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DRAFT FOR ATTORNEY REVIEW — NOT FINAL

Caitlin Cromar, Et Ano, V. Tag Realty, Llc. (2026)

Citation
Caitlin Cromar, Et Ano, V. Tag Realty, Llc. (2026)
Parent Document
Caitlin Cromar, Et Ano, V. Tag Realty, Llc. (2026)
Jurisdiction
Washington (state)
Effective Date
2026-01-12

Other Sections in This Document (502)

Full Text

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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
87780-1-I/9 and $450 for Santiago. The court entered the following findings of fact: 9