The Big Lie — Chapter 1 (Election Night 2020; the Peaceful Transfer of Power on January 6, 2021)

Summary

Chapter 1, The Big Lie, from a report that refers to the Select Committee to Investigate the January 6th Attack on the United States Capitol. The chapter states that late on election night 2020 President Donald J. Trump addressed the nation from the East Room of the White House, and that Trump Campaign Manager William Stepien and Jason Miller advised against declaring victory. It states that the Committee assembled evidence of preplanning, including communications from Tom Fitton and an audio recording of Steve Bannon dated October 31, 2020. Its sections cover the Red Mirage, pre-election plans to declare victory and efforts to delegitimize mail-in voting, and it ends with numbered source notes.

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                              THE BIG LIE

Late on election night 2020, President Donald J. Trump addressed the
nation from the East Room of the White House. When Trump spoke, at 2:21
a.m. on November 4th, the President’s re-election was very much in doubt.
Fox News, a conservative media outlet, had correctly called Arizona for for-
mer Vice President Joseph R. Biden. Every Republican presidential candidate
since 1996 had won Arizona. If the President lost the State, and in the days
ahead it became clear that he had, then his campaign was in trouble. But as
the votes continued to be counted, President Trump’s apparent early lead in
other key States—States he needed to win—steadily shrank. Soon, he would
not be in the lead at all—he’d be losing.
    So, the President of the United States did something he had planned to
do long before election day: he lied.
    “This is a fraud on the American public. This is an embarrassment to
our country,” President Trump said. “We were getting ready to win this
election,” the President continued. “Frankly, we did win this election. We
did win this election.” Trump claimed, without offering any evidence, that a
“major fraud” was occurring “in our nation.” 1
    Neither of President Trump’s claims were true. He had no basis for
claiming victory or that fraud was taking place. Millions of votes still had
not been counted. The States were simply tabulating the ballots cast by the
American people. Trump’s own campaign advisors told him to wait—that it
was far too early to declare victory.
    As the evening progressed, President Trump called in his campaign
team to discuss the results. Trump Campaign Manager William Stepien and
other campaign experts advised him that the results of the election would
not be known for some time, and that he could not truthfully declare vic-
tory. Stepien was of the view that, because ballots were going to be counted
for days, “it was far too early to be making any proclamation [about having



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won the election].” Stepien told President Trump that his recommendation
was to say, “votes are still being counted. It's . . . too early to call the
race.” 2
    Jason Miller, another senior Trump Campaign advisor, told the Select
Committee that he argued in conversations with Stepien and others that
night against declaring victory at the time as well, because “it was too early
to say one way [or] the other” who had won. Miller recalled recommending
that “we should not go and declare victory until we had a better sense of
the numbers.” 3
    According to testimony received by the Committee, the only advisor
present who supported President Trump’s inclination to declare victory was
Rudy Giuliani, who, according to Miller, was “definitely intoxicated” that
evening.4
    President Trump’s decision to declare victory falsely on election night
and, unlawfully, to call for the vote counting to stop, was not a spontaneous
decision. It was premeditated. The Committee has assembled a range of
evidence of President Trump’s preplanning for a false declaration of vic-
tory. This includes multiple written communications on October 31st and
November 3, 2020, to the White House by Judicial Watch President Tom
Fitton.5 This evidence demonstrates that Fitton was in direct contact with
President Trump and understood that he would falsely declare victory on
election night and call for vote counting to stop. The evidence also includes
an audio recording of President Trump’s advisor Steve Bannon, who said
this on October 31, 2020, to a group of his associates from China:
      And what Trump’s going to do is just declare victory, right? He’s
      gonna declare victory. But that doesn’t mean he’s the winner. He’s
      just gonna say he’s a winner. . . . The Democrats, more of our people
      vote early that count. Their vote in mail. And so they’re gonna
      have a natural disadvantage, and Trump’s going to take advantage
      of it. That’s our strategy. He’s gonna declare himself a winner.
      So when you wake up Wednesday morning, it’s going to be a
      firestorm. . . . Also, if Trump, if Trump is losing, by ten or eleven
      o’clock at night, it’s going to be even crazier. No, because he’s
      gonna sit right there and say ‘They stole it. I’m directing the Attor-
      ney General to shut down all ballot places in all 50 states. It’s going
      to be, no, he’s not going out easy. If Trump—if Biden’s winning,
      Trump is going to do some crazy shit.6
   Also in advance of the election, Roger Stone, another outside advisor to
President Trump, made this statement:
                                 THE BIG LIE                                197

   I really do suspect it will still be up in the air. When that happens,
   the key thing to do is to claim victory. Possession is 9/10s of the
   law. No, we won. Fuck you, Sorry. Over. We won. You’re wrong.
   Fuck you.7
    In the days after the election, the President’s own campaign team told
him he had lost and there was no evidence of significant fraud. When his
campaign staff wouldn’t tell him what he wanted to hear, President Trump
replaced them with what Attorney General William Barr described as a
“clown car” of individuals willing to promote various conspiracy theories.8
    But Donald Trump was no passive consumer of these lies. He actively
propagated them. Time and again President Trump was informed that his
election fraud claims were not true. He chose to spread them anyway. He
did so even after they were legally tested and rejected in dozens of lawsuits.
Not even the electoral college’s certification of former Vice President
Biden’s victory on December 14, 2020, stopped the President from lying.
Throughout, the Big Lie remained central to President Trump’s efforts to
block the peaceful transfer of power on January 6, 2021.


1.1 THE BIG LIE REFLECTED DELIBERATE EXPLOITATION OF THE “RED MIRAGE”

President Trump’s “Big Lie” on election night was based on simple differ-
ences in how Americans vote. In 2020, it was well-known that Democrats
were much more likely to vote via mail-in ballots than in person in 2020.
On the other hand, Republicans generally preferred to vote in person on
election day.9 In key swing States with tight margins between the candi-
dates, the election day votes would favor President Trump and dispropor-
tionately be counted first. Mail-in ballots, which would favor former Vice
President Biden, would disproportionately be counted later. In some States
it would take days to process the remaining mail-in ballots.
    The timing of how votes are counted created the potential for what is
known as a “Red Mirage”—or an illusion of a Republican (Red) victory in
the early stages of vote counting. President Trump would appear to be in
the lead on election night, but this was not the whole picture. Many mail-in
votes for former Vice President Biden would not be counted on election day.
Therefore, the actual winner would likely not be known on election night.
    The “Red Mirage” phenomenon was widely known prior to the 2020
presidential election. Chris Stirewalt was the head of the Fox News elections
desk that correctly called Arizona for Biden. Stirewalt and his team tried to
warn viewers of the Red Mirage. He testified that over the past 40 or 50
years, “Americans have increasingly chosen to vote by mail or early or
absentee,” and that “Democrats prefer that method of voting more than
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Republicans do.” 10 In nearly “every election,” Stirewalt elaborated,
“Republicans win Election Day and Democrats win the early vote, and then
you wait and start counting.” It “[h]appens every time.” 11
    President Trump’s campaign team made sure the President was briefed
on the timing of vote tallying. Stepien, his campaign manager, told the
Select Committee that President Trump was reminded on election day that
large numbers of mail-in ballots would still remain to be counted over the
coming days.12 Stepien added that he personally reminded the President
that while early returns may be favorable, the counting would continue: “I
recounted back to 2016 when I had a very similar conversation with him on
election day . . . I recounted back to that conversation with him in which I
said, just like I said in 2016 was going to be a long night, I told him in 2020
that, you know, it was going to be a process again, as, you know, the early
returns are going to be positive. Then we’re going to, you know, be watch-
ing the returns of ballots as, you know, they rolled in thereafter.” 13
    Ordinarily, the “Red Mirage” anomaly does not create problems in the
election process because candidates wait for the votes to be tallied before
declaring victory or conceding. As Stirewalt emphasized, prior to President
Trump, “no candidate had ever tried to avail themselves of this quirk in the
election counting system.” 14
                                THE BIG LIE                             199

    President Trump, however, made a different choice. In an extraordinary
breach of the American democratic process, he decided to exploit the
potential for confusion about the staggered timing of vote counting to
deceive the American public about the election results. He and his allies
foreshadowed this decision in their statements in the months leading up to
the November 2020 election.


1.2 TRUMP’S PRE-ELECTION PLANS TO DECLARE VICTORY

On Halloween, advisor Steve Bannon, who had served four years earlier as
Donald Trump’s 2016 campaign manager, laid out the election night plan.
“What Trump’s gonna do is just declare victory. Right? He’s gonna declare
victory. But that doesn’t mean he’s a winner,” Bannon told a private audi-
ence. “He’s just gonna say he’s a winner.” 15
    Bannon explained that the Democrats “[would] have a natural disad-
vantage” on election night, because more Democrats would vote by mail
than Republicans and it would take time to count the mail-in ballots. This
would give President Trump the illusion of a lead. “And Trump’s going to
take advantage of it,” Bannon said. “That’s our strategy. He’s gonna
declare himself a winner.” 16
    In an interview on Fox News the morning of the election, Bannon
insisted that President Trump needed to address the nation that night, to
“provide the narrative engine for how we go forward.” 17 During an episode
of his podcast later that same day, Bannon clarified what he meant: Presi-
dent Trump is “going to claim victory. Right? He’s going to claim
victory.” 18
    Tom Fitton drafted a victory statement for the President to read on
election night.19 On October 31st, he emailed the statement to President
Trump’s assistant, Molly Michael, and social media guru, Dan Scavino. Fit-
ton wrote that election day, November 3rd, was the “deadline by which
voters in states across the country must choose a president.” Fitton argued
that counting ballots that arrived after election day would be part of an
effort by “partisans” to “overturn” the election results.20
    Of course, that claim wasn’t true—mail-in ballots are regularly pro-
cessed after election day. Regardless, Fitton encouraged the President to
pre-emptively declare victory. “We had an election today—and I won,” Fit-
ton wrote for President Trump.21 Early in the evening on election day, Fit-
ton emailed Michael again to say he had “[j]ust talked to him [President
Trump] about the draft [statement].” 22 Later that evening, before President
Trump made his election night remarks, Michael replied that she
was “ . . . redelivering to him [President Trump] now.” 23
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    Roger Stone, President Trump’s longtime political confidante, told sev-
eral associates just prior to the election that Trump needed to declare
victory—especially if the race wasn’t called on election day. “Let’s just
hope we are celebrating” on election night, Stone said. “I really do suspect
it will still be up in the air. When that happens, the key thing to do is claim
victory.” Stone elaborated with colorful language. “Possession is nine-
tenths of the law. No, we won. Fuck you. Sorry. Over. We won. You’re wrong.
Fuck you.” 24
    Indeed, published reports echoed these warnings about President
Trump’s election strategy. Two days before the election, Jonathan Swan of
Axios reported that President Trump “has told confidants he'll declare vic-
tory on Tuesday night if it looks like he's ‘ahead.’” 25 Swan added that
“Trump's team is preparing to falsely claim that mail-in ballots counted
after Nov. 3—a legitimate count expected to favor Democrats—are evidence
of election fraud.” 26 If the vote tally swung against Trump after election
night in States such as Pennsylvania, then the Trump team would claim the
Democrats had “stolen” the election.27 Fox News election analysis Chris
Stirewalt testified that he and his team “had gone to pains” to inform
viewers that early votes would favor Republicans but the lead would be illu-
sory “because the Trump campaign and the President had made it clear that
                                   THE BIG LIE                                     201

they were going to try to exploit this anomaly.” 28 Others warned that
President Trump could exploit the Red Mirage as well.29


1.3 TRUMP’S PRE-ELECTION EFFORTS TO DELEGITIMIZE THE ELECTION PROCESS

President Trump also paved the way for his false election-night declaration
of victory by blanketing voters with a blizzard of lies and statements dele-
gitimizing mail-in voting in the middle of a deadly pandemic and consis-
tently questioning the security of ballots. President Trump used the
president’s bully pulpit, including his heavily-trafficked Twitter feed, to tell
one lie after another.
    The Select Committee found dozens of instances in which President
Trump claimed that mail-in voting would produce a “rigged” election.
Trump repeatedly denounced mail-in voting on Twitter, during interviews,
and even during the presidential debate. Here is a small sample of President
Trump’s attempts to delegitimize mail-in balloting.
   On April 7, 2020, President Trump claimed:
   Mail ballots are a very dangerous thing for this country, because they’re
   cheaters. They go and collect them. They’re fraudulent in many
   cases. . . . These mailed ballots come in. The mailed ballots are corrupt, in
   my opinion. And they collect them, and they get people to go in and sign
   them. And then they—they’re forgeries in many cases. It’s a horrible
   thing.30

   The following day, April 8, President Trump tweeted:
   Republicans should fight very hard when it comes to statewide mail-in
   voting. Democrats are clamoring for it. Tremendous potential for voter
   fraud, and for whatever reason, doesn’t work out well for Republicans.
   @foxandfriends31

   On May 24, President Trump tweeted:
   The United States cannot have all Mail In Ballots. It will be the greatest
   Rigged Election in history. People grab them from mailboxes, print
   thousands of forgeries and “force” people to sign. Also, forge names.
   Some absentee OK, when necessary. Trying to use Covid for this Scam!32
   On September 17, President Trump falsely alleged that mail-in ballots
were ripe for foreign interference:
   @TrueTheVote There is a group of people (largely Radical Left Demo-
   crats) that want ELECTION MAYHEM. States must end this CRAZY mass
202                                   CHAPTER 1

      sending of Ballots. Also, a GIFT to foreign interference into our elec-
      tion!!! Stop it now, before it is too late.33
    Before the election, as President Trump campaigned against mail-in
voting, Bill Stepien sought an intercession. Along with House Minority
Leader Kevin McCarthy, Stepien attempted to convince the President that
mail-in voting was “not . . . a bad thing for his campaign.” 34 They argued
that President Trump’s decision to discourage mail-in voting, while “urg-
ing [his] voters to vote only on election day leaves a lot to chance” and
would fail to take advantage of a superior grassroots operation that could
encourage Trump voters to return their ballots.35 President Trump did not
heed their warning. He continued to demonize mail-in voting. The Red
Mirage was a key part of his “Big Lie.”
    Ominously, President Trump consistently refused to commit to accept-
ing the outcome of the election. During an interview on Fox News in July,
Chris Wallace asked: “Can you give a direct answer [if] you will accept the
election?” President Trump responded: “I have to see. Look, you—I have to
see. No, I’m not going to just say yes. I’m not going to say no, and I didn’t
last time either.” 36
    On September 23, 2020, a reporter asked President Trump if he would
commit to a “peaceful transferal of power after the election.” The President
refused, saying, “we’re going to have to see what happens.” 37 The Presi-
dent claimed, “the ballots are disaster,” adding that if he could “get rid of
the ballots . . . we’ll have a very peaceful—there won’t be a transfer, frankly;
there’ll be a continuation.” 38 That is, according to President Trump, there
would be a “continuation” of his presidency.
    The following day, September 24, another reporter followed up by ask-
ing if the election would be legitimate only if President Trump won. The
President again suggested there was something suspect about mail-in bal-
lots, adding that he was “not sure” the election could be an honest one.39


1.4 PRESIDENT TRUMP’S LAUNCH OF THE BIG LIE

Consistent with the pre-election narrative planted by President Trump,
within hours of polls closing, President Trump began pushing the claim
that late-reported vote tallies were illegitimate.40 Even though he had been
reminded by his Campaign Manager that very day that a large number of
mail-in ballots would not be counted for several hours or days,41 President
Trump claimed that Democrats were going to “find . . . ballots at four o’clock
in the morning and add them to the list.” 42 He also suggested that Demo-
crats were continuing to vote after the polls had closed.43
                                  THE BIG LIE                              203

    Indeed, this is exactly what Steve Bannon described when he said Presi-
dent Trump would “take advantage” of the Democrats’ “natural disadvan-
tage” on election night.44
    In the ensuing days and weeks, President Trump often referred to
“dumps” of votes that were injected into the counting process.45 His sup-
porters latched onto these false claims.46 There were no “dumps” of
votes—just tallies of absentee ballots as they were reported by jurisdictions
throughout the country in a fully transparent process.47 These batches of
ballots included votes for both Trump and Biden. The late-reported votes
favored the former Vice President, just as President Trump’s campaign
advisors said they would, particularly in primarily Democratic cities.48
    Attorney General Bill Barr recognized immediately that the “Red
Mirage” was the basis for President Trump’s erroneous claim of fraud.
“[R]ight out of the box on election night, the President claimed that there
was major fraud underway,” Barr said. “I mean, this happened, as far as I
could tell, before there was actually any potential of looking at evidence.” 49
President Trump’s claim “seemed to be based on the dynamic that, at the
end of the evening, a lot of Democratic votes came in which changed the
vote counts in certain states, and that seemed to be the basis for this broad
claim that there was major fraud.” 50
    President Trump knew about the Red Mirage. He chose to lie about it
repeatedly—even after being directly informed that his claims were false.
This was often the case in the post-election period. The President con-
sciously disregarded facts that did not support his Big Lie.


1.5 POST-ELECTION: PRESIDENT TRUMP REPLACES HIS CAMPAIGN TEAM

President Trump’s campaign leadership, including Bill Stepien (the cam-
paign’s manager) and Justin Clark (the campaign’s deputy manager), sup-
ported President Trump, and were willing to pursue recounts and other
standard post-election litigation, but they were not willing to promote
baseless conspiracy theories.51 Stepien and others characterized this group
as “Team Normal.” 52
    Less than two weeks after the election, President Trump pushed “Team
Normal” aside because its members didn’t tell him what he wanted to hear.
In their place, Trump promoted Rudy Giuliani and his associates, men and
women who spread baseless and extreme claims of election fraud. Giuliani,
the former mayor of New York City, recruited several investigators and
lawyers to assist him.53 Giuliani’s team included Jenna Ellis, Bernard Kerik,
Boris Epshteyn, Katherine Friess, and Christina Bobb.54 Ellis functioned as
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Giuliani’s deputy on the new Trump Campaign legal team.55 Kerik, the for-
mer commissioner of the New York Police Department and a pardoned
felon, served as Giuliani’s chief investigator.56 Other attorneys who col-
laborated with Giuliani’s legal team included Sidney Powell, Cleta Mitchell,
and John Eastman. As discussed elsewhere in this report, Eastman became a
key player in President Trump’s efforts to overturn the election.


1.6 PRESIDENT TRUMP’S CAMPAIGN TEAM TOLD HIM HE LOST THE ELECTION AND
    THERE WAS NO SIGNIFICANT FRAUD

President Trump’s campaign team quickly realized that none of the signifi-
cant fraud claims were real. Bill Stepien testified that, as of November 5th,
the Trump Campaign had not found any proof of fraudulent activity. There
were “allegations and reports,” but “nothing hard [and] fast” that drew the
results of the election into question.57
    The Trump Campaign continued to investigate claims of fraud into the
second week after the election. According to Stepien, as people shared “wild
allegations” with the President, the campaign team was forced to review
the facts and then serve as a “truth telling squad” to the President regard-
ing why the claims “didn’t prove to be true.” 58 For example, Stepien
recalled someone alleging that thousands of illegal votes had been cast in
Arizona. That wasn’t true. The votes had been submitted by overseas voters
(such as military deployed or stationed abroad) who were obviously eligible
to participate in the election.59
    Alex Cannon was a lawyer for the Trump Campaign and previously
worked for the Trump Organization. After the election, Cannon was tasked
with looking into allegations of voter fraud in the 2020 election—including
the claim that thousands of ineligible votes had been cast in Arizona.60
Cannon recalled that Vice President Pence asked him what he was finding.
“And I said that I didn't believe we were finding it, or I was not personally
finding anything sufficient to alter the results of the election,” Cannon
responded. Vice President Pence thanked him.61
    Cannon reported his assessment to Mark Meadows, the White House
Chief of Staff, as well. In mid to late-November 2020, Meadows asked Can-
non what his investigation had turned up. “And I remember sharing with
him that we weren't finding anything that would be sufficient to change the
results in any of the key states,” Cannon told Meadows. “So there is no
there, there?” Meadows replied.62
                                 THE BIG LIE                                 205

    Jason Miller, a senior advisor to the Trump Campaign, pushed claims of
election fraud in public. In private, however, Miller says that he told Presi-
dent Trump a different story, informing him numerous times that there
was not enough election fraud to have changed the election:
   Miller: My understanding is that I think there are still very valid
   questions and concerns with the rules that were changed under the
   guise of COVID, but, specific to election day fraud and irregularities,
   there were not enough to overturn the election.
   Committee Staff: And did you give your opinion on that to the
   President?
   Miller: Yes.
   Committee Staff: What was his reaction when you told him that?
   Miller: “You haven't seen or heard”—I’m paraphrasing, but—“you
   haven't seen or heard all the different concerns and questions that
   have been raised.”
   Committee Staff: How many times did you have this conversation
   with the President?
   Miller: Several. I couldn't put a specific number on it, though.
   Committee Staff: But more than one?

   Miller: Correct.63
    Matthew Morgan, the Trump Campaign’s top lawyer, came to a similar
conclusion. Nearly two months after the election, on January 2nd, Morgan
met with the Vice President’s staff. According to Morgan, the consensus in
the room was that even if all the claims of fraud and irregularities were
“aggregated and read most favorably to the campaign . . . it was not suffi-
cient to be outcome determinative.” 64
    As far as the Trump Campaign’s professional leadership was concerned,
there was no evidence that the election had been “stolen” from President
Trump. To the contrary, they had seen ample evidence that President
Trump simply lost—and told the President so.
    On November 6th, Jared Kushner arranged for the senior campaign staff
to brief President Trump in the Oval Office on the state of the race.65 Since
election day, Matt Oczkowski, the Campaign’s leading data expert, had
tracked voting returns in the swing States to analyze the campaign’s odds
of success.66 Miller texted such updates on data from key States to Mead-
ows.67 The Trump Campaign’s data did not add up to victory. Oczkowski
“delivered to the President in pretty blunt terms that he was going to lose”
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the election.68 There were not enough outstanding votes in the battle-
ground States for President Trump to overcome Biden’s lead. President
Trump disagreed and insisted that he would still prevail through legal chal-
lenges.69

      But the data did not lie.
     On November 7th, the Associated Press called Pennsylvania and the
overall presidential election for former Vice President Biden.70 At that
point, a small team of the President’s campaign advisors including Stepien
met with the President and told him that his path to victory was virtually
non-existent.71 The campaign team conveyed to the President that his
chance of success was only “5, maybe 10 percent,” which Stepien explained
to the Committee was a “very, very, very bleak” assessment.72
     In retrospect, the campaign’s estimate of a 5 to 10 percent chance of
winning, as of November 7th, was far too optimistic. In one of the most
favorable possible scenarios, for example, President Trump and his team
would need to win recounts in Arizona and Georgia, while also prevailing in
litigation challenging absentee or vote by mail ballots in Wisconsin, or pos-
sibly Michigan or Pennsylvania.73 But the election wasn’t even close enough
to trigger automatic recounts in Arizona or Georgia.
                                 THE BIG LIE                             207

    The narrowest margin of total votes between the two candidates was in
Arizona, where former Vice President Biden won by more than 10,000 votes.
This may seem like a small number of votes, but it was more than enough
to avoid an automatic recount. As Benjamin Ginsberg, a longtime Republi-
can elections lawyer, explained to the Select Committee, “the 2020 election
was not close.” 74 Previous campaigns had successfully challenged vote dif-
ferentials in the hundreds—not thousands—of votes.75 Ginsberg explained,
“you just don't make up those sorts of numbers in recounts.” 76 Georgia
performed a hand recount of all the ballots anyway, confirming within
weeks of the election that Biden had won the State.77 Also, by January 6th,
Arizona and New Mexico had conducted statutory post-election audits of
voting machines or randomly-selected, representative samples of ballots at
the State- or county-level that affirmed the accuracy of their election
results.78
    Chris Stirewalt, who led the elections desk at Fox News at the time,
concurred with Ginsberg’s analysis. Asked what President Trump’s odds of
victory were as of November 7th, Stirewalt replied: “None.” 79
    Meanwhile, the Trump Campaign continued to crunch the numbers. On
the morning of November 12th, Oczkowski circulated among top campaign
advisors a presentation describing what happened in each of the battle-
ground States the campaign was monitoring.80 This analysis by the data
team examined the turnout and margins on a county-by-county basis in a
dozen States while also analyzing demographic changes that impacted the
results.81 Among the States were Arizona, Georgia, Michigan, Pennsylvania,
Nevada, and Wisconsin.82 Oczkowski’s team determined that President
Trump lost each of those six States because Biden had performed better
than President Trump in certain areas like population centers or suburbs.83
Yet, in the weeks that followed, President Trump and his new legal team—
the “clown car”—went to great lengths to challenge the results of the elec-
tion in these six states, spreading multiple conspiracy theories.
    The voting data told a clear story: President Trump lost. But, regardless
of the facts, the President had no intention of conceding defeat.
    On election night, President Trump and Rudy Giuliani agreed that the
President should just declare victory—even though he had no basis for
doing so. Giuliani also told the Select Committee that President Trump
asked him on November 4th to take over his campaign’s legal operation.84
Giuliani thought the only way that it would work would be for the President
to call the existing campaign team to announce Giuliani’s takeover because,
in Giuliani’s words, “they are going to be extraordinarily resentful, because
they don’t like me already, and I don’t trust them.” 85 He said that the
President agreed.86
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     Although Giuliani wouldn’t assume leadership of the Campaign’s legal
operations until mid-November, the former New York City mayor quickly
began to butt heads with “Team Normal.”
     On November 6th, Giuliani and his team met with the Trump Cam-
paign’s leadership at its headquarters in Arlington, Virginia.87
     “Team Normal” was not impressed. Stepien told the Select Committee
the campaign team was concerned that Giuliani would be a distraction to
them and to President Trump.88 When Giuliani suggested traveling to
Pennsylvania to assist in the campaign’s efforts, the campaign team
“didn’t dissuade him from doing so.” 89 After just 10 to 15 minutes in the
conference room, Stepien and other staffers left the meeting.90
     That same day, President Trump discussed the Campaign’s legal strat-
egy in the Oval Office with Giuliani, Clark, and Matt Morgan, the Trump
Campaign’s General Counsel.91 Prior to the election, Morgan was respon-
sible for the Campaign’s litigation strategy.92 Morgan and his team filed
lawsuits challenging the changes States made to voting practices during the
coronavirus pandemic.93 Morgan also studied previous elections to deter-
mine the types of cases that were likely to succeed.94 Clark described how
the Campaign’s original legal strategy was based on his general theory for
election cases: “to look at what do you think, what do you know, and what
can you prove” and then determine which cases to file from there.95
     Giuliani had other ideas and advocated to President Trump that he be
put in charge of the Campaign’s legal operation so that he could pursue his
preferred strategy.96 “Mr. Giuliani didn’t seem bound by those cases or by
those precedents. He felt he could press forward on anything that he
thought was wrong with the election and bring a strategy around that,”
Morgan explained.97 “Rudy was just chasing ghosts,” Clark said.98 Morgan
and Clark excused themselves from the meeting because it “was going
nowhere.” 99
     The next day, November 7th, Giuliani held a press conference at Four
Seasons Total Landscaping in Philadelphia, Pennsylvania. He immediately
began making outlandish claims, arguing that the Democrats had conspired
to steal the election. “As you know from the very beginning, mail-in ballots
were a source of some degree of skepticism, if not a lot of skepticism, as
being innately prone to fraud,” Giuliani said. “Those mail-in ballots could
have been written the day before by the Democratic Party hacks that were
all over the Convention Center.” 100 Giuliani offered no evidence to support
his shocking and baseless allegation. Echoes of President Trump’s relent-
less campaign against mail-in balloting, and his decision to exploit the Red
Mirage, were easy to hear.
                                THE BIG LIE                                      209




                                                 Photo by Chris McGrath/Getty Images


     On November 10th, Giuliani and Kerik met with President Trump in the
Oval Office to discuss their investigation into voter fraud. White House
Counsel Pat Cipollone and White House Senior Advisor Eric Herschmann
were also in attendance. After Giuliani’s presentation, President Trump
asked Cipollone whether he had spoken to Attorney General Barr about the
allegations of fraud.101 One day before, Barr had issued a memorandum out-
lining a shift in DOJ policy that allowed Federal prosecutors to investigate
claims of voting irregularities without waiting for the results to be certi-
fied.102 President Trump’s question was an early indication that he was
going to pressure the DOJ to endorse his phony fraud claims.
     Days later, Giuliani and Justin Clark engaged in a screaming match dur-
ing a meeting in the Oval Office.103 Giuliani was urging President Trump to
file a lawsuit in Georgia, but Clark pointed out that a hand recount was
already being conducted and argued it was better to wait.104 Giuliani told
President Trump that Clark was lying to him.105 A formal changing of the
guard would follow.
     On November 14th, President Trump announced on Twitter that Giu-
liani was now the head of his campaign’s legal team.106 “Team Normal”
saw drastic changes to their roles on the newly-structured campaign
210                               CHAPTER 1

team—some self-imposed—and many outside law firms that had signed up
to support the campaign’s legal efforts disengaged completely.107
    “I didn’t think what was happening was necessarily honest or profes-
sional at that point in time,” Stepien explained. “This wasn’t a fight that I
was comfortable with,” he added.108
    On the day the leadership change was announced, Giuliani participated
in a “surrogate” briefing to coordinate messaging by Trump loyalists dur-
ing their media appearances.109 Giuliani announced that the messaging
strategy should be “to go hard on Dominion/Smartmatic, bringing up
Chavez and Maduro.” 110 Giuliani claimed that additional lawsuits would
soon be filed “to invalidate upwards of 1M ballots.” 111
    Consistent with the messaging advanced by the new campaign team,
President Trump in mid-November remained dug-in, still refusing to con-
cede defeat. President Trump continued to insist that he was cheated out of
victory, endorsing one wild conspiracy theory after another to deny the
simple fact that he lost.


1.7 PRESIDENT TRUMP HAD HIS DAY IN COURT

“We’ve proven” the election was stolen, but “no judge, including the
Supreme Court of the United States, has had the courage to allow it to be
heard.” 112 That was how President Trump described efforts to overturn the
election in court one day before the electoral college met on December 14,
2020. That was false.
     Judges across the nation did evaluate President Trump’s claims that the
election was stolen. As longtime Republican election attorney Benjamin
Ginsberg testified before the Select Committee, the President’s camp “did
have their day in court,” it’s just that “in no instance did a court find that
the charges of fraud were real.” 113 In total, the Trump Campaign and allies
of President Trump filed 62 separate lawsuits between November 4, 2020,
and January 6, 2021, calling into question or seeking to overturn the elec-
tion results.114 Out of 62 cases, only one case resulted in a victory for the
President Trump or his allies, which affected relatively few votes, did not
vindicate any underlying claims of fraud, and would not have changed the
outcome in Pennsylvania.115 Thirty of the cases were dismissed by a judge
after a hearing on the merits.116
     In every State in which claims were brought, one or more judges spe-
cifically explained as part of their dismissal orders that they had evaluated
the plaintiffs’ allegations or supposed proof of widespread election fraud or
other irregularities, and found the claims to be entirely unconvincing. In
                                  THE BIG LIE                               211




Arizona, for example, the plaintiffs in Bowyer v. Ducey alleged that the elec-
tion was tainted by the introduction of “hundreds of thousands of illegal,
ineligible, duplicate or purely fictitious ballots.” 117 A Federal judge dis-
missed their suit, finding it “void of plausible allegations” and “sorely
wanting of relevant or reliable evidence.” 118 Likewise, in Ward v. Jackson, an
Arizona State-court judge dismissed a lawsuit by the State GOP chair fol-
lowing a two-day trial, finding no evidence of misconduct, fraud, or illegal
votes.119 This ruling was unanimously upheld by the State supreme court,
where all seven justices were appointed by GOP governors.120
    In Georgia, a State court dismissed Boland v. Raffensperger, which
alleged that tens of thousands of illegal ballots were cast by out-of-State
voters or with invalid signature matches.121 The judge found that “the Com-
plaint’s factual allegations . . . rest on speculation rather than duly pled
facts” and “do not support . . . a conclusion that sufficient illegal votes were
cast to change or place in doubt the result of the election.” 122 The judge
who issued this decision had been appointed by a Republican governor, as
had seven of the eight justices of the State supreme court who upheld her
ruling.123 Likewise, a Federal judge denied relief to the plaintiff in Wood v.
Raffensperger, which alleged that new procedures for checking absentee
ballot signatures spoiled the result by making it harder to reject illegal bal-
lots, finding “no basis in fact or law to grant him the relief he seeks.” 124
212                                CHAPTER 1

The judge wrote that “[t]his argument is belied by the record” because
absentee ballots were actually rejected for signature issues at the same rate
as in 2018.125
       In Michigan, a Federal judge found in King v. Whitmer that the plaintiffs’
claims of “massive election fraud” were based on “nothing but speculation
and conjecture that votes for President Trump were destroyed, discarded or
switched to votes for Vice President Biden. . . .” 126 Similarly, a State-court
judge rejected plaintiffs’ claims in two cases brought against Detroit and
the surrounding county that accused them of systematic fraud in how
absentee ballots were counted; the judge found that one group of plaintiffs
“. . . offered no evidence to support their assertions,” 127 and that the other
group’s “interpretation of events is incorrect” and “decidedly contra-
dicted” by “highly-respected” election experts.128
       In Nevada, a State-court judge rejected a litany of claims of systematic
election fraud in Law v. Whitmer, ruling that plaintiffs “did not prove under
any standard of proof that illegal votes were cast and counted, or legal
votes were not counted at all, due to voter fraud” or “for any other
improper or illegal reason.” 129 The ruling was unanimously upheld by the
Nevada Supreme Court.130
       In Pennsylvania, a Federal judge dismissed Donald Trump for President v.
Boockvar, finding that the Trump Campaign had presented nothing but
“strained legal arguments without merit and speculative accusations
unpled in the operative complaint and unsupported by evidence.” 131 The
dismissal was upheld by the United States Court of Appeals for the Third
Circuit, which held: “[C]alling an election unfair does not make it so.
Charges require specific allegations and then proof. We have neither
here.” 132 That opinion was authored by another Trump appointee.133
       Lastly, in Wisconsin, another judge dismissed a lawsuit accusing the
Wisconsin Elections Commission of “constitutional violations” that “likely
tainted more than 50,000 ballots.” 134 The judge ruled: “This Court has
allowed plaintiff the chance to make his case and he has lost on the mer-
its,” failing to show that the outcome was affected by Commission rules
about drop boxes, ballot addresses, or individuals who claimed “indefinitely
confined” status to vote from home.135 The ruling was upheld by a three-
judge panel of the United States Court of Appeals for the Seventh Circuit, all
of whom were Republican appointees, including one appointed by President
Trump himself.136
       In all, the judges who heard these post-election cases included 22 Fed-
eral judges appointed by Republican presidents.137
       President Trump and his lawyers were well-aware that courts were
consistently rejecting his claims. During a December 18th meeting in the
                                 THE BIG LIE                              213

Oval Office with President Trump, Sidney Powell and others, White House
Senior Advisor Eric Herschmann pointed out that President Trump’s law-
yers had their opportunity to prove their case in court, and failed. Powell
fired back that “the judges are corrupt.” Herschmann responded: “Every
one? Every single case that you’ve done in the country you guys lost, every
one of them is corrupt, even the ones we appointed?” 138
    President Trump was faced with another choice after having his day in
court. He could accept that there was no real evidence of voter fraud, or he
could continue to amplify conspiracy theories and lies. He chose the latter.


1.8 PRESIDENT TRUMP REPEATEDLY PROMOTED CONSPIRACY THEORIES

Instead of accepting his defeat, President Trump attempted to justify his
Big Lie with a series of increasingly preposterous claims. The President was
not simply led astray by those around him. The opposite was true. He
actively promoted conspiracy theories and false election fraud claims even
after being informed they were baseless. Millions of President Trump’s
supporters believed the election was stolen from him. Many of them still
do, but President Trump knew the truth and chose to lie about it.
     The power of the President’s bully pulpit should not be underestimated,
especially in the digital age.139 President Trump’s relentless lying sowed
seeds of distrust in America’s election system. Researchers who studied this
election-denial phenomenon have noted: “President Trump didn’t just
prime his audience to be receptive to false narratives of election fraud—he
inspired them to produce those narratives and then echoed those false
claims back to them.” 140 Social media played a prominent role in amplify-
ing erroneous claims of election fraud. Shortly after election day, the “Stop
the Steal” campaign, discussed more fully in Chapter 6, went viral. “Stop
the Steal” influencers echoed President Trump’s premature declaration of
victory, asserting that he won the election, the Democrats stole it from him,
and it was the responsibility of American “patriots” to combat this sup-
posed injustice.141
     This resulted in what Attorney General Barr has described as an “ava-
lanche” of false claims, as President Trump’s supporters attempted to jus-
tify his “Big Lie.” 142 The post-election allegations of fraud or other
malfeasance were “completely bogus,” “silly” and “usually based on com-
plete misinformation,” Barr explained.143 Nonetheless, many of President
Trump’s supporters wanted to believe them. The stolen election narrative
has proven to be remarkably durable precisely because it is a matter of
belief—not evidence, or reason. Each time a claim was debunked, more
214                               CHAPTER 1




                                                  Photo by Michael Ciaglo/Getty Images


claims emerged in its place. Barr later complained that this dynamic forced
him and others to play “whack-a-mole.” 144
     The United States Department of Justice, under Barr’s leadership and
then Acting Attorney General Jeffrey Rosen, was forced to knock down one
lie after another. As discussed in Chapter 4, Barr took unprecedented steps
to investigate the “avalanche” of lies. Claims of election fraud were referred
to United States Attorney’s offices and the FBI for investigation. Deputy
Attorney General Richard Donoghue tracked dozens of investigations. None
of them were found to have merit.145 The top officials in President Trump’s
Justice Department personally told the President that the claims he was
promoting were false. But that did not matter to the President. As Barr told
the Select Committee, President Trump never showed any “indication of
interest in what the actual facts were.” 146
     For example, on December 27th, Rosen and Donoghue spent approxi-
mately two hours on the phone with President Trump. They debunked a
litany of claims regarding the election, explaining that each had been
investigated and found to be baseless.147 According to Donoghue, President
Trump “had this arsenal of allegations that he wanted to rely on.” Dono-
ghue thought it was necessary to explain to the President “based on actual
investigations, actual witness interviews, actual reviews of documents, that
                                 THE BIG LIE                              215

these allegations simply had no merit.” Donoghue wanted “to cut through
the noise” and be “very blunt” with the President, making it clear “these
allegations were simply not true.” 148
     During their December 27th conversation with President Trump, Rosen
and Donoghue rebutted false claims regarding: suitcases of ballots in Geor-
gia, Dominion’s voting machines in Antrim County, a truckload of ballots in
Pennsylvania, ballots being scanned multiple times, people voting more
than once, dead people voting, Native Americans being paid to vote, and
more votes than voters in particular jurisdictions.149 As the officials
debunked each claim, President Trump “would just roll on to another
one.” 150 Donoghue told President Trump that Federal law enforcement
officials had conducted dozens of investigations and hundreds of inter-
views, and they had concluded that the major allegations were not sup-
ported by the evidence developed.151 Donoghue and Rosen told President
Trump “flat out” that “much of the information he [was] getting [was]
false and/or just not supported by the evidence.” 152 President Trump
responded: “You guys may not be following the internet the way I do.” 153
     The Department of Justice was not alone in trying to contain the Presi-
dent’s conspiracy-mongering. President Trump’s lies were often debunked
in real-time by State authorities, judges, experts, journalists, Federal offi-
cials, and even members of his own legal team. As discussed above, the
President’s campaign team found that there was no significant fraud in the
election. So, the President pushed them aside. The courts rejected nearly
every claim brought by the President’s legal team. Even though courts
rejected the claims as speculative, unsupported and meritless, President
Trump, Rudy Giuliani, and others continued to assert them as truth to
Trump’s followers in speeches, tweets, and podcasts.154
     The burden of refuting the false claims made by President Trump and
his surrogates often fell on State and local officials. For example, in Michi-
gan, the Secretary of State’s office posted thorough and prompt responses
to the claims of election fraud on a “Fact Check” page on its website.155 In
Georgia, the Secretary of State’s office issued news releases and held fre-
quent press conferences in the weeks following the election to respond to
claims of fraud.156 County clerks in the contested States also spoke out pub-
licly to refute allegations. Even as the President undermined the public’s
confidence in how votes are cast and counted, these clerks assured voters
that their elections were secure and they could have confidence in the
results.157 Outside experts also publicly denounced and dismantled the
claims being raised and amplified by President Trump. This was done in the
216                              CHAPTER 1

context of litigation, congressional hearings, and press releases.158 Presi-
dent Trump simply ignored these authoritative sources and continued to
promote false claims that had been soundly discredited.
    Below, the Select Committee presents two case studies demonstrating
how President Trump and his surrogates lied in the face of overwhelming
evidence. The first case study deals with Dominion Voting Systems. Presi-
dent Trump repeatedly claimed that Dominion’s software “switched votes”
and “rigged” the election well after the leaders of campaign and Justice
Department officials told him that these claims were baseless. The Presi-
dent’s smear of Dominion was central to his “Big Lie.”
    The second case study examines video footage recorded in Fulton
County on election night. President Trump and his representatives con-
cocted a fictional narrative based on a deceptively edited version of the
footage. After these two case studies, the Select Committee examines a
variety of other claims the President repeatedly made. Once again, these
claims had no basis in truth.

DOMINION VOTING SYSTEMS
Between election day and January 6th, President Trump repeatedly spread
conspiracy theories about Dominion voting machines. The President
tweeted or retweeted false claims about Dominion more than 30 times.159
He also repeatedly lied about the company’s software during his post-
election speeches and interviews.160 President Trump’s own campaign staff,
administration officials, and State officials, all told him the claims had no
merit. Hand recounts confirmed the fidelity of the machines. But none of
this overwhelming evidence mattered. President Trump demonstrated a
conscious disregard for the facts and continued to maliciously smear
Dominion.
    President Trump’s allies began spreading false claims regarding
Dominion within days of the election. On November 8th, the day after net-
works called the election for Joe Biden, Sidney Powell claimed on Fox News
that Dominion machines “were flipping votes in the computer system or
adding votes that did not exist.” 161 On November 12th, Rudy Giuliani
appeared on Fox News to claim that Dominion was connected to Venezuelan
dictator Hugo Chavez and its software was created “in order to fix elec-
tions.” 162 The same day, President Trump retweeted a “REPORT” claiming
that Dominion had “DELETED 2.7 MILLION TRUMP VOTES NATIONWIDE”
and switched hundreds of thousands of votes in key swing states.163
    By that time, the Trump Campaign team had looked into allegations
regarding Dominion and its software and concluded that the claims were
false. An internal campaign memo, dated November 12, said that Domin-
ion’s software “did not lead to improper vote counts” and cited reports
                                 THE BIG LIE                              217

concluding that, among other things, Dominion machines “Did Not Affect
The Final Vote Count.” 164 The memo also addressed various claims of for-
eign influence regarding Dominion.165 Jason Miller told the Select Commit-
tee that by November 12th he had told President Trump the results of the
analysis of the Dominion claims by the campaign’s internal research team,
specifically telling him “that the international allegations for Dominion
were not valid.” 166 Emails and text messages show that this same analysis
was shared with Mark Meadows, President Trump’s chief of staff.167 White
House Press Secretary Kayleigh McEnany told the Select Committee that
she found herself “waving [President Trump] off of the Dominion theory,”
encouraging him to use more “fact-driven” arguments.168 But it was to no
avail.
    Even though members of the Trump Campaign team reported that the
result of the election was not compromised by any problems with Dominion
machines, the President continued to assail Dominion on Twitter in the
days that followed, for example retweeting a false claim that Dominion’s
machines were “engineered by China, Venezuela, [and] Cuba” and claiming
that Dominion had “[r]igged” the election.169
    Officials in the Trump administration also worked to debunk the false
rumors about vote manipulation. The United States Department of Home-
land Security’s Cybersecurity & Infrastructure Security Agency (CISA)
released a joint statement of election security officials on November 12,
reassuring voters that the election was “the most secure in American his-
tory.” CISA emphasized: “There is no evidence that any voting system
deleted or lost votes, changed votes, or was in any way compromised.” 170
    This was another decision point for the President. He could choose to
endorse the findings of his administration’s own cyber security experts, or
he could continue to promote baseless fictions about Dominion. President
Trump chose the lies. The President and his supporters never did produce
any evidence showing that Dominion’s machines affected the results of the
election. But President Trump was undeterred by the facts. Indeed, the
President and his supporters seized upon a simple human error in a small
Michigan county as their initial pretense for these allegations as well as to
keep the Dominion conspiracy theory alive.
    During the early-morning hours of November 4th, Sheryl Guy, a clerk
in Antrim County, Michigan, reported the unofficial results of the vote
count.171 Guy’s online report was odd. It showed that former Vice President
Biden had somehow won Antrim, a county that is majority-Republican and
President Trump was expected to easily win. Trump’s supporters quickly
pointed to Biden’s improbable win as evidence that Dominion had tampered
with the votes.172 That wasn’t true. Guy had made a mistake in updating the
218                               CHAPTER 1

election counting software after a late addition of a local candidate to the
ballot in some of the county’s precincts, which caused her unofficial counts
to be off when she tallied the votes reported by the various precincts.173
Guy, a Republican, was informed of the odd result and began to investigate
immediately. The result was corrected, and President Trump won Antrim
just as was expected.174
    Within days, local and State officials in Michigan explained to the public
what had happened. On November 7th, the Michigan Secretary of State’s
office issued a detailed description of Guy’s error and assured the public
that the official results were not impacted.175 The Michigan Senate’s Com-
mittee on Oversight, led by Republican Senator Ed McBroom, conducted its
own comprehensive review of the claims related to Antrim County and con-
firmed that the initial reporting error was entirely attributable to an honest
mistake by the county clerk.176
    The mix-up in Antrim County was quickly corrected. A human erred—
not the voting machines. But President Trump used it as a pretext to con-
tinue lying about Dominion.
    On November 12th, the same day CISA released its statement on election
security, President Trump asked Tim Walberg, a Republican Congressman
from Michigan, to “check with key leadership in Michigan’s Legislature as
to how supportive they could be in regards to pushing back on election
irregularities and potential fraud.” 177 That night, President Trump asked
his Acting Secretary of Homeland Security, Chad Wolf, to look into allega-
tions of election irregularities in Michigan.178 The next day, President
Trump’s assistant sent Wolf a letter from Michigan State legislators raising
claims about the election, including an incorrect claim that flawed Domin-
ion software had caused votes to be counted for the wrong candidate.179
    Administration officials quickly knocked down the Dominion claim.
Wolf forwarded the allegations to the leadership of CISA, including CISA
Director Christopher Krebs.180 Krebs provided Wolf with a press release
from the Michigan Secretary of State that debunked the false claim about
Antrim County and Dominion’s software in detail.181 Wolf shared an update
about the information he received from Krebs with White House Chief of
Staff Mark Meadows.182
    On November 17th, Krebs tweeted out a statement issued by the
nation’s leading election scientists that dismissed claims that election sys-
tems had been manipulated as either “unsubstantiated” or “technically
incoherent.” 183 President Trump fired Krebs that same day.184 President
Trump claimed the statement released by Krebs was “highly inaccurate, in
that there were massive improprieties and fraud.” 185 The President had no
evidence for his claim.
                                  THE BIG LIE                               219

    On November 19th, Rudy Giuliani, Sidney Powell, and Jenna Ellis held a
press conference at the Republican National Committee (RNC) headquarters
in Washington, DC. Powell asserted that there was “massive influence of
communist money through Venezuela, Cuba, and likely China in the inter-
ference with our elections here in the United States.” 186 She pointed a fin-
ger at Dominion, claiming its software was “created in Venezuela at the
direction of Hugo Chavez to make sure he never lost an election,” and Giu-
liani echoed her claims.187
    Hope Hicks told the Select Committee how that press conference was
received in the White House. The day after the press conference, President
Trump spoke by phone with Sidney Powell from the Oval Office. During the
call, Powell repeated the same claims of foreign interference in the election
she had made at the press conference. While she was speaking, the Presi-
dent muted his speakerphone and laughed at Powell, telling the others in
the room, “This does sound crazy, doesn’t it?” 188
    A few days later, the Trump Campaign issued a statement claiming
Powell was not part of the Trump Campaign’s legal team.189 But Powell’s
outlandish claims were no different from those President Trump was mak-
ing himself. On November 19th, the same day as Powell’s appearance at the
RNC, President Trump tweeted and retweeted a link to a segment on One
America News Network (OAN) that was captioned, “Dominion-izing the
Vote.” 190 The segment claimed that Dominion had switched votes from
Trump to Biden. OAN featured a supposed cyber expert, Ron Watkins, a key
figure in the QAnon conspiracy movement.191 On his own Twitter account,
Watkins celebrated and thanked his supporters just minutes after President
Trump tweeted the clip, and President Trump went on to share the clip
again several times in the days that followed.192
    Officials inside the Trump administration continued to debunk the
Dominion conspiracy theory, including during in-person meetings with
President Trump. Attorney General Bill Barr met with President Trump
face-to-face on three occasions after the election.193 Barr told the Select
Committee, “every time I was with the President, I raised the machines as
sort of Exhibit A of how irresponsible this was.” 194 During the first of these
meetings, on November 23rd, Barr explained to the President that the con-
spiracy theory about Dominion’s voting machines had “zero basis,” and
was “one of the most disturbing allegations.” Barr stressed that this was
“crazy stuff” and was poisoning Americans’ confidence in the voting sys-
tem for no reason. This “complete nonsense” was “doing [a] great, great
disservice to the country,” Barr said.195
    President Trump ignored Barr’s grave concerns. On November 29th,
President Trump was interviewed by Fox News’ Maria Bartiromo. It was the
220                               CHAPTER 1

President’s first interview since he lost his bid for reelection. He claimed
the election was “rigged” and rife with “theft” and “a total fraud.” 196 He
repeated various conspiracy theories, leading with the claim that Domin-
ion’s voting machines had “glitches,” which he alleged moved “thousands
of votes from my account to Biden’s account.” 197 He claimed that there had
been “big, massive dumps” of votes—a reference to the Red Mirage.198 He
rambled off various other, spurious allegations, including that dead people
voted in significant numbers.199 None of it was true.
     On December 1st, Attorney General Barr met again with President
Trump and told him that “the stuff his people were shoveling out to the
public was bullshit.” 200 Attorney General Barr specifically told President
Trump that the claims about Dominion voting machines were “idiotic
claims.” 201 President Trump was still not dissuaded from continuing the
lie. The day after his meeting with the Attorney General, President Trump
released a video in which he repeated several claims of election fraud,
including a claim that “votes had been wrongly switched from Trump to
Biden” using Dominion voting machines.202
     By early-December, courts had assessed and rejected claims that
Dominion machines were manipulated to affect the outcome of the 2020
election. In Michigan, a Federal judge found that claims, including those
related to fraud due to the use of Dominion voting machines, were based on
“nothing but speculation and conjecture that votes were destroyed, dis-
carded or switched. . . .” 203 In Arizona, a Federal judge dismissed claims that
Dominion machines had deleted, switched, or changed votes.204 But Presi-
dent Trump and his supporters refused to accept denunciations of the fab-
ricated Dominion claims.
     Through December, President Trump and his legal team tried to echo
the Dominion conspiracy theory by claiming to have found evidence that
votes were switched in Antrim County. The clerk’s unintentional error was
fixed weeks earlier and there was no evidence showing that Dominion had
altered the vote tally in Antrim, or anywhere else.205 But President Trump’s
legal team used a case challenging a local marijuana ordinance that had
passed by one vote to gain access to Dominion’s voting machines. An
Antrim County judge issued an order granting the plaintiff’s experts access
to the county’s computer, Dominion voting machines, thumb drives and
memory cards.206 Although the purpose of the order was to allow the plain-
tiff to seek evidence related to his ordinance challenge, it soon became clear
that President Trump’s legal team was behind the effort.207
     An organization named Allied Security Operations Group (“ASOG”), led
by Russell Ramsland, conducted an analysis of Antrim County’s voting
machines and related systems. On December 13th, ASOG released a report
                                 THE BIG LIE                             221

on its findings. The inspection yielded no evidence of vote manipulation.
Still, the report included an unsubstantiated assertion that the Dominion
voting machines used in Antrim County and throughout Michigan were
“purposefully designed with inherent error to create systemic fraud and
influence election results” and that a malicious algorithm was used to
manipulate the results of the 2020 election.208 Documents obtained by the
Select Committee show that President Trump and Vice President Mike
Pence were briefed on ASOG’s findings by Giuliani’s team.209 On December
14th, President Trump widely disseminated the ASOG report and accompa-
nying talking points prepared by Giuliani’s team.210 He also trumpeted the
report on Twitter, writing on December 14th: “WOW. This report shows
massive fraud. Election changing result!” 211
     During a meeting with Attorney General Bill Barr that day, President
Trump claimed the ASOG report was “absolute proof that the Dominion
machines were rigged” and meant he was “going to have a second
term.” 212 Barr told the Select Committee that he believed the ASOG report
was “very amateurish,” its authors lacked “any real qualifications,” and it
failed to provide any supporting information for its sweeping conclusions
about Dominion.213 Barr told President Trump he would look into the
report, but that the DOJ already had a good idea of what happened in
Antrim County and it was human error, not a problem with the machines.214
In any event, Barr promised President Trump they would have a definitive
answer within a couple of days because a hand recount was being con-
ducted.215
     In the ensuing days, as Barr predicted, the ASOG report was swiftly and
soundly criticized by experts within and outside the Trump Administration,
including the Department of Justice and the Department of Homeland
Security.216 The initial analysis of election security experts at the Depart-
ment of Homeland Security was that the ASOG report was “false and mis-
leading” and “demonstrates a callous misunderstanding of the actual
current voting certification process.” 217 Subsequent analyses of the ASOG
report and the underlying data from Antrim County were even more criti-
cal.218 These thorough assessments of the Antrim County data and the ASOG
report demonstrate that virtually every one of the claims that President
Trump and his surrogates made about the report was false.219 ASOG’s
inspection did not reveal any malicious software or algorithms or any other
evidence that the voting machines had been compromised.220
     Most importantly, as Attorney General Barr had promised President
Trump, within days of the release of the ASOG report, a full hand recount of
every ballot cast in Antrim County confirmed the results reported by the
Dominion machines and refuted ASOG’s assertion that an algorithm has
222                               CHAPTER 1

manipulated the vote count.221 Giuliani’s chief investigator, Bernie Kerik,
acknowledged that his team was not able to find any proof that a Dominion
voting machine improperly switched, deleted, or injected votes during the
2020 election.222
    President Trump was not swayed by these basic facts. The President
continued to promote the ASOG report, hounding DOJ to investigate the
matter further. He returned to ASOG’s claims during a December 27th call
with Acting Attorney General Rosen and Acting Deputy Attorney General
Donoghue, citing the report’s claimed error rate of 68 percent in Antrim
County. Donoghue pointed out to the President that the difference between
the computer and hand count was only one vote and that he “cannot and
should not be relying on” ASOG’s fraudulent claim, because it was simply
“not true.” 223
    President Trump’s fixation on Dominion’s voting machines and the
baseless theory that the machines had manipulated votes led to a concerted
effort to gain access to voting machines in States where President Trump
was claiming election fraud. On the evening of December 18th, Powell, Lt.
Gen. Michael Flynn (ret.) and Patrick Byrne met with the President at the
White House. Over several hours, they argued that President Trump had the
authority, under a 2018 executive order, to seize voting machines. Several
administration officials joined the meeting and forcefully rejected this
extreme proposal.224 Multiple lawyers in the White House, including Eric
Herschmann, Derek Lyons, and White House Counsel Pat Cipollone “pushed
back strongly” against the idea of seizing voting machines. Cipollone told
the Select Committee it was a “horrible idea,” which had “no legal
basis,” 225 and he emphasized that he had “seen no evidence of massive
fraud in the election.” 226 White House advisor Eric Herschmann similarly
told the Select Committee that he “never saw any evidence whatsoever” to
sustain the allegations against Dominion.227 National Security Adviser Rob-
ert O’Brien phoned into the December 18th meeting and was asked if he had
seen “any evidence of election fraud in the voting machines or foreign
interference in our voting machines.” O’Brien responded that his team had
“looked into that, and there’s no evidence of it.” 228
    Around the same time, President Trump, Mark Meadows, and Rudy
Giuliani were repeatedly asking the leadership of DHS whether the agency
had authority to seize voting machines, and they were repeatedly told that
DHS has no such unilateral authority.229 Giuliani and Powell were also
engaged in efforts to access voting machines in multiple States with the
assistance of sympathetic local election officials.230 Those efforts turned up
no evidence of any vote manipulation by any Dominion machine, but Presi-
dent Trump continued to press this bogus claim.
                                 THE BIG LIE                             223

    On January 2, 2021, President Trump had a lengthy phone call with
Georgia Secretary of State Brad Raffensperger. The President repeatedly
brought up Dominion’s voting machines, alleging that they were at the
heart of a conspiracy against him.231 Raffensperger was incredulous. “I
don’t believe that you’re really questioning the Dominion machines,”
Raffensperger said. “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 vir-
tually the same result.” 232 In other words, the story in Georgia was the
same as the story in Antrim County, Michigan: Officials performed a hand
recount to put to rest any allegations that Dominion’s machines had
manipulated the vote. But once again, President Trump consciously disre-
garded these basic facts and persisted with his lies.
    During a January 4, 2021, speech in Dalton, Georgia, President Trump
chose to ignore Secretary Raffensperger’s straightforward observations.
The President rhetorically attacked Dominion once again, claiming that a
“crime” had been “committed in this state” and it was “immeasurable.” 233
The President called for an “immediate forensic audit of an appropriate
sampling of Dominion’s voting machines and related equipment.” 234 His
allegations were both false and nonsensical. Georgia had already performed
a statewide hand recount of all ballots.
    President Trump and his allies have never provided any evidence show-
ing that Dominion’s voting software altered votes in the 2020 presidential
election. In fact, some of the most vocal proponents of the Dominion claims
harbored their own misgivings about the claims they were making in public.
For example, Rudy Giuliani repeatedly claimed in public that Dominion vot-
ing machines stole the election, and that foreign countries had interfered in
the election, but the evidence uncovered by the Select Committee reveals
that he did not believe either of those things to be true. Giuliani testified
that he did not believe that voting machines stole the election.235 He also
acknowledged that he had seen no evidence that foreign countries had
interfered in the election or manipulated votes.236
    This testimony is consistent with his lead investigator Bernie Kerik’s
acknowledgment that he had not come across proof that voting machines
were used to switch, delete, or inject votes improperly.237 Christina Bobb,
an attorney who worked with Giuliani, similarly could not point to any evi-
dence of wrongdoing by Dominion.238 Even Sidney Powell, perhaps the
most committed proponent of the Dominion falsehoods, was unable to pro-
vide the Select Committee with any evidence or expert report that demon-
strated that the 2020 election outcome in any State had been altered
through manipulation of voting machines.239 And Powell defended herself
224                               CHAPTER 1

in a defamation suit brought by Dominion by claiming that “no reasonable
person would conclude that her statements were truly statements of
fact.” 240
    By January 6, 2021, President Trump’s claims regarding Dominion had
been debunked time and again. The President knew, or should have known,
that he had no basis for alleging that Dominion’s voting machines had cost
him the election.

THE STATE FARM ARENA VIDEO
President Trump also recklessly promoted allegations that video footage
from a ballot counting center in Fulton County, Georgia, was proof of major
election fraud. He was repeatedly informed that these allegations were
false, but he pressed them anyway.
    On December 3rd, Rudy Giuliani presented State legislators with selec-
tively edited footage of ballots being counted on Election Night at Fulton
County’s State Farm Arena.241 Giuliani misrepresented the video as “a
smoking gun” proving election fraud.242 The President repeatedly claimed
that he would have won Georgia, if not for a supposed conspiracy that
unfolded on election night. President Trump and some of his supporters
alleged that political operatives faked a water main rupture to expel Repub-
lican poll watchers.243 These same operatives then supposedly took illegal
ballots from suitcases hidden under tables and added those ballots to the
official count multiple times over by scanning them more than once.244 Not
one of these allegations was true.
    In a speech on December 5th, President Trump made the false claim
about the State Farm Arena and claimed that “if you just take the crime of
what those Democrat workers were doing . . . [t]hat’s 10 times more than I
need to win this state.” 245 During a December 22nd speech, he played the
same deceptive footage presented by Giuliani several weeks earlier.246
President Trump also repeatedly scapegoated one of these Fulton County
election workers during his January 2nd phone call with Georgia’s Secretary
of State, repeatedly referencing her by name and calling her “a professional
vote scammer and hustler.” 247 It was a malicious smear.
    President Trump was directly notified at least four different times that
the allegations he was making were false. On December 15th, then-Deputy
Attorney General Jeffrey Rosen told him: “It wasn’t a suitcase. It was a bin.
That’s what they use when they’re counting ballots. It’s benign.” 248
Rosen’s deputy, Richard Donoghue, also debunked this claim, including on
a phone call on December 27th and in a meeting in the Oval Office on
December 31st: “I told the President myself . . . several times, in several con-
versations, that these allegations about ballots being smuggled in in a
                                  THE BIG LIE                              225

suitcase and run through the machines several times, it was not true, that
we had looked at it, we looked at the video, we interviewed the witnesses,
and it was not true.” 249
    Likewise, Georgia Secretary of State Brad Raffensperger told President
Trump that his allegations about the video were false. During his January
2nd call with the President, Raffensperger explained that Giuliani’s team
“sliced and diced that video and took it out of context” and that “the events
that transpired are nowhere near what was projected” once one looks at
more complete footage.250 Raffensperger also explained to the President
that his team “did an audit of that, and we proved conclusively that they
were not scanned three times.” 251 Yet, when Raffensperger said he would
send President Trump a link to the television segment, the President
refused: “I don’t care about the link. I don’t need it.” 252
    The actual evidence contradicted all of President Trump’s claims about
what the Fulton County video depicted. For example, the chief investigator
for Raffensperger’s office explained in a December 6th court filing that
“there were no mystery ballots that were brought in from an unknown
location and hidden under tables. . . .” 253 As the investigator noted, the
security footage showed there was nothing under the table when it was
brought into the room. Hours later, with reporters and observers present,
the “video shows ballots that had already been opened but not counted
placed in the boxes, sealed up, [and] stored under the table.” 254 This find-
ing was affirmed by the FBI, DOJ, and the Georgia Bureau of Investigation,
which interviewed witnesses and reviewed the full video footage and
machine data from the site.255
    The ballots in question were not double counted. This was confirmed by
a full hand recount in November, as well as a subsequent review by investi-
gators.256 They found that although one of the workers was shown in the
video scanning certain batches multiple times, this was for a valid reason:
her scanner kept jamming. The investigators confirmed from scanner logs,
as well as the footage, that she only hit the “accept” button once per
batch.257 Investigators also found that staff likely did not tell the observers
to leave, let alone forcefully eject them from the facility.258
    Despite this conclusive evidence and testimony, President Trump con-
tinued to point to the Fulton County video as evidence of a grand con-
spiracy. On January 5th, for instance, President Trump’s executive assistant
emailed a document “from POTUS” to Senator Josh Hawley (R-MO), Sena-
tor Ted Cruz (R-TX), and Representative Jim Jordan (R-OH) that cited
“Suitcase Gate” among the “worst fraud incidents” in Georgia.259
226                                 CHAPTER 1

    During his January 6th speech, President Trump told the crowd that “in
Fulton County, Republican poll watchers were ejected, in some cases,
physically from the room under the false pretense of a pipe burst.” The
President continued:
      . . . 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 for Joe Biden, almost
      none for Donald Trump.260
    No part of President Trump’s story was true. He had already been
informed that it was false.
    In June 2021, when Giuliani’s law license was revoked by a New York
State appellate court, the court’s ruling cited his statements about sup-
posed suitcases of ballots in Georgia as one of its reasons for doing so. “If,
as respondent claims, he reviewed the entire video, he could not have rea-
sonably reached a conclusion that illegal votes were being counted,” the
court’s ruling reads.261
    President Trump's conspiracy-mongering endangered innocent public
servants around the country, including in Fulton County. For example, dur-
ing a December 10, 2020, appearance in Georgia, Giuliani falsely accused
Ruby Freeman and Shaye Moss, two Black public servants shown in the
Fulton County video, of “surreptitiously passing around USB ports as if
they’re vials of heroin or cocaine.” 262 In fact, Moss had been given a ginger
mint by her mother, Freeman.263 As described in Chapter 2, baseless accu-
sations like these forever changed the lives of election workers like Free-
man and Moss. All in service of President Trump's Big Lie.

THE FAKE BALLOT MYTH
The Trump Campaign’s distortion of the State Farm Arena video is just one
example of the “fake ballots” lie. President Trump frequently claimed that
“fake ballots” for Biden were injected into the vote-counting process. To
hear the President tell it, there were truckloads of ballots delivered in the
middle of the night to vote-counting centers and millions more votes were
cast than there were registered voters. Judges, Trump administration offi-
cials, State authorities, and independent election experts found each itera-
tion of the “fake ballot” claim to be just that: fake. The Trump Campaign
and its surrogates brought nine cases that raised some version of a “fake
ballots” claim. Every one of those cases was promptly dismissed.264 For
example, in Costantino v. City of Detroit, a Michigan court ruled that the
plaintiff’s claims regarding forged, backdated and double-counted votes in
                                 THE BIG LIE                              227

Detroit were “incorrect and not credible” and “rife with speculation and
guess-work about sinister motives.” 265
    Many of the fake ballot claims were publicly raised and repeated by
President Trump, but never included in any lawsuit. For example, a truck
driver for the U.S. Postal Service claimed that he delivered hundreds of
thousands of completed ballots from Bethpage, New York to Lancaster,
Pennsylvania.266 President Trump repeated this allegation numerous
times.267 The DOJ and FBI interviewed the relevant witnesses, including the
truck driver, and reviewed the loading manifests. They determined that the
allegation was not true.268 Both Attorney General Barr and his successor,
Jeffrey Rosen, told President Trump this claim was false. But that didn’t
stop the President from repeating it.
    Another alleged “truckload of ballots” was supposedly delivered to the
Detroit counting center at 4:30 a.m. on election night. This truck allegedly
carried 100,000 ballots in garbage cans, wastepaper bins, cardboard boxes,
and shopping baskets.269 A widely circulated video purportedly showed an
unmarked van dropping off ballots, which were then wheeled into the
counting center on a wagon.270 In fact, the only ballot delivery in Detroit
after midnight on election night was an official delivery of 16,000 ballots,
stacked in 45 well-organized trays of approximately 350 ballots each.271
The wagon depicted in the video contained camera equipment being pulled
by a reporter.272 The claim of 100,000 fake ballots being smuggled into the
counting center in the middle of the night is even more ridiculous in light
of the fact that only 174,384 absent voter ballots were recorded in the City
of Detroit in the 2020 election.273 The addition of 100,000 fake ballots to
approximately 74,000 legitimate ballots would certainly have been obvious
to election officials.274
    President Trump also repeatedly claimed that more votes were cast
than there were registered voters in certain States, cities, or precincts. It
was easy to fact-check these allegations and demonstrate they were false.
    For example, in Pennsylvania, approximately nine million people were
registered to vote and approximately 6.8 million votes were cast in the 2020
presidential election.275 Nevertheless, President Trump and his allies made
numerous “more votes than voters” claims in Pennsylvania. Citing 2020
mail-in voting data tweeted by Pennsylvania State Senator Doug Mastriano,
President Trump claimed that 1.1 million ballots had been “created” and
counted improperly.276 In fact, there was no discrepancy in the actual
numbers—Mastriano erroneously compared the 2.6 million mail-in ballots
cast in the November general election to the 1.5 million ballots that were
returned in the June primary election.277
228                                CHAPTER 1

    President Trump also promoted a false claim by a different Pennsylva-
nia legislator that Pennsylvania had 205,000 more votes than voters.278
This claim was based on a flawed comparison by State Representative Frank
Ryan of the votes recorded by State election authorities as having been cast
and those reflected in a separate State registry.279 In fact, the discrepancy
was a result of some counties not yet uploading their official results to the
registry.280 In late-December 2020, Acting Deputy Attorney General Dono-
ghue told President Trump that this allegation was baseless.281 President
Trump kept repeating it anyway.282
    The President and his surrogates made similar false claims concerning
excess votes in Michigan. Many of those claims originated with a grossly
inaccurate affidavit submitted by Russell Ramsland, the person behind the
“very amateurish” and “false and misleading” ASOG report regarding
Dominion voting machines in Antrim County.283 Ramsland claimed in a
similar affidavit filed in Federal court in Georgia that 3,276 precincts in
Michigan had turnout of between 84% and 350%, with 19 precincts report-
ing turnout in excess of 100%.284 Ramsland’s affidavit was widely ridiculed,
in part, because he relied on data for dozens of precincts that are located in
Minnesota, not Michigan.285 Even after he corrected his affidavit to remove
the Minnesota townships, his Michigan data remained wildly off-base.286

THE “MULTIPLE COUNTING OF BALLOTS” FICTION
The President and his surrogates repeatedly claimed that ballots for former
Vice President Biden were counted multiple times.287 These claims origi-
nated when some noticed election officials re-running stacks of ballots
through counting machines. But the allegation is based on a fundamental
misunderstanding of the vote-counting process—it is routine and appro-
priate for election officials to re-scan ballots if they are not properly
scanned and tabulated in the initial effort. In Costantino v. City of Detroit, the
court rejected the “incorrect and not credible” affidavits speculating that
ballots were run through scanners and counted multiple times in favor of
the “more accurate and persuasive explanation of activity” put forward by
the “highly-respected” election official with 40 years of experience.288
    As with other misguided claims of election fraud, the claim that ballots
were counted multiple times disregards the safeguards in the voting pro-
cess. In particular, as noted above, it would certainly have been apparent in
the canvassing process if hundreds of ballots were counted multiple times
in Detroit because the total number of ballots would greatly exceed the
number of voters who voted. But that was not the case.
                                 THE BIG LIE                                229

THE IMAGINARY “DEAD” AND “INELIGIBLE” VOTERS
In addition to their false claims regarding fake ballots, President Trump
and his surrogates also relentlessly asserted that tens of thousands of bal-
lots were cast by dead or otherwise ineligible voters. For example, President
Trump and Giuliani frequently alleged that more than 66,000 unregistered
juveniles voted in Georgia.289 In fact, no underage people voted in Geor-
gia.290 Giuliani offered several different made-up figures of the number of
non-citizens who supposedly voted in Arizona, but provided no evidence to
substantiate his claims.291 In fact, Arizona requires every new voter to pro-
vide proof of citizenship in order to register to vote—or to complete a Fed-
eral voter registration form that requires the individual to sign an
attestation to citizenship status under penalty of perjury—and no person
can vote without being registered.292 By mid-November, Trump Campaign
staff determined this allegation that thousands of non-citizens voted in
Arizona was based on “highly unreliable” information, and it is one of the
false claims that led to Giuliani losing his New York law license.293 These
“ineligible” voters did not exist.
     Nor were thousands of votes cast in the names of dead Americans.
     During his January 2nd, call with Georgia Secretary of State Raffensper-
ger, the President claimed that “close to about 5,000 [dead] voters” cast
ballots in the election. Raffensperger quickly informed the President this
wasn’t true. 294 But the “dead voter” lie wasn’t limited to Georgia. President
Trump wanted Americans to believe that “dead voters” contributed to his
defeat in several battleground States.295
     But even the Trump Campaign and its lawyers recognized early on that
the claims regarding “dead voters” were grossly exaggerated, to say the
least. By early November, Trump lawyers discovered that many people
listed by the campaign as having died were actually alive and well.296 In
early December, Eric Herschmann advised Chief of Staff Meadows by text
message that the Trump legal team had determined that the claim of more
than 10,000 dead people voting in Georgia was not accurate.297 The ensuing
exchange makes clear that both men knew that Giuliani’s claims were
absurd:
   Herschmann: Just an FYI. Alex Cannon and his team verified that
   the 10k+ supposed dead people voting in GA is not accurate
   Meadows: I didn’t hear that claim. It is not accurate. I think I found
   22 if I remember correctly. Two of them died just days before the
   general
   Herschmann: It was alleged in Rudy's hearing today. Your number
   is much closer to what we can prove. I think it's 12
230                                CHAPTER 1

      Meadows: My son found 12 obituaries and 6 other possibles
      depending on the Voter roll acuracy [sic]
      Herschmann: That sounds more like it. Maybe he can help Rudy find
      the other 10k ??
      Meadows: lol 298
    Shortly thereafter, a Georgia court dismissed the claim that there were
tens of thousands of votes cast by ineligible voters, noting the claims “rest
on speculation rather than duly pled facts.” 299
    The Trump Campaign’s own expert on the supposed “dead voters”
admitted that the Campaign lacked the necessary data to make any conclu-
sions about whether any (or how many) votes were cast in the name of a
deceased person.300 State officials did have such data, however, and were
able to conduct the type of matching analysis required. These State authori-
ties determined that there were only a handful of cases in which people
voted on behalf of deceased individuals.301
    Even in those cases where the person who voted actually did die, Presi-
dent Trump’s lawyers knew that the vast majority of the voters included on
their list of dead voters actually cast their votes before they passed.302 In
early-January 2021, just days before January 6th, Republican Senator Lind-
sey Graham asked several Trump lawyers to provide evidence to support the
Campaign’s claims regarding dead voters.303 As Giuliani’s team investi-
gated, they concluded that they could not find evidence of dead voters any-
where near the number that Giuliani and President Trump were claiming
publicly. After noting the shortcomings in their evidence, Katherine Friess,
a lawyer working with the Giuliani legal team, warned that Senator Graham
would “push back” on their evidence.304 As predicted by Friess, Senator
Graham was not impressed by the information provided by Giuliani’s team.
In his speech on the Senate floor on January 6th, Graham explained why he
would not object to the certification of electoral votes. Senator Graham
referred to the failure of the Trump attorneys to provide the evidence he
requested:
      They said there’s 66,000 people in Georgia under 18 voted. How
      many people believe that? I asked, ‘Give me 10.’ Hadn’t had one.
      They said 8,000 felons in prison in Arizona voted. Give me 10.
      Hadn’t gotten one. Does that say there’s—There’s problems in
      every election. I don’t buy this. Enough’s enough. We’ve got to end
      it. 305

   Documents obtained by the Select Committee reveal that President
Trump and his lawyers knew that the claims being made in court about
                                 THE BIG LIE                               231

dead or ineligible voters in Georgia were inaccurate, and the lawyers were
concerned that if the President vouched for those claims in another court
pleading he might be criminally prosecuted. On December 31st, as the law-
yers rushed to file a Federal lawsuit in Georgia, some of the lawyers raised
concerns about the President signing a “verification” under oath that the
allegations regarding voter fraud in Georgia, including claims regarding
dead people voting, were true. As Eastman noted in an email to his col-
leagues on December 31st:

   Although the President signed a verification [regarding the Georgia
   claims] back on Dec. 1, he has since been made aware that some
   of the allegations (and evidence proffered by the experts) has
   been inaccurate. For him to sign a new verification with that
   knowledge . . . would not be accurate. And I have no doubt that an
   aggressive DA or US Atty someplace will go after both the President
   and his lawyers once all the dust settles on this.306
    Despite these concerns, President Trump and his attorneys filed a com-
plaint that incorporated the same inaccurate numbers, and President
Trump signed a verification swearing under oath that the inaccurate num-
bers were “true and correct” or “believed to be true and correct” to the best
of his knowledge and belief.307 A Federal judge reviewing the relevant
emails and pleadings recently concluded:
   The emails show that President Trump knew that the specific num-
   bers of voter fraud were wrong but continued to tout those num-
   bers, both in court and to the public. The Court finds that these
   emails are sufficiently related to and in furtherance of a conspiracy
   to defraud the United States.308


1.9 PRESIDENT TRUMP’S JANUARY 6TH SPEECH

At noon on January 6, 2021, President Trump addressed thousands of his
supporters at a rally just south of the White House. The election had been
decided two months earlier. The courts found there was no evidence of sig-
nificant fraud. The States certified their votes by mid-December. It was
over—President Trump lost. But that’s not what the President told those in
attendance. He delivered an incendiary speech from beginning to end,
arguing that nothing less than the fate of America was at stake.
    “Our country has had enough,” President Trump said. “We will not take
it anymore and that's what this is all about.” 309 He claimed that his follow-
ers had descended on Washington to “save our democracy” and “stop the
232                              CHAPTER 1




                                                  Photo by Samuel Corum/Getty Images


steal.” 310 He refused, once again, to concede. And he proclaimed that
“[t]oday I will lay out just some of the evidence proving that we won this
election and we won it by a landslide.” 311
     For months, President Trump had relentlessly promoted his Big Lie.312
He and his associates manufactured one tale after another to justify it. For
more than an hour on January 6th, the President wove these conspiracy
theories and lies together.313
     By the Select Committee’s assessment, there were more than 100 times
during his speech in which President Trump falsely claimed that either the
election had been stolen from him, or falsely claimed that votes had been
compromised by some specific act of fraud or major procedural violations.
That day, President Trump repeated many of the same lies he had told for
months—even after being informed that many of these claims were false.
He lied about Dominion voting machines in Michigan, suitcases of ballots
in Georgia, more votes than voters in Pennsylvania, votes cast by non-
citizens in Arizona, and dozens of other false claims of election fraud.314
None of those claims were true.
     As explained in the chapters that follow, the Big Lie was central to
President Trump’s plan to stay in power. He used the Big Lie to pressure
                                         THE BIG LIE                                            233

State and local officials to undo the will of the people. His campaign con-
vened fake electors on the baseless pretense that former Vice President
Biden won several States due to fraud or other malfeasance. The President
tried to subvert the Department of Justice by browbeating its leadership to
endorse his election lies. And when the DOJ’s senior personnel did not
acquiesce, President Trump sought to install a loyalist who would.
    When all those efforts failed, President Trump betrayed his own Vice
President. He pressured Vice President Pence to obstruct the joint session of
Congress on January 6th, falsely claiming that he had the power to refuse to
count certain electoral votes. President Trump knew this was illegal but
attempted to justify it with lies about the election.
    On December 19, 2020, President Trump summoned a mob to Washing-
ton, DC on the same day that Congress was set to certify former Vice Presi-
dent Biden’s victory by claiming the election was stolen and promising a
“wild” protest.315
    And the bogus stolen election claim was the focus of President Trump’s
speech on January 6th. The litany of lies he told riled up a mob that would
march to the U.S. Capitol to intimidate Vice President Pence and Members
of Congress.
    “And we fight. We fight like hell. And if you don't fight like hell, you're
not going to have a country anymore,” President Trump told the crowd.316
He incited them with these words just after praising his own election night
lie—the Big Lie.
    President Trump told his followers to “fight” to “save” their country
from a bogus specter of supposed election fraud.317 And many of them did.

ENDNOTES
 1.   “Donald Trump 2020 Election Night Speech Transcript,” Rev, (Nov. 4, 2020), available at
      https://www.rev.com/blog/transcripts/donald-trump-2020-election-night-speech-
      transcript.
 2.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
      scribed Interview of William Stepien, (Feb. 10, 2022), pp. 54, 60.
 3.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Depo-
      sition of Jason Miller, (Feb. 3, 2022), pp. 74-75.
 4.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Depo-
      sition of Jason Miller, (Feb. 3, 2022), pp. 75, 78.
 5.   Documents on file with the Select Committee to Investigate the January 6th Attack on the
      United States Capitol (National Archives Production), 076P-R000010020_0001 (Email chain
      between Tom Fitton and Molly Michael, starting on October 31, 2020, and ending on
      November 3, 2020, discussing a draft victory statement for President Trump).
 6.   We note that Bannon refused to testify and has been convicted of criminal contempt by a
      jury of his peers. See “Stephen K. Bannon Sentenced to Four Months in Prison on Two
      Counts of Contempt of Congress,” Department of Justice, (Oct. 21, 2022), available at
234                                       CHAPTER 1

      https://www.justice.gov/usao-dc/pr/stephen-k-bannon-sentenced-four-months-prison-
      two-counts-contempt-congress; Dan Friedman, "Leaked Audio: Before Election Day, Bannon
      Said Trump Planned to Falsely Claim Victory," Mother Jones, (July 12, 2022), available at
      https://www.motherjones.com/politics/2022/07/leaked-audio-steve-bannon-trump-2020-
      election-declare-victory/.
 7.   At his interview, Stone invoked his Fifth Amendment Right not to incriminate himself,
      including to questions regarding his direct communications with Donald Trump and his
      role on January 6th. Select Committee to Investigate the January 6th Attack on the United
      States Capitol, Business Meeting on the January 6th Investigation, 117th Cong., 2d sess.,
      (Oct. 13, 2022), at 39:15 - 39:33 available at https://www.youtube.com/watch?v=
      IQvuBoLBuC0.
 8.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
      scribed Interview of William Barr, (June 2, 2022), p. 27.
 9.   Jennifer Agiesta and Marshall Cohen, “CNN Poll: Questions about Accuracy of Vote Counting
      Rise as Most Want to Vote before Election Day,” CNN, (Aug. 18, 2020), available at https://
      www.cnn.com/2020/08/18/politics/cnn-poll-trump-biden-election-security-mail-in-voting/
      index.html; Mark Murray, “Biden Leads Trump by 10 points in Final Pre-Election NBC News/
      WSJ poll,” NBC News, (Nov. 1, 2020, updated Nov. 2, 2020), available at https://
      www.nbcnews.com/politics/meet-the-press/biden-leads-trump-10-points-final-pre-
      election-nbc-news-n1245667.
10.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Hear-
      ing on the January 6th Investigation, 117th Cong., 2d sess., (June 13, 2022), available at
      https://www.govinfo.gov/committee/house-january6th.
11.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Hear-
      ing on the January 6th Investigation, 117th Cong., 2d sess., (June 13, 2022), available at
      https://www.govinfo.gov/committee/house-january6th.
12.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
      scribed Interview of William Stepien, (Feb. 10, 2022), p. 44.
13.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
      scribed Interview of William Stepien, (Feb. 10, 2022), pp. 44-45.
14.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Hear-
      ing on the January 6th Investigation, 117th Cong., 2d sess., (June 13, 2022), available at
      https://www.govinfo.gov/committee/house-january6th.
15.   Dan Friedman, “Leaked Audio: Before Election Day, Bannon Said Trump Planned to Falsely
      Claim Victory,” Mother Jones, (July 12, 2022), available at https://www.motherjones.com/
      politics/2022/07/leaked-audio-steve-bannon-trump-2020-election-declare-victory/. During
      our October 13 hearing, Robert Costa tweeted: "CBS News has confirmed that Oct. 31, 2020,
      was a key date in the pre-election maneuvers by Trump. Set off alarm with WH counsel
      and Herschmann, among others. I’ve seen texts from that night from some aides and they
      knew it was no joke; declaring victory was Trump’s plan. Period." Maggie Haberman
      retweeted Costa, writing: "Trump told a conference call of a bunch of lawyers and informal
      advisers working for him earlier that month that he was going to go up and say he won,
      first reported by @jonathanvswan." Robert Costa (@costareports), Twitter, Oct. 13, 2022
      1:29 p.m. ET, available at https://twitter.com/costareports/status/
      1580611586674151424?lang=en; see also Maggie Haberman (@maggieNYT), Twitter, Oct. 13,
      2022 1:35 p.m. ET, available at https://twitter.com/maggienyt/status/1580613143637635072
      (“Trump told a conference call of a bunch of lawyers and informal advisers working for
      him earlier that month that he was going to go up and say he won, first reported by
      @jonathanvswan”).
16.   Dan Friedman, “Leaked Audio: Before Election Day, Bannon Said Trump Planned to Falsely
      Claim Victory,” Mother Jones, (July 12, 2022), available at https://www.motherjones.com/
      politics/2022/07/leaked-audio-steve-bannon-trump-2020-election-declare-victory/.
                                           THE BIG LIE                                           235

17.   Fox Business, “Steve Bannon: Trump Won’t Allow the Election to Be Stolen,” YouTube, at
      3:24, Nov. 3, 2020, available at https://www.youtube.com/watch?v=PDdxoyAUqoo.
18.   “Steve Bannon: Donald Trump Will Claim Victory ‘Right Before the 11 O'clock News’,” Media
      Matters, (Nov. 3, 2020), available at https://www.mediamatters.org/steve-bannon/steve-
      bannon-donald-trump-will-claim-victory-right-11-oclock-news-0.
19.   Documents on file with the Select Committee to Investigate the January 6th Attack on the
      United States Capitol (National Archives Production), 076P-R000010020_0001 (Email chain
      between Tom Fitton and Molly Michael, starting on October 31, 2020, and ending on
      November 3, 2020, discussing a draft victory statement for President Trump).
20.   Documents on file with the Select Committee to Investigate the January 6th Attack on the
      United States Capitol (National Archives Production), 076P-R000010020_0001 (Email chain
      between Tom Fitton and Molly Michael, starting on October 31, 2020, and ending on
      November 3, 2020, discussing a draft victory statement for President Trump).
21.   Documents on file with the Select Committee to Investigate the January 6th Attack on the
      United States Capitol (National Archives Production), 076P-R000010020_0001 (Email chain
      between Tom Fitton and Molly Michael, starting on October 31, 2020, and ending on
      November 3, 2020, discussing a draft victory statement for President Trump).
22.   Documents on file with the Select Committee to Investigate the January 6th Attack on the
      United States Capitol (National Archives Production), 076P-R000010020_0001 (Email chain
      between Tom Fitton and Molly Michael, starting on October 31, 2020, and ending on
      November 3, 2020, discussing a draft victory statement for President Trump).
23.   Documents on file with the Select Committee to Investigate the January 6th Attack on the
      United States Capitol (National Archives Production), 076P-R000010020_0001 (Email chain
      between Tom Fitton and Molly Michael, starting on October 31, 2020, and ending on
      November 3, 2020, discussing a draft victory statement for President Trump).
24.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Busi-
      ness Meeting on the January 6th Investigation, 117th Cong., 2d sess., (Oct. 13, 2022), at 38:18
      - 39:32, available at https://www.youtube.com/watch?v=IQvuBoLBuC0.
25.   Jonathan Swan, “Trump Plans to Declare Premature Victory If He Appears on Election
      Night,” Axios, (Nov. 1, 2020), available at https://www.axios.com/2020/11/01/trump-claim-
      election-victory-ballots.
26.   Jonathan Swan, “Trump Plans to Declare Premature Victory If He Appears on Election
      Night,” Axios, (Nov. 1, 2020), available at https://www.axios.com/2020/11/01/trump-claim-
      election-victory-ballots.
27.   Jonathan Swan, “Trump Plans to Declare Premature Victory If He Appears on Election
      Night,” Axios, (Nov. 1, 2020), available at https://www.axios.com/2020/11/01/trump-claim-
      election-victory-ballots.
28.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Hear-
      ing on the January 6th Investigation, 117th Cong., 2d sess., (June 13, 2022), available at
      https://www.govinfo.gov/committee/house-january6th.
29.   Months prior to the election, Josh Mendelsohn, the CEO of Hawkfish, a Democratic data
      and analytics firm, warned that President Trump would try to take advantage of the Red
      Mirage. See Margaret Talev, “Exclusive: Dem Group Warns of Apparent Trump Election Day
      Landslide,” Axios, (Sept. 1, 2020), available at https://www.axios.com/2020/09/01/
      bloomberg-group-trump-election-night-scenarios. For other accounts warning that elec-
      tion night would see a Red Mirage, see Marshall Cohen, “Deciphering the ‘Red Mirage,’ the
      ‘Blue Shift,’ and the Uncertainty Surrounding Election Results This November,” CNN, (Sept.
      1, 2020), available at https://www.cnn.com/2020/09/01/politics/2020-election-count-red-
      mirage-blue-shift/index.html; Darragh Roche, “Trump Is Heading for a ‘Red Mirage’ Win on
      Election Night, Bloomberg-Funded Data Firm Says,” Newsweek, (Sept. 1, 2020), available at
      https://www.newsweek.com/trump-phantom-win-election-1528948; Tom McCarthy, “‘Red
236                                        CHAPTER 1

      Mirage’: The ‘Insidious’ Scenario If Trump Declares Victory,” The Guardian, (Oct. 31, 2020),
      available at https://www.theguardian.com/us-news/2020/oct/31/red-mirage-trump-
      election-scenario-victory.
30.   “Remarks by President Trump, Vice President Pence, and Members of the Coronavirus Task
      Force in Press Briefing,” White House, April 7, 2020, available at https://
      trumpwhitehouse.archives.gov/briefings-statements/remarks-president-trump-vice-
      president-pence-members-coronavirus-task-force-press-briefing-april-7-2020/.
31.   Donald J. Trump (@realDonaldTrump), Twitter, Apr. 8, 2020 8:20 a.m. ET, available at http://
      web.archive.org/web/20201201162757/https://twitter.com/realDonaldTrump/status/
      1247861952736526336 (archived).
32.   Donald J. Trump (@realDonaldTrump), Twitter, May 24, 2020 10:08 a.m. ET, available at
      http://web.archive.org/web/20200701075716/https://twitter.com/realDonaldTrump/status/
      1264558926021959680 (archived).
33.   Donald J. Trump (@realDonaldTrump), Twitter, Sept. 17, 2020 7:56 a.m. ET, available at
      http://web.archive.org/web/20201115164217/https://twitter.com/realDonaldTrump/status/
      1306562791894122504 (archived).
34.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
      scribed Interview of William Stepien, (Feb. 10, 2022), p. 36; Documents on file with the
      Select Committee to Investigate the January 6th Attack on the United States Capitol,
      (National Archives Production), 076P-R000010941_0001-2, 076P-R000010940_0001-6 (July 23,
      2020, emails regarding scheduling a meeting for the President with McCarthy, Stepien, and
      others).
35.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
      scribed Interview of William Stepien, (Feb. 10, 2022), p. 36.
36.   Fox News, “President Trump Goes One-on-One with Chris Wallace,” YouTube, July 19, 2020,
      available at https://www.youtube.com/watch?v=W6XdpDOH1JA; Pat Ward (@WardDPatrick),
      Twitter, July 19, 2020 10:15 a.m. ET, available at https://twitter.com/WardDPatrick/status/
      1284854318575878144.
37.   “Remarks by President Trump in Press Briefing,” White House, Sept. 23, 2020, available at
      https://trumpwhitehouse.archives.gov/briefings-statements/remarks-president-trump-
      press-briefing-092420/.
38.   “Remarks by President Trump in Press Briefing,” White House, Sept. 23, 2020, available at
      https://trumpwhitehouse.archives.gov/briefings-statements/remarks-president-trump-
      press-briefing-092420/.
39.   Barbara Sprunt, “Trump Questions Election Again after White House Walked Back His Ear-
      lier Remarks,” NPR, (Sept. 24, 2020), available at https://www.npr.org/2020/09/24/
      916440816/republican-leaders-reject-trump-hedging-on-transfer-of-power-amid-war-over-
      confi.
40.   Donald J. Trump (@realDonaldTrump), Twitter, Nov. 4, 2020 12:49 a.m. ET, available at
      http://web.archive.org/web/20201105044240/https://twitter.com/realDonaldTrump/
      status/1323864823680126977 (archived); Donald J. Trump (@realDonaldTrump), Twitter, Nov.
      4, 2020 10:04 a.m. ET, available at http://web.archive.org/web/20201104153504/https://
      twitter.com/realDonaldTrump/status/1324004491612618752 (archived).
41.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
      scribed Interview of William Stepien, (Feb. 10, 2022), pp. 44-45.
42.   “Donald Trump 2020 Election Night Speech Transcript,” Rev, (Nov. 4, 2020), available at
      https://www.rev.com/blog/transcripts/donald-trump-2020-election-night-speech-
      transcript.
                                           THE BIG LIE                                            237

43.   See “Donald Trump 2020 Election Night Speech Transcript,” Rev, (Nov. 4, 2020), available at
      https://www.rev.com/blog/transcripts/donald-trump-2020-election-night-speech-
      transcript; Donald J. Trump (@realDonaldTrump), Twitter, Nov. 4, 2020 12:49 a.m. ET, avail-
      able at http://web.archive.org/web/20201104060648/https://twitter.com/
      realDonaldTrump/status/1323864823680126977 (archived).
44.   Dan Friedman, “Leaked Audio: Before Election Day, Bannon Said Trump Planned to Falsely
      Claim Victory,” Mother Jones, (July 12, 2022), available at https://www.motherjones.com/
      politics/2022/07/leaked-audio-steve-bannon-trump-2020-election-declare-victory/.
45.   Factba.se, “Interview: Maria Bartiromo Interviews Donald Trump on Fox News - November
      29, 2020,” Vimeo, Nov. 29, 2020, at esp. 1:42-3:35, available at https://vimeo.com/485180163;
      Donald J. Trump (@realDonaldTrump), Twitter, Nov. 4, 2020 10:17 a.m. ET, available at
      https://media-cdn.factba.se/realdonaldtrump-twitter/1324007806694023169.jpg (archived);
      Donald J. Trump (@realDonaldTrump), Twitter, Nov. 4, 2020 10:04 a.m. ET, available at
      https://media-cdn.factba.se/realdonaldtrump-twitter/1324004491612618752.jpg (archived);
      Donald J. Trump (@realDonaldTrump), Twitter, Nov. 18, 2020 8:22 p.m. ET, available at
      https://media-cdn.factba.se/realdonaldtrump-twitter/1329233502139715586.jpg (archived);
      Donald J. Trump (@realDonaldTrump), Twitter, Nov. 19, 2020 8:49 p.m. ET, available at
      https://media-cdn.factba.se/realdonaldtrump-twitter/1329602736053252107.jpg (archived).
46.   For example, one widely shared post claimed that, in the early-morning hours of Novem-
      ber 4, hundreds of thousands of mail in ballots were “found” in Wisconsin, Michigan, and
      Pennsylvania, and all of the ballots were for Biden. Nick Adams (@NickAdamsinUSA), Twit-
      ter, Nov. 4, 2020 4:48 p.m., available at https://web.archive.org/web/20201110150437/
      https://twitter.com/NickAdamsinUSA/status/1324151663641448448 (archived).
47.   In many metropolitan areas, absentee ballots are counted in centralized locations and
      reported in batches. For example, the ballots that were supposedly “found” in Wisconsin
      were absentee ballots reported by Milwaukee County when that county completed its tally.
      Of the approximately 181,000 votes reported between 3:26 and 3:44 a.m., Biden received
      approximately 83% of the votes and Trump received approximately 17%. See Eric Litke and
      Madeline Heim, “Fact check: Wisconsin Did Not 'Find' 100K Ballots around 4 a.m. the Morn-
      ing after the Election, or Take Break from Counting Votes,” Milwaukee Journal Sentinel,
      (Nov. 4, 2020), available at https://www.jsonline.com/story/news/politics/elections/2020/
      11/04/wisconsin-didnt-find-ballots-stop-count-voter-fraud-claims-untrue-politifact/
      6165435002/. In Michigan, no ballots were “found” between 3:30-5:00 a.m. Rather,
      approximately 200,000 votes were reported by Wayne County shortly after 6:00 a.m., the
      vast majority of which were for Biden. See Geoffrey Skelley, “Live Bog: 2020 Election
      Results Coverage: Michigan’s Morning Update,” FiveThirtyEight, (Nov. 4, 2020), available at
      https://fivethirtyeight.com/live-blog/2020-election-results-coverage/#294294. Overall,
      Biden won 68% of the vote in Wayne County, to 30% for Trump. However, among absentee
      voters, Biden won 75% to Trump’s 23%. See “November 3, 2020 - General Election Results,”
      Charter County of Wayne, Michigan, available at https://www.waynecounty.com/elected/
      clerk/november-3-2020-general-election-results.aspx.
48.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
      scribed Interview of William Stepien, (Feb. 10, 2022), p. 45; See also John Curiel, Charles
      Stewart III, and Jack Williams, One Shift, Two Shifts, Red Shift, Blue Shifts: Reported Election
      Returns in the 2020 Election, MIT Election Data and Science Lab, (July 9, 2021), p. 40, avail-
      able at https://electionlab.mit.edu/sites/default/files/2021-07/
      curiel_stewart_williams_blue_shift_esra_final.pdf, (detailed analysis of timed reporting
      data shows that “smaller and more rural counties, which favored Trump, could report their
      ballots before the counties with hundreds of precincts and hundreds of thousands of vot-
      ers”).
49.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
      scribed Interview of William Barr, (June 2, 2022), p. 8.
50.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
      scribed Interview of William Barr, (June 2, 2022), p. 8.
238                                       CHAPTER 1

51.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
      scribed Interview of William Stepien, (Feb. 10, 2022), p. 119, 124-26, 174.
52.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
      scribed Interview of William Stepien, (Feb. 10, 2022), p. 174.
53.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Depo-
      sition of Rudy Giuliani, (May 20, 2022), pp. 22–23.
54.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Depo-
      sition of Rudy Giuliani, (May 20, 2022), pp. 23, 26.
55.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Depo-
      sition of Rudy Giuliani, (May 20, 2022), p. 35 (describing Ellis as “a co-counsel” and “my
      number two person” so “generally, if you got an opinion from Jenna, it would be just like
      getting an opinion from me”).
56.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
      scribed Interview of Bernard Kerik, (Jan. 13, 2022), pp. 10, 15–18.
57.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
      scribed Interview of William Stepien, (Feb. 10, 2022), p. 92.
58.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
      scribed Interview of William Stepien, (Feb. 10, 2022), pp. 111–112.
59.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
      scribed Interview of William Stepien, (Feb. 10, 2022), p. 134; Documents on file with the
      Select Committee to Investigate the January 6th Attack on the United States Capitol, (Mark
      Meadows Production), MM007288, (November 13, 2020, email from Bill Stepien to Mark
      Meadows, Justin Clark, and Jason Miller titled “Fwd: AZ Federal ID Voters”).
60.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
      scribed Interview of Alex Cannon, (Apr. 13, 2022), pp. 19–23.
61.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
      scribed Interview of Alex Cannon, (Apr. 13, 2022), pp. 38–39.
62.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
      scribed Interview of Alex Cannon, (Apr. 13, 2022), pp. 33-34.
63.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Depo-
      sition of Jason Miller (Feb. 3, 2022), p. 119.
64.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
      scribed Interview of Matthew Morgan, (Apr. 25, 2022), pp. 117–18.
65.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
      scribed Interview of William Stepien, (Feb. 10, 2022), pp. 112–13.
66.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Depo-
      sition of Jason Miller (Feb. 3, 2022), p. 88–91.
67.   Documents on file with the Select Committee to Investigate the January 6th Attack on the
      United States Capitol (Mark Meadows Production), MM010951-52 (November 3, 2020, Jason
      Miller text message to Mark Meadows at 10:27 pm); Documents on file with the Select Com-
      mittee to Investigate the January 6th Attack on the United States Capitol (Mark Meadows
      Production), MM010972 (November 3, 2020, Jason Miller group text message to Mark Mead-
      ows and David Bossie at 11:53 pm); Documents on file with the Select Committee to Inves-
      tigate the January 6th Attack on the United States Capitol (Mark Meadows Production),
      MM011343 (November 6, 2020, Jason Miller group text message to Mark Meadows, Ivanka
      Trump, Bill Stepien, Hope Hicks, Dan Scavino, and Jared Kushner at 11:10 am).
68.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Depo-
      sition of Jason Miller (Feb. 3, 2022), p. 91.
69.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Depo-
      sition of Jason Miller (Feb. 3, 2022), p. 91.
                                           THE BIG LIE                                           239

70.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
      scribed Interview of William Stepien, (Feb. 10, 2022), pp. 115–17; Brian Slodysko, “Explainer:
      Why AP Called Pennsylvania for Biden,” Associated Press (Nov. 7, 2020), available at
      https://apnews.com/article/ap-called-pennsylvania-joe-biden-why-
      f7dba7b31bd21ec2819a7ac9d2b028d3.
71.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
      scribed Interview of William Stepien, (Feb. 10, 2022), pp. 115–20.
72.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
      scribed Interview of William Stepien, (Feb. 10, 2022), p. 118.
73.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
      scribed Interview of William Stepien, (Feb. 10, 2022), p. 119.
74.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Hear-
      ing on the January 6th Investigation, 117th Cong., 2d sess., (June 13, 2022), available at
      https://www.govinfo.gov/committee/house-january6th.
75.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Hear-
      ing on the January 6th Investigation, 117th Cong., 2d sess., (June 13, 2022), available at
      https://www.govinfo.gov/committee/house-january6th.; Federal Election Commission,
      “Federal Elections 2020 – Election Results for the U.S. President, the U.S. Senate and the
      U.S. House of Representatives,” Oct. 2022, p. 12, available at https://www.fec.gov/
      resources/cms-content/documents/federalelections2020.pdf.
76.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Hear-
      ing on the January 6th Investigation, 117th Cong., 2d sess., (June 13, 2022), available at
      https://www.govinfo.gov/committee/house-january6th.
77.   “Risk-Limiting Audit Report – Georgia Presidential Contest, November 2020,” Georgia Secre-
      tary of State, (Nov. 19, 2020), available at https://sos.ga.gov/sites/default/files/2022-02/
      11.19_.20_risk_limiting_audit_report_memo_1.pdf.
78.   See “Summary of Hand Count Audits – 2020 General Election,” Arizona Secretary of State,
      (Nov. 17, 2020), available at https://azsos.gov/2020-general-election-hand-count-results;
      “Agreed Upon Procedures Report – Evaluation of the Accuracy of Voting Machine Tabula-
      tors Used for the 2020 General Elections Held on November 3, 2020 (Voting System Check),”
      New Mexico Secretary of State, (Dec. 15, 2020), available at https://
      api.realfile.rtsclients.com/PublicFiles/ee3072ab0d43456cb15a51f7d82c77a2/f740346c-7b6b-
      4479-acd6-068829382307/
      2020%20Post%20Election%20Voting%20System%20Check%20Audit%20Results.pdf. Similar
      audits conducted by Michigan, Pennsylvania, and Wisconsin also affirmed the results in
      those states, but their results are excluded from this list because in those instances their
      audit results were not available until after January 6th. Shortly after the election, Nevada
      also conducted some post-election checks that supported the validity of the results there
      too, including testing a sample of the voting machines to make sure votes were accurately
      recorded. Deposition of Joseph Gloria at 33, Law v. Whitmer, No. A-22-858609-W (Nev. Ct.,
      Clark Cty. Dec. 1, 2020), p. 33, available at https://www.democracydocket.com/wp-content/
      uploads/2022/09/2022.10.31-NV-Poll-Worker-Response-to-Application-for-Mandamus-
      STAMPED.pdf; Rex Briggs, “Trump Supporters Asked me to Look into Voter Fraud in Nevada;
      What I found Debunked What They were Alleging,” Nevada Independent, (Dec. 22, 2020),
      available at https://thenevadaindependent.com/article/trump-supporters-asked-me-to-
      look-into-voter-fraud-in-nevada-what-i-found-debunked-what-they-were-alleging.
79.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Hear-
      ing on the January 6th Investigation, 117th Cong., 2d sess., (June 13, 2022), available at
      https://www.govinfo.gov/committee/house-january6th.
80.   Documents on file with the Select Committee to Investigate the January 6th Attack on the
      United States Capitol (Jared Kushner Production), JK_00115, JK00117-132 (November 12, 2020,
      email from Matt Oczkowski, and attached analysis of battleground states).
240                                        CHAPTER 1

81.   Documents on file with the Select Committee to Investigate the January 6th Attack on the
      United States Capitol (Jared Kushner Production), JK_00115, JK_00117-132 (November 12,
      2020, email from Matt Oczkowski, and attached analysis of battleground states).
82.   Documents on file with the Select Committee to Investigate the January 6th Attack on the
      United States Capitol (Jared Kushner Production), JK_00115, JK_00117-132 (November 12,
      2020, email from Matt Oczkowski, and attached analysis of battleground states).
83.   Documents on file with the Select Committee to Investigate the January 6th Attack on the
      United States Capitol (Jared Kushner Production), JK_00115, JK_00117-132 (November 12,
      2020, email from Matt Oczkowski, and attached analysis of battleground states).
84.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Depo-
      sition of Rudolph Giuliani (May 20, 2022), pp. 22-23.
85.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Depo-
      sition of Rudolph Giuliani (May 20, 2022), pp. 22-23.
86.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Depo-
      sition of Rudolph Giuliani (May 20, 2022), pp. 22-23.
87.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
      scribed Interview of William Stepien, (Feb. 10, 2022), pp. 106-107. Sidney Powell and Jenna
      Ellis accompanied Giuliani. The campaign was represented by Jared Kushner, Bill Stepien,
      David Bossie (a former senior official on President Trump’s 2016 campaign), Derek Lyons,
      and Justin Clark. See Select Committee to Investigate the January 6th Attack on the United
      States Capitol, Transcribed Interview of Jared Kushner, (Mar. 31, 2022), pp. 50-51; Select
      Committee to Investigate the January 6th Attack on the United States Capitol, Transcribed
      Interview of Derek Lyons, (Mar. 17, 2022), pp. 64-65. Eric Herschmann also arrived at the
      campaign headquarters as the meeting was underway. See Select Committee to Investigate
      the January 6th Attack on the United States Capitol, Transcribed Interview of Eric Her-
      schmann, (Mar. 17, 2022), pp. 160-61.
88.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
      scribed Interview of William Stepien, (Feb. 10, 2022), p. 109.
89.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
      scribed Interview of William Stepien, (Feb. 10, 2022), p. 109.
90.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
      scribed Interview of William Stepien, (Feb. 10, 2022), p. 107.
91.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
      scribed Interview of Justin Clark, (May 17, 2022), p. 63; Select Committee to Investigate the
      January 6th Attack on the United States Capitol, Transcribed Interview of Matthew Morgan,
      (Apr. 25, 2022), pp. 34-35.
92.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
      scribed Interview of Matthew Morgan, (Apr. 25, 2022), pp. 14-16.
93.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
      scribed Interview of Matthew Morgan, (Apr. 25, 2022), p. 14-16.
94.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
      scribed Interview of Matthew Morgan, (Apr. 25, 2022), p. 41.
95.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
      scribed Interview of Justin Clark, (May 17, 2022), p. 63.
96.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
      scribed Interview of Matthew Morgan, (Apr. 25, 2022), pp. 34-35, 41-42.
97.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
      scribed Interview of Matthew Morgan, (Apr. 25, 2022), p. 41.
98.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
      scribed Interview of Justin Clark, (May 17, 2022), p. 63.
                                             THE BIG LIE                                             241

 99.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
       scribed Interview of Justin Clark, (May 17, 2022), p. 63.
100.   “Rudy Giuliani Trump Campaign Philadelphia Press Conference at Four Seasons Total Land-
       scaping,” Rev, (Nov. 7, 2020), available at https://www.rev.com/blog/transcripts/rudy-
       giuliani-trump-campaign-philadelphia-press-conference-november-7.
101.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
       scribed Interview of Bernard Kerik, (Jan. 13, 2022), pp. 30-32.
102.   “Memorandum from Attorney General William Barr on Post-Voting Election Irregularity
       Inquiries to the United States Attorneys, to the Assistant Attorneys General for the Crimi-
       nal Division, Civil Rights Division, and National Security Division, and to the Director of the
       Federal Bureau of Investigation,” Department of Justice, (Nov. 9, 2020), available at https://
       www.documentcloud.org/documents/20403358-william-barr-election-memo-november-9.
       Longstanding DOJ policy had been not to conduct such investigations prior to certification
       to avoid impacting election results. See Federal Prosecution of Election Offenses, 8th ed.
       Department of Justice, December 2017, at 84, available at https://www.justice.gov/
       criminal/file/1029066/download.
103.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
       scribed Interview of Justin Clark, (May 17, 2022), pp. 66-67; Mike Pence, So Help Me God,
       (New York: Simon & Schuster, 2022), at pp. 431-432.
104.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
       scribed Interview of Justin Clark, (May 17, 2022), pp. 66-67.
105.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
       scribed Interview of Justin Clark, (May 17, 2022), p. 67; Mike Pence, So Help Me God, (New
       York: Simon & Schuster, 2022), at pp. 431.
106.   See Donald J. Trump (@realDonaldTrump), Twitter, Nov. 15, 2020 7:11 p.m. ET, available at
       http://web.archive.org/web/20201117115935/https://twitter.com/realDonaldTrump/status/
       1327811527123103746 (archived).
107.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
       scribed Interview of Matthew Morgan, (Apr. 25, 2022), pp. 37-38.
108.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
       scribed Interview of William Stepien, (Feb. 10, 2022), pp. 174-175.
109.   Documents on file with the Select Committee to Investigate the January 6th Attack on the
       United States Capitol, (Mark Meadows Production), MM007112 (Nov. 14, 2020 email from
       Jason Miller to Bill Stepien, Justin Clark, David Bossie, Mark Meadows, and Jared Kushner
       describing Rudy Giuliani's surrogate briefing).
110.   Documents on file with the Select Committee to Investigate the January 6th Attack on the
       United States Capitol, (Mark Meadows Production), MM007112 (Nov. 14, 2020 email from
       Jason Miller to Bill Stepien, Justin Clark, David Bossie, Mark Meadows, and Jared Kushner
       describing Rudy Giuliani's surrogate briefing).
111.   Documents on file with the Select Committee to Investigate the January 6th Attack on the
       United States Capitol, (Mark Meadows Production), MM007112 (Nov. 14, 2020 email from
       Jason Miller to Bill Stepien, Justin Clark, David Bossie, Mark Meadows, and Jared Kushner
       describing Rudy Giuliani's surrogate briefing).
112.   Factba.se, “Interview: Brian Kilmeade of Fox News Interviews Donald Trump - December 13,
       2020,” Vimeo, at 7:47, Dec. 13, 2020, available at https://vimeo.com/490517184.
113.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Hear-
       ing on the January 6th Investigation, 117th Cong., 2d sess., (June 13, 2022), available at
       https://www.govinfo.gov/committee/house-january6th.
114.   Select Committee staff analyzed the lawsuits. See also, Brendan Williams, Did President
       Trump’s 2020 Election Litigation Kill Rule 11?, 30 Pub. Interest L. J. 181, 189 (2021), available
       at https://www.bu.edu/pilj/files/2021/06/Williams.pdf.
242                                          CHAPTER 1

115.   The only case that involved a victory for the campaign was the Pennsylvania case of Trump
       v. Boockvar. In that case, the court found that the Pennsylvania Secretary of State could
       not extend the deadline for voters to cure their failure to provide proper identification for
       absentee ballots. This decision affected just a few thousand votes, which were not
       included in any tallies. Trump v. Boockvar, No. 602 MD 2020 (Pa. Commw. Ct. Nov. 12, 2020),
       available at https://www.democracydocket.com/wp-content/uploads/2020/11/602-MD-20-
       1.pdf.
116.   See John Danforth, Benjamin Ginsberg, Thomas B. Griffith, et al., Lost, Not Stolen: The Con-
       servative Case that Trump Lost and Biden Won the 2020 Presidential Election, (July 2022), p.
       3, available at https://lostnotstolen.org/download/378/.
117.   Complaint at 2, Bowyer v. Ducey, 506 F. Supp. 3d 699 (D. Ariz. Dec. 2, 2020) (No. 2:20-cv-
       02321), ECF No. 1.
118.   Bowyer v. Ducey, 506 F. Supp. 3d 699, 706, 723 (D. Ariz. 2020).
119.   Minute Entry and Order at 6-9, Ward v. Jackson, No. CV2020-015285 (Az. Sup. Ct. Dec. 4,
       2020).
120.   See Ward v. Jackson, No. CV-20-0343-AP, 2020 Ariz. LEXIS 313, at *6 (Ariz. 2020), also avail-
       able at https://www.clerkofcourt.maricopa.gov/home/showpublisheddocument/1984/
       637437053596970000; Howard Fischer, “State Supreme Court rejects GOP bid to void
       election,” Arizona Capitol Times, (Dec. 8, 2020), available at https://azcapitoltimes.com/
       news/2020/12/08/federal-judge-hears-arguments-in-election-challenge/; “Meet the Jus-
       tices,” Arizona Judicial Branch, (Dec. 8, 2020), available at http://web.archive.org/web/
       20201208032900/https://www.azcourts.gov/meetthejustices/ (archived); “Brutinel Elected
       as Next Arizona Supreme Court Chief Justice,” Associated Press, (Nov. 20, 2018), available at
       https://apnews.com/article/27b725d44d384e2cb7a0e491ac82fe7f; Bob Christie, “Ducey
       Names 2 to New Arizona Supreme Court Seats,” Associated Press, (Nov. 28, 2016), available
       at https://apnews.com/article/26fc7f154b0e4b4fb358987941ded8d0; “Arizona Governor
       Appoints New Supreme Court Justice,” Associated Press, (Apr. 26, 2019), available at
       https://apnews.com/article/4ce4bf1d79724c03b1d4cf36f4b97cf1; Jonathan J. Cooper, “Ducey
       Appoints Montgomery to Arizona Supreme Court," Associated Press, (Sep. 4, 2019), available
       at https://apnews.com/article/bac43d42185c4b8bb9e8c465a59792c8.
121.   Complaint at 1-2, Boland v. Raffensperger, No. 2020CV343018 (Ga. Super. Ct. Nov. 30, 2020),
       available at https://electioncases.osu.edu/wp-content/uploads/2020/11/Boland-v-
       Raffensperger-Complaint.pdf.
122.   Final Order at 5-6, Boland v. Raffensperger, No. No. 2020CV343018 (Ga. Super. Ct. Dec. 8,
       2020), available at https://electioncases.osu.edu/wp-content/uploads/2020/11/Boland-v-
       Raffensperger-Order-Dismissing-Complaint.pdf.
123.   Order Denying Appeal, Boland v. Raffensperger, No. S21M0565 (Ga. Dec. 14, 2020), available
       at https://electioncases.osu.edu/wp-content/uploads/2020/11/Boland-v-Raffensperger-
       GA-SC-Order-Denying-Appeal.pdf; Jonathan Ringel, “Deal Picks Krause, Richardson for Ful-
       ton Superior,” Law.com, (Dec. 28, 2018), available at https://www.law.com/
       dailyreportonline/2018/12/28/deal-picks-krause-richardson-for-fulton-superior/; “Chief
       Justice Harold D. Melton,” Supreme Court of Georgia, (Oct. 16, 2020), available at http://
       web.archive.org/web/20201016174745/https://www.gasupreme.us/court-information/
       biographies/justice-harold-d-melton/ (archived); “Presiding Justice David E. Nahmias,”
       Supreme Court of Georgia, (Nov. 20, 2020), available at http://web.archive.org/web/
       20201120204518/https://www.gasupreme.us/court-information/biographies/justice-david-
       e-nahmias/ (archived); “Chief Justice Michael P. Boggs,” Supreme Court of Georgia, (last
       accessed Dec. 3, 2022), available at https://www.gasupreme.us/court-information/
       biographies/justice-michael-p-boggs/; “Presiding Justice Nels S.D. Peterson,” Supreme
       Court of Georgia, (last accessed Dec. 3, 2022), available at https://www.gasupreme.us/
       court-information/biographies/justice-nels-s-d-peterson/; “Justice Sarah Hawkins Warren,”
       Supreme Court of Georgia, (last accessed Dec. 3, 2022), available at https://
       www.gasupreme.us/court-information/biographies/justice-sarah-hawkins-warren/; “Justice
       Charles J. Bethel,” Supreme Court of Georgia, (last accessed Dec. 3, 2022), available at
                                            THE BIG LIE                                          243

       https://www.gasupreme.us/court-information/biographies/justice-charles-j-bethel/; “Jus-
       tice Carla Wong McMillian,” Supreme Court of Georgia, (last accessed Dec. 3, 2022), avail-
       able at https://www.gasupreme.us/court-information/biographies/justice-carla-wong-
       mcmillian/.
124.   Wood v. Raffensperger, 501 F. Supp. 3d 1310, 1317, 1327, 1331 (N.D. Ga. 2020).
125.   Wood v. Raffensperger, 501 F. Supp. 3d 1310, 1327 (N.D. Ga. 2020).
126.   Complaint for Declaratory, Emergency, and Permanent Injunctive Relief, King v. Whitmer,
       Case No. 2:20-cv-13134-LVP-RSW, (E.D. Mich. Nov. 25, 2020), ECF No. 1; King v. Whitmer, 505 F.
       Supp. 3d 720, 738 (E.D. Mich. 2020). In a subsequent decision, the judge called the case “a
       historic and profound abuse of the judicial process” and sanctioned the attorneys who
       filed the lawsuit King v. Whitmer, 556 F. Supp. 3d 680, 688-89 (E.D. Mich. 2021).
127.   Opinion and Order at 1, 4, Stoddard v. City Election Commission, No. 20-014604-CZ, (Mich.
       Cty. Cir. Ct. Nov. 6, 2020), available at https://www.michigan.gov/-/media/Project/
       Websites/AG/releases/2020/november/
       Stoddard_et_al_v_City_Election_Commission_et_al_-_11-06-2020.pdf?rev=
       2fa32f93caa94365a1ee8c1c492a4e75.
128.   Opinion and Order at 12-13, Costantino v. Detroit, No. 20-014780-AW, (Mich. Cty. Cir. Ct. Nov.
       13, 2020), available at https://electioncases.osu.edu/wp-content/uploads/2020/11/
       Costantino-v-Detroit-Opinion-and-Order.pdf.
129.   Law v. Whitmer, No. 10 OC 00163 1B, 2020 Nev. Unpub. LEXIS 1160, at *1, 29-31, 33, 48-49, 52,
       54 (Nev. Dec. 8, 2020), available at https://casetext.com/case/law-v-whitmer-1 (attaching
       and affirming lower court decision).
130.   Law v. Whitmer, No. 10 OC 00163 1B, 2020 Nev. Unpub. LEXIS 1160, at *3-4 (Nev. Dec. 8,
       2020), available at https://casetext.com/case/law-v-whitmer-1 (attaching and affirming
       lower court decision).
131.   Donald J. Trump for President v. Boockvar, 502 F. Supp. 3d 899, 906 (M.D. Pa. 2020).
132.   Donald J. Trump for President v. Boockvar, 803 Fed. App'x. 377, 381 (M.D. Pa. 2020).
133.   “Eleven Nominations Sent to the Senate Today,” Trump White House Archives, (June 19,
       2017), available at https://trumpwhitehouse.archives.gov/presidential-actions/eleven-
       nominations-sent-senate-today-3/.
134.   Complaint at 72, Trump v. Wisconsin Election Commission, 506 F. Supp. 3d 620 (E.D. Wis.
       2020) (No. 2:20-cv-01785), ECF No. 1; Trump v. Wisconsin Election Commission, 506 F. Supp.
       3d 620, 625 (E.D. Wis. 2020) (dismissing case with prejudice).
135.   Trump v. Wisconsin Election Commission, 506 F. Supp. 3d 620, 637-39 (E.D. Wis. 2020).
136.   Trump v. Wisconsin Election Commission, 983 F.3d 919, 922 (7th Cir. 2020); Bill Glauber, “Fed-
       eral Appeals Court Turns Down Donald Trump Push to Overturn Election Results in Wiscon-
       sin,” Milwaukee Journal Sentinel, (Dec. 24, 2020), available at https://www.jsonline.com/
       story/news/politics/elections/2020/12/24/federal-appeals-court-rejects-trump-bid-
       overturn-wisconsin-results/4043650001/.
137.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Hear-
       ing on the January 6th Investigation, 117th Cong., 2d sess., (June 23, 2022), available at
       https://www.govinfo.gov/committee/house-january6th.
138.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
       scribed Interview of Eric Herschmann, (Apr. 6, 2022), pp. 170-71.
139.   For example, Select Committee data analysts found that certain legacy media networks
       played a role in promoting false claims of voter fraud and other election conspiracies. See
       Staff Memorandum from Select Committee to Investigate the January 6th Attack on the
       United States Capitol Data Analysts, "Legacy Media Analysis," (Dec. 3, 2022).
244                                         CHAPTER 1

140.   Center for an Informed Public, Digital Forensic Research Lab, Graphika, & Stanford Internet
       Observatory, The Long Fuse: Misinformation and the 2020 Election, (Jun. 15, 2021), p. 173,
       available at https://stacks.stanford.edu/file/druid:tr171zs0069/EIP-Final-Report.pdf.
141.   Center for an Informed Public, Digital Forensic Research Lab, Graphika, & Stanford Internet
       Observatory, The Long Fuse: Misinformation and the 2020 Election, (Jun. 15, 2021), p. 82,
       available at https://stacks.stanford.edu/file/druid:tr171zs0069/EIP-Final-Report.pdf.
142.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
       scribed Interview of William Barr, (June 2, 2022), p. 9.
143.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
       scribed Interview of William Barr, (June 2, 2022), p. 10.
144.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
       scribed Interview of William Barr, (June 2, 2022), p. 9; Select Committee to Investigate the
       January 6th Attack on the United States Capitol, Transcribed Interview of Richard Peter
       Donoghue, (Oct. 1, 2021), p. 67.
145.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
       scribed Interview of Richard Peter Donoghue, (Oct. 1, 2021) pp. 59-60.
146.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
       scribed Interview of William Barr, (June 2, 2022), pp. 36-37.
147.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Hear-
       ing on the January 6th Investigation, 117th Cong., 2d sess., (June 23, 2022), available at
       https://www.govinfo.gov/committee/house-january6th.
148.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Hear-
       ing on the January 6th Investigation, 117th Cong., 2d sess., (June 23, 2022), available at
       https://www.govinfo.gov/committee/house-january6th; see also Select Committee to
       Investigate the January 6th Attack on the United States Capitol, Transcribed Interview of
       Jeffrey Rosen, (Oct. 13, 2022), p. 60.
149.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
       scribed Interview of Richard Peter Donoghue, (Oct. 1, 2021), pp. 60-61, 63-64.
150.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
       scribed Interview of Richard Peter Donoghue, (Oct. 1, 2021), pp. 53, 67.
151.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
       scribed Interview of Richard Peter Donoghue, (Oct. 1, 2021), pp. 59-60.
152.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
       scribed Interview of Richard Peter Donoghue, (Oct. 1, 2021), pp. 61-62.
153.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
       scribed Interview of Richard Peter Donoghue, (Oct. 1, 2021), pp. 54-55.
154.   See, e.g., “Transcript of Trump’s Speech at Rally Before US Capitol Riot,” Associated Press,
       (Jan. 13, 2021), available at https://apnews.com/article/election-2020-joe-biden-donald-
       trump-capitol-siege-media-e79eb5164613d6718e9f4502eb471f27; Law v. Whitmer, No. 10 OC
       00163 1B, 2020 Nev. Unpub. LEXIS 1160, at *3-4 (Nev. Dec. 8, 2020), available at https://
       casetext.com/case/law-v-whitmer-1 (attaching and affirming lower court decision); Donald
       J. Trump for President v. Boockvar, 502 F. Supp. 3d 899, 906 (M.D. Pa. 2020); Wood v. Raffen-
       sperger, 501 F. Supp. 3d 1310, 1317, 1327, 1331 (N.D. Ga. 2020); Donald J. Trump (@realDon-
       aldTrump), Twitter, Dec. 26, 6:23 a.m. ET, available at http://web.archive.org/web/
       20201228020228/https://twitter.com/realDonaldTrump/status/1342974373632876545
       (archived); Rudy Giuliani’s Common Sense, “WATCH this BEFORE January 6th | Rudy Giu-
       liani’s Common Sense | Ep. 100,” Rumble, at 29:30, available at https://rumble.com/
       embed/vcrv8j/?pub=4.
155.   “Fact Checks,” Michigan Department of State, (last accessed on Dec. 3, 2022), available at
       https://www.michigan.gov/sos/faqs/elections-and-campaign-finance/fact-checks.
                                           THE BIG LIE                                           245

156.   See, e.g., “Secretary of State's Office Debunks Ware County Voting Machine Story,” Georgia
       Secretary of State, (Dec. 7, 2020), available at https://sos.ga.gov/news/secretary-states-
       office-debunks-ware-county-voting-machine-story; “News Conference on Georgia Vote
       Count,” C-SPAN, Nov. 9, 2020, available at https://www.c-span.org/video/?477943-1/news-
       conference-georgia-vote-count; “Georgia Election Security,” C-SPAN, Jan. 4, 2021, available
       at https://www.c-span.org/video/?507710-1/georgia-election-official-refutes-president-
       trumps-voter-fraud-allegations.
157.   See, e.g., PBS NewsHour, "WATCH: Wisconsin Elections Commission Gives Vote Counting
       Update,” YouTube, Nov. 4, 2020, available at https://www.youtube.com/watch?v=
       Yg5liyyrObc.
158.   See, e.g., Declaration of Charles Stewart III, Trump v. Raffensperger, No. 2020CV33255 (Ga.
       Super. Ct. filed Dec. 14, 2020) (expert declaration of political scientist at MIT); Examining
       Irregularities in the 2020 Election Before the S. Comm. on Homeland Security and Govern-
       mental Affairs, 116th Cong. (Dec. 16, 2020) (statement of Chris Krebs, former Director of the
       Cybersecurity and Infrastructure Security Agency); “Scientists Say No Credible Evidence of
       Computer Fraud in the 2020 Election Outcome, But Policymakers Must Work with Experts to
       Improve Confidence,” Matt Blaze's Exhaustive Search, (Nov. 16, 2020), available at https://
       www.mattblaze.org/blog/election-letter/.
159.   Search results for “Dominion,” Trump Twitter Archive V2, (last accessed Dec. 12, 2022),
       available at https://www.thetrumparchive.com/?searchbox=%22dominion%22.
160.   See, e.g., “Remarks by President Trump During Thanksgiving Video Teleconference with
       Members of the Military,” Trump White House archives, (Nov. 27, 2020), available at
       https://trumpwhitehouse.archives.gov/briefings-statements/remarks-president-trump-
       thanksgiving-video-teleconference-members-military/; Factba.se, “Interview: Maria Bar-
       tiromo Interviews Donald Trump on Fox News – November 29, 2020,” Vimeo, Nov. 29, 2020,
       available at https://factba.se/trump/transcript/donald-trump-interview-fox-news-sunday-
       morning-futures-maria-bartiromo-november-29-2020; “Donald Trump Speech on Election
       Fraud Claims Transcript December 2,” Rev, (Dec. 2, 2020), available at https://
       www.rev.com/blog/transcripts/donald-trump-speech-on-election-fraud-claims-transcript-
       december-2; Factba.se, “Donald Trump Vlog: Contesting Election Results – December 22,
       2020,” (Dec. 22, 2020), available at https://factba.se/transcript/donald-trump-vlog-
       contesting-election-results-december-22-2020; “Donald Trump Rally Speech Transcript Dal-
       ton, Georgia: Senate Runoff Election,” Rev, (Jan. 4, 2021), available at https://www.rev.com/
       blog/transcripts/donald-trump-rally-speech-transcript-dalton-georgia-senate-runoff-
       election; “Transcript of Trump’s Speech at Rally Before US Capitol Riot,” Associated Press,
       (Jan. 13, 2021), available at https://apnews.com/article/election-2020-joe-biden-donald-
       trump-capitol-siege-media-e79eb5164613d6718e9f4502eb471f27.
161.   J.M. Rieger, “The False Claims from Fox News and Trump Allies Cited in Dominion’s $1.6 Bil-
       lion Lawsuit,” Washington Post, (Mar. 26, 2021), available at https://
       www.washingtonpost.com/politics/2021/03/26/fox-trump-election-dominion/.
162.   Elahe Izadi and Sarah Ellison, “Fox News Has Dropped ‘Lou Dobbs Tonight,’ Promoter of
       Trump’s False Election Fraud Claims,” Washington Post, (Feb. 5, 2021), available at https://
       www.washingtonpost.com/media/2021/02/05/lou-dobbs-canceled-fox/; 60 Minutes,
       “Dominion Voting Systems and the Baseless Conspiracy Theories about the 2020 Election |
       60 Minutes,” YouTube, at 2:12 – 3:20, (Oct. 23, 2022), at 2:12-2:51, available at https://
       youtu.be/492jILlPtlA?t=132.
163.   Donald J. Trump (@realDonaldTrump), Twitter, Nov. 12, 2020 11:34 a.m. ET, available at
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       1326926226888544256 (archived).
164.   Documents on file with the Select Committee to Investigate the January 6th Attack on the
       United States Capitol (Zach Parkinson Production), Parkinson0388-0407 (Internal Trump
       Campaign memo dated November 12, 2020); Select Committee to Investigate the January
       6th Attack on the United States Capitol, Deposition of Andrew Zachary “Zach” Parkinson,
       (May 18, 2022), pp. 46-47.
246                                         CHAPTER 1

165.   Documents on file with the Select Committee to Investigate the January 6th Attack on the
       United States Capitol (Zach Parkinson Production), Parkinson0388-0407 (Internal Trump
       Campaign memo dated November 12, 2020).
166.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Depo-
       sition of Jason Miller, (Feb. 3, 2022), pp. 117, 133.
167.   Documents on file with the Select Committee to Investigate the January 6th Attack on the
       United States Capitol (Mark Meadows Production), MM007666, MM007669 (November 12,
       2020, email and attachment from Jason Miller to Mark Meadows transmitting abridged and
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       Investigate the January 6th Attack on the United States Capitol (Mark Meadows Produc-
       tion), MM011902, MM011974 (Nov. 12 and 13, 2020 text messages from Jason Miller to Mark
       Meadows discussing the investigation into Dominion and the lack of evidence of foreign
       interference).
168.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Depo-
       sition of Kayleigh McEnany, (Jan. 12, 2022), pp. 143, 291.
169.   Donald J. Trump (@realDonaldTrump), Twitter, Nov. 16, 2020 8:22 a.m. ET, available at
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       (archived); Donald J. Trump (@realDonaldTrump), Twitter, Nov. 16, 2020 8:26 a.m. ET, avail-
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170.   “Joint Statement from Elections Infrastructure Government Coordinating Council & the
       Election Infrastructure Sector Coordinating Executive Committees,” Department of Home-
       land Security's Cybersecurity & Infrastructure Security Agency, (Nov. 12, 2020), available at
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       government-coordinating-council-election.
171.   Mark Bowden and Matthew Teague, “How a County Clerk in Michigan Found Herself at the
       Center of Trump’s Attempt to Overthrow the Election,” Time, (Dec. 15, 2021), available at
       https://time.com/6128812/the-steal-antrim-county-michigan/; Emma Brown, Aaron C.
       Davis, Jon Swaine, and Josh Dawsey, “The Making of a Myth,” Washington Post, (May 9,
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       trump-election-fraud-texas-businessman-ramsland-asog/.
172.   Steven Nelson, “Michigan Republicans Claim Software Issue Undercounted Trump Votes,”
       New York Post, (Nov. 6, 2020), available at https://nypost.com/2020/11/06/michigan-gop-
       claims-software-issue-undercounted-trump-votes/.
173.   “Isolated User Error in Antrim County Does Not Affect Election Results, Has No Impact on
       Other Counties or States,” Michigan Secretary of State, (Nov. 7, 2020), available at https://
       www.michigan.gov/-/media/Project/Websites/sos/30lawens/Antrim_Fact_Check.pdf?rev=
       7a929e4d262e4532bbe574a3b82ddbcf; “Hand Audit of All Presidential Election Votes in
       Antrim County Confirms Previously Certified Results, Voting Machines Were Accurate,”
       Michigan Secretary of State, (Dec. 17, 2020), available at https://www.michigan.gov/sos/
       resources/news/2020/12/17/hand-audit-of-all-presidential-election-votes-in-antrim-
       county-confirms-previously-certified-result; J. Alex Halderman, Analysis of the Antrim
       County, Michigan November 2020 Election Incident, (Mar. 26, 2021), pp. 17-27, available at
       https://www.michigan.gov/-/media/Project/Websites/sos/30lawens/Antrim.pdf?rev=
       fbfe881cdc0043a9bb80b783d1bb5fe9; Michigan Senate Oversight Committee, Report on the
       November 2020 Election in Michigan, (June 23, 2021), pp. 14-19, 36-55, available at https://
       misenategopcdn.s3.us-east-1.amazonaws.com/99/doccuments/20210623/
       SMPO_2020ElectionReport_2.pdf.
174.   Michigan Senate Oversight Committee, Report on the November 2020 Election in Michigan,
       (June 23, 2021), pp. 14-15, available at https://misenategopcdn.s3.us-east-
       1.amazonaws.com/99/doccuments/20210623/SMPO_2020ElectionReport_2.pdf.
175.   “Isolated User Error in Antrim County Does Not Affect Election Results, Has No Impact on
       Other Counties or States,” Michigan Secretary of State website, (Nov. 7, 2020), available at
                                           THE BIG LIE                                             247

       https://www.michigan.gov/-/media/Project/Websites/sos/30lawens/
       Antrim_Fact_Check.pdf?rev=7a929e4d262e4532bbe574a3b82ddbcf.
176.   Michigan Senate Oversight Committee, Report on the November 2020 Election in Michigan,
       (June 23, 2021), pp. 14-19, available at https://misenategopcdn.s3.us-east-
       1.amazonaws.com/99/doccuments/20210623/SMPO_2020ElectionReport_2.pdf.
177.   Documents on file with the Select Committee to Investigate the January 6th Attack on the
       United States Capitol (National Archives Production), 076P-R000010292_0001 (November 12,
       2020, email from Tim Walberg to Molly Michel re: Additional Presidential Phone call follow
       up).
178.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
       scribed Interview of Chad Wolf, (Jan. 21, 2022), pp. 70-74; Documents on file with the Select
       Committee to Investigate the January 6th Attack on the United States Capitol, (Department
       of Homeland Security Production), CTRL0000033284, (Nov. 13, 2020, email from Molly
       Michael to Chad Wolf titled “Re: Michigan Letter”).
179.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
       scribed Interview of Chad Wolf, (Jan. 21, 2022), pp. 72-74; Documents on file with the Select
       Committee to Investigate the January 6th Attack on the United States Capitol, (Department
       of Homeland Security Production), CTRL0000033284, (Nov. 13, 2020, email from Molly
       Michael to Chad Wolf titled “Re: Michigan Letter”); Select Committee to Investigate the
       January 6th Attack on the United States Capitol, Transcribed Interview of Chad Wolf, (Jan.
       21, 2022), Exhibit 44, CTRL0000926977 (Nov. 13, 2020 letter to Michigan Secretary of State
       Jocelyn Benson from Michigan State Senators Lana Theis and Tom Barrett).
180.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
       scribed Interview of Chad Wolf, (Jan. 21, 2022), pp. 74-77 Select Committee to Investigate
       the January 6th Attack on the United States Capitol, Transcribed Interview of Chad Wolf
       (Jan. 21, 2022), Exhibit 45, CTRL0000926978, (Nov. 16, 2020 email from Christopher Krebs
       responding to Chad Wolf, Matthew Travis, and Brandon Wales entitled “RE: Allegations”).
181.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
       scribed Interview of Chad Wolf, (Jan. 21, 2022), pp. 74-77; Select Committee to Investigate
       the January 6th Attack on the United States Capitol, Transcribed Interview of Chad Wolf
       (Jan. 21, 2022), Exhibit 45, CTRL0000926978, (Nov. 16, 2020 email from Christopher Krebs to
       Chad Wolf, Matthew Travis, and Brandon Wales entitled “RE: Allegations”); “Isolated User
       Error in Antrim County Does Not Affect Election Results, Has No Impact on Other Counties
       or States,” Michigan Secretary of State, (Nov. 7, 2020), available at https://
       www.michigan.gov/-/media/Project/Websites/sos/30lawens/Antrim_Fact_Check.pdf?rev=
       7a929e4d262e4532bbe574a3b82ddbcf.
182.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
       scribed Interview of Chad Wolf, (Jan. 21, 2022), pp. 78-80. Even as the acting Secretary of
       DHS was providing Meadows information he received from his Director of CISA debunking
       the Dominion claims, the acting Assistant Secretary of DHS, Ken Cuccinelli, was providing
       back channel information to Meadows in a possible effort to promote the false Dominion
       claims. See Documents on file with the Select Committee to Investigate the January 6th
       Attack on the United States Capitol (National Archives Production), TEXT0000072,
       TEXT0000073, (Nov. 12, 2020 text messages from Ken Cuccinelli to Mark Meadows) (Cuc-
       cinelli: “I have the dominion list of everywhere the machines are deployed that we know
       of. [I]t is pretty extensive. It is in my DHS email account. Where do you want me to send
       it?” Meadows then provided Cuccinelli with his personal email address.)
183.   Chris Krebs #Protect2020 (@CISAKrebs), Twitter, Nov. 17, 2020 11:45 a.m. ET, available at
       https://twitter.com/CISAKrebs/status/1328741106624901120.
184.   Documents on file with the Select Committee to Investigate the January 6th Attack on the
       United States Capitol (National Archives Production), 076P-R000010360_0001, 076P-
       R000010361_0001, (November 17, 2020 email and attached letter to Christopher Krebs from
       White House Office of Presidential Personnel, stating respectively that “the President has
248                                          CHAPTER 1

       terminated your appointment” and that “Pursuant to the direction of the President, your
       appointment… is hereby terminated, effective immediately”).
185.   Donald J. Trump (@realDonaldTrump), Twitter, Nov. 17, 2020 7:07 p.m. ET, available at
       http://web.archive.org/web/20201118040513/https://twitter.com/realdonaldtrump/status/
       1328852352787484677 (archived); Donald J. Trump (@realDonaldTrump), Twitter, Nov. 17,
       2020 7:07 p.m. ET, available at http://web.archive.org/web/20201118040930/https://
       twitter.com/realDonaldTrump/status/1328852354049957888 (archived).
186.   “Rudy Giuliani Trump Campaign Press Conference Transcript November 19: Election Fraud
       Claims,” Rev, (Nov. 19, 2020), available at https://www.rev.com/blog/transcripts/rudy-
       giuliani-trump-campaign-press-conference-transcript-november-19-election-fraud-claims.
187.   “Rudy Giuliani Trump Campaign Press Conference Transcript November 19: Election Fraud
       Claims,” Rev, (Nov. 19, 2020), available at https://www.rev.com/blog/transcripts/rudy-
       giuliani-trump-campaign-press-conference-transcript-november-19-election-fraud-claims.
188.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
       scribed Interview of Hope Hicks, (Oct. 25, 2022), pp. 88-91. See also Tucker Carlson: “Time
       for Sidney Powell to Show Us Her Evidence: We Asked the Trump Campaign Attorney for
       Proof of her Bombshell Claims. She Gave Us Nothing,” Fox News, (Nov. 19, 2020), available
       at https://www.foxnews.com/opinion/tucker-carlson-rudy-giuliani-sidney-powell-election-
       fraud.
189.   Jenna Ellis (@JennaEllisEsq), Twitter, Nov. 22, 2020, 5:23 p.m. ET, available at https://
       twitter.com/JennaEllisEsq/status/1330638034619035655.
190.   Donald J. Trump, (@realDonaldTrump), Twitter, Nov. 19, 2020 12:41 a.m. ET and 3:47 p.m. ET,
       available at https://www.thetrumparchive.com/?searchbox=%22dominion-izing%22
       (archived).
191.   One America News Network, “Cyber Analyst on Dominion Voting: Shocking Vulnerabilities,”
       YouTube, at 0:41-1:14, 1:37-2:23, 2:42-3:36, Nov. 15, 2020, available at https://
       www.youtube.com/watch?v=eKcPoCNW8AA.
192.   Ron Watkins, (@codemonkeyz), Twitter, Nov. 19, 2020 12:45 a.m. ET, available at http://
       web.archive.org/web/20201121092200/https://twitter.com/CodeMonkeyZ/status/
       1329299640848584710 (archived); Ron Watkins, (@codemonkeyz), Twitter, Nov. 19, 2020
       12:46 a.m. ET, available at http://web.archive.org/web/20201201175413/https://twitter.com/
       CodeMonkeyZ/status/1329300069623820289 (archived); Donald J. Trump, Twitter, Nov. 21,
       2020 11:30 p.m. ET, Nov. 21, 2020, 11:31 p.m. ET, Nov. 21, 2020, 11:32 p.m. ET, Nov. 22, 2020,
       3:35 p.m. ET, available at https://www.thetrumparchive.com/?searchbox=%22dominion-
       izing%22&dates=%5B%222020-11-20%22%2C%222020-11-24%22%5D (archived).
193.   Barr met with President Trump between election day and January 6th on November 23,
       December 1, and December 14. See Select Committee to Investigate the January 6th Attack
       on the United States Capitol, Transcribed Interview of William Barr, (Jun. 2, 2022), pp. 16, 22,
       28.
194.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
       scribed Interview of William Barr, (Jun. 2, 2022), pp. 25, 27, 50; William Barr, One Damn
       Thing After Another: Memoirs of an Attorney General, (New York: HarperCollins, 2022), at pp.
       539, 554.
195.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
       scribed Interview of William Barr, (Jun. 2, 2022), p. 19.
196.   Factba.se, “Interview: Maria Bartiromo Interviews Donald Trump on Fox News - November
       29, 2020,” Vimeo, Nov. 29, 2020, at. 1:00-1:43, 3:23-4:36, available at https://vimeo.com/
       485180163.
197.   Factba.se, “Interview: Maria Bartiromo Interviews Donald Trump on Fox News - November
       29, 2020,” Vimeo, at 1:00-1:43, Nov. 29, 2020, available at https://vimeo.com/485180163.
                                            THE BIG LIE                                           249

198.   Factba.se, “Interview: Maria Bartiromo Interviews Donald Trump on Fox News - November
       29, 2020,” Vimeo, at 1:50-2:40, Nov. 29, 2020, available at https://vimeo.com/485180163.
199.   Factba.se, “Interview: Maria Bartiromo Interviews Donald Trump on Fox News - November
       29, 2020,” Vimeo, at 3:50-4:24, 22:40-23:52, 24:26-24:50, Nov. 29, 2020, available at https://
       vimeo.com/485180163.
200.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
       scribed Interview of William Barr, (Jun. 2, 2022), pp. 22, 25-26.
201.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
       scribed Interview of William Barr, (Jun. 2, 2022), pp. 22, 25-26.
202.   “Donald Trump Speech on Election Fraud Claims Transcript December 2,” Rev, (Dec. 2,
       2020), available at https://www.rev.com/blog/transcripts/donald-trump-speech-on-
       election-fraud-claims-transcript-december-2.
203.   King v. Whitmer, 505 F. Supp. 3d 720, 738 (E.D. Mich. 2020)
204.   Bowyer v. Ducey, 506 F. Supp. 3d 699, 723 (D. Ariz. 2020) (finding the complaint “void of
       plausible allegations that Dominion voting machines were hacked or compromised in Ari-
       zona during the 2020 General Election”).
205.   “Isolated User Error in Antrim County Does Not Affect Election Results, Has No Impact on
       Other Counties or States,” Michigan Secretary of State, (Nov. 7, 2020), available at https://
       www.michigan.gov/-/media/Project/Websites/sos/30lawens/Antrim_Fact_Check.pdf?rev=
       7a929e4d262e4532bbe574a3b82ddbcf.
206.   Decision and Order Granting Plaintiff's Motion for an Ex Parte Temporary Restraining
       Order, Show Cause Order and Preliminary Injunction, No. 2020009238CZ (Mich. Cty. Cir. Ct.
       Dec. 4, 2020).
207.   Rudy W. Giuliani (@RudyGiuliani), Twitter, Dec. 4, 2020 7:12 p.m. ET, available at https://
       twitter.com/RudyGiuliani/status/1335014224532221952?s=20&t=20AZkk4gS2DeBo6q6QR-mw;
       Ronn Blitzer, “Trump Legal Team Celebrates after Michigan Judge Allows Probe of Domin-
       ion Voting Machines,” Fox News, (Dec. 6, 2020), available at https://www.foxnews.com/
       politics/trump-legal-team-michigan-antrim-county-judge-order-dominion-machines;
       Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
       scribed Interview of Bernard Kerik, (Jan. 13, 2022), pp. 19, 147.
208.   Documents on file with the Select Committee to Investigate the January 6th Attack on the
       United States Capitol (National Archives Production), 076P-R000001368_00001, pp. 1, 6
       (Allied Security Operations Group Antrim Michigan Forensics Report, dated Dec. 13, 2020).
209.   Documents on file with the Select Committee to Investigate the January 6th Attack on the
       United States Capitol (National Archives Production), 076P-R00001254_00001 (December 14,
       2020, email from Joanna Miller to Peter Navarro attaching the ASOG Report and noting that
       "POTUS and VPOTUS are briefed").
210.   See, e.g., Documents on file with the Select Committee to Investigate the January 6th
       Attack on the United States Capitol (Department of Justice Production), HouseSelect-Jan6-
       PartII-01132022-000798(December 14, 2020, email from Molly Michael re: From POTUS asking
       the AG to look at ASOG report); Documents on file with the Select Committee to Investigate
       the January 6th Attack on the United States Capitol (National Archives Production), 076P-
       R000001337_00001(December 14, 2020, email from Molly Michael to Acting Attorney General
       Jeffrey Rosen re: From POTUS attaching ASOG report); Documents on file with the Select
       Committee to Investigate the January 6th Attack on the United States Capitol (National
       Archives Production), 076P-R000001367_00001(December 14, 2020, email from Molly Michael
       to Michigan Senate Majority Leader Mike Shirkey re: From POTUS attaching ASOG report);
       Documents on file with the Select Committee to Investigate the January 6th Attack on the
       United States Capitol (National Archives Production) 076P-R000001361_00001(December 14,
       2020, email from Molly Michael to Senator Kelly Loeffler re: From POTUS attaching ASOG
       report); Documents on file with the Select Committee to Investigate the January 6th Attack
250                                        CHAPTER 1

       on the United States Capitol (National Archives Production), 076P-
       R000001358_00001(December 14, 2020, email from Molly Michael to Arizona Governor Doug
       Ducey re: From POTUS attaching ASOG report); Documents on file with the Select Commit-
       tee to Investigate the January 6th Attack on the United States Capitol (National Archives
       Production), 076P-R000001370_00001 (December 14, 2020, email from Molly Michael to
       Republican Party Chairwoman Ronna McDaniel re: From POTUS attaching ASOG report);
       Documents on file with the Select Committee to Investigate the January 6th Attack on the
       United States Capitol (National Archives Production), 076P-R000001378_00001 (December
       14, 2020, email from Molly Michael to Pennsylvania State Senator Doug Mastriano re: From
       POTUS attaching ASOG report).
211.   Donald J. Trump (@realDonaldTrump), Twitter, Dec. 14, 2020 2:59 p.m. ET, available at
       http://web.archive.org/web/20201214214435/https://twitter.com/realdonaldtrump/status/
       1338574268154646528 (archived).
212.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
       scribed Interview of William Barr, (Jun. 2, 2022), pp. 28-29.
213.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
       scribed Interview of William Barr, (Jun. 2, 2022), p. 29.
214.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
       scribed Interview of William Barr, (Jun. 2, 2022), pp. 29-30.
215.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
       scribed Interview of William Barr, (Jun. 2, 2022), pp. 29-30.
216.   See, e.g., Select Committee to Investigate the January 6th Attack on the United States Capi-
       tol, Transcribed Interview of William Barr, (Jun. 2, 2022), pp. 29-30.
217.   See Documents on file with the Select Committee to Investigate the January 6th Attack on
       the United States Capitol (Department of Homeland Security Production) CTRL0000915111,
       CTRL0000915117-CTRL0000915118 (draft analyses of ASOG report). Notably, the final version
       of this review, which had been requested by the Attorney General, was edited by senior
       DHS officials to remove the language most critical of ASOG before being sent to the
       Department of Justice by Acting Assistant Secretary Ken Cuccinelli. See Documents on file
       with the Select Committee to Investigate the January 6th Attack on the United States Capi-
       tol (Department of Homeland Security Production) CTRL0000915120 (emails circulating
       draft analyses), CTRL0000926941 (noting report was “currently in the Secretary’s office”);
       Documents on file with the Select Committee to Investigate the January 6th Attack on the
       United States Capitol (Department of Justice Production) HCOR-Pre-CertificationEvents-
       07262021-000687-HCOR-Pre-CertificationEvents-07262021-000688 (email and report pro-
       vided to Donoghue by Cuccinelli); Select Committee to Investigate the January 6th Attack
       on the United States Capitol, Transcribed Interview of Richard Peter Donoghue, (Oct. 1,
       2021), pp. 29-31.
218.   See Michigan Senate Oversight Committee, Report on the November 2020 Election in Michi-
       gan, (June 23, 2021), p. 16, available at https://misenategopcdn.s3.us-east-
       1.amazonaws.com/99/doccuments/20210623/SMPO_2020ElectionReport_2.pdf; J. Alex
       Halderman, Analysis of the Antrim County, Michigan November 2020 Election Incident,”
       (Mar. 26, 2021), available at https://www.michigan.gov//media/Project/Websites/sos/
       30lawens/Antrim.pdf?rev=fbfe881cdc0043a9bb80b783d1bb5fe9.
219.   For example, President Trump and others frequently cited ASOG’s finding that the Domin-
       ion machines had a “68% error rate,” but that conclusion was based on a complete misun-
       derstanding of the scanner log files reviewed by ASOG. Their report also claimed that, due
       to these perceived “errors,” a “staggering number of votes” were determined through an
       adjudication process that allowed for manipulation of votes, but no adjudication software
       was installed on the Dominion machines. J. Alex Halderman, Analysis of the Antrim County,
       Michigan November 2020 Election Incident, (Mar. 26, 2021), pp. 40-41, available at https://
       www.michigan.gov/-/media/Project/Websites/sos/30lawens/Antrim.pdf?rev=
       fbfe881cdc0043a9bb80b783d1bb5fe9.
                                           THE BIG LIE                                           251

220.   Halderman concluded that “I am not aware of any credible evidence that any security
       problem was ever exploited against Antrim County's election system. As my analysis
       shows, the anomalies that occurred in the November 2020 results are fully explained by
       human error.” J. Alex Halderman, Analysis of the Antrim County, Michigan November 2020
       Election Incident, (Mar. 26, 2021), p. 46, available at https://www.michigan.gov/-/media/
       Project/Websites/sos/30lawens/Antrim.pdf?rev=fbfe881cdc0043a9bb80b783d1bb5fe9.
221.   "Audits of the November 3, 2020 General Election," Michigan Secretary of State, (April 21,
       2021), p. 32, available at https://www.michigan.gov/-/media/Project/Websites/sos/
       30lawens/BOE_2020_Post_Election_Audit_Report_04_21_21.pdf?rev=
       a3c7ee8c06984864870c540a266177f2.; “Hand Count Calculation Sheet (Office: President of
       the United States, County: Antrim),” Michigan Secretary of State, available at https://
       www.michigan.gov/-/media/Project/Websites/sos/30lawens/
       AntrimCounty_Presidential_Race_Full_Hand_Count_November2020.pdf?rev=
       0bf12f08c33444c59bd145fbcfbb3e40.
222.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
       scribed Interview of Bernard Kerik, (Jan. 13, 2022), p. 182.
223.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Hear-
       ing on the January 6th Investigation, 117th Cong., 2d sess., (June 23, 2022), available at
       https://www.govinfo.gov/committee/house-january6th.
224.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
       scribed Interview of Derek Lyons, (Mar. 17, 2022), pp. 21-22, 99; Select Committee to Investi-
       gate the January 6th Attack on the United States Capitol, Transcribed Interview of Pasquale
       Anthony “Pat” Cipollone, (Jul. 8, 2022), pp. 44-50.
225.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
       scribed Interview of Pasquale Anthony “Pat” Cipollone, (Jul. 8, 2022), pp. 42-43.
226.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
       scribed Interview of Pasquale Anthony “Pat” Cipollone, (Jul. 8, 2022), p. 50.
227.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
       scribed Interview of Eric Herschmann, (Apr. 6, 2022), p. 129.
228.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
       scribed Interview of Robert O'Brien, (Aug. 23, 2022), pp. 163-65.
229.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
       scribed Interview of Chad Wolf, (Jan. 21, 2022), pp. 97-98, 102-103; Select Committee to
       Investigate the January 6th Attack on the United States Capitol, Transcribed Interview of
       Ken Cuccinelli, (Dec. 7, 2021), pp. 49-54.
230.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Depo-
       sition of Rudolph Giuliani (May 20, 2022), pp. 157-59; Select Committee to Investigate the
       January 6th Attack on the United States Capitol, Deposition of Sidney Powell, (May 7, 2022),
       pp. 102-03; Documents on file with the Select Committee to Investigate the January 6th
       Attack on the United States Capitol, (Jenna Ellis Production), J.007465Ellis, J.007467Ellis
       (December 28-29, 2020, emails with Katherine Freiss, Doug Mastriano, Christina Bobb, Giu-
       liani, and others about accessing voting machines); Emma Brown and Jon Swaine, “Inside
       the Secretive Effort by Trump Allies to Access Voting Machines,” Washington Post, (Oct. 28,
       2022), available at https://www.washingtonpost.com/investigations/2022/10/28/coffee-
       county-georgia-voting-trump/.
231.   Brad Raffensperger, Integrity Counts (New York: Simon & Schuster, 2021), p. 191 (reproduc-
       ing the call transcript);Amy Gardner and Paulina Firozi, “Here’s the Full Transcript and
       Audio of the Call Between Trump and Raffensperger,” Washington Post, (Jan. 5, 2021), avail-
       able at https://www.washingtonpost.com/politics/trump-raffensperger-call-transcript-
       georgia-vote/2021/01/03/2768e0cc-4ddd-11eb-83e3-322644d82356_story.html.
232.   Brad Raffensperger, Integrity Counts (New York: Simon & Schuster, 2021), p. 191 (reproduc-
       ing the call transcript); Amy Gardner and Paulina Firozi, “Here’s the Full Transcript and
252                                         CHAPTER 1

       Audio of the Call Between Trump and Raffensperger,” Washington Post, (Jan. 5, 2021), avail-
       able at https://www.washingtonpost.com/politics/trump-raffensperger-call-transcript-
       georgia-vote/2021/01/03/2768e0cc-4ddd-11eb-83e3-322644d82356_story.html.
233.   “Donald Trump Rally Speech Transcript Dalton, Georgia: Senate Runoff Election,” Rev, (Jan.
       4, 2021), available at https://www.rev.com/blog/transcripts/donald-trump-rally-speech-
       transcript-dalton-georgia-senate-runoff-election.
234.   “Donald Trump Rally Speech Transcript Dalton, Georgia: Senate Runoff Election,” Rev, (Jan.
       4, 2021), available at https://www.rev.com/blog/transcripts/donald-trump-rally-speech-
       transcript-dalton-georgia-senate-runoff-election.
235.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Depo-
       sition of Rudolph Giuliani, (May 20, 2022), p. 111.
236.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Depo-
       sition of Rudolph Giuliani, (May 20, 2022), p. 166.
237.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
       scribed Interview of Bernard Kerik (Jan. 13, 2022), p. 182. Kerik also emailed President
       Trump’s chief of staff, Mark Meadows, on December 28, 2020, writing: “We can do all the
       investigations we want later, but if the president plans on winning, it’s the legislators that
       have to be moved, and this will do just that.” Document on file with the Select Committee
       (National Archives Production) 076P-R000004125_0001.
238.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
       scribed Interview of Christina Bobb, (Apr. 21, 2022), p. 46.
239.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Depo-
       sition of Sidney Powell, (May 7, 2022), pp. 89-96.
240.   Defendant’s Motion to Dismiss at 27-28, U.S. Dominion, Inc. v. Powell, No. 1:21-cv-00040
       (D.D.C. filed Mar. 22, 2021), ECF No. 22-2.
241.   Justin Gray, “Georgia Election Officials Show Frame-by-Frame What Happened in Fulton
       Surveillance Video,” WSB-TV, (Dec. 4, 2020), https://www.wsbtv.com/news/politics/georgia-
       election-officials-show-frame-by-frame-what-really-happened-fulton-surveillance-video/
       T5M3PYIBYFHFFOD3CIB2ULDVDE/.
242.   11Alive, “Second Georgia Senate election hearing,” YouTube, at 5:31:50-5:32:45, Dec. 3, 2020,
       available at https://www.youtube.com/watch?v=hRCXUNOwOjw.
243.   See, e.g., Donald J. Trump, (@realDonaldtrump), Twitter, Dec. 14, 2020 8:57 a.m. ET, avail-
       able at http://web.archive.org/web/20201217181730/https://twitter.com/realDonaldTrump/
       status/1338483200046354434; Brad Raffensperger, Integrity Counts (New York: Simon &
       Schuster, 2021), p. 191 (reproducing the call transcript); Amy Gardner and Paulina Firozi,
       “Here’s the Full Transcript and Audio of the Call Between Trump and Raffensperger,” Wash-
       ington Post, (Jan. 5, 2021), available at https://www.washingtonpost.com/politics/trump-
       raffensperger-call-transcript-georgia-vote/2021/01/03/2768e0cc-4ddd-11eb-83e3-
       322644d82356_story.html.
244.   Brad Raffensperger, Integrity Counts (New York: Simon & Schuster, 2021), p. 191 (reproduc-
       ing the call transcript); Amy Gardner and Paulina Firozi, “Here’s the Full Transcript and
       Audio of the Call Between Trump and Raffensperger,” Washington Post, (Jan. 5, 2021), avail-
       able at https://www.washingtonpost.com/politics/trump-raffensperger-call-transcript-
       georgia-vote/2021/01/03/2768e0cc-4ddd-11eb-83e3-322644d82356_story.html.
245.   Ryan Taylor, “Donald Trump Georgia Rally Transcript Before Senate Runoff Elections
       December 5,” Rev, (Dec. 5, 2020), available at https://www.rev.com/blog/transcripts/
       donald-trump-georgia-rally-transcript-before-senate-runoff-elections-december-5.
246.   “Donald Trump Vlog: Contesting Election Results—December 22, 2020,” Factba.se, (Dec. 22,
       2020), at 9:11 – 9:31, available at https://factba.se/transcript/donald-trump-vlog-
       contesting-election-results-december-22-2020.
                                           THE BIG LIE                                            253

247.   Ryan Taylor, “Donald Trump Georgia Phone Call Transcript with Sec. of State Brad Raffens-
       perger: Says He Wants to ‘Find’ Votes,” Rev, (Jan. 4, 2021), available at https://
       www.rev.com/blog/transcripts/donald-trump-georgia-phone-call-transcript-brad-
       raffensperger-recording.
248.   U.S. Senate Committee on the Judiciary, Transcribed Interview of Jeffrey Rosen, (Aug. 7,
       2021), pp. 30-31, available at https://www.judiciary.senate.gov/imo/media/doc/
       Rosen%20Transcript.pdf.
249.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
       scribed Interview of Richard Peter Donoghue, (Oct. 1, 2021), pp. 42-43.
250.   Brad Raffensperger, Integrity Counts (New York: Simon & Schuster, 2021), p. 191 (reproduc-
       ing the call transcript); Amy Gardner and Paulina Firozi, “Here’s the Full Transcript and
       Audio of the Call Between Trump and Raffensperger,” Washington Post, (Jan. 5, 2021), avail-
       able at https://www.washingtonpost.com/politics/trump-raffensperger-call-transcript-
       georgia-vote/2021/01/03/2768e0cc-4ddd-11eb-83e3-322644d82356_story.html.
251.   Brad Raffensperger, Integrity Counts (New York: Simon & Schuster, 2021), p. 191 (reproduc-
       ing the call transcript); Amy Gardner and Paulina Firozi, “Here’s the Full Transcript and
       Audio of the Call Between Trump and Raffensperger,” Washington Post, (Jan. 5, 2021), avail-
       able at https://www.washingtonpost.com/politics/trump-raffensperger-call-transcript-
       georgia-vote/2021/01/03/2768e0cc-4ddd-11eb-83e3-322644d82356_story.html.
252.   Brad Raffensperger, Integrity Counts (New York: Simon & Schuster, 2021), p. 191 (reproduc-
       ing the call transcript); Amy Gardner and Paulina Firozi, “Here’s the Full Transcript and
       Audio of the Call Between Trump and Raffensperger,” Washington Post, (Jan. 5, 2021), avail-
       able at https://www.washingtonpost.com/politics/trump-raffensperger-call-transcript-
       georgia-vote/2021/01/03/2768e0cc-4ddd-11eb-83e3-322644d82356_story.html.
253.   Declaration of Frances Watson at 1-3, Pearson v. Kemp, 831 F. App'x. 467 (N.D. Ga. 2020) (No.
       1:20-cv-04809), ECF No. 72-1.
254.   Declaration of Frances Watson at 1-3, Pearson v. Kemp, 831 F. App'x. 467 (N.D. Ga. 2020) (No.
       1:20-cv-04809), ECF No. 72-1.
255.   U.S. Senate Judiciary Committee, Transcribed Interview of Byung J. “BJay” Pak, (Aug. 11,
       2021), pp. 14-25, available at https://www.judiciary.senate.gov/imo/media/doc/
       Pak%20Transcript.pdf; Response of the Georgia Secretary of State to the Court's Order of
       September 20, 2021 at 4-6, Favorito v. Wan, No. 2020CV343938 (Ga. Super. Ct. filed Oct. 12,
       2021).
256.   “Georgia Election Officials Briefing Transcript December 7: Will Recertify Election Results
       Today,” Rev, (December 7, 2020), available at https://www.rev.com/blog/transcripts/
       georgia-election-officials-briefing-transcript-december-7-will-recertify-election-results-
       today; Response of the Georgia Secretary of State to the Court's Order of September 20,
       2021 at 4-6, Favorito v. Wan, No. 2020CV343938 (Ga. Super. Ct. filed Oct. 12, 2021).
257.   “Georgia Election Officials Briefing Transcript December 7: Will Recertify Election Results
       Today,” Rev, (December 7, 2020), available at https://www.rev.com/blog/transcripts/
       georgia-election-officials-briefing-transcript-december-7-will-recertify-election-results-
       today; Response of the Georgia Secretary of State to the Court's Order of September 20,
       2021, at 4-6 and Exhibit A: Videotaped Deposition of James P. Callaway (Deputy Chief Inves-
       tigator of the Office of the Secretary of State) at 29-35, Favorito v. Wan, No. 2020CV343938
       (Ga. Super. Ct. filed Oct. 12, 2021) available at, https://s3.documentcloud.org/documents/
       21084096/favorito-sos-brief-in-response-to-order-of-92021-with-exs-a-and-b.pdf.
258.   Declaration of Frances Watson at 2-3, Pearson v. Kemp, 831 F. App'x. 467 (N.D. Ga. 2020) (No.
       1:20-cv-04809), ECF No. 72-1; U.S. Senate Judiciary Committee, Transcribed Interview of
       Byung J. “BJay” Pak, (August 11, 2021), pp. 14-25, available at https://
       www.judiciary.senate.gov/imo/media/doc/Pak%20Transcript.pdf.
254                                          CHAPTER 1

259.   Documents on file with the Select Committee to Investigate the January 6th Attack on the
       United States Capitol, (National Archives Production), 076P-R000004670_0001-0013, 076P-
       R000004888_0001-0013, 076P-R000004948_0001-0013 (January 5, 2021, emails from Molly
       Michael re: “from POTUS” to Senators Josh Hawley and Ted Cruz and to Representative Jim
       Jordan attaching Background Briefing on 2020 Fraud).
260.   “Transcript of Trump’s Speech at Rally Before US Capitol Riot,” Associated Press, (Jan. 13,
       2021), available at https://apnews.com/article/election-2020-joe-biden-donald-trump-
       capitol-siege-media-e79eb5164613d6718e9f4502eb471f27.
261.   In the Matter of Rudolph W. Giuliani, No. 2021-00506, slip op at *2, 22 (N.Y. App. Div. May 3,
       2021), available at https://int.nyt.com/data/documenttools/giuliani-law-license-
       suspension/1ae5ad6007c0ebfa/full.pdf.
262.   GA House Mobile Streaming, Governmental Affairs 12.10.20, Vimeo – Livestream, at 2:09:03
       to - 2:13:10, available at https://livestream.com/accounts/25225474/events/9117221/
       videos/214677184.
263.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Hear-
       ing on the January 6th Investigation, 117th Cong., 2d sess., (June 21, 2022), available at
       https://www.govinfo.gov/committee/house-january6th.
264.   See John Danforth, Benjamin Ginsberg, Thomas B. Griffith, et al., “Lost, Not Stolen: The
       Conservative Case that Trump Lost and Biden Won the 2020 Presidential Election,” (July
       2022), p. 3, available at https://lostnotstolen.org/download/378/.
265.   Opinion and Order at *6, 13, Costantino v. Detroit, No. 20-014780-AW (Mich. Cty. Cir. Ct. filed
       Nov. 13, 2020), available at https://electioncases.osu.edu/wp-content/uploads/2020/11/
       Costantino-v-Detroit-Opinion-and-Order.pdf.
266.   Complaint, Exhibit 2: Affidavit of Jesse Richard Morgan at 2, 10, Mecalfe v. Wolf, 2020 Pa.
       Commw. LEXIS 794 (Pa. Commw. Ct. 2020) (No. 636 MD 2020), available at https://
       www.pacourts.us/Storage/media/pdfs/20210603/212420-file-10836.pdf.
267.   See, e.g., Donald J. Trump (@realdonaldtrump), Twitter, Dec. 1, 2020 2:31 p.m. ET, available
       at http://web.archive.org/web/20201202014959/https://twitter.com/realdonaldtrump/
       status/1333856259662077954 (archived); Donald J. Trump (@realdonaldtrump), Twitter, Dec.
       1, 2020 3:49 p.m. ET, available at http://web.archive.org/web/20201201221335/https://
       twitter.com/realDonaldTrump/status/1333875814585282567 (archived); Donald J. Trump
       (@realdonaldtrump), Twitter, Dec 2, 2020 6:42 p.m. ET, available at http://web.archive.org/
       web/20201203024425/https://twitter.com/realDonaldTrump/status/1334327204847775744
       (archived).
268.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
       scribed Interview of Richard Peter Donoghue, (Oct. 1, 2021), p. 60; Select Committee to
       Investigate the January 6th Attack on the United States Capitol, Transcribed Interview of
       William Barr, (Jun. 2, 2022), pp. 45-46.
269.   FOX News, “Sean Hannity,” Nov. 19, 2020, available at https://archive.org/details/
       FOXNEWSW_20201120_060000_Hannity?start/1983.1.end/2077.5.
270.   Brandon Waltens, “VIDEO: Wagons, Suitcases, and Coolers Roll into Detroit Voting Center at
       4 AM [UPDATED],” Texas Scorecard, (Nov. 4, 2020), available at https://texasscorecard.com/
       federal/video-wagons-suitcases-and-coolers-roll-into-detroit-voting-center-at-4-am/;
       “Rudy Giuliani Trump Campaign Press Conference Transcript November 19: Election Fraud
       Claims,” Rev, (Nov. 19, 2020), at 22:29-26:53, available at https://www.rev.com/blog/
       transcripts/rudy-giuliani-trump-campaign-press-conference-transcript-november-19-
       election-fraud-claims.
271.   Affidavit of Christopher Thomas ¶ 18, Texas v. Pennsylvania, 592 U.S. ____ (2020) (describ-
       ing ballot delivery), available at https://www.supremecourt.gov/DocketPDF/22/22O155/
       163387/20201210145418055_22O155%20MI%20APP.pdf; see also Opinion and Order at *6, 13,
       Costantino v. Detroit, No. 20-014780-AW (Mich. Cty. Cir. Ct. filed Nov. 13, 2020), available at
                                            THE BIG LIE                                        255

       https://electioncases.osu.edu/wp-content/uploads/2020/11/Costantino-v-Detroit-Opinion-
       and-Order.pdf (relying on Christopher Thomas’ affidavit to deny a petition for various
       relief related to allegations that the November 3, 2020 election in Michigan was fraudu-
       lent).
272.   “How a WXYZ Wagon Sparked False Election Fraud Claims in Detroit,” WXYZ, (Nov. 5, 2020),
       available at https://www.wxyz.com/news/how-a-wxyz-wagon-sparked-false-election-fraud-
       claims-in-detroit.
273.   “Election Summary Report,” City of Detroit, (Nov. 19, 2020), available at https://
       detroitmi.gov/document/november-3-2020-general-election-official-results.
274.   A canvassing process in every State verifies that the number of voters indicated as having
       voted matches the number of ballots cast. If, as claimed, tens of thousands of illegitimate
       ballots were counted at the TCF Center in Detroit, the total number of ballots counted
       would be substantially higher than the total number of voters who voted, but in Detroit
       slightly fewer ballots were counted than voters who were listed as having voted. The net
       number of ballots for the City of Detroit counting boards was 21 more names than ballots,
       out of approximately 174,000 absentee votes cast. Michigan Secretary of State, “Audits of
       the November 3, 2020 General Election,” (Apr. 21, 2021), p. 20, available at https://
       www.michigan.gov/-/media/Project/Websites/sos/30lawens/
       BOE_2020_Post_Election_Audit_Report_04_21_21.pdf?rev=
       a3c7ee8c06984864870c540a266177f2.
275.   Approximately 4.2 million ballots were cast in-person on election day and 2.6 million mail
       and absentee ballots were cast. See “Pennsylvania's Election Stats,” Pennsylvania Depart-
       ment of State, (accessed Dec. 4, 2022), available at https://www.dos.pa.gov/
       VotingElections/BEST/Pages/BEST-Election-Stats.aspx;“Official Returns – 2020 Presidential
       Election,” Pennsylvania Department of State, (accessed Dec. 4, 2022), available at https://
       www.electionreturns.pa.gov/General/SummaryResults?ElectionID=83&ElectionType=
       G&IsActive=0.
276.   Donald J. Trump, (@realDonaldTrump), Twitter, Nov. 28, 2020 12:09 a.m. ET, available at
       http://web.archive.org/web/20201128080915/https://twitter.com/realDonaldTrump/status/
       1332552283553476608 (archived), retweeting Senator Doug Mastriano (@SenMastriano),
       Twitter, Nov. 27, 2020, 1:59 p.m. ET, available at https://twitter.com/SenMastriano/status/
       1332398733401591808.
277.   Jessica Calefati, “Fact-Checking False Claims about Pennsylvania's Presidential Election by
       Trump and His Allies,” Philadelphia Inquirer, (Dec. 7, 2020), available at https://
       www.inquirer.com/politics/election/pennsylvania-election-results-trump-fraud-fact-check-
       20201206.html.
278.   Donald J. Trump (@realDonaldTrump), Twitter, Dec. 28, 2020, 4:00 p.m. ET, available at
       http://web.archive.org/web/20201228211304/https://twitter.com/realdonaldtrump/status/
       1343663159085834248 (archived); Donald J. Trump (@realDonaldTrump), Twitter, Dec. 29,
       2020, 8:59 a.m. ET, available at http://web.archive.org/web/20201229205204/https://
       twitter.com/realDonaldTrump/status/1343919651336712199 (archived); Donald J. Trump
       (@realDonaldTrump), Twitter, Dec. 29, 2020, 5:55 p.m. ET, available at http://
       web.archive.org/web/20201229225512/https://twitter.com/realdonaldtrump/status/
       1344054358418345985. Note that timestamps in archived tweets may reflect a time zone
       different from that where the tweet originated.
279.   See Pennsylvania House Republican Caucus, “PA Lawmakers: Numbers Don’t Add Up, Certi-
       fication of Presidential Results Premature and In Error,” (Dec. 28, 2020), available at
       https://www.pahousegop.com/News/18754/Latest-News/PA-Lawmakers-Numbers-
       Don%E2%80%99t-Add-Up,-Certification-of-Presidential-Results-Premature-and-In-Error.
       Representative Ryan also promoted the groundless claim of an unexplained discrepancy of
       400,000 mail-in ballots in the state’s database, which was based entirely on his ignorance
       of the fact that the database in question accounts for mail-in ballots and absentee ballots
       separately. Senate Committee on Homeland Security & Governmental Affairs, Examining
       Irregularities in the 2020 Election, (Dec. 16, 2020), Written Testimony of Pennsylvania State
256                                          CHAPTER 1

       Representative Frank Ryan, available at https://www.hsgac.senate.gov/imo/media/doc/
       Testimony-Ryan-2020-12-16.pdf; Senate Committee on Homeland Security & Governmental
       Affairs, Examining Irregularities in the 2020 Election, (Dec. 16, 2020), Letter Submitted by
       Pennsylvania Secretary of the Commonwealth Kathy Boockvar, available at https://
       www.dos.pa.gov/about-us/Documents/statements/2020-12-16-Senator-Johnson-and-
       Peters.pdf.
280.   “Dept. of State: Republicans' Election Claims Are ‘Repeatedly Debunked Conspiracy Theo-
       ries’,” WJAC-TV, (Dec. 29, 2020), available at https://wjactv.com/news/local/dept-of-state-
       republicans-election-claims-are-repeatedly-debunked-conspiracy-theories.
281.   Senate Committee on the Judiciary, Transcribed Interview of Richard Donoghue, (Aug. 6,
       2021), p. 156, available at https://www.judiciary.senate.gov/imo/media/doc/
       Donoghue%20Transcript.pdf.
282.   See “Donald Trump Rally Speech Transcript Dalton, Georgia: Senate Runoff Election,” Rev,
       (Jan. 4, 2021), at 58:09, available at https://www.rev.com/blog/transcripts/donald-trump-
       rally-speech-transcript-dalton-georgia-senate-runoff-election; “Transcript of Trump’s
       Speech at Rally Before US Capitol Riot,” Associated Press (January 13, 2021), available at
       https://apnews.com/article/election-2020-joe-biden-donald-trump-capitol-siege-media-
       e79eb5164613d6718e9f4502eb471f27.
283.   Select Committee to Investigate the January 6th Attack on the United States Capitol, Tran-
       scribed Interview of William Barr, (Jun. 2, 2022), p. 29; Affidavit of Russell James Ramsland,
       Jr., 556 F. Supp. 3d. 680, 724 (E.D. Mich. 2021), ECF 6-24, available at https://
       www.courtlistener.com/docket/18693929/6/24/king-v-whitmer/. Ramsland submitted a
       similar affidavit in a case in Georgia. See Affidavit of Russell Ramsland, Wood v. Raffens-
       perger, 501 F. Supp. 3d 1310 (N.D. Ga. 2020), ECF No. 7-1.
284.   Affidavit of Russell Ramsland, Wood v. Raffensperger, 501 F. Supp. 3d 1310 (N.D. Ga. 2020),
       ECF No. 7-1.
285.   Aaron Blake, “The Trump Campaign’s Much-Hyped Affidavit Features a Big, Glaring Error,”
       Washington Post, (Nov. 20, 2020), available at https://www.washingtonpost.com/politics/
       2020/11/20/trump-campaigns-much-hyped-affidavit-features-big-glaring-error/.
286.   For example, Ramsland claimed 781.91% turnout in North Muskegon (actual turnout:
       77.78%); 460.51% turnout in Zeeland Charter Township (actual turnout: 80.11%); and 139.29%
       turnout in Detroit (actual turnout: 50.88%). See King v. Whitmer, 556 F. Supp. 3d. 680, 724
       (E.D. Mich. 2021); Michigan Senate Oversight Committee, Report on the November 2020 Elec-
       tion in Michigan, (June 23, 2021), available at https://misenategopcdn.s3.us-east-
       1.amazonaws.com/99/doccuments/20210623/SMPO_2020ElectionReport_2.pdf.
287.   See, e.g., “Transcript of Trump’s Speech at Rally Before US Capitol Riot,” Associated Press,
       (Jan. 13, 2021), available athttps://apnews.com/article/election-2020-joe-biden-donald-
       trump-capitol-siege-media-e79eb5164613d6718e9f4502eb471f27; “Donald Trump Speech on
       Election Fraud Claims Transcript December 2” Rev (Dec. 2, 2020), available at https://
       www.rev.com/blog/transcripts/donald-trump-speech-on-election-fraud-claims-transcript-
       december-2; Donald J. Trump (@realDonaldTrump), Twitter, Dec. 3, 2020, 4:11 p.m. ET,
       available at http://web.archive.org/web/20201203211154/https://twitter.com/
       realdonaldtrump/status/1334606278388277253 (archived); “Trump Lawyers Rudy Giuliani &
       Jenna Ellis Testify Before Michigan House Oversight Committee: Full Transcript,” Rev, (Dec.
       3, 2020), at 26:13, available at https://www.rev.com/blog/transcripts/trump-lawyers-rudy-
       giuliani-jenna-ellis-testify-before-michigan-house-oversight-committee-transcript; Affida-
       vit of Mellissa A. Carone, King v. Whitmer, 505 F. Supp. 3d 720 (E.D. Mich. 2020), ECF No. 1-5,
       available at https://www.courtlistener.com/docket/18693929/1/5/king-v-whitmer/.
288.   See, e.g., Opinion and Order at *3, 12-13, Costantino v. Detroit, No. 20-014780-AW (Mich. Cty.
       Cir. Ct. filed Nov. 13, 2020), available at https://electioncases.osu.edu/wp-content/
       uploads/2020/11/Costantino-v-Detroit-Opinion-and-Order.pdf; Affidavit of Christopher
       Thomas ¶¶ 2-18, Texas v. Pennsylvania, 592 U.S. ____ (2020) (describing his experience and
                                             THE BIG LIE                                             257

       the process for tabulating votes), available at https://www.supremecourt.gov/DocketPDF/
       22/22O155/163387/20201210145418055_22O155%20MI%20APP.pdf.
289.   See, e.g., “Transcript of Trump’s Speech at Rally Before US Capitol Riot,” Associated Press
       (January 13, 2021), available at https://apnews.com/article/election-2020-joe-biden-
       donald-trump-capitol-siege-media-e79eb5164613d6718e9f4502eb471f27; Rudy Giuliani’s
       Common Sense, “I CAN’T SAY THIS On National Television | Rudy Giuliani | Ep. 98,” Rumble,
       at 13:10 – 13:25, Dec. 30, 2020, available at https://rumble.com/vex72l-i-cant-say-this-on-
       national-television-rudy-giuliani-ep.-98.html.
290.   Right Side Broadcasting Network, “LIVE: Georgia House Hearing on Election Fraud, Brad
       Raffensperger to Participate 12/23/20,” YouTube, at 27:28, 43:02-43:28, Dec. 23, 2020, avail-
       able at https://www.youtube.com/watch?v=R4cuakECmuA&t=2582s (Testimony of Ryan Ger-
       many, counsel to Georgia Secretary of State, before Georgia legislature stating: “The total
       number of underage people who voted is zero. We were able to look at everyone who
       voted and look at their birthdate in the voter registration system, and I think there was
       four people who requested a ballot before they turned 18, and they all turned 18 prior to
       November 3rd, which means they’re allowed to vote.”).
291.   See, e.g. Bannon’s War Room, “Episode 980 – The Border Tipping Point … Peter Navarro on
       the Stolen Election and Desperation in Del Rio,” Rumble, May 27, 2021, available at https://
       rumble.com/vhpam3-episode-980the-border-tipping-pointpeter-navarro-on-the-stolen-
       election-and.html; Bannon’s War Room, “Episode 979 – The HQ of the Runaway Train …
       Rachel Maddow’s Anna Karenina Moment,” Rumble, May 27, 2021, available at https://
       rumble.com/vhp8yn-episode-979-the-hq-of-the-runaway-train-rachel-maddows-anna-
       karenina-moment.html; Right Side Broadcasting Network, “LIVE: Arizona State Legislature
       Holds Public Hearing on 2020 Election,” YouTube, at 2:06:33-2:07:02, Nov. 30, 2020, available
       at https://www.youtube.com/watch?v=rri6flxaXww.
292.   “Proof of Citizenship Requirements,” Arizona Secretary of State, (accessed Dec. 4, 2022),
       available at https://azsos.gov/elections/voting-election/proof-citizenship-requirements.
       In 2013, the Supreme Court struck down Arizona’s “evidence-of-citizenship” requirement as
       applied to federal elections. See Arizona v. Inter Tribal Council of Arizona, Inc., 570 U.S. 1, 4,
       19 (2013). Arizona law allows voters to register as “federal only” voters without proof of
       citizenship, but those voters must provide a driver’s license or Social Security Number,
       which is then checked by election officials against immigration records before the person
       is added to voter registration rolls. Daniel González, “Are Undocumented Immigrants Vot-
       ing Illegally in Arizona?,” Arizona Republic, (Oct. 27, 2016), available at https://
       www.azcentral.com/story/news/politics/elections/2016/10/27/voter-fraud-undocumented-
       immigrants-voting-illegally-arizona-donald-trump/91703916/.
293.   Documents on file with the Select Committee to Investigate the January 6th Attack on the
       United States Capitol, (Mark Meadows Production), MM007288, (November 13, 2020, email
       from Bill Stepien to Mark Meadows, Justin Clark, and Jason Miller re: AZ Federal ID Voters);
       In the Matter of Rudolph W. Giuliani, No. 2021-00506, slip op at *23-25 (N.Y. App. Div. May 3,
       2021), available at https://int.nyt.com/data/documenttools/giuliani-law-license-
       suspension/1ae5ad6007c0ebfa/full.pdf.
294.   Brad Raffensperger, Integrity Counts (New York: Simon & Schuster, 2021), p. 191 (reproduc-
       ing the call transcript); Amy Gardner and Paulina Firozi, “Here’s the Full Transcript and
       Audio of the Call Between Trump and Raffensperger,” Washington Post, (Jan. 5, 2021), avail-
       able at https://www.washingtonpost.com/politics/trump-raffensperger-call-transcript-
       georgia-vote/2021/01/03/2768e0cc-4ddd-11eb-83e3-322644d82356_story.html.
295.   For example, the President alleged in his January 6th speech that large numbers of ballots
       were cast on behalf of dead people not just in Georgia but also in Michigan, Nevada, and
       Pennsylvania. “Transcript of Trump’s Speech at Rally Before US Capitol Riot,” Associated
       Press (January 13, 2021), https://apnews.com/article/election-2020-joe-biden-donald-
       trump-capitol-siege-media-e79eb5164613d6718e9f4502eb471f27; See also Rudy Giuliani’s
       Common Sense, “I CAN’T SAY THIS On National Television | Rudy Giuliani | Ep. 98,” Rumble,
258                                         CHAPTER 1

       at 15:10-15:46, (Dec. 30, 2020, reposted Mar. 22, 2021), available at https://rumble.com/
       vex72l-i-cant-say-this-on-national-television-rudy-giuliani-ep.-98.html (making similar
       claims).
296.   Documents on file with the Select Committee to Investigate the January 6th Attack on the
       United States Capitol, (Alex Cannon Production) AC-0013946, (November 12, 2020, email
       from Alex Cannon to Matt Wolking, Zach Parkinson, Tim Murtaugh, Ali Pardo, Matthew Mor-
       gan, and Andrew Clark titled “Re: dead voters”); Documents on file with the Select Commit-
       tee to Investigate the January 6th Attack on the United States Capitol, (Tim Murtaugh
       Production) XXM-0009451 (November 8, 2020, email from Jason Miller to Zach Parkinson,
       Tim Murtaugh, and Matt Wolking re: PA Death Data stating that quality control checks will
       “significantly decrease[]” the number of “possible dead voters”), XXM-0009467 (November
       8, 2020, email from Jason Miller to Zach Parkinson, Tim Murtaugh, and Matt Wolking re: GA
       Dead Voters), XXM-0009566 (November 9, 2020 email from Zach Parkinson to Jason Miller,
       Tim Murtaugh, and Matt Wolking re PA Death Data noting there “may be errors” with their
       data about people who were dead voters); Mark Niesse, “Alleged ‘Dead’ Georgia Voters
       Found Alive and Well after 2020 Election,” Atlanta Journal-Constitution, (Dec. 27, 2021),
       available at https://www.ajc.com/politics/alleged-dead-georgia-voters-found-alive-and-
       well-after-2020-election/DAL3VY7NFNHL5OREMHD7QECOCA/.
297.   Documents on file with the Select Committee to Investigate the January 6th Attack on the
       United States Capitol, (National Archives Production), TEXT0000198, (December 3, 2020, text
       message from Eric Herschmann to Mark Meadows).
298.   Documents on file with the Select Committee to Investigate the January 6th Attack on the
       United States Capitol, (National Archives Production), TEXT0000198-203, (December 3, 2020,
       text messages between Eric Herschmann and Mark Meadows).
299.   Final Order at 5-6, Boland v. Raffensperger, No.2020CV343018 (Ga. Super. Ct. filed Dec. 14
       2020), available at https://electioncases.osu.edu/wp-content/uploads/2020/11/Boland-v-
       Raffensperger-Order-Dismissing-Complaint.pdf.
300.   The expert, Bryan Geels, based his claims on a comparison of public voter information to
       public death records. See Documents on file with the Select Committee to Investigate the
       January 6th Attack on the U.S. Capitol (Christina Bobb Production), BOBB_CONG_00000683-
       84, 692-93, 706-07 (Affidavit of Bryan Geels dated Dec. 1, 2020, in Trump v. Barron, a case
       filed by the Trump Campaign in a Georgia Superior Court in Fulton County). However, the
       records reviewed included only name and year of birth for each individual listed. Id. at ¶
       28. Based on this limited information, it was impossible for Geels (or anyone else) to con-
       clude that the person with a particular name and birth year was the same person listed in
       public death records with that name and birth year. See id., at ¶ 50 (only the Secretary of
       State has the information to conduct a full analysis of this issue); see also Declaration of
       Charles Stewart III at 22, Trump v. Raffensperger, No. 2020CV33255 (Ga. Super. Ct. filed Dec.
       14, 2020).
301.   In Georgia, the Secretary of State found four cases where people voted in the names of
       deceased individuals. Mark Niesse, “Alleged ‘Dead’ Georgia Voters Found Alive and Well
       after 2020 Election,” Atlanta Journal-Constitution, (Dec. 27, 2021), available at https://
       www.ajc.com/politics/alleged-dead-georgia-voters-found-alive-and-well-after-2020-
       election/DAL3VY7NFNHL5OREMHD7QECOCA/; In Arizona, the Attorney General recently
       concluded its investigation into claims of supposed dead voters in the 2020 election and
       found only one instance in which a vote was cast on behalf of a person who died prior to
       the election. Mark Brnovich, Arizona Attorney General to The Honorable Karen Fann, Ari-
       zona Senate President, (Aug. 1, 2022), available at https://www.azag.gov/sites/default/
       files/2022-08/Letter%20to%20Fann%20-%20EIU%20Update%20080122.pdf. In Michigan, the
       Senate Oversight Committee found only two instances in which votes were cast in the
       names of dead people: one was a clerical error (poll worker attributed vote to deceased
       father of person with same name residing at same address) and the other was a woman
       who died four days before the election but had sent in her absentee ballot before her
       death. Michigan Senate Oversight Committee, Report on the November 2020 Election in
                                           THE BIG LIE                                          259

       Michigan, (June 23, 2021), available at https://misenategopcdn.s3.us-east-
       1.amazonaws.com/99/doccuments/20210623/SMPO_2020ElectionReport_2.pdf.
302.   In an email obtained by the Select Committee, Katherine Friess, a lawyer who worked
       closely with Giuliani, shared this information with Giuliani and noted, “I don’t think this
       makes a particularly strong case.” Documents on file with the Select Committee to Investi-
       gate the January 6th Attack on the U.S. Capitol (Christina Bobb Production), BOBB-
       _CONG_00000621 (January 4, 2021, email from Katherine Friess re: Chairman Graham dead
       votes memo for your consideration).
303.   Documents on file with the Select Committee to Investigate the January 6th Attack on the
       U.S. Capitol (Cleta Mitchell Production), CM00026036 (January 5, 2021 email from Cleta
       Mitchell to Richard Perry re: GA Data request by Senator Graham); Documents on file with
       the Select Committee to Investigate the January 6th Attack on the U.S. Capitol (Christina
       Bobb Production), BOBB_CONG_00000621 (January 4, 2021, email from Katherine Friess re:
       Chairman Graham dead votes memo for your consideration); Select Committee to Investi-
       gate the January 6th Attack on the United States Capitol, Transcribed Interview of Christina
       Bobb, (Apr. 21, 2022), pp. 141-42.
304.   Documents on file with the Select Committee to Investigate the January 6th Attack on the
       U.S. Capitol (Christina Bobb Production), BOBB_CONG_00000621 (January 4, 2021, email
       from Katherine Friess re: Chairman Graham dead votes memo for your consideration).
305.   ABC News, “Lindsey Graham Delivers Remarks on Capitol Breach,” YouTube, at 3:05-3:30,
       Jan. 6, 2021, available at https://www.youtube.com/watch?v=JKHkYlRm_XM.
306.   Documents on file with the Select Committee to Investigate the January 6th Attack on the
       United States Capitol, (Chapman University Production), Chapman060742, (Dec. 31, 2020
       email from John Eastman to Alex Kaufman and Kurth Hibert); see also Documents on file
       with the Select Committee to Investigate the January 6th Attack on the United States Capi-
       tol, (National Archives Production), 076P-R000008384_0001 (December 31, 2020, email from
       Eric Herschmann to Cleta Mitchell and cc’ed to Mark Meadows and Molly Michael in which
       Herschmann wrote: “I was concerned about the President signing a verification about facts
       that may not be sustainable upon detailed scrutiny.”).
307.   Order Re Privilege of Remaining Documents at 17, Eastman v. Thompson, No. 8:22-cv-99-
       DOC_DFM, (Oct. 19, 2022), ECF no. 372, available at https://www.courtlistener.com/docket/
       62613089/372/john-c-eastman-v-bennie-g-thompson/.
308.   Order Re Privilege of Remaining Documents at 17, Eastman v. Thompson, Case 8:22-cv-
       00099-DOC_DFM, (Oct. 19, 2022), ECF no. 372, available at https://www.courtlistener.com/
       docket/62613089/372/john-c-eastman-v-bennie-g-thompson/.
309.   “Transcript of Trump’s Speech at Rally Before US Capitol Riot,” Associated Press, (Jan. 13,
       2021), https://apnews.com/article/election-2020-joe-biden-donald-trump-capitol-siege-
       media-e79eb5164613d6718e9f4502eb471f27.
310.   “Transcript of Trump’s Speech at Rally Before US Capitol Riot,” Associated Press, (Jan. 13,
       2021), https://apnews.com/article/election-2020-joe-biden-donald-trump-capitol-siege-
       media-e79eb5164613d6718e9f4502eb471f27.
311.   “Transcript of Trump’s Speech at Rally Before US Capitol Riot,” Associated Press, (Jan. 13,
       2021), https://apnews.com/article/election-2020-joe-biden-donald-trump-capitol-siege-
       media-e79eb5164613d6718e9f4502eb471f27.
312.   See “Donald Trump 2020 Election Night Speech Transcript,” Rev, (Nov. 4, 2020), available at
       https://www.rev.com/blog/transcripts/donald-trump-2020-election-night-speech-
       transcript.
313.   See “Donald Trump Speech ‘Save America’ Rally Transcript January 6,” Rev, (Jan. 6, 2021),
       available at https://www.rev.com/blog/transcripts/donald-trump-speech-save-america-
       rally-transcript-january-6.
314.   “Transcript of Trump’s Speech at Rally Before US Capitol Riot,” Associated Press, (Jan. 13,
260                                         CHAPTER 1

       2021), https://apnews.com/article/election-2020-joe-biden-donald-trump-capitol-siege-
       media-e79eb5164613d6718e9f4502eb471f27.
315.   Donald J. Trump (@realDonaldTrump), Twitter, Dec. 19, 2020, 1:42 a.m. ET, available at
       https://www.thetrumparchive.com/?searchbox=%22wild+protest%22 (archived).
316.   “Transcript of Trump’s Speech at Rally Before US Capitol Riot,” Associated Press, (Jan. 13,
       2021), https://apnews.com/article/election-2020-joe-biden-donald-trump-capitol-siege-
       media-e79eb5164613d6718e9f4502eb471f27.
317.   “Transcript of Trump’s Speech at Rally Before US Capitol Riot,” Associated Press, (Jan. 13,
       2021), https://apnews.com/article/election-2020-joe-biden-donald-trump-capitol-siege-
       media-e79eb5164613d6718e9f4502eb471f27.


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