unfounded claims regarding State Farm Arena, and the two top Justice Department officials again rebutted the allegations, telling him that the Justice Department had reviewed videotape and interviewed witnesses, and had not identified any suspicious conduct.
30. On December 31, the Defendant signed a verification affirming false election fraud allegations made on his behalf in a lawsuit filed in his name against the Georgia Governor. In advance of the filing, Co-Conspirator 2—who was advising the Defendant on the lawsuit—acknowledged in an email that he and the Defendant had, since signing a previous verification, “been made aware that some of the allegations (and evidence proffered by the experts) has been inaccurate” and that signing a new affirmation “with that knowledge (and incorporation by reference) would not be accurate.” The Defendant and Co-Conspirator 2 caused the Defendant’s signed verification to be filed nonetheless.
31. On January 2, four days before Congress’s certification proceeding, the Defendant and others called Georgia’s Secretary of State. During the call, the Defendant lied to the Georgia Secretary of State to induce him to alter Georgia’s popular vote count and call into question the validity of the Biden electors’ votes, which had been transmitted to Congress weeks before, including as follows:
a. The Defendant raised allegations regarding the State Farm Arena video and repeatedly disparaged one of the same election workers that Co-Conspirator 1 had maligned on December 10, using her name almost twenty times and falsely referring to her as “a professional vote scammer and hustler.” In response, the Georgia Secretary of State refuted this: “You’re talking about the State Farm video. And I think it’s extremely unfortunate that [Co-Conspirator 1] or his people, they sliced and diced that video and took it out of context.” When the Georgia Secretary of State then offered a link to a video that would disprove Co-Conspirator 1’s claims, the Defendant responded, “I don’t care about a link, I don’t need it. I have a much, [Georgia Secretary of State], I have a much better link.”
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