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

Filing 194

MOTION for Leave to File Third Amended Complaint, filed by Plaintiffs Commonwealth of Massachusetts, State of California, State of Maryland, State of New York, State of Washington, Intervenor Plaintiff State of Oregon. (Attachments: # 1 Complaint 3rd Amended, # 2 Index of Exhibits, # 3 Index of Declarations, # 4 Exhibit A, # 5 Exhibit B, # 6 Exhibit C, # 7 Exhibit D, # 8 Exhibit E, # 9 Exhibit F, # 10 Exhibit G, # 11 Exhibit H, # 12 Exhibit I, # 13 Exhibit J, # 14 Exhibit K, # 15 Exhibit L, # 16 Exhibit M, # 17 Exhibit N, # 18 Decl of Joint Former National Security Officials, # 19 Decl of Nima Ala, # 20 2nd Decl of Rabyaah Althaibani, # 21 Decl of Alireza Ayoubi, # 22 Decl of Shervin Beygi, # 23 Decl of Bahareh Bina, # 24 Decl of Ethan Devenport, # 25 Decl of Yasaman Esmaili, # 26 Decl of Mahdi Hajiaghayi, # 27 Decl of Mojdeh Jalali Heravi, # 28 Decl of Vahid Jazayeri, # 29 Decl of Mohammad Shafiei Khadem, # 30 Decl of Ahmad Moghaddam, # 31 Decl of Younes Nouri, # 32 Decl of Proshat Parsimoghadam, # 33 Decl of Emad Soroush, # 34 Decl of Tannaz Sattari Tabrizi, # 35 Decl of Seyed Danial Vaezi, # 36 Decl of Banafsheh Samareh Abolhasani, # 37 Decl of Armin Alaghi, # 38 Decl of Pegah Jalali Asheghabadi, # 39 3rd Decl of Rovy Branon, # 40 5th Decl of Asif Chaudhry, # 41 Decl of Maryam Dadkhahan, # 42 Decl of Jason Detwiler, # 43 2nd Decl of David Eaton, # 44 Decl of Kiana Ehsani, # 45 Decl of Ali Farhadi, # 46 Decl of Hoda Farhadi, # 47 Decl of Maryam Fayazi, # 48 Decl of Mohammad Ghaedi, # 49 Decl of Anne Greenbaum, # 50 Decl of Hannaneh Hajishirzi, # 51 2nd Decl of Deirdre Heatwole, # 52 Decl of Parisa Hosseinzadeh, # 53 Decl of Adam Mokhalalati, # 54 Decl of Shima Nofallah, # 55 4th Decl of Jeffrey Riedinger, # 56 Decl of Solmaz Shakerifard, # 57 Decl of Khadijeh Sheikhan, # 58 Decl of Ali Shojaie, # 59 Decl of Hema Yoganarasimhan, # 60 2nd Decl of Kathy Oline, # 61 2nd Decl of Dave Soike, # 62 2nd Decl of Rita Zawaideh, # 63 2nd Decl of Mitra Akhtari, # 64 2nd Decl of Melanie de Leon, # 65 Decl of Payam Fotouhiyehpour, # 66 2nd Decl of Marc Overbeck, # 67 2nd Decl of Sana Parsian, # 68 Decl of Sahar Z. Zangenah, # 69 2nd Decl of Dennis Galvan, # 70 Proposed Order) Noting Date 10/16/2017, (Melody, Colleen)

Third Amended
Complaint
Exhibit N

Donald Trump's Muslim immigration statement gone from campaign site

Page 1 of 2

'Preventing Muslim immigration' statement
disappears from Trump's campaign site
Jessica Estepa (http://www.usatoday.com/staff/29685/jessica-estepa/), USA TODAY

Published 3:32 p.m. ET May 8, 2017 | Updated 6:03 a.m. ET May 9, 2017

On Monday morning, President Trump's campaign website featured his December 2015
statement about "preventing Muslim immigration."
Later that afternoon, it did not.
The deletion of the statement appeared to come after Cecilia Vega of ABC News asked at
Monday's White House press briefing about the statement: "If this White House is no longer
calling this a Muslim ban as it did initially, why does the president's website still explicitly call
for 'preventing Muslim immigration'?"
Trump spokesman Sean Spicer replied that he wasn't aware of what was on dthe campaign's
website and referred questions about the statement to campaign staff.
"I know how we've talked about this from the first day of this administration: as a travel ban
that's in this country's national security interests, as to make sure that people who are coming
in here, are coming in here with the right motive and reason," he said. "We've been very
consistent."

The statement first appeared on Trump's campaign website on Dec. 7, 2015, less than a
week after a Muslim couple killed 14 people and injured 22 others in a mass shooting in San
Bernardino. Then a candidate in the GOP primary season, Trump stood by his statement.
And while it was controversial, it clearly didn't stop Trump's momentum.
Why did it come up now? The president's second attempt at a travel ban on six Muslim
majority countries began on Monday a new round of federal court hearings
(/story/news/politics/2017/05/07/trumps-immigration-travel-ban-faces-familiar-foe-appealscourts-trump/101334230/). The statement was brought up during proceedings in Richmond.
For the record, here's the full statement from Trump's site (courtesy of the Internet Archive
(https://web.archive.org/web/*/https://www.donaldjtrump.com/press-releases/donald-j.-trumpstatement-on-preventing-muslim-immigration)):
Donald J. Trump is calling for a total and complete shutdown of Muslims entering the United
States until our country's representatives can figure out what is going on. According to Pew
Research, among others, there is great hatred towards Americans by large segments of the
Muslim population. Most recently, a poll from the Center for Security Policy released data
showing "25% of those polled agreed that violence against Americans here in the United
States is justified as a part of the global jihad" and 51% of those polled, "agreed that Muslims

https://www.usatoday.com/story/news/politics/onpolitics/2017/05/08/preventing-muslim-immigration-st... 10/9/2017

Donald Trump's Muslim immigration statement gone from campaign site

Page 2 of 2

in America should have the choice of being governed according to Shariah." Shariah
authorizes such atrocities as murder against non-believers who won't convert, beheadings
and more unthinkable acts that pose great harm to Americans, especially women.
Mr. Trump stated, "Without looking at the various polling data, it is obvious to anybody the
hatred is beyond comprehension. Where this hatred comes from and why we will have to
determine. 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. If I win the election for
President, we are going to Make America Great Again."

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