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IN THE UNITED STATES DISTRICT COURTFOR THE WESTERN DISTRICT OF WISCONSIN

CHELSEA TORRES and JESSAMYTORRES, individually and as next friends and

parents of A.T., a minor child,

Plaintiffs,

versus

KITTY RHOADES, in her officialcapacity as Secretary of the State of

Wisconsin Department of Health Services,

Defendant.

CASE NO. 15-cv-288

COMPLAINT FOR

DECLARATORY AND

INJUNCTIVE RELIEF

Plaintiffs CHELSEA TORRES (“Chelsea”) and JESSAMY TORRES

(“Jessamy”), individually and as next friends and parents of A.T., a minor child

(collectively, “Plaintiffs” or the “Torres family”), by and through their attorneys, file this

Complaint against Defendant KITTY RHOADES, in her official capacity as Secretary of

the Wisconsin Department of Health Services (“DHS”) and allege as follows:

INTRODUCTION

1. Chelsea and Jessamy are a legally married lesbian couple residing in

Madison, Wisconsin, in Dane County. Their infant son, A.T., was conceived through

anonymous donor insemination and born in Meriter Hospital in Madison, Wisconsin after

Chelsea’s marriage to Jessamy. Chelsea and Jessamy filled out the birth certificate

worksheet at the hospital, indicating on the form that they are married and that both are

A.T.’s parents. However, DHS has refused to provide A.T. with an accurate birth

certificate that identifies both Chelsea and Jessamy as his parents. Indeed, upon

information and belief, DHS has refused to provide any child born to same-sex spouses

an accurate birth certificate listing both spouses as parents absent a court order of

Case: 3:15-cv-00288 Document #: 2 Filed: 05/13/15 Page 1 of 12

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adoption or parentage—even though DHS routinely provides two-parent birth certificates

to all children born to different-sex spouses without requiring a court order, and without

any regard to how these children are conceived, or whether these children share a genetic

connection to both spouses.

2. The refusal by DHS to provide an accurate two-parent birth certificate to

A.T. and other children born to same-sex spouses deprives these children of the dignity,

legitimacy, security, support, and protections available upon birth to children of married

different-sex parents, and denies Chelsea, Jessamy, and other same-sex spouses who are

parents the privacy, dignity, security, support, and protections available to married

different-sex parents.

3. The refusal by DHS to provide a two-parent birth certificate to A.T. and

other children of same-sex spouses violates the equal protection guarantee of the United

States Constitution by discriminating against Chelsea, Jessamy, and other married same-

sex parents on the basis of their sexual orientation and sex, and against A.T. and other

children on the basis of their parents’ sex, sexual orientation, and status, all without

adequate justification.

4. The refusal also violates the due process guarantee of the United States

Constitution by unconstitutionally infringing on the liberty interests of each member of

the Torres family and other same-sex spouses and their children to family privacy,

integrity, and association, which includes the fundamental right to security in their legal

parent-child bonds. The refusal also violates the fundamental right to parental autonomy

shared by Chelsea, Jessamy, and other same-sex spouses who have children, including

their fundamental right to make decisions concerning whether and how to increase their

family, and decisions concerning the care, custody, and control of their children that are


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presumptively in their children’s best interests. The refusal by DHS to treat both same-

sex spouses as parents of children born to them after their marriage also violates these

spouses’ liberty interests shielded by the fundamental right to marry.

5. The Torres family now brings this action asking this Court to: (1) declare

that Defendant’s refusal to issue accurate two-parent birth certificates for children born to

same-sex spouses, including A.T., is unconstitutional; (2) enjoin Defendant from

continuing her policy, or custom and practice, of denying children born to same-sex

spouses birth certificates that list both spouses as the child’s parents; and (3) further order

Defendant immediately to issue a correct birth certificate to A.T. that lists both Chelsea

and Jessamy as his parents in reliance on Chelsea’s and Jessamy’s marriage.

JURISDICTION AND VENUE

6. Plaintiffs bring this action under 42 U.S.C. §§ 1983 and 1988 to redress

the deprivation of rights secured by the laws and the Constitution of the United States.

7. This Court has original jurisdiction over the subject matter of this action

pursuant to 28 U.S.C. § 1331 because the matters in controversy arise under the laws and

Constitution of the United States.

8. This Court has personal jurisdiction over Defendant because she is

domiciled in the State and/or has otherwise made and established contacts with the State

sufficient to permit the exercise of personal jurisdiction over her.

9. Venue is proper in the Western District of Wisconsin under 28 U.S.C.

§ 1391(b)(1) and (2) because Defendant resides in this district, and a substantial part of

the events that gave rise to Plaintiffs’ claims occurred in Madison, Wisconsin, in Dane

County.


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PARTIES

10. Plaintiffs Chelsea Andiar Torres, age 36, and Jessamy Flaherty Torres, age

35, both women, are spouses who reside in Madison, Dane County, Wisconsin. They

each appear individually and as parent and next friend of their son, Plaintiff A.T., a minor

child. Chelsea and Jessamy are harmed by the denial of a birth certificate to A.T. that

names both Chelsea and Jessamy as his parents.

11. Plaintiff A.T. sues through his parents and next friends, Plaintiffs Chelsea

and Jessamy Torres, who bring this action on behalf of A.T. because he is harmed by the

denial of a birth certificate naming both Chelsea and Jessamy as his parents.

12. Defendant Kitty Rhoades is sued in her official capacity as Secretary of

DHS. Defendant is a person within the meaning of 42 U.S.C. § 1983 and was acting

under color of state law at all times relevant to this Complaint. The Wisconsin Vital

Records Office, which is responsible for the filing, preserving, protecting, changing, and

issuing copies of birth certificates, is a unit of DHS and is controlled by Defendant.

STATEMENT OF FACTS

13. Chelsea and Jessamy Torres are a lesbian couple who have been friends

since 2001. They have been in a loving, committed relationship since 2010. They were

married on September 7, 2012, in New York, New York, in front of friends and family.

Jessamy is a deputy with the Dane County Sheriff’s Department, and Chelsea works for a

local cleaning company.

14. From the beginning of their relationship, Chelsea and Jessamy knew that

they wanted to be parents and have children together. In or around September 2013,

Chelsea and Jessamy began working with a fertility clinic in order for Chelsea to

conceive via assisted reproductive technology, which was ultimately successful. They


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both considered themselves and each other to be partners in the process, including with

respect to selection of the anonymous donor.

15. On or about March 13, 2015, Chelsea was admitted to Meriter Hospital in

Madison, Wisconsin to give birth. During the birth, there were complications, and

Jessamy watched as her wife hemorrhaged and her son turned blue due to lack of oxygen.

Jessamy was terrified that her wife and child would not survive. Fortunately, both

Chelsea and A.T. survived, though both were required to spend several days in the

hospital following the birth, and A.T. was placed in intensive care. Jessamy stayed at the

hospital throughout this period, moving between floors to help care for both her wife and

son.

16. On or about March 14, 2015, while at the hospital, Chelsea and Jessamy

filled out a DHS form for the purpose of obtaining a birth certificate for A.T. On the

form, Chelsea and Jessamy indicated that they are married and that both are parents to

A.T., and they supplied DHS with the requested information for both parents.

17. On March 30, 2015, Chelsea and Jessamy received a “Notification of

Birth Certificate Registration” from DHS that, without explanation, incorrectly omitted

all of Jessamy’s information and listed only Chelsea as A.T.’s parent. A copy of the

Notification is included as an exhibit to the attached Exhibit A.

18. On April 24, 2015, counsel for the Torres family sent a letter to Defendant

requesting confirmation within seven days of its receipt that DHS intends to issue a

correct birth certificate that accurately lists both Chelsea and Jessamy as A.T.’s parents.

A copy of the letter is attached hereto as Exhibit A.

19. On May 1, 2015, the Chief Legal Counsel for DHS wrote to counsel for

the Torres family stating that the “Vital Records Office . . . is evaluating the request and


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will respond when that evaluation is complete.” At the time of filing this Complaint, the

Torres family has not received a correct copy of A.T.’s birth certificate that lists both of

his parents.

20. Under Wisconsin law, a birth mother’s spouse is the presumed parent of a

child born during the marriage (hereafter termed the “spousal presumption of parentage”

or “spousal presumption”). Specifically, Wis. Stat. § 891.41(1)(a) states that a “man is

presumed to be the natural father of a child” if “he and the child’s natural mother are or

have been married to each other and the child is conceived or born after marriage and

before the granting of a decree of legal separation, annulment or divorce between the

parties.” The spousal presumption also applies to married couples who use assisted

reproductive technology. See Wis. Stat. § 891.40 (“If, under the supervision of a licensed

physician and with the consent of her husband, a wife is inseminated artificially with

semen donated by a man not her husband, the husband of the mother at the time of the

conception of the child shall be the natural father of a child conceived.”).

21. In accordance with the spousal presumption, Wis. Stat. § 69.14(1)(e)1

provides: “If the mother of a registrant under the this section was married at any time

from the conception to the birth of the registrant, the name of the husband of the mother

shall be entered on the birth certificate as the legal father of the registrant. The name of

the father entered under this subdivision may not be changed except by a proceeding

under ch. 767.”

22. Upon information and belief, and as required by Wis. Stat. § 69.14(1)(3)1,

DHS issues birth certificates to children born to married different-sex couples listing both

spouses as parents regardless of whether these children have a genetic connection to both

spouses. Thus, DHS issues two-parent birth certificates to children born to different-sex


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spouses even when the husband is not the child’s genetic parent because the couple

achieved pregnancy through use of donor insemination, or because the mother had

intercourse with a man other than her spouse.

23. Defendant’s refusal to provide the Torres family with an accurate birth

certificate for A.T. poses significant and ongoing harm to A.T. and his parents, Chelsea

and Jessamy, and renders the family vulnerable to future harm.

24. Without an accurate birth certificate, it is difficult if not impossible for the

Torres family to comply with legal identification requirements for A.T. Birth certificates

are vital to A.T.’s ability to obtain a Social Security card and a passport.1

25. When A.T. or his parents must produce a birth certificate to establish

Jessamy’s parental rights and Jessamy’s ability to take actions on A.T.’s behalf, such as

to enroll him in daycare or school or extracurricular activities (Wis. Stat. § 118.01 et seq.)

or authorize medical treatment (Wis. Stat. § 146.81(5)), they are unable to do so.

26. State agencies and employers often request birth certificates to enroll a

child for needed benefits. See, e.g., Wis. Stat. 632.885 (regarding health insurance for a

child through a parent’s employer-sponsored group plan). Recognition of a parent on a

birth certificate also provides for Social Security survivor benefits to the child in the

event of the parent’s death and provides inheritance to the child if a parent dies intestate.

See Social Security Administration, Benefits for Children, available at

http://www.ssa.gov/pubs/EN-05-10085.pdf.; Wis. Stat. § 852.05.

27. Birth certificates often are most essential when a family goes through

unforeseen family tragedies or crises. Indeed, during A.T.’s birth, Jessamy feared that

1See Social Security Administration, Learn What Documents You Need To Get A Social

Security Card , available at http://www.ssa.gov/ssnumber/ss5doc.htm; United States

Department of State, Passports for Minors Under 16 , available at

http://travel.state.gov/content/passports/english/passports/under-16.html.


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Chelsea might not survive, and that she would lose both her wife and her ability to

establish her parental rights with respect to her newborn son. Fortunately, the staff at

Meriter Hospital treated Jessamy as A.T.’s parent, but absent an accurate birth certificate,

she may not be as fortunate in future medical emergencies.

28. If a family falls on hard economic times, birth certificates may be required

to apply for benefits on behalf of the child. Moreover, if A.T. were to go missing or be

kidnapped, law enforcement agencies often require parents to produce a birth certificate

to report a missing child or secure his return.

29. If a couple’s marriage breaks down, birth certificates commonly are

necessary for a state agency to obtain delinquent child support.

30. Even if Chelsea and Jessamy can explain the discrepancies in the birth

certificate and establish Jessamy’s equal claim to exercise control over A.T.’s care and

custody, having to do so is likely to invade the privacy of the Torres family by revealing

which parent has a genetic connection to A.T., which is a fact that Plaintiffs may not wish

to share in all circumstances.

31. Defendant’s policy and practice of denying birth certificates to children

born to same-sex parents serves as an unjustified barrier to the ability of the Torres

family to exercise their rights stemming from their legal parent-child relationships by

making it more difficult for them to obtain the benefits and protections that families

whose children have married different-sex parents can more easily obtain.

32. Defendant’s discriminatory denial of an accurate birth certificate to A.T.

denies him the dignity, legitimacy, security, support, and protections available upon birth

to children of married different-sex parents, and denies Chelsea and Jessamy the privacy,

dignity, security, support, and protections available to married different-sex parents.


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There is no justification, let alone a constitutionally adequate one, for imposing these

harms on the Torres family.

CLAIMS FOR RELIEF

COUNT IDeprivation of Equal Protection

U.S. CONST. Amend. XIV

(42 U.S.C. § 1983)

33. Plaintiffs incorporate by reference and re-allege all of the preceding

paragraphs of this Complaint as though fully set forth herein.

34. Plaintiffs state this cause of action against Defendant in her official

capacity for purposes of seeking declaratory and injunctive relief.

35. The Fourteenth Amendment to the United States Constitution, enforceable

pursuant to 42 U.S.C. § 1983, provides that no state shall “deny to any person within its

jurisdiction the equal protection of the laws.” U.S. Const. amend. XIV, § 1.

36. Defendant’s refusal to apply the spousal presumption of parentage to

same-sex spouses and accordingly to issue two-parent birth certificates to children born

to same-sex spouses discriminates against Chelsea and Jessamy on the basis of both their

sex and sexual orientation without even a rational justification let alone the required

compelling showing that the overall societal benefits of the discrimination clearly

outweigh the harms inflicted upon its victims.

37. Defendant’s refusal to provide an accurate two-parent birth certificate to

A.T. harms him by incorrectly labeling him the child of an unwed parent, depriving him

of access to immediate, clear proof of his relationship to both of his parents and the

security that comes with having two parents on his birth certificate. The denial of an

accurate birth certificate to children born to same-sex spouses discriminates against such

children on the basis of their parents’ status as a same-sex couple, and their parents’ sex


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and sexual orientation. There is not even a rational, let alone important, justification for

such discrimination.

COUNT II

Deprivation of Due Process

U.S. CONST. Amend. XIV(42 U.S.C. § 1983)

38. Plaintiffs incorporate by reference and re-allege all of the preceding

paragraphs of this Complaint as though fully set forth herein.

39. Plaintiffs state this cause of action against Defendant in her official

capacity for purposes of seeking declaratory and injunctive relief.

40. The Fourteenth Amendment to the United States Constitution, enforceable

pursuant to 42 U.S.C. § 1983, provides that no state shall “deprive any person of life,

liberty, or property, without due process of law.” U.S. Const. amend. XIV, § 1.

41. The Torres family has a liberty interest in their family privacy, integrity,

and association, which includes the fundamental right to security in their legal parent-

child bonds. Moreover, Chelsea and Jessamy have a protected liberty interest in their

parental autonomy, including the fundamental right to make decisions concerning

whether and how to increase their family, and concerning the care, custody, and control

of their child, A.T., that are presumptively in his best interests.

42. By refusing to issue A.T. a birth certificate that correctly identifies both

Chelsea and Jessamy as his parents, Defendant is unconstitutionally infringing on those

liberty interests and depriving the Torres family of the single most important identity

document necessary to demonstrate their familial relationship to A.T.

43. The interest of parents in the care, custody, and control of their children is

deeply intertwined with the fundamental right to marry. Wisconsin’s spousal presumption

of parentage is a benefit of marriage that protects a marital child and his or her bonds to


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and right of support from both parents. By declining to apply the spousal presumption of

parentage to children born to same-sex spouses, and depriving these families of accurate

two-parent birth certificates, Defendant not only has infringed impermissibly on same-

sex spouses’ fundamental parental interests, but also upon their fundamental liberty

interests in their existing marriage.

44. There is no constitutionally adequate basis for Wisconsin’s decision to

infringe on the fundamental rights of same-sex parents, let alone an interest that can

survive the elevated scrutiny required to justify infringement of these fundamental rights.

PRAYER FOR RELIEF

WHEREFORE, Plaintiffs respectfully request that this Court enter judgment:

A. Declaring that Defendant’s refusal to issue a birth certificate to A.T. on the

same terms as to children of married different-sex parents violates all Plaintiffs’

guarantees of equal protection under the Constitution of the United States;

B. Declaring that Wis. Stat. §§ 69.14(1)(e)1, 891.40(1), and 891.41(1)(a) are

invalid and unconstitutional as written and are henceforth to be construed in a gender-

neutral manner to require application of the spousal presumption of parentage to same-

sex couples and issuance of two-parent birth certificates to same-sex spouses

accordingly;

C. Declaring that Defendant’s refusal to issue a birth certificate to A.T. that

names both Chelsea and Jessamy as his parents violates all Plaintiffs’ rights under the

Due Process Clause of the Constitution of the United States;

D. Enjoining Defendant from continuing to enforce her policy, or custom and

practice, of denying to children born to same-sex spouses birth certificates that list both

spouses as the child’s parents;


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E. Ordering Defendant to immediately issue a correct birth certificate to

A.T. that lists both Chelsea and Jessamy as his parents in reliance on Chelsea’s and

Jessamy’s marriage;

F. Awarding Plaintiffs costs, expenses, and reasonable attorneys’ fees

pursuant to, inter alia, 42 U.S.C. § 1988 and other applicable laws; and,

G. Granting such other and further relief as the Court deems just and proper.

DATED: May 13, 2015 Respectfully submitted,

/s/ Clearesia A. Lovell-Lepak Tamara B. Packard Clearesia A. Lovell-Lepak

Cullen Weston Pines & Bach LLP Lovell-Lepak Law Office

122 West Washington Avenue, Suite 900 Post Office Box #44623Madison, Wisconsin 53703 Madison, Wisconsin 53744(608) 251-0101 (800) 216-3921

[email protected] [email protected]

Kyle A. Palazzolo*

Camilla B. Taylor*

Christopher R. Clark*Lambda Legal Defense and Education Fund,

Inc.

105 W. Adams, Ste. 2600

Chicago, Illinois 60603(312) 663-4413

* Motions for admission [email protected]

pro hac vice pending [email protected]@lambdalegal.org

ATTORNEYS FOR PLAINTIFFS


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S 44 (Rev. ) CIVIL COVER SHEETThe JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as pr

y local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the purpose of inhe civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)

. (a) PLAINTIFFS DEFENDANTS

(b) County of Residence of First Listed Plaintiff County of Residence of First Listed Defendant(EXCEPT IN U.S. PLAINTIFF CASES) (IN U.S. PLAINTIFF CASES ONLY)

NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATIONTHE TRACT OF LAND INVOLVED.

(c) Attorneys (Firm Name, Address, and Telephone Number) Attorneys (If Known)

I. BASIS OF JURISDICTION (Place an “X” in One Box Only) III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an “X” in One Box for (For Diversity Cases Only) and One Box for Defendant

1 U.S. Government 3 Federal Question PTF DEF PTF D

Plaintiff (U.S. Government Not a Party) Citizen of This State 1 1 Incorporated or Principal Place 4

of Business In This State

2 U.S. Government 4 Diversity Citizen of Another State 2 2 Incorporated and Principal Place 5

Defendant (Indicate Citizenship of Parties in Item III) of Business In Another State

Citizen or Subject of a 3 3 Foreign Nation 6

Foreign Country

V. NATURE OF SUIT (Place an “X” in One Box Only)CONTRACT TORTS FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTE

110 Insurance PERSONAL INJURY PERSONAL INJURY 625 Drug Related Seizure 422 Appeal 28 USC 158 375 False Claims Act

120 Marine 310 Airplane 365 Personal Injury - of Property 21 USC 881 423 Withdrawal 400 State Reapportionm

130 Miller Act 315 Airplane Product Product Liability 690 Other 28 USC 157 410 Antitrust

140 Negotiable Instrument Liability 367 Health Care/ 430 Banks and Banking

150 Recovery of Overpayment 320 Assault, Libel & Pharmaceutical PROPERTY RIGHTS 450 Commerce

& Enforcement of Judgment Slander Personal Injury 820 Copyrights 460 Deportation

151 Medicare Act 330 Federal Employers’ Product Liability 830 Patent 470 Racketeer Influence

152 Recovery of Defaulted Liability 368 Asbestos Personal 840 Trademark Corrupt Organizatio

Student Loans 340 Marine Injury Product 480 Consumer Credit

(Excl. Veterans) 345 Marine Product Liability LABOR SOCIAL SECURITY 490 Cable/Sat TV

153 Recovery of Overpayment Liabili ty PERSONAL PROPERTY 710 Fair Labor Standards 861 HIA (1395ff) 850 Securities/Commod

of Veteran’s Benefits 350 Motor Vehicle 370 Other Fraud Act 862 Black Lung (923) Exchange

160 Stockholders’ Suits 355 Motor Vehicle 371 Truth in Lending 720 Labor/Mgmt. Relations 863 DIWC/DIWW (405(g)) 890 Other Statutory Acti

190 Other Contract Product Liability 380 Other Personal 740 Railway Labor Act 864 SSID Title XVI 891 Agricultural Acts

195 Contract Product Liability 360 Other Personal Property Damage 751 Family and Medical 865 RSI (405(g)) 893 Environmental Matt

196 Franchise Injury 385 Property Damage Leave Act 895 Freedom of Informa

362 Personal Injury - Product Liability 790 Other Labor Litigation Act Med. Malpractice 791 Empl. Ret. Inc. 896 Arbitration

REAL PROPERTY CIVIL RIGHTS PRISONER PETITIONS Security Act FEDERAL TAX SUITS 899 Administrative Proc

210 Land Condemnation 440 Other Civil Rights 510 Motions to Vacate 870 Taxes (U.S. Plaintiff Act/Review or Appe

220 Foreclosure 441 Voting Sentence or Defendant) Agency Decision

230 Rent Lease & Ejectment 442 Employment Habeas Corpus: 871 IRS—Third Party 950 Constitutionality of

240 Torts to Land 443 Housing/ 530 General 26 USC 7609 State Statutes

245 Tort Product Liability Accommodations 535 Death Penalty IMMIGRATION

290 All Other Real Property 445 Amer. w/Disabilities - 540 Mandamus & Other 462 Naturalization Application

Employment 550 Civil Rights 463 Habeas Corpus -

446 Amer. w/Disabilities - 555 Prison Condition Alien Detainee

Other 560 Civil Detainee - (Prisoner Petition)

448 Education Conditions of 465 Other Immigration

Confinement Actions

V. ORIGINTransferred fromanother district(specify)

(Place an “X” in One Box Only)

1 OriginalProceeding

2 Removed fromState Court

3 Remanded fromAppellate Court

4 Reinstated or Reopened

5 6 MultidistrictLitigation

VI. CAUSE OF ACTION

Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity ):

Brief description of cause:

VII. REQUESTED IN

COMPLAINT:

CHECK IF THIS IS A CLASS ACTION

UNDER F.R.C.P. 23

DEMAND $ CHECK YES only if demanded in complaint

JURY DEMAND: Yes No

VIII. RELATED CASE(S)

IF ANY(See instructions):

JUDGE DOCKET NUMBER

DATE SIGNATURE OF ATTORNEY OF RECORD

FOR OFFICE USE ONLY

RECEIPT # AMOUNT APPLYING IFP JUDGE MAG. JUDGE

Declaratory and Injunctive Relief

CHELSEA TORRES and JESSAMY TORRES, individually and as nextriends and parents of A.T., a minor child

DANE

see attachment)

KITTY RHOADES, in her official capacity as Secretary of the StaWisconsin Department of Health Services

DANE

Attorney Sandra M. Rowe, Chief Legal Counsel, WisconsinDepartment of Health Services, 1 W Wilson St Ste 651, PO Box Madison WI 53707-7850

42 U.S.C. §§ 1983 and 1988

Const. challenge to DHS's refusal to provide two-parent birth certificates to children born to same-sex spouse

05/13/2015 /s/ Clearesia A. Lovell-Lepak

Case: 3:15-cv-00288-bbc Document #: 2-1 Filed: 05/13/15 Page 1 of 2

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Attachment to

CIVIL COVER SHEET

I. (c) Attorneys for Plaintiffs

Clearesia A. Lovell-Lepak

Lovell-Lepak Law Office

P.O. Box 44623

Madison, Wisconsin 53744

(800) 216-3921

Kyle A. Palazzolo*

Camilla B. Taylor*

Christopher R. Clark*

Lambda Legal Defense and Education Fund, Inc.105 W. Adams, Ste. 2600

Chicago, Illinois 60603

(312) 663-4413

Tamara B. Packard

Cullen Weston Pines & Bach LLP

122 West Washington Avenue, Suite 900

Madison, Wisconsin 53703

(608) 807-0752

*Motions for admission pro hac vice pending


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