State of Texas et al v. United States of America et al

Filing 64

REPLY in Support of 5 Opposed MOTION for Preliminary Injunction, filed by Phil Bryant, Paul R. LePage, Patrick L. McCrory, C.L. "Butch" Otter, Bill Schuette, State of Louisiana, State of Alabama, State of Arizona, State of Arkansas, State of Florida, State of Georgia, State of Idaho, State of Indiana, State of Kansas, State of Montana, State of Nebraska, State of North Dakota, State of Ohio, State of Oklahoma, State of South Carolina, State of South Dakota, State of Texas, State of Utah, State of West Virginia, State of Wisconsin. (Attachments: # 1 Exhibit Ex 1, # 2 Exhibit Ex. 2, # 3 Exhibit Ex. 3, # 4 Exhibit Ex. 4, # 5 Exhibit Ex. 5, # 6 Exhibit Ex. 6, # 7 Exhibit Ex. 7, # 8 Exhibit Ex. 8, # 9 Exhibit Ex. 9.a, # 10 Exhibit Ex. 9.b, # 11 Exhibit Ex. 10.a, # 12 Exhibit Ex. 10.b, # 13 Exhibit Ex. 10.c, # 14 Exhibit Ex. 10.d, # 15 Exhibit Ex. 10.e, # 16 Exhibit Ex. 10.f, # 17 Exhibit Ex. 10.g, # 18 Exhibit Ex. 10.h, # 19 Exhibit Ex. 10.i, # 20 Exhibit Ex. 10.j, # 21 Exhibit Ex. 10.k, # 22 Exhibit Ex. 10.l, # 23 Exhibit Ex. 10.m, # 24 Exhibit Ex. 10.n, # 25 Exhibit Ex. 10.0, # 26 Exhibit Ex. 10.p, # 27 Exhibit Ex. 10.q, # 28 Exhibit Ex. 10.r, # 29 Exhibit Ex. 10.s, # 30 Exhibit Ex. 11, # 31 Exhibit Ex. 12, # 32 Exhibit Ex. 13, # 33 Exhibit Ex. 14, # 34 Exhibit Ex. 15, # 35 Exhibit Ex. 16, # 36 Exhibit Ex. 17, # 37 Exhibit Ex. 18, # 38 Exhibit Ex. 19, # 39 Exhibit Ex. 20, # 40 Exhibit Ex. 21, # 41 Exhibit Ex. 22, # 42 Exhibit Ex. 23, # 43 Exhibit Ex. 24, # 44 Exhibit Ex. 25, # 45 Exhibit Ex. 26, # 46 Exhibit Ex. 27, # 47 Exhibit Ex. 28, # 48 Exhibit Ex. 29, # 49 Exhibit Ex. 30, # 50 Exhibit Ex. 31, # 51 Exhibit Ex. 32, # 52 Exhibit Ex. 33, # 53 Exhibit Ex. 34, # 54 Exhibit Ex. 35)(Oldham, Andrew)

EXHIBIT 25

App. 0879

IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF TEXAS
BROWNSVILLE DIVISION

STATE OF TEXAS, et al.,
Plaintiffs,

Case No. 1:14-cv-00254

v.
UNITED STATES OF AMERICA, et al.
Defendants.

DECLARATION OF SHERI POLLOCK

I, Sheri G. Pollock, have personal knowledge of the following facts and
declare:
1. I am the Deputy Chief Legal Counsel of the Wisconsin Department

of Workforce Development.

I provide legal advice and services for the

Department, which includes advice on the administration of the state's
Unemployment Insurance Program.
2.

The Unemployment Insurance Program, administered by the

Wisconsin Department of Workforce Development, is governed by both
federal and state law.

The program provides unemployment insurance

benefit payments, as determined by state law, to eligible workers who lose

App. 0880

Declaration of Sheri G. Pollock
Case No. 1:14-cv-00254

employment through no fault of their own.

Benefit payments are funded

entirely through taxes paid by Wisconsin employers.
3.

An individual who is not a citizen of the United States but is

lawfully present in the United States and otherwise qualifies by having
employment and losing employment in accordance with the requirements of
state law, is eligible to apply for and receive unemployment insurance benefit
payments.
4. Deferred action status under the U. S. Department of Homeland
Security memorandum dated November 20, 2014, causes an individual
covered by such status to be lawfully present in the Unites States for the
purposes of the Wisconsin state unemployment insurance law. These
individuals will work pursuant to a federally issued work authorization.
5. An otherwise eligible applicant, who has deferred action status, will
be paid unemployment benefits that are funded entirely through taxes paid
by Wisconsin employers.
6. In 2013, DWD paid claims for unemployment benefits, totaling
$570,745 to 168 unique claimants who indicated they were non-citizens,
working lawfully under a federal work authorization.

-page 2 of 3-

App. 0881

Declaration of Sheri G. Pollock
Case No. 1:14-cv-00254

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

Executed on December 22, 2014.

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-page 3 of 3-

App. 0882