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Bar, which held disciplinary hearings in December 2022, arguing that he did not make frivolous claims because he reasonably relied on poll worker statements in the chaotic period after the election, when the “fastmoving” case “did not permit him to investigate fully.”[475] Eastman adopted a similar defense in response to disbarment proceedings in California, where he was charged with committing “moral turpitude” by using false or misleading claims (such as “7 states have transmitted dual slates of electors” and the election was tainted by “outright fraud”) in his memos on the “Jan 6 scenario” to make legally unsupported arguments purporting to authorize Vice President Pence to refuse Electoral College certification for Biden.[476] In his response, Eastman doubled down on debunked claims of fraud, arguing that there was “significant evidence” at the time of a “strategic Democratic plan to systematically flout existing election laws” in Pennsylvania, repeating claims about the illegality of state mail-in protocols that had been rejected by the Pennsylvania Supreme Court well before he authored the memos, and asserting that he did not know his statements were false since “evidence of ‘fraud’ was hotly contested at the time and remains so.”[477] While the D.C

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