Exhibit G

Case: 2:18-cv-00272-MHW-CMV Doc #: 87-18 Filed: 02/01/21 Page: 1 of 4 PAGEID #: 3188
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 KARA N. INGELHART

I, Kara N. Ingelhart, 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 Staff Attorney at Lambda Legal Defense and Education Fund (“Lambda 

Legal”), and I represent Plaintiffs in this litigation.

3. Lambda Legal is a nationwide non-profit organization that relies upon the 

contributions of its 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 December 22, 2015. 

5. I am also admitted in the United States District Courts for the Northern District of 

Illinois and the Western District of Michigan, and in the Fourth, Seventh, and 

Ninth Circuit Courts of Appeals.

6. I have been with Lambda Legal for my entire career, beginning as a Skadden 

Fellow, then as a law fellow, and then as a staff attorney. I work in Lambda 

Judge: Michael Watson 

Magistrate Judge: Chelsey Vascura 

Case: 2:18-cv-00272-MHW-CMV Doc #: 87-18 Filed: 02/01/21 Page: 2 of 4 PAGEID #: 3189
Legal’s Midwestern Regional Office, which is based in Chicago, Illinois. I am a 

recipient of the National LGBT Bar Association’s Best LGBT Lawyers Under 40 

Award. 

7. I have accumulated experience working on complex constitutional and other 

federal civil rights litigation similar to the work I performed in this lawsuit.

8. During my time at Lambda Legal, I have acquired specialized experience and knowledge 

litigating cases involving discrimination against transgender people, including challenging 

the denial of identity documents that accurately reflect their gender identity. I heavily 

relied upon that experience and knowledge for my representation of Plaintiffs. 

Representative examples of the cases that I have litigated include the following: F.V. v. 

Barron, 286 F. Supp. 3d 1131 (D. Idaho 2018) (counsel in challenge to denial of birth 

certificates reflecting gender identity); Karnoski v. Trump, 926 F.3d 1180 (9th Cir. 2019) 

(counsel in challenge to ban on open military service by transgender people); Arroyo 

González v. Rosselló (D. Puerto Rico 2018); Hobby Lobby v. Ill. Human Rights Comm’n; 

Ill. Dept. of Human Rights; & Meggan Sommerville (Ill. App. Ct. 2nd Dist. 2021) (amicus

counsel in denial of restroom access for transgender employee under Title VII); Evancho v. 

Pine Richland School District (W.D. Pa. 2018) (counsel for transgender students in Pine 

Richland School District challenging a School District resolution that requires transgender 

student to use restrooms according to their sex assigned at birth). I have also worked with 

experts regarding the importance of access to accurate identity documents for transgender 

people, which was relevant to the effective representation of Plaintiffs.

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

as Exhibit G-1. 

10. Along with my co-counsel Elizabeth Bonham, I performed the majority of the 

attorney work in this litigation. Elizabeth and I have amongst the lowest billing 

rates of our counsel group. 

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

Exhibit G-2.

12. 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 six-minute increments.

13. 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. 

14. I am seeking fees for 456.2 hours of work on this case at a rate of $250 per hour. Exhibit G2 to this Declaration is a true and correct copy of the task-based itemized charges for my 

time in this case, which I have reviewed and approved. I exercised billing judgment to 

ensure that the time spent was reasonable and necessary under the circumstances. The 

current rates for an attorney with my years of experience in the Chicago market performing 

comparable civil litigation would be more than $300 per hour.

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

reasonable hours expended by my reasonable rate, is 456.2*250 = $114,050. 

Dated: February 1, 2021 

By:/s/ Kara Ingelheart 

Kara N. Ingelhart (6321949) 

Lambda Legal 

65 E. Wacker Pl. 

Chicago, IL 60611 4506 

Chester Ave. 

Cleveland, OH 44103 

Phone: (312) 663-4413 

Facsimile: (312) 663-4307 Email: 

kingelhart@lambdalegal.org 

Attorney for Plaintiffs

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