Case Document 55-26 Filed 04/25/19 Page 1 of 9

EXHIBIT 26

Case 3:19-cv-00066-DB Document 55-26 Filed 04/25/19 Page 2 of 9

UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF TEXAS
EL PASO DIVISION
________________________________________________
)
EL PASO COUNTY, TEXAS
)
500 E. San Antonio
)
El Paso, TX 79901,
)
)
BORDER NETWORK FOR HUMAN RIGHTS
)
2115 N Piedras St
)
El Paso, TX 79930,
)
Plaintiffs,
)
)
v.
)
Civil Action No. 3:19-cv-66
)
DONALD J. TRUMP, in his official capacity as
)
DECLARATION OF
President of the United States of America
)
RICARDO SAMANIEGO
1600 Pennsylvania Avenue, NW
)
Washington, D.C. 20500,
)
)
PATRICK M. SHANAHAN, in his official capacity as
)
Acting Secretary of Defense
)
1000 Defense Pentagon
)
Washington, D.C. 20301,
)
)
KEVIN McALEENAN, in his official capacity as
)
Secretary of Homeland Security
)
245 Murray Lane, SW, Mail Stop 0485
)
Washington, DC 20528-0485,
)
)
TODD T. SEMONITE, in his official capacity as
)
Commanding General
)
United States Army Corps of Engineers
)
441 G Street, NW
)
Washington, DC 20314-1000,
)
)
DAVID BERNHARDT, in his official capacity as
)
Acting Secretary of the Interior
)
1849 C Street, NW
)
Washington, DC 20240,
)
)
Defendants.
)
_______________________________________________ )

 Case 3:19-cv-00066-DB Document 55-26 Filed 04/25/19 Page 3 of 9

DECLARATION OF RICARDO SAMANIEGO
My name is Ricardo Samaniego. I hereby declare:
1. I am over the age of 18. I provide this declaration based on personal knowledge. I would
testify to the facts in this declaration under oath if called upon to do so.
2. I was elected to be El Paso County Judge on May 22, 2018, and entered office in January
2019. As County Judge, I preside over the El Paso County Commissioners Court. The
County Judge and four-member Commission set the County’s tax rate and oversee its
budget.
3. El Paso County is bilingual, bi-national, multicultural, and geographically distinct. El
Paso County has over 800,000 residents, more than 82 percent of whom are Hispanic and
more than 25 percent of whom are foreign born. It is part of the largest border community
on the Rio Grande, and one of the safest communities in the nation. El Paso County takes
great pride in protecting all of its residents and its values, and has been a leader in the
fight against discrimination of all types for decades, with a special focus on protecting the
civil rights of its immigrant communities.
4. From the beginning of my tenure as County Judge, I have been a strong advocate for
economic development and tourism in El Paso County. El Paso County’s ability to
compete for business development projects and attract tourists to our community both
depend on El Paso County’s reputation as a safe place to live, work, and visit, as well as
the natural beauty and accessibility of the tourist destinations in the region, including the
border itself.
5. Our current budget projects that El Paso County will take in $4 million in tax revenue
based on tourism. Any drop-off in that revenue would significantly damage the County’s

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financial health. And any threat to our ability to compete for tourism both causes us to
spend time and resources now to meet the threat and damages our future economic
prospects.
6. Based on my experience in business and organizational development, prior to holding
elective office and my current experience in County government, I know that the
President’s Proclamation declaring an emergency at the southern border is a serious
threat to both tourism and economic development because of the false and negative
impression of El Paso that it creates. It is an immediate blow to our competitive position
in the market.
7. The President’s Proclamation is an official government statement that designates the
southern border as a danger zone and that directly contradicts the key selling points El
Paso County has spent millions of dollars to develop and promote. The truth about El
Paso County – and our central marketing message to outside investors and tourists – is
that it is one the safest and most beautiful destinations in the country precisely because of
the multilingual and multinational character of our community and our proximity to and
positive relationship with Juarez, Mexico.
8. The President’s Proclamation has falsely told the world the exact opposite of who we are
and what we promote, and has taken away our greatest promotional asset. The
Proclamation tells the nation and the world that El Paso County and the southern border
are crime-ridden and dangerous, that our immigrant community comprises criminals and
drug traffickers that threaten our community, that our proximity to Mexico is an
existential threat, and that we can be rescued only through the blight of massive wall
construction and militarization of our border.

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9. This designation could not have come at a worse time for El Paso County’s economic
fortunes and our future planning for growth. In recent years, El Paso County has
undertaken major efforts at great taxpayer expense to promote economic development.
Increasing tourism is a key driver of that development. El Paso has secured the opening
of new downtown hotels and refurbished historical sites as part of a strategic plan to
bring tourism and its attendant revenue to the County. El Paso County entered into and
helped to fund a three-year multi-million dollar tourism campaign with the City of El
Paso that is aimed specifically at raising El Paso’s share of the Texas tourism market.
10. In my capacity as County Judge, I have already heard personally from people who have a
false impression that El Paso County is a dangerous place and who do not want to come
here.
11. And I have already observed the effects of this false impression on the County’s
opportunities to compete for development initiatives and tourism. As part of my position,
I frequently consult with local business leaders and partner with them on economic
growth initiatives. Those interactions have indicated to me that the President’s
Proclamation is harming our economic development efforts on an ongoing basis,
including by generating fears of potential investors that the community will be mired in a
long-term state of chaos that includes both violent crime, the blight of construction, and
impediments to crossing back and forth across the border. In short, every meeting anyone
promoting El Paso has must now include extra efforts to persuade people that El Paso
County is a good place to invest in and visit.
12. The President’s Proclamation has fundamentally altered the character of my first 100
days in office and I’ve had to change the way I spend my time. Instead of focusing on

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meeting directly with business leaders to bring business to El Paso as I had planned to do,
I have spent approximately 30% of my time making public statements and answering
media requests about the “emergency” in El Paso, defending El Paso’s reputation as a
safe community through public and private conversations, strategizing with County staff
and local business leaders about how to defend our reputation, and controlling the
damage that the President’s specific attacks on Mexico have inflicted on our unique local
economy and lifestyle. El Paso County simply cannot allow the message that proximity
to Mexico is negative and dangerous to sink in, as our closeness to Mexico is critical to
our economic and cultural survival. My time is now also beholden to the uncertainty
created by the constant need to respond to these issues.
13. To be sure, I have also spent significant time responding to the humanitarian issues
presented by the large presence of migrants in El Paso County and to the issues presented
by long wait times at the border, which are not the direct result of the President’s
Proclamation. But the Proclamation that falsely maligns our community, our immigrant
residents, and our Mexican neighbors, makes every current challenge we are facing that
much worse.
14. In addition to the outright falsehoods perpetuated by the President that have damaged El
Paso County’s reputation, the Proclamation also delivers the imminent threat of
additional economic harm to our region through construction, the deployment of troops,
and the diversion of funds away from Fort Bliss, the army base that drives our economy.
15. According to a 2016 Report from the Texas Comptroller’s Office, Fort Bliss contributes
$23.13 billion to the Texas economy. According to other recent studies, such as the one
undertaken by the University of Texas-El Paso’s Institute for Policy and Economic

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Development in 2013, Fort Bliss and its adjacent medical center have a $5.9 billion
economic impact on El Paso County, and create nearly 62,000 jobs with more than $4
billion in compensation to area households. In my view, Fort Bliss is the lifeblood of the
El Paso economy. I know from my own experience in both business and government that
the financial health of Fort Bliss affects the real estate market and every other aspect of
the economy in El Paso.
16. The Department of Defense, acting pursuant to the President’s Proclamation, recently
identified $52.3 million appropriated for military construction projects at Fort Bliss as
available to be reprogrammed for construction of border barriers. This announcement
creates the imminent prospect of economic harm to El Paso County.
17. The administration has also now announced imminent plans to engage in wall
construction with the funds it is illegally reprogramming under the Proclamation, and the
Army Corps of Engineers has awarded contracts to start work within a few weeks. Much
of this construction will happen at our immediate neighboring border area in New
Mexico. According to the Department of Defense’s announcement, it will affect the
nearby port in Santa Teresa, Mexico, which is only 20 minutes from downtown El Paso,
and the entirety of the border in Dona Ana County, which immediately adjoins El Paso
County. This construction is a threat to El Paso County because it creates uncertainty
about traffic, the accessibility of nearby ports, and blighted and obstructed natural sites
that are tourist destinations for visitors to El Paso County. This uncertainty, in turn,
further affects our efforts to promote business development and tourism.
18. The blight of construction across the entirety of the Mexico-New Mexico border affects
the prospects of business development in El Paso County because of our immediate

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proximity to it. As with the Proclamation’s effects on our ability to compete for business
investment and tourism, the blight of construction acts as an equally destructive strike
against us in our various negotiations, as does the uncertainty of how it will play out.
19. Massive construction in New Mexico also affects tourism in El Paso County. When
people come to El Paso County, they often come to visit attractions here, in New Mexico,
and Mexico at the same time. Uncertainty about construction that will impede such visits
undercuts another of our selling points and threatens our revenues.
20. Finally, the construction defeats the residents of El Paso County in their own enjoyment
of their border community home. Residents of El Paso value their ability to access and
enjoy the natural beauty of the New Mexico-Mexico border. The administration’s illegal
construction will greatly restrict our ability to do so.
21. I declare under the penalty of perjury under the law of the United States that the
foregoing is true and correct to the best of my knowledge.

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