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1 Case :-cv-0-gw-jcg Document - Filed 0// Page of Page ID #: 0 ROBERT D. NEWMAN (SBN rnewman@wclp.org S. LYNN MARTINEZ (SBN 0 slmartinez@wclp.org NAVNEET K. GREWAL (SBN 0 ngrewal@wclp.org RICHARD A. ROTHSCHILD (SBN rrothschild@wclp.org WESTERN CENTER ON LAW AND POVERTY 0 Wilshire Boulevard, Suite 0 Los Angeles, CA 000 Telephone: ( - Fax: ( -0 ATTORNEYS FOR PLAINTIFFS [ADDITIONAL COUNSEL ON NEXT PAGE] UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA 0 MARCO A. GALINDO and EMMA GULLETTE, on behalf of themselves and all others similarly situated, vs. Plaintiffs, HOUSING AUTHORITY OF THE CITY OF LOS ANGELES, a public agency; DOUGLAS GUTHRIE, President and Chief Executive Officer of the Housing Authority of the City of Los Angeles; and DOES -0, inclusive, Defendants. Case No.: CV --GW (JCGx CLASS ACTION DECLARATION OF DAN STORMER IN SUPPORT OF MOTION FOR ATTORNEYS FEES Hearing Date: February, 0 Hearing Time: :0 a.m. Courtroom:0 Judge George H. Wu DECLARATION OF DAN STORMER IN SUPPORT OF MOTION FOR ATTORNEYS FEES

2 Case :-cv-0-gw-jcg Document - Filed 0// Page of Page ID #: JENNIFER A. SKLENAR (SBN 00 Jennifer.Sklenar@aporter.com TIFFANY M. IKEDA (SBN 00 Tiffany.Ikeda@aporter.com ARNOLD & PORTER LLP South Figueroa Street th Floor Los Angeles, CA 00- Telephone: ( -000 Fax: ( - ERIKA DIAZ (SBN 0 erika@laclj.org GLADYS LATORRE (SBN gladys@laclj.org LOS ANGELES CENTER FOR LAW AND JUSTICE South Soto Street # 0 Los Angeles, CA 00 Telephone: ( 0-00 Fax: ( 0-0 JAMES R. GROW (SBN jgrow@nhlp.org NATIONAL HOUSING LAW PROJECT 0 Market Street, Suite 000 San Francisco, CA 0 Telephone: ( -000 Fax: ( -00 ATTORNEYS FOR PLAINTIFFS [ADDITIONAL COUNSEL ON PREVIOUS PAGE] DECLARATION OF DAN STORMER IN SUPPORT OF MOTION FOR ATTORNEYS FEES

3 Case :-cv-0-gw-jcg Document - Filed 0// Page of Page ID #:0 DECLARATION OF DAN STORMER I, DAN STORMER, declare and state as follows: BACKGROUND. I am an attorney licensed to practice law by the State of California. I have personal knowledge of the facts contained in this Declaration and if called to testify, could and would competently testify thereto.. I am a partner of the law firm of Hadsell Stormer & Renick LLP, an -attorney firm which practices primarily in the area of employment law, constitutional, civil rights, InternatiOnal Human Rights, and public interest law. I have been in the practice of law for 0 years and a member of the State Bar of California since, an inactive member of the State Bar of Colorado (, and former member of the State Bar of Washington (.. I am "AV Preeminent" rated by Martindale-Hubbell. I have been listed in "The Best Lawyers In America" since. Also, as a result of surveys of attorneys by the Daily Journal, I have been repeatedly listed as one of the "Top 00 Most Influential Lawyers in California" (Cal. Law Business, as well as the Top Labor and Employment Lawyers. I have been repeatedly selected as a SUPER LAWYER by Los Angeles Magazine and Law & Politics Magazine. In the same surveys, I was also selected as one of the top 0 lawyers in the Los Angeles area. I have been listed since in "Guide to the World's Leading Labour and Employment Lawyers." Each of the partners in our firm was also selected as a SUPER LAWYER. I have been named as a Fellow of the College by the Governors of The College of Labor and Employment Lawyers. I have been rated as one of the top ten employment lawyers in this state. I have also been listed as one of the top five plaintiff employment lawyers in California (Chambers USA America's Leading Business Lawyers, Our firm is also listed in the same study as being one of the top four firms in the state.. I have co-authored three law review articles: Stormer and Bernstein, The Impact of Kolender v. Lawson on Law Enforcement and Minority Groups, Hastings Constitutional Law Quarterly, 0 (; Stormer and Ferber, Legal Responses to Unconstitutional Termination of Disability Benefits, Idaho Law Review 0 (-; Stormer and Richardson, The Graying of America: Age Discrimination in the Nineties, West Los Angeles Law Review (. I

4 Case :-cv-0-gw-jcg Document - Filed 0// Page of Page ID #:0 previously wrote a monthly column for the Matthew Bender-California Labor and Employment Bulletin. I have contributed to literally dozens of other publications, including a chapter in the James Publications Book: Sexual Harassment.. During the past 0 years, I have taught at over 0 legal programs and seminars as well as having been a key note and graduation speaker. I have taught at Hastings College of Law (Trial Advocacy, Pre-Trial Criminal Procedure, Loyola College of Law (Prisoners' Rights, San Fernando Valley College of Law (Trial Advocacy, and at Southwestern University College of Law (Political Trials. I have also taught trial advocacy for the National Institute of Trial Advocacy, Hastings College of Trial Advocacy, and California Institute of Trial advocacy. I have lectured extensively on Civil Rights and Harassment to students, bar groups, CEB organizations and community groups.. I have been the subject of numerous Daily Journal profiles, including May 00, August,, and December, and numerous Top 00 Lawyer profiles and Top Labor and Employment profiles, one profile in the Los Angeles Lawyer (December, one in the California Lawyer (December and one in the Legal Exchange (May 0 and in California Law Business (November as well as the Pasadena Star News (April 0, 00. I have repeatedly been listed as one of the top employment lawyers in California as the result of Daily Journal surveys. I was also profiled in the Wagner alumni journal (Fall 00. Additionally, I was profiled in the Santa Monica Community College semi-annual publication "Voices on Higher Education" in.. I have been acknowledged internationally as one of the leading civil rights, employment, plaintiff-side labor and constitutional law attorneys, as recognized in "The Best Lawyers in America," Euromoney Publications' "Guide to the Worlds' Leading Labour and Employment Lawyers," "America's Registry of Outstanding Professionals," as well as the National and International "Who's Who of Professionals.". As noted above, I am often asked to speak to legal groups on various issues concerning civil rights and trials. I have been a law school commencement address speaker. I have spoken and/or delivered papers in over 0 seminars. For instance, I have spoken to the Los Angeles Trial Lawyers Association on the issue of how to try an employment discrimination case; the Los Angeles County Labor Law Section held a seminar on "The Care and Feeding of Juries" in which I was a primary

5 Case :-cv-0-gw-jcg Document - Filed 0// Page of Page ID #:0 0 0 speaker; the California Employment Law Council presented a program on mediation in which I was one of three speakers; the Trial Lawyers Association presents each year a "Masters Series" involving, as they describe it, "prominent successful attorneys," and I was one of those persons selected to present a closing argument. I have been the key-note speaker at the annual California State Bar Labor and Employment law symposium. I have been the commencement speaker at the graduation for The Thomas Jefferson School of Law. I have also spoken at seminars on civil rights trials presented by MALDEF, ACLU, Consumer Attorneys of California, Consumer Attorneys Association of Los Angeles, Florida Trial Lawyers, Western Trial Lawyers Association, National Employment Lawyers Association, Los Angeles County Bar, California State Bar, National Lawyers Guild, California Trial Lawyers Association, American Trial Lawyers Association, Association of Business Trial Lawyers, The National Institute of Trial Advocacy and many others. These seminars are only some of the engagements at which I have spoken. I have also spoken at several ABA conventions and at literally hundreds of trial practice workshops and other legal educational seminars.. I have received a number of awards: Religious Liberty Award by the ACLU in 0; Certificate of Special Congressional Recognition by Congressman Howard L. Berman in 0; LGBT Award by the ACLU Foundation of Southern California in 00; The Honorable Robert W. Kenny Award by the Los Angeles Chapter of the National Lawyers Guild in 00; Los Angeles Regional Social Justice Award by Occidental College - Urban & Environmental Policy Institute; Certificate of Recognition for Human Rights Legal Representation by the California State Assembly; Joseph Posner Award by the California Employment Lawyer's Association; Certificate of Recognition for Fighting Discrimination by the California State Assembly Resolution; The Los Angeles Office of the City Attorney's Commendation for outstanding contribution to the citizens of Los Angeles in ; the California Lieutenant Governor's Commendation for longstanding commitment to ensure equal justice and for service to the community in ; the Pursuit of Justice Award by the California Women's Law Center in, the California Assembly Resolution honoring me for my commitment to civil rights, constitutional law and public interest law in ; the Clarence Darrow Award by People's College of Law in ; the Hollywood Fair Housing Council Award in ; the Pro Bono Firm of the Year by Public Counsel Law Center in ; and the Pro Bono Service Award given to me by the Legal Aid

6 Case :-cv-0-gw-jcg Document - Filed 0// Page of Page ID #:0 0 0 Foundation of Los Angeles in. 0. I have tried many cases to juries. On a number of occasions I have achieved results of a million dollars or more, examples are Martin v. Texaco (0 million, Schell v. Parks (. million, Zinzun v. City of Los Angeles (. million, Ruiz v. Jackson (. million, Wysinger v. The Automobile Club of Southern California (. million, and Bonsangue v. ADP (slightly over million. I have been co-counsel or lead counsel in several dozen cases which have settled for seven or eight figures (no decimals included. This declaration is made in support of the motion filed by the plaintiff for an award of attorneys' fees payable to class counsel. I am only attesting to the reasonableness of the hourly rates being requested. HOURLY RATES AND MULTIPLIER. Our firm primarily takes cases on a contingency basis. Because of the contingent nature of our practice it is necessary that we recover a fee that is substantially more than that which we would normally charge paying clients on an hourly basis. To attract persons to taking such contingent cases and to properly compensate lawyers for this type of litigation it is typically expected that if a case goes to trial or arbitration there will be a multiplier of approximately.0 to.0 simply because of the contingent nature of the case.. The hourly rates charged by my firm are consistent with those of comparable experience, expertise and skill in the community. The rates for attorneys in my firm (and their year of admission to the Bar are as follows: Dan Stormer (, $,000; Barbara Hadsell (, $; Randy Renick (, $0; Cornelia Dai (000, $0; Joshua Piovia-Scott (00, $00; Cindy Panuco (00, $0; Lincoln Ellis (0, $; Mary Tanagho Ross (0, $; Mohammad Tajsar (0, $; and Acrivi Coromelas (0 $00. Though as stated most of our cases are taken on a contingency basis, we also represent some clients on an hourly basis. The above rates are those we charge such clients. FAMILIARITY WITH ROBERT NEWMAN'S EXCELLENT LITIGATION SKILLS. I am informed that the fee motion in this case will seek $0 per hour for the work of lead class counsel Robert Newman. In my opinion, this is not only reasonable, but considerably lower than I would value Mr. Newman's services. I have known Mr. Newman for about 0 years. I have lost track of the number of cases where the two of us have co-counseled. Mr. Newman has a part-time private

7 Case :-cv-0-gw-jcg Document - Filed 0// Page of Page ID #:0 0 practice. When I am initiating a case, one of the first things I do is evaluate the resources that will be needed and determine whether our firm can handle the case by itself. If the answer to that question is no and the case requires complex legal questions or difficult factual challenges, the first person I call is Bob Newman. He has an encyclopedic knowledge of discovery practice; is an outstanding strategist; researches exhaustively but efficiently; writes persuasively; and has excellent judgment. I am aware of very few, if any, all-around better attorneys than Mr. Newman. FAMILIARITY WITH THE WESTERN CENTER ON LAW AND POVERTY. I am quite familiar with the work of the Western Center on Law and Poverty. I was a staff attorney at the Western Center in the early 0s, have co-counseled with Western Center on several cases, and know many of their attorneys, past and present. The Western Center has a welldeserved reputation as one of the premiere law firms in the country devoted to poverty law issues. The work of the Western Center is excellent and deserving of the hourly rates sought in this case. I declare under penalty of perjury under the laws of the State of California and the United States of America that the foregoing is true and correct. Executed January d t(, 0, at Pasadena, California. DAN STORMER 0