Sounds like a similar Declaration I presented to Eric Holder and my State Execs. We wrote this whil in a TX DOJ facility. It was written by one of the head lawyers for the MCI/WorldCom debacle. I sent it in and got nothing but nasty replies from all the County and State as well as City agencies that were the Defendants.
My County tried to tell me how much money it was going to cost me… literally a scare tactic. I spent considerable time assessing whether or not to move forward and finally filed for a Motion to Dismiss. The environment just was not ready. This was 2008. I have a copy of it still online. I was ho[ping someone else would approach the unconstitutionality of the Registry from any level, beit Federal or State. If you look closely at your State Constitutions you will find plenty to go on.
The jurisdiction thing is a scapegoat for the courts. They will use it faster than lighting just to get the case off their desk.
I am so glad NARSOL and friends are moving forward with this. It is about the Constitution 100%. You can discount the fact that there are just too many wrong factors that are associated with the registry and no one out side of the peeps that are on the registry want to admit it.
I am also thrilled that the judgment also includes the registrants’ families as part of the pain and suffering inflicted which validates the registry as punitive. WomenAgainstRegisty has a strong lead on this approach and my feelings are that this is one of the few angles of which a judge and jury would look close enough at to see where the pain and suffering is effecting more than just the single registrant.
Keep up the good work. My 42 U.S.C. § 1983 Complaint For Declaratory and Injunctive Relief is here for those who want to read/use it: http://sexoffense.org/243-2/