The Defendant's Plan to Obstruct the Electoral Vote Through Deceit of State Officials

The plan capitalized on ideas presented in memoranda drafted by co-conspirator five, an attorney who was assisting the defendant's campaign with legal efforts related to a recount in Wisconsin. Under the plan, the submission of these fraudulent slates would create a fake controversy at the certification proceeding and position the vice president presiding as president of the Senate for January 6th. The memorandum suggested that the defendant's electors in six purportedly contested states, Arizona, Georgia, Michigan, Nevada, Pennsylvania, and Wisconsin should meet and mimic best their actions were legitimate Biden electors. On January 6, the vice president should open and count the fraudulent votes setting up a fake controversy that would derail the proper certification of Biden