Page:CTRL0000034605 - Transcribed Interview of Angela McCallum, (December 8, 2021).pdf/96

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outcome of the Presidential election at the time that you were making the calls was that they had been—that, in those States, President Biden had been determined to be the winner of the Presidential election?

Mr. Brothers. I'm going to object to vagueness. I think the problem we're running into here is, determining the results of an election is somewhat complex, right? You have the media call, and we all know that occurs weeks before the formal governmental steps occur.

And so, when you say "outcome determined" or "called," there is absolutely no clarification of what you're meaning, whether you're meaning media's calling this or whether you're meaning that the formal legislative process has been completed.

So she has no guidance for how to determine if she had personal knowledge at the time of the call whether the media had called for that State or whether she had personal knowledge that the State had finished whatever formal process it could be. And I will note that the State's formal processes include multiple actors, like the secretary of state and the legislators and all of that.

And so at what point you're in that process has become the nebulous thing. Sol think I'm going to object to vagueness. I would suggest we really—if you want these questions answered, we really need to get specific.

  Okay. How about—

The Witness. Let me—

  Sorry. Go ahead.

The Witness. I just have something more to add on that. You know, I'm not a Rolodex of dates. I can't just recite to you when the secretary of state in a certain State said, you know, the election was certified or complete or something like that. I don't know.