Page:CTRL0000034608 - Deposition of John Eastman, (Dec. 9, 2021).pdf/25

25 electoral votes on January 6th, 2021?

Fifth.

If you look at exhibit 16 -- I'm staying on the topic of that two-page memo -- but exhibit 16 is an opinion and commentary under the heading "Viewpoints" published in The Sacramento Bee. It indicates that it was authored by you.

In that commentary, you describe your two-page memo, which I believe is the one we just went over, as, quote, "a preliminary and incomplete one, a draft of a more complete memo that outlined all the scenarios that had become topics of discussion following the November 2020 election," close quote.

Do you know whether your two-page memo, despite being preliminary and incomplete, was provided to the President of the United States?

Fifth.

Do you know whether that memo was provided to any advisers of the President of the United States?

Fifth.

Dr. Eastman, did you write the opinion piece that's in tab 16?

Fifth.

Okay. Just so I understand, Dr. Eastman, you're invoking your Fifth Amendment right against self-incrimination to question whether this opinion and commentary piece with the byline John C. Eastman, you're invoking the Fifth Amendment right to not answer that question?

On advice of counsel, I'm invoking the Fifth.

Okay. I'm going to pause there to see if any members have any questions. And we're still on the first memo, so we haven't yet gotten to the longer version of the memo.