State of California et al v. Trump et al

Filing 183

REPLY (re 176 MOTION for Partial Summary Judgment ) filed byState of California, State of New Mexico. (Attachments: # 1 Declaration, # 2 Request for Judicial Notice)(Sherman, Lee) (Filed on 6/24/2019)

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XAVIER BECERRA
Attorney General of California
ROBERT W. BYRNE
SALLY MAGNANI
MICHAEL L. NEWMAN
Senior Assistant Attorneys General
MICHAEL P. CAYABAN
CHRISTINE CHUANG
EDWARD H. OCHOA
Supervising Deputy Attorneys General
BRIAN J. BILFORD
NOAH M. GOLDEN-KRASNER
SPARSH S. KHANDESHI
HEATHER C. LESLIE
JANELLE M. SMITH
JAMES F. ZAHRADKA II
LEE I. SHERMAN (SBN 272271)
Deputy Attorneys General
300 S. Spring St., Suite 1702
Los Angeles, CA 90013
Telephone: [phone]
Fax: [phone]
E-mail: [e-mail]
Attorneys for Plaintiff State of California

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IN THE UNITED STATES DISTRICT COURT

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FOR THE NORTHERN DISTRICT OF CALIFORNIA

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OAKLAND DIVISION

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STATE OF CALIFORNIA et al.;

Case No. 4:19-cv-00872-HSG

Plaintiffs, PLAINTIFF STATES OF CALIFORNIA
AND NEW MEXICO’S
v.
SUPPLEMENTAL REQUEST FOR
JUDICIAL NOTICE RE: REPLY IN
SUPPORT OF MOTION FOR PARTIAL
DONALD J. TRUMP, in his official capacity SUMMARY JUDGMENT REGARDING
as President of the United States of America SECTIONS 284, 8005, AND 9002, AND
et al.;
OPPOSITION TO DEFENDANT’S
MOTION FOR PARTIAL SUMMARY
Defendants. JUDGMENT
Judge:

Honorable Haywood S. Gilliam,
Jr.
Trial Date:
None Set
Action Filed: February 18, 2019

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Pl. States of California and New Mexico’s Supp. Req. for Jud. Notice

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Plaintiffs hereby respectfully request, pursuant to Federal Rule of Evidence 201, that this
Court take judicial notice of the following documents:

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1. Attached hereto as Exhibit 10 is a true and correct copy of an excerpt of the United States

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Government Accountability Office Report to Congressional Requesters dated February

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2017, and titled “SOUTHWEST BORDER SECURITY: Additional Actions Needed to

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Better Assess Fencing’s Contributions to Operations and Provide Guidance for Identifying

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Capability Gaps.” As of June 24, 2019, the full report can be found at

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https://www.gao.gov/assets/690/682838.pdf.

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2. Attached hereto as Exhibit 11 is a true and correct copy of the United States Department

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of Homeland Security, U.S. Customs and Border Protection media release dated June 20,

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2019, and titled “Border Patrol Arrests Man Attempting to Smuggle Meth and Heroin.”

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As of June 24, 2019, the media release is posted on the United States Department of

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Homeland Security, U.S. Customs and Border Protection website, at

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https://www.cbp.gov/newsroom/local-media-release/border-patrol-arrests-man-

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attempting-smuggle-meth-and-heroin.

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3. Attached hereto as Exhibit 12 is a true and correct copy of the United States Department

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of Homeland Security, U.S. Customs and Border Protection media release dated June 14,

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2019, and titled “Border Patrol Seizes Meth at Checkpoint.” As of June 24, 2019, the

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media release is posted on the United States Department of Homeland Security, U.S.

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Customs and Border Protection website, at https://www.cbp.gov/newsroom/local-media-

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release/border-patrol-seizes-meth-checkpoint#.

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4. Attached hereto as Exhibit 13 is a true and correct copy of the United States Department

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of Homeland Security, U.S. Customs and Border Protection media release dated June 3,

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2019, and titled “Border Patrol Arrests Man Attempting to Smuggle Meth.” As of June

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24, 2019, the media release is posted on the United States Department of Homeland

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Security, U.S. Customs and Border Protection website at

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https://www.cbp.gov/newsroom/local-media-release/border-patrol-arrests-man-

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attempting-smuggle-meth-0.
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Pl. States of California and New Mexico’s Supp. Req. for Jud. Notice

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5. Attached hereto as Exhibit 14 is a true and correct copy of the United States Department

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of Homeland Security, U.S. Customs and Border Protection media release dated April 18,

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2019, and titled “Border Patrol Agents Seize more than $1M in Narcotics at Checkpoint.”

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As of June 24, 2019, the media release is posted on the United States Department of

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Homeland Security, U.S. Customs and Border Protection website at

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https://www.cbp.gov/newsroom/local-media-release/border-patrol-agents-seize-more-1m-

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narcotics-checkpoint.

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6. Attached hereto as Exhibit 15 is a true and correct copy of the United States Department

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of Homeland Security, U.S. Customs and Border Protection media release dated April 17,

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2019, and titled “El Centro Sector Border Patrol Seizes more than 100 Pounds of Meth.”

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As of June 24, 2019, the media release is posted on the United States Department of

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Homeland Security, U.S. Customs and Border Protection website at

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https://www.cbp.gov/newsroom/local-media-release/el-centro-sector-border-patrol-seizes-

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more-100-pounds-meth.

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7. Attached hereto as Exhibit 16 is a true and correct copy of the United States Department

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of Homeland Security, U.S. Customs and Border Protection media release dated March

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18, 2019, and titled “Border Patrol Arrests Woman Attempting to Smuggle Meth.” As of

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June 24, 2019, the media release is posted on the United States Department of Homeland

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Security, U.S. Customs and Border Protection website at

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https://www.cbp.gov/newsroom/local-media-release/border-patrol-arrests-woman-

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attempting-smuggle-meth.

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8. Attached hereto as Exhibit 17 is a true and correct copy of the United States Department

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of Homeland Security, U.S. Customs and Border Protection media release dated February,

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19, 2018, and titled “Methamphetamine Seized at Border Patrol Checkpoint.” As of June

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24, 2019, the media release is posted on the United States Department of Homeland

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Security, U.S. Customs and Border Protection website at

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https://www.cbp.gov/newsroom/local-media-release/methamphetamine-seized-border-

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patrol-checkpoint.
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Pl. States of California and New Mexico’s Supp. Req. for Jud. Notice

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9. Attached hereto as Exhibit 18 is a true and correct copy of the United States Department

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of Homeland Security, U.S. Customs and Border Protection media release dated February

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8, 2019, and titled “Border Patrol Stops Two Smuggling Attempts.” As of June 24, 2019,

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the media release is posted on the United States Department of Homeland Security, U.S.

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Customs and Border Protection website at https://www.cbp.gov/newsroom/local-media-

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release/border-patrol-stops-two-smuggling-attempts.

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10. Attached hereto as Exhibit 19 is a true and correct copy of the United States Department

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of Homeland Security, U.S. Customs and Border Protection media release dated February

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1, 2019, and titled “Border Patrol Arrests Man Attempting to Smuggle Meth.” As of June

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24, 2019, the media release is posted on the United States Department of Homeland

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Security, U.S. Customs and Border Protection website at

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https://www.cbp.gov/newsroom/local-media-release/border-patrol-arrests-man-

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attempting-smuggle-meth.

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11. Attached hereto as Exhibit 20 is a true and correct copy of the United States Department

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of Homeland Security, U.S. Customs and Border Protection media release dated January

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28, 2019, and titled “Border Patrol Discovers Liquid Methamphetamine in Gas Tank.” As

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of June 24, 2019, the media release is posted on the United States Department of

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Homeland Security, U.S. Customs and Border Protection website at

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https://www.cbp.gov/newsroom/local-media-release/border-patrol-discovers-liquid-

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methamphetamine-gas-tank.

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12. Attached hereto as Exhibit 21 is a true and correct copy of the United States Department

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of Homeland Security, U.S. Customs and Border Protection media release dated January

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28, 2019, and titled “Agents Seize Cocaine, Meth in Single Smuggling Attempt.” As of

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June 24, 2019, the media release is posted on the United States Department of Homeland

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Security, U.S. Customs and Border Protection website at

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https://www.cbp.gov/newsroom/local-media-release/agents-seize-cocaine-meth-single-

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smuggling-attempt.

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Pl. States of California and New Mexico’s Supp. Req. for Jud. Notice

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13. Attached hereto as Exhibit 22 is a true and correct copy of the United States Department

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of Homeland Security, U.S. Customs and Border Protection media release dated

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December 17, 2018, and titled “Ultralight Aircraft Incursion Leads Border Patrol to Meth

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Seizure and 2 Arrests.” As of June 24, 2019, the media release is posted on the United

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States Department of Homeland Security, U.S. Customs and Border Protection website at

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https://www.cbp.gov/newsroom/local-media-release/ultralight-aircraft-incursion-leads-

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border-patrol-meth-seizure-and-2.

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14. Attached hereto as Exhibit 23 is a true and correct copy of the United States Department
of Homeland Security, U.S. Customs and Border Protection media release dated

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December 10, 2018, and titled “Agents Foil Multiple Methamphetamine Attempts.” As of

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June 24, 2019, the media release is posted on the United States Department of Homeland

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Security, U.S. Customs and Border Protection website at

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https://www.cbp.gov/newsroom/local-media-release/agents-foil-multiple-

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methamphetamine-attempts.

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15. Attached hereto as Exhibit 24 is a true and correct copy of the United States Department

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of Homeland Security, U.S. Customs and Border Protection media release dated

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November 5, 2018, and titled “Border Patrol Agents Intercept Smuggling Attempt.” As of

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June 24, 2019, the media release is posted on the United States Department of Homeland

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Security, U.S. Customs and Border Protection website at

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https://www.cbp.gov/newsroom/local-media-release/border-patrol-agents-intercept-

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smuggling-attempt.

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16. Attached hereto as Exhibit 25 is a true and correct copy of the United States Department

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of Homeland Security, U.S. Customs and Border Protection media release dated October

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15, 2018, and titled “Border Patrol Seize Meth Hidden Inside a Vehicle.” As of June 24,

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2019, the media release is posted on the United States Department of Homeland Security,

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U.S. Customs and Border Protection website at https://www.cbp.gov/newsroom/local-

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media-release/border-patrol-seize-meth-hidden-inside-vehicle.

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Pl. States of California and New Mexico’s Supp. Req. for Jud. Notice

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17. Attached hereto as Exhibit 26 is a true and correct copy of the United States Department

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of Homeland Security, U.S. Customs and Border Protection media release dated October

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10, 2018, and titled “Alien Smuggling Warrant Yields Arrests of Gang Members and

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Weapons.” As of June 24, 2019, the media release is posted on the United States

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Department of Homeland Security, U.S. Customs and Border Protection website at

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https://www.cbp.gov/newsroom/local-media-release/alien-smuggling-warrant-yields-

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arrests-gang-members-and-weapons.

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18. Attached hereto as Exhibit 27 is a true and correct copy of the United States Department

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of Homeland Security, U.S. Customs and Border Protection media release dated October

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9, 2018, and titled “Border Patrol Seize Heroin from Body Carrier.” As of June 24, 2019,

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the media release is posted on the United States Department of Homeland Security, U.S.

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Customs and Border Protection website at https://www.cbp.gov/newsroom/local-media-

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release/border-patrol-seize-heroin-body-carrier.

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19. Attached hereto as Exhibit 28 is a true and correct copy of the United States Department

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of Homeland Security, U.S. Customs and Border Protection media release dated October

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3, 2019, and titled “DACA Recipient Arrested by Border Patrol for Smuggling Meth.” As

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of June 24, 2019, the media release is posted on the United States Department of

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Homeland Security, U.S. Customs and Border Protection website, at

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https://www.cbp.gov/newsroom/local-media-release/daca-recipient-arrested-border-

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patrol-smuggling-meth.

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Exhibits 10-28 are judicially noticeable because they are posted on official government

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websites. See Daniels–Hall v. Nat’l Educ. Ass’n, 629 F.3d 992, 998–99 (9th Cir. 2010) (judicially

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noticing information contained on a government website); Paralyzed Veterans of America v.

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McPherson, No. C 06–4670 SBA, 2008 WL 4183981, at *5 (N.D. Cal. Sept. 9, 2008) (finding

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that courts commonly take judicial notice of information and documents on government websites,

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citing cases from various jurisdictions). Thus, the statements of government departments and

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agencies contained within this exhibit are not subject to reasonable dispute, as the statements “can

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Pl. States of California and New Mexico’s Supp. Req. for Jud. Notice

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be accurately and readily determined from sources whose accuracy cannot reasonably be

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questioned.” Fed. R. Evid. § 201(b)(2).

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Exhibits 10-28 are judicially noticeable because government memoranda, bulletins, letters,

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statements, and opinions are matters of public record appropriate for judicial notice. See Brown v.

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Valoff, 422 F.3d 926, 933 n.9 (9th Cir. 2005) (judicially noticing an administrative bulletin);

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Mack v. S. Bay Beer Distribs., Inc., 798 F.2d 1279, 1282 (9th Cir. 1986) (court may take judicial

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notice of records and reports of state administrative bodies), abrogated on other grounds by

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Astoria Fed. Sav. & Loan Ass’n v. Solimino, 501 U.S. 104, 111 (1991); Interstate Nat. Gas. Co. v.

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S. Cal. Gas. Co., 209 F.2d 380, 385 (9th Cir. 1953) (judicially noticing government agency

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records and reports); Cnty. of Santa Clara v. Trump, 250 F. Supp. 3d 497, 520 n. 5, 522, n. 8, and

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523, n. 11 (N.D. Cal. 2017) (taking judicial notice of government memoranda and letters).

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Exhibits 10-28 are judicially noticeable because the statements of government officials or

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entities contained within these exhibits are not subject to reasonable dispute, as the statements

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“can be accurately and readily determined from sources whose accuracy cannot reasonably be

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questioned.” Fed. R. Evid. § 201(b)(2).

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Pl. States of California and New Mexico’s Supp. Req. for Jud. Notice

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Dated: June 24, 2019

Respectfully submitted,

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XAVIER BECERRA
Attorney General of California
ROBERT W. BYRNE
SALLY MAGNANI
MICHAEL L. NEWMAN
Senior Assistant Attorneys General
MICHAEL P. CAYABAN
CHRISTINE CHUANG
EDWARD H. OCHOA
Supervising Deputy Attorneys General
BRIAN J. BILFORD
NOAH M. GOLDEN-KRASNER
SPARSH S. KHANDESHI
HEATHER C. LESLIE
JANELLE M. SMITH
JAMES F. ZAHRADKA II

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/s/ Lee I. Sherman
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LEE I. SHERMAN
Deputy Attorneys General
Attorneys for Plaintiff State of California

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Pl. States of California and New Mexico’s Supp. Req. for Jud. Notice

EXHIBIT

United States Government Accountability Office

Report to Congressional Requesters

February 2017

SOUTHWEST
BORDER SECURITY
Additional Actions
Needed to Better
Assess Fencing's
Contributions to
Operations and
Provide Guidance for
Identifying Capability
Gaps

GAO-17-331

El Centro, California
Sector map
The geography of El Centro is largely desert, but also includes
rugged mountains, agricultural areas, a designated wilderness
area, and several military reservations. Cities near the border
include Mexicali, Mexico (population 900,000) and Calexico, CA
(population 40,000).
Land border
Land area
Border zones / interior zones
Primary fencing
Patrol roads
Agents assigned
Funds obligated for tactical infrastructure
operations and maintenance (FY 2015)
Percentage of total estimated known illegal
entries in southwest border zones recorded in
the El Centro sector (FYs 2013-2015)

United States
Nevada
Arizona
California

70 miles
107,750 square miles
20 / 30
59 miles
214 miles
1004
$3.7 million

El Centro

Yuma

Tucson

San Diego
San Diego

Yuma
Mexicali

Tijuana

Tucson

San Luis
Rio Colorado

Sunland

Nogales
Nogales

Mexico

4 percent
Legend
State line

Source: U.S. Customs and Border Protection. | GAO-17-331

Sector boundary

State name

Note: FY: Fiscal Year. Zone counts are as of Sept. 2015; miles and layers of
fencing, Sept. 2016; patrol roads, Nov. 2015; agents assigned, Sept. 2015.

Border

Sector name

U.S. city

Mexican city

Source: U.S. Customs and Border Protection; MapInfo (map). | GAO-17-331

Percentage of sector border miles covered by
fencing, by layer, type, and design (September 2016)

Fencing overview
About nine percent of all miles of primary fencing along the
southwest border are located in the El Centro sector, where three of
the sector’s 20 border zones are completely covered by pedestrian
fencing and an additional 11 border zones are partially covered by
pedestrian fencing. Border Patrol agents recorded approximately
years 2013-2015 in the three border zones partially covered by
legacy pedestrian fencing, where agents had apprehension rates of
60 percent. Agents recorded 23 percent of estimated known illegal
entries in the six border zones without any pedestrian fencing and
apprehended 70 percent of illegal entrants in those zones. Border
Patrol agents in the sector had an estimated overall apprehension
rate of 67 percent, higher than the 56 percent apprehension rate for
the southwest border as a whole.

Primary layer
Secondary layer
Tertiary layer
0

20

40

60

80

100

Percentage covered
Legacy pedestrian

Legacy vehicle

Modern pedestrian

No fence

Modern vehicle

Source: GAO analysis of U.S. Customs and Border Protection data. | GAO-17-331

Note: Due to rounding, percentages may not total 100.

Total estimated known
illegal entries
Primary fence type (2015)
(number and percent of border zones)
No fence (2, 10%)
Pedestrian fence (PF) total (11, 55%)
Modern PF complete coverage (2, 10%)

Estimated known
drive throughs

Number

Percentage

Number

Estimated known turn
backs and got aways
Number

Apprehension rate
of estimated known
entrants

Percentage

Percentage
70

6,147

12

9

1,814

11

32,001

61

0

11,896

69

63

2,273

4

0

617

4

73

Modern PF partial coverage (5, 25%)

9,178

17

0

3,560

21

61

Legacy PF partial coverage (3, 15%)

15,426

29

0

6,177

36

60

Mixed PF complete coverage (1, 5%)

5,124

10

0

1,542

9

70

5,947

11

19

1,505

9

75

Mixed vehicle fence (VF) partial coverage
(4, 20%)
Mixed PF/VF complete coverage (3, 15%)
Total (20, 100%)

8,508

16

6

1,980

12

77

52,603

100

34

17,195

100

67

Source: GAO analysis of U.S. Customs and Border Protection data. | GAO-17-331

Note: “Mixed” fencing coverage refers to border zones with a mixture of legacy and modern fencing designs. Due to rounding, percentages may not total 100.

Page 49

GAO-17-331 Tactical Infrastructure

El Paso, New Mexico and Texas
Sector map
The sector includes mountains, deserts, irrigation canals, and
rivers and just over a half of the sector area consists of small
towns and isolated rural areas. The international border
separates the cities of Ciudad Juarez, Mexico (population 1.3
million) and El Paso, TX (population 670,000).
Land border / river border
Land area
Border zones / interior zones
Primary fencing
Patrol roads
Agents assigned
Funds obligated for tactical infrastructure
operations and maintenance (FY 2015)
Percentage of total estimated known illegal
entries in southwest border zones recorded in
the El Paso sector (FYs 2013-2015)

United States
Arizona

180 miles / 88 miles
125,000 square miles
39 / 41
166 miles
465 miles
2,364
$5.9 million

New Mexico

Tucson

El Paso
Texas

Tucson
ado

Las Cruces
Sunland Park

Nogales

El Paso
Big Bend

Ciudad
Juarez

Nogales

Mexico

Del Rio

Legend

5 percent

State line

Sector boundary

State name

Border

Sector name

U.S. city

Mexican city

Source: U.S. Customs and Border Protection. | GAO-17-331
Source: U.S. Customs and Border Protection; MapInfo (map). | GAO-17-331

Note: FY: Fiscal Year. Zone counts are as of Sept. 2015; miles and layers of
fencing, Sept. 2016; patrol roads, Nov. 2015; agents assigned, Sept. 2015.

Fencing overview
Approximately 25 percent of all primary border fencing miles
along the southwest border are located in the El Paso sector, as
well as about a third of all secondary and tertiary fencing. Agents
recorded about 67 percent of estimated known illegal entries in
border zones partially covered with pedestrian fencing and eight
percent in zones with complete pedestrian fencing. Agents recorded
the lowest estimated zone apprehension rate on the southwest
border (17 percent) in the three border zones in the sector that are
completely covered by modern pedestrian fencing; four percent of
total estimated known illegal entries were recorded in these zones.
Agents recorded 25 percent of estimated known illegal entries in
the sector in border zones with no pedestrian fencing, where the
estimated apprehension rate ranged from 52 to 58 percent.

Total estimated known
illegal entries
Primary fence type (2015)
(number and percent of border zones)
No fence (7, 18%)
Pedestrian fence (PF) total (21, 54%)

Percentage of sector border miles covered by
fencing, by layer, type, and design (September 2016)
Primary layer
Secondary layer
Tertiary layer
0

20

40

60

80

100

Percentage covered
Legacy pedestrian

Legacy vehicle

Modern pedestrian

No fence

Modern vehicle

Source: GAO analysis of U.S. Customs and Border Protection data. | GAO-17-331

Estimated known
drive throughs

Estimated known turn
backs and got aways

Apprehension rate
of estimated known
entrants

Number

Percentage

Number

Number

Percentage

Percentage

8,021

13

15

3,848

11

52

41,066

68

1

27,667

78

33

Modern PF complete coverage (3, 8%)

2,661

4

0

2,203

6

17

Modern PF partial coverage (13, 33%)

18,534

30

1

12,474

35

33

Legacy PF partial coverage (2, 5%)

7,072

12

0

5,391

15

24

Mixed PF complete coverage (1, 3%)

2,273

4

0

1,689

5

26

Mixed PF partial coverage (2, 5%)

10,526

17

0

5,910

17

44

7,004

12

14

2,919

8

58

Modern VF partial coverage (7, 18%)

5,454

9

7

2,334

7

57

Legacy VF partial coverage (1, 3%)

703

1

6

406

1

42

Vehicle fence (VF) total (9, 23%)

Mixed VF partial coverage (1, 3%)
Mixed PF/VF partial coverage (2, 5%)
Total (39, 100%)

847

1

1

179

1

79

4,737

8

2

1,188

3

75

60,828

100

32

35,622

100

41

Source: GAO analysis of U.S. Customs and Border Protection data. | GAO-17-331

Note: “Mixed” fencing coverage refers to border zones with a mixture of legacy and modern fencing designs. Due to rounding, percentages may not total 100.
Page 52

GAO-17-331 Tactical Infrastructure

EXHIBIT 1

Border Patrol Arrests Man Attempting to Smuggle Meth and Heroin | U....

1 of 2

https://www.cbp.gov/newsroom/local-media-release/border-patrol-arrest...

Official website of the Department of Homeland Security

6/23/2019, 6:58 PM

Border Patrol Arrests Man Attempting to Smuggle Meth and Heroin | U....

2 of 2

https://www.cbp.gov/newsroom/local-media-release/border-patrol-arrest...

6/23/2019, 6:58 PM

EXHIBIT 2

Border Patrol Seizes Meth at Checkpoint | U.S. Customs and Border Prot...

1 of 2

https://www.cbp.gov/newsroom/local-media-release/border-patrol-seize...

Official website of the Department of Homeland Security

6/23/2019, 6:59 PM

EXHIBIT 3

Border Patrol Arrests Man Attempting to Smuggle Meth | U.S. Customs ...

1 of 2

https://www.cbp.gov/newsroom/local-media-release/border-patrol-arrest...

Official website of the Department of Homeland Security

6/23/2019, 7:00 PM

EXHIBIT 4

Border Patrol Agents Seize more than $1M in Narcotics at Checkpoint | ...

1 of 2

https://www.cbp.gov/newsroom/local-media-release/border-patrol-agents...

Official website of the Department of Homeland Security

6/21/2019, 9:30 AM

Border Patrol Agents Seize more than $1M in Narcotics at Checkpoint | ...

2 of 2

https://www.cbp.gov/newsroom/local-media-release/border-patrol-agents...

6/21/2019, 9:30 AM

EXHIBIT 5

El Centro Sector Border Patrol Seizes more than 100 Pounds of Meth | U....

1 of 2

https://www.cbp.gov/newsroom/local-media-release/el-centro-sector-bor...

Official website of the Department of Homeland Security

6/23/2019, 6:33 PM

El Centro Sector Border Patrol Seizes more than 100 Pounds of Meth | U....

2 of 2

https://www.cbp.gov/newsroom/local-media-release/el-centro-sector-bor...

6/23/2019, 6:33 PM

EXHIBIT 6

Border Patrol Arrests Woman Attempting to Smuggle Meth | U.S. Custo...

1 of 2

https://www.cbp.gov/newsroom/local-media-release/border-patrol-arrest...

Official website of the Department of Homeland Security

6/23/2019, 7:46 PM

EXHIBIT 7

Methamphetamine Seized at Border Patrol Checkpoint | U.S. Customs a...

1 of 2

https://www.cbp.gov/newsroom/local-media-release/methamphetamine-s...

Official website of the Department of Homeland Security

6/21/2019, 9:35 AM

EXHIBIT 8

Border Patrol Stops Two Smuggling Attempts | U.S. Customs and Border...

1 of 2

https://www.cbp.gov/newsroom/local-media-release/border-patrol-stops...

Official website of the Department of Homeland Security

6/23/2019, 6:39 PM

Border Patrol Stops Two Smuggling Attempts | U.S. Customs and Border...

2 of 2

https://www.cbp.gov/newsroom/local-media-release/border-patrol-stops...

6/23/2019, 6:39 PM

EXHIBIT 9

Border Patrol Arrests Man Attempting to Smuggle Meth | U.S. Customs ...

1 of 2

https://www.cbp.gov/newsroom/local-media-release/border-patrol-arrest...

Official website of the Department of Homeland Security

6/23/2019, 6:40 PM

EXHIBIT 20

Border Patrol Discovers Liquid Methamphetamine in Gas Tank | U.S. Cu...

1 of 2

https://www.cbp.gov/newsroom/local-media-release/border-patrol-discov...

Official website of the Department of Homeland Security

6/23/2019, 6:42 PM

Border Patrol Discovers Liquid Methamphetamine in Gas Tank | U.S. Cu...

2 of 2

https://www.cbp.gov/newsroom/local-media-release/border-patrol-discov...

6/23/2019, 6:42 PM

EXHIBIT 2

Agents Seize Cocaine, Meth in Single Smuggling Attempt | U.S. Custom...

1 of 2

https://www.cbp.gov/newsroom/local-media-release/agents-seize-cocain...

Official website of the Department of Homeland Security

6/23/2019, 6:42 PM

Agents Seize Cocaine, Meth in Single Smuggling Attempt | U.S. Custom...

2 of 2

https://www.cbp.gov/newsroom/local-media-release/agents-seize-cocain...

6/23/2019, 6:42 PM

EXHIBIT 22

Ultralight Aircraft Incursion Leads Border Patrol to Meth Seizure and 2 ...

1 of 2

https://www.cbp.gov/newsroom/local-media-release/ultralight-aircraft-in...

Official website of the Department of Homeland Security

6/21/2019, 9:36 AM

Ultralight Aircraft Incursion Leads Border Patrol to Meth Seizure and 2 ...

2 of 2

https://www.cbp.gov/newsroom/local-media-release/ultralight-aircraft-in...

6/21/2019, 9:36 AM

EXHIBIT 23

Agents Foil Multiple Methamphetamine Attempts | U.S. Customs and B...

1 of 2

https://www.cbp.gov/newsroom/local-media-release/agents-foil-multipl...

Official website of the Department of Homeland Security

6/21/2019, 9:43 AM

Agents Foil Multiple Methamphetamine Attempts | U.S. Customs and B...

2 of 2

https://www.cbp.gov/newsroom/local-media-release/agents-foil-multipl...

6/21/2019, 9:43 AM

EXHIBIT 24

Border Patrol Agents Intercept Smuggling Attempt | U.S. Customs and ...

1 of 2

https://www.cbp.gov/newsroom/local-media-release/border-patrol-agents...

Official website of the Department of Homeland Security

6/23/2019, 6:47 PM

EXHIBIT 25

Border Patrol Seize Meth Hidden Inside a Vehicle | U.S. Customs and B...

1 of 2

https://www.cbp.gov/newsroom/local-media-release/border-patrol-seize-...

Official website of the Department of Homeland Security

6/21/2019, 9:50 AM

Border Patrol Seize Meth Hidden Inside a Vehicle | U.S. Customs and B...

2 of 2

https://www.cbp.gov/newsroom/local-media-release/border-patrol-seize-...

6/21/2019, 9:50 AM

EXHIBIT 26

Alien Smuggling Warrant Yields Arrests of Gang Members and Weapons...

https://www.cbp.gov/newsroom/local-media-release/alien-smuggling-wa...

Official website of the Department of Homeland Security

1 of 2

6/21/2019, 9:51 AM

Alien Smuggling Warrant Yields Arrests of Gang Members and Weapons...

2 of 2

https://www.cbp.gov/newsroom/local-media-release/alien-smuggling-wa...

6/21/2019, 9:51 AM

EXHIBIT 27

Border Patrol Seize Heroin from Body Carrier | U.S. Customs and Borde...

1 of 2

https://www.cbp.gov/newsroom/local-media-release/border-patrol-seize-...

Official website of the Department of Homeland Security

6/21/2019, 8:51 AM

Border Patrol Seize Heroin from Body Carrier | U.S. Customs and Borde...

2 of 2

https://www.cbp.gov/newsroom/local-media-release/border-patrol-seize-...

6/21/2019, 8:51 AM

EXHIBIT 28

DACA Recipient Arrested by Border Patrol for Smuggling Meth | U.S. C...

https://www.cbp.gov/newsroom/local-media-release/daca-recipient-arres...

Official website of the Department of Homeland Security

español (/newsroom/local-media-release/patrulla-fronteriza-arresta-beneficiario-de-daca-porcontrabandear?language=es)

1 of 2

6/21/2019, 9:54 AM

DACA Recipient Arrested by Border Patrol for Smuggling Meth | U.S. C...

2 of 2

https://www.cbp.gov/newsroom/local-media-release/daca-recipient-arres...

6/21/2019, 9:54 AM