Mr. Khalil Has Filed His Amended Complaint (In NJ Fed. Dist. Ct.) Against Pam Bondi And Kristi Noem (And Others) -- For Kidnapping Him. It Will Prevail.

The nice thing about the version of the amended complaint I am attaching is that it shows every change from the original filing. This is a specifically marked amendment -- and a muscular one. It may even one day support criminal referrals against Noem, et al. as they clearly knew they were taking a self-evidently unlawful series of actions, against Mr. Khalil, and many others.

Do recall here that the First Amendment -- by its express terms -- doesn't limit these freedoms to US citizens; it uses the all inclusive phrase "the people" -- and that means anyone present on our shores (or interior). [We are all free people -- no matter what Tangerine belches on and on about.] And the heads of border agencies (like Noem, Rubio and Bondi) -- if appointed by the POTUS -- MUST be aware of, and comply with. . . the applicable Constitutional law of the US.

Just as last week, the able USDC Judge Crenshaw in Nashville found it "plausible" that Noem and Co. acted lawlessly in trying to punish Abrego Garcia with a felony indictment (for seeking habeas corpus, out of El Salvador), so too here -- it seems plain Noem snatched Mr. Khalil because he had spoken out (entirely peacefully and lawfully) about Gaza and the Palestinians, at Columbia University. Do stay tuned; this 55 pager will be a barn burner:

. . .[The Manchurian Cantaloupe's lawless] Executive Order 14161 states that it is the United States’ policy to “protect its citizens” from noncitizens who “espouse hateful ideology.” It further articulates the administration’s desire to target noncitizens who “advocate for, aid, or support designated foreign terrorists and other threats to our national security,” those who hold “hateful” views, and those who “bear hostile attitudes toward [America’s] citizens, culture, government, institutions, or founding principles.” The order’s broad framing of “hostile attitudes” towards the American government could encompass any form of political dissent, including Palestinian rights advocacy.

[The lawless] Executive Order 14188 states that, in order to “combat campus anti-Semitism,” the administration will target for investigation “post-October 7, 2023, campus anti-Semitism.” The order adopts a definition of antisemitism that includes constitutionally protected criticism of the Israeli government and its policies.

In a "fact" sheet accompanying Executive Order 14188, the White House described the measure as “forceful and unprecedented,” specifically targeting “leftist, anti-American colleges and universities.” [This it cannot lawfully do.] It framed the order as a “promise” to “deport Hamas sympathizers and revoke student visas,” sending a clear message to all “resident aliens who participated in pro-jihadist protests” that the federal government “will find you. . . and deport you. . . .”

Every bit of that Trump 'sharpie scribble' called 14188 violates the people's First Amendment -- and is plainly beyond his lawful powers. Noem deporting people -- and relying on it. . . well-knew -- or is deemed to well know --she was committing crimes. Damn. Do stay tuned.

नमस्ते