Free Response to Motion - District Court of Arizona - Arizona

Case 2:O2—cv—O2281—SI\/II\/I D0cument269-2 Filed O2/O3/2006 Page10f3

AFFIDAVIT OF
ANN-MARTHA ANDREWS
STATE OF ARIZONA )
) ss.
COUNTY OF Maricopa )
Ann-Martha Andrews, first being duly swom, states:
l. I am a partner in the Insurance Litigation Practice Group at Lewis and Roca LLP.
2. I have personal knowledge of the following facts and am competent to make this
affidavit.
3. I am admitted to practice law, and currently actively practice, in Arizona and
Nevada. I have been practicing civil litigation in Arizona for over 16 years. For the past ten
years, my practice has focused on insurance coverage and bad faith litigation.
4. I am familiar with the rates generally charged by lawyers and paralegals at Lewis
and Roca, and believe those rates to be competitive in the Phoenix market for civil litigators.
Having reviewed our customary hourly rates, it is my experience and opinion that:
A. A reasonable rate for a very experienced paralegal (15-20 years’
experience) is in the range of $150-$170 per hour;
B. A reasonable rate for a paralegal who is trained, but early in his or her
career, is approximately $120-$130 per hour;
C. A reasonable rate for first-year associates is approximately $160-$175 per
hour;
D. A reasonable rate for third·year associates is approximately $215—$235 per
hour
Case 2:02-cv-O2281—SIVIIVI Document 269-2 Filed O2/O3/2006 Page 2 of 3<>=¤¤3·-1

E. A reasonable rate for an experienced insurance bad faith lawyer (20+ year
range) is $350 to $400 per hour.
F. A reasonable rate for an experienced appellate lawyer is $350 to $410 per
hour (10-15 year range).
5. I am unaware of any junior associate or paralegal in the Phoenix market who
commands a rate approaching $500 per hour.
Dated this 3"1 day of February, 2006.
Ann-Martha Andrews
Subscribed and swom to before me this 3rd day of February, 2006.
4’ .
otary Public
My Commission Expires:

SZ ~\¤i?)=§.s&Y PQBQG - State cf Arizona
2 _ f¥ll£lHiL;éiPM?01lNW Q
‘ c`i·
Case 2:02-cv-02281-SIVIIVI Document 269-2 Filed O2/O3/2006 Page 3 of 30ml

Case 2:02-cv-02281-SMM

Document 269-2

Filed 02/03/2006

Page 1 of 3

Case 2:02-cv-02281-SMM

Document 269-2

Filed 02/03/2006

Page 2 of 3

Case 2:02-cv-02281-SMM

Document 269-2

Filed 02/03/2006

Page 3 of 3