International Refugee Assistance Project v. Trump

Filing 34

Joint FULL ELECTRONIC APPENDIX and full paper appendix by Appellants Daniel R. Coats, Department of State, John F. Kelly, Office of the Director of National Intelligence, Rex Tillerson, Donald J. Trump and United States Department of Homeland Security. Method of Filing Paper Copies: courier. Date paper copies mailed dispatched or delivered to court: 03/27/2017. [1000049094] [17-1351] H. Thomas Byron

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Case 8:17-cv-00361-TDC Document 95-3 Filed 03/11/17 Page 2 of 7 J.R.037 J.A. 298 Case 8:17-cv-00361-TDC Document 95-3 Filed 03/11/17 Page 3 of 7 J.R.038 J.A. 299 Case 8:17-cv-00361-TDC Document 95-3 Filed 03/11/17 Page 4 of 7 J.R.039 J.A. 300 Case 8:17-cv-00361-TDC Document 95-3 Filed 03/11/17 Page 5 of 7 J.R.040 J.A. 301 Case 8:17-cv-00361-TDC Document 95-3 Filed 03/11/17 Page 6 of 7 J.R.041 J.A. 302 Case 8:17-cv-00361-TDC Document 95-3 Filed 03/11/17 Page 7 of 7 J.R.042 J.A. 303 Case 8:17-cv-00361-TDC Document 95-4 Filed 03/11/17 Page 1 of 4 J.R.043 J.A. 304 Case 8:17-cv-00361-TDC Document 95-4 Filed 03/11/17 Page 2 of 4 J.R.044 J.A. 305 Case 8:17-cv-00361-TDC Document 95-4 Filed 03/11/17 Page 3 of 4 J.R.045 J.A. 306 Case 8:17-cv-00361-TDC Document 95-4 Filed 03/11/17 Page 4 of 4 J.R.046 J.A. 307 Case 8:17-cv-00361-TDC Document 95-5 Filed 03/11/17 Page 1 of 4 J.R.047 J.A. 308 Case 8:17-cv-00361-TDC Document 95-5 Filed 03/11/17 Page 2 of 4 J.R.048 J.A. 309 Case 8:17-cv-00361-TDC Document 95-5 Filed 03/11/17 Page 3 of 4 J.R.049 J.A. 310 Case 8:17-cv-00361-TDC Document 95-5 Filed 03/11/17 Page 4 of 4 J.R.050 J.A. 311 Case 8:17-cv-00361-TDC Document 95-6 Filed 03/11/17 Page 1 of 4 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND SOUTHERN DIVISION INTERNATIONALREFUGEE ASSISTANCE PROJECT, et al., Civil Action No.: 8:17-CV-00361-TDC Plaintiffs, v. DONALD TRUMP, et al, Defendants. DECLARATION OF MOHAMMED METEAB I, Mohammed Meteab, upon my personal knowledge, hereby submit this declaration pursuant 28 U.S.C. § 1746 and declare as follows: 1. I am a lawful permanent resident of Iraqi origin, and I live in Springfield, Massachusetts. 2. I came to the United States in 2015 as a refugee, along with my wife and two children. All of us are now lawful permanent residents. My third child, who was born in the United States, is a U.S. citizen. 3. I am one of five brothers. We lived together with our families in Iraq. During and after the 2003 invasion of Iraq, my brothers and I all cooperated with the U.S. military, helping to establish the transitional government in the wake of the conflict in Najaf, Iraq. 4. Because of our cooperation with the U.S. government, we received threats and were shot at by armed militia groups in Iraq. In 2013, my brother Abdullateef found a note for us from the League of the Righteous milita saying we had to leave Najaf or be killed. J.R.051 J.A. 312 Case 8:17-cv-00361-TDC Document 95-6 Filed 03/11/17 Page 2 of 4 5. I am a Sunni Muslim, as are my brothers. We lived in a Shi’a neighborhood in Najaf, Iraq. 6. In 2013, my family received death threats because we were Sunni. We were warned by neighbors and members of the community that we would be killed if we stayed. A few days after receiving death threats, my nephew was shot in the leg. On December 25, 2013, my older brother Shareef, his children, and two of our nephews (Abdullateef’s sons, Walid and Mosad, who was shot, and their wives), fled to Jordan. 7. Eleven days later, on January 5, 2014, I fled to Jordan with my wife and our two children. My three other brothers, Ahmed, Abdullateef, and Ali, joined us in Jordan in 2014. Like my wife, children and I, my brothers applied for refugee status soon after arriving in Jordan. 8. My wife, two children, and I were approved as refugees in March 2014. 9. On August 20, 2015, my wife, children, and I came to the United States as refugees. My nephew Walid and his wife were also approved and came to the U.S. as a refugee in July 2015. My older brother Shareef and his children also came to the United States as refugees in August 2015. Shareef’s daughter and her husband, Mosad (who had been shot in Iraq) came to the United States in December 2015. 10. My remaining three brothers, Ahmed, Abdullateef, and Ali, had also applied for refugee status in 2014. Ahmed and Ali were approved for resettlement in the United States in 2016. In April 2015, Abdullateef was approved for resettlement in Canada. He is still in Jordan, awaiting final clearance to go to Canada. 11. In November 2016, Ahmed and Ali, who were still in Jordan, were informed by the International Organization for Migration that while their refugee applications had been 2 J.R.052 J.A. 313 Case 8:17-cv-00361-TDC Document 95-6 Filed 03/11/17 Page 3 of 4 approved, my brothers and their families still did not have travel documents to come to the United States. Jewish Family Services gave me this update at the same time. 12. I expected that my brothers and their families would arrive in the United States in early 2017. However, when I learned from the news about the Executive Order in January, I realized my brothers would not be able to join us in the United States. 13. My brothers are living as refugees in Jordan. Like me, they fled threats to their lives in Iraq and were looking forward to starting a new life and sending their children to school here in the United States. Because of the January and now the updated Executive Order, they continue to live in insecurity as refugees awaiting resettlement. 14. Because of the Executive Order and official anti-Muslim sentiment motivating it, I have felt isolated and disparaged in my community. It is causing me and my wife a lot of mental stress. Particularly when my wife, who wears a hijab, and I are in public, I sense a lot of hostility from people around me. For example, at crosswalks, people refuse to stop their cars for us, and I see people staring at us. My wife doesn’t not want to go outside the house except for doctors’ appointments. My nieces, who wear hijab to school, say that people make mean comments and stare at them for being Muslim. One day, a student pulled the hijab off of my niece’s head in class. On another occasion, as my niece was getting off the school bus, an older woman came up to her and pushed her to the ground. 3 J.R.053 J.A. 314 Case 8:17-cv-00361-TDC Document 95-6 Filed 03/11/17 Page 4 of 4 J.R.054 J.A. 315 Case 8:17-cv-00361-TDC Document 95-7 Filed 03/11/17 Page 1 of 5 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND SOUTHERN DIVISION INTERNATIONAL REFUGEE ASSISTANCE PROJECT, et al., Plaintiffs, v. Civil Action No.: 8:17-CV-00361-TDC DECLARATION OF JANE DOE #2 DONALD TRUMP, et al., Defendants. DECLARATION OF JANE DOE #2 I, Jane Doe #2, upon my personal knowledge, hereby submit this declaration pursuant to 28 U.S.C. § 1746 and declare as follows: 1. I am a United States Citizen of Syrian origin, and I live in Mecklenburg County, North Carolina. 2. I am currently enrolled in college and studying to become a healthcare 3. My sister was born in Damascus, Syria, where she grew up and spent most technician. of her life. She is married and has two young boys, aged 7 and 2. In 2012, government planes bombed her neighborhood in Damascus and destroyed her house. She and her family fled to the home of her parents-in-law with nothing but their passports and the clothes on their backs. After remaining with her in-laws for several weeks, my sister and her family eventually moved to a home about two hours outside of Damascus, but shelling eventually reached that town, too. 4. While internally displaced within Syria, my sister and her husband heard rumors that the Syrian government’s selective service would eventually be expanded to include 1 J.R.055 J.A. 316 Case 8:17-cv-00361-TDC Document 95-7 Filed 03/11/17 Page 2 of 5 men over the age of 30. After my sister’s husband saw some of his friends taken for the selective service, she told him to flee to Yemen, because only Yemen and Sudan accept Syrian refugees without visas. She stayed behind in Syria with their first child, pregnant with their second, because as a teacher, she was a government employee and was required to apply for government approval to stop working and leave the country. She remained in Syria, enduring constant shelling of their town, until she received permission from the government to leave work, at which point she fled to Yemen with her child to join her husband. 5. In Yemen, my sister’s family registered with the United Nations High Commissioner for Refugees and received a temporary protection certificate explaining that they should be protected from forcible return to Syria. They remained in Yemen for approximately a year and a half, but war broke out in the country six or seven months after they arrived and the capitol, where they were staying, was soon besieged. They had no electricity, fuel, clean water, or food. Her husband had to risk his life to leave the city every day to find food and clean water for them because no trucks could enter the city to deliver supplies. 6. War engulfed the capitol and at one point, the house where my sister’s family was staying was taken over by insurgents as a site for launching shells. She and her children, including her newborn baby, were locked into a room for three to four days while insurgent militiamen used their house to fire rockets. In the meantime, her husband, who had left to find food, was prevented from entering. After the insurgents finally left, my sister and her husband fled that same day for the Saudi Arabian border. 7. My sister’s family is now in a refugee hotel on the Saudi Arabia-Yemen border and living in terrible, life-threatening conditions. They endure regular shelling from the Yemeni side of the border; where they live is shelled so often that the local school is open only 2 J.R.056 J.A. 317 Case 8:17-cv-00361-TDC Document 95-7 Filed 03/11/17 Page 3 of 5 one or two days a week, if at all. The building in which they live is infested with bugs; human refuse from the bathroom of the unit above them leaks into their room. They are constantly sick and their children are throwing up all the time. The Saudi Arabian government often turns off the power to the building in an attempt to make the living conditions there so intolerable that the refugees will leave. 8. Discrimination against Syrian refugees in Saudi Arabia is severe. My sister’s husband searches for work every day, but is often cheated out of his wages and kicked out of jobs without payment because he is Syrian. Because her husband is gone during the day, my sister must remain inside with her children; if she went out in public by herself, it is unquestionable that she would be abducted because she is a woman and a Syrian. The only time she and her children are able to leave the room where they are staying is at night, when her husband returns home and can accompany them outside. For this reason, their children did not believe that the sun rose and set in Saudi Arabia for the first year they were in the country because they room where they were staying had no windows. Her children never have the opportunity to play outside, but instead remain in their room for most of the day. During the rare times that they are able to emerge from the building at night, my sister’s younger son cries and tries to run away whenever they have to return to the hotel. 9. My sister’s older son always asks her, “When am I going to have friends?” He has not been able to make any friends because he is rarely able to go to school or to interact with other children and his entire life has been a continual experience of displacement. 10. I am very worried that my participation in this lawsuit against federal government officials could jeopardize my sister’s visa application. My I-130 petition for her is currently pending. Once approved for an I-130 visa, she will be able to access the U.S. Refugee 3 J.R.057 J.A. 318 Case 8:17-cv-00361-TDC Document 95-7 Filed 03/11/17 Page 4 of 5 Admissions Program (USRAP) through the Priority-2 Direct Access Program for Iraqi and Syrian Beneficiaries of Form I-130 Petition for Alien Relatives. I do not want my participation in this lawsuit to adversely impact either her visa or refugee applications and delay or prevent her from joining me in the United States. 11. I fear that whether or not my sister’s visa and refugee application are denied, my participation in this case could result in harassment of me and my sister. Persecution of Syrian refugees in Saudi Arabia is rampant, and the Saudi Arabian government tries to make conditions difficult for Syrian refugees in the country. I fear that if my identity is made public, it would be easy to identify her as well, making her susceptible to harassment or further persecution. 12. While participating in this lawsuit is important to me, I am also fearful that my participation may lead to me and my family being targeted for harassment if my identity were made public. 13. Even as a United States citizen, I am fearful of leaving the United States because I am afraid the Executive Order may result in difficulty or harassment upon my return to the United States. 14. I am aware of the reports indicating that harassment and violence targeting Muslims has been on the rise recently. In fact several of my friends have experienced such harassment on account of their perceived or actual religious affiliation. I am aware of the shooting at the mosque in Quebec and the bombings of mosques here in the United States. 15. For these reasons, I feel that my personal security and that of my family necessitates that I be allowed to proceed under a pseudonym. 4 J.R.058 J.A. 319 Case 8:17-cv-00361-TDC Document 95-7 Filed 03/11/17 Page 5 of 5 J.R.059 J.A. 320 Case 8:17-cv-00361-TDC Document 95-8 Filed 03/11/17 Page 1 of 2 J.R.060 J.A. 321 Case 8:17-cv-00361-TDC Document 95-8 Filed 03/11/17 Page 2 of 2 J.R.061 J.A. 322 Case 8:17-cv-00361-TDC Document 95-9 Filed 03/11/17 Page 1 of 4 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND SOUTHERN DIVISION INTERNATIONALREFUGEE ASSISTANCE PROJECT, et al., Civil Action No.: 8:17-CV-00361-TDC Plaintiffs, v. DONALD TRUMP, et al, Defendants. DECLARATION OF PAUL HARRISON I, Paul Harrison, upon my personal knowledge, hereby submit this declaration pursuant 28 U.S.C. § 1746 and declare as follows: 1. I am a United States citizen, and I live in Euless, Texas. 2. My fiancé is an Iranian national who lives in Tehran, Iran. We have been together since November 2015. He was raised Muslim. 3. In March 2016, I petitioned for a K-1 visa for my partner—by then, my fiancé— so he could join me in the United States. He had an interview at the U.S. Embassy in Ankara, Turkey on November 7, 2016. 4. On January 17, 2017, we found out via an email from the U.S. Embassy in Ankara that my partner’s visa processing was complete. 5. On January 27, 2017, President Trump signed Executive Order 13769, entitled “Protecting the Nation from Foreign Terrorist Entry Into the United States,” which barred all Iranian nationals from coming to the United States. J.R.062 J.A. 323 Case 8:17-cv-00361-TDC Document 95-9 Filed 03/11/17 Page 2 of 4 6. On January 30, 2017, we received a subsequent email from the U.S. Embassy in Ankara, stating that my fiancé should not submit his passport because his visa process had been placed on hold until further notice. The email said he should check online and contact the Embassy when the ban was lifted to continue his visa processing. 7. On February 7, 2017, my partner received another email from the Embassy, informing him that he could now submit his passport for the visa because the Department of Justice had informed the embassy of the Washington State court ruling, barring the U.S. government from enforcing certain provisions of Executive Order 13769, including those related to visas and travel. 8. My partner and I made plans to meet in Turkey and to submit his passport for the visa processing. We arrived in Turkey on March 3, 2017. On March 6, 2017, we learned there was a new Executive Order that also barred Iranian nationals from coming to the United States unless their visa had already been issued. 9. We looked at the website of the U.S. Embassy in Ankara to see if there was an instruction not to submit passports because of the new order, but there was no new information. On March 8, 2017, we submitted my partner’s passport to the U.S. Embassy in Ankara through an express mail carrier. 10. The Executive Order is creating a significant hardship for me and my partner. I cannot visit him in Iran, given Iran’s reciprocal ban on U.S. citizen visitors, and the continued cost of flying to Turkey to be together is a considerable financial hardship. 11. Moreover, homosexuality is a crime in Iran, punishable in some cases by death. My partner has had two incidents with the morality police in Iran who harassed him on one occasion and assaulted him on another. For him, living each day hiding who he is and in J.R.063 J.A. 324 Case 8:17-cv-00361-TDC Document 95-9 Filed 03/11/17 Page 3 of 4 constant fear of exposure for his homosexuality is incredibly emotionally and mentally stressful. He wants the opportunity to live as himself, and I am eager for him to join me here in the United States where we can live openly together as a couple. 12. I am concerned that, even if there is a possibility of a waiver, my partner will have to start this lengthy process over again, and there is no guarantee that he will receive a waiver, even after previously being approved for a visa to the United States. I am also concerned that, as relations deteriorate between the United States and Iran, it will only become more difficult for my partner if the U.S. Embassy requires more information from Iran to process his visa. J.R.064 J.A. 325 Case 8:17-cv-00361-TDC Document 95-9 Filed 03/11/17 Page 4 of 4 J.A. 326 J.R.065 A.160 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 1 of 119 J.R.066 J.A. 327 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 2 of 119 J.R.067 J.A. 328 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 3 of 119 J.R.068 J.A. 329 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 4 of 119 J.R.069 J.A. 330 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 5 of 119 J.R.070 J.A. 331 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 6 of 119 J.R.071 J.A. 332 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 7 of 119 Exhibit A J.R.072 J.A. 333 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 8 of 119 Trump promises new immigration order as DOJ holds off appeals court By Laura Jarrett, Allie Malloy and Dan Merica, CNN Updated 11:38 PM ET, Thu February 16, 2017 New travel ban will be based on court decision 02:24 Story highlights Trump said Thursday that his administration will issue "a new and very comprehensive order to protect our people" next week Washington (CNN) — President Donald Trump vowed Thursday to roll out a new immigration executive order next week that will be tailored to the federal court decision that paused his travel ban. "The new order is going to be very much tailored to what I consider to be a very bad decision," said Trump during a news conference, referring to a decision by the Ninth Circuit Court of Appeals that blocked his travel ban earlier this month. The original three-judge panel retains control of the case and the travel ban remains on hold Meanwhile, the Justice Department told the Ninth Circuit Court of Appeals that it did not need a larger panel of judges to rehear its failed emergency challenge to a lower court's temporary suspension of Trump's executive order on immigration at this time, because a new order is on the way. The Ninth Circuit agreed Thursday evening to put any rehearing of the matter on hold for now. Trump press conference The Justice Department wrote at length in a 47-page about the "seriously flawed" Ninth Circuit ruling from last week, but neverthless said: "(r)ather than continuing this litigation, the President intends in the near future to rescind the order and replace it with a new, substantially revised executive order to eliminate what the panel erroneously thought were constitutional concerns." • • • • • • • • Amazing moment in history Most memorable lines To Jewish reporter: 'Sit down' To black reporter: 'Set up a meeting' Treatment of first lady 'unfair' OPINION: Performance fuels worry OPINION: Trump voters applaud presser Full transcript "In so doing, the President will clear the way for immediately protecting the country rather than pursuing further, potentially time-consuming litigation," it added. Questions have swirled over what the Trump administration would do this week after a three-judge panel on the Ninth Circuit refused to lift a federal judge's temporary restraining order on Trump's executive order barring foreign nationals from Iran, Sudan, Libya, Somalia, Syria, Iraq and Yemen from entering the country for 90 days, all refugees for 120 days and all refugees from Syria indefinitely. Last Friday, an unidentified judge on the Ninth Circuit requested that the full court vote on whether to rehear the decision reached by the three-judge panel. Such requests are not uncommon, but the call for a vote came at time when the Justice Department's position on pursuing the appeal was uncertain. The states that brought the lawsuit -- Washington and Minnesota -- said in their court filing on Thursday that there is no basis for rehearing the case, as the opinion from the three-judge panel is "firmly grounded in precedent." And while the nation waits on a new or modified executive order on immigration from the Trump administration, at least one federal court is barreling ahead on litigation over the original one. J.R.073 J.A. 334 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 9 of 119 US District Court Judge James Robart in Seattle -- the judge who originally halted the key provisions of the travel ban -- denied a request from the Trump administration earlier this week to postpone any further proceedings in his court, which means the parties will now proceed to the discovery phase of the case. Schwarzenegger's theory on Donald Trump 4 reasons why Republicans did Obamacare repeal before tax reform AARP comes out against House GOP health care bill Trump vs. Obama: A rocky relationship J.R.074 J.A. 335 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 10 of 119 Exhibit B J.R.075 J.A. 336 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 11 of 119 White House press secretary Sean Spicer said Tuesday that President Donald Trump will not rescind the original order. | Getty White House creates confusion about future of Trump's travel ban By MATTHEW NUSSBAUM, JOSH GERSTEIN and CRISTIANO LIMA | 02/21/17 05:06 PM EST | Updated 02/21/17 08:15 PM EST The White House is sending mixed signals as to whether or not it will rescind President Donald Trump's controversial travel ban even as officials seek to craft a new order that will be less vulnerable to legal challenge. The Justice Department told the 9th Circuit Court of Appeals last week that Trump will "rescind...and replace" the original order, which remains largely on hold after an appeals court panel upheld a lower court’s broad injunction. J.R.076 J.A. 337 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 12 of 119 But White House press secretary Sean Spicer said at the conclusion of his daily briefing Tuesday that Trump will not rescind the original order. Instead, the first order is being updated, Spicer insisted. The contradictory statements sowed further confusion about the fate of Trump's original order, which bars immigrants from seven Muslim-majority countries and halts the entry of refugees. "The new order is going to be very much tailored to what I consider to be a very bad decision," Trump said last week. White House creates confusion about future of Trump's travel ban An excerpt of Sean Spicer's remarks on Tuesday. 02/21/17 05:30 PM EST Spicer said the administration remains confident in the legality of its original order, but is also working with Cabinet agencies to prepare a new one. His statements seemed to leave open the possibility that there could be two orders in effect at once — a situation that could complicate efforts to defend the new order in court. The White House said Tuesday afternoon it intended to issue a clarification about the conflicting statements. J.R.077 J.A. 338 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 13 of 119 But a statement from the administration — released on Tuesday evening — did little to clear up any confusion. "The administration continues to defend the President’s national security Executive Order in court, and though we believe it to be fully lawful, we are simultaneously finalizing a revised policy tailored to the Ninth Circuit’s ruling," White House spokesman Michael Short said in a written statement. During an appearance on Fox News Tuesday, White House aide Stephen Miller similarly left the door open for the initial order to remain in place, adding only that the new policy would be "responsive" to recent court rulings. "These are mostly minor technical differences, fundamentally," he said of the forthcoming revised order. "You are still going to have the same basic policy outcome for the country but you are going to have a lot of technical issues brought up by the court." Miller added that the administration would be rolling out the details of the revised order "in the next few days." He also stood by the original executive order's constitutionality, despite the flurry of legal challenges to it. "The president's actions were clearly legal and constitutional and consistent with the longstanding traditions of presidents in the past to exercise the authority in the Immigration and Nationality Act to suspend immigration when it poses a threat to our security," he said. J.R.078 J.A. 339 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 14 of 119 Exhibit D J.R.079 J.A. 340 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 15 of 119 J.R.080 J.A. 341 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 16 of 119 J.R.081 J.A. 342 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 17 of 119 J.R.082 J.A. 343 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 18 of 119 J.R.083 J.A. 344 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 19 of 119 Exhibit E J.R.084 J.A. 345 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 20 of 119 - DECEMBER 07, 2015 - CATEGORIES DONALD J. TRUMP STATEMENT ON PREVENTING MUSLIM IMMIGRATION (New York, NY) December 7th, 2015, -- Donald J. Trump is calling VIEW ALL STATEMENTS ANNOUNCEMENTS for a total and complete shutdown of Muslims entering the United ENDORSEMENTS going on. According to Pew Research, among others, there is great hatred towards Americans by large segments of the Muslim ADS Center for Security Policy released data showing "25% of those polled agreed that a part of the global jihad" and 51% of those polled, "agreed that ARCHIVE Muslims in America should have the choice of being governed according to Shariah." Shariah authorizes such atrocities as murder unthinkable acts that pose great harm to Americans, especially women. NOVEMBER 2016 OCTOBER 2016 SEPTEMBER 2016 obvious to anybody the hatred is beyond comprehension. Where this hatred comes from and why we will have to determine. Until we dangerous threat it poses, our country cannot be the victims of horrendous attacks by people that believe only in Jihad, and have AUGUST 2016 JULY 2016 JUNE 2016 no sense of reason or respect for human life. If I win the election for President, we are going to Make America Great Again." - Donald J. Trump MAY 2016 APRIL 2016 MARCH 2016 Next Release: Donald J. Trump Announces State Directors in J.R.085 [2/12/2017 5:18:09 PM] FEBRUARY 2016 J.A. 346 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 21 of 119 Exhibit G J.R.086 J.A. 347 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 22 of 119 Full transcript: President Donald Trump's news conference Updated 4:12 AM ET, Fri February 17, 2017 Source: CNN President Trump's full press conference 01:16:56 PRESIDENT DONALD TRUMP HOLDS A NEWS CONFERENCE TO ANNOUNCE HIS NEW NOMINEE FOR SECRETARY OF LABOR FEBRUARY 16, 2017 SPEAKER: PRESIDENT DONALD TRUMP J.R.087 J.A. 348 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 23 of 119 [*] TRUMP: Thank you very much. I just wanted to begin by mentioning that the nominee for secretary of the Department of Labor will be Mr. Alex Acosta. He has a law degree from Harvard Law School, was a great student; former clerk for Justice Samuel Alito. And he has had a tremendous career. He's a member and has been a member of the National Labor Relations Board, and has been through Senate confirmation three times, confirmed; did very, very well. And so Alex, I've wished him the best. We just spoke. And he's going to be -- I think he'll be a tremendous secretary of labor. And also as you probably heard just a little while ago, Mick Mulvaney, former congressman, has just been approved weeks late, I have to say that, weeks, weeks late, Office of Management and Budget. And he will be I think a fantastic addition. Paul Singer just left. As you know, Paul was very much involved with the anti-Trump or as they say, "never Trump." And Paul just left and he's given us his total support. And it's all about unification. We're unifying the party and hopefully we're going to be able to unify the country. It's very important to me. I've been talking about that for a long time. It's very, very important to me. So I want to thank Paul Singer for being here and for coming up to the office. He was a very strong opponent, and now he's a very strong ally. And I appreciate that. I think I'll say a few words, and then we'll take some questions. And I had this time. We've been negotiating a lot of different transactions to save money on contracts that were terrible, including airplane contracts that were out of control and late and terrible; just absolutely catastrophic in terms of what was happening. And we've done some really good work. We're very proud of that. And then right after that, you prepare yourselves, we'll do some questions, unless you have enough questions. That's always a possibility. I'm here today to update the American people on the incredible progress that has been made in the last four weeks since my inauguration. We have made incredible progress. I don't think there's ever been a president elected who in this short period of time has done what we've done. Trump press conference • • • • • • • • Amazing moment in history Most memorable lines To Jewish reporter: 'Sit down' To black reporter: 'Set up a meeting' Treatment of first lady 'unfair' OPINION: Performance fuels worry OPINION: Trump voters applaud presser Full transcript A new Rasmussen poll, in fact -- because the people get it -- much of the media doesn't get it. They actually get it, but they don't write it. Let's put it that way. But a new Rasmussen poll just came out just a very short while ago, and it has our approval rating at 55 percent and going up. The stock market has hit record numbers, as you know. And there has been a tremendous surge of optimism in the business world, which is -- to me means something much different than it used to. It used to mean, "Oh, that's good." Now it means, "That's good for jobs." Very different. Plants and factories are already starting to move back into the United States, and big league -- Ford, General Motors, so many of them. I'm making this J.R.088 J.A. 349 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 24 of 119 presentation directly to the American people, with the media present, which is an honor to have you. This morning, because many of our nation's reporters and folks will not tell you the truth, and will not treat the wonderful people of our country with the respect that they deserve. And I hope going forward we can be a little bit -- a little bit different, and maybe get along a little bit better, if that's possible. Maybe it's not, and that's OK, too. TRUMP: Unfortunately, much of the media in Washington, D.C., along with New York, Los Angeles in particular, speaks not for the people, but for the special interests and for those profiting off a very, very obviously broken system. The press has become so dishonest that if we don't talk about, we are doing a tremendous disservice to the American people. Tremendous disservice. We have to talk to find out what's going on, because the press honestly is out of control. The level of dishonesty is out of control. I ran for president to present the citizens of our country. I am here to change the broken system so it serves their families and their communities well. I am talking -- and really talking on this very entrenched power structure, and what we're doing is we're talking about the power structure; we're talking about its entrenchment. As a result, the media is going through what they have to go through too often times distort - not all the time - and some of the media is fantastic, I have to say - they're honest and fantastic. But much of it is not a - the distortion -- and we'll talk about it, you'll be able to ask me questions about it. But we're not going to let it happen, because I'm here again, to take my message straight to the people. As you know, our administration inherited many problems across government and across the economy. To be honest, I inherited a mess. It's a mess. At home and abroad, a mess. Jobs are pouring out of the country; you see what's going on with all of the companies leaving our country, going to Mexico and other places, low pay, low wages, mass instability overseas, no matter where you look. The middle east is a disaster. North Korea - we'll take care of it folks; we're going to take care of it all. I just want to let you know, I inherited a mess. Beginning on day one, our administration went to work to tackle these challenges. On foreign affairs, we've already begun enormously productive talks with many foreign leaders, much of it you've covered, to move forward towards stability, security and peace in the most troubled regions of the world, which there are many. We have had great conversations with the United Kingdom, and meetings. Israel, Mexico, Japan, China and Canada, really, really productive conversations. I would say far more productive than you would understand. We've even developed a new council with Canada to promote women's business leaders and entrepreneurs. It's very important to me, very important to my daughter Ivanka. I have directed our defense community headed by our great general, now Secretary Mattis. He's over there now working very hard to submit a plan for the defeat of ISIS, a group that celebrates the murder and torture of innocent people in large sections of the world. It used to be a small group, now it's in large sections of the world. They've spread like cancer. ISIS has spread like cancer - another mess I inherited. And we have imposed new sanctions on the nation of Iran, whose totally taken advantage of our previous administration, and they're the world's top sponsor of terrorism, and we're not going to stop until that problem is properly solved. And it's not properly solved now, it's one of the worst agreements I've ever seen drawn by anybody. I've ordered plan to begin building for the massive rebuilding of the United States military. Had great support from the Senate, I've had great from Congress, generally. We've pursued this rebuilding in the hopes that we will never have to use this military, and I will tell you that is my - I would be so happy if we never had to use it. But our country will never have had a military like the military we're about to build and rebuild. We have the greatest people on earth in our military, but they don't have the right equipment and their equipment is old. I used it; I talked about it at every J.R.089 J.A. 350 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 25 of 119 stop. Depleted, it's depleted - it won't be depleted for long. And I think one of the reason I'm standing here instead of other people is that frankly, I talked about we have to have a strong military. We have to have a strong law enforcement also. So we do not go abroad in the search of war, we really are searching for peace, but its peace through strength. At home, we have begun the monumental task of returning the government back to the people on a scale not seen in many, many years. In each of these actions, I'm keeping my promises to the American people. These are campaign promises. Some people are so surprised that we're having strong borders. Well, that's what I've been talking about for a year and a half, strong borders. They're so surprised, oh, he having strong borders, well that's what I've been talking about to the press and to everybody else. One promise after another after years of politicians lying to you to get elected. They lied to the American people in order to get elected. Some of the things I'm doing probably aren't popular but they're necessary for security and for other reasons. And then coming to Washington and pursuing their own interests which is more important to many politicians. I'm here following through on what I pledged to do. That's all I'm doing. I put it out before the American people, got 306 electoral college votes. I wasn't supposed to get 222. They said there's no way to get 222, 230's impossible. 270 which you need, that was laughable. We got 306 because people came out and voted like they've never seen before so that's the way it goes. I guess it was the biggest electoral college win since Ronald Reagan. In other words, the media's trying to attack our administration because they know we are following through on pledges that we made and they're not happy about it for whatever reason. And - but a lot of people are happy about it. In fact, I'll be in Melbourne, Florida five o'clock on Saturday and I heard - just heard that the crowds are massive that want to be there. I turn on the T.V., open the newspapers and I see stories of chaos. Chaos. Yet it is the exact opposite. This administration is running like a fine- tuned machine, despite the fact that I can't get my cabinet approved. And they're outstanding people like Senator Dan Coats who's there, one of the most respected men of the Senate. He can't get approved. How do you not approve him? He's been a colleague - highly respected. Brilliant guy, great guy, everybody knows it. We're waiting for approval. So we have a wonderful group of people that's working very hard, that's being very much misrepresented about and we can't let that happen. So, if the Democrats who have - all you have to do is look at where they are right now. The only thing they can do is delay because they screwed things up royally, believe me. Let me list to you some of the things that we've done in just a short period of time. I just got here. And I got here with no cabinet. Again, each of these actions is a promise I made to the American people. I'll go over just some of them and we have a lot happening next week and in the weeks - in the weeks coming. We've withdrawn from the job-killing disaster known as Trans Pacific Partnership. We're going to make trade deals but we're going to have one on one deals, bilateral. We're going to have one on one deals. We've directed the elimination of regulations that undermine manufacturing and call for expedited approval of the permits needed for America and American infrastructure and that means plant, equipment, roads, bridges, factories. People take 10, 15, 20 years to get disapproved for a factory. They go in for a permit, it's many, many years. And then at the end of the process -- they spend 10s of millions of dollars on nonsense and at the end of the process, they get rejected. J.R.090 J.A. 351 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 26 of 119 Now, they may be rejected with me but it's going to be a quick rejection. Not going to take years. But mostly it's going to be an acceptance. We want plants built and we want factories built and we want the jobs. We don't want the jobs going to other countries. We've imposed a hiring freeze on nonessential federal workers. We've imposed a temporary moratorium on new federal regulations. We've issued a game-changing new rule that says for each one new regulation, two old regulations must be eliminated. Makes sense. Nobody's ever seen regulations like we have. You go to other countries and you look at indexes (ph) they have and you say "let me see your regulations" and they're fraction, just a tiny fraction of what we have. And I want regulations because I want safety, I want environmental - all environmental situations to be taken properly care of. It's very important to me. But you don't need four or five or six regulations to take care of the same thing. We've stood up for the men and women of law enforcement, directing federal agencies to ensure they are protected from crimes of violence. We've directed the creation of a task force for reducing violent crime in America, including the horrendous situation -- take a look at Chicago and others, taking place right now in our inner cities. Horrible. We've ordered the Department of Homeland Security and Justice to coordinate on a plan to destroy criminal cartels coming into the United States with drugs. We're becoming a drug infested nation. Drugs are becoming cheaper than candy bars. We are not going to let it happen any longer. We've undertaken the most substantial border security measures in a generation to keep our nation and our tax dollars safe. And are now in the process of beginning to build a promised wall on the southern border, met with general -- now Secretary Kelly yesterday and we're starting that process. And the wall is going to be a great wall and it's going to be a wall negotiated by me. The price is going to come down just like it has on everything else I've negotiated for the government. And we are going to have a wall that works, not gonna have a wall like they have now which is either non-existent or a joke. We've ordered a crackdown on sanctuary cities that refuse to comply with federal law and that harbor criminal aliens, and we have ordered an end to the policy of catch and release on the border. No more release. No matter who you are, release. We have begun a nationwide effort to remove criminal aliens, gang members, drug dealers and others who pose a threat to public safety. We are saving American lives every single day. The court system has not made it easy for us. And are even creating a new office in Homeland Security dedicated to the forgotten American victims of illegal immigrant violence, which there are many. We have taken decisive action to keep radical Islamic terrorists out of our country. No parts are necessary and constitutional actions were blocked by judges, in my opinion, incorrect, and unsafe ruling. Our administration is working night and day to keep you safe, including reporters safe. And is vigorously defending this lawful order. I will not back down from defending our country. I got elected on defense of our country. I keep my campaign promises, and our citizens will be very happy when they see the result. They already are, I can tell you that. Extreme vetting will be put in place and it already is in place in many places. In fact, we had to go quicker than we thought because of the bad decision we received from a circuit that has been overturned at a record number. I have heard 80 percent, I find that hard to believe, that is just a number I heard, that they are overturned 80 percent of the time. I think that circuit is -- that circuit is in chaos and that circuit is frankly in turmoil. But we are appealing that, and we are going further. We're issuing a new executive action next week that will comprehensively protect our country. So we'll be going along the one path and hopefully winning that, at the same time we will be issuing a new and very comprehensive order to protect our people. That will be done sometime next week, toward the J.R.091 J.A. 352 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 27 of 119 beginning or middle at the latest part. We have also taken steps to begin construction of the Keystone Pipeline and Dakota Access Pipelines. Thousands and thousands of jobs, and put new buy American measures in place to require American steel for American pipelines. In other words, they build a pipeline in this country, and we use the powers of government to make that pipeline happen, we want them to use American steel. And they are willing to do that, but nobody ever asked before I came along. Even this order was drawn and they didn't say that. TRUMP: And I'm reading the order, I'm saying, why aren't we using American steel? And they said, that's a good idea, we put it in. To drain the swamp of corruption in Washington, D.C., I've started by imposing a five-year lobbying ban on White House officials and a lifetime ban on lobbying for a foreign government. We've begun preparing to repeal and replace Obamacare. Obamacare is a disaster, folks. It is's disaster. I know you can say, oh, Obamacare. I mean, they fill up our alleys with people that you wonder how they get there, but they are not the Republican people our that representatives are representing. So we've begun preparing to repeal and replace Obamacare, and are deep in the midst of negotiations on a very historic tax reform to bring our jobs back, to bring our jobs back to this country. Big league. It's already happening. But big league. I've also worked to install a cabinet over the delays and obstruction of Senate Democrats. You've seen what they've done over the last long number of years. That will be one of the great cabinets ever assembled in American history. You look at Rex Tillerson. He's out there negotiating right now. General Mattis I mentioned before, General Kelly. We have great, great people. Mick is with us now. We have great people. Among their responsibilities will be ending the bleeding of jobs from our country and negotiating fair trade deals for our citizens. Now look, fair trade. Not free, fair. If a country is taking advantage of us, not going to let that happen anymore. Every country takes advantage of us almost. I may be able to find a couple that don't. But for the most part, that would be a very tough job for me to do. Jobs have already started to surge. Since my election, Ford announced it will abandon its plans to build a new factory in Mexico, and will instead invest $700 million in Michigan, creating many, many jobs. Fiat Chrysler announced it will invest $1 billion in Ohio and Michigan, creating 2,000 new American jobs. They were with me a week ago. You know you were here. General Motors likewise committed to invest billions of dollars in its American manufacturing operation, keeping many jobs here that were going to leave. And if I didn't get elected, believe me, they would have left. And these jobs and these things that I'm announcing would never have come here. Intel just announced that it will move ahead with a new plant in Arizona that probably was never going to move ahead with. And that will result in at least 10,000 American jobs. Walmart announced it will create 10,000 jobs in the United States just this year because of our various plans and initiatives. There will be many, many more, many more, these are a few that we're naming. Other countries have been taking advantage of us for decades -- decades, and decades, and decades, folks. And we're not going to let that happen anymore. Not going to let it happen. J.R.092 J.A. 353 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 28 of 119 And one more thing, I have kept my promise to the American people by nominating a justice of the United States Supreme Court, Judge Neil Gorsuch, who is from my list of 20, and who will be a true defender of our laws and our Constitution, highly respected, should get the votes from the Democrats. You may not see that. But he'll get there one way or the other. But he should get there the oldfashioned way, and he should get those votes. This last month has represented an unprecedented degree of action on behalf of the great citizens of our country. Again, I say it. There has never been a presidency that's done so much in such a short period of time. And we have not even started the big work yet. That starts early next week. Some very big things are going to be announced next week. So we are just getting started. We will be giving a speech, as I said, in Melbourne, Florida, at 5:00 p.m. I hope to see you there. And with that, I just say, God bless America, and let's take some questions. Mara (ph), Mara (ph), go ahead. You were cut off pretty violently at our last news conference. QUESTION: (OFF-MIKE) TRUMP: Mike Flynn is a fine person, and I asked for his resignation. He respectfully gave it. He is a man who there was a certain amount of information given to Vice President Pence, who is with us today. And I was not happy with the way that information was given. He didn't have to do that, because what he did wasn't wrong -- what he did in terms of the information he saw. What was wrong was the way that other people, including yourselves in this room, were given that information, because that was classified information that was given illegally. That's the real problem. And, you know, you can talk all you want about Russia, which was all a, you know, fake news, fabricated deal, to try and make up for the loss of the Democrats and the press plays right into it. In fact, I saw a couple of the people that were supposedly involved with all of this -- that they know nothing about it; they weren't in Russia; they never made a phone call to Russia; they never received a phone call. It's all fake news. It's all fake news. The nice thing is, I see it starting to turn, where people are now looking at the illegal -- I think it's very important -- the illegal, giving out classified information. It was -and let me just tell you, it was given out like so much. I'll give you an example. I called, as you know, Mexico. It was a very, very confidential, classified call. But I called Mexico. And in calling Mexico, I figured, oh, well that's -- I spoke to the president of Mexico; I had a good call. All of a sudden, it's out there for the world to see. It's supposed to be secret. It's supposed to be either confidential or classified, in that case. Same thing with Australia. All of a sudden, people are finding out exactly what took place. The same thing happened with respect to General Flynn. Everybody saw this. And I'm saying -- the first thing I thought of when I heard about it is: How does the press get this information that's classified? How do they do it? You know why? Because it's an illegal process and the press should be ashamed of themselves. But more importantly, the people that gave out the information to the press should be ashamed of themselves, really ashamed. Yes, go ahead. J.R.093 J.A. 354 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 29 of 119 QUESTION: (OFF-MIKE) TRUMP: Because when I looked at the information, I said, "I don't think he did anything wrong; if anything, he did something right." He was coming into office. He looked at the information. He said, "Huh, that's fine." That's what they're supposed to do. They're supposed to -- he didn't just call Russia. He called and spoke to both ways, I think there were 30-some-odd countries. He's doing the job. You know, he was doing his job. The thing is, he didn't tell our vice president properly, and then he said he didn't remember. So either way, it wasn't very satisfactory to me. And I have somebody that I think will be outstanding for the position. And that also helps, I think, in the making of my decision. But he didn't tell the vice president of the United States the facts. And then he didn't remember. And that just wasn't acceptable to me. Yes? QUESTION: (inaudible) clarification here. During your campaign, did anyone from your team (inaudible) Russian government or Russian intelligence? And if so, what was the nature of those conversations (inaudible)? TRUMP: The failing New York Times wrote a big, long front-page story yesterday. And it was very much discredited, as you know. It was -- it's a joke. And the people mentioned in the story, I notice they were on television today saying they never even spoke to Russia. They weren't even a part, really -I mean, they were such a minor part. They -- I hadn't spoken to them. I think the one person -- I don't think I've ever spoken to him. I don't think I've ever met him. And he actually said he was a very low-level member of I think a committee for a short period of time. I don't think I ever met him. Now, it's possible that I walked into a room and he was sitting there, but I don't think I ever met him. I didn't talk to him ever. And he thought it was a joke. The other person said he never spoke to Russia; never received a call. Look at his phone records, et cetera, et cetera. And the other person, people knew that he represented various countries, but I don't think he represented Russia, but knew that he represented various countries. That's what he does. I mean, people know that. That's Mr. Manafort, who's -- by the way, who's by the way a respected man. He's a respected man. But I think he represented the Ukraine or Ukraine government or somebody, but everybody -- people knew that. Everybody knew that. So, these people -- and he said that he has absolutely nothing to do and never has with Russia. And he said that very forcefully. I saw his statement. He said it very forcefully. Most of the papers don't print it because that's not good for their stories. TRUMP: So the three people that they talked about all totally deny it. And I can tell you, speaking for myself, I own nothing in Russia. I have no loans in Russia. I don't have any deals in Russia. President Putin called me up very nicely to congratulate me on the win of the election. He then, called me up extremely nicely to congratulate me on the inauguration, which was terrific. But so did many other leaders, almost all other leaders from almost all of the country. So that's the extent. Russia is fake news. Russia -- this is fake news put out by the media. The real news is the fact that people, probably from the Obama administration because they're there, because we have our new people going in place, right now. J.R.094 J.A. 355 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 30 of 119 As you know, Mike Pompeo has -- has now taken control of the CIA, James Comey at FBI, Dan Coats is waiting to be approved, I mean he is a senator and a highly respected one and he's still waiting to be approved. But our new people are going in. And just while you're at it, because you mentioned this, Wall Street Journal did a story today that was almost as disgraceful as the failing New York Time's story, yesterday. And it talked about -- these are (ph) front page. So director of national intelligence just put out, acting a statement, any suggestion that the United States intelligence community, this was just given to us, is withholding information and not providing the best possible intelligence to the president and his national security team is not true. So they took this front page story out of The Wall Street Journal top and they just wrote the story that its not true. And I'll tell you something, I'll be honest, because I sort of enjoy this back and forth that I guess I have all my life but I've never seen more dishonest media than frankly, the political media. I thought the financial media was much better, much more honest. But I will say that, I never get phone calls from the media. How did they write a story like that in The Wall Street Journal without asking me or how did they write a story in The New York Times, put it on front page? That was like the story they wrote about the women and me, front page, big massive story. And it was nasty and then they called, they said we never said that, we like Mr. Trump. They called up my office, we like Mr. Trump, we never said that. And it was totally -- they totally misrepresented those very wonderful women, I have to tell you, totally misrepresented. I said give us the retraction. They never gave us a retraction and frankly, I then went on to other things. OK, go ahead. QUESTION: (OFF-MIKE) said today that you have big intellectual margins (inaudible) 300 or more (ph), or 350 (ph) electoral (ph) votes. President Obama about 365 (OFF-MIKE). (CROSSTALK) TRUMP: Yeah. QUESTION: Obama (OFF-MIKE) 426 on (OFF-MIKE). So why should Americans... (CROSSTALK) TRUMP: ...I'm skipping that information, I don't know, I was just given (ph) we had a very, very big margin. QUESTION: (OFF-MIKE) why should Americans trust you (OFF-MIKE) the information (OFF-MIKE)? TRUMP: Well, I don't know, I was given that information. I was given -- I actually, I've seen that information around. But it was a very substantial victory, do you agree with that? OK thank you, that's... (CROSSTALK) TRUMP: Go ahead Sir, yes? J.R.095 J.A. 356 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 31 of 119 QUESTION: Can you tell us in determining that Lieutenant General Flynn did -- whether there was no wrongdoing in your mind, what evidence was weighed? Did you ask for transcripts of these telephone intercepts with Russian officials, particularly the Ambassador Sergey Kislyak, who he was communicating with? What-- what evidence did you weigh to determine that there was no wrongdoing? Further to that, Sir, you said on a couple of locations this morning, you are going to aggressively pursue the source of these leaks. TRUMP: We are. QUESTION: Can we ask what you're going to do and also, we've heard about a -- a review of the intelligence community headed up by Steven Feinberg, what can you tell us about that? TRUMP: Well, first of all about that, we now have Dan Coats, hopefully soon, Mike Pompeo and James Comey and they're in position so I hope that we'll be able to straighten that out without using anybody else. The gentleman you mentioned is a very talented man, very successful man and he's offered his services and you know, it's something we may take advantage of. But I don't think we're need that at all because of the fact that you know, I think that we are gonna be able to straighten it out very easily on its own. As far as the general's concerned, when I first heard about it, I said huh, that doesn't sound wrong. My counsel came, Don McGahn, White House Counsel, and he told me and I asked him, he can speak very well for himself. He said he doesn't think anything is wrong, you know, really didn't think. It was really, what happened after that but he didn't think anything was done wrong. I didn't either because I waited a period of time and I started to think about it, I said "well I don't see" -- to me, he was doing the job. The information was provided by -- who I don't know, Sally Yates. And I was a little surprised because I said "doesn't sound like he did anything wrong there." But he did something wrong with respect to the vice president and I thought that was not acceptable. As far as -- as far as the actual making the call, fact I've watched various programs and I've read various articles where he was just doing his job. That was very normal. You know, first everybody got excited because they thought he did something wrong. After they thought about it, it turned out he was just doing his job. So -- and I do. And by the way, with all of that being said, I do think he's a fine man. QUESTION: Sir, if I could, on the leaks -- on the leaks, sir... TRUMP: ...Go ahead. Finish off then I'll get you. QUESTION: I'm sorry. What will you do on the leaks? You've said twice today... TRUMP: ...Yes, we're looking at them very -- very, very serious. I've gone to all of the folks in charge of the various agencies and we're -- I've actually called the Justice Department to look into the leaks. Those are criminal leaks. They're put out by people either in agencies -- I think you'll see it stopping because now we have our people in. You know, again, we don't have our people in because we can't get them approved by the Senate. We just had Jeff Sessions approved. Injustice, as an example (ph). So, we are looking into that very seriously. It's a criminal act. You know what I say, when I -- when I was called out on Mexico, I was J.R.096 J.A. 357 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 32 of 119 shocked because all this equipment, all this incredible phone equipment -- when I was called out on Mexico, I was -- honestly, I was really, really surprised. But I said "you know, it doesn't make sense. That won't happen" but that wasn't that important a call, it was fine, I could show it to the world and he could show it to the world, the president who's a very fine man, by the way. Same thing with Australia. I said "that's terrible that it was leaked" but it wasn't that important. But then I said to myself "what happens when I'm dealing with the problem of North Korea?" What happens when I'm dealing with the problems in the Middle East? Are you folks going to be reporting all of that very, very confidential information, very important, very -- you know, I mean at the highest level? Are you going to be reporting about that too? So, I don't want classified information getting out to the public and in a way that was almost a test. So I'm dealing with Mexico, I'm dealing with Argentina, we were dealing on this case with Mike Flynn. All this information gets put into the "Washington Post" and gets put into the "New York Times" and I'm saying "what's going to happen when I'm dealing on the Middle East? What's going to happen when I'm dealing with really, really important subjects like North Korea? We got to stop it. That's why it's a criminal penalty. QUESTION: I just want to get you to clarify this very important point. Can you say definitively that nobody on your campaign had any contacts with the Russians during the campaign? And on the leaks, is it fake news or are these real leaks? TRUMP: Well the leaks are real. You're the one that wrote about them and reported them, I mean the leaks are real. You know what they said, you saw it and the leaks are absolutely real. The news is fake because so much of the news is fake. So one thing that I felt it was very important to do -- and I hope we can correct it. Because there's nobody I have more respect for -- well, maybe a little bit but the reporters, good reporters. It's very important to me and especially in this position. It's very important. I don't mind bad stories. I can handle a bad story better than anybody as long as it's true and, you know, over a course of time, I'll make mistakes and you'll write badly and I'm OK with that. But I'm not OK when it is fake. I mean, I watch CNN, it's so much anger and hatred and just the hatred. I don't watch it any more because it's very good -- he's saying no. It's OK, Jim (ph). It's OK, Jim (ph), you'll have your chance. But I watch others too. You're not the only one so don't feel badly. But I think it should be straight. I think it should be -- I think it would be frankly more interesting. I know how good everybody's ratings are right now but I think that actually -- I think that'd actually be better. People -- I mean, you have a lower approval rate than Congress. I think that's right. I don't know, Peter (ph), is that one right? Because you know I think they have lower -- I heard lower than Congress. But honestly, the public would appreciate it, I'd appreciate it -- again, I don't mind bad stories when it's true but we have an administration where the Democrats are making it very difficult. TRUMP: I think we're setting a record or close to a record in the time of approval of a cabinet. I mean, the numbers are crazy. When I'm looking, some of them had them approved immediately. I'm going forever and I still have a lot of people that we're waiting for. And that's all they're doing, is delaying. And you look at Schumer and the mess that he's got over there and they have nothing going. The only thing they can do is delay. And, you know, I think that they'd be better served by, you know, approving and making sure that they're happy and everybody's good. J.R.097 J.A. 358 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 33 of 119 And sometimes -- I mean, I know President Obama lost three or four, and you lose them on the way, and that's OK. That's fine. But I think it would -- I think they would be much better served, John, if they just went through the process quickly. This is pure delay tactics. And they say it, and everybody understands it. Yeah, go ahead, Jimmy. QUESTION: (OFF-MIKE) TRUMP: Well, I had nothing to do with it. I have nothing to do with Russia. I told you, I have no deals there, I have no anything. Now, when WikiLeaks, which I had nothing to do with, comes out and happens to give, they're not giving classified information. They're giving stuff -- what was said at an office about Hillary cheating on the debates. Which, by the way, nobody mentions. Nobody mentions that Hillary received the questions to the debates. Can you imagine -- seriously -- can you imagine if I received the questions? It would be the electric chair. OK, he should be put in the electric -- you would even call for the reinstitution of the death penalty, OK. Maybe not you John. Yes? We'll do you next Jim, I do you next(ph). QUESTION: (OFF-MIKE) clarify -TRUMP: Yes, yes, sure QUESTION: Did you direct Mike Flynn to discuss sanctions with the Russian ambassador -TRUMP: No, I didn't. QUESTION: -- prior to your -- TRUMP: No, I didn't. QUESTION: -- inauguration. TRUMP: No, I didn't. QUESTION: And then fired him -TRUMP: Excuse me. QUESTION: (OFF-MIKE) TRUMP: No, I fired him because of what he said to Mike Pence. Very simple. Mike was doing his job. He was calling countries and his counterparts. So, it certainly would have been OK with me if he did it. I would have directed him to do it if I thought he wasn't doing it. I didn't direct him, but I would have directed him because that's his job. And it came out that way -- and in all fairness, I watched Dr. Charles Krauthammer the other night say he was doing his job and I agreed with him. And since then, I've watched many other people say that. No, I didn't direct him, but I would have directed him if he didn't do it. OK? Jim? QUESTION: Thank you very much, and just for the record, we don't hate you. I don't hate you. TRUMP: OK. QUESTION: So, pass that along -TRUMP: Ask -- ask Jeff Zucker how he got his job. OK? J.R.098 J.A. 359 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 34 of 119 QUESTION: If I may follow up on some of the questions that have taken place so far here, sir -TRUMP: Well, that's -- well, you know, we do have other people. You do have other people and your ratings aren't as good as some of the other people that are waiting. QUESTION: It's pretty good right now, actually. TRUMP: OK, go ahead, John. QUESTION: If I may ask, sir, you said earlier that WikiLeaks was revealing information about the Hillary Clinton campaign during the election cycle. You welcomed that. At one time -TRUMP: I was OK with it. QUESTION: -- you said -- you said that you loved WikiLeaks. At another campaign press conference you called on the Russians to find the missing 30,000 e-mails. I'm wondering, sir, if you -- TRUMP: Well, she was actually missing 33 and then that got extended with a pile after that. QUESTION: Then(ph), your(ph) numbers(ph) were off too. TRUMP: No -- no, but I did say 30. But it was actually higher than that. QUESTION: If -- if I may ask you, sir, it -- it sounds as though you do not have much credibility here when it comes to leaking if that is something that you encouraged during(ph) the campaign -TRUMP: OK, fair question. Ready? QUESTION: Well, if I may ask you that -TRUMP: No -- no, but let me do one at a time. QUESTION: If I may as a follow up? TRUMP: Do you mind? QUESTION: Yes, sir. TRUMP: All right. So, in one case, you're talking about highly classified information. In the other case, you're talking about John Podesta saying bad things about the boss. I will say this, if John Podesta said that about me and he was working for me, I would have fired him so fast your head would have spun. He said terrible things about her. But it wasn't classified information. But in one case, you're talking about classified -- regardless, if you look at the RNC, we had a very strong -- at my suggestion -- and I give Reince great credit for this -- at my suggestion, because I know something about this world, I said I want a very strong defensive mechanism. I don't want to be hacked. And we did that. And you have seen that they tried to hack us and they failed. The DNC did not do that. And if they did it, they could not have been hacked. But they were hacked and terrible things came in. And, you know, the only thing that I do think is unfair is some of the things were so -- they were -- when I heard some of those things I picked up the papers the next morning and said, oh, this is going to be front page, it wasn't even in the papers. J.R.099 J.A. 360 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 35 of 119 Again, if I had that happen to me, it would be the biggest story in the history of publishing or the head of newspapers. I would have been headline in every newspaper. I mean, think of it. They gave her the questions to a debate and she -- and she should have reported herself. Why did Hillary Clinton announce that, "I'm sorry, but I have been given the questions to a debate or a town hall, and I feel that it's inappropriate, and I want to turn in CNN for not doing a good job." QUESTION: And if I may follow up on that, just something that Jonathan Karl (ph) was asking you about. You said that the leaks are real, but the news is fake. I guess I don't understand. It seems that there's a disconnect there. If the information coming from those leaks is real, then how can the stories be fake? TRUMP: The reporting is fake. Look, look... (CROSSTALK) TRUMP: You know what it is? Here's the thing. The public isn't -- you know, they read newspapers, they see television, they watch. They don't know if it's true or false because they're not involved. I'm involved. I've been involved with this stuff all my life. But I'm involved. So I know when you're telling the truth or when you're not. I just see many, many untruthful things. And I'll tell you what else I see. I see tone. You know the word "tone." The tone is such hatred. I'm really not a bad person, by the way. No, but the tone is such -- I do get good ratings, you have to admit that -the tone is such hatred. I watched this morning a couple of the networks. And I have to say, Fox & Friends in the morning, they're very honorable people. They're very -- not because they're good, because they hit me also when I do something wrong. But they have the most honest morning show. That's all I can say. It's the most honest. But the tone, Jim. If you look -- the hatred. The, I mean, sometimes -- sometimes somebody gets... (CROSSTALK) TRUMP: Well, you look at your show that goes on at 10 o'clock in the evening. You just take a look at that show. That is a constant hit. The panel is almost always exclusive anti-Trump. The good news is he doesn't have good ratings. But the panel is almost exclusive anti-Trump. And the hatred and venom coming from his mouth; the hatred coming from other people on your network. Now, I will say this. I watch it. I see it. I'm amazed by it. And I just think you'd be a lot better off, I honestly do. The public gets it, you know. Look, when I go to rallies, they turn around, they start screaming at CNN. They want to throw their placards at CNN. You know. I -- I think you would do much better by being different. But you just take a look. Take a look at some of your shows in the morning and the evening. If a guest comes out and says something positive about me, it's -- it's brutal. Now, they'll take this news conference -- I'm actually having a very good time, OK? But they'll take this news conference -- don't forget, that's the way I won. Remember, I used to give you a news conference every time I made a speech, which was like every day. OK? (CROSSTALK) TRUMP: No, that's how I won. I won with news conferences and probably speeches. I certainly didn't win by people listening to you people. That's for sure. But I'm having a good time. J.R.100 J.A. 361 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 36 of 119 Tomorrow, they will say, "Donald Trump rants and raves at the press." I'm not ranting and raving. I'm just telling you. You know, you're dishonest people. But -- but I'm not ranting and raving. I love this. I'm having a good time doing it. But tomorrow, the headlines are going to be, "Donald Trump rants and raves." I'm not ranting and raving. Go ahead. QUESTION: If I may, just one more followup... TRUMP: Should I let him have a little bit more? What do you think, Peter? Peter, should I have -- let him have a little bit more? Sit down. Sit down. We'll... (CROSSTALK) QUESTION: Just because of the attack of fake news and attacking our network, I just want to ask you, sir... TRUMP: I'm changing it from fake news, though. QUESTION: Doesn't that under... TRUMP: Very fake news. QUESTION: ... I know, but aren't you... (LAUGHTER) TRUMP: Go ahead. QUESTION: Real news, Mr. President, real news. TRUMP: And you're not related to our new... QUESTION: I am not related, sir. No. I do like the sound of Secretary Acosta, I must say. TRUMP: I looked -- you know, I looked at that name. I said, wait a minute, is there any relation there? Alex Acosta. QUESTION: I'm sure you checked that out, sir. TRUMP: OK. Now I checked it -- I said -- they said, "No, sir." I said, "Do me a favor, go back and check the family tree." QUESTION: But aren't you -- aren't you concerned, sir, that you are undermining the people's faith in the First Amendment, freedom of the press, the press in this country, when you call stories you don't like "fake news"? Why not just say it's a story I don't like. TRUMP: I do that. QUESTION: When you call it "fake news," you're undermining confidence in our news media (inaudible) important. J.R.101 J.A. 362 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 37 of 119 TRUMP: No, no. I do that. Here's the thing. OK. I understand what you're -- and you're right about that, except this. See, I know when I should get good and when I should get bad. And sometimes I'll say, "Wow, that's going to be a great story." And I'll get killed. I know what's good and bad. I'd be a pretty good reporter, not as good as you. But I know what's good. I know what's bad. And when they change it and make it really bad, something that should be positive -- sometimes something that should be very positive, they'll make OK. They'll even make it negative. So I understand it. So, because I'm there. I know what was said. I know who's saying it. I'm there. So it's very important to me. Look, I want to see an honest press. When I started off today by saying that it's so important to the public to get an honest press. The press -- the public doesn't believe you people anymore. Now, maybe I had something to do with that. I don't know. But they don't believe you. If you were straight and really told it like it is, as Howard Cosell used to say, right? Of course, he had some questions also. But if you were straight, I would be your biggest booster. I would be your biggest fan in the world, including bad stories about me. But if you go - as an example, you're CNN, I mean it's story after story after story is bad. I won. I won. And the other thing, chaos because zero chaos. We are running - this is a fine-tuned machine and Reince happens to be doing a good job but half of his job is putting out lies by the press (ph). You know, I said to him yesterday this whole Russia scam that you guys are building so that you don't talk about the real subject which is illegal leaks, but I watched him yesterday working so hard to try and get that story proper. And I'm saying "here's my chief of staff," a really good guy, did a phenomenal job at RNC. I mean, he won the election, right? We won the presidency. We got some senators, we got some - all over the country, you take a look, he's done a great job. And I said to myself, you know - and I said to somebody that was in the room, I said "you take a look at Reince, he's working so hard just putting out fires that are fake fires." I mean, they're fake. They're not true. And isn't that a shame because he'd rather be working on healthcare, he'd rather be working on tax reform, Jim (ph). I mean that. I would be your biggest fan in the world if you treated me right. I sort of understand there's a certain bias maybe by Jeff (ph) or somebody, you know - you know, whatever reason. But - and I understand that. But you've got to be at least a little bit fair and that's why the public sees it. They see it. They see it's not fair. You take a look at some of your shows and you see the bias and the hatred. And the public is smart, they understand it. Go ahead. QUESTION: (inaudible) ...for those who believe that there is something to it, is there anything that you have learned over the last few weeks that you might be able to reveal that might ease their concerns that this isn't fake news? And second... TRUMP: ...I think they don't believe it. I don't think the public - that's why the Rasmussen poll just has me through the roof. I don't think they believe it. Well, I guess one of the reasons I'm here today is to tell you the whole Russian thing, that's a ruse. That's a ruse. And by the way, it would be great if we could get along with Russia, just so you understand that. Now tomorrow, you'll say "Donald Trump wants to get along with Russia, this is terrible." It's not terrible. It's good. We had Hillary Clinton try and do a reset. We had Hillary Clinton give Russia 20 percent of the uranium in our country. You know what uranium is, right? This thing called nuclear weapons like lots of things are done with uranium including some bad things. J.R.102 J.A. 363 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 38 of 119 Nobody talks about that. I didn't do anything for Russia. I've done nothing for Russia. Hillary Clinton gave them 20 percent of our uranium. Hillary Clinton did a reset, remember? With the stupid plastic button that made us all look like a bunch of jerks. Here, take a look. He looked at her like, what the hell is she doing with that cheap plastic button? Hillary Clinton - that was the reset, remember it said reset? Now if I do that, oh, I'm a bad guy. If we could get along with Russia, that's a positive thing. We have a very talented man, Rex Tillerson, who's going to be meeting with them shortly and I told him. I said "I know politically it's probably not good for me." The greatest thing I could do is shoot that ship that's 30 miles off shore right out of the water. Everyone in this country's going to say "oh, it's so great." That's not great. That's not great. I would love to be able to get along with Russia. Now, you've had a lot of presidents that haven't taken that tack. Look where we are now. Look where we are now. So, if I can - now, I love to negotiate things, I do it really well, and all that stuff. But - but it's possible I won't be able to get along with Putin. Maybe it is. But I want to just tell you, the false reporting by the media, by you people, the false, horrible, fake reporting makes it much harder to make a deal with Russia. And probably Putin said "you know." He's sitting behind his desk and he's saying "you know, I see what's going on in the United States, I follow it closely. It's going to be impossible for President Trump to ever get along with Russia because of all the pressure he's got with this fake story." OK? And that's a shame because if we could get along with Russia - and by the way, China and Japan and everyone. If we could get along, it would be a positive thing, not a negative thing. QUESTION: Is tax reform on the line (ph)? QUESTION: Mr. President? Mr. President? Mr. President, since you... TRUMP: Tax reform is going to happen fairly quickly. We're doing Obamacare. We're in final stages. We should be submitting the initial plan in March, early March, I would say. And we have to, as you know, statutorily and for reasons of budget, we have to go first. It's not like, frankly, the tax would be easier, in my opinion, but for statutory reasons and for budgetary reasons, we have to submit the healthcare sooner. So we'll be submitting healthcare sometime in early March, mid- March. And after that, we're going to come up, and we're doing very well on tax reform. Yes? QUESTION: Mr. President, you mentioned Russia. Let's talk about some serious issues that have come up in the last week that you have had to deal with as president of the United States. TRUMP: OK. QUESTION: You mentioned the vessel -- the spy vessel off the coast of the United States. TRUMP: Not good. QUESTION: There was a ballistic missile test that many interpret as a violation of an agreement between the two countries; and a Russian plane buzzed a U.S. destroyer. TRUMP: Not good. QUESTION: I listened to you during the campaign ... J.R.103 J.A. 364 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 39 of 119 TRUMP: Excuse me, excuse me. When did it happen? It happened when, if you were Putin right now, you would say, "Hey, we're back to the old games with the United States; there's no way Trump can ever do a deal with us." Because the -- you have to understand. If I was just brutal on Russia right now, just brutal, people would say, you would say, "Oh, isn't that wonderful." But I know you well enough. Then you would say, "Oh, he was too tough; he shouldn't have done that." Look, all of the... (CROSSTALK) QUESTION: I'm just trying to find out your orientation to those... (CROSSTALK) TRUMP: Wait a minute. Wait, wait. Excuse me just one second. (CROSSTALK) TRUMP: All of those things that you mentioned are very recent, because probably Putin assumes that he's not going to be able to make a deal with me because it's politically not popular for me to make a deal. So Hillary Clinton tries a re-set. It failed. They all tried. But I'm different than those people. Go ahead. QUESTION: How are you interpreting those moves? And what do you intend to do about them? Have you given Rex Tillerson any advice or counsel on how to deal? TRUMP: I have. I have. And I'm so beautifully represented. I'm so honored that the Senate approved him. He's going to be fantastic. Yes, I think that I've already... QUESTION: Is Putin testing you, do you believe, sir? TRUMP: No, I don't think so. I think Putin probably assumes that he can't make a deal with me anymore because politically it would be unpopular for a politician to make a deal. I can't believe I'm saying I'm a politician, but I guess that's what I am now. Because, look, it would be much easier for me to be tough on Russia, but then we're not going to make a deal. Now, I don't know that we're going to make a deal. I don't know. We might. We might not. But it would be much easier for me to be so tough -- the tougher I am on Russia, the better. But you know what? I want to do the right thing for the American people. And to be honest, secondarily, I want to do the right thing for the world. If Russia and the United States actually got together and got along -- and don't forget, we're a very powerful nuclear country and so are they. There's no up-side. We're a very powerful nuclear country and so are they. I have been briefed. And I can tell you one thing about a briefing that we're allowed to say because anybody that ever read the most basic book can say it, nuclear holocaust would be like no other. They're a very powerful nuclear country and so are we. If we have a good relationship with Russia, believe me, that's a good thing, not a bad thing. J.R.104 J.A. 365 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 40 of 119 QUESTION: So when you say they're not good, do you mean that they are... TRUMP: Who did I say is not good? QUESTION: No, I read off the three things that have recently happened. Each one of them you said they're not good. (CROSSTALK) TRUMP: No, it's not good, but they happened. QUESTION: But do they damage the relationship? Do they undermine... TRUMP: They all happened recently. No... (CROSSTALK) QUESTION: ... this country's ability to work with Russia? TRUMP: They all happened recently. And I understand what they're doing because they're doing the same thing. Now, again, maybe I'm not going to be able to do a deal with Russia, but at least I will have tried. And if I don't, does anybody really think that Hillary Clinton would be tougher on Russia than Donald Trump? Does anybody in this room really believe that? OK? But I tell you one thing, she tried to make a deal. She had the re-set. She gave all that valuable uranium away. She did other things. You know, they say I'm close to Russia. Hillary Clinton gave away 20 percent of the uranium in the United States. She's close to Russia. QUESTION: Can we... TRUMP: I gave -- you know what I gave to Russia? You know what I gave? Nothing. QUESTION: Can we conclude there will be no response to these particular provocations? TRUMP: I'm not going to tell you anything about what response I do. I don't talk about military response. I don't say I'm going into Mosul in four months. "We are going to attack Mosul in four months." Then three months later, "We are going to attack Mosul in one month." "Next week, we are going to attack Mosul." In the meantime, Mosul is very, very difficult. Do you know why? Because I don't talk about military, and I don't talk about certain other things, you're going to be surprised to hear that. And by the way, my whole campaign, I'd say that. So I don't have to tell you. I don't want to be one of these guys that say, "Yes, here's what we're going to do." I don't have to do that. I don't have to tell you what I'm going to do in North Korea. (CROSSTALK) TRUMP: Wait a minute. I don't have to tell you what I'm going to do in North Korea. And I don't have to tell you what I'm going to do with Iran. You know why? Because they shouldn't know. And eventually, you guys are going to get tired of asking that question. J.R.105 J.A. 366 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 41 of 119 TRUMP: So when you ask me what am I going to do with a ship, the Russian ship as an example, I'm not going to tell you. But hopefully, I won't have to do anything, but I'm not going to tell you. OK. QUESTION: Could I just ask you -- thank you very much, Mr. President. The trouble... TRUMP: Where are you from? QUESTION: BBC. TRUMP: Here's another beauty. QUESTION: That's a good line. Impartial, free and fair. TRUMP: Yeah. Sure. QUESTION: Mr. President... TRUMP: Just like CNN right? QUESTION: On the travel ban -- we could banter back and forth. On the travel ban would you accept that that was a good example of the smooth running of government... TRUMP: Yeah, I do. I do. Let me tell you about this government... QUESTION: Were there any mistakes... TRUMP: Wait. Wait. I know who you are. Just wait. Let me tell you about the travel ban. We had a very smooth rollout of the travel ban. But we had a bad court. Got a bad decision. We had a court that's been overturned. Again, may be wrong. But I think it's 80 percent of the time, a lot. We had a bad decision. We're going to keep going with that decision. We're going to put in a new executive order next week some time. But we had a bad decision. That's the other thing that was wrong with the travel ban. You had Delta with a massive problem with their computer system at the airports. You had some people that were put out there, brought by very nice busses, and they were put out at various locations. Despite that the only problem that we had is we had a bad court. We had a court that gave us what I consider to be, with great respect, a very bad decision. Very bad for the safety and security of our country. The rollout was perfect. Now, what I wanted to do was do the exact same executive order, but said one thing. I said this to my people. Give them a one-month period of time. But Gen. Kelly, now Sec. Kelly, said if you do that, all these people will come in and (inaudible) the bad ones. You do agree there are bad people out there, right? That not everybody that's like you. You have some bad people out there. J.R.106 J.A. 367 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 42 of 119 Kelly said you can't do that. And he was right. As soon as he said it I said wow, never thought of it. I said how about one week? He said no good. You got to do it immediately because if you do it immediately they don't have time to come in. Now nobody ever reports that. But that's why we did it quickly. Now, if I would've done it a month, everything would've been perfect. The problem is we would've wasted a lot of time, and maybe a lot of lives because a lot of bad people would've come into our country. Now in the meantime, we're vetting very, very strongly. Very, very strongly. But we need help. And we need help by getting that executive order passed. QUESTION: Just a brief follow-up. But if it's so urgent, why not introduce... TRUMP: Yes? Go ahead. QUESTION: Thank you. I was just hoping that we could get a yes or no answer on one of these questions involving Russia. Can you say whether you are aware that anyone who advised your campaign had contacts with Russia during the course of the election? TRUMP: Well I told you, Gen. Flynn obviously was dealing. So that's one person. But he was dealing, as he should have been. QUESTION: During the election? TRUMP: No. Nobody that I know of. Nobody... QUESTION: So you're not aware of any contact during the course.. TRUMP: Look, look, look... QUESTION: ... of the election? TRUMP: How many times do I have to answer this question? QUESTION: Can you just say yes or no? TRUMP: Russia is a ruse. I know you have to get up and ask a question. It's so important. Russia is a ruse. I have nothing to do with Russia. Haven't made a phone call to Russia in years. Don't speak to people from Russia. Not that I wouldn't. I just have nobody to speak to. I spoke to Putin twice. He called me on the election. I told you this. And he called me on the inauguration, a few days ago. We had a very good talk, especially the second one, lasted for a pretty long period of time. I'm sure you probably get it because it was classified. So I'm sure everybody in this room perhaps has it. But we had a very, very good talk. I have nothing to do with Russia. To the best of my knowledge no person that I deal with does. J.R.107 J.A. 368 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 43 of 119 Now, Manafort has totally denied it. He denied it. Now people knew that he was a consultant over in that part of the world for a while, but not for Russia. I think he represented Ukraine or people having to do with Ukraine, or people that -- whoever. But people knew that. Everybody knew that. QUESTION: But in his capacity as your campaign manager, was he in touch with Russian officials during the election? TRUMP: You know what? He said no. I could only tell you what he -- now he was replaced long before the election. You know that, right? He was replaced long before the election. When all of this stuff started coming out, it came out during the election. But Paul Manafort, who's a good man also by the way, Paul Manfort was replaced long before the election took place. He was only there for a short period of time. QUESTION: Mr. President... TRUMP: How much longer should we stay here, folks? QUESTION: Mr. President... TRUMP: Five more minutes. Is that OK? Five? QUESTION: Mr. President, on national... TRUMP: Wait. Let's see. Who's -- I want to find a friendly reporter. QUESTION: Mr.... TRUMP: Are you a friendly reporter? Watch how friendly he is. Wait. Wait. Watch how friendly he is. Go ahead. QUESTION: (OFF-MIKE)... TRUMP: Go ahead. QUESTION: So first of all, my name is (Inaudible) from (Inaudible) Magazine. I (inaudible). I haven't seen anybody in my community, including yourself or any of the -- anyone on your staff of being (OFF-MIKE). Because (OFF-MIKE). However, what we've already heard about and what we (OFF-MIKE) is (OFF-MIKE) so you're general forecast (ph) like 48 (OFF-MIKE). There are people who are everything (ph) happens through their packs (ph) is one of the (OFF-MIKE)... (CROSSTALK) TRUMP:...he said he was gonna ask a very simple, easy question. And it's not, its not, not -- not a simple question, not a fair question. OK sit down, I understand the rest of your question. So here's the story, folks. Number one, I am the least anti- Semitic person that you've ever seen in your entire life. Number two, racism, the least racist person. In fact, we did very well relative to other people running as a Republican -- quiet, quiet, quiet. See, he lied about -- he was gonna get up and ask a very straight, simple question, so you know, welcome to the world of the media. But let me just tell you something, that I hate the charge, I find it repulsive. J.R.108 J.A. 369 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 44 of 119 I hate even the question because people that know me and you heard the prime minister, you heard Ben Netanyahu (ph) yesterday, did you hear him, Bibi? He said, I've known Donald Trump for a long time and then he said, forget it. So you should take that instead of having to get up and ask a very insulting question like that. (CROSSTALK) TRUMP: Yeah, go ahead. Go ahead. QUESTION: Thank you, I'm Lisa (ph) from the... (CROSSTALK) TRUMP: See, it just shows you about the press, but that's the way the press is. QUESTION: Thank you, Mr. President. Lisa Dejardown (ph) from the PBS News Hour. On national security and immigration, can you give us more details on the executive order you plan for next week? Even its broad outlines? TRUMP: Yeah. QUESTION: Will it be focused on specific... TRUMP: It's a very fair question. QUESTION: ...countries? And in addition, on the DACA program for immigration. TRUMP: Right. QUESTION: What is your plan, do you plan to continue that program or to end it? TRUMP: We're gonna show great heart, DACA is a very, very difficult subject for me, I will tell you. To me, it's one of the most difficult subjects I have because you have these incredible kids. In many cases, not in all cases. And some of the cases, having DACA and they're gang members and they're drug dealers, too. But you have some absolutely, incredible kids, I would say mostly. They were brought here in such a way -- it's a very -- it's a very, very tough subject. We're gonna deal with DACA with heart. I have to deal with a lot of politicians, don't forget and I have to convince them that what I'm saying is -- is right. And I appreciate your understanding on that. But the DACA situation is a very, very -- it's a very difficult thing for me because you know, I love these kids, I love kids, I have kids and grandkids. And I find it very, very hard doing what the law says exactly to do and you know, the law is rough. I'm not talking about new laws, I'm talking the existing law, is very rough, it's very, very rough. As far as the new order, the new order is going to be very much tailored to the what I consider to be a very bad decision. But we can tailor the order to that decision and get just about everything, in some ways, more. But we're tailoring it now to the decision, we have some of the best lawyers in the country working on it. And the new executive order, is being tailored to the decision we got down from the court. OK? J.R.109 J.A. 370 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 45 of 119 QUESTION: Mr. President... (CROSSTALK) QUESTION: ...reopening of the White House Visitors Office? TRUMP: Yes. QUESTION: And she does a lot of great work for the country as well (ph). Can you talk a little bit about what's first for (ph) Melania Trump does for the country and (inaudible) so opening White House Visitors Office, what does that mean... TRUMP: Now, that's what I call a nice question. That is very -- who are you with? QUESTION: (OFF-MIKE) TRUMP: Good, I'm gonna start watching, all right? Thank you very much. Melania's terrific, she was here last night, we had dinner with Senator Rubio and his wife who is by the way, lovely. And we had a really good discussion about Cuba because we have very similar views on Cuba. And Cuba was very good to me in the Florida election, as you know the Cuban Americans. And I think that Melania's gonna be outstanding, that's right, she just opened up the visitors center, in other words, touring of the White House. She, like others that she's working with, feel very, very strongly about women's issue, women's difficulties. Very, very strongly, she's a very, very strong advocate. I think she's a great representative for this country. And a funny thing happens, because she gets -- she gets so unfairly -- Melania, the things they say. I've known her for a long time, she was a very successful person, she was a very successful model. She did really well. She would go home at night and didn't even want to go out with people. She was a very private person. She was always the highest quality that you'll ever find. And the things they say -- I've known her for a long time -- the things they say are so unfair. And actually, she's been apologized to, as you know, by various media because they said things that were lies. I'll just tell you this. I think she's going to be a fantastic first lady. She's going to be a tremendous representative of women and of the people. And helping her and working her will be Ivanka, who is a fabulous person and a fabulous, fabulous woman. And they're not doing this for money. They're not doing this for pay, they're doing this because they feel it; both of them. And Melania goes back and forth and after Barron finishes school -- because it's hard to take a child out of school with a few months left -- she and Barron will be moving over to the White House. OK, thank you, that's a very nice question. (CROSSTALK) TRUMP: Go ahead. QUESTION: Mr. Trump? TRUMP: Yes, oh, this is going to be a bad question, but that's OK. QUESTION: It doesn't(ph) have(ph) to be a bad question. TRUMP: Good, because I enjoy watching you on television. Go ahead. J.R.110 J.A. 371 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 46 of 119 QUESTION: Well, thank you so much. Mr. President, I need to find out from you, you said something as it relates to inner cities. That was one of your platforms during your campaign. Now you're -TRUMP: Fix the inner cities. QUESTION: -- president. Fixing the inner cities. TRUMP: Yep. QUESTION: What will be that fix and your urban agenda as well as your HBCU Executive Order that's coming out this afternoon? See, it wasn't bad, was it? TRUMP: That was very professional and very good. QUESTION: I'm very professional. TRUMP: We'll be announcing the order in a little while and I'd rather let the order speak for itself. But it could be something that I think that will be very good for everybody concerned. But we'll talk to you about that after we do the announcement. As far as the inner cities, as you know, I was very strong on the inner cities during the campaign. I think it's probably what got me a much higher percentage of the African American vote than a lot of people thought I was going to get. We did, you know, much higher than people thought I was going to get. And I was honored by that, including the Hispanic vote, which was also much higher. And by the way, if I might add, including the women's vote, which was much higher than people thought I was going to get. So, we are going to be working very hard on the inner cities, having to do with education, having to do with crime. We're going to try and fix as quickly as possible -- you know, it takes a long time. It's taken more a hundred years and more for some of these places to evolve and they evolved, many of them, very badly. But we're going to be working very hard on health and healthcare, very, very hard on education, and also we're going to be working in a stringent way, in a very good way, on crime. You go to some of these inner city places and it's so sad when you look at the crime. You have people -- and I've seen this, and I've sort of witnessed it -- in fact, in two cases I have actually witnessed it. They lock themselves into apartments, petrified to even leave, in the middle of the day. They're living in hell. We can't let that happen. So, we're going to be very, very strong. That's a great question and -- and it's a -- it's a very difficult situation because it's been many, many years. It's been festering for many, many years. But we have places in this country that we have to fix. We have to help African American people that, for the most part, are stuck there. Hispanic American people. We have Hispanic American people that are in the inner cities and their living in hell. I mean, you look at the numbers in Chicago. There are two Chicagos, as you know. There's one Chicago that's incredible, luxurious and all -- and safe. There's another Chicago that's worse than almost any of the places in the Middle East that we talk, and that you talk about, every night on the newscasts. So, we're going to do a lot of work on the inner cities. I have great people lined up to help with the inner cities. OK? QUESTION: Well, when you say the inner cities, are you going -- are you going to include the CBC, Mr. President, in your conversations with your -- your urban agenda, your inner city agenda, as well as -- J.R.111 J.A. 372 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 47 of 119 TRUMP: Am I going to include who? QUESTION: Are you going to include the Congressional Black Caucus and the Congressional -TRUMP: Well, I would. I tell you what, do you want to set up the meeting? QUESTION: -- Hispanic Caucus -TRUMP: Do you want to set up the meeting? QUESTION: No -- no -- no. I'm not -TRUMP: Are they friends of yours? QUESTION: I'm just a reporter. TRUMP: Well, then(ph) set up the meeting. QUESTION: I know some of them, but I'm sure they're watching right now. TRUMP: Let's go set up a meeting. I would love to meet with the Black Caucus. I think it's great, the Congressional Black Caucus. I think it's great. I actually thought I had a meeting with Congressman Cummings and he was all excited. And then he said, well, I can't move, it might be bad for me politically. I can't have that meeting. I was all set to have the meeting. You know, we called him and called him. And he was all set. I spoke to him on the phone, very nice guy. QUESTION: I hear he wanted that meeting with you as well. TRUMP: He wanted it, but we called, called, called and can't make a meeting with him. Every day I walk and say I would like to meet with him because I do want to solve the problem. But he probably was told by Schumer or somebody like that, some other lightweight. He was probably told - he was probably told "don't meet with Trump. It's bad politics." And that's part of the problem in this country. OK, one more. QUESTION: (inaudible) TRUMP: No, no, one question. Two we can't handle. This room can't handle two. Go ahead, give me the better of your two. QUESTION: (inaudible) ...not about your personality or your beliefs, talking about (inaudible), some of it by supporters in your name. What do you... TRUMP: ...And some of it - can I be honest with you? And this has to do with racism and horrible things that are put up. Some of it written by our opponents. You do know that. Do you understand that? You don't think anybody would do a thing like that. Some of the signs you'll see are not put up by the people that love or like Donald Trump, they're put up by the other side and you think it's like playing it straight? No. But you have some of those signs and some of that anger is caused by the other side. They'll do signs and they'll do drawings that are inappropriate. It won't be my people. It will be the people on the other side to anger people like you. OK. J.R.112 J.A. 373 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 48 of 119 (CROSSTALK) TRUMP: Go ahead, go ahead. QUESTION: You're the president now. What are you going to do about it? TRUMP: Who is that? Where is that? QUESTION: What are you going to do about - what are you going to do about (inaudible). TRUMP: Oh, I'm working on it. I'm working on it very - no, no, look. Hey, just so you understand, we had a totally divided country for eight years and long before that. In all fairness to President Obama, long before President Obama we have had a very divided - I didn't come along and divide this country. This country was seriously divided before I got here. We're going to work on it very hard. One of the questions I was asked, I thought it was a very good question was about the inner cities. I mean, that's part of it. But we're going to work on education, we're going to work on - you know, we're going to stop - we're going to try and stop the crime. We have great law enforcement officials, we're going to try and stop crime. We're not going to try and stop, we're going to stop crime. But it's very important to me - but this isn't Donald Trump that divided a nation. We went eight years with President Obama and we went many years before President Obama. We lived in a divided nation. And I am going to try - I will do everything within my power to fix that. I want to thank everybody very much. It's a great honor to be with you. Thank you. Thank you very much, thanks. DC restaurant alleges unfair competition in suit against Trump, DC hotel EPA chief: Carbon dioxide not 'primary contributor' to climate change Trump vs. Obama: A rocky relationship J.R.113 It took FOIA for Park Service to release photos of Obama, Trump… J.A. 374 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 49 of 119 Exhibit H J.R.114 J.A. 375 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 50 of 119 Trump Signs New Travel Ban Order Last Updated: March 06, 2017 11:35 PM William Gallo Victoria Macchi WASHINGTON — U.S. President Donald Trump signed a new executive order Monday, barring travelers from six countries to the United States for three months, and all refugees for four months, after federal appeals judges blocked a similar order last month. The new ban includes a grace period and will take effect on March 16. It will not affect legal permanent residents — those with green cards — or travelers who already had valid visas as of Jan. 27, 2017. "This executive order is a vital measure for strengthening our national security," Secretary of State Rex Tillerson said at press conference announcing the new ban. "It is the president's solemn duty to protect the American people." The rollout of the new security measures amounts to an acknowledgement by the Trump administration that its original travel ban, issued January 27, was flawed. But critics immediately assailed the new order as merely making "cosmetic changes" to the original ban and argued that it still creates a religious test for entering the United States and will therefore not stand up to judicial scrutiny. WATCH: Related video report by Steve Herman In an attempt to ensure a smoother rollout of the travel ban and protect it from legal scrutiny, the new executive order differs from the old version in several key aspects. J.R.115 J.A. 376 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 51 of 119 Among the most notable changes is the exclusion of Iraqis from the list of suspended travelers. The new order bans nationals and citizens from Iran, Libya, Somalia, Sudan, Syria, and Yemen. Monday’s order also removes a provision indefinitely barring Syrian refugees from the U.S. Also removed is language giving preference to "religious minorities," a provision that had been widely seen as an attempt to follow through on Trump's promise to prioritize Christian refugees. Iraq promises more cooperation Iraq was removed from the list after officials there promised increased cooperation with U.S. officials regarding the vetting process, according to a senior official with the Department of Homeland Security (DHS), who spoke to reporters on a conference call. Baghdad, a key ally in the U.S. fight against Islamic State militants, had complained when Iraq was included in the original travel ban. "The close cooperative relationship between the United States and the democratically-elected Iraqi government, the strong U.S. diplomatic presence in Iraq, the significant presence of U.S. forces in Iraq, and Iraq's commitment to combat ISIS justify different treatment," said a Q&A sheet distributed by the Trump administration. ISIS is an acronym for Islamic State. WATCH: Tillerson on removal of Iraq Critics of the original order questioned whether the seven countries affected — all majority-Muslim — were targeted for religious reasons. The DHS official on Monday again denied those accusations, saying: "This is not a Muslim ban in any way, shape or form." White House officials also stressed the temporary nature of the order, but suggested that the travel ban may be expanded after the 90 days expire and that other countries could be added to the list. J.R.116 J.A. 377 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 52 of 119 Reaction Even with the changes, the bill is still likely to face legal challenges by groups that view the order as a partial fulfillment of Trump's campaign call for a "total and complete shutdown of Muslims entering the United States." "Nothing substantive has changed," said Lavinia Limon, who heads the U.S. Committee for Refugees and Immigrants (USCRI). "It's around the edges, right? If this had come out a month ago, we would be outraged." The American Civil Liberties Union, or ACLU, which filed successful legal challenges against the original order, also said the revised ban "has the same fatal flaws" as the original. "These are again, simply cosmetic changes," said Ed Yohnka, the ACLU's Director of Communications and Public Policy. "This is still unconstitutional, this remains a religious test to enter the United States of America. This is something fundamentally that our nation has never permitted. And we will not permit it again." "The only way to actually fix the Muslim ban is not to have a Muslim ban. Instead, President Trump has recommitted himself to religious discrimination, and he can expect continued disapproval from both the courts and the people," said Omar Jadwat, director of the ACLU's Immigrant Rights Project. "What's more, the changes the Trump administration has made, and everything we've learned since the original ban rolled out, completely undermine the bogus national security justifications the president has tried to hide behind and only strengthen the case against his unconstitutional executive orders." White House: Ban needed to mitigate refugee risk Administration officials, meanwhile, were walking a fine line between insisting the new order was different enough from the old measure to withstand legal challenges but similar enough so that it would still be effective. J.R.117 J.A. 378 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 53 of 119 "The principles of the executive order remain the same," said White House press secretary Sean Spicer, adding, "We continue to maintain the [original travel ban] order was fully lawful." The Trump administration leans heavily on the rationale that refugees, as well as immigrants and travelers from certain countries, are a security risk to the United States; however, it has proffered little evidence of that risk. White House officials on Monday released a memorandum saying that the FBI is carrying out "terrorism-related investigations" into approximately 300 individuals across the U.S. who were admitted as refugees. It is not clear whether those being investigated came from the list of banned countries, or how many have been charged with a crime. When pushed for details, the senior DHS official declined further comment, saying only that the 300 people were being investigated for "potential terrorism-related activities" and that it was "truly an alarming number from all our perspectives." Filippo Grandi, who heads the U.N.'s refugee agency, said the U.S. has long been a partner in finding solutions for refugees, but expressed concern about how the order will affect those fleeing violence and persecution. "The imperative remains to provide protection from people fleeing deadly violence, and we are concerned that this decision, though temporary, may compound the anguish for those it affects," Grandi said. * Differences in executive orders restricting travel (click here to see) Smoother rollout? Administration officials are promising a smoother rollout this time, insisting the White House has cooperated with DHS, the State Department, and the Justice Department on drafting and implementing the new executive order. J.R.118 J.A. 379 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 54 of 119 "We're going to have a very smooth implementation period," the senior DHS officials told reporters in a press call, adding that there will not be any "chaos, or alleged chaos" at airports. WATCH: Kelly on vetting of refugees seeking to enter US The original order was announced early on the evening of Jan. 27 — a Friday right when most federal employees were finishing their first full week of work under the new administration — creating confusion at international airports across the country. Travelers from the seven countries — including legal permanent residents of the United States — were detained by U.S. Customs and Border Protection agents. Law enforcement didn’t know what to do with the refugees mid-flight when the order came down that banned them, as well. Still others were turned away at airports abroad, denied by airline officials who questioned the validity of their already-issued visas. DHS Secretary John Kelly, who was confirmed by the Senate a week before the original executive order was issued, shouldered the blame for the bungled implementation of the original order. "The thinking was to get it out quick so that potentially people that might be coming here to harm us would not take advantage of some period of time they could jump on an airplane and get here," he testified at a hearing of the House Homeland Security Committee on Feb. 7. More than a dozen lawsuits were filed across the country challenging the January order. Federal appeals court judges ruled in February to suspend the order in support of the "free flow of travel," as well as "in avoiding separation of families, and in freedom from discrimination." J.R.119 J.A. 380 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 55 of 119 Trump’s travel restrictions have not received broad public support. A poll released in late February by Pew Research Center showed that 59 percent of those surveyed opposed the ban, while 38 percent approved. A CNN poll released Monday suggested that 55 percent of Americans disapprove of the way Trump has handled immigration issues, compared to 44 percent who approve. On national security issues, Americans were split, the poll found, with 50 percent approving and 49 percent disapproving. WATCH: History of US Immigration Restrictions J.R.120 J.A. 381 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 56 of 119 Exhibit I J.R.121 J.A. 382 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 57 of 119 Inside the confusion of the Trump executive order and travel ban By Evan Perez, Pamela Brown and Kevin Liptak, CNN Updated 11:29 AM ET, Mon January 30, 2017 Story highlights Trump's unilateral moves reflect the President's desire to quickly make good on his campaign promises But they also encapsulate the pitfalls of an administration largely operated by officials with scant federal experience The White House overruled DHS regarding allowing green card holders to enter the country Trump's immigration order: Which countries are affected? • • • • • • • Iran Iraq Syria Sudan Libya Yemen Somalia Washington (CNN) — When President Donald Trump declared at the Pentagon Friday he was enacting strict new measures to prevent domestic terror attacks, there were few within his government who knew exactly what he meant. Administration officials weren't immediately sure which countries' citizens would be barred from entering the United States. The Department of Homeland Security was left making a legal analysis on the order after Trump signed it. A Border Patrol agent, confronted with arriving refugees, referred questions only to the President himself, according to court filings. Saturday night, a federal judge granted an emergency stay for citizens of the affected countries who had already arrived in the US and those who are in transit and hold valid visas, ruling they can legally enter the US. Trump's unilateral moves, which have drawn the ire of human rights groups and prompted protests at US airports, reflect the President's desire to quickly make good on his campaign promises. But they also encapsulate the pitfalls of an administration largely operated by officials with scant federal experience. It wasn't until Friday -- the day Trump signed the order banning travel from seven Muslim-majority countries for 90 days and suspending all refugee admission for 120 days -- that career homeland J.R.122 J.A. 383 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 58 of 119 security staff were allowed to see the final details of the order, a person familiar with the matter said. The result was widespread confusion across the country on Saturday as airports struggled to adjust to the new directives. In New York, two Iraqi nationals sued the federal government after they were detained at John F. Kennedy International Airport, and 10 others were detained as well. Related Article: More protests against Trump's immigration policies planned The ban and its impact • • • • • • • • • What we know so far What it's like in the 7 impacted countries How the countries were chosen What the ban says: The full text What to know about the restrictions Is the ban legal? These are the people directly impacted The ban's Christian focus A family's plight just got more complicated • Bergen: Trump's big mistake • All of Trump's executive orders, memos and proclamations • Comparing Trump to previous presidents In Philadelphia, a Syrian family of six who had a visa through a family connection in the US was placed on a return flight to Doha, Qatar, and Department of Homeland Security officials said others who were in the air would be detained upon arrival and put back on a plane to their home country. Asked during a photo opportunity in the Oval Office Saturday afternoon about the rollout, Trump said his government was "totally prepared." "It's working out very nicely," Trump told reporters. "You see it at the airports. You see it all over. It's working out very nicely and we're going to have a very, very strict ban, and we're going to have extreme vetting, which we should have had in this country for many years." The policy team at the White House developed the executive order on refugees and visas, and largely avoided the traditional interagency process that would have allowed the Justice Department and homeland security agencies to provide operational guidance, according to numerous officials who spoke to CNN on Saturday. Homeland Security Secretary John Kelly and Department of Homeland Security leadership saw the final details shortly before the order was finalized, government officials said. Friday night, DHS arrived at the legal interpretation that the executive order restrictions applying to seven countries -- Iran, Iraq, Libya, Somalia, Syria, Sudan and Yemen -- did not apply to people with lawful permanent residence, generally referred to as green card holders. The White House overruled that guidance overnight, according to officials familiar with the rollout. That order came from the President's inner circle, led by Stephen Miller and Steve Bannon. J.R.123 J.A. 384 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 59 of 119 Related Article: Trump's immigration ban sends shockwaves Their decision held that, on a case by case basis, DHS could allow green card holders to enter the US. There had been some debate whether green card holders should be even allowed to board international flights. It was decided by the Department of Homeland Security they could fly to the US and would be considered on a case-bycase basis after passing a secondary screening. But the guidance sent to airlines on Friday night, obtained by CNN, said clearly, "lawful permanent residents are not included and may continue to travel to the USA." Related Video: Travel ban affects citizens of 7 Muslim-majority nations 02:26 As of Saturday afternoon, Customs and Border Protection continued to issue the same guidance to airlines as it did Friday, telling airlines that fly to the US that green card holders can board planes to the US but they may get extra scrutiny on arrival, according to an airline official. Before the President issued the order, the White House did not seek the legal guidance of the Office of Legal Counsel, the Justice Department office that interprets the law for the executive branch, according to a source familiar with the process. White House officials disputed that Sunday morning, saying that OLC signed off and agency review was performed. Related Video: Iran says it will ban US citizens 02:16 A source said the creation of the executive order did not follow the standard agency review process that's typically overseen by the National Security Council. J.R.124 J.A. 385 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 60 of 119 Separately, a person familiar with the matter said career officials in charge of enforcing the executive order were not fully briefed on the specifics until Friday. The officials were caught off guard by some of the specifics and raised questions about how to handle the new banned passengers on US-bound planes. Related Video: Trump: Travel ban working out very nicely 01:07 Regarding the green card holders and some of the confusion about whether they were impacted, the person familiar with the matter said if career officials had known more about the executive order earlier, some of the confusion could have been avoided and a better plan could be in place. Administration officials also defended the process Saturday. They said the people who needed to be briefed ahead of time on the plane were briefed and that people at the State Department and DHS who were involved in the process were able to make decisions about who to talk and inform about this. Executive orders: Read more • All of Trump's executive orders, memos and proclamations • Will the orders and actions stick? • How Trump's actions stack up against previous presidents • What Trump can and cannot do • What's the difference between and order and action? Bannon and Miller were running point on this order and giving directives regarding green cards, according to a Republican close to the White House. But even after the Friday afternoon announcement, administration officials at the White House took several hours to produce text of the action until several hours after it was signed. Adviser Kellyanne Conway even said at one point it was not going to be released before eventually it did get sent out. Administration officials also seemed unsure at first who was covered in the action, and a list of impacted countries was only produced later on Friday night, hours after the President signed the document at the Pentagon. This story has been updated to include the White House's response on the issue of Justice Department review. CNN's Rene Marsh and Athena Jones contributed to this report. J.R.125 J.A. 386 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 61 of 119 Schwarzenegger's theory Cummings, Trump find on Donald Trump common ground on need for drug pricing reforms It took FOIA for Park Service to release photos of Obama, Trump… Trump vs. Obama: A rocky relationship J.R.126 J.A. 387 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 62 of 119 Exhibit J J.R.127 J.A. 388 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 63 of 119 Judge Blocks Trump Order on Refugees Amid Chaos and Outcry Worldwide By MICHAEL D. SHEAR, NICHOLAS KULISH and ALAN FEUER JAN. 28, 2017 WASHINGTON — A federal judge in Brooklyn came to the aid of scores of refugees and others who were trapped at airports across the United States on Saturday after an executive order signed by President Trump, which sought to keep many foreigners from entering the country, led to chaotic scenes across the globe. The judge’s ruling blocked part of the president’s actions, preventing the government from deporting some arrivals who found themselves ensnared by the presidential order. But it stopped short of letting them into the country or issuing a broader ruling on the constitutionality of Mr. Trump’s actions. The high-stakes legal case played out on Saturday amid global turmoil, as the executive order signed by the president slammed shut the borders of the United States for an Iranian scientist headed to a lab in Massachusetts, a Syrian refugee family headed to a new life in Ohio and countless others across the world. The president’s order, enacted with the stroke of a pen at 4:42 p.m. Friday, suspended entry of all refugees to the United States for 120 days, barred Syrian refugees indefinitely, and blocked entry into the United States for 90 days for citizens of seven predominantly Muslim countries: Iran, Iraq, Libya, Somalia, Sudan, Syria and Yemen. The Department of Homeland Security said that the order also barred green card holders from those countries from re-entering the United States. In a briefing for J.R.128 J.A. 389 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 64 of 119 reporters, White House officials said that green card holders from the seven affected countries who are outside the United States would need a case-by-case waiver to return. Mr. Trump — in office just a week — found himself accused of constitutional and legal overreach by two Iraqi immigrants, defended by the American Civil Liberties Union. Meanwhile, large crowds of protesters turned out at airports around the country to denounce Mr. Trump’s ban on the entry of refugees and people from seven predominantly Muslim countries. Lawyers who sued the government to block the White House order said the judge’s decision could affect an estimated 100 to 200 people who were detained upon arrival at American airports. Judge Ann M. Donnelly of Federal District Court in Brooklyn, who was nominated by former President Barack Obama, ruled just before 9 p.m. that implementing Mr. Trump’s order by sending the travelers home could cause them “irreparable harm.” She said the government was “enjoined and restrained from, in any manner and by any means, removing individuals” who had arrived in the United States with valid visas or refugee status. The ruling does not appear to force the administration to let in people otherwise blocked by Mr. Trump’s order who have not yet traveled to the United States. The judge’s one-page ruling came swiftly after lawyers for the A.C.L.U. testified in her courtroom that one of the people detained at an airport was being put on a plane to be deported back to Syria at that very moment. A government lawyer, Gisela A. Westwater, who spoke to the court by phone from Washington, said she simply did not know. Hundreds of people waited outside of the courthouse chanting, “Set them free!” as lawyers made their case. When the crowd learned that Judge Donnelly had ruled in favor of the plaintiffs, a rousing cheer went up in the crowd. Minutes after the judge’s ruling in New York City, another judge, Leonie M. Brinkema of Federal District Court in Virginia, issued a temporary restraining order J.R.129 J.A. 390 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 65 of 119 for a week to block the removal of any green card holders being detained at Dulles International Airport. In a statement released early Sunday morning, the Department of Homeland Security said it would continue to enforce all of the president’s executive orders, even while complying with judicial decisions. “Prohibited travel will remain prohibited,” the department said in a statement, adding that the directive was “a first step towards re-establishing control over America’s borders and national security.” Around the nation, security personnel at major international airports had new rules to follow, though the application of the order appeared chaotic and uneven. Humanitarian organizations delivered the bad news to overseas families that had overcome the bureaucratic hurdles previously in place and were set to travel. And refugees already on flights when the order was signed on Friday found themselves detained upon arrival. “We’ve gotten reports of people being detained all over the country,” said Becca Heller, the director of the International Refugee Assistance Project. “They’re literally pouring in by the minute.” Earlier in the day, at the White House, Mr. Trump shrugged off the sense of anxiety and disarray, suggesting that there had been an orderly rollout. “It’s not a Muslim ban, but we were totally prepared,” he said. “It’s working out very nicely. You see it at the airports, you see it all over.” But to many, the government hardly seemed prepared for the upheaval that Mr. Trump’s actions put into motion. There were numerous reports of students attending American universities who were blocked from returning to the United States from visits abroad. One student said in a Twitter post that he would be unable to study at Yale. Another who attends the Massachusetts Institute of Technology was refused permission to board a plane. A Sudanese graduate student at Stanford University was blocked for hours from entering the country. J.R.130 J.A. 391 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 66 of 119 Human rights groups reported that legal permanent residents of the United States who hold green cards were being stopped in foreign airports as they sought to return from funerals, vacations or study abroad. There was widespread condemnation of the order, from religious leaders, business executives, academics, political leaders and others. Mr. Trump’s supporters offered praise, calling it a necessary step on behalf of the nation’s security. Homeland Security officials said on Saturday night that 109 people who were already in transit to the United States when the order was signed were denied access; 173 were stopped before boarding planes heading to America. Eighty-one people who were stopped were eventually given waivers to enter the United States, officials said. Legal residents who have a green card and are currently in the United States should meet with a consular officer before leaving the country, a White House official, who spoke on the condition of anonymity, told reporters. Officials did not clarify the criteria that would qualify someone for a waiver, other than that it would be granted “in the national interest.” But the week-old administration appeared to be implementing the order chaotically, with agencies and officials around the globe interpreting it in different ways. The Stanford student, Nisrin Omer, a legal permanent resident, said she was held at Kennedy International Airport in New York for about five hours but was eventually allowed to leave the airport. Others who were detained appeared to be still in custody or sent back to their home countries. White House aides claimed on Saturday that there had been consultations with State Department and homeland security officials about carrying out the order. “Everyone who needed to know was informed,” one aide said. But that assertion was denied by multiple officials with knowledge of the interactions, including two officials at the State Department. Leaders of Customs and Border Protection and of Citizenship and Immigration Services — the two agencies J.R.131 J.A. 392 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 67 of 119 most directly affected by the order — were on a telephone briefing on the new policy even as Mr. Trump signed it on Friday, two officials said. The A.C.L.U.’s legal case began with two Iraqis detained at Kennedy Airport, the named plaintiffs in the case. One was en route to reunite with his wife and son in Texas. The other had served alongside Americans in Iraq for a decade. Shortly after noon on Saturday, Hameed Khalid Darweesh, an interpreter who worked for more than a decade on behalf of the United States government in Iraq, was released. After nearly 19 hours of detention, Mr. Darweesh began to cry as he spoke to reporters, putting his hands behind his back and miming handcuffs. “What I do for this country? They put the cuffs on,” Mr. Darweesh said. “You know how many soldiers I touch by this hand?” The other man the lawyers are representing, Haider Sameer Abdulkhaleq Alshawi, who was en route to Houston, was released Saturday night. Before the two men were released, one of the lawyers, Mark Doss, a supervising attorney at the International Refugee Assistance Project, asked an official, “Who is the person we need to talk to?” “Call Mr. Trump,” said the official, who declined to identify himself. While the judge’s ruling means that none of the detainees will be sent back immediately, lawyers for the plaintiffs in the case expressed concern that all those at the airports would now be put in detention, pending a resolution of the case. The White House said the restrictions would protect “the United States from foreign nationals entering from countries compromised by terrorism” and allow the administration time to put in place “a more rigorous vetting process.” But critics condemned Mr. Trump over the collateral damage on people who had no sinister intentions in trying to come to the United States. Peaceful protests began forming Saturday afternoon at Kennedy Airport, where nine travelers had been detained upon arrival at Terminal 7 and two others at J.R.132 J.A. 393 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 68 of 119 Terminal 4, an airport official said. Similar scenes were playing out at other airports across the nation. An official message to all American diplomatic posts around the world provided instructions about how to treat people from the countries affected: “Effective immediately, halt interviewing and cease issuance and printing” of visas to the United States. Internationally, confusion turned to panic as travelers found themselves unable to board flights bound for the United States. In Dubai and Istanbul, airport and immigration officials turned passengers away at boarding gates and, in at least one case, ejected a family from a flight it had boarded. Seyed Soheil Saeedi Saravi, a promising young Iranian scientist, had been scheduled to travel in the coming days to Boston, where he had been awarded a fellowship to study cardiovascular medicine at Harvard, according to Thomas Michel, the professor who was to supervise the research fellowship. But Professor Michel said the visas for the student and his wife had been indefinitely suspended. “This outstanding young scientist has enormous potential to make contributions that will improve our understanding of heart disease, and he has already been thoroughly vetted,” Professor Michel wrote to The New York Times. A Syrian family of six who have been living in a Turkish refugee camp since fleeing their home in 2014 had been scheduled to arrive on Tuesday in Cleveland. Instead, the family’s trip has been called off. “Everyone is just so heartbroken, so angry, so sad,” said Danielle Drake, the community manager for US Together, an agency that resettles refugees. A Christian family of six from Syria said in an email to Representative Charlie Dent, Republican of Pennsylvania, that they were being detained on Saturday morning at Philadelphia International Airport despite having legal paperwork, green cards and visas that had been approved. J.R.133 J.A. 394 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 69 of 119 In the case of the two Iraqis held at Kennedy Airport, the legal filings by his lawyers say that Mr. Darweesh was granted a special immigrant visa on Jan. 20, the same day Mr. Trump was sworn in as president. A husband and father of three, Mr. Darweesh arrived at Kennedy Airport with his family. Mr. Darweesh’s wife and children made it through passport control and customs, but agents of Customs and Border Protection detained him. In Istanbul, during a stopover on Saturday, passengers reported that security officers had entered a plane after everyone had boarded and ordered a young Iranian woman and her family to leave the aircraft. Iranian green card holders who live in the United States were blindsided by the decree while on vacation in Iran, finding themselves in a legal limbo and unsure whether they would be able to return to America. “How do I get back home now?” said Daria Zeynalia, a green card holder who was visiting family in Iran. He had rented a house and leased a car, and would be eligible for citizenship in November. “What about my job? If I can’t go back soon, I’ll lose everything.” Michael D. Shear reported from Washington, and Nicholas Kulish and Alan Feuer from New York. Reporting was contributed by Mark Mazzetti, Matthew Rosenberg, Ron Nixon and Adam Liptak from Washington; Thomas Erdbrink from Tehran; Manny Fernandez from Houston; Julie Bosman from Chicago; and Liam Stack, Russell Goldman, Joe Goldstein, Liz Robbins, Stephanie Saul and Sean Piccoli from New York. J.R.134 J.A. 395 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 70 of 119 Exhibit K J.R.135 J.A. 396 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 71 of 119 MENU REFUGEES Malevolence Tempered by Incompetence: Trump’s Horrifying Executive Order on Refugees and Visas By Benjamin Wittes Saturday, January 28, 2017, 10:58 PM Omphalos: Middle East Conflict in Perspective The malevolence of President Trump’s Executive Order on visas and refugees is mitigated chiefly—and perhaps only—by the astonishing incompetence of its drafting and construction. NBC is reporting that the document was not reviewed by DHS, the Justice Department, the State Department, or the Department of Defense, and that National Security Council lawyers were prevented from evaluating it. Moreover, the New York Times writes that Customs and Border Protection and U.S. Citizen and Immigration Services, the agencies tasked with carrying out the policy, were only given a briefing call while Trump was actually signing the order itself. Yesterday, the Department of Justice gave a “no comment” when asked whether the Office of Legal Counsel had reviewed Trump’s executive orders—including the order at hand. (OLC normally reviews every executive order.) This order reads to me, frankly, as though it was not reviewed by competent counsel at all. CNN offers extraordinary details: J.R.136 J.A. 397 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 72 of 119 Administration officials weren't immediately sure which countries' citizens would be barred from entering the United States. The Department of Homeland Security was left making a legal analysis on the order after Trump signed it. A Border Patrol agent, confronted with arriving refugees, referred questions only to the President himself, according to court filings. ... It wasn't until Friday -- the day Trump signed the order banning travel from seven Muslim-majority countries for 90 days and suspending all refugee admission for 120 days -- that career homeland security staff were allowed to see the final details of the order, a person with the familiar the matter said. ... The policy team at the White House developed the executive order on refugees and visas, and largely avoided the traditional interagency process that would have allowed the Justice Department and homeland security agencies to provide operational guidance, according to numerous officials who spoke to CNN on Saturday. Homeland Security Secretary John Kelly and Department of Homeland Security leadership saw the final details shortly before the order was finalized, government officials said. Friday night, DHS arrived at the legal interpretation that the executive order restrictions applying to seven countries -- Iran, Iraq, Libya, Somalia, Syria, Sudan and Yemen -- did not apply to people who with lawful permanent residence, generally referred to as green card holders. The White House overruled that guidance overnight, according to officials familiar with the rollout. That order came from the President's inner circle, led by Stephen Miller and Steve Bannon. Their decision held that, on a case by case basis, DHS could allow green card holders to enter the US. As I shall explain, in the short term, the incompetence is actually good news for people who believe in visa and refugee policies based on criteria other than—let’s not be coy about this—bigotry and religious discrimination. The President has J.R.137 J.A. 398 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 73 of 119 created a target-rich environment for litigation that will make his policies, I suspect, less effective than they would have been had he subjected his order to vetting one percent as extreme as the vetting to which he proposes to subject refugees from Bashar al-Assad and the bombing raids of Vladimir Putin. Indeed, even as I write these words, the ACLU has already If you are finding Lawfare useful in succeeded in petitioning a federal these times, please consider making a court for a class-wide stay of contribution to support what we do. deportations of immigrants and refugees trapped in airports by Trump’s order. And a federal judge in Virginia has issued a temporary restraining order preventing the removal of green card holders detained in Dulles International Airport and requiring that these legal residents of the United States have access to counsel. In the broader sense, however, it is most emphatically not good news to have a White House that just makes decisions with no serious thought or interagency input into what those decisions might mean. In fact, it’s really dangerous. Let’s start with the malevolence of the document, which Amira Mikhail summarized and Adham Sahloul analyzed earlier today. I don’t use the word “malevolence” here lightly. As readers of my work know, I believe in strong counterterrorism powers. I defend non-criminal detention. I’ve got no problem with drone strikes. I’m positively enthusiastic about American surveillance policies. I was much less offended than others were by the CIA’s interrogations in the years after September 11. I have defended military commissions. Some of these policies were effective; some were not. Some worked out better than others. And I don’t mean to relitigate any of those questions here. My sole point is that all of these policies were conceptualized and designed and implemented by people who were earnestly trying to protect the country from very real threats. And the policies were, to a one, proximately related to important goals in the effort. While some of these policies proved tragically misguided and caused great harm to innocent people, none of them was designed or intended to be cruel to vulnerable, J.R.138 J.A. 399 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 74 of 119 concededly innocent people. Even the CIA’s interrogation program, after all, was deployed against people the agency believed (mostly correctly) to be senior terrorists of the most dangerous sort and to garner information from them that would prevent attacks. I actually cannot say that about Trump’s new executive order—and neither can anyone else. Here’s how the order describes its purpose: J.R.139 J.A. 400 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 75 of 119 Section 1. Purpose. The visa-issuance process plays a crucial role in detecting individuals with terrorist ties and stopping them from entering the United States. Perhaps in no instance was that more apparent than the terrorist attacks of September 11, 2001, when State Department policy prevented consular officers from properly scrutinizing the visa applications of several of the 19 foreign nationals who went on to murder nearly 3,000 Americans. And while the visa-issuance process was reviewed and amended after the September 11 attacks to better detect would-be terrorists from receiving visas, these measures did not stop attacks by foreign nationals who were admitted to the United States. Numerous foreign-born individuals have been convicted or implicated in terrorism-related crimes since September 11, 2001, including foreign nationals who entered the United States after receiving visitor, student, or employment visas, or who entered through the United States refugee resettlement program. Deteriorating conditions in certain countries due to war, strife, disaster, and civil unrest increase the likelihood that terrorists will use any means possible to enter the United States. The United States must be vigilant during the visa-issuance process to ensure that those approved for admission do not intend to harm Americans and that they have no ties to terrorism. In order to protect Americans, the United States must ensure that those admitted to this country do not bear hostile attitudes toward it and its founding principles. The United States cannot, and should not, admit those who do not support the Constitution, or those who would place violent ideologies over American law. In addition, the United States should not admit those who engage in acts of bigotry or hatred (including "honor" killings, other forms of violence against women, or the persecution of those who practice religions different from their own) or those who would oppress Americans of any race, gender, or sexual orientation. Color me skeptical that this is the real purpose. After all, if this is the real purpose, then the document is both wildly over-inclusive and wildly under-inclusive. On the over-inclusive side, it will keep tens of thousands of innocent refugees who have been subject to unspeakable violence outside of the protection of the United States J.R.140 J.A. 401 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 76 of 119 on the vanishingly small chance that these people might be terrorists—indeed, to make it impossible for them even to apply for refugee admission if they are Syrian. It will prevent untold numbers of people about whom there is no whiff of suspicion from coming here as students, as professionals, as tourists. It overtly treats members of a particular religion differently from other people. On the underinclusive side, the order wouldn’t have blocked the entry of many of the people responsible for the worst recent terrorist attacks. There is, in fact, simply no rational relationship between cutting off visits from the particular countries that Trump targets (Muslim countries that don’t happen to be close U.S. allies) and any expected counterterrorism goods. The 9/11 hijackers, after all, didn’t come from Somalia or Syria or Iran; they came from Saudi Arabia and Egypt and a few other countries not affected by the order. Of the San Bernardino attackers (both of Pakistani origin, one a U.S. citizen and the other a lawful permanent resident), the Orlando shooter (a U.S. citizen whose parents were born in Afghanistan), and the Boston marathon bombers (one a naturalized U.S. citizen, one a green card holder who arrived in Massachusetts from Kyrgyzstan), none came from countries listed in the order. One might argue, I suppose, that the document is tied to current threats. But come now, how could Pakistan not be on a list guided by current threat perception? What’s more, the document also takes steps that strike me as utterly orthogonal to any relevant security interest. If the purpose of the order is the one it describes, for example, I can think of no good reason to burden the lives of students individually suspected of nothing who are here lawfully and just happen to be temporarily overseas, or to detain tourists and refugees who were mid-flight when the order came down. I have trouble imagining any reason to raise questions about whether green card holders who have lived here for years can leave the country and then return. Yes, it’s temporary, and that may lessen the costs (or it may not, depending on the outcome of the policy review the order mandates), but temporarily irrational is still irrational. Put simply, I don’t believe that the stated purpose is the real purpose. This is the first policy the United States has adopted in the post-9/11 era about which I have ever said this. It’s a grave charge, I know, and I’m not making it lightly. But in the rational pursuit of security objectives, you don’t marginalize your expert security J.R.141 J.A. 402 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 77 of 119 agencies and fail to vet your ideas through a normal interagency process. You don’t target the wrong people in nutty ways when you’re rationally pursuing real security objectives. When do you do these things? You do these things when you’re elevating the symbolic politics of bashing Islam over any actual security interest. You do them when you’ve made a deliberate decision to burden human lives to make a public point. In other words, this is not a document that will cause hardship and misery because of regrettable incidental impacts on people injured in the pursuit of a public good. It will cause hardship and misery for tens or hundreds of thousands of people because that is precisely what it is intended to do. To be sure, the executive order does not say anything as crass as: “Sec. 14. Burdening Muslim Lives to Make Political Point.” It doesn’t need to. There’s simply no reason in reading it to ignore everything Trump said during the campaign, during which he repeatedly called for a ban on Muslims entering the United States. Even while he was preparing to sign the order itself, he declared, "This is the ‘Protection of the Nation from Foreign Terrorist Entry into the United States.’ We all know what that means." Indeed, we do. This document is the implementation of a campaign promise to keep out Muslims moderated only by the fact that certain allied Muslim countries are left out because the diplomatic repercussions of including them would be too detrimental. Many years ago, the great constitutional law scholar Charles Black Jr., contemplating the separate but equal doctrine, asked: does segregation offend against equality? Equality, like all general concepts, has marginal areas where philosophic difficulties are encountered. But if a whole race of people finds itself confined within a system which is set up and continued for the very purpose of keeping it in an inferior station, and if the question is then solemnly propounded whether such a race is being treated "equally," I think we ought to exercise one of the sovereign prerogatives of philosophers—that of laughter. J.R.142 J.A. 403 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 78 of 119 I think we can, without drawing any kind of equivalence between this order and Jim Crow, make a similar point here: Is this document a reasonable security measure? There are many areas in which security policy affects innocent lives but within which we do not presumptively say that the fact that some group of people faces disproportionate burdens renders that policy illegitimate. But if an entire religious grouping finds itself irrationally excluded from the country for no discernible security benefit following a lengthy campaign that overtly promised precisely such discrimination and exactly this sort of exclusion, if the relevant security agencies are excluded from the policy process, and if the question is then solemnly propounded whether the reasonable pursuit of security is the purpose, I think we ought to exercise one of the sovereign prerogatives of philosophers—that of laughter. So yes, the order is malevolent. But here’s the thing: Many of these malevolent objectives were certainly achievable within the president’s lawful authority. The president’s power over refugee admissions is vast. His power to restrict visa issuances and entry of aliens to the United States is almost as wide. If the National Security Council had run a process of minimal competence, it could certainly have done a lot of stuff that folks like me, who care about refugees, would have gnashed our teeth over but which would have been solidly within the President’s authority. It could have all been implemented in a fashion that didn’t create endless litigation opportunities and didn’t cause enormous diplomatic friction. How incompetent is this order? An immigration lawyer who works for the federal government wrote me today describing the quality of the work as “look[ing] like what an intern came up with over a lunch hour. . . . My take is that it is so poorly written that it’s hard to tell the impact." One of the reasons there’s so much chaos going on right now, in fact, is that nobody really knows what the order means on important points. Some examples: • Sec. 3(c) bans "entry"—which to the best of my knowledge has had no meaning in the Immigration and Nationality Act (INA) since the passage of the Illegal Immigration Reform and Immigrant Responsibility Act (IIRIRA) in 1996. PreIIRIRA law did use the term “entry,” but that is no longer the case. • Section 3(g) talks of waivers on a case-by-case basis for people who are otherwise denied visas or other benefits under the immigration laws pursuant to the order. If a person needs a waiver to obtain "other benefits," does that J.R.143 J.A. 404 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 79 of 119 mean that nationals of the seven countries are denied any benefit under the INA without a waiver, benefits such as naturalization, adjustment of status, or temporary protected status, even if they are already in the US? • On its face, the order bars entry of both immigrants and non-immigrants. Again, as entry is not defined, and no one was given any time to draft implementing guidance or to clarify any points, it’s no surprise that Customs and Border Protection doesn’t seem to know how to apply it to lawful permanent residents (LPRs). The INA, at section 101(a)(13)(C), says that green card holders will not be deemed as seeking admission absent the factors enumerated therein—factors that do not include an executive order banning entry. Yet Reuters and The Guardian are both reporting quotations from a DHS public relations official, stating that the order does apply to LPRs. If that interpretation lasts, look for DHS to get its ass handed to it on a platter in federal court—a defeat it will richly deserve. • Another big mystery is how the order will apply to asylees. Will people even be allowed to apply? On the one hand, the right to seek asylum is right there in the INA. But to apply for asylum, you have to be interviewed by a U.S. Citizen and Immigration Services officer to determine if you have a credible fear of persecution. Is that interview a benefit under the act? And if so, is it barred? From what I hear, right now anyway, Customs and Border Protection is not allowing anyone to claim asylum and have a credible fear interview. I could go on, but you get the point. This order is a giant birthday present to the ACLU and other immigration litigators. And godspeed to them in going after it—which, as I noted above, they are already succeeding in doing. But the incompetence actually does not stop at running a process that causes legal chaos and probable manhandling by the federal courts. Consider, for example, the likely diplomatic fallout. In his first week in office, Trump has managed to create a major rift with Mexico, our peaceable neighbor to the south with whom we have no earthly reason to be spatting and haven’t had bilateral problem this serious since Pancho Villa. Trump’s new order seems certain to raise tensions with other countries too—and not just the countries whose nationals it targets (Iran, for example, which today restricted travel by U.S. nationals in retaliation; a great many U.S. citizens have family in Iran and now can’t visit them). J.R.144 J.A. 405 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 80 of 119 Because the order applies to dual nationals, where a person is a citizen of one restricted country and one non-restricted country, it appears to bar entry to hundreds of thousands of citizens of the U.K. and Canada—including a British Member of Parliament and a Canadian-Iranian consultant who lives in the United States but now can no longer safely travel to her business’s headquarters in Toronto without being blocked from reentry. British Prime Minister Theresa May wasn’t showing a lot of spine today over the matter, but what happens when she starts getting political blowback at home for the not standing up to the U.S. over its treatment of her nationals? And Canadian Prime Minister Justin Trudeau is already making noise. He tweeted today: Justin Trudeau Follow @JustinTrudeau To those fleeing persecution, terror & war, Canadians will welcome you, regardless of your faith. Diversity is our strength #WelcomeToCanada 12:20 PM - 28 Jan 2017 428,644 778,454 In some ways, the most stunning incompetence in the document appears in one of the least discussed sections: The section at the end that mandates reporting on the nefarious terrorist activities of foreigners in the United States. This section requires regular reports from DHS on terrorism-related offenses by foreign nationals, and gender-based violence and honor killings by foreign nationals (because remember, Mexico sends us their rapists and Muslims all kill their daughters when they date Americans). The White House appears to have included this section because the Trumpists think it will show that large numbers of foreigners are coming to the United States and committing acts of terrorism here. But that is delusional, and the data will not show that—as I suspect someone at DHS would have pointed out had they had the chance. Here’s Politifact summarizing the extant data on the citizenship status of the authors of terrorist attacks in the United States: J.R.145 J.A. 406 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 81 of 119 The New America Foundation, a Washington think tank that promotes datadriven research for social and economic policy, did an analysis of "homegrown extremism" since 2000. The foundation compiled data on 499 extremists, who either adhered to jihadist ideology inspired by al-Qaida or were motivated by right- or left-wing political beliefs. This database includes attacks as well as those accused of terrorism-related offenses, such as plotting attacks or fundraising. New America found that about 64 percent of the extremists were U.S.-born citizens and 80 percent were either American-born or naturalized citizens. The database shows eight out of 499 extremists were illegal residents; all eight were jihadists. A New York Times analysis cited by many experts we interviewed found that half of the jihadist attacks since 2001 were committed by men born in the United States. Many others were naturalized citizens. Some were noncitizens but were traveling legally, such as Richard Reid, the attempted shoe bomber in Miami in 2001, who didn’t need a visa because he was from Britain. Overall, databases of terrorist acts in the United States show that many were committed by Americans or naturalized citizens, though some high-profile incidents have involved legal immigrants. "Empirically, domestic terrorism is carried out by citizens—not immigrants—with right-wing terrorism, racial hate crimes, and the sovereigncitizen movement making up a majority of domestic terrorist incidents," said Joel Day, assistant professor of security and global studies at the University of Massachusetts Lowell. "Other domestic incidents have indeed been carried out by those who came here through legal channels.’’ In other words, the executive order sets up a reporting mechanism that will almost certainly falsify its own premise. J.R.146 J.A. 407 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 82 of 119 I would wax triumphant about the mitigating effect of incompetence on this document, but alas, I can’t do it. The president’s powers in this area are vast, as I say, and while the incompetence is likely to buy the administration a world of hurt in court and in diplomacy in the short term, this order is still going take more than a few pounds of flesh out of a lot of innocent people. Moreover, it’s a very dangerous thing to have a White House that can’t with the remotest pretense of competence and governance put together a major policy document on a crucial set of national security issues without inducing an avalanche of litigation and wide diplomatic fallout. If the incompetence mitigates the malevolence in this case, that’ll be a blessing. But given the nature of the federal immigration powers, the mitigation may be small and the blessing short-lived; the implications of having an executive this inept are not small and won’t be shortlived. Topics: Donald Trump, Omphalos, Refugees Benjamin Wittes is editor in chief of Lawfare and a Senior Fellow in Governance Studies at the Brookings Institution. He is the author of several books and is co-chair of the Hoover Institution's Working Group on National Security, Technology, and Law. @benjaminwittes MORE ARTICLES J.R.147 J.A. 408 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 83 of 119 RELATED ARTICLES Trump’s Revised Refugee and Visa Order: A Quick and Dirty Analysis Benjamin Wittes Mon, Mar 6, 2017, 4:14 PM Eight Buckets of Cold Water for the Trump Wiretap Story Stewart Baker Sun, Mar 5, 2017, 6:53 PM Should the Acting Attorney General Provide FISA Court Orders to White House Counsel? Jane Chong Sun, Mar 5, 2017, 5:30 PM Ten More Questions for President Trump Benjamin Wittes Sun, Mar 5, 2017, 7:48 AM Ten Questions for President Trump Benjamin Wittes Sat, Mar 4, 2017, 11:46 AM SUPPORT LAWFARE J.R.148 J.A. 409 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 84 of 119 Exhibit L J.R.149 J.A. 410 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 85 of 119 Kelly: There are '13 or 14' more countries with questionable vetting procedures By Daniella Diaz, CNN Updated 2:09 AM ET, Tue March 7, 2017 Source: CNN Kelly says more countries have vetting issues 01:08 Story highlights Washington (CNN) — Secretary of Homeland Security John Kelly said that apart from the six countries listed on Monday's travel ban, there are "13 or 14" other countries that also have questionable vetting procedures. Trump signed a new executive order that bans immigration from six Muslim-majority countries Kelly didn't name any of the additional countries the administration is concerned about and acknowledged he doesn't expect the list of countries subject to the travel ban will grow. Kelly says the ban is not a Muslim ban "There will probably be other countries we will look at," he told CNN's Wolf Blitzer on "The Situation Room." "I don't believe the list will be expanded, but there are countries out there that we will ask, like Iraq has done ... to cooperate with us better, to get us the information we need to safeguard the country." Revised US travel ban • • • • • • • Trump signs new travel ban How this ban is different Muslims in Congress blast new order Will this impact the court cases? Travel ban: Read the full executive order Instant backlash to new travel ban This time around, ban offers wiggle room He continued: "There's a number of them out there, I don't want to speculate. There's probably 13 or 14 countries, not all of them Muslim countries, not all of them in the Middle East, that have questionable vetting procedures we can rely on. And if we overlay additional vetting procedures, the chances are these countries will be minimum citizens from those countries that visit our country." President Donald Trump on Monday signed a new executive order that bans immigration from six Muslim-majority countries, dropping Iraq from January's previous order and reinstates a temporary blanket ban on all refugees. Iraq was removed from a revised version of an executive order banning travel from certain Muslim-majority countries after intensive lobbying from the Iraqi government at the highest levels, a senior US official told CNN Monday. President Donald Trump signs new travel ban, exempts Iraq The new measures will block citizens of Syria, Iran, Libya, Somalia, Sudan and Yemen from obtaining visas for at least 90 days. The new ban, which will be implemented March 16, comes six weeks after Trump's original executive order caused chaos at airports nationwide before it was blocked by federal courts. J.R.150 J.A. 411 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 86 of 119 The ban removes language in the original order that indefinitely banned Syrian refugees and called for prioritizing the admission of refugees who are religious minorities in their home countries. Kelly told Blitzer that the ban is not a "Muslim ban," which is what it's being called by critics of the executive order. "Three of the six (countries in the travel ban) now are designated as terrorism supporters," Kelly said. "We can't rely on those governments ... It's not a Muslim ban ... there are 51 overwhelmingly Muslim countries." Related Video: Trump signs revised travel ban, Iraq is exempt 03:12 EPA veteran quits, says Trump admin isn't supporting 'vulnerable… Pence dodges question on Trump's wiretapping claims Working for Trump is an embarrassment Trump vs. Obama: A rocky relationship J.R.151 J.A. 412 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 87 of 119 Exhibit M J.R.152 J.A. 413 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 88 of 119 F.B.I. Casts Wide Net Under Relaxed Rules for Terror Inquiries, Data Show By CHARLIE SAVAGE MARCH 26, 2011 WASHINGTON — Within months after the Bush administration relaxed limits on domestic-intelligence gathering in late 2008, the F.B.I. assessed thousands of people and groups in search of evidence that they might be criminals or terrorists, a newly disclosed Justice Department document shows. In a vast majority of those cases, F.B.I. agents did not find suspicious information that could justify more intensive investigations. The New York Times obtained the data, which the F.B.I. had tried to keep secret, after filing a lawsuit under the Freedom of Information Act. The document, which covers the four months from December 2008 to March 2009, says the F.B.I. initiated 11,667 “assessments” of people and groups. Of those, 8,605 were completed. And based on the information developed in those low-level inquiries, agents opened 427 more intensive investigations, it says. The statistics shed new light on the F.B.I.’s activities in the post-Sept. 11 era, as the bureau’s focus has shifted from investigating crimes to trying to detect and disrupt potential criminal and terrorist activity. It is not clear, though, whether any charges resulted from the inquiries. And because the F.B.I. provided no comparable figures for a period before the rules change, it is impossible to determine whether the numbers represent an increase in investigations. J.R.153 J.A. 414 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 89 of 119 Still, privacy advocates contend that the large number of assessments that turned up no sign of wrongdoing show that the rules adopted by the Bush administration have created too low a threshold for starting an inquiry. Attorney General Eric H. Holder Jr. has left those rules in place. Michael German, a former F.B.I. agent who is now a policy counsel for the American Civil Liberties Union, argued that the volume of fruitless assessments showed that the Obama administration should tighten the rules. “These are investigations against completely innocent people that are now bound up within the F.B.I.’s intelligence system forever,” Mr. German said. “Is that the best way for the F.B.I. to use its resources?” But Valerie E. Caproni, the bureau’s general counsel, said the numbers showed that agents were running down any hint of a potential problem — including vigilantly checking out potential leads that might have been ignored before the Sept. 11 attacks. “Recognize that the F.B.I.’s policy — that I think the American people would support — is that any terrorism lead has to be followed up,” Ms. Caproni said. “That means, on a practical level, that things that 10 years ago might just have been ignored now have to be followed up.” F.B.I. investigations are controlled by guidelines first put in place by Attorney General Edward H. Levi during the Ford administration, after the disclosure that the bureau had engaged in illegal domestic spying for decades. After the Sept. 11 attacks, those rules were loosened by Attorney General John Ashcroft and then again by Attorney General Michael B. Mukasey. Some Democrats and civil liberties groups protested the Mukasey guidelines, contending that the new rules could open the door to racial or religious profiling and to fishing expeditions against Americans. In 2006, The New York Times reported that the National Security Agency had each month been flooding the bureau with thousands of names, phone numbers and e-mail addresses that its surveillance and data-mining programs had deemed J.R.154 J.A. 415 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 90 of 119 suspicious. But frustrated agents found that virtually all of the tips led to dead ends or innocent Americans. When the Mukasey guidelines went into effect in December 2008, they allowed the F.B.I. to use a new category of investigation called an “assessment.” It permits an agent, “proactively or based on investigative leads,” to scrutinize a person or a group for signs of a criminal or national security threat, according to the F.B.I. manual. The manual also says agents need “no particular factual predication” about a target to open an assessment, although the basis “cannot be arbitrary or groundless speculation.” And in selecting subjects for such scrutiny, agents are allowed to use ethnicity, religion or speech protected by the First Amendment as a factor — as long as it is not the only one. An assessment is less intensive than a more traditional “preliminary” inquiry or a “full” investigation, which requires greater reason to suspect wrongdoing but also allows agents to use more intrusive information-gathering techniques, like wiretapping. Still, in conducting an assessment, agents are allowed to use other techniques — searching databases, interviewing the subjects or people who know them, sending confidential informers to infiltrate an organization, attending a public meeting like a political rally or a religious service, and following and photographing people in public places. In March 2009, Russ Feingold, then a Democratic senator from Wisconsin, asked the F.B.I. how many assessments it had initiated under the new guidelines and how many regular investigations had been opened based on information developed by those assessments. In November 2010, the Justice Department sent a classified letter to the Senate Judiciary Committee answering Mr. Feingold’s question. This month, it provided an uncensored copy of the same answer to The Times as a result of its Freedom of Information Act lawsuit. J.R.155 J.A. 416 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 91 of 119 F.B.I. officials said in an interview that the statistics represented a snapshot as of late March 2009, so the 11,667 assessment files were generated over a roughly four-month period. But they said they believed that agents had continued to open assessments at roughly the same pace since then. Some aspects of the statistics are hazy, officials cautioned. For example, even before the December 2008 changes, the bureau routinely followed up on low-grade tips and leads under different rules. But that activity was not formally tracked as an “assessment” that could be easily counted and compared. F.B.I. officials also said about 30 percent of the 11,667 assessments were just vague tips — like a report of a suspicious car that included no license plate number. Such tips are entered into its computer system even if there is no way to follow up on them. Finally, they said, it is impossible to know precisely how many assessments turned up suspicious facts. A single assessment may have spun off more than one higher investigation, and some agents may have neglected to record when such an investigation started as an assessment. Ms. Caproni also said that even though the F.B.I. manual says agents can open assessments “proactively,” they still must always have a valid reason — like a tip that is not solid enough to justify a more intensive level of investigation but should still be checked out. But Mr. German, of the A.C.L.U., said that allowing agents to initiate investigations without a factual basis “seems ripe for abuse.” He added, “What they should be doing is working within stricter guidelines that help them focus on real threats rather than spending time chasing shadows.” J.R.156 J.A. 417 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 92 of 119 Exhibit N J.R.157 J.A. 418 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 93 of 119 People From 7 Travel-Ban Nations Pose No Increased Terror Risk, Report Says By RON NIXON FEB. 25, 2017 When President Trump signed an executive order last month temporarily barring visitors from seven mostly Muslim countries, he said he was moving to protect the United States from terrorist attacks. The Homeland Security secretary, John F. Kelly, echoed the president, saying the travel ban was necessary because vetting procedures “in those seven countries are suspect.” But an internal report written by intelligence analysts at Mr. Kelly’s department appears to undercut the assessment that people from the seven countries — Iran, Iraq, Libya, Somalia, Sudan, Syria and Yemen — pose a heightened threat of terrorism. The three-page report found that “country of citizenship is unlikely to be a reliable indicator of potential terrorist activity.” The report adds to the difficulties the Trump administration has faced in carrying out the travel ban. Federal judges have suspended the order, and the administration has said it will redo it to withstand legal scrutiny, but has not given a timetable. J.R.158 J.A. 419 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 94 of 119 The Department of Homeland Security assessment, first reported by The Associated Press, found that only a small number of people from the seven countries had been involved in terrorism-related activities in the United States since the Syrian civil war began in 2011. In addition, the report noted, while terrorist groups in Iraq, Syria and Yemen pose a threat to the United States, militant groups in the other four countries have a more regional focus. The report also found that in the past six years, the terrorism threat reached much more widely than the seven countries listed — individuals from 26 countries had been “inspired” to carry out attacks in the United States. Furthermore, few individuals from the seven countries affected by the ban have access to the United States, the report said, noting the small numbers of visas granted by the State Department to citizens of those nations. The White House and the Department of Homeland Security sought to play down the significance of the report. The White House said that it was politically motivated and disregarded information that would have provided support for the travel ban. The Department of Homeland Security said the report was just a draft and “not a final comprehensive review of the government’s intelligence.” Stephen Miller, a senior aide to Mr. Trump, told Fox News on Tuesday that the redrawn executive order would “have the same basic policy outcome.” The Trump administration on Friday also took the first steps toward following through on the president’s plan to build a wall along the border with Mexico. Customs and Border Protection, an agency within the Department of Homeland Security, announced that it would begin accepting design proposals for a wall. The agency said it would need the proposals by March 10. After it chooses a list of potential vendors, full proposals would be required a few weeks later. The agency said it could make a final decision by the middle of April. J.R.159 J.A. 420 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 95 of 119 J.R.160 J.A. 421 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 96 of 119 Exhibit O J.R.161 J.A. 422 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 97 of 119 The Rachel Maddow Show / The MaddowBlog Exclusive: DHS intel doc contradicts case for Trump's travel ban, 3/2/17, 9:02 PM ET TRMS Exclusive: DHS document undermines Trump case for travel ban 03 /0 2/ 17 0 9 :15 PM—UPDA TED 0 3/0 3/1 7 1 2:14 AM The Rachel Maddow Show has obtained, exclusively, a Department of Homeland Security intelligence assessment document. The document, from the Office of Intelligence and Analysis, makes the case that most foreign-born, U.S.-based violent extremists are likely not radicalized when they come to the U.S., but rather become radicalized after living in the U.S. for a number of years. The document follows another piece of research (pdf) from Homeland Security that undercut President Trump’s rationale for a travel ban as a means of keeping violent extremists out. On Friday, the Associated Press published an analysis from Homeland J.R.162 J.A. 423 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 98 of 119 Security that said citizenship in any given country – including the seven countries listed in the executive order – is likely an unreliable indicator of whether someone poses a terrorist threat. The new assessment, obtained by the Rachel Maddow Show and dated March 1, tracks 88 violent, foreign-born extremists in the United States. More than half of them had been in the U.S. more than 10 years before they were indicted or killed. Homeland Security tonight has confirmed the authenticity of the document. The department says production of it began in August 2016, and that it likely would have reached the White House. We have asked the White House for comment tonight. They have not responded. Read the document below: (Scribd pdf link here) J.R.163 J.A. 424 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 99 of 119 J.R.164 J.A. 425 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 100 of 119 J.R.165 J.A. 426 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 101 of 119 J.R.166 J.A. 427 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 102 of 119 J.R.167 J.A. 428 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 103 of 119 J.R.168 J.A. 429 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 104 of 119 J.R.169 J.A. 430 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 105 of 119 J.R.170 J.A. 431 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 106 of 119 Explore: The MaddowBlog Thursday's Mini-Report, 3.2.17 Team Trump's Russian communications come... J.R.171 J.A. 432 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 107 of 119 Exhibit P J.R.172 J.A. 433 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 108 of 119 J.R.173 J.A. 434 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 109 of 119 J.R.174 J.A. 435 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 110 of 119 J.R.175 J.A. 436 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 111 of 119 Exhibit Q J.R.176 J.A. 437 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 112 of 119 J.R.177 J.A. 438 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 113 of 119 J.R.178 J.A. 439 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 114 of 119 J.R.179 J.A. 440 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 115 of 119 J.R.180 J.A. 441 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 116 of 119 J.R.181 J.A. 442 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 117 of 119 J.R.182 J.A. 443 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 118 of 119 Exhibit R J.R.183 J.A. 444 Case 8:17-cv-00361-TDC Document 95-10 Filed 03/11/17 Page 119 of 119 Library COUNTRY RELIGIONS(%) Afghanistan (../geos/af.html) Albania (../geos/al.html) Algeria (../geos/ag.html) American Samoa (../geos/aq.html) Andorra (../geos/an.html) Angola (../geos/ao.html) Anguilla (../geos/av.html) Antigua and Barbuda (../geos/ac.html) Argentina (../geos/ar.html) J.R.184 J.A. 445 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 1 of 119 Armenia (../geos/am.html) Aruba (../geos/aa.html) Australia (../geos/as.html) Austria (../geos/au.html) Azerbaijan (../geos/aj.html) Bahamas, The (../geos/bf.html) Bahrain (../geos/ba.html) Bangladesh (../geos/bg.html) Barbados (../geos/bb.html) Belarus (../geos/bo.html) Belgium (../geos/be.html) Belize (../geos/bh.html) Benin (../geos/bn.html) Bermuda (../geos/bd.html) Bhutan (../geos/bt.html) J.R.185 J.A. 446 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 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e.html) Western Sahara (../geos/w i.html) World (../geos/xx.html) J.R.197 J.A. 458 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 14 of 119 Yemen (../geos/ym.html) Zambia (../geos/za.html) Zimbabwe (../geos/zi.html) J.R.198 J.A. 459 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 15 of 119 Exhibit S J.R.199 J.A. 460 Brody File Exclusive: President Trump Says Persecuted Christians Will Be Given Priority... Page 9 of 16 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 16 of 119 Watch About/Follow Brody File Exclusive: President Trump Says Persecuted Christians Will Be Given Priority As Refugees blogs thebrodyfile Brody File Exclusive: President Trump Says Persecuted Christians Will Be Given Priority As Refugees 01-27-2017 David Brody Share Tweet Email +126 In an exclusive interview with The Brody File, President Donald Trump says persecuted Christians will be given priority when it comes to applying for refugee status in the United States. “We are going to help them,” President Trump tells CBN News. “They’ve been horribly treated. Do you know if you were a Christian in Syria it was impossible, at least very tough to get into the United States? If you were a Muslim you could come in, but if you were a Christian, it was almost impossible and the reason that was so unfair, everybody was persecuted in all fairness, but they were chopping off the heads of everybody but more so the Christians. And I thought it was very, very unfair.” J.R.200 J.A. 461 http://www1.cbn.com/thebrodyfile/archive/2017/01/27/brody-file-exclusive-president-trum... 2/12/2017 Brody File Exclusive: President Trump Says Persecuted Christians Will Be Given Prior... Page 10 of 16 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 17 of 119 The Brody File conducted the interview Friday morning in the Blue Room at The White House. More newsworthy clips are coming soon. The entire interview can be seen this Sunday at 11pm on Freeform (cable TV, formerly ABC Family Channel) during our special CBN News show. This is just the third interview President Trump has done from The White House and it will be the only interview that will air in its’ entirety this weekend. MANDATORY VIDEO AND COURTESY: CBN NEWS/THE BRODY FILE DAVID BRODY: “Persecuted Christians, we’ve talked about this, the refugees overseas. The refugee program, or the refugee changes you’re looking to make. As it relates to persecuted Christians, do you see them as kind of a priority here?” PRESIDENT TRUMP: “Yes.” DAVID BRODY: “You do?” PRESIDENT TRUMP: “They’ve been horribly treated. Do you know if you were a Christian in Syria it was impossible, at least very tough to get into the United States? If you were a Muslim you could come in, but if you were a Christian, it was almost impossible and the reason that was so unfair, everybody was persecuted in all fairness, but they were chopping off the heads of everybody but more so the Christians. And I thought it was very, very unfair. So we are going to help them.” While you are here... We'd like to ask for your help. At CBN News, we strive to bring you the most current, pertinent and reliable news possible. We are able to bring you this important news from a Christian perspective because of the help of friends like you who know how vital it is to have an alternative to the news you hear from major media outlets. Would you help ensure that we can continue to provide this important service to you and our country by considering a special gift today? Or would you become a monthly partner so we know we can count on the resources we need to bring you the best news possible? Thanks for being a part of the dynamic future of CBN News, as well as helping The Christian Broadcasting Network share the love of Jesus with hurting people everywhere. Become a Partner Give a special gift Share Tweet Email +126 JOIN THE CONVERSATION Login Write a comment 126 Comments Steve Subscribe RSS 12 days ago Christian persecution is running at about 100,000 deaths per month. I'm so glad that our President is cognizant of this and willing to alleviate some of the pain and suffering of these people. Like Reply Share Israel Friend Di 0 13 days ago Our President Donald Trump is doing his Christian duty by banning terrorists Muslims and illegals into the USA that want to promote Sharia laws upon us and terrorize this country. Isis and Hamas chop off the heads of their own people if they are found to be worshipping the GOD OF ISRAEL, our GOD, KING JESUS. This has to be stopped before they completely destroy the entire USA and all Christians and Jews, including ISRAEL. The Muslim religion is a hate religion unlike our Judea, Christianity. We love all people of every race and don't kill to please our GOD. Our GOD died, shed HIS innocent blood as the final Lamb of GOD sacrifice and was resurrected to save us from our sins. Like Reply Share 0 J.R.201 J.A. 462 http://www1.cbn.com/thebrodyfile/archive/2017/01/27/brody-file-exclusive-president-trum... 2/12/2017 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 18 of 119 Exhibit T J.R.202 J.A. 463 Trump signs order limiting refugee entry, says he will prioritize Christian refugees - The ... Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 19 of 119 Acts of Faith Trump signs order limiting refugee entry, says he will prioritize Christian refugees By Sarah Pulliam Bailey January 27 President Trump signed an executive order Friday instituting “extreme vetting” of refugees, aimed at keeping out “radical Islamic terrorists.” “I’m establishing a new vetting measure to keep radical Islamic terrorists out of the United States of America,” Trump said during his signing of the order. “We don’t want them here. We want to make sure we are not admitting into our country the very threats our soldiers are fighting overseas.” According to drafts of the executive action, the order bars people from the Muslim-majority countries of Iraq, Syria, Iran, Sudan, Libya, Somalia or Yemen from entering the United States for 30 days and suspends the U.S. Refugee Admissions Program for 120 days. The program will be reinstated “only for nationals of countries for whom” members are vetted by Trump’s administration. In an interview Friday with the Christian Broadcast Network, Trump said he plans to help persecuted Christians. “Do you know if you were a Christian in Syria it was impossible, at least very tough, to get into the United States?” Trump said. “If you were a Muslim you could come in, but if you were a Christian, it was almost impossible and the reason that was so unfair, everybody was persecuted in all fairness, but they were chopping off the heads of everybody but more so the Christians. And I thought it was very, very unfair.” J.R.203 J.A. 464 https://www.washingtonpost.com/news/acts-of-faith/wp/2017/01/27/we-dont-want-them-th... 1/30/2017 Trump signs order limiting refugee entry, says he will prioritize Christian refugees - The ... Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 20 of 119 In a statement, the American Civil Liberties Union declared Trump’s action “just a euphemism for discrimination against Muslims.” From both legal and historical perspectives, the plan to ban refugees from specific countries is within the powers granted to the president under current law and historical precedent, according to Charles Haynes, vice president of the Newseum Institute’s Religious Freedom Center. However, whether the president can limit the ban to one religious group is another question. Many Muslims, especially Shiites, are among the religious minorities under attack, Haynes said. This “raises moral and humanitarian concerns about excluding them from entrance to the U.S. while permitting people of other faiths,” he said. “Whether this policy rises to the level of a constitutional violation is uncertain and will be debated by constitutional scholars in the coming weeks.” Issues related to the Constitution and religion are usually associated with matters of sex, such as contraceptives and LGBT discrimination, but some observers said they expect Trump’s actions on immigration to raise new challenges for religious freedom, according to Chelsea Langston Bombino of the Institutional Religious Freedom Alliance at the Center for Public Justice. Several organizations, she noted, are speaking out against orders that “will hurt the very people that their organizations were established, out of a religious calling, to serve,” she said. Trump’s actions have been decried by several religious groups this week. “The expected cutbacks to U.S. refugee programs and funding will compromise our ability to do this work and the infrastructure needed to serve refugees in the years to come,” evangelical ministry World Relief said in a statement. Acts of Faith newsletter Sign up Conversations about faith and values. And in a strongly worded statement, Rabbi Jack Moline, the Interfaith Alliance president, noted that this decision was announced on International Holocaust Remembrance Day. “For decades, the United States has prided itself as a safe bastion for refugees around the globe escaping war and persecution,” he said. “President Trump is poised to trample upon that great legacy with a de facto Muslim ban.” The Council on American-Islamic Relations will on Monday announce a federal lawsuit on behalf of more than 20 people challenging the constitutionality of the executive order. J.R.204 J.A. 465 https://www.washingtonpost.com/news/acts-of-faith/wp/2017/01/27/we-dont-want-them-th... 1/30/2017 Trump signs order limiting refugee entry, says he will prioritize Christian refugees - The ... Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 21 of 119 “There is no evidence that refugees – the most thoroughly vetted of all people entering our nation – are a threat to national security,” said CAIR national litigation director Lena F. Masri. “This is an order that is based on bigotry, not reality.” This post has been updated. Sarah Pulliam Bailey is a religion reporter, covering how faith intersects with politics, culture and...everything. Follow @spulliam The Post Recommends An ‘America first’ philosophy? During May’s visit, it’s more like ‘Trump first.’ The new president’s view of the world seems to revolve around him and his personal relationships. Facing criticism, Trump administration has no regrets about leaving out Jews in Holocaust statement What might have been seen as an oversight was confirmed by White House spokeswoman Hope Hicks to have been an intentional decision. Trump orders Pentagon to draft ISIS strategy, restructuring of security council New rules concerning lobbying are also among executive orders signed Saturday. PAID PROMOTED STORIES Recommended by J.R.205 J.A. 466 https://www.washingtonpost.com/news/acts-of-faith/wp/2017/01/27/we-dont-want-them-th... 1/30/2017 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 22 of 119 Exhibit U J.R.206 J.A. 467 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 23 of 119 - DECEMBER 07, 2015 - CATEGORIES DONALD J. TRUMP STATEMENT ON PREVENTING MUSLIM IMMIGRATION (New York, NY) December 7th, 2015, -- Donald J. Trump is calling VIEW ALL STATEMENTS ANNOUNCEMENTS for a total and complete shutdown of Muslims entering the United ENDORSEMENTS going on. According to Pew Research, among others, there is great hatred towards Americans by large segments of the Muslim ADS Center for Security Policy released data showing "25% of those polled agreed that a part of the global jihad" and 51% of those polled, "agreed that ARCHIVE Muslims in America should have the choice of being governed according to Shariah." Shariah authorizes such atrocities as murder unthinkable acts that pose great harm to Americans, especially women. NOVEMBER 2016 OCTOBER 2016 SEPTEMBER 2016 obvious to anybody the hatred is beyond comprehension. Where this hatred comes from and why we will have to determine. Until we dangerous threat it poses, our country cannot be the victims of horrendous attacks by people that believe only in Jihad, and have AUGUST 2016 JULY 2016 JUNE 2016 no sense of reason or respect for human life. If I win the election for President, we are going to Make America Great Again." - Donald J. Trump MAY 2016 APRIL 2016 MARCH 2016 Next Release: Donald J. Trump Announces State Directors in J.R.207 [2/12/2017 5:18:09 PM] FEBRUARY 2016 J.A. 468 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 24 of 119 Exhibit V J.R.208 J.A. 469 2/15/2017 Donald J. Trump on Twitter: "Just put out a very important policy statement on the extraordinary influx of hatred & danger coming into our country. We mu… Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 25 of 119   Home Search Twitter Moments  Have an account? Log in   Donald J. Trump   @realDonaldTrump Follow  Just put out a very important policy statement on the extraordinary influx of hatred & danger coming into our country. We must be vigilant! RETWEETS LIKES 2,460 5,679 1:47 PM - 7 Dec 2015  2.0K  2.5K 5.7K https://twitter.com/realdonaldtrump/status/673982228163072000?lang=en J.R.209 J.A. 470 1/1 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 26 of 119 Exhibit W J.R.210 J.A. 471 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 27 of 119 J.R.211 J.A. 472 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 28 of 119 J.R.212 J.A. 473 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 29 of 119 J.R.213 J.A. 474 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 30 of 119 Exhibit X J.R.214 J.A. 475 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 31 of 119 J.R.215 J.A. 476 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 32 of 119 J.R.216 J.A. 477 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 33 of 119 J.R.217 J.A. 478 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 34 of 119 J.R.218 J.A. 479 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 35 of 119 J.R.219 J.A. 480 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 36 of 119 J.R.220 J.A. 481 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 37 of 119 J.R.221 J.A. 482 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 38 of 119 J.R.222 J.A. 483 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 39 of 119 J.R.223 J.A. 484 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 40 of 119 J.R.224 J.A. 485 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 41 of 119 J.R.225 J.A. 486 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 42 of 119 J.R.226 J.A. 487 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 43 of 119 J.R.227 J.A. 488 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 44 of 119 J.R.228 J.A. 489 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 45 of 119 J.R.229 J.A. 490 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 46 of 119 J.R.230 J.A. 491 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 47 of 119 J.R.231 J.A. 492 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 48 of 119 J.R.232 J.A. 493 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 49 of 119 J.R.233 J.A. 494 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 50 of 119 J.R.234 J.A. 495 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 51 of 119 J.R.235 J.A. 496 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 52 of 119 J.R.236 J.A. 497 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 53 of 119 J.R.237 J.A. 498 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 54 of 119 J.R.238 J.A. 499 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 55 of 119 J.R.239 J.A. 500 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 56 of 119 J.R.240 J.A. 501 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 57 of 119 J.R.241 J.A. 502 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 58 of 119 J.R.242 J.A. 503 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 59 of 119 J.R.243 J.A. 504 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 60 of 119 Exhibit Y J.R.244 J.A. 505 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 61 of 119 Zeke Miller contributed to this report. J.R.245 J.A. 506 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 62 of 119 Exhibit Z J.R.246 J.A. 507 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 63 of 119 J.R.247 J.A. 508 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 64 of 119 J.R.248 J.A. 509 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 65 of 119 J.R.249 J.A. 510 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 66 of 119 J.R.250 J.A. 511 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 67 of 119 Exhibit AA J.R.251 J.A. 512 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 68 of 119 J.R.252 J.A. 513 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 69 of 119 J.R.253 J.A. 514 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 70 of 119 Exhibit BB J.R.254 J.A. 515 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 71 of 119 Donald Trump: 'I think Islam hates us' By Theodore Schleifer, CNN Updated 5:56 PM ET, Thu March 10, 2016 Story highlights "I think Islam hates us," Trump told CNN's Anderson Cooper, deploring the "tremendous hatred" that he said partly defined the religion Asked if the hated was "in Islam itself," Trump would only say that was for the media to figure out Washington (CNN) — Donald Trump said Wednesday that he thinks "Islam hates us," drawing little distinction between the religion and radical Islamic terrorism. "I think Islam hates us," Trump told CNN's Anderson Cooper, deploring the "tremendous hatred" that he said partly defined the religion. He maintained the war was against radical Islam, but said, "it's very hard to define. It's very hard to separate. Because you don't know who's who." J.R.255 J.A. 516 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 72 of 119 Donald Trump CNN interview (part 1) 10:15 READ: Donald Trump: 'It's over' if I win Ohio and Florida Asked if the hate was "in Islam itself," Trump would only say that was for the media to figure out. "You're gonna have to figure that out, OK?" he told Cooper. "We have to be very vigilant. We have to be very careful. And we can't allow people coming into this country who have this hatred of the United States." J.R.256 J.A. 517 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 73 of 119 Donald Trump CNN interview (part 2) 10:59 Trump made headlines in December when he called for a temporary ban on Muslims entering the U.S., "until our country's representatives can figure out what is going on." Despite widespread condemnation of the remarks, Trump has stood by the proposal. Speaking to CNN's Wolf Blitzer on "The Situation Room" Thursday, Trump spokeswoman Katrina Pierson said the real-estate magnate stood by the sentiment that many Muslims worldwide sympathize with ISIS, but said Trump should've used "radical Islam." "It is radical Islamic extremists that do participate in these types of things," Pierson said, calling for a "broader perspective" of Muslims' ties to terror. "We've allowed this propaganda to spread all through the country that this is a religion of peace." In speaking with Cooper, Trump added that "there can be no doctrine" when asked to outline how he would project power overseas. Trump also tried to clarify his position on how far he would go in targeting the families of terrorists. He has said in the past that he is in favor of "expanding the laws" that govern how the U.S. can combat and deter terrorism, and Trump has called to bring back waterboarding, even vowing the U.S. "should go a lot further than waterboarding." J.R.257 J.A. 518 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 74 of 119 Donald Trump talks about working with Democrats 00:51 READ: Trump: My Muslim friends don't support my immigration ban But Trump on Wednesday declined to say what specific measures he would support. "I'll work on it with the generals," he told Cooper. He added, "We have to play the game at a much tougher level than we're playing it now." Pence's sphere of influence questioned in wake of Flynn fallout Trump shows his true hand on LGBTQ rights Feinstein, Grassley seek full briefing, transcripts of Flynn calls Obama photographer shades Trump over secure discussions J.R.258 J.A. 519 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 75 of 119 J.R.259 J.A. 520 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 76 of 119 Exhibit CC J.R.260 J.A. 521 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 77 of 119 J.R.261 J.A. 522 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 78 of 119 J.R.262 J.A. 523 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 79 of 119 Exhibit DD J.R.263 J.A. 524 Case: 17-35105, 02/11/2017,Document 14 Filed 02/06/17 Page 123 of 68 Case 2:17-cv-00135-JLR ID: 10316343, DktEntry: 140-3, Page of 5 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 80 of 119 J.R.264 J.A. 525 Case: 17-35105, 02/11/2017,Document 14 Filed 02/06/17 Page 224 of 68 Case 2:17-cv-00135-JLR ID: 10316343, DktEntry: 140-3, Page of 5 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 81 of 119 J.R.265 J.A. 526 Case: 17-35105, 02/11/2017,Document 14 Filed 02/06/17 Page 325 of 68 Case 2:17-cv-00135-JLR ID: 10316343, DktEntry: 140-3, Page of 5 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 82 of 119 J.R.266 J.A. 527 Case: 17-35105, 02/11/2017,Document 14 Filed 02/06/17 Page 426 of 68 Case 2:17-cv-00135-JLR ID: 10316343, DktEntry: 140-3, Page of 5 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 83 of 119 J.R.267 J.A. 528 Case: 17-35105, 02/11/2017,Document 14 Filed 02/06/17 Page 527 of 68 Case 2:17-cv-00135-JLR ID: 10316343, DktEntry: 140-3, Page of 5 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 84 of 119 J.R.268 J.A. 529 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 85 of 119 Exhibit EE J.R.269 J.A. 530 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 86 of 119 https://nyti.ms/2jLMxKS N.Y. / REGION Disorder at Airports as Travelers Are Detained Without Lawyers By BENJAMIN MUELLER and MATTHEW ROSENBERG JAN. 29, 2017 Drab airport screening areas and waiting rooms were transformed into chaotic scenes on Sunday, with lawyers saying that border agents had put pressure on detainees and created an information blackout that left many struggling to discern how President Trump’s immigration order was being applied. In New York, a lawyer said detainees were being moved from one terminal to another in handcuffs. In Los Angeles, an Iranian graduate student was pushed by border agents to sign documents allowing them to send her out of the country, her lawyers said. And in the Washington area, agents told lawyers that officials had barred detainees from getting legal help, despite a federal judge’s order that legal permanent residents be given access to lawyers. Panic gave way to euphoria in some cases as travelers who had been detained for many hours were released and reunited with relatives. But well into Sunday, two days after Mr. Trump signed an executive order keeping many foreigners from entering the country, lawyers were still sweeping airport arrival sections in search of waiting relatives, often their only source of information about who was being held. Some detainees said they had slept on office chairs. In Los Angeles, lawyers said Customs and Border Protection agents had told them there were cots but had declined to say how many there were, or how many people were being held. J.R.270 J.A. 531 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 87 of 119 Detainees were told their phones would be disruptive and had to be taken. Lawyers and relatives were growing increasingly concerned about older detainees with medical problems. Among those with ailments were an Iranian couple who had arrived in Los Angeles on visitors’ visas. The man, in his late 60s, had been through two open-heart operations, and he and his wife, in her late 50s, were both diabetic. After arriving at the airport on Saturday afternoon, they were allowed to call their daughter in the United States only once, around 1 a.m. on Sunday, said Patricia Corrales, a private lawyer working on detainees’ cases there. Relatives and lawyers repeatedly asked whether the couple were receiving proper medical care but learned nothing further from border agents. Ms. Corrales, who was an Immigration and Customs Enforcement lawyer for 17 years, said, “I think they don’t necessarily have the resources, the staff and experience to deal with these large numbers.” In a statement, the Department of Homeland Security said, “We are committed to ensuring that all individuals affected by the executive orders, including those affected by the court orders, are being provided all rights afforded under the law.” Some detainees were reportedly pressured to sign documents they hardly understood and then put on flights out of the country. When two brothers from Yemen, Tareq Aqel Mohammed Aziz, 21, and Ammar, 19, landed on Saturday morning at Dulles International Airport near Washington with immigrant visas, they planned to board a connecting flight to Flint, Mich., to join their father. Instead, they were taken off the plane, put into handcuffs and told they needed to sign a form or face being barred from the country for five years, said their lawyer, Simon Y. Sandoval-Moshenberg, of the Legal Aid Justice Center in Virginia. They signed the form and were quickly put on a plane to Ethiopia. A 24-year-old Iranian woman who is a graduate student in the United States told relatives of a similar problem at Los Angeles International Airport, where she J.R.271 J.A. 532 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 88 of 119 arrived on Saturday after a trip visiting family members in Europe. Border agents told the woman that her student visa was no longer valid, which lawyers said was not true, and that if she did not sign a document saying she was leaving voluntarily, she would be forcibly deported and barred from entry for five years. The Iranian student signed. She had not been allowed to consult a lawyer and was permitted only three calls to relatives before her phone was confiscated and searched, said Ms. Corrales and Judy London, the directing attorney of the nonprofit Public Counsel’s Immigrants’ Rights Project, both of whom spoke with the woman’s relatives. On Saturday night, after a federal judge in Brooklyn ruled the government could not remove travelers who had arrived with valid visas, she was put on a plane back to Europe, her lawyers said. They declined to share her name out of concern for her safety. On Sunday morning, Ms. Corrales spoke to a supervisor from the customs agency who suggested that the Iranian student was still at the Los Angeles airport. The supervisor told Ms. Corrales that “they were waiting for orders from higherups in terms of how to enforce the injunction,” Ms. Corrales said, referring to the Brooklyn judge’s ruling. Some detainees dealt with the whiplash of plans changing by the hour. A group of five Iranians detained in New York told family members on Sunday morning that the government planned to put them on a 1:30 p.m. flight back to Turkey, said Melanie Zuch, a staff lawyer at the Urban Justice Center. Several hours later, some of them were told they would be allowed to stay. Vahideh Rasekhi, a graduate student at Stony Brook University on Long Island who was also detained at Kennedy Airport, said she and other detainees were also told they would be put on flights back out of the country, with agents promising only that if they held out a little longer, they might work out a way to keep them in the United States. Eventually they did, and shortly after 2:30 p.m., Ms. Rasekhi walked into Terminal 4 and was immediately surrounded by loved ones, lawyers and journalists. J.R.272 J.A. 533 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 89 of 119 “I’m just so exhausted,” she said. She said that detainees had been given meals and water and that agents had even satisfied one person’s request for a lemon. Others gave accounts of more difficult conditions; one lawyer, Justin Orr, said some detainees had been given nothing but chocolate to eat. Mousa Ahmadi, 30, an Iranian graduate student at the New Jersey Institute of Technology, gave a long hug to his sister, Dr. Fahimeh Ahmadi, 40, after she was released from additional screening at Kennedy. The siblings had not seen each other for over three years. Dr. Ahmadi, a general practitioner in the Australian city of Gold Coast and a dual citizen of Australia and Iran, arrived for a long-planned visit without the siblings’ parents, who hold only Iranian passports and canceled their flights on Saturday. “My Mom said, ‘If they don’t let me in the country do you think I can see him even for a half hour?’” Dr. Ahmadi recalled. “She said, ‘Is there a window where I can see him?’” Lawyers at J.F.K. said that about half a dozen detainees were still in custody by late Sunday afternoon. The Los Angeles Police Department told lawyers there earlier on Sunday that about 40 people were being held. A federal judge in Alexandria, Va., on Saturday ordered government officials to give lawyers access to all legal permanent residents being detained at Dulles. But when lawyers showed border agents there the court order and requested access to detainees, a supervisor replied, “That’s not going to happen.” Matt Zeller, who runs No One Left Behind, a group that helps bring over Iraqis and Afghans who worked for the military, said he was told that there were 40 to 55 people who had been pulled aside by customs officers at Dulles on Sunday evening, and that at least some were Iraqis, although it was not clear if any had worked for the military. Detainees who had been released overnight — many of whom had J.R.273 J.A. 534 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 90 of 119 green cards — spoke of hours of uncertainty as they waited to find out if they would be allowed into a country that they called home but that no longer seemed to want them. “This is not the America that I have lived in,” said one man who had been released, Seifollah Moradi, 34, a student from Columbia, Md., who has a green card. “We used to be treated with respect. This is the land of freedom.” Mr. Moradi had been held for six hours after returning from Tehran, where he was visiting his sick father. Protesters, who were lined up just past the set of one-way doors that separate the public areas of the Dulles arrival hall from the immigration and baggage claim areas for international flights, cheered loudly as Mr. Moradi came through the doors. They chanted, “Welcome to the U.S.A.,” and, “No hate, no fear, refugees are welcome here.” Mr. Moradi, his face drawn, hardly seemed to notice. Reporting was contributed by Ruth Bashinsky, Sheri Fink, Sean Piccoli and Liz Robbins. A version of this article appears in print on January 30, 2017, on Page A13 of the New York edition with the headline: Confusion and Disorder at Airports as Travelers Are Detained Without Lawyers. © 2017 The New York Times Company J.R.274 J.A. 535 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 91 of 119 Exhibit FF J.R.275 J.A. 536 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 92 of 119 J.R.276 J.A. 537 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 93 of 119 J.R.277 J.A. 538 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 94 of 119 J.R.278 J.A. 539 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 95 of 119 Exhibit GG J.R.279 J.A. 540 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 96 of 119 J.R.280 J.A. 541 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 97 of 119 J.R.281 J.A. 542 Case 8:17-cv-00361-TDC Document 95-11 Filed 03/11/17 Page 98 of 119 J.R.282 J.A. 543 Case 8:17-cv-00361-TDC Document 95-11 Filed 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