Uncovering the Truth, and then again during a January 5, 2021 episode of the War Room podcast. The above identified misstatements violate RPC 4.1 and RPC 8.4(c). At various times, respondent claimed that 65,000 or 66,000 or 165,00 underage voters illegally voted in the Georgia 2020 election. The Georgia Office of the Secretary of State undertook an investigation of this claim. It compared the list of all of the people who voted in Georgia to their full birthdays. The audit revealed that there were zero (0) underage voters in the 2020 election. While a small number of voters (four) had requested a ballot prior to turning 18, they all turned 18 by the time the election was held in November 2020. Respondent does not expressly deny the truth of this information. Instead respondent claims that he reasonably relied on “expert” affidavits, including one by Bryan Geels, in believing the facts he stated were true. None of these affidavits were provided to the Court. Respondent claims that Mr. Geels opined that there were “more than 65,000 individuals who voted had registered to vote prior to their 17th birthday” (Giuliani affidavit ¶62). At a bare minimum, the statement attributed to Mr. Geels does not support respondent’s claim that the number of underage teenage voters was 165,000. But respondent’s statement about what was said to him is insufficient as to all of respondent’s statements on underage voters for other reasons. We do not have the affidavit that respondent claims Mr. Geels prepared and he relied on. We do not know when the affidavit was provided to respondent. We do not know what data or source information Mr. Geels relied on in reaching his conclusion, nor do we know what methodology Mr. Geels used for his analysis. Other than respondent calling him an “expert,” we do not know Mr. Geels' actual area of expertise or what qualifies him as such (see Guide to NY Evid Rule 7.01, Opinion of Expert 18