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)

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