International Refugee Assistance Project et al v. Trump et al

Filing 5

MOTION for Other Relief for Leave to Proceed Under Pseudonyms by Jane Doe 1, John Doe1-4 (Attachments: # 1 Declarations of John Does 1-4 & Jane Doe 1, # 2 Declaration of Nicholas Espiritu & Exhibits A through V, # 3 Proposed Order)(Cox, Justin)

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MARYLAND
SOUTHERN DIVISION

INTERNATIONAL REFUGEE
ASSISTANCE PROJECT, a project of the
Urban Justice Center, Inc., on behalf of
itself and its clients; HIAS, Inc., on behalf
of itself and its clients; ALLAN HAKKY;
SAMANEH TAKALOO; JOHN DOES #
1-4; and JANE DOE #1,
Plaintiffs,
v.

Civil Action No.: 8:17-cv-00361-TDC

DECLARATION OF NICHOLAS
ESPÍRITU IN SUPPORT OF DOE
PLAINTIFFS’ MOTION FOR LEAVE TO
PROCEED UNDER PSEUDONYMS

DONALD TRUMP, President of the
United States; DEPARTMENT OF
HOMELAND SECURITY;
DEPARTMENT OF STATE; OFFICE OF
THE DIRECTOR OF NATIONAL
INTELLIGENCE; JOHN KELLY,
Secretary of Homeland Security; REX
TILLERSON, Secretary of State; and
MICHAEL DEMPSEY, Acting Director
National Intelligence.
Defendants.
DECLARATION OF NICHOLAS ESPÍRITU
I, Nicholas Espíritu, upon my personal knowledge, hereby submit this declaration
pursuant to 28 U.S.C. § 1746 and declare as follows:
1.

I am an attorney with the National Immigration Law Center (NILC), and

counsel of record for Plaintiffs in this action. I am licensed in the State of California and have a
forthcoming pro hac vice application to practice before this Court. I make this declaration based
on my personal knowledge (except where expressly noted herein) and, if called upon as a witness,
I could and would testify competently as to the matters set forth below.
1

2.

Attached as Exhibit A is a true and correct copy of the Order Granting

Motion to Proceed Under Pseudonyms issued in Hispanic Interest Coalition of Alabama v. Bentley,
No. 11-2484 (N.D. Ala. filed Aug. 12, 2011).
3.

Attached as Exhibit B is a true and correct copy of the Order Granting

Motion to Proceed Anonymously issued in Friendly House v. Whiting, No. 10-1061 (D. Ariz. filed
June 21, 2010).
4.

On February 5, 2017, I visited the website of the Pew Research Center and

downloaded a copy of the report, “Anti-Muslim assaults reach 9/11-era levels, FBI data show,”
available at http://www.pewresearch.org/fact-tank/2016/11/21/anti-muslim-assaults-reach-911era-levels-fbi-data-show. A true and correct copy of this report is attached as Exhibit C.
5.

On February 5, 2017, I visited the New York Times website and

downloaded a copy of an article, written by Eric Lichtblau and titled, “Hate Crimes Against
American

Muslims

Most

Since

Post-9/11

Era,”

available

at

https://www.nytimes.com/2016/09/18/us/politics/hate-crimes-american-muslims-rise.html?_r=0.
The article was published on the New York Times website on September 17, 2016. A true and
correct copy of this article is attached to this declaration as Exhibit D.
6.

On February 5, 2017, I visited the New York Times website and

downloaded a copy of an article, written by Patrick Healy and Michael Barbaro titled, “Donald
Trump

Calls

for

Barring

Muslims

From

Entering

U.S.,”

available

at

https://www.nytimes.com/politics/first-draft/2015/12/07/donald-trump-calls-for-banningmuslims-from-entering-u-s/. The article was published on the New York Times website on
December 7, 2015. A true and correct copy of this article is attached to this declaration as Exhibit
E.

2

7.

On February 5, 2017, I visited the Slate Magazine website and downloaded

a copy of an article, written by Isaac Chotiner and titled, “Donald Trump and the Spike in AntiMuslim

Hate

Crimes

in

the

U.S..,”

available

at

http://www.slate.com/blogs/the_slatest/2016/05/09/donald_trump_and_the_rise_of_anti_muslim
hate crimes.html. The article was published on the Slate Magazine website on May 9, 2016. A
true and correct copy of this article is attached to this declaration as Exhibit F.
8.

On February 5, 2017, I visited the San Jose Mercury News website and

downloaded a copy of an article, written by Jason Green and titled, “Hijab-wearing woman
describes San Jose State attack,” available at http://www.mercurynews.com/2016/11/09/womanwearing-hijab-attacked-at-san-jose-state/. The article was published on the San Jose Mercury
News website on November 11, 2016. A true and correct copy of this article is attached to this
declaration as Exhibit G.
9.

On February 5, 2017, I visited the San Diego Tribune website and

downloaded a copy of an article, written by Kate Morrissey and titled, “Post-election note to El
Cajon business: ‘BE PREPARED TO GO BACK TO YOUR COUNTRY WITH ISIS,’” available
at

http://www.sandiegouniontribune.com/news/immigration/sd-me-hate-incidents-20161130-

story.html. The article was published on the San Diego Tribune website on November 30, 2016.
A true and correct copy of this article is attached to this declaration as Exhibit H.
10.

On February 5, 2017, I visited the Washington Post website and

downloaded a copy of an article, written by Kristine Guerra and titled, “A Muslim teacher receives
an anonymous note about her headscarf: ‘Hang yourself with it,’” available at
https://www.washingtonpost.com/news/post-nation/wp/2016/11/12/a-muslim-teacher-receivesan-anonymous-note-about-her-headscarf-hang-yourself-with-

3

it/?postshare=2351478980457522&tid=ss_tw&utm_term=.c64ede6913ad.

The article was

published on the Washington Post website on November 12, 2016. A true and correct copy of this
article is attached to this declaration as Exhibit I.
11.

On February 5, 2017, I visited the Washington Post website and

downloaded a copy of an article, written by Samantha Schmidt and titled, “She became the nation’s
first Somali American lawmaker. A month later, she was harassed in a D.C. cab for being
Muslim,’” available at https://www.washingtonpost.com/news/morning-mix/wp/2016/12/08/shebecame-the-nations-first-somali-american-lawmaker-a-month-later-she-was-harassed-in-a-d-ccab-for-being-muslim/?utm_term=.1e364c7bb134. The article was published on the Washington
Post website on December 8, 2016. A true and correct copy of this article is attached to this
declaration as Exhibit J.
12.

On February 5, 2017, I visited the website of the Southern Poverty Law

Center and downloaded a copy of the report, “Update: More Than 400 Incidents of Hateful
Harassment

and

Intimidation

Since

the

Election,”

available

at

https://www.splcenter.org/hatewatch/2016/11/15/update-more-400-incidents-hateful-harassmentand-intimidation-election. A true and correct copy of this report is attached as Exhibit K.
13.

On February 5, 2017, I visited the Washington Post website and

downloaded a copy of an article, written by Samantha Schmidt and titled, “Man shoves Muslim
New York City transit worker on stairs, shouting ‘You’re a terrorist,’” available at
https://www.washingtonpost.com/news/morning-mix/wp/2016/12/06/man-shoves-muslim-newyork-city-transit-worker-down-stairs-shouting-youre-aterrorist/?tid=a_inl&utm_term=.f64a4719ca5c. The article was published on the Washington Post

4

website on December 6, 2016. A true and correct copy of this article is attached to this declaration
as Exhibit L.
14.

On February 5, 2017, I visited the official website of the Governor of New

York and downloaded a copy of the statement of December 5, 2016, identified on the website as
“Statement from Governor Andrew M. Cuomo on New York City Hate Crimes,” available at
https://www.governor.ny.gov/news/statement-governor-andrew-m-cuomo-new-york-city-hatecrimes. A true and correct copy of this recommendation is attached as Exhibit M.
15.

On February 5, 2017, I visited the Washington Post website and

downloaded a copy of an article, written by Sarah Larimer and titled, “‘We can’t allow this’: Man
accused

of

threatening

to

slit

throat

of

Muslim

NYPD

officer,”

available

at

https://www.washingtonpost.com/news/post-nation/wp/2016/12/05/we-cant-allow-this-manaccused-of-threatening-to-slit-throat-of-muslim-nypd-officer/?hpid=hp_no-name_hp-in-thenews%3Apage%2Fin-the-news&tid=a inl&utm term=.442723af6730. The article was published
on the Washington Post website on December 5, 2016. A true and correct copy of this article is
attached to this declaration as Exhibit N.
16.

On February 5, 2017, I visited the Los Angeles Times website and

downloaded a copy of an article, written by Matt Stevens and Matt Hamilton and titled, “Man stabs
worshiper near Simi Valley mosque in hate crime, police allege,” available at
http://www.latimes.com/local/lanow/la-me-ln-simi-valley-mosque-stabbing-20161211story.html. The article was published on the Los Angeles Times website on December 12, 2016.
A true and correct copy of this article is attached to this declaration as Exhibit O.
17.

On February 5, 2017, I visited the KSWO website and downloaded a copy

of an article, written by Rhiannon Poolaw and titled, “Lawton Islamic Center falls victim to

5

potential hate crime,” available at http://www.kswo.com/story/34010579/lawton-islamic-centerfalls-victim-to-potential-hate-crime.

The article was published on the KSWO website on

December 8, 2016. A true and correct copy of this article is attached to this declaration as Exhibit
P.
18.

On February 5, 2017, I visited the CNN website and downloaded a copy of

an article, written by Tony Marco and titled, “Police: Mosque outside Seattle torched,” available
at http://www.cnn.com/2017/01/15/us/washington-mosque-arson/. The article was published on
the CNN website on January 15, 2017. A true and correct copy of this article is attached to this
declaration as Exhibit Q.
19.

On February 5, 2017, I visited the Fusion website and downloaded a copy

of an article, written by Nidhi Prakash and titled, “A Muslim organizer of the Women’s March is
under attack from Islamophobic trolls,” available at http://fusion.net/story/382460/linda-sarsourwomens-march-islamophobic-attacks/. The article was published on the Fusion website on
January 23, 2017. A true and correct copy of this article is attached to this declaration as Exhibit
R.
20.

On February 5, 2017, I visited the Fox News website and downloaded a

copy of an article titled, “Attacks target Muslim-American activist after DC march,” available at
http://www.foxnews.com/us/2017/01/26/attacks-target-muslim-american-activist-after-dcmarch.html. The article was published on the Fox News website on January 26, 2017. A true and
correct copy of this article is attached to this declaration as Exhibit S.
21.

On February 5, 2017, I visited the Texas Tribune website and downloaded

a copy of an article, written by Sanya Mansoor and titled, “Two Texas mosques burned to the
ground this month,” available at https://www.texastribune.org/2017/01/30/two-texas-mosques-

6

burned-ground-january. The article was published on the Texas Tribune website on January 30,
2017. A true and correct copy of this article is attached to this declaration as Exhibit T.
22.

On February 5, 2017, I visited the website of the Southern Poverty Law

Center and downloaded the report by Ryan Lenz titled, “Daily Stormer Targets Federal Judges
Ruling

Against

Trump's

Muslim

Ban,”

available

at

https://www.splcenter.org/hatewatch/2017/02/01/daily-stormer-targets-federal-judges-rulingagainst-trumps-muslim-ban. The article was published on the Southern Poverty Law Center
website on February 1, 2017. A true and correct copy of this article is attached to this declaration
as Exhibit U.
23.

On February 7, 2017, , I visited the CNN website and downloaded a copy

of the editorial, written by Dean Obeidallah titled, “Donald Trump's most bone-chilling tweet,”
available at http://www.cnn.com/2017/02/04/opinions/donald-trumps-most-bone-chilling-tweetobeidallah-opinion/. The editorial was published on the CNN website on February 6, 2017. A true
and correct copy of this article is attached to this declaration as Exhibit V.

I declare under penalty of perjury and under the laws of the United States that the foregoing is true
and correct. Executed at Los Angeles, California on February 6, 2017.

Nicholas Espíritu
NATIONAL IMMIGRATION LAW CENTER
3435 Wilshire Boulevard, Suite 1600
Los Angeles, CA 90010
[phone]
[e-mail]

7

Index of Exhibits
Ex. A

Order Granting Motion to Proceed Under Pseudonyms issued in Hispanic Interest
Coalition of Alabama v. Bentley, No. 11-2484 (N.D. Ala. filed Aug. 12, 2011).

Ex. B

Order Granting Motion to Proceed Anonymously, Friendly House v. Whiting, No.
10-1061 (D. Ariz. filed June 21, 2010).

Ex. C

Pew Research Center, Anti-Muslim assaults reach 9/11-era levels, FBI data show.

Ex. D

Eric Lichtblau, Hate Crimes Against American Muslims Most Since Post-9/11 Era,
New York Times, September 17, 2016.

Ex. E

Patrick Healy and Michael Barbaro, Donald Trump Calls for Barring Muslims
From Entering U.S., New York Times, December 7, 2015.

Ex. F

Isaac Chotiner, Donald Trump and the Spike in Anti-Muslim Hate Crimes in the
U.S., Slate Magazine, May 9, 2016.

Ex. G

Jason Green, Hijab-wearing woman describes San Jose State attack, San Jose
Mercury News, November 11, 2016.

Ex. H

Kate Morrissey, Post-election note to El Cajon business: ‘BE PREPARED TO GO
BACK TO YOUR COUNTRY WITH ISIS’, San Diego Tribune, November 30,
2016.

Ex. I

Kristine Guerra, A Muslim teacher receives an anonymous note about her
headscarf: ‘Hang yourself with it’, Washington Post, November 12, 2016.

Ex. J

Southern Poverty Law Center, Update: More Than 400 Incidents of Hateful
Harassment and Intimidation Since the Election.

Ex. K

Samantha Schmidt, She became the nation’s first Somali American lawmaker. A
month later, she was harassed in a D.C. cab for being Muslim, Washington Post,
December 8, 2016.

Ex. L

Samantha Schmidt, Man shoves Muslim New York City transit worker on stairs,
shouting ‘You’re a terrorist’, Washington Post, December 6, 2016.

Ex. M

Governor Andrew M. Cuomo, Statement from Governor Andrew M. Cuomo on
New York City Hate Crimes Garden (December 5, 2016).

Ex. N

Sarah Larimer, ‘We can’t allow this’: Man accused of threatening to slit throat of
Muslim NYPD officer, Washington Post, December 5, 2016.

8

Ex. O

Matt Stevens and Matt Hamilton, Man stabs worshiper near Simi Valley mosque in
hate crime, police allege, Los Angeles Times, December 12, 2016.

Ex. P

Rhiannon Poolaw, Lawton Islamic Center falls victim to potential hate crime,
KSWO, December 8, 2016.

Ex. Q

Tony Marco, Police: Mosque outside Seattle torched, CNN, January 15, 2017.

Ex. R

Nidhi Prakash, A Muslim organizer of the Women’s March is under attack from
Islamophobic trolls, Fusion, January 23, 2017.

Ex. S

Attacks target Muslim-American activist after DC march, Fox News, January 26,
2017.

Ex. T

Sanya Mansoor, Two Texas mosques burned to the ground this month, Texas
Tribune, January 30, 2017.

Ex. U

Ryan Lenz, Daily Stormer Targets Federal Judges Ruling Against Trump's Muslim
Ban, Southern Poverty Law Center, February 1, 2017.

Ex. V

Dean Obeidallah, Donald Trump's most bone-chilling tweet, CNN, February 6,
2017.

9

EXHIBIT A

FILED

2011 Aug-12 PM 03:06
U.S. DISTRICT COURT
N.D. OF ALABAMA

UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ALABAMA
NORTHEASTERN DIVISION
HISPANIC INTEREST COALITION OF )
ALABAMA; et al.,
)
)
Plaintiffs,
)
)
vs.
)
)
ROBERT BENTLEY, in his official )
capacity as Governor of the State of )
Alabama; et al.,
)
)
Defendants.
)

Case Number: 5:11-CV-2484-SLB

RT. REV. HENRY N. PARSLEY, JR., in
his official capacity as Bishop of the
Episcopal Church in the Diocese of
Alabama, et al.,

)
)
)
)
)
Plaintiffs,
)
)
vs.
)
)
ROBERT BENTLEY, in his official )
capacity as Governor of the State of )
Alabama,
)
)
Defendants.
)
)
)
Plaintiff
)
)
vs.
)
)
STATE OF ALABAMA; GOVERNOR )
ROBERT J. BENTLEY,
)
)
Defendants.
)

Case Number: 5:11-CV-2736-CLS

UNITED STATES OF AMERICA,

Case Number: 2:11-CV-2746-LSC

ORDER
This case is presently pending before the court on the Doe plaintiffs’ Motion for
Leave to Proceed under Pseudonyms. (Doc. 2.)1 Plaintiffs contend, “All twelve Doe
Plaintiffs should be permitted to pursue this litigation under pseudonyms. . . . [I]f the Doe
Plaintiffs’ identities and participation in this lawsuit were to become public, there would be
an increased risk that they or their family members would be subjected to unconstitutional
detention by the police, the initiation of removal proceedings or other adverse immigration
consequences, and public hostility, harassment, and even violence.” (Id. at 1-2.) Defendants
oppose this Motion. (Doc. 46.)
The court notes the following standard governs its determination:
In this Circuit, Federal Rule of Civil Procedure 10(a) requires that
“every pleading” in federal court “must name all the parties.” Fed. R. Civ. P.
10(a) (2010). “This rule serves more than administrative convenience. It
protects the public’s legitimate interest in knowing all of the facts involved,
including the identities of the parties.” [Doe v.] Frank, 951 F.2d [320,] 322
[(11th Cir. 1992)] (citing Doe v. Rostker, 89 F.R.D. 158, 160 (N.D. Cal. 1981)
and Doe v. Deschamps, 64 F.R.D. 652, 653 (D. Mont. 1974)). This creates a
strong presumption in favor of parties’ proceeding in their own names.
Defendants have the right to know who their accusers are, as they may be
subject to embarrassment or fundamental unfairness if they do not. See Doe
v. Smith, 429 F.3d 706, 710 (7th Cir. 2005)(“[The plaintiff] has denied [the
defendant] the shelter of anonymity yet it is [the defendant], and not the
plaintiff, who faces disgrace if the complaint's allegations can be substantiated.
And if the complaint's allegations are false, then anonymity provides a shield
behind which defamatory charges may be launched without shame or
liability.”).

1

Reference to a document number, [“Doc. ___”], refers to the number assigned to each
document as it is filed in the court’s record in the first-filed case, Hispanic Interest Coalition
of Alabama v. Bentley, 5:11-CV-2484-SLB.
2

Nonetheless, the rule is not absolute. A party may proceed
anonymously in a civil suit in federal court by showing that he “has a
substantial privacy right which outweighs the ‘customary and
constitutionally-embedded presumption of openness in judicial proceedings.’”
Frank, 951 F.2d at 323 (quoting [Doe v.] Stegall, 653 F.2d [180,] 186 [(5th
Cir. Unit A Aug. 1981)]. In evaluating whether a plaintiff has shown that he
has such a right, the court “should carefully review all the circumstances of a
given case and then decide whether the customary practice of disclosing the
plaintiff's identity should yield to the plaintiff's privacy concerns.” Id. (citing
S. Methodist Univ. Ass'n of Women Law Students v. Wynne & Jaffe, 599 F.2d
707, 713 (5th Cir. 1979) [hereinafter, SMU]).
The first step in analyzing a plaintiff’s claim of a substantial privacy
right is to look at the three factors analyzed in SMU. See Stegall, 653 F.2d at
185 (restating the test). First, are the plaintiffs seeking anonymity challenging
governmental activity? Second, will they be required to disclose information
of the utmost intimacy? Third, will the plaintiffs be compelled to admit their
intention to engage in illegal conduct and thus risk criminal prosecution?
...
After the Stegall court clarified that the three-part SMU test was only
the first step for evaluating whether to let a plaintiff proceed to trial
anonymously, courts have considered other contexts in analyzing all the
circumstances of a given case. Courts have looked at factors such as whether
the plaintiffs were minors, Stegall, 653 F.2d at 186, whether they were
threatened with violence or physical harm by proceeding in their own names,
id., and whether their anonymity posed a unique threat of fundamental
unfairness to the defendant. See SMU, 599 F.2d at 713.
Plaintiff B v. Francis, 631 F.3d 1310, 1315-16 (11th Cir. 2011). “Lawsuits are public events.
A plaintiff should be permitted to proceed anonymously only in those exceptional cases
involving matters of a highly sensitive and personal nature, real danger of physical harm, or
where the injury litigated against would be incurred as a result of the disclosure of the
plaintiff's identity.” Frank, 951 F.2d 324.

3

Plaintiffs raise three grounds for allowing the Doe plaintiffs to proceed anonymously:
First, public disclosure of the Doe Plaintiffs’ identities and participation
in this action would seriously jeopardize the very constitutional protections
that they and the other plaintiffs seek to vindicate in this lawsuit. The Doe
Plaintiffs reasonably fear that, if their identities were to become public, there
would be an increased risk that they or their family members would be
subjected to unconstitutional detention by state or local law enforcement
officials acting under the auspices of HB 56. They also fear that they or their
family members could suffer adverse immigration consequences, including
immigration detention, the initiation of removal proceedings, and removal
from the United States.
Second, the issue of immigration in general and HB 56 in particular
have been the subject of intense and heated debate in Alabama. In this highly
charged atmosphere, the Doe Plaintiffs fear harassment, retaliation, and even
physical harm if their identities and personal stories are disclosed publicly.
Third, this case turns on legal questions, not on the identities of any
particular individuals. Thus, the public’s interest in open judicial proceedings
will not be affected if the Doe Plaintiffs are permitted to proceed
anonymously.
Finally, Defendants will not suffer any prejudice if the Doe Plaintiffs
are permitted to proceed anonymously, because this case turns solely on the
constitutionality of HB 56.
(Doc. 2-1 at 1-2.)
The court notes that the Doe plaintiffs and/or their family members are aliens; some
are unlawfully in the country. They are challenging governmental activity, specifically HB
56. Some allege threats and harassment based on their ethnicity and national origin.
Defendants concede “there is . . . a sufficient amount of material to indicate a hostility to
illegal immigrants.” (Doc. 46 at 16.) The court finds sufficient evidence of a genuine threat
of harassment and violence to the Doe plaintiffs and/or their families should their identities

4

be revealed publicly.

The court finds that these facts outweigh the customary and

constitutionally-embedded presumption of openness in judicial proceedings.
Defendants contend that they must “know the identities of the Doe Plaintiffs so that
[they] may test matters such as standing, conduct any appropriate discovery, [and] crossexamine [plaintiffs’] evidence.” (Doc. 46 at 2.) The court finds that any prejudice to
defendants may be remedied by limited disclosure and protective orders. Therefore, the court
finds that unfair prejudice to defendants is not a sufficient reason to deny plaintiffs the right
to proceed anonymously in light of other circumstances.
Upon consideration of the record, the submissions of the parties, and the relevant law,
the Doe plaintiffs’ Motion for Leave to Proceed under Pseudonyms, (doc. 2), is GRANTED.

5

EXHIBIT B

MINUTES OF THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF ARIZONA
Friendly House, et al. v. Whiting, et al.
THE HONORABLE JOHN W. SEDWICK
PROCEEDINGS:

2:10-cv-1061 JWS

ORDER FROM CHAMBERS

June 21, 2010

At docket 3, plaintiffs John Doe #1, Jane Doe #1 and Jane Doe #2 ask to
proceed under pseudonyms. No response has been filed, but not all defendants have
been served, and there are motions to intervene not yet decided. Nevertheless, given
the number of parties, the number of motions already filed, the potential for a torrent of
motions in the future, the nature of the motion, and the context of this litigation, the
court deems it desirable to address the motion now.
John Doe #1 received political asylum as a result of persecution for opposing the
policies of the Chinese government. This is disclosed in the complaint. He works in a
Chinese restaurant and associates closely with others of Chinese ancestry. He fears
that if his identity is disclosed, his opposition to the policies would become known
resulting in loss of his job and exposure to harassment by other members of his
community who support the policies of the Chinese government. Jane Doe #1 is from
South Asia and is currently seeking asylum on grounds of religious persecution, facts
set out in the complaint. She was subjected to degrading treatment in South Asia and
fears disclosure of her identity would result in disclosure of her experiences in South
Asia to her detriment including abuse from her husband who has abused her in the
past. Jane Doe #2 is a family abuse victim living in transitional housing who fears,
among other things, that disclosure of her identity in this lawsuit would result in physical
abuse by persons who have abused her in the past.
According to the Ninth Circuit a trial court evaluating whether a party may
proceed anonymously should consider five factors: (1) severity of threatened harm;
(2) reasonableness of fearing harm; (3) vulnerability to retaliation; (4) prejudice to
opposing parties; and (5) the public interest. Doe v. Kamehameha Schools/Bernice
Pauahi Bishop Estate, 596 F.3d 1036, 1042 (9th Cir. 2010). Here the threatened harm

includes loss of employment and physical abuse; both are serious. The circumstances
disclosed in the supporting declarations show it is reasonable to fear the harm
threatened. Each of the Doe plaintiffs is in a vulnerable position. In a case involving a
score of named plaintiffs as well as three unnamed plaintiffs which does not seek
damages for specific plaintiffs but only common declaratory and injunctive relief, the
prejudice to defendants of allowing three individuals to proceed anonymously appears
insignificant, at least until such point as it might be determined that none of the named
parties has standing. Finally, while the public interest always weighs in favor of public
disclosure of litigant identities, it weighs less heavily here than in many cases because
of the large number of named plaintiffs and the fact that the nature of the unnamed
plaintiffs’ interest in the litigation is discernible without knowing their identities.
The Ninth Circuit has said that striking an appropriate balance between a party’s
need to proceed anonymously and the strong interest in completely open judicial
proceedings may change during the course of litigation. Does I Thru XXIII v. Advanced
Textile Corp., 214 F.3d 1058, 1069 (9th Cir. 2000). At this very early stage, the court
finds the balance of relevant factors favors allowing the Doe plaintiffs to proceed
anonymously. If circumstances change any party may seek disclosure of the identities,
at which time the court might require the Doe plaintiffs to choose between continued
participation in the lawsuit and disclosure of their identities.
The motion at docket 3 is GRANTED as follows: Pending any further order which
might require choosing between proceeding as an identified party and being dismissed,
John Doe #1, Jane Doe #1, and Jane Doe #2 may proceed anonymously.
________________

EXHIBIT C

Overall, the FBI reported 257 incidents of anti-Muslim hate crimes in 2015, a 67% increase from the
previous year. These incidents included 301 individual crimes, 71% of which were crimes against people, as
opposed to property. (Incidents can encompass more than one crime.) By contrast, crimes perpetrated
against other religious groups more often involved property offenses, such as vandalism or theft. For
example, 64% of anti-Jewish and 51% of anti-Catholic offenses in 2015 involved vandalism, compared with
just 23% of anti-Muslim offenses.
Most Americans say there is “a lot” of discrimination against Muslims in the United States today – roughly
six-in-ten U.S. adults (59%) said this in a January 2016 Pew Research Center survey
(http://www.pewforum.org/2016/02/03/republicans-prefer-blunt-talk-about-islamic-extremism-democrats-favorcaution/#views-of-discrimination-against-muslims-in-the-u-s) . About three-quarters of Americans (76%) also

said discrimination against Muslims in the U.S. was increasing.
The same survey found that almost half of American adults (49%) think at least “some” Muslims in the
U.S. are anti-American, including 11% who think “most” or “almost all” are anti-American. Another
survey from about the same time (http://www.people-press.org/2015/12/15/views-of-governments-handling-ofterrorism-fall-to-post-911-low/#perceptions-of-islam-and-violence) (December 2015) found that 46% of

Americans thought Islam was more likely than other religions to encourage violence.
FBI data for 2016 will not be released until next year, but there have been anecdotal reports of a continued
rise in anti-Muslim hate crimes this year. While not all incidents can be confirmed
(http://www.nbcnews.com/news/us-news/hundreds-hate-crimes-reported-election-splc-n683761) , the Southern

Poverty Law Center (https://www.splcenter.org/hatewatch/2016/11/15/update-more-400-incidents-hatefulharassment-and-intimidation-election) , a civil rights advocacy group that tracks hate crimes, reported more

than 30 cases (https://www.splcenter.org/hatewatch/2016/11/15/update-more-400-incidents-hateful-harassmentand-intimidation-election) of anti-Muslim incidents in the five days following the presidential election alone.

The FBI collects hate crime data from about 15,000 law enforcement agencies that voluntarily participate,
which means the annual statistics likely undercount the number of hate crimes in a given year. Still, the
report is a useful tool for comparing hate crimes over time and tracking the minimum number of these
crimes that occurred in a given year.

EXHIBIT D

https://nyti.ms/2cOyV19

Hate Crimes Against American Muslims
Most Since Post-9/11 Era
By ERIC LICHTBLAU

SEPT. 17, 2016

WASHINGTON — Hate crimes against American Muslims have soared to their
highest levels since the aftermath of the Sept. 11, 2001 attacks, according to data
compiled by researchers, an increase apparently fueled by terrorist attacks in the
United States and abroad and by divisive language on the campaign trail.
The trend has alarmed hate crime scholars and law-enforcement officials, who
have documented hundreds of attacks — including arsons at mosques, assaults,
shootings and threats of violence — since the beginning of 2015.
While the most current hate crime statistics from the F.B.I. are not expected
until November, new data from researchers at California State University, San
Bernardino, found that hate crimes against American Muslims were up 78 percent
over the course of 2015. Attacks on those perceived as Arab rose even more
sharply.
Police and news media reports in recent months have indicated a continued
flow of attacks, often against victims wearing traditional Muslim garb or seen as
Middle Eastern.
Some scholars believe that the violent backlash against American Muslims is

driven not only by the string of terrorist attacks in Europe and the United States
that began early last year, but also by the political vitriol from candidates like
Donald J. Trump, who has called for a ban on immigration by Muslims and a
national registry of Muslims in the United States.
“We’re seeing these stereotypes and derogative statements become part of the
political discourse,” said Brian Levin, the director of the Center for the Study of
Hate and Extremism at the San Bernardino campus. “The bottom line is we’re
talking about a significant increase in these types of hate crimes.”
He said that the frequency of anti-Muslim violence appeared to have increased
immediately after some of Mr. Trump’s most incendiary comments.
The latest major episode of anti-Muslim violence came last weekend, when an
arsonist on a motorcycle started a fire that engulfed the Islamic Center of Fort
Pierce, Fla., where Omar Mateen — the gunman in the June massacre at the Pulse
nightclub in Orlando — had sometimes prayed.
The police, who called the attack “a terrible tragedy” for the community,
arrested a local man who had criticized Islam in social media postings.
The arson, along with an earlier assault on a congregant outside the mosque
and other episodes there, has left worshipers scared, said Mohammed Malik, 43, a
businessman who has attended the mosque for nearly a decade.
“There is a lot of negative rhetoric,” he said. “The negative rhetoric is causing
the hate, and in turn the hate is causing the violent acts.”
The new study from Mr. Levin’s nonpartisan group, based on official police
reports in 20 states, estimated that there were about 260 hate crimes against
Muslims nationwide in 2015.
That was the most since the record 481 documented hate crimes against
Muslims in 2001, when the Sept. 11 attacks set off waves of crimes targeting
Muslims and Middle Easterners, Mr. Levin said. The huge increase last year was

also the biggest annual rise since 2001, he said.
The rise came even as hate crimes against almost all other groups — including
blacks, Hispanics, Jews, gays and whites — either declined or increased only
slightly, his study found. One exception was hate crimes against transgender
people, which rose about 40 percent.
An advance copy of the study was provided to The New York Times.
The statistics almost certainly understate the extent of the problem,
researchers say, because victims are often reluctant to report attacks for fear of
inflaming community tensions, and because it is sometimes difficult for
investigators to establish that religious, ethnic or racial hatred was a cause.
In the killing last year of three Muslim students in Chapel Hill, N.C., for
instance, the authorities did not bring hate crime charges against a neighbor who is
charged with murdering them, despite calls from Muslims who said there were
religious overtones to the violence. The police said that a parking dispute, not
bigotry, may have led to the killings.
Sometimes, the evidence is more clear-cut.
“I hate ISLAM!” a former Marine named Ted Hakey Jr. wrote to a friend on
Facebook after last November’s terrorist attacks in Paris. Hours later, in a drunken
rampage, he fired a high-powered rifle four times into the mosque next door to his
Connecticut home.
Last month, an apologetic Mr. Hakey began a six-month prison sentence after
pleading guilty to a hate crime charge.
In Brooklyn, two women out walking their children in strollers were attacked
this month, the police said, by a woman who screamed anti-Muslim obscenities
and tried to rip off their traditional veils. And in Queens, a man was beaten in April
by three strangers who shouted “ISIS, ISIS.”
In Minneapolis, a man shouting obscenities about Islam shot two Muslim men

in traditional religious garb in June, the authorities said.
In St. Louis, a man was arrested in February after the police said he pointed a
gun at a Muslim family shopping on his block and told them they “all should die.”
Last month, an imam in Queens and his assistant were shot and killed
execution-style on the sidewalk. The authorities have charged a 35-year-old man in
the attack but have not determined a motive or whether it should be treated as a
hate crime.
The increase in reports of apparent hate crimes has worried Justice
Department officials.
“We saw it after 9/11, and we continue to see an uptick in allegations of haterelated incidents today following the tragic events over the past year,” said Vanita
Gupta, who leads the Justice Department’s civil rights division.
“We see criminal threats against mosques; harassment in schools; and reports
of violence targeting Muslim-Americans, Sikhs, people of Arab or South-Asian
descent and people perceived to be members of these groups,” Ms. Gupta said.
The Justice Department has moved to draw public attention to the problem
and marshal resources to combat it as part of a broader effort against religious
discrimination.
A number of experts in hate crimes said they were concerned that Mr. Trump’s
vitriol may have legitimized threatening or even violent conduct by a small fringe
of his supporters.
In a few cases, people accused of hate crimes against Muslims and others have
even cited Mr. Trump.
The police here in Washington released a videotape in May of a woman who
reportedly poured liquid on a Muslim woman after berating Islam and declaring
that she was going to vote for Mr. Trump so that he could “send you all back where
you came from.”

On Thursday, Hillary Clinton charged that Mr. Trump had “incited violence”
in a campaign marked by “bigotry” and “hatred.”
Mr. Trump’s supporters say that he has never endorsed violence against any
minorities, and some conservatives have challenged data showing an increase in
violence against American Muslims as a creation of liberal-leaning researchers.
Mr. Trump has said he is not responsible for any violence by his supporters.
“They’re not angry about something I’m saying,” he said on “Meet the Press” in
March. “I’m just a messenger. The people are angry about the fact that, for 12
years, the workers in this country haven’t had a pay increase.”
James Nolan, a former F.B.I. crime analyst who teaches about hate crimes at
West Virginia University, said that the data seemed to show “a real spike” in hate
crimes against American Muslims, caused in part by candidates’ “raising the
specter that radical Islam is at our doorstep.”
Mark Potok, a senior fellow at the Southern Poverty Law Center, which
monitors hate groups and extremism, went further.
“I don’t have the slightest doubt that Trump’s campaign rhetoric has played a
big part” in the rising attacks, he said.
Adam Goldman contributed reporting.
Follow The New York Times’s politics and Washington coverage on Facebook and
Twitter, and sign up for the First Draft politics newsletter.
A version of this article appears in print on September 18, 2016, on Page A13 of the New York edition with
the headline: Level of Hate Crimes Against U.S. Muslims Highest Since After 9/11.

© 2017 The New York Times Company

EXHIBIT E

Donald Trump Calls for Barring
Muslims From Entering U.S.
4:36 pm ET
Patrick Healy and Michael Barbaro

Updated, 10:42 p.m. | Donald J. Trump called on Monday for the United
States to bar all Muslims from entering the country until the nation’s leaders can
“figure out what is going on” after the terrorist attacks in San Bernardino, Calif., an
extraordinary escalation of rhetoric aimed at voters’ fears about members of the

Islamic faith.
A prohibition of Muslims – an unprecedented proposal by a leading American
presidential candidate, and an idea more typically associated with hate groups –
reflects a progression of mistrust that is rooted in ideology as much as politics.
Mr. Trump, who in September declared “I love the Muslims,” turned sharply
against them after the Paris terrorist attacks, calling for a database to track
Muslims in America and repeating discredited rumors that thousands of Muslims
celebrated in New Jersey on 9/11. His poll numbers rose largely as a result, until a
setback in Iowa on Monday morning. Hours later Mr. Trump called for the ban,
fitting his pattern of making stunning comments when his lead in the Republican
presidential field appears in jeopardy.
Saying that “hatred” among many Muslims for Americans is “beyond
comprehension,” Mr. Trump said in a statement that the United States needed to
confront “where this hatred comes from and why.”
“Until we are able to determine and understand this problem and the
dangerous threat it poses, our country cannot be the victims of horrendous attacks
by people that believe only in jihad, and have no sense of reason or respect for
human life,” Mr. Trump said.
Asked what prompted his statement, Mr. Trump said, “death,” according to a
spokeswoman.
Repudiation of Mr. Trump’s remarks was swift and severe among religious
groups and politicians from both parties. Mr. Trump is “unhinged,” said one
Republican rival, former Gov. Jeb Bush of Florida, while another, Senator Marco
Rubio of Florida, called the ban “offensive and outlandish.” Hillary Clinton said the
idea was “reprehensible, prejudiced and divisive.” Organizations representing
Jews, Christians and those of other faiths quickly joined Muslims in denouncing
Mr. Trump’s proposal.
“Rooting our nation’s immigration policy in religious bigotry and

discrimination will not make America great again,” said Rabbi Jack Moline,
executive director of Interfaith Alliance, putting a twist on Mr. Trump’s campaign
slogan.
Mr. Trump made his remarks a day after President Obama delivered a
national address from the Oval Office urging Americans not to turn against
Muslims in the wake of the terrorist attacks.
Experts on immigration law and policy expressed shock at the proposal
Monday afternoon.
“This is just so antithetical to the history of the United States,” said Nancy
Morawetz, a professor of clinical law at New York University School of Law, who
specializes in immigration. “It’s unbelievable to have a religious test for admission
into the country.”
She added: “I cannot recall any historical precedent for denying immigration
based on religion.”
Putting the policy into practice would require an unlikely act of Congress, said
Stephen Yale-Loehr, a professor of law at Cornell and a prominent authority on
immigration.
Should Congress enact such a law, he predicted, the Supreme Court would
invalidate it as an overly restrictive immigration policy under the equal protection
clause of the 14th Amendment.
“It would certainly be challenged as unconstitutional,” he said. “And I predict
the Supreme Court would strike it down.”
Mr. Trump has a track record of making surprising and even extreme
comments whenever he is overtaken in opinion polls by other Republican
candidates – as happened on Monday just hours before he issued his statement
about Muslims. A new Monmouth University survey of likely Iowa Republican
caucus-goers found that Mr. Trump had slipped from his recent top spot in the

state, which holds the first presidential nomination contest on Feb. 1. According to
the poll, Senator Ted Cruz of Texas earned 24 percent of support, while Mr. Trump
had 19 percent and Senator Marco Rubio of Florida had 17 percent. But another
Iowa poll released on Monday, by CNN/OCR, showed Mr. Trump with a
comfortable lead but Mr. Cruz gaining ground on him.
Mr. Trump, who boasts about his strong poll numbers at the beginning of
virtually every campaign speech, launched an unusually stinging attack against Ben
Carson, another Republican candidate, when Mr. Carson took a lead in Iowa polls
this fall; Mr. Trump, citing Mr. Carson’s memoir about his sometimes-violent
youth, called him “pathological” and compared his state of mind to a child
molester’s.
Several Republican strategists and politicians said they believe that Mr.
Trump’s maneuver against Muslims was partly a challenge to Mr. Cruz and other
Republicans to stake out positions on terrorism that were as audacious as his own.
But they also said that the ban reflected anxiety and anger among many voters that
the federal government was not acting aggressively enough to protect them at
home.
“I think Trump’s idea may be too strong, but I think something jarring is very
helpful in leading to a national debate in how big this problem is, and how
dangerous it is,” said Newt Gingrich, a former Republican speaker of the House
who ran for president in 2012. “Nine percent of Pakistanis agree with ISIS,
according to one poll. That’s a huge number. We need to put all the burden of proof
on people coming from those countries to show that they are not a danger to us.”
Tens of thousands of Muslims enter and stay in the United States each year as
tourists or through the immigration system, experts say, with an estimated
100,000 Muslims becoming United States permanent residents in 2012, according
to the Pew Research Center. The United States issued 680,000 green cards to
migrants from Muslim-majority countries in the five-year period from fiscal year
2009 through fiscal year 2013, according to the Senate Judiciary Committee’s
Subcommittee on Immigration and the National Interest, which cited data from

the Department of Homeland Security.
At a rally at the U.S.S. Yorktown in South Carolina on Monday night, Mr.
Trump drew sustained cheers from the audience as he outlined his idea for the ban.
“We have no choice,” Mr. Trump said. “Our country cannot be the victim of
tremendous attacks by people who believe only in jihad.”
While several Republican presidential candidates have called for increased
intelligence gathering and more aggressive investigations of suspected terrorists, as
well as a halt to Muslim refugees entering the United States from Syria, Mr.
Trump’s pointed suspicions about Muslims have been in a category by themselves.
At his campaign rallies, he has drawn strong applause from thousands of
voters for his calls on the government to monitor mosques, and he has refused to
rule out his earlier proposal to enter names of Muslims in America into a database.
He has also made a series of ominous comments about President Obama’s
leadership in fighting terrorism, suggesting that there was “something going on”
with Mr. Obama that Americans were not aware of.
In his statement, Mr. Trump quoted a poll by the Center for Security Policy,
whose president and founder, Frank Gaffney, has claimed that President Obama is
aligned with the Muslim Brotherhood, an extremist political movement born in
Egypt, and that agents of the Muslim Brotherhood have infiltrated the U.S.
government, the Republican Party and conservative political organizations.
Barring non-citizen Muslims from the United States has drawn support from
organizations like the Society of Americans for National Existence and the Daily
Stormer, which the Southern Poverty Law Center has described as hate groups.
The proposal drew immediate condemnation from Muslim-Americans. Eboo
Patel, the president of Interfaith Youth Core, based in Chicago, said, “I’m standing
in a building right now where I am looking up at the Sears Tower, which was
designed by Fazlur Rahman Khan,” a structural engineer originally from
Bangladesh who was behind what is now known as the Willis Tower.

“What if we had barred Russians from America because of the Cold War? Who
would have invented Google?” Mr. Patel asked, referring to Google’s co-founder,
Sergey Brin.
While many critics of Mr. Trump reassured themselves that neither he nor his
idea would ultimately go anywhere, they were aghast that a mainstream
presidential candidate would ever utter it.
“It would be particularly bizarre,” said Ms. Morawetz, “to have an immigration
test based on religion given that the country was founded by people who were
fleeing religious persecution.”
Donald Trump’s Republican Rivals Condemn His Call to Bar Muslims From Entering
U.S.

By ALAN RAPPEPORT
Donald J. Trump’s call to bar Muslims from entering the United States has drawn swift
condemnation from his Republican rivals for the nomination, raising the question of
whether the billionaire businessman has finally gone too far.
95,000 Words, Many of Them Ominous, From Donald Trump’s Tongue

By PATRICK HEALY and MAGGIE HABERMAN
An analysis of 95,000 words Mr. Trump said in public in the past week reveals powerful
patterns in his speech which, historians say, echo the appeals of demagogues of the past
century.

Laurie Goodstein and Thomas Kaplan contributed reporting.
Find out what you need to know about the 2016 presidential race today, and get
politics news updates via Facebook, Twitter and the First Draft newsletter.
A version of this article appears in print on 12/08/2015, on page A1 of the
NewYork edition with the headline: Trump Wants to Block Entry of All
Muslims.

Fri. Dec. 04 22 Posts Tue. Dec. 08 19 Posts

© 2017 The New York Times Company

EXHIBIT F

YOUR NEWS COMPANION

MAY 9 2016 3:36 PM

Donald Trump and the Spike in Anti-Muslim
Hate Crimes in the U.S.
By Isaac Chotiner

A protest against presidential candidate Donald Trump on March 19 in New York.
Eduardo Munoz Alvarez/Getty Images

Several weeks ago, in Washington, D.C., a Muslim woman was called “a worthless piece of Muslim trash” and a “terrorist” by a fellow
Starbucks customer and, presumably, American citizen. After pouring something on the Muslim woman, the assaulter told her victim that she
was planning on voting for Donald Trump, who would send Muslims “back to where you come from.” As horrific as this incident was, it was not
unique. According to a new study from the Center for Muslim-Christian Understanding at Georgetown University, anti-Muslim hate crimes
increased in 2015, coinciding with attacks in Paris and San Bernardino, California, and the rise of Donald Trump, the presumptive GOP
nominee for president who has called for a ban on Muslims entering the United States.
The larger context for anti-Muslim hate crimes remains the atmosphere after the 9/11 attacks. Prior to 9/11, there were somewhere between 20
and 30 annual hate crimes committed against Muslims. Since that time, the number has increased to more than 100 annually. But 2015 was
especially bad. Trump entered the race for the presidency in June. In November, Paris was attacked. In early December, San Bernardino was
attacked. And several days later, Trump announced his Muslim ban proposal.

It was during December that the study saw a huge spike, recording 53 separate attacks on Muslims during this month, nearly one-third of the
total in the entire year. To discuss these findings, I spoke by phone with Engy Abdelkader, the author of the report and a lawyer. “There are
increasing threats of anti-Muslim violence,” she told me. “We saw this in 2015, which was perhaps the worst year in this regard since Sept. 11.”
Abdelkader was careful to say that her study—based on news reports—may not be completely comprehensive, in part because some acts do
not get reported. But by her count, there were 174 reported incidents in 2015, including 12 murders.
Abdelkader realizes how hard it is to pin specific acts on Trump or any other particular person or event (and the San Bernardino attacks and
Trump’s rhetoric in response are especially difficult to separate), but the study does note that at least three of the chronicled incidents—in
addition to the one in Washington, D.C.—were committed by avowed Trump supporters. Muslim leaders and victims of crime time and again,
Abdelkader told me, relayed a strong perception that they were facing increased threats because of the heightened political atmosphere

EXHIBIT G

The 19-year-old sophomore psychology student struggled to
breathe as the man pulled hard at her head scarf inside the third
floor of the West Garage at Fourth and San Salvador streets.
“I was trying to gasp for air,” Altun said. “I
couldn’t say or do anything. I was paralyzed.”
The attack lasted just a few seconds. Altun
fought back by leaning forward, and when her
attacker let go she fell hard to her knees. The
man did not say a word, she said.

Esra Altun

The attack came a day after the election of
Republican Donald Trump, who at one point
proposed a temporary ban on the immigration

of Muslims to the United States.
University police told Altun they could not treat it as a hate crime,
but she believes it was racially motivated.
“It happened a day after Trump was announced as presidentelect,” Altun said. “If it was for another reason, it’s such a weird
coincidence.”
University President Mary Papazian said she also found the attack
troubling.
“I think our students have the perception that they were targeted
because of their faith,” Papazian said. “Whether or not it rises to
the literal level of what a hate crime would be, it certainly is
something that we have to pay attention to. And we need to make
sure that we have the conversations on campus about how our
students of various backgrounds, orientations and affinities are
feeling in a time when our nation is having a very dynamic
conversation around these issues.”
There were no cameras in the part of the garage where the attack
took place, and Papazian said the college planned to study adding
them.
Similar attacks have been reported elsewhere, including at San
Diego State University, where a Muslim student was assaulted and
robbed in a campus parking lot. Authorities say the woman, who
was wearing a hijab, was targeted because of her faith and that the
suspects made comments about Trump’s election, according to the
Associated Press. The assault and robbery is being investigated as
a hate crime.

EXHIBIT H

Post-election note to El Cajon business: 'BE
PREPARED TO GO BACK TO YOUR
COUNTRY WITH ISIS'

During a news conference at the Islamic Center of Southern California in Los Angeles on Monday, Muslim Public Affairs Council
President Salam Al-Marayati called for the person behind threatening letters sent to mosques in California and Georgia to come forward
and talk with Muslims face to face. (Brian van der Brug / Los Angeles)

By Kate Morrissey

NOVEMBER 30, 2016, 5:00 PM

I

n the ten days following the election of Donald Trump as president, the U.S. saw a “national outbreak of
hate” — 867 reported incidents, according to a report released Tuesday by the Southern Poverty Law

Center.
Ninety-nine of those incidents happened in California and nine in the San Diego area, according to data from
the Southern Poverty Law Center. The share of reported incidents for both California and San Diego
are roughly equivalent to the areas’ shares of the U.S. population, according to U.S. Census data.
Of the San Diego incidents, three were anti-immigrant, according to data from the Southern Poverty Law
Center. Three were anti-black. One incident was anti-Muslim, one was anti-LGBT, and one was pro-white
nationalist.
The report provides details for only one of the local incidents. According to the report, a business in El Cajon
received a note that said, “BE PREPARED TO GO BACK TO YOUR COUNTRY WITH ISIS…DONALD
TRUMP WILL KICK ALL OF YOUR ASS BACK WHERE YOU CAME FROM.”
Nationwide, close to 30 percent of the incidents were considered anti-immigrant by the report.
In one such incident, a 10-year-old boy in Hermosa Beach, California, was told by a middle-aged white man
whom he did not know to “get the f--- out” of the country. The man also called the boy a “beaner.”
“At this point, it is not enough for Trump to look in the camera and say ‘Stop it!’ to the harassers, as he did
on ‘60 Minutes.’ Nor is it enough for him to simply ‘disavow’ the white supremacists who see him as their
champion, as he did at The (New York) Times,” the report says. “If he is to make good on the first promise he
made as the president-elect — his pledge to ‘bind the wounds of division’ in our country — he must repair the
damage that his campaign has caused. Rather than feign ignorance, he must acknowledge that his own
words have opened ‘wounds of division’ in our country.”
Twenty-three of the hate incidents reflected animosity toward Trump or his supporters. His campaign
headquarters in Denver was vandalized with the word “No” the day after the election, as one example given
in the report.
The Southern Poverty Law Center also recently surveyed teachers about the effect of the election in their
classrooms.
More than 10,000 teachers responded to the survey, according to the report. Nine out of 10 said that the
election had negatively affected their classrooms, and eight in 10 reported heightened anxiety

among immigrant, Muslim, African-American and students who are LGBT or lesbian, gay, bisexual or
transgender.
Four out of 10 said that they’d heard derogatory language directed at those student groups.

EXHIBIT I

The note, scribbled in black ink, also told her to “tie” her headscarf around
her neck and “hang yourself with it.”
The note ended with the word “America” along with a drawing of the
American flag.
Mairah Teli, a teacher at Dacula High School in Gwinnett County, located
outside Atlanta, posted a picture of the note to her Facebook page Friday.
“As a Muslim, I wear a headscarf as a practice of my faith. I want to share
this to raise awareness about the reality and climate of our community.
Spreading hate isn’t going to ‘make America great again,’” she wrote.
Sloan Roach, a spokeswoman for the Gwinnett County Schools, said in a
statement that school officials are working to find out who wrote the note.
“We take a threat against a staff member a serious matter,” Roach said.
It’s unclear at this time whether the person who wrote it was inspired by
Donald Trump’s election to the presidency, but Teli’s post on Facebook
assumed as much.
“I feel children feel safe making comments that are racist or sexist because of
him,” she told the Atlanta Journal-Constitution.
The incident comes as similar incidents involving harassment and hateful
messages against people from certain backgrounds were reported in other
parts of the country following Trump’s victory. On the campaign trail, the
president-elect had promised to keep Muslims from entering the United
States. He later backed off from a complete ban, saying his proposal would
keep immigrants from countries that have been “compromised by
terrorism.”

In his victory speech, Trump kept a unifying tone and promised to be
“president of all Americans” — a departure from his campaign rhetoric.
“He said, ‘We’re going to calm the waters. We’re going to bring people
together,'” Republican National Committee Chairman Reince Priebus told
Fox News on Wednesday morning.
y
g
But the aftermath of the election is anything but calm, as waves of antiTrump protests — some more violent than others — spread across the
country. Protests continue Saturday, four days after the election.
Trump echoed his victory speech in a tweet:
But division and vitriol seem to have intensified in the past few days.
According to the Southern Poverty Law Center, there have been more than
200 incidents of harassment and intimidation since Trump was elected.
Many were directed toward African Americans, immigrants, Muslims and
the LGBT community.
The nonprofit group tallied individual incidents reported on the news and on
social media, as well as those reported directly to the organization’s website.
The center, however, cautioned that not all incidents involved direct
references to Trump, and not every incident could be independently verified.
Many of the incidents were vandalisms, while others involved direct attacks.
In Ohio, a Muslim woman, her children and elderly parents were threatened
by a man while they were stopped at a traffic light, according to the Ohio
chapter of the Council on American-Islamic Relations. The man allegedly
approached the family’s car, banged on the window, and told the woman
that she “doesn’t belong in this country” — while yelling obscenities and
taking pictures of her children.
In Pennsylvania, students were seen on video holding a Trump sign and

parading through the hallways of their York County school. One student
shouted “white power,” police said. Minority students at the York County
School of Technology said the harassment has been an issue for a month but
has gotten worse since Trump was elected.
Victorria Markle, who is part black, told the York Dispatch that other
students have called her the n-word and have threatened to kill her. Eibreha
Drayden, who is part Mexican, said students have called her “Papi” and
whistled at her like a dog.
In Michigan, students at Royal Oak Middle School chanted “build the wall”
during lunch period in their school’s cafeteria. A Facebook video that
appears to show the incident had been viewed 10 million times as of
Saturday.
In Georgia’s DeKalb County, located next to the county where Teli teaches, a
teacher was removed from class after allegedly going on a racist tirade
against undocumented immigrants, the Atlanta Journal-Constitution
reported.
The Washington Post was unable to immediately contact Teli on Saturday.
Teli, according to the Atlanta Journal-Constitution, is a California native
who grew up in Gwinnett County and teaches language arts at Dacula High
School.
She told the Atlanta Journal-Constitution that after receiving the note, she
told her students that she would be happy to speak with them about why she
wears a headscarf.
“We are living in a time with a lot of disagreement, a lot of conflict,” Teli
said, adding that it’s important to teach students to disagree peacefully and
respectfully.

Lindsey Bever and Sarah Larimer contributed to this article.

EXHIBIT J

such incidents.
The Twin Cities, home to the nation’s largest community of Somali
immigrants, gained national attention through the FBI’s pursuit there of 10
p
young men from the Somali American community, whom they accused of
conspiring to join the Islamic State. Nine were recently sentenced on terror
charges.
Just before the election, Donald J. Trump made reference to the issue, facing
criticism from some for singling out Somalis while speaking to crowds in
g g
Minnesota about halting the flow of immigration.
“Here in Minnesota, you’ve seen firsthand the problems caused with faulty
refugee vetting, with large numbers of Somali refugees coming into your
state without your knowledge, without your support or approval, and with
some of them then joining ISIS and spreading their extremist views all over
our country and all over the world,” Trump said.
But within the same Somali community, women in hijabs have been making
national headlines for other reasons. Last month, Halima Aden became the
first to compete in the Miss Minnesota USA pageant while fully clothed. She
p
made the semifinals while wearing a hijab, as well as a full-body suit called a
burkini during the swimsuit competition.
As she celebrated her win on the night of the election, Omar was on the verge
of tears, hugging and kissing other women in hijabs, a video by the Star
Tribune shows.
“Injustices that are rooted in our society are the root of all of our problems,”
she said during her acceptance speech. “I will never give up fighting for you
and I hope you never give up fighting for me.”
As her father wrote in a letter on her campaign website, Omar has been
fighting since a young age, when she would walk miles to get water or wood

for her family in the Kenyan refugee camp where they lived. She was 8 years
old when the family fled Somalia’s civil war. After moving to Minnesota, she
developed an interest in politics at the age of 14, when she served as her
grandfather’s interpreter so he could participate in the local DemocraticFarmer-Labor caucus.
Most recently, Omar served as the director of policy initiatives at Women
Organizing Women, where she worked with East African women and
encouraged them to take on civic leadership roles, according to her website.
At Omar’s victory rally on election night, one supporter, Hodan Hassan, a
member of a Somali American task force, said Omar’s story has shaped the
Somali community.
“It just shows you that people like Donald Trump cannot bully us. We’re here
to stay,” she said. “I hope we can have a hundred Ilhans in the coming
years.”

EXHIBIT K

HATEWATCH

Update: More Than 400 Incidents of Hateful Harassment and Intimidation Since the Election
November 15, 2016

by Hatewatch Staff

Between Wednesday, November 9, the day after the presidential election, and the morning
of Monday, November 14, the Southern Poverty Law Center collected 437 reports of
hateful intimidation and harassment.
The following reports were collected through news reports, social media, and direct
submissions via SPLC's #ReportHate page. These incidents, aside from news reports,
are largely anecdotal. The SPLC did follow up with a majority of user submissions in an
effort to confirm reports. As we reported earlier, many incidents involved direct
references to the Trump campaign and its slogans.
Here's the overview:

Most of the reports involved anti-immigrant incidents (136), followed by anti-black (89)
and anti-LGBT (43). Some reports (8) included multiple categories like anti-Muslim and
anti-immigrant. The "Trump" category (41) refers to incidents where there was no clear
defined target, like the pro-Trump vandalism of a "unity" sign in Connecticut. We also
collected 20 reports of anti-Trump intimidation and harassment.
Here are some examples from around the country:

In Oregon:
A Muslim woman was riding the Max to Beaverton in the early afternoon and
a group of teenagers went to the corner of the car where she was sitting and
got up in her face yelling at her that she was a terrorist, that our new president
was going to deport her, that she can't wear her hijab anymore. They got
increasingly menacing, and my friend went over and made them get off the
train. When they were leaving through the door they tried to spit on her.

A gay man in North Carolina:
My boyfriend and I were walking down the sidewalk in Raleigh, North
Carolina. It was 9:30 PM, and we were holding hands and walking to a
restaurant for dinner. A white car passed us and a white male in the back
passenger side seat leaned out the window and yelled, "Fucking faggots!" at us.

A Latina woman in Texas reported:
I was walking my baby at my neighborhood park and a truck drove by with a
male driving and a female passenger. The female yelled "white power" at us as
they drove by and then sped away.

Venues of harassment included K-12 schools (99), businesses (76), and universities (67).
Common also was vandalism and leafleting on private property (40) and epithets and
slurs hurled from moving vehicles (38).
At an elementary school in Texas:
My 13 yo half Filipino daughter was approached by a child she didn't know as
she waited to board her bus after school. The young man stated "You're Asian,
right? When they see your eyes you are going to be deported" and he walked
away. I reported this to my district Superintendent.

From a news report in Georgia:

A Gwinnett County high school teacher said she was left a note in class Friday
telling her that her Muslim headscarf "isn't allowed anymore." “Why don’t you
tie it around your neck & hang yourself with it...,” the note said, signed
"America!"

Vandalism involving swastikas (35) was also frequently reported. In California:
A swastika was spray painted on a billboard for the movie "Almost
Christmas," which shows an African American cast.

It appears that incidents are subsiding, although earlier incidents are still being
reported:

EXHIBIT L

The mayor attributed the spike in part to rhetoric used by President-elect
Donald Trump during his campaign.
“We now need to work with him,” de Blasio said. “He has a chance to make it
better by amending his comments and being a force of reconciliation. I think
he has to do more of that.”
Salama, the transit employee, is a 45-year-old mother of four who works as a
Metropolitan Transportation Authority station agent, WABC reported. In 20
years of living in New York City, “it is my first time I face something like
that,” she told the station.
“I wasn’t able to say anything,” she told CBS New York. “I was afraid he was
going to throw me down the tracks or do more bad to me than he already
did. He was, like, pushing me down.”
A passerby stopped to help Salama, who was transported to a hospital for
treatment, according to a statement from Gov. Andrew M. Cuomo.
The governor said in the statement he wished the woman a “speedy
recovery” and said the state’s Hate Crimes Task Force will “continue to crack
down on this type of criminal behavior.”
“We do not allow intolerance or fear to divide us because we know diversity
is our strength and we are at our best when we stand united,” Cuomo said in
the statement.
Afaf Nasher, executive director of the New York chapter of the Council on
American-Islamic Relations, said in a statement that New York’s subways
and buses are emblematic of the city’s diversity and must not be permitted to
be become “a venue for hatred and violence.”
“President-elect Trump has a duty to forcefully denounce this wave of
violence against the Muslim community,” Nasher said. “Mr. Trump’s

rhetoric normalized hate, racism and xenophobia, and these attacks are the
unavoidable byproduct.”
A separate incident involving anti-Muslim bias on a subway train took
place Thursday night, police said, when three men reportedly taunted a
Muslim woman wearing hijab on a subway train, calling her a terrorist and
yelling “Donald Trump.”
Police said the men told the 18-year-old woman, “You don’t belong here,”
and called her hijab a “rag,” according to the Associated Press. As the train
pulled into Grand Central Terminal, one of the men tried unsuccessfully to
pull off her hijab.
Adding to a series of suspected anti-Semitic incidents affecting the
Metropolitan Transportation Authority, the inside of a New York City 1 train
was found Saturday to have been vandalized with multiple swastikas. Last
week, KKK fliers and business cards were distributed at the Patchogue and
Hampton Bay Stations on the Long Island Rail Road, according to Cuomo’s
statement.
Similar hate crimes targeting Muslims, Jews, immigrants and other minority
groups have been reported across the country since the election. CAIR has
tracked more than 100 suspected anti-Muslim incidents nationwide, and the
Southern Poverty Law Center has documented almost 1,000 incidents
targeting different minority groups, according to a statement from CAIR.
Salama was nursing a twisted knee and a swollen ankle late Monday, CBS
New York reported.
In light of the altercation, she told WABC that she plans to be a bit more
cautious, but will continue to wear her headscarf.
“I would never think about not wearing my hijab,” Salama said. “I will still
wear it. It’s never going to affect me.”

EXHIBIT M

EXHIBIT N

police, who said officers responded to a call about an assault in progress.
When they arrived at the scene, police were told that a man threatened to slit
an off-duty officer’s throat during a dispute involving her son.
Mayor Bill de Blasio on Monday addressed the alleged incident at a news
conference on crime statistics, saying he was “sick to my stomach” when he
heard that a police officer had faced threats because of her religion.
“Now, it makes no difference to me whether she was off duty or on duty at
the time. She serves this city,” de Blasio said. “She is an example of
everything we would want from our fellow citizens — a commitment to
others, a commitment to service, a willingness to do something greater than
herself. And what does she get for it? Threats to her life and bigotry. Taunts.
We can’t allow this. It’s unacceptable in this city, it’s unacceptable in this
nation.”
Elsokary appeared at the news conference alongside de Blasio, who said that
he wanted to ensure that those who read about the incident or saw it on
televised broadcasts could put a real face to the story.
“Think of what we value in this city and this nation,” he said. “We value
people who put on a uniform and protect us. We value people who have a
faith and live it out. And she has done all those things, and it’s absolutely
unacceptable that she or anyone would be treated with hatred or bigotry.”
De Blasio also noted that the assailant allegedly yelled “go back to your
country” at Elsokary and her son during the attack.
“Well, this is Officer Elsokary’s country,” he said. “She is an American, she is
a New Yorker. She’s already at home. And we cannot allow this kind of
hatred and bias to spread. We have to stop it every single time.”
De Blasio also cited a 2014 incident in which Elsokary assisted during a
blaze. That fire and Elsokary’s heroics are detailed in a New York Daily News
y

report, which states that she was on patrol with a sergeant when they heard a
police call about a fire.
While the pair were working at the scene, Elsokary heard a baby cry, so
she rushed up. She discovered a woman and a 1-year-old, whom she escorted
out of the two-story building, the newspaper reported.
“I became a police officer to show the positive side of a New Yorker, a
Muslim woman that can do the job, that is non-biased, that I help everybody
no matter what’s your religion, what’s your faith, what do you in New York,”
Elsokary said at the news conference. “I’m born and raised here. And I’m
here to protect you, and I know that my department and my city is here to
protect me.”
Nelson was arraigned Monday morning, according to the Brooklyn district
attorney’s office. A message left with his attorney was not immediately
returned Monday afternoon.
“This defendant allegedly subjected the victim and her son to deplorable and
ugly acts of hate, including threats of violence, simply because they are
Muslim,” acting Brooklyn District Attorney Eric Gonzalez said in a
statement. “Biased-motivated crimes will not be tolerated anywhere in
Brooklyn. And those who commit hate crimes will be held accountable for
their reprehensible and offensive actions.”
The New York chapter of the Council on American-Islamic Relations on
Sunday condemned the alleged attack in a Facebook post, in which CAIR-NY
Executive Director Afaf Nasher called on President-elect Donald Trump to
“forcefully and repeatedly address the ugly hatred growing rampant
through-out our nation.”
Since Trump’s victory, a number of charged incidents have been reported
across the country, including some that involve Muslims.

Last month, a Muslim teacher in Georgia said a note was left in her
classroom telling her that her “headscarf isn’t allowed anymore.”
The anonymous note instructed her to “tie” the scarf around her neck and
“hang yourself with it.”
And at the University of Michigan, a female student was approached by a
pp
y
man who threatened to set her on fire if she didn’t take off her hijab, or head
covering. The student complied, police said.
In a “60 Minutes” interview that aired last month, Trump said he was “so
saddened to hear” that people were harassing others in his name. “And I say,
‘Stop it,’” the president-elect said. “If it — if it helps, I will say this, and I will
say it right to the cameras: ‘Stop it.’”
This post has been updated.

EXHIBIT O

Man stabs worshiper near Simi Valley mosque
in hate crime, police allege

A man was arrested Saturday after a stabbing in Simi Valley.

By Matt Stevens and Matt Hamilton
DECEMBER 12, 2016, 2:50 PM

A

29-year-old Simi Valley man has been arrested and booked on suspicion of committing a hate
crime after an apparent worshiper was stabbed near a mosque, authorities say.
About 11:15 p.m. Saturday, Simi Valley police received reports of people fighting in a shopping

center parking lot in the 1800 block of Erringer Road, said Sgt. Adam Darough. The shopping center is
“adjacent” to a mosque, Darough said.
After officers arrived and separated those involved in the fight, police discovered that a man had been
stabbed, Darough said.

“During their investigation, [officers] discovered a suspect had confronted a worshiper from the mosque,
and after a verbal altercation, they began to fight,” Darough said. “During the fight, [someone] stabbed the
victim.”
Police arrested John Matteson nearby, Darough said. Matteson was taken into custody and booked into
Ventura County jail on suspicion of a hate crime, Darough said.
Authorities initially said Matteson was suspected of carrying out the attack. On Monday, however, police said
that Matteson was involved in the fight but that another unidentified man committed the stabbing.
Jail records show that Matteson’s bail was set at $25,000. He was booked on suspicion of making felony
criminal threats, performing a felony violation of civil rights and disturbing the peace by fighting, the records
show.
Matteson is scheduled to appear in court Tuesday, according to jail records. It’s unclear if he was being
represented by an attorney.
The Simi Valley Police Department has investigated a man with the same name and birth date as Matteson
in connection with several incidents in recent years, according to Ventura County Superior Court records.
He pleaded no contest in October to disturbing the peace by loud noise, an infraction. In July, Matteson
pleaded guilty to a misdemeanor count of public intoxication from a June 30 incident, according to court
records. He also pleaded guilty to a misdemeanor count of disturbing the peace stemming from a Nov. 9,
2015, incident.
Last year, he also pleaded guilty to a misdemeanor count of making terrorist threats.
Authorities did not provide additional details about the victim. They said he was taken to a local hospital
with non-life-threatening injuries and is in stable condition.
“We’re investigating whether or not this was instigated by [the victim’s] appearance and the association with
the mosque,” Darough said. “We’re quite concerned that this occurred. We want to keep people of all faiths
safe in the city.”
Hussam Ayloush, executive director of the Greater Los Angeles chapter of the Council on American-Islamic
Relations, said Sunday that he had spoken with several Muslims in Simi Valley and that they were
“heartbroken.”

Members of the community told Ayloush that the stabbing had occurred near a “prayer area” where locals
had gathered — but he said he did not know the exact address or type of building where the gathering took
place.
Since election day, CAIR has received almost 200 reports of hate incidents directed at Muslims in America,
Ayloush said.
“It’s hard to believe that in this day and age we still have to deal with such hate and violence in our country,
and especially in a place as diverse as Southern California,” Ayloush said.
The stabbing comes amid a national surge in anti-Muslim crimes, which jumped 67% in 2015, according to
FBI statistics.
Researchers at Cal State San Bernardino have said the rise in anti-Muslim crimes accelerated after the San
Bernardino terror attack in December 2015 and was fanned by Donald Trump’s call to bar Muslims from
entering the United States during his successful campaign for the presidency.
In recent weeks, mosques across California have received letters threatening genocide and referring to
Muslims as “vile and filthy people.”
Officials note the difference between a hate crime and cruel comments, the latter of which are often
protected by the First Amendment. The law prohibits physically harming someone based on his or her race,
religion, national origin, gender or sexual orientation, among other characteristics.

UPDATES:
Dec. 12, 2:50 p.m.: This article was updated with information from the police that another unidentified
man is suspected of the actual stabbing, not John Matteson.
Dec. 11, 6:10 p.m.: This article was updated with additional reaction and information about previous hate
crimes.
This article was originally published Dec. 11 at 1:35 p.m.

EXHIBIT P

Lawton Islamic Center falls victim to potential
hate crime
Published: Thursday, December 8th 2016, 6:08 pm EST
Updated: Thursday, December 8th 2016, 6:08 pm EST

By Rhiannon Poolaw, Digital Content Manager
LAWTON, OK (KSWO)- Lawton Police are investigating a possible hate crime after they say a dead pig was dumped o� at the Islamic Center on
Southwest "F" Avenue.
The incident happened sometime Tuesday night. Surveillance video from The Islamic Center shows a pick-up truck pulling into the parking lot and
turning around. Moments later the truck backs up and the carcass falls o� the tailgate. The truck then takes o�.
A Lawton Police o�cer who was driving in the area noticed the carcass and called the Islamic Center's Director, Dr. Hassan Ahmed.
Doctor Ahmed told 7News he is not sad or angry but shocked. He says it's highly o�ensive to Islamic people to drop a pig carcass in from of any
Islamic center.
According to the Quran, members of the Islamic faith are forbidden to eat pork and an act such as dumping a dead pig can be considered highly
o�ensive, much like a swastika would be o�ensive to members of Judaism.  
He doesn't know who did it but says he forgives them.
"What shocked me is a person has to take a lot of preparation and time and travel and come there and drop o� a wild hog in front of the mosque
that is not thinking about good things for the community and for the nation. It just shocked me," said Dr. Hassan Ahmed.
Since the presidential election, some cities have seen an increase in what they believe are hates crimes.
“Well, I don't want to call it a hate crime because I didn't know exactly the intentions of the person, the perpetrator. I don't know their intentions
and what they did it is it something that they don't know anything. I don't know but if their intentions was nagging the Islamic center or the prime
business of the Muslims here in the US. I would call it hate crime," said Dr. Ahmed.
Dr. Ahmed adds that regardless of what religion or ethnicity you are, dumping a dead animal at a mosque is just wrong. And, according to Lawton
Animal Control, it is illegal to dump any carcass in front of a business, home, or street in the city of Lawton.
Dr, Ahmed says education is key, not just regarding Islam but all religions.
"Education is power. No doubt, education is power. If a person is educated, actually in practice of education. The only reason a person does this
kind of thing is because of fear of others. Not knowing the others is what makes it a problem,” said Dr. Ahmed.
Dr. Ahmed says he is moving forward. He says they will continue to worship in Lawton because they are a part of the community.
While the dumping of a carcass is illegal here in Lawton, Animal Welfare says you can drop o� carcasses at the city Land�ll on Southwest 11th
Street.
The investigation is ongoing; police say they have no suspects.
Copyright 2016 KSWO. All rights reserved. 

EXHIBIT Q

EXHIBIT R

A community of Muslim Americans learns how to protect itself amid rising Islamophobia
(http://fusion.net/video/252626/muslim-americans-protect-themselves-amid-rising-islamophobia/)

By Nidhi Prakash (http://fusion.net/author/nidhiprakash/)

FOLLOW (HTTPS://TWITTER.COM/INTENT/FOLLOW?SCREEN_NAME=NIDHIPRAKASH)
FEED (HTTP://FUSION.NET/AUTHOR/NIDHIPRAKASH/FEED/)

By Nidhi Prakash (http://fusion.net/author/nidhiprakash/)

In the days after the historic Women’s March on Washington (http //fusion net/story/380533/wom
ens march on washington radical feminist platform/) one of the leaders of the protest is being
subjected to a torrent of Islamophobic abuse online

“When the opposition including islamophobes are flooding your timeline with hate—you know you
did something right #womensmarch” she wrote on Twitter on Sunday
I’ve reached out to Sarsour for further comment and will update this post if I hear back

EXHIBIT S

NEW YORK – Linda Sarsour is used to slings and arrows, but not like this.
In the days since she helped organize the massive Women's March on Washington, the Brooklyn-born, hijab-wearing
activist has been targeted on the internet by false reports that she supports Islamic State militants and favors replacing
the U.S. legal system with Islamic religious law.
On social media, critics have circulated a photo of her holding up one finger, like a sports fan celebrating a championship,
and claimed she's giving "the ISIS one-fingered salute." In fact, she is on record as calling the Islamic State a global
cancer.
Other posts have falsely claimed that she supports the imposition of Islamic law on the U.S., citing, as evidence, a
sarcastic tweet she made in 2015 that was actually intended to ridicule conspiracy theories about secret Muslim plots to
take over the American legal system.
Bloggers and conservative websites also circulated a picture of her at a convention of Muslim civic leaders, standing with
a group of people that included a Milwaukee activist whose brother was arrested in Israel in 1998 and convicted of giving
$40,000 to a Hamas leader. The photo, they said, was proof of "ties" to Hamas.
"Ludicrous," said Sarsour, who was out rallying again Wednesday night in her hometown of New York City, protesting
executive orders on immigration and border security signed by President Donald Trump.
The online attacks, Sarsour said, were the work of "fake news purveyors" and "right-wing media outlets recirculating false
information."
"I'm not going to be intimidated or silenced," the-36-year-old married mother of three said.
Sarsour, the executive director of the Arab American Association of New York, cut her teeth as an activist defending the
civil rights of U.S. Muslims after the Sept. 11 attacks and came to wider prominence in recent years protesting against
police surveillance of Muslims. She's become a regular at Black Lives Matter protests, too, and a frequent TV
commentator on feminism.
The White House, during the Obama administration, honored Sarsour as a "champion of change."
Her profile got a lot higher, though, after last weekend's Women's March, where she was one of four national co-chairs of
an event that brought out well over a million people in Washington, D.C., and around the country.
Supporters responded to the online criticism with the Twitter hashtag #IMarchWithLinda.
Some people who know her work in New York said the idea that she is a foot-soldier for the oppressive view of Islam
promoted by Islamic State militants is laughable.
Steven Choi, executive director of the New York Immigration Coalition, called the attacks "part of a right-wing agenda to
undermine a Muslim-American woman who has dedicated her life to public service."
Detractors often focus in on Sarsour's frequent criticism of Israel's policies in the occupied territories. The child of
Palestinian immigrants, she has acknowledged publicly that members of her extended family have been arrested on
accusations of supporting Hamas.
The White House webpage that included information about the recognition she got during the Obama administration was
taken down after Trump took office.
Sarsour said the anti-Trump march was high point in her career as an activist.

"I've proved I could do things people didn't think I could do," she said. But it has also made her feel "much more unsafe."
She said she doesn't go out alone. Her three children aren't allowed to be home alone. She's taken additional steps lately,
like using car services to get around, rather than public transportation.
"It puts myself in danger. It puts my family in danger," she said of the online vitriol. The accusations of supporting a
terrorist group have been particularly upsetting for her children, she said.
___

EXHIBIT T

Two Texas mosques
burned to the ground this
month
The Islamic Center of Victoria was destroyed
by a massive fire Saturday, less than three
weeks after the partly constructed Islamic
Center of Lake Travis suffered the same fate.
! "
BY SANYA MANSOOR

JAN. 30, 2017

5:13 PM

The FBI, ATF and other agencies sift through the burned
remains of the Victoria Islamic Center a mosque in
Victoria on Jan. 29 2017. # Bob Daemmrich for The
Texas Tribune

The Islamic Center of Victoria was destroyed by a
massive fire Saturday, less than three weeks after
the partly constructed Islamic Center of Lake
Travis suffered the same fate.
The two fires come amid a time of increased
unease within Muslim communities across the
country.
Shakeel Rashed, executive board member of the
Islamic Center of Lake Travis, said the January
7 blaze that destroyed the progress made in
building the facility immediately worried Muslims
in the area.
“The initial reaction from the community was
‘Hey, this is definitely a hate crime.’ Some kids
actually put that on Facebook and Twitter,”
Rashed said. “But I told them we can’t say that
yet, until we determine the cause.”

The Victoria fire occurred hours after President
Donald Trump signed an executive order that in
part restricted migration from seven Muslimmajority countries, sparking chaos and distress at
airports across the country.
That timing drew national attention to the
incident. In two days, the Victoria center, which
serves about 40 families, has raised nearly
$900,000 toward rebuilding, according to

a crowdfunding page.
“The community has responded wonderfully with
support," said Dr. Shahid Hashmi, president of the
Victoria Islamic Center. "Every trait, religion, race
– everybody showed up and has been very
supportive. That’s been uplifting.”
Both the Victoria and Lake Travis fires are
currently under investigation and neither cause
has been made public. On Monday, the Austin
American-Statesman reported that federal
officials have determined the cause of the fire
that destroyed the Lake Travis facility, but
authorities were delaying the release of
information because of the investigation into the
fire in Victoria.
This was news to Shakeel Rashed, executive board
member of the Islamic Center of Lake Travis, who
said Monday afternoon that they had expected to
hear from the fire marshal within the next week
or two.
While he doesn't yet know the cause of the Lake
Travis Center fire remains unknown, Rashed is
certain that the mosque will be rebuilt. The
center has raised more than $50,000 of it's
$400,000 goal toward rebuilding.

“There are a lot more people who are in support

EXHIBIT U

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ǻřřěșť ťħįș ẅǿmǻň įmměđįǻťěŀỳ ǻňđ ħǻvě ħěř čħǻřģěđ ẅįťħ ťřěǻșǿň. İf ǿťħěř
jųđģěș přǿťěșť, ħě ňěěđș ťǿ đěčŀǻřě mǻřťįǻŀ ŀǻẅ ǻňđ ħǻvě ťħěm ǻŀŀ řǿųňđěđ
ųp ǻňđ įňťěřňěđ. Ẅě ǻřě ǻť ẅǻř ħěřě. Ťħįș įșň’ť ǻ ģǻmě.”
Ǻňģŀįň șťǿppěđ șħǿřť ǿf ťħřěǻťěňįňģ Đǿňňǿŀŀỳ đįřěčťŀỳ, bųť įň ǻň ųpđǻťě, ħě
čǻŀŀěđ fǿř Ťřųmp ťǿ đěpŀǿỳ ťħě “Ňǻťįǿňǻŀ Ģųǻřđ ťǿ ťħě přǿťěșť șįťěș” ǻť
ǻįřpǿřťș ǻčřǿșș ťħě čǿųňťřỳ ǻňđ “șħųť ťħěm đǿẅň čǿmpŀěťěŀỳ.”
Șųčħ pǿșťųřįňģ įșň’ť ňěẅ fǿř Ǻňģŀįň, ǿř fǿř ťħǻť mǻťťěř, ųňěxpěčťěđ.
Jųșť ŀǻșť mǿňťħ, ħě pŀǻňňěđ bųť ŀǻťěř ǻbǻňđǿňěđ ǻň ǻřměđ přǿťěșť įň
Ẅħįťěfįșħ, Mǿňťǻňǻ, ǻfťěř ťħě mǿťħěř ǿf Ǻŀť-Řįģħť ŀěǻđěř Řįčħǻřđ Șpěňčěř
ǿf ťħě Ňǻťįǿňǻŀ Pǿŀįčỳ İňșťįťųťě čǻmě ųňđěř čǿmmųňįťỳ přěșșųřě fǿř fǻįŀįňģ
ťǿ čǿňđěmň ħěř șǿň’ș vįěẅș. Ǻňģŀįň pųbŀįșħěđ ťħě pěřșǿňǻŀ įňfǿřmǻťįǿň ǿf
měmběřș ǿf Ŀǿvě Ŀįvěș Ħěřě, ǻ ňǿň-přǿfįť įň Mǿňťǻňǻ’ș Fŀǻťħěǻđ Vǻŀŀěỳ

ťħǻť ǻđđřěșșěș ħǻťě ǻňđ ěxťřěmįșm –– ǻ řěťǻŀįǻťǿřỳ ťǻčťįč ųșěđ bỳ ǿňŀįňě
ťřǿŀŀș, ķňǿẅň ǻș đǿxxįňģ.
Ǻňģŀįň đįđň’ť pųbŀįșħ Đǿňňěŀŀỳ’ș pěřșǿňǻŀ įňfǿřmǻťįǿň. Bųť ǿňě řěǻđěř,
pǿșťįňģ ųňđěř ťħě ňǻmě “fǿřběșmǻģ,” přǿvįđěđ ťħě fěđěřǻŀ jųđģě’ș ħǿmě
pħǿňě ňųmběř, ħěř ħųșbǻňđ’ș ňǻmě ǻňđ ǻ měșșǻģě: “Ťřǻįťǿřǿųș įđįǿť șčųm
‘jųđģě’ Ǻňň Mǻřįě Đǿňňěŀŀỳ, ǻppǿįňťěđ bỳ ťħě fǻķě ňįģģěř přěșįđěňť fřǿm
Ķěňỳǻ, ǿň ťħě řěčǿmměňđǻťįǿň ǿf ķįķě ‘șěňǻťǿř’ Čħųčķ Șčħųměř.” Ǻș ǿf
Ẅěđňěșđǻỳ, Đǻįŀỳ Șťǿřměř ǻđmįňįșťřǻťǿřș ħǻđ ňǿť řěmǿvěđ ťħě čǿmměňť.
Fǻř-řįģħť ěxťřěmįșťș ǿfťěň ųșě đǿxxįňģ ťǿ įňťįmįđǻťě ťħěįř pěřčěįvěđ
ěňěmįěș, įňčŀųđįňģ jųđģěș.
Čřǻįģ Čǿbb, ťħě ẅħįťě șųpřěmǻčįșť ẅħǿ įň 2013 ǻťťěmpťěđ ťǿ ěșťǻbŀįșħ ǻň
ěňčŀǻvě ǿf řǻčįșťș įň Ňǿřťħ Đǻķǿťǻ, ťǿǿķ įșșųě mǿřě ťħǻň ǻ đěčǻđě ǻģǿ ẅįťħ
Ų.Ș. Đįșťřįčť Jųđģě Jǿǻň Ħųmpħřěỳ Ŀěfķǿẅ ǻfťěř șħě řųŀěđ ǻģǻįňșť ťħě
Ẅǿřŀđ Čħųřčħ ǿf ťħě Čřěǻťǿř įň ǻ ťřǻđěmǻřķ įňfřįňģěměňť șųįť įň 2000.
Ģřǿųp ŀěǻđěř Mǻťťħěẅ Ħǻŀě ẅǻș ǻřřěșťěđ fǿř șǿŀįčįťįňģ Ŀěfķǿẅ’ș mųřđěř.
Ħě ẅǻș čǿňvįčťěđ ǻňđ șěňťěňčěđ ťǿ 40 ỳěǻřș įň přįșǿň, ẅħěřě ħě řěmǻįňș.
İň řěťǻŀįǻťįǿň, Čǿbb, ǻ fǿŀŀǿẅěř ǿf ťħě Čřěǻťįvįťỳ Mǿvěměňť, pųbŀįșħěđ
Ŀěfķǿẅ’ș ħǿmě ǻđđřěșș ǻňđ ǻ mǻp ťǿ įťș ŀǿčǻťįǿň ǿň ťħě İňťěřňěť. Ħě ǻŀșǿ
pǿșťěđ pįčťųřěș ǿf Ŀěfķǿẅ’ș ħųșbǻňđ ǻňđ čħįŀđřěň ǿň Șťǿřmfřǿňť, ųňťįŀ
řěčěňťŀỳ ťħě ẅǿřŀđ’ș ŀǻřģěșť ẅħįťě șųpřěmǻčįșť ẅěbșįťě.
Ťẅǿ ỳěǻřș ǻfťěř ťħǻť, įň 2005, Ŀěfķǿẅ’ș ħųșbǻňđ ǻňđ mǿťħěř ẅěřě
mųřđěřěđ įňșįđě ħěř Čħįčǻģǿ ħǿųșě. Ťħě ķįŀŀěř ẅǻș ňǿť įňvǿŀvěđ įň ẅħįťě
șųpřěmǻčỳ bųť ẅǻș ǻňģřỳ ǿvěř Ŀěfķǿẅ’ș řųŀįňģ įň ǻňǿťħěř čǻșě.
Ǻňǿťħěř ẅħįťě șųpřěmǻčįșť, Ħǻŀ Ťųřňěř, ǻ ǿňě-ťįmě řǻčįșť řǻđįǿ ħǿșť ẅħǿ
ǻŀșǿ șěřvěđ ǻș ǻň FBİ įňfǿřmǻňť, ẅǻș čħǻřģěđ įň Jųňě 2009 ẅįťħ
ťħřěǻťěňįňģ ťǿ ǻșșǻųŀť ǻňđ mųřđěř ťħřěě fěđěřǻŀ jųđģěș. Ħě ŀįșťěđ ťħěįř
ẅǿřķ ǻđđřěșșěș ǻňđ pħǿťǿș ǿň ħįș bŀǿģ, ẅřįťįňģ, “Ťħěșě Jųđģěș đěșěřvě ťǿ
bě ķįŀŀěđ.” Ǻfťěř ťẅǿ mįșťřįǻŀș șťěmmįňģ fřǿm jųřǿř čǿňfųșįǿň ǻbǿųť ħįș FBİ
řǿŀě, Ťųřňěř ẅǻș fǿųňđ ģųįŀťỳ įň Ǻųģųșť 2010 ǿf ťħřěǻťěňįňģ ťǿ ǻșșǻųŀť ǻňđ
mųřđěř ťħě jųđģěș. Ħě ẅǻș șěňťěňčěđ ťǿ 25 mǿňťħș ǻňđ ẅǻș řěŀěǻșěđ fřǿm
přįșǿň įň 2012.Ťřųmp’ș ěxěčųťįvě ǿřđěř įňđěfįňįťěŀỳ bǻřș Șỳřįǻň řěfųģěěș
fřǿm ěňťěřįňģ ťħě Ųňįťěđ Șťǻťěș ǻňđ șųșpěňđș ťħě ěňťřỳ ǿf ǻŀŀ řěfųģěěș fǿř
120 đǻỳș. İť ǻŀșǿ bŀǿčķș čįťįżěňș ǻňđ řěfųģěěș ǿf șěvěň Mųșŀįm-mǻjǿřįťỳ
čǿųňťřįěș –– İřǻň, İřǻq, Ŀįbỳǻ, Șǿmǻŀįǻ, Șųđǻň, Șỳřįǻ ǻňđ Ỳěměň –– fřǿm
ěňťěřįňģ ťħě Ųňįťěđ Șťǻťěș fǿř 90 đǻỳș.

İň řěpǿřťįňģ ǿň įňťěřňǻťįǿňǻŀ ťřǻvěŀ přǿbŀěmș, Ťħě Ňěẅ Ỳǿřķ Ťįmě ẅřǿťě,
“Ťħě ģŀǿbǻŀ čǿňfųșįǿň ťħǻť șįňčě ěřųpťěđ įș ťħě șťǿřỳ ǿf ǻ Ẅħįťě Ħǿųșě ťħǻť
řųșħěđ ťǿ ěňǻčť, ẅįťħ ŀįťťŀě řěģǻřđ fǿř bǻșįč ģǿvěřňįňģ, ǻ čǿřě čǻmpǻįģň
přǿmįșě ťħǻť Mř. Ťřųmp mǻđě ťǿ ħįș mǿșť fěřvěňť șųppǿřťěřș.”
Ťħǿșě șųppǿřťěřș ģǿ fǻř běỳǿňđ ťħě řǻňķ-ǻňđ-fįŀě ǿf ťħě mǻįňșťřěǻm
Ǻměřįčǻň čǿňșěřvǻťįvě mǿvěměňť. Ťħěỳ įňčŀųđě ěxťřěmįșťș ŀįķě Ǻňģŀįň,
ẅħǿ ģǻvě Ťřųmp ťħě mǿňįķěř “Ǿųř Ģŀǿřįǿųș Ŀěǻđěř” đųřįňģ ťħě čǻmpǻįģň
ǻňđ, fǿř ǻ ťįmě, břǻňđěđ ħįș ẅěbșįťě ťħě mǿșť ťřųșťěđ “Řěpųbŀįčǻň” șįťě ǿň
ťħě ẅěb.
İť’ș ňǿ șųřpřįșě ẅħỳ. Bųįŀđįňģ ǻ ẅǻŀŀ ǿň ťħě Ų.Ș. bǿřđěř ẅįťħ Měxįčǿ ǻňđ
bǻřřįňģ řěfųģěěș fřǿm ẅǻř-ťǿřň, přěđǿmįňǻňťŀỳ Mųșŀįm čǿųňťřįěș ǻřě įđěǻș
ťħǻť ěňěřģįżěđ ťħě ẅħįťě ňǻťįǿňǻŀįșť mǿvěměňť đųřįňģ ťħě čǻmpǻįģň.
Řěbřǻňđįňģ įťșěŀf ǻș ťħě Ǻŀť-Řįģħť ťǿ ěșčǻpě ťħě pǿŀįťįčǻŀ bǻģģǻģě ťħě
įđěǿŀǿģỳ ħǻđ ǻčqųįřěđ ťħřǿųģħ ťħě ỳěǻřș, ťħě mǿvěměňť ħěǻřđ įň Ťřųmp’ș
přǿmįșě ǻ șǿŀųťįǿň ťǿ ẅħǻť įť șǻẅ ǻș ǻ ťħřěǻť ťǿ Ǻměřįčǻ –– įmmįģřǻťįǿň.
Ňǿẅ, įň ẅħǻť ťħě řǻčįșť řįģħť čǻŀŀș “Ťřųmpměřįčǻ,” fřįňģě fįģųřěș ŀįķě
Ǻňģŀįň ħǻvě ģǻįňěđ ǻ ňěẅ přǿmįňěňčě, ťħǿųģħ řěmǻįň fǻř ǿųťșįđě ťħě
mǻįňșťřěǻm.
Ǻňģŀįň ħǻș ẅǻřňěđ, ťįmě ǻňđ ťįmě ǻģǻįň, ťħǻť ťħěřě įș ňǿ řǿǿm ųňđěř
Ťřųmp fǿř đįșșěňť, ňǿť ěvěň įf įť čǿměș fřǿm ťħě jųđįčįǻřỳ.
“Ťřųmp șẅǿřě ťǿ přǿťěčť ťħįș ňǻťįǿň fřǿm ěňěmįěș fǿřěįģň ǻňđ đǿměșťįč,
ǻňđ įň ťħįș čǻșě, ỳǿų ħǻvě ǻ đǿměșťįč ěňěmỳ přǿťěčťįňģ ǻ fǿřěįģň ǿňě,”
Ǻňģŀįň ẅřǿťě. “Ẅě ħǻvě ťǿ șħųť įť đǿẅň. Fǿř ģřěǻť jųșťįčě.”
***

EXHIBIT V

By Dean Obeidallah
 Updated 4:12 PM ET, Mon February 6, 2017

Trump rips federal judge who halted travel ban 01:33

Story highlights
Trump's attempt to delegitimize the federal
judiciary is terrifying, says Dean Obeidallah

Editor's Note: Dean Obeidallah, a former attorney, is the host
of SiriusXM radio's daily program "The Dean Obeidallah
Show" and a columnist for The Daily Beast. Follow him
@deanofcomedy. The opinions expressed in this
commentary are his.

Trump seems intent on bypassing our system
of checks and balances, he writes

(CNN) — On Saturday morning, President Donald Trump may
have unleashed his most bone-chilling tweet -- at least to those
who believe the United States should not become a Trump-led
dictatorship. And I don't make that comment simply to be
provocative or without giving it a great deal of thought. Our democracy is far more fragile than some might grasp
and Trump is engaging in a concerted e㴂ort to undermine the workings of it.
Here is Trump's truly jaw-dropping tweet from Saturday morning: "The opinion of this so-called judge, which
essentially takes law-enforcement away from our country, is ridiculous and will be overturned!"
Why is this so concerning? It's OK to argue about whether the judge should or shouldn't have issued this order. But
Trump is apparently attempting to delegitimize our federal judiciary by calling Judge James Robart, a George W.
Bush-appointed judge, a "so-called" judge while arguing that his decision is "ridiculous."