PLAINTIFFS' OBJECTIONS TO EVIDENCE SUBMITTED BY DEFENDANTS BUSH AND CHENEY
Plaintiffs respectfully object to the Declaration of Allie Beth Allman and to the Declaration of William A. Kramer, submitted in the Appendix filed with the Response and Brief of Defendants Governor George W. Bush and Richard B. Cheney in Opposition to Plaintiffs' Preliminary Injunction Application.
1.00 Both the Declaration of Allie Beth Allman and the Declaration of William A. Kramer refer to a purported sale of the Highland Park residence of Defendant Cheney. None of the sale documents are attached to either Declaration.
2.00 Despite the fact that Defendant Cheney's Highland Park residence was not under contract as of November 27, 2000 ( See Affidavit of Ann Hubener, p. 23 of Plaintiffs' Appendix), Defendants have now submitted declarations stating that, as of November 30, 2000, a sale has been completed, although none of the sale documents are attached.
3.00 Plaintiffs object to paragraph 2 of the Declaration of Allie Beth Allman and to paragraphs 2 and 3 of the Declaration of William A. Kramer on the grounds that all such paragraphs contain inadmissible hearsay.
4.00 Plaintiffs object to paragraph 2 of the Declaration of Allie Beth Allman and to paragraphs 2 and 3 of the Declaration of William A. Kramer on the grounds that all such paragraphs violate the Best Evidence Rule since none of the documents to which reference is made are attached.
Plaintiffs thus respectfully request that this Court sustain Plaintiffs' Objections paragraph 2 of the Declaration of Allie Beth Allman and to paragraphs 2 and 3 of the Declaration of William A. Kramer and strike these portions from the record.