Page:CTRL0000034608 - Deposition of John Eastman, (Dec. 9, 2021).pdf/23

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A Fifth.

Q Dr. Eastman, to whom did you give this memo?

A Fifth.

Q Dr. Eastman, the first sentence of the memo starts off by saying, "7 States have transmitted dual slates of electors to the President of the Senate."

Is that statement in this memo true?

A Fifth.

Q Dr. Eastman, at the bottom of page 1 this memorandum states, "So here's the scenario we propose."

Dr. Eastman, who is the "we" you were -- who is the "we" that the author of this memo referred to?

A Fifth.

Q Dr. Eastman, on the next page there are six numbered paragraphs. The one that starts with third reads, quote, "At the end, he announces that because of the ongoing dispute in the 7 States, there are no electors that can be deemed validly appointed in those States," close quote, and so President Trump would have a majority of the electors counted, and, quote, "Pence then gavels President Trump as re-elected," close quote.

Dr. Eastman, did you advise the President of the United States that the Vice President could reject electors from seven States and declare that the President had been re-elected?

A Fifth.

Q In the paragraph starting with -- paragraph No. 4, it starts with, "Howls, of course" -- you describe that the Vice President could declare that no candidate received a majority of the electoral votes and, therefore, the election would go to the House of