HomeMy WebLinkAbout071618_ca04JEFFERSON COUNTY
BOARD OF COUNTY COMMISSIONERS
AGENDA REQUEST
TO: Board of Commissioners
FROM: Philip C. Hunsucker, Chief Civil Deputy Prosecuting Attorney
DATE: July 16, 2018
RE: Foster Pepper Law Firm Special Deputy Prosecuting Attorney Retention to Represent the
County on Long -Term, Long -Distance Solid Waste Contract
STATEMENT OF ISSUE:
The County's current long-haul solid waste contract comes to an end in April 2019. Given the complexity of
the contract, including the need to comply with solid waste law, and the total amount of the contract over
many years, beginning the bidding process as soon as possible is important. Public Works has requested that
the Prosecuting Attorney approve the law firm of Foster Pepper (http://www.foster.com/) to act as a special
deputy prosecuting attorney pursuant to RCW 36.27.040.
ANALYSIS:
RCW 36.27.040 provides, in its relevant part:
The prosecuting attorney may appoint one or more special deputy prosecuting attorneys upon
a contract or fee basis whose authority shall be limited to the purposes stated in the writing
signed by the prosecuting attorney and filed in the county auditor's office. Such special
deputy prosecuting attorney shall be admitted to practice as an attorney before the courts of
this state but need not be a resident of the county in which he or she serves and shall not be
under the legal disabilities attendant upon prosecuting attorneys or their deputies except to
avoid any conflict of interest with the purpose for which he or she has been engaged by the
prosecuting attorney. The prosecuting attorney shall be responsible for the acts of his or her
deputies and may revoke appointments at will.
The Prosecuting Attorney agrees that Foster Pepper should be appointed a special deputy prosecuting
attorney pursuant to RCW 36.27.040, provided:
(1) The Board of County Commissioners approves the funding of and reasonable terms for the Foster
Pepper contract;
(2) Foster Pepper is subject to the supervision of the Prosecuting Attorney or designee; and,
(3) Foster Pepper agrees to reasonable billing guidelines and other reasonable contract provisions.
Foster Pepper is particularly well suited to the appointment as a special deputy prosecuting attorney for this
project for at least the following reasons:
• Foster Pepper is one of the few firms with extensive solid waste management experience that does
not represent the private sector.
Foster Pepper's extensive waste management experience includes representation of. (a) King County
in Rabanco v. King County, 125 Wn. App. 794 (2005), confirming that county's flow control
authority; (b) Klickitat County for decades with respect to the planning, development and ongoing
maintenance of the Roosevelt Regional Landfill. See Klickitat County Citizens Against Imported
Waste v. Klickitat County, 122 Wn.2d 619 (1993); (c) Clark County in its recurring issues with Waste
Connections, including new contracts, contract amendments and the successful defense of the County
regarding development of the Washougal Transfer Station; (d) Cowlitz County in a potential
procurement regarding that county's headquarters landfill; (e) Spokane County in litigation regarding
that county's flow control authority; and, (f) Island County in its various solid waste contract issues.
Foster Pepper has a long history of serving as bond counsel and as special deputy prosecuting
attorney in resolving disputes, including with a County software vendor; litigation with Western
Industrial over the Queets Bridge painting contract (case settled in 2015); and, ongoing work
regarding planning and development of the Port Hadlock waste water facilities ULID.
In short, Foster Pepper is a highly regarding law firm with extensive applicable experience.
Foster Pepper possesses the necessary depth of experience in solid waste law this project requires that the
Prosecuting Attorney's Office lacks.
The proposed contract attached as Appendix 1 meets the three requirements outlined above.
FISCAL IMPACT:
Public Works already accounted for the retention of outside counsel in its budget for this project. The project
is not funded through the general fund, kw, is 41 K, S,t.,42
RECOMMENDATION:
Approve the contract in Appendix 1 for Foster Pepper to be paid as a special deputy prosecuting attorney for
the purpose of representing the County in connection with the drafting, bidding and any bid defense required
for the long-range solid waste contract.
DEPARTMENT CONTACT:
Philip C. Hunsucker, Chief Civil Deputy Prosecuting Attorney at Extension 219.
REVIEWED BY:
Date
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APPENDIX 1
VIA E-MAIL and U.S. MAIL
Mr. Philip Hunsucker
Chief Civil Deputy Prosecuting Attorney
P.O. Box 1220
Port Townsend, WA 98368
Re: Solid Waste Procurement
Dear Mr. Hunsucker:
In response to Jefferson County's request, we provide a brief synopsis of our past relationship with
Jefferson County, our experience in assisting counties with solid waste management issues, and the approach
to assisting the County regarding potential procurement and contracting for long-haul solid waste services.
Foster Pepper has a long history of serving as bond counsel and special counsel for Jefferson County.
I have been directly involved as special deputy prosecutor attorney in resolving disputes with a County
software vendor (Spillman) with respect JeffCom and computer assisted dispatch; the litigation with Western
Industrial over the Queets Bridge painting contract (case settled in 2015); and, ongoing work regarding
planning and development of the Port Hadlock waste water facilities ULID. We are available to assist the
County with its solid waste issues as well.
We are one of the few firms with extensive solid waste management experience that does not
represent the private sector. We represented Klickitat County for decades with respect to the planning,
development and ongoing maintenance of the Roosevelt Regional Landfill. See Klickitat County Citizens
Against Imported Waste v. Klickitat County, 122 Wn.2d 619 (1993). We represent Clark County in its
recurring issues with Waste Connections, including new contracts, contract amendments and the successful
defense of the County regarding development of the Washougal Transfer Station. We are currently
representing Cowlitz County in a potential procurement regarding that county's headquarters landfill. We
represent Spokane County in current litigation regarding that county's flow control authority. We
represented King County in Rabanco v. King County, 125 Wn. App. 794 (2005) confirming that county's
flow control authority. We also represent Island County in its various solid waste contract issues.
We have long history representing government in Jefferson County in addition to the County,
including the PUD and City of Port Townsend.
We understand that the County seeks our initial review and comment on potential issues and
opportunities arising from draft contracts for solid waste procurement, and for a limit on fees for such
service. We can limit our fees when there is a predictability of the work. In other cases, we can provide an
estimated budget. The budget is only an estimate and actual fees may exceed budget for reasons outside our
control (such as protracted contract negotiations). In discussions with Tom Boatman, we have established the
following schedule of tasks and fixed or estimated fees.
• Assistance in preparing the initial RFP to potential solid waste vendors: $10,000. This is a
fixed budget and will not be exceeded absent separate County approval. The following are
additional tasks, with only an estimated budget for each task.
Assistance in responding to vendors in RFP process and in subsequent negotiations. This
service may also include defense of County from challenges to procurement process or
County decisions: $5,000.
• Draft amendments to County solid waste code, including an ordinance to provide for control
of flow to County -designated facilities: $2,500. This task may also entail work on an
interlocal agreement with the City of Port Townsend.
• Address post -contracting issues or disputes, including defense of County in contract litigation
relating to the County's solid waste services: $5,000.
By separate transmittal we provide a rate sheet and sample form of authorizing resolution. However,
this assignment only may be authorized by appointment by the Prosecuting Attorney as a special deputy
prosecuting attorney pursuant to RCW 36.27.040. Our services will be subject to the prosecuting attorney's
oversight.
We endeavor to have the work performed at the most efficient and cost-effective level to serve the
County's interest. A copy of our Terms for Engagement of Services is attached as Appendix A. We will
employ billing guidelines acceptable to the office of prosecuting attorney attached as Appendix B. If there
are any questions in this regard, please do not hesitate to contact us. Additionally, should you need
references (although you are already familiar with our experience in this area), please do not hesitate to ask.
If the foregoing is acceptable to the County, the engagement will be approved by the Board of County
Commissioners.
We look forward to the further opportunity to be of service to Jefferson County.
Enclosures
cc: Tom Boatman
ACKNOWLEDGED & ACCEPTED
this day of , 2018.
Very truly yours,
FOSTER PEPPER PLLC
P. Stephen DiJulio
Managing Partner
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JEFFERSON COUNTY WASHINGTON
Board of County Commissioners
Jefferson County, Washington
IN
David Sullivan, Chair Date
SEAL:
ATTEST:
Carolyn Galloway Date
Deputy Clerk of the Board
Approved as to form only:
Philip C. Hunsucker Date
Chief Civil Deputy Prosecuting Attorney
Appendix A
Terms for Engagement of Services
Thank you for choosing Foster Pepper PLLC. Our Engagement Letter and these "Terms" constitute
our agreement with you for performing the engagement described in that letter. We pride ourselves
on responsive and vigorous representation and strive to develop excellent working relationships with
our clients. Therefore, we wish to share with you the terms of our engagement as your lawyers and
tell you about our firm. Our web page (www.foster.com) contains additional information about the
firm and its capabilities. If you have questions or concerns, please contact us immediately.
Scope of Work
Our policy -and the foundation of a sound client -attorney relationship -is to ensure that we understand
your legal needs and that you understand the nature of the services we will provide. Communication
between us is critical. We regularly will keep you informed of our activities on your behalf and will
act in your interest at all times to the best of our abilities, subject to our knowledge of the facts and
the state of the law during the representation.
Generally, one lawyer will be responsible for and will oversee your representation. Other lawyers and
legal assistants may work on your behalf -especially when special skill or expertise is required or
when delegation is more expeditious and cost- effective, or for other appropriate reasons. Your
responsible lawyer will be your point of contact for all aspects of your representation. If at any time
you are unhappy with any person working on your behalf, please tell your responsible lawyer or the
Chair of the firm's Executive Committee. The situation will be addressed immediately.
We need your help to represent you to the best of our abilities. We rely on you to be candid with and
responsive to us, as we will be with you. Please inform us immediately of any change of
circumstance affecting the representation or our ability to contact you. We both must respond
promptly and completely to inquiries and requests to enable us to represent you effectively. While we
cannot assure a successful result in any engagement, we pledge to use our best efforts on your behalf.
You may terminate our representation of you at any time and for any reason. In addition, we may
choose to withdraw from the representation, but only in accordance with the applicable Rules of
Professional Conduct in effect in the jurisdiction where our relationship exists. If we choose to
withdraw as your lawyers, we will notify you in writing. At termination or withdrawal, you will
remain obligated to pay us promptly for all charges for legal services rendered as well as charges
resulting from the termination or withdrawal, including working with any successor counsel. We will
cooperate with successor counsel to assure a smooth transfer of the representation.
Conflicts of Interest
Because our representation of you is limited in scope and because we have a large number of clients,
we wish to clarify the extent to which our representation of you may affect our ability to represent
other clients in other matters, including matters in which you may be involved. We employ internal
procedures to ensure that our representation of other clients will not cause a conflict of interest with
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you. Your identity as our client is the person or entity named as the client in our Engagement Letter
and does not include any of your affiliates, officers, directors, principals or other related parties unless
so specified. Accordingly, we may represent another client with interests adverse to any such affiliate
without obtaining your consent, and we respectfully decline to be bound by any contrary policy. If we
discover any actual or potential conflict of interest affecting our representation of you, we will notify
you promptly.
Depending upon our relationship, at the conclusion of the engagement described in the Engagement
Letter, you will no longer be considered a current client of the firm. As a former client, you may
expect that we will not represent another person in the same or a substantially related matter if that
client's interests are adverse to your interests unless you have consented in writing to the
representation after consultation and full disclosure of material facts. You may also expect that we
will preserve appropriately the confidentiality of your information and secrets. Without your prior
written consent, we will not represent a client adverse to you in a different matter if we have obtained
confidences or secrets from you that are material to that matter.
Records Retention
We maintain policies regarding retention and destruction of records. Records include our files and related
electronic documentation, including e-mails. Records (including materials provided by you to us and all
electronic documentation) relating to this engagement will be destroyed according to our policies unless
you request that they be returned to you. Our own files pertaining to the matter will be retained in
accordance with the policies. Our own files include, for example, firm administrative records, time and
expense reports, personnel and staffing materials, credit and accounting records, internal lawyers' work
product such as drafts, notes, internal memoranda, and legal and factual research, including investigative
reports, prepared by or for the internal use of lawyers. We retain client files for ten years after a matter is
closed. We will endeavor to remind you of this policy on completion of the engagement, but we reserve
the right to destroy records in accordance with our policy without further notice to you.
Fees for Services
We generally charge on an hourly basis for time expended on your behalf. This includes, for example,
telephone conversations, face-to-face conferences, strategy development and planning, document
preparation and review, research, drafting, negotiating, court appearances and travel. Through hourly
billing, you pay only for work performed on your behalf. We maintain daily time records that include a
brief description of the work done so that you will understand why you are being billed. We record our
time in units of tenths of an hour.
Upon request, we will work with you to produce an estimate of the anticipated legal fees and costs for a
particular engagement. Any such estimate will be based on our prior experience with similar engagements
as well as information you provide us about your particular needs. Unless we reach a clear, written
understanding that the fee will be a fixed amount, any estimate we make may be revised based upon the
facts and circumstances we encounter during your representation.
Our rates (which are subject to change prospectively with notice) should always be discussed in advance
with your responsible attorney. Generally, rates are revised annually and adjustments will be reflected in
our invoices in the month following any adjustment. On occasion, and after discussion with you, we may
perform services on a non -hourly basis. Our agreement with you to do so will be in writing. We strive to
keep fees and charges at a level appropriate to the task.
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Expenses
In addition to fees for legal services, you will be charged for expenses advanced on your behalf and
ancillary costs incurred by us during the course of your representation. Such charges may be revised from
time to time and will be reflected in our invoice in the month following any revision approved by you.
These charges include such things as photocopying, document binding, external messenger service,
electronic records searches, special mailing or courier services, and costs associated with managing
electronically stored information [e.g., scanning, image processing, data collection, database services, web
hosting, document summaries, etc.]. You will not be billed for long distance telephone charges, facsimile
transmissions or standard postage charges. Please note that should your work require secretarial overtime
(not caused by a secretary working for another client during the regular work day), you will be charged for
such service.
You may be asked to pay certain non -routine expenses directly to the service provider. These may include
travel expenses, filing fees, and fees and expenses of independent professionals• such as appraisers,
accountants, investigators, court reporters, and other consultants and experts. Often, these expenses must
be paid in advance. Normally, we will send the charge directly to you for payment or obtain in advance
funds from you to pay such costs. While we are under no obligation to do so, we may advance payment of
such expenses and subsequently bill you for the charges.
Billing Policy
Usually, you will be billed monthly. For your convenience, the billing statement will describe briefly the
matter and legal services performed and will set forth the fees and expenses relating to the legal services
provided. The bill typically will contain charges incurred during the prior month. Charges for some
expense items such as copy and delivery charges may not be processed and billed until sometime after the
expense has been incurred. Bills are due upon receipt, and may be paid by check, wire transfer, Visa,
MasterCard or American Express. We strive to provide clear and prompt billing statements. If you
have any questions regarding your invoice, please promptly call your responsible attorney or our
accounting department.
Advance Fee and Trust Deposits
If required by your Engagement Letter, you must pay in advance an amount equal to our estimate of the
fees and costs for some or all of the work contemplated by the scope of the engagement. Any amount
remaining at the conclusion of the engagement will be returned to you. If, after commencing work, it
appears the advance payment will be insufficient to cover legal fees and costs, you may be asked to
advance additional amounts.
If required by your Engagement Letter, you must pay a retainer to secure our availability for a given
period of time, which is considered earned by us when paid.
Amounts you pay to us in trust, including advance payments for fees and costs, will be deposited in a
trust account that we maintain for the benefit of our clients as required by the Rules of Professional
Conduct. Under these rules, if your deposit is not expected to earn a "positive net return" given its size,
the expected duration of the deposit and prevailing interest rates (less reasonable bank and
administrative charges), we will place the deposit into a pooled account. The interest earned on this
account must be paid to a charitable foundation established by court rule. If your deposit likely will earn
a "positive net return", you may request that it be placed into a segregated account and interest earned
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on that account will be added to your deposit and will be reported by our bank to the Internal Revenue
Service as taxable income to you. If you wish us to place such funds into a segregated account for your
benefit, you must provide us with your Federal Tax Identification Number.
Attorney -Client Privilege
Our attorneys and staff recognize our duty to maintain confidentiality. The attorney-client privilege
protects communications between us, whether oral or written, as long as neither of us discloses those
communications to anyone else. Privileged communications cannot be used in court without your
consent. Therefore, to preserve the privilege and confidentiality of our communications, you should
not show our written communications or discuss any oral communications between us with anyone.
Furthermore, certain communications and documents prepared in anticipation of litigation are also
privileged even if no attorney is involved. Because disputes can arise as to whether certain
communications are privileged, if you have any questions regarding what you can do, be sure to seek
advice from the lawyer with whom you are working.
We are not acting as your counsel with respect to the provisions of this statement of Terms for
Engagement of Services and to do so would be a conflict of interest. If you wish to seek advice from
independent counsel of your choice about whether you should agree to these terms, please do so. In
addition, if you have any questions or would like additional information, we are happy to discuss this
statement with you further. These terms of engagement will govern our relationship, however, unless
we reach a different agreement in writing.
Independent Contractor
We are an independent contractor and no member or employee of our firm shall be deemed to be your
employee.
Indemnity and Insurance
We shall indemnify Client against and hold the County harmless from any claim against you for damages
made by a vendor who provided goods or services to us in connection with the engagement.
We will have in effect professional liability insurance ("errors and omissions") that provides coverage for
errors and omissions by us for the engagement that has limits in the full amount customarily carried by
us. This errors and omissions insurance shall be primary if any allegation is made of professional
malpractice arising from our representation of you. We will place such insurance with insurers licensed to
do business in the State of Washington and have A.M. Best Company ratings of no less than A -VII, with the
exception that excess and umbrella coverage used to meet the requirements for limits of liability or gaps in
coverage need not be placed with insurers or reinsurers licensed in the State of Washington.
We shall furnish the County with properly executed certificates of insurance or a signed policy endorsement
which will clearly evidence all insurance required within 10 days after the effective date of this Engagement
Letter. The certificate(s) or endorsement(s) shall, at a minimum, list limits of liability and coverage. The
certificate(s) or endorsement(s) will provide that the underlying insurance contract may not be canceled, or
allowed to expire, except on 30 -days' prior written notice to the County. Any certificate or endorsement
limiting or negating the insurer's obligation to notify the County of cancellation or changes must be amended
so as not to negate the intent of this provision.
X
If applicable, we will request that the Washington State Department of Labor and Industries, Workers
Compensation Representative, send written verification to your risk manager that we are currently paying
workers' compensation.
Written notice of cancellation or change in errors and omissions insurance shall be provided by Attorneys to
County at the following address:
County Risk Manager
Jefferson County
P.O. Box 1220
Port Townsend, WA 98368
We shall provide a copy of all insurance policies required above upon request of your risk manager.
Appointment as a Special Deputy Prosecuting Attorney
Our representation is conditioned on an appointment by the Jefferson County Prosecuting Attorney
pursuant to RCW 36.27.040 and that we are subject to billing guidelines agreed upon between us and the
Jefferson County Prosecuting Attorney's Office, a copy of which is attached as Appendix B. Where the
agreed upon billing guidelines and these terms conflict, the billing guidelines control.
We understand that you have selected us not only for our expertise, but also for our reputation as
responsive and creative counsel. Be assured that we will strive to live up to your expectations. If you
have any questions, please do not hesitate to call.
Seattle: Foster Pepper PLLC
1111 Third Avenue, Suite 3000
Seattle, Washington 98101-3299
Phone: (206) 447-4400 or (800)
995-5902
Facsimile: (206) 447-9700 or
9283
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Spokane: Foster Pepper PLLC
618 West Riverside Avenue, Suite 300
Spokane, Washington 99201-5102
Phone: (509) 777-1600
Facsimile: (509) 777-1616
Appendix B
Billing Guidelines for Outside Counsel Working On Behalf of Jefferson Coun
1. Approval as Counsel Required Before Billing_ Appointment as a special deputy
prosecuting attorney pursuant to RCW 36.27.040 must be obtained outside counsel working on
behalf of the County (outside counsel) and a contract must be approved by the Jefferson County
Board of Commissioners (Board) prior to submission of any invoice for payment.
2. Conflicts of Interest. Jefferson County (the County) expects outside counsel to be free of
any conflict of interest and the appearance of any conflict of interest during the course of
representation of the County. Jefferson County recognizes that a conflict between outside counsel
and its representation of the County may arise, and the County will consider waiving a conflict of
interest when the County's interests are not impaired or compromised. If any ethical or business
conflict arises, outside counsel shall contact the Jefferson County Prosecuting Attorney
(Prosecuting Attorney) immediately.
3. Staffing Philosophy. Outside counsel are retained by the County because of their expertise
in the matter for which they are retained. The County expects that all matters handled on behalf of
the County will be properly, economically and effectively staffed. The lead or managing attorney
at a firm representing the County is responsible for appropriately staffing the matter to ensure
minimal duplication of efforts and to ensure tasks are assigned to staff at the appropriate level of
expertise and billing rate. The goal is to minimize the number of timekeepers involved in the
effective completion of tasks necessary for representation in the matter.
4. Staffing Approval. Outside counsel shall propose, and the Prosecuting Attorney shall
approve, the initial staffing of the matter. New timekeepers may be added to the representation of
the County only with the approval of the Prosecuting Attorney, which approval shall not be
unreasonably withheld.
5. Status Reportin& Outside counsel shall provide status reports as required by the
Prosecuting Attorney. The Prosecuting Attorney's strong preference is for oral, not written status
reports.
6. Settlements. No settlement can be made without obtaining a recommendation from the
Prosecuting Attorney and approval by the Board.
7. Third -Party Vendors. No third -party vendor shall be hired without prior discussion with
and approval by the Prosecuting Attorney. The County shall not accept any invoice from a third -
party vendor without prior discussion and approval in advance of the initiation of billing activity
by the third -party vendor.
8. Legal Research. Legal research should be included in the outside counsel's overhead and
shall not be billed to the County without prior approval.
9. Temporary or Contract Employees. Temporary or contract employees (including summer
associates) shall not be used by outside counsel without prior approval of the Prosecuting
Attorney. The County shall only pay the actual cost of temporary or contract employees.
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10. Rates. The County shall pay outside counsel based on hourly rates or flat fees previously
approved by the County, as set forth in a written document sent to the Prosecuting Attorney. A
request to increase hourly rates may be made by outside counsel once per year during the term of
the engagement. No unilateral rate increase shall be honored. Long-term travel of more than 50
miles (100 miles including the return) shall be billed at'/2 the hourly rate, when the timekeeper
cannot bill for the work.
11. Billing Procedure. The County shall pay only for the actual, reasonable and necessary
work spent completing at task or series of tasks. Each billing entry shall list the date, the identity
of the timekeeper and the task being billed in a manner sufficient for the County to determine what
task was accomplished and why the work was necessary for the progress of the matter. Duplicate
work by multiple timekeepers or the same timekeeper shall not be billed. The minimum billing
entry shall be 0.10 of an hour. Tasks on a given day that take less than one minimum entry shall
be grouped as one minimum entry. Each individual task (or a grouping of minimum tasks) shall be
stated separately for each timekeeper on an invoice. Expenses shall be separately documented,
billed and copies of the receipts, invoices, or other backup for the expenses shall be provided with
each invoice.
12. Billing Frequency. Invoices shall be submitted at least quarterly, monthly is strongly
preferred.
13. Overhead Expenses Not Reimbursable. Unless approved in advance by the County,
overhead expenses are not reimbursable and include but are not limited to: Internal copying or
scanning costs of over 10 cents per page; costs for converting paper materials in to electronic
materials and vice versa; overtime charges for salaries, meals or transportation, rent or utilities;
continuing legal education or attendance at seminars; conference rooms or facilities; software and
equipment rental; refreshments or meals during meetings; any alcoholic beverages; gratuities in
excess of 15%; local travel (less than 50 miles and 100 miles including the return); travel agent or
booking service fees; temporary employee agency fees; incoming faxes; markups of costs;
computerized legal research such as Westlaw or LexisNexis; internet connections; case
management or litigation software systems; or, cell phone charges.
14. No Billing for Local Travel. Costs for travel of less than 50 miles (100 miles including the
return) shall not be billed.
15. Invoice Submission, Review and Payment Procedure. Invoices shall be submitted to the
Prosecuting Attorney for review with standards of reasonableness, necessity and efficiency. After
this review for consistency, the Prosecuting Attorney shall submit all approved amounts for
processing by the County Auditor. Payment of any invoice by the County does not constitute a
waiver of the County's right to subsequently review, dispute, seek reimbursement of, compromise
or request future credits of legal fees from outside counsel. Payment of hourly rates that have not
been approved does not constitute acceptance of those hourly rates. Any adjustments to invoices
shall be detailed in an invoice report that shall be sent to outside counsel by email. Outside
counsel may request reconsideration of any material adjustments to an invoice by making such
request to the Prosecuting Attorney within 60 -days of receipt of an invoice report.
16. No Interest Shall Be Charged on Invoices. Interest shall not be charged due to any claim
of late payment of any invoice.
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