Case 8:17-cv-01596-PJM Document 116 Filed 05/18/18 Page 1 of 20 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND Greenbelt Division THE DISTRICT OF COLUMBIA and THE STATE OF MARYLAND, Plaintiffs, v. Civil Action No. 8:17-cv-01596-PJM DONALD J. TRUMP, President of the United States of America, in his official capacity and in his individual capacity, Defendant. DECLARATION OF BRANDON BROCKMYER IN SUPPORT OF PLAINTIFFS’ OPPOSITION TO DEFENDANT’S MOTION TO DISMISS IN HIS INDIVIDUAL CAPACITY I, BRANDON BROCKMYER, hereby declare under penalty of perjury, pursuant to 28 U.S.C. § 1746, that the following is true and correct: 1.! I am the Research Director for Citizens for Responsibility and Ethics in Washington, which serves as counsel to plaintiffs the District of Columbia and the State of Maryland in the above-captioned case. I am personally familiar with the facts set forth herein. 2.! Attached hereto as Exhibit 1 is a true and correct copy of the article titled “Trump discusses his presidential campaign at Linthicum GOP dinner,” published by the Capital Gazette on June 23, 2015, as it appeared on the website http://www.capitalgazette.com/news/ph-ac-cn- trump-republican-dinner-0624-20150623-story.html on May 16, 2018. In a video and audio recording published on the same website, President Trump stated, “I know Baltimore, I have so many friends . I’m in Baltimore a lot.” 3.! Attached hereto as Exhibit 2 is a true and correct copy of the article titled “Trump Criticizes Bush, Democrats in Maryland GOP Speech,” published by WBAL News Radio 1090 1 Case 8:17-cv-01596-PJM Document 116 Filed 05/18/18 Page 2 of 20 on June 23, 2015, as it appeared on the website http://www.wbal.com/article/115732/3/trump- criticizes-bush-democrats-in-maryland-gop-speech on May 16, 2018. In an audio recording published on the same website, President Trump stated, “We’ve had a great relationship to Maryland. I’ve been here so many times, and I have so many friends . we work very closely with the people of Maryland. So we’ve just had a really spectacular relationship to the people of Maryland.” 4.! Attached hereto as Exhibit 3 is a true and correct copy of the article titled “Updated: Trump Re-Issues Message to ‘Take the Country’ Back at Rally in Worcester County,” published by WBOC 16 on April 21, 2016, as it appeared on the website http://www.wboc.com/story/31775229/attenders-protestors-on-hand-ahead-of-trump-rally-in- worcester-county on May 16, 2018. 5.! Attached hereto as Exhibit 4 is a true and correct copy of the article titled “Trump draws thousands to Hagerstown airport rally,” published by Herald-Mail Media on April 24, 2016, as it appeared on the website https://www.heraldmailmedia.com/news/local/trump-draws- thousands-to-hagerstown-airport-rally/article_bc5f407c-0a76-11e6-b6b3-9304f74a9c19.html on May 16, 2018. 6.! Attached hereto as Exhibit 5 is a true and correct copy of the article titled “Trump supporters, protesters confront each other in Baltimore,” published by the Baltimore Sun on September 12, 2016, as it appeared on the website http://www.baltimoresun.com/news/maryland/politics/bs-md-ci-trump-rally-protest-20160912- story.html on May 16, 2018. 2 Case 8:17-cv-01596-PJM Document 116 Filed 05/18/18 Page 3 of 20 7.! Attached hereto as Exhibit 6 is a true and correct copy of the website titled “The Grounds: Camp David,” published by the White House, as it appeared on the website https://www.whitehouse.gov/about-the-white-house/camp-david/ on May 16, 2018. 8.! Attached hereto as Exhibit 7 is a true and correct copy of the article titled “Trump returns to Camp David in search of a legislative agenda,” published by the Baltimore Sun on January 5, 2018, as it appeared on the website http://www.baltimoresun.com/news/maryland/politics/blog/bs-md-trump-camp-david-20180105- story.html on May 16, 2018. 9.! Attached hereto as Exhibit 8 is a true and correct copy of the article titled “Trump addresses military families at Joint Base Andrews,” published by UPI on September 15, 2017, as it appeared on the website https://www.upi.com/Trump-addresses-military-families-at-Joint- Base-Andrews/1031505498032/ on May 16, 2018. 10.! Attached hereto as Exhibit 9 is a true and correct copy of the transcript titled “Remarks by President Trump at the Conservative Political Action Conference,” published by the White House and dated February 24, 2017, as it appeared on the website https://www.whitehouse.gov/briefings-statements/remarks-president-trump-conservative- political-action-conference/ on May 16, 2018. The transcript began by stating, “Gaylord National Resort & Convention Center,” indicating the location of the remarks. 11.! Attached hereto as Exhibit 10 is a true and correct copy of the article titled “Trump tells conservative gathering that his supporters are the GOP’s future,” published by the Washington Post on February 24, 2017, as it appeared on the website https://www.washingtonpost.com/politics/trump-tells-conservative-gathering-that-his-supporters- 3 Case 8:17-cv-01596-PJM Document 116 Filed 05/18/18 Page 4 of 20 are-the-partys-future/2017/02/24/5fd33764-fab7-11e6-bf01- d47f8cf9b643_story.html?utm_term=.0dedfdc2b2c5 on May 16, 2018. 12.! Attached hereto as Exhibit 11 is a true and correct copy of the website titled “2017 CPAC Speakers,” as it appeared on the website http://cpac.conservative.org/cpac-2017- speakers/ on May 16, 2018. The website listed at least 38 speakers other than President Trump who were at the time domestic government officials, including 17 state and local officials. The website also listed Nigel Farage as a speaker. 13.! Attached hereto as Exhibit 12 is a true and correct copy of the website titled “ARCHIVED: CPAC 2017 Agenda,” as it appeared on the website http://cpac.conservative.org/agenda/cpac2017/ on May 16, 2018. The website listed both President Trump and “Nigel Farage, Member of the European Parliament,” as scheduled to speak at CPAC on February 24, 2017. 14.! Attached hereto as Exhibit 13 is a true and correct copy of the article titled “Nigel Farage says Brexit and Trump win are ‘beginning of global revolution,’” published by The Guardian on February 24, 2017, as it appeared on the website https://www.theguardian.com/us- news/2017/feb/24/nigel-farage-cpac-speech-trump-brexit-global-revolution on May 16, 2018. 15.! Attached hereto as Exhibit 14 is a true and correct copy of the European Parliament website for Nigel Farage, member from the United Kingdom, as it appeared on the website http://www.europarl.europa.eu/meps/en/4525/NIGEL_FARAGE_home.html on May 16, 2018. 16.! Attached hereto as Exhibit 15 is a true and correct copy of the article titled “Inside Trump’s Secret Dinner: A Side of the President You Don’t Ever See,” published by IJR News on February 26, 2017, as it appeared on the website https://ijr.com/2017/02/810965-trump-ditched- 4 Case 8:17-cv-01596-PJM Document 116 Filed 05/18/18 Page 5 of 20 the-press-to-have-dinner-heres-how-the-president-acts-when-no-one-is-watching/ on May 16, 2018. The article described President Trump’s dinner at the BLT Prime at the Trump International Hotel on February 25, 2017, the day after his and Nigel Farage’s CPAC speeches. Specifically, the article stated: (a) “5:50 PM: . Inside the restaurant, on the first level, an uncommon guest is having a cocktail. It’s Nigel Farage, the Brexit leader and Trump ally, who is sitting at a table with three other people.”; (b) “8:17 PM: Without any announcement or indication, President Trump enters the hotel lobby which bears his name, . Trump is rushed by fans in the lobby as he makes his way to the steakhouse. Secret Service makes a barrier for him, and the President waves and shakes hands on his way. The young crew are the first in line. Also waiting in line as the President arrives is Nigel Farage.”; (c) This part of the article was followed by a photograph with the caption, “Trump and Farage meeting in the lobby”; (d) “Trump stops momentarily to speak with Farage and points upstairs in the steakhouse, seemingly inviting him to dinner.”; (e) This part of the article was followed by a photograph that showed President Trump pointing up; (f) “Trump eventually sits precisely where I expected he would hours earlier. He is joined by Farage, Governor Rick Scott of Florida, and his daughter Ivanka and her husband Jared Kushner.”; (g) The article later included photographs of Mr. Farage eating with President Trump and his other guests; (h) “11:01 PM: Nigel Farage can be found wandering the lobby of the hotel with a large glass of red wine. His teeth are wine-stained, and the British politician is happily swaying and speaking with anyone who approaches him.” 17.! Attached hereto as Exhibit 16 is a true and correct copy of the article titled, “‘Dinner with the Donald’: Nigel Farage joins Trump’s table at Washington hotel,” published by The Guardian on February 26, 2017, as it appeared on the website https://www.theguardian.com/politics/2017/feb/26/nigel-farage-dinner-with-the-donald-joins- 5 Case 8:17-cv-01596-PJM Document 116 Filed 05/18/18 Page 6 of 20 trumps-table-at-washington-hotel on May 16, 2018.