Page:USA v Trump-Jan6 Indictment.pdf/23

 55. The plan began in early December, and ultimately, the conspirators and the Defendant’s Campaign took the Wisconsin Memo and expanded it to any state that the Defendant claimed was “contested”—even New Mexico, which the Defendant had lost by more than ten percent of the popular vote. This expansion was forecast by emails the Defendant’s Chief of Staff sent on December 6, forwarding the Wisconsin Memo to Campaign staff and writing, “We just need to have someone coordinating the electors for states.”

56. On December 6, the Defendant and Co-Conspirator 2 called the Chairwoman of the Republican National Committee to ensure that the plan was in motion. During the call, Co-Conspirator 2 told the Chairwoman that it was important for the RNC to help the Defendant’s Campaign gather electors in targeted states, and falsely represented to her that such electors’ votes would be used only if ongoing litigation in one of the states changed the results in the Defendant’s favor. After the RNC Chairwoman consulted the Campaign and heard that work on gathering electors was underway, she called and reported this information to the Defendant, who responded approvingly.

57. On December 7, Co-Conspirator 1 received the Wisconsin Memo and the Fraudulent Elector Memo. Co-Conspirator 1 spoke with Co-Conspirator 6 regarding attorneys who could assist in the fraudulent elector effort in the targeted states, and he received from Co-Conspirator 6 an email identifying attorneys in Arizona, Georgia, Michigan, Nevada, New Mexico, Pennsylvania, and Wisconsin.

58. The next day, on December 8, Co-Conspirator 5 called the Arizona attorney on Co-Conspirator 6’s list. In an email after the call, the Arizona attorney recounted his conversation with Co-Conspirator 5 as follows:

I just talked to the gentleman who did that memo, [Co-Conspirator 5]. His idea is basically that all of us (GA, WI, AZ, PA,