# United States of America v. Donald J. Trump - Government's Motion for Immunity Determinations/Section 1C

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​C. The Defendant Aimed Deceit at the Targeted States to Alter Their Ascertainment and Appointment of Electors
Shortly after election day, the defendant began to target the electoral process at the state level by attempting to deceive state officials and to prevent or overturn the legitimate ascertainment and appointment of Biden’s electors. As President, the defendant had no official responsibilities related to the states’ administration of the election or the appointment of their electors, and instead contacted state officials in his capacity as a candidate. Tellingly, the defendant contacted only state officials who were in his political party and were his political supporters, and only in states he had lost. The defendant’s attempts to use deceit to target the states’ electoral process played out in Arizona, Georgia, Michigan, Nevada, Pennsylvania, and Wisconsin, as well as across these and other states that used certain voting machines. In addition to the following evidence of the defendant’s conduct during the charged conspiracies, at trial the Government will elicit testimony from election officials from the targeted states to establish the objective falsity—and often, impossibility—of the defendant’s fraud claims. Notably, although these election officials would have been the best sources of information to determine whether there was any merit to specific allegations of election fraud in their states, the defendant never contacted any of them to ask.
    1. Arizona
The defendant was on notice that there was no evidence of widespread election fraud in Arizona within a week of the election. On November 9, for instance, two days after news networks projected that Biden had won, the defendant called Arizona Governor P16 to ask him what was happening at the state level with the presidential vote count in Arizona. At that point, though Fox News had projected that Biden had won the state, several other news outlets—including ABC, NBC, CNN, and the New York Times—had not yet made a projection. P16 walked the defendant through the margins and the votes remaining to be counted, which were primarily from Pima County, which favored Biden, and Maricopa County, which was split. P16 described the situation to the defendant as "the ninth inning, two outs, and [the defendant] was several runs down." The defendant also raised claims of election fraud, and P16 asked the defendant to send him supporting evidence. Although the defendant said he would—stating, "we're packaging it up"—he never did. Shortly thereafter, on November 13, Campaign Manager P2 told the defendant directly that a false fraud claim that had been circulating—that a ​substantial number of non-citizens had voted in Arizona—was false. The same day, as noted previously, Campaign attorneys conceded in court that the remaining election lawsuit in Arizona was moot.
The defendant and CC1 continued to try to influence P16 For example, CC1 tried to contact P16 on November 22—the same day the defendant and CC1 reached out to the Arizona Speaker of the House, as described below. And on November 30, the day P16 signed the Arizona certificate of ascertainment formally declaring Biden's electors as the legitimate electors for Arizona, P16 received a call from the defendant and Pence. P16 advised them that Arizona had certified the election; when the defendant brought up fraud claims, P16 —eager to see the evidence—again asked the defendant to provide it, but the defendant never did. Instead, later that evening and into the following morning, the defendant repeatedly and publicly attacked P16 (as well as Georgia Governor P17 ) on Twitter, re-tweeting posts by others, such as "Who needs Democrats when you have Republicans like P17 and P16 "Watching the Arizona hearings and then watching Gov. P16 sign those papers, why bother voting for Republicans if what you get is P16 and P17; " P17 'My state ran the most corrupt election in American history.' P16 'Hold my beer,'"; and "Why is P16 still pretending he's a member of the Republican Party after he just certified fraudulent election results in Arizona that disenfranchised millions of Republicans?"
​The defendant and co-conspirators also attempted to use false fraud claims to convince political allies in the Arizona state legislature to ignore the popular vote and appoint illegitimate electors. On November 22, CC1 called P18 the Speaker of the Arizona House of Representatives. CC1 did most of the talking. During the call, the defendant and CC1 levied multiple false fraud claims—including of non-citizen, non-resident, and dead voters that affected the defendant's race—and asked P18 to use them as a basis to call the state legislature into session to replace Arizona's legitimate electors with illegitimate ones for the defendant. When P18 voiced his deep skepticism, CC1 said, "well, you know, we're all kind of Republicans and we need to be working together." P18 refused, and asked CC1 to provide evidence supporting his fraud claims. CC1 never did.
Indeed, CC1 met with P18 in person approximately a week later and still had nothing to back up his claims. On November 30, CC1 P12 and others arrived in Arizona for a "hotel hearing"—an unofficial meeting with Republican legislators—during which they promoted false fraud allegations. In a meeting the day after the hearing, when state legislators pressed CC1 and P12 for evidence to support their claims, CC1 conceded that even on that late date, "[w]e don't have the evidence, but we have lots of theories." When the legislators were frustrated that CC1 had no support for his claims and asked him tough questions, CC1 expressed surprise at the way he was being treated, stating, "Man, I thought we were all ​Republicans . . . . [T]his is a little more hostile a reception. I'm amazed at the reception I'm getting here."
On December 4, P18 released a public statement in which he explained that he did not have the authority to use the legislature "to reverse the results of the election" and that doing so would constitute an attempt "to nullify the people's vote based on unsupported theories of fraud." P18 made clear that he was disappointed with the legitimate election results because he "voted for President Trump and worked hard to reelect him" but would not "violate current law to change the outcome of a certified election." On Twitter, P19 a Campaign staffer who worked with CC6 attacked P18 for his statement, writing that P18 "is intentionally misleading the people of Arizona to avoid the inevitable." The defendant re-tweeted P19 false post and praised her.
A month later, just two days before January 6, CC2 —another of the defendant's private attorneys and a co-conspirator—called P18 and P18 counsel, P20 and urged P18 one last time to use the legislature to decertify Arizona's legitimate electors and overturn the valid election results. When P18 told CC2 that there was no evidence of substantial fraud in Arizona, and that he could not legally call the legislature into session, CC2 was undeterred. He conceded that he "[didn't] know enough about the facts on the ground" regarding ​fraud in Arizona, and said that P18 should nonetheless falsely claim that he had the authority to convene the legislature and "let the courts sort it out." P18 again refused.
In the post-election period, P18 was harassed; on several occasions, individuals gathered outside P18 home with bullhorns and screamed and honked their vehicle horns to create noise. Once, an individual in visible possession of a pistol and wearing a t-shirt in support of a militia group came onto P18 property and screamed at him. At the time of these events, P18 daughter was at home and was very ill, and the noise caused her "disruption and angst."
    2. Georgia
The defendant had early notice that his claims of election fraud in Georgia were false. Around mid-November, Campaign advisor P4 told the defendant that his claim that a large number of dead people had voted in Georgia was false. The defendant continued to press the claim anyway, including in a press appearance on November 29, when he suggested that a large enough number of dead voters had cast ballots to change the outcome of the election in Georgia.
Four days later, on December 3, CC1 orchestrated a presentation to a Judiciary Subcommittee of the Georgia State Senate. In the morning in advance of it, CC1 had spoken to the defendant on the phone for almost twenty minutes. And at the hearing, CC1 arranged for co-conspirators and agents to repeat the false dead voter claim. The claim was so patently false ​that everyone around the defendant knew it: during the hearing, Chief of Staff P21 and P9 exchanged text messages on their personal phones confirming that a Campaign attorney, P22 had verified that CC1 claim of more than 10,000 dead voters was false and that the actual number was around 12 and could not be outcome-determinative.
During the subcommittee hearing, the conspirators also set in motion a sensational and dangerous lie about election workers at State Farm Arena that would result in the defendant's supporters harassing and threatening those workers. First, P23 one of the defendant's privat attorneys, claimed that more than 10,000 dead people had voted in Georgia. Next, P24 an agent of the defendant, played misleading exerpts of closed-circuit camera footage from State Farm Arena and insinuated that it showed election workers committing misconduct—counting "suitcases" of illegal ballots. Lastly, based on the false fraud allegations, CC2 who had already been engaged as a private lawyer for the defendant but did not disclose that at the hearing—encouraged the Georgia legislators to decertify the state's legitimate electors.
While the hearing was ongoing, the defendant simultaneously amplified the misinformation about the State Farm Arena election workers, falsely tweeting, "Wow! Blockbuster testimony taking place right now in Georgia. Ballot stuffing by Dems when Republicans were forced to leave the large counting room. Plenty more coming, but this alone ​leads to an easy win of the State!" He did this just after re-tweeting two of his Campaign account's Tweets that promoted the false claim about election workers at State Farm Arena.
Over the next week, the claim of misconduct at State Farm Arena was disproven publicly as well as directly to the defendant. The day after the hearing, P25 the Chief Operating Officer of the Georgia Secretary of State's Office, posted a Tweet explaining that Secretary of State officers had watched the video in its entirety and confirmed that it showed "normal ballot processing." P18 again forcefully debunked the conspirators' claim about the State Farm video in a press conference on December 7, explaining at length the election workers' innocent conduct depicted in the closed-circuit camera footage and stating:
And what's really frustrating is the President's attorneys had this same videotape. they saw the exact same things the rest of us could see. And they chose to mislead state senators and public about what was on that video. I'm quite sure that they will not characterize the video if they try to enter it into evidence because that's the kind of thing that could lead to sanctions because it is obviously untrue. They knew it was untrue and they continue to do things like this.
On December 8, the defendant called Georgia Attorney General P26 P26 had advance notice that the topic of the call was Texas v. Pennsylvania, an election lawsuit in which Texas was suing other states—including Georgia—to attempt to prevent the certification of the election. U.S. Senator P27 told P26 that the defendant had heard that P26 was "whipping," or lobbying, other state attorneys general against filing amicus briefs in support of ​Texas. P26 was not lobbying against the suit, and told P27 so; P27 asked P26 if he would speak with the defendant about it, and P26 agreed. Shortly thereafter, the defendant called P26 and immediately raised Texas v. Pennsylvania, saying, "I hope you're not talking to your AGs and encouraging them not to get on the lawsuit." P26 told the defendant that he was not affirmatively calling other state attorneys general, but that if they called him, he was telling them what he was seeing in his state—which was something that the defendant probably did not want to hear: P26 was just not seeing evidence of fraud in Georgia. The defendant nonetheless raised various fraud claims. P26 told him that state authorities had investigated the State Farm Arena allegations and found no wrongdoing, and that he thought another claim the defendant raised about Coffee County, Georgia, had been similarly resolved, but would check. The defendant asked P26 to look at them again "because we're running out of time." P26 tried to steer the call to an end by thanking the defendant and telling him that he had voted for him twice and appreciated the defendant, to which the defendant responded, "Yeah, I did a hell of a job, didn't I?" At one point, the defendant raised with P26 the impending run-off election for Georgia's U.S. Senate seats and how important it was to re-elect P27 and P28 The day after the call, the defendant—in his private capacity as a candidate for president—intervened in support of Texas v. Pennsylvania; his attorney for that matter was CC2 <ref>Mot. to Intervene, Texas v. Pennsylvania, No. 22-O-155 (S. Ct. Dec. 9, 2020).
​On the same day as the defendant's call with P26 the defendant's Campaign staff acknowledged that the State Farm Arena claim was unsupported, emailing one another about the fact that television networks may decline to run Campaign advertisements promoting it. In frustration regarding the claim and others like it, P4 —who spoke with the defendant on a daily basis and had informed him on multiple occasions that various fraud claims were false—wrote, "When our research and campaign legal team can't back up any of the claims made by our Elite Strike Force Legal Team, you can see why we're 0-32 on our cases. I'll obviously hustle to help on all fronts, but it's tough to own any of this when it's all just conspiracy shit beamed down from the mothership."
On December 10, however, CC1 further perpetuated the false State Farm Arena claim when he appeared at another hearing, this one before the Georgia House of Representatives' Government Affairs Committee. During it, he displayed some of the same footage as had been used in the December 3 hearing that had been debunked in the interim by Georgia officials, and nonetheless claimed that it showed "voter fraud right in front of people's eyes." He then named two election workers— P29 and her mother, P30 —and baselessly accused them of "quite obviously surreptitiously passing around USB ports as if they are vials of heroin or cocaine," and then suggested that they were criminals whose "places of work, their homes, should have been searched for evidence of ballots, for evidence of USB ports, for evidence of voter fraud." As these false claims about P30 and P29 spread, the women were barraged by racist death threats. In the years since, they have spoken about the effect of the defendant and coconspirators' lies about about them; as P30 explained in an interview with congressional ​investigators, "when someone as powerful as the President of the United States eggs on a mob, that mob will come. They came for us with their cruelty, their threats, their racism, and their hats. They haven't stopped even today." Indeed, to this day, the defendant has never stopped falsely attacking P30 and P29 Although none of the false claims against them were ever corroborated, the defendant has continued to levy them on social media, including when the defendant attacked P30 in January 2023 just after her testimony to congressional investigators was made public.
Throughout the post-election period, the defendant used Twitter to publicly attack Georgia Governor P17 with particular aggression. In the thirty-five days between November 30, 2020, and January 3, 2021, the defendant tweeted critically about P17 by name or title, more than forty times. These tweets included the ones also attacking P16 described anove, as well as others particular to P17 like, "Why won't Governor @ P17 the hapless Governor of Georgia, use his emergency powers, which can be easily done, to overrule his obstinate Secretary of State, and do a match of signatures on envelopes. It will be a 'goldmine' of fraud, and we will easily WIN the state"; "I will easily & quickly win Georgia if Governor @ P17 or the Secretary of State permit a simple signature verification. Has not been done and will show large scale discrepancies. Why are these two 'Republicans' saying no? If we win Georgia, everything else falls in place!"; "The Republican Governor of Georgia Refuses to do signature verification, which would give us an easy win. What's wrong with this guy? What is he ​hiding?"; and "How does Governor @ P17 allow certification of votes without verifying signatures and despite the recently released tape of ballots being stuffed? His poll numbers have dropped like a rock. He is finished as governor!"
In the post-election period, the defendant also made false claims in court about fraud in Georgia—unsuccessfully. For example, in Trump v. Kemp, a federal lawsuit in which the defendant sued Georgia's Governor and Secretary of State, the defendant signed a verification of fraud allegations that he and his attorney on the case, CC2 knew was inaccurate. P9 spoke with the defendant and CC2 and another private attorney, P31 that they could not have the defendant sign it because they could not verify any of the facts. And P9 told the defendant that any lawyer that signed the complaint that the verification supported would get disbarred. CC2 acknowledged this problem in an email on December 31 to P32 lead counsel for the defendant as candidate in Trump v. Kemp, and another private attorney, writing that in the time since the defendant signed a previous verification in the case, he "had been made aware that some of the allegations (and evidence proffered by the experts) has been inaccurate" and that signing a new affirmation "with that knowledge (and incorporation by reference) would not be accurate." Nonetheless, on December 31, the defendant signed the verification, and CC2 caused it to be filed.
​On January 2, Georgia Secretary of State P33 appeared on Fox News and said that various rumors of election fraud were false, and the defendant had lost in Georgia:
Our office has been very busy with what I call the rumor whack-a-mole. Every day, a rumor will pop up and then we whack it down. What we do is, we basically whack it down with the truth. And people can't handle the truth sometimes because they're very disappointed in the results. And I get that. I voted for President Trump also, but at the end of the day, we did everything we could. We did an audit of the race; President Trump still lost. Then we did a full recount; President Trump still lost…we had a safe, secure process.
P33 like P17 had been on the receiving end of the defendant's Tweets. These included: "Why isn't the @GASecofState P33 a so-called Republican, allowing us to look at signatures on envelopes for verification? We will find tens of thousands of fraudulent and illegal votes"; "RINOS @ P17 @ P34 & Secretary of State P33 will be solely responsible for the potential loss of our two GREAT Senators from Georgia, @ P27 & @ P28 Won't call a Special Session or check for Signature Verification! People are ANGRY!;" and "Georgia, where is signature verification approval? What do you have to lose? Must move quickly! @ P17 @ P34 @GaSecofState."
Shortly after seeing the interview, the defendant set up a call with P33 to discuss his pending private lawsuit, Trump v. Kemp, in which P33 was a named defendant. For this reason, P33 at first hoped to avoid speaking with the defendant but ultimately ​acquiesced because the defendant was persistent in seeking to set it up. Also because of the pending lawsuit, P33 arranged for his general counsel, P35 to participate. Joining the defendant on the call were Chief of Staff P21 and three private attorneys— P32 and P36 counsel of record in Trump v. Kemp and the attorneys whom CC2 had emailed about the defendant's false verification and P31 whom P21 introduced on the call as someone "who is not the attorney of record but has been involved."
The defendant began the call with an animated monologue in which he argued that he had won the election in Georgia, saying, "Okay, thank you very much P33 and P35 and everybody. We appreciate the time and the call. So we've spent a lot of time on this, and if we could just go over some of the numbers, I think it's pretty clear that we won. We won very substantially, uh, Georgia." Throughout the call, the defendant continued to state that he had won and referenced Biden's margin of victory that he needed to overcome to prevail in the state, including by asserting that "I just want to find 11,780 votes." He did not reference other elections on the same ballot. After the defendant's opening salvo, P33 stated, "Well, I listened to what the President has just said. President Trump, we've had several lawsuits, and we've had to respond in court to the lawsuits and the contentions. We don't agree that you have won."
The defendant raised multiple false claims of election fraud, each of which P33 refuted in turn. When the defendant attacked P30 called her "a professional vote scammer ​and hustler." and mentioned her dozens of times throughout the call, P33 said, "You're talking about the State Farm video. And I think it's extremely unfortunate that CC1 or his people, they sliced and diced that video and took it out of context." He then offered the defendant a link to a video disproving the claim, to which the defendant responded, "I don't care about a link, I don't need it. I have a much, P33 I have a much better link." When the defendant claimed that 5,000 dead people had voted in Georgia, P33 said, "Well, Mr. President, the challenge you have is the data you have is wrong . . . The actual number were two. Two. Two people that were dead that voted. And so that's wrong, that was two. When the defendant claimed that thousands of out-of-state voters had cast ballots, P33 counsel, P35 responded, "We've been going through each of those as well, and those numbers that we got, that Ms. P31 was just saying, they're not accurate."
At one point, the defendant became frustrated after both P33 and P35 explained repeatedly that his claims had been investigated and were not true and stated, "And you're gonna to find that they are—which is totally illegal—it's, it's, it's more illegal for you than it is for them because, you know what they did and you're not reporting it. That's a criminal, you know, that's a criminal offense. And you know, you can't let that happen. That's a big risk to you and to P35 your lawyer. That's a big risk." The call ended with P35 stating that he ​would coordinate with the lawyer representing the P33 office in the private lawsuit together with P32 as agreed earlier in the call.
The day after the call, on January 3, the defendant falsely tweeted, "I spoke to Secretary of State P33 yesterday about Fulton County and voter fraud in Georgia. He was unwilling, or unable, to answer questions such as the 'ballots under the table' scam, ballot destruction, out of state 'voters', dead voters, and more. He has no clue!" P33 promptly responded in a Tweet of his own: "Respectfully, President Trump: What you're saying is not true. The truth will come out."
    3. Michigan
On November 20, three days before Michigan's Governor signed a certificate of ascertainment appointing Biden's electors based on the popular vote, the defendant met with P37 and P38 Michigan's Senate Majority Leader and Speaker of the House, at the Oval Office. The defendant initiated the meeting by asking RNC Chairwoman P39 to reach out to P38 and gauge his receptivity to a meeting. The defendant also asked P39 to participate in the meeting, but P39 told him that she had consulted with her attorney and that she could not be involved in a meeting with legislators because it could be perceived as lobbying. After P39 made the first contact, on November 18, the defendant reached out to P37 and P38 to extend an invitation. The same day that he contacted ​ P37 and P38 the defendant issued a false Tweet: "In Detroit, there are FAR MORE VOTES THAN PEOPLE. Nothing can be done to cure that giant scam. I win Michigan!"
When the defendant called P37 and P38 to invite them to the White House, he did not provide the topic of the meeting, but he did ask about allegations of fraud in the election in Michigan. The legislators told him that they and the Michigan legislature were examining the allegations. Both P37 and P38 assumed that the defendant wanted to see them to discuss claims of election fraud, and they wanted to be firm that they had not seen evidence that would change the outcome of the election.
Over the course of the meeting, the defendant dialed in both P39 —despite her request not to participate—and CC1 P21 was present for some, but not all, of the meeting. After some small talk with the legislators in the Oval Office, the defendant raised various fraud claims, including that he had lost Michigan because of fraud or misconduct in Wayne County, where Detroit is located. P37 corrected the defendant and told him that he had lost primarily because in two routinely Republican counties, the defendant had underperformed with educated ​females, and if he had received the same number of votes where as the two winning local sheriffs, he likely would have won Michigan. P37 could tell by the defendant's body language that he was not happy to hear P37 assessment. Notably, the defendant only raised fraud claims to the extent that they affected the outcome in his own race, not those for other offices in Michigan.
CC1 participation came after the legislators assured the defendant that they were looking into fraud claims; the defendant dialed CC1 into the meeting and said, " CC2 tell them what's going on." CC2 then launched into a fraud monologue. Finally, P37 interrupted and asked, "So when are you going to file a lawsuit in Michigan?"—a question that CC1 ignored and did not answer.
Immediately after the meeting, P37 and P38 released a public statement in which they stated that they had "not yet been made aware of any information that would change the outcome of the election in Michigan."
On November 21, the defendant acknowledged P37 and P38 statement when he tweeted, "This is true, but much different than reported by the media" and implicitly conceded that he had not provided evidence of fraud yet when he added "We will show them massive and unprecedented fraud!" Days later, the defendant's Campaign ​declined to request a state-wide recount in Michigan, for which it would have had to pay unless the recount succeeded in changing the outcome of the election.
Despite failing to establish any valid fraud claims, CC1 followed up with P37 and P38 and attempted to pressure them to use the Michigan legislature to overturn the valid election results. On December 4, CC1 sent a message to P38 claiming that Georgia was poised to do so (based on CC1 and CC3 false advocacy there in the December 3 hearing) and asked P38 for help: "Looks like Georgia may well hold some factual hearings and change the certification under ArtII sec 1 cl 2 of the Constitution. As CC2 explained they don't just have the right to do it but the obligation. . . .Help me get this done in Michigan." On December 7, CC1 attempted to send P37 a message (though failed because he typed the wrong number into his phone): "So I need you to pass a joint resolution from the Michigan legislature that states that, * the election is in dispute, * there's an ongoing investigation by the Legislature, and * the Electors sent by Governor Whitmer are not the official Electors of the State of Michigan and do not fall within the Safe Harbor deadline of Dec 8 under Michigan law." Campaign operative P5 was involved in the drafting of this message with the assistance of P41 who was associated with the defendant's Campaign efforts in Michigan. The following day, CC1 shared the draft with the defendant, sending it to his executive assistant, P42 by email.
​These efforts failed. On December 14, the day that duly-appointed electors across the country met and cast their electoral votes, P37 and P38 issued public statements confirming that the defendant had lost Michigan and the legislators still had not received evidence of outcome-determinative fraud in their state. P37 public statement included, "[W]e have not recieved evidence of fraud on a scale that would change the outcome of the election in Michigan. P38 stated, in part:
We've diligently examined these reports of fraud to the best of our ability. . .I fought hard for President Trump. Nobody wanted him to win more than me. I think he's done an incredible job. But I love our republic, too. I can't fathom risking our norms, traditions and institutions to pass a resolution retroactively changing the electors for Trump, simply because some think there may have been enough widespread fraud to give him the win. That's unprecedented for good reason. And that's why there is not enough support in the House to cast a new slate of electors. I fear we'd lose our country forever. This truly would bring mutually assured destructed for every future election in regards to the Electoral College. And I can't stand for that. I won't.
On January 3, the defendant's Campaign publicly posted P37 phone number, and attempted to post P38 (but erred by one digit), in a Tweet urging, "Contact Speaker P38 & Senate Majority Leader P37 !" P37 recieved four thousand text messages in two hours, forcing him to get a new phone number.
    4. Nevada
On November 17, in Law v. Whitmer, agents of the defendant in Nevada filed suit, claiming "substantial irregularities, improprieties, and fraud" in the presidential election, including based ​on machines used in ballot signature matching and votes by non-resident and dead voters. The defendant approved a press conference by his surrogates announcing the suit.
On November 19, P43 sent an email to P44 an RNC spokesperson, warning about inaccuracies in the suit: "Just FYI that I don't believe the claims in the contest regarding dead voters, those voting from out-of-state, etc. are substantiated. We are working with the campaign on a data matching project and those numbers are going to be a lot lower than what the NV people have come up with. They are also targeting our military voters. To be frank, the contest has little chance of succeeding. Happy to discuss this stuff if you want more info. P44 then sent a copy of P43 email from her personal email account to the personal email account of P45 one of the defendant's White House staffers who also volunteered for the Campaign.
Notwithstanding the RNC Chief Counsel's warning, the defendant re-tweeted and amplified news of the lawsuit on November 24, calling it "Big News!" that a Nevada Court had agreed to hear it. But the defendant did not similarly promote the fact that within two weeks, on December 4, the Nevada District Court dismissed Law v. Whitmer, finding in a detailed opinion that "there is no credible or reliable evidence that the 2020 General Election in Nevada was affected by fraud," including through the signature-match machines, and that Biden won the election in the state. Four days later, on December 8, Nevada's Supreme Court unanimously ​affirmed the District Court's decision, noting that despite its "earlier order asking appellants to identify specific findings with which they take issue, appellants have not pointed to any unsupported factual findings, and we have identified none." Later, in his Elipse speech on January 6, the defendant repeated multiple claims explicitly rejected by Nevada courts.
On December 18, the Nevada Secretary of State's Office released a "Facts vs. Myths" document to combat disinformation that the defendant and others were propagating about the election, including false claims that the Secretary of State's Office had not investigated claims of fraud even though it had "been presented with evidence of wide-spread fraud"—to which the Office responded, "While we are pursuing action in a number of isolated cases, we have yet to see any evidence of wide-spread fraud." The "Facts vs. Myths" document also stated publicly that courts had universally rejected fraud claims: "Four separate cases were heard by Nevada judges including the NV Supreme Court. After examining records presented, each case was discounted due to a lack of evidence."
    5. Pennsylvania
Two days after the election, on November 6, the defendant called P46 the Chairman of the Pennsylvania Republican Party—the entity responsible for supporting Republican ​candidates in the commonwealth at the federal, state, and local level.  P46 had a prior relationship with the defendant, including having represented him in litigation in Pennsylvania after the 2016 presidential election. The defendant asked P46 how, without fraud, he had gone from winning Pennsylvania on election day to trailing in the days afterward. Consistent with what Campaign staff already had told the defendant, P46 confirmed that it was not fraud; it was that there were roughly 1,750,000 mail-in ballots still being counted in Pennsylvania, which were expected to be eighty percent for Biden. Over the following two months, the defendant spread false claims of fraud in Pennsylvania anyway.
In early November, in a Campaign meeting, when the defendant suggested that more people in Pennsylvania voted than had checked in to vote, Deputy Campaign Manager P3 corrected him. Around the same time, Philadelphia City Commissioner P47 appeared on television and stated that there was no evidence of widespread fraud in Philadelphia. After seeing the interview, the defendant targeted P47 tweeting, "A guy named P47 a Philadelphia Commissioner and so-called Republican (RINO), is being used big time by the Fake News Media to explain how honest things were with respect to the Election in Philadelphia. He refuses to look at a mountain of corruption & dishonesty. We win!" As a result of the defendant's attack, threats that P47 already was receiving became more targeted and detailed—and included his address and the names of his family members.
​On the defendant's behalf, CC1 too spread patently false claims about Pennsylvania. On November 25, CC1 and P12 attended an unofficial hearing with Republican state legislators in a Gettysburg hotel conference room. The defendant called in, claimed to have been watching, and demanded that the election in Pennsylvania "has to be turned around." During the event, CC1 falsely stated that Pennsylvania issued 1.8 million absentee ballots and received 2.5 million in return. The claim was rooted in an obvious error—the comparison of the number of ballots sent out in the primary election to the number of ballots received in the general election. After seeing CC1 make this claim, P43 the RNC's Chief Counsel, tweeted publicly, "This is not true." In the following days, Campaign staff internally confirmed that CC1 was lying; when one Campaign staffer wrote in an email that CC1 claim was "just wrong" and "[t]here's no way to defend it," P3 responded, "We have been saying this for a while. It's very frustrating." Likewise, in late November or December, P9 informed the defendant directly that a claim CC1 was spreading, that "Pennsylvania received 700,000 more mail-in ballots than were mailed out," was "bullshit" and explained the error.
P43 followed up on his public Tweet in a private email on November 28 to P44 the RNC spokesperson, expressing his concern about CC1 and P12 spread of disinformation: "I'm really not trying to give you a hard time but what CC1 and P12 are doing is a joke and they are getting laughed out of court. It's setting us back in our fight for election integrity and ​they are misleading millions of people who have wishful thinking that the president is going to somehow win this thing." When CC1 learned of P43 Tweet and email, on November 28, he called P43 and left a threatening voicemail, stating, "I really do not need an explanation for what you said today because if there isn't a good one, you should resign. Got it? So call me or I'll call the boss and get you to resign. Call me. It'd be better for you if you do." CC1 also contacted RNC Chairwoman P39 to demand that P43 be fired, and thereafter P43 was relieved of his duties as RNC Chief Counsel.
On December 3, four Republican leaders of the Pennsylvania legislature issued a public letter stating that the General Assembly lacked the authority to overturn the popular vote and appoint its own slate of electors, and that doing so would violate the state Election Code and Constitution. P48 —an agent of the defendant who worked closely with CC1 —issued a Tweet showing the four legislators' names and signatures and wrote, "These are the four cowardice Pennsylvania legislators that intend to allow the Democrat machine to #StealtheVote! #Cowards #Liars #Traitors" while linking to the legislators' Twitter accounts. On Sunday December 6, at 12:56 a.m., from the White House residence—having just returned from a political rally in Valdosta, Georgia—the defendant re-tweeted and amplified P48 post.
    6. Wisconsin
On November 29, a recount that the defendant's Campaign had petitioned and paid for confirmed that Biden had won in Wisconsin—and increased the defendant's margin of defeat. On December 14, the Wisconsin Supreme Court rejected the Campaign's election lawsuit there. As a result, on December 21, Wisconsin's Governor signed a certificate of final determination confirming the prior certificate of ascertainment that established Biden's electors as the valid electors for the state.
In response, the defendant issued a series of Tweets attacking P49 the Wisconsin Supreme Court Justice who had written the majority opinion rejecting his Campaign's lawsuit and advocating that the Wisconsin legislature overturn the valid election results:
Two years ago, the great people of Wisconsin asked me to endorse a man named P49 for State Supreme Court Justice, when he was getting destroyed in the Polls against a tough Democrat Candidate who had no chance of losing. After my endorsement, P49 easily won! WOW, he just voted against me in a Big Court Decision on voter fraud (of which there was much!), despite many pages of dissent from three highly respected Justices. One thing has nothing to do with another, but we ended up losing 4-3 in a really incorrect ruling! Great Republicans in Wisconsin should take these 3 strong decisions to their State Legislators and overturn this ridiculous State Election. We won in a LANDSLIDE!"
After the defendant's Tweet, the state marshals responsible for P49 safety arranged to provide P49 with additional police protection based on social media traffic and other threatening communications.
    7. Voting Machines in Multiple States
Throughout the post-election period, the defendant and co-conspirators repeatedly made claims about the security and accuracy of voting machines across multiple states, despite the fact that they were on notice that the claims were false. As early as November 12, for instance, the National Association of Secretaries of State, the National Association of State Election Directors, and other coordinated federal, state, and private entities issued a public statement declaring that the 2020 election was "the most secure in American history" and that there was "no evidence that any voting system deleted or lost votes, changed votes, or was in any way compromised."
On November 14, in the Tweet announcing that CC1 was to lead his Campaign legal efforts, the defendant also named CC3 a private attorney who was fixated on voting machine claims, and P10 another private attorney. Two days later, on November 16, on the defendant's behalf, executive assistant P42 sent CC3 and other private attorneys an email, titled "From POTUS," attaching a document containing bullet points critical of C3 a company that manufactured voting machines used in certain states, and writing, "See attached—Please include as is, or almost as is, in lawsuit." CC3 responded nine minutes later, writing, "IT MUST GO IN ALL SUITS IN GA AND PA IMMEDIATELY WITH A FRAUD CLAIM THAT REQUIRES THE ENTIRE ELECTION TO BE SET ASIDE in those states and machines impounded for non-partisan professional inspection."
On November 17, P50 the director of the Department of Homeland Security's Cybersecurity and Infrastructure Security Agency (CISA), publicly tweeted that a group of private ​election security experts concluded that claims of computer-based election fraud "either have been unsubstantiated or are technically incoherent."
Two days later, on November 19, CC1 CC3 P10 and others held a press conference at the RNC headquarters, on behalf of the defendant and his Campaign. During it, CC3 made false and factually impossible claims regarding C9 and the integrity of the country's election infrastructure. That night, Fox News television personality C51 stated on air that because of CC3 incendiary comments about voting machines, he had invited her on his television program. He further stated, "[b]ut she never sent us any evidence, despite a lot of requests, polite requests. Not a page. When we kept pressing, she got angry and told us to stop contacting her. When we checked with others around the Trump Campaign, people in positions of authority, they told us CC3 has never given them any evidence either. . .she never demonstrated that a single actual vote was moved illegitimately by software from one candidate to another. Not one."
The defendant saw his private attorneys' RNC press conference and P51 discussion of CC3 and he acknowledged to P4 and CC3 had appeared "unhinged" in the press conference. On November 20, the day after the press conference, the defendant made a similar comment to P7 and P45 two White House staffers who also volunteered for his Campaign. In casual conversation after another meeting had ended, the defendant told P7 ​and P45 that P51 had "eviscerated" or "destroyed" CC3 The defendant then had a call with CC3 on speakerphone, while P7 and P45 listened in, and mentioned the P51 segment to CC3 While CC3 responded, the defendant placed the call on mute and to P7 and P45 mocked and laughed at CC3 called her claims "crazy," and made a reference to the science fiction series Star Trek while describing her allegations. In the same time period, when P9 told the defendant that CC3 claims were unreliable and should not be included in lawsuits, the defendant agreed that he had not seen anything to substantiate CC3 allegations.
On November 22, notwithstanding the defendant's Tweet from eight days prior announcing CC3 involvement, CC1 issued a statement on behalf of the Campaign distancing the defendant from CC3 " CC3 is practicing law on her own. She is not a member of the Trump Legal Team. She is also not a lawyer for the President in his personal capacity." Nonetheless, the defendant continued to support and publicize CC3 knowingly false claims. For example, within days of CC1 statement, the defendant promoted a lawsuit that CC3 was about to file, tweeting on November 24, "BREAKING NEWS: @ CC3 says her lawsuit in Georgia could be filed as soon as tomorrow and says there's no way there was anything but widespread election fraud. #MAGA #AmericaFirst #Dobbs." CC3 filed a lawsuit the next day against the Governor of Georgia falsely alleging "massive election fraud" accomplished ​through C3 election software and hardware. The defendant again promoted the lawsuit in a Tweet. The lawsuit was dismissed within two weeks, on December 7.
On November 29, P50 who was no longer the CISA Director, appeared on the television program 60 Minutes. P50 stated that he was confident that the election had been secure and "that there was no manipulation of the vote on the machine count side." In response, the defendant tweeted publicly about P50 appearance: "@60Minutes never asked us for a comment about their ridiculous, one sided story on election security, which is an international joke. Our 2020 Election, from poorly rated C3 to a Country FLOODED with unaccounted for Mail-In ballots, was probably our least secure EVER!" A few days later, P10 appeared on a radio program as the defendant's agent and said that because of P50 comments to promote confidence in the security of the election infrastructure, CC1 "should be drawn and quartered. Taken out at dawn and shot." Thereafter, P50 was subjected to death threats. In a press conference on December 1 that the defendant acknowledged watching, P25 a Georgia election official, decried P10 and the defendant's public statements spreading disinformation and said that if they did not stop, "someone is going to get killed."
​On December 1, Attorney General P52 stated publicly that the Justice Department had not seen evidence of fraud sufficient to change the election results. With respect to voting machines, he said, "There's been one assertion that would be systemic fraud and that would be the claim that machines were programmed essentially to skew the election results. And the DHS and DOJ have looked into that, and so far, we haven't seen anything to substantiate that." CC1 and P12 immediately issued a formal Campaign statement attacking P52 and the Justice Department, writing, "With all due respect to the Attorney General, there hasn't been any semblance of a Department of Justice Investigation. . .his opinion appears to be without any knowledge or investigation of the substantial irregularities and evidence of systemic fraud."
In mid-December, the defendant spoke with RNC Chairwoman P39 and asked her to publicize and promote a private report that had been released on December 13 that purported to identify flaws in the use of C3 machines in Antrim Country, Michigan. P39 refused, telling the defendant that she already had discussed the report with P38 Michigan's Speaker of the House, who had told her that the report was inaccurate. P39 conveyed to the defendant P38 exact assessment: the report was "fucking nuts."
On January 2, during the defendant's call with Georgia Secretary of State P33 said of false claims regarding voting machines, "I don't believe that you're really questioning the C3 machines. Because we did a hand re-tally, a 100 percent re-tally of all the ballots, and compared them to what the machines said and came up with virtually the same ​result. Then we did the recount, and we got virtually the same result. So I guess we can probably take that off the table." In response, the defendant falsely claimed that "in other states, we think we found tremendous corruption with C3 machines, but we'll have to see."
At the Ellipse on January 5, the defendant and co-conspirators who spoke at the rally continued to make unsubstantiated and false claims about C3 machines. CC1 claimed that in the U.S. Senate run-off election in Georgia the day before, "the votes were deliberately changed by the same algorithm that was used in cheating President Trump and Vice President Pence." CC2 continued the false attack: "We now know because we caught it live last time in real time, how the machines contributed to that fraud. . . .They put those ballots in a secret folder in the machines sitting there waiting, until they know how many they need. And then the machine after the close of polls, we now know who's voted. And we know who hasn't. And I can now in that machine match those unvoted ballots with an unvoted voter and put them together in the machine. . . .We saw it happen in real time last night and it happened on November 3rd as well." In his own speech, the defendant again raised the false specter of "the highly troubling matter of C3 and lied about machines flipping votes from the defendant to Biden and an "astronomical and astounding" error rate in the machines' ballot scanning.
* ↑ GA 656-658 ( ); GA 727 ( ).
* ↑ See, e.g., Democrats flip Arizona as Biden, Kelly score key election wins, Fox News, Nov. 3, 2020, available at https://www.foxnews.com/video/6206934979001; Dan Merica, Biden carries Arizona, flipping a longtime Republican stronghold, CNN.com, Nov. 13, 2020, available at https://www.cnn.com/2020/11/12/politics/biden-wins-arizona/index.html; Luis Ferré-Sadurni et al., Biden flips Arizona, further cementing his presidential victory, N.Y. Times, Nov. 12, 2020, available at https://www.nytimes.com/2020/11/12/us/biden-wins-arizona.html; Election Latest: Biden Projected Winner in Arizona, NBC 4 New York, Nov. 12, 2020, available at https://www.nbcnewyork.com/news/politics/decision-2020/election-latest-biden-talks-to-world-leaders-about-virus/2718671/.
* ↑ GA 667 ( ).
* ↑ Id.
* ↑ GA 657 ( ).
* ↑ Id.
* ↑ GA 603-608 ( ).
* ↑ GA 661 ( ).
* ↑ GA 658 ( ).
* ↑ GA 658, GA 667-668 ( ).
* ↑ GA 840 (Trump Twitter Archive 11/30/2020).
* ↑ GA 833-834 (Donald J. Trump Tweet 11/30/2020).
* ↑ GA 831-832 (Donald J. Trump Tweet 11/30/2020).
* ↑ GA 839 (Trump Twitter Archive 12/01/2020).
* ↑ GA 735 ( ); GA 21-22 ( ).
* ↑ See GA 30 ( ).
* ↑ GA 22-24 ( ).
* ↑ GA 28 ( ).
* ↑ GA 22-33 ( ).
* ↑ GA 25 ( ).
* ↑ GA 1906 at 56:19 (Video of Arizona Hotel Hearing 11/30/2020).
* ↑ GA 36 ( ).
* ↑ GA 35 ( ).
* ↑ GA 1041-1042 ( Statement 12/04/2020).
* ↑ GA 1042 ( Statement 12/04/2020).
* ↑ GA 854-855 (Donald J. Trump Tweet 12/06/2020); GA 852-853 (Donald J. Trump Tweet 12/06/2020).
* ↑ GA 37-44 ( ); GA 408-409 ( ).
* ↑ GA 1144 ( ); GA 39 ( ).
* ↑ GA 41-42 ( ).
* ↑ GA 45-47 ( ).
* ↑ GA 46-47 ( ).
* ↑ GA 47 ( ).
* ↑ GA 388-390 ( ).
* ↑ GA 1969 at 22:43—23:51 (Video of Trump Interview with Maria Bartiromo 11/29/2020).
* ↑ GA 1934 (Video of Georgia Senate Judiciary Subcommittee Hearing 12/03/2020).
* ↑ GA 739 at 1 ( ).
* ↑ ECF No. 226 ¶ 26(a); GA 1146 ( ); see also GA 364-365 ( ).
* ↑ GA 1934 at 30:54 (Video of Georgia State Judiciary Subcommittee Hearing 12/03/2020); GA 1146 ( ).
* ↑ GA 1934 at 34:06 (Video of Georgia Senate Judiciary Subcommittee Hearing 12/03/2020); ECF No. 226 ¶ 26(b).
* ↑ GA 1934 at 4:44:05 (Video of Georgia Senate Judiciary Subcommittee Hearing 12/03/2020).
* ↑ GA 846-847 (Donald J. Trump Tweet 12/03/2020).
* ↑ GA 845, GA 1893 (Donald J. Trump Tweet 12/03/2020); GA 844, GA 1894 (Donald J. Trump Tweet 12/03/2020).
* ↑ GA 848 ( P25 Tweet 12/04/2020).
* ↑ GA 1933 at 8:43 (Video of Georgia Secretary of State Press Conference 12/07/2020).
* ↑ GA 742 ( ).
* ↑ GA 61-62 ( ).
* ↑ GA 62 ( ).
* ↑ GA 61-62 ( ).
* ↑ GA 64 ( ).
* ↑ Id.
* ↑ GA 65-66 ( ).
* ↑ GA 66 ( ).
* ↑ GA 67 ( ).
* ↑ Id.
* ↑ GA 1147 ( ).
* ↑ GA 1932 at 1:37:18-1:48:33 (Video of Georgia House Committee Hearing 12/10/2020).
* ↑ GA 1932 at 1:57:10-1:58:00 (Video of Georgia House Committee Hearing 12/10/2020).
* ↑ GA 171 ( ).
* ↑ GA 966 (Donald J. Trump Truth Social Post 01/03/2023); GA 964 (Donald J. Trump Truth Social Post 01/02/2023); GA 965 (Donald J. Trump Truth Social Post 01/03/2023).
* ↑ GA 829-830 (Donald J. Trump Tweet 11/30/2020).
* ↑ GA 850-851 (Donald J. Trump Tweet 12/05/2020).
* ↑ GA 857, GA 859 (Donald J. Trump Tweet 12/07/2020).
* ↑ GA 864 (Donald J. Trump Tweet 12/10/2020).
* ↑ GA 238-239 ( ).
* ↑ GA 239 ( ).
* ↑ GA 1152 ( ).
* ↑ Complaint at 33-34, Trump v. Kemp, No. 1:20-cv-5310 (N.D. Ga. Dec. 31, 2020), ECF No. 1.
* ↑ GA 1949 at 3:22 (Video of P33 Interview with Cavuto 01/02/2021).
* ↑ GA 813-814 (Donald J. Trump Tweet 11/24/2020); GA 862-863 (Donald J. Trump Tweet 12/08/2020); GA 865-866 (Donald J. Trump Tweet 12/11/2020).
* ↑ GA 367-368 ( ).  ); Complaint at 33-34, Trump v. Kemp, No. 1:20-cv-5310 (N.D. Ga. Dec. 31, 2020), ECF No. 1.
* ↑ GA 514 ( ).
* ↑ GA 514-515 ( ).
* ↑ GA 1154 (Tr. of P33 Call 01/02/2021).
* ↑ GA 1165 (Tr. of P33 Call 01/02/2021).
* ↑ GA 1157 (Tr. of P33 Call 01/02/2021).
* ↑ GA 1155 (Tr. of P33 Call 01/02/2021).
* ↑ GA 1160 (Tr. of P33 Call 01/02/2021).
* ↑ GA 1161 (Tr. of P33 Call 01/02/2021).
* ↑ GA 1159 (Tr. of P33 Call 01/02/2021).
* ↑ GA 1162 (Tr. of P33 Call 01/02/2021).
* ↑ GA 1165 (Tr. of P33 Call 01/02/2021).
* ↑ GA 1172-1173 (Tr. of P33 Call 01/02/2021).
* ↑ GA 919-920 (Donald J. Trump Tweet 01/03/2021).
* ↑ GA 925 ( P33 Tweet 01/03/2021).
* ↑ GA 555-557, 565 ( ); GA 15 ( ).
* ↑ GA 70-71 ( ).
* ↑ GA 330-337 ( ).
* ↑ GA 556-557 ( ).
* ↑ GA 797-798 (Donald J. Trump Tweet 11/18/2020).
* ↑ GA 556-557 ( ).
* ↑ GA 558 ( ).
* ↑ GA 74-78 ( ).
* ↑ GA 330-337 ( ); GA 82 ( ); GA 560-561 ( ).
* ↑ GA 361-362 ( ).
* ↑ GA 562-564 ( ).
* ↑ GA 564 ( ).
* ↑ GA 563-565 ( ).
* ↑ GA 560-571 ( ); GA 70-94 ( ).
* ↑ GA 575 ( ); GA 567-569 ( ).
* ↑ GA 569 ( ); GA 575 ( ).
* ↑ GA 1040 ( Joint Statement 11/20/2020); GA 94-95 ( ).
* ↑ GA 799-800 (Donald J. Trump Tweet 11/21/2020).
* ↑ GA 49-53 ( ); GA 15-19 ( ).
* ↑ GA 1175 ( ).
* ↑ GA 1177 ( ); GA 1178-1187 ( ).
* ↑ GA 1188 ( ).
* ↑ GA 1189 ( ).
* ↑ GA 1190-1192 ( Press Releases 12/14/2020).
* ↑ GA 1191 ( Press Releases 12/14/2020).
* ↑ GA 1192 ( Press Releases 12/14/2020).
* ↑ GA 917 (Team Trump Tweet 01/03/2021); GA 918 (Team Trump Tweet 01/03/2021).
* ↑ GA 573-574, 576-577 ( ).
* ↑ Complaint at 1, Law v. Whitmer, No. 20OC001631B (Nev. Dist. Ct. Nov. 17, 2020) available at: https://electioncases.osu.edu/wp-content/uploads/2020/11/Law-v-Gloria-Complaint.pdf; GA 1963 (Video of Trump Campaign Press Conference 11/17/2020).
* ↑ GA 1193-1194 ( ).
* ↑ GA 1195 ( ).
* ↑ GA 1196-1197, 1195 ( ).
* ↑ GA 817-818 (Donald J. Trump Tweet 11/24/2020).
* ↑ Order at 13-24, 28-34, Law v. Whitmer, No. 20OC001631B (Nev. Dist. Ct. Dec. 4, 2020) available at: https://electioncases.osu.edu/wp-content/uploads/2020/11/Law-v-Gloria-Order-Granting-Motion-to-Dismiss.pdf.
* ↑ Law v. Whitmer, 136 Nev. 840 (Nev. 2020).
* ↑ Compare Order at 18-20, Law v. Whitmer, No. 20OC001631B (Nev. Dist. Ct. Dec. 4, 2020) available at https://electioncases.osu.edu/wp-content/uploads/2020/11/Law-v-Gloria-Order-Granting-Motion-to-Dismiss.pdf (finding no support for claims of double ballots, non-resident, and deceased voters) with GA 1134-1135 (Ellipse Rally Speech Draft Tr. 01/06/2021) ("there were also more than 42,000 double votes in Nevada"; "1,500 ballots were cast by individuals whose names and dates of birth match Nevada residents who died in 2020 prior to November 3rd election. More than 8,000 votes were cast by individuals who had no address and probably didn't live there.").
* ↑ GA 1198 (Nevada Facts vs. Myths 12/18/2020).
* ↑ GA 1199 (Nevada Facts vs. Myths 12/18/2020).
* ↑ GA 618-619 ( ); GA 723-724 ( ).
* ↑ GA 616-617 ( ).
* ↑ GA 619-620 ( ).
* ↑ GA 620 ( ).
* ↑ GA 159 ( ).
* ↑ GA 1953 at 2:20-4:13 (Video of P47 Interview with CNN 11/11/2020).
* ↑ GA 777-778 (Donald J. Trump Tweet 11/11/2020).
* ↑ GA 550-551 ( ).
* ↑ GA 1945 (Video of Pennsylvania Hotel Hearing 11/25/2020).
* ↑ GA 1945 at 2:06:23-2:07:23 (Video of Pennsylvania Hotel Hearing 11/25/2020).
* ↑ GA 1945 at 2:21:30-2:21:53 (Video of Pennsylvania Hotel Hearing 11/25/2020).
* ↑ GA 819 ( P43 Tweet 11/25/2020).
* ↑ GA 1203-1206 ( ).
* ↑ GA 721 ( ); GA 1207-1208 ( ).
* ↑ GA 1209 ( ).
* ↑ GA 1976 ( ).
* ↑ GA 1210-1214 ( ); GA 11215 ( ); GA 342-346 ( ).
* ↑ GA 1222-1223 (Letter from Pennsylvania Legislators 12/03/2020); GA 173 ( ).
* ↑ GA 849 ( Tweet 12/04/2020).
* ↑ GA 856, 858 (Donald J. Trump Tweet 12/06/2020).
* ↑ GA 1224-1225 (Wisconsin Order for Recount 11/19/2020); GA 1226 (Wisconsin Statement of Canvass 11/30/2020); Trump v. Biden, 394 Wis. 2d 629, 633 (Wis. 2020)
* ↑ Trump v. Biden, 394 Wis. 2d 629, 633 (Wis. 2020).
* ↑ GA 1235 (Wisconsin Certificate of Ascertainment 11/03/2020).
* ↑ GA 875, GA 876, GA 877, GA 880, GA 879, and GA 878 (Donald J. Trump Tweets 12/21/2020).
* ↑ GA 184-186, GA 188-189 ( ).
* ↑ GA 1236 (Election Security Joint Statement 11/12/2020)
* ↑ GA 784-785 (Donald J. Trump Tweet 11/14/2020).
* ↑ GA 1238-1239 ( ).
* ↑ GA 1240 ( ).
* ↑ GA 790 (P50 Tweet 11/17/2020).
* ↑ GA 1950 (Video of RNC Press Conference 11/19/2020).
* ↑ GA 1950 at 38:58-52:34 (Video of RNC Press Conference 11/19/2020).
* ↑ GA 1972 at 9:18-10:02 (Video of P51 Show 11/19/2020).
* ↑ GA 391-392 ( ).
* ↑ GA 248-249 ( ); GA 528 ( )
* ↑ GA 258-259 ( ).
* ↑ GA 256-259 ( ).
* ↑ GA 258-260 ( ).
* ↑ GA 206 ( ).
* ↑ GA 1241 (Trump Campaign Statement 11/22/2020).
* ↑ GA 815-816 (Donald J. Trump Tweet 11/24/2020).
* ↑ Complaint at 2, Pearson v. Kemp, No. 1:20-cv-4809 (N.D. Ga. Nov. 25, 2020), ECF No. 1.
* ↑ GA 820-821 (Donald J. Trump Tweet 11/26/2020)
* ↑ Transcript of Mots. Hr'g at 41-44, Pearson v. Kemp, (N.D. Ga. Dec. 7, 2020), ECF No. 79.
* ↑ GA 1940 (Video of P50 on 60 Minutes 11/29/2020).
* ↑ GA 1940 at 4:14-4:19 (Video of P50 on 60 Minutes 11/29/2020).
* ↑ GA 825-826 (Donald J. Trump Tweet 11/29/2020).
* ↑ GA 1887 (Audio of P10 on 11/30/2020).
* ↑ GA 295-296 ( ).
* ↑ GA 841-842 (Donald J. Trump Tweet 12/01/2020).
* ↑ GA 1961 at 3:23-3:55 (Video of P25 Press Conference 12/01/2020).
* ↑ GA 12-13 ( ).
* ↑ GA 1242-1243 (Email from Comms Alert 12/01/2020).
* ↑ GA 1244 (Trump Campaign Press Release 12/01/2020).
* ↑ GA 338-339 ( ).
* ↑ GA 338-339 ( ).
* ↑ Id.
* ↑ GA 1889 at 15:58-16:27 (Audio of Trump- P33 Call on 01/02/2021).
* ↑ GA 1889 at 16:32-17:26 (Audio of Trump- P33 Call on 01/02/2021).
* ↑ GA 1928 at 2:22:41-2:23:07 (Video of Ellipse Rally 01/06/2021).
* ↑ GA 1928 at 2:25:25-22:26:56 (Video of Ellipse Rally 01/06/2021).
* ↑ GA 1136 (Elipse Rally Speech Draft Tr. 01/06/2021).