Page:CTRL0000034608 - Deposition of John Eastman, (Dec. 9, 2021).pdf/14

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A Fifth.

Q Dr. Eastman, do you know who drafted that document?

A Fifth.

Q Dr. Eastman, did you draft any certificates of electoral votes for any other States?

A Fifth.

  Okay. I think Mr. Raskin may have a question.

Mr. Raskin. Yes. Thank you.

I wanted to ask Dr. Eastman whether he's asserting the Fifth just with respect to the actions he took on January 6th and days leading up or whether he is asserting the Fifth with respect to the ideas that he has promoted about the electoral college.

Mr. Burnham. I beg the Congressman's pardon. As I mentioned to   a moment ago, I've instructed my client that he should claim the Fifth not only in response to questions about the subject matter of the subpoena, but also as to questions about the basis for the Fifth Amendment, as doing so would defeat the protection of the Fifth Amendment itself.

But to help, as best as I can, I suspect that most of the questions asked under the heading of the general subject matters that were just offered would probably result in an invocation.

I hope that's helpful.

Mr. Raskin. I appreciate that. But I'm not asking with respect to the basis for his invocation of the Fifth. I'm asking for which questions he will answer and which not.

Will he answer questions with respect to the substantive content of his ideas about the Vice President and the electoral college?

Mr. Burnham. I've advised him not to answer such questions on Fifth