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

Filing 18

AMENDED COMPLAINT against defendant(s) All Defendants, filed by State of Washington. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Exhibit, # 4 Exhibit, # 5 Exhibit, # 6 Exhibit, # 7 Exhibit, # 8 Exhibit, # 9 Exhibit, # 10 Exhibit, # 11 Exhibit, # 12 Exhibit, # 13 Exhibit, # 14 Exhibit, # 15 Exhibit, # 16 Exhibit, # 17 Exhibit)(Purcell, Noah)

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First Amended Complaint Exhibit 3 Orlando Shooting: Read Donald Trump's Speech | Time.com Read Donald Trump's Speech on the Orlando Shooting Trump Pushes Muslim Ban After Orlando Shooting  DONALD TRUMP Read Donald Trump's Speech on the Orlando Shooting Ryan Teague Beckwith Updated: Jun 13, 2016 8:36 PM Pacific Donald Trump addressed the shooting at a gay club in Orlando in a prepared speech Monday, calling for suspending immigration from countries with a history of terrorism. Here is a full transcript of his remarks, as given. TRUMP: (OFF-MIKE) This was going to be a speech on Hillary Clinton and all of the bad things and we all know what's going on, and especially how poor she'd do as president in these very, very troubled times of radical Islamic terrorism. TRUMP: Even her former Secret Service agent, who's seen her under pressure and in times of http://time.com/4367120/orlando-shooting-donald-trump-transcript/[1/29/2017 7:56:40 PM] Orlando Shooting: Read Donald Trump's Speech | Time.com stress, has stated that she lacks the temperament and integrity to be our president. There will be plenty of opportunity to discuss these important issues at a later time, and I will deliver that speech very, very soon. But today, there's only one thing to discuss, the growing threat of terrorism inside of our borders. The attack on the Pulse nightclub in Orlando, Florida, was the worst terror strike on our soil since September 11th, and the worst mass shooting in our country's history. So many people -- it's just hard to believe, but just so many people dead, so many people gravely injured, so much carnage, such a disgrace. The horror is beyond description. The families of these wonderful people are totally devastated, and they will be forever. Likewise, our whole nation and indeed the whole world is devastated. We express our deepest sympathies to the victims, the wounded, and their families. We mourn as one people for our nation's loss, and pledge our support to any and all who need it. I would like to ask now that we all observe a moment of silence for the victims of this attack. Thank you. Our nation stands together in solidarity with the members of Orlando's LGBT community. They have been through something that nobody could ever experience. This is a very dark moment in America's history. A radical Islamic terrorist targeted the nightclub, not only because he wanted to kill Americans, but in order to execute gay and lesbian citizens, because of their sexual orientation. It's a strike at the heart and soul of who we are as a nation. It's an assault on the ability of free people to live their lives, love who they want, and express their identity. It's an attack on the right of every single American to live in peace and safety in their own country. We need to respond to this attack on America as one united people, with force, purpose, and determination. But the current politically correct response cripples our ability to talk and to think and act clearly. We're not acting clearly, we're not talking clearly, we've got problems. If we don't get tough, and if we don't get smart, and fast, we're not going to have our country anymore. There will be nothing, absolutely nothing, left. The killer, whose name I will not use, or ever say, was born in Afghan, of Afghan parents, who immigrated to the United States. His father published support for the Afghan Taliban, a regime which murders those who don't share its radical views, and they murdered plenty. The father even said he was running for president of Afghanistan. The bottom line is that the only reason the killer was in America in the first place, was because we allowed his family to come here. That is a fact, and it's a fact we need to talk about. We have a dysfunctional immigration system, which does not permit us to know who we let into our country, and it does not permit us to protect our citizens properly. We have an incompetent administration. And if I'm elected president, that will not change, I will tell you, that will not change over the next four years. We have an administration that will not change. But if I get in there, it's going to change, and it's going to change quickly. We're going from totally incompetent to just the opposite, believe me. (APPLAUSE) TRUMP: Thank you. http://time.com/4367120/orlando-shooting-donald-trump-transcript/[1/29/2017 7:56:40 PM] Orlando Shooting: Read Donald Trump's Speech | Time.com With 50 people dead and perhaps more ultimately and dozens more wounded, we cannot afford to talk around issues anymore. We have to address these issues head-on. I called for a ban after San Bernardino and was met with great scorn and anger but now many years and I have to say many years but many are saying that I was right to do so. And although the pause is temporary we must find out what is going on. We have to do it. It will be lifted -- this ban -- when and as a nation we're in a position to properly and perfectly screen these people coming into our country. They're pouring in and we don't know what we're doing. The immigration laws of the United States give the president powers to suspend entry into the country of any class of persons. Now, any class -- it really is determined and to be determined by the president for the interests of the United States. And it's as he or she deems appropriate. Hopefully it's he in this case. (APPLAUSE) Thank you. I will use this power to protect the American people. When I'm elected I will suspend immigration from areas of the world where there's a proven history of terrorism against the United States, Europe or our allies until we fully understand how to end these threats. After a full ... (APPLAUSE) Thank you. And by the way we have no choice. After a full and partial and long -- really long overdue security assessment we will develop a responsible immigration policy that serves the interests and values of America. (APPLAUSE) We cannot continue to allow thousands upon thousands of people to pour into our country many of whom have the same thought process as this savage killer. Many of the principles of radical Islam are incompatible with Western values and institutions. (APPLAUSE) Remember this, radical Islam is anti-woman, anti-gay and anti- American. (APPLAUSE) I refuse to allow America to become a place where gay people, Christian people, Jewish people are targets of persecution and intimation by radical Islamic preachers of hate and violence. (APPLAUSE) This is not just a national security issue. It's a quality of life issue. If we want to protect the quality of life for all Americans -- women and children, gay and straight, Jews and Christians and all people then we need to tell the truth about radical Islam and we need to do it now. (APPLAUSE) We need to tell the truth also about how radical Islam is coming to our shores. And it's coming ... (APPLAUSE) With these people, folks, it's coming. We're importing radical Islamic terrorism into the West through a failed immigration system and through an intelligence community held back by our president. Even our own FBI director has admitted that we cannot effectively check the backgrounds of people we're letting into America. All of the September 11th hijackists were issued visas. Large numbers of Somali refugees in Minnesota have tried to join ISIS. http://time.com/4367120/orlando-shooting-donald-trump-transcript/[1/29/2017 7:56:40 PM] Orlando Shooting: Read Donald Trump's Speech | Time.com The Boston bombers came here through political asylum. The male shooter in San Bernardino again whose name I will not mention was the child of immigrants from Pakistan and he brought his wife, the other terrorist from Saudi Arabia through another one of our easily exploited visa programs. (APPLAUSE) TRUMP: Immigration from Afghanistan into the United States has increased nearly five fold -five fold in just one year. According to Pew Research, 99 percent of the people in Afghanistan support oppressive sharia law. We admit many more, and that's just the way it is. We admit many more from other countries in the region. And I'll tell you what: They share these oppressive views and values. We want to remain a free and open society. Then, and if we do, then we have to control our borders. We have to control, and we have to control them now, not later. Right now. (APPLAUSE) Thank you. Yet Hillary Clinton, for months, and despite so many attacks, repeatedly refused to even say the words radical Islam until I challenged her yesterday. And, guess what, she will probably say them. She sort of has said them, but let's see what happens. She really has no choice, but she doesn't want to. However, she's really been forced, and she has been forced to say these words. She supports, and the reason is, she supports so much of what is wrong, and what is wrong with this country, and what's going wrong with our country and our borders. She has no clue, in my opinion, what radical Islam is and she won't speak honestly about it if she does, in fact, know. She's in total denial, and her continuing reluctance to ever name the enemy broadcasts weakness across the entire world -- true weakness. I don't know if you know this, but just a few weeks before San Bernardino, the slaughter, that's all it was was a slaughter, Hillary Clinton explained her refusal to say the words "radical Islam." Here is what she said, exact quote, "Muslims are peaceful and tolerant people, and have nothing whatsoever to do with terrorism." That is Hillary Clinton. So, she says the solution is to ban guns. They tried that in France which has among the toughest gun laws anywhere in the world, and 130 people were brutally murdered by Islamic terrorists in cold blood. Her plan is to disarm law abiding Americans, abolishing the Second Amendment, and leaving only the bad guys and terrorists with guns. No good. Not going to happen, folks. Not going to happen. Not going to happen. (APPLAUSE) Thank you. She wants to take away American's guns and then admit the very people who want to slaughter us. Let them come into the country, we don't have guns. Let them come in, let them have all the fun they want. I will be meeting with the NRA, which has given me their earliest endorsement in a presidential race, to discuss how to ensure Americans have the means to protect themselves in this age of terror. I will be always defending the Second Amendment. http://time.com/4367120/orlando-shooting-donald-trump-transcript/[1/29/2017 7:56:40 PM] Orlando Shooting: Read Donald Trump's Speech | Time.com (APPLAUSE) Thank you. Thank you. The bottom line is that Hillary supports policies that bring the threat of radical Islam into American and allow it to grow oversees, and it is growing. In fact, Hillary Clinton's catastrophic immigration plan will bring vastly more radical Islamic immigration into this country, threatening not only our society but our entire way of life. When it comes to radical Islamic terrorism, ignorance is not bliss. It's deadly -- totally deadly. The Obama administration, with the support of Hillary Clinton and others, has also damaged our security by restraining our intelligence gathering and we have, just, no intelligence gathering information. We need this information so badly, and he stopped it. We don't have the support. We don't have the support of the law enforcement system because Obama is not letting them do their job. They are not being allowed to do their job. And, they can do it well -- better than anybody. We need a new leader. We need a new leader fast. (APPLAUSE) TRUMP: Thank you. They have put political correctness above common sense, above your safety, and above all else. I refuse to be politically correct. (APPLAUSE) I want to do the right thing. I want to straighten things out and I want to make America great again. (APPLAUSE) The days of deadly ignorance will end, and they will end soon if I'm elected. As president I will give our intelligence community, law enforcement and military the tools they need to prevent terrorist attacks. They don't have those tools now. (APPLAUSE) We need an intelligence gathering system second to none. Second to none. That includes better cooperation between state, local and federal officials, and with our allies, very importantly. I will have an Attorney General, a Director of National Intelligence and a Secretary of Defense who'll know how to fight a war on radical Islamic terrorism. (APPLAUSE) And they will have the support that they need to get the job done right, not like it is right now. It's not right. (APPLAUSE) We also must ensure the American people are provided the information they need to understand the threat. The Senate subcommittee on Immigration has already identified hundreds of immigrants charged with terrorist activities inside the United States since September 11th. Nearly a year ago, the Senate Subcommittee asked President Obama's Department of Justice, State and Homeland Security to provide the immigration history of all terrorists inside the United States. These Departments refused to comply. Nobody even knows why. They refused to comply. President Obama must release the full and complete immigration histories of all individuals http://time.com/4367120/orlando-shooting-donald-trump-transcript/[1/29/2017 7:56:40 PM] Orlando Shooting: Read Donald Trump's Speech | Time.com implicated in terrorist activities of any kind since September 11th. So important. The public has a right to know how these people got here, how they came on to this great land, why are they here? (APPLAUSE) We have to screen applicants to know whether they are affiliated with or supporting radical groups and beliefs, very simple. We have to control the amount of future immigration into this country and we have to prevent large pockets of radicalization from forming inside America. Not complicated. (APPLAUSE) Every - and just think of this. Take a look. Every single event, even a single individual can be devastating, and all you have to do is take a look at what happened in Orlando and what happened in other cases. Just a single event. And just one person. Can you imagine what they'll do in large groups, which we're allowing now to come here. Truly our President doesn't know what he's doing. He's failed us and he's failed us badly. Under his leadership this situation will not get any better, it will only get worse. And I've been saying that for a long time. Each year the United States permanently admits 100,000 immigrants from the Middle East and many more from Muslim countries outside of the Middle East. Our government has been admitting ever- growing numbers, year after year, without any effective plan for our own security. In fact, Clinton's State Department was in charge of admissions and the admissions process for people applying to enter from overseas. Having learned nothing from these attacks, she now plans to massively increase admissions without a screening plan including a 500 percent increase in Syrian refugees coming into our country. Tell me, tell me - how stupid is that? This could be a better, bigger, more horrible version than the legendary Trojan Horse ever was. Altogether, under the Clinton plan, you'd be admitting hundreds of thousands of refugees from the Middle East with no system to vet them, or to prevent the radicalization of the children and their children. Not only their children, by the way, they're trying to take over our children and convince them how wonderful ISIS is and how wonderful Islam is and we don't know what's happening. TRUMP: The burden is on Hillary Clinton to tell us why she believes immigration from these dangerous countries should be increased without any effective system to really to screen. We're not screening people. So why don't we have an effective screening system? We don't. We're being laughed at all over the world. The burden is on Hillary Clinton to tell us why we should admit anyone into our country who supports violence of any kind against gay and lesbian Americans. The burden is on Hillary Clinton to tell us how she will pay for it, her plan will cost hundreds of billions of dollars long term. Wouldn't this be money better spent rebuilding America for our current population including the many poor people already living here. We have cities, we have inner cities... (APPLAUSE) We have poverty all over and this is how we're spending billions of dollars. We have to stop the tremendous flow of Syrian refugees into the United States. We don't know who they are, they http://time.com/4367120/orlando-shooting-donald-trump-transcript/[1/29/2017 7:56:40 PM] Orlando Shooting: Read Donald Trump's Speech | Time.com have no documentation and we don't know what they're planning and we won't unless we have proper supervisor and proper leadership in which case they're out of here. What I want... (APPLAUSE) What I want is common sense. I want a mainstream immigration policy that promotes American values. That's a choice I put before the American people. A mainstream immigration policy designed to benefit America or Hillary Clinton's radical immigration policy designed to benefit politically correct special interests. That's all it is. We've got to get smart and tough and vigilant and we've got to do it now because later is too late -- going to be too late for our country. The media talks about home grown terrorism but Islamic radicalism and that's a very, very important term -- a term that the president refuses to use and the networks that nurture it are imports from overseas whether you like it or whether you don't like it. Yes, there are many radicalized people already inside our country as a result of poor policies of the past. But the whole point is that we will be much, much and it will be easier to deal with our current problem if we don't keep on bringing people who add to the problem. And that's what they're doing. We're letting all of these people -- hundreds of thousands of people come in and all they're doing is adding to this incredible problem we have. For instance, the controversial mosque attended by the Boston bombers had at its founder and as its founder an immigrant from overseas charged in an assassination plot. This shooter and amazingly in Orlando was the child of an immigrant father who supported one of the most repressive regimes on earth. Why would we admit people who support violent hatred? Hillary Clinton can never claim to be a friend of the gay community as long as she continues to support immigration policies that bring Islamic extremists to our country and who suppress women, gays and anyone who doesn't share their views or values. (APPLAUSE) She can't have it both ways. She can't claim to be supportive of these communities while trying to increase the number of people coming in who want to oppress these same communities. How does this kind of immigration make our lives better? How does this kind of immigration make our country better? Why does Hillary Clinton want to bring people in in vast numbers who reject our values? Why? Explain. Ask yourself who is really the friend of women and the LGBT community, Donald Trump with actions or Hillary Clinton with her words? TRUMP: I will tell you who the better friend is and some day I believe that will be proven out bigly (ph). (APPLAUSE) And by the way the LGBT community is just -- what's happened to them is just so sad and to be thinking about where their policies are currently with this administration is a disgrace to that community, I will tell you right now. Clinton wants to allow radical Islamic terrorists to pour into our country. They enslave women, and they murder gays. I don't want them in our country. (APPLAUSE) http://time.com/4367120/orlando-shooting-donald-trump-transcript/[1/29/2017 7:56:40 PM] Orlando Shooting: Read Donald Trump's Speech | Time.com Immigration is a privilege, and we should not let anyone into this country who doesn't support our communities. All of our communities, every single one of them. Americans already admitted four times more immigrants than any country on Earth, anybody in the world. Four times more. At least, because we don't even know who's coming in. And we continue to admit millions more with no real checks or scrutiny. Not surprisingly, wages for our workers haven't budged. In almost 20 years. You wonder why we get the crowds, you wonder why we get this tremendous support, you wonder why I've gotten more votes than any Republican in any primary in the history of the Republican Party? Take a look at that. Take a look at your security, take a look at the wages. For 18 years they've been stagnant, they've even gone down. So whether it's a matter of national security, or financial security, we can't afford to keep on going like this. Cannot afford it. We owe $19 trillion in debt. And no longer have any options. Our communities from all backgrounds are ready for some relief. This is not an act of offense against anyone. It's really an act of defense. I want us all, all of us, to work together. We have to form a partnership, with our Muslim communities. We have Muslim communities in this country that are great, and we have to form that partnership. Now, the Muslim community, so important. They have to work with us. They have to cooperate with law enforcement and turn in the people who they know are bad. They know it. And they have to do it, and they have to do it forthwith. I want to fix our schools. I want to fix our bridges. And our jobs market, we're going to have it rocket again, we're going to make great trade deals. But I want every American to succeed including Muslims. But the Muslims have to work with us. They have to work with us. They know what's going on. They know that he was bad. They knew the people in San Bernardino were bad. But you know what? They didn't turn them in. And you know what? We had death, and destruction. Hillary Clinton wants to empty out the Treasury to bring people into the country that include individuals who preach hate against our citizens. I want to protect our citizens, all of our citizens. The terrorist attack on Pulse nightclub demands a full and complete investigation into every single aspect of the assault. In San Bernardino, as an example, people who knew what was going on, they knew exactly, but they used the excuse of racial profiling for not reporting it. They said oh, "We thought so but we didn't want to use racial profiling." Which was probably an excuse given to them by their lawyer, so they don't get in trouble. We need to know what the killer discussed with his relatives, parents, friends and associates. We need to know if he was affiliated with any radical mosques or radical activists and what, if any, is their immigration status. We have to know, and we have to know fast. We need to know if he traveled anywhere and who he traveled with. We need to know, and we need to make sure, every single last person involved in this plan, including anyone who knew something but didn't tell us, is brought to justice, so when people know what's going on and they don't tell us, and we have an attack, and people die, these people have to have consequences. Big consequences. (APPLAUSE) America must do more -- much more -- to protect its citizens, especially people who are potential http://time.com/4367120/orlando-shooting-donald-trump-transcript/[1/29/2017 7:56:40 PM] Orlando Shooting: Read Donald Trump's Speech | Time.com victims of crimes based on their backgrounds or sexual orientation, as you just saw in Orlando. TRUMP: It also means we must change our foreign policy. The decision to overthrow the regime in Libya, then pushing for the overthrow of the regime in Syria, among other things, without plans for the day after, have created space for ISIS to expand and grow like nobody has ever seen before. These actions, along with our disastrous Iran deal, have also reduced our ability to work in partnership with our Muslim allies in the region. That is why our new goal must be to defeat Islamic terrorism not nation building. No more nation building. It's never going to work. And by the way we've spent almost $5 trillion over the years on trying to nation build in the Middle East and it has been complete and total disaster. We're further away now than we were 15 years ago. For instance, the last major NATO mission was Hillary Clinton's war in Libya. That mission helped to unleash ISIS on a new continent. I've said NATO need to change its focus and stop terrorism. We have to focus on terrorism and we have to stop terrorism. Since I've raised that criticism and it's OK. I've gotten no credit for it but these are minor details -- NATO has since announced a new initiative -- front page of the Wall Street Journal four days ago focused on just that. America must unite the whole civilized world in the fight against Islamic terrorism. (APPLAUSE) Pretty much like we did with communism during the Cold War. We tried it President Obama's way, doesn't work. He gave the world his apology tour. We got ISIS and many other problems in return. That's what we got. Remember the famous apology tour. We're sorry for everything. I'd like to conclude my remarks today by again expressing our solitarily with the people of Orlando who have come under this horrific attack. When I'm president I pledge to protect and defend all Americans who live inside our borders. Wherever they come from, wherever they were born, I don't care. All Americans living here and following our laws not other laws will be protected. (APPLAUSE) Thank you. Thank you. We're going to be tough and we're going to be smart and we're going to do it right. America will be a tolerant and open society. America will also be a safe society. We will protect our borders at home. We will defeat ISIS overseas. We have no choice. We will ensure every parent can raise their children in peace and safety. We will make America rich again. We will make America safe again. We will make America great again. Thank you. Thank you very much. Thank you very much. (APPLAUSE) Thank you. Thank you very much, everybody. Appreciate it. Thank you. by SPONSORED STORIES http://time.com/4367120/orlando-shooting-donald-trump-transcript/[1/29/2017 7:56:40 PM]

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