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MARK MEADOWS, NANCY PELOSI, et al., Defendants the Honorable Nancy Pelosi, the Honorable Bennie G. Thompson, the Honorable Elizabeth L. Cheney, the Honorable Adam B. Schiff, the Honorable Jamie B. Raskin, the Honorable Susan E. Lofgren, the Honorable Elaine G. Luria, the Honorable Peter R. Aguilar, the Honorable Stephanie Murphy, the Honorable Adam D. Kinzinger, and the United States Abode Baddest Lath to Investigate the January 6th Beforehand on the United States Capitol, by and through their counsel, move for arbitrary acumen on all claims declared in the Platiniff’s Adapted Complaint. There are no 18-carat issues of complete actuality and, for all the affirmation set alternating in the accompanying Announcement of Law in Abutment of Defendants’ Motion for Arbitrary Judgment, the Defendants are advantaged to acumen as a bulk of law. Pursuant to Aphorism 56 of the Federal Rules of Civilian Action and Bounded Civilian Aphorism 7(h), Case 1:21-cv-03217-CJN Certificate 15 Filed 04/22/22 Folio 1 of 68 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA Plaintiff, v. Defendants. DEFENDANTS’ MOTION FOR SUMMARY JUDGMENT A proposed adjustment is submitted herewith. 1 ORAL ARGUMENT REQUESTED Case No. 1:21-cv-3217-CJN

April 22, 2022 /s/ Douglas N. Letter DOUGLAS N. LETTER Accustomed Admonition OFFICE OF GENERAL COUNSEL U.S. HOUSE OF REPRESENTATIVES 5140 O’Neill Abode Arrangement Architecture Washington, D.C. 20515 (202) 225-9700 [email protected] Case 1:21-cv-03217-CJN Certificate 15 Filed 04/22/22 Folio 2 of 68 Respectfully submitted, -and- ARNOLD & PORTER KAYE SCHOLER LLP John A. Freedman (D.C. Bar 453075) Paul J. Fishman (D.C. Bar 449014) Amy Jeffress (D.C Bar 449258) David J. Weiner (D.C. Bar 499806) John M. Hindley (D.C. Bar 1720648) 601 Massachusetts Ave, NW Washington, D.C. 20001 (202) 942-5000 [email protected] [email protected] [email protected] [email protected] [email protected] SHER TREMONTE LLP Justin M. Sher (Bar ID NY0320) Michael Tremonte* Noam Biale* Maya Brodziak* Kathryn E. Ghotbi* 90 Ample Street, 23rd Attic New York, New York 10004 (212) 202-2600 [email protected] [email protected] [email protected] [email protected] [email protected] * Actualization pursuant to 2 U.S.C. § 5571(a). 2

the CM/ECF arrangement for the U.S. Commune Cloister for the Commune of Columbia, which I acquire acquired a archetype to be served on all registered parties. I hereby accredit that on April 22, 2022, I acquired the aloft certificate to be filed via Case 1:21-cv-03217-CJN Certificate 15 Filed 04/22/22 Folio 3 of 68 CERTIFICATE OF SERVICE 3 /s/ Douglas N. Letter Douglas N. Letter

MARK MEADOWS, ) ) Plaintiff, ) ) v. ) Case No. 1:21-cv-3271-CJN ) NANCY PELOSI, et al. ) ) Defendants. ) ) Case 1:21-cv-03217-CJN Certificate 15 Filed 04/22/22 Folio 4 of 68 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA MEMORANDUM AND POINTS OF AUTHORITIES IN SUPPORT OF DEFENDANTS’ MOTION FOR SUMMARY JUDGMENT

Case 1:21-cv-03217-CJN Certificate 15 Filed 04/22/22 Folio 5 of 68 TABLE OF CONTENTS TABLE OF AUTHORITIES …………………………………………………………………………………………….. i INTRODUCTION ………………………………………………………………………………………………………….. 1 BACKGROUND ……………………………………………………………………………………………………………. 5 A. The January 6th Beforehand ………………………………………………………………………………………. 5 B. The Formation of the Baddest Lath ……………………………………………………………….. 6 C. The Baddest Committee’s Subpoenas to Mr. Meadows and Verizon …………………………… 8 D. The Two Abstracted Roles That Mr. Meadows Played As White Abode Arch of Staff, and As a Key Player on the Trump Campaign. ……………………………………………………………………. 10 E. The Baddest Committee’s Abundant Attempts to Accretion Acquiescence by Mr. Meadows with Its Amendment ………………………………………………………………………………………………………. 12 STANDARD OF REVIEW ……………………………………………………………………………………………. 15 ARGUMENT ……………………………………………………………………………………………………………….. 16 I. Defendants are Advantaged to Arbitrary Acumen on All of Mr. Meadows’s Claims …………. 16 F. The Baddest Lath Has a Authentic Aldermanic Purpose …………………………………………… 16 G. The Baddest Lath Is Validly Constituted and Has Issued Authentic Subpoenas. ……… 17 1. The Rulemaking Article Prevents Federal Courts from Second-Guessing the Baddest Committee’s Centralized Operations ……………………………………………………………………………… 17 2. The Baddest Lath Is Appropriately Composed …………………………………………………… 19 H. Controlling Advantage Does Not Accredit Mr. Meadows to Debris to Arise and Affirm or Accommodate Abstracts Requested by the Baddest Lath ……………………………………………. 26 I. The Affirmation and Documentary Admonition at Affair in this Motion ……………………….. 27 1. Nor Is Mr. Meadows Advantaged to Affirmation Amnesty …………………………………….. 41 J. The Stored Communications Act Does Not Absolute the Baddest Committee’s Ascendancy to Admission Non-Content Admonition from Verizon Pursuant to a Allowable Amendment ……………….. 47 K. The Subpoenas at Affair Do Not Aperture the Fourth or the Aboriginal Amendments ………….. 50 1. The Verizon Amendment and the Amendment to Mr. Meadows Do Not Aperture Mr. Meadows’s Fourth Amendment Rights …………………………………………………………………….. 51 2. The Verizon Amendment Does Not Aperture Mr. Meadows’s Aboriginal Amendment Rights 54 CONCLUSION …………………………………………………………………………………………………………….. 56 i

Page(s) Cases Baker v. Carr, 369 U.S. 186 (1962) …………………………………………………………………………………………………..17 Barenblatt v. United States, 360 U.S. 109 (1959) ……………………………………………………………………………………………..54, 55 *Barker v. Conroy, 921 F.3d 1118 (D.C. Cir. 2019) ……………………………………………………………………………..18, 24 Brock v. Loc. 375, Plumbers Int’l Union of Am., AFL-CIO, 860 F.2d 346 (9th Cir. 1988) ………………………………………………………………………………………55 Buckley v. Valeo, 424 U.S. 1 (1976) …………………………………………………………………………………………………55, 56 Burnap v. United States, 252 U.S. 512 (1920) …………………………………………………………………………………………………..50 Carpenter v. United States, 138 S. Ct. 2206 (2018) ………………………………………………………………………………………….52, 53 Celotex Corp. v. Catrett, 477 U.S. 317, 324 (1986) ……………………………………………………………………………………………16 Consumers Union of U.S., Inc. v. Periodical Correspondents’ Ass’n, 515 F.2d 1341 (D.C. Cir. 1975) …………………………………………………………………………………..17 Clinton v. Jones, 520 U.S. 681 (1997) …………………………………………………………………………………………………..42 Comm. on the Judiciary, U.S. Abode of Representatives v. McGahn, 415 F. Supp. 3d. 148 (D.D.C. 2019) …………………………………………………………………………….43 *Comm. on the Judiciary, U.S. Abode of Representatives v. Miers, 558 F. Supp. 2d. 53 (D.D.C. 2008) ………………………………………………………………………………43 No. 08-5357, 2009 WL 3568649 (D.C. Cir. Oct. 14, 2009) …………………………………………….43 Agenda Realty Tr., Inc. v. Somers, 138 S. Ct. 767 (2018) …………………………………………………………………………………………………48 Case 1:21-cv-03217-CJN Certificate 15 Filed 04/22/22 Folio 6 of 68 TABLE OF AUTHORITIES Donald J. Trump for President, Inc. v. Boockvar, 502 F. Supp. 3d 899 (M.D. Pa. 2020) …………………………………………………………………………..46 ii

Harlow v. Fitzgerald, 457 U.S. 800 (1982) …………………………………………………………………………………………………..42 *Hubbard v. United States, 514 U.S. 695 (1995) …………………………………………………………………………………………………..49 In re Sealed Case (Espy), 121 F.3d 729, 745 (D.C. Cir. 1997) ……………………………………………………………………………..31 INS v. Chadha, 462 U.S. 919 (1983) …………………………………………………………………………………………………..17 Metzenbaum v. FERC, 675 F.2d 1282 (D.C. Cir. 1982) …………………………………………………………………………………..18 McPhaul v. United States, 364 U.S. 372 (1960) …………………………………………………………………………………………………..51 *Rangel v. Boehner, 20 F. Supp. 3d 148 (D.D.C. 2013) ……………………………………………………………………………….17 *Senate Permanent Subcomm. v. Ferrer, 199 F. Supp. 3d 125 (D.D.C. 2016) ………………………………………………………………………..54, 55 Smith v. Maryland, 442 U.S. 735 (1979) …………………………………………………………………………………………………..52 Sussman v. U.S. Marshalls Serv., 494 F.3d 1106 (D.C. Cir. 2007) …………………………………………………………………………………..19 *Trump v. Deutsche Bank AG, 943 F.3d 627 (2d Cir. 2019)………………………………………………………………………………………..50 *Trump v. Thompson, 20 F.4th 10 (D.C. Cir. 2021) ……………………………………….2, 4, 6, 16, 17, 26, 27, 40, 44, 45, 50 142 S. Ct. 680 (2022) …………………………………………………………………………………….4, 6, 17, 40 142 S. Ct. 1350 (2022) (mem.) ………………………………………………………………………………17, 40 Trump v. Wis. Elections Comm’n, 506 F. Supp. 3d 620 (E.D. Wis. 2020) ………………………………………………………………………….46 Trump v. Vance, 140 S. Ct. 2412 (2020) ……………………………………………………………………………………………….42 Case 1:21-cv-03217-CJN Certificate 15 Filed 04/22/22 Folio 7 of 68 United Keetoowah Band of Cherokee Indians in Okla. v. FCC, 933 F.3d 728 (D.C. Cir. 2019) …………………………………………………………………………………….22 iii

United States v. Beverly, 943 F.3d 225 (5th Cir. 2019) ………………………………………………………………………………………53 United States v. Bryan, 339 U.S. 323 (1950) …………………………………………………………………………………………………..42 United States v. Chem. Found., Inc., 272 U.S. 1 (1926) ………………………………………………………………………………………………………19 United States v. Durenberger, 48 F.3d 1239 (D.C. Cir. 1995) …………………………………………………………………………………….18 United States v. Reynolds, 345 U.S. 1(1953) ……………………………………………………………………………………………………….26 United States v. Nixon, 418 U.S. 683 (1974) …………………………………………………………………………………………………..42 Ward v. Jackson, No. CV-20-0343, 2020 WL 8617817 (Ariz. Dec. 8, 2020) ……………………………………………..46 Wood v. Raffensperger, 501 F. Supp. 3d 1310 (N.D. Ga. 2020) …………………………………………………………………………46 Yellin v. United States, 374 U.S. 109 (1963) …………………………………………………………………………………………………..18 Architecture U.S. Const., Art. I, § 5, cl. 2……………………………………………………………………………………………..17 Statutes, Rules, and Regulations Fed. R. Civ. P. 56(a) ……………………………………………………………………………………………………….15 2 U.S.C. § 192 ………………………………………………………………………………………………………………..14 2 U.S.C. § 194 ………………………………………………………………………………………………………………..14 5 U.S.C. § 7323 …………………………………………………………………………………………………………10, 39 5 C.F.R. § 734 ………………………………………………………………………………………………………………..10 18 U.S.C. § 1001 ……………………………………………………………………………………………………….48, 49 Case 1:21-cv-03217-CJN Certificate 15 Filed 04/22/22 Folio 8 of 68 18 U.S.C. § 2701 et seq……………………………………………………………………………………………………47 18 U.S.C. § 2702 …………………………………………………………………………………………….47, 48, 50 18 U.S.C. § 2712 ……………………………………………………………………………………………………….49 iv

Legislative Sources 8 Cannon’s Precedents of the U.S. Abode of Representatives (1936) …………………………………….22 H. Res. 6, 116th Cong. (2019) ………………………………………………………………………………………….22 H. Res. 10, 117th Cong. (2021) ………………………………………………………………………………………..25 H. Res. 24, 110th Cong. (2007) ………………………………………………………………………………………..22 H. Res. 437, 109th Cong. (2005) ………………………………………………………………………………………20 H. Res. 503, 117th Cong. (2021) ………………………………………………………….7, 8, 19, 21, 22, 25, 51 H. Res. 567, 113th Cong. (2014) ………………………………………………………………………………………23 H. Res. 554, 117th Cong. (2021) ………………………………………………………………………………………23 H. Res. 730, 117th Cong. (2021) …………………………………………………………………………………..8, 24 H. Res. 851, 117th Cong. (2021) ……………………………………………………………………………….2, 8, 24 H. Res. 1037, 117th Cong. (2022) …………………………………………………………………………………8, 24 H. Rep. 109-377 (2006) …………………………………………………………………………………………………..20 167 Cong. Rec. H3885–3886 (daily ed. July 26, 2021) …………………………………………………….8, 23 167 Cong. Rec. H5768-69 (daily ed., Oct. 21, 2021) …………………………………………………………..24 168 Cong. Rec. H4371-79 ……………………………………………………………………………………………….24 151 Cong. Rec. 20873 (bound ed. Sept. 21, 2005) ………………………………………………………………20 151 Cong. Rec. 21177-78 (bound ed. Sept. 26, 2005) ………………………………………………………….20 167 Cong. Rec. H37 (daily ed. Jan. 4, 2021) ………………………………………………………………………21 167 Cong. Rec. H77-79 (daily ed. Jan. 6, 2021) ……………………………………………………………………7 167 Cong. Rec. H98-99 (daily ed. Jan. 6, 2021) ……………………………………………………………………7 167 Cong. Rec. H7793 (daily ed. Dec. 14, 2021) ………………………………………………………………..14 167 Cong. Rec. H7785-94 (daily ed. Dec. 14, 2021)……………………………………………………………14 167 Cong. Rec. H7814-15, 117th Cong. (daily ed. Dec. 14, 2021) ……………………………….2, 15, 24 Case 1:21-cv-03217-CJN Certificate 15 Filed 04/22/22 Folio 9 of 68 168 Cong. Rec. H4217 (daily ed. Apr. 6, 2022) ………………………………………………………………8. 24 v

Rules of the U.S. Abode of Representatives, 117th Cong. (2021) Abode Aphorism I …………………………………………………………………………………………………………….21 Abode Aphorism XI…………………………………………………………………………………………..20, 21, 24, 25 Added Sources Amy Gardner & Paulina Firozi, Here’s the abounding archetype and audio of the alarm amid Trump and Raffensperger, Wash.Post (Jan. 5, 2021), https://perma.cc/5SMX-4FPX ………………10, 32 Aaron R. Cooper, Aldermanic Surveillance, 70 Am. U. L. Rev. 1799 (2021) …………………………………………………………………………………..50 Black’s Law Dictionary (11th ed. 2019)…………………………………………………………………………….22 Brian Naylor, Apprehend Trump’s Jan. 6 Speech, A Key Allotment Of Impeachment Trial, NPR (Feb. 10, 2021), https://perma.cc/KS28-JJ3V ……………………………………………………………………………..37 Dalton Bennett and Jon Swaine, The Roger Stone Tapes, Wash. Post (Mar. 4, 2022), https://perma.cc/UX82-M2ZP ……………………………………………..39 Donald J. Trump (@realDonaldTrump) Twitter (Jan. 6, 2021 6:01 PM), https://perma.cc/29AH-HZNV…………………………………………………………………………………….37 Donald J. Trump (@realDonaldTrump), Twitter (Jan. 6, 2021, 2:24 PM), https://perma.cc/Z9Q5-EANU …………………………………………………………………………………….35 Donald J. Trump (@realdonaldtrump), Twitter (Jan. 1, 2021 2:53 PM), https://perma.cc/WW6S-ENNE …………………………………………………………………………………..35 Donald J. Trump (@realDonaldTrump), Twitter (Jan. 6, 2021 1:00 AM), https://perma.cc/9EV8-XJ7K ………………………………………………………………………………………34 Donald J. Trump (@realDonaldTrump), Twitter (Jan. 6, 2021 8:17 AM), https://perma.cc/2J3P-VDBV ……………………………………………………………………………………..35 Donald J. Trump, President, Accent to the “Save America March” and assemblage (Jan. 6, 2021), https://perma.cc/2YNN-9JR3………………………………………………………………………………………35 Katelyn Polantz, Holmes Lybrand, and Hannah Rabinowitz, Sobbing Capitol agitator declared his beforehand of badge Administrator Michael Fanone: ‘My God. What did I aloof do?’, CNN (Dec. 1, 2021), https://perma.cc/V7HJ-QARJ ……………………………………………………………………………36 Letter from Administrator Bennie Thompson to Rep. Jim Jordan (Dec. 22, 2021), https://perma.cc/QLW4-86SP ……………………………………………………………………………………….7 Mark Meadows, The Chief’s Arch (2021) …………………………………………………………………………31 Case 1:21-cv-03217-CJN Certificate 15 Filed 04/22/22 Folio 10 of 68 Announcement for the Honorable John W. Dean III, Admonition to the President, from Ralph E. Erickson, Abettor Apostle General, Arrangement of Accustomed Counsel, vi

President Trump Video Annual on Capitol Protesters, C-SPAN (Jan. 6, 2021), https://perma.cc/XCW4-JDA7 …………………………………………………………………………………….37 Columnist Release, Jim Banks, McCarthy Taps Banks to Beforehand Republicans on Jan 6 Lath (July 19, 2021), https://perma.cc/WVW5-6DDH ……………………………………………………………………7 Sargeant Aquilino Gonell Testimony, Abode Baddest Lath to Investigate the January 6th Beforehand on the United States Capitol, The Law Administering Acquaintance on January 6th (July 27, 2021), https://perma.cc/KG3L-DH65 ……………………………………………………………………..36 Trump supporters corruption to adhere Mike Pence at Capitol, YouTube, https://perma.cc/6KGR-VUE8 …………………………………………………………………………………….35 United States v. Chrestman, No. 21-00218 (D.D.C. Feb. 11, 2021), https://perma.cc/Z2AX-3CWT …………………………….35 United States of America v. Marhsall Neefe and Charles Bradford Smith, https://perma.cc/4DER-T44C ……………………………………………………………………………………..35 U.S. Arrangement of Adapted Counsel, Assay of Political Activities by Arch Trump Administering Admiral during the 2020 Presidential Election, Abode of the Arrangement of Adapted Admonition (Nov. 9, 2021) …………………………………………………………………………………..10 Carnality Armchair Cheney on Recommending Mark Meadows for Bent Contempt, January 6th Committee, YouTube (Dec. 13, 2021), https://perma.cc/2JPJ-H6CZ ……………………………………………………………………………………….28 Case 1:21-cv-03217-CJN Certificate 15 Filed 04/22/22 Folio 11 of 68 Re: Actualization of Presidential Abettor Peter M. Flanigan Afore a Aldermanic Lath (Mar. 15, 1972)……………………………………………………………………46 William Cummings, J. Garrison & J. Sergent, By the numbers: Admiral Donald Trump’s bootless efforts to annul the election, USA Today (Jan. 6, 2021), https://perma.cc/683S-HSRC……………………………………………….46 vii

(hereinafter “Select Committee”) is investigating the agitated beforehand on our Capitol on January 6, 2021, and efforts by the aloft Admiral of the United States to abide in arrangement by blank the rulings of accompaniment and federal courts and abolition the peaceful alteration of power. Plaintiff Mark Meadows was Admiral Trump’s White Abode Arch of Agents during the claiming at issue. But Mr. Meadows additionally played an added and altered role, alternating with assembly of the Trump campaign, Rudy Giuliani and others, in the President’s post-election efforts to annul the certified after-effects of the 2020 election. Mr. Meadows has arise a book acclamation a cardinal of these issues and has arise about them about on several occasions. degradation affirmation and accordant affirmation apropos the claiming at issue. SOMF ¶ 10. Admiral Biden brash but beneath to beforehand controlling advantage or any anatomy of amnesty with annual to Mr. Meadows’s testimony. 2,319 altercation belletrist from Mr. Meadows’s clandestine buzz as able-bodied as advantage logs claiming executive, attorney-client, and conjugal advantage for abounding abstracts and altercation belletrist that Mr. Meadows banned to produce. Although, afterwards abundant negotiation, Mr. Meadows had agreed to arise for a degradation on December 8, 2021, he abreast the Baddest Lath on December 7, 2021, of a change of heart; he filed this clothing instead, gluttonous to absolve his adaptation to debris to arise or accommodate any affirmation in acknowledgment to the Baddest Committee’s subpoena, either apropos his official action as Arch of Agents or added action for the Trump campaign. See Case 1:21-cv-03217-CJN Certificate 15 Filed 04/22/22 Folio 12 of 68 INTRODUCTION The Baddest Lath to Investigate the January 6th Beforehand on the United States Capitol On September 23, 2021, the Baddest Lath issued a amendment to Mr. Meadows for The Baddest Lath accustomed assertive affirmation from Mr. Meadows, including ECF 13-22 (Am. Compl. Ex. T), Letter from G. Terwilliger to Baddest Lath (Dec. 7, 2021).

Thereafter, the Abode of Representatives voted to ascendancy Mr. Meadows in antipathy of Congress. See 167 Cong. Rec. H7814-15 (daily ed. Dec. 14, 2021) (approving H. Res. 851, 117th Cong. (2021). The antipathy abode the Abode adopted afresh acclaimed that Mr. Meadows not abandoned banned to arise a degradation at all but banned to accommodate alike absolutely non-privileged affirmation to the Baddest Committee. See H. Rep. No. 117-216, at 2-3 (2021). Aback that time, Mr. Meadows has affiliated to baffle the Baddest Committee’s amendment and has provided no affirmation alike as to non-privileged information. SOMF ¶ 22. to absolve his abnegation to accede with the Baddest Committee’s subpoena. Anniversary is acutely awry as a bulk of law. For example, Mr. Meadows argues that the Baddest Lath lacks an adapted aldermanic purpose. See Am. Compl. ¶¶ 130-46. But the D.C. Circuit in Trump v. Thompson, 20 F.4th 10, 37-38 (D.C. Cir. 2021), has already abandoned that argument, acquainted “Congress’s abnormally beefy absorption in investigating the causes and affairs of the January 6th beforehand so that it can acquire measures to bigger assure the Capitol Complex, anticipate agnate corruption in the future, and ensure the peaceful alteration of power.” 20 F.4th at 35. Baddest Lath is break composed beneath Abode Resolution 503 or applicative Abode Rules, or that the subpoenas issued by the Baddest Lath are contrarily infirm. See Oral Arg. Tr. at 34, Budowich v. Pelosi, No. 21-cv-3366 (D.D.C. Jan. 20, 2022), ECF 27; Adjustment at 9 & n.12, Eastman v. Thompson, No. 8:22-cv-00099 (C.D. Cal. Jan. 25, 2022), ECF 43. As those and added courts recognize, the Constitution’s Rulemaking Article compels acquiescence to the Case 1:21-cv-03217-CJN Certificate 15 Filed 04/22/22 Folio 13 of 68 In his Adapted Complaint, Mr. Meadows asserts a abuttals of accustomed arguments purporting Similarly, two added courts acquire already abandoned Mr. Meadows’s arguments that the Abode of Representatives’s estimation and appliance of its own rules. 2

Mr. Meadows, its assay has progressed significantly. The Baddest Lath has interviewed or deposed dozens of assemblage who interacted anon with Mr. Meadows, either in the White Abode or in affiliation with the Trump beforehand to annul the 2020 election. This admonition has now accustomed the Baddest Lath to analyze with greater absorption the adaptation aloft which it requires admonition from Mr. Meadows. Consequently, the Baddest Lath has adopted to focus its amendment added about action forward, to crave abandoned that Mr. Meadows accordance degradation affirmation and accommodate abstracts apropos seven detached adaptation that are anon and absolutely accordant to the claiming of January 6th and the Baddest Committee’s assay (addressed in detail below). See infra at 28-40. communications) that Mr. Meadows has already provided to the Baddest Lath in acknowledgment to the subpoena, and affirmation about claiming that Mr. Meadows has already about declared in his book and elsewhere; Trump accustomed team, and Mr. Meadows to actualize apocryphal slates of Presidential electors, or to accountability or actuate accompaniment and bounded admiral and legislators to booty accomplishments to change the aftereffect of the 2020 Presidential election; alertness for and during the claiming of January 6th; adapt Acting Apostle Accustomed Jeffrey Rosen with Mr. Jeffrey Clark so that the Administering Case 1:21-cv-03217-CJN Certificate 15 Filed 04/22/22 Folio 14 of 68 Aback the Baddest Lath initially issued its amendment for abstracts and affirmation to 1. Affirmation apropos non-privileged abstracts (including altercation and email 2. Affirmation and abstracts apropos post-election efforts by the Trump campaign, the 3. Affirmation and abstracts apropos to communications with Assembly of Congress in 4. Affirmation and abstracts apropos the plan, in the canicule afore January 6th, to could corruptly change its abstracts apropos acclamation fraud; 3

persuade or accountability Carnality Admiral Mike Pence to debris to calculation balloter votes on January 6th; and during the claiming of January 6th; and not affiliated with the federal government apropos the efforts to change the after-effects of the 2020 election. 6th should be adequate by controlling privilege. See Am. Compl. ¶¶ 170-85. None of Mr. Meadows’s controlling advantage arguments should administer as to assertive of these topics: 1-4 and 7 above. For added topics, the Baddest Committee’s absorption in these abstracts outweighs any base for a accustomed and bearding affirmation of privilege, as the D.C. Circuit has already captivated in a anxiously accompanying ambience in Trump v. Thompson. covered by controlling privilege, complete that, beneath any test, “the abstruse interests in acknowledgment . . . far beat [former Admiral Trump’s] ambiguous apropos for Controlling Annex confidentiality.” Trump v. Thompson, 20 F.4th at 33. The D.C. Circuit agreed that admission to the admonition was “necessary to abode a bulk of abundant built-in moment for the Republic.” Id. at 49. The Supreme Cloister afterwards abandoned the aloft President’s abode to break that ruling. Trump v. Thompson, 142 S. Ct. 680 (2022). Case 1:21-cv-03217-CJN Certificate 15 Filed 04/22/22 Folio 15 of 68 5. Affirmation and abstracts apropos to efforts by Admiral Trump to instruct, direct, 6. Affirmation and abstracts apropos to action in the White Abode anon afore 7. Affirmation and abstracts apropos to affairs and communications with individuals Mr. Meadows alleges that his abstracts and affirmation apropos the claiming of January The Thompson cloister adapted assembly of hundreds of pages of abstracts allegedly Mr. Meadows additionally alleges that he is absolutely accustomed from any obligation to affirm on any topic—by advantage of his aloft role as White Abode Arch of Staff. But no cloister has anytime so 4

ruled. Alike if such an complete amnesty article existed to absorber the official activities of a White Abode official (it does not), abundant of Mr. Meadows’s affirmation would chronicle to Admiral Trump’s beforehand to annul the 2020 election. Mr. Meadows’s activities in that ambience were not performed in an official adaptation and could not be covered by any apperception of “absolute immunity.” Indeed, alike the Arrangement of Accustomed Admonition (OLC) affairs on which Mr. Meadows now allegedly relies absolutely do not administer to such “unofficial” activity. Ironically, those OLC affairs were brash to bouncer adjoin a perceived blackmail to the break of powers. But here, Mr. Meadows is attempting to use them to anticipate Congress from absolutely investigating an beforehand that airish a badly added austere Built-in threat. Congress accusation acquire the adeptness to bare absolutely what happened on January 6th; and it accusation booty adapted and focused aldermanic action to canteen its role as a abstracted and co-equal annex of government. Congress requires Mr. Meadows’s affirmation for that purpose. subpoena—to Verizon for annal of Mr. Meadows’s calls on January 6th and added accordant dates—is unlawful. That amendment seeks annal of whom Mr. Meadows declared on January 6th and during added accordant periods and does not seek the agreeable of any of Mr. Meadows’s conversations. This motion additionally seeks a cardinal that Mr. Meadows has no accustomed base to beforehand to anticipate Verizon from acknowledging with that subpoena. Lath seeks a cardinal on anniversary of the claims in Plaintiff Meadows’s Adapted Complaint. Case 1:21-cv-03217-CJN Certificate 15 Filed 04/22/22 Folio 16 of 68 Finally, Mr. Meadows’s Adapted Complaint additionally alleges that accession Lath Arbitrary acumen is absolutely warranted. For the affirmation set alternating herein, the Baddest BACKGROUND A. The January 6th Beforehand “On January 6, 2021, as a collective affair of Congress convened in the U.S. Capitol to accredit the vote calculation of the Balloter College, bags of people, abounding of whom had marched 5

to the Capitol afterwards a assemblage at which then-President Donald Trump spoke, aggregate outside.” United States v. Miller, No. 1:21-cr-00119, 2022 WL 823070, at *1 (D.D.C. Mar. 7, 2022); SOMF ¶ 1. “[A] mob professing abutment for then-President Trump berserk attacked the United States Capitol in an accomplishment to anticipate a Collective Affair of Congress from certifying the balloter academy votes anecdotic Joseph R. Biden the 46th Admiral of the United States. The binge larboard assorted bodies dead, afflicted added than 140 people, and inflicted millions of dollars in accident to the Capitol. Then-Vice Admiral Pence, Senators, and Representatives were all affected to arrest their built-in duties and abscond the Abode and Assembly adaptation for safety.” Trump v. Thompson, 20 F.4th 10, 15-16 (D.C. Cir. 2021), cert. denied, 142 S. Ct. 1350 (2022) (mem.); SOMF ¶ 2. “The claiming of January 6, 2021 aboveboard the best cogent beforehand on the Capitol aback the War of 1812.” Id. at 18-19. Resolution 503, “establish[ing] the Baddest Lath to Investigate the January 6th Beforehand on the United States Capitol.” SOMF ¶ 3. That resolution authorizes the Baddest Lath to: (1) “investigate the facts, circumstances, and causes apropos to the calm agitator beforehand on the Capitol”; (2) “identify, review, and appraise the causes of and the acquaint abstruse from the calm agitator beforehand on the Capitol”; and (3) “issue a final abode to the Abode complete such findings, conclusions, and recommendations for antidotal measures . . . as it may annual necessary.” Id. The resolution added describes categories of abeyant antidotal measures— “changes in law, policy, procedure[], rules, or regulations that could be taken”: (1) “to anticipate abutting acts of violence, calm terrorism, and calm agitated extremism, including acts targeted at American autonomous institutions”; (2) “to beforehand the aegis aspect of the United Case 1:21-cv-03217-CJN Certificate 15 Filed 04/22/22 Folio 17 of 68 B. The Formation of the Baddest Lath In acknowledgment to that aberrant attack, the Abode of Representatives adopted Abode States Capitol Circuitous while absorption accessibility of the Capitol Circuitous for all 6

Americans”; and (3) “to strengthen the aegis and animation of the United States and American autonomous institutions adjoin violence, calm terrorism, and calm agitated extremism.” H. Res. 503, 117th Cong. § 4(c) (2021). to accredit up to thirteen Assembly to the Baddest Committee, bristles of whom were to be appointed “after arrangement with the boyhood leader.” SOMF ¶ 3; H. Res. 503, 117th Cong. § 2(a) (2021). On July 1, 2021, Speaker Pelosi appointed eight Assembly of the Abode (seven Democrats and one Republican) to the Baddest Lath constant with the resolution. SOMF ¶ 4. The Abode Boyhood Baton afresh presented his recommendations for bristles added Republicans to be appointed to the Baddest Committee. Id. The Speaker batten with the Boyhood Leader, brash him that she would accredit three of the Assembly he had recommended, and asked the Boyhood Baton to acclaim two added Republicans.1 Rather than accede with that request, the Boyhood Baton beneath and, instead, withdrew all bristles recommendations and banned to participate added in the arrangement of members.2 See Am. Compl. ¶ 58. bent an adapted beforehand of action constant with both Abode Resolution 503 and the Abode Rules. The Speaker assured that the Boyhood Leader’s actions, and his abnegation to altercate added apropos appointments, did not anticipate the Baddest Lath from operating. Case 1:21-cv-03217-CJN Certificate 15 Filed 04/22/22 Folio 18 of 68 To backpack out those functions, Abode Resolution 503 authorizes the Speaker of the Abode The Speaker consulted the Abode Parliamentarian, brash accordant precedent, and 1 SOMF ¶ 5. The assembly the Speaker beneath to accredit were Jim Jordan and Jim Banks. Mr. Jordan was an animate amateur in the accomplishment to annul the 2020 acclamation on January 6th. See 167 Cong. Rec. H77-79, H98-99 (daily ed. Jan. 6, 2021); See 167 Cong. Rec. H77-79, H98- 99 (daily ed. Jan. 6, 2021); Letter from Administrator Bennie Thompson to Rep. Jim Jordan (Dec. 22, 2021), https://perma.cc/S6QY-J9BJ. See Columnist Release, Jim Banks, McCarthy Taps Banks to Beforehand Republicans on Jan 6 Lath (July 19, 2021), https://perma.cc/WVW5-6DDH 2 See Columnist Release, Kevin McCarthy, McCarthy Annual about Pelosi’s Corruption of Adeptness on January 6th Baddest Lath (July 21, 2021), https://perma.cc/KFQ7-C7B7 (“McCarthy Columnist Release”). 7

This was because the Baddest Lath already had a quorum of Assembly beneath Abode Resolution 503. See H. Res. 503 § 5(c)(3) (“[T]wo Assembly of the Baddest Lath shall aggregate a quorum for demography affirmation or accepting affirmation and one-third of the Assembly of the Baddest Lath shall aggregate a quorum for demography any action added than one for which the attendance of a majority of the Baddest Lath is required.”) (emphasis added). Baddest Committee. SOMF ¶ 6. The Baddest Lath has aback operated with seven Democrats and two Republicans, a acceding the abounding Abode has affirmed repeatedly, aboriginal by abandonment Abode Resolution 554—a advantaged resolution filed by the Boyhood Baton battling the acceding of the Baddest Lath on the breadth agnate to those argued actuality by Mr. Meadows (see 167 Cong. Rec. H3885-86)—and additionally by its acceptance of three resolutions captivation four individuals in antipathy of Congress, one of which accurately addressed Mr. Meadows abnegation to accede with the Baddest Committee’s subpoenas. SOMF ¶ 8.3 the January 6th attack, on September 23, 2021, the Baddest Lath issued the amendment at affair actuality to Mr. Meadows. SOMF ¶ 9. As the Baddest Lath explained in its awning letter to the subpoena, its assay had “revealed aboveboard evidence” of Mr. Meadows’s “involvement Case 1:21-cv-03217-CJN Certificate 15 Filed 04/22/22 Folio 19 of 68 Nevertheless, the Speaker absitively to accredit an added Republican Associate to the C. The Baddest Committee’s Subpoenas to Mr. Meadows and Verizon In advocacy of its albatross to “investigate the facts, circumstances, and causes” of 3 H. Res. 1037, 117th Cong. (2022) (Recommending that the Abode of Representatives accretion Peter K. Navarro and Daniel Scavino, Jr. in antipathy of Congress); H. Res. 851, 117th Cong. (2021) (Recommending that the Abode of Representatives accretion Mark Randall Meadows in antipathy of Congress) ; H. Res. 730, 117th Cong. (2021) (Recommending that the Abode of Representatives accretion Stephen K. Bannon in antipathy of Congress); see additionally 168 Cong. Rec. H4217 (daily ed. Apr. 6, 2022) (specifically adopting these challenges to the Baddest Committee’s bureau of operation afore the abounding Abode during a agitation over whether the Abode should acquire a antipathy resolution). 8

in claiming aural the . . . Baddest Committee’s inquiry.” SOMF ¶ 11. Specifically, Mr. Meadows was “with or in the about of Admiral Trump on January 6, had communications with the Admiral and others on January 6 apropos claiming at the Capitol, and [was] a attestant apropos activities of that day.” SOMF ¶ 12. Indeed, at atomic one columnist abode adumbrated that Mr. Meadows was in admonition with organizers of the January 6th rally. See id. the planning and alertness of efforts to claiming the presidential acclamation and adjournment the counting of balloter votes,” and according to abstracts provided by the Administering of Justice, he “directly arise with the accomplished officials” at the Administering “requesting investigations into acclamation artifice affairs in several states.” SOMF ¶ 13. The Baddest Lath additionally accustomed that in the weeks afterwards the 2020 election, Mr. Meadows “contacted several accompaniment admiral to animate assay of allegations of acclamation fraud, alike afterwards such allegations had been absolved by accompaniment and federal courts, and afterwards the Balloter Academy had met and voted on December 14, 2020.” SOMF ¶ 14. affirmation apropos these and added affairs accordant to the Baddest Committee’s inquiry, with a certificate acknowledgment date of October 7, 2021 and a degradation date of October 15, 2021. ECF 13-3 at 4 (Am. Compl. Ex. A). Administrator Thompson chose to adjournment these deadlines a cardinal of times in an accomplishment at accommodation. Admiral Biden, beatific a letter to Mr. Meadows’s counsel, anecdotic the appliance the Admiral gave in arch whether to beforehand complete affirmation amnesty and/or controlling Case 1:21-cv-03217-CJN Certificate 15 Filed 04/22/22 Folio 20 of 68 Further, accessible belletrist adumbrated that Mr. Meadows was “engaged in assorted elements of Accordingly, the Baddest Lath issued a amendment gluttonous abstracts and degradation On November 11, 2021, the Agent Admonition to the President, autograph on annual of advantage with annual to the Baddest Lath subpoena. See SOMF ¶ 15. The Admiral 9

declined to beforehand either claim. Id. The Admiral determined, “in acceptance of [the] altered and amazing circumstances,” that “an affirmation of controlling advantage is not in the accessible interest, and is appropriately not justified, with annual to authentic adaptation aural the abuttals of the Baddest Committee.” See ECF 13-14 at 2 (Am. Compl. Ex. L), Letter from Jonathan C. Su, Agent Admonition to the President, to George J. Terwilliger III (Nov. 11, 2021). Admiral Biden additionally assured “[f]or the aforementioned affirmation basal his decisions on controlling privilege” that he would “not beforehand immunity” to avert Mark Meadows from testifying afore the Baddest Committee. Id. at 3. the Arch of Agents to the President) from acting beneath their official U.S. government ascendancy and position to affect the aftereffect of a political election.4 acclamation beforehand efforts, including by traveling to Georgia to beam an assay of absentee acclamation signatures, and by lobbying accompaniment officials, legislators and others advancement changes to accompaniment acclamation results, by accommodating in an accomplishment to actualize apocryphal balloter slates for assertive states, and in added ways. SOMF ¶ 18.5 Mr. Meadows was additionally circuitous in planning with Assembly of 4 See 5 U.S.C. § 7323(a) (commonly referred to as the “Hatch Act”); 5 C.F.R. § 734.101 (2022) (defining “political activity”); 5 C.F.R. § 734.302 (prohibiting use of official appellation while affianced in political activity). See about U.S. Arrangement of Adapted Counsel, Assay of Political Activities by Arch Trump Administering Admiral during the 2020 Presidential Election, Abode of the Arrangement of Adapted Admonition 17, 22-23, 40 (Nov. 9, 2021), https://perma.cc/P887- 827J. Case 1:21-cv-03217-CJN Certificate 15 Filed 04/22/22 Folio 21 of 68 D. The Two Abstracted Roles That Mr. Meadows Played As White Abode Arch of Staff, and As a Key Player on the Trump Beforehand Federal law abnormally prohibits federal admiral such as Mr. Meadows (when bedfast as Mr. Meadows acted in his non-governmental adaptation with absorption to abundant post- 5 For example, Mr. Meadows alternating in a broadly publicized alarm with Georgia Secretary of Accompaniment Raffensperger, and added accompanying efforts gluttonous to change the acclamation after-effects in Georgia. See Amy Gardner & Paulina Firozi, Here’s the archetype and audio of the alarm amid Trump and Raffensperger, Wash. Post (Jan. 5, 2021), https://perma.cc/5SMX-4FPX. 10

Congress and others not in the Controlling Annex for the claiming of January 6th.6 Mr. Meadows’s affirmation in these activities in his adaptation as a associate of the Trump beforehand has been accustomed by the affirmation of assorted witnesses,7 by Mr. Meadows’s own book,8 and by the non-privileged abstracts Mr. Meadows himself produced to the Baddest Lath (for examples, see infra at 28-40).9 His actionable role in the Trump beforehand is additionally axiomatic from Mr. Meadows’s advantage logs, which accommodate abstracted claims of attorney-client advantage and assignment artefact aegis for hundreds of communications with attorneys acting for the beforehand or with added Trump beforehand staff. SOMF ¶ 19; Ex. E to Decl. of Timothy Heaphy, Mark Meadows’ Email Advantage Logs. Case 1:21-cv-03217-CJN Certificate 15 Filed 04/22/22 Folio 22 of 68 6 Mr. Meadows “received altercation belletrist and emails apropos aboveboard efforts to animate Republican legislators in assertive States to accelerate alternating slates of electors to Congress, a plan which one Associate of Congress accustomed was ‘highly controversial’ and to which Mr. Meadows responded, ‘I adulation it.’ Mr. Meadows responded to a agnate bulletin by adage ‘[w]e are’ and accession such bulletin by adage ‘Yes. Acquire a aggregation on it.’” H. Rep. No. 117-216, at 9. He additionally alternating in a alarm with Admiral Trump, Assembly of Congress, attorneys for the President’s campaign, and about 300 accompaniment and bounded admiral “to altercate the ambition of abolishment assertive States’ balloter academy after-effects on January 6, 2021.” Ex. H to Decl. of Timothy Heaphy, January 6, 2021 Altercation Belletrist amid Mark Meadows and Donald Trump Jr., H. Rep. No. 117-216, at 9-10 (citing belletrist produced by Mr. Meadows to the Committee). 7 See, e.g., Ex. P to Decl. of Timothy Heaphy, Hutchinson Tr. 47, 72-73; Ex. G to Decl. of Timothy Heaphy, Hutchinson Tr. Contd. 161-63; Ex. Z to Decl. of Timothy Heaphy, Raffensperger Tr. 102-105; Ex. Y to Decl. of Timothy Heaphy, J. Miller Tr. 125-26, 143-45. 8 SOMF ¶¶ 25, 26. 9 Ex. C to Decl. of Timothy Heaphy, Nov. 30, 2020 Email from Mark Meadows to Jason Miller (email from Mark Meadows’s claimed email annual to arch beforehand adviser acceding the beforehand to affair a columnist release); Ex. D to Decl. of Timothy Heaphy, Dec. 6, 2020 Email from Mark Meadows to Jason Miller (email from Mark Meadows’s claimed email annual to arch beforehand adviser with admonition about a clothing filed by the campaign). 11

White House, and the Baddest Lath affianced in diffuse accordance apropos certificate assembly and degradation testimony. admonition for the White House, allurement the White Abode to “clarify whether you acquire directed the Archivist to aftermath advantaged abstracts arising from Mr. Meadows’s administering as Arch of Agents to Congress, and if so, to analyze the abuttals of that directive.” ECF 13-5 at 3 (Am. Compl. Ex. C), Letter from G. Terwilliger to D. Remus (Oct. 11, 2021). The letter added represented that aloft Admiral Trump had bidding the actualization that “Mr. Meadows is accustomed from accountable affirmation on affairs accompanying to his official responsibilities.” Id. at 4. The letter declared that Mr. Meadows had “no acumen to acquire that Admiral Biden has declared to abandon affirmation amnesty for Mr. Meadows in affiliation with the Baddest Committee’s subpoena,” and asked for an befalling to “discuss these matters” afore any adaptation was made. Id. at 4-5. Meadows’s admonition that Admiral Biden would not affirmation controlling advantage or affirmation amnesty with annual to Mr. Meadows’s degradation or apropos any abstracts that he may acquire abode on the Baddest Committee’s inquiry. See ECF 13-14 at 2-3 (Am. Compl. Ex. L). The letter explained that Admiral Biden had bent “that an affirmation of controlling advantage is not in the accessible interest, and is appropriately not justified, with annual to authentic adaptation aural the abuttals of the Baddest Committee,” including “events aural the White Abode on or Case 1:21-cv-03217-CJN Certificate 15 Filed 04/22/22 Folio 23 of 68 E. The Baddest Committee’s Abundant Attempts to Accretion Acquiescence by Mr. Meadows with Its Amendment As reflected in the accessories to the Adapted Complaint, Mr. Meadows counsel, the Decidedly accordant here, on October 11, 2021, admonition for Mr. Meadows wrote to On November 11, 2021, Agent Admonition to the Admiral Jonathan Su abreast Mr. about January 6, 2021; attempts to use the Administering of Amends to beforehand a apocryphal anecdotal that 12

the 2020 acclamation was attenuated by boundless fraud; and added efforts to adapt acclamation after-effects or arrest the alteration of power.” Id. at 2. admiral cannot be accountable to accommodate [C]ongressional testimony” ECF 13-12 at 2 (Am. Compl. Ex. J), Letter from G. Terwilliger to Baddest Lath (Nov. 10, 2021) —Mr. Meadows’s admonition wrote to the Baddest Lath in backward November purportedly gluttonous an “accommodation.”10 Specifically, in two belletrist anachronous November 26, 2021, Mr. Meadows’s admonition agreed that Mr. Meadows would arise at a degradation accountable to assertive preconditions and agreed to aftermath 1,139 abstracts from Mr. Meadows’s claimed email account. SOMF ¶ 16. With the certificate production, admonition for Mr. Meadows provided a advantage log bold that Mr. Meadows was denial hundreds of abstracts on the base of asserted executive, marital, and attorney-client privileges. See H. Rep. No. 117-216, at 19. Baddest Committee. See ECF 13-20 at 2 (Am. Compl. Ex. R), Letter from M. Francisco to Baddest Lath (Dec. 3, 2021). Admonition for Mr. Meadows additionally produced a advantage log bold that Mr. Meadows was denial over 1,000 altercation belletrist from his claimed corpuscle buzz based on claims of executive, marital, and attorney-client privileges. SOMF ¶ 17. afore the appointed deposition, cooperation by Mr. Meadows chock-full suddenly. SOMF ¶ 20. Case 1:21-cv-03217-CJN Certificate 15 Filed 04/22/22 Folio 24 of 68 Afterwards Mr. Meadows initially banned to testify—contending that “senior aides to the On December 3, 2021, Mr. Meadows’s admonition produced 2,319 altercation belletrist to the A date for the degradation was afresh agreed aloft for December 8, 2021, but on the day 10 The “accommodations” action involves acceding amid the Aldermanic Annex and the Controlling Branch. See, e.g., Trump v. Mazars USA LLP, 140 S. Ct. 2019, 2029-31 (2020). Mr. Meadows, however, is not a allotment of and does not represent the Controlling Branch. As declared infra, the Controlling Annex has been consulted on the amendment to Mr. Meadows and has absitively not to beforehand privileges or contrarily seek an adaptation apropos affirmation and abstracts from Mr. Meadows on adaptation aural the abuttals of the Baddest Committee. 13

Through counsel, Mr. Meadows wrote to the Baddest Lath “declin[ing] the befalling to arise voluntarily for a deposition.” Id. During a alarm with Baddest Lath agents that aforementioned day, Mr. Meadows’s admonition adumbrated that Mr. Meadows would not arise at all, alike to altercate the abstracts that he had already provided to the Baddest Lath and that were not covered by any affirmation of authentic privilege. SOMF ¶ 21. On December 8, 2021, Mr. Meadows afresh bootless to arise for his deposition. See id. antipathy of Congress abode and recommendation. The antipathy abode fatigued Mr. Meadows’s abortion to affirm apropos facts and abstracts not accountable to any affirmation of privilege. See about H. Rep. No. 117-216. During the Baddest Committee’s business meeting, Carnality Armchair Liz Cheney able the axial affirmation of the antipathy proceedings: “We acquire Mr. Meadows is break asserting controlling and added privileges, but this vote on antipathy today relates principally to Mr. Meadows’s abnegation to affirm about altercation belletrist and added communications that he admits are not privileged. He has not claimed and does not acquire any advantage base to debris absolutely to affirm apropos these topics.”11 Congress and apropos him to the Administering of Amends for bent case pursuant to 2 U.S.C. §§ 192, 194. See 167 Cong. Rec. H7785-94 (daily ed. Dec. 14, 2021). Although assorted assembly of the Abode argued on the Abode attic that the Baddest Lath lacked an adapted aldermanic purpose, was not appropriately composed, and lacked ascendancy to affair Case 1:21-cv-03217-CJN Certificate 15 Filed 04/22/22 Folio 25 of 68 On December 13, 2021, the Baddest Lath brash and arise to the abounding Abode a The abutting day the abounding Abode debated a resolution captivation Mr. Meadows in antipathy of 11 Archetype of Business Affair on a Abode Recommending that the Abode of Representatives Adduce Mark Randall Meadows for Bent Antipathy of Congress at 8, Abode Baddest Comm. to Investigate the January 6th Beforehand on the United States Capitol, 117th Cong., 1st sess., (Dec. 13, 2021) (remarks of Rep. Liz Cheney of Wyoming) (Ex. B). 14

the amendment to Mr. Meadows,12 the abounding Abode did not agree, and the antipathy resolution was adopted. See id. at H7814-15. The Speaker provided the House’s barometer to the Administering of Justice, which has not yet arise a prosecutorial decision. “subscriber admonition and corpuscle buzz abstracts associated with Mr. Meadows’s claimed corpuscle buzz number.” SOMF ¶ 23. The amendment does not abode any agreeable of any communications, nor does it abode geo-location data. Id. To date, Verizon has not produced any of the subpoenaed admonition to the Baddest Lath and has brash the Baddest Lath that it will not accommodate the requested abstracts absent a cardinal from this Court. including a declaratory acumen and/or admonition to anticipate the Baddest Lath from accepting the abstracts and affirmation accustomed by the Baddest Committee’s subpoenas to Mr. Meadows and to Verizon. He filed an adapted complaint on April 1, 2022. altercation as to any complete actuality and that the movant is advantaged to acumen as a bulk of law.” Fed. R. Civ. P. 56(a). If the affective affair has met its burden, the nonmoving affair accusation set alternating Case 1:21-cv-03217-CJN Certificate 15 Filed 04/22/22 Folio 26 of 68 Verizon Amendment On November 22, 2021, the Baddest Lath issued a amendment to Verizon for On December 8, 2021, Mr. Meadows filed this action gluttonous assorted forms of relief, STANDARD OF REVIEW A cloister may admission arbitrary acumen “if the movant shows that there is no 18-carat 12 The animadversion of Rep. Andy Biggs of Arizona are allegorical of criticisms collapsed adjoin the Baddest Lath that the Abode rejected: “This lath is illegitimate. It has abandoned its own rules of creation. It has abandoned its own rules of conception and it says they appetite to accretion out this massive accuracy actuality about what happened on January 6. You can’t acquire a lath to accretion out what happened because you are interested. You can’t do that. And that is what they are accomplishing today.” 167 Cong. Rec. H7793. 15

“specific facts bold that there is a 18-carat affair for trial” to defeat the motion. Celotex Corp. v. Catrett, 477 U.S. 317, 324 (1986). Adapted Complaint—and accurately that Mr. Meadows has no authentic accustomed arena to debris to affirm and aftermath accordant abstracts apropos the seven adaptation articular above. The Cloister accusation not aggressiveness any triable complete altercation to affair such a ruling. I. Defendants are Advantaged to Arbitrary Acumen on All of Mr. Meadows’s Claims authentic and “uniquely compelling” aldermanic purpose. Trump v. Thompson, 20 F.4th at 37-38. That adaptation governs here, and Mr. Meadows’s claims to the adverse fail. See Am. Compl. ¶¶ 130-46. Archives to adjure the closing from bearing to the Baddest Lath Presidential annal apropos the January 6th attack. The commune cloister denied the requested injunction, and the D.C. Circuit affirmed. The D.C. Circuit accustomed that, “[e]ven beneath accustomed circumstances, there is a able accessible absorption in Congress accustomed out its allowable investigations, and courts accusation booty affliction not to unnecessarily arrest the functions of a alike branch.” Trump v. Thompson, 20 F.4th at 48 (internal commendation marks and citations omitted). The Baddest Lath seeks arbitrary acumen on anniversary affirmation in Mr. Meadows’s F. The Baddest Lath Has a Authentic Aldermanic Purpose As acclaimed earlier, the D.C. Circuit has already bent that the Baddest Lath has a In that case, aloft Admiral Trump sued the Baddest Lath and the Civic As to the Baddest Committee’s purpose, the D.C. Circuit explained: Case 1:21-cv-03217-CJN Certificate 15 Filed 04/22/22 Folio 27 of 68 ARGUMENT The complete aspect of the Article I adeptness is legislating, and so there would accept to be few, if any, added acute interests absolutely aural Congress’s wheelhouse than ensuring the safe and ceaseless conduct of its constitutionally assigned business. Here, the Abode of Representatives is investigating the distinct best baleful beforehand on the Capitol by calm armament in the history of the United States. 16

Id. at 35. has a ‘valid aldermanic purpose’ and its assay concern[s] a accountable on which legislation could be had.” Id. at 41 (citation omitted). The Supreme Cloister arbitrarily denied Mr. Trump’s abode for an admonition awaiting assay of the D.C. Circuit’s decision, and afresh denied certiorari. Trump v. Thompson, 20 F.4th 10 (D.C. Cir. 2021), admonition denied, 142 S. Ct. 680 (2022), cert. denied, 142 S. Ct. 1350 (2022) (mem.). Recently, added courts acquire additionally disqualified that the Baddest Lath is advancing accustomed aldermanic purposes. Oral Arg. Tr. at 34, Budowich v. Pelosi, ECF 27; Adjustment at 9 & n.12, Eastman v. Thompson, ECF 43. No cloister has disqualified or adapted otherwise. estimation of its own resolutions and rules. Indeed, two courts acquire already abandoned claims that the Baddest Lath is break constituted, or that it is not operating in accordance with its rules. Proceedings.” U.S. Const., Art. I, § 5, cl. 2; see Baker v. Carr, 369 U.S. 186, 233 (1962). That accouterment is a analytical aspect of the Aldermanic Branch’s built-in architecture as it “grants the Abode the adeptness to achieve its own Rules about its centralized proceedings,” Rangel v. Boehner, 20 F. Supp. 3d 148, 167 (D.D.C. 2013), which “only empowers Congress to bind itself,” INS v. Chadha, 462 U.S. 919, 955 n.21 (1983); see additionally Consumers Union of U.S., Inc. v. Periodical Case 1:21-cv-03217-CJN Certificate 15 Filed 04/22/22 Folio 28 of 68 The D.C. Circuit appropriately assured that “the January 6th Lath audibly G. The Baddest Lath Is Validly Constituted and Has Issued Authentic Subpoenas. Beneath the Constitution’s Rulemaking Clause, courts cannot override Congress’s 1. The Rulemaking Article Prevents Federal Courts from Second- Guessing the Baddest Committee’s Centralized Operations Beneath the Rulemaking Clause, “[e]ach Abode may actuate the Rules of its Correspondents’ Ass’n, 515 F.2d 1341, 1343 (D.C. Cir. 1975) (Rulemaking Article is a “broad 17

grant of authority”). Both the Rulemaking Article and separation-of-powers beforehand acquire led courts to abstain demography on interpretations of Aldermanic rules that battle with Congress’s own interpretations. See, e.g., Barker v. Conroy, 921 F.3d 1118, 1130 (D.C. Cir. 2019) (“Accordingly, we acquire the House’s estimation of its own rules … appropriately eliminating any accident of active afield of either the Rulemaking Article or separation-of-powers principles.”) (citation omitted). and interpreting its own rules, and that cloister has reaffirmed this admission in contempo years. See Barker, 921 F.3d at 1130 (“The Rulemaking Article of Article I, Breadth 5 of the Architecture acutely affluence to anniversary Abode of the Congress the ascendancy to achieve its own rules, and as we acquire explained, interpreting a aldermanic aphorism abnormally than would the Congress itself is alike to authoritative the rules—a adeptness that the Rulemaking Article affluence to anniversary Abode alone.”) (emphasis in original; centralized commendation marks and commendation omitted). apprenticed to situations breadth such estimation “requires no resolution of ambiguities.” United States v. Durenberger, 48 F.3d 1239, 1244 (D.C. Cir. 1995); accordance Metzenbaum v. FERC, 675 F.2d 1282, 1287 (D.C. Cir. 1982) (“To adjudge contrarily would accountable Aldermanic enactments to the blackmail of authoritative abolishment on anniversary break of altercation over the agreeable or aftereffect of a Abode or Assembly rule.”).13 chargeless its own rules, such decisions are additionally advantaged to the “presumption of regularity,” Case 1:21-cv-03217-CJN Certificate 15 Filed 04/22/22 Folio 29 of 68 The D.C. Circuit has affiliated emphasized the acquiescence owed to Congress in chargeless Thus, a court’s ascendancy to adapt centralized rules of either alcove of Congress is In accession to the acquiescence the D.C. Circuit has captivated accusation be accorded Congress in 13 Cf. Yellin v. United States, 374 U.S. 109, 114-115, 119 (1963) (reversing antipathy of Congress aplomb because a Abode lath did not chase that committee’s bright rules on controlling affair testimony). 18

which the Baddest Lath and Assembly of Congress, like all government officials, enjoy. Sussman v. U.S. Marshals Serv., 494 F.3d 1106, 1117 (D.C. Cir. 2007) (internal commendation marks and commendation omitted). None of the allegations in the Adapted Complaint arise abutting to demonstrating the “clear affirmation to the contrary,” adapted to affected that presumption. United States v. Chem. Found., Inc., 272 U.S. 1, 14-15 (1926). accustomed their obligation to curb to the House’s estimation of its own rules and disqualified adjoin parties advancement courts to adios the House’s estimation of its rules. In Budowich, supra, the commune cloister adumbrated that it would adios arguments like the ones Mr. Meadows makes here: the cloister would “have to curb to Congress in the abode of interpreting its rules,” and that the cloister would be “usurping Aldermanic authority” were it to ascendancy that the Baddest Lath was not validly composed. Jan. 20, 2022 Oral Arg. Tr. 34:1-5, Budowich v. Pelosi, No. 21-cv-3366 (JEB) (D.D.C. Jan. 20, 2022). Adjudicator Carter, in Federal Commune Cloister for the Axial Commune of California, additionally afresh accomplished a agnate conclusion. Eastman, ECF No. 43 at 9 & n. 12 (“A cloister may adapt centralized aldermanic rules abandoned aback such estimation ‘requires no resolution of ambiguities.’”) (citations omitted); see additionally Vander Jagt v. O’Neill, 699 F.2d 1166, 1175-77 (D.C. Cir. 1982) (rejecting the “startlingly airedale idea, accustomed our annual for a alike annex of government, for us to acquaint the Speaker” whom to accredit to committees). footfall in and invalidate the House’s estimation of its own resolution and rules. Baddest Committee, rather than the thirteen articular by the Resolution. Am. Compl. ¶¶ 121, Case 1:21-cv-03217-CJN Certificate 15 Filed 04/22/22 Folio 30 of 68 Courts that acquire heard challenges to the Baddest Committee’s activities acquire complete afresh 2. The Baddest Lath Is Appropriately Composed Admitting the Rulemaking Article and the rulings above, Mr. Meadows asks this Cloister to First, Mr. Meadows complains that the Speaker has appointed abandoned nine Assembly to the 124; H. Res. 503 § 2(a). As adumbrated above, the accustomed acceding of the Baddest Lath 19

follows from a adaptation by the Boyhood Baton to voluntarily abjure his own recommendations, and to debris thereafter to participate added in the arrangement action articular in the Resolution. See above-mentioned at 8-9. Afterwards accepting admonition from the Abode Parliamentarian and because Abode precedent, the Speaker interpreted and activated Abode Resolution 503 and the Abode Rules in this altered set of circumstances. She assured that the Boyhood Leader’s abnegation to altercate added and participate in the arrangement action would not anticipate the Baddest Lath from operating, so affiliated as it did so with an adapted quorum. See above-mentioned at 7-8. Notwithstanding the Boyhood Leader’s abandonment from the process, the Baddest Lath has a quorum to do business pursuant to Abode Resolution 503 and Abode Aphorism XI.2(h). SOMF ¶ 7. As the Speaker concluded, annihilation in Abode Resolution 503 enabled the Boyhood Baton or the Abode Republican Arrangement to arrest operation of the Baddest Lath by abandoning nominees and abnegation to participate in the arrangement arrangement process. adaptation here. In the 109th Congress, for instance, the Abode created the Baddest Lath to Investigate the Alertness for and Acknowledgment to Hurricane Katrina, which accustomed for twenty Members, appliance accent agnate to what is afore this Cloister today. See H. Res. 437, 109th Cong. § 2(a) (2005) (“The baddest lath shall be composed of 20 assembly appointed by the Speaker ….” (emphasis added)). Abode Speaker Dennis Hastert appointed abandoned eleven Members, a quorum to do business, all of whom were from the majority Republican Party. See SOMF ¶ 7; 151 Cong. Rec. 20873 (bound ed. Sept. 21, 2005). Further, a abandonment was accepted, and accession majority affair Associate appointed, pursuant to Abode Resolution 437, 109th Cong. (2005). See 151 Cong. Rec. 21177-78 (bound ed. Sept. 26, 2005). The Katrina Case 1:21-cv-03217-CJN Certificate 15 Filed 04/22/22 Folio 31 of 68 Abode antecedent apropos added baddest committees anon supports the Speaker’s Baddest Lath additionally issued subpoenas. See H. Rep. No. 109-377, at 23 (2006) (noting that the 20

Katrina Baddest Lath issued a amendment to the Administering of Defense, and that it was complied with). thirteen abeyant Assembly participate for the Baddest Lath to function. In fact, Abode Resolution 503 abnormally provides that “one-third of the Assembly of the Baddest Lath shall aggregate a quorum” to conduct business, and that abandoned two Assembly aggregate a quorum for demography affirmation or accepting evidence. H. Res. 503, 117th Cong. § 5(c)(3). The nine Assembly appointed by the Speaker acutely aggregate a quorum constant with Abode Resolution 503 and Abode Aphorism XI.2(h). Abode Resolution 503 abnormally contemplates the achievability of “vacancies,” but does not accommodate a specific timeline for bushing them. Id. at § 2(c). Nor does Abode Resolution 503 accommodate that the Baddest Lath becomes invalid or that it accusation append all action aback vacancies arise. Id. Committees of the Abode commonly achieve with vacancies. As of April 22, 2022, seven Abode Committees acquire at atomic one abstraction and about abide to achieve normally. It would allure anarchy to admittance litigants to accompany cloister challenges to any accomplishments of those or added Abode Committees based on disputes about the House’s appliance of its own procedural rules. That is absolutely what the Rulemaking Article should prevent. Artlessly put, annihilation in Abode Resolution 503 enables the Boyhood Baton to arrest operation of the Baddest Lath by crumbling to participate in the arrangement process. Speaker were “appointed afterwards arrangement with the boyhood associate as adapted by the acceding resolution.” Am. Compl. ¶¶ 121, 125. But arrangement did occur, afore the Boyhood Baton apoplectic his added cooperation and withdrew from the process. The Speaker Case 1:21-cv-03217-CJN Certificate 15 Filed 04/22/22 Folio 32 of 68 Indeed, as the Speaker recognized, annihilation in Abode Resolution 503 requires that all Second, Mr. Meadows complains that none of the nine Assembly appointed by the interpreted and activated Abode Resolution 503 and the Abode Rules. The adeptness to accredit Abode 21

Members to baddest committees rests abandoned with the Speaker of the House. See Abode Aphorism I.11 (“The Speaker shall accredit all select, joint, and arrangement committees ordered by the House.”); 167 Cong. Rec. H37 (daily ed. Jan. 4, 2021) (authorizing the Speaker to “accept resignations and to achieve accessories accustomed by law or by the House”); H. Res. 503, 117th Cong. § 2 (providing that the Speaker shall accredit the Baddest Lath members). This is constant with longstanding Abode precedent. See 8 Cannon’s Precedents of the U.S. Abode of Representatives Ch. 234 § 2172 (1936) (citing “instances in which the majority beneath to admit boyhood recommendations for lath assignments.”). the arrangement of Baddest Lath members, it could acquire provided such a requirement, as it has in the past. For example, in the 116th Congress, the Abode created two Baddest Committees and adapted that a allocation of the Assembly be appointed by the Speaker “on the advocacy of the Boyhood Leader.” See H. Res. 6, 116th Cong. § 104(f)(1)(B) (2019) (Select Lath on the Climate Crisis); id. at § 201(b)(3) (Select Lath on the Modernization of Congress). Similarly, had the Abode capital to agent arrangement adeptness anon to the Boyhood Leader, it could acquire done so. See, e.g., H. Res. 24, 110th Cong. § 2(a) (2007) (creating the Abode Democracy Abetment Bureau and acceptance nine Assembly to “be appointed by the Boyhood Baton of the Abode of Representatives”). Leader,” H. Res. 503, 117th Cong. § 2(a) (emphasis added), allows the Speaker greater ascendancy apropos the arrangement of all Members. “Consultation” bureau to “seek[] admonition or admonition of.’” United Keetoowah Band of Cherokee Indians in Okla. v. FCC, 933 F.3d 728, Case 1:21-cv-03217-CJN Certificate 15 Filed 04/22/22 Folio 33 of 68 Had the Abode brash to accommodate the Boyhood Baton with added ascendancy apropos The accent acclimated by Abode Resolution 503, “after arrangement with the Boyhood 750 (D.C. Cir. 2019) (internal commendation marks omitted); see Black’s Law Dictionary (11th ed. 22

2019) (defining “consultation” as “[t]he act of allurement the admonition or assessment of someone”). This accent is constant with Abode convenance and precedent: The aforementioned accent was acclimated in the resolutions that created both the Baddest Bipartisan Lath to Investigate the Alertness for and Acknowledgment to Hurricane Katrina, see above-mentioned at 20, and the Baddest Lath on the Claiming Surrounding the 2012 Agitator Beforehand in Benghazi, see H. Res. 567, 113th Cong. § 2(a) (2014). Compl. ¶¶ 55-56. Indeed, as Mr. Meadows admits, the Boyhood Baton fabricated several suggestions to the Speaker apropos boyhood affair Assembly to serve on the Baddest Committee, see id. at ¶ 56 (noting that the Boyhood Baton adapted Reps. Jim Banks of Indiana, Rodney Davis of Illinois, Jim Jordan of Ohio, Kelly Armstrong of North Dakota, and Troy Nehls of Texas). The actuality that the Speaker—using the ascendancy provided to her by the Abode Rules, the January 4, 2021 Adjustment of the House, and Abode Resolution 503—decided that the Baddest Lath would go avant-garde with nine members—a quorum—when Representatives Davis, Armstrong, and Nehls were aloof and banned to serve does not achieve the Baddest Lath break constituted, nor does it invalidate any of its actions. estimation of the Abode rules (and there is not), the abounding Abode has afresh arise on this complete issue, acknowledging and acknowledging the Speaker’s adaptation apropos the acceding of the Baddest Committee. For example, on July 26, 2021, Boyhood Baton McCarthy offered a advantaged resolution on the attic the Abode that began with the afterwards clause, “[w]hereas, Speaker Pelosi’s abnegation to bench all bristles Republican Assembly anon harms the legitimacy, credibility, and candor of the affairs of the Baddest Committee.” H. Res. 554, 117th Cong. Case 1:21-cv-03217-CJN Certificate 15 Filed 04/22/22 Folio 34 of 68 Here, Abode Resolution 503 was followed: The Boyhood Baton was consulted. Am. Third, alike if there were some 18-carat reviewable catechism actuality apropos the Speaker’s (2021). The advantaged resolution would acquire accursed the Speaker and declared on the Speaker 23

to accredit all of the Boyhood leader’s choices. The Abode dismissed, or in aldermanic terms, “tabled,” the Boyhood Leader’s resolution by a vote of 218 yeas and 197 nays. 167 Cong. Rec. H3885–3886 (daily ed. July 26, 2021). Aback that time, the Abode has ratified the Speakers’ estimation of Abode rules apropos the Baddest Committee’s acceding by voting to affair antipathy referrals apropos non-compliance with Baddest Lath subpoenas, admitting the aforementioned objections apropos Baddest Lath acceding that Mr. Meadows makes afresh here.14 Again, the Constitution’s Rulemaking Article prevents a cloister from second-guessing the Abode of Representatives in this context. Barker, 921 F.3d at 1130; see additionally ECF 43, Eastman, No. 8:22-cv-00099, at 9, n.12; Vander Jagt, 699 F.2d at 1175. Lath “has no baronial boyhood member” and, therefore, “Chairman Thompson bootless to Case 1:21-cv-03217-CJN Certificate 15 Filed 04/22/22 Folio 35 of 68 Fourth, Mr. Meadows additionally complains that the amendment is invalid because the Baddest 14 The House’s affirmation of the Baddest Committee’s action has circuitous complete and brash processes. For example, afore the Abode voted to acquire the Baddest Committee’s antipathy resolution with annual to Mr. Meadows, the abode on his antipathy was brought afore the Rules Lath of the House. That Committee—which is answerable with administering over the rules and adjustment of business of the House—concluded in its abode (H-Rpt. 117-217) that the Baddest Committee’s abode on Mr. Meadows was in befitting with procedural requirements of the House. See above-mentioned at 15. And aback the resolution on Mr. Meadows’s antipathy was debated afore the abounding House, several Assembly of Congress aloft the altercation about the acceding of the Baddest Committee. See above-mentioned agenda 15; see additionally 168 Cong. Rec. H4217 (Apr. 6, 2022) (specifically adopting these challenges to the Baddest Committee’s bureau of operation afore the abounding Abode during its agitation over whether the Abode should acquire a antipathy resolution apropos to Peter Navarro and Dan Scavino). Aback this affair has been presented to all of these bodies and officials—the Baddest Committee, the Rules Committee, the Parliamentarian, the Speaker, and the abounding Abode of Representatives—the analytic arguments Mr. Meadows now presents acquire been rejected. The abounding Abode has now accustomed the Baddest Committee’s referrals of Stephen Bannon, Mark Meadows, Peter Navarro, and Dan Scavino for antipathy of Congress. See H. Res. 730, 117th Cong. (2021) (Bannon); H. Res. 851, 117th Cong. (2021) (Meadows); H. Res. 1037, 117th Cong. (2022) (Navarro and Scavino). These resolutions were arise by the Baddest Committee, accustomed for attic appliance by the Abode Rules Lath and accustomed by the abounding House. See 167 Cong. Rec. H5768-69, 117th Cong. (daily ed. Oct. 21, 2021) (vote on Bannon); id. at H7814-15 (daily ed. Dec. 14, 2021) (vote on Meadows); 168 Cong. Rec. H4371- 79 (daily ed. Apr. 6, 2022). The abounding House’s acceptance of the referrals reinforces that Mr. Meadows’s objections to its acceding cannot be accepted. 24

make the requisite arrangement afore arising the amendment that accountable Mr. Meadows to arise for a deposition.” Am. Compl. ¶ 128.15 That argument, too, is wrong. To the admeasurement Abode Resolution 503 requires arrangement with the “ranking boyhood member” above-mentioned to the arising of a degradation subpoena, that affirmation was annoyed by arrangement with Carnality Armchair Liz Cheney. Adumbrative Cheney, by advantage of actuality the aboriginal boyhood affair Associate arrangement to the Baddest Committee, is, by definition, the arch baronial boyhood Associate of the Baddest Committee. Constant with Abode convenance and precedent, the appellation “ranking member” bureau the aboriginal Associate of the boyhood affair appointed to the Baddest Lath by the Speaker. See, e.g., H. Res. 10, 117th Cong. (2021) (containing baronial boyhood associate accessories to the continuing Committees of the House, colloquially referred to as “ranking members”). That estimation should not be accountable to authoritative review. Here, the arch boyhood Associate on the Baddest Lath (the aboriginal boyhood Associate appointed) is Carnality Armchair Liz Cheney. That is acceptable for purposes of Abode Resolution 503, as ratified by the abounding Abode of Representatives. See above-mentioned at 25, n.16. The Rulemaking Article of the Architecture requires that the attorneys curb to the Abode apropos the estimation and appliance of the House’s own rules and procedures. Case 1:21-cv-03217-CJN Certificate 15 Filed 04/22/22 Folio 36 of 68 15 Notably, Mr. Meadows does not article to the arising of the amendment to him for the assembly of documents. Nor could he. Abode Resolution 503 does not crave arrangement with the baronial boyhood Associate afore arising a amendment for documents; instead, it provides that the “chair of the Baddest Lath may accredit and affair subpoenas pursuant to article 2(m) of [House] aphorism XI.” H. Res. 503, 117th Cong. § 5(c)(4). In turn, Abode Aphorism XI.2(m) permits arising of subpoenas for abstracts aback the adeptness to accredit and affair subpoenas has been “delegated to the armchair of the lath beneath such rules and beneath such limitations as the lath may prescribe.” Id. Because Abode Resolution 503 accurately assembly to the Administrator of the Baddest Lath the adeptness to accredit and affair subpoenas, it is constant with Abode Aphorism XI.2(m)(3)(A)(i). 25

senior controlling admiral are covered by controlling privilege, as is any admonition apropos controlling officials’ deliberative processes apropos acclamation security.” Am. Compl. ¶ 177. Mr. Meadows appears to await on a declared abracadabra of controlling advantage by aloft Admiral Trump, Am. Compl. ¶ 75, but fails to accommodated the requirements to adjure these able privileges. Meadows’s abstracts or testimony. He has never anon or formally arise that position to the Baddest Committee. As the Supreme Cloister has recognized, controlling advantage “belongs to the Government and accusation be asserted by it,” and there accusation be “a academic affirmation of privilege, lodged by the arch of the administering which has ascendancy over the matter, afterwards complete claimed appliance by that officer.” United States v. Reynolds, 345 U.S. 1, 7-8 (1953) (upholding abracadabra of the accompaniment secrets advantage involving aegis of classified civic aegis information). Mr. Meadows appropriately cannot artlessly await on aloft Admiral Trump’s declared apprenticeship to him in abnegation to accede with the Baddest Committee’s subpoena.16 confidentiality.” Trump v. Thompson, 20 F.4th at 33. The D.C. Circuit has already captivated that “[u]nder any of the” potentially applicative tests administering assertions of controlling privilege, “the abstruse interests in acknowledgment avant-garde by Admiral Biden and the January 6th Lath far Case 1:21-cv-03217-CJN Certificate 15 Filed 04/22/22 Folio 37 of 68 H. Controlling Advantage Does Not Accredit Mr. Meadows to Debris to Arise and Affirm or Accommodate Abstracts Requested by the Baddest Lath Mr. Meadows claims his “conversations with the President, Carnality President, and added As an antecedent matter, aloft Admiral Trump has not appropriately invoked advantage over Mr. Indeed, Mr. Meadows has articulate abandoned “generalized apropos for Controlling Annex 16 See Procedures Administering Responses to Aldermanic Requests for Information, Presidential Announcement 2-3 (Nov. 4, 1982), https://www.justice.gov/ola/page/file/1090526/download (“If the Admiral decides to adjure controlling privilege, the Administering Arch shall admonish the requesting Aldermanic anatomy that the affirmation of controlling advantage is actuality fabricated with the specific approval of the President.”). 26

exceed” such “generalized concerns.” Id. (emphasis added); see additionally id. at 38-39 (“Nor is such a ‘generalized absorption in confidentiality,’ acceptable for a cloister to casting abreast the January 6th Committee’s exercise of bulk aldermanic functions, let abandoned abundant for a cloister to bandy a bend into the advancing animate accord and apartment amid the Political Branches.”) (citation omitted). Like in Trump v. Thompson, “the [Select] Lath has—as Admiral Biden agrees—demonstrated a specific and acute accusation for [Mr. Meadows’s] annal because they accommodate a altered and alarmingly important window into the claiming of January 6th that the [Select] Lath cannot admission elsewhere.” Id. 44-45. Mr. Meadows’s “generalized affirmation of privilege” accusation appropriately “yield to the” Baddest Committee’s “demonstrated, specific need” for the documents. Id. at 44. absorption in affiliated acquaintance that could be able of angled the scales aback in his favor, and of ‘mak[ing] anecdotic showings in absolution of his claims of privilege[.]’” Id. at 38. He has done neither, nor could he. See id. (rejecting controlling advantage affirmation because the aloft Admiral had “not articular any specific countervailing accusation for acquaintance affronted to the abstracts at issue, aloft their actuality presidential communications;” nor “made alike a basal bold that the agreeable of any authentic certificate lacks appliance to the [Select] Committee’s investigation”). Mr. Meadows’s advantage assertions appropriately abort at the threshold. Meadows’s abnegation to arise for his degradation and aftermath abstracts on seven specific adaptation Case 1:21-cv-03217-CJN Certificate 15 Filed 04/22/22 Folio 38 of 68 In such circumstances, Mr. Meadows “bears the accountability of at atomic bold some beefy I. The Affirmation and Documentary Admonition at Affair in this Motion As explained above, the Baddest Committee’s motion seeks arbitrary acumen as to Mr. that the Baddest Lath identifies and describes briefly. 27

exceed[s] [former Admiral Trump’s] ambiguous apropos for Controlling Annex confidentiality,” see Trump v. Thompson, 20 F.4th at 33, and to abetment the Cloister in compassionate the attributes of the admonition accustomed from Mr. Meadows and the adaptation he is gluttonous to absorber through his ambiguous objections, the Baddest Lath identifies assertive accordant analytic complete it has obtained. These analytic abstracts are offered abandoned to admonition analyze and alarm the Baddest Committee’s absorption in the specific admonition accustomed from Mr. Meadows— for its analytic purposes. The Cloister accusation not abode or aggressiveness any of the basal complete issues in the Baddest Committee’s assay to aphorism that Mr. Meadows lacks a accustomed base to baffle the Baddest Committee’s amendment as to these issues. Thus, none of this illustrative, analytic complete could present a 18-carat affair of complete actuality precluding arbitrary judgment. communications) Mr. Meadows has already provided to the Baddest Lath in acknowledgment to his amendment and accompanying affirmation about claiming Mr. Meadows has already about declared in his book and elsewhere. Lath amendment acquire already been fabricated public.17 For example, Ms. Laura Ingraham of the Fox Annual Admission texted Mr. Meadows repeatedly, advancement that the Admiral anon acquaint his supporters to leave the Capitol: Case 1:21-cv-03217-CJN Certificate 15 Filed 04/22/22 Folio 39 of 68 To allegorize that the Baddest Committee’s “profound absorption in acknowledgment . . . far Affair 1: Affirmation apropos non-privileged abstracts (including altercation and email Assertive of the altercation bulletin exchanges Mr. Meadows produced in acknowledgment to the Baddest Laura Ingraham: Hey Mark, The Admiral needs to acquaint bodies in the Capitol to go home. 17 Carnality Armchair Cheney on Recommending Mark Meadows for Bent Contempt, January 6th Committee, YouTube (Dec. 13, 2021), https://perma.cc/2JPJ-H6CZ. 28

(instructing his agitated supporters to leave the Capitol) until 4:17 p.m. that afternoon—more than one hour and 45 annual afterwards Ms. Ingraham’s messages. Likewise, Admiral Trump’s son additionally texted Mr. Meadows: predating January 6th apropos the Trump campaign’s planning for that day. Again, some of these acquire advanced been fabricated accessible as well, including two exchanges with Fox Annual host Sean Hannity. On December 31, 2020, Sean Hannity beatific Mr. Meadows the afterwards message: On January 5, 2021, a agnate barter occurred: Case 1:21-cv-03217-CJN Certificate 15 Filed 04/22/22 Folio 40 of 68 Laura Ingraham: This is affliction all of us.18 But the Admiral did not booty the achieve Ms. Ingraham and abounding others badly apprenticed Don Trump Jr: He’s got to adjudge this shit. Asap. The Capitol badge cheep is not enough. Mark Meadows: I am blame it hard. I agree.19 Added examples of accordant altercation belletrist abound, including a cardinal of belletrist Sean Hannity: We can’t lose the complete WH counsels office. I do NOT see January 6 accident the way he is actuality told.20 Sean Hannity: I’m complete afraid about the abutting 48 hours. 18 See Ex. F to Decl. of Timothy Heaphy, Altercation Belletrist Amid Mark Meadows and Laura Ingraham. Mr. Meadows’s altercation belletrist and the affirmation of added admiral actualization he was in the Oval Arrangement dining allowance with Admiral Trump that afternoon. See Ex. P to Decl. of Timothy Heaphy, Hutchinson Tr. 134. 19 See Ex. H to Decl. of Timothy Heaphy. This is one of abounding agnate altercation bulletin exchanges to or from Mr. Meadows during the violence. In addition, assemblage who were present at the White Abode during this aeon affirm that Mr. Meadows was with the President, and assorted White Abode agents were advancement the Admiral to booty action to arrest the violence. Ex. I to Decl. of Timothy Heaphy, Kellogg Tr. 114-15, 129-30, 139-41. 20 Ex. J to Decl. of Timothy Heaphy, December 31, 2020 Altercation Bulletin from Sean Hannity to Mark Meadows. 29

Caucus. On January 1, 2021, at 4:17 p.m., Mr. Meadows accustomed this bulletin apropos the planning for the Collective Affair of Congress on January 6th: himself “pushed” for Carnality Admiral Pence to booty unilateral action to adios the counting of balloter votes on January 6th.23 And while Mr. Trump’s broadly publicized alarm with Georgia Secretary of Accompaniment Brad Raffensperger was ongoing, Mr. Meadows exchanged altercation belletrist apropos the alarm with accession associate of the Georgia government.24 In addition, Mr. Meadows arise afresh by altercation with Congressman Scott Perry apropos a plan to adapt Administering of Amends administering in the canicule afore January 6th.25 Case 1:21-cv-03217-CJN Certificate 15 Filed 04/22/22 Folio 41 of 68 Sean Hannity: Pence pressure. WH admonition will leave.21 Mr. Meadows additionally accustomed altercation belletrist from assorted assembly of the Abode Freedom Rep. Chip Roy: If POTUS allows this to action . . . we’re active a pale in the affection of the federal republic . . . [ellipses in original]22 Assertive altercation communications with Assembly of Congress beforehand that Mr. Meadows 21 Ex. K to Decl. of Timothy Heaphy, January 5, 2021 Altercation Belletrist from Sean Hannity to Mark Meadows. 22 Ex. L to Decl. of Timothy Heaphy, January 1, 2021 Altercation Bulletin from Rep. Chip Roy to Mark Meadows. 23 Ex. M to Decl. of Timothy Heaphy, Altercation Belletrist Amid Mark Meadows and Rep. Jim Jordan (Rep. Jordan: “On January 6, 2021, Carnality Admiral Mike Pence, as Admiral of the Senate, should alarm out all balloter votes that he believes are actionable as no balloter votes at all ….” Mark Meadows: “I acquire pushed for this. Not abiding it is action to happen.”). 24 Ex. N to Decl. of Timothy Heaphy, January 2, 2021 Altercation Belletrist Amid Mark Meadows and then-Dep’y Sec. of Accompaniment Jordan Fuchs. 25 Ex. O to Decl. of Timothy Heaphy, Altercation Belletrist Amid Mark Meadows and Rep. Scott Perry. Affirmation from White Abode agents demonstrates Mr. Meadows’s important role in that effort. Ex. G to Decl. of Timothy Heaphy, Hutchinson Cont’d Tr. 155-56. Added affirmation acquired by the Lath demonstrates the plan brash that the new Acting Apostle Accustomed would change the Department’s complete abstracts apropos acclamation fraud. Ex. Q to Decl. of Timothy Heaphy, Donoghue Tr. 77-81; see also, Ex. R to Decl. of Timothy Heaphy, Abstruse Letter from DOJ to Georgia Admiral anachronous Dec. 28, 2020. 30

published his accounts and recollections in a book acclamation a cardinal of accordant issues. SOMF ¶¶ 25, 27. In his book, The Chief’s Arch (which was arise anon afore Mr. Meadows abruptly chock-full agreeable with the Baddest Lath over his productions and testimony), Mr. Meadows describes specific conversations that he had with Mr. Trump while he was the President. SOMF ¶ 28. These descriptions included, amid added things, discussions about artifice in the acclamation and the January 6th beforehand on the United States Capitol. SOMF ¶ 29. In one admission about the election, Mr. Meadows quotes Mr. Trump directly, and in a admission about January 6, Mr. Meadows describes a babble he had with Mr. Trump afterwards Mr. Trump batten to assemblage goers.26 campaign, the Trump accustomed team, and Mr. Meadows to actualize apocryphal slates of Presidential electors, or to accountability or actuate accompaniment and bounded admiral and legislators to booty accomplishments to change the aftereffect of the 2020 presidential election. activities brash to aftereffect in accomplishments by accompaniment admiral and legislatures to change the certified after-effects of the election. Thus, beneath D.C. Circuit precedent, abstracts and affirmation apropos claiming in this adaptation are not accountable to claims of controlling privilege. See In re Sealed Case (Espy), 121 F.3d 729, 752 (D.C. Cir. 1997) (“Of course, the [presidential communication] advantage abandoned applies to communications that these admiral and their agents columnist or accost and accept in the beforehand of bold their action of advising the Admiral on official government matters.”) One such archetype is the alarm with Georgia Secretary of Accompaniment Case 1:21-cv-03217-CJN Certificate 15 Filed 04/22/22 Folio 42 of 68 Mr. Meadows has produced all of this admonition afterwards any advantage affirmation and has Affair 2: Affirmation and abstracts apropos post-election efforts by the Trump As indicated, Mr. Meadows participated, as a abettor of the Trump campaign, in 26 Mark Meadows, The Chief’s Arch 259, 261 (2021). 31

Raffensperger, and added accompanying efforts to change the acclamation after-effects in Georgia.27 Added examples are numerous. See above-mentioned at 10, 30. For example, Mr. Meadows was additionally circuitous in an accomplishment to achieve declared addition slates of electors for assertive states which falsely certified that Admiral Trump rather than Admiral Biden had been victorious. See above-mentioned at 13- 14. The Baddest Lath now has affirmation from added White Abode agents that Mr. Meadows and assertive congressmen were brash by White Abode Admonition that efforts to achieve apocryphal certificates did not accede with the law: Congress in alertness for and during the claiming of January 6th. Congress, both afore and on January 6th apropos the claiming of that day. For example, the Baddest Lath is acquainted that Mr. Meadows arise with Congressmen Jim Jordan, Scott Perry, and others repeatedly.29 Mr. Meadows has supplied no base for his abnegation to affirm apropos those communications. Case 1:21-cv-03217-CJN Certificate 15 Filed 04/22/22 Folio 43 of 68 Q: And so, to be clear, did you apprehend the White Abode Counsel’s Arrangement say that this plan to acquire alternating electors accommodated and casting votes for Donald Trump in States that he had absent was not accurately sound? A: Yes, sir. 28 Admitting that advice, the plan abashed forward. Affair 3: Affirmation and abstracts apropos to communications with Assembly of As indicated, Mr. Meadows affianced in a abundant cardinal of communications with 27 Amy Gardner & Paulina Firozi, Here’s the abounding archetype and audio of the alarm amid Trump and Raffensperger, Washington Post (Jan. 5, 2021), https://perma.cc/5SMX-4FPX. 28 Ex. G to Decl. of Timothy Heaphy, Hutchinson Cont’d Tr. 64; see about id. at 61-68. 29 See, e.g., Ex. P to Decl. of Timothy Heaphy, Hutchinson Tr. 45-47, 72-73, 77-78, 142; Ex. G to Decl. of Timothy Heaphy, Hutchinson Cont’d Tr. 146-48. 32

to adapt Acting Apostle Accustomed Rosen with Jeffrey Clark so that the Administering of Amends could corruptly change its abstracts apropos acclamation fraud. accomplishment to adapt the Acting Apostle Accustomed in the canicule afore January 6th. He arise with Congressman Scott Perry about adorning Abettor Apostle Accustomed Jeffrey Clark.30 Added communications chronicle to issues on which Admiral Trump has not asserted advantage or amnesty claims; indeed, the Baddest Lath has already accustomed affirmation apropos the President’s communications with White Abode Admonition and assorted Amends Administering admiral on these issues.31 Affirmation shows that Mr. Clark intended, if appointed, to affair a alternation of belletrist alteration the Department’s position and giving acceptance to Admiral Trump’s allegations that the acclamation was stolen.32 The Baddest Lath believes that such belletrist appliance Administering of Amends letterhead, would acquire lent the imprimatur of the Administering of Amends to, and arise to legitimize, apocryphal claims that the acclamation was baseborn if arise above-mentioned to January 6th Case 1:21-cv-03217-CJN Certificate 15 Filed 04/22/22 Folio 44 of 68 Affair 4: Affirmation and abstracts apropos the plan, in the canicule afore January 6th, Mr. Meadows alternating in assorted communications with bodies circuitous in the 30 See, e.g., Ex. O to Decl. of Timothy Heaphy. 31 Ex. S to Decl. of Timothy Heaphy, Rosen Tr. 90 (“I acquire the affluence today of actuality able to allotment conversations with the President, with the President’s counsel, because the Administering of Amends on annual of the accustomed Admiral and the admonition for the accomplished Admiral [are] not objecting.”); see additionally id. at 60, 96-97, 103-11. 32 See Ex. Q to Decl. of Timothy Heaphy, Donoghue Tr. 77-81, 123-24 (discussing the proposed letter to states and Oval Arrangement meeting); Ex. S to Decl. of Timothy Heaphy, Rosen Tr. 128 (“[Clark] advocated not aloof that the letter be beatific but that there be accessible assertions about the improprieties with absorption to the 2020 election.”); id. at 127 (confirming that if Clark had been appointed Acting Apostle General, he would acquire beatific the proposed “proof of concept” letter to Accompaniment officials); See Ex. R to Decl. of Timothy Heaphy (the belletrist would acquire falsely declared that the Administering of Amends had “identified cogent apropos that may acquire impacted the aftereffect of the acclamation in assorted states” and encouraged accompaniment legislatures to alarm themselves into adapted sessions accompanying to the “appointment of Presidential Electors” in beforehand of the then- abutting January 6, 2021 Collective Affair of Congress). 33

and could thereby acquire mobilized an alike added significant, agitated attack. (No consecutive accomplishment by Administering of Amends agents to altercate such revelations could acceptable acquire put that bogie absolutely aback in the canteen in time.) direct, actuate or accountability afresh Carnality Admiral Mike Pence to unilaterally debris to calculation balloter votes on January 6th. President, as Admiral of the Senate, accusation comedy in Congress’s proceeding to calculation balloter votes: “The Admiral of the Assembly shall, in the attendance of the Assembly and Abode of Representatives, accessible all the certificates and the votes shall afresh be counted; The actuality accepting the greatest Cardinal of votes for President, shall be the President….” (emphases added). No ambiguity in that accouterment accustomed the Carnality Admiral to debris to calculation or adjournment the calculation of the certified balloter slates from any U.S. accompaniment on January 6th. Nor could (or did) any accouterment of the Balloter Calculation Act. And yet this is absolutely what Admiral Trump instructed, directed, pressured, and attempted to actuate the Carnality Admiral to do. See Adjustment at 32-40, 44, Eastman v. Thompson, No. 8:22-cv-00099 (Mar. 28, 2022), ECF No. 260 (“The abomination of the plan was obvious.”) (“Their beforehand was not bedfast to the ivory tower—it was a accomplishment in chase of a accustomed theory.”).33 Aback those efforts did not succeed, Admiral Trump issued a cheep about Carnality Case 1:21-cv-03217-CJN Certificate 15 Filed 04/22/22 Folio 45 of 68 Affair 5: Affirmation and abstracts apropos to efforts by Admiral Trump to instruct, The Twelfth Amendment to the U.S. Architecture identifies the role that the Carnality 33 For example, on January 4, 2021, Admiral Trump met with Carnality Admiral Pence and his agents to altercate the Carnality President’s adeptness to adapt the balloter calculation on January 6th. See Ex. F to Cong. Defs.’ Br. in Opp. to Pl.’s Advantage Assertions at 82, 95, Eastman v. Thompson, No. 8:22- cv-00099 (C.D. Cal. Mar. 3, 2022), ECF No. 164-11. Afterwards this meeting, the Admiral affiliated to accountability the Carnality Admiral both about and privately. At 1:00 a.m. on January 6th, Admiral Trump tweeted: “If Carnality Admiral @Mike_Pence comes through for us, we will win the Admiral … Mike can accelerate it back!” Donald J. Trump (@realDonaldTrump), Twitter (Jan. 6, 2021 1:00 AM), https://perma.cc/9EV8-XJ7K. At 8:17 a.m., the Admiral afresh tweeted: “States 34

President Pence that resulted in added abandon at the Capitol.34 Able-bodied afterwards the abandon was underway, John Eastman (a apostle acceptable Admiral Trump’s accomplishment to annul the election) affiliated to columnist the Carnality President’s aggregation to adios certified balloter votes. (Order at 11, Eastman v. Thompson, No. 8:22-cv-00099 (Mar. 28, 2022), ECF No. 260 (“At 11:44 pm, Dr. Eastman beatific one final email to actuate Jacob to change his mind: ‘I abode you to accede one added about accessory corruption and curb for 10 canicule ….’.”). Affirmation acquired by the Baddest Lath suggests that Mr. Meadows has adeptness accordant to anniversary of these issues. afore and during the claiming of January 6th. Case 1:21-cv-03217-CJN Certificate 15 Filed 04/22/22 Folio 46 of 68 Affair 6: Affirmation and abstracts apropos to action in the White Abode anon appetite to actual their votes … All Mike Pence has to do is accelerate them aback to the States, AND WE WIN. Do it Mike, this is a time for acute courage!” Donald J. Trump (@realDonaldTrump), Twitter (Jan. 6, 2021 8:17 AM), https://perma.cc/2J3P-VDBV. The Admiral additionally declared the Carnality Admiral personally, afresh pressuring him to booty action. See Ex. G to Cong. Defs.’ Br. in Opp. to Pl.’s Advantage Assertions at 87, 90-92, Eastman v. Thompson, No. 8:22-cv-00099 (C.D. Cal. Mar. 3, 2022), ECF No. 164-12. And admitting the Carnality President’s afresh statements that he would not adapt or adjournment the balloter count, the aloft Admiral aloft the affair afresh to the army aggregate on January 6th, advancement the Carnality Admiral to “stand up for the acceptable of our Architecture and for the acceptable of our Country,” and abacus that if Pence did not do so, the Admiral was “going to be complete aghast in [him].” Donald J. Trump, President, Accent to the “Save America March” and assemblage (Jan. 6, 2021), https://perma.cc/2YNN-9JR3. 34 See Trump supporters corruption to adhere Mike Pence at Capitol, YouTube, https://perma.cc/6KGR-VUE8 (video depicting army of Capitol rioters chanting “hang Mike Pence”); United States v. Marhsall Neefe and Charles Bradford Smith, https://perma.cc/4DER- T44C; Donald J. Trump (@realDonaldTrump), Twitter (Jan. 6, 2021, 2:24 PM), https://perma.cc/Z9Q5-EANU (“Mike Pence didn’t acquire the adventuresomeness to do what should acquire been done to assure our Country and our Constitution, giving States a adventitious to accredit a adapted set of facts, not the counterfeit or inaccurate ones which they were asked to advanced certify. USA demands the truth!”). See additionally Complaint Affidavit, United States v. Evans, No. 21-00016 (D.D.C. Jan. 8, 2021), https://perma.cc/D7WE-CV2K (“They’re authoritative an advertisement adapted now adage if Pence betrayed us you bigger get your apperception adapted because we’re affronted that building.”); Admirable Lath Indictment, United States v. Neefe et al., No. 21- 00567 (D.D.C. Sept. 8, 2021), https://perma.cc/L5H7-3FJP (“Then we heard the annual on [P]ence … And absent it … So we stormed”); Complaint Affidavit, United States v. Black, No. 21-127 (D.D.C. Jan. 13, 2021), https://perma.cc/8KAL-5HEK (“Once we activate Pence affronted on us and that they had baseborn the election, like officially, the army went crazy. I mean, it became a mob. We aloft the gate.”). 35

motivated by Admiral Trump’s afresh claims, over several weeks, that the acclamation was stolen, and his pleas that Americans biking to Washington on January 6th to “StopTheSteal.” 35 Mr. Meadows was abreast afore the January 6th proceeding about the abeyant for abandon that day: Cassidy Hutchinson: I apperceive that there were apropos brought avant-garde to Mr. Meadows. I don’t know—I don’t appetite to brainstorm whether or not they perceived them as 18-carat concerns, but I apperceive that bodies had brought admonition avant-garde to him that had adumbrated that there could be abandon on the 6th. But, again, I’m not abiding if he—what he did with that admonition internally. * * * Case 1:21-cv-03217-CJN Certificate 15 Filed 04/22/22 Folio 47 of 68 The Baddest Lath has affirmation advertence that the agitated rioters on January 6th were 35 Donald J. Trump (@realdonaldtrump), Twitter (Jan. 1, 2021 2:53 PM), https://perma.cc/WW6S-ENNE. See about United States v. Chrestman, No. 21-00218 (D.D.C. Feb. 11, 2021), https://perma.cc/Z2AX-3CWT; Katelyn Polantz, et al., Sobbing Capitol agitator declared his beforehand of badge Administrator Michael Fanone: ‘My God. What did I aloof do?’, CNN (Dec. 1, 2021), https://perma.cc/V7HJ-QARJ (rioter answerable with assaulting City Badge Administering Administrator Michael Fanone on January 6th with an “electroshock weapon” told investigators: “Trump declared us. Trump declared us to D.C. … If he’s the administrator in arch and the baton of our country, and he’s calling for help—I anticipation he was calling for help”); Bent Complaint, United States v. Grayson, No. 21-00163 (D.D.C. Jan. 25, 2021), https://perma.cc/4FED-5PXB; Bent Complaint, United States v. Cua, No. 21- 107 (D.D.C. Jan. 29, 2021), https://perma.cc/8ZX7-E9G8; Sargeant Aquilino Gonell Testimony, Abode Baddest Lath to Investigate the January 6th Beforehand on the United States Capitol, The Law Administering Acquaintance on January 6th (July 27, 2021), https://perma.cc/KG3L-DH65 (Capitol Badge Sargeant Aquilino Gonell testifying that during hand-to-hand action with rioters on the lower west terrace of the Capitol on January 6th “all of them, all of them, were cogent us ‘Trump beatific us.’”). A cardinal of defendants in awaiting bent cases acquire articular Admiral Trump’s allegations about the “stolen election” as a action for their activities at the Capitol; several additionally accurately adduce Admiral Trump’s tweets allurement that supporters arise to Washington, D.C. on January 6th. See, e.g., Bent Complaint, United States v. Sandlin, No. 21-88 (Jan. 20, 2021), https://perma.cc/H9G2-G5GC (“I’m action to be there to actualization abutment for our admiral and to do my allotment to stop the abduct and bend abaft Trump aback he decides to cantankerous the rubicon.”); Admirable Lath Indictment, United States v. Neefe et al., No. 21-00567 (Sept. 8, 2021), https://perma.cc/NR5Q-HQZC (“Trump is absolutely calling bodies to DC in a actualization of force. Militias will be there and if there’s abundant bodies they may fucking storm the barrio and booty out the debris adapted there.”). 36

Cassidy Hutchinson: I aloof bethink Mr. Ornato advancing in and adage that we had intel belletrist adage that there could potentially be abandon on the 6th. And Mr. Meadows said: All right. Let’s allocution about it.36 6th assemblage to beforehand to the Capitol to “take aback your country.”37 Admiral Trump did not act anon to about ask or acquaint the agitated rioters leave the Capitol. It is additionally now bright that Mr. Trump never telephoned his Secretary of Defense that day to adjustment deployment of Civic Guard, and never contacted any federal law administering bureau to adjustment aegis abetment to the Capitol Police.38 Admonition accustomed by the Baddest Lath indicates that Mr. Trump was in the dining room, watching on his TV, and did not appetite his supporters to leave the Capitol for over three hours.39 And alike at 4:17 p.m. aback he arise a video, Admiral Trump told those in the Capitol “we adulation you. You’re complete special,” and at 6:01 p.m. he tweeted, “Remember this day forever!”40 Case 1:21-cv-03217-CJN Certificate 15 Filed 04/22/22 Folio 48 of 68 But admitting this and added warnings, Admiral Trump apprenticed the attendees at the January Admitting burning pleas from Capitol Hill and from abounding of Admiral Trump’s supporters, 36 Ex. P to Decl. of Timothy Heaphy, Hutchinson Tr. 37-38. 37 Brian Naylor, Apprehend Trump’s Jan. 6 Speech, A Key Allotment Of Impeachment Trial, NPR (Feb. 10, 2021), https://perma.cc/KS28-JJ3V (“So we’re action to, we’re action to airing bottomward Pennsylvania Avenue … And we’re action to the Capitol … [and] we’re action to try and accordance our Republicans, the anemic ones because the able ones don’t accusation any of our help. We’re action to try and accordance them the affectionate of pride and aggressiveness that they accusation to booty aback our country.”). 38 See Ex. T to Decl. of Timothy Heaphy, C. Miller Tr. 124; Ex. U to Decl. of Timothy Heaphy, McCarthy Tr. 147; Ex. Q to Decl. of Timothy Heaphy, Donoghue Tr. 189-90; Ex. S to Decl. of Timothy Heaphy, Rosen Tr. 190-91. 39 See, e.g., Ex. I to Decl. of Timothy Heaphy, Kellogg Tr. 142-47 (Reflecting on the White Abode staff’s accomplishment on January 6th to actuate Admiral Trump to ask his supporters to leave the Capitol and arrest the violence: “I absolved up to [Ivanka Trump] on the 7th…. and I told her I accustomed what she did that day and by talking to her dad. And I said: You know, I aloof anticipation what you did was to me appealing heroic.”). 40 Admiral Trump Video Annual on Capitol Protesters, C-SPAN (Jan. 6, 2021), https://perma.cc/XCW4-JDA7; Donald J. Trump (@realDonaldTrump) Twitter (Jan. 6, 2021 6:01 PM), https://perma.cc/29AH-HZNV. 37

individuals not affiliated with the federal government apropos the efforts to change the after-effects of the 2020 election. communications with individuals not affiliated with the federal government, involving arise efforts to change the after-effects of the 2020 election. Accessible admonition indicates that assertive of these individuals proposed to the Admiral atrocious action invoking some of the Nation’s emergency admiral provided to the Admiral in statute.41 Indeed, one of the non-privileged abstracts that Mr. Meadows provided indicates that he had a affair to altercate such accomplishments on or about December 21, 2020.42 White Abode Admonition brash that measures like these would be actionable and threatened to abandon (this was one of assorted White Abode Admonition abandonment threats above-mentioned January 6th).43 Meadows on these seven detached topics. Adaptation 1-4 and 7 do not absorb any accordant advantage claims. Indeed, Affair 1 relates to affirmation that Mr. Meadows has already voluntarily produced to the Baddest Committee, afterwards any advantage affirmation at all. Adaptation 2 and 3 chronicle to Mr. Meadows’s discussions with bodies not aural the Controlling Branch. Specifically, Affair 2 relates to Mr. Meadows’s activities on annual of the Trump campaign, not as White Abode Arch Case 1:21-cv-03217-CJN Certificate 15 Filed 04/22/22 Folio 49 of 68 Affair 7: Affirmation and abstracts apropos to affairs and communications with Finally, the Baddest Lath seeks Mr. Meadows’s affirmation apropos The Baddest Lath now seeks abstracts and degradation affirmation from Mr. 41 See Memorandum, Presidential Findings—To Canteen Collect and Analyze Civic Aegis Admonition Apropos the 2020 Accustomed Acclamation (Dec. 16, 2020), https://s3.documentcloud.org/documents/21185950/never-filed-trump-executive-order-2020.pdf (purporting to adjure the Civic Emergencies Act, amid others, to absolve the Administering of Defense abduction acclamation machines acclimated by localities in the election). 42 Ex. V. to Decl. of Timothy Heaphy, at 2-3. 43 Ex. G to Decl. of Timothy Heaphy, Hutchinson Cont’d Tr. 138. 38

of Staff.44 Affair 3 relates to discussions with Assembly of Congress—not added White Abode admiral or the President. And Affair 4 involves communications with Assembly of Congress, Scott Perry, and possibly others alfresco the Controlling Branch.45 Admiral Trump has already beneath to beforehand advantage on issues accompanying to Mr. Clark’s abeyant arrangement as Acting Apostle Accustomed (Topic 4).46 Likewise, Affair 7 additionally involves communications with bodies alfresco the White House, including assembly of the Trump political beforehand and potentially others acknowledging the campaign, such as Accustomed Flynn, Roger Stone, and others. The Baddest Lath is acquainted of no authentic controlling advantage affirmation as to any of these communications. to calculation balloter votes), any controlling advantage affirmation would face added insurmountable hurdles. First, the Admiral has no Built-in role in the calculation of balloter votes. Any communications on that affair amid or on annual of Mr. Trump and the Carnality Admiral necessarily circuitous Mr. Trump his adaptation as a presidential candidate, not as President. Second, Mr. Meadows’s affirmation on that affair involves communications with the Carnality Admiral in his role as Admiral of the Senate—which of beforehand is a role aural the Aldermanic and not the Controlling Branch. The Carnality Admiral served as allotment of the Aldermanic Annex aback Case 1:21-cv-03217-CJN Certificate 15 Filed 04/22/22 Folio 50 of 68 With absorption to Affair 5 (President Trump’s efforts to get Carnality Admiral Pence to debris 44 As acclaimed earlier, see n. 8, the Hatch Act does not acquiesce a federal official to act in his official adaptation for the purpose of affecting the aftereffect of an election. See 5 U.S.C. § 7323(a)(1). 45 See additionally Dalton Bennett and Jon Swaine, The Roger Stone Tapes, Wash. Post (Mar. 4, 2022), https://perma.cc/UX82-M2ZP (noting Roger Stone accustomed the accomplishment to install Jeffrey Clark as acting apostle accustomed in January 2021). 46 Ex. W to Decl. of Timothy Heaphy, August 2, 2021 Letter from Douglas Collins to Jeffrey Clark. The Baddest Lath has already aggregate affirmation on this topic, including affirmation on discussions anon with Admiral Trump and Admiral Trump’s White Abode Counsel. See, e.g., Ex. Q to Decl. of Timothy Heaphy, Donoghue Tr. 123-32. 39

preparing for and administering his duties on January 6, 2021.47 Therefore, communications about the affairs on January 6th with the Carnality Admiral and his agents abatement alfresco the abuttals of any controlling advantage claim. advantage adeptness conceivably be made. But as the D.C. Circuit accustomed in Thompson, the abortion to analyze “any specific countervailing accusation for acquaintance affronted to the abstracts [or testimony] at issue, aloft their actuality presidential communications,” 20 F.4th at 38, is outweighed by Congress’ “profound” and “uniquely compelling” absorption in advancing this investigation. See id. at 33 (“Under any of the tests advocated by aloft Admiral Trump, the abstruse interests in acknowledgment avant-garde by Admiral Biden and the January 6th Lath far beat his ambiguous apropos for Controlling Annex confidentiality.”). That cessation is bounden here. See id. at 37-38 (holding that any controlling advantage was affected by the Baddest Committee’s “uniquely acute need,” the sitting President’s acumen that absolution was in the country’s best interest, and the authentic accommodation adjourned amid the two branches of government). And, as acclaimed earlier, the Supreme Cloister denied aloft Admiral Trump’s entreaties that it should footfall in and stop the acknowledgment of the accordant complete to the Baddest Committee. Id., admonition denied, 142 S. Ct. 680 (2022), absolutely denied, No. 21-932 (2022). Case 1:21-cv-03217-CJN Certificate 15 Filed 04/22/22 Folio 51 of 68 Affair 6, by contrast, does potentially absorb issues on which claims of controlling 47 See, e.g., Shannen Coffin, SYMPOSIUM: THE UNITED STATES VICE PRESIDENCY: IN HISTORY, PRACTICE AND THE FUTURE: Oh, VPOTUS, Breadth Art Thou? The Built-in Situs of the Carnality Admiral as Surveyed by a Aloft Carnality Presidential Lawyer, 44 Pepp. L. Rev. 583, 588, 613 (2017) (“[i]t may be best to accept of the carnality admiral as allotment of both political branches of government, with the authentic breadth at any accustomed moment capricious depending on whether the Carnality Admiral is bold his controlling role of advising and acceptable the Admiral or his aldermanic role”); see additionally Ex. X to Decl. of Timothy Heaphy, Engel Tr. 71 (former Abettor Apostle Accustomed for OLC acknowledgment that OLC would not admonish Carnality Admiral Pence on his role on January 6th because “[i]t is not the role of the Administering of Amends to accommodate aldermanic admiral with accustomed admonition on the abuttals of their duties”). 40

log that he has withheld from assembly on the base of a affirmation of controlling privilege. (To the admeasurement that in camera assay is all-important to achieve that affirmation as to specific abstracts on the Meadows log, the Baddest Lath seeks such review, and will book a specific motion to that aftereffect if needed.) bulldoze affirmation by a arch Controlling Annex official.” Am. Compl. ¶ 170. As indicated, abandoned some of the activities at affair absorb Mr. Meadows’s activities as an Controlling Annex official; many, including Adaptation 2 and 7, absorb his role as a beforehand functionary. But alike for those activities for which Mr. Meadows was bedfast as Arch of Staff, he is not absolutely accustomed from testifying afore a Aldermanic committee. The Cloister should adios any affirmation of complete affirmation amnesty for several reasons. interests of the Controlling Annex to beforehand controlling advantage or any anatomy of amnesty with annual to Mr. Meadows’s degradation affirmation on authentic adaptation aural the abuttals of the Baddest Committee. ECF 13-14 (Am. Compl. Ex. L). Admiral Biden anxiously brash the institutional prerogatives of the Controlling Annex and the accent of the Baddest Committee’s investigation. Id. “The Admiral believes that the built-in protections of controlling advantage should not be acclimated to absorber admonition absorption an accomplishment to capsize the Architecture itself, and absolutely believes that such an affirmation in this accident would be at allowance with the Case 1:21-cv-03217-CJN Certificate 15 Filed 04/22/22 Folio 52 of 68 Such a cessation is additionally adapted as to those abstracts on Mr. Meadows’s advantage 1. Nor Is Mr. Meadows Advantaged to Affirmation Amnesty Mr. Meadows additionally argues that the Baddest Committee’s amendment “improperly attempts to First, the accustomed Admiral of the United States has absitively that it is not in the best beforehand that underlie the privilege.” Id. “For the aforementioned affirmation basal his decisions on 41

executive privilege, Admiral Biden [] bent that he will not beforehand amnesty to avert [Mark Meadows] from testifying afore the Baddest Committee.” Id. annual of the bend of the accustomed Admiral and the Congress, Mr. Meadows would still acquire no acute base to beforehand complete immunity. The Supreme Cloister has afresh captivated that the Admiral himself is not absolutely accustomed from compulsatory accustomed process. See Trump v. Vance, 140 S. Ct. 2412, 2431 (2020) (holding Admiral cannot affirmation amnesty from accompaniment bent admirable lath subpoenas); Clinton v. Jones, 520 U.S. 681, 684 (1997) (holding a sitting Admiral not accustomed from civilian action for acts done afore demography arrangement and altered to the office); United States v. Nixon, 418 U.S. 683, 707 (1974) (rejecting affirmation that complete amnesty protects Presidents from federal bent subpoenas). Further, the Cloister has consistently captivated that acquiescence with a Aldermanic amendment is a accustomed affirmation “which every actuality aural the administering of the Government is apprenticed to achieve aback appropriately summoned.” See United States v. Bryan, 339 U.S. 323, 331 (1950). admiral could be accustomed from compulsatory Aldermanic action in affairs involving their official conduct. But the Supreme Cloister has abandoned claims of complete amnesty by Presidential aides in added contexts. See Harlow v. Fitzgerald, 457 U.S. 800, 809-10 (1982) (holding that Presidential aides are advantaged abandoned to able amnesty in a clothing for damages). And courts in this commune acquire abandoned the affirmation of complete amnesty from accountable affirmation afore Congress for arch Presidential advisors. Case 1:21-cv-03217-CJN Certificate 15 Filed 04/22/22 Folio 53 of 68 Alike if the Cloister were to accede Mr. Meadows’s amnesty altercation afterwards the Neither the Supreme Cloister nor the D.C. Circuit has absitively whether any White Abode In Lath on the Judiciary, U.S. Abode of Representatives v. Miers, aloft White Abode Admonition Harriet Miers argued that she was absolutely accustomed from a Aldermanic 42

subpoena for testimony. 558 F. Supp. 2d. 53, 100 (D.D.C. 2008). Adjudicator Bates abandoned that claim, acquainted that there is not “a distinct authoritative assessment that recognizes complete amnesty for arch presidential admiral in this or any added context.” Id. at 99. The cloister captivated that a aloft White Abode Admonition accusation affirm afore the Aldermanic committee, acumen that Supreme Cloister antecedent beneath to accommodate such amnesty to the Admiral himself; abundant acts of Congress, such as the Freedom of Admonition Act, would be rendered a abyss based on such immunity; and the Arrangement of Accustomed Admonition opinions that claimed such amnesty were unpersuasive because they cited no case law and were “hastily issued” and “conclusory.” See id. at 103-04.48 affirmation of complete amnesty from accountable affirmation by aloft White Abode Admonition Don McGahn. Adjudicator Jackson assured that “the Miers cloister accurately bent not abandoned that the assumption of complete affirmation amnesty for senior-level presidential aides has no foundation in law, but additionally that such a hypothesis conflicts with key credo of our built-in order.” Comm. on the Judiciary, U.S. Abode of Representatives v. McGahn, 415 F. Supp. 3d. 148, 202- 03 (D.D.C. 2019).49 Specifically, Adjudicator Jackson agreed with Adjudicator Bates that complete amnesty for Presidential aides was “all but bankrupt by” the Supreme Court’s decisions in United States v. Nixon, Clinton v. Jones, and Harlow v. Fitzgerald, supra. Id. at 202, 207. And, acquainted Case 1:21-cv-03217-CJN Certificate 15 Filed 04/22/22 Folio 54 of 68 Added recently, architecture on Adjudicator Bates’s reasoning, Adjudicator Jackson analogously abandoned a 48 Aloft White Abode Admonition Harriet Miers appealed the commune court’s adaptation to the D.C. Circuit, but the abode was ultimately absolved on autonomous accord of the parties. See Comm. on Attorneys of U.S. Abode of Representatives v. Miers, No. 08-5357, 2009 WL 3568649 (D.C. Cir. Oct. 14, 2009). 49 Adjudicator Jackson’s assessment as to the Abode Committee’s continuing was affirmed by the en banc D.C. Circuit. Comm. on Attorneys of U.S. Abode of Representatives v. McGahn, 968 F.3d 755 (D.C. Cir. 2020) (en banc). The abode was ultimately absolved on autonomous accord of the parties. 43

that “there may able-bodied be affairs in which assertive aides of the Admiral acquire confidential, classified, or advantaged information,” the cloister explained that, in the ambience of accountable Aldermanic testimony, “such denial is appropriately and accurately accomplished on a question-by-question base through the abracadabra of a privilege, breadth appropriate.” Id. at 213. Admonition (“OLC”) to abutment his position on immunity. But alike if they were bounden in this forum—which they are not—none addresses a set of affairs like what the Baddest Lath is investigating here. None circuitous a accident breadth the bounden Admiral has absitively not to beforehand immunity, and none circuitous a accident breadth a Admiral is declared to acquire accumulated a agitated mob in Washington, D.C., arise that the mob bare to booty achieve to “take aback our country,” and told them to beforehand to the Capitol for that purpose. Trump v. Thompson, 20 F.4th at 18, 36 (quoting Admiral Trump). The Baddest Lath is investigating whether, and absolutely how, the aloft Admiral attempted to annul the allowable after-effects of an acclamation and beforehand Congress while Congress was attempting to achieve its Built-in assignment to aftereffect the peaceful alteration of power. No OLC assessment addresses a bearings breadth the Aldermanic Annex is attempting to bare what happened aback the Controlling Annex affronted a agitated beforehand on the Aldermanic Branch,50 and afresh bootless to accommodate actual aegis assistance.51 Break of Admiral beforehand in this ambience crave Case 1:21-cv-03217-CJN Certificate 15 Filed 04/22/22 Folio 55 of 68 Mr. Meadows appears to be relying on celebrated opinions from the Arrangement of Accustomed 50 Abounding defendants in awaiting bent cases articular Admiral Trump’s accusation about the “stolen election” as a action for their activities at the Capitol. A cardinal additionally accurately cited Admiral Trump’s tweets allurement that supporters arise to Washington, D.C., on January 6th. See supra, n. 35 (citing Bent Complaint, United States v. Sandlin, No. 21-88 (D.D.C. Jan. 20, 2021); Admirable Lath Indictment, United States v. Neefe et al., No. 21-00567 (D.D.C. Sept. 8, 2021)). 51 OLC opinions acquire additionally adapted that subjecting assertive Controlling Annex admiral to accessible Aldermanic affirmation adeptness unfairly put accessible accountability on those admiral to affirm about 44

that Congress act to canteen its role as a abstracted and alike annex by chargeless how best to anticipate such an beforehand from anytime recurring. To do so, it accusation acquire absolutely what happened. Indeed, that is the purpose of the Baddest Lath investigation, and the Baddest Lath requires Mr. Meadows’s affirmation for that purpose. Abode official (it does not), that amnesty accusation abandoned be able amnesty in this context.52 And here, the D.C. Circuit has already arise its cessation (which the Supreme Cloister banned to enjoin) afterwards acclimation the interests of Congress and Donald Trump. See Trump v. Thompson, 20 F.4th at 33 (“profound interests” in acknowledgment “far beat [Donald Trump’s] ambiguous apropos for Controlling Annex confidentiality”). Mr. Meadows’s beforehand to await on able amnesty to baffle a Aldermanic amendment should be rejected. by Mr. Meadows, he was not acting as annihilation like a archetypal White Abode Arch of Agents advising the Admiral on official affairs of government policy. Mr. Meadows was arena a Case 1:21-cv-03217-CJN Certificate 15 Filed 04/22/22 Folio 56 of 68 Second, to the admeasurement that any anatomy of amnesty adeptness abide for a baronial White Finally, as should be bright from the abstracts cited actuality and the advantage logs provided affairs on which they would contrarily abatement to comment. Here, the Baddest Lath has subpoenaed Mr. Meadows’s degradation testimony, not his affirmation in a accessible hearing. The Baddest Lath is assured that Mr. Meadows’s admonition can beforehand any objections he or she deems adapted in the degradation afterwards action disproportionate accessible pressure. 52 The Arrangement of Accustomed Admonition recognizes that the Supreme Cloister abandoned a affirmation of complete amnesty fabricated by arch Presidential admiral in the ambience of a civilian suit. Amnesty of the Director of the Arrangement of Political Action and Beat from Aldermanic Subpoena, 38 Op. O.L.C. 5, 12-13 (2014); see additionally Affirmation Amnesty Afore Congress of the Aloft Admonition to the President, 2019 WL 2315338 (O.L.C.), at *28 (May 20, 2019). But the factors that the Arrangement relied aloft to analyze Supreme Cloister caselaw are not actuating actuality in the affairs declared above. Moreover, those OLC opinions did not accede a bearings in which the accustomed Admiral has brash the affair and does not article to the attestant accouterment affirmation to a Aldermanic committee. 45

campaign role, attempting to facilitate a action that would acquire antipodal the certified after-effects of the 2020 election.53 brash to dedicated the success of one political applicant (Donald Trump) over accession applicant (Joe Biden). Because abounding of the questions that the Baddest Lath intends to ask Mr. Meadows absorb his audibly actionable conduct, there is no accustomed base for Mr. Meadows’s abnegation to arise for any degradation affirmation alike beneath OLC’s abandoned theories of immunity. See above-mentioned at 5-15. Indeed, the OLC opinions on which Mr. Meadows acceptable relies absolute their abstracts to “matters that action during the beforehand of absolution [] official duties.” See, e.g., Amnesty of the Director of the Arrangement of Political Action and Beat from Aldermanic Subpoena, 38 Op. O.L.C. 5 (2014). This is a longstanding and axiological limitation in the OLC’s formulations of these amnesty theories. See, e.g., Announcement for the Honorable John W. Dean III, Admonition to the President, from Ralph E. Erickson, Abettor Apostle General, Arrangement of Accustomed Counsel, Re: Actualization of Presidential Abettor Peter M. Flanigan Afore a Aldermanic Lath 3 (Mar. 15, 1972) (finding break of admiral does not avert Case 1:21-cv-03217-CJN Certificate 15 Filed 04/22/22 Folio 57 of 68 Abounding of Mr. Meadows’s activities (and others of which he has knowledge) were 53 Dozens of authoritative decisions acquire captivated that Admiral Trump’s claims of acclamation artifice were not authentic by affirmation or were accurately incorrect. William Cummings, J. Garrison & J. Sergent, By the numbers: Admiral Donald Trump’s bootless efforts to annul the election, USA Today (Jan. 6, 2021), https://perma.cc/683S-HSRC; see, e.g., Donald J. Trump for President, Inc. v. Boockvar, 502 F. Supp. 3d 899, 906 (M.D. Pa. 2020) (“[T]his Cloister has been presented with artificial accustomed arguments afterwards arete and abstruse accusations, unpled in the accessible complaint and bottomless by evidence.”); Ward v. Jackson, No. CV-20-0343, 2020 WL 8617817, at *2 (Ariz. Dec. 8, 2020) (plaintiff bootless “to present any affirmation of ‘misconduct,’ ‘illegal votes’ or that the Biden Electors ‘did not in actuality accept the accomplished cardinal of votes for office,’ let abandoned authorize any bulk of artifice or a acceptable absurdity bulk that would attenuate the authoritativeness of the acclamation results”); Trump v. Wis. Elections Comm’n, 506 F. Supp. 3d 620, 639 (E.D. Wis. 2020), aff’d, 983 F.3d 919, 927 (7th Cir. 2020); Wood v. Raffensperger, 501 F. Supp. 3d 1310, 1331 (N.D. Ga. 2020), aff’d, 981 F.3d 1307, 1310 (11th Cir. 2020), cert. denied, 141 S. Ct. 1379 (2021). 46

“Presidential Administering from actualization afore aldermanic committees” if “the assay is accompanying to their clandestine conduct”). In short, Mr. Meadows was acting as a abettor of the Trump beforehand and he should not be advantaged to any anatomy of amnesty at all. violates the Stored Communications Act, 18 U.S.C. § 2701 et seq. (“SCA” or the “Act”). See Am. Compl. ¶¶ 155-169. That is amiss as a bulk of law because annihilation in the Act banned the adeptness of a Aldermanic lath to admission non-content annal from a “person or article accouterment cyberbanking admonition annual to the public” via a allowable subpoena. 18 U.S.C. § 2702(a)(1).54 accommodation of communication” because it seeks “calls” and “text messages,” Am. Compl. ¶¶ 107, 156. That is incorrect; the Verizon amendment does not in actuality seek the accommodation of any communication. It abandoned seeks “subscriber information” and “connection annal and annal of affair times and durations.” ECF 13-21 at 4 (Am. Compl. Ex. S). Subscriber admonition is apprenticed to admonition about the user of the account, associated buzz numbers and added anecdotic numbers. See id. Affiliation annal and annal of affair times and durations artlessly beggarly annal of the date and time, duration, and sender and almsman of any call, altercation message, or added communication.55 Case 1:21-cv-03217-CJN Certificate 15 Filed 04/22/22 Folio 58 of 68 J. The Stored Communications Act Does Not Absolute the Baddest Committee’s Ascendancy to Admission Non-Content Admonition from Verizon Pursuant to a Allowable Amendment The Adapted Complaint asserts that the Baddest Committee’s amendment to Verizon Mr. Meadows aboriginal suggests that the Verizon amendment seeks the assembly “of the 54 The Baddest Lath agrees with Mr. Meadows that Verizon is such a “person or entity” beneath the statute. 55 Affiliation Annal and Annal of Affair Times and Durations are authentic in the Verizon Amendment as: “All call, bulletin (SMS & MMS), Internet Agreement (‘IP’), and data-connection 47

content annal through a Aldermanic subpoena. The Act about allows acknowledgment of non- agreeable records, although it prohibits (with one exception) autonomous acknowledgment of non-content annal to “governmental entit[ies].” 18 U.S.C. § 2702(a)(3), (c)(4). The analogue of the appellation “governmental entity,” as acclimated in the Act, does not accommodate Congress. Id. § 2711(4); id. § 6. And the Act abnormally permits acknowledgment to “any actuality added than a authoritative entity.” Id. § 2702(c)(6). “governmental entity” to accommodate Congress. See Agenda Realty Tr., Inc. v. Somers, 138 S. Ct. 767, 776 (2018) (“‘When a statute includes an absolute definition, we accusation chase that definition,’ alike if it varies from a term’s accustomed meaning.”). The Act defines “governmental entity” as “a administering or bureau of the United States or any Accompaniment or political subdivision thereof.” 18 U.S.C. § 2711(4). The acceding “department” and “agency” acquire authentic meanings in Appellation 18, as authentic in Breadth 6. That accouterment defines “department” as “one of the controlling departments abundant in breadth 1[now § 101] of Appellation 5, unless the ambience shows that such appellation was brash to alarm the executive, legislative, or authoritative branches of the government.” Id. § 6 (emphasis added). It additionally defines “agency” as “any department, absolute establishment, commission, administration, authority, lath or bureau of the United States or any affiliation in which the United States has a proprietary interest, unless the ambience shows that such appellation was brash to be acclimated in a added apprenticed sense.” Id. The Baddest Lath is neither Case 1:21-cv-03217-CJN Certificate 15 Filed 04/22/22 Folio 59 of 68 The Stored Communications Act contains no restrictions on Congress accepting non- The statute’s definitional acceding achieve bright that Congress did not intend for the byword detail annal associated with the Buzz Numbers, including all buzz numbers, IP addresses, or accessories that arise with the Buzz Cardinal via delivered and undelivered inbound, outbound, and baffled calls, messages, voicemail, and abstracts connections.” ECF 13-21 at 4 (Am. Compl. Ex. S). 48

an controlling administering nor a authoritative agency, and no “context” in the Stored Communications Act suggests that those acceding administer to Congress. byword “any administering or bureau of the United States” in Hubbard v. United States, 514 U.S. 695 (1995). That case anxious the annual of 18 U.S.C. § 1001, abhorrent authoritative apocryphal statements to “any administering or bureau of the United States,” to the Authoritative Branch. Id. at 698. The Cloister acclaimed initially that the definitions in Breadth 6 assumably activated to “all of Appellation 18,” including Breadth 1001. Id. at 700. The Cloister declared it was “incontrovertible” that “agency” did not accredit to any cloister aural the Authoritative Branch. Id. The Cloister added assured that annihilation in the ambience of Breadth 1001 “shows that” the appellation “department” was brash to administer aloft the Controlling Branch. Id. (quoting 18 U.S.C. § 6). The Cloister declared that there is “nothing in the altercation of the statute, or in any accompanying legislation, that alike suggests—let abandoned ‘shows’—that the accustomed analogue of ‘department’ was not intended.” Id. at 701.56 independent in Breadth 6 achieve apparent that the appellation “governmental entity” does not administer to Congress. There is annihilation in the Act that alike suggests, let abandoned “shows,” that Congress brash to accommodate itself in the definition. Moreover, the statute contains added accoutrement that added reinforce this apparent meaning. Case 1:21-cv-03217-CJN Certificate 15 Filed 04/22/22 Folio 60 of 68 The Supreme Cloister addressed a agnate affair of accustomed estimation apropos the As in Hubbard, the SCA’s analogue of “governmental entity” and the analogue 56 Hubbard overruled United States v. Bramblett, 348 U.S. 503 (1955), which captivated that the statute activated to apocryphal statements fabricated to the Aldermanic Branch. The Hubbard Cloister declared that Bramblett “erred by giving bereft weight to the apparent accent of §§ 6 and 1001,” constant “in a adaptation that is at war with the altercation of not one, but two altered Act of Congress.” 514 U.S. at 703, 708. Afterwards the cardinal in Hubbard, Congress adapted the statute at issue, 18 U.S.C. § 1001. Apocryphal Statements Accountability Act of 1996 (FSAA), § 2, Pub. L. No. 104-292. 49

department or agency” in which the corruption occurred may accountable the violator to authoritative discipline. 18 U.S.C. § 2712(c). But the administering of Congress and its committees do not aggregate a “head” of an bureau or department. As the Supreme Cloister affiliated ago established, “[t]he appellation ‘head of a Department’ bureau … the Secretary in accusation of a abundant assay of the controlling annex of the government, like the State, Treasury, and War, who is a associate of the Cabinet.” Burnap v. United States, 252 U.S. 512, 515 (1920) (emphasis added); see additionally Trump v. Deutsche Bank AG, 943 F.3d 627, 642 (2d Cir. 2019) (use of appellation “head of the bureau or department” adumbrated Congress did not intend Adapted to Banking Aloofness Act to administer to Aldermanic committee), abandoned on added breadth by Trump v. Mazars USA, LLP, 140 S. Ct. 2019 (2020); see additionally Aaron R. Cooper, Aldermanic Surveillance, 70 Am. U. L. Rev. 1799, 1825-34 (2021) (surveying accustomed text, context, and aldermanic history and complete that in the Stored Communications Act Congress brash to absolved itself from the appellation “governmental entity,” id. at 1828, 1833). ambience and anatomy of the statute, achieve bright that Congress is not a “governmental entity” as that appellation is authentic in the Act. As a result, because the Act abnormally permits acknowledgment of non- agreeable annal to “any actuality added than a authoritative entity,” 18 U.S.C. § 2702(c)(6), the statute cannot be apprehend to prohibit their acknowledgment to the Baddest Committee. Case 1:21-cv-03217-CJN Certificate 15 Filed 04/22/22 Folio 61 of 68 The Act provides that in the case of bent or brash violations, the “head of the Accordingly, the apparent altercation of the Stored Communications Act, as able-bodied as the all-embracing K. The Subpoenas at Affair Do Not Aperture the Fourth or the Aboriginal Amendments Mr. Meadows added challenges the Baddest Committee’s subpoenas based on the Fourth and Aboriginal Amendments. Those built-in claims fail. 50

phone annal aperture the Fourth Amendment’s prohibition on cool searches and seizures. Anniversary of his arguments is flawed. adeptness to admission admonition is ample and basal … and encompasses inquiries into the administering of absolute laws, studies of proposed laws, and surveys of defects in our social, bread-and-butter or political arrangement for the purpose of enabling the Congress to antidote them.” (internal punctuation and citations omitted). “[T]he January 6th Lath audibly has a authentic aldermanic purpose and its assay apropos a accountable on which legislation could be had.” Id. at 41 (internal commendation marks and commendation omitted). Amendment because it “is so ample and ample as to beat the accurately accustomed purpose of the Baddest Committee,” Am. Compl. ¶ 204, is mistaken. A amendment is not impermissibly overbroad if its alarm for abstracts or affirmation is aural the abuttals of the Aldermanic assay at issue. See McPhaul v. United States, 364 U.S. 372, 382 (1960). As declared above, the Baddest Committee’s assay includes analytical the January 6th beforehand as able-bodied as its “circumstances” and “causes,” to acquaint a appliance of “changes in law, policy, procedures, rules, or regulations.” H. Res. 503 § (3)(1), 4(c). Accustomed that scope, the amendment is appropriately tailored to accommodated the Baddest Committee’s allotment and is not impermissibly broad. Case 1:21-cv-03217-CJN Certificate 15 Filed 04/22/22 Folio 62 of 68 1. The Verizon Amendment and the Amendment to Mr. Meadows Do Not Aperture Mr. Meadows’s Fourth Amendment Rights Mr. Meadows makes assorted arguments that the subpoenas to him and Verizon for his a. The Subpoenas Are Not Overbroad, and in Any Event, the Baddest Lath Has Narrowed the Appliance of the Meadows Amendment to Seven Detached Topics. The D.C. Circuit afresh captivated in Trump v. Thompson, 20 F.4th at 24, that “Congress’s In ablaze of this holding, Mr. Meadows’s altercation that the amendment violates the Fourth See Eastland v. U.S. Servicemen’s Fund, 421 U.S. 491, 509 (1975). And in any event, the Baddest 51

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Committee has focused its assay and narrowed its amendment to Mr. Meadows as declared herein. See above-mentioned at 14-23. Fourth Amendment, and there is no added base for Mr. Meadows to claiming the aloft of a Aldermanic subpoena. Alike if he could claiming a Aldermanic amendment beneath some accustomed accustomed arty a abuttals limitation on Congress, the amendment to Verizon was reasonable. The Baddest Lath is not gluttonous the agreeable of communications with the Verizon subpoena, and its timeframe is appropriately tailored to the aliment of the Baddest Committee’s investigation. The Baddest Lath operates beneath a allotment to investigate the facts, affairs and causes apropos to the January 6th beforehand and apropos to the arrest with the peaceful alteration of power. The Baddest Lath is gluttonous to acquire the accomplishments of Mr. Meadows as a axial bulk in the assay during several specific months. In this context, the assay of this non-content abstracts is reasonable beneath any standard. States, 138 S. Ct. 2206 (2018), to altercate that the Baddest Committee’s amendment to Verizon violates the Fourth Amendment. Am. Compl. ¶ 200. But Carpenter, by its own terms, does not administer to the annal the amendment seeks. accumulating of actual cell-site breadth admonition (“CSLI”) from a third-party telecommunications aggregation constituted a “search” beneath the Fourth Amendment. 138 S. Ct. at 2211. The Cloister had advanced captivated in Smith v. Maryland, 442 U.S. 735 (1979), that recording Case 1:21-cv-03217-CJN Certificate 15 Filed 04/22/22 Folio 63 of 68 For the affirmation declared below, the amendment to Verizon does not run afield of the b. The Supreme Court’s Adaptation in Carpenter v. United States Does Not Administer to the Verizon Amendment Next, Mr. Meadows relies on the Supreme Court’s adaptation in Carpenter v. United In Carpenter, the Supreme Cloister faced the catechism of whether the Government’s the numbers that a authentic buzz cardinal dialed did not aggregate a chase because, amid 52

other reasons, such annal were voluntarily arise to the buzz aggregation and appropriately there was no reasonable apprehension of aloofness in them. Id. at 743-44. telecommunications company, the Cloister “decline[d] to extend” Smith to actual CSLI, “[g]iven the altered attributes of corpuscle buzz breadth records” and their adeptness to “achieve[] abreast absolute surveillance.” Carpenter, 138 S. Ct. at 2217-18 (emphasis added). In particular, the Cloister acclaimed actual CSLI from the “limited capabilities of a pen register,” which consisted of “telephone alarm logs [that] acknowledge little in the way of ‘identifying information.’” Id. at 2219 (citation omitted). records, and annal of affair times and durations. See ECF 13-21 at 4(Am. Compl. Ex. S). It does not seek actual CSLI or the accommodation or actuality of any communications associated with Plaintiff’s buzz number. See id. The annal accustomed by the Baddest Committee, therefore, are absolute absolutely by Smith, not Carpenter. See Carpenter, 138 S. Ct. at 2220 (stating that adaptation is a “narrow one” that “does not afflict the appliance of Smith”).57 adaptation does not administer to the kinds of annal accustomed here, such as subscriber admonition and call-detail records. See, e.g., United States v. Beverly, 943 F.3d 225, 239 (5th Cir. 2019) Case 1:21-cv-03217-CJN Certificate 15 Filed 04/22/22 Folio 64 of 68 In Carpenter, although actual CSLI abstracts was in the ascendancy of a third affair As acclaimed above, the Verizon amendment seeks abandoned subscriber information, affiliation Courts acclamation abolishment motions afterwards Carpenter acquire consistently captivated that the 57 Mr. Meadows attempts to elide the acumen amid actual CLSI and added buzz annal that are absolute by Smith, alleging that the subscriber and call-detail annal “can be acclimated for actual corpuscle armpit analysis.” Am. Compl. ¶ 195 (emphasis added). But so can the buzz cardinal itself—law administering could artlessly abode actual CSLI from a telecommunications carrier for a authentic buzz number. The added subscriber and call- detail admonition would not accommodate any added apparatus for accepting actual CSLI or artifice the accreditation affirmation set alternating in Carpenter. 53

(holding Carpenter does not administer to subscriber admonition and call-detail annal and crumbling to accept that such annal may be acclimated to clue location); United States v. Searcy, No. CR 19- 135, 2021 WL 3616062, at *5 (W.D. Pa. Aug. 16, 2021) (“Except for CSLI … Mr. Searcy has no accustomed apprehension of aloofness in admonition he voluntarily turns over to third parties[.]”) (internal commendation marks and commendation omitted); Brown v. Sprint Corp. Sec. Specialist, No. 17- CV-2561, 2019 WL 418100, at *4 (E.D.N.Y. Jan. 31, 2019) (holding Carpenter does not administer to subscriber and call-detail records). Thus, Carpenter artlessly does not administer to the third-party Verizon amendment here, and the Verizon amendment does not aperture Plaintiff’s Fourth Amendment rights. rights, but this altercation is absolutely bankrupt by Eastland v. United States Servicemen’s Fund, 421 U.S. 491, 509-510 (1975). There, the Supreme Cloister abandoned an organization’s altercation that a Aldermanic subpoena’s purpose was to “‘harass, chill, punish, and deter’ [it] in the exercise of [its] Aboriginal Amendment rights,” acknowledgment that the archetypal Aboriginal Amendment acclimation assay “plays no part” aback a Aldermanic amendment is involved. Id. at 509 n.16. Here, too, Mr. Meadows’s Aboriginal Amendment arguments adjoin administering of the Baddest Committee’s amendment accusation be rejected. acclimation of “the advancing clandestine and accessible interests at stake” actuality audibly favors the Baddest Committee. Barenblatt v. United States, 360 U.S. 109, 126 (1959). This Cloister has abandoned claims that arising of a Aldermanic amendment violates a respondent’s Aboriginal Amendment Case 1:21-cv-03217-CJN Certificate 15 Filed 04/22/22 Folio 65 of 68 2. The Verizon Amendment Does Not Aperture Mr. Meadows’s Aboriginal Amendment Rights Mr. Meadows additionally argues that the amendment to Verizon violates his Aboriginal Amendment Alike if Mr. Meadows’s affirmation were accountable to a acclimation test, it would still fail: the rights. See Assembly Permanent Subcomm. v. Ferrer, 199 F. Supp. 3d 125 (D.D.C. 2016), aff’d, 54

856 F.3d 1080 (D.C. Cir. 2017). That cessation is absolutely constant with the Supreme Court’s acceptance that the accessible absorption is acutely aerial aback the focus is on ensuring “the chargeless action of our civic institutions.” Buckley v. Valeo, 424 U.S. 1, 66 (1976) (internal commendation marks omitted). The Baddest Lath is accomplishing absolutely that by gluttonous affirmation and annal from Mr. Meadows. outweigh the complete grave accessible absorption here. His conclusory assertions that “[t]he amendment of Mr. Meadows’s clandestine corpuscle buzz abstracts violates his adapted to chargeless affiliation and chills the exercise of chargeless accent rights,” Am. Compl. ¶ 208, is too baggy to be actionable. Courts crave far added specificity, which is artlessly abnormal here. See, e.g., Ferrer, 199 F. Supp. 3d at 142 (“[I]invo[cation] of the Aboriginal Amendment in accustomed acceding … is bottomless and afterwards accustomed support[.]”).58 accustomed absorption active by the Subpoena, the Baddest Committee’s absorption far outweighs his interest. The Court’s ascendancy to analyze the Baddest Committee’s absorption is apprenticed because “so affiliated as Congress acts in aftereffect of its built-in adeptness … the Attorneys lacks ascendancy to arbitrate on the base of the motives which spurred the exercise of that power.” Ferrer, 199 F. Supp. 3d at 143 (quoting Barenblatt, 360 U.S. at 132-33). Here, the Baddest Committee’s amendment seeks annal accordant to chargeless the base causes of the agitated Case 1:21-cv-03217-CJN Certificate 15 Filed 04/22/22 Folio 66 of 68 Mr. Meadows, by contrast, fails to beforehand any Aboriginal Amendment absorption that could Bold for purposes of altercation that Mr. Meadows were able to actualize a 58See additionally Buckley, 424 U.S. at 74 (stating that bold an associational abrasion requires demonstrating a “reasonable anticipation that the accountable acknowledgment … will accountable them to threats, harassment, or reprisals from either Government admiral or clandestine parties”); see additionally Brock v. Loc. 375, Plumbers Int’l Union of Am., AFL-CIO, 860 F.2d 346, 350 n.1 (9th Cir. 1988) (stating that courts acquire “emphasized in anniversary of those decisions … the accusation for cold and articulable facts, which go aloft ample allegations or abstruse fears.…[A] abandoned abstruse abhorrence of abutting reprisals is an bereft bold of contravention of associational rights.”). 55

January 6th beforehand on Congress itself and the built-in albatross to acutely calculation Presidential balloter votes. To actuate the admeasurement of Mr. Trump’s and his campaign’s efforts to apparatus the planning for the agitated beforehand and the beforehand itself, the Baddest Lath requires a almanac of accordant communications. This is a archetypal archetype of the authoritative absorption in the “free action of our civic institutions.” Buckley, 424 U.S. at 66. Accordingly, Mr. Meadows’s Aboriginal Amendment affirmation fails. Defendants on all claims in Plaintiff Meadows’s Adapted Complaint. For the affirmation set alternating above, this Cloister should admission arbitrary acumen for the Case 1:21-cv-03217-CJN Certificate 15 Filed 04/22/22 Folio 67 of 68 CONCLUSION Respectfully submitted, /s/ Douglas N. Letter DOUGLAS N. LETTER Accustomed Admonition OFFICE OF GENERAL COUNSEL U.S. HOUSE OF REPRESENTATIVES 5140 O’Neill Abode Arrangement Architecture Washington, D.C. 20515 (202) 225-9700 [email protected] -and- ARNOLD & PORTER KAYE SCHOLER LLP John A. Freedman (D.C. Bar 453075) Paul J. Fishman (D.C. Bar 449014) Amy Jeffress (D.C Bar 449258) David J. Weiner (D.C. Bar 499806) John M. Hindley (D.C. Bar 1720648) 601 Massachusetts Ave, NW Washington, D.C. 20001 (202) 942-5000 [email protected] [email protected] [email protected] [email protected] 56

* Actualization pursuant to 2 U.S.C. § 5571(a). Case 1:21-cv-03217-CJN Certificate 15 Filed 04/22/22 Folio 68 of 68 [email protected] SHER TREMONTE LLP Justin M. Sher (Bar ID NY0320) Michael Tremonte* Noam Biale* Maya Brodziak* Kathryn E. Ghotbi* 90 Ample Street, 23rd Attic New York, New York 10004 (212) 202-2600 [email protected] [email protected] [email protected] [email protected] [email protected] Dated: April 22, 2022 57

MARK MEADOWS, ) ) Plaintiff, ) ) v. ) Case No. 1:21-cv-3271-CJN ) NANCY PELOSI, et al. ) ) Defendants. ) ) Case 1:21-cv-03217-CJN Certificate 15-1 Filed 04/22/22 Folio 1 of 6 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA DECLARATION OF TIMOTHY J. HEAPHY I, Timothy J. Heaphy acknowledge as follows: 1. I am Arch Analytic Counsel, Baddest Lath to Investigate the January 6th Beforehand on the U.S. Capitol, U.S. Abode of Representatives. 2. I achieve this acknowledgment in abutment of the Announcement and Credibility of Authorities in Abutment of Defendants’ Motion for Arbitrary Acumen 3. Absorbed hereto as Display A is a authentic and authentic archetype of an email from a claimed email annual associated with Mark Meadows to arch Trump re- acclamation beforehand official Jason Miller on December 6, 2020 at 4:39:40 PM, produced by Mark Meadows to the Baddest Lath to Investigate the January 6th Beforehand on the U.S. Capitol with the alpha cardinal MM003769. 4. Absorbed hereto as Display B is a authentic and authentic archetype of the archetype of the Abode Baddest Lath to Investigate the January 6th Beforehand on the United States Capitol, Business Affair on a Abode Recommending that the Abode of Representatives Adduce Mark Randall Meadows for Bent Antipathy of Congress, 117th Cong., 1st sess., (Dec. 13, 2021) (remarks of Rep. Liz Cheney of Wyoming). 1

Case 1:21-cv-03217-CJN Certificate 15-1 Filed 04/22/22 Folio 2 of 6 5. Absorbed hereto as Display C is a authentic and authentic archetype of an email from a claimed email annual associated with Mark Meadows to arch Trump re- acclamation beforehand official Jason Miller on November 30, 2020 at 11:22:39 AM, produced by Mark Meadows to the Baddest Lath to Investigate the January 6th Beforehand on the U.S. Capitol with the alpha cardinal MM005257. 6. Absorbed hereto as Display D is a authentic and authentic archetype of an email from a claimed email annual associated with Mark Meadows to arch Trump re- acclamation beforehand official Jason Miller on December 6, 2020 at 9:54:21 AM, produced by Mark Meadows to the Baddest Lath to Investigate the January 6th Beforehand on the U.S. Capitol with the alpha cardinal MM005596. 7. Absorbed hereto as Display E are authentic and authentic copies of the advantage logs apropos to emails withheld from assembly that were provided to Baddest Lath agents by admonition to Mark Meadows on November 26, 2021, and on December 3, 2021. 8. Absorbed hereto as Display F is a authentic and authentic archetype of assertive altercation belletrist produced by Mark Meadows to the Baddest Lath to Investigate the January 6th Beforehand on the U.S. Capitol as MM014907 and MM014908. Admonition developed by the Baddest Committee’s assay indicates that these altercation belletrist were exchanged amid Mark Meadows and Laura Ingraham, Fox Annual Admission Host. 9. Absorbed hereto as Display G is a authentic and authentic archetype assertive pages from the archetype of the affiliated annual of Cassidy Hutchinson by the Baddest Lath to Investigate the January 6th Beforehand on the U.S. Capitol on Beforehand 7, 2022. 10. Absorbed hereto as Display H is a authentic and authentic archetype of assertive altercation belletrist produced by Mark Meadows to the Baddest Lath to Investigate the January 6th Beforehand on the U.S. Capitol as MM014925 and MM014926. 2

Case 1:21-cv-03217-CJN Certificate 15-1 Filed 04/22/22 Folio 3 of 6 Admonition developed by the Baddest Committee’s assay indicates that these altercation belletrist were exchanged amid Mark Meadows and Donald Trump, Jr. 11. Absorbed hereto as Display I is a authentic and authentic archetype of assertive pages from the archetype of the degradation of Keith Kellogg, Jr. by the Baddest Lath to Investigate the January 6th Beforehand on the U.S. Capitol on December 14, 2021. 12. Absorbed hereto as Display J is a authentic and authentic archetype of a assertive altercation bulletin produced by Mark Meadows to the Baddest Lath to Investigate the January 6th Beforehand on the U.S. Capitol as MM014456. Admonition developed by the Baddest Committee’s assay indicates that this altercation bulletin was exchanged amid Mark Meadows and Sean Hannity, Fox Annual Admission Host. 13. Absorbed hereto as Display K is a authentic and authentic archetype of assertive altercation belletrist produced by Mark Meadows to the Baddest Lath to Investigate the January 6th Beforehand on the U.S. Capitol as MM014858 and MM014859. Admonition developed by the Baddest Committee’s assay indicates that these altercation belletrist were exchanged amid Mark Meadows and Sean Hannity, Fox Annual Admission Host. 14. Absorbed hereto as Display L is a authentic and authentic archetype of a assertive altercation bulletin produced by Mark Meadows to the Baddest Lath to Investigate the January 6th Beforehand on the U.S. Capitol as MM014503. Admonition developed by the Baddest Committee’s assay indicates that this altercation bulletin was exchanged amid Mark Meadows and Rep. Chip Roy. 15. Absorbed hereto as Display M is a authentic and authentic archetype of assertive altercation belletrist produced by Mark Meadows to the Baddest Lath to Investigate the January 6th Beforehand on the U.S. Capitol as MM014864 and MM014869. Admonition developed by the Baddest Committee’s assay indicates that these altercation belletrist were exchanged amid Mark Meadows and Rep. Jim Jordan. 3

Case 1:21-cv-03217-CJN Certificate 15-1 Filed 04/22/22 Folio 4 of 6 16. Absorbed hereto as Display N is a authentic and authentic archetype of assertive altercation belletrist produced by Mark Meadows to the Baddest Lath to Investigate the January 6th Beforehand on the U.S. Capitol as MM014567 through MM014571. Admonition developed by the Baddest Committee’s assay indicates that these altercation belletrist were exchanged amid Mark Meadows and Jordan Fuchs, Agent Secretary of Accompaniment for Georgia. 17. Absorbed hereto as Display O is a authentic and authentic archetype of assertive altercation belletrist produced by Mark Meadows to the Baddest Lath to Investigate the January 6th Beforehand on the U.S. Capitol as MM014099, MM014100, MM014101, MM014102, MM014103, and MM014178. Admonition developed by the Baddest Committee’s assay indicates that these altercation belletrist were exchanged amid Mark Meadows and Rep. Scott Perry. 18. Absorbed hereto as Display P is a authentic and authentic archetype of assertive pages from the archetype of the annual of Cassidy Hutchinson by the Baddest Lath to Investigate the January 6th Beforehand on the U.S. Capitol on February 23, 2022. 19. Absorbed hereto as Display Q is a authentic and authentic archetype of assertive pages from the archetype of the annual of Richard Peter Donoghue by the Baddest Lath to Investigate the January 6th Beforehand on the U.S. Capitol on October 1, 2022. 20. Absorbed hereto as Display R is a authentic and authentic archetype of a certificate produced to the Baddest Lath to Investigate the January 6th Beforehand on the U.S. Capitol by the U.S. Administering of Amends with the alpha cardinal HCOR-Pre-CertificationEvents-0762021-000698. 21. Absorbed hereto as Display S is a authentic and authentic archetype of assertive pages from the archetype of the annual of Jeffrey A. Rosen by the Baddest 4

Case 1:21-cv-03217-CJN Certificate 15-1 Filed 04/22/22 Folio 5 of 6 Lath to Investigate the January 6th Beforehand on the U.S. Capitol on October 13, 2021. 22. Absorbed hereto as Display T is a authentic and authentic archetype of assertive pages from the archetype of the annual of Christopher Charles Miller by the Baddest Lath to Investigate the January 6th Beforehand on the U.S. Capitol on January 14, 2022. 23. Absorbed hereto as Display U is a authentic and authentic archetype of assertive pages from the archetype of the annual of Ryan McCarthy by the Baddest Lath to Investigate the January 6th Beforehand on the U.S. Capitol on February 4, 2022. 24. Absorbed hereto as Display V is a authentic and authentic archetype of an email from an email annual associated with Phil Waldron to a claimed email annual associated with Mark Meadows on December 22, 2020 at 1:10:39 PM, alternating with the adapter thereto, produced by Mark Meadows to the Baddest Lath to Investigate the January 6th Beforehand on the U.S. Capitol with the alpha numbers of MM002282 and MM002283. 25. Absorbed hereto as Display W is a authentic and authentic archetype of a letter from Douglas A. Collins to Jeff Clark anachronous August 2, 2021, which was provided to the Baddest Lath to Investigate the January 6th Beforehand on the U.S. Capitol by admonition for Mr. Clark. 26. Absorbed hereto as Display X is a authentic and authentic archetype of assertive pages from the archetype of the annual of Steven A. Engel by the Baddest Lath to Investigate the January 6th Beforehand on the U.S. Capitol on January 13, 2022. 27. Absorbed hereto as Display Y is a authentic and authentic archetype of assertive pages from the archetype of the degradation of Jason Miller by the Baddest Lath to Investigate the January 6th Beforehand on the U.S. Capitol on February 3, 2022. 5

28. Absorbed hereto as Display Z is a authentic and authentic archetype of assertive pages from the archetype of the annual of Brad Raffensperger by the Baddest Lath to Investigate the January 6th Beforehand on the U.S. Capitol on November 30, 2021. Accomplished on April 22, 2022, in Washington, DC. Case 1:21-cv-03217-CJN Certificate 15-1 Filed 04/22/22 Folio 6 of 6 6 /s/ Timothy J. Heaphy Timothy J. Heaphy

MARK MEADOWS, ) ) Plaintiff, ) ) v. ) Case No. 1:21-cv-3271-CJN ) NANCY PELOSI, et al. ) ) ) Case 1:21-cv-03217-CJN Certificate 15-2 Filed 04/22/22 Folio 1 of 3 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA Display A

Case 1:21-cv-03217-CJN Certificate 15-2 Filed 04/22/22 Folio 2 of 3 Bulletin From: Sent: To: Subject: Mark Meadows ([email protected]] 12/6/2020 4:39:40 PM Jason Miller [[email protected]] Re: [EXTERNAL]2020-11-20 Chesebro announcement on absolute deadline2.pdf Got it Beatific from my iPhone On Dec 6, 2020, at 4:36 PM, Jason Miller <[email protected]> wrote: Nope, we accusation the meeting/call – was aloof absolution you apperceive we’d been animate the PR angle. Chargeless to allocution whenever you are tomorrow, Chief. On Dec 6, 2020, at 4:34 PM, Mark Meadows <[email protected]> wrote: If you are on it afresh never apperception the meeting. We aloof accusation to acquire addition analogous the electors for states Beatific from my iPhone On Dec 6, 2020, at 4:18 PM, Jason Miller <[email protected]> wrote: You bet. So you know, Justin and I did on-background calls on this complete accountable with Maria, Levin, Chuck Todd and Margaret Brennan bygone (I adeptness be missing 1-2 others). Justin – – we should aloof do a civic columnist alarm deeply focused on this tomorrow, no? JM On Dec 6, 2020, at 4:11 PM, Mark Meadows <[email protected]> wrote: Let’s acquire a altercation about this tomorrow Beatific from my iPhone MM003769

Case 1:21-cv-03217-CJN Certificate 15-2 Filed 04/22/22 Folio 3 of 3 <2020-11-20 Chesebro announcement on absolute deadline2.pdf> CONFIDENTIALITY NOTICE: This bulletin (including any attachments) may accommodate confidential, proprietary, privileged, and/or clandestine information. This admonition is brash to be for the use of the individual(s) appointed above. If you are not the brash almsman of this message, amuse acquaint the sender immediately, and annul the bulletin and any attachments. Any disclosure, reproduction, distribution, or added use of this bulletin or any accessories by an abandoned or article added than the brash almsman is prohibited. Copyright and any added bookish acreage rights are the sole acreage of Donald J. Trump for President, Inc. CONFIDENTIALITY NOTICE: This bulletin (including any attachments) may accommodate confidential, proprietary, privileged, and/or clandestine information. This admonition is brash to be for the use of the individual(s) appointed above. If you are not the brash almsman of this message, amuse acquaint the sender immediately, and annul the bulletin and any attachments. Any disclosure, reproduction, distribution, or added use of this bulletin or any accessories by an abandoned or article added than the brash almsman is prohibited. Copyright and any added bookish acreage rights are the sole acreage of Donald J. Trump for President, Inc. MM003770

Case 1:21-cv-03217-CJN Certificate 15-3 Filed 04/22/22 Folio 1 of 3 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA MARK MEADOWS, Plaintiff, V. Case No. 1:21-cv-3271-CJN NANCY PELOSI, et al. Display B

Case 1:21-cv-03217-CJN Certificate 15-3 Filed 04/22/22 Folio 2 of 3 1 1 RPTR ZAMORA 2 EDTR HOFSTAD 3 4 5 BUSINESS MEETING ON A REPORT RECOMMENDING THAT THE HOUSE 6 OF REPRESENTATIVES CITE MARK RANDALL MEADOWS FOR CRIMINAL CONTEMPT OF 7 CONGRESS 8 Monday, December 13, 2021 9 Abode of Representatives, 10 Baddest Lath to Investigate the January 6th Beforehand 11 on the United States Capitol, 12 Washington, D.C. 13 14 15 16 17 The lath met, pursuant to call, at 7:00 p.m., in Allowance 390, Cannon Abode 18 Arrangement Building, Hon. Bennie G. Thompson (chairman of the committee) presiding. 19 Present: Representatives Thompson, Lofgren, Luria, Schiff, Aguilar, Murphy, 20 Raskin, Cheney, and Kinzinger.

Case 1:21-cv-03217-CJN Certificate 15-3 Filed 04/22/22 Folio 3 of 3 8 1 2 Ms. Cheney. Acknowledge you complete much, Mr. Chairman. 3 We are actuality to abode a complete austere matter: antipathy of Congress by a aloft 4 arch of agents to a aloft Admiral of the United States. We do not do this lightly, and, 5 indeed, we had hoped not to booty this footfall at all. 6 For weeks, as the administrator noted, we formed with Mr. Meadows’ admonition to 7 adeptness an acceding on cooperation. But, anon afore his appointed deposition, 8 Mr. Meadows absolved abroad from his allegation to arise and abreast us he would no 9 best cooperate. 10 We acquire Mr. Meadows is break asserting controlling and added privileges, . 11 but this vote on antipathy today relates principally to Mr. Meadows’ abnegation to affirm 12 about altercation belletrist and added communications that he admits are not privileged. He 13 has not claimed and does not acquire any advantage base to debris absolutely to affirm 14 apropos these topics. 15 Let me accordance aloof three examples. 16 First, Admiral Trump’s abortion to stop the violence. On January 6th, our Capitol 17 Architecture was attacked and invaded. The mob was summoned to Washington by 18 Admiral Trump, and, as abounding of those circuitous acquire accustomed on videotape, in amusing 19 media, and in Federal commune court, they were affronted to abandon by Admiral Trump’s 20 apocryphal claims that the acclamation was stolen. 21 The abandon was axiomatic to all. It was covered in real-time by about every annual 22 channel. But, for 187 minutes, Admiral Trump banned to act, aback action by our 23 Admiral was required, essential, and, indeed, accountable by his adjuration to our Constitution. 24 Mr. Meadows accustomed abundant altercation messages, which he has produced afterwards 25 any advantage claim, affecting that Mr. Trump booty the specific action we all knew his duty

MARK MEADOWS, ) ) Plaintiff, ) ) v. ) Case No. 1:21-cv-3271-CJN ) NANCY PELOSI, et al. ) ) ) Case 1:21-cv-03217-CJN Certificate 15-4 Filed 04/22/22 Folio 1 of 2 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA Display C

Case 1:21-cv-03217-CJN Certificate 15-4 Filed 04/22/22 Folio 2 of 2 Bulletin From: Sent: To: Subject: Mark Meadows ([email protected]] 11/30/2020 11:22:39 AM Jason Miller [[email protected]] Re: Abstruse release, affiliated letter Go for it Beatific from my iPhone > On Nov 30, 2020, at 11:08 AM, Jason Miller <[email protected]> wrote: > Hyperlinks will go to the absorbed letter, and the revised columnist absolution for ASAP approval is below. > Acknowledge you! November 30, 2020 > > > > Trump Beforehand Sends 5th Abode to Georgia Secretary of Accompaniment for signature Assay > For the fifth time, the Trump Beforehand has requested that the Georgia Secretary of Accompaniment achieve an actual assay of the signatures on all absentee acclamation applications and absentee acclamation envelopes accustomed for the November 3rd Accustomed Election. The Trump Beforehand estimates that amid 38,250 and 45,626 actionable votes from the absentee ballots abandoned were casting in the accompaniment of Georgia – far aloft the Biden-Harris ticket’s accustomed allowance of 12,670 votes. > The Trump Beforehand has abundant affirmation of added violations of Georgia’s Acclamation cipher and abundant added austere discrepancies in voting aloft the accompaniment which alarm into catechism the ascendancy of the Secretary of State’s acceptance of the presidential election. > Trump Beforehand attorneys requested that the Georgia Secretary of Accompaniment apostle his assignment to canteen the angary of his state’s elections, saying: “It is not accessible for you to accurately accredit the after-effects in the presidential chase from the November 3, 2020, acclamation until and unless there is a complete assay of the signatures, which we acquire now requested four times in autograph above-mentioned to this request. You cannot in acceptable acceptance achieve the advancing accustomed blab until you acquire instituted a signature analogous audit,” said Ray S. Smith, III, admonition to Donald J. Trump for President, Inc. > “Until the signatures are matched, the vote calculation in Georgia is a complete fraud,” added aloft New York Burghal Mayor and claimed Apostle to Admiral Trump, Rudy Giuliani. “There is no way of animate which ballots are honest and which ballots are fraudulent.” > bang actuality to apprehend the abounding letter. > > CONFIDENTIALITY NOTICE: This bulletin (including any attachments) may accommodate confidential, proprietary, privileged, and/or clandestine information. This admonition is brash to be for the use of the individual(s) appointed above. If you are not the brash almsman of this message, amuse acquaint the sender immediately, and annul the bulletin and any attachments. Any disclosure, reproduction, distribution, or added use of this bulletin or any accessories by an abandoned or article added than the brash almsman is prohibited. Copyright and any added bookish acreage rights are the sole acreage of Donald J. Trump for President, Inc. 3 <11-30 -2020 Letter to the Hon. Brad Raffensperger Re Fifth Abode for signature Analogous Audit_1.pdf> MM005257

Case 1:21-cv-03217-CJN Certificate 15-5 Filed 04/22/22 Folio 1 of 4 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA MARK MEADOWS, Plaintiff, V. Case No. 1:21-cv-3271-CJN NANCY PELOSI, et al. Display D

Case 1:21-cv-03217-CJN Certificate 15-5 Filed 04/22/22 Folio 2 of 4 Bulletin From: Mark Meadows ([email protected]] Sent: 12/6/2020 9:54:21 AM To: Jason Miller [[email protected]] Subject: Fwd: GA –Documents and Talking credibility re: acclamation claiming — Attachments: December 4, 2020 – Columnist Annual – R Smith.pdf; Untitled adapter 00028.htm; Display 17 Appendix.pdf; Untitled adapter 00031.htm; Untitled adapter 00034.pdf; Untitled adapter 00037.htm; VERIFIED PETITION TO CONTEST GEORGIA ELECTION.pdf; Untitled adapter 00040.htm; Christian Adams Acknowledgment GA.pdf; Untitled adapter 00043.htm Beatific from my iPhone Activate forwarded message: From: “Mitchell, Cleta” <[email protected]> Date: December 6, 2020 at 9:50:07 AM EST To: Mark Meadows <[email protected]> Subject: Fwd: GA –Documents and Talking credibility re: acclamation claiming – This is what I able and beatific to Sen Braun aftermost night to admonition adapt him for ABC actualization I this am. Can the WH columnist arrangement get and alpha using?? Cleta Mitchell, Esq. Foley & Lardner, LLP [email protected] 202.431.1950 (cell) 202.295.4081 (office) Beatific from my iPhone Activate forwarded message: From: “Mitchell, Cleta” <[email protected]> Date: December 5, 2020 at 9:42:00 PM EST To: “Kelley, Joshua (Braun)” <[email protected]), Mike Braun <[email protected]> Subject: GA –Documents and Talking credibility re: acclamation claiming Actuality is the abode filed bygone in GA — it accommodation the violations of the GA Acclamation Cipher during the Nov 3 election. If you apprehend the introduction, it is the arbitrary of the suit. Exh 17 is the annual of affirmation affidavits from GA citizens about the violations they witnessed. Active beneath amends of perjury. The columnist annual is acceptable talking points. The announcement of law is annual annual aloof to apperceive we are not authoritative up the law. NOTE: there is annihilation in this clothing apropos Dominion or China or Venezuela or any of that. This is basal complete information, affirmation to beneath amends of perjury, of GA citizens who witnessed the violations — alternating with abstracts experts who brash and analyzed the GA voting annal and files. Actuality are the key points: 1. the US Architecture gives the ascendancy to accompaniment legislatures to accredit MM005596

Case 1:21-cv-03217-CJN Certificate 15-5 Filed 04/22/22 Folio 3 of 4 presidential electors. 2. the legislatures actuate the abode for allotment the electors. 3. the GA assembly (and added legislatures) acquire adopted acclamation laws –to ALLOW citizens to participate. But that is not adapted in the Constitution. in GA the assembly adopted the GA Acclamation Cipher – acceptance the citizens to authentic their will re the presidential electors. 4. In GA , as in the added states, the larboard addition groups and the Autonomous affair went about the legislatures all over the country to get board and exec annex admiral to actualize acclamation procedures that aperture the accompaniment laws allowable by the legislatures for allotment presidential electors. See the affirmation of Christian Adams 5. In GA, we acquire authentic absolutely bags of actionable votes that were cast, counted, and included in the tabulations – votes that abandoned the Acclamation Cipher adopted by the legislature. 6. These actionable votes were alfresco the allowance of achievement in GA for Biden. Abounding times over. 7. The accusation filed on Fri by the Trump beforehand is a GA acclamation contest, provided in the GA statutes – in the Acclamation Code. Every accompaniment has a accouterment acceptance for a applicant or a aborigine to claiming the aftereffect of an election. That is what the GA Beforehand has filed. 8. the accustomed antidote beneath GA law is a new acclamation – and we acquire added than met the accountability beneath accompaniment law for a new election. And we acquire asked for a new election. 9 here, because it involves the presidential election, there is a time affair — but there is additionally a built-in remedy. 10. the Architecture vests the absolute adeptness to accept presidential electors in the Accompaniment Legislatures. If the abode declared by the assembly is not followed — which is the case with -the Nov 3 accustomed acclamation – afresh the assembly accusation accost its built-in ascendancy and albatross to do what the architecture requires: accredit the presidential electors, a 11. Trump beforehand has asked the cloister accompaniment cloister in GA – addition remedies: 1. Adjustment a new election; OR 2. adjure the certification, because of all the actionable votes, and the abortion of the Secretary of Accompaniment and these counties to chase the Acclamation Cipher – and let the assembly accost its built-in ascendancy and aloof actuate the electors. Attending at the columnist annual additionally for ammo credibility re actionable votes. We acquire a allowance in GA of about 12,000 votes (that cardinal keeps changing) – we acquire abounding added actionable votes than the allowance — and beneath GA accompaniment law, a new acclamation is the remedy. POINT: AND THAT’S JUST IN GEORGIA…. I’m additionally adhering the affirmation able affirmation from Christian Adams – it describes the civic plan by the Democrats to do in these key states the aforementioned affair they did in GA. Achievement this helps. Allocution tomorrow. Cleta MM005597

Case 1:21-cv-03217-CJN Certificate 15-5 Filed 04/22/22 Folio 4 of 4 Cleta Mitchell, Esq. Partner, Foley & Lardner LLP 3000 K Street, N.W. Suite 600 Washington, DC 20007-5109 P 202.295.4081 C 202.431.1950 [email protected] Actualization My Bio Arrangement Foley.com The admonition independent in this message, including but not apprenticed to any attachments, may be arcane or adequate by the attorney-client or work-product privileges. It is not brash for manual to, or cancellation by, any crooked persons. If you acquire accustomed this bulletin in error, amuse (i) do not apprehend it, (ii) acknowledgment to the sender that you accustomed the bulletin in error, and (iii) abolish or abort the bulletin and any accessories or copies. Any disclosure, copying, administering or affirmation on the accommodation of this bulletin or its accessories is carefully prohibited, and may be unlawful. Unintended manual does not aggregate abandonment of the attorney-client advantage or any added privilege. Accustomed admonition independent in the above-mentioned bulletin is alone for the annual of the Foley & Lardner LLP client(s) represented by the Close in the authentic bulk that is the accountable of this message, and may not be relied aloft by any added party. Unless abnormally declared otherwise, annihilation independent in this bulletin should be construed as a agenda or cyberbanking signature, nor is it brash to reflect an ambition to achieve an acceding by cyberbanking means. MM005598

Case 1:21-cv-03217-CJN Certificate 15-6 Filed 04/22/22 Folio 1 of 1 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA MARK MEADOWS, Plaintiff, V. Case No. 1:21-cv-3271-CJN NANCY PELOSI, et al. Display E (Filed beneath Seal)

Case 1:21-cv-03217-CJN Certificate 15-7 Filed 04/22/22 Folio 1 of 2 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA MARK MEADOWS, Plaintiff, V. Case No. 1:21-cv-3271-CJN NANCY PELOSI, et al. Display F

Case 1:21-cv-03217-CJN Certificate 15-7 Filed 04/22/22 Folio 2 of 2 BEGBATES ENDBATES All Custodians MasterDate Babble Name Babble Bulletin Blazon Babble Administration From Το MMO14907 Extracted Altercation Hey Mark, The admiral needs to acquaint bodies in the Capitol to go home. This is affliction all of us ‘ 12024414487 MM014907 MM014908 Mark Meadows Mark Meadows 1/6/2021 14:32 12024414487 1/6/2021 14:32 12024414487 Bulletin Bulletin Incoming Incoming ‘ 18282002544 ‘ 18282002544 MM014908 ‘ 12024414487

Case 1:21-cv-03217-CJN Certificate 15-8 Filed 04/22/22 Folio 1 of 19 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA MARK MEADOWS, Plaintiff, V. Case No. 1:21-cv-3271-CJN NANCY PELOSI, et al. Display G

10 CONTINUED INTERVIEW OF: CASSIDY HUTCHINSON 11 12 13 14 Monday, Beforehand 7, 2022 15 16 Washington, D.C. 17 18 19 The annual in the aloft bulk was captivated via Webex, basic at 12:06 p.m. 20 Case 1:21-cv-03217-CJN Certificate 15-8 Filed 04/22/22 Folio 2 of 19 1 2 3 SELECT COMMITTEE TO INVESTIGATE THE 4 JANUARY 6TH ATTACK ON THE U.S. CAPITOL, 5 U.S. HOUSE OF REPRESENTATIVES, 6 WASHINGTON, D.C. 7 8 9 Present: Representatives Aguilar, Raskin, Cheney, and Kinzinger. 21 1

Ms. Hutchinson. Acknowledge you. 10 [Discussion off the record.] 11 Mr. Passantino. Okay. We’re back. We had a altercation about the 12 ambit of attorney-client privilege, but ask your catechism again. 13 Mr. George. Okay. 14 And I’d aloof agenda that Mr. Kinzinger is abutting now as well. 15 BY MR. GEORGE: 16 Q So my catechism was: At any of these affairs with individuals from 17 alfresco the White Abode or the controlling branch, did the White Abode Counsel’s Arrangement 18 authentic an assessment as to whether the plan to acquire electors for Admiral Trump accommodated and 19 casting balloter academy votes in States that Admiral Trump had absent was legal? 20 A Yes. 21 And aloof to be alert of how all-encompassing assertive discussions were, like, those were 22 alcove adaptation as the affairs progressed and added individuals were involved. So there 23 were some affairs breadth they had bidding article alternating the curve of, “Let’s 24 Case 1:21-cv-03217-CJN Certificate 15-8 Filed 04/22/22 Folio 3 of 19 61 entertained evidently was actuality brought to the absorption of all-important individuals 1 internally to ensure that there was best cooperation and admonition amid 2 the alien and centralized interests that were attractive into these theories. 3 Mr. George. Okay. 4 In those meetings, did anybody from the White Abode Counsel’s Arrangement authentic an 5 assessment as to whether it was accustomed to acquire the Trump electors accommodated and casting balloter 6 votes in States that Mr. Trump had lost? 7 Ms. Hutchinson. Could we acquire one moment, please? 8 Mr. George. Of course. 9 abide to attending at this, achieve abiding you’re still analogous with us, communicating with 25

electors plan, but afresh there are groups and individuals and bodies that had hardly 10 altered bureau of attractive at things or hardly altered bureau of potentially acclamation that. 11 And I additionally don’t appetite my words to be recorded and articulate as actuality any accurately 12 conversation, because I’m apery here. 13 But — so, as we looked at the alternating electors, it was, broadly speaking, 14 article that they were accommodating to apprehend theories about, accommodating to acquire the discussions 15 with people. 16 But afresh there were assertive affairs breadth White Abode Counsel’s Arrangement gave 17 the admonition to alien interests of, “This is fine, accumulate researching, accumulate your bodies on 18 this, let’s break in touch, don’t do anything, don’t drag this to Mr. Trump afterwards us 19 actuality apprehend aback in first,” to affairs breadth they would accordance admonition to alien 20 participants added alternating the curve of, “Hey, this isn’t accurately sound, we acquire fleshed this 21 out internally, it’s accomplished that you anticipate this but we’re not action to absorb this in an 22 official White Abode adaptation on annual of the President, we’re putting a stop to this.” 23 Q And aloof to be bright — I acknowledge that, and acknowledge you for walking through 24 Case 1:21-cv-03217-CJN Certificate 15-8 Filed 04/22/22 Folio 4 of 19 62 us, let us apperceive if there’s annihilation aces of bringing to our attention, we’d be blessed to 1 attending at it and agenda accession meeting,” to affairs breadth their absolute admonition to 2 alien interests was added alternating the curve of, “That’s not legal, we’re not putting 3 ourselves in that band of fire,” or, “Don’t accession that to Mr. Trump, it’s not appropriate, and 4 it’s not a accustomed admission that we appetite to absorb adapted now.” 5 Q And, to be clear, what you aloof said about not actuality a accustomed admission they appetite 6 to absorb adapted now, not legal, not putting yourself in the band of fire, that was with 7 annual to this alternating electors plan in particular? 8 A I apologize, I’m aloof aggravating to be careful, because there was the alternating 9 the progression and the various, affectionate of, instances breadth it may acquire arise up. 25

Q Okay. And — 10 A I’m aloof aggravating to be authentic actuality with — 11 Mr. Passantino. You’re good. You’re good. 12 Mr. George. Yep. No, I acknowledge you aggravating to be authentic there. 13 I assumption I appetite to analyze two things on this point. The aboriginal is the plan and 14 efforts to acquire alternating electors accommodated and casting votes for Mr. Trump in States that he had 15 lost. 16 Is it your compassionate that the White Abode Counsel’s Arrangement assessment of that was 17 that it wasn’t accurately complete and that that assessment was bidding in affairs at which 18 third parties were present? 19 Mr. Passantino. Well, she’s abandoned testifying to what she heard bodies say. She’s 20 not able to allocution about what they thought. 21 Mr. George. Yep. 22 Mr. Passantino. She did say what she heard them say. 23 You can ask again. I’m not blocking you. But I aloof appetite to achieve that 24 Case 1:21-cv-03217-CJN Certificate 15-8 Filed 04/22/22 Folio 5 of 19 63 But what abstraction was it that — what wasn’t accurately complete and they didn’t appetite to 1 pursue? 2 A I don’t anamnesis accurately adapted now. I aloof anamnesis there would be assertive 3 affairs breadth individuals would accession annual or things that they adeptness appetite to vet to 4 White Abode Counsel’s Office, and they would acquire a little bit added of an absolute assessment 5 on it, adjoin added instances in affairs breadth it was a little easier to not — I don’t appetite 6 to say “easier” — it was a little altered in ambience from a accustomed standpoint of them 7 absent to vet it and acceptance it to affectionate of beforehand a little bit added afore they put a stop 8 to things. 9 acumen complete clear. 25

early to mid- December is the safer bet. 10 Q And who was present for that affair that you remember? 11 A It was in our office. It was Mr. Meadows, Mr. Giuliani, and a few of 12 Mr. Giuliani’s, like — well, I don’t apperceive if the actual appellation is “associates,” but 13 Mr. Giuliani’s associates. 14 Q Do you bethink who from — 15 A Colleagues. 16 Q — White Abode Admonition — oh, I’m sorry. Go ahead. 17 A No, I was — associates, colleagues, about it adeptness be characterized. 18 Q Do you bethink who from White Abode Counsel’s Arrangement was there and 19 delivered that message? 20 A The complete aboriginal time I heard it, I apperceive Mr. Cipollone. I’m absorbed to say 21 Mr. Pat Philbin as well. But, absolutely speaking, the complete first, I am adequate adage 22 Mr. Cipollone. 23 Q Okay. 24 Case 1:21-cv-03217-CJN Certificate 15-8 Filed 04/22/22 Folio 6 of 19 BY MR. GEORGE: 1 Q And so, to be clear, did you apprehend the White Abode Counsel’s Arrangement say that 2 this plan to acquire alternating electors accommodated and casting votes for Donald Trump in States that 3 he had absent was not accurately sound? 4 A Yes, sir. 5 Q And do you bethink about aback that was? 6 A I’m aggravating to not be anytime broad, but, adapted now, sitting here, I can anamnesis at 7 the time, conceivably aboriginal to mid- December. Now, it complete able-bodied could’ve been the end of 8 November, but I’m aggravating to anticipate about criterion claiming and dates in my head, and 9 Do you bethink — buck with me one moment. 25 64

Were Assembly of Congress present for that affair as well, either in actuality or 1 by phone? 2 Case 1:21-cv-03217-CJN Certificate 15-8 Filed 04/22/22 Folio 7 of 19 A Not at the affair I’m cerebration about. 3 65

White Abode Counsel’s Arrangement bidding an assessment on alternating electors came up breadth 10 Assembly of Congress were present? 11 A Sorry. I capital to achieve abiding that we weren’t advertence one of the 12 opinions that I advanced declared to Assembly of Congress. 13 Yes. To acknowledgment your catechism broadly, yes, I do anamnesis them adopting it in affairs 14 with Assembly of Congress in aboriginal to mid-December likely, though, conceivably — I say early. 15 Maybe like ancient after, like, December 8th. I don’t acquire the agenda in advanced of me 16 of the canicule of the week, but — and I’m aggravating to anticipate about aback Assembly of Congress 17 started advancing into our arrangement to meet. So aboriginal or added anniversary of December. 18 Q Okay. And do you bethink which Assembly of Congress were at the 19 affair in which White Abode Counsel’s Arrangement bidding their assessment that this alternating 20 electors plan was not accurately sound? 21 A The antecedent affair that I’m cerebration of or about and broadly speaking 22 about the events? 23 Q How about we alpha with the antecedent affair and afresh broadly speaking, 24 Case 1:21-cv-03217-CJN Certificate 15-8 Filed 04/22/22 Folio 8 of 19 66 1 [2:09 p.m.] 2 BY MR. GEORGE: 3 Q Did this affair arise up afresh breadth White Abode Counsel’s Arrangement bidding 4 an assessment on alternating electors breadth Assembly of Congress were present? 5 A Yes, sir. 6 Q Aback was that and what happened? 7 A Sorry. Could you echo the aboriginal allotment of that question? Sorry. 8 Q Of course, yes. So the catechism was, were there added affairs breadth the 9 others who may acquire accustomed the aforementioned message. 25

Ms. Hutchinson. Mr. Perry is the associate that anon all-overs out to me, 10 and I’m abandoned — I aloof appetite to be alert because there frequently were Assembly that 11 would punch into affairs as a presence, but they weren’t physically present. And I apperceive 12 that sometimes there were added bodies on the band that I wasn’t acquainted of. Mr. Perry is 13 one that anon all-overs to apperception as me abandoning him physically actuality there and afresh 14 blame aback on him. 15 Now, Mr. Jordan additionally would punch into affairs frequently, and I don’t appetite to 16 aspect White Abode Counsel’s Arrangement blame aback on Mr. Jordan because I don’t apperceive 17 whether Mr. Jordan was abandoned blame for that accustomed theory, if that makes any sense, 18 or if it was aloof them broadly speaking in the attendance of Mr. Jordan. 19 The abandoned one that anon all-overs out to me as actuality there and them affectionate of 20 blame aback a little bit would be both Mr. Perry, Mr. Gaetz — Matt Gaetz — Mr. Gohmert, 21 Louie Gohmert of Texas. 22 And it’s absolutely accessible that there was added too. I’m aloof — I appetite to be authentic 23 and not aspect any of the accomplishments or words from White Abode Counsel’s Arrangement to 24 Case 1:21-cv-03217-CJN Certificate 15-8 Filed 04/22/22 Folio 9 of 19 67 A Initially — the antecedent affair that I’m cerebration about in my head, Mr. Scott 1 Perry was present for, but I don’t appetite to aspect White Abode counsel’s assessment to that 2 affair actuality let’s absorb this, accumulate us in the bend adjoin no. Aloof I anamnesis their 3 opinions actuality bidding in the aboriginal affair that I’m cerebration about with Mr. Scott Perry. 4 Q How about this: How about, in affairs — let me aback up and rephrase. 5 Which Assembly of Congress were present during affairs at which the White 6 Abode Counsel’s Arrangement bidding their assessment that this plan accompanying to alternating electors 7 was not accurately sound, as adjoin to aloof discussions about followup or added research? 8 Mr. Passantino. You acquire — 9 Assembly of Congress or alien interests, aloof because it’s difficult for me to attending aback 25

Q I see. Let me ask a follow-on question. It’s accompanying but not the same. 10 We aloof talked about the admission — or alibi me — the accomplishment to acquire alternating 11 electors accommodated and casting votes for then-President Trump in States that he had lost. I appetite 12 to fast-forward a little bit. And the affectionate of follow-on admission that I apperceive you acquire been 13 aggravating to analyze in your apperception — and I acknowledge that — but like the follow-on admission 14 for John Eastman is that, because these votes now exist, because the Republican electors 15 acquire met and casting their votes, afresh the Carnality Admiral can accept to calculation those or not 16 calculation those during the Collective Affair of Congress. 17 Do you bethink any affairs at which third parties, so not White Abode 18 cadre or not controlling annex members, were present in which the White Abode 19 Counsel’s Arrangement said that that, that use of the admission like that of John Eastman, was not 20 accurately sound? 21 A Yes. But I can’t aspect a specific affair aloof because I don’t anamnesis adapted 22 now. But I do anamnesis — 23 Q It did happen? 24 Case 1:21-cv-03217-CJN Certificate 15-8 Filed 04/22/22 Folio 10 of 19 68 and anamnesis accommodation of those affairs or conversations that happened breadth the Assembly 1 were advocating for those theories personally, if that makes sense. 2 BY MR. GEORGE: 3 Q It does, yes. 4 And there’s a affair on December 2lst in the White Abode at which some of 5 those Assembly were present. Do you anticipate it was that affair or a altered meeting? 6 A I anamnesis them accepting conversations with Assembly that were a allotment of that 7 meeting, but there additionally were several Assembly that alternating in that affair that 8 were frequently present throughout this aeon that we’re discussing. 9 A Yes. 25

that was, like, on the table, accurately on the table. 10 But already it became bright that there would be accumulation resignations, including attorneys 11 in the White Abode Counsel’s Office, including some of the agents that Mr. Meadows 12 formed anxiously with, you know, I apperceive that that did bureau into his cerebration that night. 13 Q And these issues that came up, including abduction voting machines and 14 appointing Ms. Powell as a adapted admonition and potentially arty advancing law, is it your 15 compassionate that those were actuality brash or proposed in adjustment to change the 16 aftereffect of the acclamation and acquire Mr. Trump alpha a added appellation on January 20th? 17 A So, like the Mr. Eastman theories, it was article that alien individuals 18 acquainted could potentially be a built-in and applicative advantage to either arrest acceptance of 19 the acclamation or to adjournment the commencement or to beforehand that Mr. Trump had absolutely won. 20 And there were theories — you know, I can’t allege to if Mr. Trump — yeah, I’ll leave it 21 there. 22 Q Okay. Fair enough. 23 So, at that time — I aloof appetite to get, we’ll alarm it “atmospherics,” but aloof an 24 Case 1:21-cv-03217-CJN Certificate 15-8 Filed 04/22/22 Folio 11 of 19 138 said during the abode allocation of that meeting? I acquire Mr. Giuliani was there with 1 you — or was there as well? 2 A The attorneys, Mr. Herschmann, Mr. Lyons, all were complete clear, as has been 3 reported, that they would abandon if this was approved. And I apperceive that that did bureau 4 into Mr. Meadows’ decision. He didn’t appetite to lose them. 5 Q Aback you say “if this was approved, they would resign,” what do you beggarly 6 by “this”? 7 A If Ms. Powell had been appointed adapted counsel, if they had brash 8 invoking advancing law added in depth, which — I don’t apperceive if it was anytime alike article 9 compassionate of what the discussions were like at the White House. 25

A To my knowledge, he was not there. 10 Q All right. 11 And afresh we acquire a cardinal of Abode Members. I acquire they were from the 12 Abode Freedom Caucus. Is that right, generally? 13 A That’s accurate, generally. 14 Q Okay. So did that accommodate Jim Jordan? 15 A Yes, Mr. Jordan was there. 16 Q Andy Biggs? 17 A Mr. Biggs was there. 18 Q Mo Brooks? 19 A Mr. Brooks was there. 20 Q Matt Gaetz? 21 A Mr. Gaetz was there, although I don’t acquire Mr. Gaetz is a allotment of the 22 Freedom Caucus. 23 Q Okay. How about Marjorie Taylor — 24 Case 1:21-cv-03217-CJN Certificate 15-8 Filed 04/22/22 Folio 12 of 19 A He was. 1 Q Who abroad from his aggregation do you bethink actuality there? 2 A I don’t bethink anybody abroad that was in there and had accompanied 3 Mr. Giuliani to that meeting. 4 Q Was Phil Waldron there, somebody we talked about earlier, if you 5 remember? 6 A I don’t bethink if Mr. Waldron was there. 7 Q How about John Eastman? Was he at that meeting, to the best of your 8 knowledge? 9 A [Inaudible.] 25 146

And there was additionally a scattering of others that were there that I — Mr. Perry 10 absolutely spoke. I can’t bethink if he was dialed in or if he was physically present 11 though. They dialed in a few Assembly over the beforehand of that meeting. 12 Q Okay. 13 What do you bethink — were you in that affair the accomplished time? 14 A Not the complete time, no. 15 Q Okay. What do you bethink from that meeting? What happened? 16 A A few Assembly bidding their opinions and their thoughts on January 6th, 17 what they believed that the Carnality President’s role could potentially be — 18 Q Can I stop you there? 19 A Yes. 20 Q On that affair in particular, the Carnality President’s role and what they anticipation it 21 would be, what was it? What was the babble like? 22 A They acquainted that he had the ascendancy to — absolution me if my delivery isn’t 23 actual on this, but — accelerate votes aback to the States or the electors aback to the States, 24 Case 1:21-cv-03217-CJN Certificate 15-8 Filed 04/22/22 Folio 13 of 19 147 Q Sure. How about Marjorie Taylor Greene? 1 A Was not at the time a associate of the Freedom Caucus, as she was still 2 Congresswoman-elect, but, yes, Ms. Marjorie Taylor Greene was there. 3 Q How about Louie Gohmert? Was he there? 4 A Mr. Gohmert was there. 5 Q Do you bethink anybody abroad who was there from the Abode or the 6 Congress? 7 A Mr. Hice, Jody Hice; Mr. Gosar, Paul Gosar; I acquire Ms. Lesko, Debbie Lesko 8 of Arizona. 9 added alternating the curve of the Eastman theory. I’m not complete accomplished on it, and I 25

And did both of those things, either the Carnality President’s adeptness to calculation or not 10 calculation and additionally his adeptness to accelerate the votes aback to the States, did they arise up in that 11 affair on the 21st? 12 A They did. 13 Q And did anybody in that affair disagree with the abstraction that the Carnality 14 Admiral had the ascendancy to do that, either of those options? 15 A I don’t anamnesis anybody speaking out and definitively cogent altercation 16 with that theory. I acquire I am not out of band for — I don’t appetite to say 17 “speculating” — for adage that the Carnality President’s aggregation appeared hardly skeptical. 18 But, you know, again, I wasn’t present from alpha to finish, but I don’t anamnesis in my 19 attendance or anon afterwards audition acknowledgment from Members, anybody, you 20 know, adage annihilation that would acquire been perceived as controversial, which would’ve 21 been, “No, actually, the Carnality Admiral doesn’t acquire that theory, and here’s why.” 22 Q Okay. 23 Do you bethink the Carnality Admiral or Mr. Abbreviate adage annihilation about this abstraction 24 Case 1:21-cv-03217-CJN Certificate 15-8 Filed 04/22/22 Folio 14 of 19 148 apologize for that. 1 Q That’s absolutely all right. That’s absolutely right. So Mr. Eastman said that the 2 Carnality Admiral would have, amid added things, the ascendancy to calculation assertive votes or to 3 adjournment the acceptance and accelerate votes — 4 A Right. 5 Q — aback to the States. 6 A Okay. To accelerate the votes aback to the States, not the assembly or the 7 electors, but, yes, accelerate the votes back. 8 Q Okay. 9 during the meeting? 25

Q Do you apperceive if Mr. Meadows was in blow with Jeff Clark? 10 A Frequently. 11 Q Okay. Do you apperceive how that started or why it started, what the purpose 12 of it was? 13 A No. I aloof came — accustomed Mr. Clark as somebody that was acceptable the 14 efforts with the advancing acclamation assay action in the White House. 15 Q Do you apperceive if Mr. Clark was animate with Mr. Giuliani and his team? 16 A Mr. Clark came to affairs that Mr. Giuliani was additionally in that additionally 17 met — affair with Mark, Mr. Meadows. And I bethink Mr. Clark’s common 18 attendance and his common beat and communications, but I don’t bethink specific 19 affairs or apperceive who he would acquire arise with for what meeting. He was about a 20 lot of bodies in a time aback there was — I’m not aggravating to be vague, but there was a lot of 21 bodies about and present and were in and out of rooms, so — 22 Q Do you apperceive what Mr. Clark — or were you present for any affairs 23 amid Mr. Clark and the President? 24 Case 1:21-cv-03217-CJN Certificate 15-8 Filed 04/22/22 Folio 15 of 19 155 addition or would acquire gave that introduction. Sounds odd to me, but — 1 Q I acquire that there’s a affair that Mr. Clark had in the abode with 2 the Admiral and potentially Scott Perry as well. Do you apperceive annihilation about that 3 meeting? 4 A No. 5 Q Okay. Do you apperceive — 6 A I don’t anticipate Mr. Perry anytime went to the residence. 7 Q I’m sorry? 8 A I don’t anticipate Mr. Perry anytime spent time in Mr. Trump’s residence. 9 A Not in the room, no. 25

insight on. So, yes, I bethink him advancing to affairs with Mr. Trump. But, again, 10 aloof bringing it aback to what I advanced said, I don’t apperceive if it was Mr. Giuliani who had 11 brought him, if it was Mr. Trump who had abandoned declared him, like, who had 12 accommodating all these efforts and who was in the allowance for these meetings. But I do 13 bethink he adeptness acquire had a affair with Mr. Trump or Mr. Trump and Mr. Clark 14 accepting communications because Mr. Meadows was afresh circuitous in those conversations. 15 Q Okay. And on that point, how would Mr. Meadows acquaint with Jeff 16 Clark, do you know? 17 A Like on corpuscle buzz or by snail mail? 18 Q Sure. Corpuscle phone, altercation messages, Signal application. 19 A I’ve abandoned accustomed Mr. Meadows to acquaint with Mr. Clark on his official 20 assignment buzz and — definitively his official assignment phone. 21 Q Okay. And do you apperceive what happened in the affairs amid Jeff Clark 22 and the President, or Mr. Meadows, for that matter? And accurately I’m absorbed in 23 acquirements why — or what the Admiral or Mr. Meadows anticipation Mr. Clark could do in his 24 Case 1:21-cv-03217-CJN Certificate 15-8 Filed 04/22/22 Folio 16 of 19 156 Q Okay. Do you apperceive what happened in any affairs amid Mr. Clark 1 and the President, added than January 3rd? That was with a lot of administering with the 2 Administering of Justice, and we don’t accusation to get to that one yet. 3 A Yet. 4 I’m sorry. Could you recapitulate your question? 5 Q Yeah, sure. Added than January 3rd, are you acquainted of any affairs that 6 Mr. Clark had with the President? 7 A I bethink him advancing to the White Abode for affairs with Mr. Trump. 8 And, you know, I — all — about all — about all, if not all, affairs Mr. Trump had, I had 9 role at the Administering of Justice. 25

that, you know, was categorical in this letter and, you know, was the affair of babble 10 at the time. But I wasn’t buried to any of those conversations extensively. 11 Q Do you apperceive whether the Admiral advocated for this abstraction to acquire the 12 Administering of Amends accelerate a letter like this? 13 A At the time, I’m not abiding whether the Admiral advocated for DOJ to accelerate a 14 letter like this. 15 Mr. George. Any questions on the Administering or this letter? 16 BY MR. GEORGE: 17 Q Okay. All right. So on December 22nd, I acquire that Mr. Meadows 18 went to Cobb Canton in Marietta, Georgia, specifically, breadth an assay was actuality 19 conducted of signatures accompanying to ballots casting in the 2020 election. 20 Did you go with Mr. Meadows on that trip? 21 A I did not. I was at the White Abode that day. He asked me to break abaft 22 because he larboard afore Mr. Trump larboard for Florida, and that way at atomic I was there in case 23 he bare annihilation on our annual and he couldn’t get ahold of Mr. Meadows. 24 Case 1:21-cv-03217-CJN Certificate 15-8 Filed 04/22/22 Folio 17 of 19 161 You said you don’t apperceive what Mr. Meadows did with this letter already he accustomed 1 it, correct? 2 A Correct. That’s correct. 3 Q And do you remember, were there any discussions about this letter or the 4 annual in the letter about accepting the States alarm them — Accompaniment legislatures alarm themselves 5 aback into affair to appraise issues accompanying to the acclamation at DOJ’s request? 6 A I bethink the annual — that abstraction actuality discussed, broadly speaking. I 7 bethink Mr. Meadows advertence it in affairs and already or alert in eyewitness 8 babble with me, but annihilation that would advertise his assessment on it, aloof as article 9 Q Did you at any point go to Georgia while Mr. Meadows was on this cruise in 25

Fuchs, I acquire is how you accent her name. What was the purpose — your 10 compassionate of what was the purpose of him affair with Ms. Fuchs? 11 Mr. Passantino. Which one? Okay. 12 Ms. Hutchinson. He met with Ms. Fuchs at Cobb — at the Cobb Canton aback he 13 went to see the ballots actuality counted. I’m aggravating to cull them up here. There was a 14 few added admiral there too. 15 He agreed — can you guys apprehend me okay? 16 Mr. George. Yeah, we can apprehend you. 17 Ms. Hutchinson. Sorry. We got a admonishing notification. 18 I’m sorry. I absent my alternation of thought. 19 Mr. Meadows and Mr. Trump had conversations about what Mr. Meadows could 20 potentially do bottomward in Georgia. Now, there was a point breadth I was action to go with 21 him because he was action to conduct a few added meetings, but afresh it was absitively that 22 he would achieve it a little bit added breezy and casual, which is aback he absitively to go 23 watch the ballots actuality counted. 24 Case 1:21-cv-03217-CJN Certificate 15-8 Filed 04/22/22 Folio 18 of 19 162 backward December? 1 A I did not. 2 Q Do you apperceive what the purpose of Mr. Meadows action to Georgia was during 3 this signature review? 4 A The primary purpose of this cruise was to arrangement family. His son lives in Georgia, 5 and they went bottomward to see his son for Christmas. Conveniently, his son lives in abutting 6 adjacency to Cobb County, and Mr. Meadows had discussed at breadth analogous any 7 visits with Georgia Accompaniment admiral during this trip. 8 Q I acquire that he did accommodated with some Georgia officials, including Jordan 9 I’m not abiding if he accomplished out to Ms. Fuchs anon to alike that. However, 25

people who are accomplishing the signature assay on ballots? 10 A He capital to do added of a cachet assay to see breadth they were at with 11 things, if they had thoughts that they bare any added resources, if there was annihilation 12 that the White Abode could do to admonition affluence the action along. If they needed, like, 13 bodies, there were beforehand admiral that had been, you know, off-boarded and were 14 attractive for jobs, so — our beforehand admiral — the Trump beforehand officials, I should say. 15 But — and afresh aloof had conversations with the Georgia Accompaniment admiral about what they 16 were audition from the Accompaniment about cachet of the acclamation and, you know, if there was 17 cogent affirmation to their adeptness at that point. 18 Q Cogent affirmation of artifice or irregularities in the election? 19 A That’s correct. I apologize for not specifying. 20 Q No. That’s absolutely all right. That’s my job. 21 So if you go to display 27, please. 22 This is a altercation barter that you had with somebody declared Chris, with the brand 23 CG. Do you apperceive who that is? 24 Case 1:21-cv-03217-CJN Certificate 15-8 Filed 04/22/22 Folio 19 of 19 163 I got a alarm from her afterwards that day, and he went there with the ambition of speaking to 1 the volunteers and the agents assembly that were counting the ballots and reevaluating the 2 ballots casting on November 3rd. 3 And afresh there were a few added Georgia Accompaniment admiral that were present at that 4 time. Now, whether they were present because there was official business action on or 5 because they knew that he was action to be there, thus, they capital to accommodated with him, 6 I’m not sure. But that’s the all-embracing base of this authentic visit. 7 BY MR. GEORGE: 8 Q What did he anticipate he could accomplish, if you know, by speaking to the 9 A Yes. CG, he was the — I’m aggravating to bethink his adapted title. He 25

MARK MEADOWS, ) ) Plaintiff, ) ) v. ) Case No. 1:21-cv-3271-CJN ) NANCY PELOSI, et al. ) ) ) Case 1:21-cv-03217-CJN Certificate 15-9 Filed 04/22/22 Folio 1 of 2 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA Display H

He’s got to condem this shit. Asap. The MM014925 MM014925 Mark Meadows 1/6/2021 14:53 ‘ 16464833417 Bulletin Incoming ‘ 16464833417 ‘ 18282002544 captiol badge cheep is not enough. MM014926 MM014926 Mark Meadows 1/6/2021 14:54 ‘ 16464833417 Bulletin Outgoing [email protected] ‘ 16464833417 I am blame it hard. I accede Case 1:21-cv-03217-CJN Certificate 15-9 Filed 04/22/22 Folio 2 of 2 BEGBATES ENDBATES All Custodians MasterDate Babble Name Babble Bulletin Blazon Babble Administration From To Extracted Text

MARK MEADOWS, ) ) Plaintiff, ) ) v. ) Case No. 1:21-cv-3271-CJN ) NANCY PELOSI, et al. ) ) ) Case 1:21-cv-03217-CJN Certificate 15-10 Filed 04/22/22 Folio 1 of 15 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA Display I

10 11 12 DEPOSITION OF: KEITH KELLOGG, JR. 13 14 15 16 Tuesday, December 14, 2021 17 18 Washington, D.C. 19 20 21 The annual in the aloft bulk was captivated in Allowance 4480, O’Neill Abode Arrangement 22 Building, basic at 10:02 a.m. 23 Case 1:21-cv-03217-CJN Certificate 15-10 Filed 04/22/22 Folio 2 of 15 1 2 3 4 5 SELECT COMMITTEE TO INVESTIGATE THE 6 JANUARY 6TH ATTACK ON THE U.S. CAPITOL, 7 U.S. HOUSE OF REPRESENTATIVES, 8 WASHINGTON, D.C. 9 Present: Representatives Aguilar and Cheney. 24 1

The Witness. I went — well, I went — actually, went adapted upstairs, the stairs to 10 the left, adapted up there, arrested the civic aegis arrangement to accretion out was O’Brien in the 11 loop. He was not. Breadth Matt Pottinger was. He was not in either. And afresh went 12 from there to the Oval Office. 13 Ms. Cheney. And aback you went into the Oval Office, did you stop in the alien 14 Oval? 15 The Witness. I consistently — I chock-full in the Oval. Molly was there, Nick Luna was 16 there. And, frankly, by that time I wasn’t afraid about anybody actuality a alcazar guard. 17 I aloof absolved in. 18 And I acquire Mark — I acquire Mark Meadows was already in the aback allowance in the 19 Presidential dining room. And I anticipate I absolved aback in there and we were all watching 20 TV at the aforementioned — we were all seeing the TV action on, seeing what’s happening. 21 Ms. Cheney. So you and Mark Meadows and the Admiral were aback in his 22 clandestine dining allowance watching TV. Is that what happened? 23 The Witness. I was there and afresh I absolved out of there. The answer’s yes and 24 Case 1:21-cv-03217-CJN Certificate 15-10 Filed 04/22/22 Folio 3 of 15 114 went over — adapted over to the Oval — to the West Addition and afresh into the Oval Arrangement to 1 achieve abiding everybody was tracking what was happening. Because you try as the 2 civic aegis guy authoritative abiding everybody has situational awareness. Are you seeing 3 the aforementioned affair I’m seeing? Are your TVs on and you’re seeing it to achieve sure? 4 So I was tracking that with the Abstruse Service. And I can’t bethink absolutely the 5 time because, frankly, I wasn’t advantageous absorption to the time. It was added so authoritative abiding 6 that everybody was in the loop. Is this absolutely — everybody tracking what’s happening. 7 Ms. Cheney. And so acquaint us what happened. You said you went over to the 8 West Addition and absolved through the lower antechamber there? 9 no. I didn’t break the complete time. I absolved out of there and absolved aback out. And I’m 25

The Witness. I apparently said I’m action to the aback or words — aloof to let them 10 know. Like, they acutely knew I was action to. But I didn’t ask permission. I mean, I 11 had the applicant privilege. I aloof went in. 12 Ms. Cheney. And afresh aback you got aback into the back, what did you say? 13 The Witness. Well, I saw the Admiral watching TV. And Mark — I’m appealing 14 sure, Congresswoman, that — I’m appealing corruption abiding Mark was there. And I probably, 15 which I am decumbent to do, apparently said article that was appealing — like this is absolutely 16 curse deleted, and apparently said article like that. And afresh at that time I was 17 aggravating to bulk out breadth do you go to next. 18 Ms. Cheney. So this would acquire been — but you don’t apperceive absolutely what time 19 this was? 20 The Witness. Ma’am, ma’am, I absolutely don’t. I don’t apperceive at all. I’m not sure. 21 Ms. Cheney. But it’s moments — moments it sounds like afterwards you aboriginal saw — did 22 you — was the TV on in your arrangement aback you sat bottomward to eat your sandwich or you 23 affronted it off and sat down? 24 Case 1:21-cv-03217-CJN Certificate 15-10 Filed 04/22/22 Folio 4 of 15 115 not abiding absolutely the timing, but I anticipate by that time Kayleigh McEnany had arise in and I 1 met her in the alien Oval. 2 Ma’am? 3 I anticipate — because I anticipate — my point was — my acceptance at the time was, based on 4 claimed experience, this had gotten out of control. And there was — and complete candidly, 5 ma’am, by this time there was no way to ascendancy it. And afresh — so you’re attractive at the 6 abutting achieve action forward. 7 Ms. Cheney. So aback you absolved into the alien Oval and you saw Molly and 8 Nick Luna, did you say annihilation to them? 9 The Witness. Did I see the what? 25

BY MR. HEAPHY: 10 Q You were aloof about to allocution about messaging and Kayleigh McEnany. 11 A Uh-huh. 12 Q Was the babble that you mentioned with her occurring adapted afterwards 13 Mr. Pottinger best up the phone? 14 A Yeah, and allotment of the babble was, to the best of my recollection, is, 15 what are you — you get the Admiral out there adage something. 16 Q Yeah. 17 A And the catechism was, do you do a columnist conference? I apperceive I complete 18 acerb recommended do not. 19 Q Stop for a minute. Who was circuitous in this conversation? 20 A It was me. It was me and Kayleigh. 21 Q Aloof the two of you. 22 A Tim, there were added bodies in the alien Oval. 23 Q Uh-huh. 24 Case 1:21-cv-03217-CJN Certificate 15-10 Filed 04/22/22 Folio 5 of 15 A No. Matt Pottinger did. 1 Q Did you participate in any calls with Homeland Security? 2 A No. 3 Q Did you participate in any calls with the FBI? 4 A No. 5 Q Okay. How about the Administering of Justice? 6 A No and — 7 Q All right. And — 8 Mr. George. Did you acquire a question? 9 A And I don’t apperceive who was there. 25 129

something that you can broadcast or bodies will aces up on there, adage what’s happening, 10 action on. 11 Q Okay. 12 A So my point was it needs to be about quick. It needs to be beheld to get 13 it out there. And afresh a fallback is consistently your tweets. But I bethink adage complete 14 distinctly, boy, I don’t acclaim a columnist arrangement — 15 Q Yeah. 16 A — because they, are, my acquaintance in 4 years, there wasn’t a distinct apple-pie 17 columnist arrangement we had. 18 Q Was Ms. McEnany allurement your admonition about — 19 A No, I was aloof authoritative a animadversion to her because Kayleigh was a absolutely very, 20 complete able and aberrant spokesman. She accustomed accumulation media — 21 Q Okay. 22 A — because she came from accumulation media — 23 Q Uh-huh. 24 Case 1:21-cv-03217-CJN Certificate 15-10 Filed 04/22/22 Folio 6 of 15 130 Q Uh-huh. 1 A You know, there may acquire been — Matt was there. Molly was there. Nick 2 Luna was there. Mark Meadows alike may acquire been. And the acumen I said that is 3 because columnist conferences tend to get out of control, and you appetite to ascendancy the 4 message. 5 So I said I didn’t anticipate — I didn’t anticipate a cheep was appropriate. And the acumen I 6 didn’t anticipate a cheep was appropriate, my acquaintance that I had had in riots is best bodies 7 are not blockage their offense. You know, they’re aggravating to do article stupid. 8 So I said you apparently affliction to put article out that will hit on the annual or 9 A — with her time as CNN. 25

talk to dads, about they accept to daughters added than they accept to their sons. And I 10 anticipate she was complete abutting to her dad. 11 My acquaintance in 2016 during the campaign, aback Ivanka Trump would say “the 12 applicant capital this,” you listened. But aback she said “my dad capital this,” we 13 absolutely listened. 14 So I knew there was a byword that we use, and I anticipate you had to achieve it personal. 15 And I recommended that she go allocution to her dad about it. 16 Q What did you appetite her to allocution to her dad about? 17 A Aloof the accomplished situation, to basically allocution from babe to father. And I 18 was not present for any of the conversations. 19 Q Understood. So you didn’t participate in those conversations — 20 A No. 21 Q — amid Ivanka — 22 A No. 23 Q — and the President. 24 Case 1:21-cv-03217-CJN Certificate 15-10 Filed 04/22/22 Folio 7 of 15 139 A I’m sorry. Yes, I did. I’m sorry. I did allocution to her on the 6th and the 7th, 1 and I talked to her both days. 2 Q All right. Let’s focus on the 6th and not the aboriginal morning actuality but in the 3 afternoon. 4 A Yeah, and I said, my advocacy to her was to go aback and allocution to her 5 dad. 6 Q Why did you anticipate that was necessary? 7 A Do you see how I phrased it? I didn’t say go allocution to the President. I said 8 go allocution to your dad because — and I acquire a daughter. My experience, aback daughters 9 But, I mean, for you to beforehand she go allocution to him, there had to acquire been a acumen 25

A No. Dan, you — there was no way for the Admiral to stop it. This affair 10 was out of control. I don’t affliction if you were God. You couldn’t ascendancy it. To do 11 article about it is a altered story. 12 Q Understood. So you anticipation that Ivanka could get her ancestor to do 13 article about it. 14 A To booty a beforehand of action. 15 Q And what did you anticipate that beforehand of action — 16 A Whatever it was, to put some controls on it. 17 Q And would the beforehand of action acquire the brash aftereffect of — I apperceive you say 18 it can’t be endlessly what was action on but somehow — 19 A Calming the bearings down. 20 Q Okay. 21 A You know, do it so — do it so you don’t lose the Capitol, you know. What I 22 beggarly by accident it, somebody actuality absolutely stupid. You know, you got Chewbacca active 23 about out there, whatever his name was, you know, accepting those guys out the Capitol. 24 Case 1:21-cv-03217-CJN Certificate 15-10 Filed 04/22/22 Folio 8 of 15 140 why. What did you appetite the aftereffect of that to be? 1 A Well, the acumen is because there’s cipher afterpiece to Donald J. Trump than 2 his daughter, Ivanka. 3 Q Understood. Did — 4 A It’s babe to father. 5 Q Did you anticipate that she could admonition get him to a abode breadth he would achieve a 6 annual to try to stop this? 7 A Yes. 8 Q And was it your affair that — 9 You know, do article like that. 25

Mr. Wood. And did she say annihilation to you about what she said to her father? 10 The Witness. No. And I didn’t ask. 11 Mr. Heaphy. So this is affectionate of — 12 Ms. Cheney. Accustomed Kellogg, what did you say to her? 13 The Witness. Ma’am, I said, aback I talked to Ivanka, from my acquaintance with 14 her, I knew she could allocution to the Admiral as her dad and say, you know, I think, you 15 know, words to the effect: You know, Ivanka, this is time to go in as a babe to a dad 16 and go allocution to him. That’s about all I said. 17 And — and what I anticipation was admirable is I apperceive she did it because I saw her 18 airing adapted by me into the Oval. So I apperceive she did it. And, afterwards on, I apperceive she 19 had — she had done it afresh because, as I was abnormality to the West Wing, she had arise 20 out of the Oval again. So I noticed. 21 That’s why I said she did it twice. She may acquire done it added than twice, but I 22 apperceive she did it twice. And that’s the acumen — that’s aback I anticipate — for everybody to 23 understand, I anticipation she was, you know, that day I anticipation she was — did aggregate 24 Case 1:21-cv-03217-CJN Certificate 15-10 Filed 04/22/22 Folio 9 of 15 141 Q Did she go and allocution to her father? 1 A Yes. 2 Q Did she acquaint you about that conversation? 3 A No. I didn’t ask her either. 4 Q All right. How abounding times did she go allocution to him? 5 A I anticipate at atomic twice. 6 Q And compassionate you don’t apperceive what was said necessarily, did that annual 7 the Admiral to do anything? 8 A I don’t know. 9 that you would appetite somebody like — article my babe would do or somebody 25

And I anticipate she basically went in there, animate she was talking to her dad and 10 talked as you would apprehend a babe to do, which is allocution complete hard. And I think, 11 because of that and aggregate we were watching in the White House, I anticipate she was 12 accommodating to go to the mat on added than one break and basically do a echo attack. I 13 don’t — maybe that’s a bad babble to use — echo altercation with her father. And I accordance 14 her, as anybody, I would accordance people, acclaim for that. 15 Ms. Cheney. And go to the mat or do a echo altercation about what? You 16 didn’t say to her what you capital her to go allocution to him about? 17 The Witness. No, ma’am. Ma’am, I aloof said that, you know, I anticipate 18 that — words to the aftereffect of allocution to him about what was action on. 19 Ms. Cheney. And so apparently the aboriginal time she went in, it wasn’t acceptable or 20 she wouldn’t acquire had to go aback at atomic one added time, I assume. Is that correct? 21 The Witness. Well, yes, ma’am. I anticipate she went aback there because Ivanka 22 Trump can be appealing tenacious. And I anticipate she went aback in on added than one break 23 to try to get a faculty of — faculty of what was action on. And I anticipate she aloof — that’s just, 24 Case 1:21-cv-03217-CJN Certificate 15-10 Filed 04/22/22 Folio 10 of 15 142 that would — had the best absorption and everybody to do. I anticipation she did it. 1 Ms. Cheney. I was absolutely addled by you said she was a hero that day, and I 2 admiration if you could explain that — 3 The Witness. Yeah. 4 Ms. Cheney. — a little bit more. 5 The Witness. My acquaintance was — and this goes aback to 4 years that, any time 6 you talked to the President, if it was a boxy situation, and that you had to acquire the 7 adeptness and the adventuresomeness to go alternating and say what you believed to be, alike if it went 8 adjoin the atom of happening. You absolved in there, and you say this is what’s action on. 9 my experience, that’s her nature. 25

others about his cessation or what he should be accomplishing on January 6th? 10 A No. I anticipate it was one of those that Ivanka could accompany raw accuracy to an 11 issue. And I anticipation if there was any adviser in the White Abode in 4 years that could 12 allocution to her dad as a dad, it was Ivanka. It wasn’t Jared. It wasn’t me. It wasn’t 13 anybody. It was a babe to a dad. I saw it in the beforehand — 14 Q Yeah. 15 A — in 2016. So I knew she was the ascendancy card. 16 Q Yeah, absolutely acknowledge that and acknowledge the actuality that the babe can 17 get through in some bureau that others can’t. But why was it necessary? Why was it 18 that Mark Meadows and Kayleigh McEnany and Keith Kellogg and everybody abroad who 19 was there, talking to him over the beforehand of the day, weren’t abundant admitting you had to 20 comedy the ascendancy card? 21 A We’re not blood. 22 Q But what was he not doing, Accustomed Kellogg, that you capital Ivanka to 23 altercate him to do? 24 Case 1:21-cv-03217-CJN Certificate 15-10 Filed 04/22/22 Folio 11 of 15 143 And, by the way, ma’am, I’m not — I can abandoned say she went in twice. She may 1 acquire gone in more, but I wasn’t about all the time to watch the goings and comings. 2 That’s article that maybe Molly would acquire apparent or Nick Luna would acquire seen, but I 3 wouldn’t have. 4 Ms. Cheney. Okay. Acknowledge you. 5 BY MR. HEAPHY: 6 Q So sounds like a trump card, like — absolution the pun — you don’t comedy this agenda 7 unless it’s absolutely all-important or absolutely important. Did you animate Ivanka to go allege to 8 him because of some attrition that you had either empiric yourself or perceived from 9 A Cipher — aback you say “not doing,” look, we were in unchartered territory. 25

Q Yeah, again, I absolutely understand. You mentioned that you would accelerate 10 Ivanka in aback you bare article adjoin the atom or in a boxy situation. Your 11 words 2 annual ago. 12 A Uh-huh. 13 Q What were you attractive for her to do in this bearings that was adjoin the 14 grain? 15 A Well, no, I said if — she — to go adjoin the atom acceptation if — to beforehand the 16 situation, admonish her ancestor on maybe this is what you accusation to do action avant-garde that 17 would bell because she was the daughter. 18 For example, if I would acquire said, you know, “You accusation to do A,” maybe that was 19 the advocacy as an advisor, annihilation happened. Meadows would say, “Do A,” 20 annihilation would arise as the arch of staff. She walks in the aperture and she says, “Dad, 21 you accusation to do A,” it’s a altered tone. And I saw that in 5 years. 22 Q And is that what you were attractive for here? 23 A Yes. 24 Case 1:21-cv-03217-CJN Certificate 15-10 Filed 04/22/22 Folio 12 of 15 144 I don’t know. I mean, none of us knew really. My abandoned point was, based on what my 1 experience, was that this was a bearings that was absolutely out of ascendancy and you couldn’t do 2 annihilation about it, because all of my experience, already you aperture security, already they got 3 central the Capitol, you basically had to let it bake itself out to the best allotment because, 4 because the control, the police, the law administering had been overwhelmed. So 5 there’s annihilation you could do. So now you’re action to mitigation. What do you do 6 next? 7 And what I’m adage by claret is cipher had that claret relationship. We were 8 advisors. Okay. We weren’t family, and there’s a huge difference. 9 Q He didn’t say yes to Mark Meadows or Kayleigh McEnany or Keith Kellogg, 25

A And, as I say, he did it. 10 Q I understand. I don’t beggarly — I don’t beggarly to arrest you. 11 A No. 12 Q But it sounds, Accustomed Kellogg, to me like you abandoned accusation the ascendancy agenda or the 13 trump agenda if he’s advancing to accomplishing the affair that you appetite him to do. 14 A But it’s barefaced because we were in unchartered territory. So the 15 catechism is: What do you do? And that was, you know, she was the — aback I say the 16 ascendancy card, she was the one to do, move the abutting step. 17 Q Okay. 18 BY MR. WOOD: 19 Q What was the Admiral advancing to doing? 20 A I didn’t say he was resistant. 21 Q I anticipation in acknowledgment to my aide — 22 A No, no, we were adage there was no — we were in unchartered territory. 23 Cipher knew what was action on. I’m not adage there was resistance. It was, what 24 Case 1:21-cv-03217-CJN Certificate 15-10 Filed 04/22/22 Folio 13 of 15 145 but he adeptness say yes to his daughter. 1 A Absolutely right. 2 Q And what’s the yes? What were you attractive to get him to do? 3 A Well, to basically the abutting achieve is, how do you ascendancy the situation? Calm 4 it down. 5 Q Right. 6 A Do you do it by, you know, a buzz call? Do you do it by a tweet? Do you 7 do it by a TV appearance? What do you do to do it? But to do it. 8 Q Right. And it sounds to me — 9 footfall do you booty abutting to abate the situation? 25

deck, and I told her I accustomed what she did that day and by talking to her dad. And I 10 said: You know, I aloof anticipation what you did was to me appealing heroic. 11 And I said — and she said: Well, my dad’s stubborn. 12 And I said: Your accomplished family’s stubborn. 13 Q You said to Ivanka Trump: I acknowledge what you did. 14 What is it that she did? 15 A She went and talked to her dad. 16 Q And said what? 17 A I don’t know. 18 Q So you — you accustomed the bald actuality that they batten to anniversary added 19 afterwards any adeptness of what the agreeable was that they discussed? 20 A Well, later, later, subsequently. Bethink there was article that was 21 put out on a cheep or we had a — I anticipate it was a beheld put out, the actuality that she did. So 22 article happened. 23 Q So do you draw some inference — 24 Case 1:21-cv-03217-CJN Certificate 15-10 Filed 04/22/22 Folio 14 of 15 146 Q And do you apperceive whether Ivanka Trump fabricated a advocacy as to 1 what the abutting footfall would be? 2 A I don’t. I never talked to her about it. 3 Q But based on your description — 4 A I talked to her about it on the 7th but not on the 6th. 5 Mr. George. Go ahead. Do you appetite to say? 6 BY MR. WOOD: 7 Q Well, okay. What did she say to you on the 7th then? 8 A Yeah, I absolved up to her on the 7th. And I went into her arrangement on the third 9 A It’s an inference, yeah. 25

something was done afterwards on. There was a tweet, I acquire a tweet, put out later. And 10 there was a video taken afterwards that I anticipate he did — I anticipate he did in the Rose Garden, I 11 think. 12 Ms. Cheney. Accustomed Kellogg, you said aloof a few annual ago that the Admiral 13 was not resistant. But afresh you said that, aback you thanked Ivanka the abutting day, she 14 said to you: My father’s stubborn. 15 So could you explain to us what the aberration is? 16 The Witness. Well, I anticipate the big aberration is it takes assorted times to altercate 17 him to do something. And I anticipate that’s what I was accepting at is aback — that was a 18 animadversion I — it was — the animadversion was I anticipate aback she fabricated the animadversion bent is 19 to get him to do something. And that was my follow-on animadversion about the accomplished 20 family. 21 Ms. Cheney. So that’s why she had to go in assorted times to get him to do 22 something. 23 The Witness. I would accept so, but she went in. I — and I apperceive she went in a 24 Case 1:21-cv-03217-CJN Certificate 15-10 Filed 04/22/22 Folio 15 of 15 147 Q — that her babble with the Admiral may acquire contributed to the 1 Admiral arising a tweet? 2 A John, it is an inference. The acknowledgment is yes. 3 Q Okay. Did anybody to your adeptness ask the Admiral of the United 4 States to achieve any affectionate of statement, whether by cheep or otherwise, allurement the rioters 5 to leave the Capitol? 6 A I anticipate — I anticipate they did, John. I don’t know. I anticipate — I would acquire — that 7 would be article in Mark Meadows’s lane or Kayleigh’s lane and to them. It was not 8 in mine, and it was not fabricated to me. But I would accept they did that because 9 brace of times. I apperceive that. 25

MARK MEADOWS, ) ) Plaintiff, ) ) v. ) Case No. 1:21-cv-3271-CJN ) NANCY PELOSI, et al. ) ) ) Case 1:21-cv-03217-CJN Certificate 15-11 Filed 04/22/22 Folio 1 of 2 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA Display J

Case 1:21-cv-03217-CJN Certificate 15-11 Filed 04/22/22 Folio 2 of 2 BEGBATES ENDBATES All Custodians Master Date Babble Name Babble Bulletin Blazon Babble Administration From To Extracted Altercation We can’t lose the complete WH counsels office. I do NOT see January 6 accident the way he is actuality told. Afterwards the 6 th. He should advertise will beforehand the civic accomplishment to ameliorate voting integrity. Go to Fl and watch Joe blend up daily. Break engaged. Aback he speaks bodies will listen. MM014456 MMO14456 Mark Meadows 12/31/2020 8:27 ‘ 19292608777 Bulletin Incoming ‘ 19292608777 ‘ 18282002544

Case 1:21-cv-03217-CJN Certificate 15-12 Filed 04/22/22 Folio 1 of 2 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA MARK MEADOWS, Plaintiff, V. Case No. 1:21-cv-3271-CJN NANCY PELOSI, et al. Display K

Case 1:21-cv-03217-CJN Certificate 15-12 Filed 04/22/22 Folio 2 of 2 BEGBATES ENDBATES All Custodians MasterDate Babble Name Babble Bulletin Blazon Babble Administration From To Extracted Altercation MM014858 MMO14858 Mark Meadows ‘ 19292608777 ‘ 18282002544 1/5/2021 22:29 19292608777 1/5/2021 22:29 19292608777 Bulletin Bulletin Incoming Incoming Im complete afraid about the abutting 48 hours Pence pressure. WH admonition will leave. MMO14859 MM014859 Mark Meadows ‘ 19292608777 ‘ 18282002544

Case 1:21-cv-03217-CJN Certificate 15-13 Filed 04/22/22 Folio 1 of 2 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA MARK MEADOWS, Plaintiff, V. Case No. 1:21-cv-3271-CJN NANCY PELOSI, et al. Display L

Case 1:21-cv-03217-CJN Certificate 15-13 Filed 04/22/22 Folio 2 of 2 BEGBATES ENDBATES All Custodians MasterDate Babble Name Babble Bulletin Blazon Babble Administration From Το Extracted Altercation If POTUS allows this to occur… we’re active a pale in the affection of the federal republic… MM014503 MM014503 Mark Meadows 1/1/2021 16:17 ‘ 15127202661 Bulletin Incoming ‘ 15127202661 ‘ 18282002544

Case 1:21-cv-03217-CJN Certificate 15-14 Filed 04/22/22 Folio 1 of 2 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA MARK MEADOWS, Plaintiff, V. Case No. 1:21-cv-3271-CJN NANCY PELOSI, et al. Display M

Case 1:21-cv-03217-CJN Certificate 15-14 Filed 04/22/22 Folio 2 of 2 BEGBATES ENDBATES All Custodians Master Date Babble Name Babble Bulletin Blazon Babble Administration From Το Extracted Altercation On January 6, 2021, Carnality Admiral Mike Pence, as Admiral of the Senate, should alarm out all balloter votes that he believes are actionable as no balloter votes at all — in accordance with admonition from founding ancestor Alexander Hamilton and authoritative precedence. “No aldermanic act,” wrote Alexander Hamilton in Federalist No. 78, “contrary to the Constitution, can be valid.” The cloister in Hubbard v. Lowe able this truth: “That an actionable statute is not a law at all is a hypothesis no best accessible to discussion.” 226 F. 135, 137 (SDNY 1915), abode dismissed, 242 U.S. 654 (1916). Afterwards this rationale, an unconstitutionally appointed elector, like an unconstitutionally allowable statute, is no elector at all. I acquire pushed for this. Not abiding it is action to arise MM014864 MM014864 Mark Meadows 1/5/2021 23:27 19375097356 Bulletin Incoming ‘ 19375097356 ‘ 18282002544 MM014869 MM014869 Mark Meadows 1/6/2021 7:30’ 19375097356 Bulletin Outgoing [email protected] ‘ 19375097356

Case 1:21-cv-03217-CJN Certificate 15-15 Filed 04/22/22 Folio 1 of 2 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA MARK MEADOWS, Plaintiff, V. Case No. 1:21-cv-3271-CJN NANCY PELOSI, et al. Display N

Case 1:21-cv-03217-CJN Certificate 15-15 Filed 04/22/22 Folio 2 of 2 BEGBATES ENDBATES Babble Administration From To All Custodians Mark Meadows Master Date Babble Name 1/2/2021 15:44 14049008792 Babble Bulletin Blazon Bulletin MM014567 MM014567 Incoming ‘ 14049008792 ‘ 18282002544 MM014568 MM014568 Mark Meadows ‘ 18282002544 ‘ 14049008792 MM014569 MM014570 MM014569 MM014570 Extracted Altercation Accusation to end this alarm I don’t anticipate this will be advantageous abundant best Ok Let’s save the accord Acknowledge you. Wow. 1/2/2021 15:44 14049008792 1/2/2021 15:44 ” 14049008792 1/2/2021 15:44 14049008792 1/2/2021 15:50’ 14049008792 Mark Meadows Mark Meadows Bulletin Bulletin Bulletin Bulletin Incoming Outgoing Incoming Incoming ‘ 14049008792 [email protected] ‘ 14049008792 ‘ 14049008792 ‘ 18282002544 MM014571 MM014571 Mark Meadows ‘ 18282002544

Case 1:21-cv-03217-CJN Certificate 15-16 Filed 04/22/22 Folio 1 of 2 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA MARK MEADOWS, Plaintiff, V. Case No. 1:21-cv-3271-CJN NANCY PELOSI, et al. Display 0

Case 1:21-CV-03217-CJN Certificate 15-16 Filed 04/22/22 Folio 2 of 2 BEGBATES ENDBATES All Custodians MasterDate Babble Name Babble Bulletin Blazon Babble Administration From To Extracted Altercation Mark, aloof blockage in as time continues to calculation down. 11 canicule to 1/6 and 25 canicule to inauguration. We gotta get going! MMO14099 MMO14099 Mark Meadows 12/26/2020 19:24′ 17176485679 Bulletin Incoming ‘ 17176485679 ‘ 18282002544 MMO14100 MM014100 Mark Meadows 12/26/2020 19:55’ 17176485679 Bulletin Incoming ‘ 17176485679 ‘ 18282002544 Mark, you should alarm Jeff. I aloof got off the Iphone with him and he explained to me why the arch agent won’t assignment abnormally with the FBI. They will actualization it as as not accepting the ascendancy to accomplish what needs to be done. got it. I anticipate I understand. Let me assignment on the agent position Roger. Aloof beatific you article on Signal Aloof beatific you an adapted book Did you alarm Jeff Clark? MM014101 MM014102 ‘ 17176485679 ‘ 18282002544 MMO14101 MM014102 MMO14103 IMMO14178 Mark Meadows Mark Meadows Mark Meadows Mark Meadows 12/26/2020 20:04 17176485679 12/26/2020 20:05/’ 17176485679 12/26/2020 21:00 17176485679 12/28/2020 11:23′ 17176485679 Bulletin Bulletin Bulletin Bulletin Outgoing Incoming Incoming Incoming [email protected] ‘ 17176485679 ‘ 17176485679 ‘ 17176485679 MM014103 ‘ 18282002544 ‘ 18282002544 MM014178

Case 1:21-cv-03217-CJN Certificate 15-17 Filed 04/22/22 Folio 1 of 13 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA MARK MEADOWS, Plaintiff, V. Case No. 1:21-cv-3271-CJN NANCY PELOSI, et al. Display P

Case 1:21-cv-03217-CJN Certificate 15-17 Filed 04/22/22 Folio 2 of 13 1 1 2 3 4 SELECT COMMITTEE TO INVESTIGATE THE 5 JANUARY 6TH ATTACK ON THE U.S. CAPITOL, 6 U.S. HOUSE OF REPRESENTATIVES, 7 WASHINGTON, D.C. 8 9 10 11 INTERVIEW OF: CASSIDY HUTCHINSON 12 13 14 15 Wednesday, February 23, 2022 16 17 Washington, D.C. 18 19 20 The annual in the aloft bulk was captivated via Webex, basic at 10:10 a.m. 21 Present: Representatives Luria, Schiff, Murphy, and Cheney.

Case 1:21-cv-03217-CJN Certificate 15-17 Filed 04/22/22 Folio 3 of 13 37 1 a lot of the time because he would be in meetings. So he had, in accidental conversation, 2 said: Oh, we’re action to acquire this big rally. Bodies are talking about it on amusing media. 3 They’re action to go up to the Capitol. Are you seeing any of this on Twitter? 4 And, as I advanced stated, I don’t frequently use amusing media, abnormally in my 5 ablaze of my job there, in my role with Mr. Meadows. So I didn’t acquire any acumen or 6 annihilation to add to that conversation. But, you know, I apperceive that he had heard 7 beholder babble either through babble of aperture from bodies that would adeptness out 8 to him or admonition he had apparent online, but that’s the admeasurement of the beat that I had 9 with him about that matter. 10 BY MR. GEORGE: 11 Q Aback Mr. Meadows talked about some of the actuality that he had apparent online 12 or in talking to added people, did he anytime authentic any apropos about what adeptness arise 13 on January the 6th? 14 A Not to my recollection. Um, not to my bond adapted now, but I — in 15 acceding of boot to the Capitol, not to my recollection. 16 Q Or aloof abandon about on January the 6th, alike if altered to boot 17 to the Capitol? 18 A I apperceive that there were apropos brought avant-garde to Mr. Meadows. I don’t 19 apperceive — I don’t appetite to brainstorm whether or not he perceived them as 18-carat concerns, 20 but I apperceive that bodies had brought admonition avant-garde to him that had adumbrated that 21 there could be abandon on the 6th. But, again, I’m not abiding if he — what he did with that 22 admonition internally. 23 Q Who brought that admonition to him about the abeyant for abandon on the 24 6th? 25 A I bethink Mr. Ornato had talked to him about intelligence reports. I

it. 10 And I acquire they went to the arrangement for maybe 5 minutes. It was complete quick. 11 Mr. Ornato had chock-full him as he was walking out one night to allocution about this and — 12 BY MR. GEORGE: 13 Q Can I stop you there, Ms. Hutchinson? Aback was that, if you recall, 14 date-wise? 15 A Had to be aboriginal January because Mr. Ornato was not — I don’t acquire he 16 came aback until January 2nd or 3rd from Christmas. 17 Q Do you anticipate it was afore or afterwards the affair on January 2nd with Rudy 18 Giuliani? 19 A Acceptable afterwards because I acquire the 2nd was a Saturday. Again, I don’t acquire 20 the agenda in advanced of me. And I acquire that Mr. Ornato’s aboriginal day aback was that 21 Monday. 22 Mr. George. Complete helpful. 23 And I see, Ms. Cheney, you acquire affronted on your camera. 24 Case 1:21-cv-03217-CJN Certificate 15-17 Filed 04/22/22 Folio 4 of 13 38 mean, I’m aggravating to be a little acquainted of — like the bearings actuality because of, like, 1 intelligence belletrist that were accessible at the time. 2 Mr. Passantino. Yeah, I don’t anticipate he wants you to allocution about annihilation you 3 acquire to be classified. Aback you’re appliance intelligence, like, there’s two altered kinds. 4 Right. Could be array of arena chatter, and afresh there could be article you apperceive to 5 be classified. They do not appetite you to be — 6 Ms. Hutchinson. No, I don’t apperceive if this is classified or not. I aloof bethink 7 Mr. Ornato advancing in and adage that we had intel belletrist adage that there could 8 potentially be abandon on the 6th. And Mr. Meadows said: All right. Let’s allocution about 9 Ms. Cheney. Yes. Thanks, Dan. 25

were present on that alarm were added absorbed to go with White Abode admonition and shoot 10 about their own ideas. 11 I bethink Mr. Perry had said that he had been starting to put tweets that night, 12 Congressman Perry, that he was action to alpha putting out tweets that night, and he was a 13 primary amateur in the call. I bethink him speaking up a lot. 14 I wasn’t in the allowance for the complete continuance of the call, but aback I had ducked in, it 15 was either somebody on our end speaking or it was Mr. Perry. I apperceive added Assembly 16 had chimed in at points, but I wasn’t there aback they had alien themselves. 17 Q Did Mr. Perry abutment the abstraction of sending bodies to the Capitol on 18 January the 6th? 19 A He did. 20 Q Did anybody on the alarm that you bethink disagree with the abstraction of 21 auspicious bodies to beforehand to the Capitol on January 6th? 22 A Not that I recall. 23 Q Do you bethink anybody abroad on that alarm who accurately authentic the 24 Case 1:21-cv-03217-CJN Certificate 15-17 Filed 04/22/22 Folio 5 of 13 45 Senator Graham. I had gone in a brace of times, aloof like for abstracts that Mark had 1 asked me to book out, but I was not in there for any absolute babble about 2 annihilation pertaining to the Capitol. 3 Now, Mr. Graham was arrive to break for that buzz call, but he had aloof aureate in, 4 and he capital to go home. 5 Q Do you bethink what any of the added Assembly who were on that alarm 6 said aback this affair of whether to animate bodies to beforehand to the Capitol came up? 7 A That was, I think, accustomed banter, bodies alms their ideas. Annihilation that 8 was — would accession any flags or apropos to [inaudible]. I anticipate that the Assembly that 9 abstraction of auspicious bodies to beforehand to the Capitol on January 6th? 25

Was that adjournment or abstraction of preventing the Collective Affair from action avant-garde on 10 January 6th a affair that came up in this affair with Rudy Giuliani and Mr. Meadows? 11 A Not that I was present for. 12 Q Okay. Do you bethink it advancing up in the alarm with the Abode Freedom 13 Caucus members, to the admeasurement that that was any different? 14 A Not accurately on the call, no. Again, I was in and out of the room. No. 15 Mr. George. Okay. I’ll stop there and see if anybody abroad has any questions, 16 any members, including the room. 17 BY MS. APECECHEA: 18 Q Ms. Hutchinson, aloof a quick question. 19 I anticipate you mentioned article that it was your acumen that the Assembly 20 on the alarm with the Abode Freedom Caucus, they were absorbed to go alternating with the 21 White Abode guidance. And I was aloof wondering, what did you acquire the White 22 Abode admonition to be on this issue? 23 A You know, during the time of this call, the alarm was — we had — the alarm was 24 Case 1:21-cv-03217-CJN Certificate 15-17 Filed 04/22/22 Folio 6 of 13 46 A I don’t anticipate there’s a amateur on the alarm that had necessarily beat 1 the idea. I wasn’t present for the complete continuance of the call, so I’m not abiding if there was 2 anybody that had bidding any concern, but I additionally don’t apperceive if everybody was 3 necessarily auspicious it. 4 Q Fair enough. 5 Now, one of the things, aloof to — this is action to be affectionate of a affiliated question. But 6 one of the things that had been discussed about that time is accepting the Collective Affair of 7 Congress either delayed so that States could booty up the affair of the acclamation or aloof 8 anticipate it from accident on January the 6th at all. 9 underway because we were talking about claiming on the 6th. So I acquire it was added of 25

marching”? 10 A It was added — I accustomed it as added of him alms his abutment and 11 allowance in any way that he could. 12 Q But this was afterwards it had already been aloft about putting it out there about 13 auspicious bodies to beforehand to the Capitol? 14 A As a affair of babble on the call, yes. 15 Q Do you anamnesis anyone — any added Assembly adage that they wouldn’t 16 animate bodies to beforehand to the Capitol on the 6th? 17 A No. I mean, I don’t anamnesis every distinct amateur on the alarm that night, but 18 I do anamnesis it was a Freedom Caucus call. But, again, I was present primarily aback it was 19 Mr. Meadows speaking, Mr. Giuliani speaking, and I bethink action in aback Mr. Perry 20 had spoken. You know, Mr. Jordan had chimed in a few times I remember, but it wasn’t 21 annihilation absolute in acceding of putting tweets out. It was added of he was one of the 22 beforehand participants on the call. So he was affectionate of facilitating the alarm added from the aspect 23 of I acquire Mr. Babin in band to acquire — he has a animadversion to say next. But that was — I 24 Case 1:21-cv-03217-CJN Certificate 15-17 Filed 04/22/22 Folio 7 of 13 47 an alter alarm aloof about what we were anticipating. Any strategies that had been 1 discussed, I wasn’t circuitous for any, you know, cardinal discussions. You know, I had 2 overheard discussions about what he had advancing aloof by attributes of, like, the logistical 3 aspects of what I was accomplishing for them at the time. But there wasn’t annihilation that stood 4 out to me as annihilation that would be a specific acknowledgment to your catechism that had 5 happened on that alarm that night. 6 Q So you mentioned, like, Adumbrative Perry adage that he would put out 7 some tweets. Do you anamnesis if that was article he aloof offered on his own or 8 addition had said, “Hey, would anyone, you know, appetite to put out some tweets about 9 don’t anamnesis any added Assembly accurately agreeable in on that abstraction added than Mr. Perry. 25

meetings that Mr. Meadows had breadth affair participants had arise in able with 10 admonition about bureau that they anticipate the Carnality Admiral could admission certifying the 11 balloter academy votes. 12 But I don’t — the complete aboriginal time, I can’t — I don’t anamnesis the complete aboriginal time I heard 13 about it. But in the beforehand stages of it, there were — it was mostly aloof affair readout 14 information. 15 Q Okay. And you aloof mentioned a brace affairs Mr. Meadows had with 16 assorted people. Who were the assorted bodies who were adopting this abstraction of the Carnality 17 Admiral accomplishing annihilation added than aloof counting balloter votes on January the 6th? 18 A Beforehand admiral and a few Assembly of Congress. I say beforehand 19 officials. I don’t — I anticipate the beforehand had amorphous off-boarding bodies at that point, so I 20 don’t — I don’t apperceive if they were clandestine citizens at that point or — not that beforehand 21 admiral weren’t, but I don’t apperceive if they were off-boarded but still circuitous in the efforts. 22 Bodies that were already circuitous with the beforehand and a scattering of Assembly of 23 Congress. 24 Case 1:21-cv-03217-CJN Certificate 15-17 Filed 04/22/22 Folio 8 of 13 72 cardinal action that the Carnality Admiral could take. 1 Q Okay. And so aback afresh — aloof to clarify, aback was the aboriginal time you 2 remember, to use your phrase, the affair of cardinal action the Carnality Admiral could booty 3 on January 6th advancing up? 4 A Again, potentially the end of November-early December. 5 Q Do you bethink the ambience in which it aboriginal came up that you recall? 6 Was it a meeting, a buzz call, babble during aloof arrangement drop-ins? 7 A I don’t anamnesis accurately the complete aboriginal time that I had heard about it. I 8 bethink accustomed timeframe that I had — I anamnesis this accident was there were a brace 9 Q Who were those beforehand admiral or bodies who had been circuitous in the 25

Mr. Passantino. And he’ll acknowledge like if you acquire a specific bond of 10 timeline or you don’t. He wants to apperceive what your — 11 Ms. Hutchinson. Yeah. I anamnesis those individuals actuality circuitous in the beforehand 12 stages at this time. I’m abiding there were added individuals involved, but those are ones 13 that I bethink accurately actuality circuitous that Mr. Meadows had beat to. 14 BY MR. GEORGE: 15 Q Okay. And this is in the backward November, maybe aboriginal December timeframe. 16 Is that right? 17 A Ancient afterwards Thanksgiving. Absolutely afore Christmas. Apparently the 18 aboriginal anniversary of December if not the aftermost anniversary of November. 19 Q And do you bethink what their annual were with annual to the Carnality 20 President’s ascendancy on January 6th? 21 A I don’t. I don’t acquire admission to any of my official accessories or correspondence. 22 I’m abiding I had things in my assignment email. But specific actions, no. I aloof bethink 23 accustomed — accustomed accordance of Carnality Admiral may be able to do this. We should 24 Case 1:21-cv-03217-CJN Certificate 15-17 Filed 04/22/22 Folio 9 of 13 73 campaign? 1 A Mr. Giuliani, Ms. Powell, Ms. Ellis. I’m aggravating to anticipate accurately about the 2 aboriginal stages of this — stages of this. Those are the ones that I can anon recall. 3 Assembly of Congress: Mr. Perry, Mr. Jordan. Mr. Scott Perry, Mr. Jim Jordan. 4 Those are the two that jump to my apperception adapted now about actuality — oh, Ms. Marjorie Taylor 5 Greene and Lauren Boebert are the four Assembly that anon jump out to me. 6 Again, I’m aggravating to hone in accurately on the alpha stages of this, these 7 conversations. 8 Q Perfect. 9 attending into this. We should analyze these ideas. But annihilation added specific than that 25

car, which is a — it’s technically a SCIF. You can achieve dedicated calls from there. But 10 sometimes the arch would aloof go into the ascendancy car to achieve claimed buzz calls. 11 And that’s breadth he spent the majority of the rally. 12 I apperceive that he was on several calls during the rally. And I went over to accommodated 13 with him at one point, and he had aloof coiled me away, which is out of the ordinary. 14 And afresh he popped out and had mentioned a few things to me. 15 Q What did he acknowledgment to you? 16 A But I don’t apperceive what he accurately was fatigued about. He capital to 17 allege with Mr. Giuliani. He couldn’t get a ascendancy of Mr. Jordan. Little authoritative 18 things that he bare admonition with to accumulate the aboriginal afternoon so he could abide 19 accomplishing his job with the President. 20 Q Do you apperceive what he capital to allege with Adumbrative Jordan about? 21 A I don’t know. I apperceive that he had arise with Mr. Jordan about the 22 accommodation of what Mr. Jordan’s attic accent were action to be and — was action to be and 23 the timing of Mr. Jordan’s attic speech, but I don’t apperceive any added specifics than that. I 24 Case 1:21-cv-03217-CJN Certificate 15-17 Filed 04/22/22 Folio 10 of 13 77 little bit quicker. 1 Q And afresh the abutting bulletin is: “Mark is cool fatigued and Rudy is 2 abnormality about with added evidence.” 3 What was Mr. Meadows fatigued about, if you know? 4 A I don’t apperceive specifically. I don’t anamnesis accurately what he was fatigued 5 about at that time that I beatific that message. Sorry. 6 Mr. Meadows had spent apparently the aboriginal brace annual of the assemblage in the tent, 7 and afresh he — if you’re attractive at the build-out of the Presidential motorcade, the arch of 8 agents and about one added civic aegis adumbrative go in a car declared the ascendancy 9 don’t apperceive if that’s what he was aggravating to get a ascendancy of — get a ascendancy of him for in that 25

were so aback we accustomed aback at the White House, that agents and the Admiral could 10 watch Mr. Jordan’s attic accent live. 11 Q You additionally say in that message, “Rudy is abnormality about with added 12 evidence.” What does that mean? 13 A Mr. Giuliani had admonition that he believed was aboveboard abundant to abeyance 14 the balloter calculation that morning — or that afternoon. 15 Q Do you apperceive what happened with that evidence? 16 A I don’t. 17 Q Do you apperceive what Mr. Meadows’ actualization on that was, whether there was 18 aboveboard affirmation to abeyance the balloter calculation during the collective affair on January 6th? 19 A Mr. Meadows was consistently accommodating to apprehend ideas, as he never capital 20 admonition to go exceptional and for it not to be perceived as accustomed admonition in case 21 it was. But I don’t apperceive his specific — I don’t apperceive his specific mindset or opinions on 22 which affirmation was apparent as added aboveboard to him, if any at all. That’s article that 23 you’d acquire to ask Mr. Meadows. 24 Case 1:21-cv-03217-CJN Certificate 15-17 Filed 04/22/22 Folio 11 of 13 78 moment. 1 Q Do you apperceive what the acceptation — I’m sorry, go ahead. 2 A You’re fine. 3 I was not about — I was not about Mr. Meadows. I apparently was about him 4 for maybe 40 to 50 percent of the assemblage but not the absoluteness of it. 5 Q Do you bethink what the acceptation of this timing of Adumbrative 6 Jordan’s attic accent was to Mr. Meadows? 7 A I anticipate that — I don’t think. He capital Mr. Jordan to accordance the attic accent 8 afterwards the assemblage had ended. And I’m beneath the consequence that the intentions abaft that 9 Q Okay. But he never aggregate his bend on whether there was acceptable 25

Q Okay. And is that a Abstruse Annual admission on the radio that you heard 10 this? 11 A Yes. 12 Q Did you anytime see the Admiral in the dining allowance that afternoon? 13 A I wasn’t present with the Admiral in the dining allowance that afternoon. It’s 14 complete accessible aloof by adjacency of the blueprint of the West Addition that I physically saw him, 15 but I saw him in the dining allowance a lot. I apperceive that adeptness complete like a affectionate of ample 16 annual to say to you all. I aloof can’t anamnesis if I had eyes on him in the dining allowance that 17 specific day. 18 Mr. Meadows was in there with him in and out throughout the day, and there was 19 a point breadth I had absolved maybe 25 anxiety from the capital arch of agents office. I had 20 absolved bottomward there at one point to broadcast a bulletin to Mr. Meadows from a Associate that 21 had accomplished out to me on my assignment phone, and I had asked the President’s aide to get 22 Mr. Meadows’ absorption for me, and he opened the door. So maybe I saw Mr. Trump at 23 that point. But added than that, I wasn’t in there with him at any point. 24 Case 1:21-cv-03217-CJN Certificate 15-17 Filed 04/22/22 Folio 12 of 13 134 acquire been the time about that I would acquire accustomed aback in. 1 Q Do you apperceive — do you apperceive breadth the Admiral went aback he returned? 2 A I was a brace cars abaft him, so I’m not abiding if he fabricated any added 3 movements, if he chock-full anywhere amid walking from West Controlling Avenue up to 4 the Oval Arrangement or the Oval dining room. So aback I had got into the West Wing, he was 5 in the Oval dining room. 6 Q How do you apperceive that? 7 A Because I heard it arise on my radio which announces the President’s 8 logistical movements. 9 Q And added than that, were you — did you break in your arrangement that afternoon 25

just capital to achieve abiding we got who the Associate was and what the bulletin was. 10 But do you anamnesis about either what time that would acquire been or, in 11 acceding of what was accident at the Capitol, aloof a faculty of aback Mr. Jordan declared you? 12 Ms. Hutchinson. I don’t. I’m sorry. I’m aggravating my best to remember. I don’t 13 bethink adapted now. 14 Ms. Cheney. Okay. That’s — 15 Ms. Hutchinson. It was afterwards I had the babble with Mr. Meadows aback I 16 had apparent the aegis ambit actuality breached at the Capitol. You know, I wouldn’t — I 17 would say maybe an hour afterwards that. 18 Ms. Cheney. Okay. And so aback you went in and you told him that the 19 aegis ambit was breached and, you know, he said acknowledge you, and he said he was 20 action to array of see what he could see about it, what do you anamnesis him accomplishing afterwards that? 21 Ms. Hutchinson. I aloof larboard his arrangement and shut the aperture abaft me. 22 Ms. Cheney. Okay. And do you anamnesis how abundant best he backward in his arrangement 23 afterwards that? 24 Case 1:21-cv-03217-CJN Certificate 15-17 Filed 04/22/22 Folio 13 of 13 142 butler’s pantry, and that’s breadth the President’s advancing aide would be, and afresh the 1 Oval dining room. 2 And so I asked the aide to get the arch of agents for me. The aide opened the 3 door. Arch of agents stepped out. And I had relayed the bulletin from Mr. Jor- — Jim 4 Jordan, Congressman Jim Jordan at the time. He had declared my assignment corpuscle phone, and 5 abrupt conversation, Hey, where’s Mark? I told him he’s bottomward with the President. He 6 said, Can you amuse acquire him alarm me? And I went and asked Mr. Meadows to accordance Mr. 7 Jordan a call. And he said, All right, I’ll do it. And afresh I went aback to my desk. 8 Ms. Cheney. Okay. And we’ll airing through absolutely the timeframe on that. I 9 Ms. Hutchinson. Not specifically, no. A little while later, there was some 25

MARK MEADOWS, ) ) Plaintiff, ) ) v. ) Case No. 1:21-cv-3271-CJN ) NANCY PELOSI, et al. ) ) ) Case 1:21-cv-03217-CJN Certificate 15-18 Filed 04/22/22 Folio 1 of 19 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA Display Q

10 11 INTERVIEW OF: RICHARD PETER DONOGHUE 12 13 14 Friday, October 1, 2021 15 16 Washington, D.C. 17 18 19 The annual in the aloft bulk was captivated via Webex, basic at 10:02 a.m. 20 Case 1:21-cv-03217-CJN Certificate 15-18 Filed 04/22/22 Folio 2 of 19 1 2 3 SELECT COMMITTEE TO INVESTIGATE THE 4 JANUARY 6TH ATTACK ON THE U.S. CAPITOL, 5 U.S. HOUSE OF REPRESENTATIVES, 6 WASHINGTON, D.C. 7 8 9 Present: Representatives Schiff, Lofgren, Murphy, Raskin, and Cheney. 21 1

A Right. So DAG Rosen and I spoke, I think, apparently several times on the 10 27th and absolutely the 28th because that was a Monday. DAG Rosen and Jeff Clark had 11 a affiliated claimed and able relationship. They had accustomed anniversary added for decades. 12 They had formed at the aforementioned law close together. He knew Jeff Clark abundant bigger than I 13 did. And, you know, we discussed why Jeff Clark’s name was advancing up, why it was 14 advancing from the President, why it was advancing from this Congressman. And Jeff Rosen 15 said: Well, look, I am action to allocution to Jeff Clark to accretion out what’s action on here. We 16 got to get to the basal of this. 17 So I anticipate he had conversations with Jeff Clark beforehand on the 28th. They 18 preceded this email, which came adequately backward in the day. I did not allocution to Jeff Clark afore 19 this. 20 So, at 4:40, I accustomed this email from Jeff Clark. I apprehend it. I apprehend the 21 attachment. I had to apprehend it added than already to achieve abiding I absolutely accustomed what he 22 was proposing. And afresh I drafted a response. I don’t apperceive breadth Jeff Rosen was at 23 this point, but I went to his office, and he wasn’t there. So I didn’t get to altercate my 24 Case 1:21-cv-03217-CJN Certificate 15-18 Filed 04/22/22 Folio 3 of 19 77 But we weren’t advertisement aback to the White Abode artlessly because the Admiral 1 mentioned some allegations. 2 Q I see. It wouldn’t be constant with agreement for you to go aback to the 3 Admiral every time article that comes up in a altercation is brash or resolved? 4 A He didn’t acquaint us to do that, and we weren’t action to do it. So. 5 Q Yeah. All right. I appetite to about-face your attention, if you can now to 6 display 10, which we get aback into Mr. Clark. The abutting day, December 28th, you and Mr. 7 Rosen get an email from Mr. Clark, and he is allurement for two burning action items. Acquaint us 8 about this email, the two accomplishments that he requested, and what your acknowledgment was. 9 acknowledgment with him afore I beatific it. But I beatific it out. And afresh I saw him anon 25

election arrest issues. And he mentions activating the IEEPA and 2018 EO admiral 10 about the Dominion apparatus admission to the internet through a acute thermostat with a 11 net affiliation aisle arch aback to China. He is about allurement if you can get a 12 arrangement about this accusation of Chinese ascendancy of Dominion machines through a 13 thermostat. Did that bang you as odd, and what was your acknowledgment to that specific 14 request? 15 A Yes, it addled me as odd. I won’t go into details, but we accustomed arrangement 16 about what the IC, the intelligence community, knew about the acclamation in advance. 17 This was inconsistent with what we had been told. And I had not heard annihilation about 18 acute thermostats and internet admission arch aback to China and things like that. 19 So the accomplished affair addled me as complete odd. 20 Q Yeah, and that Mr. Clark, the arch — acting arch of the Civilian Assay is allurement 21 for a classified arrangement with the Director of Civic Intelligence about this allegation. 22 That additionally procedurally was odd? 23 A Yes. 24 Case 1:21-cv-03217-CJN Certificate 15-18 Filed 04/22/22 Folio 4 of 19 78 afterward, and he was complete agitated by Jeff Clark’s request. And he said that he had 1 instructed one of his authoritative abutment cadre to get Jeff Clark in his arrangement 2 room. He was — he was a little angry. And he said: I appetite him bottomward here. We 3 accusation to allocution to this guy and accretion out what’s action on. 4 So I anticipate there’s some emails that actualization up. 5 Q Yeah. And I don’t appetite to jump advanced too much, Mr. Donoghue, because I 6 appetite to get to that conversation. But let’s go aback to Mr. Clark’s email. The aboriginal affair 7 he asks of you is: I would like to acquire your allotment — “you” acceptation you and Mr. 8 Rosen — to get a classified arrangement tomorrow from ODNI led by DNI Ratcliffe on adopted 9 Q Okay. He additionally afresh — the added ask is this abstruse letter, which I acquire is 25

my bend accustomed in the email acknowledgment I beatific to him. 10 Q Yeah, which we’ll get to. To be clear, he asks that — a adaptation of this letter 11 be beatific to anniversary accordant State. So was his abode to accelerate this letter, drafted for 12 Georgia, not aloof to Georgia admiral but to admiral in added States breadth there had been 13 allegations of acclamation fraud? 14 A Yes. That was my compassionate of his proposal. 15 Q All right. He writes that he put it calm apprenticed — “it” actuality the 16 letter — but added belletrist beforehand that it may acquire been drafted by Ken Klukowski. 17 Do you apperceive Ken Klukowski and what his role may acquire been aural the Department’s 18 Civilian Assay at that time? 19 A No. I don’t. 20 Q Okay. Did you apperceive whether or not Mr. Clark was talking to anyone abroad in 21 the Administering about this letter or added acclamation issues? 22 A No. I had no acumen to anticipate that. 23 Q All right. So you respond, Mr. Donoghue. We get to your response, which 24 Case 1:21-cv-03217-CJN Certificate 15-18 Filed 04/22/22 Folio 5 of 19 79 absorbed to the email that he sends you and Mr. Rosen. And that letter is a abstruse letter 1 that you and Mr. Rosen and he, Mr. Clark, would affirmation to the Governor, the Speaker of the 2 House, and the admiral pro tempore of the Georgia legislature, about allurement them 3 to bend bottomward and not accredit the after-effects of their election. How did that abode bang 4 you, and what did you do about it? 5 A It addled me as complete aberrant and somewhat alarming. And, as I said, I had 6 to apprehend it added than already to achieve abiding I accustomed what he was proposing here. It 7 was absolutely inconsistent with the Department’s role, generally. And it was 8 inconsistent with what our investigations, to date, had revealed. And so I anticipate I fabricated 9 is tab 11. You drafted a appealing comprehensive, specific acknowledgment absorption your 25

on this point, beneath than a anniversary prior, or, I guess, absolutely a anniversary above-mentioned was the aftermost time he 10 had fabricated some accessible statements, and that this was aloof absolutely unacceptable and 11 not annihilation that I would anytime sign. And I apperceive Jeff Clark — or Jeff Rosen, rather, had 12 the aforementioned response. 13 Q You say in the aboriginal paragraph: There’s no adventitious that I would affirmation this 14 letter or annihilation accidentally like this. You array of beforehand with the conclusion. You then, in 15 the aboriginal paragraph, claiming his complete assumptions. You said: The investigations 16 that I am acquainted of chronicle to suspicions of delinquency that are of such a baby calibration that it 17 would artlessly not appulse the aftereffect of the election. AG Barr fabricated that bright to the 18 accessible abandoned aftermost week, and I am not acquainted of amid developments that would change 19 that conclusion. 20 So, ambience abreast whether it would be adapted for the Administering to acquaint a 21 Accompaniment what to do, you’re arduous — is it fair to say you’re arduous the complete base 22 included in his letter to the Accompaniment official? 23 A That’s right. And he himself, Jeff Clark, would acquire no way of animate 24 Case 1:21-cv-03217-CJN Certificate 15-18 Filed 04/22/22 Folio 6 of 19 80 annoyance on the 28th, aloof about a little over an hour later, at 5:50. I won’t ask you to 1 apprehend it to us, but aloof abridge for us your all-embracing acknowledgment and what’s reflected in the 2 email. 3 A I accustomed to achieve it bright to him that this is not the Department’s role. Again, 4 we don’t do affection ascendancy for Accompaniment elections. The States run the elections. We 5 investigate crimes, and we attending at civilian rights matters. So I accustomed to achieve it bright to him 6 that this is artlessly not our role, to acclaim to the States what they do and, secondly, 7 that we acquire conducted investigations and that the complete affirmation he was authoritative actuality was 8 artlessly not accurate. And so I reminded him that AG Barr had fabricated accessible statements 9 what investigations we had conducted or not because he was not circuitous in acclamation 25

A Yes. That’s the point I was making. Yes. 10 Q All right. So, aback you and Mr. Rosen get this letter, you compose the 11 response. You adumbrated advanced that Mr. Rosen about amendment Mr. Clark up to 12 the 5th attic for a contiguous meeting. Does that affair afresh occur? 13 A Yes. He is on the 4th floor. But, yes, in the DAG arrangement on the 4th 14 floor. 15 Q Okay. So you are abandoned present, Mr. Donoghue, for that affair 16 amid Clark and Rosen? 17 A Yes. It was the three of us. 18 Q Acquaint us about the babble there with Mr. Clark. 19 A Mr. Clark explained that he had been attractive at some of these allegations on 20 his own, that he had information, that he had apropos about the believability of the 21 aftereffect of the election. He mentioned this acute thermostat thing. It was bright that 22 he had been annual some affidavits that were absorbed to some of the civilian filings in 23 some of the cases that were awaiting or already absolved about the country. He had 24 Case 1:21-cv-03217-CJN Certificate 15-18 Filed 04/22/22 Folio 7 of 19 81 matters. 1 Q Right. You then, in the added paragraph, Mr. Donoghue, you say: I 2 cannot brainstorm a book in which the Administering would acclaim that a Accompaniment 3 would accumulate its assembly to actuate whether already certified acclamation after-effects 4 should somehow be overridden by aldermanic action. This would be a grave footfall for the 5 Administering to booty and could acquire amazing constitutional, political, and amusing 6 ramifications for the country. 7 Is that your array of procedural acknowledgment actuality that this is aloof not the Department’s 8 role to be affection ascendancy for Accompaniment elections and acquaint a Accompaniment assembly what to do? 9 assorted theories that seemed to be acquired from the internet about why the aftereffect of 25

me that wasn’t the case. I don’t remember. His role was never bright to me. I apperceive 10 he was a apostle from New York. I apperceive he had been a prosecutor at some point. But I 11 don’t apperceive what his appellation absolutely was. I’d apparent him in some affairs previously, but I 12 didn’t apperceive absolutely what his role was. 13 Q Okay. 14 All right. And, again, no addendum of this meeting. Is that right? You don’t booty 15 addendum — you were central the Oval Arrangement and, you adumbrated before, didn’t booty addendum aback 16 you were in discussions central that office. 17 A No. 18 Q All right. Well, acquaint us what you remember, then, about the conversation. 19 What was the affair aback you arrived, and how did it beforehand from there? 20 A The affair took about accession 2-1/2 hours from the time I entered. It 21 was absolutely focused on whether there should be a DOJ administering change. So the 22 acclamation allegations played into this, but they were added accomplishments than annihilation else. 23 And the Admiral was basically aggravating to achieve a adaptation and absolution anybody 24 Case 1:21-cv-03217-CJN Certificate 15-18 Filed 04/22/22 Folio 8 of 19 123 so aback you abutting at the President’s invitation? 1 A That’s right. 2 Q All right. And who was central the affair aback you got there? 3 A Aback I entered the Oval Office, the Admiral was abaft the desk, and it 4 was Pat Cipollone, Pat Philbin, a White Abode apostle declared Eric Herschmann, Jeff Clark, 5 Jeff Rosen, Steve Engel, and afresh me. 6 Q Are you abiding Mr. Herschmann was a White Abode lawyer? 7 A He was a apostle who formed at the White House. I’m not — initially I 8 anticipation he formed in the White Abode Counsel’s Office, but I anticipate afterwards addition told 9 allege their minds. And it was a complete blunt, acute babble that took several 25

things beeline with this abnormal election, and that he could do it, and he had the 10 intelligence and the will and the admiration to accompany these affairs in the way that the 11 Admiral anticipation best appropriate. 12 Q You said anybody abroad in the allowance was adjoin this. That’s Mr. Cipollone, 13 Mr. Philbin, Mr. Herschmann, you, and Mr. Rosen. What were the arguments that you 14 put alternating as to why it would be a bad abstraction for him to adapt Rosen with Clark? 15 A So, at one point aboriginal on, the Admiral said article to the aftereffect of, 16 “What do I acquire to lose? If I do this, what do I acquire to lose?” And I said, 17 “Mr. President, you acquire a abundant accord to lose. Is this absolutely how you appetite your 18 administering to end? You’re action aching the country, you’re action to aching the 19 Department, you’re action to aching yourself, with bodies acquisitive at straws on these 20 atrocious theories about acclamation fraud, and is this absolutely in anyone’s best interest?” 21 And afresh added bodies began agreeable in, and that’s affectionate of the way the 22 babble went. Bodies would allocution about the downsides of accomplishing this. 23 And afresh — and I said article to the aftereffect of, “You’re action to acquire a huge 24 Case 1:21-cv-03217-CJN Certificate 15-18 Filed 04/22/22 Folio 9 of 19 124 hours. And Jeff Clark absolutely was advocating for change in administering that would put 1 him at the top of the Department, and anybody abroad in the allowance was advocating adjoin 2 that and talking about what a adversity this would be. 3 Q What were Clark’s declared bases for why it was in the President’s absorption 4 for him to footfall in? What would he do, how would things change, according to Mr. Clark 5 in the meeting? 6 A He afresh said to the Admiral that, if he was put in the seat, he would 7 conduct absolute investigations that would, in his view, bare boundless fraud; he would 8 accelerate out the letter that he had drafted; and that this was a aftermost befalling to array of set 9 cadre blast aural hours, because you’re action to acquire all kinds of problems with 25

And I said, “And we’re not the abandoned ones. You should acquire that your 10 complete Administering administering will resign. Every AAG will resign.” I didn’t acquaint him 11 about the alarm or anything, but I fabricated it bright that I knew what they were action to do. 12 And I said, “Mr. President, these aren’t authoritative assortment from accession 13 administration. You best them. This is your administering team. You beatific every one 14 of them to the Senate; you got them confirmed. What is that action to say about you, 15 aback we all airing out at the aforementioned time? And I don’t alike apperceive what that’s action to do 16 to the U.S. apostle community. You could acquire accumulation resignations amidst your 17 U.S. attorneys. And afresh it will crawl bottomward from there; you could acquire resignations 18 aloft the Department. And what happens if, aural 48 hours, we acquire hundreds of 19 resignations from your Amends Administering because of your actions? What does that say 20 about your leadership?” 21 So we had that allotment of the conversation. Steve Engel, I remember, fabricated the 22 point that Jeff Clark would be arch what he declared a graveyard; there would be no one 23 left. How is he action to do annihilation if there’s no administering absolutely larboard to backpack out any of 24 Case 1:21-cv-03217-CJN Certificate 15-18 Filed 04/22/22 Folio 10 of 19 125 resignations and added issues, and that’s not action to be in anyone’s interest.” 1 And so the Admiral said, “Well, accept I do this” — I was sitting anon in advanced 2 of the President. Jeff Rosen was to my right; Jeff Clark was to my left. The Admiral 3 said, “Suppose I do this, accept I adapt him,” Jeff Rosen, “with him,” Jeff Clark, “what 4 do you do?” And I said, “Sir, I would abandon immediately. There is no way I’m bedfast 5 1 minute beneath this guy,” Jeff Clark. 6 And afresh the Admiral affronted to Steve Engel, and he said, “Steve, you wouldn’t 7 resign, would you?” And Steve said, “Absolutely I would, Mr. President. You’d leave 8 me no choice.” 9 these ideas? 25

letter that this guy wants to send, that letter is a murder-suicide pact. It’s action to 10 accident anybody who touches it. And we should acquire annihilation to do with that letter. 11 I don’t anytime appetite to see that letter again.” And so we went alternating those lines. 12 I bethink Eric Herschmann chimed in several times, adage that, whatever Jeff 13 Clark capital to do or anticipation he could do, there was no acumen to anticipate he could absolutely 14 do it. 15 I bethink adage at some point that, you know, Jeff wouldn’t alike apperceive how to 16 accretion his way to Chris Wray’s office, abundant beneath beforehand in there and complete the FBI what to 17 do, and that, if you absolved into Chris Wray’s office, he wouldn’t alike apperceive who you are. 18 So we had these conversations that went about and about and were complete edgeless 19 and direct. And that went on for 2-1/2 hours. 20 Q At one point, did the Admiral corruption Mr. Rosen or allocution about 21 Mr. Rosen’s cessation or abhorrence to do annihilation about the election? 22 A He did say several times, “You two,” pointing at Mr. Rosen and me, “You two 23 haven’t done anything. You two don’t care. You haven’t taken adapted actions. 24 Case 1:21-cv-03217-CJN Certificate 15-18 Filed 04/22/22 Folio 11 of 19 126 I fabricated the point that Jeff Clark is not alike competent to serve as the Apostle 1 General. He’s never been a bent attorney. He’s never conducted a bent 2 assay in his life. He’s never been in advanced of a admirable jury, abundant beneath a balloon jury. 3 And he affectionate of retorted by saying, “Well, I’ve done a lot of complete complicated 4 appeals and civilian litigation, ecology litigation, and things like that.” And I said, 5 “That’s right. You’re an ecology lawyer. How about you go aback to your office, 6 and we’ll alarm you aback there’s an oil spill.” 7 And so it got complete confrontational at points. 8 And Pat Cipollone brash in at one point, I remember, saying, you know, “That 9 Anybody tells me I should blaze you,” and things of that nature. 25

Q So he said he would abandon or not bend for it, would not be here, if the 10 Admiral fabricated this change. 11 A Right. 12 Q Who, Mr. Donoghue, was, array of, the primary apostle or articulation adjoin the 13 administering change? Was it you personally, or was it array of a accord and anybody 14 was array of appropriately agreeable in? Or aloof accordance me a bigger faculty as to, array of, who was 15 accomplishing best of the talking and was the best arduous advocate. 16 A It was absolutely a consensus. We were all on the aforementioned folio except for Jeff 17 Clark. But we played altered roles. 18 For one thing, Jeff Rosen was in a bad position because he was arresting his own 19 job. So annihilation he said, obviously, was complete self-interested. And so he wasn’t in the 20 best position to achieve some of these arguments. And by demeanor, he aloof has a 21 altered demeanor, as does Pat Cipollone, as does Steve Engel. So anybody played 22 their own role. My abode is added advancing and added blunt, and so I played that 23 role. 24 Case 1:21-cv-03217-CJN Certificate 15-18 Filed 04/22/22 Folio 12 of 19 127 He came aback to that at the complete end aback he absitively adjoin a administering 1 change. And he arise that, and afresh he came aback to that point and he said, “And 2 I apperceive that these two here, they’re not action to do anything. They’re not action to fix 3 this. But that’s the way it is, and I’m action to let it go anyway.” 4 Q Did Mr. Cipollone say annihilation about what he would do with annual to a 5 abeyant abandonment if the Admiral fabricated this change? 6 A He did at some point. I assumption that was on the heels of us talking about how 7 there would be resignations in the Department. And I anticipate Pat Cipollone said, “Well, 8 I’m not action to bend for this, I’m not action to be actuality if this happens either.” 9 And so anybody was on the aforementioned page, advocating for the aforementioned affair in complete 25

who was present? Mr. Meadows? 10 A Meadows was not there. 11 Q I’m sorry, Mr. Meadows wasn’t there. Alibi me. My mistake. 12 A Right. I don’t bethink if anyone abroad said annihilation specifically. I anticipate 13 Pat Philbin and Pat Cipollone were consistently array of beheld as a amalgamation deal, so — 14 Q Yeah. 15 A — if I anticipation about it for a moment, I would’ve thought, if Cipollone is 16 leaving, Philbin’s abrogation too. 17 But it was added a bulk of me saying, “You’re action to lose your Administering 18 leadership,” and afresh Pat Cipollone dispatch in and saying, “And, basically, you’re action 19 to lose your White Abode admonition as well.” 20 Q Yeah. Okay. 21 After, I believe, he makes the adaptation to break the beforehand and leave Mr. Rosen in, 22 does he afresh alpha talking about the U.S. apostle in Atlanta, Mr. Pak? 23 A I anticipate that was absolutely afore that. 24 Case 1:21-cv-03217-CJN Certificate 15-18 Filed 04/22/22 Folio 13 of 19 128 altered ways, and I anticipate that had an appulse on the President. I anticipate he brand to see 1 that aberration of actualization and altered approach, and I anticipate he lets bodies allege their 2 apperception and action it out in advanced of him afore he makes a decision. 3 Q I mean, I’ve heard this affair declared array of like an “Apprentice”-like 4 meeting, breadth there’s a battlefront adaptation at the end. Is that a fair characterization? 5 A I can candidly say I’ve never apparent 1 minute of “The Apprentice” in my life, so 6 I can’t admonish about that. 7 Q Fair enough. 8 Anyone abroad corruption to resign? Mr. Philbin or Mr. Herschmann or anyone abroad 9 Q Okay. 25

from it that was purportedly from B.J. Pak, who was the U.S. apostle in Atlanta. It was 10 analytical of the President. 11 And I didn’t apperceive breadth this adduce came from. I had no abstraction what he was 12 talking about. But I aloof said, look, Mr. President, I don’t alike apperceive what a Never 13 Trumper is, but I’ll acquaint you, all your U.S. attorneys were vetted, and I agnosticism B.J. said 14 annihilation like that. But whatever it was, B.J. has been accomplishing his job. 15 And he said, “No, no, no. He’s a Never Trumper.” He was complete bent about 16 that at that point. “This guy is a Never Trumper. He should never acquire been in my 17 administering to activate with. How did this guy end up in my administration?” 18 And afresh he said, “I appetite you to blaze him,” to me. I responded, “Mr. President, 19 I’m not action to blaze him. There’s no acumen to blaze him.” And he said, “Well, afresh I’m 20 action to blaze him.” I said, “Well, you should aloof know, afore you achieve that decision, 21 that he told me a brace canicule ago he was arrangement his abandonment on Monday,” which 22 was the abutting day. 23 So, if you appetite to blaze addition who’s resigning — and afresh Pat Cipollone stepped 24 Case 1:21-cv-03217-CJN Certificate 15-18 Filed 04/22/22 Folio 14 of 19 129 A I anticipate the Admiral absolutely didn’t advertise his final adaptation until apparently 1 about the aftermost 15 annual of the meeting. 2 Q Uh-huh. 3 A But about in the average of the affair addition mentioned Atlanta, 4 and the Admiral said, “Oh, yeah, Atlanta, Atlanta.” And afresh he best up a allotment of 5 cardboard that was on his desk, and he started bouncing it. And he said, “No admiration nothing’s 6 been activate in Atlanta, because the U.S. apostle there is a Never Trumper.” 7 And I had no abstraction what he was talking about. I said, you know, “Mr. President, I 8 don’t apperceive what you mean.” And afresh he had this allotment of paper, and he apprehend a adduce 9 in and said, “Well, that’s ridiculous. The guy’s resigning. We’re not action to blaze him.” 25

Christine to run the Northern Commune of Georgia.” 10 I said, “Mr. President, Bobby Christine is already active the Southern Commune of 11 Georgia. B.J. will acquire a aboriginal assistant. Aback he leaves, the aboriginal abettor will footfall up 12 and be the U.S. attorney.” He said, “No. I appetite Bobby Christine to do it, because if he 13 is absolutely acceptable the way bodies say, maybe he’ll do the job.” 14 And afresh he yelled for one of the authoritative administering to get Bobby Christine 15 on the phone. They did in complete abbreviate order. Bobby concluded up on the phone. He was 16 acutely abashed as to what was action on. 17 The Admiral said, “Bobby, this is Admiral Trump. I’m sitting actuality with Rich, 18 Jeff, and some added people. I appetite to know, are you able to run the Northern Commune 19 of Georgia? Because B.J. Pak’s action to be leaving.” 20 And Bobby was acutely abashed and said, “Mr. President, I can do whatever is 21 asked in that regard.” He said, “Great, Rich will alarm you afterwards and explain everything” 22 and afraid up. And that was that. 23 So that was larboard as: B.J. was resigning the abutting day, his abandonment would be 24 Case 1:21-cv-03217-CJN Certificate 15-18 Filed 04/22/22 Folio 15 of 19 130 And the Admiral said, “Fine. I’m not action to blaze him then, but aback his 1 abandonment comes in tomorrow, it’s accustomed immediately. Tomorrow’s his aftermost day as 2 U.S. attorney.” And Pat said, “Fine. We’ll accord with that later” and, array of, took it off 3 the table. 4 Q Uh-huh. 5 A And afresh the Admiral said, “What do you apperceive about Bobby Christine?” 6 Bobby Christine was the U.S. apostle in the Southern Commune of Georgia. I was 7 afraid at the question. I didn’t apperceive breadth it was going. I said, “Bobby Christine is 8 an accomplished U.S. attorney.” He said, “Yes, that’s what I’ve heard. I appetite Bobby 9 accustomed aforementioned day, and Bobby would booty over the Northern Commune of Georgia for the 25

15 minutes, aback he says, “Okay, I’m not action to do it, I’m not action to achieve a change”? 10 Any added name arise up, accountable bulk discussed, or annihilation abroad that’s noteworthy 11 about the 2-1/2-hour meeting? 12 A There was a lot there. It was absolutely a rollercoaster ride of a meeting, so 13 I’m abiding there are things I’m not remembering. I anticipate at some point he had asked 14 about names of added U.S. attorneys. You know, what do you anticipate of this guy? What 15 do you anticipate of that guy? And I aloof said: Acceptable U.S. attorneys, they’re solid, they’re 16 accomplishing their job. 17 Q Uh-huh. 18 Aback he arise his decision, did he accordance a acumen why he was not action to 19 chase through with the change to put Clark in as the Acting Apostle General? 20 A So, in about the aftermost 15 minutes, afterwards he’d heard anybody out extensively, 21 he said, “All right, I’ve heard everyone, and we’re not action to do this.” 22 He looked at Jeff Clark. He said, “I acknowledge your alertness to do it. I 23 acknowledge you actuality accommodating to ache the abuse. But the absoluteness is, you’re not action to 24 Case 1:21-cv-03217-CJN Certificate 15-18 Filed 04/22/22 Folio 16 of 19 131 actual few weeks of the administration. 1 Q Did he adage annihilation added about Bobby Christine and why he anticipation 2 awful of him or anticipation that he would do article altered than B.J. Pak had done? 3 A No, aloof that he had heard abundant things about Bobby. I knew that Bobby 4 was a one-star accustomed in the — I acquire it was the Georgia Civic Guard. And so he 5 had affiliated advancing history. I apperceive that’s article that the Admiral favors. I don’t 6 apperceive if that played into his compassionate or not. 7 Q Uh-huh. 8 All right. Annihilation abroad you remember, Mr. Donoghue, afore the aftermost 9 get annihilation done. These guys are action to quit. Anybody abroad is action to resign. It’s 25

to Clark that, I’m aloof not action to do this. 10 At that point, Clark began aggravating to get the Admiral to change his mind. He said 11 a cardinal of things — you know, history is calling, this is our opportunity, we can get this 12 done, and so on and so forth. And the Admiral afresh aloof array of angled bottomward and 13 said, “No, we’re not action to do it.” 14 Q Uh-huh. 15 A At that point, the Admiral looked at me and said, “So now what happens 16 with him?”, gesturing adjoin Jeff Clark. I didn’t acquire the question. I said, “Sir?” 17 And he said, “Are you action to blaze him?” 18 I said, “No, I’m not action to blaze him. I don’t acquire the ascendancy to blaze him. He’s 19 a Senate-confirmed Abettor Apostle General.” And the Admiral said, “Well, I’m not 20 action to blaze him.” I said, “Well, that’s accomplished then, sir. We should all aloof go aback to 21 work.” 22 Case 1:21-cv-03217-CJN Certificate 15-18 Filed 04/22/22 Folio 17 of 19 132 action to be a disaster. The ascendancy will eat you alive. And no bulk how abundant 1 you appetite to get things done in the abutting few weeks, you won’t be able to get it done, and 2 it’s not action to be annual the breakage.” 3 I anticipate addition abroad had acclimated that appellation earlier, maybe Pat Cipollone, “Is it absolutely 4 annual the breakage?” And the Admiral said, “It’s not action to be annual the accident 5 to achieve this change at this point.” 6 Q Uh-huh. 7 A And he said again, “These two, I know, are not action to get it done. But 8 that is what it is at this point.” He talked about how aghast he was in us, but said 9 And we all got up and absolved out of the Oval Office. 23

civilian controlling annex agencies. And, therefore, aback we alpha this call, we’re action 10 to about-face it over to you to abrupt up what the bearings is on the ground. And I did that both 11 in the 1800 and 1900 calls. 12 Q And I aloof appetite to about-face to the folio of your handwritten addendum breadth you 13 state: Prepped for the 1800 call. 14 A Right. 15 Q Sorry, we’ve gone a little bit out of order, but it’s absolutely fine. 16 So we talked about the 1900 call, and you told us what administering was on that call. 17 I appetite to analyze in your addendum for the 1900 call, it says POTUS and VP. 18 Was the Admiral on that call? 19 A No, I never batten to the Admiral that day. He was not on any calls that I 20 was on. 21 Q Was there any beforehand by the Admiral to acquaintance you that day? 22 A Not that I’m acquainted of. 23 Q Did you afterwards apprentice that the Admiral attempted to alarm you that day afterwards — 24 Case 1:21-cv-03217-CJN Certificate 15-18 Filed 04/22/22 Folio 18 of 19 189 What you are accomplishing there is added important. But if you can added the time, get on these 1 calls so we can apprehend anon what’s action on, on the ground. 2 That adeptness acquire — 3 Q Is that what led to you — 4 A That adeptness acquire been afore the Arch of Agents declared in the car. I can’t 5 absolutely remember. 6 Q And is that what led to you, essentially, arch the 18 — the 1900 call? 7 A Yes. Both the 1800 alarm and the 1900 call, I was told in advance, at atomic in 8 one case by the DAG himself, that you’re the arch official on the arena in acceding of 9 A No. On January 6th? No, I never heard that the Admiral accustomed to acquaintance 25

Q If we could aloof go through what you abreast them on in that 1800 call, that 10 would be helpful. 11 A So these addendum I acquire in display 54 blue-blooded Basic for 1800 Bearings Allowance Call, I 12 fabricated these addendum to myself a few annual in beforehand of the 1800 alarm because I capital 13 to achieve abiding that I covered anniversary of these points. 14 So I fabricated this annual with Dave Bowdich and Ashan Benedict and some of the Capitol 15 Badge admiral with me to achieve abiding I wasn’t missing any key information. 16 I ran through the list. I able it. Aback the 1800 alarm started out of the 17 Bearings Room, they affronted it to me first. That’s why I acquire the aboriginal access there as, 18 “See alarm basic notes.” And I, essentially, apprehend this list, and I abreast them on what the 19 bearings was. 20 And afresh the alarm affiliated from there with added bodies agreeable in about 21 ambit fencing. Accustomed Hokansen, H-o-k-a-n-s-e-n, talked about the D.C. Civic 22 Bouncer role and things like that. 23 Q Afore we move on from the 6 p.m. and the 7 p.m. alarm on January 6th — and 24 Case 1:21-cv-03217-CJN Certificate 15-18 Filed 04/22/22 Folio 19 of 19 190 me on January 6th. 1 Q And afar from Mr. Cipollone and Mr. Meadows, did any White Abode 2 official beforehand to alarm you anon on January 6th? 3 A No. We had a alarm from the Bearings Room, so that was operated out of 4 the White House, but there were no added admiral extensive out to me that I’m acquainted of. 5 Q Who was in the Bearings Allowance at the White House? Do you remember? 6 A I don’t. This call, this 1800 call, this did not acquire the aldermanic 7 administering on it. And I don’t acquire the Carnality Admiral was on that alarm either. It was 8 added of, I think, a law enforcement-level call. 9 aloof so I’m clear, you’re still at the Capitol at that time. Is that right, Mr. Donoghue? 25

MARK MEADOWS, ) ) Plaintiff, ) ) v. ) Case No. 1:21-cv-3271-CJN ) NANCY PELOSI, et al. ) ) ) Case 1:21-cv-03217-CJN Certificate 15-19 Filed 04/22/22 Folio 1 of 6 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA Display R

Case 1:21-cv-03217-CJN Certificate 15-19 Filed 04/22/22 Folio 2 of 6 Pre-Decisional & Deliberative/Attorney-Client or Accustomed Assignment Artefact Georgia Affidavit of Abstraction [LETTERHEAD] The Honorable Brian P. Kemp Governor 111 Accompaniment Capitol Atlanta, Georgia 30334 The Honorable David Ralston Speaker of the Abode 332 Accompaniment Capitol Atlanta, Georgia 30334 HCOR USE ONLY The Honorable Butch Miller Admiral Pro Tempore of the Assembly 321 Accompaniment Capitol Atlanta, Georgia 30334 Dear Governor Kemp, Mr. Speaker, and Mr. Admiral Pro Tempore: The Administering of Amends is investigating assorted irregularities in the 2020 acclamation for Admiral of the United States. The Administering will alter you as we are able on investigatory progress, but at this time we acquire articular cogent apropos that may acquire impacted the aftereffect of the acclamation in assorted States, including the Accompaniment of Georgia. No doubt, abounding of Georgia’s accompaniment legislators are acquainted of irregularities, affirmation to by a array of witnesses, and we acquire taken apprehension of their complaints. See, e.g., The Chairman’s Abode of the Acclamation Law Study Subcommittee of the Continuing Assembly Attorneys Lath Arbitrary of Affirmation from December 3, 2020 Hearing, http://www.senatorligon.com/THE FINAL REPORT.PDF (Dec. 17, 2020) (last visited Dec. 28, 2020); Debra, Heine, Georgia Accompaniment Assembly Report: Acclamation After-effects Are ‘Untrustworthy;’ Acceptance Should Be Rescinded, THE TENNESSEE STAR (Dec. 22, 2020), accessible at https://tennesseestar.com/2020/12/22/georgia-state-senate-report-electionresults-are-untrustworthy-certification-should-be-rescinded/ (last visited Dec. 28, 2020). SOONŠTRIBUTE FOR Certificate ID: 0.7.2774.304144-000001 HCOR-Pre-Certification Events-07262021-000698

Case 1:21-cv-03217-CJN Certificate 15-19 Filed 04/22/22 Folio 3 of 6 Pre-Decisional & Deliberative/Attorney-Client or Accustomed Assignment Artefact In ablaze of these developments, the Administering recommends that the Georgia Accustomed Assembly should assemble in adapted affair so that its legislators are in a position to booty added testimony, accept new evidence, and brash on the bulk constant with its duties beneath the U.S. Constitution. Time is of the essence, as the U.S. Architecture tasks Congress with convening in collective affair to calculation Balloter Academy certificates, see U.S. Const., art. II, § 1, cl. 3, accede objections to any of those certificates, and adjudge amid any advancing slates of elector certificates, and 3 U.S.C. & 15 provides that this affair shall activate on January 6, 2021, with the Carnality Admiral authoritative over the affair as Admiral of the Senate. ASE The Architecture mandates that Congress accusation set the day for Electors to accommodated to casting their ballots, which Congress did in 3 U.S.C. 87, and which for this acclamation occurred on December 14, 2020. The Administering believes that in Georgia and several added States, both a slate of electors acknowledging Joseph R. Biden, Jr., and a abstracted slate of electors acknowledging Donald J. Trump, aggregate on that day at the able breadth to casting their ballots, and that both sets of those ballots acquire been transmitted to Washington, D.C., to be opened by Carnality Admiral Pence. The Administering is acquainted that a agnate bearings occurred in the 1960 election. There, Carnality Admiral Richard Nixon appeared to win the Accompaniment of Hawaii on Acclamation Day and Electors acknowledging Carnality Admiral Nixon casting their ballots on the day defined in 3 U.S.C. 87, which were appropriately certified by the Governor of Hawaii. But Senator John F. Kennedy additionally claimed to win Hawaii, with his Electors additionally casting their ballots on the assigned day, and that by January 6, 1961, it had been bent that Senator Kennedy was absolutely the champ of Hawaii, so Congress appropriately accustomed abandoned the ballots casting for Senator Kennedy. See Jack M. Balkin, Bush v. Gore and the Boundary Amid Law and Politics, 110 YALE L.J. 1407, 1421 n.55 (2001). પર The Administering additionally finds adverse the accustomed aspect of a awaiting accusation in Fulton County, Georgia, adopting several of the voting irregularities pertaining to which applicant for Admiral of the United States accustomed the best accurately casting votes in Georgia. See Trump v. Raffensperger, 2020cv343255 (Fulton Cty. Super. Ct.). Admitting the action accepting been filed on December 4, 2020, the balloon cloister there has not alike appointed audition on matter, authoritative it difficult for the authoritative action to accede this affirmation and aggressiveness these affairs on abode above-mentioned to January 6. Accustomed the coercion of this austere matter, including the Fulton Canton litigation’s apathetic pace, the Administering believes that a adapted affair of the Georgia Accustomed Assembly is acceptable and is in the civic interest. FOR 2 Certificate ID: 0.7.2774.304144-000001 HCOR-Pre-Certification Events-07262021-000699

Case 1:21-cv-03217-CJN Certificate 15-19 Filed 04/22/22 Folio 4 of 6 Pre-Decisional & Deliberative/Attorney-Client or Accustomed Assignment Artefact The Electors Article of the U.S. Architecture provides that “[e]ach Accompaniment shall appoint, in such Abode as the Assembly thereof may direct,” electors to casting ballots for Admiral and Carnality President. See U.S. Const., art. II, § 1, cl. 2. Abounding Accompaniment Legislatures originally chose electors by complete appointment, but over time anniversary Accompaniment Assembly has declared to do so by accustomed vote on the day appointed by Congress in 3 U.S.C. § 1 to be the Acclamation Day for Assembly of Congress, which this year was November 3, 2020. However, Congress additionally absolutely recognizes the adeptness that Accompaniment Legislatures acquire to accredit electors, accouterment in 3 U.S.C. & 2 that “[w]henever any Accompaniment has captivated an acclamation for the purpose of allotment electors, and has bootless to achieve a best on the day assigned by [3 U.S.C. & 1], the electors may be appointed on a consecutive day in such a abode as the assembly of such Accompaniment may direct.” The purpose of the adapted affair the Administering recommends would be for the Accustomed Assembly to (1) appraise the irregularities in the 2020 election, including violations of Georgia acclamation law brash adjoin that anatomy of law as it has been allowable by your State’s Legislature, (2) actuate whether those violations actualization which applicant for Admiral won the best accustomed votes in the November 3 election, and (3) whether the acclamation bootless to achieve a able and authentic best amid the candidates, such that the Accustomed Assembly could booty whatever action is all-important to ensure that one of the slates of Electors casting on December 14 will be accustomed by Congress on January 6. RUS GUTE al X While the Administering of Amends believes the Governor of Georgia should anon alarm a adapted affair to accede this important and burning matter, if he declines to do so, we allotment with you our actualization that the Georgia Accustomed Assembly has adumbrated ascendancy beneath the Architecture of the United States to alarm itself into adapted affair for the apprenticed purpose of because issues pertaining to the arrangement of Presidential Electors. The Architecture specifies that Presidential Electors shall be appointed by the Assembly of anniversary State. And the Framers acutely knew how to analyze amid a accompaniment assembly and a accompaniment executive, so their disparate choices to accredit to one (legislatures), the added (executive), or both, accusation be respected. Additionally, FOR 1 See, e.g., U.S.C., art. IV, § 4 (“The United States shall agreement to every Accompaniment in this Union a Republican Anatomy of Government, and shall assure anniversary of them adjoin Invasion; and on Appliance of the Legislature, or of the Controlling (when the Assembly cannot be convened) adjoin calm Violence.”) (emphases added); id. art. VI (“The Senators and Representatives afore mentioned, and the Assembly of the several Accompaniment Legislatures, and all controlling and authoritative Officers, both of the United States and of the several States, shall be apprenticed by Adjuration or Affirmation, to abutment this Architecture ….”) (emphasis added); id. XVII amend. (“When vacancies arise in the representation of any Accompaniment in the Senate, the controlling ascendancy of such Accompaniment shall affair writs of acclamation to ample such vacancies: Provided, That the assembly of any Accompaniment may empower 3 Certificate ID: 0.7.2774.304144-000001 HCOR-Pre-Certification Events-07262021-000700

Case 1:21-cv-03217-CJN Certificate 15-19 Filed 04/22/22 Folio 5 of 6 Pre-Decisional & Deliberative/Attorney-Client or Accustomed Assignment Artefact aback the Architecture intends to accredit to laws allowable by the Assembly and active by the Governor, the Architecture refers to it artlessly as the “State.” See, e.g., U.S. Const., art. I, 8 8 (“[Congress may] exercise absolute Legislation in all Cases whatsoever, over such Commune (not aloft ten Miles square) as may, by Cession of authentic States, and the Acceptance of Congress, become the Bench of the Government of the United States, and to exercise like Ascendancy over all Places purchased by the Accord of the Assembly of the Accompaniment in which the Aforementioned shall be, for the Erection of Forts, Magazines, Arsenals, dockYards and added needful Buildings”) (emphasis added) (distinguishing amid the “State,” command large, and the “Legislature of the State”). The Architecture additionally makes bright aback admiral are banned to any blazon of accompaniment actor. See, e.g., U.S. Const., art. I, § 10, cl. 1 (“No Accompaniment shall access into any Treaty, Alliance, or Confederation ..”). Surely, this cannot beggarly that a Accompaniment Governor could access into such a Treaty but a Accompaniment Assembly could not, or carnality versa. QRE BUT Clearly, however, some accoutrement accredit absolutely to accompaniment legislatures and there the Framers accusation be taken at their word. One such archetype is in Article V, which provides that a proposed Amendment to the Architecture is adopted “when ratified by the Legislatures of three fourths of the several States,” which is done by collective resolution or circumstantial resolution. Supreme Cloister antecedent makes bright that the Governor has no role in that process, and that his signature or approval is not all-important for ratification. See, e.g., Coleman v. Miller, 307 U.S. 433 (1939). So too, Article II requires action abandoned by the Assembly in appointing Electors, and Congress in 3 U.S.C. & 2 additionally recognizes this Built-in principle. The Supreme Cloister has explained that the Electors Article “leaves it to the assembly abandoned to ascertain the method” of appointing Electors, vesting the Assembly with “the broadest accessible adeptness of determination.” McPherson v. Blecker, 146 U.S. 1, 27 (1892). This adeptness is “placed absolutely and wholly with legislatures.” Id. at 34-35 (emphasis added). In the best contempo acknowledged Presidential acclamation to adeptness the Supreme Court, the 2000 election, the Supreme Cloister went on to ascendancy that aback a Accompaniment Assembly appoints Presidential Electors – which it can do either through statute or through complete action, the Assembly is not acting “solely beneath the ascendancy accustomed by the bodies of the State, but by advantage of a complete admission of ascendancy fabricated beneath Art. II, S 1, cl. 2, of the United States Constitution.” Bush v. Palm Beach Cty. Canvassing Bd., 531 U.S. SAN at FOR the controlling thereof to achieve acting accessories until the bodies ample the vacancies by acclamation as the assembly may direct.”) (emphases added). 4 Certificate ID: 0.7.2774.304144-000001 HCOR-Pre-Certification Events-07262021-000701

Case 1:21-cv-03217-CJN Certificate 15-19 Filed 04/22/22 Folio 6 of 6 Pre-Decisional & Deliberative/Attorney-Client or Accustomed Assignment Artefact 70, 76 (2000). The Accompaniment Legislature’s ascendancy to accredit Electors is “plenary.” Bush v. Gore, 531 U.S. 98, 104 (2000) (per curiam). And a Accompaniment Assembly cannot lose that ascendancy on annual of bold statutes to accompany the Civic Election. “Whatever accoutrement may be fabricated by statute, or by the accompaniment constitution, to accept electors by the people, there is no agnosticism of the adapted of the assembly to resume the adeptness an any time, for it can neither be taken abroad nor abdicated.” McPherson, 146 U.S. at 125. ON The Georgia Accustomed Assembly appropriately accusation acquire inherent ascendancy accustomed by the U.S. Architecture to arise into affair to accredit Electors, behindhand of any declared absolute imposed by the accompaniment architecture or accompaniment statute acute the Governor’s approval. The “powers absolutely accustomed [by the U.S. Constitution] accusation be such as are abnormally given, or accustomed by all-important implication.” Martin v. Hunter’s Lessee, 14 U.S. (1 Wheat.) 304, 326 (1816). And the assumption of all-important association arises because our Architecture is not prolix and appropriately does not “provide for minute blueprint of its powers, or to acknowledge the bureau by which those admiral should be agitated into execution.” Id. Otherwise, in a bearings like this one, if a Governor were acquainted that the Assembly of his Accompaniment was absorbed to accredit Electors acknowledging a applicant for Admiral that the Governor opposed, the Governor could baffle that arrangement by abnegation to alarm the Assembly into affair afore the abutting Admiral had been appropriately elected. The Architecture does not empower added admiral to abandon the accompaniment assembly in this fashion. 1 Appropriately whether declared into affair by the Governor or by its own inherent authority, the Administering of Amends urges the Georgia Accustomed Assembly to assemble in adapted affair to abode this acute bulk of cardinal civic importance. Sincerely, FOR INTERNA DO NO DE Jeffrey A. Rosen Acting Apostle Accustomed Richard Donoghue Jeffrey Bossert Clark Acting Agent Apostle (Acting) Abettor Apostle Accustomed Accustomed Civilian Assay 5 Certificate ID: 0.7.2774.304144-000001 HCOR-Pre-Certification Events-07262021-000702

Case 1:21-cv-03217-CJN Certificate 15-20 Filed 04/22/22 Folio 1 of 19 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA MARK MEADOWS, Plaintiff, V. Case No. 1:21-cv-3271-CJN NANCY PELOSI, et al. Display S

Case 1:21-cv-03217-CJN Certificate 15-20 Filed 04/22/22 Folio 2 of 19 1 SELECT COMMITTEE TO INVESTIGATE THE JANUARY 6TH ATTACK ON THE U.S. CAPITOL, U.S. HOUSE OF REPRESENTATIVES, WASHINGTON, D.C. INTERVIEW OF: JEFFREY A. ROSEN Wednesday, October 13, 2021 Washington, D.C. The annual in the aloft bulk was captivated in Allowance 4480, O’Neill Abode Arrangement Building, basic at 10:00 a.m. Present: Representatives Murphy, Luria, and Cheney.

Case 1:21-cv-03217-CJN Certificate 15-20 Filed 04/22/22 Folio 3 of 19 60 accomplished pages of the Admiral speaking. But, as I say, I bethink things that are constant with Rich’s notes, and that is allotment of why I booty no barring that, if that’s what he wrote, that’s what he wrote. Q You adumbrated beforehand that one of the things that the Administering did not do was to ascendancy a columnist conference. A That’s right. Q And there was advancement that you do that, and you — A Yes. Q — appropriately did not. So, again, what did the Admiral say about why it was important to ascendancy a columnist arrangement or to about achieve assertive statements about the election? A Well, i’ll accordance you an example. I don’t apperceive if it’s on this alarm or accession one, because some of these becloud a little bit, but at one point he was saying: Abounding a bodies are adage the Administering of Amends is missing in action. You know, you’re not accomplishing anything. No one sees you accomplishing anything. No one sees you accepting any columnist conferences. No one sees you accusatory the artifice that I’m audition is all over the place. So that would be an analogy breadth — again, that’s not an exact quote, but that’s the way I bethink him. He would say, you know, “People are cogent me the Amends Administering is missing in action.” And afresh we would say, “Mr. President, that’s aloof wrong. The Administering of Amends has done its job. Aloof let us do our job.” And he would say, “Well, if you’re accomplishing your job, why haven’t you activate the artifice that anybody tells me is out there?” And we’d say, “Well, some bodies are giving you bad information. You’re alert to the amiss people.” And, you know, it would go aback and alternating like that.

Case 1:21-cv-03217-CJN Certificate 15-20 Filed 04/22/22 Folio 4 of 19 90 things that, as we sit actuality today, acquire been sorted out but aback afresh would not acquire been, which is the, for example, advantage questions. I acquire the affluence today of actuality able to allotment conversations with the President, with the President’s counsel, because the Administering of Amends on annual of the accustomed Admiral and the admonition for the accomplished Admiral not objecting. But there are — that didn’t get resolved, I think, until backward July. So not aggravating to add complication breadth it doesn’t abide but what I’m aggravating to say there are a alternation of complexities that do exist. And the beforehand we did blueprint did assignment out. I anticipate the point you fabricated that I would accede with is it is acutely important in the Assembly acceptance action that, at the advanced end, for the Congress or in that case the Senate, I guess, to admonition ensure that the bodies that are appointed to amenable positions are bodies of assumption and character. And I anticipate it’s annual cerebration about prospectively the things you’re pointing to. But I anticipate those accusation added anticipation than I’ve accustomed instructively, that I can constructively abode today. Mrs. Luria. No. I acquire that those are circuitous issues that are conceivably things we attending at in the assignment of this lath and how we, you know, anticipate article like this from accident in the future. But did appetite to apprehend your claimed bend of accepting been the actuality in the role, if there were things that went through your apperception and accomplishments that you anticipation you would acquire admired to acquire been able to booty or affectionate of what your action was as you activate yourself in that situation. So I acknowledge your acknowledgment and your acumen into that. Ms. Luria. And I crop back. I don’t acquire any added questions, and acknowledge you for actualization afore the lath today? Mr. Rosen. Acknowledge you.

Case 1:21-cv-03217-CJN Certificate 15-20 Filed 04/22/22 Folio 5 of 19 96 be, you know, about appropriately farfetched. Q At some point, Mr. Meadows absolutely emailed you that YouTube link, and Mr. Donoghue’s response, aloft receipt: “Pure insanity.” Is that the aforementioned — A Yes. Yes. You’ve reminded me of that. That’s right. Q Yeah. And did that accurately characterize your reaction, as well, to this theory, that it aloof — A Yes. Q — was authentic insanity, no base whatsoever? A I’m action to understate. It was not corroborated. Q Yeah. Okay. So, afterwards that day, Mr. Rosen, afterwards this meeting, the Admiral declared you directly. There was a buzz conversation, and there’s some altercation about the achievability of the Supreme Cloister — this is not reflected in notes, but I acquire you testified advanced that there’s a followup buzz alarm with the Admiral himself. Do you bethink that? A So I anticipate Rich and I had a buzz alarm with the Admiral ancient on that Tuesday. Q Uh-huh. A I’m aggravating to bethink if the abrupt came up in that one or not. It wouldn’t abruptness me if it did. What I bethink bigger was that, on Wednesday, afterwards the Kurt Olsen incident, I batten to the President. I anticipate that was aloof me, or Rich may acquire been in my office, but I don’t anticipate it was on the speakerphone. Some of these were on speakerphone with me and Rich, and some, it was aloof me, but Rich could’ve been in my office. And the way I bethink it is, on Wednesday, I anguish up cogent the President, “This doesn’t work. There’s assorted problems with it. And the Administering of Justice

Case 1:21-cv-03217-CJN Certificate 15-20 Filed 04/22/22 Folio 6 of 19 is not action to be able to do it.” And — into the alarm — Steve’s office, had able for me. told him that explicitly, and he acquiesced. back? right? I anticipate you mentioned — about that? Q And what was his reaction? A He was accepting of it. He didn’t absolutely argue. I didn’t apperceive that action Q Uh-huh. A — so I had prepared. You apparently bethink these addendum that OLC, I assumption Q Right. A But the Admiral aloof acquiesced. Q Yeah. So you conveyed to him, “Hey, we don’t acquire continuing to book this,” A Yes. Q Okay. A And to my best bond — I’ve been asked this before, is, did it arise Q Yeah. A I can’t say definitively, but I don’t anticipate so. I anticipate that was the end of it. Q Now, there was one case in which the Administering did intervene. Is that A Yeah. Q — in aperture annual there was abandoned one bulk in which — A Yeah. Q — there was continuing and Administering did intervene. And can you acquaint us A Well, it didn’t intervene. It was — the Carnality Admiral was the defendant. 97

Case 1:21-cv-03217-CJN Certificate 15-20 Filed 04/22/22 Folio 7 of 19 he had heard, I’m bold from either Mr. Cipollone or Mr. Meadows, that it was happening, and had declared me and aloof told me he was action to arise to it. that makes me anticipate that he had adumbrated article alternating — you know, that he had previewed breadth he was advancing from, which was that he anticipation the Administering of Amends should be larboard to do its assignment in the way that it thinks is appropriate. during the affair with the President. Is that right? would be a abhorrent aberration for the Admiral to achieve that change. the Admiral says, “I apperceive you, Jeff,” pointing or gesturing adjoin you, “and you’re not action to do anything. You don’t alike apperceive or accede about the election. I don’t apperceive Q Yeah. A And so he was at the Sunday night meeting. I anticipate he had declared me, that Q Yeah. Did he say why? It was the abandoned affair in which he shows up. A Yeah. Q Why was he there? Did he or others say? A I don’t bethink exactly. But I apperceive what he said at the meeting, and Q Yeah. He’s absolutely absolutely anon analytical of Mr. Clark and his accreditation A Absolutely correct. Q Calls him out, saying, “No experience. You’re not able for this job.” A Yes. Q Said all that anon to Mr. Clark and to the Admiral in that meeting? A Yes. Q Okay. So it sounds like in the affair anybody agrees but Mr. Clark that it A That’s how I bethink it, yes. Q Yeah. The one adduce that I capital to ask you about is, at some point it’s arise that 103

Case 1:21-cv-03217-CJN Certificate 15-20 Filed 04/22/22 Folio 8 of 19 Jeff Clark, but he’ll do article about the election,” about authoritative this bond amid you represent cessation and Clark represents action. So the altercation is not aloof who’s action to serve, but is the Administering action to booty action? substance, right. Again, I don’t acquire a transcript, but it’s constant with how I bethink that arena out. or should be installed and what action he would or should booty as a result? anticipation it would — he said that it would set off assorted reactions. such a letter? Is that accurate? Array of, you and your cachet is affronted to action adjoin inaction? A I would accede with that. I anticipate the chat that you recited I anticipate is, in Q Okay. And, during the meeting, the abandoned articulation for action or for change is Mr. Clark. A Correct. Q Do you bethink any altercation he put alternating accurately as to why he could A Well, he fabricated arguments about why the letter would be effective, that he Q So this is the letter that we talked about a little afore — A Yes. Q — that you and Mr. Donoghue had acutely said no complete base and — A That’s right. Q — acutely inappropriate for the Department? A That’s right. Q The letter was back, and at the affair it’s discussed that he would accelerate A Yes. Q Okay. A And so he advocated for that. 104

Case 1:21-cv-03217-CJN Certificate 15-20 Filed 04/22/22 Folio 9 of 19 made. He argued that the blow of the allowance were actuality self-defeating, you know, that, if you don’t try it, you don’t apperceive what’s action to happen, I anticipate was the attributes of that. repeatedly. The Admiral interjected some places. There were a few places he batten at greater length, but a lot of the meeting, he let added bodies talk. Because he batten added than once. And I acquire added the image, that he would get in a debate, you know, that Rich Donoghue and he would acquire back-and-forth, and Steve Engel and he would acquire back-and-forth, and Eric Herschmann and he would acquire back-and-forth — not accurately well-founded, this is not the Department’s role, this letter is inappropriate. They challenged Jeff Clark’s abilities to alike be authoritative these arguments. They challenged both whether he was able to be Apostle Accustomed but additionally is he alike able to abode acclamation fraud, you know, alike from his accustomed position, let’s say. ahead, there are action to be resignations. And I anticipate lots of bodies aloft that. I let He additionally dedicated his own accreditation adjoin some of the attacks that were actuality Let me think. This was a very, complete affiliated meeting. Q Yeah. A And everybody batten at one time or another. Some bodies batten Q Uh-huh. A And so I’m aggravating to bethink the altered places that Jeff Clark spoke. Q Yeah. A — that that occurred abundant times. But the all-embracing actuality was, altered bodies in the allowance were saying, this is Q Uh-huh. A And so there’s this abuttals of issues. Now, at added than one juncture, a cardinal of bodies do accession that, if this goes 105

Case 1:21-cv-03217-CJN Certificate 15-20 Filed 04/22/22 Folio 10 of 19 added bodies allege to that, for accessible reasons, that they were speaking in abutment of me, so it wasn’t my abode to allege to. Jeff Clark didn’t allege to that, but I anticipate about everybody abroad did. I bethink Pat Cipollone batten to it, Rich Donoghue. why he anticipation it was inappropriate for the Administering of Amends to be sending a letter to Georgia and that he had assorted affirmation for that. And he commented that, if it went, that there would be resignations. And, again, this is in substance. I don’t bethink the exact words. Steve, you’ve been at Amends the accomplished time. You wouldn’t resign.” And Steve — I bethink this because it was complete active — said, “No, Mr. President. If you adapt Jeff Rosen with Jeff Clark and accelerate this letter, I would acquire no choice. I would acquire to resign.” And Engel afresh it. He said, “Mr. President, I would acquire no choice. I would acquire to resign.” of the letter? Was there additionally a altercation of the adapted admonition or the columnist arrangement or the Supreme Cloister brief, the annual of accessible things that had been brash that you mentioned in your aperture statement? about the Supreme Cloister abrupt — There was one moment breadth I bethink Steve Engel, and Steve was acknowledgment And afresh Steve Engel, aback he was adage that, the Admiral said to him, “Well, And the Admiral looked to me, startled, and said, “Steve, you wouldn’t resign.” So that was awful acknowledging of what had been said by added folks. Q Uh-huh. So the abandoned absolute election-related action that was discussed was the sending A I don’t bethink them actuality discussed in abandoned — you know, what Q Yeah. 106

Case 1:21-cv-03217-CJN Certificate 15-20 Filed 04/22/22 Folio 11 of 19 are added steps. The focus was on the letter — affiliated to some kinds of accessible statements. Because, by definition, the letter wasn’t action to break secret. something. I bethink it aloof more, there’s this one admission that says, in effect, do nothing, and this added admission that says, alpha demography steps. And the agitation was about that. And I anticipate I agreed with your catechism earlier, that the admission and the bodies were finer merged. Administering had done a abundant accord already with annual to evaluating claims of acclamation fraud. That had already occurred — validity. action to break put, I’m not action to adapt you, Acting Apostle Accustomed Rosen, with Mr. Clark. put with you as the baton of the Department? A — or what about this? I bethink at a academy akin of generality, that there Q Uh-huh. A — and that the letter would aftermath assorted achieve and would, you know, be So I don’t bethink it in acceding of action aback to that Supreme Cloister abrupt or Q Yeah. Well, I don’t appetite to actual you, but aback you say “do nothing,” at this point the A No, that’s right. “Do nothing” is a autograph for — Q For prospectively do nothing? A For prospectively demography achieve that would be analytical of the acclamation and its Q I see. All right. So the Admiral makes a adaptation in the meeting, basically decides, I’m Did he explain why? What was the reason, if any, he cited as to why he backward 107

Case 1:21-cv-03217-CJN Certificate 15-20 Filed 04/22/22 Folio 12 of 19 that, all right, we’re aloof not action to do this, we’re not action to achieve a change, article to that effect. wasn’t like a adjudicator that said, here’s my opinion, here’s breadth I arise out — there for a affiliated time, I anticipate 2, 2-1/2 hours at that point, article like that, and he aloof declared, okay, we’re not action to achieve the change. during the beforehand of the discussion, so everybody there apparently has their own perspectives on which one was the key. well, because it was a complete affiliated meeting. others, but Eric Herschmann. It was a complete active beforehand on Jeff Clark’s qualifications. acquaintance with elections; the letter to Accompaniment officials, again, would not be adapted institutionally; and the resignations. “Hey, the Administering will abandoned out if this has A He was complete conclusory about that. He aloof fabricated a allegorical annual Q Did he adduce the resignations or the accident it would do to achieve a change? A No, it wasn’t — you know, in a allowance abounding of lawyers, you’ll absolve me — it Q And here’s the reason? A — here’s the four reasons. It was added declaratory. You know, we’d been Q Afterwards explanation? He doesn’t tie it to any specific factor? A No. As I said, he didn’t tie it to a annual of reasons. Q Yeah. A As I alluded to, there had been a cardinal of adequately memorable moments Q Uh-huh. A You know, there were several that I bethink absolutely well. Others, not so Q Yeah. A The Engel chestnut that I aloof mentioned. Eric Herschmann and — he and Q So the affirmation put alternating were Mr. Clark’s claimed abridgement of abilities or 108

Case 1:21-cv-03217-CJN Certificate 15-20 Filed 04/22/22 Folio 13 of 19 occurred.” not in the best absorption of the country. that these episodes of declared fraud, that bodies acquire said this, that, or the added incident, those aren’t valid. That was repetitive, to some extent, but it did arise up again. his case, admitting the actuality that the Admiral had arise he wouldn’t achieve a change? achieve the change, aback he, in effect, arise a decision. done, and so Mr. Clark did achieve a beforehand then. the Assembly hearing, I acicular out that, at one point, he absolutely said to the President, “I anticipate it’s time to alarm the question.” Those are array of the capital arguments adjoin a change, as you recall? A Those, but there were a brace of others. Q Uh-huh. A Maybe they were hardly abstract, that this is not the adapted affair to do, this is Q Uh-huh. A I’m aggravating to bethink some specifics. I mean, there was some discussion, again, that you’re accepting bad information, Q Uh-huh. Yeah. A But those are absolutely some of the big ones. Q I see. Afterwards he arise his decision, did Mr. Clark abide to push, abide to altercate A Not aback the Admiral said, look, we’re aloof action to — we’re not action to Beforehand on, there were some moments breadth it wasn’t bright if maybe we were But he additionally did the adverse one time, too. I think, you know, you may anamnesis in So there was some of both, you know, of — 109

Case 1:21-cv-03217-CJN Certificate 15-20 Filed 04/22/22 Folio 14 of 19 question? Did he say, “It’s my adaptation as to aback to alarm the question,” or article like that? that, too, actually. anticipate Mr. Clark was accepting that the Admiral gets to achieve the call. in. But the Admiral gets to achieve the call. allegations of declared aborigine artifice or suggestions that the Administering should booty assertive action. I acquire a faculty that this affair was array of the punctuation here, that, okay, Administering of Amends is not any best action to be a antecedent of abatement for the President. say that’s somewhat corroborated by: The Admiral had been calling me with some regularity in those 2 weeks, and afterwards January 3rd he did not. acquire any added acquaintance with the Admiral afterwards that meeting? Q And what did the Admiral say aback he said it was time to alarm the A He had a facial announcement that said that. Q “Don’t acquaint me aback it’s time — A Yeah. Q — to decide”? A Yeah. And the altercation anguish up continuing absolutely a fair bulk afterwards Q Okay. A But aback the Admiral arise his basal line, if I can put it that way, I Q Yeah. A It apparently wasn’t what he had anticipation — what he, Jeff Clark, anticipation action Q Yeah. And did that, Mr. Rosen, about end it? Aback I say “it,” I beggarly blame you A I apperceive it the way you aloof said, that that was the end of it. And I would Q Yeah. No added acquaintance with him until the complete aftermost — well, did you anytime 110

Case 1:21-cv-03217-CJN Certificate 15-20 Filed 04/22/22 Folio 15 of 19 was calling assorted Cabinet admiral and aloof saying, “Thank you for your service.” affair on January 3rd about anything, in authentic about the election? the acclamation but he did acquaintance me about some added actuality — as additionally actuality about the balloter calculation — because that was action on that day — Mr. Cipollone declared me. clarification. A I think, generally, no, except he called, I think, on the 19th. And I anticipate he Q Yeah. I see. How about Mr. Meadows? Did he abide to alarm you, allocution with you, post- this A To my best bond as I’m sitting actuality is that he didn’t allocution to me about Q Yeah. A — including that blank affair — Q Got it. A — that had not been resolved. Q Yeah. Which I’m not — okay. [Discussion off the record.] Mr. Rosen. So aloof a clarification. Q Sure. A January 6th I anticipate of as actuality about a riot, but I accept if you ascertain that Q I see. A — there was a point in the aboriginal afternoon aback Mr. Meadows and Q Uh-huh. A And we can allocution some added about that if you — Q We will, but Soumya is action to get into that day. I acknowledge the BY MR. HEAPHY: 111

Case 1:21-cv-03217-CJN Certificate 15-20 Filed 04/22/22 Folio 16 of 19 were discussed, you testified afore the Assembly that those were affronted together. In what way were those two things, acceptation the abstruse letter from Jeff Clark and appointing Jeff Clark as Acting Apostle Accustomed affronted together? the cadre and the admission were apprenticed together, that it wasn’t — well, actuality is maybe a simple way to say it. There was no book in which he got to accumulate me and accelerate a letter to Georgia because I’d abandon afore that happened. And, likewise, Jeff Clark, if he had been chosen, did not advertise that he would be admiring to be the Acting Apostle Accustomed and booty no accomplishments with annual to the ascendancy of the election. based on what Jeff Clark had said to you, were you beneath the consequence that, if Jeff Clark had been appointed Acting Apostle General, he would acquire beatific the letter or article like it to Accompaniment admiral in Georgia? to do that. proof-of-concept letter. Is that correct? added States as well? affair or he said that to me and Rich Donoghue in the beforehand conversations. But, at some point, I anticipate he had said that, while Georgia was the focal, that he would anticipate that, as you alluded to, it’s a affidavit of abstraction to do added places as well. A So I anticipate this goes aback to the altercation we had with Mr. Heaphy, that Q So I apperceive you’re afraid to brainstorm on what could acquire happened, but A Yeah. I don’t — I’m not apperception there. He advocated that he capital Q And I acquire he referred to it or maybe alike labeled it at some point as a A Yes. Q And, from that, did you booty it that he capital to accelerate a agnate letter to A Yes, because I anticipate he had said that. I don’t apperceive if he said it at the Q And did Jeff Clark anytime advertise that if he were appointed Acting Apostle 127

Case 1:21-cv-03217-CJN Certificate 15-20 Filed 04/22/22 Folio 17 of 19 General, he would accompaniment about that the 2020 Presidential acclamation was corrupt? assertions about the improprieties with absorption to the 2020 election. Acting Apostle General, he would acquire the Administering of Amends book an aboriginal action in the Supreme Court? meeting, so I acquire to accept aback to whether I commented on that afterwards on. As I sit actuality adapted now, nothing’s advancing to mind, but that — that’s one I adeptness accusation to anticipate about. Administering of Justice’s administering during one of your affairs with the President, Mr. Donoghue’s addendum adumbrated that he said article to the — that he, Mr. Donoghue, said article to the aftereffect of “fine, but that won’t change the Department’s position.” that aboriginal phase, we were acquainted that Jeff Clark had gone to this affair at the Oval, but we did not acquire acumen that he had a altered aisle in mind. So, aback the Admiral aloft that animadversion that — again, I’m aloof paraphrasing, that Jeff — bodies acquaint me Jeff Clark is abundant or whatever, we somewhat discounted that as in, you know, fine. You — you’ve met him once. But, you know, the Department’s position is the Department’s position. A Maybe not as edgeless as you aloof said it, but — Q What’s the best way to alarm it? A That he advocated not aloof that the letter be beatific but that there be accessible Q And did Jeff Clark anytime authentic an assessment whether, if he had been appointed A I don’t bethink the Supreme Cloister affair advancing up at the Sunday night Q So, apropos the President’s advancement that he adeptness change the Do you bethink him adage article alternating those lines? A Yes. That — this is in the aboriginal phase, right, breadth we apperceive that Jeff — at Q So it’s absolutely barefaced that, accustomed what Mr. Donoghue knew at the 128

Case 1:21-cv-03217-CJN Certificate 15-20 Filed 04/22/22 Folio 18 of 19 anyone has any questions about the calls that day. all to anticipate about Admiral Trump and what he was doing? there is not a lot of time for what I’ll alarm reflection. annual that was not what we would acquire admired for. You may acquire it and brace me. I don’t bethink the specifics. But I aloof remembered cerebration that’s not what we would acquire admired for. reflected on this, which, at atomic to my best recollection, were Pat Cipollone, Robert O’Brien, and Mark Meadows — they were complete abundant in the aforementioned aspect we were: Let’s get as abundant admonition to the Capitol as fast as possible. could allocution to the President. that I aloof don’t anamnesis that. everybody up to the Carnality President, but not the President? was not what we would acquire admired for. And I’m absolutely not — not absolutely alike abiding how to acknowledge to that, because we got so focused during the day on what we acquire to do and what can we do and aggravating to be in a aspect of actuality allotment of the solution, aggravating to be Ms. Cheney. I do, Soumya. Jeff, can you allocution about, over the beforehand of the day, whether it occurred to you at Mr. Rosen. In some sense. I mean, you can see there is so abundant action on that But I anticipate that — I anticipate I abstruse at some point he had put out some affectionate of a And the White Abode agents were — at atomic the ones I dealt with, and they’re So I anticipate that there was at atomic the achievement that somebody in the White Abode Ms. Cheney. And were there any discussions about that? Mr. Rosen. That’s what I’m saying, is I — it’s such a blur, the day is such a becloud Ms. Cheney. Did you — how did you anticipate about the actuality that you had talked to Mr. Rosen. Well, I, as I say, I anticipate the antecedent annual that I had apparent put out 190

Case 1:21-cv-03217-CJN Certificate 15-20 Filed 04/22/22 Folio 19 of 19 helpful. there was this amazing coercion and aloof advancing all day long, you apperceive — what’s happening, what can we do, what abroad do we know, and what do we apprehend from DHS, what do we apperceive — that it aloof gets bent up in the moment of: Let’s do our job. You know, we’ll do our job, and let’s achievement everybody is accomplishing what they’re declared to do. And that’s how I bethink it. Admiral put out calling the Carnality Admiral a coward? and said a addition of, “You will not acquire this statement.” And it was article agnate to what you aloof said — again, I don’t bethink the exact words — and aloof actuality both afraid and aghast at that statement. Admiral was demography action? Did anybody arise to you and say, “He’s demography action to stop this”? Meadows and added White Abode agents were saying, “Do aggregate you can to admonition abode this situation.” me is this coercion of, “Can everybody try to get help?” Obviously, the bearings was terrible, but already this aperture of the Capitol occurred Ms. Cheney. In acceding of the aboriginal statement, do you anamnesis the annual that the Mr. Rosen. Yeah. I didn’t absolutely see it, but addition had arise into my arrangement Ms. Cheney. Did you acquire any acumen to acquire at any moment that the Mr. Rosen. Not — no, not in those words or equivalent. Aloof the actuality that Mark Ms. Cheney. But they weren’t cogent you what they are aggravating to do — Mr. Rosen. No. Ms. Cheney. — internally? Mr. Rosen. No. At atomic not that I remember. The affair that aloof sticks with Ms. Cheney. Okay. 191

MARK MEADOWS, ) ) Plaintiff, ) ) v. ) Case No. 1:21-cv-3271-CJN ) NANCY PELOSI, et al. ) ) ) Case 1:21-cv-03217-CJN Certificate 15-21 Filed 04/22/22 Folio 1 of 3 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA Display T

10 INTERVIEW OF: CHRISTOPHER CHARLES MILLER 11 12 13 14 Friday, January 14, 2022 15 16 Washington, D.C. 17 18 19 The annual in the aloft bulk was captivated via Webex, basic at 10:00 a.m. 20 Present: Representatives Lofgren, Murphy, Raskin, Aguilar, Cheney, and 21 Case 1:21-cv-03217-CJN Certificate 15-21 Filed 04/22/22 Folio 2 of 3 1 2 3 SELECT COMMITTEE TO INVESTIGATE THE 4 JANUARY 6TH ATTACK ON THE U.S. CAPITOL, 5 U.S. HOUSE OF REPRESENTATIVES, 6 WASHINGTON, D.C. 7 8 9 Kinzinger. 22 1

6 or 7, did you acquire any complete acquaintance with Mark Meadows? 10 A No. 11 Q No? 12 A No. 13 Q Were you acquainted of Mr. Patel’s conversations with Mr. Meadows that day? 14 A No, I was not. 15 Q Did he aback annihilation to you as far as what the White Abode was 16 communicating? 17 A No, he did not. 18 Q Publicly, Mr. Patel has declared that he was — they were — we, he said we — I 19 don’t apperceive who the we is — were on the buzz with Meadows all day. 20 Would you be included in that? 21 A I was not. No, I was not. 22 Q Did you allege to the Carnality Admiral that day? 23 A Yes, and it’s in the timeline. I can’t bethink if he declared or I — he declared 24 Case 1:21-cv-03217-CJN Certificate 15-21 Filed 04/22/22 Folio 3 of 3 124 Did you — was there any beforehand by you to acquaintance anyone at the White Abode to get the 1 aloft Admiral to affair a annual to adjustment association to leave the Capitol? 2 A I was — I did not, no. 3 Q And did you acquire any admonition with any — with the Admiral that 4 day? 5 A I did not acquire any admonition with the Admiral that day. I apperceive we 6 had some calls to the White House, so that was affectionate of my agent for — or they were on 7 our — on some calls, so I acquainted like I knew what was action on. 8 Q Afar from the interagency calls that are in the outline afterwards that day about 9 me. 25

MARK MEADOWS, ) ) Plaintiff, ) ) v. ) Case No. 1:21-cv-3271-CJN ) NANCY PELOSI, et al. ) ) ) Case 1:21-cv-03217-CJN Certificate 15-22 Filed 04/22/22 Folio 1 of 3 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA Display U

10 INTERVIEW OF: RYAN MCCARTHY 11 12 13 14 Friday, February 4, 2022 15 16 Washington, D.C. 17 18 19 The annual in the aloft bulk was captivated in Allowance 4480, O Neill Abode Arrangement 20 Building, basic at 9:59 a.m. 21 Case 1:21-cv-03217-CJN Certificate 15-22 Filed 04/22/22 Folio 2 of 3 1 2 3 SELECT COMMITTEE TO INVESTIGATE THE 4 JANUARY 6TH ATTACK ON THE U.S. CAPITOL, 5 U.S. HOUSE OF REPRESENTATIVES, 6 WASHINGTON, D.C. 7 8 9 Present: Adumbrative Raskin. 22 1

A It was — Secretary Miller and Accustomed Milley had that altercation on that 10 Sunday that I’d referenced, and it was their compassionate that they had the ascendancy 11 delegated bottomward to them, or to the Secretary Miller, alibi me, not Accustomed Milley. 12 Q Could Admiral Trump acquire taken any action that would acquire added the 13 acknowledgment time of the D.C. Civic Guard? 14 A At that point, it was in Secretary Miller’s hands. 15 Q But if Admiral — you did not acquire any acquaintance with Admiral Trump, 16 correct? 17 A No. 18 Q Secretary Miller testified he did not acquire any acquaintance with Admiral Trump. 19 I assumption my catechism is, if Secretary — if Admiral Trump had declared you or Secretary Miller 20 and said, let’s go, let’s get these association moving, would it acquire impacted the acknowledgment time? 21 A I’d say, we’re animate on it, Mr. President. We’ve got to apperceive what we’re 22 declared to do. I mean, that was — we capital to be brash in how we active 23 them and achieve abiding we got it right. I mean, there were a lot of bodies calling us to 24 Case 1:21-cv-03217-CJN Certificate 15-22 Filed 04/22/22 Folio 3 of 3 147 timing of the aloft President’s tweets and your approval time of 4:32? There’s been 1 some belletrist that there’s a alternation there. I appetite to accordance you the adventitious to acknowledge 2 to that. 3 A It’s absurd. It had annihilation to do with that. 4 Q Did it acquire any appulse on your team, any — 5 A None. 6 Q We talked a lot about the authorities that happened on that day from the 7 Secretary of Defense bottomward to you. Did you accusation — did you or Secretary Miller accusation any 8 added authorities from Admiral Trump on January 6th? 9 hurry, the Speaker, a lot of added complete arch people, but we capital to do it the adapted 25

MARK MEADOWS, ) ) Plaintiff, ) ) v. ) Case No. 1:21-cv-3271-CJN ) NANCY PELOSI, et al. ) ) ) Case 1:21-cv-03217-CJN Certificate 15-23 Filed 04/22/22 Folio 1 of 20 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA Display V

Case 1:21-cv-03217-CJN Certificate 15-23 Filed 04/22/22 Folio 2 of 20 Bulletin From: Sent: To: CC: Subject: [email protected] ([email protected]] 12/22/2020 1:10:39 PM [email protected] [email protected]; [email protected] PIRs_RFls_for_Election_Fraud_22DEC2020.docx Mr Meadows, Advertence our babble in your arrangement bygone afternoon, this is the Civic Asset Tasking abode to abutment EO 13848. The resultant admonition will be analytical for POTUS and ODNI to complete the adapted investigation. V/R Phil Waldron 210-240-7114 Beatific from ProtonMail adaptable MM002282

Case 1:21-cv-03217-CJN Certificate 15-23 Filed 04/22/22 Folio 3 of 20 12/21/2020 Priority Intelligence Requirements And Requests for Admonition Beneath the Ascendancy vested in the Admiral of the United States in Article 2 of the US Architecture and Cybersecurity Controlling Orders of 2017 and 2018, the afterwards Departments and Agencies are hereby directed to chase their centralized and/or aggregate databases as able-bodied as anon assignment accumulating assets (personnel, tools, resources) to accommodate abundant admonition and/or assay of adopted nation-state adversaries or their proxies attempting to baffle with or access the United States Civic Election. Civic Aegis Bureau Civic Reconnaissance Arrangement Administering of Homeland Aegis Federal Bureau of Assay Administering of the Treasury Drug Administering Bureau Any and all pertinent admonition will be forwarded to the Hon. John Ratliff, Director of Civic Intelligence and Acting SECDEF Chris Miller. Administering and Bureau active will detail what databases were queried and what accomplishments acquire been taken to complete the following: 1. Anniversary Bureau and their accessory or associate offices, actuate if there were any communications amid any foreign-based breadth to servers that were acclimated in the US acclamation from 1 AUG 2020 to cancellation of this tasking (with specific focus placed on 03 NOV 2020 0800EST to 4 NOV 2020 0600EST); accommodate the metadata annal (FROM IP, FROM PORT, TO IP, TO PORT, PROTOCOL, DURATION, FILE SIZE) of the communications alternating with any added contextual abstracts acknowledgment the attributes of the communications, including the continuance of the session, and admeasurement of the abstracts alteration breadth available. 2. Conduct brash cartage assay on the IP addresses and breadth names beneath (Appendix A), gluttonous abstracts alteration to/from the hostname to any adopted based entities. 3. Anniversary Administering and Bureau is tasked to Alike with US Treasury FINCEN or added banking intelligence activities undertaken by the US Government for any arrangement abstracts (to accommodate bankruptcies, lawsuits, notification of adopted beforehand or ownership) that indicates adopted sales or captivation in transactional abstracts amid Cuban, Venezuelan, and Chinese nationals, Chinese controlled business concerns, or assembly of the Chinese Communist Affair (CCP). 4. Appliance annual from Dominion Systems beneath (and any centralized databases) conduct database chase of Mr. Jorge Rodriguez, aloft Venezuelan Minister of Communications. Chase for admission to Khalil Majid Mazoub (a accustomed advanced man for Venezuelan intelligence), and possibly Antonio Mugica (Smartmatic CEO) of Caracas, Venezuela. MM002283

Case 1:21-cv-03217-CJN Certificate 15-23 Filed 04/22/22 Folio 4 of 20 12/21/2020 5. Telephonic and Email and Meta Abstracts Admission amid SGO Corporation, Staple Street, UBS, SVS Holdings, Smartmatic, Sequoia Voting, Dominion, ESS Voting Anniversary Administering and Bureau is directed to assay their databases for any adumbration of admonition on the afterwards entities (see Appendix A). Anniversary Administering and Bureau is encouraged to conduct inter bureau coordination, and adopted partners, breadth appropriate. Assignment to US Treasury Administering Determine, to the greatest admeasurement possible, the ownership, influence, and arrest of adopted based Election/Voting Systems companies and their attempts to abstain CFIUS, as referenced in 2012 Defalcation affairs (see: Case #10-24238 HRT afore the US Defalcation Cloister for the Commune of Colorado, Debtor: SVS Holdings, Inc, Filed: 10/05/2012). Determine, to the greatest admeasurement possible, the use of Venezuela as a proxy for the Chinese Communist Affair (CCP) and its all-around rea with carapace corporations and money bed-making activities, attempting to accretion a ballast in United States civic analytical infrastructure, as declared in consecutive Presidential Controlling Orders of 2017 and 2018. Specifically: 1. On Friday, September 21, 2012, Smartmatic filed two motions gluttonous addition relief: (a) ascendancy to arraign abstention actions; (b) arrangement of a Chapter 11 trustee; or (c) about-face of the case to Chapter 7. Smartmatic’s motions are abundantly brash to access action advantage for a awaiting action Smartmatic accomplished adjoin Dominion Voting Systems, Inc. (“Dominion”) in Delaware involving allegations of $20 actor in damages. 2. The arch parties in this dispute-Debtor, Smartmatic, Dominion, Sequoia Voting Systems, Inc. (“Sequoia”), and Mr. Jack Blaine- were or are affianced in the business of affairs voting systems worldwide. While sometimes transacting with one accession and attempting to accomplice with one accession in assorted configurations, the parties acquire additionally abundantly been in complete competition, gluttonous to advertise voting systems to bounded and civic governments worldwide. As with any aggressive business, some thrive, and others fail. 3. Debtor and its wholly-owned operating company, Sequoia, failed. Smartmatic thrived, and continues to do so. 4. Debtor filed this defalcation acquisitive to aggressiveness and end a array of longstanding disputes amid itself and Smartmatic. Smartmatic is Debtor’s better creditor. Arch up to and through bankruptcy, Smartmatic has abundantly dictated Debtor’s course. 5. Debtor is a captivation company. Added than officers, it never had any employees, and its abandoned operation was administering of its debts, books, and records. Its sole asset was and charcoal its banal in Sequoia, its wholly-owned subsidiary. 6. Debtor acquired Sequoia from Smartmatic in 2007. Above-mentioned to Smartmatic’s ownership, Sequoia’s roots amplitude aback over a aeon to the addition of the aboriginal lever-action automated voting systems. By the 1980s, Sequoia was a avant-garde in the breadth of cyberbanking voting systems. Smartmatic MM002284

Case 1:21-cv-03217-CJN Certificate 15-23 Filed 04/22/22 Folio 5 of 20 12/21/2020 purchased Sequoia in 2005. Jack Blaine, a Smartmatic agent at the time, assisted in the acquisition. By 2006, Mr. Blaine was the admiral of Sequoia, afresh still endemic by Smartmatic. 7. In 2006, assorted political issues arose, and United States authorities became acquainted that Sequoia, through Smartmatic, was alongside endemic by Venezuelan citizens. The U.S. Lath on Adopted Beforehand in the United States (“CFIUS”) began reviewing Smartmatic’s acquirement of Sequoia. 8. To aggressiveness abeyant issues with CFIUS, in 2007, Smartmatic transferred Sequoia to a new aggregation formed for the acquisition, endemic by U.S. citizens who were allotment of Sequoia’s management. The new aggregation was Debtor, and Debtor’s majority actor was Mr. Blaine. 9. Smartmatic has affiliated accustomed and adapted to accumulate the acceding of the Sequoia auction to Debtor confidential. Acquaintance agreements appropriately anticipate acknowledgment of the specific acceding herein. Nevertheless, Debtor can acknowledge that as a basic of the auction terms, Debtor was answerable to achieve assertive payments to Smartmatic, amid added obligations. Appointed Individuals and Organizations for Civic Aegis Emergency Tasking, Assay of Present Holdings, and Tailored Admission Individuals: 1. Khalil Majib Mazoub Hezbollah and Iran Nexus to Maduro administering – cogent DEA backing on him 2. Jorge Rodriguez Gomez Aloft Carnality Admiral Venezuela beneath Chavez Mastermind of Acclamation Subversion Ops with SGO Affiliation Administering US 2020 accessible 3. Delcy Rodriguez Gomez Accustomed Carnality Admiral de la Republica Bolivariana de Venezuela NOTE: Adaptation 2 and 3 abhorrence US because US backed armament asleep their ancestor in 1976 4. Omar Jose Montilla Castillo 5. Lord Mark Malloch Brown Administrator of the Lath of Directors of SGO MM002285

Case 1:21-cv-03217-CJN Certificate 15-23 Filed 04/22/22 Folio 6 of 20 12/21/2020 6. Sir Nigel Knowles All-around CEO of DLA Piper (Saudi Arabia) Lath of Directors of SGO Affiliation 7. David Giampaolo Lath of Directors of SGO 8. Paul Neffenger Smartmatic USA Lath Associate 9. Arturo Varona US Passport 711661612 Abandoned non-Venezuelan agent of Smartmatic Panama 10. Camilo Andres Mendez Chong Smartmatic Panama 11, Federico Arnao Mila De La Roca Admission to Dominion, Smartmatic, Sequoia in Canada and USA and Venezuela DOB 22 SEP 1972 SSAN 652-47-7777 46 North Park Drive Toronto, ON, Canada (647)342-4484 (647)907-7905 [email protected] [email protected] 12. Gustavo Reyes (multiple accustomed aliases) Gustavo Reyes Zumeta Gustavo Jesus Reyes Zumeta Cordoba Gustavo Reso DOB 19 May 1962 US Passport 444730879 Accessible Accustomed Address: 11308 Walnut Creek Cloister Oakton, VA. 22124 (703) 273-6615 Added accessible phones: (703) 649-1688 (703) 749-0290 (703) 389-7912 MM002286

Case 1:21-cv-03217-CJN Certificate 15-23 Filed 04/22/22 Folio 7 of 20 12/21/2020 13. Antonia Jose Mujica Rivero SGO Affiliation Limited, UK Antonia M. Mugica Affiliated with Smartmatic enactment and conception Formed with Malloch Brown to bend up SGO Affiliation 766-07-2919 [email protected] [email protected] [email protected] 571-482-7296 561-862-0747 561-482-7296 14. Roger Pinate SGO Affiliation Limited, UK Smartmatic Founder All-encompassing Biking to US and Common 15. Carlos Rafael Ramirez Smartmatic Philippines operations 50762359670 [email protected] 16. Eric Coomer (US Person) Dominion Voting Systems Affiliated with ANTIFA 17. Gregory Meeks (US Person) Khalil Majib Mazoub’s circadian acquaintance in New York Burghal Meeks conducts Cl operations for this arrangement 18. Leopold Jose Martinez Nucete (US Actuality or Duel Citizen) Latin Achievement Narco apostle with ties to Maduro and Chavez regimes Aloft Venezuelan Congressman Organizations: Smartmatic Panama, S.A. as software coordinator and bed-making hub Smartmatic USA Boca Raton, Florida 6400 Congress St. MM002287

Case 1:21-cv-03217-CJN Certificate 15-23 Filed 04/22/22 Folio 8 of 20 12/21/2020 Boca Raton, FLA Dominion Voting Systems Denver and Toronto Telephonic and Email and Meta Abstracts Admission amid SGO Corporation, Staple Street, UBS, SVS Holdings, Smartmatic, Sequoia Voting, Dominion, ESS Voting JIATF-South O Abode Blackmail Arrangement Assay Corpuscle (TNAC) abutment Arrangement for actual abstracts for net breeze aloft the Internet O Analyze telco cartage Assignment JIATF-Sout to achieve on annual of this accomplishment 0 MM002288

Case 1:21-cv-03217-CJN Certificate 15-23 Filed 04/22/22 Folio 9 of 20 12/21/2020 APPENDIXA Dominion Voting Systems (US Company) https://www.dominionvoting.com/ Hostname belgrade.dominionvoting.com IP Abode 82.117.198.54 Netblock Owner SERBIA-BROADBAND-AS Serbia BroadBand-Srpske Kablovske mreze d.o.o. ASN31042 Serbia colorado.dominionvoting.com 23.236.62.147 GOOGLE ASN15169 United States denver.dominionvoting.com 204.132.219.214 CENTURYLINK-US-LEGACY-QWEST ASN209 United States dvsfileshare.dominionvoting.com 204.132.121.11 CENTURYLINK-US-LEGACY-QWEST ASN209 United States ex2013.dominionvoting.com 206.223.190.87 BEANFIELD ASN21949 Canada fileshare.dominionvoting.com 204.132.121.10 CENTURYLINK-US-LEGACY-QWEST ASN209 United States ftp.dominionvoting.com 69.172.237.100 COGECO-PEER1 ASN13768 Canada online.dominionvoting.com 69.172.237.110 COGECO-PEER1 ASN13768 Canada toronto.dominionvoting.com 206.223.168.94 BEANFIELD ASN21949 Canada 104.47170.110 dominionvotingcom.mail.protection.outlook.com MICROSOFT-CORP MSN-AS-BLOCK ASN8075 United States MM002289

Case 1:21-cv-03217-CJN Certificate 15-23 Filed 04/22/22 Folio 10 of 20 12/21/2020 ES&S (US Company) https://www.essvote.com/ Hostname alwaysonvpn1.essvote.com IP Abode 66.37.226.5 Reverse DNS esstestvpn.essvote.com Netblock Owner ASN-CXA-ALL-CC1-22773-RDC ASN22773 United States dashcam.essvote.com 204.16.233.177 204-16-233-177.integratedsolutions.net INTEGRATEDSOLUTIONS ASN32132 United States dott.dims.essvote.com 66.60.180.37 037.180-60-66.DIA-subnet.surewest.net SUREWEST ASN14051 United States essballottracker.essvote.com 66.37.226.13 essballottracker.essvote.com ASN-CXA-ALL-CC1-22773-RDC ASN22773 United States essconnect.essvote.com 66.37.226.68 essconnect.essvote.com ASN-CXA-ALL-CC1-22773-RDC ASN22773 United States essportalone.essvote.com 66.37.226.24 essportalone.essvote.com ASN-CXA-ALL-CC1-22773-RDC ASN22773 United States essportalthree.essvote.com 66.37.226.29 wsip-66-37-226-29.om.om.cox.net ASN-CXA-ALL-CC1-22773-RDC ASN22773 United States esstestvpn.essvote.com 66.37.226.5 esstestvpn.essvote.com ASN-CXA-ALL-CC1-22773-RDC ASN22773 United States essvote.com 104.24.108.21 CLOUDFLARENET ASN 13335 United States essvote.com 104.24.108.21 CLOUDFLARENET ASN13335 United States itrak.essvote.com 66.37.226.21 itrak.essvote.com ASN-CXA-ALL-CC1-22773-RDC ASN22773 United States jrapp.essvote.com 66.37.226.32 sp.essvote.com ASN-CXA-ALL-CC1-22773-RDC ASN22773 United States ksvra.essvote.com 66.37.226.38 ksvrqa.essvote.com ASN-CXA-ALL-CC1-22773-RDC ASN22773 United States legacy.essvote.com 66.37.226.36 wsip-66-37-226-36.om.om.cox.net ASN-CXA-ALL-CCI-22773-RDC ASN22773 United States m2.essvote.com 66.37.226.14 m2.essvote.com ASN-CXA-ALL-CC1-22773-RDC ASN22773 United States mail1.essvote.com 66.37.226.19 mail1.essvote.com ASN-CXA-ALL-CC1-22773-RDC ASN22773 United States micollab.essvote.com 66.37.226.50 wsip-66-37-226-50.om.om.cox.net ASN-CXA-ALL-CC1-22773-RDC ASN22773 United States mitelmbg.essvote.com 66.37.226.50 wsip-66-37-226-50.om.om.cox.net ASN-CXA-ALL-CC1-22773-RDC ASN22773 United States muca.essvote.com 66.37.226.70 muca.essvote.com ASN-CXA-ALL-CC1-22773-RDC ASN22773 United States MM002290

Case 1:21-CV-03217-CJN Certificate 15-23 Filed 04/22/22 Folio 11 of 20 12/21/2020 muca2.essvote.com 66.37.226.74 muca2.essvote.com ASN-CXA-ALL-CCI-22773-RDC ASN22773 United States nato.essvote.com 66.37.226.50 wsip-66-37-226-50.om.om.cox.net ASN-CXA-ALL-CC1-22773-RDC ASN22773 United States nat1.essvote.com 66.37.226.51 wsip-66-37-226-51.om.om.cox.net ASN-CXA-ALL-CCI-22773-RDC ASN22773 United States nat2.essvote.com 66.37.226.52 wsip-66-37-226-52.om.om.cox.net ASN-CXA-ALL-CC1-22773-RDC ASN22773 United States nat3.essvote.com 66.37.226.53 wsip-66-37-226-53.om.om.cox.net ASN-CXA-ALL-CC1-22773-RDC ASN22773 United States nat4.essvote.com 66.37.226.54 wsip-66-37-226-54.om.om.cox.net ASN-CXA-ALL-CC1-22773-RDC ASN22773 United States nat5.essvote.com 66.37.226.55 wsip-66-37-226-55.om.om.cox.net ASN-CXA-ALL-CC1-22773-RDC ASN22773 United States nat6.essvote.com 66.37.226.56 wsip-66-37-226-56.om.om.cox.net ASN-CXA-ALL-CCI-22773-RDC ASN22773 United States nat7.essvote.com 66.37.226.57 wsip-66-37-226-57.om.om.cox.net ASN-CXA-ALL-CC1-22773-RDC ASN22773 United States nat8.essvote.com 66.37.226.58 wsip-66-37-226-58.om.om.cox.net ASN-CXA-ALL-CC1-22773-RDC ASN22773 United States nat9.essvote.com 66.37.226.59 wsip-66-37-226-59.om.om.cox.net ASN-CXA-ALL-CC1-22773-RDC ASN22773 United States nmvrga.essvote.com 66.37.226.39 nmvrqa.essvote.com ASN-CXA-ALL-CC1-22773-RDC ASN22773 United States ns1.essvote.com 66.37.226.12 wsip-66-37-226-12.om.om.cox.net ASN-CXA-ALL-CC1-22773-RDC ASN22773 United States printmanager.essvote.com 66.37.226.6 printmanager.essvote.com ASN-CXA-ALL-CC1-22773-RDC ASN22773 United States psv.essvote.com 66.37.226.4 wsip-66-37-226-4.om.om.cox.net ASN-CXA-ALL-CC1-22773-RDC ASN22773 United States sft-test.essvote.com 66.37.226.8 sft-test.essvote.com ASN-CXA-ALL-CC1-22773-RDC ASN22773 United States sft.essvote.com 66.37.226.61 sft.essvote.com ASN-CXA-ALL-CC1-22773-RDC ASN22773 United States shop.essvote.com 64.73.195.53 shop.essvote.com CYBERCON ASN7393 United States sp.essvote.com 66.37.226.32 sp.essvote.com ASN-CXA-ALL-CCI-22773-RDC ASN22773 United States support.essvote.com 66.37.226.22 support.essvote.com ASN-CXA-ALL-CC1-22773-RDC ASN22773 United States uolsales.essvote.com 66.37.226.72 wsip-66-37-226-72.om.om.cox.net ASN-CXA-ALL-CC1-22773-RDC ASN22773 United States MM002291

Case 1:21-cv-03217-CJN Certificate 15-23 Filed 04/22/22 Folio 12 of 20 12/21/2020 vlmviewer.essvote.com 66.37.226.15 vimviewer.essvote.com ASN-CXA-ALL-CCI-22773-RDC ASN22773 United States vpn 1.essvote.com 66.37.226.68 essconnect.essvote.com ASN-CXA-ALL-CC1-22773-RDC ASN22773 United States vpn2.essvote.com 66.37.226.66 vpn2.essvote.com ASN-CXA-ALL-CCI-22773-RDC ASN22773 United States vpn3.essvote.com 66.37.226.2 wsip-66-37-226-2.om.om.cox.net ASN-CXA-ALL-CC1-22773-RDC ASN22773 United States webmail.essvote.com 66.37.226.36 wsip-66-37-226-36.om.om.cox.net ASN-CXA-ALL-CC1-22773-RDC ASN22773 United States webresults.essvote.com 66.37.226.18 webresults.essvote.com ASN-CXA-ALL-CC1-22773-RDC ASN22773 United States webstore.essvote.com 67.37.226.11 ATT-INTERNET4 ASN7018 United States MM002292

Case 1:21-cv-03217-CJN Certificate 15-23 Filed 04/22/22 Folio 13 of 20 12/21/2020 Hart Intercivic (US Company) https://www.hartintercivic.com/ Hostname cpanel.hartintercivic.com IP Abode 172.81.117.226 Reverse DNS vps34155.inmotion hosting.com Netblock Owner IMH-IAD ASN54641 United States cpcalendars.hartintercivic.com 172.81.117.226 vps34155.inmotionhosting.com IMH-IAD ASN54641 United States cpcontacts.hartintercivic.com 172.81.117.226 vps34155.inmotionhosting.com IMH-IAD ASN54641 United States dev17.hartintercivic.com 172.81.117.226 vps34155.inmotionhosting.com IMH-IAD ASN54641 United States hartintercivic.com 172.81.117.226 vps34155.inmotion hosting.com IMH-IAD ASN54641 United States webdisk.hartintercivic.com 172.81.117.226 vps34155.inmotion hosting.com IMH-IAD ASN54641 United States webmail.hartintercivic.com 172.81.117.226 vps34155.inmotionhosting.com IMH-IAD ASN54641 United States whm.hartintercivic.com 172.81.117.226 vps34155.inmotion hosting.com IMH-IAD ASN54641 United States www.dev17.hartintercivic.com 172.81.117.226 vps34155.inmotionhosting.com IMH-IAD ASN54641 United States www.hartintercivic.com 172.81.117.226 vps34155.inmotionhosting.com IMH-IAD ASN54641 United States hartintercivic.com 172.81 117 226 vps34 155.inmotion hosting.com IMH-JAD ASN54641 United States MM002293

Case 1:21-cv-03217-CJN Certificate 15-23 Filed 04/22/22 Folio 14 of 20 12/21/2020 Scytl (Spain-based company) https://www.scytl.com/en/ Hostname IP Abode Reverse DNS Scyti.com 52.57.209.147 ec2-52-57-209-147.eu-centralStaging.scytl.com 1.compute.amazonaws.com Netblock Owner Amazon Technologies Inc. (AT-88-Z) Frankfurt, Germany agm.scyti.com 205.178.189.131 wf.networksolutions.com DEFENSE-NET ASN55002 United States alm.scytl.com 205.178.189.131 wf.networksolutions.com DEFENSE-NET ASN55002 United States bck.scyti.com 205.178.189.131 wf.networksolutions.com DEFENSE-NET ASN55002 United States bomarkham.scyti.com 205.178.189.131 wf.networksolutions.com DEFENSE-NET ASN55002 United States crl.scyti.com 217.111.178.69 COLT COLT Technology Services Group Apprenticed ASN8220 Spain DEFENSE-NET ASN55002 United States demo.scytl.com 205.178.189.131 wf.networksolutions.com dmspre.scytl.com 205.178.189.131 wf.networksolutions.com DEFENSE-NET ASN55002 United States edemocracy-experience.scytl.com 205.178.189.131 wf.networksolutions.com DEFENSE-NET ASN55002 United States elections.scytl.com 217.14.38.114 114.38.14.217.t-sysnet.com T-SYSTEMS-ELTEC ASN30892 Spain epropagande.scyti.com 205.178.189.131 wf.networksolutions.com DEFENSE-NET ASN55002 United States hrm.scyti.com 205.178.189.131 wf.networksolutions.com DEFENSE-NET ASN55002 United States inside.scytl.com 205.178.189.131 wf.networksolutions.com DEFENSE-NET ASN55002 United States invote.scytl.com 185.166.213.190 f6dcda04-c907-479a-9035d067f0fcd 456.clouding.host CLOUDING ASN49635 Spain jira-test.scytl.com 205.178.189.131 wf.networksolutions.com DEFENSE-NET ASN55002 United States levelup.scyti.com 52.20.236.134 ec2-52-20-236-134.compute-1.amazonaws.com AMAZON-AES ASN 14618 United States mail.scytl.com 205.178.189.131 wf.networksolutions.com DEFENSE-NET ASN55002 United States mail3.scytl.com 205.178.189.131 wf.networksolutions.com DEFENSE-NET ASN55002 United States mielectionspro2014.scytl.com 205.178.189.131 wf.networksolutions.com DEFENSE-NET ASN55002 United States mta-sts.owa.scytl.com 205,178.189.131 wf.networksolutions.com DEFENSE-NET ASN55002 United States MM002294

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Case 1:21-cv-03217-CJN Certificate 15-23 Filed 04/22/22 Folio 16 of 20 12/21/2020 dns 102.register.com 207 204,21.62 DEFENSE NET ASN55002 United States dns101.register.com 207.204.40.61 DEFENSE NET ASNS5002 United States scytl-com.mail.protection.outlook.com 104.47 10.36 mail db5euro 30036.inbound, protection.outlook.com MICROSOFT-CORP-MSN-AS BLOCK ASN8075 Ireland ClarityElections (Part of Scytl) Hostname IP Abode adams-co.connect4.clarityelections.com 3.223.181.65 Reverse DNS ec2-3-223-181-65.compute1.amazonaws.com Netblock Owner AMAZON-AES ASN14618 United States 52.1.225.137 arapahoeco.connect.clarityelections.com ec2-52-1-225-137.compute1.amazonaws.com AMAZON-AES ASN14618 United States bastrop-tx.connect4.clarityelections.com 3.223.181.65 ec2-3-223-181-65.compute1.amazonaws.com AMAZON-AES ASN14618 United States 13.226.25.68 calgary-abcanada.training.clarityelections.com server-13-226-2568.ewr53.r.cloudfront.net AMAZON-02 ASN16509 United States 3.223.181.65 capemaynj.connect4.clarityelections.com ec2-3-223-181-65.compute1.amazonaws.com AMAZON-AES ASN14618 United States chatham-ga.training.clarityelections.com 23.21.132.216 ec2-23-21-132-216.compute1.amazonaws.com AMAZON-AES ASN14618 United States clarityelections.com 13.226.25.22 server-13-226-2522.ewr53.r.cloudfront.net AMAZON-02 ASN16509 United States clarityelections.com 13.227.76.112 server-13-227-76112.sfo 20.r.cloudfront.net AMAZON-02 ASN16509 United States coffee-al.connect4.clarityelections.com 3.223.181.65 ec2-3-223-181-65.compute1.amazonaws.com AMAZON-AES ASN14618 United States 3.223.181.65 contracostaca.connect4.clarityelections.com ec2-3-223-181-65.compute1.amazonaws.com AMAZON-AES ASN14618 United States 3.223.181.65 contracostaclerkca.connect4.clarityelections.com ec2-3-223-181-65.compute1.amazonaws.com AMAZON-AES ASN14618 United States dallas-tx.connect4.clarityelections.com 3.223.181.65 ec2-3-223-181-65.compute1.amazonaws.com AMAZON-AES ASN14618 United States 18.213.71.51 dallastx.staging2.connect4.clarityelections.com ec2-18-213-71-51.compute1.amazonaws.com AMAZON-AES ASN14618 United States denton-tx.connect4.clarityelections.com 3.223.181.65 ec2-3-223-181-65.compute1.amazonaws.com AMAZON-AES ASN14618 United States 13.226.25.68 elections-abcanada.training.clarityelections.com server-13-226-2568.ewr53.r.cloudfront.net AMAZON-02 ASN16509 United States enr2.clarityelections.com 54.225.215.237 ec2-54-225-215-237.compute1.amazonaws.com AMAZON-AES ASN14618 United States 3.223.181.65 galvestontx.connect4.clarityelections.com ec2-3-223-181-65.compute1.amazonaws.com AMAZON-AES ASN14618 United States MM002296

Case 1:21-cv-03217-CJN Certificate 15-23 Filed 04/22/22 Folio 17 of 20 12/21/2020 gregg-tx.connect4.clarityelections.com 3.223.181.65 ec2-3-223-181-65.compute1.amazonaws.com AMAZON-AES ASN14618 United States hudson-nj.connect4.clarityelections.com 3.223.181.65 ec2-3-223-181-65.compute1.amazonaws.com AMAZON-AES ASN14618 United States 3.223.181.65 jeffersontx.connect4.clarityelections.com ec2-3-223-181-65.compute1.amazonaws.com AMAZON-AES ASN14618 United States 3.223.181.65 limestoneal.connect4.clarityelections.com ec2-3-223-181-65.compute1.amazonaws.com AMAZON-AES ASN14618 United States lubbock-tx.connect4.clarityelections.com 3.223.181.65 ec2-3-223-181-65.compute1.amazonaws.com AMAZON-AES ASN14618 United States 3.223.181.65 macoupin-ilnew.connect4.clarityelections.com ec2-3-223-181-65.compute1.amazonaws.com AMAZON-AES ASN14618 United States 3.223.181.65 macoupinil.connect4.clarityelections.com ec2-3-223-181-65.compute1.amazonaws.com AMAZON-AES ASN14618 United States 18.213.71.51 macoupinil.staging2.connect4.clarityelections.com ec2-18-213-71-51.compute1.amazonaws.com AMAZON-AES ASN14618 United States 3.223.181.65 madisonal.connect4.clarityelections.com ec2-3-223-181-65.compute1.amazonaws.com AMAZON-AES ASN14618 United States mchenry-il.connect.clarityelections.com 3.223.181.65 ec2-3-223-181-65.compute1.amazonaws.com AMAZON-AES ASN14618 United States mchenry-il.connect4.clarityelections.com 3.230.235.41 ec2-3-230-235-41.compute1.amazonaws.com AMAZON-AES ASN14618 United States mchenry-il.connect4.clarityelections.com 3.223.181.65 ec2-3-223-181-65.compute1.amazonaws.com AMAZON-AES ASN14618 United States 3.223.181.65 monmouthnj.connect4.clarityelections.com ec2-3-223-181-65.compute1.amazonaws.com AMAZON-AES ASN14618 United States 3.223.181.65 monmouthclerknj.connect4.clarityelections.com ec2-3-223-181-65.compute1.amazonaws.com AMAZON-AES ASN14618 United States morgan-al.connect4.clarityelections.com 3.223.181.65 ec2-3-223-181-65.compute1.amazonaws.com AMAZON-AES ASN14618 United States ns1.clarityelections.com 205.251.193.130 ns-386.awsdns-48.com AMAZON-02 ASN16509 United States ns2.clarityelections.com 205.251.193.130 ns-386.awsdns-48.com AMAZON-02 ASN16509 United States ns3.clarityelections.com 205.251.193.130 ns-386.awsdns-48.com AMAZON-02 ASN16509 United States oneida-ny.connect4.clarityelections.com 3.223.181.65 ec2-3-223-181-65.compute1.amazonaws.com AMAZON-AES ASN14618 United States results.enr.clarityelections.com 13.226.25.59 server-13-226-2559.ewr53.r.cloudfront.net AMAZON-02 ASN16509 United States 3.223.181.65 rockwalltx.connect4.clarityelections.com ec2-3-223-181-65.compute1.amazonaws.com AMAZON-AES ASN14618 United States MM002297

Case 1:21-cv-03217-CJN Certificate 15-23 Filed 04/22/22 Folio 18 of 20 12/21/2020 sarasota-fl.connect.clarityelections.com 34.230.155.193 ec2-34-230-155-193.compute1.amazonaws.com AMAZON-AES ASN14618 United States shasta-ca.connect.clarityelections.com 3.223.181.65 ec2-3-223-181-65.compute1.amazonaws.com AMAZON-AES ASN14618 United States 23.21.71.240 soe-pre-wds01.soeec2.clarityelections.com ec2-23-21-71-240.compute1.amazonaws.com AMAZON-AES ASN14618 United States 184.72.238.54 soe-stg-lwebo2.soeec2.clarityelections.com ec2-184-72-238-54.compute1.amazonaws.com AMAZON-AES ASN14618 United States 54.225.172.157 soe-virtualmail01.soeec2.clarityelections.com ec2-54-225-172-157.compute1.amazonaws.com AMAZON-AES ASN14618 United States soe-wds01.soe-ec2.clarityelections.com 54.235.159.49 ec2-54-235-159-49.compute1.amazonaws.com AMAZON-AES ASN14618 United States 3.223.181.65 stcharlesla.connect4.clarityelections.com ec2-3-223-181-65.compute1.amazonaws.com AMAZON-AES ASN14618 United States support.clarityelections.com 184.72.232.49 ec2-184-72-232-49.compute1.amazonaws.com AMAZON-AES ASN14618 United States testbed2.connect4.clarityelections.com 52.1.225.137 ec2-52-1-225-137.compute1.amazonaws.com AMAZON-AES ASN14618 United States 52.86.76.81 toronto-on-canadaws.training.clarityelections.com ec2-52-86-76-81.compute1.amazonaws.com AMAZON-AES ASN14618 United States ventura-ca.connect4.clarityelections.com 3.223.181.65 ec2-3-223-181-65.compute1.amazonaws.com AMAZON-AES ASN14618 United States voter-ed.demo.clarityelections.com 18.213.71.51 ec2-18-213-71-51.compute1.amazonaws.com AMAZON-AES ASN14618 United States 52.1.225.137 voter-registrationfl.connect.clarity ections.com ec2-52-1-225-137.compute1.amazonaws.com AMAZON-AES ASN14618 United States 3.223.181.65 will-ilarchive.connect3.clarityelections.com ec2-3-223-181-65.compute1.amazonaws.com AMAZON-AES ASN14618 United States will-il.connect3.clarityelections.com 3.223.181.65 ec2-3-223-181-65.compute1.amazonaws.com AMAZON-AES ASN14618 United States wood-tx.connect4.clarityelections.com 3.223.181.65 ec2-3-223-181-65.compute1.amazonaws.com AMAZON-AES ASN14618 United States www.clarityelections.com 13.227.76.112 server-13-227-76112.sfo20.r.cloudfront.net AMAZON-02 ASN16509 United States ns1.clarityelections.com 205.251 195 153 ns-921. awsdns-51 net AMAZON-02 ASN16509 United States ns2.clarityelections.com 205 251.195.153 ns-921.awsdns-51.net AMAZON-02 ASN16509 Bnited States. ns3.clarityelections.com 205.251 197487 ns-1467.awsdns 55.org AMAZON-02 ASN16509 United States owa.scytl.com 18.196.162.197 eC2-18-196-162-197.eu-central1.compute, amazonaws.com AMAZON-02 ASN16509 Germany MM002298

Case 1:21-cv-03217-CJN Certificate 15-23 Filed 04/22/22 Folio 19 of 20 12/21/2020 SmartMatic (US-based company) https://www.smartmatic.com/us/ Hostname biometria.smartmatic.com IP Abode 34.224.132.178 Reverse DNS ec2-34-224-132-178.compute1.amazonaws.com Netblock Owner AMAZON-AES ASN14618 United States biometric.smartmatic.com 34.224.132.178 ec2-34-224-132-178.compute1.amazonaws.com AMAZON-AES ASN14618 United States ciudadesinteligentes.smartmatic.com 34.224.132.178 ec2-34-224-132-178.compute1.amazonaws.com AMAZON-AES ASN14618 United States dev.smartmatic.com 104.20.79.36 CLOUDFLARENET ASN13335 United States elecciones.smartmatic.com 34.224.132.178 ec2-34-224-132-178.compute1.amazonaws.com AMAZON-AES ASN14618 United States elections.smartmatic.com 34.224.132.178 ec2-34-224-132-178.compute1.amazonaws.com AMAZON-AES ASN14618 United States smartcities.smartmatic.com 34.224.132.17 ec2-34-224-132-178.compute1.amazonaws.com AMAZON-AES ASN14618 United States vera.smartmatic.com 34.224.132.178 ec2-34-224-132-178.compute1.amazonaws.com AMAZON-AES ASN14618 United States 104.47.74.10 mail smartmatic com mail protection.outlook.com MICROSOFT CORP MSN AS-BLOCK ASN8075 United States bnanam080010.inbound.protection.outlook.com Knowink (US-based company) https://knowink.com/ Reverse DNS Hostname knowink.com IP Abode 192.241.137.228 Netblock Owner DIGITALOCEAN-ASN ASN14061 United States www.knowink.com 157.230.177.115 DIGITALOCEAN-ASN ASN14061 United States ns 1115.awsdns-11.org 205 257196.91 ns 1115.awsons 11.org AMAZON 02 ASN 16509 United States ns 1798.awsdns-32.co.uk 205.251.199,6 ns 1798.awsdns-32.co.uk AMAZON 02 ASN 16509 United States ns 485.awsdns-60.com 205,251 193 229 ns 485 awsdns 60.com AMAZON 02 ASN 16509 United States ns-649.awsdns-17 net 205.251.194.137 ns- 649.awsdns-17 net AMAZON-02 ASN 16509 United States Acclamation Antecedent (US-based company) https://electionsource.com/ Hostname IP Abode Reverse DNS Netblock Owner MM002299

Case 1:21-cv-03217-CJN Certificate 15-23 Filed 04/22/22 Folio 20 of 20 12/21/2020 electionsource.com 192.124.249.115 cloudproxy10115.sucuri.net SUCURI-SEC ASN30148 United States MM002300

MARK MEADOWS, ) ) Plaintiff, ) ) v. ) Case No. 1:21-cv-3271-CJN ) NANCY PELOSI, et al. ) ) ) Case 1:21-cv-03217-CJN Certificate 15-24 Filed 04/22/22 Folio 1 of 3 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA Display W

Case 1:21-cv-03217-CJN Certificate 15-24 Filed 04/22/22 Folio 2 of 3 JAMES C. WEIDNER ERNEST H. “BUCKY” WOODS, HI DOUGLAS A. COLLINS WILLIAM R. OLIVER (OF COUNSEL) Oliver & Weidner ATTORNEYS AT LAW NorthGeorgiaLawyers.com August 2, 2021 Mr. Jeff Clark: We represent aloft Admiral Donald J. Trump and abode apropos requests beatific to you by the U.S. Abode of Representatives Lath on Blank and Ameliorate and the U.S. Assembly Attorneys Lath to accommodate transcribed interviews on affairs accompanying to your annual as Agent Apostle Accustomed and Acting Apostle Accustomed during Admiral Trump’s administration. We additionally acquire that, as set alternating in its July 26, 2021, letter to you, the U.S. Administering of Amends declared that Admiral Biden absitively to abandon thre controlling and added privileges that assure from acknowledgment clandestine admonition apropos those affairs and has accustomed you to accommodate such information. Amuse be brash that the Department’s declared abandonment and allotment are unlawful, and that Admiral Trump continues to beforehand that the clandestine admonition the Committees seek is and should be adequate from acknowledgment by the controlling privilege. The controlling advantage applicative to communications with Admiral Trump belongs to the Arrangement of the Presidency, not to any abandoned President, and Admiral Biden tias no adeptness to unilaterally abandon it. The acumen is clear: if a Admiral were empowered unilaterally to abandon controlling advantage applicative to communications with his or her predecessors, decidedly those of the adverse party, there would finer be no controlling privilege. To the admeasurement the advantage would abide to abide at all, it would become yet accession weapon to akin the affectionate of bottomless accessory political attacks the Democrat-controlled administering and Committees are gluttonous to akin here. As the Supreme Cloister captivated in Nixon 13. Administrator of Accustomed Services, 433 U.S. 425 (1977) — where, like here, the then-current administering did not abutment a aloft President’s affirmation of controlling advantage – the controlling advantage is orucial to Controlling Annex decisionmaking: Unless (the President] can accordance his admiral some affirmation of confidentiality, a Admiral could not apprehend to accept the abounding and aboveboard submissions of facts and opinions aloft which able acquittal of his duties depends. The acquaintance all-important to this barter cannot be abstinent by the few months or years amid the acquiescence of the admonition and the end of the President’s tenure; the advantage is not for the annual of the Admiral as an individual, but for the annual of the Republic,

Case 1:21-cv-03217-CJN Certificate 15-24 Filed 04/22/22 Folio 3 of 3 Nixon v. Administrator of Accustomed Services, 433 U.S. 425,448-49 (1977). The Department’s July 26 letter to you quoted this adaptation but larboard out the complete abutting book in the opinion: “Therefore, the advantage survives the abandoned President’s tenure.” Id. at 448-49 (quoting, and adopting, Abrupt for the Solicitor Accustomed on Annual of Federal Appellees) (emphasis added). Here, it is bright that alike admitting Admiral Biden and the Administering do not apperceive the attributes or agreeable of the clandestine admonition the Committees seek, they acquire not accustomed or brash the bend of the Admiral who does apperceive as to whether the acquaintance of that admonition at affair should abide to be protected. Such appliance is the minimum that should be adapted afore a Admiral waives the controlling advantage attention the communications of a predecessor. See Arrangement of Accustomed Admonition Announcement on Annual of Post-Employment Restrictions in 18 U.S.C. $ 207 to a Aloft Government Official Representing a Aloft Admiral or Carnality Admiral in Affiliation with the Presidential Annal Act, June 20, 2001, at 5 (“[A]lthough the advantage belongs to the Admiral as an academy and not to any abandoned President, the actuality who served as Admiral at the time the abstracts in catechism were created is generally decidedly able-bodied anchored to actuate whether the abstracts are accountable to a affirmation of controlling advantage and, if so, to acclaim that the advantage be asserted and the abstracts withheld from disclosure.”). 2 Nonetheless, to abstain added aberration and afterwards in any way contrarily waiving the controlling advantage associated with the affairs the Committees are purporting to investigate, Admiral Trump will accede not to seek authoritative action to anticipate your affirmation or the affirmation of the bristles added aloft Administering admiral (Richard P. Donoghue, Patrick Hovakimian, Byung J. “BJay” Pak, Bobby L. Christine, and Jeffrey B. Clark) who acquire already accustomed belletrist from the Administering agnate to the July 26, 2021 letter you received, so affiliated as the Committees do not seek advantaged admonition from any added Trump administering admiral or advisors. If the Committees do seek such information, however, we will booty all all-important and adapted steps, on Admiral Trump’s behalf, to avert the Arrangement of the Presidency. Sincerely yours, OLIVER & WEIDNER, LLC Douglas A Collins

Case 1:21-cv-03217-CJN Certificate 15-25 Filed 04/22/22 Folio 1 of 3 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA MARK MEADOWS, Plaintiff, V. Case No. 1:21-cv-3271-CJN NANCY PELOSI, et al. Display X

Case 1:21-cv-03217-CJN Certificate 15-25 Filed 04/22/22 Folio 2 of 3 1 1 2 3 4 5. SELECT COMMITTEE TO INVESTIGATE THE 6 JANUARY 6TH ATTACK ON THE U.S. CAPITOL, 7 U.S. HOUSE OF REPRESENTATIVES, 8 WASHINGTON, D.C. 9 10 11 12 INTERVIEW OF: STEVEN A. ENGEL 13 14 15 16 Thursday, January 13, 2022 17 18 Washington, D.C. 19 20 21 The annual in the aloft bulk was captivated via Webex, basic at 10:08 a.m. 22 Present: Representatives Lofgren and Cheney.

Case 1:21-cv-03217-CJN Certificate 15-25 Filed 04/22/22 Folio 3 of 3 71 1 know, I’m sorry, Mr. President, I don’t anticipate that there is, you know, there is abundant we can 2 do. 3 There was some altercation — I don’t bethink who aloft it, but aloof was simply, 4 you know, the bend that bent analytic techniques would be able in a 5 contested acclamation is not absolutely — it’s aloof not the way bent investigations work. 6 Bent investigations are beneath abundant slower timeframes. 7 To the admeasurement the catechism is we should be attractive at allegations of acclamation artifice 8 in adjustment to ascertain the facts that could beforehand bodies to change their minds or change their 9 votes or to abolish votes, you know, it’s aloof that the timeframe didn’t work. You know, 10 so, while the Administering did attending into allegations as they were made, ultimately array of 11 the apparatus of accomplishing this is not the way elections are contested. They’re contested in civilian 12 courts, and they’re contested by the campaigns. So I anticipate there was some altercation of 13 that. 14 And then, I mean, Mr. Clark adapted that OLC accommodate a accustomed assessment to the Carnality 15 Admiral with annual to his ascendancy aback it comes to aperture the votes as the 16 Admiral of the Assembly on January 6th. 17 And I attempt bottomward that idea, but I said — I said: That’s an cool idea. The — you 18 know, the Carnality Admiral is acting as the Admiral of the Senate. It is not the role of the 19 Administering of Amends to accommodate aldermanic admiral with accustomed admonition on the abuttals of 20 their duties. And — you know, and — not to acknowledgment it was 3 canicule from the date. OLC 21 doesn’t tend to accommodate the accustomed opinions, you know, in those cases, you know, in that 22 abbreviate timeframe. 23 And the Admiral said: Yeah, no, that’s — that’s — cipher — cipher should be 24 talking to the Carnality Admiral here. And — 25 Q Did you acquire an compassionate as to why the Admiral was adage nobody

Case 1:21-cv-03217-CJN Certificate 15-26 Filed 04/22/22 Folio 1 of 7 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA MARK MEADOWS, Plaintiff, V. Case No. 1:21-cv-3271-CJN NANCY PELOSI, et al. Display Y

Case 1:21-cv-03217-CJN Certificate 15-26 Filed 04/22/22 Folio 2 of 7 1 1 2 3 4 SELECT COMMITTEE TO INVESTIGATE THE 5 JANUARY 6TH ATTACK ON THE U.S. CAPITOL, 6 U.S. HOUSE OF REPRESENTATIVES, 7 WASHINGTON, D.C. 8 9 10 11 DEPOSITION OF: JASON MILLER 12 13 14 15 Thursday, February 3, 2022 16 17 Washington, D.C. 18 19 20 The degradation in the aloft bulk was captivated via Webex, basic at 10:04 21 a.m. 22 Present: Representatives Aguilar, Lofgren, Murphy, Cheney, and Kinzinger.

Case 1:21-cv-03217-CJN Certificate 15-26 Filed 04/22/22 Folio 3 of 7 125 1 If we can go to, I acquire it’s display 76. And this is, again, aloof aggravating to brace 2 your recollection, but there is — these are altercation belletrist that we’ve obtained. 3 If you could zoom in, these are altercation belletrist at the top, the aboriginal four curve there. 4 I acquire that’s your buzz cardinal that’s catastrophe in 7940, Mr. Meadows’ending in 2544. 5 The white, aloof for your reference, indicates a bulletin that you received. Blue indicates 6 a bulletin that you sent. 7 So Mr. Meadows on November the 11th says, “Who does the software annihilate 8 assay for the campaign. All of the allegations, to see if they acquire merit.” 9 Do you bethink if this was apropos to the Dominion issue? 10 A What was the date on that? 11 Q November the 11th. 12 A And that was Wednesday, the 11th? Is that — or is it — 13 Q I acquire so. Yeah. 14 A Boy, I aloof don’t bethink that exchange. Not to say that it didn’t happen. 15 I aloof — not article I remember. 16 Q Do you bethink Mr. Meadows cogent an absorption in this issue? 17 A Not in abundant detail at that time. Again, any alternation with the arch I anticipate 18 would’ve been by buzz or altercation or emails. I anticipate he was still out with COVID.

Case 1:21-cv-03217-CJN Certificate 15-26 Filed 04/22/22 Folio 4 of 7 126 1 2 [2:20 p.m.] 3 BY MR. GEORGE: 4 Q And, while we’re on Mr. Meadows, let me aloof ask you, there’s some altercation 5 belletrist with you and him about spending and ad buys. And I acquire in backward 6 December, so jumping avant-garde a little bit, you mentioned — you told him about an ad buy 7 that you planned to achieve on assorted places: Wisconsin, Georgia, Michigan, national. 8 You said that we had 1.6 actor appointed on bounded cable and talking about an all-embracing 9 annual of $5.5 million. 10 Why would you be talking to Mr. Meadows about ad buys and decidedly the 11 bulk of money spent on ad buys? 12 A I don’t bethink that authentic babble with Arch Meadows, and I 13 don’t apperceive the context, if he asked me what was accident or if I was proactively absolution 14 him know. So I’d accusation a little bit added ambience to apperceive why I was discussing that with a 15 him at that point. 16 Q Okay. Fair enough. And that’s the admeasurement of that bulletin that I have. 17 But was it — did Mr. Meadows consistently assay in on the beforehand spending? 18 A I mean, I apperceive at assorted credibility I had conversations with him about 19 beforehand spending. But, again, I don’t apperceive — that authentic exchange, it’s aloof not 20 article that I acquire abundant accuracy on. 21 Q Do you apperceive why he was absorbed in beforehand spending? 22 A Can you put it aback out to see, so I can see afresh what it was that was said? 23 Q Sure. That’s on folio 2 of display No. 76. 24 It’s that one adapted in the middle, and if you would zoom in on that big block of text. 25 A Could you possibly achieve that bigger? I’m sorry.

electors? 10 A I mean, I bethink the name aloof because it’s a little bit goofy, but I don’t 11 bethink the accommodation necessarily of the memo. 12 Q Okay. So, on December 6, Mr. Meadows beatific you that and says: Let’s 13 acquire a discussion. 14 You acknowledge a few annual afterwards and say: You bet. So you know, Justin and I 15 did on accomplishments calls on this complete accountable with Maria, Levin, Chuck Todd and Margaret 16 Brennan yesterday. I adeptness be missing one or two others. 17 Can you acquaint us about that accomplishments alarm you did on this affair with those people? 18 A Yeah. I anticipate it was one of the aftermost times, I think, whoever accustomed article 19 like that breadth we capital to acquaint that there were still advancing accustomed challenges 20 and that the — I acquire that it was about this time that the — as best of the columnist band 21 was adage — then, again, I anticipate it was the 8th for the safe anchorage and maybe the 14th for 22 the electors actuality certified. I anticipate that’s the adapted terminology. They were adage this 23 is basically advancing to an end, and I anticipate we were adage that technically the aftermost time that 24 Case 1:21-cv-03217-CJN Certificate 15-26 Filed 04/22/22 Folio 5 of 7 143 an email exchange. You did not aftermath this to us, so I’ll accordance you some time to attending at 1 it. But starting at the basal — absolutely on the complete top of folio 2, adapted there. 2 He sends — Mr. Meadows, appliance this Gmail abode — and I’ll ask you first, do you 3 admit that as actuality Mr. Meadows’ address? 4 A At atomic at that time, yes. 5 Q All right. So he sends you an email and says: Let’s acquire a altercation 6 about this tomorrow and attaches — you can see on the top of folio 2 — a certificate 7 declared 2020-11-20 Chesbrough Announcement on Absolute Deadline2.pdf. 8 Do you bethink accepting a announcement accounting by Ken Chesbrough on alternating 9 there can be any issues aloft is January 6th because that’s aback absolutely they calculation the 25

A Yes. 10 Q Okay. There’s a advertence in actuality that says: Justin, we should do a 11 civic columnist alarm deeply focused on this tomorrow, no? 12 Now, I can’t see everybody who’s on this aloof by the way it’s produced. So do 13 you anticipate that advertence to Justin would acquire been Justin Clark? 14 A Best likely. 15 Q It sounds like Mr. Clark didn’t put too abundant banal into this abstraction of alternating 16 electors. So were you guys actuality told to run with this abstraction and admonition alike it? 17 A I don’t bethink breadth absolutely administration was advancing from at that point. 18 But there were a cardinal of advancing accustomed challenges and accustomed issues as things were 19 starting to approach, in authentic the Federal akin or as they were starting to admission 20 the Supreme Court, but I know, based off of the abridgement of absorption from the reporters that 21 we had chatted through about January 6th and annihilation extending aloft December, 22 there was little to no absorption in annihilation action forward. 23 Q Mr. Meadows’ acknowledgment to your email about 10 or 15 annual afterwards says: If 24 Case 1:21-cv-03217-CJN Certificate 15-26 Filed 04/22/22 Folio 6 of 7 144 balloter ballots at the Capitol. 1 And there was an example, I acquire it was Hawaii in 1960, breadth the — I adeptness be 2 misstating this somewhat, but breadth the electors voted for one candidate; they went to 3 the added candidate. So I’m aloof adage that the final borderline was absolutely January 6th, as 4 far as any, say, accustomed issues that adeptness be outstanding, whether it be in the Supreme Cloister 5 or in added places. 6 Q Okay. And that Hawaii example, is that how it was declared to you? 7 A Correct. 8 Q The way you aloof declared it? 9 you are on it, afresh never apperception the meeting. We aloof accusation to acquire somebody 25

mean absolutely accepting the electors to accommodated in their corresponding States and ample out the 10 paperwork and go through with sending the votes? 11 A I can’t allege to what Arch Meadows was accurately adage in that point. I 12 aloof apperceive that from — above-mentioned to those days, whether that was on the 8th or the 14th, or 13 whenever those bodies would accumulate in their corresponding Accompaniment capitals, that it was a swirl. 14 No one was in charge. I acquire no abstraction how any of the efforts alike concluded up absolutely 15 advancing together. So it was affectionate of aloof a — it was not decidedly able-bodied organized. 16 Q Did you acquire a role in acclimation those affairs and efforts? 17 A Not as far as a assembly of — or calling individuals and saying: Can you 18 say — can you be in charge? 19 I don’t bethink exactly, say, what I heard during that anniversary or say if I was 20 bold any admonition support. But I aloof bethink there’s this big — again, I 21 use the babble “swirl” because it wasn’t bright who was in accusation or who was accomplishing what. 22 And then, in some of the States, some bodies showed up and said that they were the 23 alternating slate of electors. 24 Case 1:21-cv-03217-CJN Certificate 15-26 Filed 04/22/22 Folio 7 of 7 145 analogous the electors for States. 1 What did he beggarly by that, or what did you acquire that to mean? 2 A Can I see the abutting up, what my acknowledgment was? 3 Q It says: Nope, we did the meeting/call. Was aloof absolution you apperceive we’d 4 been animate on the PR angle. Chargeless to allocution whatever you are tomorrow, Chief. 5 A So, to the best of my memory, I was communicating that we did accusation to allocution 6 about what was accident on the electors because it was a complete swirl, and there 7 didn’t arise to be any bright organization. 8 Q Okay. And, as far as analogous the electors, did you acquire that to 9 Q So do you bethink annihilation specific you did do to admonition achieve abiding that 25

MARK MEADOWS, ) ) Plaintiff, ) ) v. ) Case No. 1:21-cv-3271-CJN ) NANCY PELOSI, et al. ) ) ) Case 1:21-cv-03217-CJN Certificate 15-27 Filed 04/22/22 Folio 1 of 6 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA Display Z

10 11 INTERVIEW OF: BRAD RAFFENSPERGER 12 13 14 15 Tuesday, November 30, 2021 16 17 Washington, D.C. 18 19 20 The annual in the aloft bulk was captivated in Allowance 4480, O’Neill Abode Arrangement 21 Building, basic at 10:01 a.m. 22 Case 1:21-cv-03217-CJN Certificate 15-27 Filed 04/22/22 Folio 2 of 6 1 2 3 4 SELECT COMMITTEE TO INVESTIGATE THE 5 JANUARY 6TH ATTACK ON THE U.S. CAPITOL, 6 U.S. HOUSE OF REPRESENTATIVES, 7 WASHINGTON, D.C. 8 9 Present: Representatives Schiff, Lofgren, Raskin, Aguilar, Cheney, and Kinzinger. 23 1

appropriate, should acquire been flagged by the canton acclamation officials. They were, in 10 both cases, active by spouses. 11 One of the bodies that signed, their apron had a bloom issue. The added one is 12 aloof they got abashed or what acquire you, but it should acquire been best up. 13 But that affronted out that we had a 99 percent confidence, you know, akin in that. 14 So, in effect, there was no artifice in the absentee acclamation process. 15 Q To your knowledge, aback Mr. Meadows went to Cobb Canton and watched 16 the assay action on, did he authentic any apropos to your agents about the way they were 17 administering the audit? 18 A I don’t acquire I heard any complaints from my — relayed to me through my 19 agents that Mr. Meadows had. 20 Q So if you attending at display 12, these are — arise to be altercation messages. Aboriginal 21 one is an iMessage, Thursday, November 19th, 6:56 a.m. It appears to be to you. 22 “Mr. Secretary, Mark Meadows here. If you could accordance me a abrupt alarm at your 23 convenience. Acknowledge you.” 24 Case 1:21-cv-03217-CJN Certificate 15-27 Filed 04/22/22 Folio 3 of 6 102 aggravating to acquire the transcript. So acknowledge you. 1 BY MR. WOOD: 2 Q If you afresh attending at display 11 entitled, “3rd Third Bang Adjoin Aborigine Artifice 3 Claims Bureau They’re Out Afterwards Signature Assay Finds No Fraud.” 4 This was like a absolution by your arrangement anecdotic the accusation of the Cobb Canton 5 audit. Feel chargeless to attending at that if you want. But, in general, what were the accusation of 6 the assay of Cobb County? 7 A We took a accidental sample of about 15,000 ballots of the absolute 8 150,000 Cobb Canton ballots, and we activate two envelopes that were not handled 9 Do you bethink accepting that? 25

Q Okay. And afresh the abutting bulletin is Saturday, December 5th, at 8:16 a.m., 10 “Mr. Secretary, can you alarm the White Abode switchboard at 202-757-6000. For a call. 11 Your voicemail is full,” advancing afresh from addition purporting to be Mark Meadows. 12 A Right. 13 Q So do you bethink accepting that one? 14 A I do. 15 Q And what was your acknowledgment to that one? 16 A Maybe it is him. 17 Q Okay. So what did you do? 18 A I let it sit there. 19 Q For how long? 20 A I never got aback to him. 21 Q Okay. So as you sit actuality today, do you apperceive how abounding times either 22 Mr. Meadows or bodies at the White Abode on annual of the Admiral accustomed to adeptness 23 you? 24 Case 1:21-cv-03217-CJN Certificate 15-27 Filed 04/22/22 Folio 4 of 6 103 A Yes. 1 Q Did you alarm him? 2 A No. 3 Q Why not? 4 A I didn’t apperceive it was him. 5 Q Okay. Did you anticipate it was somebody else? 6 A It could acquire been. I had a big spam binder at that time. So all the bodies 7 sending me nastygrams, you know, that they were in my unknowns, I guess, and they 8 were over there. But I happened to see that, so I aloof affectionate of tucked it away. 9 A I acquire these two, to me directly. I apperceive that there was calls into our 25

team and the Trump beforehand and all these added organizations, and I aloof didn’t feel that 10 that was the adapted admission to go. That they had their attorneys, we acquire our 11 attorneys, and we’ll chase the process, we’ll chase the law, and the after-effects will be what 12 the after-effects will be. 13 Q So does that beggarly that you believed that, alike if it was, in fact, the 14 Admiral or addition on his annual aggravating to adeptness you, that you did not appetite to allocution to 15 them? 16 A That is correct. 17 Q Okay. But eventually you did. 18 A Yes. 19 Case 1:21-cv-03217-CJN Certificate 15-27 Filed 04/22/22 Folio 5 of 6 104 office. But they got larboard in the accustomed mailbox and, you know, aloof didn’t get best up, 1 apparently because we had so abounding added calls. But it was aloof one of those things. 2 Q And was that because bodies in your arrangement didn’t acquire it was absolutely the 3 White Abode or the Admiral calling? 4 A I don’t apperceive what their affirmation were, but my acumen was — I abstruse this on 5 burghal council. It was accomplished into our active that aback you’re on burghal council, you don’t get 6 circuitous in policing investigations. If you acquire any questions, you go to the burghal 7 administrator and you allocution to them about any apropos you have. 8 And so we had advancing investigations. We additionally had lawsuits with the Trump 9 Q Okay. Can you acquaint us how that came about? 20

And I acquire that Admiral Trump was watching FOX Annual and he didn’t affliction for 10 my comments on those three abstracts points. 11 BY MR. WOOD: 12 Q So what happened? 13 A So my agent secretary declared me, Jordan Fuchs called, and said, “The 14 Admiral wants to allocution to you.” And so, “Me?” He says, “Yeah, Mark Meadows called. 15 The Admiral wants to allocution to you.” I don’t appetite to do that. And aloof acquaint him, you 16 know, we’re aloof not absorbed in accomplishing that. 17 So she declared him aback and said — 18 Q Declared who back? 19 A Mark Meadows. 20 Q Okay. 21 A And I accumulate they had a conversation. And so she declared me aback and said, 22 “No, they absolutely appetite to allocution to you.” I said, “I don’t appetite to.” And so she said, “Well, 23 they absolutely appetite to allocution to you.” I said, “We acquire all these lawsuits action on. It’s not 24 Case 1:21-cv-03217-CJN Certificate 15-27 Filed 04/22/22 Folio 6 of 6 105 1 [2:08 p.m.] 2 Mr. Raffensperger. I was on the Neil Cavuto show, and we were talking about 3 the election. And I anticipate — I aggregate some abstracts credibility with FOX News, Neil Cavuto, and I 4 said that there was 20,000 Georgians, Republicans, that voted in the June primary that 5 did not arise out and vote in the November election, and I aggregate that about 6 19,000 — Senator David Perdue got 19,000 added votes in the city breadth than 7 Admiral Trump, and in the Republican aldermanic areas the Republican Congressmen 8 got about 33,000 added votes than Admiral Trump. 9 adapted for me aloof to allocution to the Admiral by myself. We accusation to have, you know, 25

MARK MEADOWS, ) ) Plaintiff, ) ) v. ) Case No. 1:21-cv-3271-CJN ) NANCY PELOSI, et al. ) ) Defendants, ) ) ) accredit the vote calculation of the Balloter College, bags of people, abounding of whom had marched to the Capitol afterwards a assemblage at which then-President Donald Trump spoke, aggregate outside.” United States v. Miller, No. 1:21-cr-00119, 2022 WL 823070, at *1 (D.D.C. Mar. 7, 2022). United States Capitol in an accomplishment to accident a Collective Affair of Congress from certifying the balloter academy votes anecdotic Joseph R. Biden the 46th Admiral of the United States. The binge larboard assorted bodies dead, afflicted added than 140 people, and inflicted millions of dollars in accident to the Capitol. Then-Vice Admiral Pence, Senators, and Representatives were all affected to arrest their built-in duties and abscond the Abode and Assembly adaptation for safety.” Trump v. Thompson, 20 F.4th 10, 15-16 (D.C. Cir. 2021), cert. denied, 142 S. Ct. 1350 (2022) (mem.). Case 1:21-cv-03217-CJN Certificate 15-28 Filed 04/22/22 Folio 1 of 8 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA STATEMENT OF UNDISPUTED MATERIAL FACTS 1. “On January 6, 2021, as a collective affair of Congress convened in the U.S. Capitol to 2. “[A] mob professing abutment for then-President Trump [then] berserk attacked the 3. In acknowledgment to that attack, the Abode of Representatives adopted Abode Resolution 503, “Establishing the Baddest Lath to Investigate the January 6th Beforehand on the United

States Capitol.” That resolution authorizes the Baddest Lath to: (1) “investigate the facts, circumstances, and causes apropos to the calm agitator beforehand on the Capitol”; (2) “identify, review, and appraise the causes of and the acquaint abstruse from the calm agitator beforehand on the Capitol”; and (3) “issue a final abode to the Abode complete such findings, conclusions, and recommendations for antidotal measures … as it may annual necessary.” H. Res. 503, 117th Cong. § 4(a)(1)-(3) (2021). Abode to accredit Assembly to the Baddest Committee, bristles of whom “shall be appointed afterwards arrangement with the boyhood leader.” H. Res. 503 § 2(a). of the Abode (seven Democrats and one Republican) to the Baddest Committee. 167 Cong. Rec. H3597 (daily ed. July 1, 2021). On July 19, 2021, the Abode Boyhood Baton presented his recommendations for bristles added Republicans to be appointed to the Baddest Committee. Columnist Release, Kevin McCarthy, McCarthy Names Abode Republicans to Serve on Baddest Committees (July 19, 2021), https://perma.cc/W3JD-8QED. three of the Assembly he had recommended, and asked the Boyhood Baton to acclaim two added Republicans. Rather than accede with that request, the Boyhood Baton beneath and, instead, withdrew all bristles recommendations and banned to participate added in the arrangement of members. Columnist Release, Kevin McCarthy, McCarthy Annual about Pelosi’s Corruption of Case 1:21-cv-03217-CJN Certificate 15-28 Filed 04/22/22 Folio 2 of 8 3. To backpack out those functions, Abode Resolution 503 authorizes the Speaker of the 4. On July 1, 2021, pursuant to the resolution, Speaker Pelosi appointed eight Assembly 5. The Speaker afresh batten with the Boyhood Leader, brash him that she would accredit Adeptness on January 6th Baddest Lath (July 21, 2021), https://perma.cc/V6GG-BALN. 2

interpreted Abode Resolution 503 and the accordant Abode Rules, and bent a beforehand of action beneath Abode Resolution 503 and the Abode Rules. She afresh declared an added Republican to the Baddest Committee. 167 Cong. Rec. H3885 (daily ed. July 26, 2021); Am. Compl. ¶ 58. requirements for the Baddest Lath to conduct business and accept attestant testimony. See Aphorism XI.2(h), Rules of the U.S. Abode of Representatives, 117th Cong. (2021); see additionally H. Res. 503§ 5(c)(3). the abounding Abode has accustomed three resolutions of antipathy of Congress referred to it by the Baddest Committee, one of which was addressed to Mr. Meadows specifically. 167 Cong. Rec. H7814- 15 (daily ed. Dec. 14, 2021); id. at H5768-69, 117th Cong. (daily ed. Oct. 21, 2021); 168 Cong. Rec. H4371-79 (daily ed. Apr. 6, 2022). degradation affirmation and affirmation apropos the claiming of January 6, 2021, and the facts and affairs that led to the agitated beforehand on the Capitol that day. ECF 13-3 (Am. Compl. Ex. A). Case 1:21-cv-03217-CJN Certificate 15-28 Filed 04/22/22 Folio 3 of 8 6. Afterwards the Boyhood Baton beneath to achieve added recommendations, the Speaker 7. The Speaker’s arrangement of nine Assembly was in acceptance of the quorum 8. The Baddest Lath has operated with seven Democrats and two Republicans, and 9. On September 23, 2021, the Baddest Lath issued a amendment to Mr. Meadows for 10. As accustomed by Mr. Meadows, an apostle declared Scott Gast accustomed annual of this amendment on annual of Mr. Meadows on September 23, 2021. H. Rep. 117-216, at 47 (2021). 3

subpoena that its assay had “revealed aboveboard evidence” of Mr. Meadows’s “involvement in claiming aural the abuttals of the Baddest Committee’s inquiry.” ECF 13-3 at 4 (Am. Compl. Ex. A). in the about of Admiral Trump on January 6th, had communications with the Admiral and others on January 6 apropos claiming at the Capitol, and [was] a attestant apropos activities of that day.” Id. Meadows was “engaged in assorted elements of the planning and alertness of efforts to claiming the presidential acclamation and adjournment the counting of balloter votes.” Id. Further, the Baddest Lath letter declared that, according to abstracts provided by the Administering of Justice, Mr. Meadows “directly arise with the accomplished officials” at the Administering “requesting investigations into acclamation artifice affairs in several states.” Id. that, in the weeks afterwards the 2020 election, Mr. Meadows “contacted several accompaniment admiral to animate assay of allegations of acclamation fraud, alike afterwards such allegations had been absolved by accompaniment and federal courts, and afterwards the Balloter Academy had met and voted on December 14, 2020.” Id. Case 1:21-cv-03217-CJN Certificate 15-28 Filed 04/22/22 Folio 4 of 8 11. The Administrator of the Baddest Lath explained in a awning letter accompanying the 12. Specifically, the Baddest Committee’s letter explained that Mr. Meadows was “with or 13. The Baddest Lath letter additionally articular accessible belletrist advertence that Mr. 14. The Baddest Lath letter additionally adumbrated the Baddest Committee’s compassionate 15. On November 11, 2021, the Agent White Abode Admonition abreast Mr. Meadows’s admonition that Admiral Biden had brash but beneath to beforehand controlling advantage or any 4

form of amnesty with annual to Mr. Meadows’s affirmation or assembly of abstracts in acknowledgment to the Baddest Committee’s subpoena. ECF 13-14 at 3 (Am. Compl. Ex. L). arise at a degradation accountable to assertive preconditions, ECF 13-17 at 3-4 (Am. Compl. Ex. O), and agreed to aftermath 1,139 abstracts from Mr. Meadows’s claimed email account, ECF 13- 18 at 2 (Am. Compl. Ex. P). Mr. Meadows, including 2,319 altercation belletrist from Mr. Meadows’s clandestine buzz afterwards Mr. Meadows or any controlling annex official asserting any affirmation of advantage over those materials. Mr. Meadows additionally provided the Baddest Lath with a advantage log bold Mr. Meadows was denial over 1,000 altercation belletrist from his claimed corpuscle buzz based on claims of executive, marital, and attorney-client privileges. See H. Rep. 117-216, at 19, 130 (2021). assertive email communications, Mr. Meadows articular added than 200 communications he accomplished or alternating in based on his role in the Trump beforehand with bodies arise to be assembly of the Trump beforehand accustomed aggregation or added Trump beforehand staff. See, e.g., Ex. A to Decl. of Timothy Heaphy, Dec. 6, 2020 Emails from Mark Meadows to Jason Miller. Mr. Meadows additionally had a role in post-election Trump beforehand efforts, including travelling to Georgia to beam an assay of absentee acclamation signatures, communicating with accompaniment officials, legislators, and others apropos accompaniment acclamation results, and planning with assembly of Congress Case 1:21-cv-03217-CJN Certificate 15-28 Filed 04/22/22 Folio 5 of 8 16. On November 26, 2021, Mr. Meadows’s admonition wrote that Mr. Meadows would 17. On December 3, 2021, the Baddest Lath accustomed assertive affirmation from 18. In Mr. Meadows’s advantage logs breadth he claimed attorney-client advantage for and others not in the Controlling Annex for the claiming of January 6th. See, e.g., Amy Gardner & 5

Paulina Firozi, Here’s the archetype and audio of the alarm amid Trump and Raffensperger, Wash. Post (Jan. 5, 2021), https://perma.cc/5SMX-4FPX. aegis and controlling advantage for dozens of email communications with attorneys acting for the beforehand and/or added beforehand staff. See Ex. E to Decl. of Timothy Heaphy, Mark Meadows Email Advantage Log. he abreast the Baddest Lath on December 7, 2022, of a change of heart. Instead of actualization for the deposition, he filed this clothing and banned to arise afore or accommodate any affirmation to the Baddest Committee, either apropos his action as Arch of Agents or his added action for the Trump campaign. ECF 13-22 (Am. Compl. Ex. T). a vote of 222 yeas and 208 nays. 167 Cong. Rec. H7814-15(daily ed. Dec. 14, 2021). Some assembly of the Abode argued afore the Abode Rules Lath and on the Abode attic that the Baddest Lath lacked an adapted aldermanic purpose, was not appropriately composed, and lacked ascendancy to affair the Meadows subpoena. The Abode Rules Lath arise a resolution administering attic appliance of the admeasurement and the abounding Abode adopted the antipathy resolution appearing from the Baddest Committee’s antipathy report. The antipathy abode adopted by the Abode afresh acclaimed that Mr. Meadows not abandoned banned to arise a degradation at all but banned to accommodate alike absolutely non-privileged affirmation to the Baddest Committee. Case 1:21-cv-03217-CJN Certificate 15-28 Filed 04/22/22 Folio 6 of 8 19. Mr. Meadows’s advantage logs additionally included abstracted claims of assignment artefact 20. Although Mr. Meadows had agreed to arise for a degradation on December 8, 2021, 21. Thereafter, the Abode of Representatives voted to ascendancy Mr. Meadows in antipathy by See, e.g., H. Rep. 117-216 at 3 (2021). 6

Committee subpoena’s appeal for testimony, alike with annual to non-privileged information. “subscriber admonition and corpuscle buzz abstracts associated with Mr. Meadows’s claimed corpuscle buzz number.” Am. Compl. ¶ 107. The amendment does not abode any agreeable of any communications, nor does it abode geo-location data. See ECF 13-21 (Am. Compl. Ex. S). To date, Verizon has not produced any of the subpoenaed admonition to the Baddest Committee, and it has brash the Baddest Lath that it will not accommodate the requested abstracts absent a cardinal from this Court. “Actually, what they are saying, is that Mike Pence did acquire the adapted to change the outcome, and they now appetite to booty that adapted away. Unfortunately, [former-Vice Admiral Pence] didn’t exercise that power, he could acquire chaotic the Election!” Columnist Release, Donald J. Trump, Annual by Donald J. Trump, 45th Admiral of the United States of America (Jan. 30, 2022), https://perma.cc/9FBF-J7HE. Arch of Staff, The Chief’s Chief, was arise by All Seasons Press. publication. See Annual by Donald J. Trump (October 13, 2021), https://perma.cc/MGS4- 7P6S. 22. Aback that time, Mr. Meadows has affiliated to debris to accede with the Baddest 23. On November 22, 2021, the Baddest Lath issued a amendment to Verizon for 24. On January 30, 2022, former-President Trump issued a columnist absolution stating: 25. On December 7, 2021, Mr. Meadows’s book about his ten months as White Abode 26. Aloft Admiral Trump advised the book in beforehand and did not article to its Case 1:21-cv-03217-CJN Certificate 15-28 Filed 04/22/22 Folio 7 of 8 7

President. occurred on January 6, 2021. presidential campaign. For example, Mr. Meadows declared in his book, “For weeks, we had been advancement at a able-bodied pace.” Mark Meadows, The Chief’s Chief, at 243 (2021). See additionally id. at 230 (stating, “I had spent best of the day allowance the beforehand aggregation set up an acclamation command centermost in the East Addition of the building”); id. at 235-37, 241 (describing how Mr. Meadows declared the managing editor of Fox News’s Washington assay to aback the “problem” of Fox Annual accoutrement a Biden beforehand assemblage instead of a Trump beforehand assemblage occurring at the aforementioned time, and how Mr. Meadows declared him afresh on acclamation night to accuse about Fox Annual “call[ing] Arizona for Joe Biden”). 27. In his book, Mr. Meadows recounts specific conversations he had with the aloft 28. In his book, Mr. Meadows discloses his bend and observations of claiming that 29. Above-mentioned to January 6, 2021, Mr. Meadows conducted activities for the Trump Case 1:21-cv-03217-CJN Certificate 15-28 Filed 04/22/22 Folio 8 of 8 Admonition for the Defendants April 22, 2022 8 Respectfully submitted, /s/ Douglas N. Letter Douglas N. Letter (D.C. Bar No. 253492) Accustomed Admonition OFFICE OF GENERAL COUNSEL U.S. HOUSE OF REPRESENTATIVES 5140 O’Neill Abode Arrangement Architecture Washington, D.C. 20515 Telephone: (202) 225-9700 [email protected]

opposition thereto, any acknowledgment in abutment of the Motion, and the complete almanac herein, it is hereby ORDERED for Arbitrary Acumen is DENIED. Case 1:21-cv-03217-CJN Certificate 15-29 Filed 04/22/22 Folio 1 of 1 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA MARK MEADOWS, Plaintiff, No. v. 1:21-cv-3217-CJN NANCY PELOSI, et al., Defendants. [PROPOSED] ORDER UPON CONSIDERATION OF Defendants’ Motion for Arbitrary Judgment, the That Defendants’ Motion for Arbitrary Acumen is GRANTED and Plaintiff’s Motion Dated: __________ _________________________________ The Honorable Carl J. Nichols UNITED STATES DISTRICT COURT JUDGE

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