PLAINTIFF’S REQUEST FOR HIS LIVE TESTIMONY
Plaintiff, by counsel, requests that live testimony be scheduled and accepted into evidence, which is estimated to take approximately one hour as part of the hearing on Plaintiff’s Motion for Preliminary Injunction currently scheduled for December 22, 2014.
I. GOVERNING LAW FOR LIVE TESTIMONY AT HEARING
Pursuant to Rule 65(1)(d) of the Local Rules of the U.S. District Court for the District of Columbia:
…. The practice in this jurisdiction is to decide preliminary injunction motions without live testimony where possible. Accordingly, any party who wishes to offer live testimony or cross-examine an affiant at the hearing shall so request in writing 72 hours before the hearing and shall provide the court and all other parties a list of the witnesses to be examined and an estimate of the time required. The court may decline to hear witnesses at the hearing where the need for live testimony is outweighed by considerations of undue delay, waste of time, or needless presentation of cumulative evidence. If practicable, the court shall notify all parties of its ruling on the request to adduce live testimony one business day before the hearing.
LCrR 65(1)(d).
II. TESTIMONY BY PLAINTIFF JOE ARPAIO CONCERNING STANDING AND HARM
Plaintiff Joseph Arpaio, as Sheriff of Maricopa County, Arizona, submitted his sworn affidavit that his office has observed and actually experienced increased financial costs, a drain on resources, additional workload, and greater risk of responding to a greater number of calls from criminal incidents which result directly or indirectly from repeated announcements and unconstitutional executive actions by President Obama and the other Defendants that he has in effect granted amnesty to millions of undocumented illegal aliens
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