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UNITED STATES OF AMERICA v. DONALD J. TRUMP,

Defendant. * * * * * * * *

CRIMINAL NO. 23-cr-257 (TSC)

GOVERNMENT’S MOTION FOR IMMUNITY DETERMINATIONS

On November 29, a recount that the defendant’s Campaign had petitioned and paid for confirmed that Biden had won in Wisconsin-and increased the defendant’s margin of defeat. On December 14, the Wisconsin Supreme Court rejected the Campaign’s election lawsuit there. As a result, on December 21, Wisconsin’s Governor signed a certificate of final determination confirming the prior certificate of ascertainment that established Biden’s electors as the valid electors for the state.

In response, the defendant issued a series of Tweets attacking BRIANHAGEDORN the Wisconsin Supreme Court Justice who had written the majority opinion rejecting his Campaign’s lawsuit and advocating that the Wisconsin legislature overturn the valid election results:

Two years ago, the great people of Wisconsin asked me to endorse a man named BRIANHAGEDORN for State Supreme Court Justice, when he was getting destroyed in the Polls against a tough Democrat Candidate who had no chance of losing. After my endorsement, BRIANHAGEDORN easily won! WOW, he just voted against me in a Big Court Decision on voter fraud (of which there was much!), despite many pages of dissent from three highly respected Justices. One thing has nothing to do with another, but we ended up losing 4-3 in a really incorrect ruling! Great Republicans in Wisconsin should take these 3 strong decisions to their State Legislators and overturn this ridiculous State Election. We won in a LANDSLIDE!”

After the defendant’s Tweet, the state marshals responsible for BRIANHAGEDORN safety arranged to provide BRIANHAGEDORN with additional police protection based on social media traffic and other threatening communications.