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)
<![CDATA[
Index of Exhibits
Third Amended Complaint
(In order of Citation)
Docket No.
ECF 194-4
3d Am. Compl.
Ex. A
ECF 194-5
3d Am. Compl.
Ex. B
ECF 194-6
3d Am. Compl.
Ex. C
ECF 194-7
3d Am. Compl.
Ex. D
ECF 118-2
Page Nos.
9
2-22
2
2-4
Source
Time
Whitehouse.gov
U.S. Census.
American
Community Survey
Washington Times
2
N.Y. Times
ECF 118-2
7
UC Office of the
President
ECF 118-2
12-13
ECF 118-2
18
ECF 118-2
21
Donald J. Trump
Campaign
The Washington Post
ECF 118-2
28
Politico
ECF 118-2
48
The American
Presidency Project
ECF 118-2
65
ECF 118-2
84
Lt. Gen. Flynn
Twitter Account
(@GenFlynn)
CNN Television
Broadcast
ECF 118-2
104
Politifact
Time
Title
Date
President Trump’s Response to the Mar. 16, 2017
Travel Ban Ruling: It ‘Makes Us
Look Weak’
Enhancing Vetting Capabilities
Sep. 27, 2017
and Processes for Detecting
Attempted Entry into the United
States by Terrorists or Other
Public-Safety Threats
Chart of Impacted Immigrants in
Oct. 10, 2017
Washington
The Latest: Protest at SeattleTacoma airport continues
Jan. 29, 2017
After Travel Ban, Interest in Trips
to U.S. Declines, N.Y. Times
UC Statement and preliminary
guidance on revised executive
order, UC Office of the President
Donald Trump says if you’re from
Syria and a Christian you can’t
come to the U.S. as a refugee
Donald J. Trump Statement on
Preventing Muslim Immigration
Donald Trump says he is not
bothered by comparisons to Hitler
Trump not bothered by
comparisons to Hitler
Presidential Candidates Debates:
Republican Debate in North
Charleston, South Carolina
Fear of Muslims is RATIONAL:
please forward this to others: the
truth fears no questions…
Anderson Cooper 360 Degrees:
Exclusive Interview with Donald
Trump
Read Donald Trump’s Speech on
the Orlando Shooting
Feb. 20, 2017
Mar. 6, 2017
July 11, 2015
Dec. 7, 2015
Dec. 8, 2015
Dec. 8, 2015
Jan. 14, 2016
Feb. 26, 2016
Mar. 9, 2016
June 13, 2016
ECF 118-2
121-122
CBS News
ECF 118-2
130, 135
NBC News
ECF 118-2
168
The American
Presidency Project
ECF 118-2
196
ABC News
ECF 118-2
201
Christian
Broadcasting
Network
ECF 118-2
204
The Washington Post
ECF 118-2
209
ECF 118-2
211
United States
Department of State
United States
Department of State
ECF 118-2
213
U.S. Embassy in Iraq
ECF 118-2
216
Reuters
ECF 118-2
221
U.S. Department of
Homeland Security
ECF 118-2
223
U.S. Customs and
Border Protection
ECF 118-2
226
U.S. Customs and
Border Protection
ECF 118-2
230
Whitehouse.gov
ECF 118-2
233
The Washington Post
60 Minutes: Trump-Pence
Republican Ticket
Meet the Press – July 24, 2016
July 11, 2016
Presidential Debates: Presidential
Debate at Washington University
in St. Louis, Missouri
ABC News Anchor David Muir
Interviews President Trump
Brody File Exclusive: President
Trump Says Persecuted Christians
Will Be Given Priority As
Refugees
Trump Signs order limiting
refugee entry, says he will
prioritize Christian refugees
Edward J. Ramotowski letter
Oct. 9, 2016
Online notice advising immigrant
visa applicants that visa issuance
had been suspended and visa
interviews cancelled
2017 Statements and Press
Releases: Executive Order
Affecting Visa Travel to the United
States
Green card holders will need
additional screening: White House
Statement by Secretary John Kelly
on the Entry of Lawful Permanent
Residents into the United States
Protecting the Nation from
Foreign Terrorist Entry into the
United States
Jan. 28, 2017
Q&A for Executive Order:
Protecting the Nation from
Foreign Terrorist Entry into the
United States
President Donald J. Trump
Statement Regarding Recent
Executive Order Concerning
Extreme Vetting
Trump asked for a ‘Muslim Ban,’
Giuliani says – and ordered a
commission to do it ‘legally
Feb. 2, 2017
July 24, 2016
Jan. 25, 2017
Jan. 27, 2017
Jan. 27, 2017
Jan. 27, 2017
Jan. 28, 2017
Jan. 29, 2017
Jan. 29, 2017
Jan. 31, 2017
Jan. 29, 2017
Jan. 29, 2017
ECF 118-2
239
Donald J. Trump
If the ban were announced with a
Twitter
one week notice, the ‘bad’ would
(@realDonaldTrump) rush into our country during that
week
Jan. 30, 2017
ECF 118-2
242
Associated Press
AP Exclusive: DHS report
disputes threat from banned
nations
Feb. 24, 2017
ECF 118-2
255
U.S. Department of
Homeland Security
Citizenship Likely an Unreliable
Unknown
Indicator of Terrorist Threat to the
United States Draft Report
ECF 118-2
259-267
U.S. Department of
Homeland Security
Intelligence Assessment: Most
Mar. 1, 2017
Foreign-born, US-based Violent
Extremists Radicalized after
Entering Homeland; Opportunities
for Tailored CVE Programs Exist
ECF 118-2
269
Cato Institute Blog
Little National Security Benefit to
Trump’s Executive Order on
Immigration
Jan. 25, 2017
ECF 118-2
273
N.Y. Times
Immigration Ban Is Unlikely to
Reduce Terrorist Threat, Experts
Say
Jan. 28, 2017
ECF 118-2
280
ABC News
60,000 Visas Revoked Since
Immigration Executive Order
Signed: State Department
Feb. 3, 2017
ECF 118-2
286-287
The Washington Post
Donald Trump’s combative,
grievance-filled news conference,
annotated,
Feb. 16, 2017
ECF 118-2
325
Fox News
ECF 118-2
366-367
Whitehouse.gov
ECF 118-2
376-395
Department of
Homeland Security
Miller: New order will be
Feb. 21, 2017
responsive to judicial ruling; Rep.
Don DeSantis: Congress has
gotten off to a slow start
Press Briefing by Press Secretary Feb. 27, 2017
Sean Spicer
Department of Homeland Security, Mar. 6, 2017
Q&A: Protecting the Nation from
Foreign Terrorist Entry to the
United States
ECF 118-2
399
Whitehouse.gov
Memorandum for the Secretary of
State, the Attorney General, the
Secretary of Homeland Security
ECF 118-2
404
The Washington Post
Revised executive order bans
Mar. 6, 2017
travelers from six Muslim-majority
countries from getting visas
ECF 118-2
412
Whitehouse.gov
Press Briefing by Press Secretary
Sean Spicer
Mar. 7, 2017
ECF 118-2
452
N.Y. Times
Letter from Foreign Policy
Experts on Travel Ban, N.Y. Times
Mar. 10, 2017
Trump on the Future of Proposed
Muslim ban, registry; ‘You know
my plans,’
We need to be smart, vigilant and
tough. We need the courts to give
us back our rights. We need the
Travel Ban as an extra level of
safety!
The Justice Dept. should have
stayed with the original Travel
Ban, not the watered down,
politically correct version they
submitted to S.C.
People, the lawyers and the courts
can call it whatever they want, but
I am calling it what we need and
what it is a TRAVEL BAN
Effective Date in Executive Order
13780
Dec. 22, 2016
U.S. lays out criteria for visa
applicants from six Muslim
nations
Table 3: Persons Obtaining
Lawful Permanent Resident Status
By Region and Country of Birth:
Fiscal Years 2013 to 2015
June 28, 2017
Table 26: Nonimmigrant
Admissions (I-94 Only) By Region
and Country of Citizenship: Fiscal
Years 2013 to 2015
Dec. 15, 2016
ECF 194 -8
3d Am. Compl.
Ex. E
ECF 194-9
3d Am. Compl.
Ex. F
2
The Washington Post
2
Donald J. Trump
Twitter (@real
DonaldTrump)
ECF 194-10
3d Am. Compl.
Ex. G
2
Donald J. Trump
Twitter (@real
DonaldTrump)
ECF 194-11
3d Am. Compl.
Ex. H
2
Donald J. Trump
Twitter (@real
DonaldTrump)
ECF 194-12
3d Am. Compl.
Ex. I
ECF 194-13
3d Am. Compl.
Ex. J
ECF 194-14
3d Am. Compl.
Ex. K
3
Whitehouse.gov
ECF 194-15
3d Am. Compl.
Ex. L
2, 5
Reuters
2-12
U.S. Department of
Homeland Security
2-12
U.S. Department of
Homeland Security
Mar. 6, 2017
June 3, 2017
June 5, 2017
June 5, 2017
June 14, 2017
Dec. 15, 2016
ECF 194-16
3d Am. Compl.
Ex. M
ECF 194-17
3d Am. Compl.
Ex. N
2-39
2-3
United States
Government
Accountability Office
USA Today
DHS Should Take Steps to Ensure
Timeliness of Information Needed
to Protect U.S. National Security
Preventing Muslim Immigration’
Statement Disappears from
Trump’s Campaign Sit
May 5, 2016
May 8, 2017
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