because the claims made in the article (in which respondent was quoted) are based upon
an alleged review of public records from 2017 and 2018.8
Respondent made these false statements at least twice before the AGC brought
this motion; first at a November 7, 2020 press conference at Four Seasons Total
Landscaping and again during the November 25, 2020 meeting of the Republican State
Senate Majority Policy Committee in Gettysburg, Pennsylvania. Despite the unequivocal
evidence provided in this very motion, that Mr. Frazier is not on the Pennsylvania voting
rolls, respondent continued to endorse this fictionalized account in the March 4, March
11 and March 14, 2021 episodes of his broadcast radio show Chat with the Mayor, all of
which aired after this motion was brought.
The above identified misstatements violate RPC 4.1 and RPC 8.4(c ).
Respondent repeated to lawmakers and the public at large numerous false and
misleading statements regarding the Georgia presidential election results. These
statements, as particularized below, were all knowingly made with the object of casting
doubt on the accuracy of the vote. Respondent's general claim, without providing this
Court with any documentary support, that he relied on “hundreds of pages of affidavits
and declarations in [respondent’s] possession that document gross irregularities…” will
not suffice to controvert the specific findings that he knowingly made the false
statements that are particularized below.
Respondent made extensive and wide-ranging claims about Dominion Voting
Systems Inc.'s voting machines manipulating the vote tallies to support his narrative
that votes were incorrectly reported. Georgia, however, had completed a hand count of
8
The blogger's representation regarding what the public record revealed was inaccurate.
16