Footnotes, 15.

Engelbrecht testified that neither she nor TTV actually drafted the Validate the Vote proposal (PX 1) and that former counsel actually drafted the proposal. She testified to “recogniz[ing]” the document itself, but not some of the language in it. Tr. 848:15–18. The Court generally credits Engelbrecht’s testimony that TTV and Engelbrecht did not have a direct role in writing the Validate the Vote proposal (PX 1). However, Engelbrecht also independently testified regarding TTV’s efforts in the aftermath of the 2020 election and these actions are consistent with the “plan” articulated in the Validate the Vote proposal. Thus, while the Court will not find that TTV and Engelbrecht drafted the Validate the Vote proposal (PX 1), the Court considers the initiatives described in the proposal to be consistent with TTV’s efforts in the 2020 election period and thus weighs them in its analysis of TTV’s actions.