b. The Defendant and co-conspirators organized fraudulent slates of electors
in seven targeted states (Arizona, Georgia, Michigan, Nevada, New
Mexico, Pennsylvania, and Wisconsin), attempting to mimic the procedures
that the legitimate electors were supposed to follow under the Constitution
and other federal and state laws. This included causing the fraudulent
electors to meet on the day appointed by federal law on which legitimate
electors were to gather and cast their votes; cast fraudulent votes for the
Defendant; and sign certificates falsely representing that they were
legitimate electors. Some fraudulent electors were tricked into participating
based on the understanding that their votes would be used only if the
Defendant succeeded in outcome-determinative lawsuits within their state,
which the Defendant never did. The Defendant and co-conspirators then
caused these fraudulent electors to transmit their false certificates to the
Vice President and other government officials to be counted at the
certification proceeding on January 6.
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