The total fees claimed by Mexico in connection with the aforementioned motion, reply and motion for leave to file supplemental reply equal $17,835, reflecting work performed by a partner, associate and paralegal and employing respective hourly rates of $425, $245, and $120, based on the Laffey Matrix. See Laffey v. Northwest Airlines, Inc., 572 F. Supp. 354 (D.D.C. 1983), aff'd in part, rev'd in part on other grounds, 746 F.2d 4 (D.C. Cir. 1984), cert. denied, 472 U.S. 1021 (1985). The Laffey decision involved a claim for attorneys fees in a "complex and long standing employment discrimination suit." 746 F.2d at 7. In that case, Circuit Judge Skelly Wright, dissenting therein, agreed with the majority that "the appropriate inquiry is to determine the prevailing market rate for complex federal litigation." 746 F.2d at 32 (citing Blum v. Stenson, 104 S. Ct. At 1547 n.11). The instant case involves a claim for attorneys' fees based on work performed in connection with a motion to compel, which is not "complex."