State of Washington, et al v. Donald J. Trump, et al

Filing 142

Filed Amicus Curiae - Pending Kim Blandino motion to become amicus curiae. Deficiencies: None. Served on 02/13/2017. [10319458] (LA) [Entered: 02/14/2017 02:53 PM]

RECEIVED
MOLLY C. DWYER,
CLERK
J.S. COURT OF APPEALS

No. 17-35105

FEB 1 4 2017
FILED
DOCKETED
dAi F

INITIAI

UNITED STATES COURT OF APPEALS
FOR THE NINTH CIRCUIT

STATE OF WASHINGTON, et al.,
Plaintiffs-Appelles

V.

DONALD TRUMP, President of the United States, et al.,
Defendant-Appellants.

ON APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE
WESTERN DISTRICT OF WASHINGTON
f

MOTION TO FILE BRIEF OF AMICUS CURIAE KIM BLANDINO,
PRO SE IN SUPPORT OF DEFENDANT-APPELLANTS URGING
IMMEDIATE ACTION TO VACATE THE TRO OR IN THE ALTERNATIVE
TO TREAT THIS SUBMISSION AS AN EXTRAORDINARY WRIT OF
MANDAMUS, PROHIBITION OR ANY OTHER EXTRAORDINARY WRIT
AS KIM IS AN AFFECTED PERSON THAT IS EXPOSED TO DANGER BY
THE TRO ISSUED BY THE DISTRICT COURT

1

Kim Blandino Pro Se
C/O 441 N. 16t St.
Las Vegas Nv. 89101
Tele: [phone]
Fax Call before sending
Email: [e-mail]

The undersigned Movant, Kim Blandino, hereinafter, "Kim" was born in the U.S.
And is a denizen of the U.S and is currently residing temporarily in Las Vegas,
Nevada. Kim's two adult sons also reside in the U.S. . Kim respectfully moves this
Court under the FRAP and FRAP 29(a)(2), for leave to file the attached BRIEF OF
AMICUS CURIAE KIM BLANDINO, PRO SE IN SUPPORT . OF
DEFENDANT-APPELLANTS URGING IMMEDIATE ACTION TO VACATE
THE TRO OR IN THE ALTERNATIVE TO TREAT THIS SUBMISSION AS
AN EXTRAORDINARY WRIT OF MANDAMUS, PROHIBITION OR ANY
OTHER EXTRAORDINARY WRIT AS KIM IS AN AFFECTED PERSON
THAT IS EXPOSED TO DANGER BY THE TRO ISSUED BY THE
DISTRICT COURT in support of the Appeal filed by the Department of Justice to
the Temporary Restraining Order (TRO) issued by the U.S. District Court for the
Western District of Washington, relating to President Trump's Executive Order:
Protecting The Nation From Foreign Terrorist Entry Into The United States #13 769.
Now that this court has issued an order based on a sua sponte en banc call by the
unknown "Judge Doe" as to whether the order denying the stay on Feb 9, 2017
F)

should be reconsidered en banc and ordering a briefing schedule, potential relief must
still be requested in this court before asking the supreme court relief

relief is not given here so time is of the essence.
STATEMENT OF MOVANT'S INTEREST AND RELVANCY OF BRIEFING
Kim was born in the State of Montana, and grandson of a legal immigrant that
came in through Ellis Island . Kim is a denizen of the U.S. Kim and his sons are
directly in the "line of fire" of any terrorist or agents of terrorists or "would be
terrorists" that are a direct threat to anyone residing in America. The attacks on
Sept. 11, 2001 in New York and elsewhere and all the incidents since then to now has
proven that there is truly a "war on terror" that America did not start and is still being
waged to this day.
Kim is also an investigative journalist investigating judicial corruption in Nevada
and an individual with deep religious convictions. Kim believes that America and the
State of Israel have a common destiny to stand against evil and that terrorism is evil.
That the national security of America is of great importance. That President Trump's
executive order #13769 was established to protect America and all lawful residents,
denizens, and citizens therein, while still leaving open avenues for legal immigration
that is designed to protect against terrorist threats from outside the U.S.
The proposed submission by Kim will assist the Court in addressing crucial and

dispositive issues which have not been heretofore addressed during oral argument nor
incorporated into any of the filings.
-

-

-

::

C

:

•

i

insights, facts or data that are not to be found in the parties' briefs." See Voices for
Choices v. Bell tel. Co., 339 F.3d 542, 545 (7`" Cir. 2003).
Kim and his sons are affected by the TRO issued in the case below as now all of
America is exposed to greater danger because of the TRO and Judge Hobart was and
is not disrupting the new status quo established by the President with his Order.

CONCLUSION
For the foregoing reasons Kim requests leave of the Court to file the proposed
submission amicus curiae in support of Defendant-Appellants Donald Trump et al.

DATED this 13th day of February, 2017.

KIM BLANDINO PRO SE
C/O 441 N. 16' Street
Las Vegas, Nevada 89101
(702 )219-5657
[e-mail]

.I
►

CERTIFICATE OF COMPLIANCE
Pursuant to FRAP 32(a)(7)(C)(i) the undersigned individual, appearing pro se,
certifies that this submission: _
(i) Complies with the typeface requirements of Rule 32(a)(5) and the type
style requirements of Rule 32(a)(6). It has been prepared using OpenOffice
Writer and is set in Times New Roman with a font size of 14-point,
(ii) Complies with the length requirement of Rule 27(d)(2) because it contains
945 words.

DATED this 13th. day of February, 2017.

KIM BLANDINO PRO SE
C/O 441 N. 16t'' Street
Las Vegas, Nevada 89101
(702 )219-5657
[e-mail]

CERTIFICATE OF SERVICE
I hereby certify that on February 13, 2017, a true and correct copy of the foregoing:
MOTION with first class postage prepaid has been deposited in the U.S. Mail in
Santa Ana, California, and properly addressed to the persons whose names and
addresses are listed below.
Noah G. Purcell
Washington Attorney General's Office
E

800 Fifth Avenue, Suite 2000
Seattle, WA 98104-3188
(Courtesy copy e-mailed to [e-mail])

Acting Solicitor General, U.S. Department of Justice
950 Pennsylvania Avenue, N.W.
Washington, DC 20530
(Courtesy copy e-mailed to Noel [e-mail])

DATED: February 13, 2017

KIM BLANDINO PRO SE
C/O 441 N. 1611' Street
Las Vegas, Nevada 89101
(702 )219-5657
[e-mail]

0