claimed with respect to the number of undocumented noncitizens who voted in Arizona that “the bare minimum is 40 or 50,000, the reality is probably about 250,000 . . . .” He then used these unsubstantiated figures to support a claim that Trump won Arizona by about 50,000 votes (id.). After the New Year, in another episode of the War Room podcast, the number of “illegal immigrants” respondent was claiming had voted illegally changed yet again. This time respondent claimed there were 32,000 of such illegal votes. Respondent admitted in the podcast that he did not have the “best sources” to justify this estimate, but stated that he was relying on “newspaper and records” for his claims (id.). Respondent later either reiterated and/or agreed with statements made by others, that undocumented noncitizens had voted in Arizona in the 2020 election; he made these statements during the March 9th, 11th, and April 27, 2021 broadcasts of his Chat with the Mayor radio show and on April 21, 2021 during an appearance on the War Room podcast. Respondent made these misstatements most recently after the AGC brought this motion for his interim suspension. On their face, these numerical claims are so wildly divergent and irreconcilable, that they all cannot be true at the same time. Some of the wild divergences were even stated by respondent in the very same sentence. Moreover, at the November 30, 2020 hearing, when it was brought to respondent’s attention that no study to support the conclusions had been done, respondent persisted in making these false factual statements. In January 2021, respondent even admitted that he did not have the “best sources” to justify the numbers he was stating as fact. Nonetheless, respondent has failed to produce any sources, whether “best” or marginal, to support any of the figures he has presented to the public with authority. He has not identified, let alone produced 24

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