Declaration of Donald Mulder
Pursuant to 28 U.S.C § 1746, I certify under penalty of perjury that the following
statements are true and correct:
1.

My name is Donald Mulder. I am 52 years old. I was convicted in Wisconsin in

2005 of a sex-related crime. As a result of my conviction, I am required to register as a sex
offender for life and am classified as a “Designated Offender” under Chapter 106-51 of the
Milwaukee Code of Ordinances.
2.

At the time I committed my offense, I lived in Greenfield, Wisconsin.

3.

I currently live in a single room at 822 N. 24th Street, Milwaukee, Wisconsin,

where I have lived since November of 2013. I pay $400 per month to rent my room there.
4.

I am married to Morgana Bowne. We are both veterans of the U.S. armed forces.

We want to live together in Milwaukee, but we are currently forced to live separately. This is
because my wife cannot move into my current residence because it is too small for two people to
live in and because the residence is located in a geographic area that is too dangerous and
undesirable.
6.

At the same time, the original domicile provision of the Ordinance prevents me

from living anywhere else in Milwaukee.
7.

In addition, my wife and I have not been able to find any alternate housing in

Milwaukee that is compliant with the challenged Ordinance
8.

We have investigated every one of the addresses on the formal list published by

the City of Milwaukee identifying compliant addresses, but not a single address on the list was
available to rent.
9.

Among other things, we discovered that an area on the City’s official map

 indicating where Designated Offenders are allowed to live is actually the location of the
Milwaukee Airport.
10.

My wife lives in Glendale, Wisconsin, but I cannot move to her home because

Glendale, like many of the communities in Milwaukee County, imposes an “original domicile”
restriction that prohibits individuals convicted of sex offenses from moving to the community if
they did not live there at the time of their offense.
11.

The Wisconsin Department of Corrections has told me that I am prohibited from

living in the City of Greenfield, which is where I lived at the time of his offense, due to my
victim living there.

8-1-17
5-13-17
Date: _________________

__________________________________________
Donald Mulder