A report from the D.C. Bar Association released on Friday recommended that former Donald Trump attorney Rudy Giuliani be disbarred because of his efforts to help Trump overturn the 2020 election without evidence.

A committee that was assembled to review Giuliani’s role in the election determined that the lawyer “seriously undermined the administration of justice” by “seeking to change the result of the 2020 presidential election when he had no factual basis, and consequently, no legitimate legal grounds, to do so.”

The report further explained that Giuliani had no right to file lawsuits in an attempt to keep President Joe Biden out of office.

“The right to vote is the ‘essence of a democratic society.’ Respondent’s frivolous lawsuit attempted unjustifiably and without precedent to disenfranchise hundreds of thousands of Pennsylvania voters, and ultimately sought to undermine the results of the 2020 presidential election. He claimed massive election fraud but had no evidence of it.”

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Though the committee wrote that Giuliani “should be disbarred,” the report will not serve as a concrete decision to do so. Giuliani’s case will be brought to the bar’s Board of Professional Responsibility, and then to the D.C. Court of Appeals.

Just last week, Giuliani sat for an interview with prosecutors from special counsel Jack Smith’s office. Smith was appointed to lead the probe into claims of election fraud in 2020 and convinced Giuliani to cooperate under a proffer agreement, which allows defendants to give law enforcement information in exchange for possible lenience in future legal proceedings.

Giuliani was questioned about his role in the insurrection at the Capitol on January 6, 2021, and was asked about an alleged plan to create fake records of pro-Trump electors in swing states that were ultimately won by Biden.

While this interview may have helped Giuliani escape a few criminal charges, he is still facing possible disbarment. Hearings for the case will begin in December.

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