DISTRICT OF COLUMBIA et al v. U.S. DEPARTMENT OF AGRICULTURE et al

Filing 3

MOTION for Preliminary Injunction by DISTRICT OF COLUMBIA (Attachments: #1 Declaration STEVEN BANKS, #2 Declaration EDWARD BOLEN, #3 Declaration TIKKI BROWN, #4 Declaration CATHERINE BUHRIG, #5 Declaration ALEXIS CARMEN FERNANDEZ, #6 Declaration STEVE H. FISHER, #7 Declaration HOLLY FREISHTAT, #8 Declaration JEFFREY GASKELL, #9 Declaration DEIDRE S. GIFFORD, #10 Declaration HEATHER HARTLINE-GRAFTON, #11 Declaration DANIEL R. HAUN, #12 Declaration KATHLEEN KONOPKA, #13 Declaration ED LAZERE, #14 Declaration BRITTANY MANGINI, #15 Declaration VICTORIA NEGUS, #16 Declaration ELISA NEIRA, #17 Declaration S. DUKE STOREN, #18 Declaration DAWN M. SWEENEY, #19 Declaration LAURA ZEILINGER, #20 Text of Proposed Order)(Konopka, Kathleen). Added MOTION to Stay on 1/24/2020 (znmw).

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
DISTRICT OF COLUMBIA, STATE
OF NEW YORK, STATE OF
CALIFORNIA, STATE OF
CONNECTICUT, STATE OF
MARYLAND, COMMONWEALTH
OF MASSACHUSETTS, STATE OF
MICHIGAN, STATE OF
MINNESOTA, STATE OF NEVADA,
STATE OF NEW JERSEY, STATE
OF OREGON, COMMONWEALTH
OF PENNSYLVANIA, STATE OF
RHODE ISLAND, STATE OF
VERMONT, COMMONWEALTH
OF VIRGINIA, and CITY OF NEW
YORK,
Plaintiffs,

Case No. 1:20-cv-00119

v.

U.S. DEPARTMENT OF
AGRICULTURE; GEORGE ERVIN
PERDUE III, in his official capacity as
Secretary of the U.S. Department of
Agriculture, and UNITED STATES
OF AMERICA,
Defendants.
DECLARATION OF ED LAZERE IN SUPPORT OF
PLAINTIFFS' MOTION FOR PRELIMINARY INJUNCTION
Pursuant to 28 U.S.C. § 1746, I, Ed Lazere, declare and state as follows:
1.
I am over the age of eighteen (18) years, competent to testify to the matters
contained herein, and testify based on my personal knowledge and information.
2.
I am the Executive Director of the DC Fiscal Policy Institute (DCFPI), which I
have led since 2001. In this position, I have been recognized as a leading expert on the District's
budget and tax system and as a resource on a number of policy issues such as affordable housing
and welfare-to-work programs. In addition to my work at DCFPI, I have served as a Policy
Analyst at the Center on Budget and Policy Priorities where I worked on issues such as state
spending choices under the Temporary Assistance for Needy Families (TANF) block grant, state
level tax policies and their impact on low- and moderate-income families, and affordable

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