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 26

DECLARATION OF GABRIELA GONZALEZ-LAMBERSON
I, Gabriela Gonzalez-Lamberson, hereby declare:
1. I make this declaration based on my own personal knowledge and, if called
to testify, could and would do so competently as follows.
2. I am the Executive Director of the Instituto de Mexico, Inc. of Atlanta
(“Instituto”).
3. Instituto is a non-profit organization registered in the state of Georgia and
based in Atlanta.
4. Instituto is dedicated to fostering the development of the Mexican
community in Atlanta the history and culture of Mexico in the United States.
We place a special focus on educating Georgia youth with Mexican ancestry
about their heritage and culture.
5. Instituto was founded in 2002, and its mission is to promote understanding
and to share Mexican customs and traditions with residents of Atlanta and
surrounding areas. We also work to cultivate friendship ties and mutual
understanding of the cultural commonalities between the United States and
Mexico.

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6. To fulfill its mission, Instituto organizes cultural programs, which are open
to all Atlanta-region residents without regard to immigration status,
nationality, or citizenship.
7. These events draw attendees from across Atlanta and the rest of the state and
regularly include thousands of participants.
8. Although Instituto’s events are open to all, the majority of attendees are
Latino, including U.S. citizens and others in lawful immigration status.
9. If HB 87 is implemented, Instituto will be harmed because attendance at its
events will drop drastically, and this will undermine the Instituto’s ability to
achieve its central purpose as an organization—to promote understanding
and educate the public about Mexican cultural heritage.
10.I have direct knowledge that already, since HB 87 passed, people have
expressed fear of attending Instituto events. Individuals who regularly
attend Instituto events have expressed that they are afraid to attend these
events out of fear that they will be targeted by local police and will be
subject to immigration status inquiries if they attend large group events with
primarily Latino attendees.
11.The passage of HB 87 has created an intense climate of fear for Latinos in
Georgia, and individuals of Latino descent are afraid that any contact with

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law enforcement could result in extended interrogation, detention, and arrest
regardless of their immigration status.
I declare under penalty of perjury under the laws of the United States of America
that the foregoing is true and correct.
Executed this 7th day of June, 2011 in Atlanta, Georgia

___________________________________
Gabriela Gonzalez-Lamberson

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