I think that is being saved for SCOTUS.
PA is the lynch pin. All scenarios require Trump to take PA. The greatest and most obvious fraud occurred in PA. Then we need two others, either WI, MI, GA, AZ and/or NV.
SCOTUS reviews only the issues raised in the lower courts. Giuliani not only didn't allege fraud in the lower court, he affirmatively stipulated that the Trump campaign wasn't claiming fraud.
No matter who was representing Trump, the Court would have ruled against them. Giuliani is great.