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 b. The Defendant asked about rumors that paper ballots cast in the election were being destroyed, and the Georgia Secretary of State’s Counsel explained to him that the claim had been investigated and was not true.

c. The Defendant claimed that 5,000 dead people voted in Georgia, causing the Georgia Secretary of State to respond, “Well, Mr. President, the challenge that you have is the data you have is wrong. The actual number were two. Two. Two people that were dead that voted. And so [your information]’s wrong, that was two.”

d. The Defendant claimed that thousands of out-of-state voters had cast ballots in Georgia’s election, which the Georgia Secretary of State’s Counsel refuted, explaining, “We’ve been going through each of those as well, and those numbers that we got, that [Defendant’s counsel] was just saying, they’re not accurate. Every one we’ve been through are people that lived in Georgia, moved to a different state, but then moved back to Georgia legitimately they moved back in years ago. This was not like something just before the election.”

e. In response to multiple other of the Defendant’s allegations, the Georgia Secretary of State’s Counsel told the Defendant that the Georgia Bureau of Investigation was examining all such claims and finding no merit to them.

f. The Defendant said that he needed to “find” 11,780 votes, and insinuated that the Georgia Secretary of State and his Counsel could be subject to criminal prosecution if they failed to find election fraud as he demanded, stating, “And you are going to find that they are—which is totally illegal—it’s, it’s, it’s more illegal for you than it is for them because you know what they did and you’re not reporting it. That’s a criminal, you know, that’s a criminal offense. And you know, you can’t let that happen. That’s a big risk to you and to [the Georgia Secretary of State’s Counsel], your lawyer.”

32. The next day, on January 3, the Defendant falsely claimed that the Georgia Secretary of State had not addressed the Defendant’s allegations, publicly stating that the Georgia Secretary of State “was unwilling, or unable, to answer questions such as the ‘ballots under table’ scam, ballot destruction, out of state ‘voters’, dead voters, and more. He has no clue!”

33. On January 6, the Defendant publicly repeated the knowingly false insinuation that more than 10,300 dead people had voted in Georgia.