According to the filing:

Defendant Giuliani had now stipulated to:

• All elements of Plaintiffs’ defamation and defamation per se claims,
  including that he published his statements with actual malice;
• All elements of Plaintiffs intentional infliction of emotional distress claim,
  including that he intentionally and recklessly engaged in such conduct; and
• All elements of Plaintiffs’ civil conspiracy claim, including that there was
  a meeting of the minds on or before December 3, 2020, with Donald Trump
  and others and that Mr. Giuliani participated in overt acts pursuant to or in
  furtherance thereof.