DECLARATION OF JULIA A. OLSON IN SUPPORT OF PLAINTIFFS’ MOTION 

IN LIMINE SEEKING JUDICIAL NOTICE

JULIA A. OLSON (OR Bar 062230) 

JuliaAOlson@gmail.com

WILD EARTH ADVOCATES

1216 Lincoln Street

Eugene, OR 97401

Tel: (415) 786-4825 

PHILIP L. GREGORY (pro hac vice)

pgregory@gregorylawgroup.com

Gregory Law Group 

1250 Godetia Drive

Redwood City, CA 94062

Tel: (650) 278-2957

ANDREA K. RODGERS (OR Bar 041029)

Andrearodgers42@gmail.com

Law Offices of Andrea K. Rodgers

3026 NW Esplanade

Seattle, WA 98117

Tel: (206) 696-2851

Attorneys for Plaintiffs 

UNITED STATES DISTRICT COURT

DISTRICT OF OREGON

KELSEY CASCADIA ROSE JULIANA; 

XIUHTEZCATL TONATIUH M., through his 

Guardian Tamara Roske-Martinez; et al.

Plaintiffs,

v.

The UNITED STATES OF AMERICA; 

DONALD TRUMP, in his official capacity as 

President of the United States; et al., 

Defendants.

Case No.: 6:15-cv-01517-TC 

DECLARATION OF JULIA A. OLSON 

in Support of Plaintiffs’ Motion In Limine

Seeking Judicial Notice of Federal 

Government Documents
DECLARATION OF JULIA A. OLSON IN SUPPORT OF PLAINTIFFS’ MOTION 

IN LIMINE SEEKING JUDICIAL NOTICE

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I, Julia A. Olson, hereby declare and if called upon would testify as follows:

1. I am an attorney of record in the above-entitled action. I make this Declaration in support 

of Plaintiffs’ Motion In Limine Seeking Judicial Notice of Federal Government 

Documents. I have personal knowledge of the facts stated herein, except as to those stated 

on information and belief, and if called to testify, I would and could testify competently 

thereto.

2. Since the commencement of this litigation, counsel for Plaintiffs have been engaged in 

extensive informal discovery concerning documents available as public records from 

federal government sources. Counsel for Plaintiffs and our support staff have conducted a 

significant amount of research from Presidential libraries, government archives, and 

governmental websites. Many of the documents obtained through this process are 

relevant to the issues in this case and are properly subject to judicial notice, as suggested 

by Magistrate Judge Coffin during the June 6, 2018 Status Conference. 

3. On behalf of Plaintiffs, I have met and conferred with counsel for Defendants on this 

procedure. The questions discussed in our meet and confer concerned the following 

issues in connection with Plaintiffs’ response to the Motion for Summary Judgment: 

(i) Plaintiffs’ ability to rely upon Federal Government records that have yet to be 

authenticated, but which Plaintiffs wish to rely upon in their response; and (ii) 

declarations from Plaintiffs’ experts who have prepared expert reports but are not 

available to separately prepare declarations by June 28, when Plaintiffs’ response is due. 

As a result of these meet and confer efforts, the parties agreed: (a) Plaintiffs will attach 

and submit government records that they will Bates stamp and that they rely upon in their 

response coupled with a request that the Court take judicial notice of those records; and 
DECLARATION OF JULIA A. OLSON IN SUPPORT OF PLAINTIFFS’ MOTION 

IN LIMINE SEEKING JUDICIAL NOTICE

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(b) Plaintiffs will submit short declarations from their experts attaching and 

authenticating their expert reports.

4. Attached as Appendix 1-9 to the Motion In Limine are tables containing publicly 

available federal government documents and webpages. Each table has seven columns

contain the following information: (1) Exhibit number; (2) Title of the referenced 

document; (3) Date of the referenced document; (4) Bates number(s) given by Plaintiffs 

to the referenced document; (5) Source/Author of the referenced document; (6) website 

url for the referenced document; and (7) the date the referenced document was accessed 

by Plaintiffs. 

5. All of the documents for which Plaintiffs seek judicial notice contain material facts that 

are relevant to Plaintiffs’ claims.

6. True and correct copies of all documents listed in each of the tables that Plaintiffs seek to 

have judicially noticed are attached to my Declaration as Exhibits 1-385.

In accordance with 28 U.S.C. § 1746, I declare under penalty of perjury that the foregoing is true 

and correct.

DATED this 28th day of June, 2018.

Respectfully submitted, 

 /s/ Julia A. Olson 

Julia A. Olson