United States of America v. Arizona, State of, et al
Filing
64
Additional Attachments to Main Document re 63 Lodged Proposed Document Index - Exhibit P by Defendants Arizona, State of, Janice K Brewer. (Attachments: # 1 Exhibit Q-Y, # 2 Exhibit Z, 1, 2, # 3 Exhibit 3-8, # 4 Exhibit 9-33, # 5 Exhibit 34-41)(Bouma, John)
United States of America v. Arizona, State of, et al
Doc. 64
GOVERNOR BREWER AND THE STATE OF ARIZONA'S
RESPONSE TO MOTION FOR PRELIMINARY INJUNCTION EXHIBIT INDEX Tab # A. B. C. D. E. F. G. H. I. J. K. L. M. N. O. P. Q. R. S. T. U. Declaration of Michael Cutler Declaration of Neville Cramer Declaration of Jessica Vaughn Declaration of Jeffery Kirkham Declaration of Brendan P. Doherty Declaration of Jose Vasquez Declaration of Brandon L. Judd Declaration of Nate Gafvert Declaration of Margie Emmermann Declaration of Dan Glover Declaration of Bret Glidewell Declaration of H. Michael Donly Declaration of Wendy Glenn Declaration of Gary Thrasher Declaration of Ryan Smith Declaration of Otto Reich Declaration of Thomas Streed Declaration of James Switzer Declaration of Jennifer McGlone Declaration of Tom Tardy Declaration of Franklin Marino Exhibit Description
Dockets.Justia.com
Tab # V. W. X. Y. Z. 1. Declaration of Levi Bolton Affidavit of George Borjas
Exhibit Description
Declaration of Jayson P. Ahern Declaration of Larry Dever Declaration of Joseph G. Adams Homeland Security: Challenges to Implementing the Immigration, Testimony before the H. Subcomm. on Immigration, Border Sec. and Claims of the H. Comm. on the Judiciary, 108th Cong. (2003) (Statement of Richard M. Stana, Director Homeland Sec. and Justice) Alison Siskin, Cong. Research Serv. RL33351, CRS Report for Congress Immigration Enforcement Within the United States 1, 14 (2006). U.S. Department of Justice, Office of the Inspector general, Audit Division, Audit Report 07-07, Cooperation of SCAAP Recipients In the Removal of Criminal Aliens From the United States ___(2007). Bybee, J.S., Memorandum for the Attorney General Re Non-preemption of the authority of state and local law enforcement officials to arrest aliens for immigration violations (April 3, 2002). U.S. Immigration and Customs Enforcement, M-396, Guide to Selected U.S. Travel and Identity Documents (2008). U.S. Immigration and Customs Enforcement, Law Enforcement Support Center Fact Sheet. U.S. Customs and Border Protection, Community Informational (July 8, 2010). Enhancing DHS' Efforts to Disrupt Alien Smuggling Across Our Borders, Testimony before the Subcommittee, 111th Congress (2010) Statement of Janice Kephart, Director of National Security Center for Immigration Studies). Letter from John M. Roll, Chief Judge, Arizona District Court, to Congressional Staff Members (June 3, 2010).
2. 3.
4.
5. 6. 7. 8.
9.
10. Letter from Janet Napolitano, Governor of Arizona, to Donald Rumsfeld, Secretary, Department of Defense (Dec. 30, 2005). 11. Letter from Janet Napolitano, Governor of Arizona, to Donald Rumsfeld, Secretary, Department of Defense, and Michael Chertoff, Secretary, Department of Homeland Security (Mar. 7, 2006).
Tab #
Exhibit Description
12. Letter from Janet Napolitano, Governor of Arizona, to Michael Chertoff, Secretary, Department of Homeland Security (Mar. 11, 2008). 13. Letter from Janice K. Brewer, Governor of Arizona, to President Barack Obama (June 23, 2010). 14. Letter from Dean Martin, Treasurer of Arizona, to Janet Napolitano, Secretary of Homeland Security (Jan. 4, 2010). 15. Statement by Senators John McCain and John Kyl Regarding National Guard Troops on the Southwest Border (May 25, 2010). 16. Arizona Senators Respond to Obama Administration Decision to Sue Arizona (July 6, 2010). 17. President Barack Obama, Remarks by the President on Comprehensive Immigration Reform (July 1, 2010). 18. Letter from Arizona Senator John McCain and Jon Kyl to Michael H. Posner Assistant Secretary of State, Bureau of Democracy, Human Rights, and Labor, U.S. Department of State (May 18, 2010). 19. Article with video of interview with P.J. Crowley, Assistant Secretary of State. 20. FOXNews.com, Napolitano Admits She Hasn't Read Arizona Immigration Law in "Detail," (May 18, 2010). 21. ABC.com, Holder: Arizona Immigration Law Not Racist (May 9, 2010). 22. Devin Dwyer & Huma Khan, Arizona's Governor Signs Controversial Immigration Bill (April 23, 2010). 23. Testimony of Larry A. Dever, Sheriff, Cochise County, Arizona, Senate Committee on Homeland Security and Governmental Affairs (Apr. 20, 2009). 24. Chad C. Haddal, Cong. Research Serv., RS 21899, Border Security: Key Agencies and Their Missions 3 (2010). 25. Maricopa County Attorney's Office, Illegal Immigration (Sept. 2008). 26. Michael Hoefer, Nancy Rytina, & Bryan C. Baker, Estimates of the Unauthorized Immigrant Population Residing in the United States: January 2009, Department of Homeland Security (Jan. 2010). 27. Letter from Terry Goddard, Arizona Attorney General, to President Barack Obama (July 8, 2010). 28. Excerpts of transcript of the Senate Public Safety and Human Services Committee
Tab # Hearing, January 20, 2010.
Exhibit Description
29. Excerpts of transcript of the Senate vote on SB 1070 by the Arizona 49th Legislature, Second Regular Session, Apr. 19, 2010. 30. Bureau of Land Management- Southern Arizona Project FY 2009 Fact Sheet. 31. U.S. Customs and Border Protection, Community Informational (June 24, 2010). 32. Bureau of Land Management, Southern Arizona Project to Mitigate Environmental Damages Resulting from Illegal Immigration, Fiscal Year 2008 Year-End Report 33. Majority Staff of H. Comm. On Homeland Sec., A Line in the Sand, Confronting the Threat at the Southwest Border (2006). 34. Excerpts of transcript of Minutes of House Committee on Military Affairs and Public Safety re SB 1070, 49th Legislature, Second Regular Session, March 31, 2010. 35. Arizona Peace Officer Standards & Training Board Support Law Enforcement and Safe Neighborhoods Act Training Course, transcript of DVD. 36. Excerpts of transcript of the Senate Public Safety and Human Services Committee Hearing, Arizona 49th Legislature, Second Regular Session, Jan. 21, 2010. 37. Hillary Clinton Migrates into Arizona law Controversy (May 2, 2010) 38. Support Our Law Enforcement and Safe Neighborhoods Act: Hearing on S.B.1070 Before the S. Comm. on Pub. Safety and Human Servs., 49th Leg. 2d Reg. Sess., 2 (Ariz. 2010). 39. Support Our Law Enforcement and Safe Neighborhoods Act: Hearing on S.B. 1070 Before the H. Comm. on Military Affairs and Pub. Safety, 49th Leg. 2d Reg. Sess., 1-8 (Ariz. 2010) 40. Message from Sen. Russell Pearce (March 24, 2010) 41. Certified copies of selected Arizona Peace Officer Standards And Training Board 585 - Hour Basic Curriculum Model Lesson Plans.
11760985.1
EXHIBIT A
EXHIBIT B
EXHIBIT C
EXHIBIT D
EXHIBIT E
EXHIBIT F
EXHIBIT G
EXHIBIT H
EXHIBIT I
EXHIBIT J
EXHIBIT K
EXHIBIT L
EXHIBIT M
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(#001358) Robert A. Heny (#015104) Joseph G. Adams (#018210)
John.1. Bouma
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SNELL & WILMER U..l'. One Arizona C~nter 400 E. Van Buren
Phoenix. AZ 85004-2202
PhoDe: (602) 382-6000 Fmc (602) 382-6070 jbouma(p)swlaw.com
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bhenr(aswlaw.com
jgadms(0swlaw.co:m
Joseh A. Kacfield (#015838)
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Otlicc of Govcrnor .Janice K. Brewer
1700 W. Washington. 9t Floor
Phoenix, AZ 85007 Telephone: (602) 542-1586
Fa.x: (602) 542-7602
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Altorney.'fnr InJC:twinor Defendants Janice K. ßrewer. the. Siate alArizona. and the Siate '?lAriz(ma Governor of
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IN THF UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF ARIZONA
Friendly Hou!;~, ct at
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No. CV-10-1061-PHX-SRß
Plaintiffs.
v.
DECLARTION OF W.~NDY GLENN
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Michael B. Whiting, Apachc County Attorney, in his offcial capcity, ct aI.,
Defendants,
and
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Janice K. Brewer, Goycrnorofthe State of Arizuna, in her official capacity; and the Statc of Arizona,
Intervenor DeH..-ndant-;.
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DECLARATION OF WENDY GLENN
T, Wendy Glenn, declare as follows:
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the matters set forth
I make this dcel&ation based upon roy peronal knowledge of
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below. 1 f called upon to do so, 1 cøuld and wcu'd tcsti-r (joropctently thereto. live on a ranch east of Douglas, Arizona. 1. My husband. Warer Glcnn, and i
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and we were both born and raised in the Douglas, area. In fact. my grandfather was onc of
the founders of Douglas.
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2. My husband and 1 own a ranch along the Arizona ~tate border with Mexico. just afer we were
3. We have owned our ranch for 50 years. We bought it
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ma1Ti~d in 1960.
4. Our ranch i:i located approximately 18 miles from Douglas, Ariona. Our
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nearest neighbor is about 5 miles away.
5. We ranch 15.000 acr~s, which is approximately 23 square rnilc:;. border fence with Mexico. 6. Our ranch includL"S four miles or
7 . Ahout 8 or 9 years ago, we noliced an increase in the amount of root traffic
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across our rach propert. It has gotten much worse in the last 5 years.
8. Wc believe that thesc people are ilegally crossing the border from Mexico
into the United States.
9. In the bcginning~ W~ saw less than 10 people a month erossing though our
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land.
10. At that time, we understood that these individuals were i1egal workers
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crossing the border headed Cor their jobs in Ari7.ona.
i 1.. The number of unlawful immigrants erossin.g the ranch inereascd
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significantly about 5 years ago.
) 2. Now we estimate that at times, 500 to 800 people a week cross into our
ranch from Mexico.
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13. The presence of so many people walking across our land has lcd 'to serious
environmental problems 00 the rach.
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trash, including
14. For exainplc~ the ilegal immigrants leave large amounts or
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food, empty cans, medication, pla'\tic bags, clothing and water bottles. We regularly have
to clean up this trash.
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15. llegal immigrants cut water pipelines in our valley, to acccl)~ fresh water, H
is expensive to continually replace the pipelines and the water is wasted out on the
ground.
16. l1egal immigrants usc our water trough to wash clothing and bathe. This
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creates serious health issues for our cattle.
17. Tlegal immigrants create trails acro~s our ranch. i estimate that there aN
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about 10 trails coming north that come through the four-milc southern bordcr ofthc ranch.
18. llegal immigrants leave gates open and cut fences, sometimes letting our
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cattle out.
19. llcgal îmm1granL'; scare our caltle. causing the animals to run long distance:-
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tn fright causing stress. Stress causes the animals to lose weight, threatening thcir health.
20. Ilegal immigrnts regularly dcfecate on our property, ollen ncar our
~pdngs. This can foul the water, is unsanitary, and can lead to health problem!;.
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21. About 1 5 times a year. ilegal immigrants come to the ranch house ror
help'-(1ì:cn needing loodand medical assistance. When this happens, my husband or 1
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wil call the Border Patrol. Border PatTol agents wil come pick up the ilegal immigrants.
22. Lfthe situation warrants it, the Border Patrol wil call an ambulance for
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those who are seriously îl or injured.
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23. One time~ a woman had a baby in a pasture about 3 miles from our house. the way to the house for
She. her husband caring the baby and her brother walked all
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her. They sent an ambulance.
help. We called the Border Patrol to take care of
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24. We found a dead body last year in a pasture on the ranch. marjuana in pastures on the ranch.
25. We have found bundles of
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2K
26. Although our home has not been robbed. or experienced other violencc, we
have had solar panels stolen from one of our wells, and we live wíth the theat ofvio1cnce
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daily. Many other nearby ranchers that we know havc been victims olviolencc by ilegal
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3 27. Increased Border Patrol enforcement can have a positivc effect on the
4 numbers ofilcgalimmigrant.~ crossi.ng our ranch. But, as soon as the level of
5 enforcement drops~ th~ number of 1lcgal immigninis who cross the border and througb
6 our ranch increases again.
7 28. The issues that my husband and I face on the ranch every day are serious.
8 We spend a huge amount oftimc attempting to address the problems that illegal
9 immigrntli cause here. There have been Chinese. Pakistani~ Yemcncsc, South Amcncan
1.0 and other foreign groups tòund in our area.
11 29. T believe that the State of Arizona has a rei:ponsibilty to tr to solve these
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problems by cnfordílg the law.
30. I do not believe that the tcdcnil government is doing enough to protect our
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border.
31. 1 believe that Sß 1070 williavc a positive impact on the situat.ion at our
ranch.
32. 1 am appreciative fum by passing Sß 1070, Arizona is finally trying to help
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1 declare under penalty ofpcrjury that the foregoing is true and correct.
DATED July 8. 2010
Cochise County, Arizona.
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By
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Wendy
Glenn -T
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EXHIBIT N
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LAW OFFICES One Arizona Center, 400 E. Van Buren Phoenix, Arizona 85004-2202 (602) 382-6000
John J. Bouma (#001358) Robert A. Henry (#015104) Joseph G. Adams (#018210) SNELL & WILMER L.L.P. One Arizona Center 400 E. Van Buren Phoenix, AZ 85004-2202 Phone: (602) 382-6000 Fax: (602) 382-6070 jbouma@swlaw.com bhenry@swlaw.com jgadams@swlaw.com Joseph A. Kanefield (#015838) Office of Governor Janice K. Brewer 1700 W. Washington, 9th Floor Phoenix, AZ 85007 Telephone: (602) 542-1586 Fax: (602) 542-7602 jkanefield@az.gov Attorneys for Intervenor Defendants Janice K. Brewer, Governor of the State of Arizona, and the State of Arizona IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA Friendly House, et al. Plaintiffs, v. Michael B. Whiting, Apache County Attorney, in his official capacity, et al., Defendants, and Janice K. Brewer, Governor of the State of Arizona, in her official capacity; and the State of Arizona, Intervenor Defendants. No. CV-10-1061-PHX-SRB DECLARATION OF GARY A. THRASHER
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Snell & Wilmer L.L.P.
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LAW OFFICES One Arizona Center, 400 E. Van Buren Phoenix, Arizona 85004-2202 (602) 382-6000
DECLARATION OF GARY A. THRASHER I, Gary A. Thrasher, declare as follows: I make this declaration based upon my personal knowledge of the matters set forth below. If called upon to do so, I could and would testify competently thereto. 1. I am Gary A. Thrasher, a veterinarian who limits his practice to care for
cattle and horses at ranches in Arizona, New Mexico and Texas. 2. I live approximately 4 miles north of the U.S./Mexico international
boundary in Sothern Arizona, have a ranch operation 10 miles north of the border and also operate a cattle "stockyard/feedlot" in Cochise, Arizona. 3. I have many ranch clients that I am frequently called upon to service along
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more than 200 miles of the U.S./Mexico border in Arizona. 4. I've lived and worked out of my office, "Hereford Veterinary Service" in
Snell & Wilmer L.L.P.
Palominas for 25 years, after first coming to Southern Arizona in 1971. From 1992 through 2005, I also owned and operated "Servicios Veterinarios Asociados, Hereford, S.C.", a Mexican chartered corporation that processed cattle at ranches in Mexico for export to the U.S. 5. My travels and work along the U.S. border has given me a unique
perspective on our changing border situation from both sides of the border. 6. While our international boundary has always been porous, until 1996 it was
only a tolerable nuisance for remote rural ranchers, after 1996 it has become progressively more intolerable, uncontrolled, threatening, and violent. 7. I see firsthand the increasing degradation of the environment, losses of
livestock due to trash left behind by trespassers and vehicle chases, the unnecessary and willful destruction of private property, and intimidation of remote rural Arizona residents.
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LAW OFFICES One Arizona Center, 400 E. Van Buren Phoenix, Arizona 85004-2202 (602) 382-6000
8.
I hear, on a regular basis, the ranchers' reports of break-ins, home invasions,
vehicle thefts, and immigrant deaths on their property. 9. I've personally been confronted by large groups of illegal immigrants
demanding transportation to Tucson and Phoenix. 10. I've stopped to help some of those posing to need help only to be threatened
if I didn't help what turn out to be "coyote guides" returning to Mexico to guide their next group of illegal immigrants or drug "back-packers." 11. I've been run-off remote rural roads by high-speed vehicles trying to get
stolen vehicles back into Mexico and vehicles loaded with illegal immigrants and/or illegal drugs trying to pass into the U.S. without detection. 12. I've helped with numerous traffic fatality wrecks on interior Arizona roads
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Snell & Wilmer L.L.P.
caused by people with vehicles overloaded with illegal aliens trying to "outrun" local law enforcement trying to stop traffic offence violators. Some of those deaths and serious injuries were U.S. citizens just going about their daily lives. 13. Those of us who live and work in the remote stretches of Arizona
ranchlands had been predicting that it was only a matter of time before one of us or our immediate families would be seriously hurt or killed by the "type" of people now controlling the illegal immigrant trade and passing, wave after wave through our ranches. 14. Then Rob Krentz, a long-time friend, client, and partner was murdered on
his ranch in an extremely remote place, and at a time that the murderer had no reason to be there on foot except to be using the immigrant and drug trail that runs through his ranch. 15. Time and time again, I've seen caravans of illegal entrants on foot going
north along that trail coming from the Mexican border, and time upon time I've seen the
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LAW OFFICES One Arizona Center, 400 E. Van Buren Phoenix, Arizona 85004-2202 (602) 382-6000
one or two "coyote guides" returning to Mexico along the same trail. And that's only one of the hundreds of trails used the same way all along the remote reaches of the Tucson Border Patrol Sector border. And it's well know that the Mexican syndicate that "owns" that trail is prone to intimidation and scare tactics, but is not nearly as violent and deadly as the syndicates controlling the trails through the western end of the Tucson sector border. 16. At my home in a more populated region we have a "lay-up" in a 10-acre
pasture where illegal entrants wait for rides within 600 ft. of my front porch. 17. We report it; the Border Patrol watches it for a night or two, than as soon as
the Border Patrol assigns their watch to another location, the illegal entrants return en masse. As many as fifteen backpacks are left behind with each of their visits. 18. A pickup truck loaded with "illegal entrants" trying to out-run an unmarked
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Snell & Wilmer L.L.P.
law enforcement vehicle barreled through our pasture fence, and crashed through a dozen large mesquites before totally wrecking the vehicle less than 100 yards from my doorstep. All of the occupants escaped. I replaced ½ mile of fence and had to clean up the mess and tow away the truck myself. 19. Three times my clinic/horse barn was occupied by illegal entrants when I
went to the clinic in the morning. Twice they came in while I worked alone late at night, demanding rides, offering up to $300 a piece to take them to Phoenix, then threatening when I refused. 20. from me. 21. Twice I've stopped along lonely remote ranch roads to help desperateOnce, my daughter came to my recue with an ax handle to chase them away
looking illegals only to have them jump up and jump into my pickup truck and refuse to get out; once I had to physically drag him out of my truck. One threatened me with an
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LAW OFFICES One Arizona Center, 400 E. Van Buren Phoenix, Arizona 85004-2202 (602) 382-6000
unloaded pistol. I can only, surmise he had stolen the pistol on a return trip but wasn't able to find the ammunition. 22. Federal agencies in recent years have defended the border in more populate
border communities and at official ports of entry and sight reduced crime statistics as an accomplishment, but ten and twenty miles away from there, where many of us live and work, and where statistics are "minimal," we are being deluged. 23. There is, in fact a foreign invasion crossing the border in remote stretches
and we requested, petitioned, and even demanded, that the federal government fulfill their duty and responsibilities for many years now, to no avail. The federal government has not had the will, nor political desire, to correct the injustice, enforce our nation's laws in Arizona, nor protect Arizona's citizens and their property. 24. Recently, Mr. David Aguilar, an official in DHS was quoted saying that "the
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Snell & Wilmer L.L.P.
border is not a line in the sand nor a juridical line, but a third country between Mexico and the U.S." 25. To date he has not been made to retract, nor clarify, nor correct that
statement. It leads me to believe that we who live and work in that third country are no longer to be given the protections and security of the United States. Yet the international boundary was delineated, surveyed and ratified by both the United States and Mexico in the Gadsden Treaty, and a large portion of the lands acquired in that treaty became the Arizona Territory and later the State of Arizona. 26. The United States of America has refused to secure the international
boundary, yet Arizona's southern boundary is well defined in the Gadsden Treaty, and the U.S. government has refused to enforce its own federal immigration laws throughout the state that would mitigate the security breaches of the Arizona border. 27. Arizona residents have demanded that the federal government enforce the
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LAW OFFICES One Arizona Center, 400 E. Van Buren Phoenix, Arizona 85004-2202 (602) 382-6000
laws of the United States in Arizona, they have not, so to provide for our security along the border Arizona citizens have demanded Arizona fulfill its duties and responsibilities within the state. 28. With the passage of Arizona S.B. 1070, the Arizona legislature and
Governor have passed a law which mimics federal immigration law, and adds only antidiscrimination provisions that better clarifies how the law is to be enforced. 29. When the passage of the bill was announced many of us living and working
on the border saw an immediate reduction in illegal immigrant traffic and have heard from our Mexican counterparts on the other side of the border that the "staging" of illegal immigrants planning to come into the U.S. through Mexico is either "building-up and waiting out" the current lawsuit or being diverted elsewhere than Arizona to cross, which depends on what Mexican border community the "staging" is taking place in, and what syndicate is controlling the trails across the border in that region. 30. The law is already having a mitigating affect on illegal crossings, even
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Snell & Wilmer L.L.P.
before enforcement begins. I declare under penalty of perjury that the foregoing is true and correct. DATED ______________ Cochise County, Arizona.
By
Gary A. Thrasher
11717903
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laws of the United States in Arizona, they have not, so to provide for our security along the border Arizona citizens have demanded Arizona fulfill its duties and responsibilities within the state. 28. With the passage of Arizona S.B. 1070, the Arizona legislature and
Governor have passed a law which mimics federal immigration law, and adds only antidiscrimination provisions that better clarifies how the law is to be enforced. 29. When the passage of the bill was announced many of us living and working
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on the border saw an immediate reduction in illegal immigrant traffic and have heard from our Mexican counterparts on the other side of the border that the "staging" of illegal immigrants planning to come into the U.S. through Mexico is either "building-up and waiting out" the current lawsuit or being diverted elsewhere than Arizona to cross, which depends on what Mexican border community the "staging" is taking place in, and what syndicate is controlling the trails across the border in that region. 30. The law is already having a mitigating affect on illegal crossings, even
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