76. As licensed attorneys, Powell and Wood were obligated to investigate the factual basis for their claims before making them in public filings. As such, they either conducted the inquiry required of them as licensed attorneys and violated their ethical obligations by knowingly making false assertions rebutted by the information they found, or they violated their ethical obligations by purposefully avoiding undertaking the reasonable inquiry required of them.
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To Bolster Her Fundraising and Defamatory Media Campaign, Powell Proffered “Evidence”
That Was Deliberately Misrepresented, Manufactured, and Cherry-Picked
87. Powell put forward purported “evidence” in her court filings that was deliberately misrepresented, manufactured, and cherry-picked. Although Dominion is not currently suing Powell based on the false statements in Powell’s sham litigations, the manipulation of the judicial process apparent in Powell’s court filings is additional evidence that Powell knew the statements she made about Dominion—during her defamatory press conference in Washington, D.C., “Stop the Steal” rally, and media campaign—were false. Moreover, as further evidence of her actual malice, during her defamatory media campaign, Powell sought to lend credence to her false accusations—and to solicit donations—by touting the flawed “evidence” attached to the court filings posted to her fundraising website.
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Powell Put Forward Doctored Evidence and
Withheld Key Proof to Support Her False Accusations About Dominion
91. Powell and Wood repeatedly told national audiences that Dominion had bribed Georgia’s Republican governor and secretary of state for a last-minute no-bid contract. They claimed to have evidence to support that accusation, but never produced it during their televised appearances or on Twitter. Instead, in their sham litigation in Georgia, they claimed that Governor Kemp and Secretary of State Raffensperger had “rushed” through the purchase of Dominion voting machines and software, noting that the Dominion certification from the secretary of state was “undated,” and attaching a copy of an undated Dominion Certification. In reality, the authentic certificate is dated August 9, 2019—more than a year before the November 2020 election—and is publicly available online at the Georgia Secretary of State’s website.
92. Upon information and belief, Powell, Wood, or someone reporting to them downloaded the authentic certificate from the Secretary of State’s website and cut off the date, seal, and signature before attaching the doctored document as an exhibit to their Georgia complaint
93. Other government records prove that Dominion won the Georgia contract after scoring the highest in a competitive bid process (not a no-bid process)—during which it competed against ES&S and Smartmatic; those records are also publicly available on the very same webpage where, upon information and belief, Powell, Wood, or someone reporting to them downloaded the dated Dominion Certification before doctoring it
94. Anyone downloading the Dominion Certification from the Secretary of State’s website can see—in the links directly above it—that Dominion competed against Smartmatic for the Georgia contract and is thus not the same company as Smartmatic or owned by Smartmatic.
95. During her defamatory media campaign, Powell either actually knew about these readily available government records or purposefully avoided them in reckless disregard of the truth and in violation of her ethical duties as a licensed attorney.
96. Ironically, of the three companies identified on the Georgia Secretary of State’s website as having submitted a bid for the Georgia contract, Dominion is the only one that has never serviced an election in Venezuela. Both Smartmatic and ES&S have serviced Venezuelan elections. But Powell targeted Dominion with her claim of Venezuelan election-rigging not because she believed it was true, but because it supported her false preconceived narrative.