Exhibit I

Case: 2:18-cv-00272-MHW-CMV Doc #: 87-24 Filed: 02/01/21 Page: 1 of 4 PAGEID #: 3220
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 GABRIEL ARKLES 

Pursuant to 28 U.S.C. 1746 

I, Gabriel Arkles, 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 senior counsel at the Transgender Legal Defense and Education Fund. 

From 2017 through 2020, I was a senior staff attorney at the ACLU LGBT & 

HIV Rights Project. While at the ACLU, I represented Plaintiffs in this 

litigation.

3. The ACLU is a nationwide 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. 

Judge: Michael Watson 

Magistrate Judge: Chelsey Vascura 

Case: 2:18-cv-00272-MHW-CMV Doc #: 87-24 Filed: 02/01/21 Page: 2 of 4 PAGEID #: 3221
4. I have been licensed to practice law in New York since 2006. I am also 

admitted in the United States District Court for the Southern District of New 

York, the Ninth Circuit Court of Appeals, and the Supreme Court of the United 

States. I was admitted pro hac vice to the Southern District of Ohio for 

purposes of this litigation. 

5. I graduated law school in 2004. From 2004 to 2010, I worked at the Sylvia 

Rivera Law Project, first as a law fellow, and then as a staff attorney and 

director of prisoner justice. While there, I provided free legal services to lowincome transgender people and transgender people of color on a range of issues, 

including access to gender congruent birth certificates and ID. In addition to 

hundreds of more routine cases, I also represented transgender people in 

complex litigation in state and federal courts. From 2010 to 2017, I taught legal 

skills, social justice, and professional responsibility to law students at New 

York University School of Law (for three years) and Northeastern University 

Law School (for four years), while also volunteering for transgender advocacy 

organizations and publishing scholarly work related to gender and the law. 

From 2017 to 2020, I worked at the ACLU, where virtually all of my work 

involved transgender rights litigation. 

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

federal civil rights litigation, particularly in the area of transgender rights, 

similar to the work I performed in this lawsuit.

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

Declaration as Exhibit I-1. 

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

Exhibit I-2. 

9. 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.

10. 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. 

11. The reasonable hourly rate for my work is $375.

12. I am using a fair market rate for my time as an attorney with fourteen years’ 

experience who practices in this area of law. I believe this rate reflects my level 

of skill and experience and that it is comparable to similar attorneys in the 

region where the court is located. In my usual practice area of New York City, 

my reasonable rate would be $600, but I am using the local reasonable rate. 

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. 

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

reasonable hours expended by my reasonable rate, is 111*375 = $41,625. 

Dated: February 1, 2021 

By: Gabriel Arkles 

Gabriel Arkles 

Transgender Legal Defense and Education 

Fund 

520 8th Ave., Ste. 2204 

New York, NY 10018 

646-993-1688 

garkles@transgenderlegal.org 

Case: 2:18-cv-00272-MHW-CMV Doc #: 87-24 Filed: 02/01/21 Page: 4 of 4 PAGEID #: 3223