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 election. In fact, the same day that the electoral college met and voted former Vice President Joe Biden as the winner of the 2020 Presidential election, Shirkey received another call from President Trump and issued another public statement. Shirkey's statement that day, December 14, 2020, read: "Michigan's Democratic slate of electors should be able to proceed with their duty, free from threats of violence and intimidation" and "[i]t is our responsibility as leaders to follow the law . . . ."

Publicly, President Trump used both Twitter posts and paid social media and cable television ads to advance his pressure campaign.

In Arizona, for example, President Trump used social media to both praise and criticize legislators. When Speaker Bowers and Senate President Karen Fann requested an audit of Maricopa County's election software and equipment, President Trump publicly commended them, retweeting a press release about their announcement and commenting: "Thank you to Senate President Karen Fann and House Speaker Russell Bowers—and all, for what you are doing in Arizona. A fast check of signatures will easily give us the state." But just days later, President Trump assailed Bowers for opposing a special session to appoint new electors. He retweeted a post by Campaign lawyer Christina Bobb that accused Bowers of "intentionally misleading the people of Arizona" and that included a demand by Stop-the-Steal organizer Ali Alexander for 50,000 phone calls to Rusty Bowers "[r]ight the heck now" to threaten him with a primary challenge.

And, as his efforts to change the outcome of the election continued to meet resistance, President Trump personally approved a series of advertisements that the Campaign ran on cable television and social media in several important States. One advertisement in Arizona called for pressure on Governor Ducey in particular, alleging, "The evidence is overwhelming. Call Governor Ducey and your legislators. Demand they inspect the machines and hear the evidence." Another claimed that "illegal aliens voted, and here in Arizona Trump votes were discarded. It's an outrage. Call Governor Ducey and your legislators at 602–542–4331. Demand they inspect the machines and hear the evidence. Call Governor Ducey, at 602–542–4331. Stand up for President Trump. Call today. Paid for by Donald J. Trump for President, Inc."

Several days earlier, Trump Campaign Senior Advisor Jason Miller had explained the intention for this round of advertisements in an email. He wrote that, "the President and Mayor Giuliani want to get back up on TV ASAP, and Jared [Kushner] has approved in budgetary concept, so here's the gameplan" in order to "motivate the GOP base to put pressure on the Republican Governors of Georgia and Arizona and the Republican-controlled State legislatures in Wisconsin and Michigan to hear evidence of