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EXECUTIVE SUMMARY
- Order Re Privilege of 599 Documents Dated November 3, 2020 - January 20, 2021 at 6, Eastman v. Thompson et al., No. 8:22-cv-99 (C.D. Cal June 7, 2022), ECF No. 356.
- Order Re Privilege of 599 Documents Dated November 3, 2020 - January 20, 2021 at 20, Eastman v. Thompson et al.., No. 8:22-cv-99 (C.D. Cal June 7, 2022), ECF No. 356.
- 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/trump-raffensperger-call-transcriptgeorgia-vote/2021/01/03/2768e0cc-4ddd-11eb-83e3-322644d82356_story.html.
- Order Re Privilege of Documents Dated January 4-7, 2021 at 5, Eastman v. Thompson et al., 594 F. Supp. 3d 1156 (C.D. Cal. Mar. 28, 2022) (No. 8:22-cv-99-DOC-DFM), also available at https://www.cacd.uscourts.gov/sites/default/files/documents/Dkt%20260%2C%20Order%20RE%20Privilege%20of%20Jan.%2047%2C%202021%20Documents_0.pdf.
- Order Re Privilege of Documents Dated January 4-7, 2021 at 35, Eastman v. Thompson et al., 594 F. Supp. 3d 1156 (C.D. Cal. Mar. 28, 2022) (No. 8:22-cv-99-DOC-DFM), also available at https://www.cacd.uscourts.gov/sites/default/files/documents/Dkt%20260%2C%20Order%20RE%20Privilege%20of%20Jan.%2047%2C%202021%20Documents_0.pdf.
- After a journalist tweeted a video clip of key remarks from Gabriel Sterling’s warning addressed to President Trump, President Trump responded by quote-tweeting that post, along with a comment that doubled down on demonizing Georgia election workers in spite of Sterling’s stark and detailed warning. See Donald J. Trump (@realDonaldTrump), Twitter, Dec. 1, 2020 10:27 p.m. ET, available at http://web.archive.org/web/20201203173245/ https://mobile.twitter.com/realDonaldTrump/status/1333975991518187521 (archived) (“Rigged Election. Show signatures and envelopes. Expose the massive voter fraud in Georgia. What is Secretary of State and @BrianKempGA afraid of. They know what we’ll find!!! [linking to] twitter.com/BrendanKeefe/status/1333884246277189633”); Brendan Keefe (@BrendanKeefe), Twitter, Dec. 1, 2020 4:22 p.m. ET, available at https://twitter.com/BrendanKeefe/status/1333884246277189633 (“"It. Has. All. Gone. Too. Far," says @GabrielSterling with Georgia Sec of State after a Dominion tech's life was threatened with a noose. "Mr. President, you have not condemned these actions or this language....all of you who have not said a damn word are complicit in this."” with embedded video of Gabriel Sterling’s remarks); 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.
- Stephen Fowler, “‘Someone’s Going to Get Killed’: Election Official Blasts GOP Silence on Threats,” GPB News, (Dec. 1, 2020, updated Dec. 2, 2020), available at https://www.gpb.org/news/2020/12/01/someones-going-get-killed-election-official-blasts-gop-silence-onthreats.
- House Governmental Affairs Committee, Georgia House of Representatives, Public Hearing (Dec. 10, 2020), YouTube, at 1:55:10-1:59:10, available at https://youtu.be/9EfgETUKfsI?t=6910.
- 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), at 2:25:45 to 2:26:00, available at https://youtu.be/xa43_z_82Og?t=8745.
- Jason Szep and Linda So, “A Reuters Special Report: Trump Campaign Demonized Two Georgia Election Workers – and Death Threats Followed,” Reuters (Dec. 1, 2021), available at https://www.reuters.com/investigates/special-report/usa-election-threats-georgia/.
- Amended Complaint at 52, Freeman v. Giuliani, No. 21-cv-03354-BAH (D.D.C. filed May 10, 2022), ECF No. 22, available at https://www.courtlistener.com/docket/61642105/22/freeman-v-herring-networks-inc.