There is not a single person in the United States—not the President and not anyone else— whose job description includes slandering women they sexually assaulted. That should not be a controversial proposition. Remarkably, however, the Justice Department seeks to prove it wrong. At the behest of the White House, and following a certification from the Attorney General pursuant to the Westfall Act, 28 U.S.C. § 2679(d), federal lawyers have moved to substitute the United States of America as the defendant in this action. They assert that Defendant Donald J. Trump was acting within the scope of his employment as President when he defamed Plaintiff E. Jean Carroll, a woman he sexually assaulted over twenty years ago, as retaliation for revealing his misconduct. Trump’s defamatory lies included assertions that Carroll had falsely accused other men of rape; that she was lying about him as part of a secret political conspiracy; that she had fabricated her accusation to sell books; and that he had never met her (despite a photograph of them together). Trump also remarked, “she’s not my type.” Compl. ¶ 97. These are the statements that the Justice Department asks the Court to find that Trump uttered within the scope of his duties as President.