3:15-cv-00288 #2 - complaint
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IN THE UNITED STATES DISTRICT COURTFOR THE WESTERN DISTRICT OF WISCONSIN
CHELSEA TORRES and JESSAMYTORRES, individually and as next friends and
parents of A.T., a minor child,
Plaintiffs,
versus
KITTY RHOADES, in her officialcapacity as Secretary of the State of
Wisconsin Department of Health Services,
Defendant.
CASE NO. 15-cv-288
COMPLAINT FOR
DECLARATORY AND
INJUNCTIVE RELIEF
Plaintiffs CHELSEA TORRES (“Chelsea”) and JESSAMY TORRES
(“Jessamy”), individually and as next friends and parents of A.T., a minor child
(collectively, “Plaintiffs” or the “Torres family”), by and through their attorneys, file this
Complaint against Defendant KITTY RHOADES, in her official capacity as Secretary of
the Wisconsin Department of Health Services (“DHS”) and allege as follows:
INTRODUCTION
1. Chelsea and Jessamy are a legally married lesbian couple residing in
Madison, Wisconsin, in Dane County. Their infant son, A.T., was conceived through
anonymous donor insemination and born in Meriter Hospital in Madison, Wisconsin after
Chelsea’s marriage to Jessamy. Chelsea and Jessamy filled out the birth certificate
worksheet at the hospital, indicating on the form that they are married and that both are
A.T.’s parents. However, DHS has refused to provide A.T. with an accurate birth
certificate that identifies both Chelsea and Jessamy as his parents. Indeed, upon
information and belief, DHS has refused to provide any child born to same-sex spouses
an accurate birth certificate listing both spouses as parents absent a court order of
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adoption or parentage—even though DHS routinely provides two-parent birth certificates
to all children born to different-sex spouses without requiring a court order, and without
any regard to how these children are conceived, or whether these children share a genetic
connection to both spouses.
2. The refusal by DHS to provide an accurate two-parent birth certificate to
A.T. and other children born to same-sex spouses deprives these children of the dignity,
legitimacy, security, support, and protections available upon birth to children of married
different-sex parents, and denies Chelsea, Jessamy, and other same-sex spouses who are
parents the privacy, dignity, security, support, and protections available to married
different-sex parents.
3. The refusal by DHS to provide a two-parent birth certificate to A.T. and
other children of same-sex spouses violates the equal protection guarantee of the United
States Constitution by discriminating against Chelsea, Jessamy, and other married same-
sex parents on the basis of their sexual orientation and sex, and against A.T. and other
children on the basis of their parents’ sex, sexual orientation, and status, all without
adequate justification.
4. The refusal also violates the due process guarantee of the United States
Constitution by unconstitutionally infringing on the liberty interests of each member of
the Torres family and other same-sex spouses and their children to family privacy,
integrity, and association, which includes the fundamental right to security in their legal
parent-child bonds. The refusal also violates the fundamental right to parental autonomy
shared by Chelsea, Jessamy, and other same-sex spouses who have children, including
their fundamental right to make decisions concerning whether and how to increase their
family, and decisions concerning the care, custody, and control of their children that are
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presumptively in their children’s best interests. The refusal by DHS to treat both same-
sex spouses as parents of children born to them after their marriage also violates these
spouses’ liberty interests shielded by the fundamental right to marry.
5. The Torres family now brings this action asking this Court to: (1) declare
that Defendant’s refusal to issue accurate two-parent birth certificates for children born to
same-sex spouses, including A.T., is unconstitutional; (2) enjoin Defendant from
continuing her policy, or custom and practice, of denying children born to same-sex
spouses birth certificates that list both spouses as the child’s parents; and (3) further order
Defendant immediately to issue a correct birth certificate to A.T. that lists both Chelsea
and Jessamy as his parents in reliance on Chelsea’s and Jessamy’s marriage.
JURISDICTION AND VENUE
6. Plaintiffs bring this action under 42 U.S.C. §§ 1983 and 1988 to redress
the deprivation of rights secured by the laws and the Constitution of the United States.
7. This Court has original jurisdiction over the subject matter of this action
pursuant to 28 U.S.C. § 1331 because the matters in controversy arise under the laws and
Constitution of the United States.
8. This Court has personal jurisdiction over Defendant because she is
domiciled in the State and/or has otherwise made and established contacts with the State
sufficient to permit the exercise of personal jurisdiction over her.
9. Venue is proper in the Western District of Wisconsin under 28 U.S.C.
§ 1391(b)(1) and (2) because Defendant resides in this district, and a substantial part of
the events that gave rise to Plaintiffs’ claims occurred in Madison, Wisconsin, in Dane
County.
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PARTIES
10. Plaintiffs Chelsea Andiar Torres, age 36, and Jessamy Flaherty Torres, age
35, both women, are spouses who reside in Madison, Dane County, Wisconsin. They
each appear individually and as parent and next friend of their son, Plaintiff A.T., a minor
child. Chelsea and Jessamy are harmed by the denial of a birth certificate to A.T. that
names both Chelsea and Jessamy as his parents.
11. Plaintiff A.T. sues through his parents and next friends, Plaintiffs Chelsea
and Jessamy Torres, who bring this action on behalf of A.T. because he is harmed by the
denial of a birth certificate naming both Chelsea and Jessamy as his parents.
12. Defendant Kitty Rhoades is sued in her official capacity as Secretary of
DHS. Defendant is a person within the meaning of 42 U.S.C. § 1983 and was acting
under color of state law at all times relevant to this Complaint. The Wisconsin Vital
Records Office, which is responsible for the filing, preserving, protecting, changing, and
issuing copies of birth certificates, is a unit of DHS and is controlled by Defendant.
STATEMENT OF FACTS
13. Chelsea and Jessamy Torres are a lesbian couple who have been friends
since 2001. They have been in a loving, committed relationship since 2010. They were
married on September 7, 2012, in New York, New York, in front of friends and family.
Jessamy is a deputy with the Dane County Sheriff’s Department, and Chelsea works for a
local cleaning company.
14. From the beginning of their relationship, Chelsea and Jessamy knew that
they wanted to be parents and have children together. In or around September 2013,
Chelsea and Jessamy began working with a fertility clinic in order for Chelsea to
conceive via assisted reproductive technology, which was ultimately successful. They
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both considered themselves and each other to be partners in the process, including with
respect to selection of the anonymous donor.
15. On or about March 13, 2015, Chelsea was admitted to Meriter Hospital in
Madison, Wisconsin to give birth. During the birth, there were complications, and
Jessamy watched as her wife hemorrhaged and her son turned blue due to lack of oxygen.
Jessamy was terrified that her wife and child would not survive. Fortunately, both
Chelsea and A.T. survived, though both were required to spend several days in the
hospital following the birth, and A.T. was placed in intensive care. Jessamy stayed at the
hospital throughout this period, moving between floors to help care for both her wife and
son.
16. On or about March 14, 2015, while at the hospital, Chelsea and Jessamy
filled out a DHS form for the purpose of obtaining a birth certificate for A.T. On the
form, Chelsea and Jessamy indicated that they are married and that both are parents to
A.T., and they supplied DHS with the requested information for both parents.
17. On March 30, 2015, Chelsea and Jessamy received a “Notification of
Birth Certificate Registration” from DHS that, without explanation, incorrectly omitted
all of Jessamy’s information and listed only Chelsea as A.T.’s parent. A copy of the
Notification is included as an exhibit to the attached Exhibit A.
18. On April 24, 2015, counsel for the Torres family sent a letter to Defendant
requesting confirmation within seven days of its receipt that DHS intends to issue a
correct birth certificate that accurately lists both Chelsea and Jessamy as A.T.’s parents.
A copy of the letter is attached hereto as Exhibit A.
19. On May 1, 2015, the Chief Legal Counsel for DHS wrote to counsel for
the Torres family stating that the “Vital Records Office . . . is evaluating the request and
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will respond when that evaluation is complete.” At the time of filing this Complaint, the
Torres family has not received a correct copy of A.T.’s birth certificate that lists both of
his parents.
20. Under Wisconsin law, a birth mother’s spouse is the presumed parent of a
child born during the marriage (hereafter termed the “spousal presumption of parentage”
or “spousal presumption”). Specifically, Wis. Stat. § 891.41(1)(a) states that a “man is
presumed to be the natural father of a child” if “he and the child’s natural mother are or
have been married to each other and the child is conceived or born after marriage and
before the granting of a decree of legal separation, annulment or divorce between the
parties.” The spousal presumption also applies to married couples who use assisted
reproductive technology. See Wis. Stat. § 891.40 (“If, under the supervision of a licensed
physician and with the consent of her husband, a wife is inseminated artificially with
semen donated by a man not her husband, the husband of the mother at the time of the
conception of the child shall be the natural father of a child conceived.”).
21. In accordance with the spousal presumption, Wis. Stat. § 69.14(1)(e)1
provides: “If the mother of a registrant under the this section was married at any time
from the conception to the birth of the registrant, the name of the husband of the mother
shall be entered on the birth certificate as the legal father of the registrant. The name of
the father entered under this subdivision may not be changed except by a proceeding
under ch. 767.”
22. Upon information and belief, and as required by Wis. Stat. § 69.14(1)(3)1,
DHS issues birth certificates to children born to married different-sex couples listing both
spouses as parents regardless of whether these children have a genetic connection to both
spouses. Thus, DHS issues two-parent birth certificates to children born to different-sex
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spouses even when the husband is not the child’s genetic parent because the couple
achieved pregnancy through use of donor insemination, or because the mother had
intercourse with a man other than her spouse.
23. Defendant’s refusal to provide the Torres family with an accurate birth
certificate for A.T. poses significant and ongoing harm to A.T. and his parents, Chelsea
and Jessamy, and renders the family vulnerable to future harm.
24. Without an accurate birth certificate, it is difficult if not impossible for the
Torres family to comply with legal identification requirements for A.T. Birth certificates
are vital to A.T.’s ability to obtain a Social Security card and a passport.1
25. When A.T. or his parents must produce a birth certificate to establish
Jessamy’s parental rights and Jessamy’s ability to take actions on A.T.’s behalf, such as
to enroll him in daycare or school or extracurricular activities (Wis. Stat. § 118.01 et seq.)
or authorize medical treatment (Wis. Stat. § 146.81(5)), they are unable to do so.
26. State agencies and employers often request birth certificates to enroll a
child for needed benefits. See, e.g., Wis. Stat. 632.885 (regarding health insurance for a
child through a parent’s employer-sponsored group plan). Recognition of a parent on a
birth certificate also provides for Social Security survivor benefits to the child in the
event of the parent’s death and provides inheritance to the child if a parent dies intestate.
See Social Security Administration, Benefits for Children, available at
http://www.ssa.gov/pubs/EN-05-10085.pdf.; Wis. Stat. § 852.05.
27. Birth certificates often are most essential when a family goes through
unforeseen family tragedies or crises. Indeed, during A.T.’s birth, Jessamy feared that
1See Social Security Administration, Learn What Documents You Need To Get A Social
Security Card , available at http://www.ssa.gov/ssnumber/ss5doc.htm; United States
Department of State, Passports for Minors Under 16 , available at
http://travel.state.gov/content/passports/english/passports/under-16.html.
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Chelsea might not survive, and that she would lose both her wife and her ability to
establish her parental rights with respect to her newborn son. Fortunately, the staff at
Meriter Hospital treated Jessamy as A.T.’s parent, but absent an accurate birth certificate,
she may not be as fortunate in future medical emergencies.
28. If a family falls on hard economic times, birth certificates may be required
to apply for benefits on behalf of the child. Moreover, if A.T. were to go missing or be
kidnapped, law enforcement agencies often require parents to produce a birth certificate
to report a missing child or secure his return.
29. If a couple’s marriage breaks down, birth certificates commonly are
necessary for a state agency to obtain delinquent child support.
30. Even if Chelsea and Jessamy can explain the discrepancies in the birth
certificate and establish Jessamy’s equal claim to exercise control over A.T.’s care and
custody, having to do so is likely to invade the privacy of the Torres family by revealing
which parent has a genetic connection to A.T., which is a fact that Plaintiffs may not wish
to share in all circumstances.
31. Defendant’s policy and practice of denying birth certificates to children
born to same-sex parents serves as an unjustified barrier to the ability of the Torres
family to exercise their rights stemming from their legal parent-child relationships by
making it more difficult for them to obtain the benefits and protections that families
whose children have married different-sex parents can more easily obtain.
32. Defendant’s discriminatory denial of an accurate birth certificate to A.T.
denies him the dignity, legitimacy, security, support, and protections available upon birth
to children of married different-sex parents, and denies Chelsea and Jessamy the privacy,
dignity, security, support, and protections available to married different-sex parents.
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There is no justification, let alone a constitutionally adequate one, for imposing these
harms on the Torres family.
CLAIMS FOR RELIEF
COUNT IDeprivation of Equal Protection
U.S. CONST. Amend. XIV
(42 U.S.C. § 1983)
33. Plaintiffs incorporate by reference and re-allege all of the preceding
paragraphs of this Complaint as though fully set forth herein.
34. Plaintiffs state this cause of action against Defendant in her official
capacity for purposes of seeking declaratory and injunctive relief.
35. The Fourteenth Amendment to the United States Constitution, enforceable
pursuant to 42 U.S.C. § 1983, provides that no state shall “deny to any person within its
jurisdiction the equal protection of the laws.” U.S. Const. amend. XIV, § 1.
36. Defendant’s refusal to apply the spousal presumption of parentage to
same-sex spouses and accordingly to issue two-parent birth certificates to children born
to same-sex spouses discriminates against Chelsea and Jessamy on the basis of both their
sex and sexual orientation without even a rational justification let alone the required
compelling showing that the overall societal benefits of the discrimination clearly
outweigh the harms inflicted upon its victims.
37. Defendant’s refusal to provide an accurate two-parent birth certificate to
A.T. harms him by incorrectly labeling him the child of an unwed parent, depriving him
of access to immediate, clear proof of his relationship to both of his parents and the
security that comes with having two parents on his birth certificate. The denial of an
accurate birth certificate to children born to same-sex spouses discriminates against such
children on the basis of their parents’ status as a same-sex couple, and their parents’ sex
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and sexual orientation. There is not even a rational, let alone important, justification for
such discrimination.
COUNT II
Deprivation of Due Process
U.S. CONST. Amend. XIV(42 U.S.C. § 1983)
38. Plaintiffs incorporate by reference and re-allege all of the preceding
paragraphs of this Complaint as though fully set forth herein.
39. Plaintiffs state this cause of action against Defendant in her official
capacity for purposes of seeking declaratory and injunctive relief.
40. The Fourteenth Amendment to the United States Constitution, enforceable
pursuant to 42 U.S.C. § 1983, provides that no state shall “deprive any person of life,
liberty, or property, without due process of law.” U.S. Const. amend. XIV, § 1.
41. The Torres family has a liberty interest in their family privacy, integrity,
and association, which includes the fundamental right to security in their legal parent-
child bonds. Moreover, Chelsea and Jessamy have a protected liberty interest in their
parental autonomy, including the fundamental right to make decisions concerning
whether and how to increase their family, and concerning the care, custody, and control
of their child, A.T., that are presumptively in his best interests.
42. By refusing to issue A.T. a birth certificate that correctly identifies both
Chelsea and Jessamy as his parents, Defendant is unconstitutionally infringing on those
liberty interests and depriving the Torres family of the single most important identity
document necessary to demonstrate their familial relationship to A.T.
43. The interest of parents in the care, custody, and control of their children is
deeply intertwined with the fundamental right to marry. Wisconsin’s spousal presumption
of parentage is a benefit of marriage that protects a marital child and his or her bonds to
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and right of support from both parents. By declining to apply the spousal presumption of
parentage to children born to same-sex spouses, and depriving these families of accurate
two-parent birth certificates, Defendant not only has infringed impermissibly on same-
sex spouses’ fundamental parental interests, but also upon their fundamental liberty
interests in their existing marriage.
44. There is no constitutionally adequate basis for Wisconsin’s decision to
infringe on the fundamental rights of same-sex parents, let alone an interest that can
survive the elevated scrutiny required to justify infringement of these fundamental rights.
PRAYER FOR RELIEF
WHEREFORE, Plaintiffs respectfully request that this Court enter judgment:
A. Declaring that Defendant’s refusal to issue a birth certificate to A.T. on the
same terms as to children of married different-sex parents violates all Plaintiffs’
guarantees of equal protection under the Constitution of the United States;
B. Declaring that Wis. Stat. §§ 69.14(1)(e)1, 891.40(1), and 891.41(1)(a) are
invalid and unconstitutional as written and are henceforth to be construed in a gender-
neutral manner to require application of the spousal presumption of parentage to same-
sex couples and issuance of two-parent birth certificates to same-sex spouses
accordingly;
C. Declaring that Defendant’s refusal to issue a birth certificate to A.T. that
names both Chelsea and Jessamy as his parents violates all Plaintiffs’ rights under the
Due Process Clause of the Constitution of the United States;
D. Enjoining Defendant from continuing to enforce her policy, or custom and
practice, of denying to children born to same-sex spouses birth certificates that list both
spouses as the child’s parents;
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E. Ordering Defendant to immediately issue a correct birth certificate to
A.T. that lists both Chelsea and Jessamy as his parents in reliance on Chelsea’s and
Jessamy’s marriage;
F. Awarding Plaintiffs costs, expenses, and reasonable attorneys’ fees
pursuant to, inter alia, 42 U.S.C. § 1988 and other applicable laws; and,
G. Granting such other and further relief as the Court deems just and proper.
DATED: May 13, 2015 Respectfully submitted,
/s/ Clearesia A. Lovell-Lepak Tamara B. Packard Clearesia A. Lovell-Lepak
Cullen Weston Pines & Bach LLP Lovell-Lepak Law Office
122 West Washington Avenue, Suite 900 Post Office Box #44623Madison, Wisconsin 53703 Madison, Wisconsin 53744(608) 251-0101 (800) 216-3921
[email protected] [email protected]
Kyle A. Palazzolo*
Camilla B. Taylor*
Christopher R. Clark*Lambda Legal Defense and Education Fund,
Inc.
105 W. Adams, Ste. 2600
Chicago, Illinois 60603(312) 663-4413
* Motions for admission [email protected]
pro hac vice pending [email protected]@lambdalegal.org
ATTORNEYS FOR PLAINTIFFS
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S 44 (Rev. ) CIVIL COVER SHEETThe JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as pr
y local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the purpose of inhe civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)
. (a) PLAINTIFFS DEFENDANTS
(b) County of Residence of First Listed Plaintiff County of Residence of First Listed Defendant(EXCEPT IN U.S. PLAINTIFF CASES) (IN U.S. PLAINTIFF CASES ONLY)
NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATIONTHE TRACT OF LAND INVOLVED.
(c) Attorneys (Firm Name, Address, and Telephone Number) Attorneys (If Known)
I. BASIS OF JURISDICTION (Place an “X” in One Box Only) III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an “X” in One Box for (For Diversity Cases Only) and One Box for Defendant
1 U.S. Government 3 Federal Question PTF DEF PTF D
Plaintiff (U.S. Government Not a Party) Citizen of This State 1 1 Incorporated or Principal Place 4
of Business In This State
2 U.S. Government 4 Diversity Citizen of Another State 2 2 Incorporated and Principal Place 5
Defendant (Indicate Citizenship of Parties in Item III) of Business In Another State
Citizen or Subject of a 3 3 Foreign Nation 6
Foreign Country
V. NATURE OF SUIT (Place an “X” in One Box Only)CONTRACT TORTS FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTE
110 Insurance PERSONAL INJURY PERSONAL INJURY 625 Drug Related Seizure 422 Appeal 28 USC 158 375 False Claims Act
120 Marine 310 Airplane 365 Personal Injury - of Property 21 USC 881 423 Withdrawal 400 State Reapportionm
130 Miller Act 315 Airplane Product Product Liability 690 Other 28 USC 157 410 Antitrust
140 Negotiable Instrument Liability 367 Health Care/ 430 Banks and Banking
150 Recovery of Overpayment 320 Assault, Libel & Pharmaceutical PROPERTY RIGHTS 450 Commerce
& Enforcement of Judgment Slander Personal Injury 820 Copyrights 460 Deportation
151 Medicare Act 330 Federal Employers’ Product Liability 830 Patent 470 Racketeer Influence
152 Recovery of Defaulted Liability 368 Asbestos Personal 840 Trademark Corrupt Organizatio
Student Loans 340 Marine Injury Product 480 Consumer Credit
(Excl. Veterans) 345 Marine Product Liability LABOR SOCIAL SECURITY 490 Cable/Sat TV
153 Recovery of Overpayment Liabili ty PERSONAL PROPERTY 710 Fair Labor Standards 861 HIA (1395ff) 850 Securities/Commod
of Veteran’s Benefits 350 Motor Vehicle 370 Other Fraud Act 862 Black Lung (923) Exchange
160 Stockholders’ Suits 355 Motor Vehicle 371 Truth in Lending 720 Labor/Mgmt. Relations 863 DIWC/DIWW (405(g)) 890 Other Statutory Acti
190 Other Contract Product Liability 380 Other Personal 740 Railway Labor Act 864 SSID Title XVI 891 Agricultural Acts
195 Contract Product Liability 360 Other Personal Property Damage 751 Family and Medical 865 RSI (405(g)) 893 Environmental Matt
196 Franchise Injury 385 Property Damage Leave Act 895 Freedom of Informa
362 Personal Injury - Product Liability 790 Other Labor Litigation Act Med. Malpractice 791 Empl. Ret. Inc. 896 Arbitration
REAL PROPERTY CIVIL RIGHTS PRISONER PETITIONS Security Act FEDERAL TAX SUITS 899 Administrative Proc
210 Land Condemnation 440 Other Civil Rights 510 Motions to Vacate 870 Taxes (U.S. Plaintiff Act/Review or Appe
220 Foreclosure 441 Voting Sentence or Defendant) Agency Decision
230 Rent Lease & Ejectment 442 Employment Habeas Corpus: 871 IRS—Third Party 950 Constitutionality of
240 Torts to Land 443 Housing/ 530 General 26 USC 7609 State Statutes
245 Tort Product Liability Accommodations 535 Death Penalty IMMIGRATION
290 All Other Real Property 445 Amer. w/Disabilities - 540 Mandamus & Other 462 Naturalization Application
Employment 550 Civil Rights 463 Habeas Corpus -
446 Amer. w/Disabilities - 555 Prison Condition Alien Detainee
Other 560 Civil Detainee - (Prisoner Petition)
448 Education Conditions of 465 Other Immigration
Confinement Actions
V. ORIGINTransferred fromanother district(specify)
(Place an “X” in One Box Only)
1 OriginalProceeding
2 Removed fromState Court
3 Remanded fromAppellate Court
4 Reinstated or Reopened
5 6 MultidistrictLitigation
VI. CAUSE OF ACTION
Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity ):
Brief description of cause:
VII. REQUESTED IN
COMPLAINT:
CHECK IF THIS IS A CLASS ACTION
UNDER F.R.C.P. 23
DEMAND $ CHECK YES only if demanded in complaint
JURY DEMAND: Yes No
VIII. RELATED CASE(S)
IF ANY(See instructions):
JUDGE DOCKET NUMBER
DATE SIGNATURE OF ATTORNEY OF RECORD
FOR OFFICE USE ONLY
RECEIPT # AMOUNT APPLYING IFP JUDGE MAG. JUDGE
Declaratory and Injunctive Relief
CHELSEA TORRES and JESSAMY TORRES, individually and as nextriends and parents of A.T., a minor child
DANE
see attachment)
KITTY RHOADES, in her official capacity as Secretary of the StaWisconsin Department of Health Services
DANE
Attorney Sandra M. Rowe, Chief Legal Counsel, WisconsinDepartment of Health Services, 1 W Wilson St Ste 651, PO Box Madison WI 53707-7850
42 U.S.C. §§ 1983 and 1988
Const. challenge to DHS's refusal to provide two-parent birth certificates to children born to same-sex spouse
05/13/2015 /s/ Clearesia A. Lovell-Lepak
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Attachment to
CIVIL COVER SHEET
I. (c) Attorneys for Plaintiffs
Clearesia A. Lovell-Lepak
Lovell-Lepak Law Office
P.O. Box 44623
Madison, Wisconsin 53744
(800) 216-3921
Kyle A. Palazzolo*
Camilla B. Taylor*
Christopher R. Clark*
Lambda Legal Defense and Education Fund, Inc.105 W. Adams, Ste. 2600
Chicago, Illinois 60603
(312) 663-4413
Tamara B. Packard
Cullen Weston Pines & Bach LLP
122 West Washington Avenue, Suite 900
Madison, Wisconsin 53703
(608) 807-0752
*Motions for admission pro hac vice pending
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l)f'.f'Alff.MENT OF
:UF..ALTH SERVfCJi S
l ) i ~ i i \ i { l n n{
f'1.1hlic
Health
F..{)5211
(R.l V. til l\l)
NOTIF.ICATION'OFlllRTHCERTIFICATFlR.ECISTRATtON
Si
ATE OP
WlSCONS
P ~ l o f 2
This docmntnt •s
N O T · ~
bjrth certifimitt C A N N O T · · ~ · nscdJor d e n t i t l ~ t m n p u r p ~ e s .
A birth c e r t i f l ~ r e
for
yourbahy wa.$.regi.stere.d with the
i ~ < ; i n s i n
Vital . ~ 9 r d $ Off.lee on 03/lg;zo
S.
20150127 l O
P t e a . ~ e
rurt Qrdet
fee. Y-0u will
,oot
l . i e n o d f w 4 · . o f o o ~ t i o . n $ u n l e s s y < 1 t t p u r c h a s ~ a birth
certificate.
S t h ~ h t l c k of ilds·.form f o r i n s t r u c t i o r u i . · ~ n order
your
eidfd'5
birth
· e . t . ~ r t : U l e a t e . Y€lu ll$e d:ds fol'fu
tQ
t ~ t i e s t .a nan\e ~ h : a t ' l i e fQr y.f oot t.
... . .
- . ; ? l: . ~ · . .
·1· ·. . . . . . .
SIONATIJ tB of
Pare11t
(fur c
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