"Carter wrote that the emails are “sufficiently related to and in furtherance of a conspiracy to defraud the United States.”"
https://www.wsbtv.com/news/local/federal-judge-rules-that-president-trump-knew-ga-voter-fraud-claims-legal-documents-were-false/C7EL77PBC5BP5DEGHSY5UQJ6PM/#:~:text=Carter%20wrote%20that%20the%20emails%20are%20%E2%80%9Csufficiently%20related%20to%20and%20in%20furtherance%20of%20a%20conspiracy%20to%20defraud%20the%20United%20States.%E2%80%9D