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"If Former President Trump disrupted the certification of the electoral vote count, as plaintiffs allege here, such actions would not constitute executive action in defense of the Constitution. For these reasons, the court concludes that Former President Trump is not immune from monetary damages in this suit."; -U.S. District Judge Emmet Sullivan ruling that disenfranchising voters through allegations of "stolen election" in an attempt to remain in power does not fall into the category of protected executive actions.