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Feb. 18, 2020 - Depositions & Trials

01:57:26

Roger Stone Video Deposition in Corsi/Klayman Defamation Suits, Day 1 (Part 1 of 3)

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	We're on the record for the video deposition of Roger Stone taking the matter of Clayman v.
	Stone. Today is February 12, 2020, and the time is 9:42 a.m.
	This deposition is being conducted at 110 Southeast 6th Street, Fort Lauderdale, Florida.
	The co-reporter is Trish Bailey Enten, and the videographer is Leland Olson, both of Empire Legal Reporting.
	Will counsel please introduce themselves, after which the...
	The court reporter was swearing the witness.
	Larry Klayman for the plaintiffs.
	I just want to put on the record our amended notice of deposition, which lists six cases upon which this deposition is being taken.
	Klayman v.
	Stone, which is 19-011394 Broward County.
	Klayman v.
	Stone, et al., 19-00272 Broward County.
	Corsi v.
	Stone, 50-2019.
	Civil Action No.
	013711, Palm Beach County.
	Clayman v.
	Santilli, 50-2019-015104, Palm Beach County.
	Corsi v.
	Stone, that is 19CV324, U.S. District Court for the District of Columbia.
	And Corsi v.
	Caputo, which is 1-19-CV1573.
	District Court for the District of Columbia.
	District Court for the District of Columbia.
	So the deposition is being taken with regard to all of those cases.
	Discovery has been consolidated.
	I'll ask that the court reporter mark as Exhibit 1 the amended notice of deposition.
	And then ask the court reporter to swear the witness in.
	Sure. Does everybody else want to just announce for the record?
	Robert Buchel on behalf of Roger Stone.
	Mark Lerner, Dwayne Morris on behalf of Newsmax Media, Inc., Christopher Ruddy, John Cardillo, and John Bachman in the Corsi v.
	Stone matter in Palm Beach.
	Grant Smith, Roger Stone.
	Okay. I'm going to place you under oath.
	Would you raise your right hand?
	Do you swear from the testimony you shall give will be the truth, the whole truth, and nothing but the truth?
	I do.
	Thank you.
	I'll show you Exhibit 1, Mr. Stone.
	That's an amended notice of deposition.
	You've seen that before, have you not?
	I don't recall.
	You are aware, however, that this deposition was to begin at 9 a.m. this morning?
	That is correct.
	And you are aware that this notice of deposition was filed in the court file and sent to your counsel?
	On at least two occasions, correct?
	Yes. Yet you showed up 40 minutes late.
	That's correct.
	My understanding is that there was a problem with notice on location.
	There's no problem.
	Look at the...
	You want to get started?
	Let's get started.
	No, I'm not getting started.
	I want this on the record.
	110 South East 6th Street.
	Let me finish.
	Suite 1700, Fort Lauderdale, Florida.
	33301, correct?
	As I explained to you off the record, you noticed this at my office and then without any...
	Highlight that you change the address without consulting, a phone call, or saying, I changed the address, please note the change of address.
	Had you done that, had you done that at 9-15, we would have gotten started, but we had to get in a car and come here instead of stay in my office building.
	In fact, this meta-notice of deposition was filed for the record.
	In the court file, and you get electronic transmissions.
	Do you know that, Mr. Puschel?
	I'm not discussing it.
	I'm not the witness, but that's the explanation.
	In fact, yesterday I sent a copy to you by email again, did I not?
	Seems extraordinarily petty to me.
	Can we get started?
	It's not petty, Mr. Stone.
	Your time's not more valuable than mine.
	You have little to no respect for court or judicial process, do you?
	Objection? We're not answering that question, so let's get started with the facts of the lawsuit of this case.
	Has your counsel advised you on what it means to be under oath?
	Objection. That's attorney-client privilege.
	He's under oath.
	Let's begin the deposition.
	Mr. Stone, you've been convicted of perjury on five counts, have you not?
	Objection. We're not talking about any criminal aspect of any criminal case.
	Are you aware that it's a crime to not testify truthfully or to withhold facts?
	That you can answer?
	Yes. Okay.
	When were you born?
	August 27th, 1952.
	And run us through briefly your educational background.
	I went to John Jay High School.
	I went to the Lewisboro Elementary School in Lewisboro, New York.
	I went to John Jay High School in Katona, New York.
	I did about a year and a half at George Washington University in Washington, D.C. And when did you graduate?
	I take it you just did a year at George Washington, correct?
	A little bit more.
	What did you do after that?
	I went to work for the committee to re-elect the President of the United States.
	That was President Richard Nixon?
	Correct. And how long did you work there?
	Well, I joined in'71 through Election Day'72.
	And what happened after Election Day 72?
	What did you do at that time?
	I worked for the inaugural committee for the president.
	And how long did you work for them?
	Well, through the inauguration, which is in January of 73. What happened after January 73 in terms of your employment?
	I believe I went to the Office of Economic Opportunity, but I'm not certain.
	And how long did you work there?
	Very briefly.
	I went there essentially to work on a project.
	So what happened after that?
	I was out of work after that.
	And how long were you out of work?
	Well, let's see.
	I'm uncertain.
	When was the next time you were gainfully employed?
	Probably when I went to work with Senator Bob Dole in 1973.
	And what was your position?
	I was a research assistant to the senator.
	And how long did you remain a research assistant to Senator Bob Dole?
	Through about the middle of 1974, as I recall.
	What kind of research did you perform?
	Opposition research?
	Legislative research.
	And what happened after your tenure with Senator Dole?
	I went to work for Mills Godwin, who was running for governor.
	Of Virginia, specifically on the campaign of the Attorney General candidate M. Patton Eccles through Election Day 73. And what happened after that campaign?
	I don't recall.
	Just run us through, make it quick, your employment history.
	Well, as best as I can remember.
	73, from there...
	I go to the, well, 75, I go to the Reagan for President campaign as National Youth Director through the Convention of 76. After that, I become a founder of the National Conservative Political Action Committee, after which I go back to work for Governor Reagan again in the 1980 campaign.
	Then I go back to the, then I co-found a public affairs firm, Black Man of Fortin Stone.
	Then I take a leave from there.
	Can I give you the dates?
	When did you co-found Black Manafort Stone?
	Shortly after the 1980 election.
	Was that Black Manafort Stone and Kelly?
	Not at that point.
	Did it later become that?
	Yes, it did.
	And when did that happen?
	Don't recall.
	And what type of work did you do as a partner?
	Public affairs work.
	Lobby? No, I had some lobby clients, but mostly not.
	And how long were you with Black Manafort and Stone?
	Well, I took a leave.
	And Kelly?
	I don't recall.
	And how long were you with the firm total, even when it became Kelly?
	I don't recall.
	What did you do after that?
	I worked on the president's re-election campaign in 1984.
	Which president?
	President Ronald Reagan.
	And what did you do for President Ronald Reagan?
	I was the Northeastern political director for all the states from Maine, downtown to Delaware, as well as Ohio.
	And did you go back to Black Man of Fort Stone and Kelly after that?
	I believe I did.
	And how long were you there?
	Until about, this is a guess, I believe around'89.
	And what happened in 1989?
	We sold the firm.
	And I was obviously no longer, well, we sold the firm.
	After that I lose track.
	I think I go to work for myself.
	Did you remain in Washington, D.C.?
	I remained there until 9-11.
	The attack of 9-11.
	After 9-11, what did you do?
	Moved to Florida.
	Is that where you live today?
	That is correct.
	And you're a citizen of Florida?
	Correct. And what type of work have you done since you moved to Florida?
	I've done a combination of public affairs work.
	I have written two blogs.
	Written five books.
	I have served as a pundit, but I've been self-employed.
	Pundit on Infowars?
	Among others.
	What others?
	Newsmax as well?
	I've certainly been on Newsmax.
	Fox Television, OAN, so on.
	Have you been paid by any of these media entities?
	Only by Infowars.
	Did there come a point in time when you met me, Larry Klayman?
	Yes, indeed.
	When was that?
	When you represented me.
	Did I not meet you earlier than that at the old Ebbett Grill with regard to Jack Kemp?
	I don't recall.
	At the time that you met me, I had said I was interested in helping Jack Kemp?
	It's entirely possible.
	I just don't recall.
	And is it not true that you had me put on the executive finance committee for Jack Kemp?
	Objection of form.
	I just don't recall.
	It's certainly possible, but I'm not certain.
	Sitting on that executive, you were a supporter.
	I was a supporter of Jack Kemp.
	And in fact, you actually differed with your partner, Lee Atwater and others, that you went off and represented Kemp.
	That is correct.
	With regard to being nominated for president.
	That's correct.
	But I was, of course, a volunteer.
	What year was it?
	1988. And at that time, sitting on the executive finance committee was also Donald Trump, correct?
	For Jack Kemp.
	No, not that I recall.
	I believe he supported the Vice President.
	You have been sued by me and by Dr. Corsi, correct?
	That's my understanding.
	And in the course of being sued, you were sent document requests, correct?
	That's correct.
	What did you do after you received the request for production of documents?
	How did you look for those documents?
	I asked my attorneys to conduct the search because they had just conducted a search regarding federal matters.
	What federal matters had they conducted a search?
	I think it's rather obvious, is it not?
	What is it?
	Put it on the record.
	You have two federal cases, the DNC versus the Russian Federation in the Southern District of New York.
	You have Cockrum versus, I'm trying to remember, the lead defendant and Roger Stone.
	And then you have the federal criminal matter.
	What access to information did you give your counsel?
	Oh, entirely.
	And what counsel actually conducted the search by name?
	Grant Smith, who was with us today.
	And Mr. Bushell as well?
	Mr. Bushell certainly reviewed the material.
	Did they have anyone assisting them in looking for documents that were responsive to plaintiff's document requests in the cases that you're hearing on today?
	I am uncertain.
	Did you give them access to computers, files?
	What did you give them access to?
	Everything. And what is that?
	That would be computers, iPad, cell phone, text messages, phone records, everything.
	What cell phone provider do you use?
	AT&T.
	Was it used at that time?
	Yes. That you did the search?
	At what time?
	The time that the search was conducted by your counsel.
	Yes. How long have you been using AT&T?
	A very long time.
	Which computers did you give them access to?
	My main computer at home, which is not a PC, but a Mac.
	Do you have a laptop?
	I do, but I very rarely use it.
	And you didn't give them access to it?
	Yes, they had my laptop as well.
	Did you give them access to phone records?
	They had access to phone records through other searches.
	You're aware that the document production requested the production of phone records as well?
	There must not have been any phone records to produce, if you didn't get any.
	Text messages?
	You're aware that it required the production of text messages?
	Yes, certainly was.
	I believe that the text messages were provided.
	Emails? Yes, absolutely.
	Now, you were convicted of not providing information to Congress which had been requested.
	That is untrue.
	Objection. It's not true.
	That charge was withdrawn, but go ahead.
	And your lawyers actually sent letters to Congress on your behalf saying that you did not have documents when you did.
	Objection. I'm instructing the witness not to answer.
	We're not talking about any criminal matters.
	We're not talking about criminal matters.
	We're talking about a course of conduct.
	That's what we're talking about.
	We want to make sure he's aware that he needs to produce everything.
	I'm well aware of that.
	You learned the hard way, right?
	Objection, not answering.
	Just because your delusion does not mean that I have to be badgered by you.
	Am I delusional that you were convicted of seven counts?
	I'm not going to answer that question.
	Now, your residence, where was your residence located when the FBI came in with...
	We're not answering these questions.
	You can certify these that are not being answered.
	Please do.
	Yes. What computers did the FBI take?
	All the same computers?
	We're not answering these questions.
	This is relevant to document production.
	I'll tie it up.
	Go ahead.
	You're going to wind up getting sanctioned, Mr. Bichel.
	No, you're going to wind up getting sanctioned, Mr. Bichel.
	Like you are in D.C. So let's go.
	Let's not do that.
	Why not?
	I'm not going to be badgered by this answer.
	You're not badgered.
	Yes, I am.
	Go ahead.
	Continue. Now, I want to find out what computers...
	After that FBI raided your house, did you then buy new computers?
	I'm not answering that question.
	The FBI took all of your computers?
	That is correct.
	Did you have backup for what you had on your computers in your house before the FBI raided your house?
	Backup. I'm not sure I understand the question.
	Did you back up what was on those computers?
	I believe my lawyers had copies of everything that was on the computers, yes.
	You anticipated possibly being raided by the FBI, so you gave them back up?
	Objection. Objection.
	Do not answer that.
	We're not answering that.
	Certified. What does that have to do about your defamation?
	I want to find out where the documents are.
	There are no documents other than those you've been given.
	So where did those documents come from as to what I've been given?
	The search conducted by my attorneys.
	It was totally within their purview to do the search?
	That's correct.
	You played no role?
	Correct. You didn't review what they did?
	I reviewed it after the fact.
	Do you know whether they removed documents that were to be produced?
	I don't think they would do that.
	It would be unethical.
	But you don't know one way or the other?
	Neither do you.
	Well, we'll find out.
	I'm asking questions.
	This is just a waste of time.
	Ask your next question.
	Now, when did you purchase new computers?
	Excuse me, did the FBI take your cell phones, too?
	Objection. We're not answering these questions about what the FBI did or didn't do.
	No, it's not.
	Very few documents have been produced.
	I want to find out.
	What devices they may be on that were recalled for that he no longer has in his possession or does have in his possession?
	That's a legitimate question.
	Well, I disagree.
	Also, my questions about telling the truth are quite relevant in light of the history of this defense.
	You've got your own problems in that regard, don't you?
	Let's ask the next question.
	What computers did they take from your house?
	Objection. The FBI.
	I'm instructing him not to answer.
	We're not having any discussions about criminal cases.
	It's not criminal.
	I want to know what computers were taken.
	It has nothing to do with criminal.
	what computers were taken.
	Answer the question, please.
	I've instructed him not to.
	Ask your next question.
	What computers, if any, and cell phones...
	What were the make of the computers that were taken by the FBI?
	Same, same.
	I'm instructing them not to answer.
	What were the make of the phones that were taken by the FBI?
	Same. Instructing them not to answer.
	Now, the allegations that the complaints filed against you predate the raid of the FBI on your residence, correct?
	If you know.
	I'm not sure that I know.
	We'll be going through that.
	Now, what computers and cell phones did you purchase?
	If any, after the FBI took everything out of your house.
	You've asked that five times.
	I have not.
	Okay. Well, I'm instructing you not to answer.
	Perhaps your attention span is no greater than with regard to the notice of deposition.
	Mr. Buchel.
	Okay. Next question.
	I'm asking the question again.
	What computers and cell phones did you purchase after your house was raided?
	I'm instructing the witness not to answer.
	It's irrelevant.
	We did our document search.
	We provided the documents.
	You are aware that not producing documents in a civil case can give rise to criminal liability as it does in a criminal case.
	Objection of form.
	This is harassment.
	Just ask questions about your lawsuit.
	It's not harassment.
	I want to make sure that he understood the consequence of not producing documents.
	We've explained.
	We have produced the documents.
	That's it.
	Let's get into the facts of the case.
	What do you want to know?
	I control the deposition and the court does, not you, Mr. Buchel.
	Already you've shown the disrespect for court process.
	Do you have an office now where you keep files?
	I do not.
	Do you keep files wherever you're living?
	To the extent that I have files, yes.
	Where are you now living?
	I'm now living at...
	Well, we'll give you his address off the record.
	Do you keep paper files?
	No, not really.
	But you keep some?
	Well, yeah.
	You keep backup?
	A little bit.
	And what do you keep?
	An enormous amount of paperwork regarding this recent case.
	What case?
	The criminal case that I've just been through, that I'm not answering questions about.
	Well, I'm not asking you questions about the criminal case.
	But I just answered your question.
	Thank you.
	Do you have documents currently that concern Dr. Jerome Corsi?
	I do not.
	How do you know that?
	Because I know what I have.
	Did you give your physical documents to your counsel to review?
	Yes. Oh, it's actually the other way around.
	I think my counsel gave me the physical documents.
	They almost virtually all come from Discovery.
	But you have some in your house, correct?
	Some, yes.
	And you didn't give them those, did you?
	Objection. They gave them to me.
	Why would I give them to them?
	You write things down from time to time, do you know?
	Certainly. You keep notes.
	Once in a while.
	Did you give your counsel notes to review to see whether...
	The notes would be relevant in any of the cases that you're here on today.
	That would be work product then, wouldn't it?
	And he wouldn't have to turn it over.
	No, that wouldn't be work product, Mr. Buchel.
	Well, there are no such notes.
	There are no such notes, so we can keep moving.
	On a matter-by-matter basis, that could be claimed.
	But to have them reviewed, obviously they weren't reviewed for whether they were work product or anything else.
	Objection. You're assuming facts, not in evidence.
	Well, I'm going to ask.
	So, just to make it clear, you didn't give them any of the physical documents in your house to review in response to the request for protection in this case.
	It would be unnecessary because the documents I have came from them.
	They would be, therefore, well aware of them.
	But you keep notes yourself, correct?
	Not on any of these matters.
	I mean, yeah, I make a grocery list.
	Who doesn't?
	You never write anything down.
	Of course I write things down.
	But not pertaining to anything we're here to discuss.
	You didn't write down a lawyer claim as an asshole?
	Did I write that down with my finger?
	Not that I recall.
	That just came to you.
	Well, truth is an absolute defense.
	We'll see.
	Yes, indeed, we will.
	And we'll see what the truth is.
	Yes, we will.
	We're going to work from this binder.
	Give one to the court reporter.
	These are documents that were produced by Dr. Corsi and I in the course of this litigation.
	There are some tax returns at the end which we are going to move with consent to put under seal, Mr. Stone, so I would ask that you not disseminate them or use them in any way other than, in this case, under seal.
	But let's start with my sworn affidavit on top, and I'll ask that that be marked.
	It entails, and you can just mark it right in the book, make it easy.
	That's Exhibit 2 of the Stone deposition, and it entails 59 pages.
	Okay.
	You are aware, Mr. Stone, that I'm the founder of Judicial Watch?
	I am.
	You've spoken to Tom Fitton, haven't you?
	One time in my entire life.
	I saw him backstage at a conference at Doral maybe a couple months ago, and we shook hands and passed him.
	Beyond that, I've never spoken to the man.
	You've spoken to others at Judicial Watch, though, haven't you?
	No, actually, I haven't.
	Not that I recall.
	You may have, but you just don't recall.
	I don't recall ever speaking to anyone at Judicial Watch.
	I couldn't name anybody else at Judicial Watch other than Fitton, who I've seen online.
	And you've sent emails to Fitton?
	No, I don't believe I have.
	You've sent text messages to Fitton?
	No, I don't believe I have.
	You've communicated with him to intermediaries?
	I have not communicated with him at all.
	You know what intermediary means?
	I'm familiar with the term.
	There came a point in time when I left Judicial Watch, correct?
	That's my understanding.
	Yeah. That was around September of 2003.
	Objection of form?
	Correct. If you know.
	Now, I suggest that you don't make speaking objections if you know, okay?
	He knows.
	Actually, I don't know.
	There came a point in time before September 2003.
	That a mutual friend named Scott Reed contacted you concerning me, correct?
	Objection as to form.
	While that may be true, I don't recall.
	Who was Scott Reed?
	Scott Reed was a friend of mine.
	At the time, he was Chief of Staff to Jack Kemp at Housing and Urban Development, correct?
	Objection as to form, as seems facts.
	I just, chronologically, I don't recall.
	I'm just moving it along here.
	Otherwise, we'll be here even longer.
	Now, Scott Reed had formerly been the number two at the Republican National Committee under then-chairman Haley Barber, correct?
	That sounds correct, but I'm unsure of the exact years.
	And Scott Reed told you that I was interested in running for the U.S. Senate?
	That is correct.
	And that at that time...
	It was known publicly that one of the current senators from Florida, Bob Graham, was going to retire.
	There'd be an open seat.
	Correct? Objection to form?
	I don't really recall.
	You don't recall?
	I believe there was an open seat.
	I couldn't tell you what year it was.
	There came a point in time after Reid contacted you that you and I met, correct?
	Yes. And where did we meet?
	Don't recall.
	We met in New York City, correct?
	Objection. Don't recall.
	You had an apartment there close to the plaza.
	Objection. I did have one at one time, but I don't recall the specific meeting.
	And we had dinner, correct?
	Objection. Don't recall.
	During that meeting, we discussed whether you would be my campaign manager on the Senate campaign that I had planned to undertake in Florida.
	Objection. I don't think I've ever been a campaign manager in the last 30 years.
	You would play a role in it.
	Yes, I would agree with that.
	And I told you that if I was to retain you to do that, you would have to be exclusive to me and not representing any other political or potential political candidate.
	I have no such memory.
	And I told you that if you were to work with me, you had to do things ethically.
	Objection to form, correct?
	I have no such memory.
	Given the memory of anything dealing with ethics?
	Objection to form, that's argument.
	There came a point in time when we worked together in anticipation of my running for office in Florida, correct?
	That is correct.
	Okay, and what was your capacity?
	I believe I was working as a strategist.
	And you were then on Miami Beach.
	You had your own office down there?
	That is correct.
	Do you still have that office?
	Do not.
	And you went out and you found office space, correct?
	At your direction, as I recall.
	It was on Olton Road, correct?
	That sounds right.
	On top of the cleaners?
	That sounds right.
	It had previously been a modeling agency that had occupied the space, correct?
	I don't recall.
	You then recruited people to work on the campaign, correct?
	In your direction, yes.
	People that you had known that were friends.
	People I knew—friends, I don't mean—people I thought were competent professionals.
	Who did you recruit?
	Let's see.
	Michael Caputo.
	Teddy Siegel.
	I don't recall beyond that.
	There was somebody that was a weightlifter that was allegedly my security guard.
	Oh, Adam Powers.
	Adam Powers.
	And he also brought in a poster, did you not?
	In anticipation of my...
	Declaring for the Senate in Florida in 2003.
	Normally that would be the first step in any campaign, so I don't recall specifically.
	And that was Tony Fabrizio, correct?
	Sounds right.
	I think he's the best in the business.
	And you lined up a polling agreement with him, correct?
	I don't recall.
	Wherein he charged me $50,000 for a $10,000 survey, correct?
	I don't know that that's true.
	You'd arrange for kickbacks from Fabrizio.
	Absolutely not.
	Do you have some evidence of that?
	Well, the fact that it's five times what it would cost.
	You have no idea what a survey costs.
	How would you know?
	Apparently you do.
	I do know.
	A comprehensive statewide survey does not cost $1,000.
	So in the course, after we decided to work together, you put together a binder of Materials about cases that I had been involved in and matters that I had been involved in as the head and founder of Judicial Watch,
	correct? I have no such memory.
	In fact, you spent a lot of time putting those binders together, didn't you?
	Is your memory that bad, Mr. Stone?
	In all honesty, it wasn't all that important to me.
	I've been through quite a bit.
	No, I don't recall any of that.
	We had several meetings in anticipation of my declaring for the Senate, correct?
	Checking the form?
	Don't recall.
	Likely, but I don't recall.
	We met in your office, correct?
	I don't recall.
	You had a secretary then, or an assistant.
	What was her name?
	Diane Thorne, perhaps?
	Where is she located today?
	I believe she's in Miami somewhere.
	How is Thorne spelled?
	T-H-O-R-N-E.
	And she helped you put together those binders, did she not?
	I don't recall.
	And in those binders, you had a number of my successes at Judicial Watch, correct?
	I don't recall.
	You are aware that when I was at Judicial Watch, I played a role in triggering the China Gate scandal.
	Do you remember the China Gate scandal?
	Objection. I don't recall.
	You're aware that I'm the only lawyer who ever got a court to rule that a President of the United States, Bill Clinton, had committed a crime.
	It was in a civil context.
	Objection. You're aware of that?
	No, actually I wasn't aware of that.
	You're aware that I brought a case against the Commerce Department then run by Ron Brown.
	Objection. No, I wasn't.
	You wear your underneath, aren't you, mister?
	Yes, I certainly am.
	Do you want to recreate what happened?
	Sorry if I haven't memorized your bio, but it's just not that important to me.
	I don't know the answer to the question.
	These comments are argumentative and are not questions.
	Well, I can't stand to sit here silent with perjured testimony.
	It doesn't matter.
	It doesn't matter, and I moved to strike a comment.
	You're aware that telling the truth is not only telling the truth, but not withholding the truth.
	We've been through this.
	He's under oath.
	Ask a question about the cases.
	No, you're aware of that?
	Ask the question about the cases.
	You're aware of that?
	Ask a question about the cases.
	Are you aware that it also entails not forgetting when you, or claiming to forget when you actually remember?
	I don't remember any of the things you've just cited.
	Sorry. Do you remember that someone who worked on that campaign with me was a person named Sandy Kovas?
	Yes. Sandy was my chief of staff in Miami before she came to work on the campaign?
	Yes. At Judicial Watch?
	Yes. Nice lady.
	So she knows what went on, correct?
	What went on?
	What's the occasion?
	With the binders and the background.
	I have no idea what she knows.
	Okay. And you know that she had a daughter named...
	Lisette Tortora, T-O-R-T-O-R-A?
	I did not recall that.
	Okay. In fact, you decided to work with me, represent me, as you put it, as a consultant, because you were impressed with the work that I had done at Judicial Watch.
	Well, I think the reason I wanted to work with you is because you told me you had access to the Judicial Watch House file, and that would be necessary to finance a Senate campaign in a state this large and with these expensive media markets.
	Otherwise, it would be fruitless to try to run for the Senate without...
	So what you were interested in was money.
	No, I was interested in having the money to communicate your message.
	So what I told you was that Richard Vigery had a copy of that list, correct?
	You told me you co-owned the list, as I recall, because that was a standard in the industry.
	Well, regardless of that, you intended to make money off of doing consulting for me.
	You can do it for free.
	Objection. I was never paid anything, if that's what you're asking me.
	Now, in fact, when our relationship ended, the people that you brought in took computers I had purchased with my own money and cell phones, correct?
	Objection of form.
	I have no knowledge of that.
	And Michael Caputo was one of the people that misappropriated that objection of form.
	I have no idea.
	That property.
	I have no idea.
	You're aware that I later wrote a book, an autobiography, Horrors, Why and How I Came to Fight the Establishment.
	I'm unaware of that.
	You've never seen that?
	No, I haven't.
	You're aware that I wrote about our so-called relationship in that book?
	Objection for it.
	I don't recall.
	You weren't contacted by reporters who asked you about your role in my campaign?
	I honestly don't recall.
	Now, at the same time that you were supposed to be representing me, you were actually also representing Al Sharpton, correct?
	That is incorrect.
	I've never represented Al Sharpton.
	I know the gentleman.
	You were helping Al Sharpton, correct?
	I was indeed.
	What was he doing in 2003 politically?
	Disrupting the Democratic Party.
	How was he disrupting the Democratic Party?
	By running for president on a radical platform.
	So you were telling me when you would leave Miami to go up north that you were seeing your sick father, correct?
	I did see my sick father.
	He was ill at that time.
	Notwithstanding that, whether that's true or not, you were also up there to consult with Al Sharpton, correct?
	No, I never consulted with Al Sharpton.
	I'm certainly entitled to meet the gentleman.
	If I wish.
	And you were working with him to, as you put it, disrupt the Democratic Party.
	And that was my goal.
	And how was he going to disrupt it?
	By running on a radical platform, which drives the party to the left.
	You weren't honest with me, were you, that you were going to be exclusive to working with me?
	I don't believe I had any other client at that time.
	Where are the binders that you put together with regard to my campaign today?
	A check in a form?
	I have no idea.
	In one of the meetings that we had, it was at your then home, correct, in North Miami?
	Don't recall.
	You did have a home in North Miami, correct?
	At one time, yes.
	Right. It was on the banks of the Biscayne Bay.
	No, I think it was on the canal.
	It was on Waterway.
	Yes, it was on Waterway.
	Okay, and you remember sitting there with me outside.
	Do you not?
	I do not.
	You remember saying, gee, isn't this great, smoking a cigar?
	I feel like I'm Hyman Roth.
	Don't recall that at all.
	You have an admiration for the mafia.
	Objection of form.
	Do you have a year for this, by the way?
	No, we have two days.
	No, no.
	Year. Yes, 2003.
	Don't recall that at all.
	Okay. Okay.
	You know people who are in the Mafia, do you?
	Objection of form.
	The consulting that you did for Donald Trump was in the gambling industry, correct?
	I represented his Trump Hotels and Casino Resorts, yes.
	It's well known that the Mafia is present in the gambling industry.
	Objection of form.
	Okay, fine.
	It assumes fact's not in evidence.
	There are allegations to that case, but I don't know anybody who would meet that description.
	The Casino Control Commission in New Jersey has very, very rigorous regulation of the industry, so I would doubt that that's true in the New Jersey industry, which is the only market in which Donald Trump ever owned casinos.
	I'm not saying that President Trump is mafia or has associations.
	I'm saying the gambling industry has...
	A significant component of the mafia.
	I don't know how he's qualified to even say that.
	I've read that, but I don't know it to be true.
	I don't think it's true in New Jersey because of their rigorous regulatory scheme.
	Now, Hyman Roth was the character that played Meyer Lansky in the movie The Godfather, correct?
	Yes. And you have an admiration for him?
	I've never said anything of the kind.
	And you have an admiration for Roy Cohn, too, COHN?
	Roy Cohn was a friend of mine, yes.
	The binders which you kept had a number of my successes in it, both at Judicial Watch and in my private capacity as a lawyer, did it not?
	I have no recall of any such binders.
	You wouldn't have represented me if I was a loser, would you?
	I thought that you, if you had the money, could be a viable candidate for the Senate.
	A loser can't win for the Senate in Florida.
	Not without money.
	A loser could win?
	No, no.
	A loser cannot win unless they have money.
	What defined loser in your context?
	Someone who loses cases repeatedly and who accomplishes little to nothing, in this case in the legal profession.
	I'm not sure I understand the question.
	How did you do in the Senate race?
	We'll get to that.
	Thanks to you.
	No, thanks to you.
	No, thanks to you.
	Where's that list, Larry?
	Now, what is it that, other than money, caused you to represent me in the Senate race?
	We were friends at that time.
	You had just, as I recall, come out of Judicial Watch.
	You wanted to run for the Senate, and you had, you told me, access to the necessary elements of raising a substantial amount of money in one of the most expensive states in the country to run for a statewide office.
	Now, at the time that I declared, You had arranged for a tour of Florida on a private jet, correct?
	I don't recall.
	And we went to three different locations?
	I don't recall.
	We went to Tampa, Orlando, and Miami, correct?
	I don't recall.
	You were actually on the plane with me.
	Objection of form?
	No, I don't believe that's true.
	Who was on the plane with me?
	I don't recall there even being a plan.
	Michael Caputo was on that plane, wasn't he?
	I have no idea.
	You're aware that at each location I gave a speech, correct?
	I don't even recall the tour, so I couldn't say.
	You helped prepare that speech, did you not?
	I don't recall.
	You're aware that at the time the governor of Florida was Jeb Bush?
	It sounds correct, but I'm uncertain.
	You had sold your services to me in part by saying that you strongly disliked the Bushes, correct?
	That is definitely true.
	I've written a book on the subject.
	But you still urged me to call him when I ran.
	When I declared for the Senate as a courtesy as the Governor of Florida, correct?
	I think that would be the protocol.
	I don't recall that specifically, but normally speaking that would be the protocol.
	Now, we parted ways, did we not?
	I believe we did.
	And what did you do after we parted ways?
	What did you do after that?
	Work for Sharpton?
	Never worked for Al Sharpton.
	Consulted with him?
	Never consulted.
	He's a friend of mine.
	I gave him advice when he asked for it.
	Do you have friends that are basically race-baiting vigilante extortions?
	Objection. You consider those your friends?
	Objection of form.
	I'm instructing the witness not to answer.
	I mean, for a defamation case, you just defamed Al Sharpton.
	Are there others?
	You can't defame Al Sharpton.
	I can't defame you either.
	That's what you think.
	Would a jury decide that?
	I doubt it.
	I doubt it.
	Do you have faith in the jury system?
	Objection of form.
	These are not relevant questions.
	Ask your next relevant question, please.
	Thank you.
	You are aware that After I left, or after the Senate campaign, I started a group called Freedom Watch, correct?
	I don't know when you founded Freedom Watch.
	I do know you started such a group.
	And you're aware that while I was at Freedom Watch, and still am, I obtained preliminary injunctions against the National Security Agency for illegal mass surveillance objection.
	I was unaware of that.
	You read the media.
	Routinely, do you not?
	I do, but I don't recall reading that.
	You have an interest in the mass surveillance that's been conducted on President Trump.
	I do.
	And you're aware that it had been conducted on others before him by the NSA, FBI, CIA.
	I believe that to be true, but I don't recall.
	Reading about you in that context.
	And you believe that they've conducted mass surveillance on you, illegal mass surveillance, correct?
	Objection to form.
	The New York Times reported that on January 20, 2017, on page 1. Now, notwithstanding your, quote, not remembering, unquote, if an individual is able to obtain a preliminary injunction against the NSA,
	the CIA, or the FBI, With regard to mass surveillance, that's quite a legal achievement, is it not?
	In terms of mass surveillance?
	In all honesty, I'm not an attorney, so I couldn't tell you what a preliminary injunction
	That is getting a court to order that the alleged illegal activity cease.
	You're aware of that?
	You don't know that.
	You're aware that I played a role at Freedom Watch in having Obama's five million dollar, excuse me, five million illegal alien amnesty executive order declared.
	Void. Objection of form.
	Not familiar with that.
	That wasn't widely reported either?
	I can't tell you what was widely reported.
	I certainly didn't read it.
	You're aware that the injunctions that I did get against the NSA and the other intelligence agencies and FBI gave rise to the USA Freedom Act?
	Objection of form.
	Congress passed a new law.
	I'm unfamiliar with that.
	Now, if in fact that was the case, that would be quite a legal achievement, wouldn't it?
	Objection of form.
	You're asking for a conclusion.
	I'm unaware of any of those things.
	You don't read the media at all.
	I do read the media, but you're not ubiquitous in the media.
	Okay, see, these are the documents that were requested, okay, as to what you know about me, mentioning me, right?
	Yes. And Dr. Corsi.
	Yes. But now you've gone blank, correct?
	Objection of form.
	It's not that important to me.
	Sorry. You were important enough, I was important enough to you to make several remarks about me on InfoWars.
	Yes, indeed.
	form.
	You're aware that I'm a columnist on World Net Daily, correct?
	I am not.
	You've written articles for World Net Daily, haven't you?
	I'm uncertain.
	I don't think so.
	But I'm uncertain.
	You're aware that I have a radio show, Special Prosecutor with Larry Klayman?
	I did not know that.
	Your role as a political consultant with Black Manafort and Stone was to help presidents get elected and then call in the chips with regard to lobbying money.
	Objection of form.
	Call in the chips.
	Well, profit from that.
	I've seen some objection.
	Get someone elected president and then trade off of your...
	That would be your interpretation, not mine.
	You have called yourself a self-styled dirty trickster.
	No, actually I haven't, and I forced the Los Angeles Times to retract that.
	The self-described dirty trickster is not how I have described myself.
	I have commented that I've been called that, and therefore I'm probably stuck with it.
	But no, I have not proclaimed myself to be said.
	What was that documentary that was done about you by Netflix?
	What was that called?
	It was called Get Me Roger Stone.
	It was a quote from James A. Baker III.
	Now, during that documentary, you touted the fact that you are a master of political dirty tricks.
	I don't know that I specifically said that.
	What did you say?
	Don't recall.
	The film speaks for itself, correct?
	You can go look at the film, I guess.
	In 1996, you were accused at the Republican Convention in San Diego of attending a swingers party.
	Do you remember that?
	Rejection of form.
	Relevance? Yeah, what's the relevance of that?
	That's when I represented you with regard to get the media off your back, correct?
	I think that's correct.
	You later advocated for me to become U.S. Attorney for the Southern District of Florida, did you not?
	I don't recall that, but I certainly may have.
	Now, you wouldn't advocate for somebody that's a loser to be U.S. Attorney for the Southern District of Florida?
	Well, what year was that?
	So you're saying I became a loser after that?
	All I'm saying is that I look at the totality of your record, and I'm entitled to my opinion.
	But you're saying I've never won a case.
	You have absolute knowledge that I've never won a case?
	That was the impression I had, yes.
	What research did you do to determine that I never won a case?
	I don't know that you need research to express an opinion.
	That was an opinion.
	No, that's a fact, isn't it?
	Either you win a case or you don't win a case.
	If you say so.
	A statement like that can damage a lawyer in terms of his ability to obtain clients, his reputation, and his goodwill, correct?
	Objection of form.
	You can respond.
	You do enough of that on your own.
	You're aware that that can be very damaging to a lawyer in terms of his reputation and goodwill, correct?
	Since I'm not a lawyer, I don't know that.
	No one's going to hire a lawyer that loses every case, correct?
	I wouldn't, that's for sure.
	You hired Mr. Buchel, right?
	Yes, I had.
	Did he win?
	He's won a number of cases.
	He certainly won the case against the DNC, and he won the Cockrum case, yes.
	And despite the fact that he lost your criminal prosecution, he's still your lawyer, correct?
	On this matter, he is, yes.
	And Mr. Smith?
	On this matter, yes.
	You were alleged with regard to that swingers party of wearing a toga, correct?
	Objection of form.
	Don't recall.
	And posting pictures on the Internet of yourself half naked?
	Objection of form.
	Half naked is defined as not wearing a shirt, I think.
	And you had told me at the time that that was your houseboy that...
	Posted that.
	That's what I believed at the time.
	You posted it, didn't you?
	I don't recall doing that, no.
	Mm-hmm. Mm-hmm.
	I'm going to turn your attention to page 10 of Exhibit 2, paragraph 58. This is an appearance that was published.
	By InfoWars on January 18, 2019.
	That's what's being referenced in paragraph 58, correct?
	Yes. Appears to be.
	Now, what is InfoWars?
	It's an online, conservative-oriented news organization.
	And how did they disseminate, at that time, how did they disseminate their broadcasts?
	Online. It was on YouTube at the time?
	19, yes, it would be on YouTube.
	What was your relationship with InfoWars on or about January 18, 2019?
	At that point, I was an occasional contributor.
	I had no business relationship with them.
	You're aware that InfoWars had many viewers at that time, correct?
	Yes. They had millions of viewers, correct?
	I think that's probably true, yes.
	And they still do.
	I couldn't tell you what their viewership is today.
	And many of those viewers are in the state of Florida, correct?
	I would think so, yes.
	And in their videos, they solicit money, correct, to buy products that InfoWars sells.
	They sell products, yes.
	Now, the head of InfoWars at the time, in terms of the broadcast, was Alex Jones, correct?
	That is correct.
	Was he an owner of InfoWars at that time?
	I don't know what the ownership of InfoWars is.
	He has a father, does he not?
	He does.
	Who's that?
	I don't recall his name.
	He's an owner as well, correct?
	I don't know that.
	The broadcast which you made on January 18, 2019, you referred to me, Larry Klayman, correct?
	That appears to be the case.
	Why did you refer to me during that broadcast?
	I suspect because you did something I didn't like.
	What did I do that you didn't like?
	Don't recall.
	So you'll make negative statements about somebody even if you don't know whether anyone did anything that you didn't like?
	I'm entitled to an opinion.
	It's a free country.
	So it just came out of the blue?
	Don't recall what prompted it, to be honest with you.
	In fact, you thought somehow that I was going to be a threat to you with regard to Special Counsel Robert Mueller's.
	So-called Russian collusion investigation.
	Objection of form.
	I'm not going to answer that.
	We're not talking about the criminals.
	You were concerned about my experience with you at the time that you were consulting on my Senate campaign in Florida, correct?
	Conjecture on your part.
	You were concerned that your staff had misappropriated.
	Absolutely not, and I don't know that there's any proof of that.
	You were concerned that I didn't like you in some way, correct?
	Not particularly.
	That doesn't concern me one way or another.
	You were concerned that I was angry at you.
	For the time period that you represented me, allegedly represented me, because you were doing Sharpton.
	Actually, I was angry at you, but that's okay.
	Okay, why were you angry at me?
	Because of a number of misstatements and falsehoods that you told me regarding your ability to raise money.
	Okay, well money is all that's important to you, right?
	Money is important in terms of getting you elected to the Senate, yes.
	And it's important to fill your pockets.
	Do you not work for money, Mr. Klayman?
	You never paid me a dime.
	You violated my trust, did you not?
	You violated my trust, Mr. Clement.
	Now, you were also concerned that it had been reported that I was representing Dr. Jerome Corsi on January 18, 2019.
	Conjecture on your part, I don't recall.
	You feared Dr. Jerome Corsi, did you not?
	No, absolutely not.
	You made a number of derogatory statements about him as well during the course of the Russian collusion investigation.
	We're not answering questions about...
	All right, we'll get to the specifics.
	But you don't get to decide what he answers, okay, Mr. Bichon?
	But I do, so I'm not answering questions regarding that.
	Certify it.
	Please do.
	Now, at 125 of that broadcast, back up.
	You were concerned somehow that Dr. Corsi was going to collaborate with Special Counsel Robert Mueller and his staff against you.
	Correct. Conjecture on your part.
	Yeah, and let's not get into it.
	I'm not asking about my conjecture.
	I'm asking about you.
	We're not talking about anything related to that.
	I told you that in court when we agreed to have this deposition.
	Intent is an issue here, okay?
	So you're not...
	I'm instructing.
	You're going to wind up getting yourself sanctioned, Mr. Bischel.
	No, you're going to get yourself sanctioned, Mr. Klingman.
	As you have been in D.C., as I recall.
	Ask your next question, please.
	Dr. Jerome Corsi was material witness number one in your indictment by Special Counsel Robert Mueller,
	correct? We're not talking about any Special Counsel indictment.
	I'm laying a foundation.
	These statements were made in the context of an ongoing criminal investigation and prosecution of the defendant, in this case Stone.
	And motive and intent is relevant in this case, particularly with regard to punitive damages or anything else.
	So I'm entitled to ask these questions.
	May I respond now?
	You can respond.
	The purpose of this deposition was to have all these cases consolidated, including discovery.
	You represented to me that Newsmax would also be a part of it.
	That didn't work out.
	They're here, but they're not required to ask questions.
	You're permitted to come back on a different day.
	We didn't get the benefit of the bargain, meaning sitting here having a full and complete deposition.
	Mr. Stone still has issues regarding the criminal case, so we're not going to be answering questions today about anything relating to the special counsels.
	Are you instructing him to take the Fifth Amendment?
	No, I'm not instructing him to take the Fifth Amendment.
	Then he has to answer.
	No, I'm instructing him not to answer.
	Then you're instructing the deposition.
	I am not.
	There are motions to dismiss pending as to Mr. Corsi, and this is the time you demanded to have this deposition.
	I try to accommodate.
	It didn't work out.
	We'll do it another day.
	You're the one.
	We're doing it now.
	You're the one who suggested the consolidation, correct?
	To the judge.
	And I just explained to you what happened.
	I just explained to you what happened.
	So let's ask other questions.
	Well, there's actually an order which consolidates the discovery, correct?
	Which is not really consolidated, is it?
	Are you defying that order like you did the notice of deposition this morning?
	I did not defy any order.
	Coming up with nonsense as to why you didn't know where this was when you came in 40 minutes late?
	Thank you, Mr. Klayman.
	Move on.
	Let's go.
	Now, you were concerned that Larry Klayman and Dr. Zaram Corsi were going to do something in collaboration with Robert Mueller that would affect you in the criminal investigation and prosecution by the special counsel, correct?
	I'm not answering any questions pertaining to it.
	Certify it.
	Yes, do.
	And that's why you then launched these.
	Statements about me on InfoWars.
	Speculation on your part.
	And you're aware that I was Corsi's counsel.
	We're not answering these questions.
	Certified. At 125, you say, Defendant Stone, you say, he's, meaning claimant, never actually won a courtroom victory in his life.
	I believe that to be true at the time, yes.
	You never did any research, did you, to find out whether that was true or not before you made that statement?
	That is an impression that I had, yes.
	Okay. But, in fact, you actually did know that I had courtroom victories.
	No, actually, I didn't.
	Or you wouldn't have wanted to be my so-called consultant in the Senate campaign.
	That was a long time before this.
	Okay. You then say at 1:30, Defendant Stone says he, meaning Clayman, was ousted at Judicial Watch.
	Asked Tom Fitton why he left.
	He was ousted because of a sexual harassment complaint.
	Yes, I'd heard that.
	Where did you hear that?
	Don't recall.
	You heard it from Fitton, didn't you?
	I most certainly did not.
	Okay, but you remember that, but you don't remember where you heard it.
	I don't remember what I heard, but as I've told you previously, I've never spoken to Tom Fitton other than the one time in passing when we shook hands.
	And we certainly didn't discuss this.
	And during that one time in passing, you discussed this, correct?
	We did not.
	Okay. So you just gleaned that out of the cosmos?
	You know how politics works.
	People talk.
	Particularly about something like that.
	Well, who talked?
	What were the circumstances that you're leaving?
	Who talked?
	Why would you leave an organization that you founded?
	Who talked?
	I don't recall.
	You don't recall?
	No, I don't.
	You're lying, aren't you, Mr. Snow?
	No, you're lying, aren't you, Mr. Clayton?
	You're a convicted liar, aren't you?
	Stop, stop, stop.
	And you're about to be ousted from the bar.
	Stop. Let's take a break.
	Good time for a break.
	Have fun blessing your own children, Larry.
	I read the court decision.
	You read that, huh?
	Yeah, I did.
	We didn't read anything else.
	Fuck you.
	Are we off the record?
	Yes. Off the record, 1047.
	Back on record at 1053.
	Going back to paragraph 58. At 137 of the InfoWars broadcast, back up.
	InfoWars generally has a conservative audience, correct?
	Conservative and libertarian, I'd say.
	And you're aware that I am a conservative, correct?
	That's my understanding.
	At 137, you stated on that broadcast, he, Clayman, is incompetent.
	He's a numbskull.
	He's an idiot.
	He's an egomaniac, and he could be the single worst lawyer in America.
	With him as Jerry Corsi's lawyer, Corsi may get the electric chair.
	So your idea that he's a good guy is entirely wrong.
	Constitutionally protected free speech.
	Opinion. We'll let the jury determine that.
	Yes, I doubt it.
	Objection of form.
	Generally speaking, you need evidence to get your case that far.
	You have faith in judges?
	Objection of form.
	You have faith in Amy Byrne Jackson?
	Objection of...
	What are you doing?
	Ask questions about the case.
	This is argumentative.
	He's the one who's injecting legal analysis into it.
	You're a lawyer.
	Stop being argumentative.
	Ask a question.
	I'm asking the question.
	So you did know that I was Corsi's lawyer, correct?
	Yes, I guess I did.
	Now you remember.
	Well, I don't remember the context of this.
	In all honesty, you don't put anything ahead of it to indicate the context.
	But based on that quote, yeah, I'd say so.
	Now, Jerry Corsi didn't get the electric chair in my...
	Not that I'm aware of.
	In fact, Jerry Corsi was never indicted by special counsel Robert Mueller, correct?
	Correct. But you were, correct?
	Not answering that question.
	So I guess I'm not the single worst lawyer in America, am I?
	That's an opinion.
	That calls for an opinion.
	Okay. Okay.
	You're also talking to Alex Jones at this time, are you not?
	Alex Jones and his sidekick, Aaron Stroyer, S-T-R-O-Y-E-R.
	That's in a form.
	Correct? You're on InfoWars with them.
	In this time frame, I would think so, yes.
	So you're actually intending to damage my reputation with Alex Jones.
	Your interpretation, not mine.
	And Aaron Stroyer as well.
	Owen, I think his name is Owen.
	Owen, okay.
	That's your interpretation, not mine.
	You are aware that I was a guest frequently on InfoWars?
	No, actually I wasn't.
	You're aware that I went on Joel Gilbert's show on InfoWars?
	Yes, I did know that.
	You're aware that Joel Gilbert had a show on InfoWars?
	No, that's not my understanding.
	Occasionally, on Fridays, various people would sit in for Jones, who often took Fridays off.
	And in fact, on at least one occasion, Joel Gilbert emailed you and said, You know Larry claimed he's going to be on my show today?
	Objection of form.
	I don't recall that.
	You're aware there's an email to that effect, are you?
	There may be, but I don't recall that.
	And you didn't produce that to me, did you?
	Objection of form.
	I don't know that there is or that there isn't.
	Your lawyer pulled it out of the stack that you gave him?
	Objection to form.
	And why would he know that?
	That's the point.
	He didn't control the document production, so he claims.
	You don't know what was pulled out of anything you gave to your lawyer?
	That assumes facts.
	Nothing was pulled.
	Go ahead.
	Ask a question.
	That doesn't assume facts, not in evidence.
	Please. At 201, you say, Defendant Stone, you called me a piece of garbage, correct?
	If this is an accurate transcript, yes.
	Constitutionally protected free speech.
	Make it a practice of calling people pieces of garbage?
	When they are.
	Who else would you be called pieces of garbage?
	Nobody I can think of.
	Robert Mueller?
	Objection. We're not talking about Robert Mueller.
	Aaron Zielinski?
	Not talking about them.
	Next. The other prosecutors, you called them garbage too?
	Next. At 411, for those people out there who think that Larry Klayman's IQ is higher than 70, you're wrong.
	You said that, right?
	Yes, if this is an accurate transcript.
	Again, my opinion.
	Now, that's a factual statement, is it not, that I don't have an IQ higher than 70?
	It's an opinion.
	Someone who has an IQ of 70 or less is essentially retarded, correct?
	It's an opinion.
	You were saying that I was retarded.
	I didn't say that.
	I don't see that word here.
	You were saying that I am someone who doesn't have the mental capacity to basically do much of anything, correct?
	I don't see those words here, no.
	That's what less than 70 means.
	That's your opinion.
	You know what IQ means, correct?
	I'm familiar with it, yeah.
	And what does it mean to you?
	Intelligence. It's actually a scientific...
	Objections of intelligence.
	You're not the witness today.
	Well, he knows.
	He's an adverse witness.
	I can ask him leading questions.
	Ask him a question.
	Don't say, don't you know this?
	I can say it any which way I want, Mr. Buchel.
	Okay. Go ahead.
	What's your question?
	Yes, you're aware of that.
	An IQ test is a scientific determination of one's intelligence.
	Generally speaking, yes.
	So therefore you were stating a fact that I had a IQ...
	Stating an opinion.
	Less than 70. Stating an opinion.
	Sorry you're so sensitive.
	And in fact, when you say less than 70, you could mean it go all the way down to zero or one, correct?
	Nothing would surprise me.
	Paragraph 59. On March 22, 2017, a YouTube video published in this circuit contained false misleading.
	I'm just reading in the paragraph of defamatory statements concerning me, meaning Larry Klayman.
	This was my affidavit that we're reading from.
	These false and defamatory statements include, but they're not limited to, and these are your statements, at 45 of the hour in the YouTube video, you stated, now comes gadfly right-wing lawyer Larry Klayman.
	To say that Alex Jones and Infowars have violated the law in their release of classified documents and would be prosecuted.
	You made that statement, did you not?
	If this is a true statement of what was said on the internet, on the video, yes, on the other hand, I don't recall specifically what that refers to.
	Context. Excuse me, Mr. Clayton.
	Yes, I didn't put my thing on.
	Are you able to get my sound in here?
	Yes, I got it.
	Thank you.
	Thank you.
	You were referring to whether or not Alex Jones and Infowars had classified information from a whistleblower about national security matters, correct?
	I don't recall.
	And it was dealing with alleged mass illegal and unconstitutional surveillance.
	On the American people by the Obama, NSA, CIA, and FBI, correct?
	I don't recall.
	So you just pulled this out of the hat?
	Well, it said in the context of the time, and I don't remember the specific interview.
	I'd have to see the entire interview to understand the context.
	You are aware that at the time...
	I had represented someone by the name of Dennis Montgomery, correct?
	No, I don't think I was.
	Montgomery was an alleged whistleblower who left as a contractor of the NSA, CIA and FBI, allegedly with 47 hard drives and over 600 million pages of information,
	some of which...
	It was claimed to be classified, correct?
	Objection form?
	Is that a question?
	Yes. No, I'm unaware of that.
	You're aware that I got two immunity agreements for Montgomery so he could come forward with that information and be interviewed by the FBI?
	No, I'm unaware of that.
	You actually proposed...
	You know who Mike Zullo is?
	Yes. Yes, who's Mike Zullo?
	I think he used to work for Joe Arpaio.
	Sheriff Arpaio is my client, correct?
	You're aware of that?
	Not aware of that.
	That hasn't been widely reported either?
	I don't know whether it's been widely reported or not, but I was unaware of it.
	You don't think Arpaio would hire somebody with an IQ less than 70, do you?
	It calls for an opinion.
	Are you saying that Sheriff Arpaio has an IQ less than 70?
	I have a high regard for Sheriff Arpaio.
	And he's an intelligent man, correct?
	Yes, he is.
	Now, at the time, you had proposed to Mike Zullo That you could get Montgomery a meeting in the White House with President Trump, correct?
	I have no memory of that whatsoever.
	I don't think I've ever spoken to Mike Zullo.
	You also proposed that to Dr. Jerome Corsi, correct?
	I have no memory of that whatsoever.
	You are aware that Dr. Corsi had worked with Mike Zullo on the issue of whether or not President Obama's birth certificate was authentic or not?
	I had read that, yes.
	And you had been in communication with Corsi and Zullo.
	I have no memory of that.
	You believe that that birth certificate was not authentic, correct?
	I didn't have an opinion at the time.
	I don't think I...
	What year are we talking?
	Ever. Well, but I didn't think...
	Let's go back.
	I don't recall any such conversation.
	You said President Trump in the White House.
	I don't recall any such conversation.
	Or you would put Montgomery in touch with individuals in the Trump White House.
	I never recall saying any such thing.
	You were stating at the time that President Trump had been illegally surveilled by the intelligence agencies and the FBI in and around the time of this published statement on March 22, 2017.
	I don't recall that.
	And...
	You wanted to put this whistleblower in touch with either President Trump or people in the White House because he had come forward and said that he had knowledge from his time as a contractor for the NSA, CIA, and FBI that those agencies were surveilling President Trump unconstitutionally.
	Objection. I have no such memory.
	Again, you're aware that forgetting things when you remember is also perjury.
	Let's, I have Jack.
	My answer is the same.
	Objection of forum.
	You've been in contact with Montgomery, have you not?
	I don't believe so.
	I'm going to be getting your telephone records.
	Help yourself.
	Now, will that convince you to tell me whether or not you've been in contact with him?
	I don't believe I've ever spoken to Dennis Montgomery.
	Have you spoken with anyone on his behalf?
	I have not.
	Michael Zulo?
	I don't believe I've ever spoken to Michael Zulo, as I said previously.
	Jerry Corsi?
	Not in regard to Dennis Montgomery, not that I recall.
	With regard to illegal mass surveillance, which included the president?
	I remember reading a story, I think it was on InfoWars, regarding this program.
	And to the extent that I have any knowledge of it, it would have come from that.
	You've never, ever made any statements that the President was illegally surveilled?
	Oh, I believe he was, but we're talking about it much later.
	And you, of course, had an interest in finding out whether or not he was illegally surveilled.
	I would think every American citizen would have an interest in that.
	Style yourself as a close confidant and friend of President Trump, correct?
	I'm certainly a friend of his.
	Okay, in fact, just yesterday he suggested you shouldn't be sentenced to what the Department of Justice recommended.
	No, please not.
	We're not talking about that.
	Okay, but you're close enough that he can do something like that.
	We're not talking about that.
	Ask questions about your lawsuit, sir.
	This is about my lawsuit.
	Sure. Thank you very much.
	He's told you he's a friend of Donald Trump.
	That's what you get.
	I don't want your testimony, Buchel.
	Please. I don't need your testimony.
	maybe at some point we'll have it but not now
	What you're referring to was a concern that you perceived that I had, that Alec Jones and if it were somehow had access to classified information that was provided allegedly in a court case in Arizona concerning Sheriff Joe Arpaio with regard to alleged profiling of Latinos in Maricopa County,
	correct? Objection.
	No foundation.
	These are assumed facts, not in evidence.
	I am entitled to ask my questions.
	I'm entitled to even ask leading questions, so please don't interrupt, Mr. Bichelle, or I'll move to have you sanctioned.
	I'm not saying it's leading.
	I'm saying your questions are assuming many facts, not in evidence.
	I will say it again.
	Can you read back the question?
	What you were referring to was a concern that you perceived that Alex Jones and InfraWars somehow had access to classified information that was allegedly in a court case in Arizona concerning Sheriff Joe Arpaio with regards to a profiling of Latinos in Maricopa County.
	That's your assertion.
	I have no such memory.
	You are aware that Sheriff Arpaio was found.
	Liable for misdemeanor for alleged profiling and violation of a court order.
	I was aware of that.
	And you're aware that Dennis Montgomery entered into that case in terms of some of the information which the judge, Murray Snow, had obtained?
	I was aware of that.
	You're aware that Dennis Montgomery actually was working with the cold case posse of Mike Zullo investigating illegal surveillance in Arizona.
	Objection of form.
	I'm not aware of that.
	You're aware that that was an issue in that case?
	Objection of form.
	was not aware of that.
	At one o'clock, you also publish, quote, to be clear, Larry Klayman is a moron.
	He has never won a case in court in his life.
	He may have won a few motions.
	He's a lightweight.
	He's a know-nothing.
	Now, to be able to make the statement that I never won a case in court, you had to look back into my record as a lawyer, correct?
	Well, that's the impression I had.
	I believed that to be sure at the time I said it.
	So you basically showed a reckless disregard for the truth at a minimum.
	Are you not disputing the other things I said?
	I'm getting to that.
	Constitutionally protected free speech.
	So you then stated he may have won a few motions.
	That's what I believed at the time.
	So to do that, you would have to go back into my background to find out whether or not I had won a few motions, correct?
	It was just an impression that I had.
	And where did you get that impression?
	don't recall.
	So your concept of...
	Constitutionally protected free speech is that you can say anything you want about anyone without consequence.
	Objection of form.
	That's your view.
	You're a public figure.
	Worst has been said about you.
	Because you, Roger Stone, specialize in attacking people publicly.
	That's part of what you do.
	That's not a question.
	That's a personal attack.
	It's not a personal attack to say I've never won a court case in my life?
	That was my impression at the time.
	I believed it at the time I said it.
	It's not a personal attack to say that my IQ is less than 70?
	That was my opinion at the time.
	A moron and a retard?
	Those words are not there.
	Moron is here though, isn't it?
	Yes, it is indeed.
	That's a constitutionally protected opinion.
	You've done research on what is defamation?
	I am entitled to an opinion.
	Well, you've done research and you know what constitutes defamation, correct?
	No, I'm not an attorney.
	So you have no clue as to what defamation entails?
	I know I'm entitled to my opinion.
	And because you have no clue, that means you can say anything you want about anyone without consequence, correct?
	I'm not an attorney, I couldn't say.
	You know, if I was you talking about me, I would ask you if your IQ is less than 70. Object.
	What is your IQ?
	I'm not answering the questions.
	Those aren't questions.
	Those are attacks.
	You know what your IQ is?
	What is it?
	I couldn't tell you.
	Have you ever been tested for that?
	of.
	Turn to the next page, which is 12. You have had contact.
	You're aware that I represent Cliven Bundy, correct?
	I became aware of that, yes.
	How did you become aware of that?
	Because I spoke at a rally in Nevada in favor of a pardon for Mr. Bundy.
	And others who got caught up in that action by the federal government.
	And who did you speak to about that pardon?
	I think I sent a letter to the president.
	You spoke to Deborah Jordan, the person who works with and apparently is the girlfriend for Pete Santilli?
	I don't recall ever discussing that with her.
	She's the one that invited you to Nevada, correct, to speak?
	No, actually, I don't think so.
	I think Dean Ryan was the person who invited me to Nevada.
	Who's Dean Ryan?
	An activist out there.
	Okay. Have you spoken to anyone about that pardon with the Bundy family?
	Mrs. Bundy, Clevin's wife, I guess, was at the event, yes.
	And what, if anything, did you say to her?
	I said I thought her husband deserved a pardon.
	Did you say you were trying to get a pardon for him?
	I told him I would write the president, yeah.
	And you did?
	I believe I did.
	And you have a copy of that letter today?
	Today? No, not today.
	No, you have a copy of that in your possession, custody, or control?
	I honestly don't know.
	Did you give that to Mr. Buschel?
	I did not, but I don't see the relevance.
	Now, at the time that you met with Mrs. Bundy and others in Nevada, you were aware that I represented Cliven Bundy.
	No, actually I wasn't.
	I became aware afterwards.
	If you're asking...
	Whether your name came up, I don't recall it coming up at the time.
	In fact, the basis upon which you offered that pardon was to help yourself make money, correct?
	Absolutely not.
	I was paid nothing for my appearance there.
	You were attempting to trade off your relationship with President Donald Trump.
	I received nothing for that event.
	I did that because I think these people were wronged.
	You are aware that I told Carol Bundy not to have anything to do with you?
	I'm unaware of that.
	Because I believe that you're unethical?
	You're aware of that?
	It's argumentative.
	That's a personal attack.
	Are you aware?
	Along with defendants trying to trade off my clients like a scavenger, there's defamation for you.
	I asked nothing of the Bundys.
	Nothing. It's not even expenses.
	So this was to boost your reputation so you could make money?
	No, it was to try to help right a wrong.
	Because money is what primarily matters to you.
	That's conjecture on your part, some kind of veiled insult, I guess.
	Well, you just said that was the case when you represented me.
	No, that's not what I said at all.
	I said you needed the resources to try to communicate a message.
	And those resources would go to pay you and your staff, correct?
	Partially, but I generally believe that overhead in a campaign should be at less than 20% of the budget.
	And it would pay your friend, Tony Fabrizio, the pollster.
	Any campaign that's a serious statewide campaign needs a benchmark poll which cannot be had for $10,000.
	You were making a percentage off of what Fabrizio was charging the campaign.
	I have no such memory whatsoever.
	Do you have some evidence of
	that?
	You're a friend of Tucker Carlson, aren't you?
	I am.
	And Daily Caller.
	I am.
	And you know Chuck Ross, a reporter of the Daily Caller, correct?
	I do.
	And you've talked to him?
	Not recently, but prior to the gag order, yes.
	Yeah. And you used Tucker Carlson to make statements favorable to you during the time period that you were under a gag order and still are under a gag order.
	Objection. With Judge Jackson in Washington.
	Okay, we're not answering these questions.
	Next. Has nothing to do with your lawsuit.
	Next. In fact, you used Chuck Ross at Daily Caller to make negative statements about Jerry Corsi and his involvement with a doctor in Florida, correct?
	Say that again?
	Repeat the question.
	Sure. In fact, you used Chuck Ross at Daily Caller to make negative statements about Jerry Corsi with his involvement with a doctor in Florida, correct?
	The doctor, you're saying?
	He knows what I'm talking about.
	We'll get to it more specifically.
	I don't recall any such conversation.
	You planted a story with Chuck Ross to try to harm Dr. Corsi.
	You have no evidence of that whatsoever because it's not true.
	Well, we'll be deposing Chuck Ross.
	Good. Help yourself.
	And Tucker Carlson.
	Have fun.
	I don't think either one tells either one of those guys what to say or write.
	I certainly haven't.
	But you have had contact with him about various matters.
	Prior to the gag order, yes.
	And during the gag order.
	No. In fact, the evening before you were convicted, you had discussions with Tucker Carlson, correct?
	We're not talking about any of that.
	Next question.
	Certified. You are aware that in 2018, I told Alex Jones and his producers on Infowars that I did not want to appear on any show which included Defendant Stone.
	Or had ties to Defendant Stone, either as a guest or as a host, because I strongly felt at the time that Mueller may indict Defendant Stone.
	Defendant Stone was at the time a host on Infowars.
	That's the correct statement, is it not?
	I have no knowledge of that.
	Alex didn't tell you that I wouldn't go on a show with you?
	He did not.
	Are you aware that the National Enquirer also told them that I don't want to appear in any article where you were mentioned?
	That's paragraph 64. Yes, I just read it.
	Unfamiliar with that.
	The person at the National Enquirer told you that, correct?
	I have no memory of that.
	Now, you had a relationship with the National Enquirer, didn't you?
	I knew one woman reporter in New York who worked for the National Enquirer.
	In fact, you've written stories for the National Enquirer, correct?
	I think I wrote a sidebar on the JFK assassination, yeah.
	That's it?
	There may be others, I just don't recall.
	Paragraph 66. You're aware of this as well, are you not?
	I also warned Alex Jones not to release any information that was potentially under seal in the contempt case of Melendrez v.
	Arpaio. 07-CV 02513, District of Arizona, 2007, which he may have improperly obtained from Defendant Stone or others concerning Dennis Montgomery, another whistleblower client of mine who contracted with the U.S. government so it could use his software capabilities for intelligence gathering.
	That refreshes your recollection.
	I have no memory of that.
	You're also aware that I warned my client Dennis Montgomery to stay away from you?
	No memory of that.
	I have no knowledge of that, I should say.
	Paragraph 69. Stone wanted to and did intimidate and threaten my client Dr. Corsi since he is a material witness.
	In the Mueller investigation, his defendant Stone obviously feared that he would testify against him to Mueller.
	Defendant Stone feared me as Dr. Corsi's lawyer, as he knew that I know what type of person he is, and must have thought falsely that my representation of Dr. Corsi was my revenge for him having harmed me during my U.S. Senate campaign.
	That's an accurate statement.
	We denied it in the complaint, and we're not talking about it, but it assumes more effects.
	You denied it.
	He didn't sign the complaint.
	I can ask that question.
	He didn't sign your answer.
	I can ask the question.
	That would all be conjecture on your part.
	That was, in fact, the motive to attack me and Corsi.
	You feared us both, correct?
	We're not talking about your motives regarding the indictment or anything.
	Given that I'm a know-nothing, a moron, have IQ less than 70, never won a case, why even bother mentioning me on InfoWars?
	Don't recall.
	Just something that you had an epiphany at the time that you had to attack Larry Klayman and Dr. Jerry Corsi?
	I can't take the heat and get out of the kitchen.
	Would you attack people that have no relevance to anything?
	Is that your modus operandi?
	Objection of form.
	Not answering that question.
	Do you have any questions that pertain to your lawsuit?
	It does pertain to my lawsuit.
	In fact, the affidavit was submitted.
	and furtherance of the lawsuit.
	Paragraph 72, where I state: This vindictive malicious retaliation by Defendant Stone had a logical purpose.
	He tried to intimidate and threaten Dr. Corsi and me in order for us not to collaborate with Mueller.
	We obviously did not collaborate with Mueller, but Defendant Stone is both unstable and unhinged.
	See CDs containing videos of defamatory statements and publications.
	And apparently paranoid, and he tried to prevent collaboration at all costs in order to save his own skin.
	His conduct towards us is similar to his conduct toward Material Witness 2 and the Mueller investigation, Randy Credico.
	Who he allegedly threatened mafioso-style, in quotes, to kill.
	He even allegedly threatened to kill Credico's service dog, for which he was in part indicted.
	That, in fact, is your motive.
	Is it not for attacking Dr. Corsini?
	I'm not going to do any of that.
	It assumes facts, not in evidence, and it doesn't even make sense.
	Ask your next question, please.
	Certified. Also, Madam Corey Puert.
	At the front, list all the certified questions.
	And the questions where he was instructed not to answer, even if I didn't say certified.
	Thank you.
	You're aware that Judicial Watch filed a complaint.
	Strike that, I'll start over again.
	You are aware that Judicial Watch filed a complaint under the Freedom of Information Act, a court complaint, and before that a FOIA request to obtain documents about the raid on your house where you were arrested on January 25, 2019.
	We're not going to discuss arrest, indictment, anything.
	You are aware that they filed a complaint to get the documents from the government, the FBI, the Justice Department.
	If you're aware.
	Yes, I read that.
	Yes. And you've had discussions with people at Judicial Watch about that?
	Never spoken to anybody at Judicial Watch.
	In fact, you've contacted them to find out what documents, if any, they've gotten.
	I've never had any communications with anyone at Judicial Watch other than the one I've described previously.
	And during that discussion that you now remember, you discussed with Fitton the raid on your house?
	No, that did not come up.
	Fitton expressed sympathy for the raid on your house?
	I don't recall that.
	I think our conversation was more casual than that.
	What was your conversation?
	Hey, how you doing?
	You're doing a great job.
	Thank you very much.
	I think that was kind of it.
	We passed each other in a hallway.
	There is no other communication.
	I don't know Tom Fitt.
	Now, you're not in any way interested in what documents, if any, Judicial Watch got from the FBI, the Justice Department, and any others involved in the raid on your house on January 25, 2019?
	I don't recall that they got any.
	I thought I read that the FBI turned over nothing and they subsequently filed a suit.
	Who's been contacting with Judicial Watch in that regard on your behalf?
	No one.
	Are you saying you have no cell phone records or emails?
	Exactly what I'm saying.
	Is that what you're saying?
	Exactly what I'm saying.
	So you're saying that when I get your telephone records, they're not going to show anything like that?
	They most certainly will not.
	Your emails will not show anything like that?
	Most certainly will not.
	Because you've erased all of this, haven't you?
	Objection of form.
	It assumes facts not in evidence.
	Absolutely untrue.
	of this.
	Before your deposition today, you're aware that lawyers for Judicial Watch were in contact with your lawyers today?
	You're aware they've talked?
	I don't know that they have talked.
	Have you talked with lawyers for Judicial Watch?
	I'm not a witness today.
	Ask your next question.
	day.
	You're aware that I have a defamation judgment against judicial watch that was obtained in the Southern District of Florida on June 4th?
	June 11, 2014.
	Turn to page 28. No,
	I'm unaware of this.
	Turn to
	Page 32 of my affidavit, which is Exhibit 2 to this deposition, Larry Klayman vs.
	Everyone. This is after the clippings?
	This is 32. Look at the bottom.
	Klayman Production 32. It's called a Bates number.
	At the very bottom.
	Is this it?
	No, no.
	32? Mm-hmm.
	57. Page
	32. I don't think you're on 32. Oh, 32, I'm sorry, 37. You make it a practice to read the Washington Post as part of your work?
	No, I actually don't because they're...
	Behind a paywall, and I refuse to pay for them.
	So I rarely read the Washington Post.
	But in fact, their articles are published without being behind a paywall.
	Much later, they usually...
	A few days later.
	Yes, but I rarely...
	So you read those.
	I rarely read them.
	You get, on Google, prompts about various articles involving politics and law and things like that.
	Yeah, that would be true.
	Yeah, you read it off your phone.
	Usually. And you're aware that the Washington Post published the story Larry Klayman vs.
	Everyone in their weekend edition back in 2014, which is pages 32 through 36 of Exhibit 2 to this deposition?
	My affidavit?
	I'm unaware of that, and I've never seen this article.
	Take your time and look at it.
	I've never seen it previously.
	I was unaware of it.
	Turn to page 37. Yep.
	This is a biography that's on Freedom Watch's website.
	You've seen that before, haven't you?
	No, I can't say I have.
	You've gone to Freedom Watch's website, have you not?
	I think I get...
	Blast solicitations from you.
	I don't know if I've ever gone to the website.
	You're aware that I graduated from Duke University?
	Not aware of that.
	You're not aware that I went to Emory Law School?
	Not aware of that.
	In the course of representing me in my Senate campaign, you would not have come to know that?
	I may have then, but I don't recall it today.
	In fact, now that I read it, I'll take your word for it.
	I assume you wrote this.
	But I didn't recall it.
	In fact, when you were working with me on the Senate campaign, you actually created a website for my candidacy which had my biography on it, correct?
	That's true, but I haven't memorized your biography.
	Do you have screenshots of that website and biography?
	No. For my Senate campaign?
	I don't believe so.
	Why would I?
	In fact, you wrote the biography that was on the Senate website, correct?
	I don't recall that.
	It's certainly possible.
	And to do that, you would have had to know about my background, correct?
	or taking it from something that you had written.
	You're aware that I've sued Tom Fitton for defamation over the statement that I was ousted from Judicial Watch because of a sexual harassment complaint?
	I'm unaware of that.
	Just ask Tom Fitton.
	Objection of form.
	Turn to what I'll ask to be marked as Exhibit 3. It's already Exhibit 2, no?
	Well, Exhibit 3, the deposition.
	Oh, excuse me.
	You're right, it is Exhibit 2, the deposition.
	So turn to page 60. At the top.
	At the bottom, 60. Yes.
	Can I ask what exhibit within the affidavit that is?
	It's on page 60 of the affidavit, which is Exhibit 2 to this deposition.
	Right, but it itself is an exhibit to your affidavit, right?
	Does it have an exhibit number?
	Exhibit E. Thank you.
	Let me just double check.
	And it beats page 60. Thank you.
	check.
	Page 60 of Exhibit E to Exhibit 2 of this deposition is a complaint filed by Dr. Jerome Corsi v.
	Hugh Roger Stone, Newsmax Media Inc., Christopher Ruddy, Cassandra Fairbanks, John Cardillo, and John Bachman as defendants.
	You see that?
	Yes, I do.
	You know Christopher Ruddy, correct?
	Yes, I do.
	You know Cassandra Fairbanks, correct?
	Yes, I do.
	You know John Cardillo, correct?
	Yes, I do.
	You know John Bachman?
	Yes, I do.
	Correct. Now, how did you come to know Christopher Ruddy?
	Let's see, I've known him a long time.
	I guess I met him probably sometime around 2010, 2012.
	He is from New York.
	I think it was around the time that Donald Trump was talking about running for president in 2012.
	It may have been a little before that, but I've known him for a while.
	Did you meet him during the time that he was investigating the death of Vince Foster?
	Or did you ever talk to him during that time?
	I did not know him at that time.
	You're aware that he investigated the death?
	He wrote an excellent book.
	I've read it.
	And you are aware that he is the one who founded Newsmax?
	Yes. And what is Newsmax?
	Newsmax is a news organization that is both on cable television and digital, I think on radio, although I'm uncertain about that.
	And it purports to reach about 80 million households in the United States?
	I've heard that or read it.
	And Ruddy's the founder, correct?
	That's my understanding.
	And he's the CEO.
	I don't know his title, but I think he's the sole owner.
	I think he's the founder.
	Now, Ruddy purports to be a close friend of President Trump.
	Is that accurate?
	Objection. I don't know that he purports that at all.
	I think he's a friend of President Trump.
	Has the President ever told you that Ruddy's a friend?
	I don't recall him specifically saying that.
	Do you recall any inkling as to whether or not the President has ever made reference to Christopher Ruddy?
	I mean, I have been in both their presence, so I know they are friends, but not since he's been elected president.
	You don't know that Ruddy's a close friend?
	I wouldn't be in a position to know that.
	It is your impression that Ruddy tries to trade off of the fact that he's a close friend of the president?
	I've never said anything of the kind.
	You haven't seen articles about that?
	In the media?
	I've seen articles describing them as friends, but I believe that to be accurate.
	But not close friends?
	Again, I'm not in a position to know how close they are.
	John Cardillo, who is he?
	C-A-R-D-I-L-L-O.
	He is a commentator on Newsmax.
	How long has he been a commentator on Newsmax?
	Could not tell you.
	More than a year?
	I honestly don't know.
	Cardillo is your friend, correct?
	He is a friend of mine.
	How did you get to know Cardillo?
	I think we were introduced by a mutual friend, although I don't recall who.
	I've only known him for a couple of years.
	I was familiar with his work, just from seeing things he'd written or just watching him online, but I have not known him that long.
	A couple of years?
	Two, three years, perhaps?
	Other than being a commentator on Newsmax, what, if anything, does he do professionally?
	I do not know.
	He's a lobbyist, is he not?
	Not that I'm aware of.
	You've worked with Cardillo doing lobbying?
	I've never worked with Cardillo doing lobbying.
	If he's a lobbyist, I'm unaware of it.
	Okay. Cassandra Fairbanks.
	Yes. You know her, correct?
	I do.
	How did you come to know her?
	She was introduced to me by Jack Posobiec.
	How's that spelled?
	P-O-S-O-B-I-E-C.
	Who's Jack Posovic?
	He is a commentator for OAN, Online American News.
	And what was the context that Mr. Posovic introduced you to?
	They are friends.
	I think she was...
	I forget where she was working at the time.
	She was not at the Gateway Pundit.
	I don't recall where she was working.
	Just their close friends.
	So we were introduced sometime during the Trump campaign, I think.
	Where were you introduced?
	Don't recall.
	In New York?
	No, definitely not.
	Where does she reside?
	Don't know.
	You're aware that she claims to have a close relationship with Julian Assange, A-S-S-A-N-G-E.
	I have read that.
	You're aware that she claims to have visited Julian Assange?
	I have read that.
	You're aware that she knows Dr. Jerome Corsi?
	I understand she was on television with him, but I don't know what the extent of their relationship is.
	When was she on television with him?
	Couldn't tell you.
	Sometime in the last year.
	You have spoken with Cassandra Fairbanks, have you not?
	I have spoken to her, certainly.
	And you've spoken to her about Dr. Corsi?
	Name never came up.
	And you've spoken to Cassandra Fairbanks about me?
	Her name has never come up that I recall.
	You've spoken to Christopher Ruddy about me, have you not?
	We had one exchange, I believe, about the ridiculousness of one of your lawsuits.
	But beyond that, no, not really.
	Was it this lawsuit that was discussed?
	No. What other lawsuit was this?
	This is the one, the tortious interference lawsuit, I believe.
	I was unaware that you had a contract with them.
	Christopher Ruddy called you?
	No. You had a discussion in person at Newsmax headquarters?
	No. What was the context?
	I believe we turned that communication over.
	I told him that you had filed a lawsuit, and I believe he responded, but I don't recall you ever discussing this with me.
	And I said I didn't, because I didn't.
	Well, if the case was against Newsmax, well, strike that.
	It wasn't against you at the time, it was just against Newsmax, right?
	No, I think I'd just been served.
	I'd just been served at some event.
	You're aware that there's a separate suit just against Newsmax, correct?
	I just became aware of that today.
	You attempted to evade service of process on the cases that were served on you?
	Most certainly did not.
	In fact, I had to have you serve at a strip club, did I not?
	You attempted to have me serve at a strip club, but I don't think you were successful, but I've accepted service at home.
	And in public events for all of your suits.
	Now, the conversation that you had with Ruddy, tell us what was said.
	Never had a conversation.
	We had an exchange, which you have a copy of.
	Now, in the course of the last two years, you have gone over to Newsmax's headquarters in Boca Raton.
	Rarely, but occasionally.
	Before that, Palm Beach, right?
	Rarely, but occasionally.
	During that time period.
	You have seen Christopher Ruddy?
	Yes, sometimes.
	He's not always there.
	And you had conversations with him, correct?
	Certainly, if I was there, I had a conversation with him.
	Right. And you discussed the Mueller investigation with him?
	No. He declined to discuss that other than saying he wished me well.
	So what did you discuss with him?
	I don't recall any specific discussion.
	Generally, how are you doing?
	I'm fine.
	Nothing significant.
	He's been a friend of some well-standing.
	Regardless of being significant, what did you discuss?
	I don't recall.
	Have you ever asked Christopher Ruddy to make you a paid contributor to Newsmax?
	I have not.
	You have discussed Larry Klayman with Christopher Ruddy.
	I have never discussed Larry Klayman.
	You have discussed Dr. Corsi.
	I never discussed Jerry Corsi with Christopher Ruddy.
	Did Christopher Ruddy tell you that I put him on notice?
	And John Cardillo and John Bachman to retain any and all communications with you in writing or otherwise?
	No. I'm not aware of that.
	He has declined to discuss any of these lawsuits with me in any way, saying he would only speak through his attorneys.
	You're aware that destroying evidence that is relevant to a lawsuit or which may lead to relevant evidence can constitute obstruction of justice?
	Argumentative. We understand the oath.
	Next question.
	Ruddy ever discussed with you the documentation he has on communications with you concerning Larry Klayman and /or Jerry Corsi?
	No. Have Corsi's lawyers communicated with your lawyers over the lawsuits against you and Newsmax and Ruddy and Fairbanks, Cardillo and Bachman?
	Not that I'm aware of, but I don't know.
	Who's John Bachman?
	He's the one I know the least on this list.
	He is a talking head at, you know, an analyst at Newsmax.
	Have you ever appeared on his show?
	One time.
	When was that?
	Don't recall the exact date.
	And what was the subject?
	Don't recall the subject.
	Have you ever appeared on Cardillo's show?
	Yes. And what were the subjects discussed then, and when?
	Fairly recently, regarding the Democratic primaries and the Democratic contest for a president and impeachment subjects that I'm allowed to speak about.
	You have appeared on Cardillo's show in the past and talked about special counsel Robert Mueller?
	I don't recall whether I had, but if so, it would have been prior to the gag order, obviously.
	It has been alleged that you violated the gag order on a number of occasions.
	We're not talking about any gag order.
	I'll just ask you whether it's alleged, not whether you did it.
	You know it's alleged because there are court records.
	Yeah, go ahead.

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