Exhibit M

Case: 2:18-cv-00272-MHW-CMV Doc #: 87-35 Filed: 02/01/21 Page: 1 of 4 PAGEID #: 3268
UNITED STATES DISTRICT COURT 

FOR THE SOUTHERN DISTRICT OF OHIO 

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 EMMA KEESHIN 

Pursuant to 28 U.S.C. 1746 

I, Emma Keeshin, 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 was the Legal Assistant for the ACLU of Ohio between the years 2016 and 

2018.

3. The ACLU of Ohio is a statewide 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. As the Legal Assistant, I performed investigations, managed client 

communications, and provided other support and paralegal work to the ACLU 

of Ohio’s three-person (formerly two-person) attorney team.

Judge: Michael Watson 

Magistrate Judge: Chelsey Vascura 

Case: 2:18-cv-00272-MHW-CMV Doc #: 87-35 Filed: 02/01/21 Page: 2 of 4 PAGEID #: 3269
5. I worked on the above-captioned case, including the pre-litigation investigation 

and during the litigation, until I left the department in 2018.

6. I have a bachelor’s degree from Oberlin College, where I graduated in 2015 

with degrees in politics and in law and society. 

7. Currently, I work as a distributed organizer with Pennsylvania United, a labor 

rights organization that works to build solidarity between working-class people 

of different backgrounds in Western Pennsylvania.

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

Declaration as Exhibit M-1.

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

Exhibit M-2.

10. The time I expended and listed here is reasonable, and the records submitted are 

an accurate reflection of that time. I documented my time in six-minute 

increments.

11. I exercised billing judgment to prepare these time records. For example, I did 

not list time for many small tasks or for any tasks that did not take at least six 

minutes to complete. 

12. I also did not list my time for the many clerical tasks I had to perform for this 

litigation, such as finalizing and filing motions and pleadings.

13. I also did not list the considerable time I expended on the pre-litigation 

investigation for this case, or the work I performed to prepare for filing the 

initial complaint.

14. The reasonable hourly rate for my work is $150.

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15. I am using a fair market rate for my time, as a legal assistant in this region with 

a bachelor’s degree and multiple years of experience. I believe this rate reflects 

my level of skill and experience. These conclusions are based in part on the 

guidance published by the Ohio State Bar Association, attached to the Fee 

Petition in this case as Exhibit A.

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

reasonable hours expended by my reasonable rate, is 8.7 * 150 = $1,305.

Executed on this February 1, 2021 

 By: /s/ Emma Keeshin 

Emma Keeshin 

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