State of Hawaii v. Trump

Filing 367

MOTION for Leave to File Third Amended Complaint Neal Katyal appearing for Plaintiff State of Hawaii (Attachments: #1 Exhibit [Proposed] Third Amended Complaint, #2 Exhibit [Proposed] Ex. 1 to Third Amended Complaint, #3 Exhibit [Proposed] Ex. 2 to Third Amended Complaint., #4 Exhibit [Proposed] Ex. 3 to Third Amended Complaint, #5 Exhibit [Proposed] Ex. 4 to Third Amended Complaint, #6 Exhibit [Proposed] Ex. 5 to Third Amended Complaint, #7 Exhibit [Proposed] Ex. 6 to Third Amended Complaint, #8 Exhibit [Proposed] Ex. 7 to Third Amended Complaint, #9 Exhibit [Proposed] Ex. 8 to Third Amended Complaint, #10 Exhibit [Proposed] Ex. 9 to Third Amended Complaint, #11 Exhibit Proposed Order, #12 Certificate of Service)(Katyal, Neal)

Post Politics

‘I think Islam hates us’: A
timeline of Trump’s
comments about Islam and
Muslims
By Jenna Johnson and Abigail Hauslohner May 20

President Trump is in Saudi Arabia this weekend to meet with Arab leaders, visit the birthplace of Islam and give a speech
about religious tolerance with the hope of resetting his reputation with the world's 1.6 billion Muslims. But it's unclear if a
two-day visit is enough to overshadow his past statements about Islam and its faithful, with his rhetoric becoming more
virulent as he campaigned for president.
Here's a look back at some of the comments that he has made:
March 30, 2011: For years, Trump publicly questioned then-President Barack Obama’s religious beliefs and place of birth.
As he debated running for president in the 2012 election, Trump said in a radio interview: “He doesn't have a birth certificate,
or if he does, there's something on that certificate that is very bad for him. Now, somebody told me — and I have no idea if this
is bad for him or not, but perhaps it would be — that where it says 'religion,' it might have 'Muslim.' And if you're a Muslim,
you don't change your religion, by the way.” (Obama is a Christian, and state records show he was born in Hawaii.)
Sept. 17, 2015: At a campaign town hall in New Hampshire, a man in the audience shouted out: “We have a problem in this
country; it's called Muslims. We know our current president is one.” The man mentioned Muslim “training camps” and asked:
“When can we get rid of them?” Trump responded: “We're going to be looking at a lot of different things. You know, a lot of
people are saying that, and a lot of people are saying that bad things are happening out there. We're going to be looking at that
and plenty of other things.”
Sept. 20, 2015: On NBC News, Trump was asked if he would be comfortable with a Muslim as president; he responded: “I
can say that, you know, it's something that at some point could happen. We will see. I mean, you know, it's something that
could happen. Would I be comfortable? I don't know if we have to address it right now, but I think it is certainly something
that could happen.”

EXHIBIT 3

Sept. 30, 2015: At a New Hampshire rally, Trump pledged to kick all Syrian refugees — most of whom are Muslim — out of
the country, as they might be a secret army. “They could be ISIS, I don't know. This could be one of the great tactical ploys of
all time. A 200,000-man army, maybe,” he said. In an interview that aired later, Trump said: “This could make the Trojan
horse look like peanuts.”
Oct. 21, 2015: On Fox Business, Trump says he would “certainly look at” the idea of closing mosques in the United States.
Nov. 16, 2015: Following a series of terrorist attacks in Paris, Trump said on MSNBC that he would “strongly consider”
closing mosques. “I would hate to do it, but it's something that you're going to have to strongly consider because some of the
ideas and some of the hatred — the absolute hatred — is coming from these areas,” he said.
Nov. 20, 2015: In comments to Yahoo and NBC News, Trump seemed open to the idea of creating a database of all Muslims
in the United States. Later, he and his aides would not rule out the idea.
Nov. 21, 2015: At a rally in Alabama, Trump said that on Sept. 11 he “watched when the World Trade Center came tumbling
down. And I watched in Jersey City, N.J., where thousands and thousands of people were cheering as that building was
coming down.”
Nov. 22, 2015: On ABC News, Trump doubled down on his comment and added: “It was well covered at the time. There
were people over in New Jersey that were watching it, a heavy Arab population, that were cheering as the buildings came
down. Not good.” (While there were some reports of celebrations overseas, extensive examination of news clips turn up no
such celebrations in New Jersey.)
Nov. 30, 2015: On MSNBC, a reporter asked Trump if he thinks Islam is an inherently peaceful religion that's been
perverted by a small percentage of followers or if it is an inherently violent religion. Trump responded: “Well, all I can say …
there’s something going on. You know, there's something definitely going on. I don't know that that question can be
answered.” He also said: “We are not loved by many Muslims.”
Dec. 3, 2015: The morning after Syed Rizwan Farook and Tashfeen Malik killed 14 people in San Bernardino, Calif., Trump
called into Fox News and said: “The other thing with the terrorists is you have to take out their families, when you get these
terrorists, you have to take out their families.” (Killing the relatives of suspected terrorists is forbidden by international law.)
Later, in a speech to the Republican Jewish Coalition, Trump criticized Obama for not using the phrase “radical Islamic
terrorism” and commented: “There's something going on with him that we don't know about.”
Dec. 6, 2015: On CBS News, Trump said: “If you have people coming out of mosques with hatred and death in their eyes and
on their minds, we’re going to have to do something.” Trump also said he didn’t believe the sister of one of the San Bernardino
shooters who said she was crestfallen for the victims, saying: “I would go after a lot of people, and I would find out whether or
not they knew. I would be able to find out, because I don't believe the sister.”

Dec. 7, 2015: Trump's campaign issued a statement saying: “Donald J. Trump is calling for a total and complete shutdown of
Muslims entering the United States until our country’s representatives can figure out what is going on.” Trump read this
statement aloud at a rally in South Carolina.
Dec. 8, 2015: On CNN, Trump quoted a widely debunked poll by an anti-Islam activist organization that claimed that a
quarter of the Muslims living in the United States agreed that violence against Americans is justified as part of the global
jihad. “We have people out there that want to do great destruction to our country, whether it's 25 percent or 10 percent or 5
percent, it's too much,” Trump said.
Dec. 13, 2015: On Fox News, Trump was asked if his ban would apply to a Canadian businessman who is a Muslim. Trump
responded: “There's a sickness. They're sick people. There's a sickness going on. There's a group of people that is very sick.”
Jan. 12, 2016: At a rally in Iowa, Trump shared his suspicions about Syrian refugees and then read the lyrics to Al Wilson’s
1968 song “The Snake,” the story of a “tender woman” who nursed a sickly snake back to health but then was attacked by the
snake. Trump often read these lyrics at rallies.
Feb. 3, 2016: Trump criticized Obama for visiting a mosque in Baltimore and said on Fox News: “Maybe he feels comfortable
there … There are a lot of places he can go, and he chose a mosque.” (It was Obama's first visit to a mosque during his
presidency, and it was made in an effort to encourage religious tolerance in light of growing anti-Muslim sentiment.)
Feb. 20, 2016: After Obama skipped the funeral of Supreme Court Justice Antonin Scalia, Trump tweeted: “I wonder if
President Obama would have attended the funeral of Justice Scalia if it were held in a Mosque? Very sad that he did not go!”
(Obama did pay his respects when Scalia's body lay in repose in the Supreme Court.) That night at a rally in South Carolina,
Trump told an apocryphal tale that he would return to repeatedly about U.S. Gen. John J. Pershing fighting Muslim
insurgents in the Philippines in the early 1900s and killing a large group of insurgents with bullets dipped in pigs’ blood.
March 9, 2016: On CNN, Trump said: “I think Islam hates us. There’s something there that — there’s a tremendous hatred
there. There’s a tremendous hatred. We have to get to the bottom of it. There’s an unbelievable hatred of us.”
March 22, 2016: Soon after three suicide bombings in Brussels tied to a group of French and Belgian Muslims, Trump told
Fox Business: “We're having problems with the Muslims, and we're having problems with Muslims coming into the country.”
Trump called for surveillance of mosques in the United States, saying: “You have to deal with the mosques, whether we like it
or not, I mean, you know, these attacks aren't coming out of — they're not done by Swedish people.”
On NBC News, Trump added: “This all happened because, frankly, there’s no assimilation. They are not assimilating . . . They
want to go by sharia law. They want sharia law. They don’t want the laws that we have. They want sharia law.”
March 23, 2016: In an interview with Bloomberg TV, Trump said that Muslims “have to respect us. They do not respect us
at all. And frankly, they don't respect a lot of the things that are happening throughout not only our country, but they don't
respect other things.”

March 29, 2016: During a town hall in Wisconsin, CNN’s Anderson Cooper asked Trump: “Do you trust Muslims in
America?” Trump responded: “Do I what?” Cooper again asked: “Trust Muslims in America?” Trump responded: “Many of
them I do. Many of them I do, and some, I guess, we don't. Some, I guess, we don't. We have a problem, and we can try and be
very politically correct and pretend we don't have a problem, but, Anderson, we have a major, major problem. This is, in a
sense, this is a war.”
May 20, 2016: On Fox News, Trump said this of Muslims: “They're going to have to turn in the people that are bombing the
planes. And they know who the people are. And we're not going to find the people by just continuing to be so nice and so soft.”
June 13, 2016: The day after the mass shooting at a gay nightclub in Orlando, Trump declared in a speech in New
Hampshire that “radical Islam is anti-woman, anti-gay and anti-American.” He criticized his Democratic rival, Hillary Clinton,
for refusing to use the term “radical Islam” and for speaking positively of Islam. “Hillary Clinton's catastrophic immigration
plan will bring vastly more radical Islamic immigration into this country, threatening not only our society but our entire way
of life. When it comes to radical Islamic terrorism, ignorance is not bliss. It's deadly — totally deadly,” Trump said. Later he
added: “I want every American to succeed, including Muslims — but the Muslims have to work with us. They have to work
with us. They know what's going on.”
June 14, 2016: At a rally in North Carolina, Trump noted that the Orlando shooter’s parents are Muslim Americans who
immigrated from Afghanistan. “The children of Muslim American parents, they’re responsible for a growing number for
whatever reason a growing number of terrorist attacks,” he said, adding that immigration from Afghanistan has increased
five-fold. “… Every year we bring in more than 100,000 lifetime immigrants from the Middle East and many more from
Muslim countries outside of the Middle East. A number of these immigrants have hostile attitudes.”
June 15, 2016: On Fox News, Trump said this of Muslims who immigrate to the United States: “Assimilation has been very
hard. It's almost — I won't say nonexistent, but it gets to be pretty close. And I'm talking about second and third generation.
They come — they don't — for some reason, there's no real assimilation.”
July 21, 2016: In accepting the Republican Party's presidential nomination, Trump focused heavily on “brutal Islamic
terrorism” and promised: “I will do everything in my power to protect our LGBTQ citizens from the violence and oppression of
a hateful foreign ideology.”
July 24, 2016: On NBC News, Trump defended his proposal for a Muslim ban, despite some of his aides insisting he had
rolled it back. “People were so upset when I used the word Muslim. ‘Oh, you can’t use the word Muslim,’ " Trump said. "… But
just remember this: Our Constitution is great, but it doesn’t necessarily give us the right to commit suicide, okay? Now, we
have a religious — you know, everybody wants to be protected. And that’s great. And that’s the wonderful part of our
Constitution. I view it differently. Why are we committing suicide? Why are we doing that?”
Aug. 11, 2016: At a meeting of evangelical leaders in Orlando, Trump said: “If you were a Christian in Syria, it was virtually
impossible to come into the United States. If you were a Muslim from Syria, it was one of the easier countries to be able to find
your way into the United States. Think of that. Just think of what that means.”

Aug. 18, 2016: During a rally in North Carolina, Trump said that “all applicants for immigration will be vetted for ties to
radical ideology, and we will screen out anyone who doesn't share our values and love our people.”
Sept. 19, 2016: At a rally in Florida, Trump reacted to explosions over the weekend in New York and New Jersey and
said: “There have been Islamic terrorist attacks in Minnesota and New York City and in New Jersey. These attacks and many
others were made possible because of our extremely open immigration system, which fails to properly vet and screen the
individuals and families coming into our country. Got to be careful.”
Jan. 27, 2017: Within a week of becoming president, Trump signed an executive order blocking Syrian refugees and banning
citizens of seven predominantly Muslim countries from entering the United States for 90 days. This order goes into effect
immediately, prompting mass chaos at airports, protests and legal challenges. Rudolph W. Giuliani, a close adviser to the
president, later said on Fox News: “So when [Trump] first announced it, he said, 'Muslim ban.' He called me up. He said, 'Put
a commission together. Show me the right way to do it legally.'”
Feb. 28, 2017: Despite urging from some of his Cabinet members, Trump continues to use the term “radical Islamic
terrorism,” including in a speech to a joint session of Congress.
March 6, 2017: Trump issues a new travel ban for citizens from six majority-Muslim countries, which is also challenged in
the courts.
April 29, 2017: At a rally celebrating his 100th day in office, Trump once again dramatically read “The Snake.”
May 17, 2017: At a commencement ceremony, Trump previewed his upcoming overseas trip and said: “I'll speak with
Muslim leaders and challenge them to fight hatred and extremism and embrace a peaceful future for their faith. And they're
looking very much forward to hearing what we, as your representative, we have to say. We have to stop radical Islamic
terrorism.”

Jenna Johnson is a political reporter who covers the White House. She spent more than a year writing about Donald
Trump's presidential campaign, traveling to 35 states to attend more than 170 political rallies and interview
hundreds of Trump supporters.  Follow @wpjenna
Abigail Hauslohner is a national reporter who covers Islam, Arab affairs and America. Before coming to Washington
in 2015, she spent seven years covering war, politics and religion in the Middle East, and served as the Post’s Cairo
bureau chief. She has also covered District politics and government.  Follow @ahauslohner

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