Final Report of the Select Committee to Investigate the January 6th Attack on the United States Capitol/Chapter 2/Endnotes

by Select Committee to Investigate the January 6th Attack on the United States Capitol

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ENDNOTES

1. See, e.g., Stephen Fowler, “Risk-Limiting Audit Confirms Biden Won Georgia,” GPB, (Nov. 19, 2020), available at https://www.gpb.org/news/2020/11/19/risk-limiting-audit-confirms-biden-won-georgia; Addie Haney, “Georgia Election Recount Results: Breaking Down Final Numbers,” 11Alive, (Dec. 7, 2020), available at https://www.11alive.com/article/news/politics/elections/georgia-election-recount-results-final-numbers/85-cbaacd70-f7e0-40ae8dfa-3bf18f318645.
2. 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.

3. 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.

4. 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.
5. 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.
6. 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.
7. 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.
8. Brad Raffensperger, Integrity Counts, (New York: Simon & Schuster, 2021), at p. 194.
9. Select Committee to Investigate the January 6th Attack on the United States Capitol, Transcribed Interview of Brad Raffensperger, (Nov. 22, 2021), pp. 121-122, 126-27.
10. Brad Raffensperger, Integrity Counts, (New York: Simon & Schuster, 2021), at p. 194.
11. The Georgia Secretary of State’s Chief Operating Officer, Gabriel Sterling, gave an impassioned public statement that included these points. “Georgia Election Official Gabriel Sterling: ‘Someone’s Going to Get Killed’ Transcript,” Rev, (Dec. 1, 2020), available at https://www.rev.com/blog/transcripts/georgia-election-official-gabriel-sterling-someones-goingto-get-killed-transcript. Shortly thereafter, President Trump fired back on Twitter in the form of a quote-tweet of a journalist’s post that included the full footage of these parts of Sterling’s remarks. 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 (quoting Brendan Keefe (@BrendanKeefe), Twitter, Dec. 1, 2020 4:22 p.m. ET, available at https://twitter.com/BrendanKeefe/status/1333884246277189633).
12. See Chapter 1.
13. U.S. Const. art. II, §1, cl. 2 (“Each State shall appoint, in such Manner as the Legislature thereof may direct, a Number of Electors, equal to the whole Number of Senators and Representatives to which the State may be entitled in the Congress: but no Senator or Representative, or Person holding an Office of Trust or Profit under the United States, shall be appointed an Elector.”).
14. See “Census Bureau Releases 2020 Presidential Election Voting Report,” United States Census Bureau, (Feb. 17, 2022), available at https://www.census.gov/newsroom/pressreleases/2022/2020-presidential-election-voting-report.html.
15. Barton Gellman, “The Election That Could Break America,” Atlantic, (Sept. 23, 2020) available at https://www.theatlantic.com/magazine/archive/2020/11/what-if-trump-refusesconcede/616424/.

16. Barton Gellman, “The Election That Could Break America,” Atlantic, (Sept. 23, 2020) available at https://www.theatlantic.com/magazine/archive/2020/11/what-if-trump-refusesconcede/616424/.
17. Select Committee to Investigate the January 6th Attack on the United States Capitol, Transcribed Interview of William Stepien, (Feb. 10, 2022), pp. 145-46, 148-53, 158; Select Committee to Investigate the January 6th Attack on the United States Capitol, Transcribed Interview of Justin Clark, (May 17, 2022), pp. 96, 98; Select Committee to Investigate the January 6th Attack on the United States Capitol, Deposition of Rudolph Giuliani, (May 20, 2022), p. 42. Although certain Select Committee witnesses confirmed the existence of this state-focused strategy, none testified that they knew about the strategy before the election.
18. Select Committee to Investigate the January 6th Attack on the United States Capitol, Transcribed Interview of William Stepien, (Feb. 10, 2022), pp. 145-46.
19. Select Committee to Investigate the January 6th Attack on the United States Capitol, Transcribed Interview of William Stepien, (Feb. 10, 2022), pp. 145-46.
20. Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (Mark Meadows Production), MM011213. Donald Trump Jr. publicly urged State legislators to help the same day. He called on Twitter for his father to “go to total war over this election” and retweeted a post by Fox News host Mark Levin urging Republican State legislatures to “GET READY TO DO YOUR CONSTITUTIONAL DUTY” by exercising “THE FINAL SAY OVER THE CHOOSING OF ELECTORS.” David Knowles, “As Vote Count Swings Toward Biden, Trump's Backers Hit the Caps-Lock Key on Twitter,” Yahoo! News, (Nov. 5, 2020), available at https://www.yahoo.com/video/as-vote-count-swings-towardbiden-trump-backers-hit-the-caps-lock-on-twitter-223931950.html.
21. Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (Mark Meadows Production), MM011318 (November 6, 2020, text message from Mark Meadows to Donald J. Trump, Jr.).
22. Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (Mark Meadows Production), MM011296 (November 5, 2020, text message from Mark Meadows to Marty Harbin).
23. Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (Mark Meadows Production), MM011686, MM011687 (November 9, 2020, text messages between Mark Meadows and Russell Vought).
24. Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (Mark Meadows Production), MM011560, MM011563 (November 7, 2020, text messages between Mark Meadows and Rep. Warren Davidson).
25. Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (Mark Meadows Production), MM011449, MM011451 (November 6, 2020, text messages between Mark Meadows and Rep. Andy Biggs).
26. Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (Mark Meadows Production), MM011087 (November 4, 2020, text message from Rick Perry to Mark Meadows).
27. Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (Vincent Haley Production), VMH-00004070, p. 44; see also Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (Vincent Haley Production), VMH-00003041.

28. Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (Vincent Haley Production), VMH-00003543 (November 5, 2020, email from Vincent Haley to Johnny McEntee and Dan Huff re: State legislature plenary power under Constitution to state electoral college electors); Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (Vincent Haley Production), VMH-00003559 (November 5, 2020, email from Vincent Haley to Johnny McEntee and Dan Huff re: more notes on state legislature strategy); Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (National Archives Production), 076P-R000010233_0001 (November 6, 2020, email chain between Vincent Haley, Johnny McEntee, and Daniel Huff re: Contact Info of key leaders in key States); Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (National Archives Production), 076P-R000010198_0001 (November 6, 2020, email from Vincent Haley to Johnny McEntee and Daniel Huff re: Horowitz: How Republican-controlled state legislatures can rectify election fraud committed by courts and governors - TheBlaze); Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (National Archives Production), 076P-R000010225_0001-10226_0001 (November 6, 2020, email from Vincent Haley to Johnny McEntee and Daniel Huff re: Contact info of key leaders in key States and attaching contact info); Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (Vincent Haley Production), VMH-00004070, 4103-04, 4111-12, 4124-25 (various text messages between Vincent Haley, Johnny McEntee, and Daniel Huff discussing the state legislature plan).

29. Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (Vincent Haley Production), VMH-00003009 (November 8, 2020, email chain between Vincent Haley and Newt Gingrich re: More of my exchange with John); Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (Vincent Haley Production), VMH-00004103 (November 6, 2020, text message from Vincent Haley to Randy Evans).
30. Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (Vincent Haley Production), VMH-00002107 (November 5, 2020, email chain between Vincent Haley, Daniel Huff, and Jonny McEntee re: more notes on the state legislature strategy).
31. Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (Vincent Haley Production), VMH-00004103 (November 6, 2020, text message from Vincent Haley to Johnny McEntee).
32. Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (Vincent Haley Production), VMH-00004104 (November 6, 2020, text message from Vincent Haley to Johnny McEntee).
33. Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (National Archives Production), 076P-R000010225_0001 - 076PR000010226_0001 (November 6, 2020, email from Vincent Haley to Johnny McEntee and Daniel Huff re: Contact info of key leaders in key States and attaching contact info); Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (National Archives Production), 076P-R000010233_0001 (November 6, 2020, email chain between Vincent Haley, Johnny McEntee, and Daniel Huff re: Contact Info of key leaders in key States).
34. Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (National Archives Production), 076P-R000010225_0001 - 076PR000010226_0001 (November 6, 2020, email from Vincent Haley to Johnny McEntee and Daniel Huff re: Contact info of key leaders in key States and attaching contact info).
35. Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (Vincent Haley Production), VMH-00004122-VMH-00004123 (November 8, 2020, text messages between Vincent Haley and Johnny McEntee).
36. Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (National Archives Production), 076P-R000010533_0001 (November 10, 2020, email from Newt Gingrich to Molly Michael re: Only two options—please give to POTUS newt).

37. Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (National Archives Production), 076P-R000010533_0001 (November 10, 2020, email from Newt Gingrich to Molly Michael re: Only two options—please give to POTUS newt).
38. Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (National Archives Production), 076P-R000010586_0001 (November 10, 2020, email from Mark Meadows to Newt Gingrich re: Only two options—please give to POTUS newt).
39. Solange Reyner, “Newsmax CEO Ruddy: Trump 'Very Concerned' That Dems Will Steal Election,” Newsmax, (Nov. 4, 2020), available at https://www.newsmax.com/newsmax-tv/chrisruddy-2020-elections-democrats-white-house/2020/11/04/id/995386/; Christopher Ruddy (@ChrisRuddyNMX), Twitter, Nov. 12, 2020 4:43 p.m. ET, available at https://twitter.com/ChrisRuddyNMX/status/1327004111154319360; “Digest of Other White House Announcements (Administration of Donald J. Trump, 2020),” Government Publishing Office, p. 114, available at https://www.govinfo.gov/content/pkg/DCPD-2020DIGEST/pdf/DCPD-2020DIGEST.pdf; Michael M. Grynbaum and John Koblin,“Newsmax, Once a Right-Wing Also-Ran, Is Rising, and Trump Approves,” New York Times, (Nov. 22, 2020), available at https://www.nytimes.com/2020/11/22/business/media/newsmax-trump-fox-news.html; Cordelia Lynch, “Trump Ally on President's Next Move after Thanksgiving Phone Call,” Sky News, (Dec. 4, 2020), available at https://news.sky.com/story/trump-ally-on-presidents-nextmove-after-thanksgiving-phone-call-12150612; Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (National Archives Production), 076P-R000009409_0001 (December 2, 2020, email from John McLaughlin to Molly Michael re: Newsmax National Poll).
40. Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (Mark Meadows Production), MM008861-MM008865 (November 7, 2020, email from John McLaughlin to Mark Meadows and Newt Gingrich re: “Gerald Brant's birthday party/ my Nov 7, 2020 memo on ON 'ELECTORAL L COUNT ACT OF 1887' AND REPUBLICAN PATHWAYS: [sic],” and attaching memo forwarded by Christopher Ruddy).
41. Select Committee to Investigate the January 6th Attack on the United States Capitol, Deposition of Cleta Mitchell, (May 18, 2022), pp. 14-15; Jeremy Herb and Sunlen Serfaty, “How GOP Lawyer Cleta Mitchell Joined Trump’s ‘Team Deplorables’ Advancing His False Election Fraud Claims,” CNN, (Oct. 13, 2021), available at https://www.cnn.com/2021/10/13/politics/trump-mitchell-georgia-election/index.html.
42. Select Committee to Investigate the January 6th Attack on the United States Capitol, Deposition of Cleta Mitchell, (May 18, 2022), pp. 74-75.
43. Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (Chapman University Production), Chapman006671.
44. Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (Chapman University Production), Chapman007670-Chapman007671, Chapman008087 (November 9, 2020, email chain between John Eastman, Lisa Nelson, Rep. Seth Grove, and Cleta Mitchell re: Connections for today! and attaching memo).
45. Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (National Archives Production),076P-R000010584_0001 (November 10, 2020, email chain scheduling an external meeting with President Trump).

46. Break Up DC (@BreakItUp3), Twitter, Nov. 11, 2020, available at http://web.archive.org/web/20201111104529/https://twitter.com/BreakItUp3/status/1326475581005950976 ("Was in Oval yesterday. You are right."). For attribution of the account to Warstler, see The RSnake Show, "S01E10 - Morgan Warstler," YouTube, at 1:43:00 - 1:44:00, Apr. 20, 2022, available at https://www.youtube.com/watch?v=k-ojD3QAYfo; Break Up DC (@BreakItUp3), Twitter, June 16, 2022, available at http://web.archive.org/web/20220616124842/https://twitter.com/BreakItUp3/status/1537414050510000128 ("NO it is not. I went to the Oval right after election and spent an hour with Trump sitting at Resolute desk. I explain it all here: https://youtu.be/k-ojD3QAYfo?t=2724 . . . Hint: the electoral count act is unconstitutional—there is only one slate of electors- whatever the state leg says").

47. Break Up DC (@BreakItUp3), Twitter, June 15, 2022 7:40 p.m. ET, available at http://web.archive.org/web/20220615234134/https://twitter.com/BreakItUp3/status/1537218579225268225 (archived) (“She literally was advocating what I told whole Trump team in Oval- it's a fact - state legislatures can choose the electors- no matter what current state law OR state courts say . . . just ratify it amongst themselves That's WHY they call it a plenary power ever since Bush v. Gore.”).
48. Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (National Archives Production), 076P-R000008528_0001 - 076PR000008530_0001.
49. Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (National Archives Production), 076P-R000008528_0001-076PR000008528_0003, 076P-R000008530_0001 - 076P-R000008530_0002.
50. Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (National Archives Production), 076P-R000008528_0001 - 076PR000008528_0003, 076P-R000008530_0001 - 076P-R000008530_0002.
51. Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (National Archives Production), 076P-R000008531_0001, 076PR000008257_0001.
52. Select Committee to Investigate the January 6th Attack on the United States Capitol, Transcribed Interview of William Stepien, (Feb. 10, 2022), pp. 151-52.
53. Select Committee to Investigate the January 6th Attack on the United States Capitol, Transcribed Interview of William Stepien, (Feb. 10, 2022), p. 153. This fits with several major news reports at the time. The New York Times reported that President Trump went into the meeting on the 11th with “something he wanted to discuss with his advisors,” and “press[ed] them on whether Republican legislatures could pick pro-Trump electors in a handful of key states and deliver him the electoral votes he needs.” Maggie Haberman, “Trump Floats Improbable Survival Scenarios as He Ponders His Future,” New York Times, (Nov. 12, 2020, updated Nov. 23, 2020), available at https://www.nytimes.com/2020/11/12/us/politics/trump-future.html. Similarly, late on November 11th, the Washington Post reported that President Trump had “raised the idea of pressuring state legislators to pick electors favorable to him,” and the Wall Street Journal also called the option of state legislatures picking new electors “one potential strategy” discussed by his legal team. Philip Rucker, Josh Dawsey & Ashley Parker, “Trump Insists He’ll Win, But Aides Say He Has No Real Plan to Overturn Results and Talks of 2024 Run,” Washington Post, (Nov. 11, 2020), available at https://www.washingtonpost.com/politics/trump-election-results-strategy/2020/11/11/a32e2cba-244a-11eb-952e-0c475972cfc0_story.html; Rebecca Ballhaus, “What Is Trump’s Legal Strategy? Try to Block Certification of Biden Victory in States,” Wall Street Journal, (Nov. 11, 2020), available at https://www.wsj.com/articles/what-is-trumps-legalstrategy-try-to-block-certification-of-biden-victory-in-states-11605138852.
54. Select Committee to Investigate the January 6th Attack on the United States Capitol, Transcribed Interview of William Stepien, (Feb. 10, 2022), p. 148-49.
55. Senator Mitt Romney (@MittRomney), Twitter, Nov. 19, 2020 10:36 p.m. ET, available at https://twitter.com/MittRomney/status/1329629701447573504.
56. This figure is almost certainly a significant undercount, since it only includes public remarks by President Trump, public testimony, or the most noteworthy interviews conducted by one of his subordinates, but it does not include a review of every single remark targeting State or local officials during this period by those presidential subordinates.
57. This figure is also almost certainly an undercount, since it only includes those posts by President Trump’s campaign or advisors when they covered new ground that was substantially different from social media posts that were already made by President Trump. Also, many of these posts were replicated across multiple platforms.

58. Jonathan Oosting, “Trump Campaign Lobbies Michigan Lawmakers to Ignore Vote, Give Him Electors,” Bridge Michigan, (Dec. 2, 2020), available at https://www.bridgemi.com/michigan-government/trump-campaign-lobbies-michigan-lawmakers-ignore-vote-givehim-electors; MIRS Monday Podcast, “Call to Legislator From Someone Claiming to be with Trump Campaign (12/1/2020),” PodBean, Dec. 1, 2020, available at https://www.podbean.com/media/share/pb-iqskx-f3cfc6; Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (Angela McCallum Production), McCallum_01_001570, (Undated Basic Script for calls to Representatives/ Senators).
59. Paul Bedard, “Exclusive: Trump Urges State Legislators to Reject Electoral Votes, ‘You Are the Real Power,’” Washington Examiner, (Jan. 3, 2021), available at https://www.washingtonexaminer.com/washington-secrets/exclusive-trump-urges-statelegislators-to-reject-electoral-votes-you-are-the-real-power.
60. Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (Maricopa County Board of Supervisors Production), CTRL0000020072 (December 24, 2020, copy of voice message and a transcription) pp. 1–2); see also Yvonne Wingett Sanchez and Ronald J. Hansen, “'Asked to Do Something Huge': An Audacious Pitch to Reverse Arizona's Election Results,” AZ Central, (Dec. 2, 2021), available at https://www.azcentral.com/in-depth/news/politics/elections/2021/11/18/arizona-audit-rudygiuliani-failed-effort-replace-electors/6349795001/.
61. 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 Rep. Tim Walberg to Molly Michael).
62. 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 Rep. Tim Walberg to Molly Michael). The day after Representative Walberg's call with the President, President Trump's assistant forwarded to the Acting Secretary of the Department of Homeland Security a letter signed by two other Michigan legislators outlining claims of supposed election fraud. 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”); Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol, (no production listed, Ex. 44 from Chad Wolf interview), CTRL0000926977 (Nov. 13, 2020 letter to Michigan Secretary of State Jocelyn Benson from Michigan State Senators Lana Theis and Tom Barrett).
63. “Administration of Donald J. Trump, 2020, Digest of Other White House Announcements,” Government Publishing Office, (Dec. 31, 2020), p. 115, available at https://www.govinfo.gov/content/pkg/DCPD-2020DIGEST/pdf/DCPD-2020DIGEST.pdf; Annie Grayer, Jeremy Herb & Kevin Liptak, “Trump Courts Michigan GOP Leaders in Bid to Overturn Election He Lost,” CNN, (Nov. 19, 2020), available at https://www.cnn.com/2020/11/19/politics/gop-michiganresults-trump/.
64. Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (Mark Meadows Production), MM012007 (text from Kelli Ward to Meadows).
65. Brahm Resnik, “‘Stop the Counting’: Records Show Trump and Allies Pressured Top Maricopa County Officials Over Election Results,” 12News, (July 7, 2021), available at https://www.12news.com/article/news/politics/stop-the-counting-records-show-trump-and-alliespressured-top-maricopa-county-officials-over-election-results/75-61a93e63-36c4-4137b65e-d3f8bde846a7.
66. Select Committee to Investigation the January 6th Attack on the United States Capitol, Informal Interview with Clint Hickman, (Nov. 17, 2021); Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (Maricopa County Board of Supervisors Production), CTRL0000020004.

67. Brian Slodysko, “EXPLAINER: Why AP called Georgia for Biden,” Associated Press, (Nov. 13, 2020), available at https://apnews.com/article/why-ap-called-georgia-for-joe-biden29c1fb0502efde50fdccb5e2c3611017.
68. Donald J. Trump (@realDonaldTrump), Twitter, Nov. 13, 2020 7:50 p.m. ET, available at https://media-cdn.factba.se/realdonaldtrump-twitter/1327413534901350400.jpg (archived).
69. Donald J. Trump (@realDonaldTrump), Twitter, Nov. 14, 2020 9:29 a.m. ET, available at https://media-cdn.factba.se/realdonaldtrump-twitter/1327619653020110850.jpg (archived).
70. Donald J. Trump (@realDonaldTrump), Twitter, Nov. 16, 2020 9:04 a.m. ET, available at https://media-cdn.factba.se/realdonaldtrump-twitter/1328338211284616193.jpg (archived).
71. Donald J. Trump (@realDonaldTrump), Twitter, Nov. 19, 2020 1:46 p.m. ET, available at https://media-cdn.factba.se/realdonaldtrump-twitter/1329420741553643522.jpg (archived).
72. Donald J. Trump (@realDonaldTrump), Twitter, Nov. 30, 2020 1:59 p.m. ET, available at https://media-cdn.factba.se/realdonaldtrump-twitter/1333410419554344964.jpg (archived).
73. President Donald J. Trump, “Tweets of November 30, 2020,” The American Presidency Project, available at https://www.presidency.ucsb.edu/documents/tweets-november-30-2020; see also Fox 10 Staff, “Tweet mocking Arizona Gov. Doug Ducey and Georgia Gov. Brian Kemp Now on Billboard,” Fox 10 News, (Dec. 9, 2020), available at https://www.fox10phoenix.com/news/tweet-mocking-arizona-gov-doug-ducey-and-georgia-govbrian-kemp-now-on-billboard.
74. Miles Bryan, “From Obscure To Sold Out: The Story Of Four Seasons Total Landscaping In Just 4 Days," NPR, (Nov. 11, 2020), available at https://www.npr.org/2020/11/11/933635970/from-obscure-to-sold-out-the-story-of-four-seasons-total-landscaping-in-just-4-d.
75. Matt Friedman, “Man Featured at Giuliani Press Conference is a Convicted Sex Offender,” Politico, (Nov. 9, 2020), available at https://www.politico.com/states/new-jersey/story/2020/11/09/man-featured-at-giuliani-press-conference-is-a-sex-offender-1335241.
76. McKenzie Sadeghi, “Fact Check: No Evidence Vote Was Cast in Joe Frazier's Name,” USA Today, (Nov. 14, 2020), available at https://www.usatoday.com/story/news/factcheck/2020/11/14/fact-check-no-evidence-late-joe-frazier-voted-2020-election/6283956002/; Ledyard King and John Fritze, “Trump Attorney Rudy Giuliani Says Trump Won’t Concede, Revives Baseless Claims of Voter Fraud,” USA Today, (Nov. 7, 2020) available at https://www.usatoday.com/story/news/politics/elections/2020/11/07/joe-biden-victory-presidenttrump-claims-election-far-over/6202892002/.
77. Veronica Stracqualursi, “Republican Election Official in Philadelphia Says He’s Seen No Evidence of Widespread Fraud,” CNN, (Nov. 11, 2020), available at https://www.cnn.com/2020/11/11/politics/philadelphia-city-commissioner-2020-election-cnntv/index.html.
78. Donald Trump (@realDonaldTrump), Twitter, Nov. 11, 2020 9:03 a.m. ET, available at https://media-cdn.factba.se/realdonaldtrump-twitter/1326525851752656898.jpg (archived).
79. Select Committee to Investigate the January 6th Attack on the United States Capitol, Hearing on the January 6th Investigation, 117th Cong., 2d sess., (June 13, 2022), at 1:47:00 to 1:48:00, available at https://www.youtube.com/watch?v=pr5QUInmGI8.
80. Select Committee to Investigate the January 6th Attack on the United States Capitol, Hearing on the January 6th Investigation, 117th Cong., 2d sess., (June 13, 2022), at 1:47:00 to 1:48:00, available at https://www.youtube.com/watch?v=pr5QUInmGI8.
81. Select Committee to Investigate the January 6th Attack on the United States Capitol, Hearing on the January 6th Investigation, 117th Cong., 2d sess., (June 13, 2022), at 1:47:00 to 1:48:00, available at https://www.youtube.com/watch?v=pr5QUInmGI8.

82. See McQuade v. Furgason, 91 Mich. 438 (1892). The various Boards of Canvassers in Michigan know that the certification process is clerical because they are so instructed in the official "Michigan Boards of County Canvassers Manual." See "Procedures and Duties of the Boards of County Canvassers," State of Michigan, (July 2022), pp. 18-19, available at https://www.michigan.gov/-/media/Project/Websites/sos/02lehman/BCC_Manual.pdf?rev=7270a5ddcefa465b8ab8b95930ef5890.

83. “Minutes of Meeting Wayne County Board of Canvassers,” Wayne County Board of Canvassers, (Nov. 17, 2020), p. 1, available at https://www.waynecounty.com/elected/clerk/boardof-canvassers.aspx.
84. “Minutes of Meeting Wayne County Board of Canvassers,” Wayne County Board of Canvassers, (Nov. 17, 2020), pp. 1-5, available at https://www.waynecounty.com/elected/clerk/board-of-canvassers.aspx.
85. “Minutes of Meeting Wayne County Board of Canvassers,” Wayne County Board of Canvassers, (Nov. 17, 2020), p. 5, available at https://www.waynecounty.com/elected/clerk/boardof-canvassers.aspx.
86. Select Committee to Investigate the January 6th Attack on the United States Capitol, Informal Interview of Monica Palmer, (Sept. 28, 2021); Select Committee to Investigate the January 6th Attack on the United States Capitol, Informal Interview of Ronna Romney McDaniel, (Mar. 9, 2022); Phone records for Monica Palmer show calls from Ronna McDaniel at 9:53 PM and 10:04 PM. See Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (Verizon Production, Feb. 9, 2022).
87. Annie Grayer, Jeremy Herb, and Kevin Liptak, “Trump Courts Michigan GOP Leaders in Bid to Overturn Election He Lost,” CNN, (Nov. 19, 2020), https://www.cnn.com/2020/11/19/politics/gop-michigan-results-trump/.
88. Select Committee to Investigate the January 6th Attack on the United States Capitol, Informal Interview of Monica Palmer, (Sept. 28, 2021). Palmer told the Select Committee that she could not recall the exact words that President Trump used on the call, and she claimed that she could not even recall whether the President raised issues related to the election.
89. Kendall Karson, Katherine Faulders, and Will Steakin, “Republican Canvassers Ask to ‘Rescind’ Their Votes Certifying Michigan Election Results,” ABC News, (Nov. 19, 2020), available at https://abcnews.go.com/US/wayne-county-republican-canvassers-rescind-votescertifying-election/story?id=74290114; Krystle Holleman and Spencer Soicher, “Pair of Wayne Co. Board of Canvassers Members File Affidavits to Rescind Certification of Election Results,” WILX10, (Nov. 19, 2020), available at https://www.wilx.com/2020/11/19/pair-ofwayne-county-board-of-canvassers-members-file-affidavits-to-rescind-certification-ofelection-results/; Paul Egan, “GOP Members of Wayne County Board of Canvassers Say They Want to Rescind Votes to Certify,” Detroit Free Press, (Nov. 19, 2020), available at https://www.freep.com/story/news/politics/elections/2020/11/19/wayne-county-board-ofcanvassers-monica-palmer-william-hartmann/3775242001/.
90. Kendall Karson, Katherine Faulders, and Will Steakin, “Republican Canvassers Ask to ‘Rescind’ Their Votes Certifying Michigan Election Results,” ABC News, (Nov. 19, 2020), available at https://abcnews.go.com/US/wayne-county-republican-canvassers-rescind-votescertifying-election/story?id=74290114; Krystle Holleman and Spencer Soicher, “Pair of Wayne Co. Board of Canvassers Members File Affidavits to Rescind Certification of Election Results,” WILX10, (Nov. 19, 2020), available at https://www.wilx.com/2020/11/19/pair-ofwayne-county-board-of-canvassers-members-file-affidavits-to-rescind-certification-ofelection-results/; Paul Egan, “GOP Members of Wayne County Board of Canvassers Say They Want to Rescind Votes to Certify,” Detroit Free Press, (Nov. 19, 2020), available at https://www.freep.com/story/news/politics/elections/2020/11/19/wayne-county-board-ofcanvassers-monica-palmer-william-hartmann/3775242001/.
91. Donald Trump (@realDonaldTrump), Twitter, Nov. 18, 2020 10:38 a.m. ET, available at https://media-cdn.factba.se/realdonaldtrump-twitter/1329086548093014022.jpg (archived).
92. Select Committee to Investigate the January 6th Attack on the United States Capitol, Informal Interview of Jack Sellers and Bill Gates, (Oct. 6, 2021).

93. Select Committee to Investigate the January 6th Attack on the United States Capitol, Informal Interview of Jack Sellers and Bill Gates, (Oct. 6, 2021).
94. Select Committee to Investigate the January 6th Attack on the United States Capitol, Informal Interview of Jack Sellers and Bill Gates, (Oct. 6, 2021).
95. Jonathan J. Cooper, “Arizona Governor Silences Trump’s Call, Certifies Election,” Associated Press, (Dec. 2, 2020), available at https://apnews.com/article/election-2020-donald-trumparizona-elections-doug-ducey-e2b8b0de5b809efcc9b1ad5d279023f4.
96. Jonathan J. Cooper, “Arizona Governor Silences Trump’s Call, Certifies Election,” Associated Press, (Dec. 2, 2020), available at https://apnews.com/article/election-2020-donald-trumparizona-elections-doug-ducey-e2b8b0de5b809efcc9b1ad5d279023f4.
97. Donald Trump (@realDonaldTrump), Twitter, Nov. 30, 2020 3:39 p.m. ET, available at http://web.archive.org/web/20201201024920mp_/https:/twitter.com/realDonaldTrump/status/1333556242984431616 (archived).
98. President Donald J. Trump, “Tweets of November 30, 2020,” The American Presidency Project, available at https://www.presidency.ucsb.edu/documents/tweets-november-30-2020; “Tweet Mocking Arizona Gov. Doug Ducey and Georgia Gov. Brian Kemp Now on Billboard,” Fox 10 News, (Dec. 9, 2020), available at https://www.fox10phoenix.com/news/tweetmocking-arizona-gov-doug-ducey-and-georgia-gov-brian-kemp-now-on-billboard.
99. Donald Trump (@realDonaldTrump), Twitter, Nov. 30, 2020 3:40 p.m. ET, available at http://web.archive.org/web/20201201022358/https:/twitter.com/realDonaldTrump/status/1333556458575818754 (archived).
100. Doug Ducey (@DougDucey), Twitter, Nov. 30, 2020 9:48 p.m. ET, available at https://twitter.com/dougducey/status/1333603735855976450.
101. Doug Ducey (@DougDucey), Twitter, Nov. 30, 2020 9:48 p.m. ET, available at https://twitter.com/dougducey/status/1333603735855976450.
102. Doug Ducey (@DougDucey), Twitter, Nov. 30, 2020 9:48 p.m. ET, available at https://twitter.com/dougducey/status/1333603735855976450.
103. “Pennsylvania, Arizona, Michigan Legislatures to Hold Public Hearings on 2020 Election,”" Donald J. Trump for President, (Nov. 24, 2020), available at http://web.archive.org/web/20201130045430/https:/www.donaldjtrump.com/media/pennsylvania-arizona-michiganlegislatures-to-hold-public-hearings-on-2020-election/.
104. “Donald Trump Remarks Transcript: Pennsylvania Republican Hearing on 2020 Election,” Rev, (Nov. 25, 2020), available at https://www.rev.com/blog/transcripts/donald-trumpremarks-transcript-pennsylvania-republican-hearing-on-2020-election.
105. Teresa Boeckel and J.D. Prose, “Pa. GOP Lawmakers Host Giuliani to Hear Election Concerns. Trump Visits Via Cell Phone,” York Daily Record, (Nov. 25, 2020), available at https://www.ydr.com/story/news/politics/2020/11/25/pa-gop-lawmakers-host-rudy-giuliani-hearelection-concerns/6420319002/.
106. Select Committee to Investigate the January 6th Attack on the United States Capitol, Informal Interview of Jake Corman, (Jan. 25, 2022).

107. See Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (National Archives Production), 076P-R000008474_0001 (November 25, 2020, email from Jared Small confirming that Trump will not be present in Gettysburg); Philip Rucker, Ashley Parker, Josh Dawsey, and Amy Gardner, "20 Days of Fantasy and Failure: Inside Trump's Quest to Overturn the Election," Washington Post, (Nov. 28, 2020), available at https://www.washingtonpost.com/politics/trump-election-overturn/ 2020/11/28/34f45226-2f47-11eb-96c2-aac3f162215d_story.html; Alayna Treene and Rebecca Falconer, "Trump Cancels Pennsylvania Trip for GOP Hearing on Voter Fraud Claims," Axios, (Nov. 25, 2020) available at https://www.axios.com/2020/11/25/trump-pennsylvania-gophearing-voter-fraud-claims. Apparently, White House Chief of Staff Mark Meadows also contemplated going to Pennsylvania for the hearing when the President couldn't attend. Text messages between Cassidy Hutchinson and Meadows's Secret Service detail say, "U heard how mark is motorcading to gburg right[,] and potus isn't anymore." Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (Cassidy Hutchinson production), CH-CTRL0000000080 (Nov. 25, 2020).

108. “Donald Trump Remarks Transcript: Pennsylvania Republican Hearing on 2020 Election,” Rev, (Nov. 25, 2020), available at https://www.rev.com/blog/transcripts/donald-trumpremarks-transcript-pennsylvania-republican-hearing-on-2020-election.
109. “Pennsylvania Senate Republican Lawmaker Hearing Transcript on 2020 Election,” Rev, (Nov. 26, 2020), available at https://www.rev.com/blog/transcripts/pennsylvania-senaterepublican-lawmaker-hearing-transcript-on-2020-election.
110. “Pennsylvania Senate Republican Lawmaker Hearing Transcript on 2020 Election,” Rev, (Nov. 26, 2020), available at https://www.rev.com/blog/transcripts/pennsylvania-senaterepublican-lawmaker-hearing-transcript-on-2020-election.
111. Select Committee to Investigate the January 6th Attack on the United States Capitol, Deposition of Rudolph Giuliani, (May 20, 2022), pp. 65–66; Select Committee to Investigate the January 6th Attack on the United States Capitol, Deposition of Molly Michael, (Mar. 24, 2022), pp. 59–60, 62; “Administration of Donald J. Trump, 2020, Digest of Other White House Announcements,” Government Publishing Office, (Dec. 31, 2020), p. 116, https://www.govinfo.gov/content/pkg/DCPD-2020DIGEST/pdf/DCPD-2020DIGEST.pdf.
112. Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (Cassidy Hutchinson production), CH-CTRL0000000062 (Nov. 25, 2020, Cassidy Hutchinson's text messages with Bernie Kerik).
113. Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (Cassidy Hutchinson production), CH-CTRL0000000062 (Nov. 25, 2020, Cassidy Hutchinson's text messages with Bernie Kerik).
114. Select Committee to Investigate the January 6th Attack on the United States Capitol, Continued Interview of Cassidy Hutchinson (Mar. 7, 2022), pp. 87, 91-92.
115. Howard Fischer, “GOP Officials Still Fighting Arizona’s Vote Tally on Very Day Biden’s Win Will Be Certified,” Tuscon.com, (Nov. 30, 2020), available at https://tucson.com/news/local/gop-officials-still-fighting-arizonas-vote-tally-on-very-day-bidens-win-will-becertified/article_021fbb5c-673f-549a-9cbb-900178c17079.html.
116. Howard Fischer, “GOP Officials Still Fighting Arizona’s Vote Tally on Very Day Biden’s Win Will Be Certified,” Tuscon.com, (Nov. 30, 2020), available at https://tucson.com/news/local/gop-officials-still-fighting-arizonas-vote-tally-on-very-day-bidens-win-will-becertified/article_021fbb5c-673f-549a-9cbb-900178c17079.html.
117. Right Side Broadcasting Network, “LIVE: Arizona State Legislature Holds Public Hearing on 2020 Election,” YouTube, at 2:08:56, Nov. 30, 2020, available at https://www.youtube.com/watch?v=rri6flxaXww&t=7738s.
118. Right Side Broadcasting Network, “LIVE: Arizona State Legislature Holds Public Hearing on 2020 Election,” YouTube, at 1:21:02, Nov. 30, 2020, available at https://www.youtube.com/watch?v=rri6flxaXww&t=4862s.
119. Jenna Ellis (@JennaEllisEsq), Twitter, Nov. 30, 2020 3:04 p.m. ET, available at https://twitter.com/jennaellisesq/status/1333502306176835588.
120. “Remarks: Donald Trump Calls in to Meeting of Arizona GOP Lawmakers on Election,” Factbase, (Nov. 30, 2020), available at https://factba.se/transcript/donald-trump-remarksarizona-gop-meeting-election-november-30-2020.
121. Rudy Giuliani (@RudyGiuliani), Twitter, Nov. 30, 2020 11:17 p.m. ET, available at https://twitter.com/RudyGiuliani/status/1333626364805533696.

122. "Pennsylvania, Arizona, Michigan Legislatures to Hold Public Hearings on 2020 Election," Donald J. Trump, (Nov. 24, 2020), available at http://web.archive.org/web/20201130045430/ https:/www.donaldjtrump.com/media/pennsylvania-arizona-michigan-legislatures-to-hold-public-hearings-on-2020-election/; Jonathan Oosting (@jonathanoosting), Twitter, Nov. 24, 2020 5:35 p.m. ET, available at https://twitter.com/jonathanoosting/status/1331365885123178499; Jonathan Oosting (@jonathanoosting), Twitter, Nov. 30, 2020 3:42 p.m. ET, available at https://twitter.com/jonathanoosting/status/1333511772448370689.

123. See “Report on the November 2020 Election in Michigan,” Michigan Senate Oversight Committee, (June 21, 2020), available at https://misenategopcdn.s3.us-east-1.amazonaws.com/99/doccuments/20210623/SMPO_2020ElectionReport_2.pdf.
124. Wood TV8, “Giuliani and Laura Cox Hold 'Legal Briefing' Before Giving Testimony Wednesday Evening,” Facebook Watch, at 10:30-10:45, Dec. 2, 2020, available at https://www.facebook.com/woodtv/videos/rudy-giuliani-and-laura-cox-hold-legal-briefing-beforegiving-testimony-wednesda/1996033023872394/.
125. Wood TV8, “Giuliani and Laura Cox Hold 'Legal Briefing' Before Giving Testimony Wednesday Evening,” Facebook Watch, at 10:30-10:45, Dec. 2, 2020, available at https://www.facebook.com/woodtv/videos/rudy-giuliani-and-laura-cox-hold-legal-briefing-beforegiving-testimony-wednesda/1996033023872394/.
126. Michigan House Oversight Committee, Public Hearing, (Dec. 12, 2020), at 4:03:13-4:04:22, 4:05:59-4:07:09, available at https://www.rev.com/tc-editor/shared/QQodU0TgHNW4ACZmBtqq6EbotJVTGos3UifEuLQA8ygjV7GrDDAeGJ6hdps86h_ywJAatI_KepUqEeZnloKHBiByyMI.
127. Edward-Isaac Dovere (@IsaacDovere), Twitter, Dec. 3, 2020 7:56 a.m. ET, available at https://twitter.com/IsaacDovere/status/1334481562193317888.
128. Michigan House Oversight Committee, Public Hearing, (Dec. 12, 2020), at 4:09:04, available at https://www.rev.com/tc-editor/shared/ QQodU0TgHNW4ACZmBtqq6EbotJVTGos3UifEuLQA8ygjV7GrDDAeGJ6hdps86h_ywJAatI_KepUqEeZnloKHBiByyMI.
129. Michigan House Oversight Committee, Public Hearing, (Dec. 12, 2020), at 4:35:15, available at https://www.rev.com/tc-editor/shared/ QQodU0TgHNW4ACZmBtqq6EbotJVTGos3UifEuLQA8ygjV7GrDDAeGJ6hdps86h_ywJAatI_KepUqEeZnloKHBiByyMI.
130. 11Alive, “Second Georgia Senate Election Hearing,” YouTube, at 1:56:30 to 1:57:15, 5:29:205:32:45, Dec. 3, 2020, available at https://www.youtube.com/watch?v=hRCXUNOwOjw.
131. GA House Mobile Streaming, “Governmental Affairs 12.10.20,” Vimeo – Livestream, at 1:51:551:52:55, available at https://livestream.com/accounts/25225474/events/9117221/videos/214677184.
132. Global TV Online, “#LIVE: Georgia State Senate Holds Meeting on 2020 Election . . . ,” YouTube, at 3:08:00 to 3:09:30, 3:20:15 to 3:21:2, Dec. 30, 2020, available at https://youtu.be/D5c034r0RlU?t=12016.
133. 11Alive, “Second Georgia Senate Election Hearing,” YouTube, at 0:33:30-0:58:00, December 3, 2020, available at https://www.youtube.com/watch?v=hRCXUNOwOjw.

134. Select Committee to Investigate the January 6th Attack on the United States Capitol, Transcribed Interview of Byung J. Pak, (May 19, 2022), pp. 10-23; United States Senate Judiciary Committee, Interview of Jeffrey Rosen, (August 7, 2021), pp. 30-31, available at https://www.judiciary.senate.gov/rosen-transcript-final; Declaration of Frances Watson at 1-3, Pearson v. Kemp, No. 1:20-cv-04809 (N.D. Ga., Dec. 6, 2020), ECF No. 72-1, available at https://www.documentcloud.org/documents/20420664-frances-watson-affidavit; Response of the Georgia Secretary of State to the Court's Order of September 20, 2021 at 5-7, 41-47, 53, 55, Favorito v. Wan, No. 2020CV343938 (Fulton County Sup. Ct., Ga., October 12, 2021), available at https://s3.documentcloud.org/documents/21084096/favorito-sos-brief-inresponse-to-order-of-92021-with-exs-a-and-b.pdf; William P. Barr, One Damn Thing After Another: Memoirs of an Attorney General (Harper Collins, 2022), at pp. 541-42; "Georgia Election Officials Briefing Transcript December 7: Will Recertify Election Results Today," Rev, (December 7, 2020), available at https://www.rev.com/blog/transcripts/georgiaelection-officials-briefing-transcript-december-7-will-recertify-election-results-today.

135. 11Alive, “Second Georgia Senate Election Hearing,” YouTube, at 5:31:50-5:32:10, Dec. 3, 2020, available at https://www.youtube.com/watch?v=hRCXUNOwOjw.
136. GA House Mobile Streaming, “Governmental Affairs 12.10.20,” Vimeo – Livestream, at 2:09:00-2:13:00, available at https://livestream.com/accounts/25225474/events/9117221/videos/214677184.
137. GA House Mobile Streaming, “Governmental Affairs 12.10.20,” Vimeo – Livestream, at 2:09:00-2:13:00, available at https://livestream.com/accounts/25225474/events/9117221/videos/214677184.
138. Mike Wilkinson, “The Rudy Giuliani ‘Circus’ Has Left Lansing. The Reviews Are Bad,” Bridge Michigan, (Dec. 3, 2020), available at https://www.bridgemi.com/michigan-government/rudy-giuliani-circus-has-left-lansing-reviews-are-bad.
139. Mike Wilkinson, “The Rudy Giuliani ‘Circus’ Has Left Lansing. The Reviews Are Bad,” Bridge Michigan, (Dec. 3, 2020), available at https://www.bridgemi.com/michigan-government/rudy-giuliani-circus-has-left-lansing-reviews-are-bad.
140. Donald J. Trump (@realDonaldTrump), Twitter, Dec. 6, 2020 6:01 a.m. ET, https://mediacdn.factba.se/realdonaldtrump-twitter/1335464302766149632.jpg (archived)..
141. In the Matter of Rudolph W. Giuliani, No. 2021-00506, slip op at *2, 32 (N.Y. App. Div. May 3, 2021), available at https://int.nyt.com/data/documenttools/giuliani-law-licensesuspension/1ae5ad6007c0ebfa/full.pdf.
142. Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (Angela McCallum Production), McCallum_01_001501 (November 30, 2021, Michael Brown text message to group at 2:47 a.m.).
143. Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (Angela McCallum Production), McCallum_01_001501 (November 30, 2021, Michael Brown text message to group at 2:47 a.m.).
144. Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (Angela McCallum Production), McCallum_01_001528 - 1564 (Trump Campaign spreadsheet).
145. Mirs Monday Podcast, “Call to Legislator from Someone Claiming to Be With Trump Campaign (12/1/20),” Podbean.com, at 0:08, (Dec. 1, 2020), available at https://www.podbean.com/media/share/pb-iqskx-f3cfc6.
146. Mirs Monday Podcast, “Call to Legislator from Someone Claiming to Be With Trump Campaign (12/1/20),” Podbean.com, at 1:32, (Dec. 1, 2020), available at https://www.podbean.com/media/share/pb-iqskx-f3cfc6.
147. Jonathan Oosting, “Trump Campaign Lobbies Michigan Lawmakers to Ignore Vote, Give Him Electors,” Bridge Michigan, (Dec. 2, 2020), available at https://www.bridgemi.com/michigan-government/trump-campaign-lobbies-michigan-lawmakers-ignore-vote-givehim-electors.
148. Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (Angela McCallum production), McCallum_01_001523 (text messages with Michael Brown).
149. Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (Angela McCallum production), McCallum_01_001523 (text messages with Michael Brown).
150. Select Committee to Investigate the January 6th Attack on the United States Capitol, Transcribed Interview of Michael Shirkey, (June 8, 2022), pp. 8-10; Senator Mike Shirkey (@SenMikeShirkey), Twitter, Nov. 20, 2020 6:13 p.m. ET, available at https://twitter.com/SenMikeShirkey/status/1329925843053899780.

151. Select Committee to Investigate the January 6th Attack on the United States Capitol, Transcribed Interview of Michael Shirkey, (June 8, 2022), p. 10.
152. "Administration of Donald J. Trump, 2020, Digest of Other White House Announcements,” Government Publishing Office, (December 31, 2020), p. 115, available at https://www.govinfo.gov/content/pkg/DCPD-2020DIGEST/pdf/DCPD-2020DIGEST.pdf.
153. Select Committee to Investigate the January 6th Attack on the United States Capitol, Transcribed Interview of Michael Shirkey, (June 8, 2022), p. 16.
154. Select Committee to Investigate the January 6th Attack on the United States Capitol, Transcribed Interview of Michael Shirkey, (June 8, 2022), pp. 16-18.
155. Select Committee to Investigate the January 6th Attack on the United States Capitol, Transcribed Interview of Michael Shirkey, (June 8, 2022), pp. 21-22.
156. Select Committee to Investigate the January 6th Attack on the United States Capitol, Transcribed Interview of Michael Shirkey, (June 8, 2022), p. 22.
157. Select Committee to Investigate the January 6th Attack on the United States Capitol, Informal Interview of Lee Chatfield (Oct. 15, 2021). Leader Shirkey did not remember any specific “ask” from the President during the Oval Office meeting. Select Committee to Investigate the January 6th Attack on the United States Capitol, Transcribed Interview of Michael Shirkey, (June 8, 2022), p. 16 (“One thing I do remember is that he never, ever, to the best of my recollection, ever made a specific ask. It was always just general topics[.]”).
158. Select Committee to Investigate the January 6th Attack on the United States Capitol, Informal Interview of Lee Chatfield (Oct. 15, 2021).
159. Select Committee to Investigate the January 6th Attack on the United States Capitol, Transcribed Interview of Michael Shirkey, (June 8, 2022), p. 57.
160. “Legislative Leaders Meet with President Trump,” State Senator Mike Shirkey, (Nov. 20, 2020), available at https://www.senatormikeshirkey.com/legislative-leaders-meet-withpresident-trump/.
161. Select Committee to Investigate the January 6th Attack on the United States Capitol, Informal Interview of Lee Chatfield, (Oct. 15, 2021).
162. Select Committee to Investigate the January 6th Attack on the United States Capitol, Informal Interview of Lee Chatfield, (Oct. 15, 2021).
163. Team Trump (Text TRUMP to 88022) (@TeamTrump), Twitter, Jan. 3, 2021 9:00 a.m. ET, available at http://web.archive.org/web/20210103170109/https://twitter.com/TeamTrump/status/1345776940196659201 (archived).
164. Select Committee to Investigate the January 6th Attack on the United States Capitol, Transcribed Interview of Michael Shirkey, (June 8, 2022), p. 52; Aaron Parseghian, “Former Michigan Resident Slammed with Calls after Trump Campaign Mistakenly Posts Number on Social Media,” Fox 17 West Michigan, (Jan. 4, 2021), available at https://www.fox17online.com/news/politics/former-michigan-resident-slammed-with-calls-aftertrump-campaign-mistakenly-posts-number-on-social-media.
165. Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (Mark Meadows Production), MM012414 (text to Rep. Scott Perry from Meadows).
166. Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (Mark Meadows Production), MM012445 (text to Meadows from Rep. Scott Perry).
167. Select Committee to Investigate the January 6th Attack on the United States Capitol, Informal Interview of Jake Corman, (Jan. 25, 2022); Jake Corman and Kerry Benninghoff, “Pa. Lawmakers Have No Role to Play in Deciding Presidential Election,” Centre Daily Times, (Oct. 19, 2020), available at https://www.centredaily.com/opinion/article246527648.html.

168. Barton Gellman, “The Election That Could Break America,” The Atlantic, (Sept. 23, 2020), available at https://www.theatlantic.com/magazine/archive/2020/11/what-if-trumprefuses-concede/616424/; Select Committee to Investigate the January 6th Attack on the United States Capitol, Informal Interview of Jake Corman, (Jan. 25, 2022); see Jake Corman, “Pa. Lawmakers Have No Role to Play in Deciding Presidential Election,” Centre Daily Times, (Oct. 19, 2020) available at https://www.centredaily.com/opinion/article246527648.html. Senator Corman and other Pennsylvania lawmakers sent a letter to Congress in January that mentioned “numerous unlawful violations” of State law and asked that Congress “delay certification of the electoral college.” Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (National Archives Production), 076P-R000002160_00001. In his informal interview with the Select Committee, however, Senator Corman acknowledged that he signed the letter due to pressure he was receiving after the election, but explained that he believed fraud and these types of issues should be adjudicated in the courtroom, not the legislature, and, in any event, he said that he was never presented with credible evidence of voter fraud. See Select Committee to Investigate the January 6th Attack on the United States Capitol, Informal Interview of Jake Corman, (Jan. 25, 2022).
169. Select Committee to Investigate the January 6th Attack on the United States Capitol, Informal Interview of Jake Corman, (Jan. 25, 2022).
170. Select Committee to Investigate the January 6th Attack on the United States Capitol, Informal Interview of Jake Corman, (Jan. 25, 2022).
171. Select Committee to Investigate the January 6th Attack on the United States Capitol, Informal Interview of Jake Corman, (Jan. 25, 2022).
172. Select Committee to Investigate the January 6th Attack on the United States Capitol, Informal Interview of Jake Corman, (Jan. 25, 2022).
173. Select Committee to Investigate the January 6th Attack on the United States Capitol, Informal Interview of Jake Corman, (Jan. 25, 2022).
174. Select Committee to Investigate the January 6th Attack on the United States Capitol, Informal Interview of Jake Corman, (Jan. 25, 2022).
175. Select Committee to Investigate the January 6th Attack on the United States Capitol, Informal Interview of Jake Corman, (Jan. 25, 2022).
176. Select Committee to Investigate the January 6th Attack on the United States Capitol, Informal Interview of Jake Corman, (Jan. 25, 2022).
177. Select Committee to Investigate the January 6th Attack on the United States Capitol, Informal Interview of Jake Corman, (Jan. 25, 2022).
178. Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (Bryan Cutler Production), B_CUTLER_0000131-0000134 (Giuliani and Ellis voicemails).
179. Select Committee to Investigate the January 6th Attack on the U.S. Capitol, Transcribed Interview of Bryan Cutler, (May 31, 2022), p. 21.
180. Select Committee to Investigate the January 6th Attack on the U.S. Capitol, Transcribed Interview of Bryan Cutler, (May 31, 2022), p. 21.
181. Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (Bryan Cutler Production), B_CUTLER_0000131 (Giuliani and Ellis voicemail).
182. Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (Bryan Cutler Production), B_CUTLER_0000132 (Jenna Ellis voicemail).
183. Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (Bryan Cutler Production), B_CUTLER_0000133 (Giuliani voicemail).
184. Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (Bryan Cutler Production), B_CUTLER_0000134 (Giuliani voicemail).

185. Select Committee to Investigate the January 6th Attack on the U.S. Capitol, Transcribed Interview of Bryan Cutler, (May 31, 2022), pp. 42-44, 46-47. The New York Times reported that Speaker Cutler spoke with President Trump twice by phone, Cutler told the Select Committee that this claim was incorrect and that he only spoke with the President by phone once, followed by their second conversation on December 3rd, which was in person. See Trip Gabriel, “Trump Asked Pennsylvania House Speaker about Overturning His Loss,” New York Times, (Dec. 8, 2020), available at https://www.nytimes.com/2020/12/08/us/politics/trump-pennsylvania-house-speaker.html; see also Amy Gardner, Josh Dawsey and Rachael Bade, “Trump Asks Pennsylvania House Speaker for Help Overturning Election Results, Personally Intervening in a Third State,” Washington Post, (Dec. 8, 2020), available at https://www.washingtonpost.com/politics/trump-pennsylvania-speaker-call/2020/12/07/d65fe8c4-38bf-11eb-98c4-25dc9f4987e8_story.html.
186. Select Committee to Investigate the January 6th Attack on the U.S. Capitol, Transcribed Interview of Bryan Cutler, (May 31, 2022), pp. 43-44.
187. Select Committee to Investigate the January 6th Attack on the U.S. Capitol, Transcribed Interview of Bryan Cutler, (May 31, 2022), pp. 26-27, 44.
188. Select Committee to Investigate the January 6th Attack on the U.S. Capitol, Transcribed Interview of Bryan Cutler, (May 31, 2022), pp. 49-57; Select Committee to Investigate the January 6th Attack on the United States Capitol, Informal Interview of Jake Corman, (Jan. 25, 2022).
189. Select Committee to Investigate the January 6th Attack on the U.S. Capitol, Transcribed Interview of Bryan Cutler, (May 31, 2022), p. 50.
190. Select Committee to Investigate the January 6th Attack on the U.S. Capitol, Transcribed Interview of Bryan Cutler, (May 31, 2022), pp. 50-55.
191. Select Committee to Investigate the January 6th Attack on the U.S. Capitol, Transcribed Interview of Bryan Cutler, (May 31, 2022), pp. 54-55.
192. Select Committee to Investigate the January 6th Attack on the U.S. Capitol, Transcribed Interview of Bryan Cutler, (May 31, 2022), pp. 56-57.
193. “Statement on Election Reform,” Pennsylvania Senate GOP (Dec 3, 2020, accessed July 14, 2022), available at https://www.pasenategop.com/wp-content/uploads/2020/12/electionreform-120320.pdf.
194. Donald J. Trump (@realDonaldTrump), Twitter, Dec. 6, 2020 12:56 a.m. ET, available at https://media-cdn.factba.se/realdonaldtrump-twitter/1335463148137164802.jpg (archived).
195. Donald J. Trump (@realDonaldTrump), Twitter, Dec. 8, 2020 2:51 p.m. ET, available at https://media-cdn.factba.se/realdonaldtrump-twitter/1336322408970559495.jpg (archived); "Letter to Pennsylvania's Congressional Delegation,” Pennsylvania State GOP, (Dec. 4, 2020, last accessed July 14, 2022), available at http://www.pahousegop.com/Display/SiteFiles/1/2020/120420CongressElection2020B.pdf.
196. Select Committee to Investigate the January 6th Attack on the U.S. Capitol, Transcribed Interview of Bryan Cutler, (May 31, 2022), pp. 60-61.
197. Select Committee to Investigate the January 6th Attack on the U.S. Capitol, Transcribed Interview of Bryan Cutler, (May 31, 2022), p. 61.
198. Trip Gabriel, “Even in Defeat, Trump Tightens Grip on State G.O.P. Lawmakers,” New York Times, (Dec. 9, 2020), available at https://www.nytimes.com/2020/12/09/us/politics/trump-pennsylvania-electoral-college.html.
199. Trip Gabriel, “Even in Defeat, Trump Tightens Grip on State G.O.P. Lawmakers,” New York Times, (Dec. 9, 2020), available at https://www.nytimes.com/2020/12/09/us/politics/trump-pennsylvania-electoral-college.html.

200. 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 41:30-46:35, available at https://www.youtube.com/watch?v=xa43_z_82Og; Yvonne Wingett Sanchez and Ronald J. Hansen, "White House Phone Calls, Baseless Fraud Charges: The Origins of the Arizona Election Review," AZ Central, (Nov. 17, 2021), available at https://www.azcentral.com/in-depth/news/politics/elections/2021/11/17/arizona-audit-trumpallies-pushed-to-undermine-2020-election/6045151001/.

201. 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 41:30-46:35, available at https://www.youtube.com/watch?v=xa43_z_82Og; Yvonne Wingett Sanchez and Ronald J. Hansen, “White House Phone Calls, Baseless Fraud Charges: The Origins of the Arizona Election Review,” AZ Central, (Nov. 17, 2021), available at https://www.azcentral.com/in-depth/news/politics/elections/2021/11/17/arizona-audit-trumpallies-pushed-to-undermine-2020-election/6045151001/.
202. 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 41:30-46:35, available at https://www.youtube.com/watch?v=xa43_z_82Og; Yvonne Wingett Sanchez and Ronald J. Hansen, “White House Phone Calls, Baseless Fraud Charges: The Origins of the Arizona Election Review,” AZ Central, (Nov. 17, 2021), available at https://www.azcentral.com/in-depth/news/politics/elections/2021/11/17/arizona-audit-trumpallies-pushed-to-undermine-2020-election/6045151001/.
203. 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 41:30-46:35, available at https://www.youtube.com/watch?v=xa43_z_82Og; Yvonne Wingett Sanchez and Ronald J. Hansen, “White House Phone Calls, Baseless Fraud Charges: The Origins of the Arizona Election Review,” AZ Central, (Nov. 17, 2021), available at https://www.azcentral.com/in-depth/news/politics/elections/2021/11/17/arizona-audit-trumpallies-pushed-to-undermine-2020-election/6045151001/.
204. 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 41:30-46:35, available at https://www.youtube.com/watch?v=xa43_z_82Og.
205. 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 41:30-46:35, available at https://www.youtube.com/watch?v=xa43_z_82Og.
206. 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 41:30-46:35, available at https://www.youtube.com/watch?v=xa43_z_82Og. In his testimony to the Select Committee, Speaker Bowers said this appeal to party loyalty occurred in that call or in a later meeting, and that the President brought it up “more than once.”
207. Dillon Rosenblatt and Julia Shumway, “Giuliani COVID-19 Diagnosis Closes Arizona Legislature,” Arizona Capitol Times, (Dec. 6, 2020), available at https://azcapitoltimes.com/news/2020/12/06/giuliani-covid-19-diagnosis-closes-arizona-legislature/; Select Committee to Investigate the January 6th Attack on the United States Capitol, Informal Interview of Arizona House Speaker Rusty Bowers, (Nov. 17, 2021); Vince Leach (@VinceLeach), Twitter, Dec. 1, 2020 11:28 p.m. ET, available at https://twitter.com/VinceLeach/status/1333991317500727298. Speaker Bowers told the Committee that Giuliani and Ellis were accompanied by Katherine Friess, J. Philip Waldron, Bernard Kerik, and others. See Select Committee to Investigate the January 6th Attack on the United States Capitol, Informal Interview of Arizona House Speaker Rusty Bowers, (Nov. 17, 2021).
208. Select Committee to Investigate the January 6th Attack on the United States Capitol, Deposition of Rudolph Giuliani, (May 20, 2022), pp. 58-59; Select Committee to Investigate the January 6th Attack on the United States Capitol, Deposition of Jenna Ellis, (Mar. 8, 2022), pp. 50-51.

209. "Select Committee to Investigate the January 6th Attack on the U.S. Capitol, Transcribed Interview of Russel "Rusty" Bowers, (June 19, 2022), pp. 35-36; Select Committee to Investigate the January 6th Attack on the United States Capitol, Informal Interview of Arizona House Speaker Rusty Bowers, (Nov. 17, 2021); "Speaker Bowers Addresses Calls for the Legislature to Overturn 2020 Certified Election Results," Arizona State Legislature, (Dec. 4, 2020), available at https://www.azleg.gov/press/house/54LEG/2R/201204STATEMENT.pdf

210. 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 53:00-53:40, available at https://www.youtube.com/watch?v=xa43_z_82Og.
211. 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 53:00-53:40, available at https://www.youtube.com/watch?v=xa43_z_82Og.
212. 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 53:00-53:40, available at https://www.youtube.com/watch?v=xa43_z_82Og.
213. 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 53:00-53:40, available at https://www.youtube.com/watch?v=xa43_z_82Og.
214. 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 56:00-59:50, available at https://www.youtube.com/watch?v=xa43_z_82Og; Select Committee to Investigate the January 6th Attack on the United States Capitol, Transcribed Interview of Russell Bowers, (June 19, 2022), pp. 39-41.
215. 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 56:00-59:50, available at https://www.youtube.com/watch?v=xa43_z_82Og.
216. 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 56:00-59:50, available at https://www.youtube.com/watch?v=xa43_z_82Og.
217. “Trump Allies Leave Voicemail Messages for Maricopa County Supervisors,” AZ Central, (July 2, 2021), available at https://www.azcentral.com/videos/news/politics/elections/2021/07/02/trump-allies-left-voicemail-messages-maricopa-county-supervisors-election-andcontested-results/7837919002/.
218. “Trump Allies Leave Voicemail Messages for Maricopa County Supervisors,” AZ Central, (July 2, 2021), available at https://www.azcentral.com/videos/news/politics/elections/2021/07/02/trump-allies-left-voicemail-messages-maricopa-county-supervisors-election-andcontested-results/7837919002/.
219. See Select Committee to Investigate the January 6th Attack on the United States Capitol, Informal Interview of Clint Hickman, (Nov. 17, 2021); see also Yvonne Wingett Sanchez, “'We Need You to Stop the Counting': Records Detail Intense Efforts by Trump Allies to Pressure Maricopa County Supervisors,” AZ Central (July 2, 2021), available at https://www.azcentral.com/story/news/politics/elections/2021/07/02/records-show-trump-allieskelli-ward-rudy-giuliani-pressed-county-officials-over-election-results/7813304002/.
220. Yvonne Wingett Sanchez, “'Fighting for Democracy Here': Election Audit Pits Maricopa County Republicans vs. Arizona GOP,” AZ Central, (May 23, 2021) available at https://www.azcentral.com/story/news/politics/elections/2021/05/23/election-audit-pitsmaricopa-county-republicans-against-arizona-gop-senators/5186141001/; see also “Trump allies leave voicemail messages for Maricopa County supervisors,” AZ Central, (July 2, 2021), available at https://www.azcentral.com/videos/news/politics/elections/2021/07/02/trump-allies-left-voicemail-messages-maricopa-county-supervisors-election-and-contested-results/7837919002/.

221. Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (Maricopa County Board of Supervisors Production), CTRL0000020072, pp. 1-2 (December 24, 2020, copy of voice message and a transcription); see also Yvonne Wingett Sanchez and Ronald J. Hansen, "'Asked to Do Something Huge': An Audacious Pitch to Reverse Arizona's Election Results," AZ Central, (Dec. 2, 2021), available at https://www.azcentral.com/in-depth/news/politics/elections/2021/11/18/arizona-audit-rudygiuliani-failed-effort-replace-electors/6349795001/.

222. Select Committee to Investigate the January 6th Attack on the United States Capitol, Informal Interview of Jack Sellers and Bill Gates, (Oct. 6, 2021).
223. Yvonne Wingett Sanchez, “'We Need You to Stop the Counting': Records Detail Intense Efforts by Trump Allies to Pressure Maricopa County Supervisors,” AZ Central, (July 2, 2021), available at https://www.azcentral.com/story/news/politics/elections/2021/07/02/records-show-trump-allies-kelli-ward-rudy-giuliani-pressed-county-officials-over-electionresults/7813304002/.
224. Yvonne Wingett Sanchez, “'We Need You to Stop the Counting': Records Detail Intense Efforts by Trump Allies to Pressure Maricopa County Supervisors,” AZ Central, (July 2, 2021), available at https://www.azcentral.com/story/news/politics/elections/2021/07/02/records-show-trump-allies-kelli-ward-rudy-giuliani-pressed-county-officials-over-electionresults/7813304002/.
225. Document on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (Bill Stepien Production), WS00104-105 (December 5, 2021, email from Joshua Findlay to Matthew Morgan, Justin Clark, and Bill Stepien at 11:44 pm).
226. Brian Kemp (@BrianKempGA), Twitter, Dec. 5, 2020 12:44 p.m., available at https://twitter.com/briankempga/status/1335278871630008324.
227. Donald J. Trump (@realDonaldTrump), Twitter, Dec. 5, 2020 9:35 pm ET, available at https://media-cdn.factba.se/realdonaldtrump-twitter/1335336916582084614.jpg (archived). As detailed later in this report, the call for special sessions of legislatures in various States, including Georgia, never gained traction and, when all else failed, became a focus for two Department of Justice lawyers.
228. Office of Governor Brian P. Kemp, “Gov. Kemp, Lt. Gov. Duncan Issue Statement on Request for Special Session of General Assembly,” MadMimi.com, (Dec. 6, 2020), available at https://madmimi.com/p/50e7a11?pact=1301484-161142215-11561983238b09ac0db7ff3f3c8bd594d6a33e7f63d0cf4c135.
229. Donald J. Trump (@realDonaldTrump), Twitter, Dec. 8, 2020 3:07 p.m., available at http://web.archive.org/web/20201208200907/https://twitter.com/realdonaldtrump/status/1336401919422640128 (archived) (retweeting Lin Wood (@LLinWood), Twitter, Dec. 8, 2020, 11:22 a.m., available at http://web.archive.org/web/20201208200908/https://twitter.com/LLinWood/status/1336390712380813313 (archived)).
230. Brett Samuels, “Trump Retweets Lawyer Who Said Republican Officials in Georgia Are ‘Going to Jail’,” The Hill, (Dec. 15, 2020), available at https://thehill.com/homenews/campaign/530250-trump-retweets-lawyer-who-says-republican-officials-in-georgia-aregoing-to/.
231. Search results for “‘The Republican Governor of Georgia refuses’ | ‘As badly as we were treated in Georgia’ | kemp | @briankempga,” from November 30 to December 31, 2020, Trump Twitter Archive V2, (last accessed December 12, 2022), available at https://www.thetrumparchive.com/?searchbox=%22%5C%22The+Republican+Governor+of+Georgia+refuses%5C%22+%7C+%5C%22As+badly+as+we+were+treated+in+Georgia%5C%22+%7C+kemp+%7C+%40briankempga%22&dates=%5B%222020-11-30%22%2C%222020-12-30%22%5D&results=1.
232. Document on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (National Archives Production), 076P-R000007750_0001, (December 7, 2020 email from Bill White to Dan Scavino and others) including screenshot of Burt Jones (@burtjonesforga), Twitter, Dec. 7, 2020 11:26 a.m., available at https://twitter.com/burtjonesforga/status/1335984150789173248), available at https://twitter.com/burtjonesforga/status/1335984150789173248).

233. Donald J. Trump (@realDonaldTrump), Twitter, Dec. 7, 2020 1:29 p.m. ET, available at https://factba.se/biden/topic/twitter?q=burtjonesforga&f= (archived); Rudy W. Giuliani (@RudyGiuliani), Twitter, Dec. 7, 2020 12:25 p.m., available at https://twitter.com/RudyGiuliani/status/1335998988101804035.
234. Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (National Archives Production), 076P-R000007693_00001.
235. Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (National Archives Production), 076P-R000007693_00001.
236. Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (National Archives Production), 076P-R000007693_00001.
237. David Wickert and Greg Bluestein, “Inside the Campaign to Undermine Georgia’s Election (Part I),” Atlanta Journal-Constitution, (Dec. 30, 2021), available at https://www.ajc.com/politics/election/georgia-2020-election-what-happened/.
238. Shepherd's Sling, “Steven K. Bannon - War Room Pandemic - Ep. #568/569 (Full 2hrs Podcast),” BitChute, at 16:50 - 18:00, Dec. 8, 2020, available at https://www.bitchute.com/video/KyK4QPP7Ngyt/; John Fredericks (@jfradioshow), Twitter, Dec. 7, 2020 5:30 p.m. ET, available at https://twitter.com/jfradioshow/status/1336075668090654724; Jim Hoft, “Developing: President Trump Speaks with Georgia House Speaker David Ralston and Speaker Pro-Tem Jan Jones on Endorsing Special Session,” Gateway Pundit, (Dec. 7, 2020), available at https://www.thegatewaypundit.com/2020/12/developing-president-trumpspeaks-georgia-house-speaker-david-ralston-speaker-pro-tem-jan-jones-endorsingspecial-session/.
239. FYNTV FetchYourNews, “#BKP Has a Live Call-In with David Ralston,” YouTube, at 2:30 - 3:12 (Dec. 8, 2020), available at http://web.archive.org/web/20201224164814/https://www.youtube.com/watch?v=ZdN5vNOl6F4&gl=US&hl=en (archived); Julie Carr, “Georgia Speaker of the House David Ralston Joins BKP Politics to Discuss His Call with President Trump and a Legal Path Forward,” Tennessee Star, (Dec. 20, 2020), available at https://tennesseestar.com/2020/12/20/georgia-speaker-of-the-house-david-ralston-joins-bkppolitics-to-discuss-his-call-with-president-trump-and-a-legal-path-forward/.
240. Select Committee to Investigate the January 6th Attack on the United States Capitol, Continued Interview of Cassidy Hutchinson, (Mar. 7, 2022), pp. 162-67.
241. Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (Georgia Secretary of State Production), GA SOS ORR (21-344) 005651 (Dec. 23, 2020 call between President Trump and Frances Watson); Select Committee to Investigate the January 6th Attack on the U.S. Capitol, Informal Interview with Frances Watson (Dec. 15, 2021); see also “Georgia Secretary of State Recording of Trump Phone Call to Election Investigator,” American Oversight (Mar. 10, 2021), available at https://www.americanoversight.org/document/georgia-secretary-of-state-recording-of-trumpphone-call-to-election-investigator.
242. Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (Mark Meadows Production), MM014152 (December 27, 2020 text message at 5:18 p.m. from Mark Meadows to Jordan Fuchs).
243. Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (Mark Meadows Production), MM014153 (December 27, 2020 text message at 5:20 p.m. from Jordan Fuchs to Mark Meadows).
244. Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (Mark Meadows Production), MM012317 (November 19, 2020 text message at 9:56 a.m. from Mark Meadows to Brad Raffensperger).
245. Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (Mark Meadows Production), MM013362.

246. Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (Mark Meadows Production), MM013632-33; see also Newsmax (@newsmax), Twitter, Dec. 11, 2020 9:45 p.m. ET, available at https://twitter.com/newsmax/status/1337589238078922752.
247. Philip Rucker, Ashley Parker, Josh Dawsey, and Seung Min Kim, “Trump Sabotaging GOP on His Way Out of Office with Push to Overturn Election,” Washington Post, (Jan. 4, 2021), available at https://www.washingtonpost.com/politics/trump-sabotage-republicans/2021/01/04/df5d301e-4eb1-11eb-83e3-322644d82356_story.html.
248. “Georgia Sec. of State Discusses Phone Call with Trump About Election Results,” Good Morning America, at 1:40 to 2:20, (Jan. 4, 2021), available at https://www.goodmorningamerica.com/news/video/georgia-sec-state-discusses-phone-calltrump-election-75032599.
249. 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.
250. 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-transcript-georgia-vote/2021/01/03/2768e0cc-4ddd-11eb-83e3-322644d82356_story.html.
251. 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-transcript-georgia-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/trump-raffensperger-call-transcriptgeorgia-vote/2021/01/03/2768e0cc-4ddd-11eb-83e3-322644d82356_story.html (the Washington Post redacted Freeman’s name and instead used “[name]” in the transcript); “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-trump-georgia-phone-call-transcript-brad-raffensperger-recording.
253. 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-transcript-georgia-vote/2021/01/03/2768e0cc-4ddd-11eb-83e3-322644d82356_story.html.
254. Donald J. Trump (@realDonaldTrump), Twitter, Jan. 3, 2021 8:57 a.m. ET, available at https://media-cdn.factba.se/realdonaldtrump-twitter/1345731043861659650.jpg (archived). The archived image is in universal time.
255. Donald J. Trump (@realDonaldTrump), Twitter, Jan. 3, 2021 8:29 a.m. ET, available at https://media-cdn.factba.se/realdonaldtrump-twitter/1345723944654024706.jpg, (archived).
256. 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.
257. See, e.g., Select Committee to Investigate the January 6th Attack on the United States Capitol, Transcribed Interview of Richard Donoghue, (Oct. 1, 2021), pp. 117-32; 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-07262021-000698–000702 (Draft letter written by Jeffrey Clark).

258. “Senate Committee to Discuss Election Issues in Pennsylvania,” Pennsylvania Senate GOP website (Nov. 24, 2020, last accessed on July 15, 2022), available at https://www.pasenategop.com/blog/senate-committee-to-discuss-election-issues-inpennsylvania/; Select Committee to Investigate the January 6th Attack on the United States Capitol, Deposition of Rudolph Giuliani, (May 20, 2022), pp. 65-66. https://www.pasenategop.com/blog/senate-committee-to-discuss-election-issues-inpennsylvania/.
259. Jeremy Roebuck and Andrew Seidman, “Pa. GOP lawmaker Doug Mastriano says he left the Capitol area before the riot. New videos say otherwise,” Philadelphia Inquirer, (May 25, 2021), available at https://www.inquirer.com/news/doug-mastriano-capitol-riotpennslyvania-video-20210525.html.
260. Eric Metaxas, "Interview: Eric Metaxas Interviews Donald Trump with Douglas Mastriano,” Factba.se Archive, (Nov. 30, 2020), available at https://factba.se/transcript/donald-trumpinterview-eric-metaxas-douglas-mastriano-november-30-2020; Senator Doug Mastriano (@SenMastriano), Twitter, Nov. 30, 2020 5:56 p.m. ET, available at https://twitter.com/senmastriano/status/1333545380965986307.
261. Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (National Archives Production), 076P-R000008230_0001, 076PR000008231_0001 (email and attachment from Mastriano to Molly Michael); see also Kelly v. Pennsylvania, 141 S. Ct. 950 (2020) (order denying application for injunctive relief presented to Justice Alito and denying referral to the full Court).
262. Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (National Archives Production), 076P-R000001378_00001, 076PR000001379_00001.
263. Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (National Archives Production), 076P-R000003771_0001, 076PR000003772_0001 (Dec. 21, 2020, email from Doug Mastriano to Molly Michael titled “Letter Requested by the President”).
264. Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (National Archives Production), 076P-R000003771_0001, 076PR000003772_0001 (Dec. 21, 2020, email from Doug Mastriano to Molly Michael titled “Letter requested by the President”).
265. See, e.g., Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (National Archives Production), 076P-R000003748_0001, 076P-R000003749_0001, (Dec. 29, 2020, Doug Mastriano email to Molly Michael titled “Pennsylvania letter for AG Donoghue regarding election”; Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol, (National Archives Production), 076P-R000003753_0001, 076P-R000003754_0001, (Dec. 22, 2020, Molly Michael email to Rush Limbaugh titled “From POTUS”); Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol, (National Archives Production) 076P-R000003761_0001, 076P-R000003762_0001, (Dec. 22, 2020, Molly Michael email to Pam Bondi titled “From POTUS”); Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol, (National Archives Production) 076P-R000003766_0001, (Dec. 21, 2020, Molly Michael email to Lou Dobbs titled “2 attachments from POTUS”); Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol, (National Archives Production), 076P-R000008968_0001, (Jan. 1, 2021, Molly Michael email to Kevin McCarthy titled “From POTUS”); Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol, (National Archive Production) 076PR000003759_0001, (Dec. 22, 2020, Molly Michael email to John Eastman, Justin Clark, and Michael Farris titled “From POTUS”); Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol, (National Archives Production) 076P-R000003763_0001, (December 21, 2020, email from Molly Michael to Christopher Michel re: From POTUS).

266. Charlotte Cuthbertson, “Trump ‘Resolved, Determined’ about Election, Says Pennsylvania Senator,” Epoch Times (Dec. 24, 2020), available at https://www.theepochtimes.com/trumpresolved-determined-about-election-says-pennsylvania-senator_3632138.html; Marc Levy & Mark Scolforo, “White House Invites GOP Lawmakers in Pennsylvania to Lunch,” Associated Press, (Dec. 23, 2020), available at https://apnews.com/article/donald-trumppennsylvania-coronavirus-pandemic-c5b7f43af7794f01f6d339b7258b915a; Jan Murphy, “Pa. Senators Head to White House for Pre-Holiday Lunch with President Trump,” Penn Live – Patriot-News, (Dec. 23, 2020), available at https://www.pennlive.com/news/2020/12/pasenators-head-to-white-house-for-pre-holiday-lunch-with-president-trump.html; “Ep 608Pandemic: Merry Christmas Eve Special Hour 1 (w/ Mayor Giuliani, Dr. Peter K. Navarro, Major Sgt. Scotty Neil, Former Navy Seal Tej Gill, Christopher Flannery ),” War Room Podcast (Dec. 24, 2020), 25:17 to 25:25, available at https://warroom.org/2020/12/24/ep-608pandemic-merry-christmas-eve-special-hour-1-w-dr-peter-k-navarro-major-sgt-scotty-neilformer-navy-seal-tej-gill-christopher-flannery/. Charlotte Cuthbertson, “Trump ‘Resolved, Determined’ about Election, Says Pennsylvania Senator,” Epoch Times (Dec. 24, 2020), available at https://www.theepochtimes.com/trump-resolved-determined-about-election-sayspennsylvania-senator_3632138.html; Marc Levy & Mark Scolforo, “White House Invites GOP Lawmakers in Pennsylvania to Lunch,” Associated Press (Dec. 23, 2020), available at https://apnews.com/article/donald-trump-pennsylvania-coronavirus-pandemicc5b7f43af7794f01f6d339b7258b915a; Jan Murphy, “Pa. Senators Head to White House for PreHoliday Lunch with President Trump,” Penn Live – Patriot-News (Dec. 23, 2020), available at https://www.pennlive.com/news/2020/12/pa-senators-head-to-white-house-for-preholiday-lunch-with-president-trump.html; “Ep 608- Pandemic: Merry Christmas Eve Special Hour 1 (w/ Mayor Giuliani, Dr. Peter K. Navarro, Major Sgt. Scotty Neil, Former Navy Seal Tej Gill, Christopher Flannery)”, War Room Podcast (Dec.https://warroom.org/2020/12/24/ep608-pandemic-merry-christmas-eve-special-hour-1-w-dr-peter-k-navarro-major-sgt-scottyneil-former-navy-seal-tej-gill-christopher-flannery/.
267. See, e.g., Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (National Archives Production), 076P-R000008298_0001 (December 28, 2020, email from Molly Michael to Mark Meadows forwarding Senator Doug Mastriano info for the president), 076P-R000007593_0001 (December 28, 2020, email from Molly Michael to Scott Toland forwarding Senator Doug Mastriano info for the president), 076P-R000003748_0001, 076P-R000003749_0001 (December 29, 2020, email and attachments from Doug Mastriano to Molly Michael re: Pennsylvania letter for AG Donoghue regarding election), , 076P-R000003745_0001, 076P-R000003746_0001, 076P-R000003747_0001 (December 31, 2020, email from Doug Mastriano to Molly Michael re: Letters requested by President Trump and attachments).
268. See Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (National Archives Production), 076P-R000003745_0001, 076PR000003746_0001, 076P-R000003747_0001 (December 31, 2020, email from Doug Mastriano to Molly Michael re: Letters requested by President Trump and attachments).
269. Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (National Archives Production), 076P-R000003732_0001(Email from Molly Michael to Amy Swonger, passing along information from Mastriano, 076PR000008399_0001 (Email from Amy Swonger to Molly Michael responding)). According to the White House’s Director of the Office of Legislative Affairs, Amy Swonger, the President repeatedly asked for her to distribute political materials after the election, which led her to seek advice from the White House Counsel’s Office because fulfilling the President’s request would likely violate the Hatch Act. See Select Committee to Investigate the January 6th Attack on the United States Capitol, Transcribed Interview of Amy Swonger, (Oct. 28, 2022), pp. 52-53.
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271. Documents on file with the Select Committee to Investigate the January 6th Attack on the United States Capitol (National Archives Production), 076P-R000004788_0001, 076PR000004789_0001-0066 (January 5, 2021, email from Mastriano attaching letter for Vice President Pence signed by Pennsylvania legislators), 076P-R000004957_0001 (Molly Michael acknowledging receipt), 076P-R000005084_0001 (Molly Michael passing the letter along to Marc Short), 076P-R000007338_0001 (acknowledgment that the letter was printed for POTUS), 076P-R000004687_0001, 076P-R000004688_0001 (January 5, 2021, email and attached letter to Molly Michael re: Caucus Letter to Sen. McConnell and Rep. McCarthy).
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283. Select Committee to Investigate the January 6th Attack on the United States Capitol, Deposition of Rudolph Giuliani, (May 20, 2022), pp. 225-27; Select Committee to Investigate the January 6th Attack on the United States Capitol, Interview of Bernard Kerik, (Jan. 13, 2022), pp. 139-140.
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299. Paul Bedard, “Exclusive: Trump Urges State Legislators to Reject Electoral Votes, ‘You Are the Real Power’,” Washington Examiner, (Jan. 3, 2021), available at https://www.washingtonexaminer.com/washington-secrets/exclusive-trump-urges-statelegislators-to-reject-electoral-votes-you-are-the-real-power.
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327. Donald J. Trump (@realDonaldTrump) RT of Christina Bobb (@christina_bobb) QT of Ali #StopTheSteal Alexander (@ali), Twitter, Dec. 6, 2020 12:53 a.m. ET, available at https://media-cdn.factba.se/realdonaldtrump-twitter/1335462365370994689.jpg (archive); Donald J. Trump (@realDonaldTrump), Twitter, Dec. 6, 2020 12:53 a.m. ET, available at https://www.thetrumparchive.com/?searchbox=%22rusty+bowers%22&dates=%5B%222020-1129%22%2C%222020-12-29%22%5D&results=1 (archived) (retweeting Christina Bobb).

328. Dennis Welch (@dennis_welch), Twitter, Dec. 8, 2020 11:23 p.m. ET, available at https://twitter.com/dennis_welch/status/1336526978640302080 (retweeting people who were posting Bowers's personal information); Dennis Welch (@dennis_welch), Twitter, Dec. 8, 2020 11:28 p.m. ET, available at https://twitter.com/dennis_welch/status/1336528029791604737.
329. Select Committee to Investigate the January 6th Attack on the U.S. Capitol, Transcribed Interview with Russel “Rusty” Bowers (June 19, 2022), pp. 50-52; Kelly Weill, “Arizona GOP Civil War Somehow Keeps Getting Weirder,” Daily Beast, (Dec. 11, 2020), available at https://www.thedailybeast.com/arizona-republican-party-civil-war-somehow-keepsgetting-weirder; Yvonne Wingett Sanchez and Ronald J. Hansen, “‘Asked to do Something Huge’: An Audacious Pitch to Reserve Arizona’s Election Results,” Arizona Republic, (Nov. 18, 2021, updated Dec. 2, 2021), available at https://www.azcentral.com/in-depth/news/politics/elections/2021/11/18/arizona-audit-rudy-giuliani-failed-effort-replace-electors/6349795001/.
330. Select Committee to Investigate the January 6th Attack on the U.S. Capitol, Transcribed Interview with Russel “Rusty” Bowers (June 19, 2022), pp. 50-52.
331. House Select Committee to Investigate the January 6th Attack on the U.S. Capitol, Transcribed Interview with Russel “Rusty” Bowers (June 19, 2022), pp. 50-52.
332. Brahm Resnik, “VIDEO: Group chants ‘We are watching you’ outside Arizona Secretary of State Katie Hobbs’ home,” KPNX 12 News, (Nov. 18, 2020), available at https://www.12news.com/article/news/politics/video-group-chants-we-are-watching-you-outsidearizona-secretary-of-state-katie-hobbs-home/75-a569ae35-3b62-424e-88f8-f03ca8b89458; “Arizona Sec. of State Says She Hays Received Threats of Violence Following Election,” Fox 10 Phoenix, (Nov. 18, 2020, updated Nov. 19, 2020), available at https://www.fox10phoenix.com/news/arizona-sec-of-state-says-she-has-received-threats-ofviolence-following-election; Brahm Resnik, “Arizona Law Enforcement Investigating Social Media Threat against Top Elections Official,” KPNX 12 News, (Nov. 18, 2020), available at https://www.12news.com/article/news/local/arizona/arizona-law-enforcementinvestigating-social-media-threat-against-top-elections-official/75-486474ea-11c9-47ada325-8bbed6e3e231.
333. “Arizona Sec. of State Says She Hays Received Threats of Violence Following Election," Fox 10 Phoenix, (Nov. 18, 2020, updated Nov. 19, 2020), available at https://www.fox10phoenix.com/news/arizona-sec-of-state-says-she-has-received-threats-ofviolence-following-election; Brahm Resnik, “Arizona Law Enforcement Investigating Social Media Threat against Top Elections Official,” KPNX 12 News, (Nov. 18, 2020), available at https://www.12news.com/article/news/local/arizona/arizona-law-enforcementinvestigating-social-media-threat-against-top-elections-official/75-486474ea-11c9-47ada325-8bbed6e3e231.
334. Isaac Dovere and Jeremy Herb, “‘It’s Absolutely Getting Worse’: Secretaries of State Targeted by Trump Election Lies Live in Fear for their Safety and are Desperate for Protection,” CNN, (Oct. 26, 2021), available at https://www.cnn.com/2021/10/26/politics/secretaries-of-state-personal-threats-trump-election-lies/index.html; Michael Wines and Eliza Fawcett, “Violent Threats to Election Workers are Common. Prosecutions are Not,” New York Times, (June 27, 2022, updated July 1, 2022), available at https://www.nytimes.com/2022/06/27/us/election-workers-safety.html.
335. Committee on House Administration, Election Subversion: A Growing Threat to Election Integrity, Statement of Adrian Fontes Maricopa County Recorder (2016-2020), at *1, 6 (July 28, 2020), available at https://docs.house.gov/meetings/HA/HA00/20210728/113971/HHRG117-HA00-Wstate-FontesA-20210728.pdf.
336. Bob Christie, “Months after Biden Win, Arizona Officials Still Face Threats,” Associated Press, (Feb. 12, 2021), available at https://apnews.com/article/joe-biden-donald-trumparizona-phoenix-elections-2bd2306acb2ae89c0ef37182fbb415b7.

337. Nicole Valdes, “Online Death Threats Target Maricopa County Board of Supervisors,” ABC 15 Arizona, (Jan. 8, 2021, updated Jan. 9, 2021), available at https://www.abc15.com/news/state/enough-is-enough-online-death-threats-target-maricopa-county-board-ofsupervisors.
338. Washington Post, “The Arizona election official who faced death threats for telling the truth,” YouTube, at 0:21, Nov. 2, 2021, available at https://www.youtube.com/watch?v=6gAc47ivjYk.
339. Genesis Sandoval, “Hickman: A Year after 2020 Elections, Threats, Abuse Still Coming In,” Cronkite News Arizona PBS, (Nov. 2, 2021), available at https://cronkitenews.azpbs.org/2021/11/02/hickman-a-year-after-2020-elections-threats-abuse-still-coming-in/.
340. United States Senate Committee on the Judiciary, Hearing on Protecting our Democracy’s Frontline Workers (Aug. 3, 2022), Written testimony by Jocelyn Benson, available at https://www.judiciary.senate.gov/imo/media/doc/Testimony%20-%20Benson.pdf; Michigan Department of State, “Statement from Secretary of State Jocelyn Benson Concerning Threats against Her and Her Family,” (Dec. 6, 2020), available at https://www.michigan.gov/sos/Resources/News/2020/12/06/statement-from-secretary-of-state-jocelyn-bensonconcerning-threats-against-her-and-her-family; Select Committee to Investigate the January 6th Attack on the United States Capitol, Transcribed Interview of Jocelyn Benson, (June 2, 2022), pp. 35-39.
341. Michigan Department of State, “Statement from Secretary of State Jocelyn Benson Concerning Threats against Her and Her Family, (Dec. 6, 2020), available at https://www.michigan.gov/sos/Resources/News/2020/12/06/statement-from-secretary-of-statejocelyn-benson-concerning-threats-against-her-and-her-family; Select Committee to Investigate the January 6th Attack on the United States Capitol, Transcribed Interview of Jocelyn Benson (June 2, 2022), pp. 35-39.
342. Isaac Dovere and Jeremy Herb, “‘It’s Absolutely Getting Worse’: Secretaries of State Targeted by Trump Election Lies Live in Fear for their Safety and are Desperate for Protection,” CNN, (Oct. 26, 2021), available at https://www.cnn.com/2021/10/26/politics/secretaries-of-state-personal-threats-trump-election-lies/index.html.
343. Select Committee to Investigate the January 6th Attack on the United States Capitol, Informal Interview of Aaron Van Langevelde and Adrianne Van Langevelde, (Oct. 21, 2021); Tim Alberta, “The Inside Story of Michigan’s Fake Voter Fraud Scandal,” Politico, (Nov. 24, 2020), available at https://www.politico.com/news/magazine/2020/11/24/michigan-electiontrump-voter-fraud-democracy-440475; Rod Meloni and Natasha Dado, “Michigan AG Launches Investigation into Threats against Canvassers,” Click on Detroit, (Nov. 24, 2020), available at https://www.clickondetroit.com/news/local/2020/11/24/michigan-aglaunches-investigation-into-threats-against-canvassers/.
344. Select Committee to Investigate the January 6th Attack on the United States Capitol, Informal Interview of Aaron Van Langevelde, (Oct. 21, 2021).
345. Trey Grayson, Matthew Masterson, Orion Danjuma, and Ben Berwick, “State and Local Solutions Are Integral to Protect Election Officials and Democracy,” Just Security, (Feb. 9, 2022), available at https://www.justsecurity.org/80142/state-and-local-solutions-are-integral-toprotect-election-officials-and-democracy/; Stanford Internet Observatory, “Tina Barton – Aftermath – Death Threats,” YouTube, (Sept. 20, 2021), available at https://www.youtube.com/watch?v=Xi5Y7bwvy-Y.
346. Melissa Nann Burke and George Hunter, “‘I Feel Afraid’: Detroit Clerk Winfrey Testifies to U.S. House Panel on Death Threats She Received,” Detroit News, (July 28, 2021), available at https://www.detroitnews.com/story/news/politics/2021/07/28/winfrey-testifies-beforehouse-panel-threats-election-workers/5400419001/.
347. Linda So and Jason Szep, “Campaign of Fear: U.S. Election Workers Get Little Help from Law Enforcement as Terror Threats Mount,” Reuters, (Sept. 8, 2021), available at https://www.reuters.com/investigates/special-report/usa-election-threats-law-enforcement/.

348. Dave Boucher, “Black Michigan Lawmaker Posts Voicemails Saying She Should be Lynched,” Detroit Free Press, (Dec. 6, 2020), available at https://www.freep.com/story/news/politics/elections/2020/12/06/michigan-lawmaker-posts-voicemails-saying-she-should-lynched/3849695001/.
349. Dave Boucher, “Black Michigan Lawmaker Posts Voicemails Saying She Should be Lynched,” Detroit Free Press, (Dec. 6, 2020), available at https://www.freep.com/story/news/politics/elections/2020/12/06/michigan-lawmaker-posts-voicemails-saying-she-should-lynched/3849695001/.
350. Kayla Clarke, “Man faces felony charges for bomb threat at Michigan Capitol Building, threats against state representative,” Click on Detroit, (Jan. 8, 2021), available at https://www.clickondetroit.com/news/local/2021/01/08/man-faces-felony-charges-for-bombthreat-at-michigan-capitol-building-threats-against-state-representative/ (linking to affidavit).
351. Isaac Dovere and Jeremy Herb, “‘It’s Absolutely Getting Worse’: Secretaries of State Targeted by Trump Election Lies Live in Fear for their Safety and are Desperate for Protection,” CNN, (Oct. 26, 2021), available at https://www.cnn.com/2021/10/26/politics/secretaries-of-state-personal-threats-trump-election-lies/index.html; see also Select Committee to Investigate the January 6th Attack on the United States Capitol, Informal Interview of Kathy Boockvar, (Dec. 22, 2021).
352. Linda So and Jason Szep, “Campaign of Fear: U.S. Election Workers Get Little Help from Law Enforcement as Terror Threats Mount,” Reuters, (Sept. 8, 2021), available at https://www.reuters.com/investigates/special-report/usa-election-threats-law-enforcement/.
353. Isaac Dovere and Jeremy Herb, “‘It’s Absolutely Getting Worse’: Secretaries of State Targeted by Trump Election Lies Live in Fear for their Safety and are Desperate for Protection,” CNN, (Oct. 26, 2021), available at https://www.cnn.com/2021/10/26/politics/secretaries-of-state-personal-threats-trump-election-lies/index.html.
354. Select Committee to Investigate the January 6th Attack on the United States Capitol, Transcribed Interview of Bryan Cutler, (May 31, 2022), pp. 83-84.
355. Geoff Rushton, “Police Investigating Threat Made During State College Borough Council Meeting,” StateCollege.com, (Dec. 8, 2020), available at https://www.statecollege.com/police-investigating-threat-made-during-state-college-borough-council-meeting/.
356. Jan Murphy, “Meet Pa. Senate GOP Leader Kim Ward, the First Woman to Hold That Post: ‘I Have To Do a Good Job’, PennLive.com, (Jan. 26, 2021), https://www.pennlive.com/news/2021/01/meet-pa-senate-gop-leader-kim-ward-the-first-woman-to-hold-that-post-i-haveto-do-a-good-job.html.
357. Matt Petrillo, “‘We’re Coming after You’: Philadelphia Elections Officials Still Receiving Death Threats Following 2020 Presidential Election,” CBS Philly 3, (Nov. 1, 2021), available at https://philadelphia.cbslocal.com/2021/11/01/philadelphia-election-officials-death-threatdonald-trump-joe-biden/; Linda So and Jason Szep, “Campaign of Fear: U.S. Election Workers Get Little Help from Law Enforcement as Terror Threats Mount,” Reuters, (Sept. 8, 2021), available at https://www.reuters.com/investigates/special-report/usa-election-threatslaw-enforcement/.
358. Linda So and Jason Szep, “Special Report: Terrorized U.S. Election Workers Get Little Help from Law Enforcement,” Reuters, (Sept. 8, 2021), available at https://www.reuters.com/legal/government/terrorized-us-election-workers-get-little-help-law-enforcement-2021-0908/.
359. 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 2:10:00 to 2:11:00, available at https://www.youtube.com/watch?v=xa43_z_82Og.

360. Linda So, “Special Report: Trump-Inspired Death Threats are Terrorizing Election Workers,” Reuters, (June 11, 2021), available at https://www.reuters.com/article/us-usa-trumpgeorgia-threats-special-rep/special-report-trump-inspired-death-threats-are-terrorizingelection-workers-idUSKCN2DN14M.
361. 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 2:10:00 to 2:11:00, available at https://www.youtube.com/watch?v=xa43_z_82Og; Linda So, “Special Report: Trump-Inspired Death Threats are Terrorizing Election Workers,” Reuters, (June 11, 2021), available at https://www.reuters.com/article/us-usa-trump-georgia-threats-specialrep/special-report-trump-inspired-death-threats-are-terrorizing-election-workersidUSKCN2DN14M.
362. Jeff Pegues and Robert Legare, “Texas Man Charged with Making Election-Related Threats to Georgia Government Officials,” CBS News, (Jan. 21, 2022), available at https://www.cbsnews.com/news/chad-christopher-stark-charged-election-related-threats-georgiagovernment-officials/.
363. Linda So, “Special Report: Trump-Inspired Death Threats are Terrorizing Election Workers,” Reuters, (June 11, 2021), available at https://www.reuters.com/article/us-usa-trumpgeorgia-threats-special-rep/special-report-trump-inspired-death-threats-are-terrorizingelection-workers-idUSKCN2DN14M.
364. Linda So, “Special Report: Trump-Inspired Death Threats are Terrorizing Election Workers,” Reuters, (June 11, 2021), available at https://www.reuters.com/article/us-usa-trumpgeorgia-threats-special-rep/special-report-trump-inspired-death-threats-are-terrorizingelection-workers-idUSKCN2DN14M.
365. Linda So, “Special Report: Trump-Inspired Death Threats are Terrorizing Election Workers,” Reuters (June 11, 2021), available at https://www.reuters.com/article/us-usa-trumpgeorgia-threats-special-rep/special-report-trump-inspired-death-threats-are-terrorizingelection-workers-idUSKCN2DN14M.
366. GA House Mobile Streaming, “Governmental Affairs 12.10.20,” Vimeo – Livestream, at 2:09:00-2:13:00, available at https://livestream.com/accounts/25225474/events/9117221/videos/214677184; 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.
367. 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-georgiarally-transcript-before-senate-runoff-elections-december-5; 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/.
368. Brad Raffensperger, Integrity Counts (New York: Simon & Schuster, 2021), p. 191 (reproducing the call transcript); Amy Gardner and Paulina Firozi,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/trumpraffensperger-call-transcript-georgia-vote/2021/01/03/2768e0cc-4ddd-11eb-83e3322644d82356_story.html (the Washington Post redacted Freeman’s name and instead used “[name]” in the transcript); “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-trump-georgia-phone-call-transcript-bradraffensperger-recording.
369. 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/.

370. Freeman v. Giuliani, No. 21-cv-03354-BAH (D.D.C. filed May 10, 2022), ECF No. 22 (Amended Complaint at 52), available at https://www.courtlistener.com/docket/61642105/22/freeman-v-herring-networks-inc.
371. 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/.
372. 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/.
373. 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.
374. 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.
375. Select Committee to Investigate the January 6th Attack on the United States Capitol, Transcribed Interview of Ruby Freeman, (May 31, 2022), pp. 7-8.
376. Select Committee to Investigate the January 6th Attack on the United States Capitol, Transcribed Interview of Ruby Freeman, (May 31, 2022), pp. 7-8.
377. Government’s Motion Regarding Anticipated Trial Evidence and Notice Pursuant to Federal Rule of Evidence 404(b) at 1-2, 24-26, United States v. Rhodes, et al., No. 1:22-cr-15 (D.D.C. July 8, 2022), ECF No. 187; Brandi Buchman (@Brandi_Buchman), Twitter, Oct. 6, 2022 7:27 a.m. ET, available at https://twitter.com/Brandi_Buchman/status/1577983997711421441.
378. Hannah Rabinowitz and Holmes Lybrand, “Judge Says Oath Keepers Jury Won’t See ‘Death List’,” CNN (Oct. 6, 2022), https://www.cnn.com/2022/10/06/politics/judge-says-oathkeepers-jury-wont-see-death-list-trial-day-3.

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Georgia Electors cast their Electoral College votes at the Georgia State Capitol on December 14, 2020.

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