UNITED STATES DISTRICT COURT

FOR THE MIDDLE DISTRICT OF ALABAMA

PAUL HARD,

Plaintiff,

v.

ROBERT BENTLEY, in his official capacity as
Governor of the State of Alabama; LUTHER
JOHNSON STRANGE, III, in his official capacity
as Attorney General of the State of Alabama; PAT
FANCHER;

Defendants.





Civil Action No. 2:13-cv-922-WKW






SUPPLEMENT TO PLAINTIFFS OPPOSITION TO GOVERNOR BENTLEYS
MOTION TO DISMISS ON THE BASIS THAT HE PURPORTEDLY HAS NO
AUTHORITY IN CONNECTION WITH ALABAMAS MARRIAGE RESTRICTIONS

State Defendants Motion to Dismiss the Claims Against Governor Bentley (ECF No. 48)
remains pending with the Court. The factual basis for that motion is that Defendant Bentley lacks
authority to enforce the Sanctity Laws, which are challenged by the above-captioned matter. But
that is contradicted by the Governors own public statements as recently as two days ago. Last
Friday he is quoted as pledging that he will continue to enforce the Sanctity Laws: I believe
thats what our constitution says [referring to the Sanctity Laws] . . . My job is to uphold the laws
of this state and that is what I will do.
1
Plaintiff respectfully renews its request (ECF No. 53) for
the Court to deny the Motion to Dismiss.
October 13, 2014


1
Bentley says he will uphold Ala. same sex marriage ban, WAFF.COM,
http://m.waff.com/waff/db/330702/content/IjSGRpbU (Oct. 10, 2014). A true and correct copy is
attached hereto as Ex. A.

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Respectfully submitted,

SOUTHERN POVERTY LAW CENTER

By: /s/ David C. Dinielli

David C. Dinielli* (California Bar No. 177904)
Samuel Wolfe (ASB-2945-E63W)
400 Washington Avenue
Montgomery, Alabama 36104
Telephone: (334) 956-8200
Facsimile: (334) 856-8481
david.dinielli@splcenter.org
sam.wolfe@splcenter.org
*Admitted pro hac vice

(Attorneys for Plaintiff)

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CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 13th day of October, 2014, I electronically filed the
foregoing document with the Clerk of the Court using the CM/ECF system which will send
notification of such filing to the following counsel of record:
David Bryson Byrne, Jr., Esq.
Office of the Governor
State Capitol
600 Dexter Avenue
Suite NB-05
Montgomery, AL 36130

James William Davis, Esq.
Laura Elizabeth Howell, Esq.
State of Alabama
Office of the Attorney General
501 Washington Avenue
Montgomery, AL 36130

Gabriel Joseph Smith, Esq.
Foundation For Moral Law
1 Dexter Avenue
Opelika, AL 36103




/s/Samuel Wolfe

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EXHIBIT A



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