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ZillZ
13/4.11:34
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ALABAMA
SOUTHERN DIVISION
CV-12-BE-2451-S
SOUTH CENTRAL CONFERENCE OF
CASE NO.
SEVENTH-DA Y ADVENTISTS;
NATHANAEL DE CANAL; and JOSHUA
COMPLAINT FOR DECLARATORY
DESIRE,
JUDGMENT AND INJUNCTIVE RELIEF
Plaintiffs,
v.
CITY OF ALABASTER, ALABAMA,
Defendant.
COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF
I. INTRODUCTION
1. 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 of protection by the First Amendment.
COMPLAINT FOR DECLARATORY JUDGMENT
AND INJUNCTIVE RELIEF-l
FILED
2012 Jul-13 PM 12:09
U.S. DISTRICT COURT
N.D. OF ALABAMA
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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
2. 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.
3. 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 2012. 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.
4. 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 2012. He attends a Seventh-
COMPLAINT FOR DECLARATORY JUDGMENT
AND INJUNCTIVE RELIEF - 2
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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 of Alabaster, Alabama.
5. 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 2012, 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.
6. 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 of state law.
III. JURISDICTION AND VENUE
7. The Court has subject matter jurisdiction pursuant to 28 U.S.C. 1331
(federal question jurisdiction) and 28 U.S.C. l343 (civil rights jurisdiction) this Court also
has pendentlsupplementaljurisdiction over Plaintiffs' claims made under state law.
8. The Court has personal jurisdiction over the defendant.
9. Venue is proper in this district pursuant to 28 U.S.C. 1391(b).
COMPLAINT FOR DECLARATORY JUDGMENT
AND INJUNCTIVE RELIEF - 3
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IV. FACTS
10. 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 City-
granted license in order for such a "business or vocation" to be lawful.
b. The second ordinance is a solicitation permit ordinance which requires a City-
granted 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 22-39. 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"JU1\l"CTIVE RELIEF - 4
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apply to the non-commercial missionary activities of the Plaintiffs, and has communicated to
Plaintiffs that it is so applying and enforcing this ordinance.
12. Violations of the business license ordinance are punishable as crimes under
City of Alabaster Code of Ordinances Section 1.12. Ordinances 22-39. Section 1.12
provides for fines and imprisonment as follows:
... afine of not less than $1.00, nor more than $500.00. 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 1.12.
13. Chapter 78 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.
14. Section 78.1 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
COMPLAINT FOR DECLARATORY JUDGMENT
AND INJUNCTIVE RELIEF - 5
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and/or peddling or hawking the same is declared to be a nuisance and
punishable as provided in section 1.12.
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 78.83.
15. 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 78-34. The application must
contain the following information:
(1) The full name ofthe organization applying for a permit to solicit and
the address of the 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.
(2) 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.
COMPLAINT FOR DECLARATORY JUDGMENT
AND INJUNCTIVE RELIEF - 6
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(3) The purpose or purposes for which the gross receipts derived from
such solicitations or other activities are to be used.
(4) The name and address of the person who will be in charge of
conducting the charitable solicitations campaign.
(5) The method of solicitation to be employed.
(6) The period within which such charitable solicitations campaign
shall be conducted, including the proposed date for the beginning
and ending of such campaign.
(7) The total amount of funds proposed to be raised.
(8) 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 78-34(1) to 78-34(8).
16. 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 78-34(9).
17. Upon receipt of the application, it is examined by a committee consisting of
three persons appointed by the City Council. Ordinances 78-35(a), 78-32(a). This
committee also conducts "an investigation in connection therewith." Ordinances 78-35(a).
18. If the 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
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AND INJUNCTIVE RELIEF - 7
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required to) issue a solicitation permit. Ordinances 78-35(a).
19. 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 of completing the application.
20. 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 78-35(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 78-35(b), and failure to attend such a
hearing is grounds for denial of the permit. Ordinances 78-35(c).
21. 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 78-34.
22. 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 78-35(b).
COMPLAINT FOR DECLARATORY JUDGMENT
AND INJUNCTIVE RELIEF - 8
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23. Although there is mention of a possible appeal to the city council, Ordinances
78-38, 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 78-38. Thus, the city
council may significantly, or even indefinitely, delay proposed speech under the solicitation
ordinance.
24. The solicitation ordinance does not contain any provision which would permit
the speech to proceed if such delays were to occur.
25. 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 78-35(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 78
35(b). As long as the committee puts its decision in writing, it can deny the permit for any
reason at all.
26. The solicitation ordinance contains no mechanism for timely judicial review
of the denial of an application.
COMPLAINT FOR DEC LARA TORY JUDGMENT
AND INJUNCTIVE RELIEF - 9
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27. The solicitation ordinance contains no provision for judicial review of a denial
of the permit.
28. The solicitation ordinance contains to time limits to ensure that any judicial
review occurs promptly.
29. 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.
30. The solicitation ordinance does not contain any provision permitting the
speech to proceed in the absence of a judicial determination.
31. The solicitation ordinance does not specify any governmental interest
advanced by the restrictions upon speech that are contained in the ordinance.
32. Each of the individual Plaintiffs is an observant member of the Seventh-day
Adventist faith and attends a church in the South Central Conference.
33. One of the primary tenets ofthe Seventh-day Adventist is faith is to follow the
"Great Commission" given by Jesus Christ to "spread the Gospel."
34. One of the methods by which the Plaintiffs and other members ofthe Seventh-
day 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.
35. For many decades, the Seventh-day Adventist Church has sponsored, and
continues to sponsor, programs to facilitate these missionary and evangelistic activities by its
COMPLAINT FOR DECLARATORY JUDGMENT
AND INJUNCTIVE RELIEF -10
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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.
36. 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."
37. The individual Plaintiffs have participated as Literature Evangelists in the
Program's missionary efforts each year over a period of several years.
38. North Alabama is one the locations in which the individual Plaintiffs have
engaged in missionary activities as Literature Evangelists for the Program.
39. During the Program this year, these Literature Evangelism activities occurred,
in part, within the City of Alabaster.
40. 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
COMPLAINT FOR DECLARATORY JUDGMENT
AND INJUNCTIVE RELIEF - 11
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Program, and has taken specific concrete steps in order to make this happen.
41. 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.
42. 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.
43. 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.
44. 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.
45. During the last week of June 2012, 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.
46. 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
COMPLAINT FOR DECLARATORY JUDGMENT
AND INJUNCTIVE RELIEF -12
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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 4 and is hereby incorporated by reference.
47. The City never provided any response to this inquiry.
48. In the absence of any response, the missionaries initiated their canvassing
activities within the City of Alabaster in good faith.
49. This canvassing commenced on or about June 27,2012.
50. On June 27, 2012, 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 of Alabaster permit."
51. 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.
52. 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.
53. As a direct and proximate result of these actions and threats by the Defendant,
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AND INJUNCTIVE RELIEF - 13
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the Program and its missionaries, including but not limited to the Plaintiffs herein, suspended
their canvassing activities within the City of Alabaster, and instead devoted all their time and
effort to canvassing neighboring communities.
54. 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 2012.
55. 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
56. Plaintiffs incorporate by reference all preceding paragraphs of this Complaint.
57. 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, 4 of the Constitution of Alabama of
1901; Alabama Religious Freedom Amendment, Amend. No. 622 to 3, Ala. Const. 1901.
58. The denial of rights guaranteed by the First and Fourteenth Amendments by
the Defendant under color of state law is actionable under 42 U.S.C. 1983.
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59. 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 of free literature and solicitation of donations, and not any
sale or commercial activity.
60. 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.
61. 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.
62. 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
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ordinances provide insufficient procedural safeguards for those wishing to appeal a denial or
revocation of a license.
63. 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.
64. 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.
65. 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.
66. 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 of obtaining a license to speak on religious subjects.
67. The ordinances violate both the federal and state constitutions, chill protected
speech and substantially burden the free exercise of religion by imposing a "25% 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
COMPLAINT FOR DECLARATORY JUDGMENT
AND INJUNCTIVE RELIEF - 16
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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 25% of gross receipts upon
fundraising, or if it appears likely to do so in the imminent future. Such restrictions upon
charitable solicitation are unconstitutional.
68. 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 42 U.S.C. 1983.
69. 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
70. Plaintiffs incorporate by reference all preceding paragraphs of this Complaint.
71. The ordinances deprive Plaintiffs and their members of their speech and
liberty interests without due process of law, without adequate procedural safeguards in
COMPLAINT FOR DECLARATORY JUDGMENT
AND INJUNCTIVE RELIEF - 17
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violation of the Fourteenth Amendment of the United States Constitution and the State
Constitution.
72. The ordinances are void for vagueness and violate the Fourteenth Amendment
guarantee of procedural due process, which is actionable under 42 U.S.C. 1983.
73. 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 42 U.S.C. 1983 unless enjoined.
VI. PRAYER FOR RELIEF
74. Plaintiffs seek the following relief:
75. 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.
76. A declaratory judgment that the ordinances are unconstitutional on their face
and as applied.
77. Attorney's fees and costs pursuant to 42 U.S.C. 1988, or such other authority
as may authorize such an award.
78. Such other further relief as this Court deems proper.
79. Plaintiffs request a jury trial on all issues triable by jury.
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T, the U11dersigned, hereby state on
Complaint, and that the facts, matters and statements contained therein are true and correct to
the best of my knowledge and belief.

ORN to before me this
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VERIFICATION
that J have read the above and foregoing
day oOul; 2012.
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VERIFICATION
I, the undersigned, hereby on Qath that I have read the above and foregoing
Complaint, and that the matters and statements contained therein' are trite and cot(ect to
the best ofmy knowledge and belief. .
D SWORN to before me this L3 day of July 2012.
NOTARY PUBLIC STATE OF ALABAMA A RGE
12.2012
BONDED THRU NOTARY P UNDERWRITERS
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COMPLAINT FOR DECLARATORY JUDGMENT
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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 of the
South Central Conference of Seventh-day Adventists
day of July 2012.
My
NOi'fAflY EXPIRES Oee 12,
MY COMMI "'AflY puel.1C
J!IONOEO TrlflU NO I
COMPLAINT FOR DECLARATORY JUDGMENT
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OF COUNSEL:
WIGGINS, CHILDS, QUINN & PANTAZIS, LLC
The Kress Building
301 19
Th
Street North
Binningham, Alabama 35203
(205) 314-0500
Todd R. McFarland
Associate General Counsel
General Conference of Seventh-day Adventists
12501 Old Columbia Pike
Silver Spring MD 20904
(301) 680-6321
SERVE DEFENDANT AT:
City ofAlabaster, Alabama
Alabaster City Hall
201 1
st
Street North
Alabaster, Alabama 35007
205/664-6800
COMPLAINT FOR DECLARATORY JUDGMENT
AND INJUNCTIVE RELIEF - 22