i've consulted with lawyers and i'm now addressing it simply to security needs. has he ever said anything approaching that? >> yes, judge hawkins, he has said several things. it's detailed in the briefs. part three, walks through the comments and shows that over time the president clarified that what he was talking about were islamic terrorist groups and the countries that shelter or sponsor them. and, over time, he and his advisers clarified what he was focused on were groups like isis and al qaeda. and, really, the one post inauguration statement they've got that we all know what that means, i would encourage the court to go back and look at the ceremony in which the president signed that executive order. >> the second one? >> that's the first one. they don't have anything on the second one. even if you say that's the first one and we'll carry that through -- >> statements that his surrogates have said the president is simply carrying out his campaign promises on this