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Wash. Court of Appeals published opinion — 877801 orderandopinion.pdf

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Wash. Court of Appeals published opinion — 877801 orderandopinion.pdf
Jurisdiction
Washington (state)
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7
TAG Realty also offered a link to an unauthenticated website that counsel reported
stated “[t]he average hourly attorney rate in Washington is $322.00.” Besides being
unauthenticated and inadmissible hearsay, as an “average” the evidence is also irrelevant. Even
if a statewide “average” rate for all lawyers handling all kinds of matters could be established
through competent evidence, that alone would do nothing to shed light on the reasonable rate
for a particular lawyer, with particular expertise, in a particular market, handling a particular kind
of case. Thus, the described “average” rate was inadmissible independently under ER 402, 802,
and 901.
8
The trial court did not reduce the award for plaintiffs’ legal costs.
8
For the current opinion, go to https://www.lexisnexis.com/clients/wareports/.
87780-1-I/9

and $450 for Santiago.

The court entered the following findings of fact: 9