Judge Carter then turned to Donald Trump’s efforts to overturn the election, identifying Trump’s effort to install Jeffrey Clark as attorney general; numerous attempts to persuade state officials and legislatures to alter the election results; and a plan, coupled with sustained pressure on Vice President Pence, to ensure that certified slates of electoral votes in several key states would not be counted on January 6. The decision reached specific conclusions on the crime-fraud exception. First, Judge Carter addressed the same provision of criminal law that I had referenced in support of our
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