Respondent’s mischaracterization of the case was not simply a passing mistake or inadvertent reference. Fraud was the crown of his personal argument before the court that day. In his opening remarks, respondent claimed that the allegations in the complaint concerned “widespread, nationwide voter fraud of which this is a part…." He persisted in making wide ranging conclusory claims of fraud in Pennsylvania elections and other jurisdictions allegedly occurring over a period of many years. Respondent argued that the plaintiff’s fraud arguments pertained to the canvassing claim, notwithstanding that there was neither a fraud nor a canvassing claim before the court. Respondent’s fraud argument spanned pages 12 to 31 of the transcript. After opposing counsel pointed out, and respondent’s own co-counsel agreed, that the plaintiff had asserted no claims of fraud the court made the following inquiries and received the following answers from respondent: "THE COURT: So it's correct to say then that you're not alleging fraud in the amended complaint? "RESPONDENT: No, Your Honor, it is not, because we incorporate by reference in 150 all of the allegations that precede it, which include a long explanation of a fraudulent, fraudulent process, a planned fraudulent process. "THE COURT: So you are alleging fraud? RESPONDENT: Yes, Your Honor." Later in the transcript, after the court pointed respondent to the amended complaint, the following further court inquiries and responses occurred: cert denied sub nom Donald J. Trump for President, Inc. v Degraffenreid, ---US---, 141 SCt 1451 [2021]). The plaintiff’s subsequent efforts to reinstate the voluntarily withdrawn federal claim concerning the canvassers was also denied in Boockvar. 12