Page:CTRL0000034608 - Deposition of John Eastman, (Dec. 9, 2021).pdf/30

30 Fifth.

Dr. Eastman, was anyone else involved in writing this memo?

Fifth.

Okay. Going back to exhibit 16, again, the Sacramento Bee article, you wrote, quote, "Neither version of the memo reflects the advice I gave to then-Vice President Pence, paren, (though, to be precise, the final scenario laid out in the complete memo does), close paren," close quotes.

Was this six-page memo, which you say does not reflect the advice you gave to the Vice President, nonetheless given to President Donald Trump?

Fifth.

Dr. Eastman, was the six-page memo given to any advisers of the President?

Fifth.

Dr. Eastman, did you write a memo that did not reflect your actual advice?

Fifth.

Dr. Eastman, did your view regarding the Vice President's role change after you wrote the six-page memo?

Fifth.

Turning to the memo itself, the memo then, quote, "war games," close quote, several scenarios, including scenarios in which the Vice President rejects ballots from certain States and President Trump is elected.

Dr. Eastman, on the bottom of page 4 of your memo, did you advise the President of the United States that if State legislatures in contested States certified the Trump electors, the Vice President could count those electors and, quote, "Trump wins," close quote?

Fifth.