Strongest Evidence of Guilt: A Chart Tracking Trump’s Knowledge and Intent in Efforts to Overturn the Election

By Ryan Goodman, Justin Hendrix and Clara Apt

Just Security, July 11, 2022

The January 6th House Select Committee has produced substantial evidence about former President Donald
Trump’s knowledge and beliefs as he tried to overturn the 2020 election. This body of evidence carries potentially
great legal (and moral) weight. That’s because several of Trump’s actions would amount to criminal (and morally
outrageous) conduct if he acted with particular forms of knowledge and intent.

The Chart below presents key factual findings - concerning evidence of Trump’s knowledge and beliefs when trying
to overturn the election - based primarily on the Committee’s work to date.

Since before the hearings began, public commentary has focused, in large part, on whether Trump knew he had
lost the election. That quandary is irrelevant to the criminal intent required for several of the most relevant federal
and state crimes. It is an important yet limited way to think of the evidence of knowledge and intent that
prosecutors could rely upon in bringing charges.

The following list highlights just some of the information presented in the Chart below.

● Lying about victory on Election Night (Nov 3-Nov. 4 early AM)

● Manufacturing false allegations of election fraud (December 3, 2020-early January, 2021)

● Trying to force Department of Justice officials to lie about the department’s findings of election fraud (late
December, 2020 - Jan. 3, 2021)

● Advancing false claims of election fraud after being told by senior DOJ and campaign officials of
irrefutable flaws in the claims (Dec. 2020 - Jan. 6, 2021).

● Lying about communications with federal and state officials in efforts to pressure them (Jan. 2-Jan. 6,
2021)

The Chart contains several more entries describing related actions, knowledge, and beliefs.

The Chart is not exhaustive. For example, it does not address Trump’s state of knowledge about the legal duties of
the vice president on January 6. It does not address Trump’s knowledge and direction of the false slates of
electors. And it does not address Trump’s knowledge that some of his supporters were armed when he directed
them to the Capitol and his endorsement of their actions in private communications in the Oval Office. This
evidence – and the use of political violence in particular – may directly inform how one views other parts of the
record, that is, of an individual who was willing to support almost any means possible to overturn the election.
What follows is a body of evidence that very clearly shows other aspects of Trump’s knowledge and beliefs,
aspects of the record which have not received this level of documentation or the attention they deserve.

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TABLE OF CONTENTS

1. Lies about DOJ investigations

2. Lies about Pence’s agreement on legal authority
3. Lies about phone call with Georgia Secretary of State Brad Raffensperger
4. Red Mirage 1.0 - Falsely claims victory on Election Night
5. Red Mirage 2.0 - False claims of third party validators on Election Night
6. Absence of actual evidence of fraud - Trump legal team
7. Manufacturing conspiracy: Fulton County State Farm Arena “suitcases”
8. Willful blindness/disinterest in actual evidence
9. Claims of more votes than voters in Philadelphia
10. Dominion allegations
11. Undocumented immigrants voting in Arizona

Chart: President Trump’s Knowledge and Intent in Efforts to Overturn the Election

1. Lies about DOJ investigations

What Trump Knew What Trump Said/Did

Topline: Trump knew that the DOJ had taken Topline: Trump initially says publicly that DOJ is
extraordinary action to investigate allegations of fraud
“missing in action” and Attorney General William Barr
but found no evidence of widespread fraud. Trump
repeatedly expresses his dismay in private “hasn’t looked” into allegations of fraud (this is false
communications with DOJ officials. at the time, and Trump knows it is false). Trump later
pushes DOJ officials to say the department has found
the election to be “corrupt” and to send a letter to
Georgia and other states that says DOJ has found
significant evidence of widespread fraud (he knows
that DOJ has not) and encourages those states to
decertify on that basis.

The record is replete with examples. Here are some Phase 1 - Denial of DOJ investigation
highlights:
Nov. 29, 2020: Fox News interview:
Nov. 23, 2020: Barr meets with Trump. The A.G. tells
Trump he has expanded DOJ and FBI authority to
investigate credible allegations (see his unprecedented BARTIROMO: Where is the DOJ and the FBI in all of this,
Nov. 9 memorandum), but DOJ has not found credible Mr. President? You have laid out some serious charges
allegations of fraud. here. Shouldn't this be something that the FBI is
investigating? Are they?
Barr testifies: “I said … our role is to investigate fraud.
And if – and we’ll look at something if it’s – if it’s TRUMP (talks before question ends): Missing in action.
specific, credible, and could have affected the outcome
of the election. And – and we’re doing that, and it’s just BARTIROMO: Is the DOJ investigating?
not – they’re not – they’re just not meritorious.”

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Aside: Betrayal: The Final Act of the Trump Show, by TRUMP: Missing in action. I can't tell you where they
Jonathan Karl, p. 192-93 reporting: are. I ask are they looking at it. Everyone says yes they
are looking at it. … I know FBI and FBI is great at the
“‘Mr. President, if we get specific and credible levels that we talk about. But it is inconceivable. You
information of fraud, we will go out and look at it,’ Barr would think if you are the FBI or Department of
responded, reminding him of the controversial directive Justice this is, this is the biggest thing they could be
he had issued giving US attorneys the green light to looking at. I have not seen anything. They just keep
investigate credible allegations of election fraud. ‘I have moving along and go onto the next president.”
overruled people at DOJ to give us that latitude. I’m ________________________
going to use my judgment as to what we’re going to look
at.’ Dec. 3, 2020: Trump response to reporter’s question:

[White House Chief of Staff] Meadows didn’t say much REPORTER: President, can I ask you to respond to the
at this meeting, but [White House Counsel] Cipollone comments by your Attorney General, who indicated he
backed up Barr. ‘Mr. President, let the department do its has not seen, at this point, any evidence of fraud,
work,’ the White House counsel said. ‘If there’s enough to overturn the election results? Given that,
something to look at, I’m sure they’re going to look at it.’ why is now not the time to concede?
…
As for the allegations of fraud, Barr told Trump he fully TRUMP: Well, he hasn't done anything, so he hasn't
expected the Justice Department to come under attack looked. When he looks, he'll see the kind of evidence
for not uncovering evidence. ‘You have to expect that all that right now, you're seeing in the Georgia Senate.
you’re going to be hearing from Giuliani and the rest of They're going through hearings right now in Georgia,
these people is that Justice isn’t looking at stuff,’ Barr and they're finding tremendous volumes. So they
said. ‘They’re out there promising fraud and they’re haven't looked very hard, which is a disappointment,
empty-handed. And now people need an explanation of to be honest with you because it's massive fraud,
why is there no evidence. Well, their answer is, ‘Justice whether you go to Wisconsin, where we just filed a
isn’t looking at it.’ But the problem isn’t the absence of case, or Michigan or if you look at what's happening in
Justice, the problem is the absence of evidence.’” Georgia as an example, or Pennsylvania, if you look at
________________________ Nevada, which is moving along very rapidly or Arizona.
You saw those numbers come out yesterday. We found
Dec. 1, 2020: In Oval Office meeting with Trump, Barr massive fraud and in other states also. This is probably
goes allegation by allegation of fraud explaining why the most fraudulent election that anyone's ever seen.
each is bogus (Barr testimony hearing 1 and hearing 2; ________________________
Leonnig and Rucker book; Karl book).
________________________ Phase 2 - Pressure on DOJ to make false public
statement
Dec. 24, 2020: In a 15-20 minute phone conversation,
Trump calls Jeffrey Rosen on his first official day as Dec. 27, 2020: In a phone call with Rosen and
Acting Attorney General. Trump says that his view is Donoghue, Trump explicitly tells the DOJ leadership:
there was widespread election fraud. Rosen testifies: “I “Just say the election was corrupt and leave the rest
had told him that our reviews had not shown that to be to me and the Republican Congressmen” (Donoghue
the case.” testimony; Donoghue contemporaneous handwritten
________________________ notes).

Dec. 27, 2020: In a two-hour phone conversation with Describing the Dec. 27 meeting:
Trump, Rosen, former Acting Deputy Attorney General
Richard Donoghue, DOJ officials tell Trump they have REP. KINZINGER: Even though he had been told that

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conducted many investigations and found the allegations there was no evidence of fraud, did the President keep
meritless (Rosen testimony; Donoghue testimony; saying that the department was quote, "Obligated to
Donoghue contemporaneous hand-written notes). tell people that this was an illegal corrupt election."

Donoghue testimony: “It was incumbent on — on me to RICHARD DONOGHUE: That's also an exact quote from
make it very clear to the President what our the President. Yes.
investigations had revealed, and that we had concluded
based on actual investigations, actual witness interviews, After Rosen and Donoghue rebuff the president, Trump
actual reviews of documents that these allegations appears to threaten to fire the DOJ senior leader(s).
simply had no merit.” Donoghue’s notes read: “People tell me Jeff Clark is
________________________ great, I should put him in. People want me to replace
DOJ leadership” (see also testimony).
Dec. 23, 2020-Jan. 3, 2021: Trump complains DOJ has ________________________
not done enough.
Transcribed interview:
BENNIE THOMPSON: From the time you took over from
Attorney General Barr until January 3rd, how often did DONOGHUE: So he wanted us to say it was corrupt, you
President Trump contact you or the department to push know, for whatever reason. I'll leave that to him or
allegations of election fraud? others to explain or determine. But he wanted us to
say that it was corrupt. And this was consistent with
JEFFREY A. ROSEN: So between December 23rd and some things he said at other points about, the
January 3rd, the President either called me or met with Department should publicly say that the election is
me virtually every day with one or two exceptions like corrupt or suspect or not reliable. At one point, he
Christmas Day. mentioned the possibility of having a press conference.
… We told him we were not going to do that.
The common element of all of this was the President
expressing his dissatisfaction that the Justice Q: Yeah.
Department in his view had not done enough to
investigate election fraud. DONOGHUE: So this was something that was brought
________________________ up more than once.

Donoghue testfies: “As we got later in the month of Q: Yeah. So, again, there was a focus on public
December, the President's entreaties became more statements that something was corrupt, as opposed
urgent. He became more adamant that we weren't doing to trying specifically to get to the bottom of the
our job.” individual allegations.
________________________
DONOGHUE: Right.
Dec. 31, 2020: In a White House meeting with Rosen,
Donoghue, Cipollone, Meadows, and Patrick Philbin ________________________
(Rosen SJC testimony, p. 138; Donoghue testimony, p.
117), Trump expresses that DOJ “still haven’t found the Phase 3 - The “murder-suicide pact”
fraud” (Rosen SJC testimony, p. 139).
Dec. 28, 2020: Clark sends his “Proof of Concept” letter
to Rosen and Donoghue for them to sign. The first two
sentences of the draft letter read:

“The Department of Justice is investigating various

irregularities in the 2020 election for President of the
United States. The Department will update you as we
are able on investigatory progress, but at this time we
have identified significant concerns that may have
impacted the outcome of the election in multiple

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 States, including the State of Georgia.”

In writing, Donoghue replies, “there’s no chance that I

would sign this letter or anything like it” and that
there’s “nothing that would support the statement”
about the Department having found widespread
election fraud. In testimony, Donoghue stated:

“More importantly, this was not based on fact. This

was actually contrary to the facts as developed by
department investigations over the last several weeks
and months.”

On or after Dec. 28, 2020: Trump asks Rosen to sign

the letter (Rosen testimony)

Dec. 31, 2020: After expressing dismay that DOJ “still

haven’t found the fraud” (Rosen SJC testimony, p. 139),
Trump again threatens to fire Rosen and Donoghue.
Trump says that people have told him to “get rid of
both” of them and to “put Jeffrey Clark in” (Donoghue
SJC testimony, p. 118).

Dec. 31, 2020-Jan. 3, 2021: Trump and Clark threaten

to fire Rosen if he does not sign and send the letter
(Rosen SJC testimony, p. 144).

Jan. 3, 2021: Clark tells Rosen Trump has offered him

the job as attorney general and Clark has accepted
(Rosen SJC testimony; select committee testimony).
White House logs identify Clark as “Acting Attorney
General” by 4:22pm. Everyone understands, and it is
made explicit in the Oval Office meeting, that this
action is so Clark can send the letter as acting attorney
general.

At a 6:15pm Oval Office meeting that lasts for 2-3

hours, Trump ultimately backs down when faced with a
threat of mass resignations throughout the DOJ and
White House Counsel’s office.

Aside: In the Jan. 3 Oval Office meeting with Trump,

White House Counsel Pat Cipollone calls the letter a
“murder-suicide pact” (Steven Engle testimony;
Donoghue testimony). White House Counsel Eric
Herschmann tells Clark sending the letter would be “a
felony” (Herschmann testimony).

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 2. Lies about Pence’s agreement on legal authority

For weeks leading up to and including Jan. 6: In several communications with Trump, Pence is steadfast that as
President of the Senate he does not have the authority to reject electoral votes or otherwise suspend the electoral
count (Greg Jacob testimony (“never budged from the position”); Marc Short testimony (“was not wavering”);
Pence public statement on Feb 4, 2022).

Jan. 5, 2021: Trump releases a statement falsely saying, “The Vice President and I are in total agreement that the
Vice President has the power to act. … He can decertify the results or send them back to the states for change and
certification … He can also … send them to the House of Representatives.”:

Trump senior advisor Jason Miller testimony: “He dictated most of it. I mean, typically on these — typically on
these, I might have a couple of wording suggestions, or maybe I'd, you know, have a — a sense or a rough
framework or something of that. But I — I know with — specifically on this one that it was me and him on the
phone talking through it, and ultimately the way this came out was the way that he wanted to.”

Pence’s general counsel, Greg Jacob testimony: “We are shocked and disappointed because whoever had written
and put that statement out, it was categorically untrue.”

Pence’s chief of staff, Marc Short on call with Jason Miller testimony: “I was irritated and expressed displeasure
that a statement could have gone out that misrepresented the vice president's viewpoint without consultation.”

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3. Lies about phone call with Georgia Secretary of State Brad Raffensperger
about Raffensperger’s responses to fraud allegations

Jan. 2, 2021: Trump has a private phone call with Raffensperger, in which the Georgia Secretary of State and other
Georgia officials refute, point-by-point, Trump’s allegations of voter fraud.

Jan. 3, 2021: In a tweet, Trump makes false statements about the conversation:

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Jan. 3, 2021: Raffensperger releases a full audio recording of the phone call, and later publicly states that he has
done so because of Trump’s “false” statement about their private conversation.

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4. Red Mirage 1.0 - Falsely claims victory on Election Night

(including false statements about specific states and about what the head of the Fox News decision desk said)

What Trump Knew What Trump Said/Did

Topline: Closest aides informed Trump of the “red Topline: Using the red mirage, Trump declared victory
mirage” as they had in 2016, and they told him not to and made several related false statements.
declare victory.

Trump campaign manager Bill Stepien testimony: President Trump’s Election Night speech:

BILL STEPIEN: I recounted back to that conversation with “This is a fraud on the American public. This is an
him in which I said — just like I said in 2016 it was going embarrassment to our country. We were getting ready
to be a long night. I — I told him in 2020 that, you know, to win this election. Frankly, we did win this election.
there were — it was going to be a — a process again. We did win this election. … We want all voting to
As, you know, the early returns are going to be, you stop. We don’t want them to find any ballots at four
know, positive. Then we're gonna, you know, be o’clock in the morning and add them to the list.”
watching the returns of — of ballots as, you know, they
rolled in thereafter. “It’s also clear that we have won Georgia. We’re up by
2.5% or 117,000 votes with only 7% left. They’re never
Q: Isn't it fair to say you're trying to present a — a — going to catch us. They can’t catch us. Likewise we’ve
what you thought would be a realistic picture of what clearly won North Carolina.”
might happen over the course of that night, being
election night? “Most importantly, we’re winning Pennsylvania by a
tremendous amount of votes. … it’s going to be almost
BILL STEPIEN: That night in the days that followed. Yeah. impossible to catch. And we’re coming into good
I — I — I always — I always, you know, I always told the Pennsylvania areas where they happen to like your

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President the truth. And, you know I — I, you know, I president. So we’ll probably expand that.”
think he expected that from me. And I told him it was
going to be a process. It was going to be, you know — “We’re winning Michigan by — I’ll tell you, I looked at
you know, we're gonna have to wait and see how this the numbers, I said ‘Whoa,’ I said ‘Wow, that’s a lot’ —
turned out. So I — I — just like I did in 2016, I did the by almost 300,000 votes. And 65% of the vote is in.
same thing in 2020. And we’re winning Wisconsin. … So we won by
________________________ 107,000 votes with 81% of the vote, that’s Michigan.”

Bill Stepien testimony: “It was far too early to be making Snopes Fact Check adds: “It’s not clear to what Trump
any calls like that. Ballots – ballots were still being was referring when he appeared to contradict himself
counted, Ballots were still going to be counted for days. by saying he had ‘won by 107,000 votes with 81% of
And it was far too early to be making any proclamation the vote’ in Michigan.”
like that.”
“If you look and you see Arizona, we have a lot of life in
“My belief, my recommendation was to say that votes that. … The gentleman that called it, I watched tonight.
are still being counted. It’s too early to – to tell. Too He said, ‘Well, we think it’s fairly unlikely that he
early to call the race. But, you know, we are proud of the could catch.’ Well, fairly unlikely? And we don’t even
need it. We don’t need that. That was just a state that
race we – we run – we ran and, you know, we think – we
if we would have gotten it, it would have been nice.
think we’re in a – in a good position. And we’ll have Arizona.”
something more to say about this, you know, the next
day or the next day whenever we had something to say. Snopes Fact Check:
…
[The President] thought I was wrong. He told me so. “‘The gentleman that called it,’ as Trump described
And, you know, that they were going to, you know, go in him, was Arnon Mishkin from Fox News’ decision desk.
Contrary to Trump’s claim, Mishkin did not say it was
it – he was going – to go in a different direction.”
merely ‘fairly unlikely’ that Trump could overtake
________________________ Biden, he said he was absolutely certain that Biden
would win.
Jason Miller’s testimony: “I remember saying that I – to
the best of my memory, and I was saying that we should See Trump’s ‘Major Fraud’ Speech, Fact-Checked,
not go and declare victory until we had a better sense Snopes, Nov. 4, 2020 (including fact checks same day of
of the numbers.” claims about Arizona, Georgia, North Carolina (false at
________________________ the time), Pennsylvania); Fact check: Trump makes
series of egregious false claims in Election Night
Bill Barr testimony: “Right out of the box on election address, CNN, Nov, 4 2020 (updated); Trump’s
night, the President claimed that there was major fraud Falsehood-Filled Speech on the Election, FactCheck,
underway. I mean, this happened as far as I could tell Nov. 4, 2020.
before there was actually any potential of looking at
evidence. And it seemed to be based on the dynamic Aside: Jonathan Swan reported (on Nov. 1, 2020 and
that — that at the end of the evening a lot of January 16, 2021) that Trump planned well in advance
Democratic votes came in which changed the vote of election night to declare victory even if he lost.
counts in certain states.

And that seemed to be the basis for this broad claim that
there was major fraud. And I didn't think much of that
because people had been talking for weeks and
everyone understood for weeks that that was going to
be what happened on election night.”

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 5. Red Mirage 2.0 - False claims of third party validators on Election Night

What Trump Knew What Trump Said/Did

Trump family and aides describe the atmosphere on Trump’s Election Night speech:
election night as nervous and unsure.
“We were getting ready for a big celebration. We
Jason Miller testimony: were winning everything and all of a sudden it was just
called off. The results tonight have been phenomenal
Q: Can you just describe the atmosphere? What were and we are getting ready… I mean, literally we were
people expecting that night when you got to the White just all set to get outside and just celebrate.”
House? ________________________

JASON MILLER: I think that there was typically, for Nov. 25, 2020: President Trump’s remarks at
people who show up there on election night to be a self- Pennsylvania Republican legislators hearing:
select more positive environment. I think people were a
little bit nervous not knowing what was going to “Anybody watching television the night of the
happen with the red wave or the red mirage as the election was saying, ‘Wow.’ I was called by the biggest
debate was being carried out. political people, ‘Congratulations, sir on a big win.’
… And all of a sudden ballots were dumped all over the
Q: And so was it anger kind of directed towards Fox place.”
News for making a call more so than a disappointment
that maybe the campaign lost Arizona? “Nobody would've said, we even had a chance of
losing. And all you had to do was take a look at the
JASON MILLER: All of the above. numbers at 10 o'clock in the evening when everybody
thought the election was virtually over and then very
Q: So both? Anger and disappointment? weird things happened, but they're not weird to
professionals. And they're not weird to Dominion and
JASON MILLER: Both disappointed with Fox and other people that operate machines. And they're not
concerned that maybe our data or our numbers weren't weird to the people that handle the ballots, where they
accurate. were flooding the market.”
________________________ ________________________

Ivanka Trump testimony: “The results were still being Dec. 2, 2020, press conference:
counted. It was becoming clear that the race would not
be called on election night.” “It’s about ballots that poured in, and nobody but a
________________________ few knew where they came from, but they were
counted and they weren’t for me. It’s about big leads
Bill Stepien testimony: “It was far too early to be making on election night, tremendous leads, leads where I was
any calls like that. Ballots – ballots were still being being congratulated for a decisive, easy victory. All of
counted, Ballots were still going to be counted for days. a sudden, by morning or a couple of days later, those
And it was far too early to be making any proclamation leads rapidly evaporated. It’s about numbers of ballots
like that.” that were sent that nobody know where they came
________________________ from. It’s about machinery that was defective,
machinery that was stopped during certain parts of the
Jason Miller’s testimony: “I remember saying that I – to evening, miraculously to open with more votes.”
the best of my memory, and I was saying that we should ________________________
not go and declare victory until we had a better sense
of the numbers.” Dec. 5, 2020 rally speech in Georgia: “In fact, when I
went to bed that night, everybody was calling,
‘Congratulations. You’re up 600,000 votes in

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 Pennsylvania.’ Across all of the key swing states, there
were impossibly low rejection rates, you saw that, for
mail-in ballots, drastically less than the historic norm.”
________________________

Dec. 13, 2020, Fox & Friends:

“I go home and I watch the television to see how we're

doing. And by 10:30 in the evening, it was over. We
won. I got calls from everybody saying congrat, pros,
people you know very well saying, congratulations. I
say, let's not go so fast. I don't trust these machines.
And a lot of bad things happen with these people. And
in essentially five or six states, the local people who run
it rig the election and tens of thousands. Remember
they stopped the counting in the evening.”
________________________

Dec. 9, 2020, Trump tweets:

At 10:00 P.M. on Election Evening, we were at 97% win

with the so-called “bookies”

Dec. 13, 2020, Fox & Friends:

The election was over at 10 o'clock in the evening. I

had won. It was 97, 98%. All of the bookies all over
the world were saying the election is over. They
wouldn't even take bets on it. And then all of a sudden
around 11 o'clock ballots start getting dropped.”

This is untrue. See Fact check: Did ‘bookies’ say Trump

was a 97% favorite to win on election night?,
McClatchy, Dec. 10, 2020; Trump Mocked For Odd
Claim That 'Bookies' Favored Him On Election Eve,
Huffington Post, Dec. 9, 2020.

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6. Absence of actual evidence of fraud - Trump legal team

Arizona Speaker of the House Rusty Bowers testimony: “My recollection, [Trump personal attorney Rudy Giuliani]
said, ‘We've got lots of theories. We just don't have the evidence.’ And I don't know if that was a gaffe or maybe
he — he didn't think through what he said. But both myself and others in my group, the three in my group and my
— my counsel, both remembered that specifically.”
________________________

Trump lawyer and associate Sidney Powell, defending herself in a defamation lawsuit brought by Dominion Voting
Systems, told the court, "No reasonable person would conclude that her statements were truly statements of
fact."

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 ________________________

The New York state court opinion suspending Giuliani’s bar license determined that Giuliani had knowingly made
false allegations of widespread election fraud. As part of its decision, the court observed that Giuliani never
provided affidavits or other documents to support his claims of election fraud (e.g., “respondent fails to provide a
scintilla of evidence for any of the varying and wildly
inconsistent numbers of dead people he factually represented voted in Philadelphia during the 2020 presidential
election;” “Respondent's general claim, without providing this Court with any documentary support, that he
relied on ‘hundreds of pages of affidavits and declarations in [respondent’s] possession that document gross
irregularities…’ will not suffice to controvert the specific findings that he knowingly made the false statements that
are particularized below;” “None of these
affidavits were provided to the Court” (re underage voters); “despite having no evidence to refute the facts
developed after investigation of public records” (re dead people voting in Georgia); “there was no data available
from which to draw any conclusion” and “failed to produce any sources, whether ‘best’ or marginal, to support
any of the figures
he has presented to the public with authority” (re undocumented immigrants voting in Arizona).
________________________

REP. ADAM SCHIFF: And when you asked him [Giuliani] for evidence of this fraud what did he say?

RUSTY BOWERS: He said that they did have proof. And I asked him, do you have names? For example, we have
200,000 illegal immigrants, some large number. Five or 6,000 dead people, et cetera. And I said, do you have their
names? Yes? Will you give them to me? Yes. The President interrupted and said give the man what he needs, Rudy.
And he said I — I will. And that happened on at least two occasions, that interchange in the conversation.

REP. ADAM SCHIFF: So Mr. Giuliani was claiming in the call that there were hundreds of thousands of
undocumented people and thousands of dead people who had purportedly voted in the election?

RUSTY BOWERS: Yes.

REP. ADAM SCHIFF: And you asked him for evidence of that.

RUSTY BOWERS: I did.

REP. ADAM SCHIFF: And did you ever receive from him that evidence either during the call after the call or to this
day?

RUSTY BOWERS: Never.

________________________

See also, Giuliani in Public: “It’s a Fraud.” Giuliani in Court: “This Is Not a Fraud Case.” New York Times, Nov. 18,
2020; Donald Trump And His Lawyers Are Making Sweeping Allegations of Voter Fraud In Public. In Court, They Say
No Such Thing, Time, Nov. 20, 2020.

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 7. Manufacturing conspiracy: Fulton County State Farm Arena “suitcases”

On Dec. 3, 2020, representatives of President Trump, including Rudy Giuliani, appeared before the Georgia State
Senate’s Judiciary Subcommittee in a hearing on election fraud. They played snippets of video surveillance tape,
which they claimed showed election workers in the State Farm Arena in Fulton County bringing suitcases of ballots
to be secretly counted.

Their video evidence may best be described as deceptive editing by omission.

As the New York state court that suspended Giuliani’s bar license explained:

“When viewed in full context and not as snippets, the videos do not show secreting and counting of illegal ballots.
…
If, as respondent claims, he reviewed the entire video, he could not have reasonably reached a conclusion that
illegal votes were being counted.”

Giuliani “acknowledged that he had viewed the surveillance videos in their entirety” (p. 21).
________________________

Georgia Secretary of State Brad Raffensperger wrote:

“Giuliani and his team selectively sliced and diced the video and conjured up a false narrative to fit his
disinformation campaign. The deliberate deceit worked.”
________________________

On Dec. 7, 2020, Georgia election official Gabriel Sterling stated:

“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 the public about what was on that video.
I'm quite sure that they will not characterize the video if they try to enter into evidence because that is the kind of
thing that can lead to sanctions because it's obviously untrue.

They knew it was untrue and they continue to do things like this.”

Note: During Trump’s phone call with Raffensperger, Cleta Mitchell said, “I will tell you. I’ve seen the tape. The full
tape. So has Alex [B. Kaufman]. We’ve watched it.”

(See also Sterling testimony on “if you watch the entirety of the video.”)
________________________

Former U.S. Attorney BJ Pak testified: “Unfortunately, during the Senate hearing, Mr. Giuliani only played a clip
that showed them pulling out the official ballot box from under the table and referring to that as a smoking gun
of fraud in — in Fulton County, when in actuality in review of the entire video, it showed that that was actually an
official ballot box that was kept underneath the — the tables.”

Pak testified: “I listened to the — the tapes and reviewed the videotape myself and that there was nothing there.
Giuliani was wrong in representing that this was a suitcase full of ballots.”
________________________

Former Acting Deputy Attorney General Richard Donoghue testimony on conversation with President Trump:

Page 12 of 22
“I said, okay, well, with regard to Georgia, we ‘looked at the tape, we interviewed the witnesses. There is no
suitcase." The President kept fixating on this suitcase that supposedly had fraudulent ballots and that the suitcase
was rolled out from under the table. And I said, no, Sir, there is no suitcase. You can watch that video over and
over; there is no suitcase. There is a wheeled bin where they carry the ballots, and that's just how they move
ballots around that facility. There's nothing suspicious about that at all.

I told him that there was ‘no multiple scanning of the ballots.’ One part of that allegation was that they were taking
one ballot and scanning it through three or four or five times to rack up votes presumably for Vice President Biden.
I told him that the video did not support that.”

Former Acting Deputy Attorney General Richard Donoghue testified: “I told the President myself that several
times in several conversations, that these allegations about ballots being smuggled in in a suitcase and run
through the machine several times, it was not true, that we looked at it. We looked at the video, we interviewed
the witnesses, that it was not true.”

Donoghue’s statements to President Trump about the State Farm allegations included their phone conversation on
Dec. 27 and meeting on Dec. 31 (transcribed interview).
________________________

Barr testified: “The Fulton County allegations were — had no merit. They're — the — the ballots under the table
were legitimate ball — ballots. They weren't in a suitcase. They had been pre-opened for eventually feeding into
the machine, all the stuff about the water leak and that there was some subterfuge involved. We felt there was
some confusion, but — but there was no evidence of a subterfuge to create an opportunity to feed things into the
count. And so, we didn't see any evidence of — of fraud in the — in the Fulton County episode.”

Aside: In their book, Carol Leonnig and Philip Rucker report: “Barr told Trump he didn’t buy it. The ‘suitcases’ were
actually the standard boxes that Fulton County used to transport ballots to the central vote tallying center.” This
was presumably at the Dec. 14 meeting.
________________________

REP. SCHIFF: These are the allegations that the Department of Justice, the attorney general, the Georgia Bureau
of Investigation, and your office had all said were false. Is that right?

BRAD RAFFENSPERGER: Correct. And even more importantly, when BJ Pak resigned as US attorney of the Northern
District, President Trump appointed as acting US attorney of the Northern District Bobby Christine. And Bobby
Christine looked at that and he was quoted by the AJC [Atlanta Journal Constitution] that he found nothing, and he
dismissed that case early also.

REP. SCHIFF: Thank you, Mr. Secretary. The President references suitcases or trunks. Mr. Sterling, were the objects
seen in these videos suitcases or trunks or were they just the ordinary containers that are used by election
workers?

GABRIEL STERLING: They're stand — standard ballot carriers that allow for seals to be put on them so that they are
tamper proof.

REP. SCHIFF: And finally, the President claims that there was a minimum of 18,000 ballots somehow smuggled in
all for Biden. I take it, gentlemen, that was also categorically false?

GABRIEL STERLING: There's no — A, there's no physical way he can know who those ballots were for. But
secondarily, we had — Fulton County for years, has been an issue in our state when it comes to elections. So we
had a — they had a very difficult time during the primary — in large part because of COVID. So we had put them
under a consent decree the secretary got negotiated where we had a monitor on site and his name was Carter

Page 13 of 22
Jones.

And he took a notation. He had gone from State Farm to the English Street warehouse to look at Election Day
activities. But before he left the State Farm arena, he noted how many ballots have been counted on each one of
the machines. And when he came back after we found out they were working again, he took note again when they
closed.

And I believe the final number was something around 8,900 total ballots were scanned from the time he left to
the time about 12:30 or 1:00 in the morning. So way below 18,000.

________________________

Trump repeats the false claims about the State Farm Arena suitcases in his phone conversation with Georgia
Secretary of State Raffensperger on Jan. 2 and in his Ellipse speech on Jan. 6.

The brief filed by the House General Counsel reports (with citations) that (1) on Dec. 3, Trump’s YouTube channel
posted the edited video clips asserting the false allegations (see also Trump retweet); (2) the Trump Campaign ran
two Facebook ads on Dec. 11 and 23 featuring the selectively edited footage claiming that the video showed
“suitcases of ballots added in secret in Georgia” (ads “approved by Donald J. Trump”); and (3) the Trump Campaign
continued to run the ads after Donoghue’s conversations with Trump. In a tweet on Jan. 3, Trump lied that
Raffensperger had been unable or unwilling to address the “‘ballots under the table’ scam” in their private
conversation the day before.
________________________

Note: Trump also made wildly divergent claims about the number of votes affected in the State Farm Arena
conspiracy.

Dec. 5, 2020 rally speech in Georgia: “That’s 10 times more than I need to win this state. 10 times more. That’s 10
times, maybe more than that, but it’s 10 times more because we lost by a very close number.”

[Note: Trump lost the state by 12,000 votes; 10 times would be 120,000 votes.]

Jan. 2, 2021 phone call with GA Secretary of State: “We had at least 18,000 – that’s on tape, we had them counted
very painstakingly – 18,000 voters”

Later in same call: “The minimum number is 18,000 for [name] , but they think it’s probably about 56,000.”

Later in same call (in apparent disagreement with his lawyer, Cleta Mitchell - timestamp at 26:40):

Mitchell: Our estimate is that there were roughly 18,000 ballots. We don’t know that. If you know that —

Trump: — it was 18,000 ballots, but they used each one three times.

Mitchell: Well, I don’t know about that, but I know —

Trump: — well, I do, because we had ours magnified out

[Note: 18,000 x 3 = 54,000.]

Jan. 6, 2021 Ellipse speech: “Then election officials pull boxes, Democrats, and suitcases of ballots out from under a
table. You all saw it on television, totally fraudulent. And illegally scanned them for nearly two hours, totally
unsupervised. Tens of thousands of votes. This act coincided with a mysterious vote dump of up to 100,000 votes

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for Joe Biden, almost none for Trump. Oh, that sounds fair. That was at 1:34 a.m.”

The New York state court opinion suspending Giuliani’s bar license determined that Giuliani had knowingly made
false allegations of widespread election fraud. The court’s reasoning was based in part on the fact that Giuliani’s
“numerical claims are so wildly divergent and irreconcilable, that they all cannot be true at the same time. Some of
the wild divergences were even stated by respondent in the very same sentence.”

Return to Table of Contents

8. Willful blindness/Disinterest in actual evidence

1) Barr testimony: “When I went into this and would, you know, tell him how crazy some of these allegations were,
there was never — there was never an indication of interest in what the actual facts were.”

________________________

2) Barr testimony: “After the election, he didn't seem to be listening and I didn't think it was, you know, that I was
inclined not to stay around if he wasn't listening to advice from me or his other cabinet secretaries.”

________________________

3) Donoghue testimony: “This gets back to the point that there were so many of these allegations that when you
gave him a very direct answer on one of them, he wouldn’t fight us on it, but he would move to another
allegation.”
________________________

4) Dec. 27, 2020 Trump phone call with senior DOJ leadership (Rosen and Donoghue)

In a phone call with Rosen and Donoghue, Trump explicitly tells the DOJ leadership: “Just say the election was
corrupt and leave the rest to me and the Republican Congressmen” (Donoghue testimony; Donoghue
contemporaneous handwritten notes).

Describing the Dec. 27 meeting:

REP. KINZINGER: Even though he had been told that there was no evidence of fraud, did the President keep saying
that the department was quote, "Obligated to tell people that this was an illegal corrupt election."

RICHARD DONOGHUE: That's also an exact quote from the President. Yes.

________________________

5) Transcribed interview:

DONOGHUE: So he wanted us to say it was corrupt, you know, for whatever reason. I'll leave that to him or others
to explain or determine. But he wanted us to say that it was corrupt. And this was consistent with some things he
said at other points about, the Department should publicly say that the election is corrupt or suspect or not
reliable. At one point, he mentioned the possibility of having a press conference. We told him we were not going to
do that.

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Q: Yeah.

DONOGHUE: So this was something that was brought up more than once.

Q: Yeah. So, again, there was a focus on public statements that something was corrupt, as opposed to trying
specifically to get to the bottom of the individual allegations.

DONOGHUE: Right.

________________________

6) Jan. 2, 2021 phone call with Georgia Secretary of State Raffensperger:

From Select Committee hearing (June 21, 2022):

REP. SCHIFF:
Mr. Secretary, you were trying to push back when the President made these unsupported claims, whether they
were about suitcases of ballots or that Biden votes were counted three times. Let's play the next clip.
[Audio of Jan. 2, 2021 phone call]
RAFFENSPERGER: Mr.. President, they did not put that. We did an audit of that, and we proved conclusively that
they were not scanned three times. Yep. Mr. President, we'll send you the link from WSB –
TRUMP: I don't care about a link, I don't need it. Brad, I have a much better link.
[Audio ends.]
REP. SCHIFF: You told the president you would send him a link from WSB, which I understand is a local television
station that had an unedited video from the State Farm Arena, but the president wasn't interested in that. He said
he had a much better link.

7) Trump fired people on his Campaign who did not support false allegations (same with U.S. Attorney BJ Pak, and
attempted same with Acting Attorney General Jeff Rosen).

Bill Stepien testimony:

BILL STEPIEN: Sure. Previously, I described some of my frustration with some of the — the claims that people
would throw at President Trump regarding, you know, you know, you need to look at this. You know, this
happened in this state or that happened in that state. And it would be, you know — those would flow to us to — to
— to look into.

I — I talked about that before I think.

UNKNOWN: Yep.

BILL STEPIEN: You know, this is an example of that. I recall — I recall in Arizona someone had thrown out, I believe
this to be the claim, that there were thousands of illegal citizens, people not eligible to vote, kind of cast their

Page 16 of 22
ballots in Arizona. Someone had thrown out that claim to President Trump. And with, you know, the margins being
as close as they were as previously described, you know, that could potentially matter.

So, this — this wild claim is thrown out, which, you know, on its face didn't seem, you know, realistic or possible to
me. I asked Alex to look at the — you know, the — the claim. And I — I haven't read his full email, but I recall that
the response to that, the reality of that was not illegal citizens voting in the election, I think it was like overseas
voters voting in the election. I — I — so, obviously, you know, people who were eligible to vote. [End videotape]

ZOE LOFGREN: When these findings were passed up the chain to President Trump, he became frustrated and he
replaced the campaign's legal team. Let's play clip 14.

[Begin videotape]
BILL STEPIEN: You know, I think the president, it was during second week where things like you displayed were
occurring, where he was, you know, growing increasingly unhappy with, you know, his team, you know, me less so
because I was less involved at this point, but still me; growing increasingly unhappy with [Trump campaign senior
advisor] Justin Clark. And that — that kind of, you know — you know, paved the way for, you know, Justin to be
moved out and Mayor Giuliani be moved in as the person in charge of, you know, the legal side of the campaign
and, for all intents and purposes, the campaign at that point.
[End videotape]

Return to Table of Contents

9. Claims of more votes than voters in Philadelphia

Special Note: The logical flaw in this allegation is clear and irrefutable, such that repeating the allegation after
being made aware of the flaw indicates a deliberate effort to deceive.

What Trump Knew What Trump Said

Barr testimony (Barr told Trump on Nov. 23, Dec. 1, or On Jan. 4, 2021, Trump speech at political rally in
Dec. 14, 2020): Georgia:

“The idea the President has repeatedly suggested that “There’s an unexplained 400,000 vote discrepancy
there was some kind of outpouring of unexpected votes between the number of mail-in ballots in Pennsylvania
in inner city areas like Philadelphia as recently as January sent out reported on November 2nd, 2020. And the
13th when he walked off the NPR set. He was asked by number reported on November 4th. They can’t explain
the interviewer, you know, what's — you know, what's it. 400,000 previously unreported mail-in ballots,
your evidence of fraud? magically appeared. They couldn’t explain it. And all of
a sudden they just happened to find 400,000. That’s a
And he said more people voted in Philadelphia than lot of people.”
there were voters. And that was absolute rubbish. The
turnout in Philadelphia was in line with the state's ________________________
turnout and in fact it was not is as — as impressive as
many suburban counties. And there was nothing strange On Jan. 6, 2021, Ellipse speech:
about the Philadelphia turnout. It wasn't like there was
all these unexpected votes that came out in Philadelphia. “The day before the election, the state of Pennsylvania
reported the number of absentee ballots that had been
So, you know, I think once you actually look at the votes sent out. Yet this number was suddenly and drastically
and then if there's an obvious explanation, he — you increased by 400,000 people. It was increased. Nobody
know, for example, in Pennsylvania, Trump ran weaker knows where it came from, by 400,000 ballots, one

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than the Republican ticket generally. He ran weaker than day after the election.
two of the state candidates. He ran weaker than the
Congressional delegate — delegation running for federal “It remains totally unexplained. They said, ‘Well, ah,
Congress, and he ran weaker than the — the Republican we can't figure that.’ Now, that's many, many times
— I think, I haven't looked at this recently, but he what it would take to overthrow the state. Just that
generally was a weak element on the Republican ticket. one element. Four hundred thousand ballots appeared
So, that does not suggest that the election was stolen by from nowhere right after the election.”
fraud.

UNKNOWN: How about Pennsylvania and [former

United States Attorney] Bill McSwain? You were talking
with the US attorney in Philadelphia about an alleged
discrepancy between the number of absentee ballots
issued and the number of ballots cast.

WILLIAM BARR: Right. So, I — I — you know, that was a

— a — one of the big ones for a period of time. I think —
I think that was raised in Gettysburg by Giuliani or
something like that, but it kept on being repeated. And I
found it annoying because it didn't seem that it was
right. So, I called — I called McSwain and he got back to
me. He said no, the problem is that [Pennsylvania state
senator] Mastriano, threw out a — threw out this
number.

And what he [Mastriano] did was he mixed apples and

oranges. He took the number of applications for the
Republican primary and he compared it to the number
of absentee votes cast in the general election. But once
you actually go and look and compare apples to apples,
there's no discrepancy at all. And, you know, that's one
of the — I — I think at some point I covered that with
the president.”

Return to Table of Contents

10. Dominion allegations

What Trump Knew What Trump Said/Did

Before Nov. 19, 2020: An internal memo produced Vice Chair Liz Cheney stated: “President Trump
within the Trump Campaign debunks the outlandish persisted, repeating the false Dominion allegations in
conspiracy theories about Dominion voting machines public at least a dozen more times even after his
that are publicly espoused by Trump lawyers Giuliani and Attorney General told him, they were quote, ‘complete
Sidney Powell. nonsense.’”
________________________ ________________________

Note re Sidney Powell: Dec. 2, 2020: Trump releases public remarks in which
he states:
Powell, defending herself in a defamation lawsuit
brought by Dominion Voting Systems, told the court that “Here’s an example. This is Michigan. At 6:31 in the

Page 18 of 22
"no reasonable person would conclude that her morning, a vote dump of 149,772 votes came in
statements were truly statements of fact." unexpectedly. We were winning by a lot. That batch
________________________ was received in horror. On top of everything else, we
have a company that's very suspect. It's name is
Dec. 1, 2020: AG Barr informs Trump the Dominion Dominion. With the turn of a dial with the change of a
allegations are baseless. chip, you could press a button for Trump and the vote
goes to Biden. What kind of a system is this? ….
Barr testimony:
In one Michigan County, as an example, that used
“I reiterated that they've wasted a whole month on Dominion systems, they found that nearly 6,000 votes
these claims — on the Dominion voting machines and had been wrongly switched from Trump to Biden, and
they were idiotic claims. this is just the tip of the iceberg. This is what we
caught. How many didn't we catch? Are there 100s of
And I specifically raised the Dominion voting machines, other examples throughout the country? Are there
which I found to be among the most disturbing 1000s? We just got lucky and they called it a glitch, but
allegations. Disturbing in the sense that I saw absolutely we found numerous glitches that evening. 96% of the
zero basis for the allegations. But they were made in company's political donations went to Democrats, not
such a sensational way that they obviously were surprisingly. And, frankly, when you look at who's
influencing a lot of people — members of the public that running the company, who's in charge, who owns it,
there was this systemic corruption in the system and which we don't know, where are the votes counted?
that their votes didn't count and that these machines Which we think are counted in foreign countries, not
controlled by somebody else were actually determining in the United States, Dominion is a disaster. Election
it, which was complete nonsense. authorities in Texas have repeatedly blocked the
deployment of Dominion systems due to concerns
And it was being laid out there. And I told them that it about security vulnerabilities and the potential for
was — it was crazy stuff and they were wasting their errors and outright fraud. Every district that uses
time on that. And it was doing a great, grave disservice Dominion systems must be carefully monitored and
to the country.” carefully investigated.”
________________________ ________________________

Dec. 14, 2020: Barr warns Trump about the Dominion Dec. 5, 2020 rally speech in Georgia: “In one Michigan
allegations (re Antrim County, Michigan). Barr testimony: county using Dominion voting systems, nearly 6,000
votes were discovered that were wrongly switched
“When I walked in, sat down, he went off on a from Trump to Biden. They called it a glitch. You know
monologue saying that there was now definitive a glitch? Just like the machine broke. Numerous times
evidence involving fraud through the Dominion we found glitches, and every single time, the glitch
machines and a report had been prepared by a very went a hundred percent to Biden and no percent to
reputable cybersecurity firm, which he identified as Trump. The same systems are used in 30 states.”
Allied Security Operations Group. And he held up the
report and he had — and then he asked that a copy of it ________________________
be made for me. And while a copy was being made, he
said, you know this is absolute proof that the Dominion Dec. 15, 2020: Trump tweets:
machines were rigged.
“68% error rate in Michigan Voting Machines. Should
The report means that I am going to have a second term. be, by law, a tiny percentage of one percent.”
And then he gave me a copy of the report. And as he
talked more and more about it, I sat there flipping (see also retweet on Dec. 16, 2020)
through the poor report and looking through it. And to
be frank, it looked very amateurish to me, didn't have Dec. 17, 2020: Trump retweets a John Solomon tweet
the credentials of the people involved, but I didn't see of a report from his media outlet, JustTheNews,
any real qualifications. headlined: “Lawyer says Dominion vote-flip in Michigan
was due to software, not ‘human error.’”

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And the statements were made very conclusory like this ________________________
— these machines were designed to, you know, engage
in fraud or something to that effect, but I didn't see any Dec. 19, 2020: Trump retweets former presidential
supporting information for it. And I was somewhat assistant Peter Navarro’s report, which alleged election
demoralized because I thought, boy, if he really believes fraud that would swing the election in his favor.
this stuff he has, you know, lost contact with — with it —
he's become detached from reality if he really believes The report claims that “at least one instance of a large
this stuff. and inexplicable vote switching and vote surge in favor
of Joe Biden took place in Antrim County, Michigan –
On the other hand, you know, when I went into this and and it is associated with the controversial
would, you know, tell him how crazy some of these aforementioned Dominion-Smartmatic voting machine
allegations were. There was never — there was never an hardware-software combo. In this Republic stronghold,
indication of interest in what the actual facts were.” 6,000 votes were initially, and incorrectly, counted for
________________________ Joe Biden…when a check was done, it was discovered
that the 6,000 votes were actually for Donald J.
Dec. 15, 2020: Oval Office meeting (with Pat Cipollone, Trump.”
Pat Philbin, Jeffrey Rosen, Richard Donoghue, Chad
Mizelle, and Ken Cuccinelli), Donoghue testified before A “subsequent forensic audit of the Antrim County vote
Senate Judiciary Committee: tabulation found that the Dominion system had an
astonishing error rate of 68 percent.”
“The President raised the Antrim County matter. And he ________________________
said something to the effect of, you know, ‘Have you
guys seen this report? This is unbelievable. This is a Dec. 29, 2020: “White House Special Assistant and Oval
disaster. They've got a 68 percent error rate. They used Office Coordinator Molly Michael emailed a draft
these machines all over the country’ and so on. … Supreme Court brief to Rosen, Donoghue, and Acting
Solicitor General Jeffrey Wall. …
I recall Ken Cuccinelli saying, "The hand count will be the In short, Trump asked DOJ to petition the Supreme
gold standard. That will tell us whether that's true or Court to overturn the election results.
not." And we should know in a day or two, or maybe In support of the relief it sought, the proposed
three, at most, whether the hand recount supports or Supreme Court brief made a variety of false factual
undermines the Allied report. And so there was nothing claims about the election… Among others, these
to be decided or to be done. It was just a matter of the included
President talking about the possible implications of this, claims that:
if, in fact, the report was correct. And we all agreed that …
if there's a 68 percent error rate, then, yes, there's a A ‘forensic audit’ conducted by Allied Security Group
huge problem for the country. But let's not get ahead of found that ‘the Dominion voting system in Antrim
ourselves. The hand recount is underway and let's let County [Michigan] was designed to generate an error
that progress. And we should know in a day or two rate as high as 81.96%.’”
whether there's really anything to this.
- Senate Judiciary Report; see also Steven Engel
He seemed satisfied with that response.” testimony.
________________________ ________________________

Dec. 27, 2020: In a 90-minute phone call with the In a Jan. 2, 2021 phone call with Georgia Secretary of
President and senior Justice Department officials, State Brad Raffensperger, Trump mentions Dominion
referencing a report produced by an outside group, ten times but says he does not need to raise specific
Security Operations Group (ASOG),Donoghue testifies: allegations about the voting machines because of other
fraud claims.
“One that was very clear at that point was the Antrim ________________________
County — the ASOG report that I mentioned earlier.
Allied Security Operations Group released this report In a Jan. 4, 2021 rally in Georgia, Trump mentions
that said 68 percent error rate. There was in fact in Dominion seven times, including specific allegations

Page 20 of 22
Antrim County a hand recount. Had nothing to do with such as:
the Department. The Department did not request that.
“Three events discussed at this hearing standout and
That was pursuant to litigation brought by other parties, require a forensic auditor of the Dominion voting
but there was a hand recount. So they were able to machines in Georgia to be immediately conducted. The
compare the hand recount to what the machines had governor will not let us do it. We've been asking them
reported. And for the ballots that were actually counted now since November 4th, the day after the election, he
by machine, more than 15,000, there was one error, one won't let us do it. Why won't he let us do it? There's
ballot. And I did a quick calculation and came up with only one reason I can think of. First the Dominion
.0063 percent error rate, which is well within tolerance. voting machines employed in Fulton County … had an
astounding 93.67 error rate, 93.67 error rate, in the
And so I made it very clear to the President because he scanning of ballots requiring a review panel to
was so fixated on the ASOG report in the December 15th adjudicate or determine the voter’s intent.”
conversation that in fact our investigation revealed that ________________________
the error rate was .0063 percent. So that, Mr. President,
an example of what people are telling you that is not On Jan. 6, 2021, Trump’s Ellipse speech:
true, and that you cannot and should not be relying on.
So that was one very explicit one.” “There is the highly troubling matter of Dominion
Voting Systems. In one Michigan county alone, 6,000
Donoghue written transcribed interview: votes were switched from Trump to Biden and the
same systems are used in the majority of states in our
“So I tried to, again, put this in perspective and to try to country.” He also raises again the specific claim of a
put it in very clear terms to the President. … ‘We are 93.67% error rate with Dominion machines in Fulton
doing our job. Much of the info you're getting is false.’ County.
And then I went into, ‘For instance, this thing from
Michigan, this report about 68 percent error rate –
reality is, it was only 0.0063 percent error rate, less than
1 in 15,000.’

So the President accepted that. He said, ‘Okay, fine. But

what about the others?’”
________________________

Jan. 2, 2021: In Trump phone call with Raffensperger,

the Secretary of State provided strong if not definitive
proof that the Dominion allegations were false:

Raffensperger said: “I don’t believe that you’re really

questioning the Dominion 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. I don’t think there’s an
issue about that.”

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 11. Undocumented immigrants voting in Arizona

What Trump/Trump Campaign Knew What Trump Said

Bill Stepien testimony: “I recall in Arizona someone had Rusty Bowers testimony: “[Giuliani] said that they did
thrown out, I believe this to be the claim, that there were have proof [of fraud]. And I asked him, do you have
thousands of illegal citizens, people not eligible to vote, names? For example, we have 200,000 illegal
kind of cast their ballots in Arizona. Someone had thrown immigrants, some large number. Five or 6,000 dead
out that claim to President Trump. And with, you know, people, et. cetera. And I said, ‘do you have their
the margins being as close as they were previously names?’ ‘Yes?’ ‘Will you give them to me?’ ‘Yes.’ The
described, you know, that could potentially matter. President interrupted and said, ‘Give the man what he
needs, Rudy.’ And he said I – I will. And that happened
So, this — this wild claim is thrown out, which, you know, on at least two occasions, that interchange in the
on its face didn't seem, you know, realistic or possible to conversation.”
me. I asked Alex to look at the — you know, the — the ________________________
claim. And I — I haven't read his full email, but I recall
that the response to that, the reality of that was not Jan. 4, 2021: Trump, speaking at Georgia election rally:
illegal citizens voting in the election, I think it was like
overseas voters voting in the election. I — I — so, “In Arizona more than 36,000 votes were cast by non-
obviously, you know, people who were eligible to vote.” citizens.”
________________________
According to Leonnig and Rucker’s book (p. 379), this
episode occurred around mid-November 2020. Jan. 6, 2021: Trump, Ellipse rally speech:

“In the state of Arizona, over 36,000 ballots were

illegally cast by non-citizens.”

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END

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