State of California et al v. Trump et al

Filing 89

OPPOSITION/RESPONSE (re 59 MOTION for Preliminary Injunction ) filed by Department of Defense, David Bernhardt, Mark T. Esper, Steven T. Mnuchin, Kirstjen M. Nielsen, Patrick M. Shanahan, Richard V. Spencer, Donald J. Trump, U.S. Department of Homeland Security, U.S. Department of the Interior, U.S. Department of the Treasury, United States of America, Heather Wilson. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Exhibit, # 4 Exhibit, # 5 Exhibit, # 6 Exhibit, # 7 Exhibit, # 8 Exhibit, # 9 Exhibit, # 10 Exhibit, # 11 Exhibit, # 12 Exhibit, # 13 Exhibit, # 14 Exhibit)(Warden, Andrew) (Filed on 4/25/2019)

DEFENDANTS’ INDEX OF EXHIBITS
Ex. 1

Letter from Secretary of Homeland Security Kirstjen M. Nielsen to Members
of Congress (Mar. 28, 2019)

Ex. 2

Declaration of Jerry B. Martin, Chief of U.S. Border Patrol Strategic Planning
and Analysis Directorate (April 24, 2019)

Ex. 3

Joint Statement of John Rood, Under Secretary of Defense for Policy, and
Vice Admiral Michael Gilday, Director of Operations for the Joint Chiefs of
Staff, H. Armed Servs. Comm. Hr’g on S. Border Defense Support (Jan. 29,
2019)

Ex. 4

DHS Southwest Border Migration Statistics FY 2019

Ex. 5

U.S. Border Patrol Apprehension Statistics Since FY 2000

Ex. 6

CBP Transcript March FY19 Year to Date Statistics (April 10, 2019)

Ex. 7

President Donald J. Trump’s Border Security Victory (Feb. 15, 2019)

Ex. 8

Declaration of Lauren Flossman, Acquisition Program Manager for the Wall
Program Management Office, U.S. Customs and Border Protection (April 1,
2019)

Ex. 9

Declaration of John M. Farley, Director of the Executive Office for Asset
Forfeiture, Department of the Treasury (April 24, 2019)

Ex. 10

Declaration of Kenneth Rapuano, Assistant Secretary of Defense for
Homeland Defense and Global Security (April 25, 2019)

Ex. 11

Declaration of Paul Enriquez, Acquisitions, Real Estate and Environmental
Director for the Border Wall Program Management Office, U.S. Customs
and Border Protection (April 25, 2019)

Ex. 12

Transcript of House Armed Services Committee Hearing on Fiscal Year
2020 Defense Authorization (March 26, 2019)

Ex. 13

United States Fish and Wildlife Service, Mexican Wolf Recovery Plan, First
Revision (November 2017)

State of California, et al. v. Donald J. Trump, et al., 4:19-cv-00872-HSG – Defendants’ Opp. to Prelim. Inj