It’s Not Just the Attack on the Capitol

The “Select Committee to Investigate the January 6th Attack on the United States Capitol” has a slight branding issue: it turns out the Committee’s investigation and hearings into the conspiracy to overturn the election are not primarily about the attack on the Capitol.

The first hearing did focus on the January 6 attack, and was dominated by the riveting and horrifying video montage of footage from that day. But the second hearing focused on the many times Trump was told the election fraud claims were bogus – none of which happened on January 6. The third hearing was about the pressure campaign on vice president Mike Pence, most of which took place prior to January 6. The hearing on June 21 focused on Trump’s efforts to pressure state officials to overturn their election results — all of which happened prior to January 6. The same will be true of other hearings.

This is as it should be. A need to investigate the attack on the Capitol is, of course, what led to the Committee’s creation. But as the Committee’s investigation and hearings have unfolded, it’s become increasingly clear that the assault on the Capitol building was merely the bookend to a much broader conspiracy that unfolded over the weeks between election day and January 6.

In the context of that broader conspiracy, the physical assault on the Capitol, as terrible as it was, was not the most significant event. It was not critical to the conspiracy’s potential success. Even without the assault, the efforts to overturn the election were still potentially criminal and still could have succeeded. And in the long run, the events that took place prior to January 6 are actually more dangerous — because they are easier to repeat, and harder to detect.

Conspiracy street sign

The Language of Conspiracy

The Committee has promised that its hearings will demonstrate a “coordinated, multi-step effort to overturn the 2020 presidential election”. That is the language of conspiracy. And indeed, the most likely criminal charges would be conspiracy to obstruct a Congressional proceeding and conspiracy to defraud the United States.

In civil litigation involving the Committee’s efforts to obtain the emails of former Trump attorney John Eastman, a federal judge in California has already ruled there is evidence that Trump and Eastman likely committed those crimes. The standard in a civil case is far lower, of course, so that ruling alone does not prove a crime was committed. But it’s significant that a federal judge saw the facts that way.

The evidence required to prove these two crimes would be very similar. The central allegation would be that, through a series of actions, the conspirators corruptly sought to prevent or delay the Congressional certification of Joe Biden’s election victory at the joint session of Congress on January 6. Unlike the charge of seditious conspiracy (filed against the white supremacist groups the Proud Boys and Oath Keepers), these charges do not require the government to prove that the conspirators intended to use force to achieve their goals.

Conspiracy to obstruct a Congressional proceeding would be charged under 18 U.S.C. 1512(c)(2) and 1512(k). It’s a twenty-year felony. It requires the government to prove that the defendants conspired to corruptly obstruct, influence, or impede any official proceeding, including a proceeding in Congress. More than 200 of the rioters who actually attacked the Capitol on January 6 have been charged with this crime.

Many of those charged under 1512 have challenged their prosecution on various grounds, including claiming that the joint session of Congress was not an “official proceeding” within the meaning of the statute. About a dozen federal judges in D.C. have rejected that argument, with only one judge agreeing with the defendant and dismissing the charge. That issue is bound for the D.C. Circuit Court of Appeals and perhaps the Supreme Court, but I believe the law is on the government’s side.

A conspiracy to defraud the United States under 18 U.S.C. § 371 requires the government to prove that the defendants conspired to defeat, obstruct, or impede a lawful government function of the United States through corrupt or dishonest means. This was a leading charge in the indictment obtained by special counsel Robert Mueller of the Russian agents who interfered with the 2016 presidential election through social media and other methods. Mueller charged that, through those actions, the defendants conspired to defeat the lawful functions of the State Department, Federal Election Commission, and Justice Department.

One benefit of this charge for prosecutors is that it does not require proof that the defendants’ conduct was otherwise criminal. So, for example, if a court got hung up on the “official proceeding” requirement of 18 U.S.C. § 1512 and decided that statute did not apply, conspiracy to defraud the U.S. under §  371 could still be used to prosecute essentially the same conduct.  

Both of these potential crimes have another significant thing in common: most of the acts done in furtherance of the alleged conspiracies were carried out prior to January 6, by individuals who did not personally storm the Capitol building.

Rep. Liz Cheney
Rep. Liz Cheney (R – Wyo)

The Conspiracy to Overturn the Election

Conspiracies often involve the conspirators following different avenues to try to achieve their overall criminal goal. Different co-conspirators may have different tasks and may take part in different aspects of the conspiracy. Some paths pursued by some conspirators may be more fruitful than others. But all of their efforts are directed toward achieving their ultimate, shared criminal objective

House Committee vice-chair Rep. Liz Cheney (R-Wyo), in her opening statement on June 9, said the hearings would show that “Donald Trump oversaw and coordinated a sophisticated seven-part plan to overturn the presidential election and prevent the transfer of presidential power.” The different parts of that scheme will be the subject of different hearings. They are best viewed not in isolation but as part of a single overall plan, as Rep. Cheney said. And most of them did not depend on an assault on the Capitol. There are many ways to obstruct an official proceeding that do not involve a physical attack on the proceeding’s location.

As Rep. Cheney discussed, the different parts of this plan included:

— Spreading the big lie, by falsely claiming Trump had won the election and that there was widespread voter fraud.

— Corrupting the Department of Justice, by removing senior officials and replacing them with loyalists who would put the power of the Department behind Trump’s false claims of election fraud.

— Pressuring vice president Pence to refuse to count the lawful elector ballots and either send the issue back to state legislatures or simply reject those ballots and declare Trump the winner.

— Pressuring state officials to support false claims of election fraud and change their election results to declare Trump the winner, in states that Biden actually won.

— Sending slates of phony electors for president Trump to Washington, to falsely proclaim that they were the duly constituted electors from their states.

Notably, almost all of these efforts took place prior to January 6 and involved potential co-conspirators who were not on the ground on January 6 and did not take part in the assault on the Capitol.

The Nature of a Conspiracy Charge

Several features of a conspiracy charge make it particularly well-suited for these events. The first is simply that there are multiple individuals involved, pursuing a single criminal goal through multiple different avenues. Conspiracy charges are made to capture such efforts.

In a conspiracy charge, all co-conspirators do not need to be involved in all aspects of the conspiracy. Co-conspirators, as partners in crime, are criminally responsible for each other’s actions. If some were involved in pressuring state officials while others worked on the fake electors scheme or on corrupting the Department of Justice, all conspirators would be responsible as participants in a common enterprise pursued along multiple tracks.

Another key feature of a conspiracy charge is that the conspiracy need not succeed; the wrongful agreement itself is the crime. Hundreds of those involved in storming the Capitol have been charged with crimes that were actually completed – destruction of property, assault on a law enforcement officer, or unlawful entry into restricted areas. But in a conspiracy to prevent the certification of the election through non-violent means, it would make no difference that the certification ultimately was successful.

The proceeding on January 6 was in fact obstructed by the assault; it was delayed for hours as Congress was forced to evacuate the Capitol. But there could be conspiracy charges based on events prior to January 6 that do not include the assault on the Capitol as part of the conspiracy. In such a case, it would not matter that the conspiracy to obstruct the proceeding through other means, such as the phony electors scheme, did not ultimately succeed.

Trump fundraising email
Trump Fundraising E-mail

And Then There’s the Wire Fraud           

Compelling evidence emerged at the June 13 hearing about an entirely different area of potential criminal charges: what Committee member Zoe Lofgren (D-CA) called the “big rip-off”. Trump and his allies allegedly used the phony claims of election fraud to raise more than $250 million from donors for an “election defense fund” that apparently didn’t exist. Instead, money was diverted to Trump’s Political Action Committee and spent on other political projects and donations, including more than $200,000 that went to the Trump Hotel group.

This is an allegation of textbook wire fraud, 18 U.S.C. § 1343. There is a scheme to defraud: fundraising pitches making false claims of election fraud and promising to use donated funds to fight that supposed fraud, and then diversion of the money to other uses by the defendants. And there is the use of wireless transmissions in furtherance of the fraud: the fundraising emails and any electronic payments that were sent in. If I were writing a wire fraud hypothetical for a final exam, I couldn’t do any better.

Trump and his campaign might try to defend by claiming there was “fine print” at the bottom of the fundraising pitches that indicated the money could be used for other purposes. But if the overall design of those pitches is intended to deceive, slipping some fine print in at the bottom won’t prevent it from being considered a fraud. And the pitches also included knowingly false claims about the election being stolen as the reason for raising money, another indicator of fraud.

These additional potential criminal charges, teased by the Committee at the conclusion of the hearing, have no connection to the actual riot at the Capitol. The email solicitations could form the basis for a wire fraud case even if the assault on the Capitol had never taken place.

Bottom Line: It’s About More Than the Assault   

I think it’s useful to place all of the events being covered by these Committee hearings into two distinct categories. There’s the physical assault on the Capitol building on January 6, and there’s all of the non-violent efforts to overturn the election results — most of which took place prior to January 6. Criminal charges could be based on either.

Any potential defendant could be part of one, without being part of the other. The Proud Boys, Oath Keepers, or other rioters who attacked the Capitol (and who are now being prosecuted for that attack) likely had nothing to do with any of the other non-violent efforts to overturn the election. And someone who participated in the phony electors scheme or pressuring state election officials, for example, may have had nothing to do with the riot and may not have anticipated it at all.

We will have to see how any potential criminal charges ultimately shape up. But I could easily see a case alleging a conspiracy to overturn the election results though the various non-violent means that did not include the actual assault on the Capitol as part of that conspiracy. Charges based on the actual assault could proceed on a separate track, as hundreds of such cases already are. And with some defendants — including potentially Trump himself — there may be overlap between the two.

Viewed in this light, the assault on the Capitol is best seen as a tragic side effect of the much larger conspiracy to overturn the election. The attack ended up serving as a useful tool, because it bought the conspirators more time on that day to try to use other means to prevent the certification of Biden’s victory. But it was not essential to the conspiracy, need not have been one of its goals, and need not have been foreseen or planned by the co-conspirators. If the conspirators could have overturned the election peacefully through their various non-violent schemes, they would have done so – and it would still be a crime.

It makes sense for the January 6 Committee to spend much of its time showcasing for the American people the events that took place prior to January 6. The gravest danger to the country actually came not from the riot itself but from the schemes of those who sought to overturn the election through nonviolent means.

Security around the Capitol can be improved. Broken doors and windows can be repaired. Physical injuries can heal. Democracy itself may turn out to be more fragile.

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An Update on the January 6 Investigations

It’s been an eventful couple of months in the investigations of January 6, 2021. There are signs that DOJ’s criminal investigation is starting to close in on higher-level organizers and leaders of the attempt to overturn the election, including those in Trump’s inner circle. The aggressive Congressional investigation continues, with House attorneys alleging in federal court that they believe former president Trump himself committed crimes on January 6. And a federal judge recently ruled that civil suits seeking damages from Trump and others stemming from the Capitol riot may proceed. Overall, things definitely seem to be accelerating, and it’s a good time for an update on the January 6 investigations.

Attorney General Merrick Garland

The Department of Justice Investigations

Garland Vows to Pursue Those Responsible “At Any Level”

On January 5, 2022, Attorney General Merrick Garland gave a speech commemorating the one year anniversary of the assault on the Capitol. He said investigating those events was DOJ’s highest priority, and vowed to pursue those responsible “at any level.” He shared some remarkable statistics about the scope of the investigation, the largest in DOJ’s history.

Garland also appeared to respond to critics complaining that DOJ was charging mostly misdemeanors and did not seem to be pursuing the higher-level organizers or more serious charges. He said that, by disposing of the less serious cases first, prosecutors were following “well-worn prosecutorial practices.” He noted that in large, complex investigations, prosecutors begin with the easier, more overt cases and then work their way up the ladder to higher-level players and more serious charges as they gather more information.

Garland vowed that “the actions we have taken so far will not be our last.” And he said that although he understood the possible frustration with the lack of public information and the time it takes to investigate such cases properly, that was how DOJ must proceed: “We will and we must speak through our work.”

Stewart Rhodes, Founder of the Oath Keepers

The Oath Keepers Indictment

One week after Garland’s speech, a new indictment demonstrated that the criminal investigation was indeed moving up the ladder to more serious charges and actors. On January 13, DOJ announced the indictment of eleven members of the right-wing militia group the Oath Keepers, including its founder, Stewart Rhodes. The lead charge in that indictment is Seditious Conspiracy, 18 U.S.C. 2384, which makes it a crime to conspire to use force to overthrow the U.S. government or interfere with the execution of federal law. This was the first time any Capitol riot defendants had been charged with sedition, which essentially accuses the defendants of taking up arms against the United States to prevent the peaceful transfer of presidential power.

The Oath Keepers indictment goes into great detail about the group’s activities leading up to January 6. Using encrypted messaging apps and online forums, they formulated their plans to travel to Washington and use force to stop Congress from certifying that Joe Biden won the election. The indictment also describes how members of the group helped lead the assault on the Capitol, using military gear and tactics. Others stockpiled weapons in the D.C. suburbs and served as a “Quick Reaction Force” ready to deploy those weapons to support the attack. They even planned how they might use boats to get weapons across the Potomac if the government closed the bridges. The Oath Keepers were not mere attendees at the White House rally who later got swept up with the mob. They were organizers and leaders of the assault on the Capitol.

Joshua James, Leader of the Alabama Oath Keepers

The First Guilty Plea to Sedition

The Oath Keepers indictment represented the first time DOJ filed charges of sedition against any of the rioters. On March 2, it secured the first guilty plea to that charge. Joshua James, one of the eleven Oath Keepers named in the Rhodes indictment, pleaded guilty to seditious conspiracy and obstruction of Congress. James also agreed to cooperate with prosecutors in the ongoing investigation.

James’s plea and cooperation could be a major breakthrough. He can provide information not only about the Oath Keepers conspiracy but potentially about the involvement of other, higher-level participants in the events of January 6. In particular, James and other Oath Keepers are known to have provided personal security on January 5th and 6th for Trump advisor and confidant Roger Stone.

Stone, of course, is a well-known figure from the Trump years. The Mueller investigation revealed that Stone acted as a conduit between the 2016 Trump campaign and Wikileaks and Julian Assange for information about the release of stolen Democratic emails in the weeks leading up to the 2016 election. Stone was convicted of lying to Congress about his role in those events and was sentenced to nearly four years in prison, but was later pardoned by president Trump.

Stone was part of the group of close advisors to president Trump who gathered in Washington in the days leading up to January 6. A recent detailed report in the Washington Post described an upcoming documentary that will highlight Stone’s work with the Trump team to overturn the results of the election.

With the James guilty plea, prosecutors have now secured the cooperation of someone who was close to Stone during those pivotal days. That potentially allows investigators to move beyond the actual rioters and into a broader conspiracy involving those close to Trump who planned and organized from a distance. And as investigators move up that ladder, those senior Trump advisors are only one rung below Trump himself.

The Proud Boys Indictment

On March 8, DOJ announced the indictment of Enrique Tarrio, the former leader of another militia group, the Proud Boys. He and five other members of the Proud Boys are charged with conspiracy, obstruction of Congress, assaulting law enforcement officers, and destruction of federal property. The Proud Boys are another of the leading militia groups involved in organizing and carrying out the assault on the Capitol.

The Proud Boys featured prominently in an incident from the 2020 presidential debates. When the moderator asked president Trump whether he was willing to denounce right-wing extremist groups, he asked who he should denounce. Joe Biden suggested the Proud Boys. Trump responded, “Proud Boys, stand back and stand by.” Tarrio then Tweeted in response, “Standing by, sir.”

As with the Oath Keepers case, the Proud Boys indictment details how the members of the group planned and then participated in the assault on the Capitol. It describes how they breached the outside barriers and assaulted police officers. One of the defendants allegedly used a riot shield taken from a police officer to break a window in the Capitol that rioters then used to make their first entry into the building. After entering the building, one posted on social media, “We’ve taken the Capitol.”

Tarrio is not charged with entering the Capitol himself but with helping to coordinate the Proud Boys activities. On January 4, Tarrio had been arrested in D.C. on local charges stemming from his participation in an assault on Black Lives Matter protestors in December. As part of his conditions of release, he was ordered to stay out of D.C. Before leaving, however, the indictment alleges that on January 5 he met in a parking garage with Stewart Rhodes of the Oath Keepers and others – more evidence of a potentially broader conspiracy. He then traveled to Baltimore, where he stayed in communication with the Proud Boys who actually participated in the assault.

The Proud Boys indictment does not include the Seditious Conspiracy charge used in the Oath Keepers indictment. It’s not clear to me why that’s the case. One difference is that the Proud Boys indictment lacks any reference to gathering and bringing firearms to DC, which is a big part of the Oath Keepers case. Firearms would not be necessary for a sedition charge, but perhaps that is a discretionary distinction DOJ is drawing about when to use that charge.

Guy Reffitt

The First Conviction at Trial

Also on March 8, the first Capitol rioter to go to trial was convicted on all counts. Guy Reffitt, a member of a Texas militia group called the Three Percenters, was charged with five felonies, including obstruction of Congress and carrying a firearm during a civil disorder. He traveled to D.C. with an assault rifle and handgun. He carried the handgun with him during the assault on the Capitol, along with zip ties, a helmet, and body armor. Prosecutors alleged that he led one wave of the assault on the Capitol and served as the “tip of the spear,” helping break through police barricades before being repelled by pepper spray.

Reffitt was also convicted of obstruction of justice for threatening potential witnesses: his own children. After returning to Texas, he became paranoid about being arrested. He told his 18-year-old son and his younger sister, “If you turn me in, you’re a traitor. And traitors get shot.” His son, who does not share his father’s political views, did in fact turn him in and testified at his trial. (And you thought your Thanksgiving dinners were awkward.)

This first conviction was an important milestone for the government. Prosecutors put on an overwhelming case. It only took about a week to pick a jury and try the case, and the jury only deliberated for about three hours. This sends a strong signal to other January 6 defendants about the government’s ability to try these cases quickly and effectively. The Reffitt conviction will likely convince other defendants to plead guilty and cooperate rather than challenge the prosecution at trial.

Judge Nichols Ruling on Obstruction

Along with all these positive developments, there was one recent setback for prosecutors. On March 7, U.S. District Judge Carl Nichols ruled that prosecutors could not charge a Capitol rioter with obstruction of a Congressional proceeding under 18 U.S.C. 1512(c)(2). The ruling came in the case of Garrett Miller of Texas. Nichols ruled that this portion of the statute applies only to obstructive conduct that is similar to document shredding or other destruction of physical evidence. Because Miller was not charged with that kind of conduct, Nichols dismissed the obstruction charge. Miller remains charged with multiple other crimes.

I think Judge Nichols is wrong. I wrote here last fall about why I believe the obstruction of Congress charge does apply to the conduct of the Capitol rioters. Ten other district court judges, faced with similar motions, have ruled that the statute does apply – you can find a list here. Nichols is really out there on his own.

Nevertheless, the decision does cast a shadow over the more than 200 cases where the obstruction charge has been filed. The Proud Boys and Oath Keepers indictments discussed above include that charge. Reffitt was just convicted of it, and James pleaded guilty to it. Some defendants may now be reluctant to plead to the charge if there are doubts about its legal validity.

I see this as a speed bump for DOJ, not a major roadblock. This legal issue was always destined to be decided by the D.C. Circuit, and potentially even by the Supreme Court. DOJ will probably pursue an immediate appeal of Nichols’ order, hoping to get a relatively quick decision from the Circuit court. But in the meantime, given the overwhelming approval of the charge by every other judge to look at the issue, I expect DOJ will continue to pursue it in appropriate cases.

Members of the House Select Committee

The Congressional Investigation

The investigation of January 6 by the House Select Committee is churning along. They have hired a number of former federal prosecutors and appear to be conducting a thorough and painstaking investigation. The Committee has spoken to nearly 600 witnesses and has gathered a huge amount of evidence. They have announced plans to hold public hearings in the near future. They are continuing their efforts to gather information from very high-level people close to Trump, including his family members and senior staff.

In contrast to the DOJ criminal investigation, the House Committee is free to make its findings public. It already has released some information, such as the text messages to Trump during the riot from his family, Fox News hosts, and members of Congress, all pleading with Trump to call it off, and the draft of a proposed executive order (never signed) directing the department of defense to seize voting machines in key states. The Committee reports and hearings ultimately will provide the most detailed public findings to date about January 6 and what caused it.

Allegations Regarding John Eastman

The Committee made headlines recently based on allegations it made in litigation with former Trump attorney John Eastman. Eastman was the architect of the universally-discredited theory that on January 6 vice president Mike Pence could simply reject the electoral votes of certain states that Joe Biden won and declare Trump the winner. He was one of the Trump advisors who occupied the “war room” at the Willard Hotel in early January. The House Committee subpoenaed Eastman’s emails and he has withheld thousands of them, claiming they are protected by attorney-client privilege because he was acting as Trump’s lawyer.

In a federal court filing last week in California (where Eastman lives), attorneys for the Committee argued the emails are not protected. One of their arguments rests on the rule that communications with an attorney are not privileged if made in furtherance of a crime or fraud. They allege that Trump was communicating with Eastman in order to help Trump commit at least two federal felonies: conspiracy to defraud the United States and obstruction of a Congressional proceeding.

The judge held a hearing on the attorney-client privilege issues on March 8, and on March 9 ruled that he will review the documents to determine whether any privilege applies. The judge may order that the emails be turned over for other reasons, including that there was not a true attorney-client relationship between Trump and Eastman. But even if the judge does not rule that the crime-fraud exception applies, the implications for the criminal case are clear. Government attorneys have, for the first time, told a federal judge they believe Trump himself may have committed crimes in connection with January 6.

LIkely Criminal Referral of Trump

It now seems almost certain that the House Committee will make a criminal referral of Trump to the Department of Justice. In terms of possible crimes by Trump, attention seems to be coalescing around the two charges contained in the Eastman pleadings: conspiracy to defraud the U.S. and obstruction of Congress. In a recent “prosecution memo” published on Just Security, law professor and former U.S. Attorney Barbara McQuade argued for the application of those same charges to Trump’s efforts to overturn the election.

Conspiracy to defraud the United States prohibits interfering with lawful functions of the federal government by deceit, trickery, or other dishonest methods. It was the charge used by special counsel Robert Mueller to indict the Russians accused of interfering with the 2016 presidential election through phony social media campaigns and other methods. Obstruction of Congress is the charge discussed above, that was recently called into question by Judge Nichols.

A Congressional referral to DOJ does not mean DOJ must prosecute; Garland will still have to make that decision. And despite the Committee’s bipartisan makeup, any referral will be dismissed by many as merely political. But any formal announcement that a Congressional committee believes the former president committed crimes would still be a significant development.

The Civil Lawsuits        

A final important recent development related to January 6 involves civil suits filed by Members of Congress and Capitol Police officers against Trump and others. The plaintiffs sued Trump, the Proud Boys, the Oath Keepers, Rudy Giuliani, Donald Trump Jr., and others, seeking damages for their physical and emotional injuries stemming from the assault. The defendants moved to dismiss the lawsuits on a number of grounds. On February 18, U.S. District Judge Amit Mehta ruled the lawsuits can go forward against Trump and the militia groups, although he dismissed the cases against Giuliani and Donald Jr.

These are civil suits for damages, so they will not result in any criminal charges. But Mehta’s opinion is worth a read for the detail it provides about Trump’s encouragement and incitement of the Proud Boys, Oath Keepers, and others who engaged in the riot. Notably, he concluded that the plaintiffs, at this stage, have alleged evidence sufficient to demonstrate a civil conspiracy between Trump and the rioters to obstruct the Congressional proceeding. Mehta cited all the steps that Trump took to encourage the rioters to attend on January 6 and try to stop Congress from acting. He noted that Trump’s repeated use of the word “we” during his speech to the mob on January 6 suggested they were engaged in an enterprise together.

Mehta also observed, when discussing the Oath Keepers, that evidence of their connection to Roger Stone may end up being significant in terms of proving a larger conspiracy. As discussed above, this could be true for the criminal investigation as well.

The civil lawsuits will now proceed to the discovery phase. That could unearth yet more information about January 6 and could include efforts to take depositions from Trump himself. Proving a civil conspiracy by a preponderance of the evidence is a far cry from proving a criminal one beyond a reasonable doubt. But the facts all overlap, and the different lawsuits and investigations have the potential to help unearth more of those facts.

Garland Reaffirms DOJ’s Commitment

Attorney General Garland gave an interview just yesterday on NPR, where he reaffirmed his commitment to follow the facts and law wherever they lead and said he would not shy away from cases that may be politically controversial. He vowed the investigation will continue “until we hold everyone accountable who committed criminal acts with respect to January 6.” I take him at his word, and I think the signs we are seeing are consistent with his vow.

Things are definitely heating up. Between the DOJ criminal investigations, the House Committee investigation, and the civil lawsuits, it looks like 2022 will be an eventful year when it comes to holding accountable those responsible for the attempt to overthrow the election.

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