Georgia Latino Alliance for Human Rights et al v. Deal et al

Filing 29

MOTION for Preliminary Injunction with Brief In Support by Alterna, Asian American Legal Advocacy Center, Paul Bridges, Coalition for the People's Agenda, Coalition of Latino Leaders, DREAM Activist.org, Jane Doe # 1, John Doe # 1, Jane Doe # 2, John Doe # 2, Paul J. Edwards, Georgia Latino Alliance for Human Rights, Sharon Gruner, Everitt Howe, Instituto de Mexico, Inc. of Atlanta, Ernesto Pinon, Service Employees International Union, Jaypaul Singh, Southern Regional Joint Board of Workers' United, Benjamin Speight, Task Force for the Homeless. (Attachments: # 1 Brief Memorandum in Support of Motion for Preliminary Injunction, # 2 Index of Exhibits, # 3 Exhibit Exhibit 1 Georgia House Bill 87, # 4 Exhibit Exhibit 2 Declaration of Abraham F. Lowenthal, # 5 Exhibit Exhibit 3 Declaration of Jane Doe 2, # 6 Exhibit Exhibit 4 Declaration of David S. Kennedy, Jr., # 7 Exhibit Exhibit 5 Declaration of Paul Bridges, # 8 Exhibit Exhibit 6 Declaration of Benjamin Speight, # 9 Exhibit Exhibit 7 Declaration of Everitt Howe, # 10 Exhibit Exhibit 8 Declaration of Paul C. Edwards, Jr., # 11 Exhibit Exhibit 9 Declaration of Sharon Gruner, # 12 Exhibit Exhibit 10 Declaration of Jane Doe 1, # 13 Exhibit Exhibit 11 Declaration of George Gascon, # 14 Exhibit Exhibit 12 Declaration of Eduardo Gonzalez, # 15 Exhibit Exhibit 13 Declaration of Lewis Smith, # 16 Exhibit Exhibit 14 Declaration of Ernesto Pion, # 17 Exhibit Exhibit 15 Declaration of Jaypaul Singh, # 18 Exhibit Exhibit 16 Declaration of John Doe 1, # 19 Exhibit Exhibit 17 Declaration of John Doe 2, # 20 Exhibit Exhibit 18 Declaration of Silvia America Gruner, # 21 Exhibit Exhibit 19 Declaration of Anton Flores, # 22 Exhibit Exhibit 20 Declaration of Adelina C. Nicholls, # 23 Exhibit Exhibit 21 Declaration of Anita Beaty, # 24 Exhibit Exhibit 22 Declaration of Helen Kim Ho, # 25 Exhibit Exhibit 23 Declaration of Mohammad Abdollahi Ali-Beik, # 26 Exhibit Exhibit 24 Declaration of Eliseo Medina, # 27 Exhibit Exhibit 25 Declaration of Harris Raynor, # 28 Exhibit Exhibit 26 Declaration of Gabriela Gonzalez-Lamberson, # 29 Exhibit Exhibit 27 Declaration of Molly Lauterback and Exhibits A through F, # 30 Exhibit Exhibit 28 Exhibits G through J for Declaration of Molly Lauterback, # 31 Exhibit Exhibit 29 Exhibits K through M for Declaration of Molly Lauterback, # 32 Text of Proposed Order Proposed Order Granting Motion for Preliminary Injunction)(Lapointe, Michelle) (Attachment 20 replaced on 6/10/2011) (dgs). (Attachment 29 replaced on 6/10/2011) (dgs).

EXHIBIT 14

DECLARATION OF ERNESTO PIÑON
I, Ernesto Piñon, hereby declare,
I make this declaration based on my own personal knowledge and if called to
testify I could and would do so competently as follows.
1. I was born in Mexico in 1974. I became a U.S. Citizen in 2009.
2. I live in Sunnyside, Washington. I have a Washington State driver’s
license. I do not have a U.S. Passport, and the only government
identification I ever carry with me is my Washington State driver's license.
3. My half-sister lives in Georgia. She and I stay in touch by speaking on the
phone once or twice a month. Recently her daughter, my niece, graduated
from high school. I was very proud of her and wanted to go to Georgia to
celebrate with them. Unfortunately, due to work conflicts and financial
concerns, I wasn’t able to make the trip. I plan to travel to Georgia to visit
my half-sister and my nieces sometime before the end of the year.
4. I am not very tall and have dark skin and dark hair. I think people who see
me know that I am Latino. Also, my primary language is Spanish, and
although I can speak English I do have an accent.
5. I believe that I have been stopped by the police because I look Latino. One
time I was pulled over, and the police officer told me he had stopped me
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because my windshield was cracked. But there was no crack in my
windshield. I think he was just looking for a pretext to explain why he
stopped me. Another time I was followed by a police car after leaving a bar
where I had stopped for dinner after work. The police officer saw me and
my coworkers leave and followed us. He asked me how many beers I had
drunk. I told him I had not drunk any beers. I cannot be sure that either of
these cases was racial-profiling, but I am 80 percent confident that I was
stopped because I am Latino.
6. I do not think I am the only person who is stopped by police because he/she
looks Latino. I think this happens to a lot of people. I also think the police
in other places besides Washington stop people because they look Latino. I
believe that police in Georgia probably stop people just because they look
Latino. In fact, my half-sister has told me that with this law, the police are
putting more pressure on people who look Latino.
7. When I travel, my Washington driver’s license is the only form of ID that I
carry. I am afraid that if HB 87 goes into effect, and I travel to Georgia to
visit my sister and my nieces, I will be stopped by police and then detained
because my Washington driver’s license will not be accepted as proof that I
am a U.S. Citizen. I fear that I might be profiled again as I have been in the
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past, and although I try not to, I do sometimes drive over the speed limit. I
have been stopped by the police for speeding before. I am afraid that if the
police stop me for speeding or some other traffic violation, they will not
believe me when I tell them that I am a U.S. Citizen because I don’t have the
right identification, because of my skin color, and because of my accent. I
fear they will detain me because of this.
8. If HB 87 goes into effect, I will be more afraid to travel in Georgia. When I
visit my half-sister we will stay inside at her house more than we would
have before HB 87 was a law.
9. I am proud to stand up against this law. I believe this law is unfair to
immigrants who live or travel in Georgia. As a U.S. Citizen, I do not believe
this is what my country stands for.

I declare under penalty of perjury that the forgoing is true and correct.
EXECUTED this _______ day of June, 2011 in Sunnyside, Washington.

_____________________________
Ernesto Piñon

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