TIKTOK INC. et al v. TRUMP et al

Filing 15

MOTION for Preliminary Injunction MOTION to Expedite by BYTEDANCE LTD., TIKTOK INC. (Attachments: #1 Memorandum in Support, #2 Declaration, #3 Declaration, #4 Declaration, #5 Declaration, #6 Exhibit, #7 Exhibit, #8 Exhibit, #9 Exhibit, #10 Exhibit, #11 Exhibit, #12 Exhibit, #13 Exhibit, #14 Exhibit, #15 Exhibit, #16 Exhibit, #17 Exhibit, #18 Exhibit, #19 Exhibit, #20 Exhibit, #21 Exhibit, #22 Exhibit, #23 Exhibit, #24 Exhibit, #25 Exhibit, #26 Exhibit, #27 Exhibit, #28 Exhibit, #29 Exhibit, #30 Exhibit, #31 Exhibit, #32 Exhibit, #33 Exhibit, #34 Exhibit, #35 Exhibit, #36 Exhibit, #37 Exhibit, #38 Exhibit, #39 Exhibit, #40 Exhibit, #41 Exhibit, #42 Exhibit, #43 Text of Proposed Order)(Hall, John). Added MOTION to Expedite on 9/24/2020 (zeg).

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Case 1:20-cv-02658-CJN Document 15-10 Filed 09/23/20 Page 1 of 7 EXHIBIT 4 Case 1:20-cv-02658-CJN Document 15-10 Filed 09/23/20 Page 2 of 7   S U R I VA N O R O C ebolg eht ssorca gnidaerps saw surivanoroc sa anihC desiarp pmurT semit 51 The president has lambasted the WHO for accepting Beijing’s assurances about the outbreak, but he repeated them, as well. segamI ytteG/hcivoraM eteP | .pmurT dlanoD tnediserP DRAW TDE MP 72:60 H AY M yB 0202/51/40 Case 1:20-cv-02658-CJN Document 15-10 Filed 09/23/20 Page 3 of 7 0:00 POLITICO has compiled a list of 15 times the president hailed China for its push to prevent a pandemic in the early months of 2020 — an effort that ultimately failed: Jan. 22, Twitter: “One of the many great things about our just signed giant Trade Deal with China is that it will bring both the USA & China closer together in so many other ways. Terrific working with President Xi, a man who truly loves his country. Much more to come!” Jan. 24, Twitter: “China has been working very hard to contain the Coronavirus. The United States greatly appreciates their efforts and transparency. It will all work out well. In particular, on behalf of the American People, I want to thank President Xi!” Jan. 29, Remarks at signing ceremony for the United States-Mexico-Canada Agreement: “And, honestly, I think, as tough as this negotiation was, I think our relationship with China now might be the best it's been in a long, long time. And now it's reciprocal. Before, we were being ripped off badly. Now we have a reciprocal relationship, maybe even better than reciprocal for us.” tnemesitrevdA DA Case 1:20-cv-02658-CJN Document 15-10 Filed 09/23/20 Page 4 of 7 Jan. 30, Fox News interview: "China is not in great shape right now, unfortunately. But they're working very hard. We'll see what happens. But we're working very closely with China and other countries." Feb. 7, Remarks at North Carolina Opportunity Now Summit in Charlotte, N.C.: "I just spoke to President Xi last night, and, you know, we're working on the — the problem, the virus. It's a — it's a very tough situation. But I think he's going to handle it. I think he's handled it really well. We're helping wherever we can." Feb. 7, Twitter: “Just had a long and very good conversation by phone with President Xi of China. He is strong, sharp and powerfully focused on leading the counterattack on the Coronavirus. He feels they are doing very well, even building hospitals in a matter of only days … Great discipline is taking place in China, as President Xi strongly leads what will be a very successful operation. We are working closely with China to help! Feb. 7, Remarks before Marine One departure: "Late last night, I had a very good talk with President Xi, and we talked about — mostly about the coronavirus. They're working really hard, and I think they are doing a very professional job. They're in touch with World — the World — World Organization. CDC also. We're working together. But World Health is working with them. CDC is working with them. I had a great conversation last night with President Xi. It's a tough situation. I think they're doing a very good job.” Feb. 10, Fox Business interview: "I think China is very, you know, professionally run in the sense that they have everything under control," Trump said. "I really believe they are going to have it under control fairly soon. You know in April, supposedly, it dies with the hotter weather. And that's a beautiful date to look forward to. But China I can tell you is working very hard." Case 1:20-cv-02658-CJN Document 15-10 Filed 09/23/20 Page 5 of 7 Feb. 10, campaign rally in Manchester, N.H.: “I spoke with President Xi, and they’re working very, very hard. And I think it’s all going to work out fine.” Feb. 13, Fox News interview: “I think they've handled it professionally and I think they're extremely capable and I think President Xi is extremely capable and I hope that it's going to be resolved." Feb. 18, remarks before Air Force One departure: tnemesitrevdA DA “I think President Xi is working very hard. As you know, I spoke with him recently. He’s working really hard. It’s a tough problem. I think he’s going to do — look, I’ve seen them build hospitals in a short period of time. I really believe he wants to get that done, and he wants to get it done fast. Yes, I think he’s doing it very professionally.” Feb. 23, remarks before Marine One departure: "I think President Xi is working very, very hard. I spoke to him. He's working very hard. I think he's doing a very good job. It's a big problem. But President Xi loves his country. He's working very hard to solve the problem, and he will solve the problem. OK?" Feb. 26, remarks at a business roundtable in New Delhi, India: Case 1:20-cv-02658-CJN Document 15-10 Filed 09/23/20 Page 6 of 7 “China is working very, very hard. I have spoken to President Xi, and they’re working very hard. And if you know anything about him, I think he’ll be in pretty good shape. They’re — they’ve had a rough patch, and I think right now they have it — it looks like they’re getting it under control more and more. They’re getting it more and more under control.” Feb. 27, Coronavirus Task Force press conference: “I spoke with President Xi. We had a great talk. He’s working very hard, I have to say. He’s working very, very hard. And if you can count on the reports coming out of China, that spread has gone down quite a bit. The infection seems to have gone down over the last two days. As opposed to getting larger, it’s actually gotten smaller.” Feb. 29, Coronavirus Task Force press conference: “China seems to be making tremendous progress. Their numbers are way down. … I think our relationship with China is very good. We just did a big trade deal. We’re starting on another trade deal with China — a very big one. And we’ve been working very closely. They’ve been talking to our people, we’ve been talking to their people, having to do with the virus.” W O N K O T D E E N U O Y TA H W : S U R I VA N O R O C U.S. coronavirus death toll tops 200,000 as officials fear fall surge. 281,002 :shtaeD .S.U | 069,768,6 :sesaC .S.U demrifnoC gniees er'uoy tahw su lleT ?rekrow erac htlaeh a uoy erA  etats yb etats dekcart ,sesac surivanoroC  yltnenamrep dlrow eht egnahc lliw surivanoroc woH  S T N E M P OL E V E D P O T .cimednap eht rof "elbatnuocca anihC dloh tsum" snoitaN detinU eht dias pmurT ".ydobon yllautriv stceffa ti" gniyas elpoep gnuoy ot taerht suriv syalpnwod pmurT .mialc eniccav wen a htiw slaiciffo htlaeh stcidartnoc pmurT .enrobria si surivanoroc eht taht gninraw sti no skcartkcab CDC ehT » egarevoc surivanoroc lla daeR President Donald Trump yanked U.S. funding for the World Health Case 1:20-cv-02658-CJN Document 15-10 Filed 09/23/20 Page 7 of 7 Organization on Tuesday, complaining that the United Nations public health agency was overly deferential to China and had put too much faith in Beijing’s assertions that it had the coronavirus outbreak there was under control. “Had the WHO done its job to get medical experts into China to objectively assess the situation on the ground and to call out China’s lack of transparency, the outbreak could have been contained at its source with very little death,” the president said Tuesday. “Instead, the W.H.O. willingly took China’s assurances to face value.” tnemesitrevdA Trump, however, echoed many of those same assurances regarding China and its response to the virus throughout January and February, as the unique coronavirus began to infiltrate countries around the world. Just days before the U.S. recorded its first death from Covid-19, Trump touted China’s government for its transparency and hard work to defeat the coronavirus that causes the illness.

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