Case 8:21-cv-02956-KKM-SPF Document 1 Filed 12/21/21 Page 23 of 42 PageID 23
o. “All documents and communications relating to protests, marches, public
p. “Documents or other materials referring or relating to the financing or
q. “All recordings, transcripts, notes (including electronic and hand-written
r. “All documents and communications relating to the January 6, 2021, attack
s. “All documents and communications related to your January 2021 meetings
assemblies, rallies, and speeches in Washington, DC, on November 14,
2020, December 12, 2020, January 5, 2021, and January 6, 2021
(collectively, ‘Washington Rallies’).”
fundraising associated with the Washington Rallies and any individual or
organization’s travel to or accommodation in Washington, D.C., to attend or
participate in the Washington Rallies.”
notes), summaries, memoranda of conversation, readouts, or other
documents memorializing communications between you and President
Trump, any members of the White House staff, and/or Members of Congress
on January 5 or January 6, 2021, relating or referring in any way to the fall
2020 election or the attack on the Capitol.”
on the U.S. Capitol.”
with individuals associated with President Trump and his re-election
campaign, including, but not limited to, meetings held at the Willard Hotel.”
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Source: Elections - nytimes.com
