This week’s ruling against Eastman is a landmark win for accountability, and comes as others who aided and abetted the effort to upend U.S. democracy also face consequences for their roles. This includes former Justice Department lawyer Jeffrey Clark, who sought to use the department to advance Trump’s lies about election fraud and is now looking at potential disbarment, as well as Mike Roman, another Fulton County co-defendant who this week was subpoenaed in the Arizona attorney general’s investigation of the fake elector scheme.American Oversight, which first obtained the fake electoral certificates in 2021, has investigated the post-2020 activities of Eastman, Clark, Roman and other Trump allies as they continued their efforts to undermine trust in U.S. democracy and election results.Records we obtained indicate that Karen Fann, then the Arizona Senate president, may have met with Eastman in the weeks after the election. In a Dec. 13, 2020, email to a constituent who had demanded that the state’s election results be decertified, Fann appears to allude to Eastman and echoed the legal theory advanced in his memo: “With respect to the US Constitution Article 2 and 3 provisions, we spent an hour and a half with a nationally accredited constitutional attorney which was extremely interesting and I learned a lot,” she wrote. “He stated that the ‘plenary clause’ allowing us to convene ourselves with a simple majority applies ‘when there is no clear winner of an election.’”We also obtained a February 2021 text message sent to Fann by Phil Waldron — a prominent election denier active in challenging the election, including having briefed members of Congress on fraud theories in the days before Jan. 6 — in which he told her he was “on [a] call with Prof Eastman.” Waldron’s firm, Allied Security Operations Group, was nearly hired by Fann to conduct the Senate’s partisan “audit” of Maricopa County’s 2020 results, and had been behind the thoroughly debunked report on alleged election irregularities in Michigan.