PETITION TO THE CONGRESS OF THE UNITED STATES REQUESTING THAT PRESIDENT TRUMP BE CENSURED

PETITION TO THE CONGRESS OF THE UNITED STATES REQUESTING THAT PRESIDENT TRUMP BE CENSURED
Why this petition matters

PETITION TO THE CONGRESS OF THE UNITED STATES FOR THE REDRESS OF GRIEVANCES UNDER THE FIRST AMENDMENT REQUESTING THAT PRESIDENT TRUMP BE CENSURED
The First Amendment to the U.S. Constitution gives every citizen the right to petition Congress "for the Redress of Grievances." And the Senate and House of Representatives have the power to "Censure" (condemn) a sitting President for misconduct.
From the time Donald Trump assumed the Presidency, he has been engaging in continuing acts of misconduct requiring that he be Censured by both the Senate and House. While some of Trump's actions may be sufficient to support his impeachment, we believe that at a minimum they require his immediate Censure by Congress.
Actions for which he must be Censured include:
1. Firing FBI Director James Comey for his refusal to terminate the FBI's investigation of Russian interference in the 2016 Presidential election and his investigation of former National Security Advisor Michael Flynn;
2. Disclosing classified information to Russian representatives in the Oval Office on May 10, 2017;
3. Disgracing the Office of President by repeatedly and knowingly making false statements to the press and public;
4. Wrongfully admonishing Attorney General Sessions for recusing himself from the Russian election interference investigation;
5. Continuing to receive profits and Emoluments from foreign governments in violation of Article 1, Section 10 of the Constitution;
6. Ridiculing women on the basis of their looks and insinuating that they lack intelligence;
7. Withdrawing from the Paris climate accords;
8. Refusing to release his income tax returns;
9. Defending the improper effort by his son, son-in-law and Campaign Chairman to obtain damaging information from Russian sources about Hillary Clinton.
10. Encouraging police misconduct;
11. Adopting an unlawful immigration ban;
12. Adopting an unlawful ban on transgender people serving in the military;
13. Describing some violent racist protesters in Charlottesville as "including some very nice people";
14. Abusing the Pardon Power by pardoning flagrant law violator, Joe Arpaio;
15. Callously and cruelly withdrawing the protections of DACA from 800,000 "Dreamers."
16. Recklessly and crudely urging the owners of NFL franchises to fire players who non-violently and silently protest discrimination prior to games;
17. Recklessly threatening to “totally destroy” North Korea in violation of international law;
18. Attacking the Mayor of San Juan, Puerto Rico, for seeking additional federal assistance in connection with the Hurricane Maria humanitarian crisis;
19. Ending ACA subsidies in the billions by Executive Order which will deprive low income citizens of desperately needed health care;
20. Interfering with due process and the due administration of law by urging the Justice Department to prosecute Trump’s political opponents and adversaries, and urging capital punishment of alleged criminals before trial.
21. Publishing false and inflammatory right-wing British videos allegedly depicting Muslims engaging in violence;
22. Attacking the integrity and efficiency of the FBI and lamenting the results upon the life of General Michael Flynn from his guilty plea to a federal felony;
23. Endorsing and campaigning for Roy Moore, a racist Republican candidate for the U.S. Senate credibly accused by several Alabama women of sexually assaulting them when he was in his thirties and they were teenagers;
24. Withdrawing millions of acres of federal land from protection from mining and development;
25. Uttering a racial slur against Senator Elizabeth Warren and all Native Americans;
26. Declaring in a sexist manner that Senator Kirsten Gillibrand had come to his business office “begging” for political contributions and that she “would do anything for them.”
27. Choosing multiple unfit and dangerous federal judicial nominees for lifetime appointments, including Brett Talley who has never tried a case in court and received an unqualified ranking by the non-partisan American Bar Association and Jeff Mateer who has previously described transgender youth as part of "Satan's plan”.
28. Claiming on December 28, 2017, that he had an “absolute right to do what I want to do with the Justice Department,” notwithstanding the well-established independence of the Justice Department from political influence;
29. Again threatening North Korea with the use of his “Nuclear Button,” on January 2,2018;
30. Improperly suggesting that whether he would pardon Michael Flynn would depend on the outcome of the Mueller investigation and Flynn’s testimony;
31. Threatening an author and a publisher for having published a book critical of him, in violation of the prohibition against prior restraints and the First Amendment.
32. Insulted Senator Diane Feinstein for having released publicly a transcript of a witness’s testimony in connection with a Senatorial probe of Russian interference in the 2016 Presidential election;
33. Called our country’s libel laws a “sham” and “disgrace” and said he would consider changing them when in fact they are limited by the First Amendment’s protections of free speech;
34. In a crude and racist manner insulted Haiti and certain African countries, and their citizens, at a meeting with members of Congress on January 11, 2018;
35. By attempting to fire Special Counsel Mueller in June 2017, Trump demonstrated his intent and desire to continue to obstruct justice by interfering with Mueller’s criminal investigation of Trump and his cohorts.
36. Accusing the top leadership of his own administration’s Justice Department and the FBI of favoring Democrats against Republicans at a time when he and other White House officials are under investigation for obstruction of justice and aiding Russia’s interference in the 2016 presidential election, and Trump’s former National Security Advisor has pled guilty to lying to the FBI.
37. Improperly invoking his presidential powers to declassify material, thereby facilitating release of a congressional memo, over the objections of federal law enforcement, designed to undermine the Mueller investigation of Trump’s presidential campaign.
38. Calling Democrats “un-American” and guilty of “treason” during a speech Trump delivered on February 5, 2018, for not applauding his recent State of the Union address.
39. Ignoring and deriding the existence of Russian interference in the 2016 presidential election and failing to take actions to prevent such interference in the future.
40. Praising Communist China’s dictator, Xi Jinping, for having appointed himself “President for life,” declaring, “That’s great!” and that “Maybe we’ll give that a shot someday!” at a political fundraiser in Florida on March 3, 2018.
41. At a political campaign rally on March 10, 2018, near Pittsburgh, Trump insulted and offended California Congresswoman Maxine Waters by describing her as a “low- I.Q. Individual,” and once again referred to Massachusetts Senator Elizabeth Warren in a racially derogatory and insensitive way, as “Pocahontas.”
42. Conspired with Attorney General Sessions to Fire Deputy FBI Director Andrew McCabe, in violation of Sessions’s decision “to recuse [himself] from any existing or future investigations of any matters related in any way to the campaigns for President of the United States,” since McCabe’s discharge related to his investigations of 2016 Presidential election matters.
43. Despite the advice of his national security advisors not to congratulate Russian President Putin for his recent “election” victory, and having imposed sanctions against Russia on March 19, 2018, Trump nevertheless applauded Putin for having been elected as Russia’s President in a phone call with him the next day, which caused Senator John McCain to declare that “an American President does not lead the free world by congratulating dictators on winning sham elections.”
44. Attacking the enforcement of a subpoena of records of his counsel, Michael Cohen, by the FBI, concerning Cohen’s payment of “hush money” to porn Star Stormy Daniels, and other claims of wrongdoing, a “witchhunt” and “an attack upon our country.”
45. By declaring on May 23, 2018, that those NFL players who choose not to stand, and instead kneel during the playing of the National Anthem “maybe shouldn’t be in the country,” President Trump demonstrated his contempt and disrespect for the First Amendment’s protections of free speech and the right of citizens to peacefully protest against wrongs that they perceive in our political system.
46. By claiming that an investigation by federal law enforcement into Russian interference in the 2016 presidential election constituted instead “spying” on his election campaign, President Trump deliberately and falsely distorted the facts, seeking to make it appear that he was the victim of interference with his campaign, when the facts are entirely to the contrary and it is well-established that there was massive Russian interference seeking to assist in his election.
47. By declaring in a dictatorial manner on June 4, 2018, that “the appointment of Special Counsel [Mueller] is totally UNCONSTITUTIONAL!” and that “I [Trump] have the absolute right to PARDON myself,” Trump demonstrated that he believes himself to be above the law, and accountable to no one, in gross derogation of our Constitutional system of government, the separation of powers and the rule of law.
48. Falsely claiming on May 26, 2018, that the Federal Government is required by a “horrible law” (no such law exists) to separate hundreds of children from their parents at U.S. borders and incarcerate and hold them separately from their parents when they enter the United States seeking sanctuary or otherwise, and doing so when the office of the United Nations High Commissioner for Human Rights has declared such actions to violate International Law and the rights of the children involved.
49. Declaring that migrants who enter the United States seeking asylum or otherwise should immediately be expelled from this country without having the hearing that our laws entitle them to receive.
50. Mocking and disparaging the “Thousand Points of Light” program encouraging volunteerism established by President George H. W. Bush.
51. Shamefully and disgracefully giving “aid and comfort” to Russia and Vladimir Putin by declaring in Helsinki, in Putin’s presence, that the Mueller investigation was a “disaster for our country,” and rejecting the conclusion of the entire American intelligence community, the Mueller investigation, and Congress, that the Russian government criminally interfered in the 2016 presidential election in order to to aid Trump’s candidacy.
52. Continuing to attack the press, declaring reporters to be “unpatriotic,” and certain media to be the “enemy of the people,” thereby using his high office to undermine public confidence in a free and independent press.
53. Threatening to shut down the Federal Government if Congress fails to appropriate funds to build a border wall between Mexico and the United States.
54. Interfering in the ongoing criminal trial of Paul Manafort by publicly declaring the Mueller investigation of Manafort to be a “hoax.”
55. Calling upon recused Attorney General Jeff Sessions, on August 1, 2018, to end the Mueller investigation as a continuing “stain upon our country.”
56. Praising his former campaign chairman, Paul Manafort, as a “brave man!” for refusing to “break” under pressure from the Justice Department after Manafort was convicted by a federal jury in Alexandria, Virginia, of eight federal felonies involving tax evasion and bank fraud on August 21, 2018.
57. Attacking Attorney General Jeff Sessions on September 3, 2018, because two Republican members of Congress, Chris Collins of New York, and Duncan Hunter of California, recently were indicted by Federal grand juries on corruption charges. Trump complained to Sessions that the timing of the indictments of Collins and Hunter hurt the two Republicans’ chances of being re-elected in November, 2018.
58. Calling his former White House aide, Omarosa Manigault Newman, “a crazed, crying lowlife,” and “a dog,” after she claimed that Trump suffered from mental deterioration, and declared that he was a racist and anti-women.
59. Having been identified in open court in New York, by his former lawyer and confidante, Michael Cohen, as having directed Cohen to make payments to two women during Trump’s 2016 presidential campaign to keep them from speaking out publicly about affairs they claimed to have had with Trump. Cohen pled guilty to Federal criminal laws before the court and now awaits sentencing.
60. Deciding to revoke the security clearance of former CIA Director John Brennan because Trump claimed that Brennan had engaged in “erratic conduct and behavior.” Many former U.S. national security officials challenged Trump’s decision regarding Brennan as simply being politically motivated because of Brennan’s free speech rights.
61. Falsely claiming on September 13, 2018, that the Democrats we’re responsible for inflating the number of individuals who died as the result of Hurricane Maria in Puerto Rico in September, 2017, to almost 3000, in an effort “to make me [Trump] look as bad as possible.”] It is widely acknowledged that close to 3000 people died in Puerto Rico as the result of the Hurricane.
62. Failing to follow precedent, thereby causing the American Flag not to be flown at half-staff over the White House for the full requisite full week in connection with the death of Senator John McCain, in August, 2018, and otherwise failing fully to honor Senator McCain’s memory upon his death.
63. Participating in corrupt schemes with members of his family to evade inheritance and gift taxes owed to the Federal and New York State governments resulting in his multi-million dollar enrichment while claiming to the voting public to be a self-made billionaire.
64. Mocking Dr. Christine Blasey Ford as a liar for her testimony against Brett Kavanaugh as having sexually assaulted her while they were in high school, after Trump had declared her a “very credible witness” and “a very fine woman,״ whose testimony was “very compelling.”
65. Insulting Stormy Daniels misogynistically, who he paid $130,000 in ״hush money״ not to disclose an affair she allegedly had with Trump, by calling her a “horseface.״
66. Publicly praising Congressman Greg Gianforte (R.-Mont.), at a campaign rally, who pled guilty to an assault charge for having “body-slammed” a reporter for a British newspaper in 2017, and was sentenced by a court for having done so. Trump declared at the campaign rally that “any guy who can do a body slam...he’s my kind of guy.”
67. Threatening national security, as reported by the New York Times on October 25, 2018, by continuing to use his unsecured iPhones in talking with friends, when he has repeatedly been told by federal security agencies that both Russian and Chinese spies are listening in on his conversations.
68. Claiming that the press and media are responsible for the horrible terrorist sending of explosive devices to many Democratic leaders and others who have expressed criticism of him, including the Obamas, Clintons, Holders, Bidens, Robert DiNiro, John Brennan, George Soros, CNN, Maxine Waters, James Clapper, and others. The fact is that It was Trump whose extremist comments, beginning prior to the time that he ran for President, and thereafter, including, while he has served as President, that have encouraged the most extreme political opposition encouraging violence against his opponents, and he is encouraging extremist violent threats and actions such as we have seldom seen before in our country, but are seeing today.
69. Calling Democratic activist, Tom Steyer, “a crazed and stumbling lunatic,” in connection with his criticism of Trump in connection with Steyer’s unlawful and criminal receipt of a pipe-bomb from a terrorist supporter and admirer of Trump.
70. Calling Tallahassee Mayor Andrew Gullin “a thief” during the course of Gullin’s campaign for Governor of Florida, without citing any evidence, and despite Trump’s position as President which precludes him from making allegations of criminality against anyone in violation of their right to due process of law and the presumption of innocence of any charges. Trump did so despite his declaration that he would tamp down his campaign rhetoric and accusations after a domestic terrorist sent pipe bombs to his Democratic opponents.
71. Proposing to issue an Executive Order that would take away American citizenship of people who were born in this country despite a provision in the 14th Amendment to the United States Constitution which declares that “all persons born...in the United States are citizens.” Thus Trump proposes to amend the Constitution through issuing an Executive Order.
72. Appointing Matthew G. Whitaker as Acting Attorney General when Whitaker has never been confirmed by the Senate, which may result in violations of the “appointments” clause of the United States Constitution; and also because Whitaker publicly has expressed his opposition to the Mueller investigation of Trump and others, which disqualifies him under Justice Department ethics rules from supervising that investigation.
73. Making unsupported and irresponsible claims of fraud in the 2018 elections, including a claim that Ron DeSantis and Rick Scott should be declared elected in Florida as Governor and Senator immediately before a legally required recount is completed, because Trump has alleged that “many ballots are missing or forged,” and that “large numbers of new ballots showed up out of nowhere.” He also tweeted that “An honest vote count [in Florida] is no longer possible.” Florida election officials have said they have not seen evidence of any election irregularities.
74. Insulting and demeaning three female African American reporters during the week of November 5, 2018, in response to their simply having asked Trump questions. As to CNN reporter Abby Phillips, he said, “You ask a lot of stupid questions.” Regarding April Ryan, a correspondent for American Urban Radio Networks, he declared,” She doesn’t know what the hell she’s doing!” And as to Yamiche Alcindor of the PBS News Hour and NBC News, who asked Trump about whether describing himself as a “Nationalist” stirred up white nationalists, Trump repeatedly declared Alcindor’s question to be “racist.”
75. Withdrawing the White House press credentials of CNN reporter Jim Acosta in violation of the First Amendment’s protections of freedom of the press, and barring Acosta from the White House grounds.
76. Failing while in France to attend a wreath-laying ceremony at the Aisne-Marne American Cemetery where 2,290 American troops who fought and died in World War I are buried; and failing on Veterans Day in 2018 to lay a wreath at the Tomb of the Unknown Soldier at Arlington National Cemetery, which all presidents since at least John F. Kennedy have done to mark the solemn holiday.
77. Insulting and deriding revered retired Admiral William H. McRaven, who was a Navy Seal and Special Operations commander who oversaw the capture of Saddam Hussein and liquidation of Osama Ben Laden, as a “Hillary Clinton fan” and “Obama backer” on a November 18, 2018 television interview, adding that it “would have been nice if we got Osama Ben Laden a lot sooner...” McRaven had declared last year that Trump’s description of the news media as the “enemy of the people” was the greatest threat to democracy he had ever seen.
78. Insulting California Congressman Adam Schiff by tweeting about him on November 18, 2018, and vulgarly calling him “little Adam Schitt,” because Schiff had questioned Trump’s appointment of Matthew Whitaker as Acting Attorney General without having been confirmed by the Senate.
79. Issuing an order denying asylum seekers their legal right to seek asylum if they entered the United States illegally. This order was enjoined by a federal district court on November 19, 2018, as being contrary to law.
80. Claiming on November 20, 2018, that Federal District Judge Jon Tigar, who ruled that President Trump broke the law by denying asylum seekers their rights to seek asylum even if they entered the country illegally, was an “Obama Judge,” and declaring “we’re not going to let that happen again.” Supreme Court Chief Justice John Roberts rebuked President Trump for his remarks saying, “We don’t have Obama judges or Trump judges, Bush judges or Clinton judges.” Roberts said that the country had an independent judiciary that sought to protect the rights of all. Trump tweeted in response that the courts should not be engaged in overseeing law enforcement, and that their doing so would cause “Bedlam, chaos, injury and death.”
81. Bizarrely posting on the “Trump Train” on November 28, 2018, that “ Now that the Russian collusion has been proven a lie, when do the trials for treason begin ?״ and showing there behind bars, Presidents Obama and Clinton, Deputy Attorney General Rod Rosenstein, Hillary Clinton, and others.
82. By declaring that his supporter, Roger Stone, still “had guts” for refusing to testify before Special Counsel Mueller, and supporting Stone’s statement that he would never testify against Trump, Trump potentially violated criminal provisions of the United States Code prohibiting influencing witnesses regarding their testimony and otherwise obstructing justice.
83. Refusing to acknowledge that Saudi Crown Prince Mohammed Bin Salmon (MBS) was complicit in the murder on October 2, 2018, at the Saudi consulate in Istanbul, of Washington Post reporter Jamal Khashoggi, notwithstanding that the CIA has convinced many Senators, including Senator Lindsey Graham, that there was no doubt that MBS was responsible for Khashoggi’s killing.
84. Wishing “good luck” to Michael Flynn prior to his sentencing for lying to the FBI, and calling his former attorney, Michael Cohen, a “rat” for cooperating with federal prosecutors, all in violation of Trump’s fiduciary duties and obligations as President, and his oath of office requiring him to uphold the laws and the Constitution.
85. Withdrawing American troops from Syria over the objections of Defense Secretary Mattis and many members of Congress, thereby putting at risk of serious harm America’s Kurdish allies who are fighting terrorists in Syria, and causing Mattis to resign in protest effective February 28, 2019, so as to allow a smooth transition at the Department of Defense.
86. Precipitously replacing Mattis effective January 1, 2019, with Patrick Shanahan as Acting Secretary of Defense, thereby undermining a smooth transition of leadership at the Department of Defense as proposed by Mattis, and thereby undermining national defense.
87. Causing an unnecessary and disruptive shutdown of the Government on December 22, 2018, just before Christmas, and requiring thousands of federal employees to work during the shutdown without receiving their pay on time, as required under the Fair Labor Standards Act. .
For all of these reasons, and others specified in this Petition, he should be Censured by both Houses of Congress.
Full Petition text below:
PETITION TO THE CONGRESS OF THE UNITED STATES FOR THE REDRESS OF GRIEVANCES UNDER THE FIRST AMENDMENT REQUESTING THAT PRESIDENT TRUMP BE CENSURED
The undersigned, exercising their inalienable right, deriving from the Magna Carta and enshrined in the First Amendment to the United States Constitution, “to petition the Government for a redress of grievances,” do hereby request of each member of the United States Senate and House of Representatives that the Senate and House, separately or jointly, adopt a resolution censuring President Donald J. Trump for the misconduct described below.
The undersigned have concluded, after due deliberation, that President Donald J. Trump, from the day he took office on January 20, 2017 as the forty-fifth President, to the present, has betrayed his obligations to “preserve, protect and defend the Constitution” and to "take care that the laws be faithfully executed" by engaging in the following unlawful conduct, and conduct that contravenes, betrays, disparages and denigrates the values enshrined in the Constitution, and demeans the office of President. Far from embracing our constitutional rights and obligations, President Trump has demonstrated that he lacks allegiance to, respect for, or even knowledge of, those rights and obligations.
1. President Trump acted improperly by
(i) firing Director James Comey of the FBI for refusing to terminate the FBI’s investigation into charges that the Russian Government had sought to influence the outcome of the November 2016 presidential election, and then offering contradictory explanations of the reasons for that firing, one or more of which explanations must have been false.
(ii) interfering in the FBI’s investigation of Michael Flynn, who had been National Security Advisor until his recent firing by the President, by asking FBI Director Comey to terminate that investigation.
(iii) disclosing highly classified intelligence information to Russian Foreign Minister, Sergei Lavrov, and the Russian Ambassador to the United States, Sergei. Kislyak, in a private meeting in the Oval Office on May 10, 2017.
(iv) abusing the powers of his office and the integrity and independence of the Justice Department by admonishing Attorney General Sessions for having recused himself from involvement in the investigation of Russian interference in the 2016 presidential election.
2. President Trump has disgraced his office by repeatedly making false statements publicly in violation of 18 U.S.C. 1001 which provides, in relevant part, that "...whoever, in any matter within the jurisdiction of the executive, legislative or judicial branch of the Government of the United States, knowingly and willfully...makes any materially false, fictitious, or fraudulent statement or representation...shall be fined,...imprisoned not more than 5 years...or both.
(i) President Trump asserted on March 4, 2017 that his predecessor, then President Barack Obama, had tapped his phone at Trump Tower in New York City. Neither President Trump nor anyone else has offered any evidence to support this claim, which must, therefore, be concluded to have been false.
3. President Trump has ownership, leasehold, licensing or other interests in numerous hotels in Washington, D.C., elsewhere in the United States and abroad in which individuals holding office in foreign governments have stayed and/or enjoyed meals and entertainment, and has thereby violated Article 1, Section 10 (the “Emoluments Clause”) of the United States Constitution. Further, President Trump continues to hold and benefit from his many assets, both foreign and domestic, receiving profits and benefits, such as trademarks, from foreign powers, which constitute wrongfully received emoluments. By engaging in those violations, President Trump has also violated his oath of office to “preserve, protect and defend the Constitution of the United States.”
4. President Trump has disparaged, demeaned and ridiculed women, including statements referring to the lack of intelligence and the physical appearance of a television commentator. Such conduct betrays our Nation’s values and undermines the hard-fought equality of women in our Nation.
5. By announcing on May 31, 2017 that the United States is withdrawing from the Paris Climate Accords signed by 195 nations, President Trump has acted recklessly, without justification and contrary to the wishes of the great majority of the American people, and has thereby jeopardized the residents of our country and their descendants.
6. President Trump has refused, and made clear that he will continue to refuse, to disclose his previously filed or future federal income tax returns in violation of a long-standing tradition of disclosure honored by former Presidents. That refusal has deprived and will deprive Congress and the American people of information necessary to determine
(i) whether, and if so, the extent to which, President Trump violated the Emoluments Clause of the United States Constitution;
(ii) the President’s past, continuing and future relations with foreign individuals and entities; and
(iii) the personal impact on President Trump of any proposed amendments to the Internal Revenue Code.
7. From the moment of his inaugural address to date, President Trump has publicly and repeatedly disparaged and defamed his predecessor as President, members of Congress, the Judiciary, Government officials, political opponents, members of the press, and other individuals in a crude, and insulting manner. In addition, he has called into question the legitimacy of the other equal branches of our government, so as to undermine seriously these institutions in the eyes of our people and the world. Thus he has made us fear that our nation is headed in the direction of becoming an authoritarian dictatorship.
8. In June, 2016, Donald Trump’s agents, campaign chairman Paul Manafort, Trump’s son, Donald Trump, Jr., and his son-in-law, Jared Kushner, willfully, knowingly, and improperly, sought to obtain from Russian government sources, damaging information regarding Hillary Clinton for the purpose of aiding Donald Trump’s presidential campaign. On July 13, 2017 President Trump defended the foregoing improper actions.
9. Encouraging law enforcement officers to physically abuse arrested suspects in violation of existing police rules and regulations and the Due Process clause of the Fifth and Fourteenth Amendments to the United States Constitution; and reversing the Obama administration's policies seeking, through litigation, to curtail certain police department misconduct such as the excessive use of force, as in the case of the Chicago Police Department.
10. Imposing an immigration ban based upon religious discrimination in violation of the First Amendment's protections of freedom of religion.
11. Imposing a ban upon transgender people from serving in the military in violation of the Equal Protection Clause of the Fourteenth Amendment.
12. Encouraging violence and showing disdain for core American values by stating that Ku Klux Klan members, neo-Nazis, and their racist allied protesters in Charlottesville included "very nice people."
13. Exhibiting disdain for the Constitution and the judicial process by pardoning former Phoenix Sheriff, Joe Arpaio, who had been held in contempt of court by a federal judge for acting in "flagrant disregard" of the court's order directing that Arpaio's department cease engaging in racial profiling.
14. Callously and cruelly withdrawing the protections of President Obama's Deferred Action for Childhood Arrivals Executive Order from approximately 800,000 "Dreamers," thereby subjecting them to family and job disruption and possible deportation.
15. Recklessly and crudely urging the owners of National Football League franchises to discharge players for exercising their constitutional, statutory, and contractual rights to engage in silent non-violent protests against discrimination prior to games;
16. Threatening to “totally destroy” North Korea and annihilate its entire population, thereby suggesting genocide in violation of the United Nations Charter and international law;
17. Attacking Carmen Yulin Cruz, the Mayor of San Juan, Puerto Rico, for her pleas for additional federal assistance in response to its humanitarian crisis created by Hurricane Maria, threatening to withdraw federal assistance to Puerto Rico, and suggesting that Puerto Rico’s residents were not doing enough to help themselves;
18. Ending Federal Affordable Care Act subsidies amounting to about $7 billion in fiscal year 2017, and $10 billion in 2018, according to the Congressional Budget Office, so as to deprive low income citizens of health insurance.
19. Seeking to interfere with due process of law, as stated by Senator Bob Corker, by “pressuring...the Justice Department and FBI to pursue cases against [President Trump’s] political adversaries, and calling for punishment of alleged criminals before trials take place,” which in Senator Corker’s view “are totally inappropriate.”
20. Publishing inflammatory videos prepared and distributed by an ultra-right wing British group, Britain First, on November 21, 2017, which alleged to show Muslims committing acts of violence, of which Senator Lindsey Graham (R. S.C.), said constituted “legitimizing religious bigotry,” and British Prime Minister Theresa May condemned for promoting racism and bigotry;
21. Tweeting an attack upon the integrity of the Federal Bureau of Investigation (FBI), as being in “tatters,” on December 2, 2017, and lamenting that: “General [Michael] Flynn [Trump’s former National Security Advisor], lies to the FBI and his life is destroyed . . .,” after Flynn pled guilty in federal court to the felony of making “materially false, fictitious, and fraudulent statements and representations . . .” to the FBI concerning discussions he had with the Russian Ambassador to the United States, which impeded then pending FBI investigations;
22. Endorsing and campaigning for a candidate for the United States Senate from Alabama, Roy Moore, who has praised the slavery era, proposed banning Muslims from Congress, was twice removed from the Alabama Supreme Court for defying federal court orders, and who has been credibly accused by several Alabama women of sexually assaulting them when they were teenagers and when he was in his thirties;
23. Withdrawing some two million acres of land from two national monuments in Utah, Grande Staircase – Escalante and Bears Ears, both of which have magnificent landscapes and priceless Native American artifacts, and have been protected from mining and development. Such withdrawal already has become the subject of lawsuits brought by environmentalists and Native American groups, seeking to declare President Trump’s actions illegal;
24. Issuing an anti-Native American racist slur against Senator Elizabeth Warren, at a White House ceremony honoring Navajo code talkers on November 27, 2017, which was deeply offensive to Senator Warren and Native American communities.
25. Declaring in a sexist manner that Senator Kirsten Gillibrand had come to his business office “begging” for political contributions and that she “would do anything for them.”
26. Selecting multiple unfit and dangerous federal judicial nominees for lifetime appointments, including Brett Talley who has never tried a case in court and received an unqualified ranking by the non-partisan American Bar Association and Jeff Mateer who has previously described transgender youth as part of "Satan's plan”.
27. After having acknowledged in November, 2017, that as President he was “not supposed to be involved with the Justice Department,” in connection with its investigations, he told the New York Times on December 28, 2017, that “I have absolute right to do what I want to do with the Justice Department.”
28. Telling the press on December 15, 2017, that “I don’t want to talk about pardons for Michael Flynn yet. We’ll see what happens,” which may be construed as a violation of 18 U.S.C. 1512 (b), which declares: “Whoever...corruptly persuades another person, or attempts to-influence..or prevent the testimony of any person, in an official proceeding...shall be fined under this title or imprisoned not more than 20 years, or both.” Thus, Trump may have been signaling to Flynn that how, and whether, he testified before a grand jury or otherwise in the current Mueller investigation would influence Trump regarding pardoning Flynn.
29. Threatening North Korea by “tweeting” that he had “a Nuclear Button” that is “ much bigger and more powerful” than North Korea’s “and [his] Button works!”
30. Demanding that an author and publisher cease publishing a book critical of him, and demanding a retraction and apology from them, thereby seeking to impose a prior restraint upon them, and “chilling” them in their exercise of their First Amendment rights.
31. Publicly insulted 25-year California Senator Diane Feinstein in a tweet on January 10, 2018, by calling her “sneaky” and declaring that she had made public the Glenn Simpson Congressional hearing transcript “in an underhanded and possibly illegal way, totally without authorization, [which] is a disgrace,” and suggested that Senator Feinstein had done so because she faced a “tough Primary;”
32. Declared on January 10, 2018, that our libel laws are a “sham” and a “disgrace” and that he would take a “strong look” at changing them, when in fact the laws he referred to are subject to the First Amendment to the Constitution as well as well-settled Supreme Court doctrines and decisions such as New York Times v. Sullivan, which declare that with regard to proving a defamation case brought by a public figure, the publisher must have published the statement with malice, consisting of knowledge of the falsity of the statement or proceeding in reckless disregard of the truth or falsity thereof;
33. Declared in the crudest and most racist possible terms at a meeting on January 11, 2017, with members of Congress discussing immigration legislation, that Haiti and certain African countries were undesirable sources of immigrants and that he preferred immigrants to the United States to come from countries such as Norway, which have overwhelmingly white populations;
34. It has been reliably reported that in June 2017, President Trump ordered the firing of Special Counsel Mueller but did not implement his order because White House Counsel Donald McGahn told Trump that he would resign if Trump forced McGahn do so. This provides further evidence that Trump had the intent of obstructing the due administration of justice in connection with Special Counsel Mueller’s investigation of members of Trump’s administration by dismissing Mueller. Trump sought to cover up this report by describing it as “false-news.”
35. Publicly charged on February 2, 2018, that “ the top leadership and investigators of the Justice Department and the FBI have politicized the sacred investigative process in favor of Democrats and against Republicans...” at a time when his former National Security Advisor Michael Flynn has pled guilty to lying to the FBI, and Trump and others in the White House are under investigation by Special Counsel Mueller for obstruction of justice in connection with Trump’s firing of former FBI Director James Comey, and helping Russia interfere in the 2016 presidential election.
36. Declassifying material contained in a memorandum prepared and released by Congressman Nunes attacking actions by the Justice Department and FBI in obtaining a judicial warrant to engage in surveillance of a former Trump campaign aide, Carter Page, thereby wrongfully using the power of the presidency to thwart an investigation of him and his presidential campaign. Trump’s action was described by Senator John McCain as undermining the rule of law and “helping Putin.”
37. At an official White House visit and speech in Cincinnati, Ohio, on February 5, 2018, President Trump accused Democrats in Congress of being “un-American” and “treasonous” for having declined to applaud during his recent State of the Union address to Congress.
38. Calling the claims that Russia interfered with the 2016 presidential election a “hoax” and “a made up story,” and failing to direct action and sanctions against further Russian election interference in the face of massive evidence reported upon by the American intelligence community and in special counsel Mueller’s lawsuit filed against the Russian perpetrators on February 16, 2018.
39. Praising Communist China’s dictator, Xi Jinping, for having appointed himself “President for life,” and for being “a great gentleman,” and also proposing that “Maybe we’ll give that a shot someday!” at a political fundraiser at his Florida golf resort on March 3, 2018, where he received applause for his remarks. Trump also praised Xi for being “the most powerful president of China in 100 years.”
40. At a political campaign rally on March 10, 2018, near Pittsburgh, Trump insulted and offended California Congresswoman Maxine Waters by describing her as a “low- I.Q. Individual,” and once again referred to Massachusetts Senator Elizabeth Warren in a racially derogatory and insensitive way, as “Pocahontas.”
41. Spitefully conspired with Attorney General Sessions to discharge FBI Deputy Director Andrew McCabe two days prior to his birthday, which was the date he planned to retire and become eligible for his pension, all in violation of Session’s decision “to recuse [himself] from any existing or future investigations of any matters related in any way to the campaigns for President of the United States,” since McCabe’s discharge related to his investigations of 2016 Presidential election matters.
42. Despite the advice of his national security advisors not to congratulate Russian President Putin for his recent “election” victory, and having imposed sanctions against Russia on March 19, 2018, Trump nevertheless applauded Putin for having been elected as Russia’s President in a phone call with him the next day, which caused Senator John McCain to declare that “an American President does not lead the free world by congratulating dictators on winning sham elections.”
43.Calling the enforcement of a subpoena and an investigation by the Justice Department, Special Counsel Mueller, and the FBI, seeking attorney-client documents of President Trump’s attorney, Michael Cohen, on April 9, 2018, a “witch hunt,” a violation of “everyone’s rights,” an “an attack upon our country,” and attorney-client privilege, notwithstanding that a federal magistrate authorized such subpoena and investigation based upon a showing by the Government of “probable cause” of the commission of crimes by Cohen, and/or others, related to the investigation of wrongdoing by Special Counsel Mueller.
44. By declaring on May 23, 2018, that those NFL players who choose not to stand, and kneel instead, during the playing of the national anthem, “maybe shouldn’t be in the country,” President Trump showed his contempt and disrespect for the exercise of First Amendment rights by citizens, intended to protest racial injustices and other perceived wrongs in our political system. In addition, he was lending support to the NFL and its team owners who adopted a policy of disciplining players for exercising their Constitutional rights in the foregoing manner.
45. By falsely claiming that an investigation by federal law enforcement into Russian interference in the conduct of the 2016 Presidential election constituted spying on his campaign, President Trump deliberately and knowingly distorted the facts to make it appear that he was the victim of misconduct by governmental agencies. In fact, former National Security Advisor James Clapper responded that Trump’s allegation was Orwellian in nature and a total fabrication, and that the investigation was undertaken solely to determine whether there was Russian interference in the election, which Clapper described as being so massive as to have affected the outcome of the election in Trump’s favor.
46. By declaring in a dictatorial manner on June 4, 2018, that “the appointment of Special Counsel [Mueller] is totally UNCONSTITUTIONAL!” and that “I [Trump] have the absolute right to PARDON myself,” Trump demonstrated that he believes himself to be above the law, and accountable to no one, in gross derogation of our Constitutional system of government, the separation of powers and the rule of law.
47. Falsely asserting in a May 26, 2018 tweet that under a “horrible law” which he said was “bad legislation passed by the Democrats” but in fact does not exist, the Federal Government is required to separate hundreds of children, including toddlers, from their parents at U.S. borders and incarcerate and hold them when they and their parents enter the United States seeking sanctuary or otherwise, and continuing to do so when the office of the United Nations High Commissioner for Human Rights has declared such treatment of children by the United States to constitute a violation of International Law and the rights of the children involved.
48. President Trump proposed that migrants who seek asylum in this country or enter illegally simply should be expelled from this country summarily at the border rather than receiving the hearing that they are entitled to under applicable law, declaring that that they should immediately be sent home “without Judges or court hearings.”
49. In a freewheeling campaign meeting in Montana early in July, 2018, Trump extolled his own campaign slogans and compared them favorably to former President H.W. Bush’s “Thousand Points of Light” program encouraging voluntarism, declaring “What the hell is that?”
50. Shamefully and disgracefully providing “aid and comfort” to the Russian government, and its head of state, Vladimir Putin, by declaring publicly in Helsinki, Finland, in Putin and the world’s presence, that the Mueller investigation was a “disaster for our country,” and publicly rejecting the conclusion of the entire American intelligence community, the Mueller investigation, and Congress, that Putin, and the Russian government interfered by hacking the emails of the Clinton campaign and the Democratic Party for the purpose of supporting Trump’s campaign and defeating Clinton. As stated by the Washington Post, by “trashing [our] own country’s justice system, Mr. Trump was openly colluding with the criminal leader of a hostile power.” And as Senator John McCain declared: “No prior president has ever abased himself more abjectly before a tyrant.”
51. Continuing to attack the press on July 29, 2018, as the source of “fake-news,” as being “unpatriotic” and the “enemy of the people,” thereby encouraging individuals and groups to attack members of the press while covering events and otherwise,
52. Threatening on July 29 and 31, 2018, and thereafter, to cause a Federal Government shutdown unless Congress appropriates funds to build a wall on the border between the United States and Mexico.
53. Interfering with the independence of the Federal Judiciary by commenting publicly that Paul Manafort, who is being tried criminally, is being treated unfairly by the judicial branch, and declaring that the Mueller investigation’s prosecution of Manafort is a “hoax.”
54. Calling upon Attorney General Jeff Sessions to “stop this rigged Witch Hunt,” [Mueller Investigation] before it continues to stain our country any further,” notwithstanding that Sessions is recused from having anything to do with the ongoing Mueller investigation.
55. Praising his former campaign chairman, Paul Manafort, as a “brave man!” for refusing to “break” under government pressure after Manafort was convicted by a federal jury of eight felony counts of tax evasion and bank fraud in Virginia on August 21, 2018. On September 14, 2018, Manafort agreed to plead guilty to two felony counts in Washington, D.C. and to cooperate with the Mueller investigation, despite Trump’s praise.
56. Attacking his own Attorney General, Jeff Sessions, on September 3, 2018, because two Republican members of Congress, Chris Collins of New York, and Duncan Hunter of California, were indicted by federal grand juries of corruption charges. Trump complained to Sessions that the timing of the indictments of Collins and Hunter hurt the two Republicans’ chances of re-election in November 2018.
Senator Ben Sasse (R-Neb) criticized Trump’s statement saying that: “The United States is not some banana republic with a two-tiered system of justice- one for the majority party and one for the minority party.”
57. Calling his former White House aide, Omarosa Manigault Newman, “a crazed, crying lowlife,” and “a dog,” after she claimed that Trump suffered from mental deterioration, and declared that he was a racist and anti-women. Newman had said that Trump “has absolutely no respect for women “ or “for African Americans.”
58. Having been identified in open court in New York City by his former lawyer and confidante, Michael Cohen, as having directed Cohen to make “hush money” payments to two women during Trump’s 2016 presidential campaign to keep them from speaking out publicly about affairs they claimed to have had with Trump. Cohen pled guilty to federal crimes and presently awaits sentencing. He is cooperating with federal prosecutors. Cohen told the judge in his case that he “participated in this [illegal] conduct for the purpose of influencing the election” for president in 2016.
59. Declaring that he was revoking the security clearance of former CIA Director John Brennan because Trump claimed that Brennan had engaged in “erratic conduct and behavior.” Many former national security officials challenged Trump’s move as being a politically motivated effort to retaliate against Brennan for having criticized Trump publicly in the course of exercising his First Amendment rights of free speech. Trump’s action bypassed existing Executive Order 12968 which regulates “Access to Classified Information.”
60. Falsely claiming on September 13, 2018, that the Democrats were responsible for inflating the number of people who died in Puerto Rico in September, 2017, during Hurricane Maria “to make me look as bad as possible.” It is well established that almost 3000 people died in Puerto Rico as the result of the Hurricane. Congresswoman Ileana Ros Lehtinen, (R-Fla), commented on Trump’s statement as follows: “What kind of mind twists that statistic into ‘Oh, fake news is trying to hurt my image.’ How can you be so self-centered and try to distort the truth so much? It’s mind boggling.”
61. Failing to follow precedent, and thereby causing the American flag not to be flown at half-staff over the White House for the appropriate requisite full week in connection with the death of Senator John McCain (R-Ariz) in August 2018, and otherwise failing fully to honor Senator McCain’s death in a timely manner. Senator Lindsey Graham (R-SC) declared President Trump’s handling of McCain’s death “disturbing.”
62. Corruptly participating in schemes and artifices with other members of his family over many years in order to evade hundreds of millions of dollars in inheritance and gift taxes to which the federal and New York State governments were entitled, resulting in Trump׳s huge personal enrichment, while telling the voting public that he was a self-made billionaire. The report on Trump’s participation in these fraudulent tax dodges are contained in an 18 month study conducted by the New York Times that Trump did not deny but merely dismissed as being “boring.”
63. After having declared that Dr. Christine Blasey Ford was ״a very credible witness״ and ״a very fine woman” whose testimony was ״very compelling” that she had been sexually attacked by Brett Kavanaugh when she was in high school, Trump thereafter mocked her and declared her allegations to be false and part of a “hoax״ in order for him to help Kavanaugh be confirmed by the Senate as a Supreme Court Justice.
64. Continuing his misogynistic insulting descriptions of women, he described Stormy Daniels, who he paid $130,000 in ״hush money” for her silence concerning an affair she has alleged to have had with Trump, a “horseface.״
65. Publicly praising Congressman Greg Gianforte (R.-Mont.), at a campaign rally, who pled guilty to an assault charge for having “body-slammed” a reporter for a British newspaper in 2017, and was sentenced by a court for having done so. Trump declared at the campaign rally that “any guy who can do a body slam...he’s my kind of guy.” Trump was criticized for this statement by Senator Jeff Flake (R.-Ariz.), and many others.
66. Threatening national security, as reported by the New York Times on October 25, 2018, by continuing to use his unsecured iPhones in talking with friends, when he has repeatedly been told by federal security agencies that both Russian and Chinese spies are listening in on his conversations. White House officials have anonymously told the Times that they worry that foreign governments may use the information they obtain from eavesdropping on Trump’s phone conversations to understand better Trump’s thinking on many matters, which can be used to their political advantage.
67. Claiming that the press and media are responsible for the horrible terrorist sending of explosive devices to many Democratic leaders and others who have expressed criticism of him, including the Obamas, Clintons, Holders, Bidens, Robert DiNiro, John Brennan, George Soros, CNN, Maxine Waters, James Clapper, and others. The fact is that It was Trump whose extremist comments, beginning prior to the time that he ran for President, and thereafter, including, while he has served as President, that have encouraged the most extreme political opposition encouraging violence against his opponents, and he is encouraging extremist violent threats and actions such as we have seldom seen before in our country, but are seeing today. Trump knows that he is supporting extremists, and extremism, such as was involved in the the assasinations of Presidents Kennedy, McKinley, and Lincoln, but pretends to oppose expressions of such violent extremism, and blames others for his own actions.
68. Calling Democratic activist, Tom Steyer, “a crazed and stumbling lunatic,” in connection with his criticism of Trump in connection with Steyer’s unlawful and criminal receipt of a pipe-bomb from a terrorist supporter and admirer of Trump. Steyer claimed that Trump has undermined the rule of law by his lawless statements and activities in violation of federal law and regulations.
69. Calling Tallahassee Mayor Andrew Gullin “a thief” during the course of Gullin’s campaign for Governor of Florida, without citing any evidence, and despite Trump’s position as President which precludes him from making allegations of criminality against anyone in violation of their right to due process of law and the presumption of innocence of any charges. Trump did so despite his declaration that he would tamp down his campaign rhetoric and accusations after a domestic terrorist sent pipe bombs to Democrats, including Hillary Clinton, Barack Obama, Joseph Biden and others.
70. Proposing to issue an Executive Order that would take away American citizenship of people who were born in this country despite a provision in the 14th Amendment to the United States Constitution which declares that “all persons born...in the United States are citizens.” Thus Trump proposes to amend the Constitution through an Executive Order.
71. Appointing Matthew G. Whitaker as Acting Attorney General when Whitaker has never been confirmed by the Senate, which may result in violations of the “appointments” clause of the United States Constitution; and also because Whitaker publicly has expressed his opposition to the Mueller investigation of Trump and others, which disqualifies him under Justice Department ethics rules from supervising that investigation.
72. Making unsupported and irresponsible claims of fraud in the 2018 elections, including a claim that Ron DeSantis and Rick Scott should be declared elected in Florida as Governor and Senator immediately before a legally required recount is completed, because Trump has alleged that “many ballots are missing or forged,” and that “large numbers of new ballots showed up out of nowhere.” He also tweeted that “An honest vote count [in Florida] is no longer possible.” Florida election officials have said they have not seen evidence of any election irregularities.
73. Insulting and demeaning three female African American reporters during the week of November 5, 2018, in response to their simply having asked Trump questions. As to CNN reporter Abby Phillips, he said, “You ask a lot of stupid questions.” Regarding April Ryan, a correspondent for American Urban Radio Networks, he declared,” She doesn’t know what the hell she’s doing!” And as to Yamiche Alcindor of the PBS News Hour and NBC News, who asked Trump about whether describing himself as a “Nationalist” stirred up white nationalists, Trump repeatedly declared Alcindor’s question to be “racist.”
74. Withdrawing the White House press credentials of CNN reporter Jim Acosta in violation of the First Amendment’s protections of freedom of the press, and barring Acosta from the White House grounds.
75. Failing while in France to attend a wreath-laying ceremony at the Aisne-Marne American Cemetery where 2,290 American troops who fought and died in World War I are buried; and failing on Veterans Day in 2018 to lay a wreath at the Tomb of the Unknown Soldier at Arlington National Cemetery, which all presidents since at least John F. Kennedy have done to mark the solemn holiday.
76. Insulting and deriding revered retired Admiral William H. McRaven, who was a Navy Seal and Special Operations commander who oversaw the capture of Saddam Hussein and liquidation of Osama Ben Laden, as a “Hillary Clinton fan” and “Obama backer” on a November 18, 2018 television interview, adding that it “would have been nice if we got Osama Ben Laden a lot sooner...” McRaven had declared last year that Trump’s description of the news media as the “enemy of the people” was the greatest threat to democracy he had ever seen.
77. Insulting California Congressman Adam Schiff by tweeting about him on November 18, 2018, and vulgarly calling him “little Adam Schitt,” because Schiff had questioned Trump’s appointment of Matthew Whitaker as Acting Attorney General without having been confirmed by the Senate.
78. Issuing an order denying asylum seekers their legal right to seek asylum if they entered the United States illegally. This order was enjoined by a federal district court on November 19, 2018, as being contrary to law.
79. Claiming on November 20, 2018, that Federal District Judge Jon Tigar, who ruled that President Trump broke the law by denying asylum seekers their rights to seek asylum even if they entered the country illegally, was an “Obama Judge,” and declaring “we’re not going to let that happen again.” Supreme Court Chief Justice John Roberts rebuked President Trump for his remarks saying, “We don’t have Obama judges or Trump judges, Bush judges or Clinton judges.” Roberts said that the country had an independent judiciary that sought to protect the rights of all. Trump tweeted in response that the courts should not be engaged in overseeing law enforcement, and that their doing so would cause “Bedlam, chaos, injury and death.”
80. Bizarrely posting on the “Trump Train” on November 28, 2018, that “ Now that the Russian collusion has been proven a lie, when do the trials for treason begin ?״ and showing there behind bars Presidents Obama and Clinton, Deputy Attorney General Rod Rosenstein, Hillary Clinton, and others.
81. By declaring that his supporter, Roger Stone, still “had guts” for refusing to testify before Special Counsel Mueller, and supporting Stone’s statement that he would never testify against Trump, Trump potentially violated criminal provisions of the United States Code prohibiting influencing witnesses regarding their testimony and otherwise obstructing justice.
82. Refusing to acknowledge that Saudi Crown Prince Mohammed Bin Salmon (MBS) was complicit in the murder on October 2, 2018, at the Saudi consulate in Istanbul, of Washington Post reporter Jamal Khashoggi, notwithstanding that the CIA has convinced many Senators, including Senator Lindsey Graham, that there was no doubt that MBS was responsible for Khashoggi’s killing.
83. Wishing “good luck” to Michael Flynn prior to his sentencing for lying to the FBI, and calling his former attorney, Michael Cohen, a “rat” for cooperating with federal prosecutors, all in violation of Trump’s fiduciary duties and obligations as President, and his oath of office requiring him to uphold the laws and the Constitution.
84. Withdrawing American troops from Syria over the objections of Defense Secretary Mattis and many members of Congress, thereby putting at risk of serious harm America’s Kurdish allies who are fighting terrorists in Syria, and causing Mattis to resign in protest effective February 28, 2019, so as to allow a smooth transition at the Department of Defense.
85. Precipitously replacing Mattis effective January 1, 2019, with Patrick Shanahan as Acting Secretary of Defense, thereby undermining a smooth transition of leadership at the Department of Defense as proposed by Mattis, and thereby undermining national defense.
86. Causing an unnecessary and disruptive shutdown of the Government on December 22, 2018, just before Christmas, and requiring thousands of federal employees to work during the shutdown without receiving their pay on time, as required under the Fair Labor Standards Act.
WHEREFORE, the undersigned respectfully request that President Donald J. Trump be censured for the acts, statements and conduct specified above.
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