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March 15, 2019 - Depositions & Trials
01:58:04
Deposition of Free Speech Systems, LLC, Rob Dew - March 15, 2019
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Time Text
We are on record for the videotape deposition of Free Speech Systems LLC, Corporate Representative, Mr. Rob Dew, taken on Friday, March 15th, 2019.
The time is approximately 1247 p.m.
Please swear to witness.
Could you raise your right-hand to be sworn?
If you solemnly state the testimony you're about to give will be the truth, the whole truth, and nothing but the truth.
Yes.
Thank you.
Please say your name for us.
Rob Dew.
Mr. Dew, you are here as the corporate representative for free speech systems LLC, correct?
Correct.
Are you employed by them?
Yes.
What is your position?
Nightly News Director.
In preparing for, you understand that your capacity today is speaking on behalf of the business entity and not in your personal capacity, correct?
Correct.
Did you have an adequate amount of time to prepare for today's deposition?
Yes.
Okay.
In front of you is exhibit one.
It is a notice to this deposition.
Have you reviewed it?
Yes.
Okay.
Topic one says the free speech system LLC's organizational structure, business purposes, and method of generating revenue.
Are you prepared to testify as to that topic for as the corporate representative of the company?
Yes.
The ownership and management and management of free speech systems LLC from 2012 to 17.
Are you prepared to testify to that topic?
Yes.
Okay.
I think we can skip three.
The factual basis for free, number four, the factual basis for free speech system LLC's reporting on the Sandy Hook Elementary School shooting.
Are you prepared to give testimony on behalf of the corporate of the company for that topic?
Yes.
The roles and job duties of free speech system LLC personnel involved in the creation of InfoWars content pertaining to the Sandy Hook Elementary School shooting.
Yes.
The creation, research, editing, marketing, funding, staffing, distribution, and publication of the videos described in plaintiff's petition in this case.
Are you prepared to give testimony with regards to that topic?
Yes.
Okay.
And free speech system LLC's knowledge and relationship with Jim Fetzer, including communications related to Sandy Hook Elementary School shooting.
Are you prepared to testify on behalf of the company as to that topic?
Yes.
Free speech system LLC's relationship with regards to Wolfgang Halbig and the Sandy Hook Elementary School shooting.
Are you prepared to discuss that topic?
Yes.
And free speech LLC's knowledge and relationship with any third party conducting investigation, research, or creating media related to Sandy Hook Elementary School shooting.
You're prepared to discuss that topic?
Yes.
And last, the documents produced by Free Speech LLC in response to plaintiffs' expedited discovery.
You were prepared to discuss that topic.
Correct?
Correct.
Okay, let's start with number 10.
How many documents did you review preparing for number 10?
I don't know if I know an exact number, but I looked at, I was looking at emails.
Some emails were one or two pages, and some emails were 30 or 40 if you go back and look at the conversation.
And.
Did you look at more than 100 files?
Yes.
more than 200.
I'm not sure.
Maybe between 100 and 200.
I'm not sure of an exact number because a lot of them are pages and I would say around 200.
Sure.
Where did you get that information?
A lot of it was going through my own personal correspondence because I did have correspondence with some of these people and then looking at what our IT team provided.
Your what?
IT.
IT.
Yes.
Okay.
Did you, do you have any idea what documents have been produced in this case?
As far as I know, it's emails and articles.
Okay.
Have any of your personal emails that you reviewed and relied on in preparing for your deposition today?
Have any of those been produced?
As far as I know, I've seen my name on some of them.
Okay.
Did you look at any emails in your personal email account that weren't produced?
No, I don't think so.
I think everything that I gave, that I presented and said these are mine, all were produced to mine.
Who did you give those to?
I believe I presented them to one of the attorneys that I made printouts.
Yes.
When was this?
What would you have given all these emails?
Hmm.
I think sometime in...
Sometime in January.
I don't know the exact date.
I've so there have been several lawsuits with cons with that pertain to Sandy Hook and so a lot of it is I've been gathering stuff for a while so some of it might overlap with what this particular with this particular case I gotcha what so if you've been collecting since back then it was before mr. Barnes
involved, correct?
Mm-hmm.
Okay.
Did you review any emails between yourself and Alex Jones?
I don't think I have any emails between me and Alex Jones.
Okay.
Did you review any emails where you were the sender to Wolfgang Halbig?
Yes.
Where you were the sender to James Fetzer, Jim Fetzer?
I don't know if I was replying back to him or if I was the sender on an email to Fetzer.
I can't answer that right now.
But I know I had communication with him.
Okay.
Via email.
Do you have any idea where those emails are?
Presumably on a server.
Okay.
Free Speech System LLC.
Who owns it?
Alex Jones.
What is its business purpose?
To provide information and commentary on events that are going on.
What kind of events?
I would say anything newsworthy and
also anything where our we specifically look at instances where our constitutional rights are being eroded okay does anyone else own any shareholdings in free speech systems I do not think so I do not believe so and by I don't think so or believe so.
You don't know anyone else besides Alex Jones.
To my knowledge, it's just Alex Jones.
Right.
And to be clear, to your knowledge means to the knowledge of free speech system LLCs.
Correct.
Okay.
How does it, how does free speech system LLC make money?
We have a website where we sell products and people buy ads on the website or I would say those are probably the two primary ways prior to 2018.
did free speech systems generate revenue through Facebook and YouTube?
Definitely through YouTube and because we had a partnership agreement with YouTube.
Was it a significant amount of money?
I think in the grand scheme, it was enough to because it went up and down.
So I don't significant enough to cover the costs of one, maybe two employees to generate stuff for YouTube.
Okay.
And in the grand scheme of total revenue brought in by free speech systems, you have any idea what kind of percentage the I wouldn't have any idea of an exact percentage, but I would.
Are you specifically speaking about YouTube?
Sure.
I would say it was less than 1%.
Okay, where does the majority of revenue come from?
supplements or products or does it come from ad buys I would say it's listener-supported.
So I would say most of that is coming from people either donating or buying products.
Okay.
And speaking of, are you on any of the products from InfoWars right now?
Am I on them?
Have you taken any of them?
Supplements, anything like that?
Ever?
Today.
Oh, today.
I've not taken any today.
Do you regularly take any of them?
I would say there's a turmeric product I take irregularly.
The management system at free speech.
Who's under Alex Jones?
He's on top, and then I would say there's people under him, and then maybe people who haven't been around long enough who are being trained or organized, but there's not much of a hierarchy in terms of a corporate structure.
It's very go through that second tier, the people below Jones.
Who is that?
Well, it's kind of hard to define because Jones will say something.
If something needs to be done, he tells somebody, whoever's around him, and then that person would be either in charge of getting it done or in charge of putting the message out.
But I manage several production people, and that's on my end.
How many production people?
Right now, I'd say there's maybe I'd say anywhere between 35 and 40 production people.
Okay.
Who else manages people and InfoWars that's under Alex Jones?
Um...
There's Tim Fruger.
I would say would be more under the business side of maintaining warehouse functionality, like more of the business in.
I'm more of a production in.
Okay.
What on the business side, what does he do?
Tim?
If you know.
I don't know all of his duties, but he mainly hires people on that end, and then a lot of it is training people on how we do things, but it's a very flat organization.
There's not a lot of position titles or depth.
Okay.
I've got you in the second tier.
I've got you and I've got Tim.
Frugé, who else is on that second tier?
I'm not sure.
Well, like I said, it's not clearly defined in any corporate structure.
So I wouldn't know how to.
We have an accounting head.
Who's that?
Objection.
Sir, the instructor witness not to answer on any matters that concern privacy, including third-party identity interest at this time.
Sure.
The accounting department, they are InfoWars employees.
I mean, free speech system employees?
As far as I know.
What are their names?
Objection would instruct the witness not to answer our privacy grounds as to third-party privacy matters concerning the identities of anyone outside of something specific to Sandy Hook.
That's not operating at an ownership or management level.
This second tier of people that we're talking about, would you consider them kind of the managers of the people below them?
So...
And let me back up.
Earlier, you said you had 35 to 40 people under you.
Mm-hmm.
Are there people under the accounting department?
Well, I would not say they're all under me, but I have probably hired most of them.
And then they're doing...
It's not a typical company where you have managers and then leads, although I would say some of those people are leads.
Is there an accounting department or just
just one person I think there's more than one person okay who's in charge of that department I would say Alex Jones is in charge of that department okay we've got accounting we've got the business side which is Tim Fruger we've got you as the nightly news director who else is in the second tier?
If you know I think second tier is how I guess I would classify it personally.
I'm asking for your opinions as the corporate representative of the entity right now.
it.
And like I said, if you don't know, you don't know.
It's fine.
I don't think there's anybody else that would be at that level.
Okay.
The factual number four, topic number four.
Let's talk about that.
Okay.
The day of the shooting.
Yesterday you were in Mr. Jones's deposition.
We saw a video that was produced and played on Infowars.com the day of the Sandy Hook shooting on December 12th, 2014, or December 14th, 2012, correct?
I don't know if I saw that video.
I was not here for the whole deposition.
Okay.
A video was played on December 14th, 2012, the day of the shooting, regarding Sandy Hooks and possibly being a fake hoax or false flag, correct?
Um… Do you have an example of it?
I don't really remember what was played that day.
What's the first video or article that was produced on InfoWars.com regarding Sandy Hook and it being a hoax and/or false flag?
Thank you.
Can you explain what you mean by hoax?
Do you know what the word hoax means?
I know what the word hoax means.
What does it mean?
Something that was an a hoax is an event or a hoax is meant to fool people.
What is the factual basis that free speech systems relied on when it first reported Sandy Hook Elementary might be a hoax?
I believe most of our reporting was involved with looking at how this event would be used to take people's Second Amendment rights.
When did that conversation start?
I believe that conversation started the day of the event.
Why would you, what made free speech systems start having that conversation?
Because we have seen past events where a gun is used and when a gun is used, the gun becomes the cause and then they look at gun owners as being people that need to be stripped of their rights and gun ownership.
And so this was not the first time we had seen a shooting event occur where the next step would be, oh, now we have to start looking at people's Second Amendment rights and seeing where those could be infringed.
Who would be looking at other people's Second Amendment rights?
I think politicians and people in the media.
Okay.
So before the day of, when it was reported on InfoWars when this community, when these conversations were happening, you already had information that politicians were going after a gun that had or had not been disclosed to the public yet?
No, I didn't say that.
I'm asking you, why did you have the why did the conversation of a hoax start hours after this shooting happened?
Well, I didn't use the word hoax.
What I said was when these events happen, the step that politicians use is we have to come up with a blame.
And the media pushes that narrative of gun owners are to blame.
And then Infowars.com pushes their own narrative, which is this is a hoax.
Is that what you're saying?
No, that's not what I'm saying.
Okay.
What information did Infowars have the day that this shooting happened that this was a hoax?
The day that it happened?
Correct.
I don't think we published anything that said this is a hoax.
When did InfoWars publish content?
Okay.
The day of the Sandy Hook shooting, Mr. Jones went on his show and suggested that this was all staged by the government.
Correct?
You'd have to show me the video.
I'm asking you, what's the factual basis for Mr. Jones' theory the day of as it relates to number four listed in the piece of paper in front of you?
What was the factual basis for him saying the government staged this?
I think the factual basis goes back to a document that was declassified in the late 1990s, and it was called Operation Northwoods.
And in that, it describes situations where the government would create events and stage, one of which was bombing airlines, also staging mass shootings.
they say in theaters I believe schools is also listed in that I haven't looked at that document in a while but that document became declassified and it was signed by the heads of the of the military and given to President Kennedy okay so because that document was declassified in the 90s every single mass shooting immediately mr. Jones goes on infowars.com
on his radio show and suggest that this is staged.
I just want to make sure that I have my factual basis clear.
I think what we do is...
Not what you do, what you did.
What we did.
We remind people, or we reminded people, and I'm not even sure if he mentioned Northwoods that day or not.
But I'm sure that was in his mind, although I can't speak for him.
But that document exists.
It is a government document, and it's signed by...
I don't know their exact titles, but I think one of them was the Joint Chiefs of Staff.
Those are high-up military personnel, and they signed a document saying, these are events that we can use to carry out, we can plan and this has nothing to do with anybody at Sandy Hook or anybody in any other mass shooting.
I agree.
This has to do with our government says, put it on paper that we should do these things for political purposes.
Okay.
So.
And so I think the I think you remind people of that.
When these events happen.
Sitting here on behalf of Free Speech Systems, did the shooting at Sandy Hook Elementary happened the way that it was reported by the overwhelmingly majority of the media?
Objection is to form.
You can answer.
I still have doubts that Adam Lanza was the only person involved.
Okay.
So.
But I believe children were killed at Sandy Hook.
And I don't remember ever saying that children did not die at Sandy Hook.
Okay.
So you think this is some sort of hoax that Adam Lanza wasn't alone and someone else shot up a bunch of children in Sandy Hook Elementary School.
Sitting here as the corporate representative for Free Speech Systems.
Are you saying right now or then?
Is that true?
Right now.
Sitting here right now.
Right now.
I think things have evolved over time.
I think the government and the law enforcement in Connecticut, by their obfuscation, helped make this turn this into what it is today.
And I do not believe they helped the situation.
You don't believe they helped?
I don't believe they helped the situation in answering people's questions.
Okay.
Do you have any idea what question I asked before you said all those words?
You said, do I think Adam Lanza acted alone?
Does Free Speech Systems believe Adam Lanza acted alone or that someone else came in and shot up a bunch of children at Sandy Hook Elementary?
That was my question.
Thank you.
I think we agree with the findings that came out in January of 2018.
What findings were those?
It was a report released by the Connecticut State Police.
Okay.
And what's in there?
That is what Free Speech Systems believed happened on December 14th, 2012.
I would have to go back and examine that document again.
Did you examine it, prepare for your testimony today?
There is a lot of If you're looking at the time frame of back in January, I have not looked at it in a while.
It was before January.
So the answer to my question is no, I did not review it to prepare for my deposition today.
I believe I had a lot of that.
I believe I had most of the major instances.
I did not look at it.
I've not looked at it this year.
I'll say that.
At what point did free speech systems believe this the Sandy Hook Elementary School shooting was a hoax and staged by the government?
Well, I believe it was a couple videos that had come out on YouTube and then an article by James Tracy, who is a professor.
And I'm not going to say that's when we believed it was a hoax.
That was when we started asking more questions as to the event.
And so this is a long process.
I couldn't name a time or date or place that things happened, but we started asking more questions and we started getting looking at videos people would send us and drawing our own conclusions as to what we're actually seeing in those videos.
Because some people send videos and say, this guy's lying.
And you look at him, you go, well, you can't tell if he's lying.
Who's in charge of vetting the information that you receive?
We get the information and before it is shown to Alex and I believe he is the final vetor of the information.
Okay, you get the information and before you show it to Alex, you believe he is the inventor?
No, before it goes on air is what I meant to say.
Okay, so before it goes on air, you take it to Alex and he vets it.
Yeah.
Okay, and that's the whole process?
Not always.
It depends on if it's a person saying they have information, we ask for, say if they're from the military or from law enforcement, we ask for some sort of credential.
If they work at a place, we ask for an ID or maybe a pay stub.
So something that would validate what they're saying is, yes, I work here or I've done this.
What if it's a picture or a video?
Who bets that before it goes on?
Okay.
Those are shown to Alex, and then he would be the final call.
The buck stops with him.
the This report that was released by the Connecticut State Police in January 2018, how is it different from the original Connecticut report, the Newtown report that came out in December of 2013?
Well, from what I remember, the report that was initially released was redacted and did not have It was, I believe, it was critical of certain aspects of what happened that day.
And this new report seemed to be not as critical of the law enforcement response, the second report.
That's the only difference?
That's what I can recall comparing it to the initial report.
Yes, let me back up then.
That, what you just testified to, that information was what changed Free Speech Systems' position on whether or not Sandy Hook was real?
Correct?
Objection is to form.
I think there's a lot of different things that happen over time with these events.
Okay.
Was InfoWars wrong in its initial reporting about what happened at Sandy Hood?
At the time we reported anything, we're not putting out information that we believe to be untrue.
So if we put it out at that time, at that time we believed it to be true.
Sure, but if one person at the top is vetting all the information and he just says, well, I think it's true, you can throw up anything, right?
Correct?
I don't agree with that statement.
If Alex Jones wants something to go on the air, he can put it up and nobody can stop him at Free Speech Systems, correct?
Alex is the boss, yes.
So if Mr. Jones believes something, then Free Speech Systems can just hide behind the veil of, well, we thought it was true at the time that we put out the wrong information.
Is that true?
Objection is to form.
I don't believe we're hiding behind anything.
Okay.
Do you believe InfoWars between December of 2012 and 2017?
Do you believe InfoWars was practicing good journalism?
Objection is to form.
I believe we provide information to people that is not seen or covered on the mainstream media in a perspective that is not seen or reported on on the mainstream media.
Sure, but that in no way answered my question.
My question was: from 2012 to 2017, did InfoWars practice good journalism?
Objection is to form.
Actually, let's do one better.
Do you believe that InfoWars has that the people putting out the content at InfoWars are journalists?
I believe we wear a lot of different hats, one of which is a journalistic hat, which is providing information to people.
True vetted information to people, correct?
Objection is to form?
I believe we vet information.
Okay.
What did you do to...
We'll come back to that.
Let's talk about Wolfgang Halbig.
Did InfoWars reach out to him?
Infowords.com, reach out to him, or did he reach out to you?
He's a good one.
I believe he reached out to us at some point saying he was a school safety expert.
Okay.
And looking back in hindsight, does Free Speech Systems believe that was a good idea to start communicating and having him on the shows?
I believe one of the first things he said was that he had given money to the victims.
What does that mean?
Well, that he believed it was a real event.
And then after, from what he was doing and asking questions, he was not getting answers to his questions.
Okay.
When did Mr. Halbig tell Free Speech Systems that he gave money to the victims?
I believe he said it on air.
On your show?
Or on Free Speech Systems platform?
Yes, I believe he said that on the air.
Okay.
And InfoWars, or excuse me, yeah.
People at Infowars.com started getting a lot of information from Mr. Halbig, correct?
He sent numerous emails.
When you say numerous, it's in the hundreds, possibly thousands, correct?
An amount that I have not read even a small percentage of what he sent.
You were in Mr. Jones' deposition yesterday where he used the term kooky when we were talking about Mr. Halbig.
Do you throw him into that category as well?
I would say he's more, well, I don't know if I'd use the word kooky.
I would probably use the word obsessed.
Okay.
And I, you know, some people get obsessed on things and won't let them go.
Sure.
Have you ever been obsessed with anything regarding Sandy Hook?
Well, I did listen to probably a two-hour recording of the talks going back and forth on the CB radios.
And I've edited numerous hours of this.
I don't know if I'd call it an obsession, but I don't think I was obsessed with it.
We're going to skip to one of the other topics on your notice real quick, to number 10.
The documents that were produced by Free Speech Systems, there were a few hundred emails from Wolfgang Halbig to an assortment of people, including InfoWars personnel, not including them, some to a parent of one of the children that was killed.
When did InfoWars get those?
Do you have a specific email that you're referring to?
Because I don't necessarily look at all the who's front because his emails have lots of people added on to them, some of which get abbreviated.
Sure, let's mark this one.
We're on two.
Okay.
Before we go through this one, do you know who the plaintiff is in this lawsuit?
It's Ms. Lewis.
Okay.
Exhibit two.
You can see the signature block up top, who it's from and who it's to and the people CC'd.
Nobody from InfoWars is on that email, correct?
Nobody with an official InfoWars email.
I don't see an official InfoWars email in this.
Anybody with an unofficial InfoWars email?
I don't know everybody's emails.
So I can't confirm or deny that that Wild Rose Farm 1740 is not somebody at InfoWars.
I don't think it is.
Okay, can you read the email?
It is just a.
There's a name at the beginning.
Oh, Scarlett.
Okay.
It is just a matter of time that all the money You have has to be returned.
How could you even stop to buy coffee and you bought coffee for two other people?
What kind of mother does this does that, especially when you on the news tell everyone you ran across the fire department parking lot?
If you would, you would have spilled the coffee.
Do some serious soul searching because the scam is up.
What's the date on that?
March 10th, 2015.
What's Miss Lewis's first name?
It is Scarlett.
Okay.
And how did Free Speech Systems get that email?
Why was it in your possession?
This could have been attached to another email.
I mean, I don't know.
This is one page.
Well, I'm asking you, you're here to discuss the documents that have been produced in this case.
That was one of them.
Tell me when you got it and how.
I imagine it was included in a bevy of attachments.
And I want to stop you there.
I don't want you to imagine anything.
I want you to tell me what you know or answer I don't know, and I'm not prepared to discuss that.
On this particular email, I do not know.
Okay.
So for the email from Wolfgang Halbig to, and I'll represent to you that that is Scarlett Lewis' email address.
You do not know how Free Speech Systems got it, when they got it, but you do know that she's the plaintiff in this lawsuit.
Am I getting all those facts correct?
Okay.
I don't know that I've ever seen her email being Wild Rose Farm 1740.
Sure.
Wasn't my question.
Well, without guessing, I do not have an answer for you.
When did you, actually, how many times did Wolfgang Halving come on InfoWars programming or contribute to articles?
I would say between.
And I don't want you guessing.
No.
I don't know an exact number.
Okay.
More than five?
Yes.
More than ten?
Yes.
At what point did Free Speech Systems realize that Wolfgang Halbig was obsessed with this story?
I don't know an exact date of when that happened.
Do you have a year?
I would say sometime in time in 2015.
What was the date on the email you just read?
March 10th, 2015.
Okay.
Would have been before or after March 10th of that year.
I cannot tell you that.
I would have to look at videos of when he appeared.
Did you realize that Wolfgang Halbig was obsessed with this story in June of 2015?
I cannot put an exact date on it.
Okay.
I wouldn't say, no, I could not say that if it was June before or after.
Okay.
Free speech systems sent Mr. Badondi up to Connecticut in June of 2015, correct?
Objection is to the form.
What's the form?
The that presumes facts and evidence.
This is a deposition.
We're literally making evidence.
We.
In other words, that the it was normally that would be broken into two parts.
That's what I mean.
I'm not trying to make this part.
Tell me that's fair.
You're aware that Mr. Badondi.
Free Speech Systems is aware Mr. Bedondi went to Connecticut in June 2015.
I'm aware.
I couldn't give you the exact date.
Okay.
You watched the footage, though.
From yesterday.
That was the first time you'd ever seen it?
No, I'd seen it before.
Okay.
What is free speech system's stance on that footage?
I believe it was I would say it was reasons like that is why we didn't, he was not hired, he was no longer working for us.
At the time, he was, though.
On a freelance basis at times.
So at that time, he was working for Free Speech Systems.
I would have to see if he received a check at that time.
Okay.
There were times where he was sent to Connecticut on behalf of Free Speech Systems.
There were times where he would contact someone at the office saying, hey, I can go up here if you want us to.
And our position was we would see what came over what he would produce, because sometimes he would not produce anything.
Okay.
But after June of 2015, that's when Free Speech Systems was company-wide said we are no longer going to be associated with this guy.
I don't know if it was June or not, but there's definitely an email that I believe I sent to him or that I sent to him and said he's no longer representing or not to represent Free Speech Systems.
Okay.
And that wasn't anything to do with like a journalist source.
That was just you telling somebody to stop saying he's associated with you.
Correct.
Okay.
Where's that email?
Um...
I assume you have it.
I've never seen that email.
Love to.
Any idea where it could be?
Let's back up.
Did you give it to anybody?
Did you give it to Mr. Bankston?
Did you send it to Mr. Bankston?
I don't know if I sent any documents to Mr. Bankston.
Did you send it to Mr. Enoch?
I don't believe I sent any documents to Mr. Enoch.
I didn't send it to Mr. Barnes.
There's a lot of attorneys working on the case, and so it went to another attorney, I imagine.
Okay.
But I'm not, thinking back, it may have been a text, but I would have to look through everything again.
So you have texted, you have a texting relationship with Mr. Bedanti?
Not generally.
But you have there were text messages that were found, I guess, if you're bringing them up.
Correct?
There might be one or two or something, depending on we generally like to do things in email.
Okay.
Especially if it's don't we don't want you representing us anymore.
Okay.
And that email was sent pretty near the June 2015 incident.
Is that what you're saying?
I would have to look at the email to determine that.
Do you have access to it now?
I'd love to see it as well.
No, I don't have access to it now.
Council, either of you guys know where it is?
He said it wasn't privileged in any way, and I'm trying to figure out what's going on here.
I could try to look at it.
I think what is, we did all the same hooks search there.
So the, I don't know.
I mean, I wasn't part of it at that point, but my understanding is they were looking at those terms.
I don't know if they looked at his name may not be in the substance of it, so we'd have to track it a different way.
It's not the most sophisticated I teach us.
Mr. Davis and Alex, I don't know what Donnie is.
Yesterday, during Mr. Jones' deposition, you were in the room.
Mr. Jones testified that that day that the YouTube video with Mr. Bedandi in June 2015 went up, that he called him and said, do not do that.
Do not represent Infowars anymore.
You are in no way affiliated with that.
Was that true?
I was not there for that conversation.
But at some point, the word went out.
At some point we ended our relationship with Vedanti.
Okay.
And that was made throughout the company.
Okay.
And that company-wide it was made, and it was because of the video that he had posted that we watched a clip of from June 2015 where he's kind of following and yelling at lawyers and stuff like that, right?
I imagine that would have been around the time.
Okay.
And according to Mr. Jones, that day he was fired.
After that, he was and then soon after that, company-wide, he was told not to use him anymore.
correct There are times when we've ended relationships with people that several years later they may have something or do something and come back within our purview.
Sure.
But you're not going and asking.
Nobody from free speech is saying, calling him up, saying, hey, go back and let's do some more of that.
No.
We're not into that type of behavior.
What type?
What was on that video?
But I don't think he was the one making those curse words that you were claiming he was making.
Okay.
The Jim Fetzer.
What do you know about Jim Fetzer?
That he's an author, and I don't know if he's a talk show host, but he's been on a lot of talk shows.
Okay.
He's, I think to this day, he still holds that Sandy Hooks was a hoax.
You would agree?
I believe that is his view.
Yes.
What was your relationship with Mr. Fetzer?
He was a guest, but not that frequently.
Okay.
Why did he start becoming a guest?
I believe he was a guest long before Sandy Hook.
And I don't even But he was not a frequent guest.
So prior to Sandy Hook, he was just another believer in conspiracy theories, right?
I don't know what his beliefs are, but I imagine he's, yeah, I don't know what his beliefs are in terms of what you just said, conspiracy theories.
Do you know what a conspiracy theory is?
I guess that's the belief that two or more people get together to plan an event.
Okay.
Have you ever heard Mr. Jones use conspiracy theories on his radio show or video?
I've heard.
Is that the way he uses it on his show?
Is it the way that you just defined it?
I believe that's what you need to make a conspiracy is that two or more people get together.
And I think he's made that distinction on the air several times.
Okay.
Does free speech systems push hoaxes around news stories?
I do not believe we push hoaxes.
Did you push hoaxes?
Did you push for a number of years that Sandy Hooks was a hoax?
No, I believe we were looking at the Second Amendment aspects and now it seems the First Amendment aspects of the fallout of these events.
When you say looking at, you're not talking, you weren't looking at it.
It was actively being reported.
Correct?
What was actively being reported?
That this is as phony as a $3 bill.
I've seen actors.
I know what actors are.
I've seen soap operas.
That's not them.
He, at one point, impersonates a grieving parent by fake crying.
That's not questioning, is it?
Objections to form.
You can answer.
You were saying that that's not what?
You said we just questioned the Second Amendment aspect of this story.
But Mr. Jones has been on his show said, this is as phony as a $3 bill.
Does that sound like a question?
That sounds like a statement.
It does sound like a statement.
He also says, I've seen actors, I've seen soap operas, and these parents are actors.
Does that sound like a question?
Objections to form.
I'm not sure he was referring to parents in that capacity.
What could he possibly be, in what capacity could he possibly have otherwise been referring to?
I'll let you go with any capacity you can think of.
I believe he was looking at the way the media and even our, I think he believed he made a comment about President Obama, the way they were using this.
For between December 2012 and today, has Mr. Jones ever referred to parents as actors?
And by parents, I mean the parents of the children that died at Sandy Hook Elementary School.
I believe you have, if you look at the footage, there's even law enforcement personnel referring to people as actors.
Not my question in any shape, form, or fashion.
Has Mr. Jones ever reported that the parents of the dead children from Sandy Hook Elementary School were faking and were actors about this situation?
I do not believe he was referring to parents as I believe when he says acting, he's talking about coaching from the mainstream media and the way they paraded those poor people in front of the camera day after day after day to talk about taking people's guns.
I feel sorry to a breaking point.
I've got one, two, two follow-up questions.
As far as free speech is concerned, has anyone else at free speech said that parents were actors?
There's people who believed all kinds of things during that.
There's some people that believed everything that was coming out of the from the media was true, and there were some people that did not believe that.
So there were, and we have open debates about those things.
Right.
Because we believe that's the best place to have them is in the open.
And by open, you mean on the show?
Correct.
So, for instance, when you went on the show and you said, I know Robbie Parker is an actor, I'm an actor.
I have a degree in theater.
Does that sound like a question?
Or are you making a statement?
I was referring to him preparing right before he began speaking.
Sure.
I asked the question of, does that sound like a question or a statement, Mr. Dew?
That sounds like a statement, and that was based on experience.
And you were doing that as an employee for Free Speech Systems, correct?
I believe we are allowed to make statements.
Correct.
And you are doing it on a show that is owned and produced by Free Speech Systems, correct?
Correct?
I made that statement.
And you did it on a show owned by Free Speech Systems?
And I believed at the time, when I was looking at what I was seeing, that Robbie Parker was going through some sort of actor training.
Not my question.
My question was, you made that statement on a show owned by Free Speech Systems and produced by Free Speech Systems, correct?
Correct.
Let me take a break.
We're off the record.
1.52 p.m.
We are back on the record at 2.04 p.m.
All the content that happens on InfoWars programming is owned by Free Speech Systems, correct?
InfoWars.com?
Yes.
Correct.
InfoWars Twitter, InfoWars.
I mean, what was Infowars?
Twitter, Facebook, Instagram, stuff like that.
It's all owned by Free Speech Systems, correct?
Correct.
Which is owned by Alex Jones.
Correct.
Okay.
And that programming in February 12, 2015, you personally were on a Free Speech Systems program and said that they sealed all the death certificates.
You remember that?
What was the date?
February 12, 2015.
February 12, 2015.
I believe at the time that is what I believed that they had blocked those because they felt they weren't releasing them to the public.
What did you do to try and get it?
Did you fill out a FOIA request?
I did not.
Okay.
What'd you do to learn that they weren't giving them to the public?
I did internet searches looking for those.
I don't know if I did it that day, but I had done searches in the past looking for those because people were saying they're not providing the death certificates of these kids.
Yeah, but you're a journalist.
You're supposed to vet that information before you put it out onto the internet, right?
Objection is to four.
I'll back up.
Are you a journalist?
I provide information.
Are you a journalist?
Do you consider yourself a journalist?
I think I wear a lot of hats.
Do you wear a journalist hat?
I believe I do.
Okay.
When you get information, proper journalist integrity would say, I need to vet this to make sure this information is true, correct?
And yes.
Yes.
So you got this information from some Google searches.
Did you fill out, did you ever attempt to get a death certificate?
I did not.
Okay.
Because I read that they were not, they were sealing them.
They would not release them.
Where were you reading this?
I couldn't give you the exact article or website, but that was, I think it was common knowledge that they weren't releasing death certificates.
When you say common knowledge, please tell us who that would be having that common knowledge.
What group of people would possibly think that was common knowledge?
One doesn't come to mind.
Okay.
So you can't think of a single group of people who would think common knowledge was that the death certificates were being withheld and were sealed.
Now that we've established that, you went on to say in that same program on February 12th of 2015 that it was a felony to get those death certificates.
Remember saying that?
No, I'd have to see the video.
Okay.
Have you ever believed that it was a felony to get to order to do a FOIA request and pay the $15 or $20 to get a death certificate?
I might have been, I'd have to look at the video, but I was probably conflating several things together, one of which was a, I believe it was the head of the state police who came out and said, we're going to go after people who ask questions.
And I believe there's video of that somewhere.
Right.
And that makes it a felony?
Or did you just make that up?
I don't believe I made that up.
Okay, so you would have found a law somewhere that would have made it a felony?
Well, we're talking about something that was five years ago, six years ago.
So you would have been able to just go on the internet back then and find a law that made it a felony, correct?
Let me back up.
I'll make this a lot easier.
Other than the police officer saying he's going to go after people for asking questions that you claim have.
He said prosecute, I believe.
Prosecute.
Other than that, what could have led you to believe that doing a FOIA request for death certificates would have been a felony?
I think at the time, and that might have been information from a number of guests who were trying to get this information and were unable to.
Okay, so you just took a bunch of information from everyone else, did zero vetting, and threw it out there as true.
Objection is.
Correct?
Objection is to form.
I would have to see the video to know exactly what else was said beside from a simple quote.
Okay.
Do you ever, do you remember telling the InvoWars audience that it was a felony to try and get death certificates for the victims of Sandy Hook Elementary School?
Do you remember that?
I don't remember saying that.
I would have to see the video.
Do you remember having that belief?
Do you remember having that belief?
I remember something having to do with the Connecticut Supreme Court not releasing that information.
And which I believe they made it sealed.
And I'm not sure if it was maybe possession of those since they had sealed them was going to be a felony or asking for them.
If they made possession of sealed documents, what would make you think that was a felony?
Where did you come to the conclusion that anything was a felony?
Or did you just make it up?
It's fine if you did.
I'm just curious.
Like I said, I'd have to see the video and see exactly what else I was saying at that point.
Also, you said that the state police said he was coming after anybody that was asking questions, correct?
That's what you just said earlier?
I believe they said false, putting out false information, what they considered false information.
Spreading misinformation.
Misinformation.
Okay.
I just wanted to clear that up.
Sure.
Because it wasn't people that were asking questions.
It was people that were intentionally and willfully spreading misinformation.
Correct?
And it was that statement that made us go, this is interesting.
Now, why would they have a problem with people asking questions?
Because you could say asking a question is spreading misinformation.
No.
When you say we were questioning things and then it comes out and said, this is as fake as a $3 bill, you and I already agreed.
That's not a question.
That's a statement.
That is spreading a statement of misinformation, correct?
But you're taking statements that are misinformed.
I'm asking a question.
Correct?
Don't interrupt the deposition, Mr. Enoch.
Please let the witness finish his question.
His answer, would you do that, please, Mr. Ogden?
If Mr. Barnes would like to do it, as he's defending this deposition and you're sitting over there, I'm happy to entertain anything Mr. Barnes has to say because he's the one that is allowed to talk in this.
Do you agree?
Actually, can we?
I'm going to pause this from the time.
No, stay on the record.
Do you agree that only one attorney in Texas gets to defend a deposition and speak?
Mr. Ogden.
No, I'm asking a question.
Do you?
Please don't interrupt me again.
I haven't interrupted you.
You just interrupted my deposition.
I suggest you continue your deposition instructive.
I'm asking you, do you agree with me that only in the pursuit of the rules, one attorney is allowed to defend a deposition?
Would you please continue your deposition instructed?
Are we just going to ignore the Texas rules and civil procedure?
Is that what we're doing?
I want to know why you keep interrupting and what's the basis for?
Please continue your deposition instruction.
I keep hearing you say those words, but are you just not going to answer?
You're just going to keep interrupting and being an obstructionist?
I think you ought to go ahead and ask the questions to the witness and take your deposition, sir.
Okay.
But before I go forward, I just want you to know everything you're saying is his job.
If he's not doing it, talk to him and he can do his job.
your team decided he was defending these depositions, not you.
*Sigh*
Where were we?
I don't know.
Felonies.
I think we're beyond that.
Okay.
We can agree.
In November of 2011, 2016, a year and nine months after you claimed somewhere that it was a felony for some reason, Alex Jones then repeated that claim in November of 2016.
Are you aware of that?
I'd have to see the video.
If someone said it was a felony to get death certificates when it wasn't, that would be spreading misinformation, correct?
If somebody said that, and if that is wrong, I would say that would be misinformation.
Okay.
You and I can agree that you can order the death certificates right now online for $20 a piece, correct?
I believe they finally unsealed them.
When?
I don't know the exact date.
Well, you were prepared with the knowledge and gathering of information that was the factual basis for free speech's positions on this stuff.
So I'm asking you, when did you learn that you and Mr. Jones had previously been spreading misinformation?
Well, I don't believe I was in charge of the Sandy Hood case, and I believe that we had left that subject, and we tried to leave that subject.
Okay.
Mr. Dew, wasn't my question.
Whether you were in charge of it or not, you're here today speaking on behalf of the company for it.
They designated for it, and you should have prepared.
So I'm asking you, when did you learn that you can order the death certificates online?
So I would say maybe sometime during 2018.
Okay.
Were you covered every day?
Are you still on Twitter?
I am still on Twitter.
Is it dues, news, dues with an S, news with a Z?
Correct.
Did you get multiple tweets from a person named C.W. Wade that was telling you that you can order the death certificates online back in November of 2016?
I don't.
I may have.
Just because somebody sends you something on Twitter doesn't mean you read it.
Okay.
Did I respond to him?
Do you know who C.W. Wade is?
No.
You do not know who C.W. Wade is?
I don't know.
Is that a Twitter name or is that somebody's name?
At CW Wade's with an S, and CW Wade is the name.
The name of the person?
You are testifying under oath, under the penalty of perjury, that you don't know who C.W. Wade is.
Are you asking if I've met him in person?
Do you know who that is?
Sitting here right now, I do not know who that is.
Do you have a picture of me with him?
Okay.
I don't know.
That's my question.
That's the only question I have.
Okay.
Aiden Salazar.
You know who that is?
I know an Adon Salazar.
Adon Salazar.
What is his job title?
He's a writer.
Is he one of the writers under you?
No.
Okay.
Are you aware, is he employed by Free Speech Systems?
Yes, he is.
And is he, would you agree with me that he is the person responsible for outing Mr. Posner as the founder of the Honor organization?
I would not agree with you on that.
Okay.
Why?
Because I'm not sure if that information wasn't already public at the time.
Are you suggesting he wrote an article?
Are you referencing a specific article?
Now I'm just trying to figure out what information at the time, what prior information to that time, are you thinking that Mr. Posner was holding himself out as the founder of Honor?
I'm not sure when, Mr. Posner, but I've seen video of Mr. Posner talking about the Honor Network.
Now I don't know when that video was produced or when it was displayed because they don't always have those things when you look at video.
So after all that, the answer is I don't know.
Correct?
You're asking me if Adan Salazar was the first person to say that or right that Mr. Posner was the founder of the Honor Network.
And your answer is I don't know, correct?
That is my answer.
Okay.
Jonathan Reich or Raish or Reese, do you know who that is?
No.
R-E-I-C-H.
Jonathan R-E-I-C-H.
That name doesn't ring a bell.
I think I've heard the name, but I don't know if I've had any communication with a Jonathan Reich.
Do you have any understanding of who that is?
I imagine he's involved in this somehow.
But according to Free Speech Systems, after reviewing all of the produced documents that are listed in topic number 10, you don't have any other information on him.
Is that what you're testifying to?
I imagine he is some ancillary person that you're going to try to entrap me with some sort of gotcha moment.
Definitely not trying to do that.
I'm just curious as to what you know.
If you prepared and reviewed the documents that were produced in this case, so that we can talk about that name, because it comes up hundreds of times in dozens, if not hundreds, of documents.
So are you prepared to talk about who that is, or do you just think you may have heard the name once or twice before?
So I'll mask him.
Yeah, I don't recall hearing, I don't recall hearing the name in any major capacity at all.
And I may have heard the name, but I can't recall at this time.
Did you review any documents that had his name in it, preparing for this deposition specifically?
I don't recall Jonathan Reich being a, I looked at a lot of documents, and I've been Looking at a lot of documents, and I don't recall his name jumping out in any substantial capacity.
Were you reviewing documents on your vacation?
No.
Okay.
How many days have you spent reviewing documents?
You said you started preparing about two weeks ago, and then you had a vacation in the middle.
So, how many days have you been preparing for this deposition?
Well, and you spent the last two days preparing for InfoWars LLC.
So for this one, how many days have you prepared?
Well, there's a process of finding documents and videos.
I looked at a lot of videos, looked at a lot of emails that I had sent back and forth, and I would say let's back up there.
You only looked at the emails that you had sent or received, correct?
No, I looked at other emails that did not have my name on them.
Which ones?
Who were they from?
To and from some of them were how big?
Some of them were kind of the question we're all asking right now.
Well, I was, I also have to maintain duties over at work, and so I was also an exact number of.
Are you looking for eight-hour day segments or total?
If you want to give it to me in hours, you can give it to me in days, you can give it to me in minutes.
Just curious of how much time you spent preparing for right now, because it seems like you're slightly not prepared to talk about some names that are literally mentioned hundreds of times in the document, in the little documents we've gotten.
Seems like you reviewed some documents we haven't gotten.
I'm just trying to figure out how much time I'd say maybe six total days, but spread out.
Okay, those are eight-hour days.
If you're, yes.
So, you've spent 40 hours reviewing documents for that deposition.
No, I think a lot of it was reviewing video and finding video.
Okay.
What were you having to find?
The request just says what's been produced.
Your lawyers produced it.
We know exactly what videos or no videos have been produced, right?
Yeah, what videos were you reviewing?
They didn't produce any videos, right?
Yeah.
What videos were you produced?
What were you reviewing?
Objection is to form and misstating facts on the record.
Okay.
Videos were produced, and you have them in voluminous quality, which you previously misled the court on.
We'll get to that at a later date.
Let's back up.
Let me say for the record: all of the demonstrative laughing, over-the-top reactions of Mr. Bankston is highly unprofessional, completely unnecessary, and I would greatly appreciate it if it was not continued.
There doesn't need to be demonstrative, childlike behavior responding to a witness.
Just do it professional, please.
After yesterday, that's where we're going to go with this, Mr. Barnes?
Oh, after yesterday, after the outrageous behavior yesterday of Mr. Bankston, who was going to, and you two were laughing together repeatedly, joking with each other repeatedly?
I mean, that's what we're talking about.
There's going to be no on the witness.
No, it's on the witness.
I mean, now that that's the kind of nonsense we're dealing with.
All I'm asking is not to behave with ha ha ha, you know, talking with each other, laughing, trying to look at the witness and laugh.
It's unprofessional.
This is not brain surgery.
I'm so are you saying that's what Texas standards are?
Texas standards are behaving at the lowest possible ethical level in a way that makes lawyers look like a caricature?
I'm so confused right now, Mr. Barnes, as to what we're talking about right now.
I'm requesting, Mr. Banks, quit laughing and behaving in a demonstrative way toward the witness repeatedly.
That's all I'm asking.
Okay.
Thank you.
We understand all those words.
Correct.
That's not an unreasonable request.
I'm not going to make a comment on the reasonableness of what you just did.
But we will talk about number 10.
Actually, let's back up because you just made a representation and I just want this on the record.
Is your position that any of the defendants in this case have produced videos to us?
Yes.
Okay.
Every video that we have, we had to find ourselves.
There's two different things.
One, defendant doesn't have to produce anything.
You already have.
If it's more reasonable for you to have it, and it's clear you have them all, it's been referenced in petitions and other paperwork, then there's no duty to create duplicate videos.
Secondly, you were given a link that had all of the videos on them.
Hey, Mr. Barnes, you objected, Mr. Enoch objected to the authenticity of some of our evidence because it wasn't produced.
What do we do then?
Why don't you tell me what we do then, and I would love to hear your response.
Well, what I've been saying, in fact, what I said last week, is that I'm working on getting everything bait stamped, getting everything authenticated, if that's the issue.
What authentic videos do we have right now?
In any case.
Any case.
You tell me.
Well, I mean, it's my understanding you have all the videos.
What authentic evidence of videos do we have?
If you want something authenticated, we can do that, if that's the precise issue.
But the videos you already have, and then the link to look at all of the other videos to the degree you thought any of them were not in what you already had was provided.
There's been no attempt to withhold videos.
So, I mean, I get, if you would have told me, Mr. Barnes, what we want is we need this authenticated.
That would have been no problem.
I mean, it's been a problem in the past, so that's why we didn't.
Okay, well, I said I'm working on getting everything.
Sure.
We'll leave it at that, though.
Precisely.
Well, no, I mean, I afforded the opportunity to continue these depositions for the purposes of making sure everything was prepared and the rest.
You guys turned it down.
We had to.
Your motion gives us a strict timeline.
We don't have a lot of time here, Mr. Barnes.
Well, but what I said last week was I was willing to move it to just next week, do everything possible to both expedite and provide time.
So I'm not trying to delay anything or anything else, but I'm saying that we haven't turned anything over when you have all the videos, you're showing excerpts over and over again, you're referencing them by detail, that's not really a fair representation.
That's all I'm saying.
Okay, so.
I mean, you can authenticate videos you downloaded from sites.
You know how to do that.
I get started, I'm going to let you know I'm going to keep representing that you have not produced a single video to us.
Well, then we disagree.
Sure, that's fine.
Okay.
Where the documents that you reviewed to prepare yourself for this deposition, where did you get them?
From.
Well.
To prepare the.
Including emails, I'm sorry.
But that's including documents, is that?
Mr. Enoch.
All of them.
You didn't search your personal emails.
No, I searched my personal emails, and I think I already stated that.
Okay.
Where are those?
I believe my personal emails are included in what you have.
Okay.
Give me one second.
Would you agree with me that you are in charge of overseeing all news media for defend for free speech systems?
No, I think Alex Jones says the final call, but I do look at production standards.
but at the end of the day, it's Alex's show.
All right, so if I'm going to say that you are in charge and oversee all the news media for free speech systems, you would disagree with that.
I would say I'm not the boss of free speech systems.
Great.
It's not my question.
I'm asking if you oversee and are in charge of all news media for free speech systems.
And I believe I just said that Alex Jones has the final say on everything.
So that's a no.
I look at things.
So that would be a no to my question.
That would be a no.
you you Has Mr. Jones given you the power to kind of validate sources of information?
Yes.
Does Mr. But I would say not all sources, but sometimes yes.
Do you have the ability to put something up on the website or on the show or the radio that Mr. Jones hasn't seen?
In terms of, I would say a general, generally, and if it's a news article or a video that's already been published, I am able to put that out there.
If it's something new or breaking, that gets run.
Or if it's something that hasn't been exclusive, I would say.
Okay.
There I would defer and show it to Alex.
So if you had a piece of news on an active ongoing shooting about the shooter, would that be an exclusive piece of information or would that be something that you could just copy and paste and throw out?
Or you could write up and put it on the website as an article.
It would depend on what it is, but I don't write articles generally.
I think I've written two or three articles that I've written.
I'll do this this then.
If you got information that the mass school shooter, the day of from Columbine was a socialist, and you, in the headline, you wrote a story that said the Columbine shooter is a socialist.
Would you be able to, the day of, would you be able to throw that up, the article up on the website, or would you have to run it by Mr. Jones?
I think it would depend on how that proof is being shown.
Someone found a random picture of a shooter on the internet and he had a socialist shirt on.
That was the only thing you had.
would you be able to throw that up or would Mr. Jones have to vet that?
me personally.
I'm trying to think of, I don't know, are you trying to say that I did that?
No, I'm just asking, would you be able to?
Or would Mr. Jones have to review it before you publish the story?
Most of the stuff I come across is in video format and shooting videos with Alex.
It could be a picture or it could be a document.
But it's going to go into a video form.
And I would say most of those videos, the majority of the videos, especially pertaining to Sandy Hook, are I've gone through Jones if we're talking about Sandy Hook.
Okay.
You were in Mr. Jones' deposition yesterday.
were a little bit late, but for all the portions that you were there for, do you agree with everything that he said?
Yeah, I think I do.
Yeah.
I mean, I'd have to go back and watch.
It was a lot of stuff.
Mr. Jones mentioned that he that there were communications with free speech systems with gun rights agencies and groups.
Is that something that is normal for InfoWars?
Do you all have any relationships with anybody involved with gun rights associations?
Pro-Second Amendment, yes.
Okay, what kind of associations are we talking about?
Maybe they've sent us information.
I've interviewed some gun store owners who've been persecuted.
What associations would be providing you information?
Do you mean the types of associations, or do you want specific names?
Specific names, you've got them.
Oath Keepers would be a gun rights pro-Second Amendment organization that has provided us information.
Other websites.
Okay.
Other than Oath Keepers, can you think of any others?
Gun owners of America.
Okay.
Anybody else?
NRA organizations or anybody that's pro-guns, pro-Second Amendment, anything like that?
Yeah.
Those two are the primary that I can think of at this point.
There might have been smaller organizations that have come up and have gone, but those are and I think we even had anybody else at the top of my head.
There are editorial procedures in place at free speech systems, correct?
Are you referring to a specific date or just currently now?
I'm asking if there are any.
Do any exist?
There are now, yes.
When did those start?
I believe sometime in 2018.
Okay.
There was at least official written procedures.
Would that have been before or after free speech systems started getting sued?
I don't know.
Would you agree with me that it's it would that people should be held responsible if they spread misinformation?
Do you agree with that statement?
If they're knowingly spreading misinformation.
So as long as they stay ignorant and don't verify that it's false, it should be okay for somebody to spread misinformation.
Is that your story?
Objection is to a form.
I'm just trying to get your understanding.
Is that your understanding?
I don't believe we intentionally spread misinformation.
I didn't just ask that.
I said, as long as someone doesn't verify that something's false and spreads that information, should they be responsible for spreading misinformation?
injections to it form.
Thank you.
Thank you.
I think that's a hard question to answer.
But I maintain that we never intentionally spread misinformation or tried to hurt any parents.
Right.
So as long as you're reckless and not intentional, that's where your line starts to get a little murky.
No, I'm not saying that.
That's what you're saying.
Okay.
If you don't verify information and you start spreading it and it is false, should that person be responsible for spreading misinformation?
That's all I'm asking.
Objection is to a form.
I think you're making the assumption that there's only one source of verification.
And I'm maintaining that sometimes there are multiple sources of verification.
I'm not even saying either of those.
I'm saying, looking back, if you know something was false and you were spreading it, should you be responsible for spreading misinformation?
I don't think at the time I knew anything was false that you're claiming I was spreading.
Right.
And again, I will ask because I don't think I've gotten an answer yet.
If it turns out someone is spreading misinformation, should they be held responsible?
Objection is to form.
I think I did answer that question.
Regardless if they know, if they're doing it, should they be held responsible is my question.
Objection is to a form.
I would think a lot of people need to be held accountable then.
Okay, so you would agree with me?
I would agree with you that InfoWars is not that organization that you're trying to prescribe us as.
This is a hypothetical.
I'm asking if Free Speech Systems believes that people or entities that spread misinformation willingly or knowingly or not should be held responsible.
Objection is to form.
And I believe not if they do it unintentionally.
Okay.
Councilman has.
Okay, perfect.
I want to go through some of the people involved with the editorial process.
Kit Daniels.
Do you know who Kit Daniels is?
Does he have the authority to put up a story on the website without it being vetted by you or Mr. Jones?
Actually, let's back that up.
Can he put something on the website without Mr. Jones reviewing it first?
He can put stuff up on the website without.
If it's original content written by him?
It would depend on the situation.
Okay.
Who's Nico?
Nico?
Do you have a last name?
Nope.
Nico at Infowars.com.
We had a producer for a while named Nico.
What happened to him?
Well, I believe it's of a personal nature that he left.
He was not fired.
Okay.
He was the one who originally, it seems like, forged a relationship with Wolfgang Halbig and invited him onto the show for the first time.
So I was just curious, what was his job duty?
He was just a producer?
We have a live show that's every day 11 to 3.
And so he would be a guy getting guests at that time.
Okay.
Nemo?
Nemo.
Kurt Nimmo?
Yeah, Kurt Nemo.
He was a writer for a time for Infowars.com.
And he's no longer there?
No.
Okay.
Was he fired?
Or did he leave?
I believe he moved away.
Okay.
Rob Jacobson.
Is there a question?
Was he on the editorial staff?
What was his job?
He was an editor.
Okay, what does an editor do?
Takes different pieces of video and puts them together and puts graphics on top of them and adds music.
Okay.
In terms of video editor, is what I would say.
He was not a writer.
Did he was he fired or did he leave?
He was fired.
Okay.
Why?
I don't know What the exact reason was listed on his file, but it was, I believe, insubordination.
Okay.
Have you seen articles in the news about Mr. Jacobson?
After leaving InfoWars?
Yes.
What are they about?
I'm sure you've read them.
There's a Daily Mail article, and he claims that he was being gay groomed by Alex.
Okay.
Did you ever see that personally?
No.
Were there any inappropriate comments made by you to Mr. Jacobson?
Well, Mr. Jacobson claims that we made fun of him for being Jewish when in fact he was the one making, I would say, 95% of the Jew jokes in the office.
Right.
I wasn't asking for we, though.
I was asking for you.
For me.
Yeah.
Did you ever make an inappropriate comment or make an inappropriate picture about Mr. Jacobson?
I never made an inappropriate picture.
Okay.
Owen Schroyer, what's his job?
He is listed as a reporter and he hosts one of our afternoon shows.
Okay.
Reporter.
And I'd say reporter and host.
And you said earlier, but Dondi was a freelance reporter for you guys on a limited basis?
Right.
He would produce stuff and sometimes we would accept it and sometimes we wouldn't.
Okay.
And you'd pay him for it?
If we accepted something.
Okay.
Did you ever pay him to go to Sandy Hook or to Newtown, Connecticut?
I would have to look and see if he actually got paid for anything in particular for going to Sandy Hook.
Okay.
And Wolfgang, how big?
Was he just a guest or was he employed at some point?
I don't think he was employed ever.
Okay.
And no money, to your knowledge, was any money ever transferred from Free Speech Systems to Wolfgang Halbig?
Not to my knowledge.
Okay.
Mr. Enoch, I assume you're checking the time because I'm not going to get any extra time after the time limits.
Mr. Argyll, please continue deposition.
Okay.
Well, I want to address that now.
We've got a couple more.
Yeah, not at this time, no.
But I mean, I'll take under consideration other things, but not for today.
What's my time look like?
About two minutes.
Okay, cool.
Paul Watson, is he still with you guys?
Yes.
Okay.
You and him, did he, he disagreed with a lot of the staff at Infowars.com on the coverage of Sandy Hook, correct?
I can't speak for a lot of the staff, but he disagreed.
Well, it depends on what you're saying, disagreed with.
Do you have anything specific?
Yeah, the coverage and the narrative that Infowars.com was pushing on the Sandy Hook story for well after the event happened.
Well, I think the majority of our coverage said that it was a tragedy.
We talked about it being a mass shooting and people dying.
And I think we all agreed with that, that people did die.
Does free speech systems do they accept responsibility for spreading misinformation about anything Sandy Hook related?
Um...
Sitting here today, not at the time, sitting here right now, looking back.
What I think we were doing was seeing how this was being used politically.
And it's a shame that people's parents or parents of dead kids were being used to push a political narrative.
But I think we had a duty to point that out, that that was being done.
My question was, looking back, the information that was spread that is now we can agree wrong, does InfoWars, or does free speech systems accept responsibility for it?
I At this point, I will accept responsibility for defending the First and Second Amendment.
And as far as spreading misinformation, the stuff that we got wrong, that you guys got wrong.
At the time, I get it, but looking back now, do you accept responsibility for it?
Thank you.
I think that was a story that we wanted to get away from, and the media kept pushing it back in our bucket.
So, as far as accepting responsibility, which is the question I asked.
Right.
For stuff we know that you guys got wrong, do you accept responsibility for it now?
And I'll tell you, this is my last question as soon as I get it to answer.
Well, I think you're taking an event that happened and drawing it out over many years.
And I don't think anybody's going to get it 100% right.
And I don't think the media got it 100% right.
And I don't remember anyone else in the media coming back and saying, oh, we're sorry, we got this and this and this wrong.
Or we got this and this wrong.
So I don't feel why we have to be held to a higher standard than what mainstream media is doing back then and continually on a daily basis.
Sure.
And I'm asking, does Infowars hold itself to a higher standard than mainstream media?
And they are going to be the ones that come forward and accept responsibility.
Or are they just going to fall in line with everybody else?
That's my question.
Just for the stuff that you got wrong.
You know, we're sorry that those people died and we're sorry for those parents that they have to go through what they're going through.
But at the time, we felt we were doing the right thing and talking about it and asking questions.
And so.
And sitting here today, looking back, what's the position now?
We didn't get everything 100%, but I think we were doing our best with the resources that we had.
And as far as responsibility, are y'all going to hold that higher standard and accept responsibility for what you got wrong or fall in line with the rest of the mainstream media?
I think going forward in the future, we've already made corrective steps going forward.
And looking back.
Yeah, there's really not much you can do about changing the past.
Signs accept responsibility, right?
I'm not saying I'm accepting responsibility for anything.
Okay.
I didn't think so.
I just wanted to make sure that that came out right.
I appreciate your time.
The same, I think we put it on earlier, but for InfoWars, the same deposition is confidential.
I need to put something wrong right here too, but I think it would be a good excuse for this before I get it.
Oh, sure.
Come here, Mike.
Come here, Mike.
All right, just a little thing to put on the record.
We've concluded the deposition.
The witnesses exited the room.
I feel compelled to put a little something on the record because my professional ethics have been questioned and I've been accused of making a misrepresentation to the court.
So I'd like to have some things in the record, one of which is that I sent an email on February 26, 2019, immediately after InfoWars and the defendants provided their discovery answers.
In those discovery answers, in response to requests for production number one, asking them to identify and produce articles of videos which contain the words Sandy Hook or Newtown in the title, the defendants instead directed me to a website and told me I had a superior or equal ability to get those videos from the website.
As I wrote on that day, that our client's website only has 29 entries for videos under a search for Sandy Hook.
In my email, I attached a copy of the search.
As I pointed out, it does not include many of the YouTube videos that we know include Sandy Hook in the title, such as Creepy Illuminati Message and Batman movie hints at Sandy Hook School, why people think Sandy Hook is a hoax, Sandy Hook false narratives versus the reality.
Lawsuit could reveal the truth about Sandy Hook massacre.
Retired FBI agent investigates Sandy Hook Mega massive cover-up.
Alex Jones' final statement on Sandy Hook.
What Alex Jones really believes about Sandy Hook.
MSM continues to demonize Alex Jones over Sandy Hook lawsuits.
Therefore, I informed defendants I did not consider their response sufficient and that it was clear that their client had a superior ability to identify relevant videos than is possible through the tv.invoors.com website.
Given that there are many, many videos that we know contain Sandy Hook in the title, we very strongly believe there are many, many more that we don't know about that contain Sandy Hook in the title.
In response to my email on the same day, Mr. Enoch's Paralegal sent me a message and said the following is sent at the request of Mark Enoch.
Mr. Enoch represented, our clients are searching for the videos that you have referenced in your email today, and I have been told that I should have more information for you by the end of the week.
Unfortunately, I have learned that what the clients told me and what I told the court that our clients could search titles of the videos of all videos is not entirely accurate.
I am now told that the search is more labor-intensive than when what was thought.
Since the time that those emails have been sent, absolutely no further communications have been made with me about the status of any search for those videos, nor has a single video ever been produced to the plaintiffs.
I stand 100% behind my representations in the court.
I stand 100% behind my co-counsel's representations here, and I take deep offense to any aspersion on my professional character to represent that I have been produced videos.
That has not happened, and I will not accept that being made on my name.
I understand that defendants believe that providing tv.infowars.com established some manner of partial production.
That is not true.
We have not ever been provided any sort of 192 material, which is a video produced by the defendant.
I understand Mr. Barnes says that we apparently have all the videos.
That is clearly not true as well.
We do not have all the videos.
And in any case, saying that we have the videos and they're available to us is not an answer to, did you produce the videos?
We can all agree InfoWars has not produced videos.
Again, I renew my request in request for production number one to demand that InfoWars, as they should have done on February 25th, 2019, produce all videos with the words Sandy Hook or Newtown in the title.
There's two components on that.
First, what I have requested for plaintiffs' counsel is they identify which videos they already do have and which ones they do not have.
Which, if they want authentication independent of how they originally sourced the videos, they clearly do have to provide that request.
So that we could shorten and streamline our search.
While we disagree on whether or not the provision of the email site or the website that had all of the videos constitutes producing videos, the goal is simply to streamline the process so we don't spend a lot of time looking for videos they already have.
If they have something that just needs authentication, we can resolve it that way without spending lots of time, including hundreds of hours of time, searching through videos that are not easily accessible, given the deletion of YouTube, which was requested by plaintiff's counsel that the plant and the plaintiffs that the YouTube account of the defendants be deleted.
The fact that it was deleted destroyed the organizational format and the title structure in which it was originally done.
The goal is not to get into long contested disputes.
It's to provide a streamlined, simplified, economized way to get resolution of any issues.
Not trying to get personal or other matters.
All we want is if you need a video and don't have it, then we can focus on those, not videos you have and only need, you believe you may need authentication of if the form in which you currently have it is not, can't be separately or independently authenticated.
Unfortunately, I have to put another thing on the record now based on the representation that was made that if we had simply made a request identifying which videos we had and therefore could be excluded from that search and only identifying videos that we didn't have and excluded those from those groups, all of this could have happened.
Interrogatory number five to Free Speech Systems reads, Identify by date and title every article or video which contains the word Sandy Hook or Newtown in the title created or published by Free Speech Systems, which is not already listed in the declaration of Binkowski attached to plaintiff's motion for expedited discovery.
Similarly, request for production number one request a copy of every article and a digital copy and transcript of every video you identified in request response to interrogatory number five.
Therefore, any production responsibilities on InfoWars had already been excluded from every video that we have previously identified in Ms. Binkowski's affidavit.
Thus, none of the videos that we currently have are in any way subject to this discussion.
So just to be on the clear side, you're not requesting any videos that were identified in the declaration.
You're only those that are not identified in the declaration.
As far as those requests that you were just served in expedited discovery, yes, that is true.
Thank you.
We're off the record.
2:57 p.m.
Thank you.
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