Doe v MD Board of Elections Amended Complaint 9012011
Number of Pages:31
Date Created:September 1, 2011
Date Uploaded to the Library:February 20, 2014
Autogenerated text from PDF
JOHN DOE Brooklyn Park, Maryland THE CIRCUIT COURT JANE DOE Glen Burnie, Maryland FOR ANNE ARUNDEL JESUS ALBERTO MARTINEZ COUNTY, MARYLAND 4402 Oxford Street Garrett Park, Maryland 20896 ABBY HENDRIX CASE NO. 02-C-11-163050 9858 Ourtime Lane Columbia, Maryland 21045 KATHERINE ROSS-KELLER 6142 Newport Terrace Frederick, Maryland 21701 KIM SAMELE Murdock Road Towson, Maryland 212U CAMDEN DOUGLAS LEE 512 Silver Spring venue Silver Spring, Maryland 20910 CATHERINE BRENNAN 311 Murdock Road Baltimore, Maryland 21212 -and-* CASA MARYLAND 8151 lStb Ave. Hyattsville, Maryland 20783 Plaintiffs, MARYLAND STATE BOARD ELECTIONS 151 West Street Suite 200 Annapolis, Maryland 21401 JOHN MCDONOUGH his official capacity Secretary State Francis Street Annapolis, Maryland 21401 -and-* LINDA LAMONE her official capacity State Administrator Elections 151 West Street Annapolis, Maryland 21401 Defendants. AMENDED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF Pursuant Maryland Rule 2-341(a) Plaintiffs John Doe, Jane Doe, Jesus Alberto Martinez, Abby Hendrix, Katherine Ross-Keller, Kim Samele, Camden Douglas Lee Catherine Brennan and CASA Maryland, and through their attorneys, file this Amended Complaint for Declaratory and injunctive Relief against the Maryland State Boa.rd Elections (the 's determination and certification and will directly and specifically, and irreparably, injur.ed the Secretary State refers the Maryland DREAM Act referendlllll and. the voters not approve it. 17. Plaintiff Jane Doe currently resides Glen Burnie Maryland with her parents. She eighteen years old, has lived Maryland since she was seven years old and undocumented immigrant. She graduated from Baltimore City College (high school) June 2009, and trying earn and save enough money attend Baltimore City Community College ("BCCC"), where she wants begin her studies become nurse. she can attend BCCC, she plans apply University Maryland-College Park and ultimately train become nurse. Currently, she working the cafeteria another community college Maryland, effort eam and save enough attend BCCC. Her parents have filed Maryland income tax returns for the years 2008 through 2010, inclusive, and paid all ta,'