Footnotes, 65.

The Court herein incorporates the legal bases purported in its summary judgment order for the requirements that Defendants directed the actions that caused the intimidation. Doc. No. [222], 19–20 & 23–25. Specifically, the Court highlights the citations to Wohl, which asserted “courts have concluded that conduct putting others ‘in fear of harassment and interference with their right to vote’ constitutes intimidation ‘sufficient’ to support a Section 11(b) claim.” 498 F. Supp. 3d at 480. Wohl then proceeded to compare Section 11(b) to the Fair Housing Act, which requires “showing that the [defendant’s] activities had generated fear in the [plaintiff].” Id. at 482 (alteration in original). The Court also emphasizes the common refrain regarding Section 11(b)—that it generally attributes to Defendants the natural consequences of their actions, which implies a causation requirement. Cf. e.g., Katzenbach, House Judiciary Statement (“[D]efendants [are] deemed to intend the natural consequences of their acts.”).