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March 15, 2019 - Depositions & Trials
01:12:27
Deposition of InfoWars LLC, Rob Dew - March 15, 2019
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Time Text
We are on the record for the videotape deposition of InfoWars LLC Corporate Representative, Mr. Rob Dew, taken on Friday, March 15, 2019.
The time is approximately 10:20 a.m.
For the corporate swearing witness.
Sir, would you read anything this morning?
You saw that the testimony you're about to give will be the truth, the whole truth, and nothing but the truth?
Yes.
Can you please say your name for me?
Rob Dew.
What is your employment status with InfoWars LLC?
As far as I know, there is no employment status with InfoWars LLC.
Okay.
What is your understanding as to why you are here today?
To give a deposition.
Sure.
About what?
About, well, a couple things, I guess.
The.
You can put your mic on, just clip it to your shirt, lapel, or button.
Good.
I don't touch other people's equipment.
Sure.
As to what you're here to talk about today, what's your understanding?
It's to ask questions that are listed in here or answer questions that are listed in here for InfoWars LLC and then also for free speech systems.
Okay.
And right now it's just InfoWars LLC.
Have you ever been employed by InfoWars LLC?
Not to my knowledge.
Okay.
Have you ever received any sort of payment from InfoWars LLC?
Not to my knowledge.
Okay.
Exhibit one is in front of you.
It is the notice of deposition.
I assume prior to today you'd seen that before.
Okay.
On page two, there are six topics listed.
You see those?
Yes.
Okay.
Topic number one says the organizational structure, business purpose, and method of generating revenue for InfoWars LLC.
What did you, and none of my questions today are going to and are going to be eliciting answers that you've had conversations with either of your attorneys.
But what did you do to prepare yourself for topic number one?
As far as I know, InfoWars LLC does not have any of this.
This does not pertain to InfoWars LLC.
As far as you're aware.
As far as I'm aware.
What steps did you take to become aware or unaware of that?
What steps did I take?
I just don't know if there's any information and you didn't go look for it and try to figure it out.
I don't think there's any information, is what I'm saying.
Did you look for it?
I would not know where to look for this information.
Okay.
Did you talk to anybody?
And to clarify, when he was talking earlier about attorney client privilege, you didn't say you talked to an attorney or something.
Yeah, I just don't want to know the substance.
Substantive content.
I talked to both attorneys.
Okay.
Did you talk to anybody with InfoWars LLC?
No.
Okay.
So we didn't review any documents.
You didn't talk to anybody at InfoWars LLC.
So when you say, to your knowledge, there's no organizational structure, business purpose, how did you get to that conclusion?
As far as I know, InfoWars LLC is not a company that I work for?
Sure.
So I wouldn't have any way to gather knowledge.
Okay.
Number two, InfoWars LLC's business relationship and history of business transactions with Free Speech Assistance LLC and Alex Jones.
Are you prepared to discuss that topic today?
As far as I know, there is no am I prepared to discuss that topic?
Correct.
I'm not sure in what detail I could have provided.
And I'll ask a better question.
If I ask, I'm going to ask bad questions today.
If I do and you don't understand them, let me know and I'll rephrase it.
Okay.
Did you review any documents regarding the topic number two?
No.
Did you talk to anybody regarding topic number two?
No.
Okay.
Regarding topic number three, the ownership and management of InfoWars LLC from 2012 to 2017.
Are you prepared to talk about that topic today?
I am prepared, but I'm not sure in what detail I could provide.
Sure.
How did you prepare?
I talked with my lawyers.
Okay.
For all of the topics today, you've said you've spoken with the lawyers.
I'm assuming you mean Mr. Barnes and Mr. Enoch.
Correct.
Did you speak with anyone else?
No.
For topic number four, InfoWars LLC's involvement in the creation, distribution, licensing, marketing, funding, or staffing of InfoWars radio, video, or internet programming.
Are you prepared to testify on those top on that topic today?
Same answer as before.
I'm not sure how much detail I could provide with relation to InfoWars LLC.
And it's just, you just don't know.
Correct?
Don't know what?
The information that would be prevalent to these topics.
Is that what you're saying?
I'm not sure that there is any of this information that you're asking for.
Okay.
With topic number five, InfoWars LLC's involvement with the management, development, control, and ownership of the InfoWars.com website.
Did you prepare to discuss that topic today?
I talked, I prepared with my lawyers, yes.
Okay.
And number six, the documents, InfoWars LLC produced by in response to plaintiffs expedited discovery.
prepared to talk about that topic today?
I don't know how much detail I could provide on any of that.
Sure.
What documents did you review in preparing to discuss topic number six?
If any?
I did not look at any documents about that.
Okay.
did you have any conversations with anyone regarding topic number six?
Yes, with my lawyers.
Okay.
So as far as do you know what an interrogatory is?
What are you, can you explain it for your purposes?
Sure.
What I'm telling you is lawyers write down questions, send them to opponents in a lawsuit, and they answer those questions and then they swear to them.
You understand that?
Okay.
Okay.
Did you review the interrogatories that were submitted in this case by InfoWars LLC?
I did.
Okay.
That would be considered a document.
So when I asked, you know, the last few questions I've asked, did you review any documents?
Now that we know you did, you did review the interrogatories.
Was there anything else that you reviewed?
No.
I believe the interrogatories were the only thing.
Okay.
You didn't see any requests for production or any documents that were produced?
No.
Are you prepared to testify as to answers to requests for production or any documents that have been produced by InfoWars LLC in this case?
Here.
Are you prepared to testify today as to documents that have been produced by InfoWars LLC in this case?
I'm not sure what testimony I could provide with relationship to InfoWars LLC.
I'm specifically speaking to the documents that have been produced.
Do you know what documents have been produced by InfoWars LLC?
I've looked at a lot of documents, and I'm not sure, and they all look the same in terms of cover sheets, and I've looked at a lot of these, so I'm not sure if you're asking for something in particular?
Sure.
What I'm asking for is not the kind of legalese of this.
I'm asking for documents, actual documents that InfoWars LLC had in its records that were produced.
I'm not sure there are any records for InfoWars LLC in terms of what you're asking.
Okay.
So you have, if that's the case, you haven't reviewed any, correct?
Correct.
And you wouldn't be prepared to testify on any that have been produced.
I would not be prepared in terms of with what you're asking.
Sure.
When was InfoWars LLC registered?
I believe in 2008.
How do you know that?
It was on one of these documents.
Okay.
And who registered it?
That I don't know.
Okay.
Do you know any of the original officers that were listed on the LLC registration through the Secretary of State of Texas?
I believe there's only one.
Why do you believe that?
Because it's listed as there's one listed.
Okay.
Who is that?
It's Alex Jones.
What has InfoWars LLC ever had any other officers?
Not to my knowledge.
When you say your knowledge, you're sitting here as InfoWars LLC.
You understand that, correct?
I've been asked to sit here as a representative of InfoWars LLC.
And as a representative, you are sitting in the chair as the company.
Do you realize that?
I'm not sure I understand that.
Right.
You're not here as Rob do.
You're here as InfoWars LLC.
Has anybody explained that to you?
With the.
Timeout, timeout.
You cannot make hand gestures, Mr. Enoch.
I just saw you go and the witness looked directly at you.
You asked a question.
I did.
Would you please not interrupt me, sir?
I haven't interrupted you.
You asked a question that was so broad that it would encompass a 20-client communication.
That's a great opinion for you to have.
Are you defending this deposition?
We had this yesterday, and unfortunately, Mr. Bankson's the nice one with us.
So I'm not going to put up with it.
You can leave.
If you're going to do that, if you're going to be an obstruction in this deposition, leave now.
Otherwise, sit there quietly and don't make gestures and don't share your opinions with anybody but whispering into Mr. Barnes' ear because he is defending this deposition.
I can appreciate your opinion.
Please continue the deposition, Mr. Rogers.
Mr. Barnes, did you have something you wanted to share with us?
It was just to instruct him that he can disclose that he had conversations, but not the content of the conversations if it was with attorney.
Sure.
Has anyone explained to you?
Not, I'm not asking who.
Does anybody explain to you that you are sitting here in the corporate capacity today?
Thank you.
He can answer.
I have had conversations.
Okay.
Yes.
With anybody but your lawyers?
No.
Okay.
So when I say, has InfoWars ever had an officer other than Mr. Jones, and you say not to my knowledge, so as far as the company is aware, it's never had anyone but Alex Jones.
Is that true?
To my knowledge, yes, that is true.
Okay.
And I just want to be clear.
When you say to my knowledge, that means to InfoWars LLC's knowledge.
Okay.
And the question, can you repeat it one more time?
Sure.
Other than Mr. Jones, has Infowars LLC ever had any other officers?
Not to my knowledge.
Okay.
And I'm not trying to trick you.
I'm just, if you don't know, you don't know.
I'm just trying to figure out what you do know, okay?
The business purpose of InfoWars LLC.
What is it?
I don't know.
Okay.
Why was it created?
And by it, why was InfoWars LLC created?
I don't know.
How does Infowars LLC make money?
How does Infowars LLC make money?
I don't know.
The Infowars LLC relationship with Alex Jones sitting here today, what is it?
To my knowledge, he is the sole officer.
Okay.
What's his title?
I don't know.
Okay.
The company does not know what Mr. Jones's sole title is, and he is the only person that has anything to do with this company, correct?
I would not want to give the incorrect title.
Okay, so you just don't know?
Correct.
Okay.
Has InfoWars LLC ever made a business transaction with Free Speech Systems LLC?
Not to my knowledge.
Okay.
Did you ask Mr. Jones if he's ever made a business transaction between the two companies?
No, I did not.
Okay.
Can you think of anyone else that would have that information?
No.
So why didn't you ask Mr. Jones?
You can answer to the degree it will not disclose attorney-client communications or conversations.
If you can't answer without disclosing that, then say so.
Why did I not?
Yes, why did you not ask Mr. Jones if there's ever been a business transaction between the two companies?
Same instruction.
If you can answer without disclosing attorney-client communications, you could do so.
If you can't, then say so.
I just want to interject here, though.
For questions where attorneys gave him the corporate information, he's going to have to disclose that.
We can agree to that, correct?
But we'd be, I mean, it was like you're asking a why question.
So that's why I was going to invite you to turn it off.
I don't believe I can answer that without disclosing attorney client privilege.
Okay.
Has InfoWars LLC ever made money?
Not to my knowledge.
Okay.
Did you ask Mr. Jones if it's ever made money?
No.
Okay.
So sitting here, speaking on behalf of the company, you cannot tell us one way or the other whether or not the company has ever generated money?
Objection is true for him.
Correct?
That was the question again.
Sure.
You're sitting here in the corporate capacity and sitting here, you can't tell us one way or the other whether or not InfoWars LLC has ever generated money?
That is correct.
And is it because InfoWars LLC has never generated money or because you're unaware of whether or not the company has?
I am unaware if the company has made any money.
Okay.
Going back to are you aware of any methods InfoWars LLC has ever used to generate money as a company?
I'm not aware of any methods.
I think you already answered this, but just so we're clear, topic number three: Alex Jones is the only owner or manager of InfoWars LLC?
As far as I know, yes.
InfoWars LLC's involvement in creating the content of InfoWars Radio or the website.
Is there any relationship between InfoWars LLC and the InfoWars video, radio, or internet programming?
I do not believe there is.
Okay.
Has there ever been?
I do not believe so.
No.
Okay.
And how did you come to that conclusion?
Same instruction.
You can say you had conversations with attorneys but not disclose the content thereof.
I had conversations with my attorneys, and I'm not going to disclose the contents of this conversation.
Sure.
But in coming to your answer that you're unaware of any history between InfoWars LLC and InfoWars radio, video, or internet, you came to that conclusion based on conversations you have with your attorneys, correct?
Correct.
The relationship between InfoWars LLC and Infowars.com.
What is the relationship between those two?
I do not know of any relationship with respect to where it says management, development, control, and ownership.
Have you ever been on Infowars.com?
In what capacity?
In your personal capacity.
Yes.
Okay.
Who created it?
Are we still talking about InfoWars LLC?com.
InfoWars.com, yeah.
To my knowledge, Alex Jones created it.
Okay.
The have you ever come across InfoWars actually, are you aware that InfoWars sorry, are you aware that InfoWars LLC is listed on the Infowars.com website?
Thank you.
Thank you.
Are you asking for a location where it's located?
Are you aware of it at all?
Location, if you got one?
I'm not aware.
In preparing for today, did you come across a document that has the terms and conditions of InfoWars.com printed out or did you view it on your computer?
The terms and conditions of InfoWars.com.
Sure, not on a website.
There's terms and conditions page.
Have you ever seen those?
Yes.
Infowars.com has one.
Have you ever looked at it?
I've probably glanced at it.
I don't know if I've read it thoroughly.
Have you, anywhere on Infowars.com, have you ever seen InfoWars LLC listed?
It's something I've looked at so many times.
Honestly, I can't tell you if I have seen that or not.
Sure.
And like I said, not trying to trick you.
Just trying to figure out what you know.
Can we take a two-minute break?
My computer needs to connect remotely.
what Go ahead and go get that.
We are back on the record at 10:55 a.m.
During the break, Mr. Deal, I was able to print out a copy of a portion of the terms and conditions of InfoWars.com.
If you turn to page two, if you look about halfway down the page, you'll see a company listed.
What company is that?
Halfway down, I see website means planet.info wars and other systems.
Could you just keep your voice up just for a little bit?
Sure.
Looking specifically at 1.10.
1.10.
We, us, and our means InfoWars, LLC, a Texas Limited Liability Company.
So with regards to anyone using the Infowars.com website, all of the terms and conditions and all of the uses are in agreement with InfoWars LLC.
Objection is to form.
Is that correct?
Objection is to form.
What's the form?
As in this context, it calls for a legal conclusion.
Okay, let me rephrase.
When you read 1.10, what do you understand that to mean?
That InfoWars LLC, a Texas Limited Liability Company, is referring to the preceding numbers up above.
And when it comes to the privacy, actually, InfoWars LLC, does it have anything to do with Infowars.com?
I believe InfoWars LLC is an inactive entity.
You said inactive earlier.
What do you mean inactive?
That it doesn't play, that it would not be actively involved in any with reference to what you're asking here.
It doesn't have anything to do with creation, licensing, and marketing, staffing, programming, management, development.
You skipped over distribution, and if you're distribution.
Have you read the terms and conditions that InfoWars LLC lists as the controlling entity for the terms and conditions for Infowars.com?
Objection is to form.
I'm not sure I understand that question.
Sure.
The terms of use for InfoWars.com, what are they?
Excuse me, what do they do?
Are you referring to these?
Those are just some of the definitions.
48 pages.
I was saving a little bit of paper just to show you that in the terms of use, when it's an agreement with anyone saying we, which is used throughout the entire terms and conditions, they're defined as InfoWars LLC, not free speech systems.
You understand that?
Well, I see a comma between InfoWars and LLC, so I'm not sure that that is correct.
If you look at the notice and any filings of any business entities formally named, you'll realize that the comma is always there.
Okay.
Prior to right now, were you aware that InfoWars LLC was defined as the controlling entity with the terms of use, the InfoWars.com website?
Injection S24.
To my knowledge, InfoWars LLC is an inactive company.
Okay.
If they're listed at InfoWars LLC is listed as the entity that is in agreement with all users of Infowars.com for things like using cookies and log files to create profiles for other users, that wouldn't necessarily make them inactive, correct?
Objections to form.
What's the form?
In other words, it basically calls for a legal conclusion.
Which legal conclusion?
In other words, defining what constitutes an active or inactive entity.
I'm using inactive that he I had him define it.
Right.
That's where.
So we're using his definition.
What's the legal conclusion?
He's complied with the rules.
Not you, Mr. E. Not.
Mr. Roger, please don't raise your voice.
I'm not raising my voice.
No, this is just my voice when someone's obstructing a deposition that they shouldn't be talking in.
I'm asking you not to raise your voice at Council.
And I'm asking you not to speak any further.
Bill, we can be civil with each other.
Please just don't raise your voice at counsel.
Mr. Barnes doesn't deserve that.
I'm not raising it, Mr. Barnes.
Mr. Barnes, have I raised my voice towards you?
Let's move forward.
I mean, I get that there's a mistake here, but I'm just saying that in terms of what is incorrectly listed, the terms of service.
Mr. Barnes, hold on.
What do you mean it's incorrectly listed?
I should say free speech systems.
How is any of that a legal objection during a deposition?
And how are you not kind of coaching the witness right now?
No, no, I'm just trying to answer your question.
That's it.
In other words, I interpreted your question as calling for a legal conclusion that whether this designation constituted ownership of the site and an admission of ownership of the site?
But that wasn't my question.
That's how I interpreted the question.
It's calling for that legal conclusion.
But I asked him what is his understanding of the word that he used, and then I had to define.
I know, but it was followed up by a question that presumed and was I took as asking for a legal conclusion about whether this statement means X. What was my question?
My recollection is that this statement means: do you agree that this statement means that InfoWars owns something or is active?
And I was saying that that would call for a legal conclusion.
Okay.
Well, I will make sure that in no way will my questions be interpreted to be asking that.
Okay, thank you.
Sitting here today, are you aware that InfoWars LLC is listed in the terms and services on InfoWars.com as the controlling entity?
Um...
Seeing it here listed on the terms of service is the first time I've seen it.
Now that you're seeing it, and let's presume that it's still there right now.
when you said inactive earlier and you told me what you meant by inactive, do you still believe it's inactive?
Yes.
Okay.
What would a company have to do to be active?
I'm not sure I understand your question.
Okay.
You presumed that InfoWars LLC was listed as the controlling entity in the terms of services, and you said with that knowledge, you still believe it is inactive.
So I'm asking you, what sorts of things would a company do for you to consider them active?
To be actively, I guess, in the they would be conducting business actively.
I am not.
When you say conducting business, what did you mean by those words?
Well, I'm not a business guy, so I don't really, I don't want to put myself into legal jeopardy by claiming claiming to know certain definitions.
Okay, sure.
And I'm not asking you to define them.
I'm just asking, you used those words.
What did you mean by those words?
I believe the stuff listed in here, like creation, distribution, licensing, marketing, funding, staffing, would constitute activity.
Those words.
Okay.
Would you consider a company who is using cookies, log files, and creating profiles for users to be involved in the management of a website?
Yes, in some capacity.
Okay.
Because I know there's different services that do that.
Sure.
And when a person clicks on a website and reads the terms and services, it relies on those for things like sharing personal information and privacy, correct?
Okay.
So if someone goes to Infowars.com today, reads those, and then starts using the website, their understanding is they've entered into an agreement with InfoWars LLC as listed, correct?
Is that your understanding?
Objection is deformed.
Objection is the first one.
Well, this is the first time I'm seeing InfoWars LLC listed like this.
And I've been an employee of free speech systems for 10 years, and that's the only thing I've ever seen being used in a corporate capacity.
Okay.
So today you have knowledge that InfoWars LLC may have some sort of business relationship with InfoWars.com?
I can't accurately say yes to that.
Okay.
If the terms and conditions list InfoWars LLC and all the users that InfoWars has had over the last few years since it's been listed like that have read those and understood them, any other company sharing that information and privacy and web data would be violating people's privacy, correct?
Objection is to form.
Yeah, I'm not aware of privacy laws.
What's your understanding of who owns Infowars.com?
Infowars.com, the website?
Alex Jones.
Okay.
Who owns the content?
Well, that could get tricky because sometimes we repost other people's content.
But anything pertaining to InfoWars.com, the website, are written by the writers of InfoWars.com would be under InfoWars.com, which would be owned by Alex Jones.
What's your job title?
Official job title is Nightly News Director.
Okay.
What are your duties?
Shooting video, editing video, but this does not pertain to Infowars LLC.
This is pertaining to free speech systems.
Okay.
I've hired employees, managed employees.
Do you have any sort of management control over the website?
In terms of content, getting content posted or revised or amended, I have a working relationship with the writers in order to make that happen.
But I don't have any administrative privileges as far as I know.
Mr. Barnes, I realize that InfoWars LLC's corporate registration documents were produced, but they were just produced in a big set.
Were those produced by InfoWars LLC?
Yes, I think the because originally, and just for the record, I'll extend this.
The original person who was going to testify as InfoWars LLC was Tim, who signed the documents.
He had a medical emergency on Monday without getting into great detail, but just so you understand, it was a real medical emergency.
He was hospitalized.
He would be physically unable to, the nature of his emergency, it would be a bad idea to subject him to depositions.
Oh, no, I just meant the corporate, the LLC paperwork.
Did InfoWars LLC produce that instead of free speech?
I believe so, yes.
In the sense of, yes, I believe Tim got that from, I think we downloaded off the internet, to be honest.
We may have had paper copies, but that was all.
But, and I extend the offer to continue the InfoWars LLC part of the deposition to a later date for him to come up to speed with the stuff that Tim had.
Now, I understand you guys wanted to move forward anyway, and that's fine.
I'm just saying, not trying to delay anything or anything else.
This is the reality of what we do.
Sure.
when did you begin prepping to become prepared for this deposition?
Oh.
I don't know if I know an exact date because there's been a few.
But I would say, in terms of are we talking about the InfoWars LLC one?
Correct.
Okay.
I got thinking off into another.
And I'll represent to you that this notice was sent on February 6th.
So I'm curious, when did you begin preparing for this deposition?
For InfoWars LLC, I would say it was very recently.
I'd say within two weeks?
Yeah, about that.
I've had a vacation in between all this.
Sure.
Who is Magnolia Holdings Limited Partnership?
*Skiss*
I've heard that name, but I don't.
I believe they're involved with free speech systems in some way.
Okay.
How did you come across that name?
Jesus.
Jesus.
I don't recall exactly because I've been there for so long, so a lot of things just kind of run together.
But I couldn't tell you exactly when, but I think I saw the name at some point.
You have any idea who it is?
I don't have a definitive answer for you, but I could I'm imagining Alex Jones has something to do with Magnolia.
Okay.
Were you aware that the original manager of InfoWars LLC was Magnolia Holdings LP?
Was I aware of what?
Were you aware that the original manager of InfoWars LLC was Magnolia Holdings LP?
I was not aware.
What's the address?
Excuse me.
Yeah, what's the address At Infowars.
Where are you working?
That would be Free Speech Systems.
Free speech, excuse me.
I say InfoWars, it was encompassing them all.
Okay.
What's the address of Free Speech Systems?
The physical or the mailing address?
We can start with physical.
The physical address of free speech systems is 3019 Alvin Devane Suite.
There's a couple suites.
The direct mailing address is Suite 230.
Okay.
But same street number and street name.
Yeah, there's different suite numbers.
Okay.
Have you ever been to 100 Congress Avenue on the 22nd floor?
No.
But I presume, are we here at 100 Congress Avenue?
Okay.
I know where this building is, but.
Okay.
The 22nd floor, is that what you're asking?
Yeah.
No.
Were you aware that Magnolia Holdings is four floors above us right now?
No, I was not aware of that.
It was an extremely long pause.
Well, I'll tell you why.
Would you like to go ahead?
There's a lot of, I guess, people put a lot of stuff out on the internet and sometimes it's different.
Oh, who runs Alex Jones type stuff?
Okay.
And it goes into, you know, this company was formed here.
So I have seen, and that's where I'm thinking.
I saw the name Magnolia Holdings at one point.
But I think I've seen it in other documents, but I was not aware it was on this in this building.
What kind of documents would you have seen with Magnolia Holdings on them as the news director?
Maybe something through HR.
Being in H, working with HR at some point.
But like I said, I don't know exactly when.
I can't pinpoint the exact date or time or place because I've been there for 10 years.
Okay.
But as far as prepping for this deposition, you didn't go over any documents with Magnolia Holdings.
This is just from previous.
That is correct.
I want to go over the capitalization of InfoWars LLC, the money behind it.
Has InfoWars ever had any money?
InfoWars LLC ever had any money?
Not to my knowledge.
Okay.
And to your knowledge, again, that's as the corporate representative for InfoWars LLC, correct?
Correct.
Okay.
Is InfoWars LLC a subsidiary of free speech systems?
Not to my knowledge.
The only person that would have any sort of ownership would be Alex Jones, correct?
To my knowledge, yes.
Who owns Free Speech Systems?
I believe it's Alex Jones.
Again, no employees for InfoWars LLC?
Not to my knowledge, no.
InfoWars LLC doesn't pay any salaries to anyone?
They do not.
Do they have any bank accounts?
Not to my knowledge.
Do they have have they ever had any bank accounts?
not to my knowledge Does InfoWars LLC have an office?
Not to my knowledge.
Okay.
And in the corporate documents, it lists the governing authority as Alex Jones is the manager and has it at 100 Congress Avenue, 22nd floor.
Is there an office there?
I don't know.
I've never been to the 22nd floor.
did you ask anyone preparing for this deposition whether or not Infowars LLC had an office?
I don't believe I did.
No.
Okay.
So sitting here today, these answers are kind of just what you knew going into it, correct?
Yeah, as far, yeah.
Well, well, there's there was I mean, I've done prep with the lawyers, but that is it.
When?
What day was it?
Specific to InfoWars LLC?
Yeah.
I believe Wednesday.
Today being Friday.
Correct.
Okay.
How did you know to be preparing for kind of the two weeks before this?
Well, there was other depositions that I was preparing for.
Okay.
Thank you for clarifying.
My question earlier was: how long have you been preparing for this deposition as Infowars LLC's corporate rep?
You only started on Wednesday?
I think with respect to there being a medical emergency is when I was asked to step in.
anyone asked you to be the corporate rep prior to Monday?
Prior to Monday.
I would have to go back and look through emails because I haven't been able to do that yet because I arrived in town on Tuesday night after being away from computer access to my corporate free speech systems email.
How long were you gone?
I left the Tuesday before that.
I don't know, maybe the 9th, I believe.
Do you know who owns the office on the 22nd floor of 100 Congress?
I do not.
Does InfoWars LLC own any tangible property?
Not to my knowledge.
Has InfoWars LLC ever filed any corporate documents?
Okay.
Other than documents filing to be an LLC, I'm not aware of any other documents.
InfoWars LLC ever filed any tax documents?
Not to my knowledge.
And by not to your knowledge, you don't know.
Objection and instruct the wood is not to answer about any tax returns he may have seen or reviewed as privacy.
So to the extent you're asked about any tax returns he actually saw or the substantive content thereof that I'm instructing him not to answer.
My question was, have they ever filed tax returns?
That it gets into tax return privilege issues, does it not?
No, there's no specifics whatsoever.
Just asking if they've ever filed any tax documents.
Well, you can disclose to the degree to which you've without disclosing whether you've read or reviewed the substantive content of any such returns.
I'll ask him again.
I don't care what's in them.
I just want to know, has Infowars LLC ever filed any tax documents?
Yes.
I can't answer that.
And that's because you don't know.
I am unaware.
The lawsuit we're here for today, what's your understanding of the basis for it?
The plaintiff took issue with a video being posted.
Which video?
If you know.
I don't know the exact date, but it was a video with Owen Schroer, and he was talking about a zero hedge article.
Have you ever talked?
Well, excuse me.
What kind of article was it?
It was an article that came out after the Megan Kelly Alex Jones interview aired.
And it was looking at anomalies in the testimony of one of the parents.
What do you mean anomalies?
I believe in the video there are two, or in the article, there are two videos in the article.
And Mr. Schroyer was pointing out he played the two videos back to back.
And I believe one of the videos, the parent says he held his son after he was shot.
And then he played a video of the medical examiner who said the parents were not allowed to see the children.
And they took yeah, I believe that was it.
OK.
any corporate records for InfoWars LLC ever kept other than the original filing documents I don't believe so were did the directors listed function properly as they're listed in the corporate filing documents objection is to form I'm not sure if I can answer that sure I'll ask it a better way did mr. Jones do anything
As the manager of InfoWars LLC?
Not to my knowledge.
And by that you mean you don't know?
As far as I know, InfoWars is inactive.
LLC is inactive.
And so I don't have any knowledge of that.
Has it always been inactive?
Is it always inactive?
don't have any knowledge of that either so if it's inactive now and you don't have any knowledge of it ever being active you don't have any reason to believe it ever was active I do not have any re I believe it was formed and nothing was ever done with it why was it formed that I don't know you were in Mr. Jones deposition yesterday correct were
or are you there in your corporate capacity?
I'm not sure if I know how to answer that.
Why were you there yesterday?
I would have to consult with my attorneys, but they asked me to show up.
Okay.
Oh.
Oh.
far as info wars LLC as their corporate representative what steps did the entity take to remain legally distinct from Alex Jones objection is to form let me ask it a better way what precautions did info wars LLC take to ensure the corporation remained distinct from mr. Jones I
don't think I could answer that why because I'm not aware of anything so your answer is none to my knowledge correct repeat the question again sure were what precautions were taken by info wars LLC to ensure the corporation remained distinct from mr. Jones I'm not aware of any does
info wars LLC maintain accurate corporate records objection as to a form to which part it was calling for an opinion on the definition of the word accurate I'll ask it a better way does info wars LLC maintain any corporate records to my knowledge they're inactive so I don't so your answer is No.
I'm not sure what the rules would be on that.
Sure.
All I'm asking for is does InfoWars LLC maintain any records?
I don't know.
Does InfoWars have bylaws?
Excuse me.
Does InfoWars LLC have corporate bylaws?
Yes.
I have not seen any corporate bylaws.
Okay, did you ask anybody for them?
No.
Did you look for them anywhere?
No.
Does InfoWars LLC have any meetings of officers and directors?
Not to my knowledge.
And to your knowledge, that's to InfoWars LLC's knowledge.
they don't know To my knowledge, InfoWars is inactive, which would mean there wouldn't be any meetings.
Have there ever been any meetings?
That I do not know.
Did you ask anybody?
No.
Has Alex Jones ever used InfoWars LLC for personal purposes?
Not that I know of.
Did you ask?
No.
So a company that's owned by one single person has no employees and has one manager, you're sitting here on behalf of that company, and you didn't ask if the company's ever been used for any purpose.
Correct?
I would refer to, I guess, I had conversations with my attorneys.
Okay.
Did you ever seek to find out information of whether or not Mr. Jones has ever used InfoWars LLC for personal purposes?
No, I did not.
Did you ever seek to find information or gather information as to whether InfoWars LLC has ever been used for any purpose?
Thank you.
I believe that falls under questions or conversations I have with my attorneys.
Have you ever seen any accounting records for InfoWars LLC?
No, I have not.
What, as the manager of it, are you aware that InfoWars LLC is still an active corporation according to the laws of Texas?
I'm aware that it has an active, that it is filed LLC type paperwork and that it is all current and up to date, but that it does not do anything.
How do you know that?
Those are conversations I had with my attorneys.
I think we can take a quick break.
Thank you.
We're off the record, 1138 a.m.
We are back on the record at 1153 a.m.
Dr. McBreak.
Just have a couple of things.
We were talking about the InfoWars website, and I have exhibit two here.
It's three pages.
If you want to take a look at it, it's just a better printout of what we were looking at earlier.
not like one copy Okay.
Can you hold up exhibit two to the camera so we can see that page?
And can you, and then now you can go ahead and read what the bold title of that page is at the top of the title section.
It says InfoWars LLC Terms of Service and Privacy Policy.
Okay, and can you flip to the last page?
Or excuse me, the second page.
What is the second page?
I believe it to be the continuation of the terms of service, but it seems to be missing a few numbers.
Okay.
And the terms of service with regards to InfoWars LLC terms and conservatives, terms and service, correct?
That's the title of the document.
That is the title of the document.
Okay.
And the last page, page three.
Can you read that for us?
Where it says posted content?
Correct.
We may review and delete any content you post on the website or elsewhere using our services or system if we determine in our sole discretion that the content violates the rights of others.
It is not appropriate for the website or otherwise violates, is not appropriate for the website or otherwise violates this agreement.
Okay.
And I'm actually going to put a sticker on the one we had before, so it's part of the record.
Because the section you read said the word we, and earlier we went over what we meant.
And for the benefit of the record, can you tell us under 1.10 what we is defined as?
We, us, and R means InfoWars LLC, a Texas limited liability company.
And then I'm going to hand you exhibit three.
A little out of order, but that's exhibit three.
Have you ever seen that before?
I do not have...
I do not think I've seen this particular document.
Throughout the deposition, there have been a few times where you have answered to the best of my knowledge.
That is, to the best of your knowledge, after preparing to be the corporate representative for InfoWars LLC, correct?
What part of that are you?
What question are you asking?
No, no, I was just putting that, I was handing you that.
You said you've never seen it before.
That's all I needed on that.
My last question for you is not related to that document.
Well, I don't know if I've seen this particular document.
Okay.
My last question is, or I say last question, it might be another one.
But today you've answered a few different times to the best of my knowledge.
And that is, to the best of your knowledge, as the corporate representative of InfoWars LLC after preparing to sit here for this deposition, correct?
That is correct.
All right.
That's all I have.
The same confidence, everything is confidential for 30 days until time for us to designate further so that the debt position remains subject to the protective order until that time This concludes the debt position.
We're off record at 1157 a.m.
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