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 4
Supplemental Declaration of Scott Douglas
On behalf of Greater Birmingham Ministries

SUPPLEMENTAL DECLARATION OF SCOTT DOUGLAS
I, Scott Douglas, hereby make this declaration based on my personal
knowledge and if called to testify I could and would do so competently as
follows.
1. My name is Scott Douglas. I am the Executive Director of the Greater
Birmingham Ministries (“GBM”), based in Birmingham, Alabama. I am
providing this supplemental declaration to give further information on the
harm HB56’s education provision will cause to both future and present
school age children.
2. Section 28 directly interferes with GBM’s mission, particularly with
regard to economic justice. As I explained in Paragraph 11 of my first
declaration, undocumented individuals are afraid to enroll their children
in school because of HB 56. Our mission to provide economic justice
and improve the lives of all is undermined by Section 28 because we can
have no economic justice if children are uneducated and deterred from
going to school. In addition, we have had to divert resources from our
regular duties to educate parents about Section 28, and will now have to
divert more resources to Section 28 because the state keeps changing
what it means to “enroll” in Alabama schools. This will only create more
confusion as the school year is about to begin.
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3. GBM and its member organizations have undocumented families with
children of all ages coming to their faith communities from out of state.
Undocumented people move to Birmingham from other parts of the
country for many reasons - jobs, education and relocation from larger
cities, among other things. No matter what time of year these families
arrive, if they have not lived in Alabama before, they enroll their children
in Alabama schools for the first time.
4. As I stated in Paragraph 11 of my first declaration, GBM is affected by
HB 56’s education provision because our member congregations serve a
large number of school-age children. This includes families that have
young children who haven’t entered school yet, but will begin school
(kindergarten) for the first time next year.
5. If allowed to go forward, HB56’s education provisions will harm both
current and future students in Alabama.

I declare under penalty of perjury that the foregoing is true and correct.

EXECUTED this 15th day of August, 2011 in Birmingham, Alabama.

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____________________________________
Scott Douglas

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