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 E

Trump on the future of proposed Muslim ban, registry: ‘You know my plans’ - The Wash... Page 1 of 4

Post Politics

Trump on the future of
proposed Muslim ban,
registry: ‘You know my
plans’
By Abby Phillip and Abigail Hauslohner December 22, 2016

President-elect Donald Trump on Wednesday appeared to stand by his plans to establish a registry for
Muslims and temporarily ban Muslim immigrants from the United States.
Speaking outside his Mar-a-Lago resort in Florida, Trump did not walk back the proposals after he was
asked by a reporter whether he was rethinking or reevaluating them in the wake of a fresh terrorist attack in
Berlin.
“You know my plans all along,” Trump said.
He went on to add that the attack on a Berlin Christmas market, which was claimed by the Islamic State,
had vindicated him. German authorities said a 24-year-old Tunisian migrant, who they said has ties to
Islamist extremists, was responsible for the attack, which killed 12 people and injured dozens. The suspect
was later killed in a shootout with Italian police in Milan.
“I’ve been proven to be right. One-hundred-percent correct,” Trump said. “What’s happening is
disgraceful.”
Trump has long called for a temporary ban on Muslims entering the United States and has expressed
openness to a registry of Muslims already in the country.

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A year ago, in a statement, Trump said he wanted a “total and complete shutdown of Muslims entering the
United States until our country's representatives can figure out what is going on.”
The proposal was sharply criticized by Republicans and Democrats alike. And later, Trump and his senior
aides and surrogates sought to soften the proposal, suggesting that Trump would support a ban on
immigration only from countries that had been "compromised by terrorism."
In interviews, Trump has characterized his position as an expansion, not a contraction of his proposal.
But given an opportunity on Wednesday to clarify his remarks, Trump suggested that his plans stood as he
had articulated them early in his campaign. The statement proposing a “complete” shutdown of Muslim
immigration remains on Trump's website. And Trump has not clarified how exactly he would address the
issue as president.
On Thursday, Kellyanne Conway, a senior Trump aide, said that he would not seek an immigration ban
based on religion. Asked repeatedly on CNN whether Trump supports a ban on Muslims, Conway said,
"That in and of itself? No."
"You're going back to over a year ago and what he said about the ban versus what he said later about it when
he made it much more specific and talked about countries where we know they have a higher propensity of
training and exporting and in some cases harboring terrorists," Conway said.
The issue is the source of anxiety for Muslims and advocates across the United States.
“I think that at this point, we don’t quite know what he means when he says Muslim ban,” said Faiza Patel,
who co-directs the liberty and national security program at the Brennan Center for Justice at New York
University’s law school. “A lot of people have interpreted that as he intends to revive the NSEERS system,
which was made inoperational a few years ago,” she added, referring to the registry system developed by
current Trump adviser Kris Kobach, which civil rights groups and security experts said unfairly targeted
Muslims and provided few security benefits.
Jaime “Mujahid” Fletcher, who founded IslamInSpanish, a center for Muslim Latinos in Houston, said the
issue of a registry came up last week when he and other area Muslim leaders met with FBI agents in
Houston.

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“We met with the head of the FBI in their office,” Fletcher said. “It was all about this new administration
coming in: What can we expect from them? Is this going to be a change in the way they approach our
community?” He said the meeting was reassuring.
Muslim leaders said they felt that a registry would take America backward and the FBI seemed to agree.
“They didn’t foresee us going back to the past. They were reassuring. This is the way they see it,” Fletcher
said. It was good to hear, he said, but area Muslims are still concerned. “Obviously the community feels
there are orders and commands from higher up, and if those are sent down to a local level, will they act?
And how much of what they think now could change in the future?”
In response to other questions from reporters outside Mar-a-Lago, Trump said that he had last spoken to
President Obama two days ago.
He was also asked about his characterization of the Berlin attack as an attack on Christians.
“ISIS and other Islamist terrorists continually slaughter Christians in their communities and places of
worship as part of their global jihad,” Trump had said in a statement issued after the attack on Monday.
On Wednesday, Trump appeared unfamiliar with the statement issued in his name.
“Who said that?” Trump countered, challenging the reporter. “It’s an attack on humanity. That’s what it is.
An attack on humanity, and it’s got to be stopped.”
This post has been updated.

Abby Phillip is a national political reporter covering the White House for The Washington Post. She
can be reached at [e-mail].  Follow @abbydphillip
Abigail Hauslohner is a national reporter who covers Islam, Arab affairs and America. Before coming
to Washington in 2015, she spent seven years covering war, politics and religion in the Middle East,
and served as the Post’s Cairo bureau chief. She has also covered District politics and government.
 Follow @ahauslohner

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