Giuliani submitted this declaration as part of the ongoing civil lawsuit filed in 2021 by election workers Ruby Freeman and Wandrea "Shaye" Moss. The two women sued Giuliani for defamation.

. . .

In a declaration signed by Giuliani, he acknowledges that he made statements that “carry meaning that is defamatory per se” and that those comments were “actionable” and “false.”

This declaration also stipulates that Giuliani “believes that he has legal defenses” to the lawsuit and wants to “avoid unnecessary expenses in litigating what he believes to be unnecessary disputes.” He also said he believes his statements were constitutionally protected.

. . .