Witt v. Department of the Air Force et al

Filing 177

DECLARATION of Sher Kung filed by Plaintiff Margaret Witt re 176 MOTION FOR BILL OF COSTS (Attachments: # 1 Exhibit A-E)(Kung, Sher)

Witt v. Department of the Air Force et al

Doc. 177

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DECL. OF SHER KUNG IN SUPP. OF PL.'S MOT. FOR COSTS (Case No. C06-5195) - 1 CLU OF WASHINGTON FOUNDATION 901 Fifth Avenue 630 Seattle, Washington 98164 [phone] Dockets.Justia.com

The Honorable Ronald B. Leighton

UNITED STATES DISTRICT COURT WESTERN WASHINGTON AT MARGARET WITT, Plaintiff, v. UNITED STATES DEPARTMENT OF THE AIR FORCE; ET AL., Defendants. No. 06-5195 RBL DECLARATION OF SHER KUNG IN SUPPORT OF MOTION FOR COSTS NOTE ON MOTION CALENDAR: OCTOBER 29, 2010

Pursuant to 28 U.S.C. § 1746, I, Sher Kung, hereby declare as follows: 1. I am counsel for the plaintiff and have personal knowledge that all costs claimed

in this motion were actually incurred in this litigation and have been paid by the ACLU of Washington. 2. Attached hereto as Exhibit A is an itemized list of the total costs Plaintiff seeks to

have taxed and recover pursuant to 28 U.S.C. §1920. 3. Attached hereto as Exhibit B is an itemized list of recoverable costs pursuant to

28 U.S.C. §1920(1), and a true and correct copy of the receipt of costs.

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4.

Attached hereto as Exhibit C is an itemized list of recoverable costs pursuant to

28 U.S.C. §1920(2), and true and correct copies of the listed deposition invoices. 5. Attached hereto as Exhibit D is an itemized list of recoverable costs pursuant to

28 U.S.C. §1920(3) and 28 U.S.C. § 1821, and true and correct copies of the receipts reflecting the expenditures actually incurred. The "total hotel costs sought after reduction" amount was calculated by multiplying the GSA prescribed per diem rate of $113, by the number of nights recoverable per witness, and adding in the incurred hotel taxes. 6. Attached hereto as Exhibit E is an itemized list of recoverable costs pursuant to 28

U.S.C. §1920(4), and true and correct copies of the receipts of costs. I declare under penalty of perjury that the foregoing is true and correct, and that this Declaration was executed on October 14, 2010, in Seattle, Washington.

/s/ Sher S. Kung____________ Sher Kung, WSBA # 42077

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DECL. OF SHER KUNG IN SUPP. OF PL.'S MOT. FOR COSTS (Case No. C06-5195) - 2 CLU OF WASHINGTON FOUNDATION 901 Fifth Avenue 630 Seattle, Washington 98164 [phone]

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CERTIFICATE OF SERVICE I hereby certify that on October 14, 2010, I electronically filed Declaration of Sher Kung in Support of Plaintiff's Motion for Costs with the Clerk of the Court using the CM/ECF system which will send notification of such filing to the following: Peter Phipps [e-mail] Marion J. Mittet [e-mail] Stephen J. Buckingham [e-mail] Bryan R. Diederich [e-mail]

Attorneys for Defendants

DATED this 14th day of October, 2010.

AMERICAN CIVIL LIBERTIES UNION OF WASHINGTON FOUNDATION By: /s/_ Maly Oudommahavanh____ Maly Oudommahavanh Legal Program Assistant 901 Fifth Avenue, #630 Seattle, WA 98164 Tel. [phone] [e-mail]

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DECL. OF SHER KUNG IN SUPP. OF PL.'S MOT. FOR COSTS (Case No. C06-5195) - 3 CLU OF WASHINGTON FOUNDATION 901 Fifth Avenue 630 Seattle, Washington 98164 [phone]