United States of America v. Alabama, State of et al

Filing 68

REPLY to Response to Motion re (37 in 5:11-cv-02484-SLB) MOTION for Preliminary Injunction and Memorandum in Support filed by Aids Action Coalition, Alabama Appleseed Center for Law & Justice, Inc., Robert Barber, Jeffrey Allen Beck, Boat People SOS, Michelle Cummings, Dreamactivist.org, Greater Birmingham Ministries, Esayas Haile, Hispanic Interest Coalition of Alabama, Huntsville International Help Center, Interpreters and Translators Assocation of Alabama, Ellin Jimmerson, Pamela Long, Juan Pablo Black Romero, Service Employees International Union, Southern Regional Joint Board of Workers United, Fiseha Tesfamariam, Christopher Barton Thau, United Food and Commercial Workers International Union, Local 1657 United Food and Commercial Workers International Union, Daniel Upton, Matt Webster, Maria D. Ceja Zamora. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4)Associated Cases: 5:11-cv-02484-SLB, 5:11-cv-02736-SLB, 5:11-cv-02746-SLB(Wang, Cecillia)

Download PDF
FILED 2011 Aug-15 PM 11:22 U.S. DISTRICT COURT N.D. OF ALABAMA IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ALABAMA NORTHEASTERN DIVISION Hispanic Interest Coalition of Alabama, et al., Case No. 5:11-cv-02484-SLB Plaintiffs, v. Governor Robert Bentley, et al., Exhibits in Support of Plaintiffs’ Reply In Support of Motion For Preliminary Injunction Defendants. Exhibit 3 Supplemental Declaration of Isabel Rubio On behalf of Hispanic Interest Coalition of Alabama SUPPLEMENTAL DECLARATION OF ISABEL RUBIO I, Isabel Rubio, hereby make this declaration based on my personal knowledge and if called to testify I could and would do so competently as follows. 1. I am the executive director of the Hispanic Interest Coalition of Alabama (¡HICA!), based in Birmingham, Alabama. I am providing this supplemental declaration to give further information on the harm HB 56 will cause to ¡HICA! and its members. 2. Since HB 56 was proposed in Alabama, ¡HICA! has responded to the requests of its membership and the broader community to present information about HB 56 and its impact on Alabamians. Our response has been in the form of answering questions in the office, by phone and email, by adding information during programs on other topics, and by preparing for and giving HB 56 Know Your Rights presentations in several churches and other community settings. 3. ¡HICA! staff persons have given approximately eighteen presentations in June, July, and August 2011 in Alabama to immigrant families, allies, educators, and other community members. About thirteen of those presentations were planned in order to give information on HB 56 and its impact on Alabamians, including specifically information on enrollment of students in Alabama public schools. The other approximately five presentations had been planned to cover other topics that ¡HICA! addresses, such as humanitarian visas, basic immigration law information, and Latino Culture in Alabama, but due to audience demand, information on HB 56 was added to the agenda. Approximately 1,527 people attended the abovementioned presentations, including about 800 at a single event. 4. As mentioned in my previous declaration, visits by community members to the ¡HICA! office have increased dramatically. The majority of the new visits are by community members asking questions about how their families will be impacted by HB 56. Parents of children in kindergarten through 12th grade, including those who are preparing to enroll for the first time and those whose children are already attending public schools, are asking what will happen to their children and themselves if they are asked to reveal their immigration status in order to register their children for school, or if school officials otherwise suspect them of being undocumented. 5. ¡HICA! staff members have had to postpone other important work in order to meet this important and urgent community need for information related to HB 56 and its impact. The delayed work has included the preparation of U and T Visa applications for crime victims, and other important legal representation work. Staff members who teach classes or lead groups of community members have had to extend session times to be able to give updates on HB 56 on top of the regular class content or group discussion topic. Most ¡HICA! staff persons have seen their work expand to include giving information on the impact of HB 56 and listening to and responding to community members’ fears about the new law. 6. ¡HICA! staff persons and members also participated in a community listening session held by U.S. Department of Justice on August 4, 2011, in Birmingham, Alabama. Approximately 60 participants recounted their fears of the impact of HB 56, especially on their children who are enrolled or enrolling this year in Alabama public schools. Parents reported fears of discrimination against their children born outside of the United States, and fears of arrest for undocumented parents of children registering in school. This event required significant preparation by ¡HICA!. 7. HB 56 has already impacted ¡HICA! in a negative way, by causing the postponement of a substantial amount of our mission-required work and forcing us to divert scarce resources to inform the community about this new law. I declare under penalty of perjury that the foregoing is true and correct. Executed this 15th day of August, 2011, in Birmingham, Alabama. Isabel Rubio

Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.

Why Is My Information Online?