Beruflich Dokumente
Kultur Dokumente
JAIME VENEGAS,
Plaintiff,
v.
Defendant.
Silverstein of the American Civil Liberties Union Foundation of Colorado, and Peter R.
Bornstein of the Law Offices of Peter R. Bornstein, hereby files his Complaint for
Introduction
Plaintiff Jaime Venegas is a Colorado resident who was born in Socorro, Texas
on July 20, 1984. The United States Department of State has refused to acknowledge
Mr. Venegas’s U.S. citizenship and issue him a U.S. passport, even though Mr.
Venegas has presented proof of his citizenship, including his valid Texas birth
certificate. This action seeks a declaration under 8 U.S.C. § 1503(a) that Mr. Venegas
The Parties
District of Colorado.
Case 1:19-cv-02343 Document 1 Filed 08/16/19 USDC Colorado Page 2 of 5
States of America.
Jurisdiction
Plaintiff, who is within the United States and has been denied a right and privilege as a
citizen of the United States by a government agency, may bring an action for a
and 2202 and is brought for the purpose of determining a question of actual controversy
Venue
Colorado.
Facts
7. Plaintiff Jaime Venegas was born on July 20, 1984, in the city of Socorro,
County of El Paso, State of Texas. A copy of his Certificate of Birth from the State of
8. Following his birth in Texas, Mr. Venegas lived in Juarez, Mexico until the
age of sixteen. He then moved to El Paso, Texas and completed high school. In 2005,
married to a U.S. Citizen and is the father of two U.S. citizen children.
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9. Mr. Venegas’s U.S. citizenship was never questioned until he applied for a
passport in 2014. He had voted in elections without issue, and his mother Patricia
Venegas. She is now a U.S. citizen and also lives in Colorado. Mr. Venegas’s father
10. In 2014, Mr. Venegas applied to the United States Department of State for
11. The Department of State asserted that Mr. Venegas’s birth certificate was
insufficient to prove his U.S. citizenship and ultimately denied his passport application
citizenship insufficient.
Certifications of Vital Record from El Paso County, Texas and the Texas Department of
Health Services Vital Statistics Unit, attached as Exhibit 3; and immunization records,
attached as Exhibit 4.
15. The Department of State again denied his passport by a letter dated
16. Defendant Secretary of State of the United States has wrongfully denied
Plaintiff an American passport and denied him the right and privilege to travel outside of
the United States and return to the United States as an American citizen.
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17. Plaintiff has exhausted his administrative remedies and has no adequate
remedy at law.
18. Plaintiff seeks a declaration from this Court that he is in fact an American
Requested Relief
State;
b. An award of costs and attorney fees under the Equal Access to Justice
Act; and
c. Such other and further relief as the Court may deem necessary and
proper.
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s/ Arash Jahanian
Arash Jahanian
Mark Silverstein
AMERICAN CIVIL LIBERTIES UNION
FOUNDATION OF COLORADO
303 E. 17th Avenue, Suite 350
Denver, CO 80203
Tel: (303) 777-5482
Fax: (303) 777-1773
ajahanian@aclu-co.org
msilverstein@aclu-co.org
Peter R. Bornstein
THE LAW OFFICES OF PETER R. BORNSTEIN
6060 Greenwood Plaza Blvd., Ste. 500
Greenwood Village, CO 80111
Tel: (720) 354-4440
Fax: (720) 287-5674
pbornstein@prblegal.com
In Cooperation with the ACLU Foundation of
Colorado