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day Adventist Church located in Huntsville, Alabama, which is a member
the SouthCentral Conference
Seventh-day Adventists. At all relevant times herein, Mr. Desireparticipated in the Summer Student Missionary Program as a Literature Evangelist and teammember under the leadership
Mr. De Canal. His geographic territory includes locationswithin the City
Alabaster, Alabama.5. The South Central Conference has already scheduled, planned, and made thenecessary preparations for engaging in protected speech within the city limits
Alabaster during this year's Summer Student Missionary Program. Theseplans were implemented in late June 2012, but were immediately suspended when the SouthCentral Conference received information from the Defendant City
Alabaster that two Cityordinances prohibited this speech without City-issued permits and licenses. The SouthCentral Conference actively seeks to resume evangelism within the City
Alabaster, andstands ready, willing and able to promptly resume these efforts to seek religious convertsonce the "chill" on these efforts to speak is removed.6. Defendant City
Alabaster, Alabama is a municipal corporation organized,existing and operating under Alabama statute and located in Shelby County, Alabama, withthe capacity to sue and be sued in this name. All action by this defendant (referred to hereinas the "Defendant," the "City," or the "Defendant City") is action under color
III. JURISDICTION AND VENUE
The Court has subject matter jurisdiction pursuant to 28 U.S.C. §
(federal question jurisdiction) and 28 U.S.C.
l343 (civil rights jurisdiction) this Court also has pendentlsupplementaljurisdiction over Plaintiffs' claims made under state law.
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 JUDGMENTAND INJUNCTIVE RELIEF -3