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Feb. 18, 2020 - Depositions & Trials
01:56:50
Roger Stone Video Deposition in Corsi/Klayman Defamation Suits, Day 1 (Part 2 of 3)
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Time Text
Back on record at 1150.
The end of the day is a good day.
The end of the day is a good day.
With regard to Ms. Fairbanks, You've had discussions with her about Dr. Jerome Corsi, have you not?
I don't recall any specific conversation with her about Dr. Corsi.
You just can't recall a specific one?
I can't recall any conversation with her regarding Dr. Corsi.
Are you aware that the Clintons used to say we have no specific recollection?
No, but it's not a bad turn of phrase.
In this case, that would be the case.
That would mean that you might have some recollection, but you just don't remember now.
No, I don't recall ever having any conversation with Cassandra Fairbanks regarding Dr. Corsi.
Are you aware there are photos of Cassandra Fairbanks on the Internet?
I would think so.
Isn't she a columnist?
Are you aware that there are photos of her in other contexts on the Internet?
No. I'm trying to be polite.
No, I'm not.
Now, you had an interest in Cassandra Fairbanks because she had had contact with Julian Assange, correct?
I don't know that we've ever discussed that other than the fact that she has a concern for his well-being.
And she visited him in the embassy in London?
I've read that.
Ecuadorian embassy?
I've read that.
Are you aware that she told Dr. Corsi that she actually slept with him in the embassy?
I saw where Dr. Corsi alleged that, but I don't know to be true.
Where did you see that?
Read it somewhere.
She told you that, right?
No, she did not tell me that.
You put her up to defame Dr. Corsio Newsman.
I most certainly did not.
Do you have any evidence of that?
You are aware that there came a point in time when I appeared on Newsmax with John Cardillo, correct?
Not specifically.
I understand that you have, but I don't recall ever seeing one of your interviews.
Turn to paragraph 16. That's page 63 of Exhibit 2. On or about January 30th, this is the paragraph of the complaint against you and Newsmax and Cardillo and Fairbanks and company.
On or about January 30th, 2019, plaintiff claimant appeared on Newsmax with host Defendant Cardillo on America Talks Live.
That's Cardillo's show, correct?
Yes, I believe so.
Along with Defendant Fairbanks, who was a friend of Defendant Stone, Defendant Cardillo, and Julian Assange of WikiLeaks.
The Newsmax video is incorporated here by reference.
You are aware that I appeared on or about January 30, 2019 with John Cardillo and Cassandra Fairbanks?
No, I was not aware of that.
You've seen this complaint before.
I handed it over to my lawyers.
I must tell you I didn't study it in detail.
You know what's alleged in this complaint?
Defamation, as I understand it.
What is the defamation that's alleged?
I couldn't tell you specifically.
So when your lawyers answered the complaint, they made up the response on their own?
No. That's not an appropriate question to ask.
It's a work product.
Apparently he had no input into the answer you filed where you're denying things.
Well, I read the complaint.
I did not memorize the complaint.
There's so many of them, it's actually kind of hard to keep them separate in my mind.
I have had a few other things on my mind.
Do you have a specific question about this appearance?
Because I don't think I saw it.
Paragraph 17. So I take it you never actually saw the answer that was filed in this case on your behalf?
I did see it.
I read it very quickly.
Defendant Fairbanks at the direction of it in concert with others.
I don't know that to be true.
Certainly not me.
I'm not asking that question.
I'm not asking that question.
I noticed.
I'm just asking whether or not you were aware that I appeared with Cardillo and Fairbanks.
I was not, and I haven't seen this interview.
Thank you.
Turn to page 64. At 3.45 in the Newsmax video, Defendant Fairbanks says, quote, There are so many things that Jerome Corsi has blatantly lied about.
I confronted him last April in person about the fact that he was reporting false things about WikiLeaks, and he was using my reporting that he plagiarized in order to do so.
The fact that anyone is taking him seriously at all is making me completely just.
It makes me laugh.
It's ridiculous.
You see that?
I do.
Are you aware that Cassandra Fairbanks made these statements about Dr. Corsi?
Not specifically.
I never saw this interview.
I understood that they had clashed on the air.
Do you agree with what Cassandra Fairbanks says here about Dr. Corsi?
Cassandra Fairbanks is responsible for her statements.
I am not.
I don't know whether that's accurate or not regarding...
Plagiarizing his work, I have no idea.
Is it your view that Dr. Corsi's a serial liar?
I have no opinion on that one way or another.
Is it your view that Dr. Corsi plagiarized Cassandra Fairbank's work?
I have no opinion on that.
I have no way of knowing.
In fact, Dr. Corsi has actually ghostwritten books for you, has he not?
He's an excellent writer.
He's ghostwritten books for you, correct?
He worked out one of my books, yes.
What book was that?
Mickey the President.
He's an excellent writer.
Paragraph 20. At 6.05 in the Newsmax video, defendant Fairbanks said, quote, everything that Dr. Corsi said was completely absurd.
I mean, we're talking about someone who had no even basic understanding of how WikiLeaks works.
Yes, what about it?
Do you agree with Senator Fairbanks?
I don't have enough knowledge to know.
I didn't see this interview.
I don't know what she's specifically referring to.
Paragraph 21. At age 45 in the Newsmax video, a defendant of Fairbank said, Dr. Corsi raised money for a cancer patient with some false claims for someone who didn't even exist.
Please, he has no credibility.
Jerome Corsi has never even met the truth.
Go look at his reporting.
It's a mess.
It's outrageous that anyone, let alone Mueller, would take him seriously.
This is a clown show.
You see that?
I do.
Now you're the one who fed that statement to
That is entirely false.
In fact, what Ms. Fairbanks is referring to is the publication of an article by Chuck Ross of Daily Caller, which was owned by and may still be owned by Tucker Carlson of Fox News,
that accused him of committing a fraud with a doctor in South Florida.
I don't know that.
You are aware of the allegation by Chuck Ross?
I'm aware of that a story was written.
I presume Cassandra Fairbanks can read, but beyond that I couldn't comment.
And you fed that story to Cassandra Fairbanks?
Most certainly did not.
You're aware that a lawyer that was representing that doctor you're friends with?
Who? I'm allowed to ask the question.
Please do not interfere.
What doctor, first of all?
Well, we'll get to that.
I'm asking you a general question right now.
You have to identify the doctor before I can tell you whether I knew a lawyer who represented you.
You have had contact with a lawyer who represented this doctor in Florida.
Of course, he was raising money.
I don't know what doctor you're referring to.
Does this doctor have a name?
All right, we'll get back to it.
I'll just ask you right now.
I can't answer the question before I know who the doctor is.
Turn to the following page, 65. Yep.
These are email, these are tweets by Defendant Cardillo.
Yes. And you've seen these before.
Let me read them and I'll tell you.
I
I don't recall them specifically, but I'll take your word for it.
Let's break at this point.
That's a good break point for lunch.
We'll come back at 1 o'clock.
Back on record at 1 o'clock.
Turning to page 66 of...
Exhibit 2 to your deposition.
Paragraph 26. Mr. Klayman, as is Dr. Corsi, is a strong supporter of the President, but has publicly criticized him for his association with Defendant Stone and past association with the likes of his former and criminally-minded personal legal counsel,
Michael Cohen, and another of Defendant's Associates, Paul Manafort, who himself has been convicted of crimes.
You are aware that I've been critical of the President's association with you.
And these other people?
Actually, I'm not.
You have talked to the president about me, have you not?
I have not.
You've told the president not to have anything to do with me, correct?
I have never said anything of the kind.
You've told people in the White House not to have anything to do with me, correct?
I've never done anything of the kind.
Turning to page 70 of Exhibit 2, this is a complaint, Dr. Jerome Corsi v.
Rogers Stone in the US District Court for the District of Columbia, which I previously identified, filed on February
7, 2019.
Now, during the time that you were under a gag order, you used surrogates, so to speak, to get out information that you wanted to disclose to the media and to the public.
Objection, and we're not talking about any implications of the gag order.
This case has been pending for over a year on a motion to dismiss, so I don't know what the situation is in the District of Columbia.
Well, it's part of the...
The order for consolidated discovery, regardless of whether it's a motion to dismiss, it moves forward.
I think we're new.
We're going to have to come back on other days.
No, you're not going to get to decide for the court what to do.
There's no motion to stay discovery.
There's nothing that matters.
Well, you haven't done anything in a year, and the court hasn't done anything in a year.
I don't have to do anything.
I don't have to do anything.
We're not discussing any gag orders.
Well, you're going to be sanctioned, Mr. Buchel.
All right, I'm going to move for sanctions against you personally.
Okay, because you're obstructing process here.
You can continue with your deposition.
I'm going to ask questions about Dr. Corsi.
You have filed no motion for protective order.
You filed nothing.
And even if you did until it's ruled upon, it's of no force in effect.
Well, we had agreements on this case.
It just didn't work out.
We have an order in this case.
There's no agreements, and you've lied before to the court, and you're lying again.
I'm not going to put up with it anymore.
Well, I take exception to your characterization.
You also lied to the special counsel.
You're lucky you weren't indicted.
I mean, to Congress.
Listen, settle down.
Ask your next question.
I sat there at the trial.
I saw the letters you wrote.
Sir, I'm not a witness in this case.
That's fine.
That's why you were so patting them on the back.
You were happy they didn't indict you.
Okay. I have no idea what you're talking about, but please ask your next question.
You have been involved in defamation lawsuits before, have you not, Mr. Stone?
Yes. What lawsuits have you been involved in?
I settled a suit with a gentleman named Miles Kwok over a year ago, I guess.
That's the only one I recall at this moment.
What was that case about?
He said that I had said some inaccurate things about him on Infowars.
I had relied on a research from Sam Nunberg, which turned out to be incorrect.
I issued an apology.
He dropped the suit.
You've paid him money, did you not, in that settlement?
No, I did not.
He dismissed the suit?
The suit's been dismissed.
I believe it's subject to confidentiality.
Confidential settlement agreement?
I believe so, yes.
The plaintiff didn't pay you money, did he?
No. Now, on or about January 18th, 2019, the same time you were allegedly defaming me, you were also in Infowars talking about Dr. Jerome Corsi,
correct? I'm uncertain of that date.
I turn to page 5. That's Claiming Production 74. Which section?
Paragraph 17, 18, 19. Does that refresh your recollection?
Yes, it does.
Okay. So you were on Infowars on that day talking about both me and about Corsi, correct?
If you say so.
I don't recall the specific date, but assuming the information here is correct.
Okay. At 2.09, two minutes and nine, two hours and two minutes and nine seconds.
Into that video on InfoWars, you stated that Corsi was fired from World Net Daily, correct?
Yes, I think that's what he told me.
But you had no independent knowledge of being fired from World Net Daily?
That is correct.
So you're claiming Corsi told you that?
I believe so, yes.
At 2.27 in the InfoWars video, Stone falsely and misleadingly publishes that.
This is in the paragraph 18. He, of course, he was perfectly willing to lie, to perjure himself, saying that a memo he had wrote me was written on the 30th for the purposes of cover-up, which is further proof that Jerry lied under oath.
What proof do you have that Jerry lied under oath?
Substantial, because everything in that paragraph I said is accurate and true, and I could prove it if I needed to.
Have you had access to the grand jury transcripts with regard to Dr. Jerome Corsi?
My attorneys certainly have.
But you have not, correct?
I have.
I've reviewed all of the discovery material that was relevant.
You didn't review what Dr. Corsi had testified to?
I think I did read his testimony, actually.
I would be entitled to it under discovery, of course.
You're not sure whether you read it or not?
I believe I did read it.
Dr. Corsi was not charged with perjury as you were.
By the special counsel, correct?
Objection of form, correct?
Not that I'm aware of.
So consequently, you have no proof that he lied?
Oh, actually, I do.
Are you suggesting that the special counsel engage in selective prosecution with regard to you and Jerry Coursey?
Objection of form, if you want to answer your opinion.
We filed such a motion.
It was denied, but I think it was correct.
And in fact, that was your motive in defaming Corsi, was it not, because he thought he was testifying against you?
Well, he did say those things publicly, and they are incorrect.
At 255, this is paragraph 19 in the Infowars video, defendant falsely and misleadingly publishes, quote, and then states that I knew about John Podesta's emails being stolen in advance.
The only proof of that is Jerry's feeble alcohol-affected memory.
It's a lie.
Where did you...
All accurate.
Completely accurate.
And where do you take that information?
Because he said it repeatedly in public.
And actually, on Tucker Carlson, he said, I told many people.
With Ari Melber, he said he told many people, including me.
He actually never told me anything in the kind, verbally or in writing, anywhere.
Feeble alcohol-affected memory.
You're, in fact, stating that Dr. Corsi is an alcoholic.
I can only assume that this memory had to be caused by something because it was inaccurate.
But you didn't know whether he made the statement of the influence of alcohol, did you?
No, but I've certainly had drinks with him.
Again, Dr. Corsi was not indicted, and you were.
What's the point of that?
Objection of form.
In this context.
Is that accurate?
Yes, that's accurate.
Paragraph 20. At 355 in the Infowars video, Defendant Stone falsely and misleadingly publishes that, quote, Jerry was prepared to stab a principal Trump supporter in the back.
He was perfectly prepared to bear false witness against me, even though I had done nothing in my entire life other than to help him.
Entirely accurate.
Did Dr. Corsi ever make that stabbed you in the back?
The previous one that you just stated, for example, regarding a memo that he incorrectly said that he wrote to give me a cover story at a time that I needed no cover story because the controversy regarding John Podesta's emails,
which was never mentioned in the indictment whatsoever, would not happen until six weeks after he had written said memo.
So it's patently false.
But you were not indicted by the special counsel for a cover story.
You were indicted because you testified falsely to Congress, correct?
Let's not get into the indictments and the whole trial thing.
He answered your question.
I only ask the question a different way.
There's no aspect of your indictment that deals with a cover story by Dr. Corsi on your behalf.
It calls for a legal opinion.
No, but he certainly said that in numerous interviews and in public, so I certainly have the right to respond to it.
It's not true.
At 420, in paragraph 21, at 420 in the Infowars video, Defendant Stone falsely and misleadingly publishes that quote, all I ever did was show Jerry Corsi friendship and support and try to help him.
And his family.
And what I get is Judas Iscariot.
Iscariot. Iscariot.
I-S-C-A-R-I-O-T.
The willingness to testify against me and help the deep state bury me.
And then he makes up this story about helping me formulate a cover story.
That's your statement, is it not?
It is.
That's exactly how I felt at the time.
I did get Jerry Corsi.
I did recommend him for his position at Infowars.
I also sent him freelance work.
He's an excellent writer.
He's an excellent researcher.
I had affection for him until he went out and said things that were not true.
And when he said things that you claim are not true, such as what I just read, that's when you decided to defame him and me publicly.
That's a conjecture on your part.
I have every right to correct the record when somebody says something incorrectly in public, as do you.
But you went way beyond correcting the record.
No, I don't think so.
Saying that I had an IQ less than 70 is beyond correcting record.
Oh boy, that really got to you, didn't it?
Objection. Larry, take the heat if you want to be in the kitchen.
Oh, I can take heat.
You're a public figure.
That's why I'm sitting here with you, Roger.
I can take heat.
I'm not so sure.
That was in our previous question.
Do you want to keep going back to it?
You know I can take heat.
The question is your false statements.
You also made a statement, I never won a case.
Correct? Yes, I did say that.
We've already covered that.
What does that have to do with Jerry Corsi?
Being a Judas.
Has nothing to do with this.
I don't know why you're bringing it up.
I don't see how it's related to any of this.
You wanted to harm not just Corsi, but you also wanted to harm his lawyer and discredit him.
That's conjecture on your part.
You felt that would give you an advantage with Mueller.
Maybe you wouldn't be indicted.
That's conjecture on your part.
You were trying to cast the blame on Corsi so you wouldn't be indicted.
wild allegations on your part.
Paragraph 22, it's 626 in the InfoWars video.
Defendant Stone falsely publishes that, quote, you can always tell when Jerry Corsi is lying because his lips are moving, unquote.
See that?
Yes, definitely.
You said that, correct?
Definitely, because he was lying, as we had just said on the previous minute.
Well, this goes beyond what you claim was a specific lie, that he lies any time that he says anything, correct?
Well, I think he told multiple lies, to tell you the truth, but yes, I definitely said that.
You're calling him a total liar.
I think he lied on some occasions here, yes.
But this goes beyond just some occasions, right?
Anytime his lips are moving, he's lying, correct?
That's what I said, yeah.
In fact, that's an expression that's frequently used with regard to lawyers, isn't it?
How do you tell a lawyer's lying as lips are moving?
I've never heard it in that context.
So you're also referring to me, weren't you, in this statement?
Wild conjecture on your part.
I'm his lawyer.
Wild conjecture on your part.
Where's the word lawyer?
And you're suggesting I help him lie, correct?
Where does it say that?
That's a phrase that's used with lawyers.
But where does it say that?
It doesn't say that.
You're putting words in my mind.
You're not that clever.
Do some research on defamation by implication.
Good luck.
Apparently you've done a lot of research but won't testify truthfully.
Good luck.
Listen. Stop.
You've got to stop with your commentary, sir.
Ask your next question.
Make a commentary towards me.
You asked for it.
23. Yep.
You made these false and misleading statements knowing that they were false.
Or at a minimum with reckless disregard for their truth.
Incorrect. Objection calls for a legal conclusion.
Incorrect. Now it calls for a factual statement.
I believe everything in that paragraph to be true.
Paragraph 24. On January 2, 2019, Defendant Stone published an article on www.infowars.com titled Roger Stone Believes Jerome Corsi Works for Mueller.
In which Defendant Stone falsely, misleadingly, maliciously writes, quote, That's exactly what I believed at the time,
based on his false comments.
But what information do you have that Dr. Sean Corsi worked for Robert Mueller?
Well, I've read his book, first of all.
Which is rife with things that are incorrect.
But secondarily, we go back once again to the question of the memo that he claims was written as a cover story, which is chronologically impossible as well as illogical and false.
Did Dr. Corsi defame you?
I think he did.
You threatened to sue me, didn't you?
You said, Larry claiming, bring it on.
I welcome your suit.
I don't remember saying that.
Objection of form.
That's you suing them.
I don't recall that.
So, why didn't you sue Corsi if he defamed you?
I actually considered it.
And what caused you not to do it?
Events. Events.
In fact, the reason was because he wasn't lying.
Conjecture on your part.
False. In fact, you don't like to be in a court of law.
You'd rather destroy people outside of a court of law.
Objection. Personal attack.
This is argumentative.
Ridiculous. Yeah.
If you have questions, ask them.
That's your modus operandi, the dirty trickster, right?
That's a personal attack on me.
It's not a question.
If you have questions, ask them.
You don't like to be seen in public, do you?
I don't like to be seen in public.
In fact, when you were handling my campaign, you said you didn't really want to be visible.
You didn't want to be known that you were assisting me.
Correct? I think the candidate should get the attention in a given campaign, yes.
The reason is because of your reputation, correct?
That's a personal attack.
may not question.
Paragraph 26. In another appearance on InfoWars, which was posted to YouTube on January 17, 2019, Defendant Stone at 622 falsely and misleadingly publishes that he, Corsi, Was perfectly willing to bear false witness against me on multiple points that are complete fabrications.
That's your statement, is it not?
Yes, it is.
It's exactly what I believed at the time I said it.
And again, you were trying to implicate Corsi to get the special counsel to indict him and not you.
No, that's conjecture on your part.
I was just trying to correct the public record.
So, in fact, you were the Judas.
That's a personal attack.
It's not a question.
Do you have a question?
Well, I'm asking you, under your definition of being a Judas, Iscariot, or whatever the heck it is.
Iscariot. Okay, good.
If you've ever read the Bible, you'd know that.
I didn't know the word Iscariot.
I will definitely agree to that.
Old Testament, too.
Now, you recently found religion, right?
Objection. This is not relevant.
Right before you went to a strip club, you declared you found religion.
These are personal attacks.
I'm not going to stand for them much longer.
If you have a question, ask the question.
Well, you're mocking my knowledge of religion.
I just told you that it's a pretty broadly known term.
And yes, I do believe in Jesus Christ, and he is my personal savior.
Yes, I believe in that too.
Good. Paragraph 27. In another appearance in InfoWars, which was posted to YouTube on January 24th, Defendant Stone at 558 Fossley, and misleadingly publishes the quote, The good doctor, of course, he has told a number of lies.
In fact, he's starting to conflate his lies.
He was perfectly willing to lie about me, but now lying about Alex Jones, lying about Infowars, lying about Dr. Jones.
That's Charles' father, correct?
Yes. He's one of the nicest, gentlest, sweetest, most honest men I've ever met.
It's beyond the pale.
Jerry Corsi can no longer be believed.
You said that, correct?
Yes, I did.
And in fact, this is exactly why you recruited Cassandra Fairbanks to go on.
Categorically false.
And for which you have no evidence whatsoever.
Wild conjecture on your part.
In fact, that statement is markedly similar to what Cassandra Fairbanks said on Infowars.
Then that might be, if that's true, just because you say it doesn't make it true, that would be a coincidence.
Since I never instructed Cassandra Fairbanks to do anything.
And in fact, you worked with your friend.
John Cardillo to set me up to go on Infowars to have Cassandra Fairbanks appear and defame my client.
I'd say that earlier you called me paranoid, I'd say you're the one that's paranoid because that is entirely false.
Does 2 and 2 equal 4, Mr. Stone?
As far as I know, it does.
Do bears live in the woods?
Do you have any proof?
Evidence? Real evidence?
Not just wild conjecture, evidence.
It's called circumstantial evidence.
You don't even have circumstantial evidence.
You have a recording.
You have some proof that I spoke to Cassandra Fairbanks about this?
You have nothing.
In fact, most of your complaints have nothing.
They're just wild conjecture.
Everything about you is conjecture, right?
No, everything about you is conjecture.
It's your reputation.
You sue at the drop of a hat, but where's your evidence?
Was that your defense in your criminal prosecution?
We're not discussing that, and you know it.
Paragraph 28. In the same appearance, defendant Stone at 834 falsely and misleadingly publishes that quote.
I think you, of course, have been deep state from the beginning.
Your whole Bertha thing is used as a club to destroy conservatives.
I look forward to our confrontation.
I will demolish you.
You are a fraudster.
Out of your alcoholic haze, you have made up lies about David Jones and Alex Jones and Roger Stone, and now I suspect that you want to lie about the president.
You were threatening, Dr. Corsi.
That is incorrect.
Dr. Corsi said that he was kept on the payroll to buy his silence, I believe.
That is...
Absolutely, totally false.
In fact, I didn't even know when he came and went on the InfoWars payroll.
So that would be a false statement.
And it would certainly be one that involved those other individuals, Alex Jones and his father.
This is a statement that you made, is it not?
On InfoWars?
If you say so, I don't specifically recall it.
Again, you're calling him an alcoholic, correct?
I've drank with him.
You have no evidence he's an alcoholic.
I have some personal experience where I've seen him carried out of a restaurant, stoned drunk, yeah.
That doesn't mean that you're an alcoholic, that you were drunk on an occasion.
I've seen him drunk on more than one occasion.
Are you medically capable of making a determination?
I can certainly tell when somebody's inebriated.
You've seen Dr. Corsi many times.
When you don't claim he was inebriated.
Correct. I have.
I liked your, of course, at least I did until he started bearing false witness against me.
Are you saying that if I go out on Google, I will find no reference that you supported the principle, or at least the proposition, that Barack Obama had a false birth certificate made?
I don't think you will.
I think what you will find is a quote where I said that I thought that a substantial number of Republicans, probably a majority, believe that.
That the issue, therefore, had currency within the Republican Party.
And I think it's the reason that in 2012, after Donald Trump raised this issue publicly, he briefly jumped ahead of Mitt Romney in the Gallup poll.
But that was an analysis of the issue.
I've read excellent work on it.
I've seen a video on it.
There's something odd about...
The fact that that president didn't immediately produce his papers, but I'm not an expert on the subject.
I don't think I've ever put forward an opinion.
Now, you've been an advisor to President Trump for many years, correct?
Sometimes, yes.
And you've given him advice in politics?
I have.
And you urged him to run for the presidency?
Yes, I have.
And you had input with him up to the point that he announced his presidency in Trump Tower?
Yes, I did.
And you had input with him later, too, correct?
Some, yes.
In fact, you spoke with him later, even with regard to WikiLeaks, correct?
No, I've never spoken to him about WikiLeaks.
There were calls being placed during the period that you were under investigation by Congress to him, correct?
That came up during your trial.
Yes, indeed, but none of them regard WikiLeaks.
There was no evidence of that presented at trial.
An assertion by the government that does not make it true.
Because those communications occurred on WhatsApp, correct?
No, I don't use WhatsApp.
We're not getting into the trial.
The only person I know who used WhatsApp is Chris Ruddy, actually.
I don't particularly like WhatsApp.
Chris Ruddy uses WhatsApp because he doesn't want it to be subject to surveillance, correct?
I told you that.
No, he's never told me anything of the kind.
I don't know that.
Now, in the course of your advice to the president, you were the one that actually suggested to him to use the so-called birther issue to gather support among conservatives.
False. Incorrect.
If you know Donald Trump, you know that no one tells him anything, first of all.
He decides what he's going to talk about.
He decides what he thinks.
He decides where he's going to go.
He decides what he's going to do.
He's not handled or managed or scripted.
And he found this issue and found interest with the issue on his own.
I believe that he read Dr. Corsi's book, or at least thumbed through it.
And he came to this decision on his own.
I did not advise him to do so.
You need to give dates, too, please.
We're talking about 2012, or in the run-up to 2012.
No one tells Donald Trump what to think.
It just doesn't happen.
But you gave him advice.
It doesn't mean that he took all my advice.
In 2012, President Trump, now President Trump, wasn't perceived as a conservative, was he?
I think some people perceived him as a conservative, yes.
You actually advised him to move right, to position himself to run for president.
I didn't need to do that.
I think he knew where the Republican Party was.
And that was one of the issues, the so-called birther issue, that could garner support on the right.
I did say that I believed that the issue had currency on the right, and I'd seen polling that showed many Republicans believed.
There to be some question about the birth certificate.
But I didn't advocate the use of the issue.
Donald Trump decided that on his own.
In fact, you've seen the birth certificate that was posted on the Obama White House website, have you not?
At the time it came out, yeah.
You're aware that it listed his race in 1961, when he was born, as African-American.
I don't recall that.
In fact, the term African-American was not even coined until the 70s by...
Jesse Jackson, you're aware of that, correct?
I was not.
You're aware that every other birth certificate in Hawaii in and around 1961 either designated someone of African-American descent as black or negro?
What is the point of this?
The point is that you're aware that this was not a phony issue.
I don't have the expertise to say.
I always thought it was odd that the president didn't just put it to bed when it first came up by releasing the documents.
But I don't have the expertise to say, and I haven't studied the issue.
You just told me things I don't know.
I had read that there was a birth notice in a Honolulu newspaper, which would tend to debunk this, if that's even true.
I can't tell you whether that's true, because I haven't researched it.
You're also aware that many people who wanted to claim citizenship in and around that time, and even to today, put notices to try to prove that they were born in the United States.
I was not aware of that.
You've read Dr. Corsi's book yourself, have you not?
I actually have not.
So you're testifying under oath.
There's nothing you've ever said or written in support of the theory that the birth certificate is a fraud.
I have no specific memory of having said that.
I have memory of being interviewed about the power of the issue.
But yet you'll try to smear Dr. Corsi on the basis of his...
Book claiming that the birth certificate was fraudulent.
I don't believe I smeared him at all.
He takes that position.
I
You're claiming that his position, which apparently your confidant, President Trump, also took, The birth certificate of Barack Obama, he used that as a club to destroy conservatives.
I think that many conservatives have been damaged by it because of the allegation that it is based in racism, which was not the reason I thought.
I mean, Donald Trump's view was he's either constitutionally eligible or he's not.
This isn't a racial question.
But I did see how it could be viewed as a racial insult, yes.
But you're saying here, with regard to Dr. Corsi, as quoted in paragraph 28, your whole birther thing is used as a club to destroy conservatives.
I think it has been.
Well, you're saying that he did it intentionally to destroy conservatives, correct?
No, where's the word intentional?
I don't see that.
You're saying, I think you've, Corsi, been deep state from the beginning, your whole Bertha thing is used to destroy, is used as a club to destroy conservatives.
You're tying him to the deep state and saying that he wants to destroy conservatives with the Bertha thing.
Yes, I did say that.
That's what I thought.
Dr. You're aware that Dr. Corsi's
I'm just telling you that was my opinion, which I'm entitled to on the First Amendment.
You are aware that he's a New York Times bestselling author?
As am I. Correct?
I didn't ask you about you.
But I decided to say it because I get to answer the questions.
But that wasn't a question.
I am aware of that, yes.
I've read his book on the Kennedy assassination.
It tracked mine almost exactly.
It was a good book.
Do you think the CIA killed Kennedy?
I think they were among several institutions.
I don't think it's that simple.
Organized crime is involved.
Big Texas oil is involved.
I think, as Dr. Corsi does, the Vice President Lyndon Johnson is involved.
Motive means opportunity, eyewitness evidence, fingerprint evidence.
Dr. Corsi's book and his research tracks mine pretty closely.
You may be pleased to know I actually agree with you on this issue.
Good. But, are you concerned with regard to President Trump right now after having weathered impeachment?
With regard to the CIA?
I pray for the president's safety every single day.
So do I. Good.
Prayer has power.
Can we get back to the deposition?
You are aware that his books are purchased primarily by conservatives, libertarians, people of faith?
I don't really know who purchased his books.
I don't really know who purchased his books.
Or how?
But you're aware that they tend to be conservative-oriented?
Or borderline?
Yes, I would say probably.
It's the same people who buy my books.
So by claiming that he's part of the deep state, that he was working for Mueller, that he used the Bertha thing as a club to destroy conservatives, you're intentionally trying to harm him with his constituency and people that purchase his books?
And listen to him on radio and television and in print.
Conjecture on your part, just although his saying that I needed some cover story is probably meant to destroy my ability to sell books.
What's the point?
Do two wrongs make a right?
You are deciding what my intent is, but you can't know my intent.
Only I can know my intent.
My intent was to defend myself.
Well, the jury is in charge to figure out what intent is.
If you ever get that far.
You can rest assured in Florida that I will get that far.
I doubt it.
Okay. Hopefully you'll be available to the pier.
Let's see if you're admitted at the time.
Now, Mr. Stone, you
You, at this point, intensely dislike Dr. Corsi and me.
Objection of form.
That statement is only half true.
You only dislike me?
Yeah. And what epiphany have you had that you no longer dislike Corsi?
Objection of form.
Go ahead.
I actually have a deep affection for Corsi.
He's a great guy to hang out with.
He's a great guy to drink with.
He's very, very knowledgeable.
I do think that the enormous pressure they put him under caused him to say things that were not true about me, and that's unfortunate.
But I actually bear no ill will towards Jerry Corsi.
You, on the other hand, we have this proceeding, for example, as to why I feel the way I do.
Now, don't you think people need to be held accountable under our legal system?
Yes, of course, including you.
Isn't it more appropriate, in your opinion, to pursue legal action than to defame someone in public?
I'm not an attorney, so I guess I can't answer your question.
When I'm attacked, I will respond when I can.
But you don't respect the legal system, do you?
I'm not going to answer that question.
Now, given the fact you have great affection for Corsi, have you apologized to him for anything you've said in the past?
I'm not entitled.
I'm under a court order not to contact him at this time.
I'm not able to speak to him even if I wanted to.
That hasn't prevented you from breaking the gag order before, has it?
Objection. It's argumentative.
What's the point of those questions?
You posted a man with a crosshair to the head of the judge, Amy Berman Jackson, right?
Not responding to that.
you're behind, so let's ask some good questions.
I turn your attention to page 111 of Exhibit 2. Case-style, the District of Columbia, Corsi and Klayman.
Klayman's no longer a defendant.
Versus Michael Caputo and Roger Stone.
He's no longer a plaintiff?
Plaintiff. Okay.
Okay. Now, over the years, you've done a lot of work in Washington, D.C., correct?
That's correct.
And you continue to do work in Washington, D.C.?
No, I really don't.
I have no clients in Washington, D.C. I have no work in Washington, D.C. Your publications are, for instance, InfoWars are published in Washington, D.C. Well, I no longer work for InfoWars, but I guess InfoWars would have been seen in Washington, D.C. When did you actually work for InfoWars,
other than just as a non-paid consultant?
I could not tell you the date in which I joined them.
I can tell you I left them shortly after I was indicted by the special counsel.
Were you fired from InfoWars?
I was terminated.
And what was your position when you were employed by InfoWars?
I had a syndicated radio show that was simulcast on the Internet, and I had a contractual agreement to sit in for Alex Jones on Wednesdays.
In his stead.
You were being paid money by InfoWars?
That is correct.
How much were you being paid?
I don't recall.
You file income tax returns, correct?
Yes, but I don't really specifically recall.
In fact, you prepared a financial statement with regard to your sentencing and the criminal process.
I did.
And in there you had to list what you were paid by InfoWars.
I did, but I don't really recall.
Have you submitted that yet?
We're not talking about his sentencing reports and what he submitted and all that.
Those are confidential.
Do you have offshore bank accounts, Mr. Smith?
We're not answering?
Do you have offshore bank accounts?
No, I do not.
No, I do not.
Whatever. Do you keep resources in gold bars?
Objection. I wish I did.
This is not financial discovery.
You have no right to ask these questions.
So objection, ask relevant questions, please.
In fact, the statements that you made attacking Corsi and me were intended to help you raise money for your legal defense in the criminal prosecution.
Objection to form?
False. In fact, it was intended to take contributions away from Dr. Corsi and my organizations and, in fact, direct them to yourself.
False. Incorrect.
Conjecture on your part.
Wild speculation.
I was able, thankfully, to raise what I needed for my legal defense and hopefully can continue to do so.
Michael Caputo, what's his background?
What do you mean by what's his background?
How did you come to know Michael Caputo?
I met him when he was working for Jack Kemp as his press communications director, I guess he was, deputy communications director.
Then he went to work for the U.S. House of Representatives.
I think he went abroad after that.
And of course he worked for my campaign.
Yes, he did.
He's a very talented guy.
Caputo did.
Yes. You're a close friend of Caputo, correct?
We are good friends, yes.
Did Fenn and Caputo talk to the President about Dr. Corsi or me?
I have no way of knowing.
Has he met with the President?
I read that he did.
When did he meet with the President?
Several months ago.
It was pretty widely publicized.
And that was to urge the President to grant you a pardon?
I think the President specifically said that was not discussed.
What did you read?
That he had met with the President, but that my name did not come up.
But it was published that he was talking about a pardon for you.
I don't recall that.
In fact, you instructed him to meet with the president.
Actually, that's not true.
I haven't spoken to him since January 25th.
I haven't communicated in any way, spoken to him or any other form, including through third parties, since January 25th.
What was January 25th?
The day you were convicted?
The day that I was arrested.
I was given a no-contact list, which I have not violated.
He is among those on that list.
has been publicly reported.
Caputo has done work in Washington D.C., correct?
For you and for others?
As far as I know, yes.
And he continues to appear on cable news with studios in Washington D.C. You've seen that on TV, right?
Yes, I think so, although I don't know if he's doing those broadcasts remote or in the studio.
Paragraph 17, that's page 114.
Defendant Caputo has publicly called for President Trump to immediately pardon his close friend, mentor, and co-conspirator, Defendant Stone on Fox News.
That's correct, is it not?
I've actually never seen him say that, but if you say so.
He's entitled to his opinion.
You're aware that he has appeared on Fox News and urged your pardon?
I know he's been on Fox News.
I don't recall him specifically saying this, but he certainly may have.
He'd be entitled to his opinion.
And in fact, in an appearance on Tucker Carlson of Fox News, Caputo said, quote, pardon's done right now, Mr. Trump, correct?
I don't know that to be accurately true.
You're aware that immediately after your conviction in court...
Caputo, who was in the gallery, was thrown out by the marshal.
I heard something to that effect, but I didn't see it myself.
That he refused to stand when the jury was leaving the courtroom.
I heard that, but I did not see it myself.
And turned his back to them.
I heard that, but I did not see it myself.
He has the same lack of respect for the justice system.
What's the point of that question?
To attack him?
Go ahead.
Turn to page 7. That's page 117.
We're in it.
This is on March 29, 2019, paragraph 30. Caputo appeared in MSNBC with host Ari Melber.
A-R-I-M-E-L-B-E-R, family name, where he made several statements which are alleged to be defamatory.
You were aware that he was appearing on MSNBC on that date and at that time, correct?
I think there was a promotion for it, so yeah, I believe so.
In fact, you asked him to go on MSNBC, correct?
Absolutely false.
I had no contact with him in 2019 at all.
At eight minutes in the MSNBC video, this is paragraph 31, Defendant Caputo says, the Mueller team finds themselves at the, of the hallway, and they're staring at Jerry Corsi, who believes in those wild conspiracies in the world.
They end at the freak show tent.
You see that?
I do.
What Caputo says comports with your...
Opinion of Jerry Corsi's, your statement about Jerry Corsi as well.
No, I don't think I use those words at all.
I don't see any proportion, I guess it would be called.
Mr. Caputo is entitled to his view.
On the other hand, the line before that, this was done in concert with in the direction of Defendant Stone and published in this district nationally and internationally is categorically false, and there is no evidence of that because it's not true.
In fact, the special counsel and his staff has maintained that you have coordinated appearances through surrogates to promote your interests.
Objection. Do you expect him to speculate on that?
I'm just saying what they said.
That's not speculation.
Then it's not testimony from him.
They've taken that position.
Where? With Judge Amy Berman Jackson.
Okay, well, we're not answering that question.
In fact, that's one reason they asked for seven to nine years, correct?
No, we're not talking about it.
What's the point?
What's the point of that?
I'm probing him.
You're probing him?
About nothing to do with the lawsuit?
About the lack of truthfulness of his testimony.
Okay. Thank you.
Let's ask questions about the lawsuit.
Paragraph 32. When asked about his thoughts as to why Dr. Corsi was not indicted, Defendant Caputo said, quote, He is the luckiest man in the world.
I think he should buy a lottery ticket or 10. I'm surprised.
I also believe that it indicates that Corsi's gave them information that they were looking for, probably on Roger Stone.
We'll probably see him brought in as a witness in Roger Stone's trial.
Now, Caputo got that statement from you, correct?
Categorically false.
That Corsi is a Judas.
Categorically false.
You have no evidence to prove that.
It's a wild conjecture on your part.
And then at the end it says we'll probably see him brought in as a witness in Roger Stone's trial, correct?
It does say that.
Now, in fact, it was your counsel who subpoenaed Dr. Corsi to testify at your trial.
We're not talking about the trial.
Mr. Corsi didn't testify.
Are you aware that your client subpoenaed Corsi to testify at the trial?
You mean your lawyer?
Your lawyer, Mr. Buchel and Mr. Smith.
I'm not going to discuss anything pertaining to the trial.
You were not aware that Corsi had been subpoenaed by them?
I'm not going to discuss anything pertaining to the criminal trial.
So if Corsi was a liar, your counsel would not have subpoenaed him to give false testimony in your criminal prosecution.
Speculation, objection to form.
Caputo said that, right?
I'm asking independently.
Don't interrupt, please.
You've got to cross-exam.
I'm not going to respond to questions regarding my criminal trial.
Are you aware that during your criminal trial, which I attended as an observer for Dr. Corsi, that Caputo on several occasions cursed at me in the hallway in front of the media?
I have no knowledge of that.
Want to take a five minute break?
Yeah, let's take a five minute break.
Back on record at 2:05.
Mr. Stone, you're aware that President Trump himself has praised Dr. Corsi during the course of the Russian collusion investigation?
I don't recall that.
You are aware that Dr. Corsi refused, when presented with a guilty plea, to take that guilty plea with Robert Mueller?
I read that in his book, yes.
And you're aware that he had stated at the time that he would not lie under oath to implicate the President?
I read that in his book, yes.
And it was in that context that the President praised Dr. Corsi's courage?
I don't recall that specifically.
Now, the President never criticized Dr. Corsi vis-a-vis you that you are aware of, correct?
I'm not sure I understand your question.
In other words, he's never been critical of Dr. Corsi making the same claims that you have that Corsi was a Judas.
I don't think he...
I'm unaware of any of him doing so, no.
I'll show you what...
I'm going to get back to Exhibit 2, but let's mark this as Exhibit 3 for right now.
Did you provide this as part of your discovery response?
No, because Dr. Corsi just found it today and gave it to me.
It's available on the internet.
Did we get that?
Do we want to have that conversation again?
Did you provide this Exhibit 3 in discovery?
No, because it wasn't called for, and Dr. Corsi just found it today.
He just sent it to me, and it deals with him, not with Roger Stone.
I believe I had a discovery request saying all documents you plan to rely upon.
That's right.
Well, I'll tell you something.
This was out on the Internet.
I didn't have possession of it, neither did Dr. Corsi.
you found it this morning.
Take your time to review that.
So Exhibit 3 is an article entitled It's Cool and Normal That the President Endorsed an Infamous Conspiracy Author Who's Promoting a Cancer Quote-Unquote Miracle.
It's dated December 18, 2018.
By Ben Mathis Lilly.
Mr. Snow, do you know Ben Mathis Lilly?
I do not.
Do you know of him?
I do not.
This appears to be a leftist publication, does it not?
Objection of form.
He's expert at these things.
So far, I can't tell.
But I'm only about halfway through it.
So. So.
So.
Have you ever heard of an Andrew Strickler?
Can we let him read it first?
I'm almost done.
Last page.
Oh no, I'll take it back.
Two more pages.
Okay. Thank you.
I show you this only because, to refresh your recollection, with regard to the President praising Dr. Corsi.
This is written, obviously, by someone on the left.
And does this refresh your recollection that President Trump...
Objection of form and assumptions.
Where where I'm sorry?
I see.
Okay. Well, I had not seen this previously.
Does that refresh your recollection that the president...
Well, it doesn't tell me what he actually said.
It just appears to be a hyperlink.
But for what it's worth, yeah.
Now, I asked you a question earlier about this doctor in Florida.
I didn't remember his name at the time.
The Daily Caller reporter Chuck Ross, who works for Tucker Carlson, wrote about accusing corset fraud.
The doctor's name is Mendelsohn.
Do you know Dr. Mendelsohn?
I do not.
Have you ever heard of him?
I think I read the story when it was written.
Now the lawyer, and there's also somebody mentioned here by the name of Tommy Sickler, who is somehow associated with Dr. Mendelsohn.
Do you see that?
I do.
You know Tommy Sickler?
I do not.
Now the lawyer who represented Tommy Sickler.
You know him, do you not?
Who is it?
I'm not certain.
Do I?
Yes. Okay.
Well, I don't know Tommy Sickler, so...
I mean, I know a lot of lawyers.
If you name a lawyer, I'll tell you whether I know him.
Well, I'll go back and find my notes this evening, but I'll ask you questions about that tomorrow.
I mean, that's fine.
I don't know Tommy Sickler.
You are aware that a lawyer was in contact with me with regard to this matter with Mendelssohn and Sickler.
Whose lawyer?
I'm going to get the name.
No, I am not.
And you are aware that he claimed to be your friend.
I don't know who he is.
It's conceivable, but you've got to give me a name.
My question is, this story about...
Dr. Corsi claiming he committed a fraud with Dr. Lee Mendelsohn and Tommy Sickler.
That was something that you encouraged Chuck Ross to write, correct?
Categorically false.
You talked to him about it, correct?
Categorically false.
You talked to Tucker Carlson about it.
Categorically false.
Do you have any proof of that whatsoever?
Any evidence other than wild conjecture, supposition?
Well, you can tell your friend, Tucker Carlson, that he will be deposed at some point.
And Ross.
I'm sure if they are, they'll answer honestly.
I'm sure they're going to
go ahead and get it.
I'm sure they're going to go ahead and
get it.
Do you know or ever had contact with someone by the name of Mark Randazza, R-A-N-D-A-Z-Z-A, an attorney for InfoWars?
Can you give us a page number?
Page number 200 of Exhibit 2. Let's look it up.
I know who he is.
I don't think I've ever met him.
I may have been on air with him where he was remote.
I don't think we've ever met.
And what were you on air with him about?
InfoWars. I don't recall.
What page?
200. 200.
Okay. Were you ever in contact with him or anybody with his law firm Randazza Legal Group with regard to alleged defamation against Dr. Corsi that you allegedly had done on InfoWars?
No. Why were you fired by Infowars?
There was no way I could continue to speak.
I was entirely consumed with my defense.
But you have been on television and radio on issues other than with regard to your criminal prosecution.
Very occasionally.
You can certainly speak about a lot of other things other than that, right?
Very occasionally, but there was not a chance that I was going to continue at Infowars because there wouldn't be enough material.
You were fired from Infowars because of...
What you said on InfoWars concerning Dr. Corsi and me?
No, that's categorically false.
Because you exposed them to a defamation lawsuit?
Categorically false.
If that's so, no one ever told me that.
Persons from InfoWars, Alex Jones, Owen Stroyer, etc., have discussed the defamation lawsuits that were filed by Dr. Corsi and me against InfoWars, correct?
Discussed with whom?
You. No, other than that they were sued.
Did they show you a copy of the complaint?
They did not.
And what specifically did you discuss about the suit?
I think they were sued around the same time that I was.
That's about it.
And what specifically did you discuss with them?
Oh, I've been sued.
That's it?
That's it.
Nothing else?
Nothing else.
Did you put them in contact with your lawyers, Mr. Buchel or Mr. Smith?
No, I don't think so.
I'm sure you must have had some reaction to them being sued.
What was it?
This was a nuisance lawsuit.
More defamatory statements against Corsi and me?
It's your opinion.
More negative statements against Corsi.
There is still a First Amendment, as you probably are aware of.
Well, they'll be deposed, too, so you might want to tell me now before we find out that you're not telling me everything you know.
That's a wild guess on your part.
you have no evidence to
the contrary.
In the last two years, have you gone out to lunch with Chris Ruddy?
Or seen him in any events?
Certainly not lunch.
I don't think we have had a social occasion within the last two years.
How many times have you been in his presence in the last two years, physical presence?
I can only think of once, and that was recently.
And when was that?
Two weeks ago.
What was the context?
I was in to do an interview with both John Cardillo and Howie Carr, and he was in the office that came by and said hello.
And what was the interview about?
The Democratic candidates for president and impeachment.
So you can talk about things other than your criminal prosecution?
Some things I can, yes.
There's a lot of things going on in the world that you can talk about.
Yes, but that's not what most people want to interview me about.
During that encounter with Ruddy a few weeks ago, he mentioned the lawsuit against Newsmax, him, Cardillo, Bachman.
No, he did not.
He has stoutly refused to discuss the matter.
And as always said, that's best left to the lawyers.
What did he say about me?
I didn't say anything about you.
Your name didn't come up.
What did he say about Corsi?
Of course these names didn't
come up.
You're aware that Ruddy frequently touts his association with President Donald Trump?
I'm not aware of that.
And, in fact, you're also aware that, frankly, his association isn't that great with Trump?
I don't know that.
I don't know.
I'm gonna go to the next page.
You are aware that Dr. Corsi and I filed pleadings with Judge Amy Berman Jackson concerning defamatory statements that you made against him and me?
Yes, I've been told that by my attorneys.
Have you reviewed those pleadings?
I did not.
I understand they were rejected by the court.
Who told you they were rejected by the court?
one of my attorneys.
Turn to page 327 of Exhibit 2. We're
not discussing your filings in the criminal court.
I'm just using it through Fresh's recollection.
Of what?
I'm going to ask the questions, not you.
Okay, go ahead.
Now, you're aware that your gag order prevents you from using surrogates to pursue your objectives in the media, whatever they may be.
This is what I'm talking about, the object.
We're not talking about gag orders and anything to do with the criminal case.
Now, one of your...
Turn to paragraph 7. Yes.
On Sunday, Monday, and Tuesday this week, February 24th to 26th, 2019, persons in blue Lincoln Zephyr and a white Dodge Caravan...
In front of my house, New Jersey, in the dwelling of my stepson in New Jersey, they both lingered there for no apparent reason as if they were watching us and threatening us.
Have you ever sent any vehicles to show up in front of Dr. Corsi's home?
This pleading, document number 47, was rejected by Judge Berman Jackson.
How do you know that?
She didn't let it be filed.
Well, she did accept some pleadings, did she not?
Your amicus brief, I believe it was, on some matter, and then she rejected after that.
So this is not...
Well, I'm not asking about whether it was rejected or not.
I'm just refreshing recollection here.
Did you ever send...
He never said that he forgot something.
Did you ever send...
All right, then I'm just going to ask you straight up.
Without regard to this, that's fine.
Did you ever send people to go in front of Corsi's house to intimidate him?
Let me answer the question.
Sure. Categorically, positively, not.
Do you have some evidence to the contrary?
Present it.
Now, when you were representing me in the Senate campaign as a consultant, I told you about some difficulties I was having with Fitton and Judicial Watch,
correct? I don't recall that.
And you told me, I've got people that can take care of that, correct?
I have no memory of that whatsoever.
And in fact, I said I don't do those things?
How do we know that this even happened?
Just because you say it?
I'm asking you.
I have no recollection of that.
It's false.
And I told you not to do that?
That's completely false.
What things are you talking about, Mr. Clayton?
Mr. Stone knows.
No, Mr. Stone doesn't know.
But if you have any evidence that I sent these people to Jerry Corsi's home...
Present it.
Let's see it.
Where is it?
It's categorically false.
Now, you know Peter Santilli, don't you?
I do.
How did you get to know Peter Santilli?
He was a...
He had a talk show on the internet, kind of like Alex Jones.
And he...
I believe I met him either at or before the...
I took on the Bundy cause for free because I felt that they had been unfairly treated by the federal government.
I was glad to see that they got justice.
That's about it.
He's a convicted felon as well, is he not?
Yeah, but I think you know the circumstances of that case.
Weren't several people there unfairly treated by the federal government?
He has promoted you on his show, has he not?
His radio show.
I believe he has.
Which is?
Heard in the District of Columbia, as among other places.
I don't know that to be a fact.
In fact, you've appeared on his show, have you not?
I have appeared on his show.
And you appeared on his show and discussed me, have you not?
I don't recall that specifically.
In fact, you put him up to file a bar complaint against me in the District of Columbia, did you not?
Categorically false.
Now, during the trial, there was reference made, your criminal trial, to threatening Randy Credico with filing a bar complaint against Margaret.
You remember that?
We're not answering questions about the trial.
Putting people up and yourself filing bar complaints is one of your modus operandi to strike at people who you consider to be a threat.
Do you have a question?
That's a false assertion.
Do you have a question?
Yeah. You put Santilli up to file a bar complaint.
Categorically false.
You have some evidence of it.
Produce it.
You know Barbara Jordan?
Deborah Jordan?
By name.
That's Santilli's girlfriend, is it not?
I believe that that's his own, isn't she a co-host or something?
And a co-host.
Dual role.
Okay, if you say so.
Right, you're aware that she made statements that Jerry Corsi and I are working with Robert Mueller, correct?
I'm unfamiliar with that.
You, in fact, told her to say that.
No, actually, I did not tell her to say that.
In fact, that's the same type of language that was used earlier that we went over with regard to Corsi and me.
You really are paranoid.
No, that is false.
We didn't talk about that today?
We did talk about that, but it was false then and it's false now.
Now you're aware that, of course, you and I depend on our livelihood from conservatives and libertarians and people of faith, correct?
Objection of form.
You're aware of that?
I guess so, yeah.
So to say that we are working with Robert Mueller is to say that we're Judasists, correct?
I didn't say that about you.
But Barbara Jordan, Deborah Jordan.
I'm not responsible for the statements of Deborah Jordan.
I've never told her to say or not say anything.
In fact, you're aware that I've sued Mueller on behalf of Coursey, correct?
I did.
What happened with your lawsuit?
I was going through the courts.
Okay. Read about it.
You're aware that on behalf of Coursey, you think that's funny?
At least I did something for my client rather than sitting there during the trial and getting him convicted.
Ask your next question.
Your lawsuit was dismissed.
That's why I smiled.
Okay, fine.
Go ahead.
Are you aware that, on behalf of Corsi, I filed a criminal complaint against Mueller at the Department of Justice?
I read that, yes.
With the Inspector General and the Office of Pressures?
I read that, yes.
You did tell Randy Credico that you were going to file a bar complaint against Margaret Kunstler, his best friend, if he didn't testify the way you wanted him to testify with regard to Congress and the Special Commission.
I'm not going to address that.
That's one of your modus operandi, isn't it?
File bar complaints against people?
You asked that already.
I don't think I've ever directed anybody to file a bar complaint against anybody.
Or yourself filing them.
I don't think I've ever filed a bar complaint.
Yeah, you don't want your fingerprints on it, do you?
I don't think I've ever directed anybody else to do so.
Wild conjecture and supposition on your part.
You are aware that Santilli did file a bar complaint against me.
not.
In fact, you've talked to Santilli's lawyers, have you not?
No, I have not.
You're aware that he's been sued, are you not?
Sued by...
No, I was not aware of that.
Separate from the lawsuit you're filing here?
You are aware that you were joined as a defendant in that lawsuit?
Show them the page number, please.
I'll get to it when I want to.
Are you aware of that?
No, I don't recall it.
What's the status of the suit?
We'll get to it.
to it.
We'll get to it.
Let's take a five-minute break.
15 minutes, right.
Let's take a 15-minute break.
Are we ready?
Okay, we're going to go back on the record.
Back on the record at 247.
Mr. Stone, you testified previously that you didn't have any contact with Santilli.
A bar complaint concerning me, correct?
I said I didn't recall any.
But you have, haven't you?
In fact, the first document in composite Exhibit 4 is from Pete Santilli to you saying, here's another important document reclaiming disciplinary information.
Yeah, I didn't recall this.
But you just testified unequivocally that you didn't have any contact, correct?
I didn't recall it, certainly.
So what contact did you have over a bar complaint filed against me?
I didn't tell him to file a bar complaint against you.
I believe he did that on his own.
I don't even know the issues contained in the bar complaint.
Well, you don't care just as long as there was a bar complaint, correct?
Conjecture on your part.
You're aware that I never represented Mr. Santilli, correct, in the Bundy manner?
I didn't know whether you did or whether you didn't.
I remember reading that they would not let you come in pro hoc.
In Nevada.
Nevada. Nevada, correct.
Pardon me.
This is the first page of the binder I've given you as Composite Exhibit 4, correct?
Yes. And this is a document that your council just...
These are documents your council produced to me.
I didn't recall this.
Is this the document that was attached?
Yes, exactly.
Yeah, I don't recall reading this.
You're aware that Mr. Santilli is currently subject to supervision by the Bureau of Prisons?
I've heard that, yes.
How did you hear that?
I think his lawyer spoke to my lawyer at some point.
And what did they speak to your lawyer about?
I couldn't tell you.
have to ask one of my lawyers.
And you're aware that he's not under the terms of his status right now.
He's not to have any contact with convicted felons.
No, I wasn't aware of that, but I've had no contact with him.
Okay.
Flipping past that bar complaint is a document called"Silent No More: How I Became Political Prisoner of Mueller's Witch Hunt" by Dr. Drew.
What page is that?
Council did not Bates number the production like I did, so we have to work our way through it.
This is it, yes.
What is that document?
It appears to be a printout of Sherry Corsi's book.
Tell me, what, if anything, in that book is not accurate?
I read it so long ago I couldn't remember.
I'd have to reread it.
So you can't state anything is inaccurate at this point in time?
I remember when I read it, I concluded several things were inaccurate, but I don't remember the specifics because quite a bit of water has gone under the dam since then.
Well, if it had been so grossly inaccurate, you would remember, correct?
Objection of form?
Not necessarily.
Let's flip past the book.
turn to a letter from the Justice Department.
To Dr. Corsi, signed by Aaron Zielinski.
This is to David Gray?
Yes. How did you come into possession of this document?
There's no date on it, but on the right-hand side there's handwriting that says 9-21-18.
You see that?
Yeah, I'm...
That's David Gray's.
I'm just trying to identify the document for the record.
Yeah, I don't recall.
How did you come into possession of this?
I don't recall.
In fact, I don't recall ever seeing it again.
I remember hearing about it, but I don't know that I ever read this.
Now, this is an example of a document that you gave your counsel to produce in hardcopy.
In other words, you had a hardcopy of this?
I'm uncertain.
Did you have an email, or was it in hardcopy?
I don't recall.
Remember reviewing it?
I don't recall reading this, no.
Then flip down, there's a memo of November 25th, 2018 to David Gray from Jerome Corsi.
I see that.
JRC criminal complaint to be filed.
With Whitaker on Mueller.
See that?
Yes. Okay.
It consists of two pages.
How did you come into possession of this memorandum from David Gray to Dr. Corson?
I don't recall.
I have no memory of having read this previously, actually.
Are these documents that your counsel just decided to produce for the heck of it?
I suspect they produced them in response to your request, but I don't recall them specifically.
There were three terabytes of data in my trial, so I've had to read an enormous amount.
I don't recall this particularly.
Is this related to grand jury information?
Information obtained?
In Mueller's grand jury?
That would have been among the discoveries, certainly.
So your counsel disclosed grand jury material?
No, he didn't.
No. Is this grand jury material?
No, not that I know of.
Well, how did you get it?
I don't recall.
Turn to the document after that document.
It's an email from Andrew M. Harris, Bloomberg.
Yes. To your counsel, Mr. Buchel, Mr. Smith, player02 at hotmail.com.
Who's player02?
It's mine.
And player02 at gmail.com.
Also mine.
So this reflects that you were communicating with Andrew M. Harris on or about.
No, I reflect that he asked a question.
I don't think I responded to this.
I'm unfamiliar with Mr. Harris.
Is there a Bloomberg news story quoting me?
Or that has a blind quote?
I don't think I responded to this.
The date would have been after the gag order, so no, I definitely didn't.
How did Mr. Harris get your email address?
I have no idea, but many, many journalists have it, been in politics for a long time.
There are other people at Bloomberg News who certainly have it, the political reporters and so on.
The first thing I want to do is to make a lot of people who are not interested in the media.
Now the next document in what was produced on your behalf by your counsel is a complaint in the federal court in DC by Dr. Jerome Corsi against you, correct?
Yes, we've been over that.
Did you say when we looked at previously?
Yeah. I'll then turn to an e-mail.
To Jerome Corsi, from Ted Malick, C.C. Christopher Ruddy, Ruddy at Newsmax.com, subject EU, where it states, any chance of reviving this now with Bolton in White House?
Ideas? Yes.
Thanks, Ted.
What's that about?
Ted aspired to be appointed ambassador to the EU, which unfortunately did not happen.
And why is Ruddy...
It's a question you'd have to ask Mr. Malik.
What's the objection of that?
We just have any basis to know what was in Malik's mind.
I can ask the question.
Yeah, but I didn't send the email.
I received it, so you'd have to ask Mr. Malik that question.
So you were working with Ruddy to try to get Malik appointed to be EU ambassador?
No, I actually don't think I ever discussed it or communicated it with Ruddy.
Perhaps Mr. Malik thought...
Mr. Ruddy was a friend of the president's.
I don't know why he copied him, or maybe they have a relationship.
I don't know.
I've never discussed Ted Malick or communicated regarding Ted Malick with Mr. Ruddy.
So Ted Malick knew that you were a friend of Ruddy, so he copied Ruddy on it?
No, maybe he thought that Ruddy was influential on the question of the ambassador to the EU.
That would be conjecture on my part.
Again, you'd have to ask Mr. Malick why he copied Mr. Ruddy.
I didn't know that they knew each other.
Was Ruddy ever called before the grand jury in the Russian collusion investigation of Mueller?
Objection. He can't comment to that.
To the best of your knowledge.
Whether he was is not confidential grand jury information in any way.
He has no binding.
I don't know.
I don't know.
I have no idea.
Ted Malick was involved in that investigation, correct?
He was one of the people that...
Mueller was looking at and, in fact, an FBI agent detained him at the airport coming into the United States, correct?
Based on his knowledge?
Reported, yes.
Turn to the next document.
TylerNixon@gmail.com to you.
An attorney, yes.
At player02@gmail.com.
Yes. Of course, he claimed an amicus.
Do you remember receiving this?
No, I actually don't I'm not sure what I'm doing Maybe I didn t have no idea.
Who is Tyler P. Nixon?
An attorney who represents me.
Therefore, I would think this document would be privileged.
What does he represent you in?
He's represented me on a number of matters.
Such as?
He helped do research on my recent trial.
He's represented me on civil matters.
He represented me on numerous occasions.
He's a long-term friend and he's an attorney.
Which civil matters has he represented you in?
I don't really recall.
He does mostly contract stuff, that kind of stuff.
Where is he located?
Denver, Colorado.
Has he represented you in defamation lawsuits?
He has not.
Is he related to Richard Nixon in any way?
There is some distant relationship.
How did you get to know him?
He was very active in the Delaware Republican Party when I was running President Reagan's re-election, and Delaware was one of the states that I had responsibility for, and therefore he traveled to Washington to introduce himself to me.
Okay.
Did you respond to this email that Tyler Nixon sent you?
I don't know specifically.
He is very verbose, and he sends a lot of stuff with his opinion.
I don't respond to all of it.
Not all of it is solicited.
He's a very facile writer.
I don't recall a specific response to this.
It's dated February 15, 2019.
Yes. Correct?
Yes. Below that is an email from Alexandra.
Dukakis, otherwise known as Ali Dukakis of ABC, February 15, 2019.
Yeah, I would doubt that there was any communication.
He, generally speaking, doesn't like to talk to any reporters.
But I don't know what transpired.
During the course of your criminal prosecution, you did have frequent contact with Alexandra Dukakis, did you not?
She was certainly present.
You talked to her on the phone.
And you emailed her and texted her.
I don't know that that's true.
You never talked to her on the phone?
I don't know.
I don't recall.
It was kind of a blur.
Did she ever tell you that David Gray was sitting at the bar with her at the Wyndham Hotel in Washington, D.C., and overheard her talking to you on the phone?
No, I've never heard that.
How do we know that it's true?
Well, we'll have David Gray testify.
He's certainly a disinterested party.
Turn to the next email of February 14, 2019.
That was my recommendation.
I don't think anything came of it.
Okay. That's an email that you sent to Ali Dukakis, copy Tyler Nixon.
To understand my case, yes.
And it says it was in previous email included above, under the rules in D.C., Grant Smith will no longer be able to comment on the record about anything, but Tyler Nixon will.
Yes. So you had Tyler Nixon communicating about Dr. Corsi?
No. Why does it say Dr. Corsi's name?
Well, the document request asked for anything that referred or related to Dr. Corsi.
Well, there's, of course, the claimant amicus, yeah.
I guess she was looking for some explanation of your filing.
I don't know.
That would be conjecture on my part.
All right.
Civil matter.
Now, look at the bottom of the page from Roger Stone.
Yep. Wednesday, February 13th, 6:07 p.m., to Roger Stone.
Yep. Roger Stone and Roger J. Stone, Jr. is the same person, correct?
Correct. Copy, Tyler Nixon.
Correct. Wearing it states, Corsi claim an amicus,"Not for attribution.
I will not be commenting on the attached brief filed by Jerry Corsi in support of suspending my First Amendment rights and gagging me.
My attorney, Tyler Nixon, will be available for comment." His address is above Roger Stone.
Correct. Why did you send the email to yourself?
Couldn't tell you.
You were trying to create a false record that you hadn't communicated with Jack Dukakis.
Wild conjecture on your part.
In fact, you defamed Corsi and me with Ali Dukakis.
That's your version.
Well, we'll find out from her, too.
Yeah, good luck.
Why good luck?
You wanted to pose a journalist about their sources?
Good luck.
Were you a source?
No, but I assume that's what you want to ask her about.
If you weren't a source, then I guess I can ask her about it.
You can ask her, but she does not have to answer any questions regarding her sources, whether they're me or not.
What you're saying is you were a source to the media during your prosecution.
False, categorically false.
God, you are an asshole.
You really are a jerk.
Go ahead.
Continue. Next question.
Let's go.
The next page, another email to yourself, rogerjstonejr, player02@gmail.com.
Sent to yourself.
Yes. I may have copied my lawyers.
I don't know.
I don't see any CC there.
But I do see one below from Grant Smith to you, copied Robert Buchel, Tara Campion.
She's an attorney.
Represents me.
She works with Mr. Smith and Mr. Buchel?
No, she works with Mr. Rogow.
Oh, Rogow, yeah.
Bruce Rogow.
Who? Yes.
Okay. Who also represented you in the criminal prosecution?
Correct. And Mr. Smith is writing to you,"The attached Corsi claim an amicus was accepted for filing today.
Enjoy the read." Yep.
And who did you comment in the media to with regard to the amicus being accepted for filing today?
commented to anybody.
Next email, from Richard Johnson, rjohnson at newyorkpost.com, February 10, 2019, 1151, to player02 at gmail.com.
That's you, correct?
Correct. Subject, filed notice of amicus, attachments.
Yes, obviously you emailed it to him, as it shows.
I don't believe I responded to this.
Flipping down a few pages is the actual notice of filing of the motion for leave to file amicus brief related to case USA v.
Stone, 19-CR-18, correct?
Yes, appears to be.
And then later on is the actual amicus brief itself of Dr. Corsi, correct?
Appears to be yes I'm going to make a lot of bread What makes the mill perfect SaaS?
Okay. What is just a社 nak Hospital zak Zaz My petrol?
Please? It'snię common.
We must have had often missed that.
It's been very good since there was a lot of fun.
It's been a long time.
I'm going to go to the next day.
Now, this amicus brief refers to an Exhibit B, which is attached.
An article by Sarah Murray and Sam Folsom had a Roger Stone facing gag order to launch his counterattack.
You see that?
in the amicus brief.
*Clears throat*
Yes, I see the reference.
I'll turn to Exhibit B. It's attached to the amicus brief, as exhibit B. Where am I looking?
Is it a story?
What am I looking for?
Not finding it.
This is exhibit A. Yes.
The title of that article is Roger Stone Facing Gagler Launches Counterattack.
Now, Sarah Murray and Sam Fossum, F-O-S-S-U-M, in an article dated February 7, 2019, they work for CNN, correct?
I'm not familiar with Sam Fossum, but I certainly know Sarah Murray.
Is it not true, look at the first paragraph, excuse me, the fourth paragraph, where it says, but rather than toning down his rhetoric, Stone appears to be abiding by the principles he espouses in his books.
For instance, Stone's rule number 81, admit nothing, Deny everything, launch counterattack.
In fact, you wrote that in your book, did you not?
I'm not going to come on anything pertaining to the gay order.
No, I'm talking about the book that you wrote.
What's the name of that book?
Stone's Rule.
You should get a copy.
And that's an accurate depiction of Stone's Rule 81, correct?
I'm not sure about that number, but I've certainly said that, yes.
So basically it says, when called to answer questions, admit nothing, deny everything.
In effect, lie.
No, it doesn't say that.
Where's the word lie?
I don't see the word lie.
Admit nothing, deny everything.
So you didn't read the quote?
So is that your rule, that even if it's true, you should admit nothing and deny everything?
I don't think that's an accurate depiction of what that means.
And then launch a counterattack?
It's called politics.
And that's what you did with regard to Dr. Corsi and me?
A conjecture on your part.
No, fact on my part.
We'll see.
Look down the fifth line from the bottom.
Fifth paragraph from the bottom.
In one Instagram post, Stone is shaking hands with William Binney, a former National Security Agency official, who is turned into a vocal critic of the agency.
Bill Binney explained to me why the forensic evidence shows the DNC was never hacked by anyone, including the Russians, Stone wrote.
Who's Bill Binney?
Bill Binney is a former NSA official.
Now, you've had contact with Bill Binney, have you not?
Yes, I have.
When did you first have contact with him?
I think I met him at a...
Women for Trump event in February of 2019.
And you've talked to him many times since?
No, actually I haven't.
How many times have you interacted with him since?
I don't think I have interacted with him since.
You spoke to him about illegal NSA surveillance.
My attorney spoke to him at length.
In fact, I believe he supplied a deposition for us.
And you've talked to him as well, correct?
No, actually I haven't.
Do you know whether or not he's working with Dennis Montgomery today?
I do not know.
Have you had contact with Dennis Montgomery?
No, I have not.
In fact, you have, correct?
No, in fact I haven't.
Okay. Okay.
The last page of this document refers to OJ Simpson.
Have you had any contact with him?
I have not.
Never never I I I I
Turn to the email dated June 1st, 2019, 628, to Christopher Ruddy, claiming to PDF from Roger Stone, correct?
Yes. We're in you right to Ruddy.
Claimant is suing me because he alleges I've interfered with his relationship with Newsmax.
I don't recall having ever discussing this asshole with you or Clemente.
He is clearly insane.
Yes. Okay.
Now, who's Clemente?
Clemente is, I don't think he's there anymore, but he was their director of programming at one time.
He'd worked for Fox News, correct?
I believe that's correct.
You don't have any medical background to determine whether or not I'm insane.
Well, when one makes allegations that I had interfered with your being interviewed with Newsmax on the basis of no evidence whatsoever, having never discussed it with Ruddy or Cardillo or Clemente, the only people I knew at Newsmax, yeah,
that's pretty crazy.
You just pull that out of thin air?
That's pretty crazy.
You made an allegation that I'm medically insane?
Insane is, I think, a colloquial expression, but when someone pulls facts out of the air for which they have no evidence whatsoever, which they're just guessing because they're unhappy that they can't be interviewed when they want to, yeah, I think that's pretty crazy.
I think that's insane.
Newsmax bringing on someone like Cassandra Fairbanks to...
Call my client Corsi a liar over and over.
That's insane?
You would have to ask the people at Newsmax that.
I didn't make any recommendation or decision to have Ms. Fairbanks on the air.
I have no impact on who Newsmax chooses or does not choose to interview.
Cardillo sending out tweets in support of you?
Mr. Cardillo has First Amendment rights like every other American.
Claiming he's your great friend?
He is a good friend of mine, but I don't tell him what to tweet.
I don't tell him who to interview.
He has First Amendment rights like everyone else.
Two and two equals four, doesn't it?
You have nothing.
Is that insane?
No, no.
Wild proof.
Evidence, Larry.
Proof, Larry.
Evidence. Proof.
Evidence. Not guessing on your part with nothing.
You have nothing.
This proves nothing.
That's what you told Mueller, right?
You have nothing.
That's what your clients argued at the trial.
I'm not going to discuss the criminal case.
If you want to keep insulting me, this will be over you to run back to the judge like a little bitch.
I'm doing what?
If you want to keep insulting me, I will just end this and you go running back to the judge.
Did you just call me a bitch?
You're acting like one.
You're acting like one.
You don't have anything, my friend.
You got nothing.
You have a wild guess.
If you have some evidence that I communicated with Ruddy or Cardillo or Clemente or Cassandra, produce it.
You got nothing.
You're not going to get anything by interviewing them because it's not true.
I haven't withheld it.
If I withheld it, do that.
But you don't have that either.
We'll look for it.
You can look for it all you fucking want.
You'll find nothing.
Ask a question.
This is just, it reaches a point of absurdity.
going to make a little bit more of a bag.
Turn down again your client, not your client, your lawyer did not Bates number of the documents, so take your time and flip down in these documents and plaintiffs composite Exhibit 4 and there was an email, there is an email from John Cardillo,
cardillo.john@gmail.com to Roger Stone on August 18, 2019 at 5:24 p.m.
I did separate these electronically for you.
You're the one that mixed them together.
Larry, from Cardillo to Stone or from Stone to Cardillo?
From stone to cardilla.
Exhibit 4. Just keep flipping.
I'm looking, I'm looking.
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