8/20/2019 Motion for Preliminary injunction.pdf
1/76
Case 1:15-cv-00446-RP Document 25 Filed 08/21/15 Page 1 of 22
8/20/2019 Motion for Preliminary injunction.pdf
2/76
Case 1:15-cv-00446-RP Document 25 Filed 08/21/15 Page 2 of 22
8/20/2019 Motion for Preliminary injunction.pdf
3/76
Case 1:15-cv-00446-RP Document 25 Filed 08/21/15 Page 3 of 22
8/20/2019 Motion for Preliminary injunction.pdf
4/76
Case 1:15-cv-00446-RP Document 25 Filed 08/21/15 Page 4 of 22
8/20/2019 Motion for Preliminary injunction.pdf
5/76
Case 1:15-cv-00446-RP Document 25 Filed 08/21/15 Page 5 of 22
8/20/2019 Motion for Preliminary injunction.pdf
6/76
Case 1:15-cv-00446-RP Document 25 Filed 08/21/15 Page 6 of 22
8/20/2019 Motion for Preliminary injunction.pdf
7/76
Case 1:15-cv-00446-RP Document 25 Filed 08/21/15 Page 7 of 22
8/20/2019 Motion for Preliminary injunction.pdf
8/76
Case 1:15-cv-00446-RP Document 25 Filed 08/21/15 Page 8 of 22
8/20/2019 Motion for Preliminary injunction.pdf
9/76
Case 1:15-cv-00446-RP Document 25 Filed 08/21/15 Page 9 of 22
8/20/2019 Motion for Preliminary injunction.pdf
10/76
Case 1:15-cv-00446-RP Document 25 Filed 08/21/15 Page 10 of 22
C 1 15 00446 RP D t 25 Fil d 08/21/15 P 11 f 22
8/20/2019 Motion for Preliminary injunction.pdf
11/76
Case 1:15-cv-00446-RP Document 25 Filed 08/21/15 Page 11 of 22
Case 1:15 cv 00446 RP Document 25 Filed 08/21/15 Page 12 of 22
8/20/2019 Motion for Preliminary injunction.pdf
12/76
Case 1:15-cv-00446-RP Document 25 Filed 08/21/15 Page 12 of 22
Case 1:15-cv-00446-RP Document 25 Filed 08/21/15 Page 13 of 22
8/20/2019 Motion for Preliminary injunction.pdf
13/76
Case 1:15-cv-00446-RP Document 25 Filed 08/21/15 Page 13 of 22
Case 1:15-cv-00446-RP Document 25 Filed 08/21/15 Page 14 of 22
8/20/2019 Motion for Preliminary injunction.pdf
14/76
Case 1:15 cv 00446 RP Document 25 Filed 08/21/15 Page 14 of 22
Case 1:15-cv-00446-RP Document 25 Filed 08/21/15 Page 15 of 22
8/20/2019 Motion for Preliminary injunction.pdf
15/76
g
Case 1:15-cv-00446-RP Document 25 Filed 08/21/15 Page 16 of 22
8/20/2019 Motion for Preliminary injunction.pdf
16/76
Case 1:15-cv-00446-RP Document 25 Filed 08/21/15 Page 17 of 22
8/20/2019 Motion for Preliminary injunction.pdf
17/76
Case 1:15-cv-00446-RP Document 25 Filed 08/21/15 Page 18 of 22
8/20/2019 Motion for Preliminary injunction.pdf
18/76
Case 1:15-cv-00446-RP Document 25 Filed 08/21/15 Page 19 of 22
8/20/2019 Motion for Preliminary injunction.pdf
19/76
Case 1:15-cv-00446-RP Document 25 Filed 08/21/15 Page 20 of 22
8/20/2019 Motion for Preliminary injunction.pdf
20/76
Case 1:15-cv-00446-RP Document 25 Filed 08/21/15 Page 21 of 22
8/20/2019 Motion for Preliminary injunction.pdf
21/76
Case 1:15-cv-00446-RP Document 25 Filed 08/21/15 Page 22 of 22
8/20/2019 Motion for Preliminary injunction.pdf
22/76
Case 1:15-cv-00446-RP Document 25-1 Filed 08/21/15 Page 1
8/20/2019 Motion for Preliminary injunction.pdf
23/76
AFFIDAVIT OF ESTRELLA DE JESUS CEDILLO N
Case 1:15-cv-00446-RP Document 25-1 Filed 08/21/15 Page 2
8/20/2019 Motion for Preliminary injunction.pdf
24/76
r
Affidavit
of
Estrella de
Jesus
Cedillo Nieto
My
name is Estrella
De Jesus
Cedillo Nieto, and I swear under penalty of perjury
that the
fo
true and correct.
1. I am a citizen
of
Mexico, over the age
of
eighteen, and
of
sound mind.
2. In 2008, I was living in Texas and my son,
Hospital in March 2008.
was born in the Rio
3.
A
few
week
after
his birth, we returned
to
live in Reynosa
for
a number
of
reasons.
4. I had planned to remain in Reynosa, but as the cartel violence worsened, I realized
have
to
return
to Texas
.
5. The violence became
so
bad
that
a small child was killed
at
a school nearby
to
us
.
6. I recently returned to Texas but the crossing is extremely dangerous. I don't want m
B- , to travel this way.
7. I have my own birth certi ficate and a Mexican matricula card, but this is not enoug
to
get a birth certificate
for
B- .
My
mother, Paulina Nieto Ibarra was rejecte
though she had a Mexican matricula, passport and voter card.
8. I need
to
obtain a
U.S.
birth certificate passport
at
once
so
that my son
can
travel h
~ . - e
\ a c
e U
o l e
lo
Estrella De
Jesus
Cedillo Nieto
Signed and sworn to before me a notary public in and
for
the State
of
Texas on this
l1 fa
y
Case 1:15-cv-00446-RP Document 25-1 Filed 08/21/15 Page 3
8/20/2019 Motion for Preliminary injunction.pdf
25/76
f
Certificate of Translation
I certify
th t
I
m
fluent in the English and Spanish languages and
th t
I translated this doc
Affiant from English into Spanish and th t the Affiant indicated th t she understood its co
r a n s l
Date:
t
Case 1:15-cv-00446-RP Document 25-1 Filed 08/21/15 Page 4
8/20/2019 Motion for Preliminary injunction.pdf
26/76
AFFIDAVIT OF NANCY GARCIA
Case 1:15-cv-00446-RP Document 25-1 Filed 08/21/15 Page 5
8/20/2019 Motion for Preliminary injunction.pdf
27/76
~ o
;vJ t \ ~
N P N \ ~ . q a L \ . C . ( . c ; ~
'--\
~ u c o _ _ b a . . ) o r ~ dJ '?c p e ~ - . J r - . ; ~ c t . L l c . L _ t . ~
los
~ M ~
Ua.,.c;Lo.s.
q
~
[o
_
S ( ~
\
~ C . 1 ' . J o l q _ c i _ ~ _dJ. ~ I
C.Q
~ a:Xu.S u , .J ~ _ A 9 - ~ € . A . f \ ~ ~
fr9_u...L
....eM
( -z_()Dq)
~
'LOt'-)
,
1:
2 , ~
~
M & - a : . _ ; _ ~ , ~ _ s ; ; 5 , w ..
6
0 ~
0
i ' I A < . a ~
._.1_
A A ) A I ~
r
J
· ~ ~ ~
'?'.._)
~ ~ ~
« - = ~ ~
'-
- -- y c . t . - J . . _ ~ r • l 1 - ~ L ~ - = : : : : : :
~ ~ ~ ~ ~ = = = =
~ ~ _ _ ;
v _ ~
< . . z v . J . a . ) ~ ~ ~ ~
~ - = - - - - - = - , . . . . - f - 1
L ( 2 \ _ t : _ f _ t - e _ y ~ T - L Q _ 1 A .
) l i L u t l ~
~ ~ ~
I Pt:;, A c....
A
d.., }... A
8/20/2019 Motion for Preliminary injunction.pdf
28/76
.
_if_ ~
V l . o r e.Jl
~ _ ?
e 1 J . o
~ ~ lAS. 1._c.{ev.1
~
N d c
~
~
~ 0 5 p - ~ ~ A - t v - < J ~ M . . ' c P t . . - 9 ~ ~
~
:ell
~ ~ c ~ O J
: : >
f M I L
~
{
~ ; : > a n
~
~
q
:)
..t...R. _ _ . . o . . . _
r
~
~ U I
nV
-
~
s e R . . ' u ~ : > _ s
( £ 1 .
~
~ f ~ c . 7 e t . c ; dl..2 .L VAC. m t
/
3 0 / t o - , - . b ~ ~ ~ L s ( J . . £ L e
i
.
LU.
~ C t A - - U V -b: r M
1
d
A ~ _ _ s _ _ s ;
~
0... p e [ L . , v \
. t - . Z J ~
t . . N
0 . 5
.....;:.....;;:==::===:HlKBb = ~ ~ , b , t ? - a,
8/20/2019 Motion for Preliminary injunction.pdf
29/76
/ J ~ ~ MYRN ESMERAlDA DEA
:
i
Notary Public. Slate t Te
· · · I
Mvc
~ ; ;
o ; · . ~ ~
·
om m
fsslo
Kpfr8
'
' ',....
November 21
,
2016
5 u b ~ i b d Qtl\d s . o v r 0 bJorc_f"l'le
~ G:nrciQ Of \ ~ ( d ~ 1%
\ \ \ ~ fnmm;££>
~
«fLre.s Uoo cll
Case 1:15-cv-00446-RP Document 25-1 Filed 08/21/15 Page 8
8/20/2019 Motion for Preliminary injunction.pdf
30/76
AFFIDAVIT OF
NANCY GARCIA
: ENGLISH
TRANSLATION
My
name is Nancy Garcia and I swear under penalty
of
perjury
of the
laws
of the
United St
following
is
true:
1.
I am a citizen
of
Mexico and have lived here in
Texas
for 7 years.
2.
Three
of
my
children were born here
in
Texas
2009);
- 2010}
and
2012.)
3. I have a Mexican matricula card and my husband
has
a current Mexican driver s lic
expired Mexican electoral card.
4. At
the registrar s office in McAllen
they
would
not
give us the bir th certificates, eve
had the papers from
the
hospital.
5.
Because
of
this we could
not
baptize
our
children.
6.
- 1and- have mental health problems.
7. For
the moment
we have Medicaid, but they keep insisting
that
we have
to
presen
certificates.
8. We
worry
a lot
that
they will cut
off our
Medicaid, because
the
medicines are very
them
9. Also, last year we had serious problems with the school for - I. They said that i
present his birth certificate wi thin thirty days
they
would expel him.
In
the end the
finish
the
semester. We
don t
know
if hey
will let him enroll again.
He
needs his sp
education.
10.
Also we have applied
for
section 8 housing assistance based on the three citizen ch
Case 1:15-cv-00446-RP Document 25-1 Filed 08/21/15 Page 9
8/20/2019 Motion for Preliminary injunction.pdf
31/76
Certificate o Translation
I certify that I am fluent in the English and Spani
sh
languages and that I translated this doc
by Affiant
Nancy
Garcia
from
Spanish
into
English
Date:
Z
iS
Vf \
Case 1:15-cv-00446-RP Document 25-1 Filed 08/21/15 Page 10
8/20/2019 Motion for Preliminary injunction.pdf
32/76
AFFIDAVIT OF JUANA GOMEZ YBARRA
Case 1:15-cv-00446-RP Document 25-1 Filed 08/21/15 Page 11
8/20/2019 Motion for Preliminary injunction.pdf
33/76
Mi
nombre es Juana Gomez Ybarra, y soy mayor de edad, en plena uso de mis fa
mentales. Jura bajo pena de perjurio de
Ia
ley de Estados Unidos que lo siguiente
es de mi conocimiento personal.
1
Soy ciudadana mexicana y tengo aproximadamente 19 anos vivien o aqui en
de Mexico cuando tenia 14 anos.
2 Mis hijos
en 2002, y
3 Mi hija mas chica,
en Texas. Sus nombres son
nacido en 2007.
naci6 en Edinburg, Texas, el
4
Despues de que naci6
mi
hija, rate de obtener su acta de nacimiento. Me pres
oficina del registro Edinburg a tratar de sacarla.
5
Lleve los papeles de mi hija que me dieron en
el
hospital, y su nOmero social.
confirman que naci6 en Edinburg, asi como su fecha de nacimiento
6
Tengo matricula consular mexicana, y tambien
Ia
lleve a
Ia
oficina del registro,
identificaci6n.
La
matricula consular que tengo es
Ia
nueva, y cuenta con un m
Esta vigente, y se vence hasta el 2020.Tambien lleve mi pasaporte mexicano,
tambien esta vigente.
7 En Ia
oficina del registro de Edinburg me dijeron que
no
me pod ian dar el acta
nacimiento de
mi
h i j porque no aceptan Ia matricula consular como
identificaci6n. Tambien me dijeron que no
me
pod an dar el acta de nacimiento
que llevaba los papeles del hospital.
8
Tambien me dijeron en
el
registro de Edinburg que necesito llevar
mi
credencia
de Mexico. Pero como salt de Mexico cuando aun era me nor de edad, no Ia pu
9
A causa de no tener el acta de nacimiento, no he podido bautizar a mi hija.
10 Tambien a causa de no tener el acta de nacimiento de
mi
hija, no Ia he podido
el
programa de Head Start, ni tampoco me Ia aceptan en Ia guarderia. Me dice
necesito el acta de nacimiento.
11 Me preocupa mucho que me vayan a quitar estos beneficios a mi hija, asi com
matricularla en el Head Start y en Ia guarderia. Tambien me preocupa mucho n
bautizar.
Case 1:15-cv-00446-RP Document 25-1 Filed 08/21/15 Page 12
8/20/2019 Motion for Preliminary injunction.pdf
34/76
hizo sentir muy frustrada y humillada porque
mi
hija
es
ciudadana de este pals
todos los mismos derechos que otros ciudadanos. Despues e esto, me preoc
que migraci6n pueda detener a mi hija por falta e documentos que demuestr
ciudadana americana, principalmente
su
acta de nacimiento.
_s? Jf
8/20/2019 Motion for Preliminary injunction.pdf
35/76
[TRANSLATION OF AFFIDAVIT OF JUANA GOMEZ]
My name is Juana Gomez Ibarra, and I am over the age of eighteen and of sou
I swear under penalty of perjury under the laws of the United States that the foltrue and correct and is within my personal knowledge.
1) I am a Mexican citizen and I have been living in Texas for approximately 19 left Mexico when I was 14 years old.
2) My older children were born here in Texas. Their names are born in 2002, and born in 2007.
3) My younger daughter, , was born in Edinburg, Texas, on
4) After my daughter was born, I tried to obtain her birth certificate. I went to thof the registrar in Edinburg to try to obtain it.
5) I took the paperwork for my daughter that I was given at the hospital and he
security number. These documents confirm that she was born in Edinburg, her date of birth.
6) I have a Mexican consular identification (matricula), and I also took it to theregistrar’s office, as an identification. The consular ID I have is the new onehas a microchip. It is valid, and it doesn’t expire until 2020. I also took my Mpassport, which is also valid.
7) At the Edinburg registrar’s office, I was told that they could not give me my birth certificate because they did not accept the consular ID as a
identification. They also told me that they could not give me the birth certificthough I had the hospital paperwork.
8) They also told me at the Edinburg registrar’s office that I need to bring my Mvoter card. But since I left Mexico when I was still under 18, I cannot obtain
9) Because I do not have a birth certificate for my daughter, I have not been ab
baptize my daughter.
10) Also because I do not have a birth certificate for my daughter, I have not beto enroll her in the Head Start program, and she is also not been accepted adaycare. They tell me [at these places] that I need the birth certificate.
Case 1:15-cv-00446-RP Document 25-1 Filed 08/21/15 Page 14
8/20/2019 Motion for Preliminary injunction.pdf
36/76
for my daughter who is about to be born, and all the problems that that will cme.
13)
Approximately two months ago, when I went through the Falfurrias checkpoimmigration officials did not want to let my daughter go through because shehave a birth certificate. This made me feel very frustrated and humiliated bemy daughter is a citizen of this country, and she has the same rights as othecitizens. After this, I am very worried that immigration may detain my daughlack of documentation showing that he is an American citizen, especially hecertificate.
Signed on July 30, 2015.
[signature] 8-30-15
________________________________ _________________
Juana Gomez Ibarra Date
Signed and sworn to before me by _[Juana Gomez Ibarra] __ on July _[30]_, 20
[Notary’s Seal, Moira Kenny]
Case 1:15-cv-00446-RP Document 25-1 Filed 08/21/15 Page 15
8/20/2019 Motion for Preliminary injunction.pdf
37/76
AFFIDAVIT OF CYNTHIA IBARRA
Case 1:15-cv-00446-RP Document 25-1 Filed 08/21/15 Page 16
8/20/2019 Motion for Preliminary injunction.pdf
38/76
Affidavit of Cynthia Ibarra
My name is Cynthia Ibarra, I am over eighteen years of age and I swear under penalty
that the following is true and correct.
1
I am
the
mother ofK.E.R., my infant daughter.
2. K.E.R. was bom in Cameron County, Texas in November 2014.
3. I have a Mexican electoral card, and my husband has a Mexican matricula and driv
license. We took these with us to apply for a birth certificate for K.E.R. However, our
was denied. The identification was not good enough.
4. The hospital where K.E.R. was
bom
initially arranged for the first year of Medicaid
5. K.E.R. became extremely ll when she was two months old with a strep infection.
6
She has recovered, but she must continue to be evaluated by specialists every so of
sure the infection does not remain or recur.
7 She has an appointment with one specialist on August 31, 2015 and another with a
in
September.
8
The social worker at our clinic (Su clinica Familiar) has been working to keep the M
renewed for us, but she is telling us that we have to present the birth certificate soon o
have problems with our coverage. I have
been
told we may lose our coverage at the e
month.
9 We don t know ifthe specialists will agree to see K.E.R. if we don t have Medicaid
do not have the money to pay them ourselves.
10. We worry too about what could happen if we are ever stopped by Border Patrol o
police. How can we show that K.E.R. is our daughter? If we are removed from the Un
how would she ever get back here to claim her citizenship?
~ cll
l
a. J_[< O Co
Cynthia Ibarra
Case 1:15-cv-00446-RP Document 25-1 Filed 08/21/15 Page 17
8/20/2019 Motion for Preliminary injunction.pdf
39/76
Certificate ofTranslation
I Paula Garza certify that I
m
fluent in the English and Spanish languages and
translated this document to Affiant from English into Spanish and that the Affian
that she understood its contents.
Date:
......
zs-4/-'-;-'-
8/20/2019 Motion for Preliminary injunction.pdf
40/76
AFFIDAVIT OF PAULINA NIETO IBARRA
Case 1:15-cv-00446-RP Document 25-1 Filed 08/21/15 Page 19
8/20/2019 Motion for Preliminary injunction.pdf
41/76
Affidavit of Paulina Nieto Ibarra
My
name
is
Paulina Nieto Ibarra, and I swear under penalty of perjury
that
the following
i
correct.
1 I am a citizen of Mexico, over the age of eighteen, and of sound mind.
2 In 2008, I was living in Texas
with
my daughter Estrella De Jesus Cedillo Nieto.
3 She gave birth
to
her son, in the Rio Grande City Hospital in M
4 A few week after his birth, we all returned to live
in Reynosa
for a numberof reas
5 Two years ago the cartel violence worsened, and I returned
to Texas
.
6 The violence became
so
extreme that Estrella and I knew that it was important fo
return to Texas as well.
7
I went
to
the Registrar s office with -
·s
hospital documents and my own M
matricula, passport and voter card.
8 They denied me the birth certificate.
9 Estrella recently returned
to
Texas but the crossing is extremely dangerous. I
don
grandson - ,
to
travel this way.
10. Estrella does not have
the
documents that the Registrar requires now.
11. We need to obtain a
U S
. birth certificate passport
for
- at once so
that
he
here safely.
~ 4 - . t
Case 1:15-cv-00446-RP Document 25-1 Filed 08/21/15 Page 20
8/20/2019 Motion for Preliminary injunction.pdf
42/76
Certificate of Translation
I certify that I am
fluent
in
the
English and Spanish languages, and
that
I translated this do
ffiant from English
into
Spanish, and
that
the ffiant indicated that she understood its c
. / 1
Translatop £
.
- <
I )
,
I
Date:
1
-
I
,·
)
Case 1:15-cv-00446-RP Document 25-1 Filed 08/21/15 Page 21
8/20/2019 Motion for Preliminary injunction.pdf
43/76
AFFIDAVIT OF DINA NUNEZ
Case 1:15-cv-00446-RP Document 25-1 Filed 08/21/15 Page 22
8/20/2019 Motion for Preliminary injunction.pdf
44/76
DECL R TION OF DIN NUNEZ
My
name is Dina Nunez, I am over eighteen years
of
age, and I swear under penalty
that the
fo
lowing is true and correct.
l
I am a community advocate in Cameron County, Texas. I work for Movimie
por los Derechos Humanos (Valley Movement for Human Rights), a project
Libertad (The Liberty Project). I have worked as a co1mnunity advocate in S
for
1
0 years.
2 Projecto Libertad is a non-profit organization that serves iimnigrant families
Rio Grande Valley
3. Moviiniento del Valle
por
los Derechos Humanos
is
a grassroots human righ
the
Rio Grande Valley that teaches iimnigrant parents and their children abo
rights. In addition to working as a community advocate myself, I am also res
the
supervision of four other cmmnunity advocates.
4. As a cmmnunity advocate, I have witnessed the problems caused
by
the new
denying the birth certificates
ofTexas bom
children to undocumented paren
5. Parents who have been denied birth certificates are worried that they will be
access iinportant benefits and services for their children. Poor innnigrant fam
work
with depend upon WIC, T ANF, and other govermnent benefits to feed
These are people who are so poor that their children may go hungry if food b
cut.
6 These denials are contributing to the fear iii our cmmnunity. Some parents ar
to even request birth certificates after the official at one
of
the offices threate
ilmnigration on the undocumented parents
of one child who needed a birth c
This fear
on
the part
of
parents transfers to their children in ways that I see
o
basis.
7 This problem is affecting families with older children as well. For example,
spoke to a parent who needs a long form birth certificate for a child who has
certificate. Because she does not have the identification now being required,
obtaii1 it. Siinilarly, lost, stolen, and destroyed documents cannot be replaced
Case 1:15-cv-00446-RP Document 25-1 Filed 08/21/15 Page 23
8/20/2019 Motion for Preliminary injunction.pdf
45/76
Certificate o Translation
I Paula Garza certifY that I am fluent in the English and Spanish languages and
translated this document to Affiant from English into Spanish and that the Affia
that she understood its contents.
Date:
_
8/20/2019 Motion for Preliminary injunction.pdf
46/76
AFFIDAVIT OF MARIA ISABEL PERALES SER
Case 1:15-cv-00446-RP Document 25-1 Filed 08/21/15 Page 25
8/20/2019 Motion for Preliminary injunction.pdf
47/76
AFFIDAVIT OF MARIA ISABEL PERALES SERNA
Mi
nombre
es
Maria Isabel Perales Serna y yo
jure
que lo siguiente
es
Ia
verdad bajo pena
Ia ley de los Estados Unidos:
1 Soy ciudadana de Mexico y tengo 14 afios aquf en Texas.
2
El
Noviembre 2014 nacio
mi
hija K Z P S en el hospital en McAllen.
3
Tengo
mi
matricula y pasaporte de Mexico pero el registro en McAllen
me
neg6
I
nacimiento para mi hija K Z P S
4. A causa de esto no puedo inscribirla en el day care aquf y entonces es muy muy
encontrar empleo para mi.
5 Hace dos veces recientemente que Ia migra me pare. La primera vez yo querfa vi
escuela para
mi hijo
en san Antonio Texas. Lleve
K Z P S
con migo con
las
capias
papeles del hospi tal y su social.
6.
Me
interrogaban mucho
en Ia
segundaria a pesar de los papeles y me advirtieron
resolver Ia acta de nacimiento lo mas pronto posible.
7. La segunda vez yo andaba cerca a Progreso Texas. Un agente de Migracion me pa
me interrogo sobre los papeles de
Ia
bebe.
8.
Lo
explique mi problema y fortunadamente el me dejo salir con K Z P S
9. Por supuesto me preocupa que una de
esas
veces podrfan pensar que ella no es
podrfan separarme de
mi
bebe o detenernos mientras de investigar.
10. Peor
si
alguien secuestra
mi
hija que
voy
a hacer sin papeles oficial indicando que
de ella.
11.
Hay
un problema grande con mi medicaid porque en
Ia
tarjeta del medicaid esta m
I
Case 1:15-cv-00446-RP Document 25-1 Filed 08/21/15 Page 26
8/20/2019 Motion for Preliminary injunction.pdf
48/76
. . . /
, I c u • - . . · c. < • •
( < \
Maria Isabel
Perales Serna
:. .(
l I \
. 41• \.
~ n d
( [')I[J/ztay
of
August
2015 a Notary
Public in
and for the S
~ . ; ; f X £ ~ ~
MYRNA ESMERALDA DEANDA
~ / . l l E
t.Jotorv
Public. late or Texas
'>•)·
~ ; > §
My
Commtsston
E ~ p f r n s
~ ( o r t - · 0 N •
'''' ' ''' ovember
21
, 2 16
Case 1:15-cv-00446-RP Document 25-1 Filed 08/21/15 Page 27
8/20/2019 Motion for Preliminary injunction.pdf
49/76
Translation :AFFIDAVIT OF MARIA
ISABEL PERALES
SERNA
My
name is Maria Isabel Perales Serna and I swear
that
the
following
is
true and correct u
of perjury of the laws
of
the United States.
1. I am a citizen of Mexico and I have been in Texas for 4 years.
2 In November 2014 I gave birth to my daughter
K Z P S
in the hospital in McAllen.
3. I have my matricula and passport from Mexico
but the
registrar in McAllen refuse
the birth certificate for K Z P S
4. Because
of
this I cannot enrol l her in day care, and
so
it
is very hard
for
me
to
find
5 Recently, I have been stopped twice by immigration officers. The first time I wante
Antonio to visi t a school
for
my son. I brought
K Z P S
with me, and I had copies o
papers and her social security card.
6
At the
secondary, I was questioned a lot , despite
the
papers, and they warned me
to take care
of
the birth certificate
as
soon
as
possible.
7. The second time I was walking near Progreso, Texas. An immigration agent stoppe
was interrogated about
the
papers
for
the baby.
8 I explained my problem, and fortunate ly he let me leave with K Z P S
9
Of
course I worry that one of these times they may think she is not my daughter, a
separate me from my baby, or detain
us
while
they
investigate.
10. Worse, i f someone kidnaps my daughter, what will I do with no papers to show I a
mother?
11. There
is
a big problem
with mi
Medicaid because the card has my daughter s nam
wrong. Since
it
does
not
match
the
name on social security card, they have
not
pa
Since she
has
been sick
with
some lung problems a few times, I have terrible debt
hospitaL Also some specialists have refused
to
see her.
Without the birth
certifica
hard to correct
the
medicaid card.
Maria Isabel Perales Serna
Certificate of Translation:
Case 1:15-cv-00446-RP Document 25-1 Filed 08/21/15 Page 28
8/20/2019 Motion for Preliminary injunction.pdf
50/76
I Jennifer Harbury certify th t I m fluent in the English and Spanish languages and th t
translated this Spanish language
document
from
the
Affiant into English.
Date
Case 1:15-cv-00446-RP Document 25-1 Filed 08/21/15 Page 29
8/20/2019 Motion for Preliminary injunction.pdf
51/76
AFFIDAVIT OF QUENIA PEREZ
. .
AFFIDAVIT
OF
QUENIA PEREZ
Case 1:15-cv-00446-RP Document 25-1 Filed 08/21/15 Page 30
8/20/2019 Motion for Preliminary injunction.pdf
52/76
y name is Quenia
Perez
I am over eighteen years
of age
and I swear under penalty of p
following is true and correct and is within my personal knowledge:
1.
I live in Mission, Texas. I have lived in
Texas
for more than 1 years. y son J.A.R
Mission, Texas in March 2006. Back then, we had
no
problems getting a Texas bir
for him.
2.
About 4 years ago my ex-husband returned to Mexico, and he took all
of
J.A.R. s
him, including the birth certif icate and social security card.
3. y mother and I and even my sister have gone
to
the birth certificate office in M
replace J.A.R. s birth certificate. They turned me down, so my
mother
tried
with
h
electoral card. They told her to get a matricula, but then turned that down as we
turned down my sister s Mexican electoral card, driver s license and matr icula. In
new matricula with the microchip in it but they also turned this down.
4.
I have not been able
to
get a birth certificate
for
my new baby
Y.F.
either.
He
was
Edinburg, Texas in 2015.
5. We moved
to
Mission last year and since we did not know the people at the di ffe
began having a lot of problems because of the birth certificates.
6.
The Mission school let
J.A.R.
enroll last January and gave
us
thirty days to get a b
We could not get one, and finally convinced them to let him finish the semester.
exactly the same problem getting him enrolled for this fall. But because of the pu
this lawsuit they have agreed that he can enroll for now. I am not sure for how lo
him stay though.
7.
Also the Medicaid office here in Mission
has
told me that I have to get the birth c
J.A.R. in order
to
renew this time. I think I have till the end of September to do th
a
bit
older I will have
to
present his
as
well.
8.
I worry too, about what happens
if
we are stopped
by
police or other officials. We
that
these
two
boys are my sons.
Certificate of Translation
Case 1:15-cv-00446-RP Document 25-1 Filed 08/21/15 Page 31
8/20/2019 Motion for Preliminary injunction.pdf
53/76
I certify
th t
I m fluent in the English and Spanish languages and
th t
I have tran
document to Ms. Perez from English to Spanish and that she
h s
confirmed
th t
Case 1:15-cv-00446-RP Document 25-1 Filed 08/21/15 Page 32
8/20/2019 Motion for Preliminary injunction.pdf
54/76
AFFIDAVIT OF MARIA DEL ROSARIO TERAN UR
Case 1:15-cv-00446-RP Document 25-1 Filed 08/21/15 Page 33
8/20/2019 Motion for Preliminary injunction.pdf
55/76
j
~ - t \\0
\'\\
( \ \ .cq ; t\ . . . J 2
l ~
S('.r-
·
, t
(\(
(
9
-S
'-
J
:J
(
j
0
f'l.
_;r,j
, --\ C''d.(
c
cC9 '-.-;?j
/'• :-- '0
SC
\J' '.- \ \ . , ~ J
s
'
- ~ I . ] \ '
..
8/20/2019 Motion for Preliminary injunction.pdf
56/76
/
\;U,J
~ ·
SJ.?
(
C t·\.
(
C\ ( \ . (
fo
\
e\1
·
(\
~
J S
n;
¥ f-r J l
\..)
(\
\J \
s
c
G.)
~ c\
( 1.'-f\. c r
(?c.
\f'C\
\..;E-L
c (' t\
6.
c
{.
\; v
.C lC\. ~ \\
~ _.\-Q
.
C l -
o-
~ c u - ~
c.
t·
e
~
lJ
cf o ru
\
J
'
c.A-
0
.J:. ( t . \ l ) -
-0
~ 0 - o. C.. l. ~ o ~ U .) r1
\ p i
--0. be._ 0iJ C
V\-k
,
( ~ \ ) . , . e . . rt: , _ , ~ , . _ ~ < v ,
v
c'
l . < . _ ~ (\.
j
v O - r ~ ~
, c . _ _
J
e
0.. e U'l\.
U
c t rc\
e
t '\
c,
[\ 0 R
V
\. . (c .
k'S.,.,
\-a 0t C\.
( ]
8/20/2019 Motion for Preliminary injunction.pdf
57/76
c.)
\t
'-.Q \ c . (
v c \
cJ {
( \
l tlt e
~ , . v \ S .
c\\
c:c
8/20/2019 Motion for Preliminary injunction.pdf
58/76
y
name is Marla Del Rosario Teran Uriegas and I swear under penalty
of
perjury
of
the l
Un
ited States that the following
is
true:
1. I
am a citizen of Mexico and
I
have lived in Texas
for 7
years.
2.
y
two
sons were born here in Texas:
2013)
and
2014).
3. I have a matrlcula and passport, and the hospital documents and social security fo
- ·
y husband also has a passport and matricula.
4. They gave me a birth certificate for- but would not gi
ve
me one fo r-
5. La first time Iwent to get the certificate for-
they would not accept my ma
asked
for
a passport
but
when I went back
for
the passport they would not take it
current visa.
6.
I went a third time with- s grandmother. She had a Mexican electoral card
wou ld not
accept
it
because it was expired.
7.
I
want
to
enroll - in day care
but
when
1
went
to
one they told me they nee
certificate
for
Samuel.
8. I worry about if anything happens to - and we need urgent medical care, I c
am his mother. Also I cannot prove I am his mother if the police stop us
.
9. I also worry
that if
we are deported with- cannot show
that
Samuel was b
United States.
10. I
have to renew WIC Medicaid and food stamps soon fo r- and worry they
birth certificate
to
renew the benefits.
11.
The medical clinic where
I
go has
asked
for the birth certificates
of
all my children
produce the birth certificate
fo r
- they can t serve me now.
-30-15.
Maria Del Rosario
Teran Uriegas
date
Certificate of Translation:
Case 1:15-cv-00446-RP Document 25-1 Filed 08/21/15 Page 37
8/20/2019 Motion for Preliminary injunction.pdf
59/76
I
Jennifer Harbury certify th t I am fluent in
the
English and Spanish languages and th t I
translated this Spanish language document from the Affiant into English.
) C
Translator · ft ,
:
1
\
c Jen0 ' fer K. Harburv '
Date
Case 1:15-cv-00446-RP Document 25-1 Filed 08/21/15 Page 38
8/20/2019 Motion for Preliminary injunction.pdf
60/76
AFFIDAVIT OF LETICIA TORRES
AFFIDA
vrr
OF LETICIA
TORRES
Case 1:15-cv-00446-RP Document 25-1 Filed 08/21/15 Page 39
8/20/2019 Motion for Preliminary injunction.pdf
61/76
My name is Leticia Torres, I am
over
eighteen years
of
age and I
swear
that the fo
true and correct.
1 I am a citizen of Mexico and have been living in Texas for many years.
2. My infant daughter. S.G.G. was born in Hidalgo County Texas in 2015.
3. My husband and I have her hospital birth verification papers but we have been
birth certificate at the local city office. I have an expired Mexican electoral car
cannot be renewed here.
us
well
us
current Mexican matricula and passport. M
also has an expired Mexican electoral card and drivers license. lie had a Lase
but it is expired. None
of
this was enough to get a birth certificate.
4. My little girl has been having medical problems. She was in the hospital recen
lung infection.
5. I understand that I have to get a birth certificate to the Medicaid office very so
very worried about this problem.
6. We also worry about getting stopped by any police or Border patrol since we h
birth certificate to
show
she is our child.
This instrument was acknowledged before me
on
thi
CERTIFICATE OF
TR NSL TION
I Matias Villalobos. hereby certify that I am fluent in the English and Spanish
Case 1:15-cv-00446-RP Document 25-1 Filed 08/21/15 Page 40
8/20/2019 Motion for Preliminary injunction.pdf
62/76
AFFIDAVIT OF JUANITA VALDEZ-COX
IN THE UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF TEXAS
Case 1:15-cv-00446-RP Document 25-1 Filed 08/21/15 Page 41
8/20/2019 Motion for Preliminary injunction.pdf
63/76
AUSTIN DIVISION
Maria Isabel Perales Serna on her own
behalf and as next friend for her minor
daughter K.Z.P.S.
eta .,
§
§
§
§
§
§
Plaintiffs
v.
§ C A
1:
15-cv-00446
§
Texas Department o State Health
Services Vital Statistics Unit et al.,
§
§
§
Defendants
§
AFFIDAVIT OF JUANITA VALDEZ-COX
I Juanita Valdez-Cox, in accordance with the provisions of28 U.S.C. § 1746, declare a
1. I am the Executive Director of La Union del Pueblo Entero (LUPE). I have held
position for over ten years.
2.
LUPE is a non-profit membership organization comprised largely
of
immigrant
workers and their families who reside in Texas. Approximately one third of our
are undocumented immigrants.
3.
LUPE was founded in 1989
by
Cesar Chavez to help meet the advocacy and org
needs of
fannworkers and other low wage workers and their families. The organ
continues to
do
this work, while also responding to the immediate social and eco
needs of our members in the struggle to overcome the barriers and challenges fa
their daily lives. Many of these barriers and challenges relate to our members a
families immigration status.
4. A pati
ofLUPE s
mission has always been advocating for the fair government t
oflow income Texans, regardless of their immigration status.
5.
LUPE has operated an office in San Juan, Hidalgo County, Texas for over ten y
also has offices in the cities of Alton, Mercedes,
PhalT
and Edcouch, Texas. We
members and their families well-being. Members ask us to help them get ID re
for school enrollment, benefit applications, immigration applications, opening
b
Case 1:15-cv-00446-RP Document 25-1 Filed 08/21/15 Page 42
8/20/2019 Motion for Preliminary injunction.pdf
64/76
accounts, access to health care, voting, and the like.
8
Members
ofLUPE
have been denied birth ce1tificates for their Texas
born
child
These members are undocumented and, while they
may
have the Mexican
matri
consular they do not have and cannot obtain the identification now being requir
Members have requested our assistance in obtaining birth ce1tificates following
denials.
9. LUPE has dive1ted significant resources in
an
attempt to identify and address th
problems caused
by
denials ofbi1th ce1tificates to our members and others in
ou
community.
We
have
infonned our
leadership, staff, and others about the practic
denying birth certificates. We have expended time, energy, and
money
to identif
to assist members who have been affected by denials.
We
are working to advise
members of their right to their children s bitth certificates, in some cases referrin
to other organizations for fmther assistance, and othe1wise done what
we
can to
them. This impmtant work comes at the cost
of
other activities which are core to
miSSIOn.
10.
The
denial
of
birth ce1tificates to Texas
born
children is causing hardship and di
to our members and our community and should be stopped immediately. Our me
and their children are being hurt in ways that cannot simply
be
fixed
in
the futur
11.
LUPE s
members who have been denied bitth ce1tificates or who will
be
denied
ce1tificates cannot properly parent their children. Access to government benefits
programs requires birth ce1tificates. Parents cannot register their children for day
school without bi1th ce1tificates. Medicaid eligibility cannot
be
renewed.
For
ma
may
be
difficulties with public housing and disability benefits.
12. LUPE is deeply concerned at the prospect
of
children missing school as a result
bi1th ce1tificates. These children already face
many
hurdles to academic success
prospect
of
their parents being cited for truancy is also troubling.
13.
Our
members have also told us that some local religious institutions are refusing
baptize babies for whom birth ce1tificates have been denied. This religious cerem
very impmtant to many of our members. The inability to have their babies bapti
cause
of
great distress to some parents.
14. LUPE s members who are undocumented, and their families, live in constant fea
enforcement authorities. Apprehensions and deportations are at a historical high
increased militarization
of
the border area makes the fear
ofbeing
picked up at
a
I declare under penalty ofpe1jury that the foregoing is uu and con·ect.
Case 1:15-cv-00446-RP Document 25-1 Filed 08/21/15 Page 43
8/20/2019 Motion for Preliminary injunction.pdf
65/76
Executed on the
l
ay
of
August
2015
Juo
1-\-c\ \) 'Ida Cox. 0
Juanita Valdez Cox
Case 1:15-cv-00446-RP Document 25-1 Filed 08/21/15 Page 44
8/20/2019 Motion for Preliminary injunction.pdf
66/76
AFFIDAVIT OF VIOLETA VEGA
08 2
0/
2815
12: 41
956 3688823
TRLA
Affidavit ofVioleta
Vega
Case 1:15-cv-00446-RP Document 25-1 Filed 08/21/15 Page 45
8/20/2019 Motion for Preliminary injunction.pdf
67/76
1. My
name is
Violeta Vega . Iam over
eigh
t
een
years
o age
and I swear under
pen
alty
under the laws
of
the United States th t the following Is true
and
correct.
2.
I
ive in Hidalgo
county Texas and my son, M.G.R.
was
born herE
il l
2014
.
3. 1 have
lived
in the United Statesfor manyyears, but I
only
had a Mexican matricula
hospital papers after M.
G.R
. was born.
4.
The
city office here refused to
give me
a birth certificate with
these papers.
I
asked
son o u l d get the birth certificate, but he was
also
refused since
he is
still a minor.
5. Without the birth certificate we
are
having a lot of problems. We
lost
the
sec
tion 8
ass
i
stance
so the rent
is
now
almost triple what
it was
before.
This
is
making things
for
us
.
My
former husband
is
refusing to
he
lp with the
baby
and
it
is
ha
rd to makee
6.
We
still have Medicaid for M.G.
R.
for a few more months but then
I
am worried ab
happen ifwe have no Medicaid covera ge. How will I take of the baby then if
he
gets
LL)
ui.lL rt
x/JO/)
r
Violeta
Vega
rt _
Signed and Sworn to before me
on
day
of August
2015
a notary public in
and
for the
~
tJ
. J l l A b
.btl..__
Notary Publ ic
Certificate
of
Translation:
Case 1:15-cv-00446-RP Document 25-1 Filed 08/21/15 Page 46
8/20/2019 Motion for Preliminary injunction.pdf
68/76
I
Diana Salazar hereby
certify
that
I am
fluent in
both
the
English and Spanish languages
translated this document
to
ffiant in Spanish and she indicated that she understood its
Case 1:15-cv-00446-RP Document 25-1 Filed 08/21/15 Page 47
8/20/2019 Motion for Preliminary injunction.pdf
69/76
AFFIDAVIT OF DR. MARSHA GRIFFIN
DECLARATION OF DR MARSHA GRIFFIN
Case 1:15-cv-00446-RP Document 25-1 Filed 08/21/15 Page 48
8/20/2019 Motion for Preliminary injunction.pdf
70/76
My name is Dr. Marsha Griffin, I am over eighteen years of age, and I swear under
perjury that the following is true and correct.
l I am a pediatrician licensed to practice medicine in the state
of
Texas. have
employed
by
the Brownsville Community Health Center for the past nine ye
Pediatrics Department. I work full time and see approximately 80 patients a
patients range in age from new born to
19
years old. Up until this year, I wa
Director
of
the BCHC Department ofPediatrics and the Medical Director
of
Care Clinics, which provides health services to uninsured children in the Bro
Independent School District (BISD). I am also adjunct clinical faculty with
University
of
Texas Health Science Center at San Antonio's Regional Acade
Center, now University of
Texas Rio Grande Valley School ofMedicine.
2
The Brownsville Community Health Center BCHC} is a Federally Qualified
Center (FQHC) which is a Federal designation assigned to non-profit or pub
care organizations that serve predominantly uninsured
or
underserved popula
located in
or
serving a designated Medically Underserved Area/Population (
Our goal is to provide comprehensive primary care health services with exce
dignity to our community. Last year we served over 20,000 patients at BCH
3. The Pediatrics Department has over 6,000 patients. Essentially all
ofmy
pati
from families living well below the federal poverty line. They are almost ex
Hispanic. I treat many patients who were born in Texas, whose parents are
undocumented. This includes children
of
migrant fannworkers.
4. More than 75
of
our pediatric patients have no insurance at all. Virtually a
who do have insurance have some form
of
public insurance, such
as
Medica
Cameron County Indigent insurance coverage. We are always very concerne
poor
child is uninsured. This can have huge, sometimes permanent, conseque
or her health and well-being. Although we will always provide primary care
children in the Pediatric Department at BCHC and at BISD Campus Care Cl
need specialty care, it is always a struggle. Specialty care includes Cardiolo
Neurology, Orthopedics, Endocrinology, Puhnonology and others. There are
few sub-specialists who will see a child without insurance or cash to pay for
this area, I can count two.
5 BCHC is known in this c01mnunity as an advocate for our patients and the p
6 Parents of some of our youngest patients have reported to us about recent ch
procedures for obtaining birth certificates which have prevented them from a
Case 1:15-cv-00446-RP Document 25-1 Filed 08/21/15 Page 49
8/20/2019 Motion for Preliminary injunction.pdf
71/76
these critical documents. These are often mothers who have several other Te
children and have their birth certificate. They do not understand what is diff
their newest infant and are expressing great fear for their newest child
7 We also have lay health workers in our clinic (promotoras) who provide edu
outreach to the residents of colonias and poor neighborhoods in Brownsville
promotoras have also reported to me that mothers are afraid to go to City Hal
birth certificate for their newborn, because they have heard that others have b
their birth certificates, because of the mother s documentation status. My co
other pediatricians in this community are deeply troubled y the denial of ir
certificates to families already facing crushing poverty and other hardships.
seventeen year old mother, who came with her own mother to the clinic yest
the many fears and concerns that she has for her newborn son, one of them b
inability to obtain a birth certificate. She reported that she stops nursing whe
crying, because of the old wives tale that you can pass sorrow and fear on to
infant. She wondered
if
it
is
true that you can pass this pain to your infant. I e
her that what he needs most is her loving anns and her breast milk, and that
continues to stop nursing him frequently; she will no longer produce enough
sustain him. But I also told her that, indeed, children of all ages can sense a m
emotional pain, and that we would try to provide resources to help her. A ne
sometimes physically and emotionally tender. This
is
not the time to be infli
stress, which could trigger postpartUlll depression. This is a pressing public h
8. t
is
my opinion that that the denial
of
birth certificates to Texas-born childre
denial
or
threat of denial of benefits and services; and the resulting restriction
can cause substantial stress in these families. This would
e
the worst in fam
dealing with the challenges of illness. The health effects of such stress are no
underestimated. In my experience, undocumented parents already live lives f
burdened y poverty and discrimination, and the fear of possible separation f
children. I have personally seen this stress manifest in and exacerbate physi
mental health problems of their children. We, in the pediatric profession, hav
research on the effects of chronic stress on the long-term health trajectory of
Chronic stress in a family effects not only their health, but their child s abilit
life-saving meds. His school nurse called me, when she noticed that he was
walk to class, because of shortness ofbreath and fatigue.
t
was at that time,
Case 1:15-cv-00446-RP Document 25-1 Filed 08/21/15 Page 50
8/20/2019 Motion for Preliminary injunction.pdf
72/76
referred to our Campus Care Clinic. Our staff worked diligently to find fund
specialty care for him and medications. The damage to his body during that
be reversed, but it could have been prevented. I have had parents cut a cast
child s arm with a saw, because they could not afford to take him back to the
for follow up care. We at the clinic provided him with funds for the initial e
treatment
by
an Orthopedist. He was referred
by
his school nurse, when she
his cast was gone and his arm was deformed.
Hann
to any child is, of course
entire cmmnunity and our own future. Can
we
morally be an accessory to tll
by
denying our own Texas born children their natural right to protection und
10
Most parents
of
uninsured children are extremely averse to taking their child
emergency room, because
of
the huge expense subsequently entailed. Some
hesitancy in going to the emergency room can be deadly for a child, such as
who has a severe acute asthma attack. Or a child with a severe allergic react
stings and has an anaphylactic attack. Waiting in these instances, can
be
trag
II
There are occasions when our patients need to travel to Houston or other are
the checkpoint for needed medical care. Typically these patients have grave
conditions, which cam1ot be treated in our area. Not a single child should be
from making this journey because he
or
she does not have a birth certificate
connnon carrier.
12. Any interference with a family s access to affordable housing and public edu
also have a deleterious effect
on
the health
of
a family, especially one in whi
or
members already have health problems.
13.
In
addition, our clinic is innnediately harmed
by
any change in a patient s ac
Medicaid. Serving one of the poorest communities in the country, BCHC rel
upon
Medicaid reimbursement for medical care provided to our Medicaid eli
patients, despite the fact that the number
of
Medicaid patients is a small perc
pediatric patient load.
Case 1:15-cv-00446-RP Document 25-1 Filed 08/21/15 Page 51
8/20/2019 Motion for Preliminary injunction.pdf
73/76
AFFIDAVIT OF FLAVIA GARZA
AFFIDAVIT
OF
FLAVIA GA-Ret l q
>.. fZ
LA
Case 1:15-cv-00446-RP Document 25-1 Filed 08/21/15 Page 52
8/20/2019 Motion for Preliminary injunction.pdf
74/76
My
name
is Flavia Garza. I am
over eighteen
years
of
age
and
I
swear
under penalty
of
perj
following is
true
and correct:
1.
I have lived in Texas for many years. I arrived here as a child.
2. My son D.G.
was
born in McAllen twelve years ago.
3. I did not have much identification at the time and could not
obtain
a birth certifica
4. Igot my Mexican matricu/a in
approximately
2011
but
was again
denied
the birth c
5.
My
sonS. G.
was born in Texas in 2013.
6.
I went
to the
birth certificate office in McAllen with my matricu a, school records, a
birth certificate, with
the
social
security
card for 5.G.,
but was denied
the birth cert
They told me that when he was
18
years old he could get his own birth certificate.
7. When D.G. was little,
things
were easier
and
I was able
to
get him into school.
8. Everything is a lot harder now. I cannot sign 5.G. up for Head Start. Day
care
let hi
till provisional. I still have
to
bring in
the
birth ce rtificate. D.G. s school
is
also askin
9.
A few years
ago
when we
moved
to
Alamo, D.G. missed two weeks of school beca
have a birth certificate for him. I finally got him in.
10. D.G.
gets S51
because
of
a disability, but the case worker keeps telling
me that
I am
have
to
bring in the birth certificate
or
risk losing these benefits for him.
11.
S.G. is bi-polar and
will
also need 551, but I understand
the
birth certificate
is
going
problem
in
getting
him the SSI he needs and qualifies for.
12. The people
at
Medicaid also keep asking me for the birth certificates
too
but they
patient
and
seem
to
understand
the
problem.
q ~ ~ ~ ~ d q
Flavia Garza
Date
Sworn to
and
signed before
me
on this __f _
day
of August 2015
before me
a notary in
Case 1:15-cv-00446-RP Document 25-2 Filed 08/21/15 Page 1 of 2
8/20/2019 Motion for Preliminary injunction.pdf
75/76
Case 1:15-cv-00446-RP Document 25-2 Filed 08/21/15 Page 2 of 2
8/20/2019 Motion for Preliminary injunction.pdf
76/76