“This case comes before the Court on Senator Lindsey Graham’s Supplemental Motion to Quash [40]. After due consideration, the Court again declines to quash the subpoena in its entirety. As to the issue of partial quashal, the Court quashes the subpoena only as to questions about Senator Graham’s investigatory fact-finding on the telephone calls to Georgia election officials, including how such information related to his decision to certify the results of the 2020 presidential election.”

“The Court finds that this area of inquiry falls under the protection of the Speech or Debate Clause, which prohibits questions on legislative activity. As to the other categories, the Court finds that they are not legislative, and the Speech or Debate Clause does not apply to them. As such, Senator Graham may be questioned about any alleged efforts to encourage Secretary Raffensperger or others to throw out ballots or otherwise alter Georgia’s election practices and procedures. Likewise, the grand jury may inquire into Senator Graham’s alleged communications and coordination with the Trump Campaign and its post-election efforts in Georgia, as well as into Senator Graham’s public statements related to Georgia’s 2020 elections,” says the order by Judge Leigh Martin May.

Graham still has an appeal pending at the 11th Circuit, but this ruling certainly narrows his escape route considering how little of what was relevant would be covered by Speech and Debate.