Professional Documents
Culture Documents
UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WISCONSIN VIRGINIA WOLF, et al., Plaintiffs, vs. SCOTT WALKER, et al., Defendants. DECLARATION OF LAURENCE J. DUPUIS IN SUPPORT OF PLAINTIFFS MOTION FOR A PRELIMINARY INJUNCTION Case No.: 14-cv-64
1. I am one of the Plaintiffs attorneys in this action. I make this declaration in support of their motion for a preliminary injunction. 2. Attached as Exhibit 1 to this Declaration is a true and correct copy of a memorandum from State Representatives Mark Gundrum, Wayne Wood, Leah Vukmir and Ann Nischke, and State Senator Scott Fitzgerald, to all Wisconsin legislators, regarding co-sponsorship of LRB 4072/2 (the constitutional amendment affirming marriage) (January 29, 2004), which I obtained from the pleadings in McConkey v. Van Hollen, 2008AP1868 (Wis. Sup. Ct.). The authors of this memorandum were the principle legislative sponsors of the constitutional amendment that is now Article XIII, section 13 of the Wisconsin Constitution.
3. Attached as Exhibit 2 to this Declaration is a true and correct copy of the Wisconsin Legislative Reference Bureaus drafting file for LRB-4072, which I obtained from the Wisconsin Legislatures web site. See http://docs.legis.wi.gov/2003/related/drafting_files/assembly_intro_legislatio n/assembly_joint_resolutions/2003_ajr_066/02_ajr_66/03_4072df.pdf (last visited Feb. 26, 2014). The materials in this file led to the introduction of 2003 Assembly Joint Resolution 66, which ultimately was enacted as Article XIII, section 13 of the Wisconsin Constitution. 4. Attached as Exhibit 3 to this Declaration is a true and correct copy of a flyer entitled Vote Yes For Marriage, which was Exhibit N to the Affidavit of Julaine Appling, and submitted in connection with the Plaintiffs summary judgment pleadings in Appling v. Doyle, No. 2010CV4434 (Dane Co. Cir. Ct.). Julaine Appling was a leader of Wisconsin Family Action, the Wisconsin Family Research Institute of Wisconsin, the Vote Yes for Marriage referendum campaign, and the Wisconsin Coalition for Traditional Marriage. She and the organizations of which she was a part were the leading private proponents of the constitutional amendment that was enacted as Article XIII, section 13 of the Wisconsin Constitution. 5. Attached as Exhibit 4 to this Declaration is a true and correct copy of a Wisconsin Family Research Institute Power Point presentation entitled Preserving OneMan/One-Woman Marriage in Wisconsin, which was Exhibit C to the Affidavit
of Julaine Appling, submitted in connection with the Plaintiffs summary judgment pleadings in Appling v. Doyle, No. 2010CV4434 (Dane Co. Cir. Ct.).
I declare under penalty of perjury that the foregoing is true and correct.
s/ Laurence J. Dupuis Laurence J. Dupuis State Bar No. 1029261 One of the Attorneys for Plaintiffs American Civil Liberties Union of Wisconsin Foundation 207 E. Buffalo St., #325 Milwaukee, WI 53202 Telephone: (414) 272-4032, ext. 212 Fax: (414) 272-0182 E-mail: ldupuis@aclu-wi.org