Witness). Merely providing names and conclusory assertions that respondent had a
basis for what he said, does not raise any disputed issue about whether misconduct has
occurred.
Respondent made statements regarding underage voters in Georgia on his radio
show, Chat with the Mayor, at least on January 5, January 7, and January 22, 2021. He
then repeated this statement on the April 27th episode of his radio show, after this
motion for interim suspension was brought.
The above identified misstatements violate RPC 4.1 and RPC 8.4(c).
Respondent stated to lawmakers, and the public at large, that more than 2,500
Georgia felons voted illegally. The Georgia Secretary of State also investigated this claim.
By comparing lists from the Departments of Corrections and Community Supervision,
with the list of people who actually voted in November 2020, the Secretary of State
identified a universe of 74 potential felony voters, who were then investigated. Even if all
74 identified persons actually voted illegally, the number is nowhere near the 2,500 that
respondent claimed and the number would, in any event, be statically irrelevant in
supporting a claim that the election was stolen (see Bognet v Secretary Commonwealth
of Pa., 980 F3d 336, 351 [3d Cir 2020], cert granted, judgment vacated sub nom
Bognet v Degraffenreid ---US---, 2021 WL 1520777, 2021 US LEXIS 1952 [2021] [for
the plaintiff to have standing, challenged votes must be sufficient in number to change
outcome]; Sibley v Alexander, 916 F Supp 2d 58, 62 [DC 2013] [the plaintiff failed to
satisfy redressability element where the three challenged electoral votes would not
19