matters.
Q Right. You then, in the second paragraph, Mr. Donoghue, you say: I cannot imagine a scenario in which the Department would recommend that a State would assemble its legislature to determine whether already certified election results should somehow be overridden by legislative action. This would be a grave step for the Department to take and could have tremendous constitutional, political, and social ramifications for the country.
Is that your sort of procedural response here that this is just not the Department's role to be quality control for State elections and tell a State legislature what to do?
A Yes. That's the point I was making. Yes.
Q All right. So, when you and Mr. Rosen get this letter, you compose the response. You indicated previously that Mr. Rosen essentially summons Mr. Clark up to the 5th floor for a face-to-face meeting. Does that meeting then occur?
A Yes. He is on the 4th floor. But, yes, in the DAG conference on the 4th floor.
Q Okay. So you are personally present, Mr. Donoghue, for that meeting between Clark and Rosen?
A Yes. It was the three of us.
Q Tell us about the conversation there with Mr. Clark.
A Mr. Clark explained that he had been looking at some of these allegations on his own, that he had information, that he had concerns about the reliability of the outcome of the election. He mentioned this smart thermostat thing. It was clear that he had been reading some affidavits that were attached to some of the civil filings in some of the cases that were pending or already dismissed around the country. He had various theories that seemed to be derived from the internet about why the outcome of
