prepare for new hearings and review State response 3 10-25-2011 Continue review of other plans with Korbel 6 10-26-2011 Brief conversation with Jose Garza, MALC on joint advisory NC 10-27-2011 Review joint advisory of parties NC 10-28-2011 Review US advisory and statement of interest with George Korbel NC 10-30-2011 Work on exhibits, prepare for remedy hearing, exhibits and 8 witnesses 10-31-2011 Remedy hearing prep. and remedy hearing. 10 11-1-2011 Travel to DC prepare for hearing. NC 11-2-2011 Prepare for hearing. Hearing in DC. Travel to San Antonio. NC 12

Case 5:11-cv-00360-OLG-JES-XR Document 873-2 Filed 08/23/13 Page 13 of 17 11-3-2011 Prep for hearing and Hearing on interim plan. 10 11-4-2011 Review order on schedule. Confer with court staff. Monitor NC Senate staff. 11-7-2011 Review exhibits from interim remedy hearings, review exhibit NC Lists, organize file. Review State letter brief; review draft reponse. Confer with co-counsel; review emails w/doj. 11-8-2011 Review draft of reponse to State s letter brief review doj reponse; NC review court order. Review doj filings on Section 2 issues, review and modify court advisory file same. 11-9-2011 Review court s order; confer w/clients; review costs invoice. Work NC on files. 11-10-2011 Review state s new advisory by Texas. NC 11-14-2011 Review recent advisories filed by parties NC.7 11-16-11 Review of other advisories contined NC 11-17-2011 Confer with George Korbel about proposed plans and responses 3 11-23-2011 Review proposed congressional plan by Ct. confer with 3 other P s counsel. Review Ct s iterim house plan and dissent 11-24-2011 Review State s request for stay and confer with client. NC Prepare LULAC s advisory regarding single primary. 7 11-25-2011 File Advisory by LULAC, review other filings. NC 11-26-2011 review Court Order wth George Korbel 1 11-27-2011 Review State s request for stay congressional ct. plan. review ct s 3 Order denying motion for stay; review def s notice of appeal. Confer with other P s counsel 11-28-2011 Review State s application for stay of Texas house plan with sup. NC Ct. and review other daily filings 11-29-2011 Work on LULAC portion of joint response to State 4 Confer with other P s counsel 13

Case 5:11-cv-00360-OLG-JES-XR Document 873-2 Filed 08/23/13 Page 14 of 17 11-30-2011 Continue with Response brief short call with other P s counsel 3 12-1-2011 Final edits buy LULAC. NC 12-5-2011 Review filings with Sup. Ct. and State s response brief. Confer 4 With other P s counsel regarding joint response & kargukment 12-6-2011 Review response and reply to Application for stay. Confer with 3 clients, review status. 12-9-2011 Finalize LULAC memorandum for unified single primary 5 12-10-2011 Final LULAC memorandum for unified single primary sent to 2 Mankuel Escobar and Justin Fisher for editing and correction 12-11-2011 File LULAC memorandum for unified single primary NC 12-13-2011 Prepare and attend status conference with Court 3 12-14-2011 Review daily filing, advisories and memorandums. to Brief discussion with P s other counel on Jose Garzas NC oral argument to US Sup Ct. 1-6-2012 1-7-2012 Depart for DC for US Supreme Ct argument, Perez v Perry NC Attend Mulvaney/Harvard PK moot court with Jose Garza 1-8-2012 In DC for Sup Ct argument NC. 1-9-2012 Attended US Sup Ct argument with Jose Garza NC and other P s counsel 1-10-2012 to Prepare fr DC trial work with George Korbel and other P s NC 1-14-2012 1-15-2012 Travel to Washington DC organize files, prepare for DC trial. NC 1-16-2012 Trial preparation. NC 1-17-2012 DC trial. And prepare for next day. NC 1-18-2012 DC trial. Prepare for next day, review trial transcript. Review NC depositions. 14

Case 5:11-cv-00360-OLG-JES-XR Document 873-2 Filed 08/23/13 Page 15 of 17 1-19-2012 DC trial. NC 1-20-2012 DC Trial. NC 1-21-2012 Trial preparation. NC 1-22-2012 Trial preparation DC NC 1-23-2012 DC trial, trial preparation. NC 1-24-2012 DC trial, trial preparation. NC 1-25-2012 DC trial, trial preparation, travel to Texas. NC 1-26-12 Review US Supreme Ct remand Order with P s other counsel 4 1-27-12 Hearing preparation, Hearing on remand and election schedule. 3 Confer with other P s counsel 1-29-12 Meeting with Jose Garzs, MAL counsel on settlement 1 discussions. 1-30-12 Travel to DC for closing argument. NC 1-31-12 Closing arguments in DC. Travel to Texas. NC 22-2-12 Work on maps for interim with George Korbel 3 and other P s counsel 2-3-12 Work on DC post trial matters, brief etc NC to 2-8-2012 2-9-2012 Work on proposed changes for interim maps and P s other 8 Counsel request for George Korbel 2-13-12 Prepare for hearing on interim plans. 4 2-14-12 Interim plan hearing II. Prepare for hearing. Discuss status of 12.1 negotiations with State s counsel. Work on post hearing brief. 2-15-12 Interim plan hearing. Post meeting with P s counsel 4 2-16-12 Work on post hearing brief final 3 15

Case 5:11-cv-00360-OLG-JES-XR Document 873-2 Filed 08/23/13 Page 16 of 17 2-20-2012 Work on LULAC advisory to Court on CD 23, review analysis on 7 performance. 2-21-2012 Work on and finalize advisory on CD 23, confer with George 8 George korbel anf other p s counsel 2-22-2012 File LULAC Advisor on CD 23 and conference with P s 4 Other counsel Other Joint Advisor by LULAC and other P s counsel filed 2-28-2012 Ct releases new interim plans. NC 2-29-2012 Review Ct interim plans and election schedule. 4 Confer with other P s counsel 3-1-2012 Continue review of new map. Confer with 5 Judge David Saucedo and Jackie Callanan 3-2-2012 Review continues daily filing, advisories, and memorandums NC And Orders 8-31-2012 Status conference before Ct and Advisory filed by LULAC 4 9-5-2012 LULAC Motion to Stay implementation of Interim plan 4 to 5-20-2013 end of one year of reading continuous filings. New Order for NC 5-29-2013 hearing 5-29-2013 status hearing before Ct 3 To 7-1-2013 review all filings, advisories, memorandums and orders as NC They were filed. Prep and attend hearing before 3 judge court 4 7-10-2013 LULAC portion of jint Motion for amended complaint 3 7-26-2013 Joint Motion for Amended Complaint filed NC to 8-5-2013 Review continuous filings advisories, orders NC 8-10-2013 Review time records, adjust for possible duplication, review 1 Co-counsel affidavits, suggest modifications, modify, and declare. 16

Case 5:11-cv-00360-OLG-JES-XR Document 873-2 Filed 08/23/13 Page 17 of 17 Summary of Total Fees and Expenses Total hours through Total fee due Luis R. Vers: 800 @ $400.00 = $320,000.00 Billing judgment discount: I have NC for over 200 hours directly related to this case Total fee requested: $320,000.00 for Luis R. Vera, Jr. Unreimbursed Out of pocket expenses: $2,860.00 Copy Consignor = $1,735.00 KINKOS = $ 1,125.00 (copy and binders) Total fee and costs due Luis R. Vera, Jr.: $322,860.00 Total due for Manuel Escobar, attorney: 40 hours $175.00 = $7,000.00 Total due support staff Dolores Shepherd and Rebecca Losoya 40 hours each = 80 @ $35.00 = $2,800.00 Total award for LULAC interveners = $332,860.00 The billing in this case is solely for that work done by LULAC that contributed significantly to Perez s. Perry and does not charge for emails, reading all the voluminous documents that were filed that LULAC did not contribute or the many phone calls between the P s counsel, DOJ and the clients. Also excluded are 3 depositions attended by LULAC counsekl as they were not LULAC witnesses or part of our case in chief. We also excluded the time and prep for the deposition of our expert George Korbel by the defendants as we misplaced the time and date for that deposition. We excluded all travel time and time for our meeting in DC with DOJ that were solely for this case. We have not charged any time for our work in the DC litigation or our work in Davis v. Perry. We also charge a $35.oo per hour rate for our support staff not the ridiculously high $85.00 and above rate we have seen for simple secretarial support. This billing reflects approximately 3 ½ years of work on this redistricting effort with 2 years and 3 months of LULAC involvement in this litigation. Our billing is rounded down to the hour in favor of the Defendants in this calculation, eg. 3.7 rounded down to 3 hours. There is NC for putting together this billing statement. /s/ Luis R. Vera, Jr. 8/17/2013 17

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