Exhibit H

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UNITED STATES DISTRICT COURT 

FOR THE SOUTHERN DISTRICT OF OHIO 

EASTERN DIVISION 

STACIE RAY, et al. 

Plaintiffs, 

v. Case No.: 2:18-cv-00272-MHW-CMV 

STEPHANIE MCCLOUD, Director, 

Ohio Department Health, et al., 

Defendants. 

DECLARATION OF JOHN A. KNIGHT 

Pursuant to 28 U.S.C. 1746 

I, John A. Knight, declare under penalty of perjury that the following is true and correct 

to the best of my knowledge and belief: 

1. I am above the age of 18, I am competent to testify, and I have personal 

knowledge of the matters contained in this declaration.

2. I am a Senior Staff Attorney at the American Civil Liberties Union (“ACLU”) 

Foundation’s national LGBT Project and I represent Plaintiffs in this litigation. The ACLU 

Foundation is the legal and educational arm of the national organization, the American Civil 

Liberties Union. 

3. The ACLU is a national non-profit organization that relies upon the contributions 

of its members and supporters, and in part upon attorney fees incurred in litigation, to fund its 

operations. 

4. I am licensed to practice law in Illinois and I have been since 1989. 

Judge: Michael Watson 

Magistrate Judge: Chelsey Vascura 

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5. I am also admitted in the Northern, Central and Southern Districts of Illinois, the 

Western and Eastern Districts of Wisconsin, the Western and Eastern Districts of Michigan, the 

Sixth and Seventh Circuits, and the United States Supreme Court. I am admitted pro hac vice in 

the United States District Court for the Southern District of Ohio as counsel in this case.

6. I have been with the ACLU since March 2004. Prior to that, I was employed as a 

trial attorney by the Equal Employment Opportunity Commission from 2000 to 2004. From 

1995 until 2000, I was a clinical lecturer at the Edwin F. Mandel Legal Aid Clinic of the 

University of Chicago, where I supervised law students working on cases for persons who were 

homeless or at imminent risk of becoming homeless and co-taught a course on LGBT rights. I 

worked as an associate at the Chicago law firm of Rothschild, Barry & Myers from 1990 until 

1995. Before that, I worked for two years as a law clerk for Judge Hubert L. Will of the United 

States District Court for the Northern District of Illinois.

7. Since 1995, I have developed litigation specialties in the areas of civil rights and 

civil liberties law. I have accumulated experience working on complex constitutional and other 

federal civil rights litigation similar to the work I performed in this lawsuit. For example, I have 

been lead counsel in cases involving restrictions on transgender persons changing their sex 

designation on identification documents in Illinois, Alaska, and Michigan. 

8. My resume detailing my professional qualifications is attached to this Declaration 

as Exhibit H-1. 

9. My hours expended working on this case are attached to this Declaration as 

Exhibit H-2.

10. The time expended and costs incurred have been reasonable, and the records 

submitted are an accurate reflection of the time I expended in this case. I documented my time in 

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six-minute increments.

11. I exercised billing judgment in preparing these time records. 

12. The reasonable hourly rate for my work is $500.

13. I am using a fair market rate for a senior attorney with subject matter expertise in 

the geographic region where this case was litigated. My normal rate for this type of litigation is 

$525 and is based on the rates of civil rights attorneys in the Chicago area. The $500 rate we are 

using for my time is reduced to be comparable to local attorneys, and based in part on the 

guidance published by the Ohio State Bar Association, attached to the Fee Petition in this case as 

Exhibit A. 

14. The lodestar figure for my work on this case, determined by multiplying my 

reasonable hours expended by my reasonable rate, is 12*500 = $6,000. 

Dated: February 1, 2021 By: /s/ John A. Knight 

John A. Knight

ACLU Foundation 

150 N. Michigan Ave., Ste. 600 

Chicago, IL 60601 

Phone: (312) 201-9740 

Facsimile: (312) 288-5225 

Email: jaknight@aclu.org 

Attorney for Plaintiff

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