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Decl. of Alexandra Robert Gordon (2:17-Cv-00903-WBS-KJN) Exhibit 21

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Decl. of Alexandra Robert Gordon (2:17-Cv-00903-WBS-KJN) Exhibit 21 1 XAVIER BECERRA, State Bar No. 118517 Attorney General of California 2 TAMAR PACHTER, State Bar No. 146083 Supervising Deputy Attorney General 3 ALEXANDRA ROBERT GORDON, State Bar No. 207650 JOHN D. ECHEVERRIA, State Bar No. 268843 4 Deputy Attorneys General 455 Golden Gate Avenue, Suite 11000 5 San Francisco, CA 94102-7004 Telephone: (415) 703-5509 6 Fax: (415) 703-5480 E-mail: [email protected] 7 Attorneys for Defendants 8 IN THE UNITED STATES DISTRICT COURT 9 FOR THE EASTERN DISTRICT OF CALIFORNIA 10 11 12 13 WILLIAM WIESE, et al., 2:17-cv-00903-WBS-KJN 14 Plaintiff, EXHIBITS 21 THROUGH 28 TO THE DECLARATION OF ALEXANDRA 15 v. ROBERT GORDON IN SUPPORT OF PLAINTIFF’S MOTION FOR 16 TEMPORARY RESTRAINING ORDER XAVIER BECERRA, et al., AND PRELIMINARY INJUNCTION 17 Defendant. Date: June 16, 2017 18 Time: 10:00 a.m. Courtroom: 5 19 Judge: The Honorable William B. Shubb Action Filed: April 28, 2017 20 21 22 23 24 25 26 27 28 Decl. of Alexandra Robert Gordon (2:17-cv-00903-WBS-KJN) Exhibit 21 Gordon Declaration 00569 This Is the Assault Rifle Used by the Orlando Mass Shooter | Mother Jones This Is the Assault Rifle Used by the Orlando Mass Shoo… DONATE SUBSCRIBE DONATE POLITICS ENVIRONMENT FOOD MEDIA CRIME & JUSTICE PHOTOS INVESTIGATIONS MAGAZINE This Is the Assault Rifle Used by the Orlando Mass Shooter Developed for US special operations forces, the weapon is known as the "Black Mamba." MARK FOLLMAN JUN. 13, 2016 2:45 PM The MCX "innovative weapon system." Sig Sauer TOP NEWS In 3 Months, 3 Immigrants Have Since the massacre in Orlando early Sunday morning, pro-gun pundits have come out Died at a Private Detention in force to argue that the weapon used in the attack is not an assault rifle. The gun Center in California lobby prefers to call these weapons "modern sporting rifles," euphemistic ammo it can MADISON PAULY semantic debate. But make no mistake: What the Orlando attacker fire in an ongoing Look at All the Ways Trump's used was a weapon of war. It was designed to kill as many people as possible, as quickly as possible. Witness this harrowing audio captured by a bystander outside the Staff Is Avoiding Answering This Pulse nightclub in which Omar Mateen fires 24 shots in 9 seconds. Basic Question NATHALIE BAPTISTE According to a federal law enforcement official, the rifle Mateen used to murder and maim more than 100 people was a Sig Sauer MCX. Mateen legally purchased the How Trump's War on Free Speech Threatens the Republic weapon, similar to an AR-15, on June 4 in Port St. Lucie, Florida, near where he lived. DAVID SNYDER Gordon Declaration 00570 http://www.motherjones.com/politics/2016/06/assault-rifle-used-by-orlando-mass-shooter[6/2/2017 3:41:17 PM] This Is the Assault Rifle Used by the Orlando Mass Shooter | Mother Jones (He legally purchased a Glock 17 handgun the following day, which he also carried during the attack.) Sig Sauer bills the MCX as "an innovative weapon system built around a battle- Sig Sauer promotes the proven core." The company says it "stands MCX as "a complete as the first rifle to be silenced from the weapon system for any ground up. It also accepts a broad array of scenario or accessories, enabling you to build a environment." complete weapon system for any scenario or environment." It has a military-spec trigger and a magazine capacity of 30 rounds. According to the book Guns of Special Forces 2001-2015, the MCX is known in military circles as the "Black Mamba" and was developed at the request of the US Army's special operations forces. Although the legal civilian version of the gun fires on semi-automatic, it can be highly lethal. Indeed, like many of his recent predecessors, Mateen was able to unleash a devastating barrage of gunfire. The law enforcement official declined to comment on the total number of rounds fired in the attack. But, he said, it was "obviously a lot." Read our in-depth investigation of America's 10 biggest gunmakers. GET THE SCOOP, STRAIGHT FROM MOTHER JONES. Share on Facebook Share on Twitter MARK FOLLMAN Mark Follman is the national affairs editor at Mother Jones. Contact him with tips or feedback at [email protected]. Mother Jones is a nonprofit, and stories like this are made possible by readers like you. Donate or subscribe to help fund independent journalism. RELATED The Early Warning Signs That Could Stop the Next Shooting Rampage MARK FOLLMAN How America's Mass Shooters Now Use Weapons of War MARK FOLLMAN Gordon Declaration 00571 http://www.motherjones.com/politics/2016/06/assault-rifle-used-by-orlando-mass-shooter[6/2/2017 3:41:17 PM] This Is the Assault Rifle Used by the Orlando Mass Shooter | Mother Jones VIEW COMMENTS ABOUT US | STORE DONATE | SUBSCRIBE CUSTOMER SERVICE ADVERTISE Copyright ©2017 Mother Jones and the Foundation for National Progress. All Rights Reserved. Terms of Service Privacy Policy Contact Us Gordon Declaration 00572 http://www.motherjones.com/politics/2016/06/assault-rifle-used-by-orlando-mass-shooter[6/2/2017 3:41:17 PM] Exhibit 22 Gordon Declaration 00573 Prior signs of Weapons Total possible mental obtained Where Type of Mental Health Case Location Date Year Summary Fatalities Injured victims Venue illness Mental Health legally obtained weapons Weapon details Race Gender Sources Sources Latitude Longitude Type Kori Ali Muhammad, 39, opened fire along a street in downtown Fresno, killing three people randomly in an alleged hate crime prior to being apprehended by police. Muhammad, who is black, killed http://www.daily three white victims mail.co.uk/news/a and later described rticle- his attack as being 4443722/Gunman- racially motivated; Fresno-shooting- he also reportedly speaks-jail.html; yelled 'Allahu https://www.nyti Akbar' at the time mes.com/2017/04 he was arrested, but /18/us/fresno- authorities shooting-rampage- Fresno indicated they kori-ali- downtown Fresno, found no links to muhammad.html? shooting California 4/18/2017 2017 Islamist terrorism. 3 0 3 Other Unclear Unknown handgun .357 revolver Black M _r=0 Among other Esteban Santiago, signs, 26, flew from Santiago had Alaska to Fort gone to a FBI Lauderdale, where office in he opened fire in Anchorage http://www.nytim http://www.nyti the baggage claim and es.com/2017/01/0 mes.com/2017/0 area of the airport, 11 complained 7/us/esteban- 1/07/us/esteban- Fort killing five and (dozens that his mind santiago-fort- santiago-fort- Lauderdale Fort wounding six more were was being semiautomatic Walther 9mm lauderdale-airport-lauderdale- airport Lauderdale before police injured in controlled by handgun semi-automatic shooting- airport-shooting- shooting , Florida 1/6/2017 2017 aprehended him. 5 6 the panic) Airport Yes the CIA. Yes pistol[ Latino M .html?_r=0 .html?_r=0 Gordon Declaration 00574 Prior signs of Weapons Total possible mental obtained Where Type of Mental Health Case Location Date Year Summary Fatalities Injured victims Venue illness Mental Health legally obtained weapons Weapon details Race Gender Sources Sources Latitude Longitude Type Arcan Cetin, 20, killed a teen girl and three women in the cosmetics section of a Macy’s department store at the Cascade Mall. A man was critically wounded in the shooting and According to taken to the Cetin's Harborview stepfather he Medical Center in had "mental http://www.nbcn Seattle, where he health issues"; ews.com/news/u died. Cetin was court records http://www.nytim s-news/arcan- apprehended by showed that es.com/2016/09/2 cetin-accused- police a few hours he suffered 5/us/mall- cascade-mall- Cascade after the shooting from anxiety shooting- shooter-charged- Mall Burlington, while driving a car and washington- five-counts- shooting WA 9/23/2016 2016 near his residence. 5 0 5 Other Yes depression. Rifle M state.html murder-n654586 http://time.com/4 411027/baton- rouge-shooter- gavin-long/ ; Gavin Long, a http://www.nytim former Marine who es.com/2016/07/1 served in Iraq, 8/us/baton-rouge- killed three police shooting.html; offers responding http://www.kansa to a 911 call, and scity.com/news/lo wounded three cal/article902662 others. He was 42.html; killed in a shoot-out http://www.nola.c with other officers om/crime/index.ss responding to the f/2016/07/gavin_l scene. Prior to the ong_guns_baton_ attack, Long posted rouge_po.html; prolifically on social http://www.moth media, where he Two erjones.com/politi Baton expressed semiautomatic IWI Tavor SAR cs/2016/07/copyc Rouge admiration for the rifles; one 5.56 caliber rifle, at-mass-shooters- police Baton cop killer in Dallas semiautomatic Springfield XD rising-baton- shooting Rouge, LA 7/17/2016 2016 10 days prior. 3 3 6 Other Yes Unclear Unknown handgun 9, 9mm Black M rouge-munich Mass Gordon Declaration 00575 Prior signs of Weapons Total possible mental obtained Where Type of Mental Health Case Location Date Year Summary Fatalities Injured victims Venue illness Mental Health legally obtained weapons Weapon details Race Gender Sources Sources Latitude Longitude Type Micah Xavier Johnson, a 25-year- old Army veteran, targeted police at a peaceful Black Lives Matter Izhmash-Saiga http://www.nytim protest, killing five 5.45mm (AK- es.com/2016/07/1 officers and injuring style) 1/us/dallas- nine others as well semiautomatic shooting-micah- as two civilians. rifle with large johnson- After a prolonged capacity police.html?_r=0; standoff in a magazines; http://www.wsj.c downtown building, Glock 9mm om/articles/dallas- law enforcement Semiautomatic handgun, .25- shooter- Dallas killed Johnson rifle, caliber purchased-guns- police Dallas, using a robot- online and or semiautomatic semiautomatic legally-official- shooting Texas 7/7/2016 2016 delivered bomb.
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