Part 4 of 4
166. Select Committee to Investigate the January 6th Attack on the United States Capitol, Deposition of Jason Miller, (Feb. 3, 2022), pp. 117, 133.
167. Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (Mark Meadows Production), MM007666, MM007669 (November 12, 2020, email and attachment from Jason Miller to Mark Meadows transmitting abridged and full internal Trump Campaign memo); Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (Mark Meadows Production), MM011902, MM011974 (Nov. 12 and 13, 2020 text messages from Jason Miller to Mark Meadows discussing the investigation into Dominion and the lack of evidence of foreign interference).
168. Select Committee to Investigate the January 6th Attack on the United States Capitol, Deposition of Kayleigh McEnany, (Jan. 12, 2022), pp. 143, 291.
169. Donald J. Trump (@realDonaldTrump), Twitter, Nov. 16, 2020 8:22 a.m. ET, available at https://www.thetrumparchive.com/?result ... y+china%22 (archived); Donald J. Trump (@realDonaldTrump), Twitter, Nov. 16, 2020 8:26 a.m. ET, available at http://web.archive.org/web/202011161327 ... naldtrump/ status/1328328547598000130 (archived).
170. “Joint Statement from Elections Infrastructure Government Coordinating Council & the Election Infrastructure Sector Coordinating Executive Committees,” Department of Homeland Security's Cybersecurity & Infrastructure Security Agency, (Nov. 12, 2020), available at https://www.cisa.gov/news/2020/11/12/jo ... overnment- coordinating-council-election.
171. Mark Bowden and Matthew Teague, “How a County Clerk in Michigan Found Herself at the Center of Trump’s Attempt to Overthrow the Election,” Time, (Dec. 15, 2021), available at https://time.com/6128812/the-steal-antr ... michigan/; Emma Brown, Aaron C. Davis, Jon Swaine, and Josh Dawsey, “The Making of a Myth,” Washington Post, (May 9, 2021), available at https://www.washingtonpost.com/investig ... tive/2021/ trump-election-fraud-texas-businessman-ramsland-asog/.
172. Steven Nelson, “Michigan Republicans Claim Software Issue Undercounted Trump Votes,” New York Post, (Nov. 6, 2020), available at https://nypost.com/2020/11/06/michigan-gopclaims- software-issue-undercounted-trump-votes/.
173. “Isolated User Error in Antrim County Does Not Affect Election Results, Has No Impact on Other Counties or States,” Michigan Secretary of State, (Nov. 7, 2020), available at https:// www.michigan.gov/-/media/Project/Websit ... k.pdf?rev= 7a929e4d262e4532bbe574a3b82ddbcf; “Hand Audit of All Presidential Election Votes in Antrim County Confirms Previously Certified Results, Voting Machines Were Accurate,” Michigan Secretary of State, (Dec. 17, 2020), available at https://www.michigan.gov/sos/ resources/news/2020/12/17/hand-audit-of-all-presidential-election-votes-in-antrimcounty- confirms-previously-certified-result; J. Alex Halderman, Analysis of the Antrim County, Michigan November 2020 Election Incident, (Mar. 26, 2021), pp. 17-27, available at https://www.michigan.gov/-/media/Projec ... m.pdf?rev= fbfe881cdc0043a9bb80b783d1bb5fe9; Michigan Senate Oversight Committee, Report on the November 2020 Election in Michigan, (June 23, 2021), pp. 14-19, 36-55, available at https:// misenategopcdn.s3.us-east-1.amazonaws.com/99/doccuments/20210623/ SMPO_2020ElectionReport_2.pdf.
174. Michigan Senate Oversight Committee, Report on the November 2020 Election in Michigan, (June 23, 2021), pp. 14-15, available at https://misenategopcdn.s3.us-east- 1.amazonaws.com/99/doccuments/20210623/SMPO_2020ElectionReport_2.pdf.
175. “Isolated User Error in Antrim County Does Not Affect Election Results, Has No Impact on Other Counties or States,” Michigan Secretary of State website, (Nov. 7, 2020), available at https://www.michigan.gov/-/media/Projec ... /30lawens/ Antrim_Fact_Check.pdf?rev=7a929e4d262e4532bbe574a3b82ddbcf.
176. Michigan Senate Oversight Committee, Report on the November 2020 Election in Michigan, (June 23, 2021), pp. 14-19, available at https://misenategopcdn.s3.us-east- 1.amazonaws.com/99/doccuments/20210623/SMPO_2020ElectionReport_2.pdf.
177. Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (National Archives Production), 076P-R000010292_0001 (November 12, 2020, email from Tim Walberg to Molly Michel re: Additional Presidential Phone call follow up).
178. Select Committee to Investigate the January 6th Attack on the United States Capitol, Transcribed Interview of Chad Wolf, (Jan. 21, 2022), pp. 70-74; Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol, (Department of Homeland Security Production), CTRL0000033284, (Nov. 13, 2020, email from Molly Michael to Chad Wolf titled “Re: Michigan Letter”).
179. Select Committee to Investigate the January 6th Attack on the United States Capitol, Transcribed Interview of Chad Wolf, (Jan. 21, 2022), pp. 72-74; Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol, (Department of Homeland Security Production), CTRL0000033284, (Nov. 13, 2020, email from Molly Michael to Chad Wolf titled “Re: Michigan Letter”); Select Committee to Investigate the January 6th Attack on the United States Capitol, Transcribed Interview of Chad Wolf, (Jan. 21, 2022), Exhibit 44, CTRL0000926977 (Nov. 13, 2020 letter to Michigan Secretary of State Jocelyn Benson from Michigan State Senators Lana Theis and Tom Barrett).
180. Select Committee to Investigate the January 6th Attack on the United States Capitol, Transcribed Interview of Chad Wolf, (Jan. 21, 2022), pp. 74-77 Select Committee to Investigate the January 6th Attack on the United States Capitol, Transcribed Interview of Chad Wolf (Jan. 21, 2022), Exhibit 45, CTRL0000926978, (Nov. 16, 2020 email from Christopher Krebs responding to Chad Wolf, Matthew Travis, and Brandon Wales entitled “RE: Allegations”).
181. Select Committee to Investigate the January 6th Attack on the United States Capitol, Transcribed Interview of Chad Wolf, (Jan. 21, 2022), pp. 74-77; Select Committee to Investigate the January 6th Attack on the United States Capitol, Transcribed Interview of Chad Wolf (Jan. 21, 2022), Exhibit 45, CTRL0000926978, (Nov. 16, 2020 email from Christopher Krebs to Chad Wolf, Matthew Travis, and Brandon Wales entitled “RE: Allegations”); “Isolated User Error in Antrim County Does Not Affect Election Results, Has No Impact on Other Counties or States,” Michigan Secretary of State, (Nov. 7, 2020), available at https:// www.michigan.gov/-/media/Project/Websit ... k.pdf?rev= 7a929e4d262e4532bbe574a3b82ddbcf.
182. Select Committee to Investigate the January 6th Attack on the United States Capitol, Transcribed Interview of Chad Wolf, (Jan. 21, 2022), pp. 78-80. Even as the acting Secretary of DHS was providing Meadows information he received from his Director of CISA debunking the Dominion claims, the acting Assistant Secretary of DHS, Ken Cuccinelli, was providing back channel information to Meadows in a possible effort to promote the false Dominion claims. See Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (National Archives Production), TEXT0000072, TEXT0000073, (Nov. 12, 2020 text messages from Ken Cuccinelli to Mark Meadows) (Cuccinelli: “I have the dominion list of everywhere the machines are deployed that we know of. [I]t is pretty extensive. It is in my DHS email account. Where do you want me to send it?” Meadows then provided Cuccinelli with his personal email address.)
183. Chris Krebs #Protect2020 (@CISAKrebs), Twitter, Nov. 17, 2020 11:45 a.m. ET, available at https://twitter.com/CISAKrebs/status/13 ... 6624901120.
184. Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (National Archives Production), 076P-R000010360_0001, 076PR000010361_ 0001, (November 17, 2020 email and attached letter to Christopher Krebs from White House Office of Presidential Personnel, stating respectively that “the President has terminated your appointment” and that “Pursuant to the direction of the President, your appointment… is hereby terminated, effective immediately”).
185. Donald J. Trump (@realDonaldTrump), Twitter, Nov. 17, 2020 7:07 p.m. ET, available at http://web.archive.org/web/202011180405 ... mp/status/ 1328852352787484677 (archived); Donald J. Trump (@realDonaldTrump), Twitter, Nov. 17, 2020 7:07 p.m. ET, available at http://web.archive.org/web/20201118040930/https:// twitter.com/realDonaldTrump/status/1328852354049957888 (archived).
186. “Rudy Giuliani Trump Campaign Press Conference Transcript November 19: Election Fraud Claims,” Rev, (Nov. 19, 2020), available at https://www.rev.com/blog/transcripts/rudygiuliani- trump-campaign-press-conference-transcript-november-19-election-fraud-claims.
187. “Rudy Giuliani Trump Campaign Press Conference Transcript November 19: Election Fraud Claims,” Rev, (Nov. 19, 2020), available at https://www.rev.com/blog/transcripts/rudygiuliani- trump-campaign-press-conference-transcript-november-19-election-fraud-claims.
188. Select Committee to Investigate the January 6th Attack on the United States Capitol, Transcribed Interview of Hope Hicks, (Oct. 25, 2022), pp. 88-91. See also Tucker Carlson: “Time for Sidney Powell to Show Us Her Evidence: We Asked the Trump Campaign Attorney for Proof of her Bombshell Claims. She Gave Us Nothing,” Fox News, (Nov. 19, 2020), available at https://www.foxnews.com/opinion/tucker- ... ctionfraud.
189. Jenna Ellis (@JennaEllisEsq), Twitter, Nov. 22, 2020, 5:23 p.m. ET, available at https:// twitter.com/JennaEllisEsq/status/1330638034619035655.
190. Donald J. Trump, (@realDonaldTrump), Twitter, Nov. 19, 2020 12:41 a.m. ET and 3:47 p.m. ET, available at https://www.thetrumparchive.com/?search ... n-izing%22 (archived).
191. One America News Network, “Cyber Analyst on Dominion Voting: Shocking Vulnerabilities,” YouTube, at 0:41-1:14, 1:37-2:23, 2:42-3:36, Nov. 15, 2020, available at https:// www.youtube.com/watch?v=eKcPoCNW8AA.
192. Ron Watkins, (@codemonkeyz), Twitter, Nov. 19, 2020 12:45 a.m. ET, available at http:// web.archive.org/web/20201121092200/https://twitter.com/CodeMonkeyZ/status/ 1329299640848584710 (archived); Ron Watkins, (@codemonkeyz), Twitter, Nov. 19, 2020 12:46 a.m. ET, available at http://web.archive.org/web/202012011754 ... itter.com/ CodeMonkeyZ/status/1329300069623820289 (archived); Donald J. Trump, Twitter, Nov. 21, 2020 11:30 p.m. ET, Nov. 21, 2020, 11:31 p.m. ET, Nov. 21, 2020, 11:32 p.m. ET, Nov. 22, 2020, 3:35 p.m. ET, available at https://www.thetrumparchive.com/?search ... inionizing% 22&dates=%5B%222020-11-20%22%2C%222020-11-24%22%5D (archived).
193. Barr met with President Trump between election day and January 6th on November 23, December 1, and December 14. See Select Committee to Investigate the January 6th Attack on the United States Capitol, Transcribed Interview of William Barr, (Jun. 2, 2022), pp. 16, 22, 28.
194. Select Committee to Investigate the January 6th Attack on the United States Capitol, Transcribed Interview of William Barr, (Jun. 2, 2022), pp. 25, 27, 50; William Barr, One Damn Thing After Another: Memoirs of an Attorney General, (New York: HarperCollins, 2022), at pp. 539, 554.
195. Select Committee to Investigate the January 6th Attack on the United States Capitol, Transcribed Interview of William Barr, (Jun. 2, 2022), p. 19.
196. Factba.se, “Interview: Maria Bartiromo Interviews Donald Trump on Fox News - November 29, 2020,” Vimeo, Nov. 29, 2020, at. 1:00-1:43, 3:23-4:36, available at https://vimeo.com/ 485180163.
197. Factba.se, “Interview: Maria Bartiromo Interviews Donald Trump on Fox News - November 29, 2020,” Vimeo, at 1:00-1:43, Nov. 29, 2020, available at https://vimeo.com/485180163.
198. Factba.se, “Interview: Maria Bartiromo Interviews Donald Trump on Fox News - November 29, 2020,” Vimeo, at 1:50-2:40, Nov. 29, 2020, available at https://vimeo.com/485180163.
199. Factba.se, “Interview: Maria Bartiromo Interviews Donald Trump on Fox News - November 29, 2020,” Vimeo, at 3:50-4:24, 22:40-23:52, 24:26-24:50, Nov. 29, 2020, available at https:// vimeo.com/485180163.
200. Select Committee to Investigate the January 6th Attack on the United States Capitol, Transcribed Interview of William Barr, (Jun. 2, 2022), pp. 22, 25-26.
201. Select Committee to Investigate the January 6th Attack on the United States Capitol, Transcribed Interview of William Barr, (Jun. 2, 2022), pp. 22, 25-26.
202. “Donald Trump Speech on Election Fraud Claims Transcript December 2,” Rev, (Dec. 2, 2020), available at https://www.rev.com/blog/transcripts/do ... nelection- fraud-claims-transcript-december-2.
203. King v. Whitmer, 505 F. Supp. 3d 720, 738 (E.D. Mich. 2020)
204. Bowyer v. Ducey, 506 F. Supp. 3d 699, 723 (D. Ariz. 2020) (finding the complaint “void of plausible allegations that Dominion voting machines were hacked or compromised in Arizona during the 2020 General Election”).
205. “Isolated User Error in Antrim County Does Not Affect Election Results, Has No Impact on Other Counties or States,” Michigan Secretary of State, (Nov. 7, 2020), available at https:// www.michigan.gov/-/media/Project/Websit ... k.pdf?rev= 7a929e4d262e4532bbe574a3b82ddbcf.
206. Decision and Order Granting Plaintiff's Motion for an Ex Parte Temporary Restraining Order, Show Cause Order and Preliminary Injunction, No. 2020009238CZ (Mich. Cty. Cir. Ct. Dec. 4, 2020).
207. Rudy W. Giuliani (@RudyGiuliani), Twitter, Dec. 4, 2020 7:12 p.m. ET, available at https:// twitter.com/RudyGiuliani/status/1335014224532221952?s=20&t=20AZkk4gS2DeBo6q6QR-mw; Ronn Blitzer, “Trump Legal Team Celebrates after Michigan Judge Allows Probe of Dominion Voting Machines,” Fox News, (Dec. 6, 2020), available at https://www.foxnews.com/ politics/trump-legal-team-michigan-antrim-county-judge-order-dominion-machines; Select Committee to Investigate the January 6th Attack on the United States Capitol, Transcribed Interview of Bernard Kerik, (Jan. 13, 2022), pp. 19, 147.
208. Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (National Archives Production), 076P-R000001368_00001, pp. 1, 6 (Allied Security Operations Group Antrim Michigan Forensics Report, dated Dec. 13, 2020).
209. Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (National Archives Production), 076P-R00001254_00001 (December 14, 2020, email from Joanna Miller to Peter Navarro attaching the ASOG Report and noting that "POTUS and VPOTUS are briefed").
210. See, e.g., Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (Department of Justice Production), HouseSelect-Jan6- PartII-01132022-000798(December 14, 2020, email from Molly Michael re: From POTUS asking the AG to look at ASOG report); Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (National Archives Production), 076PR000001337_ 00001(December 14, 2020, email from Molly Michael to Acting Attorney General Jeffrey Rosen re: From POTUS attaching ASOG report); Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (National Archives Production), 076P-R000001367_00001(December 14, 2020, email from Molly Michael to Michigan Senate Majority Leader Mike Shirkey re: From POTUS attaching ASOG report); Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (National Archives Production) 076P-R000001361_00001(December 14, 2020, email from Molly Michael to Senator Kelly Loeffler re: From POTUS attaching ASOG report); Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (National Archives Production), 076PR000001358_ 00001(December 14, 2020, email from Molly Michael to Arizona Governor Doug Ducey re: From POTUS attaching ASOG report); Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (National Archives Production), 076P-R000001370_00001 (December 14, 2020, email from Molly Michael to Republican Party Chairwoman Ronna McDaniel re: From POTUS attaching ASOG report); Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (National Archives Production), 076P-R000001378_00001 (December 14, 2020, email from Molly Michael to Pennsylvania State Senator Doug Mastriano re: From POTUS attaching ASOG report).
211. Donald J. Trump (@realDonaldTrump), Twitter, Dec. 14, 2020 2:59 p.m. ET, available at http://web.archive.org/web/202012142144 ... mp/status/ 1338574268154646528 (archived).
212. Select Committee to Investigate the January 6th Attack on the United States Capitol, Transcribed Interview of William Barr, (Jun. 2, 2022), pp. 28-29.
213. Select Committee to Investigate the January 6th Attack on the United States Capitol, Transcribed Interview of William Barr, (Jun. 2, 2022), p. 29.
214. Select Committee to Investigate the January 6th Attack on the United States Capitol, Transcribed Interview of William Barr, (Jun. 2, 2022), pp. 29-30.
215. Select Committee to Investigate the January 6th Attack on the United States Capitol, Transcribed Interview of William Barr, (Jun. 2, 2022), pp. 29-30.
216. See, e.g., Select Committee to Investigate the January 6th Attack on the United States Capitol, Transcribed Interview of William Barr, (Jun. 2, 2022), pp. 29-30.
217. See Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (Department of Homeland Security Production) CTRL0000915111, CTRL0000915117-CTRL0000915118 (draft analyses of ASOG report). Notably, the final version of this review, which had been requested by the Attorney General, was edited by senior DHS officials to remove the language most critical of ASOG before being sent to the Department of Justice by Acting Assistant Secretary Ken Cuccinelli. See Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (Department of Homeland Security Production) CTRL0000915120 (emails circulating draft analyses), CTRL0000926941 (noting report was “currently in the Secretary’s office”); Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (Department of Justice Production) HCOR-Pre-CertificationEvents- 07262021-000687-HCOR-Pre-CertificationEvents-07262021-000688 (email and report provided to Donoghue by Cuccinelli); Select Committee to Investigate the January 6th Attack on the United States Capitol, Transcribed Interview of Richard Peter Donoghue, (Oct. 1, 2021), pp. 29-31.
218. See Michigan Senate Oversight Committee, Report on the November 2020 Election in Michigan, (June 23, 2021), p. 16, available at https://misenategopcdn.s3.us-east- 1.amazonaws.com/99/doccuments/20210623/SMPO_2020ElectionReport_2.pdf; J. Alex Halderman, Analysis of the Antrim County, Michigan November 2020 Election Incident,” (Mar. 26, 2021), available at https://www.michigan.gov//media/Project/Websites/sos/ 30lawens/Antrim.pdf?rev=fbfe881cdc0043a9bb80b783d1bb5fe9.
219. For example, President Trump and others frequently cited ASOG’s finding that the Dominion machines had a “68% error rate,” but that conclusion was based on a complete misunderstanding of the scanner log files reviewed by ASOG. Their report also claimed that, due to these perceived “errors,” a “staggering number of votes” were determined through an adjudication process that allowed for manipulation of votes, but no adjudication software was installed on the Dominion machines. J. Alex Halderman, Analysis of the Antrim County, Michigan November 2020 Election Incident, (Mar. 26, 2021), pp. 40-41, available at https:// www.michigan.gov/-/media/Project/Websit ... m.pdf?rev= fbfe881cdc0043a9bb80b783d1bb5fe9.
220. Halderman concluded that “I am not aware of any credible evidence that any security problem was ever exploited against Antrim County's election system. As my analysis shows, the anomalies that occurred in the November 2020 results are fully explained by human error.” J. Alex Halderman, Analysis of the Antrim County, Michigan November 2020 Election Incident, (Mar. 26, 2021), p. 46, available at https://www.michigan.gov/-/media/ Project/Websites/sos/30lawens/Antrim.pdf?rev=fbfe881cdc0043a9bb80b783d1bb5fe9.
221. "Audits of the November 3, 2020 General Election," Michigan Secretary of State, (April 21, 2021), p. 32, available at https://www.michigan.gov/-/media/Project/Websites/sos/ 30lawens/BOE_2020_Post_Election_Audit_Report_04_21_21.pdf?rev= a3c7ee8c06984864870c540a266177f2.; “Hand Count Calculation Sheet (Office: President of the United States, County: Antrim),” Michigan Secretary of State, available at https:// www.michigan.gov/-/media/Project/Websites/sos/30lawens/ AntrimCounty_Presidential_Race_Full_Hand_Count_November2020.pdf?rev= 0bf12f08c33444c59bd145fbcfbb3e40.
222. Select Committee to Investigate the January 6th Attack on the United States Capitol, Transcribed Interview of Bernard Kerik, (Jan. 13, 2022), p. 182.
223. Select Committee to Investigate the January 6th Attack on the United States Capitol, Hearing on the January 6th Investigation, 117th Cong., 2d sess., (June 23, 2022), available at https://www.govinfo.gov/committee/house-january6th.
224. Select Committee to Investigate the January 6th Attack on the United States Capitol, Transcribed Interview of Derek Lyons, (Mar. 17, 2022), pp. 21-22, 99; Select Committee to Investigate the January 6th Attack on the United States Capitol, Transcribed Interview of Pasquale Anthony “Pat” Cipollone, (Jul. 8, 2022), pp. 44-50.
225. Select Committee to Investigate the January 6th Attack on the United States Capitol, Transcribed Interview of Pasquale Anthony “Pat” Cipollone, (Jul. 8, 2022), pp. 42-43.
226. Select Committee to Investigate the January 6th Attack on the United States Capitol, Transcribed Interview of Pasquale Anthony “Pat” Cipollone, (Jul. 8, 2022), p. 50.
227. Select Committee to Investigate the January 6th Attack on the United States Capitol, Transcribed Interview of Eric Herschmann, (Apr. 6, 2022), p. 129.
228. Select Committee to Investigate the January 6th Attack on the United States Capitol, Transcribed Interview of Robert O'Brien, (Aug. 23, 2022), pp. 163-65.
229. Select Committee to Investigate the January 6th Attack on the United States Capitol, Transcribed Interview of Chad Wolf, (Jan. 21, 2022), pp. 97-98, 102-103; Select Committee to Investigate the January 6th Attack on the United States Capitol, Transcribed Interview of Ken Cuccinelli, (Dec. 7, 2021), pp. 49-54.
230. Select Committee to Investigate the January 6th Attack on the United States Capitol, Deposition of Rudolph Giuliani (May 20, 2022), pp. 157-59; Select Committee to Investigate the January 6th Attack on the United States Capitol, Deposition of Sidney Powell, (May 7, 2022), pp. 102-03; Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol, (Jenna Ellis Production), J.007465Ellis, J.007467Ellis (December 28-29, 2020, emails with Katherine Freiss, Doug Mastriano, Christina Bobb, Giuliani, and others about accessing voting machines); Emma Brown and Jon Swaine, “Inside the Secretive Effort by Trump Allies to Access Voting Machines,” Washington Post, (Oct. 28, 2022), available at https://www.washingtonpost.com/investig ... feecounty- georgia-voting-trump/.
231. Brad Raffensperger, Integrity Counts (New York: Simon & Schuster, 2021), p. 191 (reproducing the call transcript);Amy Gardner and Paulina Firozi, “Here’s the Full Transcript and Audio of the Call Between Trump and Raffensperger,” Washington Post, (Jan. 5, 2021), available at https://www.washingtonpost.com/politics ... ptgeorgia- vote/2021/01/03/2768e0cc-4ddd-11eb-83e3-322644d82356_story.html.
232. Brad Raffensperger, Integrity Counts (New York: Simon & Schuster, 2021), p. 191 (reproducing the call transcript); Amy Gardner and Paulina Firozi, “Here’s the Full Transcript and Audio of the Call Between Trump and Raffensperger,” Washington Post, (Jan. 5, 2021), available at https://www.washingtonpost.com/politics ... ptgeorgia- vote/2021/01/03/2768e0cc-4ddd-11eb-83e3-322644d82356_story.html.
233. “Donald Trump Rally Speech Transcript Dalton, Georgia: Senate Runoff Election,” Rev, (Jan. 4, 2021), available at https://www.rev.com/blog/transcripts/do ... ranscript- dalton-georgia-senate-runoff-election.
234. “Donald Trump Rally Speech Transcript Dalton, Georgia: Senate Runoff Election,” Rev, (Jan. 4, 2021), available at https://www.rev.com/blog/transcripts/do ... ranscript- dalton-georgia-senate-runoff-election.
235. Select Committee to Investigate the January 6th Attack on the United States Capitol, Deposition of Rudolph Giuliani, (May 20, 2022), p. 111.
236. Select Committee to Investigate the January 6th Attack on the United States Capitol, Deposition of Rudolph Giuliani, (May 20, 2022), p. 166.
237. Select Committee to Investigate the January 6th Attack on the United States Capitol, Transcribed Interview of Bernard Kerik (Jan. 13, 2022), p. 182. Kerik also emailed President Trump’s chief of staff, Mark Meadows, on December 28, 2020, writing: “We can do all the investigations we want later, but if the president plans on winning, it’s the legislators that have to be moved, and this will do just that.” Document on file with the Select Committee (National Archives Production) 076P-R000004125_0001.
238. Select Committee to Investigate the January 6th Attack on the United States Capitol, Transcribed Interview of Christina Bobb, (Apr. 21, 2022), p. 46.
239. Select Committee to Investigate the January 6th Attack on the United States Capitol, Deposition of Sidney Powell, (May 7, 2022), pp. 89-96.
240. Defendant’s Motion to Dismiss at 27-28, U.S. Dominion, Inc. v. Powell, No. 1:21-cv-00040 (D.D.C. filed Mar. 22, 2021), ECF No. 22-2.
241. Justin Gray, “Georgia Election Officials Show Frame-by-Frame What Happened in Fulton Surveillance Video,” WSB-TV, (Dec. 4, 2020), https://www.wsbtv.com/news/politics/georgiaelection- officials-show-frame-by-frame-what-really-happened-fulton-surveillance-video/
242. 11Alive, “Second Georgia Senate election hearing,” YouTube, at 5:31:50-5:32:45, Dec. 3, 2020, available at https://www.youtube.com/watch?v=hRCXUNOwOjw.
243. See, e.g., Donald J. Trump, (@realDonaldtrump), Twitter, Dec. 14, 2020 8:57 a.m. ET, available at http://web.archive.org/web/202012171817 ... naldTrump/ status/1338483200046354434; Brad Raffensperger, Integrity Counts (New York: Simon & Schuster, 2021), p. 191 (reproducing the call transcript); Amy Gardner and Paulina Firozi, “Here’s the Full Transcript and Audio of the Call Between Trump and Raffensperger,” Washington Post, (Jan. 5, 2021), available at https://www.washingtonpost.com/politics ... ensperger- call-transcript-georgia-vote/2021/01/03/2768e0cc-4ddd-11eb-83e3- 322644d82356_story.html.
244. Brad Raffensperger, Integrity Counts (New York: Simon & Schuster, 2021), p. 191 (reproducing the call transcript); Amy Gardner and Paulina Firozi, “Here’s the Full Transcript and Audio of the Call Between Trump and Raffensperger,” Washington Post, (Jan. 5, 2021), available at https://www.washingtonpost.com/politics ... ptgeorgia- vote/2021/01/03/2768e0cc-4ddd-11eb-83e3-322644d82356_story.html.
245. Ryan Taylor, “Donald Trump Georgia Rally Transcript Before Senate Runoff Elections December 5,” Rev, (Dec. 5, 2020), available at https://www.rev.com/blog/transcripts/ donald-trump-georgia-rally-transcript-before-senate-runoff-elections-december-5.
246. “Donald Trump Vlog: Contesting Election Results—December 22, 2020,” Factba.se, (Dec. 22, 2020), at 9:11 – 9:31, available at https://factba.se/transcript/donald-tru ... ontesting- election-results-december-22-2020.
247. Ryan Taylor, “Donald Trump Georgia Phone Call Transcript with Sec. of State Brad Raffensperger: Says He Wants to ‘Find’ Votes,” Rev, (Jan. 4, 2021), available at https:// www.rev.com/blog/transcripts/donald-tru ... ensperger- recording.
248. U.S. Senate Committee on the Judiciary, Transcribed Interview of Jeffrey Rosen, (Aug. 7, 2021), pp. 30-31, available at https://www.judiciary.senate.gov/imo/media/doc/ Rosen%20Transcript.pdf.
249. Select Committee to Investigate the January 6th Attack on the United States Capitol, Transcribed Interview of Richard Peter Donoghue, (Oct. 1, 2021), pp. 42-43.
250. Brad Raffensperger, Integrity Counts (New York: Simon & Schuster, 2021), p. 191 (reproducing the call transcript); Amy Gardner and Paulina Firozi, “Here’s the Full Transcript and Audio of the Call Between Trump and Raffensperger,” Washington Post, (Jan. 5, 2021), available at https://www.washingtonpost.com/politics ... ptgeorgia- vote/2021/01/03/2768e0cc-4ddd-11eb-83e3-322644d82356_story.html.
251. Brad Raffensperger, Integrity Counts (New York: Simon & Schuster, 2021), p. 191 (reproducing the call transcript); Amy Gardner and Paulina Firozi, “Here’s the Full Transcript and Audio of the Call Between Trump and Raffensperger,” Washington Post, (Jan. 5, 2021), available at https://www.washingtonpost.com/politics ... ptgeorgia- vote/2021/01/03/2768e0cc-4ddd-11eb-83e3-322644d82356_story.html.
252. Brad Raffensperger, Integrity Counts (New York: Simon & Schuster, 2021), p. 191 (reproducing the call transcript); Amy Gardner and Paulina Firozi, “Here’s the Full Transcript and Audio of the Call Between Trump and Raffensperger,” Washington Post, (Jan. 5, 2021), available at https://www.washingtonpost.com/politics ... ptgeorgia- vote/2021/01/03/2768e0cc-4ddd-11eb-83e3-322644d82356_story.html.
253. Declaration of Frances Watson at 1-3, Pearson v. Kemp, 831 F. App'x. 467 (N.D. Ga. 2020) (No. 1:20-cv-04809), ECF No. 72-1.
254. Declaration of Frances Watson at 1-3, Pearson v. Kemp, 831 F. App'x. 467 (N.D. Ga. 2020) (No. 1:20-cv-04809), ECF No. 72-1.
255. U.S. Senate Judiciary Committee, Transcribed Interview of Byung J. “BJay” Pak, (Aug. 11, 2021), pp. 14-25, available at https://www.judiciary.senate.gov/imo/media/doc/ Pak%20Transcript.pdf; Response of the Georgia Secretary of State to the Court's Order of September 20, 2021 at 4-6, Favorito v. Wan, No. 2020CV343938 (Ga. Super. Ct. filed Oct. 12, 2021).
256. “Georgia Election Officials Briefing Transcript December 7: Will Recertify Election Results Today,” Rev, (December 7, 2020), available at https://www.rev.com/blog/transcripts/ georgia-election-officials-briefing-transcript-december-7-will-recertify-election-resultstoday; Response of the Georgia Secretary of State to the Court's Order of September 20, 2021 at 4-6, Favorito v. Wan, No. 2020CV343938 (Ga. Super. Ct. filed Oct. 12, 2021).
257. “Georgia Election Officials Briefing Transcript December 7: Will Recertify Election Results Today,” Rev, (December 7, 2020), available at https://www.rev.com/blog/transcripts/ georgia-election-officials-briefing-transcript-december-7-will-recertify-election-resultstoday; Response of the Georgia Secretary of State to the Court's Order of September 20, 2021, at 4-6 and Exhibit A: Videotaped Deposition of James P. Callaway (Deputy Chief Investigator of the Office of the Secretary of State) at 29-35, Favorito v. Wan, No. 2020CV343938 (Ga. Super. Ct. filed Oct. 12, 2021) available at, https://s3.documentcloud.org/documents/ 21084096/favorito-sos-brief-in-response-to-order-of-92021-with-exs-a-and-b.pdf.
258. Declaration of Frances Watson at 2-3, Pearson v. Kemp, 831 F. App'x. 467 (N.D. Ga. 2020) (No. 1:20-cv-04809), ECF No. 72-1; U.S. Senate Judiciary Committee, Transcribed Interview of Byung J. “BJay” Pak, (August 11, 2021), pp. 14-25, available at https:// www.judiciary.senate.gov/imo/media/doc/ ... script.pdf.
259. Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol, (National Archives Production), 076P-R000004670_0001-0013, 076PR000004888_ 0001-0013, 076P-R000004948_0001-0013 (January 5, 2021, emails from Molly Michael re: “from POTUS” to Senators Josh Hawley and Ted Cruz and to Representative Jim Jordan attaching Background Briefing on 2020 Fraud).
260. “Transcript of Trump’s Speech at Rally Before US Capitol Riot,” Associated Press, (Jan. 13, 2021), available at https://apnews.com/article/election-202 ... mpcapitol- siege-media-e79eb5164613d6718e9f4502eb471f27.
261. In the Matter of Rudolph W. Giuliani, No. 2021-00506, slip op at *2, 22 (N.Y. App. Div. May 3, 2021), available at https://int.nyt.com/data/documenttools/ ... uspension/ 1ae5ad6007c0ebfa/full.pdf.
262. GA House Mobile Streaming, Governmental Affairs 12.10.20, Vimeo – Livestream, at 2:09:03 to - 2:13:10, available at https://livestream.com/accounts/2522547 ... s/9117221/ videos/214677184.
263. Select Committee to Investigate the January 6th Attack on the United States Capitol, Hearing on the January 6th Investigation, 117th Cong., 2d sess., (June 21, 2022), available at https://www.govinfo.gov/committee/house-january6th.
264. See John Danforth, Benjamin Ginsberg, Thomas B. Griffith, et al., “Lost, Not Stolen: The Conservative Case that Trump Lost and Biden Won the 2020 Presidential Election,” (July 2022), p. 3, available at https://lostnotstolen.org/download/378/.
265. Opinion and Order at *6, 13, Costantino v. Detroit, No. 20-014780-AW (Mich. Cty. Cir. Ct. filed Nov. 13, 2020), available at https://electioncases.osu.edu/wp-conten ... s/2020/11/ Costantino-v-Detroit-Opinion-and-Order.pdf.
266. Complaint, Exhibit 2: Affidavit of Jesse Richard Morgan at 2, 10, Mecalfe v. Wolf, 2020 Pa. Commw. LEXIS 794 (Pa. Commw. Ct. 2020) (No. 636 MD 2020), available at https:// www.pacourts.us/Storage/media/pdfs/2021 ... -10836.pdf.
267. See, e.g., Donald J. Trump (@realdonaldtrump), Twitter, Dec. 1, 2020 2:31 p.m. ET, available at http://web.archive.org/web/202012020149 ... naldtrump/ status/1333856259662077954 (archived); Donald J. Trump (@realdonaldtrump), Twitter, Dec. 1, 2020 3:49 p.m. ET, available at http://web.archive.org/web/20201201221335/https:// twitter.com/realDonaldTrump/status/1333875814585282567 (archived); Donald J. Trump (@realdonaldtrump), Twitter, Dec 2, 2020 6:42 p.m. ET, available at http://web.archive.org/ web/20201203024425/https://twitter.com/realDonaldTrump/status/1334327204847775744 (archived).
268. Select Committee to Investigate the January 6th Attack on the United States Capitol, Transcribed Interview of Richard Peter Donoghue, (Oct. 1, 2021), p. 60; Select Committee to Investigate the January 6th Attack on the United States Capitol, Transcribed Interview of William Barr, (Jun. 2, 2022), pp. 45-46.
269. FOX News, “Sean Hannity,” Nov. 19, 2020, available at https://archive.org/details/ FOXNEWSW_20201120_060000_Hannity?start/1983.1.end/2077.5.
270. Brandon Waltens, “VIDEO: Wagons, Suitcases, and Coolers Roll into Detroit Voting Center at 4 AM [UPDATED],” Texas Scorecard, (Nov. 4, 2020), available at https://texasscorecard.com/ federal/video-wagons-suitcases-and-coolers-roll-into-detroit-voting-center-at-4-am/; “Rudy Giuliani Trump Campaign Press Conference Transcript November 19: Election Fraud Claims,” Rev, (Nov. 19, 2020), at 22:29-26:53, available at https://www.rev.com/blog/ transcripts/rudy-giuliani-trump-campaign-press-conference-transcript-november-19- election-fraud-claims.
271. Affidavit of Christopher Thomas ¶ 18, Texas v. Pennsylvania, 592 U.S. ____ (2020) (describing ballot delivery), available at https://www.supremecourt.gov/DocketPDF/22/22O155/ 163387/20201210145418055_22O155%20MI%20APP.pdf; see also Opinion and Order at *6, 13, Costantino v. Detroit, No. 20-014780-AW (Mich. Cty. Cir. Ct. filed Nov. 13, 2020), available at https://electioncases.osu.edu/wp-conten ... pinionand- Order.pdf (relying on Christopher Thomas’ affidavit to deny a petition for various relief related to allegations that the November 3, 2020 election in Michigan was fraudulent).
272. “How a WXYZ Wagon Sparked False Election Fraud Claims in Detroit,” WXYZ, (Nov. 5, 2020), available at https://www.wxyz.com/news/how-a-wxyz-wa ... audclaims- in-detroit.
273. “Election Summary Report,” City of Detroit, (Nov. 19, 2020), available at https:// detroitmi.gov/document/november-3-2020-general-election-official-results.
274. A canvassing process in every State verifies that the number of voters indicated as having voted matches the number of ballots cast. If, as claimed, tens of thousands of illegitimate ballots were counted at the TCF Center in Detroit, the total number of ballots counted would be substantially higher than the total number of voters who voted, but in Detroit slightly fewer ballots were counted than voters who were listed as having voted. The net number of ballots for the City of Detroit counting boards was 21 more names than ballots, out of approximately 174,000 absentee votes cast. Michigan Secretary of State, “Audits of the November 3, 2020 General Election,” (Apr. 21, 2021), p. 20, available at https:// www.michigan.gov/-/media/Project/Websites/sos/30lawens/ BOE_2020_Post_Election_Audit_Report_04_21_21.pdf?rev= a3c7ee8c06984864870c540a266177f2.
275. Approximately 4.2 million ballots were cast in-person on election day and 2.6 million mail and absentee ballots were cast. See “Pennsylvania's Election Stats,” Pennsylvania Department of State, (accessed Dec. 4, 2022), available at https://www.dos.pa.gov/ VotingElections/BEST/Pages/BEST-Election-Stats.aspx;“Official Returns – 2020 Presidential Election,” Pennsylvania Department of State, (accessed Dec. 4, 2022), available at https:// www.electionreturns.pa.gov/General/Summ ... ctionType= G&IsActive=0.
276. Donald J. Trump, (@realDonaldTrump), Twitter, Nov. 28, 2020 12:09 a.m. ET, available at http://web.archive.org/web/202011280809 ... mp/status/ 1332552283553476608 (archived), retweeting Senator Doug Mastriano (@SenMastriano), Twitter, Nov. 27, 2020, 1:59 p.m. ET, available at https://twitter.com/SenMastriano/status/ 1332398733401591808.
277. Jessica Calefati, “Fact-Checking False Claims about Pennsylvania's Presidential Election by Trump and His Allies,” Philadelphia Inquirer, (Dec. 7, 2020), available at https:// www.inquirer.com/politics/election/penn ... act-check- 20201206.html.
278. Donald J. Trump (@realDonaldTrump), Twitter, Dec. 28, 2020, 4:00 p.m. ET, available at http://web.archive.org/web/202012282113 ... mp/status/ 1343663159085834248 (archived); Donald J. Trump (@realDonaldTrump), Twitter, Dec. 29, 2020, 8:59 a.m. ET, available at http://web.archive.org/web/20201229205204/https:// twitter.com/realDonaldTrump/status/1343919651336712199 (archived); Donald J. Trump (@realDonaldTrump), Twitter, Dec. 29, 2020, 5:55 p.m. ET, available at http:// web.archive.org/web/20201229225512/https://twitter.com/realdonaldtrump/status/ 1344054358418345985. Note that timestamps in archived tweets may reflect a time zone different from that where the tweet originated.
279. See Pennsylvania House Republican Caucus, “PA Lawmakers: Numbers Don’t Add Up, Certification of Presidential Results Premature and In Error,” (Dec. 28, 2020), available at https://www.pahousegop.com/News/18754/L ... s-Numbers- Don%E2%80%99t-Add-Up,-Certification-of-Presidential-Results-Premature-and-In-Error. Representative Ryan also promoted the groundless claim of an unexplained discrepancy of 400,000 mail-in ballots in the state’s database, which was based entirely on his ignorance of the fact that the database in question accounts for mail-in ballots and absentee ballots separately. Senate Committee on Homeland Security & Governmental Affairs, Examining Irregularities in the 2020 Election, (Dec. 16, 2020), Written Testimony of Pennsylvania State Representative Frank Ryan, available at https://www.hsgac.senate.gov/imo/media/doc/ Testimony-Ryan-2020-12-16.pdf; Senate Committee on Homeland Security & Governmental Affairs, Examining Irregularities in the 2020 Election, (Dec. 16, 2020), Letter Submitted by Pennsylvania Secretary of the Commonwealth Kathy Boockvar, available at https:// www.dos.pa.gov/about-us/Documents/state ... hnson-and- Peters.pdf.
280. “Dept. of State: Republicans' Election Claims Are ‘Repeatedly Debunked Conspiracy Theories’,” WJAC-TV, (Dec. 29, 2020), available at https://wjactv.com/news/local/dept-of-staterepublicans- election-claims-are-repeatedly-debunked-conspiracy-theories.
281. Senate Committee on the Judiciary, Transcribed Interview of Richard Donoghue, (Aug. 6, 2021), p. 156, available at https://www.judiciary.senate.gov/imo/media/doc/ Donoghue%20Transcript.pdf.
282. See “Donald Trump Rally Speech Transcript Dalton, Georgia: Senate Runoff Election,” Rev, (Jan. 4, 2021), at 58:09, available at https://www.rev.com/blog/transcripts/donald-trumprally- speech-transcript-dalton-georgia-senate-runoff-election; “Transcript of Trump’s Speech at Rally Before US Capitol Riot,” Associated Press (January 13, 2021), available at https://apnews.com/article/election-202 ... 02eb471f27.
283. Select Committee to Investigate the January 6th Attack on the United States Capitol, Transcribed Interview of William Barr, (Jun. 2, 2022), p. 29; Affidavit of Russell James Ramsland, Jr., 556 F. Supp. 3d. 680, 724 (E.D. Mich. 2021), ECF 6-24, available at https:// www.courtlistener.com/docket/18693929/6 ... v-whitmer/. Ramsland submitted a similar affidavit in a case in Georgia. See Affidavit of Russell Ramsland, Wood v. Raffensperger, 501 F. Supp. 3d 1310 (N.D. Ga. 2020), ECF No. 7-1.
284. Affidavit of Russell Ramsland, Wood v. Raffensperger, 501 F. Supp. 3d 1310 (N.D. Ga. 2020), ECF No. 7-1.
285. Aaron Blake, “The Trump Campaign’s Much-Hyped Affidavit Features a Big, Glaring Error,” Washington Post, (Nov. 20, 2020), available at https://www.washingtonpost.com/politics/ 2020/11/20/trump-campaigns-much-hyped-affidavit-features-big-glaring-error/.
286. For example, Ramsland claimed 781.91% turnout in North Muskegon (actual turnout: 77.78%); 460.51% turnout in Zeeland Charter Township (actual turnout: 80.11%); and 139.29% turnout in Detroit (actual turnout: 50.88%). See King v. Whitmer, 556 F. Supp. 3d. 680, 724 (E.D. Mich. 2021); Michigan Senate Oversight Committee, Report on the November 2020 Election in Michigan, (June 23, 2021), available at https://misenategopcdn.s3.us-east- 1.amazonaws.com/99/doccuments/20210623/SMPO_2020ElectionReport_2.pdf.
287. See, e.g., “Transcript of Trump’s Speech at Rally Before US Capitol Riot,” Associated Press, (Jan. 13, 2021), available athttps://apnews.com/article/election-2 ... naldtrump- capitol-siege-media-e79eb5164613d6718e9f4502eb471f27; “Donald Trump Speech on Election Fraud Claims Transcript December 2” Rev (Dec. 2, 2020), available at https:// www.rev.com/blog/transcripts/donald-tru ... tdecember- 2; Donald J. Trump (@realDonaldTrump), Twitter, Dec. 3, 2020, 4:11 p.m. ET, available at http://web.archive.org/web/202012032111 ... itter.com/ realdonaldtrump/status/1334606278388277253 (archived); “Trump Lawyers Rudy Giuliani & Jenna Ellis Testify Before Michigan House Oversight Committee: Full Transcript,” Rev, (Dec. 3, 2020), at 26:13, available at https://www.rev.com/blog/transcripts/tr ... ygiuliani- jenna-ellis-testify-before-michigan-house-oversight-committee-transcript; Affidavit of Mellissa A. Carone, King v. Whitmer, 505 F. Supp. 3d 720 (E.D. Mich. 2020), ECF No. 1-5, available at https://www.courtlistener.com/docket/18 ... v-whitmer/.
288. See, e.g., Opinion and Order at *3, 12-13, Costantino v. Detroit, No. 20-014780-AW (Mich. Cty. Cir. Ct. filed Nov. 13, 2020), available at https://electioncases.osu.edu/wp-content/ uploads/2020/11/Costantino-v-Detroit-Opinion-and-Order.pdf; Affidavit of Christopher Thomas ¶¶ 2-18, Texas v. Pennsylvania, 592 U.S. ____ (2020) (describing his experience and the process for tabulating votes), available at https://www.supremecourt.gov/DocketPDF/ 22/22O155/163387/20201210145418055_22O155%20MI%20APP.pdf.
289. See, e.g., “Transcript of Trump’s Speech at Rally Before US Capitol Riot,” Associated Press (January 13, 2021), available at https://apnews.com/article/election-202 ... dendonald- trump-capitol-siege-media-e79eb5164613d6718e9f4502eb471f27; Rudy Giuliani’s Common Sense, “I CAN’T SAY THIS On National Television | Rudy Giuliani | Ep. 98,” Rumble, at 13:10 – 13:25, Dec. 30, 2020, available at https://rumble.com/vex72l-i-cant-say-this-onnational- television-rudy-giuliani-ep.-98.html.
290. Right Side Broadcasting Network, “LIVE: Georgia House Hearing on Election Fraud, Brad Raffensperger to Participate 12/23/20,” YouTube, at 27:28, 43:02-43:28, Dec. 23, 2020, available at https://www.youtube.com/watch?v=R4cuakECmuA&t=2582s (Testimony of Ryan Germany, counsel to Georgia Secretary of State, before Georgia legislature stating: “The total number of underage people who voted is zero. We were able to look at everyone who voted and look at their birthdate in the voter registration system, and I think there was four people who requested a ballot before they turned 18, and they all turned 18 prior to November 3rd, which means they’re allowed to vote.”).
291. See, e.g. Bannon’s War Room, “Episode 980 – The Border Tipping Point … Peter Navarro on the Stolen Election and Desperation in Del Rio,” Rumble, May 27, 2021, available at https:// rumble.com/vhpam3-episode-980the-border-tipping-pointpeter-navarro-on-the-stolenelection- and.html; Bannon’s War Room, “Episode 979 – The HQ of the Runaway Train … Rachel Maddow’s Anna Karenina Moment,” Rumble, May 27, 2021, available at https:// rumble.com/vhp8yn-episode-979-the-hq-of-the-runaway-train-rachel-maddows-annakarenina- moment.html; Right Side Broadcasting Network, “LIVE: Arizona State Legislature Holds Public Hearing on 2020 Election,” YouTube, at 2:06:33-2:07:02, Nov. 30, 2020, available at https://www.youtube.com/watch?v=rri6flxaXww.
292. “Proof of Citizenship Requirements,” Arizona Secretary of State, (accessed Dec. 4, 2022), available at https://azsos.gov/elections/voting-elec ... quirements. In 2013, the Supreme Court struck down Arizona’s “evidence-of-citizenship” requirement as applied to federal elections. See Arizona v. Inter Tribal Council of Arizona, Inc., 570 U.S. 1, 4, 19 (2013). Arizona law allows voters to register as “federal only” voters without proof of citizenship, but those voters must provide a driver’s license or Social Security Number, which is then checked by election officials against immigration records before the person is added to voter registration rolls. Daniel González, “Are Undocumented Immigrants Voting Illegally in Arizona?,” Arizona Republic, (Oct. 27, 2016), available at https:// www.azcentral.com/story/news/politics/e ... mmigrants- voting-illegally-arizona-donald-trump/91703916/.
293. Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol, (Mark Meadows Production), MM007288, (November 13, 2020, email from Bill Stepien to Mark Meadows, Justin Clark, and Jason Miller re: AZ Federal ID Voters); In the Matter of Rudolph W. Giuliani, No. 2021-00506, slip op at *23-25 (N.Y. App. Div. May 3, 2021), available at https://int.nyt.com/data/documenttools/ ... uspension/ 1ae5ad6007c0ebfa/full.pdf.
294. Brad Raffensperger, Integrity Counts (New York: Simon & Schuster, 2021), p. 191 (reproducing the call transcript); Amy Gardner and Paulina Firozi, “Here’s the Full Transcript and Audio of the Call Between Trump and Raffensperger,” Washington Post, (Jan. 5, 2021), available at https://www.washingtonpost.com/politics ... ptgeorgia- vote/2021/01/03/2768e0cc-4ddd-11eb-83e3-322644d82356_story.html.
295. For example, the President alleged in his January 6th speech that large numbers of ballots were cast on behalf of dead people not just in Georgia but also in Michigan, Nevada, and Pennsylvania. “Transcript of Trump’s Speech at Rally Before US Capitol Riot,” Associated Press (January 13, 2021), https://apnews.com/article/election-202 ... naldtrump- capitol-siege-media-e79eb5164613d6718e9f4502eb471f27; See also Rudy Giuliani’s Common Sense, “I CAN’T SAY THIS On National Television | Rudy Giuliani | Ep. 98,” Rumble, at 15:10-15:46, (Dec. 30, 2020, reposted Mar. 22, 2021), available at https://rumble.com/ vex72l-i-cant-say-this-on-national-television-rudy-giuliani-ep.-98.html (making similar claims).
296. Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol, (Alex Cannon Production) AC-0013946, (November 12, 2020, email from Alex Cannon to Matt Wolking, Zach Parkinson, Tim Murtaugh, Ali Pardo, Matthew Morgan, and Andrew Clark titled “Re: dead voters”); Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol, (Tim Murtaugh Production) XXM-0009451 (November 8, 2020, email from Jason Miller to Zach Parkinson, Tim Murtaugh, and Matt Wolking re: PA Death Data stating that quality control checks will “significantly decrease[]” the number of “possible dead voters”), XXM-0009467 (November 8, 2020, email from Jason Miller to Zach Parkinson, Tim Murtaugh, and Matt Wolking re: GA Dead Voters), XXM-0009566 (November 9, 2020 email from Zach Parkinson to Jason Miller, Tim Murtaugh, and Matt Wolking re PA Death Data noting there “may be errors” with their data about people who were dead voters); Mark Niesse, “Alleged ‘Dead’ Georgia Voters Found Alive and Well after 2020 Election,” Atlanta Journal-Constitution, (Dec. 27, 2021), available at https://www.ajc.com/politics/alleged-de ... e-andwell- after-2020-election/DAL3VY7NFNHL5OREMHD7QECOCA/.
297. Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol, (National Archives Production), TEXT0000198, (December 3, 2020, text message from Eric Herschmann to Mark Meadows).
298. Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol, (National Archives Production), TEXT0000198-203, (December 3, 2020, text messages between Eric Herschmann and Mark Meadows).
299. Final Order at 5-6, Boland v. Raffensperger, No.2020CV343018 (Ga. Super. Ct. filed Dec. 14 2020), available at https://electioncases.osu.edu/wp-conten ... /Boland-v- Raffensperger-Order-Dismissing-Complaint.pdf.
300. The expert, Bryan Geels, based his claims on a comparison of public voter information to public death records. See Documents on file with the Select Committee to Investigate the January 6th Attack on the U.S. Capitol (Christina Bobb Production), BOBB_CONG_00000683- 84, 692-93, 706-07 (Affidavit of Bryan Geels dated Dec. 1, 2020, in Trump v. Barron, a case filed by the Trump Campaign in a Georgia Superior Court in Fulton County). However, the records reviewed included only name and year of birth for each individual listed. Id. at ¶ 28. Based on this limited information, it was impossible for Geels (or anyone else) to conclude that the person with a particular name and birth year was the same person listed in public death records with that name and birth year. See id., at ¶ 50 (only the Secretary of State has the information to conduct a full analysis of this issue); see also Declaration of Charles Stewart III at 22, Trump v. Raffensperger, No. 2020CV33255 (Ga. Super. Ct. filed Dec. 14, 2020).
301. In Georgia, the Secretary of State found four cases where people voted in the names of deceased individuals. Mark Niesse, “Alleged ‘Dead’ Georgia Voters Found Alive and Well after 2020 Election,” Atlanta Journal-Constitution, (Dec. 27, 2021), available at https:// www.ajc.com/politics/alleged-dead-georg ... fter-2020- election/DAL3VY7NFNHL5OREMHD7QECOCA/; In Arizona, the Attorney General recently concluded its investigation into claims of supposed dead voters in the 2020 election and found only one instance in which a vote was cast on behalf of a person who died prior to the election. Mark Brnovich, Arizona Attorney General to The Honorable Karen Fann, Arizona Senate President, (Aug. 1, 2022), available at https://www.azag.gov/sites/default/ files/2022-08/Letter%20to%20Fann%20-%20EIU%20Update%20080122.pdf. In Michigan, the Senate Oversight Committee found only two instances in which votes were cast in the names of dead people: one was a clerical error (poll worker attributed vote to deceased father of person with same name residing at same address) and the other was a woman who died four days before the election but had sent in her absentee ballot before her death. Michigan Senate Oversight Committee, Report on the November 2020 Election in Michigan, (June 23, 2021), available at https://misenategopcdn.s3.us-east- 1.amazonaws.com/99/doccuments/20210623/SMPO_2020ElectionReport_2.pdf.
302. In an email obtained by the Select Committee, Katherine Friess, a lawyer who worked closely with Giuliani, shared this information with Giuliani and noted, “I don’t think this makes a particularly strong case.” Documents on file with the Select Committee to Investigate the January 6th Attack on the U.S. Capitol (Christina Bobb Production), BOBB- _CONG_00000621 (January 4, 2021, email from Katherine Friess re: Chairman Graham dead votes memo for your consideration).
303. Documents on file with the Select Committee to Investigate the January 6th Attack on the U.S. Capitol (Cleta Mitchell Production), CM00026036 (January 5, 2021 email from Cleta Mitchell to Richard Perry re: GA Data request by Senator Graham); Documents on file with the Select Committee to Investigate the January 6th Attack on the U.S. Capitol (Christina Bobb Production), BOBB_CONG_00000621 (January 4, 2021, email from Katherine Friess re: Chairman Graham dead votes memo for your consideration); Select Committee to Investigate the January 6th Attack on the United States Capitol, Transcribed Interview of Christina Bobb, (Apr. 21, 2022), pp. 141-42.
304. Documents on file with the Select Committee to Investigate the January 6th Attack on the U.S. Capitol (Christina Bobb Production), BOBB_CONG_00000621 (January 4, 2021, email from Katherine Friess re: Chairman Graham dead votes memo for your consideration).
305. ABC News, “Lindsey Graham Delivers Remarks on Capitol Breach,” YouTube, at 3:05-3:30, Jan. 6, 2021, available at https://www.youtube.com/watch?v=JKHkYlRm_XM.
306. Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol, (Chapman University Production), Chapman060742, (Dec. 31, 2020 email from John Eastman to Alex Kaufman and Kurth Hibert); see also Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol, (National Archives Production), 076P-R000008384_0001 (December 31, 2020, email from Eric Herschmann to Cleta Mitchell and cc’ed to Mark Meadows and Molly Michael in which Herschmann wrote: “I was concerned about the President signing a verification about facts that may not be sustainable upon detailed scrutiny.”).
307. Order Re Privilege of Remaining Documents at 17, Eastman v. Thompson, No. 8:22-cv-99- DOC_DFM, (Oct. 19, 2022), ECF no. 372, available at https://www.courtlistener.com/docket/ 62613089/372/john-c-eastman-v-bennie-g-thompson/.
308. Order Re Privilege of Remaining Documents at 17, Eastman v. Thompson, Case 8:22-cv- 00099-DOC_DFM, (Oct. 19, 2022), ECF no. 372, available at https://www.courtlistener.com/ docket/62613089/372/john-c-eastman-v-bennie-g-thompson/.
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