we get ourselves into tomorrowideally until the end of tomorrow". However, Giuliani mistakenly left the message on the voicemail of another senator, who leaked the recording to The Dispatch. Rick Perlstein, a noted historian of the American conservative political movement, termed Giuliani's attempts to slow certification in the wake of the riot as treasonous. "Sedition. Open and shut. He talked about the time that was being opened up. He was welcoming, and using, the violence. This needs to be investigated," Perlstein tweeted on January 11, 2021. Giuliani faced criticism for his appearance at the rally and the Capitol riot that followed it. Former Congressman and MSNBC host Joe Scarborough called for the arrest of Giuliani, President Trump, and Donald Trump Jr. Manhattan College president Brennan O'Donnell stated in a January7 open letter to the college community, "one of the loudest voices fueling the anger, hatred, and violence that spilled out yesterday is a graduate of our College, Rudolph Giuliani. His conduct as a leader of the campaign to de-legitimize the election and disenfranchise millions of votershas been and continues to be a repudiation of the deepest values of his alma mater." On January 11, the New York State Bar Association, an advocacy group for the legal profession in New York state, announced that it was launching an investigation into whether Giuliani should be removed from its membership rolls, noting both Giuliani's comments to the Trump supporter rally at the Ellipse on January 6, and that it "has received hundreds of complaints in recent months about Mr. Giuliani and his baseless efforts on behalf of President Trump to cast doubt on the veracity of the 2020 presidential election and, after the votes were cast, to overturn its legitimate results". Removal from the group's membership rolls would not directly disbar Giuliani from practicing law in New York. New York State Sen. Brad Hoylman and lawyers' group Lawyers Defending American Democracy, also filed a complaints against Giuliani with the Attorney Grievance Committee of the First Judicial Department of the New York Supreme Court, which has the authority to discipline and disbar licensed New York lawyers. Also on January 11, 2021, District of Columbia Attorney General Karl Racine said that he is looking at whether to charge Giuliani, along with Donald Trump Jr. and Representative Mo Brooks, with inciting the violent attack. On January 29, 2021, Giuliani said falsely that The Lincoln Project played