Case 2:12-cv KOB Document 1 Filed 07/13/12 Page 1 of 22 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ALABAMA SOUTHERN DIVISION

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1 Case :-cv-0-kob Document Filed 0// Page of FILED Jul- PM :0 U.S. DISTRICT COURT N.D. OF ALABAMA 0 0 SOUTH CENTRAL CONFERENCE OF SEVENTH-DA Y ADVENTISTS; NATHANAEL DE CANAL; and JOSHUA DESIRE, v. UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ALABAMA SOUTHERN DIVISION Plaintiffs, CITY OF ALABASTER, ALABAMA, Defendant. CASE NO. ZillZ /.: CV--BE--S COMPLAINT FOR DECLARATORY JUDGMENT AND INJUNCTIVE RELIEF COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF I. INTRODUCTION. The City of Alabaster has enacted two sweepmg ordinances that unconstitutionally restrict the exchange of beliefs and religious principles within the Alabaster city limits. The City of Alabaster has enacted an absolute ban on door-to-door sales, and has restricted all other forms of solicitation and expression unless those wishing to engage in such religious, charitable or other such protected discourse first register with the City - not just once, but twice pay the required license fees, disclose their personal identity and a variety of personal information, and provide numerous burdensome and irrelevant details regarding their past and future speech. These ordinances directly target, and impose a prior restraint upon, speech afforded the highest levels ofprotection by the First Amendment. AND INJUNCTIVE RELIEF-l

2 Case :-cv-0-kob Document Filed 0// Page of 0 0 Courts have routinely rejected governmental efforts to impose this sort of sweeping prior restraint on speech, and particularly so when the speech involved lies at the very core of our constitutional system. For these reasons, plaintiffs seek a declaratory judgment and injunctive relief, barring the City from enforcing the ordinances, and declaring them unconstitutional on their face and as applied. II. PARTIES. Plaintiff South Central Conference of Seventh-day Adventists is an unincorporated religious membership organization with numerous members and churches located in several states, including within Shelby County, Alabama. The South Central Conference has been established and in existence for decades, and operates the Summer Student Missionary Program under the Family Health Education Service, which is one of its ministries.. Plaintiff Nathanael De Canal is an individual and a citizen and resident of the State of Alabama. Mr. De Canal has participated in the annual Summer Student Missionary Program for each of the past five years, including the current year's Program which is scheduled to continue through mid-august. He attends a Seventh-day Adventist Church located in Huntsville, Alabama, which is a member of the South Central Conference of Seventh-day Adventists. At all relevant times herein, Mr. De Canal participated in the Summer Student Missionary Program as a Literature Evangelist and team leader. His geographic territory includes locations within the City of Alabaster, Alabama.. Plaintiff Joshua Desire is an individual and a citizen of the State of Florida and a resident of the State of Alabama. Mr. Desire has participated in the annual Summer Student Missionary Program for each of the past four years, including the current year's Program which is scheduled to continue through mid-august. He attends a Seventh- AND INJUNCTIVE RELIEF -

3 Case :-cv-0-kob Document Filed 0// Page of 0 0 day Adventist Church located in Huntsville, Alabama, which is a member of the South Central Conference of Seventh-day Adventists. At all relevant times herein, Mr. Desire participated in the Summer Student Missionary Program as a Literature Evangelist and team member under the leadership of Mr. De Canal. His geographic territory includes locations within the City ofalabaster, Alabama.. The South Central Conference has already scheduled, planned, and made the necessary preparations for engaging in protected speech within the city limits of the Defendant City of Alabaster during this year's Summer Student Missionary Program. These plans were implemented in late June, but were immediately suspended when the South Central Conference received information from the Defendant City of Alabaster that two City ordinances prohibited this speech without City-issued permits and licenses. The South Central Conference actively seeks to resume evangelism within the City of Alabaster, and stands ready, willing and able to promptly resume these efforts to seek religious converts once the "chill" on these efforts to speak is removed.. Defendant City of Alabaster, Alabama is a municipal corporation organized, existing and operating under Alabama statute and located in Shelby County, Alabama, with the capacity to sue and be sued in this name. All action by this defendant (referred to herein as the "Defendant," the "City," or the "Defendant City") is action under color ofstate law. III. JURISDICTION AND VENUE. The Court has subject matter jurisdiction pursuant to U.S.C. (federal question jurisdiction) and U.S.C. l (civil rights jurisdiction) this Court also has pendentlsupplementaljurisdiction over Plaintiffs' claims made under state law.. The Court has personal jurisdiction over the defendant.. Venue is proper in this district pursuant to U.S.C. (b). AND INJUNCTIVE RELIEF -

4 Case :-cv-0-kob Document Filed 0// Page of 0 0 IV. FACTS 0. The City of Alabaster has enacted two ordinances which directly impose restraints upon any individual or group engaged in religious pamphleteering or solicitation anywhere within its city limits: a. The first ordinance is a business license ordinance which applies to "any of the businesses or vocations herein contained in the city," and requires a Citygranted license in order for such a "business or vocation" to be lawful. b. The second ordinance is a solicitation permit ordinance which requires a Citygranted permit in order for solicitation to be lawful. Both ordinances punish the failure to have a license or permit as a crime which carries not only a potential fine, but also a term of imprisonment and "hard labor." II. Under the City of Alabaster business license ordinance, it is unlawful for any person to engage in "any of the businesses or vocations herein contained in the city" without first obtaining a business license and paying the required fee. Ordinances -. A true and correct copy of this ordinance, as it was provided by the Defendant City of Alabaster, is attached to the contemporaneously filed Brief in Support of Temporary Restraining Order and Preliminary Injunctive Relief as part of Exhibit I thereto, and is hereby incorporated by reference. Notwithstanding the apparent facial inapplicability of the business license ordinance to non-commercial solicitation and pamphleteering such as that engaged in by the missionary Plaintiffs, the City of Alabaster has interpreted this business license ordinance to COMPLAINT FOR DEC LARA TORY JUDGMENT AND TI\l"JU\l"CTIVE RELIEF -

5 Case :-cv-0-kob Document Filed 0// Page of 0 0 apply to the non-commercial missionary activities of the Plaintiffs, and has communicated to Plaintiffs that it is so applying and enforcing this ordinance.. Violations of the business license ordinance are punishable as crimes under City of Alabaster Code of Ordinances Section.. Ordinances -. Section. provides for fines and imprisonment as follows:... afine ofnot less than $.00, nor more than $ In addition thereto, any person so convicted may be imprisoned or sentenced to hard labor for the city for a period not exceeding six months, at the discretion of the court trying the case; provided, however, that no penalty shall consist of a fine or sentence of imprisonment exceeding the maximum fine or sentence of imprisonment established under state law for the commission of substantially similar offenses. ' Ordinances... Chapter of the Alabaster Code of Ordinances applies to "Peddlers and Solicitors" and is referred to herein as the "solicitation permit ordinance" or "solicitation ordinance." A true and correct copy of this ordinance, as it was provided by the Defendant City of Alabaster, is attached to the contemporaneously filed Brief in Support of Temporary Restraining Order and Preliminary Injunctive Relief as part of Exhibit I thereto, and is hereby incorporated by reference.. Section. provides an outright ban on door to door "soliciting" as follows: The practice of going in and upon private residences in the city by solicitors, peddlers, hawkers, itinerant merchants or transient vendors of merchandise not having been requested or invited to do so by the owner or owners, occupant or occupants of such private residence for the purpose of soliciting orders for the sale of goods, wares, and merchandise and/or disposing of AND INJUNCTIVE RELIEF -

6 Case :-cv-0-kob Document Filed 0// Page of 0 0 and/or peddling or hawking the same is declared to be a nuisance and punishable as provided in section.. In addition to this outright ban on soliciting orders, the solicitation ordinance imposes significant restrictions upon non-commercial religious speech within the City of Alabaster. The City of Alabaster requires a permit before persons such as the Plaintiffs may engage in protected religious speech within the city limits. Such activities are regulated by the ordinance whether they are engaged in by going door to door or standing in a public place: It shall be unlawful to conduct any charitable solicitation or charitable solicitation campaign on the streets or in any public place or by house to house canvass in the city unless the person, organization or society conducting the same and responsible therefor shall first have obtained a permit therefor in compliance with this article. Ordinances... The solicitation ordinance imposes substantial informational requirements upon applicants who wish to speak on religious matters. In order to receive a permit, an applicant must fill out an application under oath. Ordinances -. The application must contain the following information: () The full name ofthe organization applying for a permit to solicit and the address ofthe headquarters in the city, or if the organization is a chapter or other affiliate of an organization having its principal office outside the city, the name and address ofthe parent organization. () The names and addresses of all officers and directors or trustees of the organization and the names and city of residence of all officers, directors or trustees ofthe parent organization, ifany. AND INJUNCTIVE RELIEF -

7 Case :-cv-0-kob Document Filed 0// Page of 0 0 () The purpose or purposes for which the gross receipts derived from such solicitations or other activities are to be used. () The name and address of the person who will be in charge of conducting the charitable solicitations campaign. () The method of solicitation to be employed. () The period within which such charitable solicitations campaign shall be conducted, including the proposed date for the beginning and ending of such campaign. () The total amount offunds proposed to be raised. () The amount of all salaries, wages, fees, commissions, expenses and costs to be expended or paid to anyone in connection with such campaign, together with the manner in which such wages, fees, commissions, expenses, and costs are to be expended, and the maximum percentage of funds collected which are to be used to pay such expenses of solicitation and collection. Ordinances -() to -().. In addition to these categories of information, the solicitation ordinance establishes an additional discretionary category of "such other information as the committee shall require." Ordinances -().. Upon receipt of the application, it is examined by a committee consisting of three persons appointed by the City Council. Ordinances -(a), -(a). This committee also conducts "an investigation in connection therewith." Ordinances -(a).. Ifthe committee "is satisfied as to the correctness of the information provided and that the solicitation is for genuine charitable purposes" the committee!!!!!.y (but is not AND INJUNCTIVE RELIEF -

8 Case :-cv-0-kob Document Filed 0// Page of 0 0 required to) issue a solicitation permit. Ordinances -(a).. The solicitation ordinance imposes significant financial burdens upon the applicant. Applicants must pay the applicable license fee and must incur the cost of compiling the voluminous and detailed information required by the City on its application, much of which is not maintained in the normal course of operation and must be specially created specifically for the purpose ofcompleting the application.. In the event that additional information is required by the City, the applicant must incur the additional expense of travelling to the City of Alabaster to attend a hearing on the application. Ordinances -(b). This hearing entails either a separate trip or an extended stay in the City of Alabaster, as it occurs no less than five days prior to planned beginning of the missionary efforts, Ordinances -(b), and failure to attend such a hearing is grounds for denial of the permit. Ordinances -(c).. The solicitation ordinance imposes significant delays upon attempts to exercise free speech rights. The permit application must be filed not less than forty-five days before the speech is to occur, unless "on good cause being shown." Ordinances -.. The solicitation ordinance does not contain any time limit for the approval or denial of an application. Although the solicitation ordinance contains a provision for a public hearing to occur at least five days before the solicitation is scheduled to begin, it contains no requirement that the decision occur at the time of that hearing, or within any specified period oftime. Ordinances -(b). AND INJUNCTIVE RELIEF -

9 Case :-cv-0-kob Document Filed 0// Page of 0 0. Although there is mention of a possible appeal to the city council, Ordinances -, there is no time limit as to when this appeal must be heard or when the appeal must be decided by the city council The solicitation ordinance merely provides that the appeal may be heard after notice at a regular or special meeting. Ordinances -. Thus, the city council may significantly, or even indefinitely, delay proposed speech under the solicitation ordinance.. The solicitation ordinance does not contain any provision which would permit the speech to proceed if such delays were to occur.. The solicitation ordinance contains no limitation upon the committee's discretion to approve or deny an application for a permit. Although it contains a list of reasons for denying the requested permit, Ordinances -(b), the solicitation ordinance also contains a discretionary exception that wholly negates any purported exclusivity of the listed reasons. Under this discretionary exception, the committee "shall find good and sufficient reason for denying the application for causes not specified in this section" with the only limitation being that in the event of denial for a different or unlisted reason, that reason merely must be stated in writing and delivered to the applicant. Ordinances (b). As long as the committee puts its decision in writing, it can deny the permit for any reason at all.. The solicitation ordinance contains no mechanism for timely judicial review of the denial ofan application. COMPLAINT FOR DEC LARA TORY JUDGMENT AND INJUNCTIVE RELIEF -

10 Case :-cv-0-kob Document Filed 0// Page 0 of 0 0. The solicitation ordinance contains no provision for judicial review of a denial ofthe permit.. The solicitation ordinance contains to time limits to ensure that any judicial review occurs promptly.. The solicitation ordinance does not require that the City bear the burden to obtain a judicial ruling if it is to prevent the speech from occurring.. The solicitation ordinance does not contain any provision permitting the speech to proceed in the absence ofa judicial determination.. The solicitation ordinance does not specify any governmental interest advanced by the restrictions upon speech that are contained in the ordinance.. Each of the individual Plaintiffs is an observant member of the Seventh-day Adventist faith and attends a church in the South Central Conference.. One ofthe primary tenets ofthe Seventh-day Adventist is faith is to follow the "Great Commission" given by Jesus Christ to "spread the Gospel.". One ofthe methods by which the Plaintiffs and other members ofthe Seventhday Adventist Church communicate their religious views is through door to door solicitation, evangelism and the distribution of free literature about the Seventh-day Adventist faith to interested persons.. For many decades, the Seventh-day Adventist Church has sponsored, and continues to sponsor, programs to facilitate these missionary and evangelistic activities by its AND INJUNCTIVE RELIEF -0

11 Case :-cv-0-kob Document Filed 0// Page of 0 0 members. One such program is the annual "Summer Student Missionary Program" (hereinafter, the "Program"), of which the South Central Conference of Seventh-day Adventists has been and continues to be a sponsor. The South Central Conference provides monetary and "in kind" support for the Program, and encourages its members to participate in the Program, which is conducted under the Family Health Education Service, which is a ministry of the South Central Conference. Its efforts have borne fruit, as members of the South Central Conference, including but not limited to the individual Plaintiffs, have for several years participated in and have been instrumental in the evangelistic efforts of the Program in Northern Alabama.. Church members, such as the Plaintiffs, who participate in missionary efforts that involve the distribution of such literature are recognized by the Seventh-day Adventist Church as "Literature Evangelists.". The individual Plaintiffs have participated as Literature Evangelists in the Program's missionary efforts each year over a period ofseveral years.. North Alabama is one the locations in which the individual Plaintiffs have engaged in missionary activities as Literature Evangelists for the Program.. During the Program this year, these Literature Evangelism activities occurred, in part, within the City of Alabaster. 0. Each individual Plaintiff ls committed to returning to North Alabama (including the City of Alabaster) for the remainder of this year's Program and next year's AND INJUNCTIVE RELIEF -

12 Case :-cv-0-kob Document Filed 0// Page of 0 0 Program, and has taken specific concrete steps in order to make this happen.. In the Summer Student Missionary Program, church members (typically college students) travel in teams to various locations during the summer months from early June through mid-august.. These teams generally consist of a team leader and from five to ten team members. Plaintiff Nathanael De Canal is a leader of such a team, and Plaintiff Joshua Desire is member of such a team.. The teams travel to a pre-determined destination and canvass door to door, offering free literature about the Seventh-day Adventist faith to interested persons, engaging in verbal evangelism, and soliciting donations to help support the Program and further its evangelistic purpose.. Such solicitations are integral to the religious message that is presented by the student missionaries, for the simple act of making such a donation is often the first step toward religious conversion, and is part and parcel of the evangelistic activities of the student missionaries.. During the last week of June, a team of Literature Evangelists, which included the Plaintiffs, was scheduled to spend several days canvassing and distributing literature under this Program in an area which included portions of the City of Alabaster.. Before any such canvassing or distribution commenced, the City was informed of the Plaintiffs' intended activities, and asked whether the City would apply the ordinances AND INJUNCTIVE RELIEF -

13 Case :-cv-0-kob Document Filed 0// Page of 0 0 to the Program's missionary team operating within the Defendant City, even though the missionaries was not engaging in any sales activity, but were merely pamphleteering and soliciting charitable contributions. A true and correct copy of this correspondence is attached to the contemporaneously filed Brief in Support of Motion for Temporary Restraining Order and Preliminary Injunctive Relief as Exhibit and is hereby incorporated by reference.. The City never provided any response to this inquiry.. In the absence of any response, the missionaries initiated their canvassing activities within the City of Alabaster in good faith.. This canvassing commenced on or about June,. 0. On June,, one of the members of the Program's missionary team was stopped by a City of Alabaster police officer and charged with "selling books door to door without a City ofalabaster permit.". Subsequent attempts by the Program to ascertain the ordinance allegedly violated resulted in a confused and delayed response from the City of Alabaster, which initially proved unable or unwilling to provide copies of the ordinances except in response to formal public records requests accompanied by a prepaid fee.. Ultimately, the City identified the two ordinances that are at issue in this case and the City stated its intent to continue to enforce these two ordinances against the Program's missionary teams, including but not limited to the Plaintiffs.. As a direct and proximate result of these actions and threats by the Defendant, AND INJUNCTIVE RELIEF -

14 Case :-cv-0-kob Document Filed 0// Page of 0 0 the Program and its missionaries, including but not limited to the Plaintiffs herein, suspended their canvassing activities within the City ofalabaster, and instead devoted all their time and effort to canvassing neighboring communities.. Unless the City of Alabaster's enforcement of these ordinances is enjoined, the Plaintiff missionaries will be unable to witness to the citizens of the City of Alabaster before the conclusion ofthe Program in mid-august.. The City has been made aware of, and provided with a copy of this Complaint, Motion and Brief which are being contemporaneously filed in this case. V. CAUSES OF ACTION FIRST CAUSE OF ACTION Deprivation of Free Speech and Associational Rights and Freedom of Religion in violation of Federal and State Constitutions. Plaintiffs incorporate by reference all preceding paragraphs ofthis Complaint.. By prohibiting and excessively limiting protected speech, the Defendant City is violating the Plaintiffs' and their members' free speech rights under the First and Fourteenth Amendments of the United States Constitution and the Alabama State Constitution, including but not limited to Article I, of the Constitution of Alabama of 0; Alabama Religious Freedom Amendment, Amend. No. to, Ala. Const. 0.. The denial of rights guaranteed by the First and Fourteenth Amendments by the Defendant under color of state law is actionable under U.S.C.. AND INJUNCTIVE RELIEF -

15 Case :-cv-0-kob Document Filed 0// Page of 0 0. The ordinances are directed specifically at protected expression and conduct commonly associated with such expression. The ordinances are overbroad and impermissibly limit individuals engaged in religious discourse and speech. As such, the ordinances are facially unconstitutional and unconstitutional as applied to the activities of the Plaintiffs which involve only the distribution offree literature and solicitation ofdonations, and not any sale or commercial activity. 0. Because Plaintiffs are required to obtain the Defendant City's permission in two separate ways before engaging in constitutionally protected speech, the ordinances are individually and collectively an unlawful prior restraint. The prior restraint is particularly burdensome because each license is valid only temporarily, requiring each solicitor who wishes to engage in protected speech to reapply for a license every time the annual Program resumes active missions.. The ordinances vest the Defendant City's agents with excessive discretion to approve, deny or revoke licenses v.ithout adequate substantive guidance or procedural safeguards.. The ordinances grant the Defendant City's agents excessive. discretion to approve or deny applications and appeals. The appeal provisions are silent as to time for resolution for an appeal, and provide no avenue for judicial appeal of the denial of an initial application. The ordinances provide no criteria or standards to guide the Defendant City's agents in their decision to approve or deny appeals when such appeals are authorized. The COMPLAINT FOR DEC LARA TORY JUDGMENT AND INJUNCTIVE RELIEF -

16 Case :-cv-0-kob Document Filed 0// Page of 0 0 ordinances provide insufficient procedural safeguards for those wishing to appeal a denial or revocation of a license.. The ordinances are not reasonable time, place, manner restrictions because they are content-based restrictions upon speech, and even if content-neutral are not narrowly tailored to advance significant or compelling state interest. Further, the ordinances are overbroad.. The ordinances are not reasonable time, place, or manner restrictions because they are content-based restrictions which prohibit protected speech in the entire city limits, and even if content-neutral, leave insufficient alternatives for expression.. The ordinances violate both the federal and state constitutions, chill protected speech and substantially burden the free exercise of religion by requiring individuals to disclose their names, home addresses, and other personal information as a condition of obtaining a license to speak on religious subjects.. The ordinances violate both the federal and state constitutions, chill protected speech and substantially burden the free exercise of religion by requiring the payment of a fee as a condition ofobtaining a license to speak on religious subjects.. The ordinances violate both the federal and state constitutions, chill protected speech and substantially burden the free exercise of religion by imposing a "% rule" for fundraising costs. The solicitation permit ordinance requires significant information designed to ascertain the percentage of an applicant's gross receipts that are expended upon AND INJUNCTIVE RELIEF -

17 Case :-cv-0-kob Document Filed 0// Page of 0 0 fundraising, and the ordinance provides that the applicant's permit may be denied if it has at any time during the past three years expended more than % of gross receipts upon fundraising, or if it appears likely to do so in the imminent future. Such restrictions upon charitable solicitation are unconstitutional.. Through the enactment, enforcement, and threatened enforcement of the ordinances, the Defendant City has, under color of state law, deprived the Plaintiffs and their members of rights, privileges, or immunities secured by the Constitution or laws of the United States, in violation of U.S.C... The injuries suffered by Plaintiffs cannot be fully compensated by monetary damages. If enforcement of the Ordinance is not enjoined, Plaintiffs and their members will suffer irreparable injury which cannot be adequately remedied at law, including but not limited to the chilling of their and their members' free speech rights and impairment of their free exercise of religion. SECOND CAUSE OF ACTION Deprivation of Liberty Interests Without Due Process of Law in violation of the Federal and State Constitutions 0. Plaintiffs incorporate by reference all preceding paragraphs of this Complaint.. The ordinances deprive Plaintiffs and their members of their speech and liberty interests without due process of law, without adequate procedural safeguards in AND INJUNCTIVE RELIEF -

18 Case :-cv-0-kob Document Filed 0// Page of 0 0 violation of the Fourteenth Amendment of the United States Constitution and the State Constitution.. The ordinances are void for vagueness and violate the Fourteenth Amendment guarantee ofprocedural due process, which is actionable under U.S.C... Through the enactment, enforcement, and threatened enforcement of the ordinances, the Defendant City has deprived and will continue to deprive the Plaintiffs and their members of rights, privileges, or immunities secured by the Constitution or laws of the United States, in violation of U.S.C. unless enjoined. VI. PRAYER FOR RELIEF. Plaintiffs seek the following relief:. A temporary restraining order, and preliminary and permanent injunctive relief, enjoining Defendant, its employees, officers, agents and persons acting in concert with them from enforcing or threatening to enforce the ordinances against Plaintiffs and other participants in the Summer Student Missionary Program.. A declaratory judgment that the ordinances are unconstitutional on their face and as applied.. Attorney's fees and costs pursuant to U.S.C., or such other authority as may authorize such an award.. Such other further relief as this Court deems proper.. Plaintiffs request a jury trial on all issues triable by jury. AND INJUNCTIVE RELIEF -

19 Case :-cv-0-kob Document Filed 0// Page of?.j VERIFICATION T, the Udersigned, hereby state on ~ath that J have read the above and foregoing Complaint, and that the facts, matters and statements contained therein are true and correct to the best of my knowledge and belief. tlla~analtc~, ""-II..~"-= ]. $ :. 0 ORN to before me this ~ day ooul;. AND INJUNCTIVE RELIEF -

20 Case :-cv-0-kob Document Filed 0// Page of 0, ls. ~~ 0 VERIFICATION I, the undersigned, hereby st~l.te on Qath that I have read the above and foregoing Complaint, and that the fa.cts~ matters and statements contained therein' are trite and cot(ect to the best ofmy knowledge and belief.. NOTARY PUBLIC STATE OF ALABAMA A D SWORN to before me this L day of July. RGE. BONDED THRU NOTARY P UNDERWRITERS I,,_.-.._. II II AND JNH.JNCTIVE RELIEF -

21 Case :-cv-0-kob Document Filed 0// Page of.0 VERIFICATIQN I, the undersigned. hereby state on oath that I have read the above and foregoing Complaint, and that the facts, matters and statements contained therein are true and correct to the best ofmy knowledge and belief. ~~ Nne: va Mattison D authori.zedrepresentative ofthe South Central Conference ofseventh-day Adventists day ofjuly. 0 My CommiS ~~Ai'fLAflG NOi'fAflY PU~~0N EXPIRES Oee, O~RS MY COMMI "'AflY puel.c IJNI)E~ J!IONOEO TrlflU NO I AND INJUNCTIVE RELIEF ~

22 Case :-cv-0-kob Document Filed 0// Page of 0 0 OF COUNSEL: WIGGINS, CHILDS, QUINN & PANTAZIS, LLC The Kress Building Th Street North Binningham, Alabama () -000 Todd R. McFarland Associate General Counsel General Conference of Seventh-day Adventists 0 Old Columbia Pike Silver Spring MD 0 () 0- SERVE DEFENDANT AT: City ofalabaster, Alabama Alabaster City Hall st Street North Alabaster, Alabama 00 /-00 AND INJUNCTIVE RELIEF -