Depositions & Trials - Deposition of Free Speech Systems, LLC, Daria Karpova - December 3, 2021

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Dec. 3, 2021 - Depositions & Trials

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Deposition of Free Speech Systems, LLC, Daria Karpova - December 3, 2021

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	Okay, this is the deposition of Daria Karpova.
	The date is December 3rd, 2021.
	The time is 10.53 a.m.
	You may swear in the witness.
	Anna, if you raise your right hand, I'll be there.
	Are you forgotten to tell the truth, the whole truth, and nothing about the truth?
	Yes.
	Thank you.
	All right.
	And do you want us to announce appearances?
	That would be great.
	Yeah, okay.
	Mark Bankston, questioning for the plaintiffs.
	Brad Reese, for the defendants.
	Before we begin, Mark, I'd like to go ahead and see if we have the same stipulations yesterday morning that this is subject to the already answered protective order in the Lewis case and the pending ones in the Heslin and Posner and Dela Rosa matters.
	Plaintiffs are agreed.
	All right.
	Ma'am, could you tell the jury your name and what you do for a living?
	Daria Karpova.
	I'm a producer for Bullers Junction.
	When were you first told you'd be given this deposition?
	I don't recall the exact date, but I believe it was a few weeks ago.
	Sometime in November, you think?
	Yes.
	Okay.
	Do you know what you're here to testify about?
	It is my understanding I'm here on behalf of Free Speech Systems.
	Have you been provided with topics you're going to testify about?
	Yes.
	Okay.
	Did you meet with your attorney before this deposition?
	Yes.
	When did you do that?
	Yesterday.
	Was that the first time you met this attorney?
	Yes.
	How long do you spend with them?
	couple hours And when I say when you met with your attorney, I'm speaking about Bradley Reeves, you're seated across from me.
	Have you met with any other attorneys?
	Yes.
	What other attorneys have you met with?
	Well, actually, hold on.
	Let me back up here.
	Have you met with any other attorneys regarding your preparation for your testimony here today?
	Yes.
	Okay, what attorneys are that?
	It's with privilege.
	Excuse me?
	You can talk about whom you attorneys you met with to not speak about the discussion you had.
	Okay, you met with Mr. Randonza.
	When did you do that?
	That was yesterday.
	Is he in the room with Mr. Reeves?
	No, that was the day before.
	Okay, I thought you met with Mr. Reeves yesterday?
	When you asked me about the attorney, that's what I thought you meant.
	So I was referring to Mr. Randaza.
	Have you ever met with Mr. Reeves?
	The day before.
	Okay.
	Okay, so actually the day before yesterday, you actually met with Mr. Reeves.
	Correct.
	Okay.
	How long did you meet with Mr. Reeves?
	Maybe an hour.
	Okay.
	Mr. Randonza, you meet with him in Austin, or was that over some sort of technology situation?
	In person.
	Okay.
	That was in Austin now?
	Yes.
	Okay.
	So let me make sure I have it straight now.
	Yesterday you met for Mr. Randonza for a couple of hours.
	And the day before, you met with Mr. Reeves for a couple of hours.
	And I didn't time the meetings, but that's what I can approximate, yes.
	Sure, sure.
	Okay, so let me just make sure I understand.
	And as a, let me also just as a warning, sort of a caution.
	We're going to have a conversation today that's not exactly natural or normal.
	If we were talking to each other, say, outside of this room, just in a room together, there's a good chance that we'd be able to anticipate each other's questions and answers, finish each other's sentences, be able to jump in and start answering before I was done for my question, because you'd know what I was saying.
	We do this all the time in normal conversation.
	It's not rude or anything.
	I'm not saying you're interrupting me or anything.
	But in a deposition, she's got to write everything down.
	And it makes it really, it makes it super difficult for her if we're ever talking at the same time.
	And so we kind of have to do this unnatural thing where you have to wait a second until I'm done with my question and then answer.
	And so it kind of seems unnatural, but I'll try to remind you if we're talking over each other.
	I'm sure if we do it really bad, She's going to remind us.
	Remember that she's not paid by any, you know, she's not part of the case.
	She's not associated with a party, so she has no interest in this.
	So she's just trying to do her job.
	So I want to make sure we try to do that for her.
	Thank you.
	I want to make sure I have it done correctly that in terms of you meeting with lawyers to prepare for this deposition, that consists of Mr. Randonza yesterday for what you think is a couple of hours, and Mr. Reeves the day before for what you think is a couple of hours.
	Correct.
	Okay.
	Tell me anybody else that you have spoken to about what you plan to testify about here today.
	I've consulted with two former corporate reps in regards to whether I was missing any information.
	They said that I wasn't.
	I've also consulted with HR regarding some of the topics for the information that I was going to need for this.
	And that's it.
	Who was the first corporate rep?
	Rob Dew.
	Okay, you met with Mr. Dew and talked to him about the topics you'd be speaking about today?
	Briefly.
	What briefly?
	What does that mean?
	I basically sort of ran through the topics and asked him if I was missing anything, if he had any information for me, and he said no.
	How long did you talk to him?
	I'd say 15, 20 minutes.
	Okay.
	Mr. Dew didn't have any other information for you?
	No.
	So nothing here that you say today is going to be coming from Mr. Dew?
	No.
	Okay.
	Who's the other corporate rep you met with?
	Michael Zimmerman.
	Okay.
	Did you get any information from Mr. Zimmerman?
	No.
	How long did you talk?
	Oh, excuse me, I'm sorry.
	Yeah, he pretty much was the same type of meeting.
	Okay, so, and I take it by when you say same type of meeting, you asked him if there was any information that you needed to know about any of these topics, and he said no, I don't have anything.
	Yes.
	Again, I'm going to caution you.
	Yeah, we'll get used to it, I promise.
	It's going to be a long day, so we'll get used to it.
	But let me ask that question again.
	What I'm taking your saying is that you met with Mr. Zimmerman for a brief period of time, asked him if he had any information about these topics, and he told you he did not have any information about these topics to give you.
	He told me that I already had the information.
	He didn't have anything new to add.
	So how did Mr. Zimmerman know what information you had?
	I believe I had read the topics that are on that sheet of paper for him.
	Okay.
	So, in other words, after reading those topics to Mr. Zimmerman and wanting to know if he had any additional information he could give to you, he said no, you should have everything.
	Is that the basic sum of it?
	Yes.
	Okay.
	No, I understand.
	I've been given a folder.
	Do you recognize this folder that I'm holding right here?
	Yes.
	Okay.
	I've been told that these are documents that you reviewed prior to this deposition.
	Yes.
	Okay.
	So you have taken the documents that you prepared yourself for today and put them in this folder?
	Correct.
	Okay.
	I want to right now.
	No, let's do them individually.
	You could do 1A1B1.
	Yeah, that's probably not the best.
	That's not the worst idea.
	Okay.
	So, ma'am, what I'm going to do is I'm going to put a sticker on this folder itself, and we're going to mark that as exhibit one.
	Okay, and I want to talk to you about some of the documents in here.
	Let me ask you this, too.
	So, these documents that you prepared and the conversations that you've had with counsel and the conversations you've had with your corporate representative, the two corporate representatives, excuse me, that would be the total universe of people that you've spoken to about the deposition.
	Is that right?
	Yes.
	Okay.
	And these documents here represent the total universe of documents that you have prepared for before the deposition.
	Is that correct?
	Yes.
	Okay.
	Can you tell me the amount of time that you have spent it up this way?
	I would assume or maybe I'm not correct, so let me know, but I would assume that in addition to meeting with the attorneys and speaking to the corporate representatives, you also spent time, say, reviewing these documents, right?
	Some time, yes.
	How much time do you think you spent reviewing these documents?
	Let's say an hour.
	Okay.
	So the things that we see here in exhibit one, these are things that you personally, outside of the company of lawyers and outside the company of corporate representatives prior, you spent about an hour reviewing this material.
	Correct.
	Okay.
	And is there anything else that I'm not talking about yet that you have done to prepare or gather information for this deposition?
	Can you repeat the question?
	Yeah, sure.
	And then let me help me try to rephrase it.
	We've talked about reviewing documents.
	We've talked about talking to people.
	there's no other people or documents other than the people we've already talked about Is that correct?
	Um, the Yeah, one of the topics for this meeting today that I have prepared included personnel for particular dates of the videos, which I had inquired from HR about.
	She had provided me with some personnel which I thought I had printed out, but they're still in my email, which when I looked through the folder, it wasn't there, so they're still in my folder.
	I mean, in my email.
	So if you need that, I could potentially print that out.
	Those documents are things that you use to determine who was working at the company at what time.
	Again, I got side things.
	And I know, again, I know you're not doing it on purpose and because I have the feeling you try to be an efficient person and you know exactly what I'm asking so you wanted to be compliant.
	No, you're fine, trust me.
	But I will stop you and remind you when that happens just because I'm trying to make sure this record is good.
	I'm glad you brought that up because I did forget about the HR person.
	And can you tell me that person's name?
	Melinda.
	Is it maybe Flores?
	Yes.
	Okay, so Melinda Flores is the HR person you talked about and did you feel like you were able to get information about who was working at different times?
	Yes.
	Okay.
	Okay.
	Before we dive in those documents, I want to talk just a little bit more about you.
	First, can you tell me a little bit about your educational background, what that looks like?
	I have a bachelor's degree in applied engineering.
	Where's your degree from?
	Expression College for Digital Arts.
	Excuse me?
	I'm sorry, I didn't get it.
	Expression College for Digital Arts.
	Gotcha.
	Okay.
	And is that your only secondary education?
	Yes.
	Okay.
	Can you is InfoWars back that up?
	When did you start working with free speech?
	Oh, I'm making assumptions.
	Is your employer Free Speech Systems LLC?
	Yes.
	Okay.
	When did you start working for them?
	I believe October 2015.
	Okay.
	Between your secondary education and Infowars, did you have other jobs?
	Here and there.
	Can you walk me through those through your resume?
	Due to the nature of my education, what I required, I would have regular gigs here and there.
	So it wasn't a one single employer.
	At times I would have several employers during the course of, say, a couple of months.
	Then I would just take regular gigs when I'm talking about the sound engineering, live sound, different production roles, different gigs for music composition, so things like that.
	Okay.
	So these jobs were not permanent employment, but you had contract work, in other words, between different people?
	Okay.
	And when you say audio production, are we talking music production?
	Are we talking for entertainment, video, news?
	What kind of things are we talking about?
	Conferences, anything that had to do with audio, again, conferences, concerts, music concerts.
	Again, anything had to do with audio, that I would be engineering that.
	Okay.
	When you were first hired by Free Speech Systems, what was your job title?
	I believe it was Assistant Producer, which is a title that is given to everybody on production.
	And my specific role was the sound board, because that was my background and I was put in that position.
	Now, and today your job title would just be producer?
	Yes.
	Okay.
	Have you had any other job titles at Infowars?
	No.
	Okay.
	how much does enforce pay you a year Or actually, I'm sorry, let me back that up for a second.
	Are you paid as a salaried employee or an hourly employee?
	Salaried.
	Okay.
	Then, same question.
	What do you make yearly for InfoWars?
	About $125,000.
	Here.
	I have, in looking into InfoWars itself, I have occasionally seen reference, usually outside the company, of you being referred to as Mr. Jones's executive assistant.
	Is that a role you play, or have they got that wrong?
	I wouldn't know where that's coming from.
	Okay.
	Again, it's outside the company.
	And I think a lot of people say a lot of things about InfoWars without really knowing what it is.
	And so sometimes I may think that I know something about what's going on in Infowars, and please feel free to correct me.
	You would, I take it as a producer, the main functions of your job is to ensure or to facilitate the creation of the video and audio broadcasts that InfoWars creates.
	Is that right?
	No, I would say it is my job to facilitate the live broadcast and production thereof, pre-production as well.
	Okay.
	So things like, let's try to separate this out.
	Infowars does a live show pretty much every day?
	Correct.
	Okay.
	And then that live show is sometimes distributed through other channels like the internet, correct?
	Yes.
	For instance, you know band.video.
	You understand what that is?
	Do you have any involvement in running that website?
	No.
	Okay.
	So in other words, the live production side and the internet side, those are two.
	would use to describe those two different parts of the business I'm not sure how to contribute.
	Well, what I'm interested in is the amount of overlap between the people who are working with you to create the live show every day and the people who are running the website and putting articles and videos on the website and band.video.
	Is there overlap between significant overlap between those two groups?
	I would say no.
	Okay.
	And do you have, as a producer, I take it you have managerial authority over different employees.
	Is that right?
	Correct.
	Okay.
	If there's somebody doing something involved in the live show and they're doing it incorrectly, you have the power to tell them to do it differently, correct?
	Correct.
	Mark, I just want to stick or note for the record that I don't believe this is covered by any of the topics in your deposition notice for the corporate representative.
	Just for purposes of the record to denote that, I'm not otherwise going to stop you from asking them, but I just wanted to denote that.
	Right.
	Do you have managerial authority or I guess maybe managerial isn't even the right word, but do you have power and authority to tell the people who are running the website what to do?
	No.
	Okay.
	Okay.
	I want to talk to you now about some things in exhibit one.
	Thank you.
	I'm hoping we have enough stickers.
	Let's see.
	Okay.
	I've marked this as 1A.
	You recognize that, correct?
	Yes.
	That's a document that you reviewed prior to this deposition, right?
	Correct.
	That is the Wikipedia entry for false flag, correct?
	Yes.
	Okay.
	Can you tell me why you looked at this document?
	I thought it would be a good idea to bring it as a reference to some of the points for topic number one.
	If I could have the list of topics that would help me to identify the exhibits.
	I understand what you're saying.
	In fact, let's do that.
	I'm going to mark this as 1B.
	And what I'm handing you right now is titled Plaintiff's Third Amended Notice of Taking the Oral and Videotape Deposition of the Corporate Representative of Free Speech Systems LLC.
	And if I'll go ahead and just give you the page of the topics on it so you can see.
	Now, hopefully you can refer to that.
	And when you were referring to topic one, you're talking about the sourcing and research for the videos described in plaintiff's petition?
	May I just take a minute?
	Hmm.
	Yes, correct.
	I've handed you 1B.
	You recognize that?
	Yes.
	That is the Wikipedia entry for the Reichstag fire, correct?
	Again, keep it.
	Yeah, I know.
	I'm going to have to keep reminding you, but it's okay.
	Couldn't you mark the depot notice as 1B?
	You're absolutely right, Brett.
	You sure are.
	You just want to make this two?
	Yeah, no, I can...
	Yeah, that'll work.
	This was in the folder, is the only reason I was.
	Oh, whatever you want to do, man.
	I just wanted to have everything in one be the document to be found.
	Yeah, that's fine.
	So what I am going to do, since that was 1B, what we're going to do is I'm actually going to make this 1C.
	So now I have handed you what I've marked as 1C, which you recognize, correct?
	Correct.
	And that is the Wikipedia entry for the Reichstag fire, correct?
	Yes.
	The Reichstag fire was a Nazi party arson attack, correct?
	Correct.
	Okay.
	Can you tell me why this is relevant to the case?
	Same answer as for the previous exhibit.
	I thought it would be a document pertaining to some of the points in topic number one as an example of false flags.
	So in other words, let's try to put it this way.
	In some of the videos in plaintiff's petition, there are statements made about false flags, correct?
	Which petition are you referring to?
	Well, okay.
	When that topic number one says sourcing and research for the videos described in plaintiff's petitions, have you seen the plaintiff's petitions?
	Briefly.
	Okay, they're not in this folder, are they?
	No.
	This folder actually doesn't represent everything that you've reviewed for this deposition.
	These are the supporting documents that I thought would be good to have for me personally to refer to some of the topics here.
	Okay.
	But in terms of plaintiff's petitions, is that something you looked at before this deposition?
	I honestly can't recall.
	You can't recall if you've seen the plaintiff's petitions?
	I've seen a lot of documents.
	I'm not, since I don't have a legal background, I have a hard time recalling right now exactly which one was which.
	Which document was which document you mean?
	Okay.
	Mark, without waiving turn client privilege, I'll stipulate that she has seen the petitions.
	I don't need you to do that.
	I don't need you to testify for it, Brad.
	Please don't do that again.
	Okay.
	I need to question her about what she testifies.
	It's fine.
	It's fine.
	All right.
	I'm not trying to testify for it.
	You absolutely are, Brad.
	And please don't do that again.
	Mark, I'm not.
	You think we're not?
	I'm going to make it for the record right now.
	I'm questioning this witness about what she has reviewed for the deposition under her duties to prepare for this deposition, and counsel has just answered for her.
	I have not.
	And I object to that, and I don't like it, and I don't want it to continue.
	All right.
	We can then say that there are other documents besides what's in this folder that you've reviewed that I don't have in front of me, correct?
	Well, can I add something to the previous point?
	Sure, I'm not sure what you mean.
	You were asking me specifically a reference to false flag from a petition that I've seen.
	When I was trying to recall that, I do not recall in the petition that specific reference.
	It might have been there, but I don't recall from all the documents that I've seen.
	Now, the reason I brought these again is to help me present some of the points when answering these topics in this petition.
	No, I understand that.
	What I'm trying to, you know, first of all, my, that's before we get back to my question, right?
	Now that I know that in addition to these documents, your counsel tells me that you've reviewed the petitions, right?
	Are there anything else that I need to know about?
	Thank you.
	Thank you.
	I don't believe so.
	Okay.
	In terms of my question was, for the videos described in plaintiff's petition, do they reference false flags?
	Repeat that again, please.
	The videos described in plaintiff's petitions, do they reference false flags?
	I'm not sure of that exact wording.
	Okay.
	Who put into you 1D?
	You recognize that?
	Yes.
	Okay.
	What website does that come from?
	HistoryToday.com.
	Okay, so this is a History Today article about the sinking of the Maine, correct?
	Correct.
	Okay.
	The USS Maine was a 19th century warship, correct?
	Correct.
	Okay.
	And that warship exploded in Havana Harbor, correct?
	Sorry.
	No problem.
	Let me ask that again.
	That warship exploded in Havana Harbor, correct?
	Correct.
	There is significant historical evidence to suggest that that ship was intentionally exploded by the United States government.
	That's correct.
	There is a controversy about it.
	In other words, what I'm wondering is, from reading that article, did you come away with the idea that there is substantial evidence, in other words, non-trivial evidence, which people could use to support the idea that the USS Maine was intentionally destroyed by the United States government?
	So, let's go.
	I would say one could infer that.
	Okay.
	Can you tell me why that particular article is relevant to your testimony today?
	It could be viewed as an example of false flags throughout History.
	I'm going to put in front of you one E. You recognize that, correct?
	Yes.
	A Wikipedia entry for the Pearl Harbor Advanced Knowledge Conspiracy Theory, correct?
	Correct.
	Is this the same answer as the other documents?
	Yes.
	Okay.
	So this is another example of potentially.
	Well, let me ask back up.
	Would you call this a false flag, for instance?
	Let me rephrase that question.
	If the allegations about this conspiracy theory are true, would you consider that a false flag?
	I would say so, yes.
	Okay.
	All right, I'm going to put in front of you one F. You recognize that?
	Yes.
	Can you explain what that is?
	Yes, it is an article that was archived from the website DC Clothesline, which includes Mr. Halbig's biography, which I wanted to have on hand.
	Okay, so this is just biographical information about one of InfoWars sources.
	Correct.
	Thank you.
	Now put in front of you what I've marked as one G. You recognize that?
	Yes.
	Okay, can you explain what that is?
	One second.
	So this is another article that contains information regarding the questions that Mr. Halbig had regarding Sandy Hook.
	Okay.
	There's also some information about Mr. Jones in there too, correct?
	There might be.
	I didn't read the entire article.
	Okay, so you didn't actually review this entire document?
	Not in its entirety.
	Did you go find this document?
	Yes.
	Okay.
	And so how did you come across this document?
	How did you find it?
	I was looking for Mr. Halbeck's questions regarding Sandy Hook.
	Okay.
	Do you feel like you have an understanding now of Mr. Halbeck's questions regarding Sandy Hook?
	Yes.
	Okay.
	Yeah, we're definitely going to need more stickers.
	Let's see if we're on G. Alright.
	All right, I'm going to show you what I've marked as one H. You recognize that?
	Yes.
	That's from Dr. Steve Pachinik's website, isn't it?
	Yes.
	Okay.
	And that's basically a biography of Dr. Steve Pachenek.
	Correct.
	Okay, and you wanted to have that because Steve Pachinik is somebody who has appeared on InfoWars at one point to talk about Sandy Hook.
	Correct.
	Thank you.
	Okay.
	I'm going to show you now what I have marked as one I. You recognize that?
	Yes.
	That's a Guardian article, right?
	Correct.
	Guardian's a newspaper in Britain.
	Am I right about that?
	Yes.
	Okay.
	This article says, headline says, Sandy Hook father Leonard Posner on death threats.
	I never imagined having to fight for my child's legacy, correct?
	Correct.
	What did you need this article for in your testimony today?
	That's not a good question.
	Why did you feel you wanted to review this article for your testimony today?
	Thank you.
	Just give me a second, please.
	Okay.
	The reason I wanted to have this article is that I thought one of the victim's mothers, there was interesting information regarding the victim's mother and her request to have an open casket for the funeral.
	What's that interesting here?
	It seems to me that the motivation for doing so would be to exploit a child's death for a political agenda.
	Might another reason for it is because a bunch of people were saying that child is fake.
	Couldn't that be a reason for it?
	I don't know.
	Sitting here right now, if your child You just had a baby, right?
	Yes.
	Okay.
	Let's say six years from now, your child walks into elementary school and is massacred in a gun violence incident, and some news organizations are saying that your child is fake.
	Can you see that a possible way to combat that would be to have an open casket funeral for your child?
	No.
	That's not something you would ever consider?
	No.
	you could use to imagine how somebody else could consider that Not if they have a heart and no political agenda.
	Okay.
	So you think that this Jewish family's choice to have an open casket funeral for their child was politically motivated?
	I'm going to object to this being outside the scope of a corporate representative testimony.
	That's fine.
	Sir, could you please speak up?
	I'm sorry.
	Mr. Brad Reeves, I objected to this as being outside the scope of the corporate representative testimony, but you can go ahead and otherwise go ahead and answer.
	No, he needs that.
	He can't have that one.
	No, because I give it to her every question you want.
	I don't want to do it.
	I don't know.
	Oh, yeah, you have a question.
	I don't know if you wanted to answer it or not.
	What was the question?
	Madam Court Porter, can you read back my last question?
	One second, please.
	No problem.
	Thank you.
	The question was, so you think that this Jewish family's choice to have an open basket funeral for their family was politically motivated?
	What has being Jewish happen to do with this?
	I'm not here to answer your question here.
	I don't know.
	My answer is, my personal opinion, I find it unconscionable.
	That's something that I would never bring myself to doing.
	People have open casket funerals every day, don't they?
	Yes, however, considering the circumstances and how the child was disfigured based on these articles, I find that just horrific.
	Okay.
	Here's another article about that, right?
	Exhibit 1J?
	Yes.
	Okay.
	So you actually pulled two separate articles about Noah Posner's funeral having an open coffin.
	Correct?
	I pulled this one article because it was linked in The Guardian, and I wanted to make sure that I have the sources of where I got the articles from.
	Okay.
	And so of all the documents that you've reviewed regarding the plaintiffs, the only ones you've reviewed that you chose to go review were two articles about Mrs. Posner choosing to have an open casket for her son.
	Correct?
	That wasn't the reason why I reviewed the article.
	That's not what I'm asking you, Ms. Karpova.
	I'm asking you, of all the documents you reviewed about the plaintiffs before this deposition, the only two that you did review are articles that discuss Noah Posner's funeral having an open casket.
	Correct?
	They happen to mention that, but that's not the only thing they discussed.
	I'm not saying that.
	I understand what you're saying.
	Let's make it even broader than for you.
	The only two pieces of documentation that you have reviewed for this deposition about the plaintiffs are two articles, both of which discuss in the article Noah Posner's open casket funeral.
	Correct?
	Yes.
	Okay.
	Tell me any other information from those articles that you believe is relevant to this deposition today.
	I've already mentioned that the state of the physical body that the child had for the open casket ceremony describes that.
	Okay, so when it comes down to the documents that you reviewed for this deposition about the plaintiffs, the only information that you're really gleaning from this that's useful to this deposition has to concerns Noah Posner's open casket and the appearance of his body.
	Correct?
	It was useful to some of the points.
	I'm not asking what it's useful for.
	I'm asking you that of all the documents that you reviewed about the plaintiffs, the only piece of information that you have gleaned from those documents that is relevant to this deposition concerns Noah Posner's open casket funeral and the appearance of his body.
	Correct?
	Okay.
	These are the articles that I chosen to bring.
	So that is correct, right?
	Let's try it this way.
	You can't give me another piece of information out of either of those two articles that you believe is relevant to this deposition, right?
	Other than Noah Passett's open casket funeral and the appearance of his body.
	Correct.
	Those are the articles for, yes.
	And those are the only articles that you've reviewed about the plaintiffs in preparation for this deposition, correct?
	Yeah.
	Okay.
	Yes.
	Okay?
	Topic number one is the sourcing and research for the videos described in plaintiffs' petitions.
	When was the last time you watched those videos?
	But back up, made an assumption there.
	Have you watched the videos in plaintiff's petition?
	Ever in your history of InfoWars?
	I've watched some of them.
	Okay.
	So one thing we can say is that in preparation for this deposition, you didn't watch those videos.
	Correct?
	I'm sorry.
	Ms. Karpov, is that a difficult question for you to answer?
	Well, I've already answered some of the videos I've seen.
	Right, no, I understand that you have in your history at Infowars since 2015, you've probably on occasion seen some of these videos.
	I understand that.
	What I'm asking you is since the date you were told you were given this deposition in November and you were preparing for this deposition, you haven't watched any of these videos, right?
	I have not.
	here.
	do you have an idea Okay, that's done.
	All right.
	In preparing for to talk about the videos in Planner's Petition, do you have an idea sitting here right now how many there are?
	Roughly.
	How many are there?
	A couple of dozen.
	Okay.
	And did you ever compile a list of those for any reason?
	Not personally.
	Okay, not outside of the petition, in other words, right?
	What I'm asking you is, did you sit down and ever write them down or type them all out?
	No.
	Okay.
	When you say not personally, did somebody give you a list of the videos?
	Objection.
	To the extent that you've received any information in discussions with your attorneys, that is privileged.
	So if there's information that you that occurred outside your attorneys, you may answer that question.
	Otherwise, that information is privileged.
	I instruct you not to answer on that.
	Is there any information that you can disclose to me that is outside your attorney's instruction?
	No.
	Okay.
	I'm going to give you what I've marked as exhibit two.
	You recognize that, right?
	Can you repeat that?
	May I have a second to review it?
	bless you man.
	Thank you.
	Yes.
	You do recognize this document.
	I believe I've seen this before.
	You believe you've seen it before?
	I've seen a lot of documents.
	I understand that.
	Well, I mean, we know how many documents you've seen that were in this folder, right?
	Correct?
	Yes.
	Okay.
	So when you say a lot of documents, you mean exhibits 1A through 1I, right?
	Correct?
	I've seen some exhibits from my attorney, which is privilege.
	Okay, Mr. Varcova, at one point I asked you if these are the documents you reviewed for this deposition.
	You testified yesterday.
	And then we found out that you reviewed the plaintiff's petitions, or at least your attorney says you reviewed the plaintiff's petitions.
	So I asked you at that point, are there any other documents that I need to know about it?
	And you told me no.
	Are you now changing that testimony?
	I didn't understand your question because the topic for one of the topics for this deposition today includes the question about the documents produced by the company.
	Okay.
	So have you reviewed documents relating to your deposition today for that topic?
	Would that be between my attorney?
	If your attorney wants to instruct you that you are not going to tell me about the documents you reviewed before this deposition, he can do that.
	If you have that's you are not to discuss any conversations that you've had with attorneys.
	That is privileged information.
	Documents that you have reviewed in preparation for this is not, unless they are provided directly to you from your attorneys as far as correspondence.
	But if it's documents that were produced or anything like that that you reviewed, that is information he can you must tell you should tell him.
	So let's try this one more time.
	Can you tell me, in addition to the plaintiff's petition and exhibit 1A through 1I or 1J, can you tell me what documents you reviewed to prepare for your deposition today?
	I don't recall, I don't have a list of all the documents that I looked at.
	That's not great.
	Objection is a sidebar.
	So in other words, there are more documents than this, but these are just the ones that you decided to bring, correct?
	Objection form?
	I've already answered that question.
	I don't think you have, ma'am.
	And what I'm specifically asking you about, there are documents that you have reviewed prior to this deposition that you did not bring to this deposition.
	I did not think they were relevant to the specific points.
	Okay.
	So now let's get back to this.
	I thought you had just told me that there was a topic on here, a specific point on here, about the documents that have been produced in Discovery, that you reviewed documents that were relevant to that topic.
	Are you saying now that the documents you reviewed aren't relevant to that topic?
	or they are relevant to that topic.
	I did not think they were relevant to bring to this deposition.
	You thought it was relevant to bring an article about Noak Posner's open casket funeral, but you didn't think it was relevant to bring the very documents you reviewed to prepare for topic number six.
	Is that correct?
	I would say topic number four is I'm referring to.
	Okay, topic number four is the one about the company's documents?
	Yes.
	Okay.
	So let me ask that question again.
	You thought it was important to bring articles about Noak Posner's open casket funeral, but did not think you should bring documents that you reviewed relevant to topic number four, correct?
	Correct.
	Okay.
	And so sitting here today, taking your deposition, there's no way for me to know what you reviewed regarding topic number four, is there?
	Okay.
	Okay.
	right Do you understand my question?
	Yes, I understand your question.
	I would say the documents that I reviewed were sent to me by my attorney.
	Okay.
	How does that tell me whether I can or cannot know what they are?
	That doesn't help me answer that question, right?
	The question is, sitting here right now in this deposition room, where I'm here to ask you questions for the company, there's no way for me to know what those documents are.
	I would assume that you guys would have those documents.
	Okay, again, I'm going to caution you not to answer over me, okay?
	If you thought we had these documents, why did you bring those?
	Because these are the documents that I know you don't have.
	How do you know I don't have those?
	Because these are supplementary articles that I thought would be helpful for me in answering some of the points personally.
	Okay.
	these are not the documents that have to do with any official legal documents.
	Okay, so in terms of, let's just make sure we understand, we now know that there are documents that you have reviewed that are not here today that I don't know what they are regarding topic number four.
	Are there any other topics where there are documents that you reviewed that I don't have here today?
	No.
	Okay.
	Regarding the documents that you reviewed on topic number four, was that during your hour that you prepared for the deposition on your own?
	Or did you review those documents during your meetings with counsel?
	Okay.
	So, in other words, we had your couple of hours with Mr. Reeves, day before yesterday, your couple of hours with Mr. Andonzi yesterday, and then about your hour on your own.
	And during those times are the times in which you reviewed documents that were relevant to topic number four.
	Yes.
	Okay.
	How many documents?
	I don't have the count.
	Exact count.
	I didn't count them.
	Okay.
	You can understand how that's not helpful to me, right?
	don't have any idea of the universe or size of documents that you would do.
	So would you be able to Would the documents fit in this folder?
	Objection form.
	Would they all fit in here, do you think?
	I think so.
	Okay.
	So you wouldn't need, say, like this to hold all of them off.
	You could hold them all, not in a banker's box like this, but in a manila folder like this, correct?
	Is that accurate?
	Yes.
	Now surely you remember some of those documents, right?
	I'm not sure.
	Okay, so the documents you reviewed for topic number four, sitting here today, you can't identify any of them for me.
	I don't want to make a mistake.
	Not off the top of my head.
	Okay.
	So in other words, whatever's in those documents, because you can't even identify them, whatever's in them is not going to be relevant to your testimony here today.
	You're not going to be giving me information from those documents, I take it.
	projection form.
	correct Well, the information, the relevant information would be pertaining to question two, topic number four.
	Right.
	But if you can't even remember what the documents are, you're not going to be able to tell me what's in them, right?
	projection form Ms. Carpova, is there something difficult to understand about that?
	Projection form.
	I don't answer the question.
	The documents are pertaining to the discovery requests that you guys have requested.
	Right?
	So you should know what's in them.
	I know what's in them.
	I know.
	Trust me, I do.
	Right.
	I want to know if you do.
	So sitting here today, you can't identify any of the documents you reviewed.
	So you're not going to, none of your testimony today is going to be based on those documents, correct?
	Not off top of my head.
	Okay.
	So that's what I'm saying.
	Right now, you're giving testimony.
	You understand that?
	Yes.
	It's coming off the top of your head, right?
	You understand that?
	Yes.
	There's not, it's somebody with a teleprompter back there, right?
	Correct.
	Okay.
	Everything that's coming right now is coming right out of your brain.
	Yes.
	And since you cannot tell me what those documents are or what they say off the top of your head, that's not going to be part of your testimony today, correct?
	Objection form.
	Well, I would say not specifically what's in those documents, because there's no way I can remember the amount of documents and what's in them.
	Right, and they're not here today, right?
	I did not print them up, no.
	Right, so they're not going to be part of your testimony, right?
	ejection form.
	Correct?
	I'm sorry.
	We're going to be here a long day today.
	No, I need to go a little bit longer.
	Okay.
	I think I got what I needed from that.
	I don't need you to answer that question.
	Okay, can you look at exhibit two for me?
	And can you go to paragraph 14?
	Do you see that paragraph 14 identifies a January 27th, 2013 video entitled, Why People Think Sandy Hook is a Hoax?
	Yes.
	Okay.
	You're familiar with the claims made in that video, right?
	projection form.
	I don't recall the exact video.
	And so sitting here today, you're not familiar with the claims made in that video?
	No.
	Okay.
	So sitting here today, you couldn't tell me who the sources were for the claims that you don't know, correct?
	From I would assume they were either Mr. Halbig or Mr. Pachenek, because these were the two sources that were that have pertained to the videos.
	Okay.
	First of all, I'm going to tell you, Ms. Karpova, do not make assumptions for me.
	So here's the thing that I need you to understand.
	You're here for testifying for the corporation.
	You understand that?
	There's sometimes questions I'm going to ask you personally, what you personally think or know.
	But when I ask you questions about the corporation when you're here testifying, there's basically three answers that you can have, which is, I know, and here's the answer.
	The corporation knows this.
	The corporation does not know this.
	Or I, Daria Karpova, do not know if the corporation knows or does not know.
	You understand those three types of answers?
	Okay.
	So in this particular situation, you don't know what claims are made in that video, correct?
	I don't.
	Okay.
	And you are telling me you're making this assumption that this must have something to do with Wolfgang Haubig or Dr. Steve Pachenik.
	But do you know if either of those individuals had ever been on InfoWars by 2013?
	Do you know?
	Not for a fact.
	I do not know.
	I could find that information if that was a question that I knew I had to prepare for.
	Well, we asked you for the sourcing.
	I mean, look at topic number one.
	You see what topic number one says?
	Right.
	This question is very broad and hard to understand what is even wanted.
	So I did my best preparing in good faith, preparing to answer these topics.
	Well, it sounds like your attorney should have objected to it if it was overbroad in bad faith.
	I get that.
	Do you realize that?
	You cannot object like that, Mark.
	So if you wouldn't, you don't need to tell her what her attorney should or shouldn't have done.
	Why don't you just go ahead and answer your question?
	Well, she wants to have legal arguments with me today.
	We're going to discuss what those legal arguments are.
	I'm not having legal arguments with you.
	Just ask your question.
	Brad, don't interrupt my testimony.
	Don't harass the witness.
	Ms. Karpova, did you just assert for me that that topic was too broad to be answered correctly?
	Is that what you told me?
	When it comes to, yes, for all intents and purposes, yes.
	So when I ask you, I want to know the sourcing for a video at InfoWars, you can't figure that out?
	That's too broad?
	Sourcing can mean a lot of different things.
	If you be more specifically what you mean by that.
	I think you know what it means.
	Don't you?
	Right, what a source is.
	What do you think a source means?
	Where you get a particular information.
	Right, and you understand that claims were made in these videos, right, about Sandy Hook.
	And they came from somewhere, right?
	They came from Alex Jones.
	So Alex Jones is the source for the information in these videos.
	It depends.
	It does.
	That's why I brought you here today.
	Right?
	But for these videos, where Wolfgang Haubig or Dr. Steve Pachinik have never said anything about Sandy Hook until at least 2014, you don't know what the sources for this video are, do you?
	I would say no.
	Thank you.
	There's a claim made in this video.
	I don't know how...
	Can we review the video right now?
	No, I'm not going to play a two-hour video for you right now.
	No.
	But you expect me to know what's going on in every video.
	I do.
	I do, Ms. Karpova.
	And I expected Rob Dew to do the same thing when he showed up to deposition to talk about sourcing and research.
	And he didn't do that.
	Twice.
	Object to the sidebar.
	I want to make sure this witness understands what she's here to do today and that my question is what they are.
	I do expect you to have done your homework and know what was in those videos.
	Yes, ma'am.
	I do.
	So for instance, in this video, there's a claim made about Charles Jayco.
	Do you know who he is?
	No.
	Okay.
	So you wouldn't be able to talk to me anyway about the claims made about Charles Jayco in the January 27, 2013 video.
	No.
	Okay.
	Can you tell me what employees were involved in researching that video?
	Who came up with those claims in that video?
	I have a list of people who were working on that day.
	From that list, I could tell you who might have been in production for that day.
	So the best we can tell you is, so the best we can figure out is who might have been working in the production side at that date, correct?
	Yes.
	Okay.
	Have you talked to any of those people for your deposition today?
	No.
	Okay.
	So in other words, if you had a list of people who were working that day, and you could, it would be within your power to do so, to walk down to wherever they work in your building and say, hey, this video right here from January 27th, 2013, when you were working that day, did you have anything to do with any of these claims made in that video?
	You could do that, couldn't you?
	Some of those people on the list do not work for the company anymore.
	Okay, but some of them do, don't they?
	Some do.
	Yeah, and you could do that, couldn't you?
	It depends on the video.
	I'm not sure about this video and who specifically worked for that day.
	Sure, but for any of the videos that we're going to talk about today, for any of the videos in Planet's petition, you had a list of who was working at Infowars at that time, correct?
	Yes.
	And you could have interviewed those employees, correct?
	I could have.
	And you didn't, correct?
	Correct.
	Okay.
	Can you go to paragraph 16 for me?
	Actually, hold on.
	Before we go into this next video, one of the things that you, I want to cover some of the things that we talked about in this first video to see if they apply for every video.
	Because I think we might be able to save some time, right?
	And you can tell me if we can or we can't.
	But from what I understand about that first video is A, you didn't watch it, and B, you didn't talk to any of the employees involved in making it.
	That's correct, right?
	Yes.
	Okay.
	Is that true for all the videos?
	Yes.
	Okay.
	And in terms of understanding what claims were made in the videos, is that the same that you don't know what claims were made in the videos for all the videos?
	Correct.
	Okay.
	Let's look at paragraph 16 for me.
	And that one talks about an April 9th, 2013 video called Obama Gun Grabbing Psyop Speech of Evil, correct?
	Correct.
	Okay.
	So in this video, for instance, that petition in front of you says, alleges, when I say that the plaintiff alleges something in a petition, you understand that that is my clients saying that this happened.
	And so part of the whole court process is to figure out whether any of that is true, right?
	You get that?
	Okay.
	So when I say that they're alleging this, I'm not going to tell you that what is being said here is fact.
	You know, that may be for you to decide, right?
	But when I'm talking about allegations, I just wanted you to understand what I meant by that.
	But here in paragraph 16, talking about that video, this plaintiff, this petition alleges that Mr. Jones said that those recent mass shootings were a government operation and that Sandy Hook was an inside job.
	You see where it alleges that, correct?
	Sitting here today, can you tell me whether that's true or not?
	Objection 4.
	Can you rephrase that, please, Mark?
	I'm not sure what you're going to do.
	So the plaintiffs allege that Mr. Jones, in that video, told his viewers that the recent mass shootings were a government operation and that Sandy Hook was an inside job.
	That's what the plaintiffs allege happened.
	Is that true?
	Is that what he said in that video?
	Or can you tell me?
	If I had the video in front of me, I'd be able to tell you.
	Or if you had watched the video prior to this deposition and looked into the researching and sourcing of it, you could tell me, correct?
	Is that correct?
	If that was something that's among the topics, yes, I would have.
	Sure.
	But because the topic was so broad, There's no way I could have known that I had to go point by point in this original petition.
	Did you raise that up did you raise that issue with your attorneys?
	Did you bring to them to the attention, I can't do this?
	Objection, don't talk to anything about you talking with your attorneys about.
	Okay.
	Did you express to anybody at the company, I can't do this?
	I can't do what?
	answer topic number one.
	Thank you.
	I'm answering it to the best of my ability.
	Okay, but you've told me it can't be answered, correct?
	It's too broad.
	There's no way you can do this, right?
	Is that correct or not correct?
	Well, if we are going point by point as you are right now, then correct.
	Yeah, so, I mean, in your mind, when the plaintiffs requested a representative of the company to talk about the sourcing and the research of the videos that make claims in plaintiff's petition, did you think they'd be uninterested in the claims made in the videos?
	It would, it would, it's pretty much impossible to figure out on that particular day of the video what was the sourcing, that we don't have that kind of documentation for every show, for every video.
	But you didn't go ask any of the employees involved, did you?
	Correct?
	Correct.
	Okay.
	Go to paragraph 17 for him.
	Do you see where there it talks about April 16th, 2013 video entitled Shadow Government Strikes Again?
	Correct?
	Yes.
	Okay.
	And again, just like our prior answers, you don't know what employee researched the information to create the claims in this video, correct?
	Correct?
	Correct.
	Okay.
	There's a quote there in the petition that's being alleged.
	It says, they staged Sandy Hook.
	The evidence is just overwhelming, and that's why I'm so desperate and freaked out.
	Do you know if that's an accurate quote for Mr. Jones?
	I don't know for a fact, no.
	Okay.
	So it's fair to say when you reviewed the petitions for these plaintiffs' videos and they had quotations from Mr. Jones, you didn't go anything to try to verify those quotations, correct?
	Correct.
	Okay.
	The company now admits.
	Actually, let me go back for a second.
	When we have a statement like this from Mr. Jones, did you ask Mr. Jones about any of these statements?
	No.
	And prior to taking this deposition, from the time you learned in November that you were going to be giving this deposition to the present day, have you talked to Mr. Jones about where your testimony is going to be in this room?
	No.
	the company now admits You see that the evidence is just overwhelming?
	Yes.
	The company now admits there was not overwhelming evidence in April 2013 that Sandy Hook, that the government staged Sandy Hooker.
	Projection form.
	Company admits that now?
	Projection form.
	To the best of our knowledge.
	To the best of your knowledge, today, sitting here today, the company, to the best of its knowledge, admits there was not overwhelming evidence in 2013.
	Projection form.
	Correct?
	To the best of our knowledge, at that time, we thought that there wasn't overwhelming evidence based on the expert witnesses that we were interviewing.
	Okay, who are those?
	Mr. Halbig and Mr. Pachenek.
	Ma'am, neither of them had been on the show by 2013.
	So can you tell me who the experts actually were for this video?
	If it wasn't a direct interview, it must have been information coming from them.
	It must have been.
	You're certain that the information in this video came from you.
	I wouldn't be able to say for sure, but I know they were the two expert witnesses that were the key people where Alex had concluded, you know, made his conclusions from.
	Okay, ma'am, I just want you to understand before we answer any more questions that Wolfgang Haubig didn't even start investigating San Diego until 2014.
	And so when I have you here under oath saying that this must come from Wolfgang Haubig, I'm a little concerned.
	So I just want to stop and make sure that we're not making assumptions, that we're answering the questions based on the knowledge that we know.
	And the reality is that when it comes to whether the evidence was overwhelming, one, you don't know what evidence is even being talked about in that statement, do you?
	I don't.
	Okay.
	Two, you don't know where any of that alleged evidence came from, do you?
	No, it's been a long time ago.
	Correct.
	That's why I'm taking this deposition.
	And sitting here today, you can't do it, can you?
	You cannot tell me what evidence is being talked about in paragraph 17.
	No.
	Okay.
	Mark, let's go ahead and take break.
	We've been going for a minute.
	I got one more question on this video.
	Regardless of what the company thought in 2013, sitting here today, the company will now admit there was not overwhelming evidence in 2013 that Stany Hook was staged.
	Correct?
	Objection form.
	I think I already answered that question.
	I think what you had told me, and let me make sure I understand your answer, was that at the time you believed there was evidence.
	At the time the company believed there was evidence.
	Correct.
	Today, though, today, sitting here right now, with the benefit of everything that's happened, with the benefit of everything that's happened in this suit, will the company now admit today there was not overwhelming evidence that the government staged San Diego in 2013?
	The company believed at that time that there was.
	Now the company does not believe.
	Right, so now the company.
	I'm sorry, go ahead and finish your answer.
	Sorry.
	Yeah.
	Okay, but now, I'm just trying to confirm, because I think I understand what your answer means.
	But now, today, the company admits there was not overwhelming evidence.
	Correct.
	Okay.
	All right, we can take a break.
	Time is 12.03 p.m.
	We are off the record.
	All right, exactly.
	Okay, time is 12.28 p.m.
	We are on.
	All right.
	I just wanted to let you know I had taken exhibits 1A through 1J.
	They're back in this folder.
	If you need them at any time, please feel free to pull them out.
	I want to show you right now what I'm going to mark as exhibit 3.
	Have you seen this document before?
	I do not remember seeing that.
	Okay.
	This was produced to us without a base number on it.
	Back up.
	I think you understand.
	Okay.
	I'm sorry.
	One of the topics you were supposed to prepare for was documents produced by the company?
	Correct?
	Okay, so you understand that the company has produced documents at several different points over the past three years?
	Correct.
	Okay.
	You understand that the first time that the company produced documents back in 2018, they didn't have any numbers on the bottom here.
	Did you know that?
	I didn't.
	Okay.
	Have you ever seen documents reviewing in this case that say FSSTX and a long number at the end of them on the bottom?
	Yes.
	Okay.
	This document doesn't have anything like that, okay?
	Because that's the way it was produced.
	Can you look at this and tell me whether this is an email that came from your files?
	Is there any way for you to do that?
	Can you specify from my files?
	I'm sorry.
	When I said your files, I mean the companies.
	Is this a free speech systems email?
	It appears so.
	Okay, so Nico, that's a free speech systems employee?
	Yes.
	He was frequently a liaison of Mr. Halbig, correct?
	That's what, that's, yes, that's my understanding.
	Okay.
	This email is dated February 25th, 2014, correct?
	Yes.
	And this is Mr. Halbig sending his resume and bio to InfoWars?
	It appears so, yes.
	Okay.
	And Mr. Haubig says, Nico, here is some information on me that you guys can check out, Wolfgang, and he gives his phone number, correct?
	Yes.
	Okay.
	Do you have any reason to believe that Infowars had any dealings with Mr. Halbig before this date?
	I don't know for sure.
	Okay.
	So let me make sure I ask this in a couple of ways.
	First of all, when you give that answer, when you say, I don't know for sure, that's based on your personal knowledge, Dari Karpova, correct?
	That's what you're saying?
	I'm saying that I think maybe let me try to help clarify because I think it maybe helped with your answer.
	What I'm trying to say is when you give the answer of, I don't have any reason to believe that we've had, I don't have any basis to say that InfoWars had contact with Mr. Haubig before that date.
	Is that based on just your own personal knowledge or is that based on information somebody else has given you?
	Objection informed.
	That wasn't testimony given.
	As far as the company knows, if there wasn't a record produced before this date, then we don't know if there was communication with Halbig before this date or not.
	Okay.
	I want to also, just before we move on to something else, I want to clear up.
	I made a representation to you, and I don't think it was quite accurate.
	We had talked about Wolfgang Haubig and when he appeared on the show, and I made a representation about that, and about him being on in 2014.
	But I also made a representation about Dr. Steve Pachenek, that at the time I was speaking, I believe he hadn't been on the show until 2014.
	We did a little checking, and it appears from what we can figure out that Dr. Steve did something on Sandy Hook on InfoWars in March of 2013.
	We don't have that video, but I just want to represent to you that what I said to you before probably isn't accurate because it looks like now there's a video out there that we don't know about.
	That was in March of 2013.
	But in terms of, and we were talking about a January 2013 video.
	But just for going forward, I want you to understand that we, I don't want to represent to you that he wasn't there before March 2013.
	Do you understand what I'm saying?
	I understand.
	Okay.
	All right.
	Thank you.
	Okay.
	Can you go to paragraph 20 for me in exhibit two?
	Okay, and exhibit 2 being Mr. Haslin's petition in paragraph 20 talks about a March 14th, 2014 video entitled Sandy Hook False Narratives versus the Reality.
	Do you see where it talks about that?
	Yes.
	Okay.
	First, I want to go through some of these videos.
	We had talked about one thing, is it true that one thing you can't do here for me today is for each of these videos in this petition, actually, no, let's just go through them a little bit this way.
	For instance, in this video, March 14th, 2014, you would not be able to tell me the specific claims that were made in that video, right?
	As far as the quotes specifically written here or anything else?
	No, anything that was claimed about Sandy Hook.
	Do you know anything?
	what was claimed about Sandy Hook in that video?
	Well, to the company's understanding, the quotes that are presented in this petition appear to be accurate.
	Okay.
	Beyond what's quoted in this petition sitting here today, you can't tell me about anything else that was claimed in that video.
	No.
	Okay.
	Well, let's talk about what we do at least now.
	You see a quote there that says, we've clearly got people where it's actors playing different parts of different people.
	Do you see where it says that?
	Yes.
	Okay.
	The company sitting here today agrees that was a ridiculous thing to say.
	Objection form.
	Correct?
	At the time of the event, with all the information that was coming in, as well as Alex's previous research, as he's a history buff of the false flags that we discussed earlier, it is company's understanding that he was entitled to his commentary and opinions in this matter.
	Okay, so in other words, the company does not agree.
	It was ridiculous to say we've clearly got people where it's actors playing different parts of different people.
	Correct?
	projection form.
	Again, this was Alex's commentary.
	I'm not sure if the company can agree or not.
	It's not a person.
	It's not a human being that can agree or not.
	So as far as this quote from Alex Jones at the time, I already answered that question.
	Okay, well, you're here as a corporate representative today, correct?
	Correct?
	Correct.
	You've been asked to give testimony in response to my questions today, correct?
	Correct.
	Speaking from what the company knows or does not know.
	Correct.
	Okay.
	The company has opinions on the people who works for it, correct?
	Objection form, can you please point out to where that's a topic in your deposition notice?
	That's not a topic of my deposition notice, no.
	Okay.
	Well, then she's not here to test it.
	She's here to testify in the corporate representative on the notice topics.
	If you're asking questions outside of that, she may certainly answer it, but that is not on behalf of the company.
	I can give you a running objection to the entire if you'd like to do that, that's great.
	Yeah, for every question that I ask, you don't have to stop anymore to do that.
	Okay, I'm not trying to interrupt you.
	No, I understand.
	I understand you're trying to preserve your record, but I know we're going to be here forever if we don't do stuff like that.
	Okay, let's do that.
	That's fine.
	All right.
	so does let's actually let's let me let me with all that question and i'll ask it this way um
	Do you have any information for me here sitting today what the source of the information it was that allowed Mr. Jones to conclude that we've clearly got people playing where he was able to conclude we've clearly got people where it's actors playing different parts of different people a lot of the information that Alex had commentary upon came from mainstream media videos articles
	There's no way to have access to every single piece of that information at this point.
	It would be hard, even the day before, to have access to whatever the sourcing was for Alex at that particular time.
	It's true that you didn't do anything to try to figure out that, correct?
	Based on my
	on my knowledge of the workflow day-to-day workflow that we've had for years and years I can make an educated guess because I've been in this position and I can tell you of the typical sourcing that is done for each show Alex's commentary upon it okay so in order and in answer to my question of you didn't In preparation for this deposition,
	you didn't do anything to try to figure that out in terms of what the source was for that statement.
	That's correct.
	Not for this specific quote.
	I can tell you the general sourcing that we have that we utilize in preparation for the shows as well as during the shows.
	That's my expertise as a day-to-day person who's involved in production.
	Okay.
	You can't tell me.
	Can you tell me what actors?
	Can you tell me what people were being alleged to be actors?
	Can you tell me what people were saying?
	Based on this quote, there's no way to tell.
	And based on what you, and you have done nothing in preparation from this deposition to determine that, correct?
	That wasn't part of the questions that I was asked.
	I'm not prepared for.
	I'm not asking what you were or were not asked to do.
	We'll figure that out.
	I want to know factually, you, when it comes to trying to figure out who he's even talking about here in terms of actors playing different parts of different people, you didn't do anything to figure that out, correct?
	Correct.
	You didn't ask Alex about this statement or this video, correct?
	Correct.
	You don't know any of the employees who may have researched and come up with this idea that there were actors playing different parts of different people, do you?
	To me, this doesn't appear as a research that's coming for a particular employee that's feeding Alex any information.
	This appears to me as Alex's opinions and commentary on the situation that he has in front of him that he's watching based on the mainstream news reporting, other sources that he might have had at that time.
	Okay, but you're guessing.
	Educated guess, yes.
	So there's two situations that could happen when Alex Jones is going to say something like this on air.
	Situation one is that some employee has found something online, some video, some article, something, that he thinks shows that there's actors playing different parts of different people.
	And he takes that to Alex, and Alex goes and puts that on the air.
	And situation two is Alex Jones himself saw something that made him arrive at this conclusion.
	One of those two things is almost certainly what happened, correct?
	Not necessarily.
	It could be that one of those things happened, but number one, that you mentioned, is unlikely, in my opinion, just from working for years in the same environment and knowing the workflow.
	Again, Alex's commentary could have been, I'm not sure what his commentary was based on.
	It's just hard to say in this particular case.
	Okay.
	Do you know who was working on this day in the production department?
	I have a list of people who were working on that day, and I can infer potentially who were working in production.
	Even that is not for sure because at any time a person could have or could have not been there.
	Okay.
	If you needed to determine, if I asked you right now who was there, would you need to look at a document to do that to figure out who was there?
	The document is in my email, yes.
	Okay, and that's not here on this table, is it?
	No.
	Thank you.
	You can go to paragraph 23 for me.
	You see where it talks about a May 13th, 2014 video entitled Bombshell Sandy Hook Massacre was a DHS illusion, says school safety expert.
	Yes.
	Okay, that school safety expert, that's Wolfgang Haupt.
	Yes.
	He's the source for This video?
	It appears so.
	Okay.
	Are you familiar with claims made in this video about CNN and a Gulf War broadcast involving a blue screen?
	Say it again, please.
	Are you aware of claims made in this video about CNN in the first Gulf War and a blue screen?
	Yes, I recall, I recall that incident.
	Okay, and you tell me what you understand that allegation about CNN, the first Gulf War and a blue screen, to be.
	The allegation is that Anderson Cooper used a green screen to report.
	Okay, do you think that Anderson Cooper was at the first Gulf War?
	No.
	Okay, so that's probably not what that is, right?
	That's the only thing that I can recall having to do with CNN or reporters.
	Okay, so any discussion about what CNN was doing during the Gulf War in Iraq in terms of a blue screen in that video is something that you do not understand the researching or sourcing for, correct?
	I do not recall.
	Okay.
	Can you go to paragraph 25?
	Do you see in paragraph 25 it discussing a September 25th, 2014 video entitled Connecticut PD has FBI falsify crime statistics, correct?
	Yes.
	Okay.
	First of all, are you familiar with the claim that InfoWars has made that the FBI either falsified crime statistics or admitted that nobody died at Sandy Oak?
	Are you familiar with those claims?
	As far as it's quoted here in this paragraph, the company believes that to be the case.
	No, what I'm asking you, Ms. Karpova, is based on the title and then this talking about FBI falsified crime statistics, are you personally right now familiar with that claim made by InfoWars?
	Personally, I'm not.
	Okay.
	Did you talk to anybody about that claim?
	No.
	Okay.
	So this video and its title, you don't really understand where that comes from, right?
	No.
	Okay.
	So you wouldn't know what employee came up with this idea that the FBI falsified crime statistics.
	There wouldn't be an employee that came up with that specific idea.
	That's a show title that's based on the information that's discussed in the video.
	That's how we title the videos.
	Do you think this allegation...
	You don't know if this allegation came from inside or outside the company, do you?
	It came from either that interview with Mr. Haldig that was included in this video or a source that Alex Jones had.
	Have you ever seen the article about this, about FBI says nobody killed at Sandy Hook?
	I might have, I don't remember now.
	Okay, it's an InfoWars article?
	I don't remember.
	Did you know it's the third most popular InfoWars article ever?
	No.
	Okay, and that's not, so none of those claims are something that you can testify about today.
	Objection form?
	I don't know if you have a running objection, but again, that's not part of the notice deposition.
	Which claim specifically?
	I'm sorry, are you objecting that her testifying about not being able to talk about the claim made in this video is not part of the artist and what I'm talking about?
	About the article.
	Ah, okay.
	Video.
	Later.
	so So do you see in that paragraph it's talking about photos of kids that are alive that they said died?
	Yes, I see that paragraph.
	Do you know what photo they're talking about?
	From what I can infer, it was probably a photo that or photos that were going around that people were talking about online?
	I'm sure, but you have no idea what they are I mean you're guessing right now right to the best of my knowledge there's no way to tell what they were you have no personal knowledge about this correct well there's no way to go back to that video because we don't keep those kinds of records of every show of any show you didn't talk to any of the employees did you it's hard to tell who worked on that day we don't have record of that either you know who wrote the article that went along with this video don't you no no idea you'd
	able to figure that out if you wanted to though couldn't you?
	If that article had a name of the author it would be there yes.
	Okay so we don't know what employee was responsible for bringing this information to the company's attention whether it was Alex Jones or another employee correct?
	Correct.
	Okay do you know if this has to do with the Super Bowl picture?
	Do you know what I mean when I say Super Bowl picture?
	I think can you be more specific?
	Yeah you know about Wolfgang Haubeck sending the company a Super Bowl picture?
	I do not know.
	Okay give me tab 24.
	Yeah it's in the first one.
	And while he's looking I may have already asked you this but on September 25th 2014 for that video on that day you don't know what employees were working that day to be involved in making that video?
	I can in I can potentially infer who were active during the production of this video based on our record of employed personnel on that day but I couldn't tell you specifically if they were in the room at that specific moment because we don't keep records of things like that.
	Okay so can you tell me who was working that day?
	If I can have access to my email?
	Never mind.
	Okay so let me just make sure I have this for the record.
	There's nothing on the table right now that's going to be able to help you answer the question of who's in that room that day making that video?
	Because we don't have keep track of that information correct?
	Wait no from what I understand you do keep track of that information and if you had access to it you could answer it but you don't have access to it as you sit in that chair right now?
	No I said I can infer from a list of employees who might have been there at that particular time.
	Okay and then from that list you could perhaps go interview those employees correct?
	Yes.
	Okay and you didn't do that correct?
	Okay.
	I think we're on four.
	Can you tell me what the last exhibit this is here?
	There's three.
	I'm going to show you what I've marked as exhibit four.
	Can you take a quick look at that real quick and then let me know if you've seen it before?
	Yes.
	you have seen this document before i have not seen i don't recall seeing that specifically like i said i've you i've reviewed a lot of documents all right so i'm just trying to make sure have you have you or have you seen this document i don't recall um Reading this particular exchange with Mr. Halbig and Nico.
	Okay.
	I'm going to start at the bottom here.
	And this is this document that I'm reading from you is marked FSS Texas, FSSTX-039429.
	And you will see at the bottom email, Mr. Halbig writes to Nico.
	Do you know who Nathaniel Fokes is, the person he copies?
	No.
	Okay.
	Nico, though, is an Infowars employee.
	Yes.
	What's his job title at this time?
	He's not employed by PreSpeci.
	At this time?
	Oh, at this time?
	He would be the head producer.
	Nico's no longer employed by InfoWars?
	Correct.
	Does Infowars possess his last known contact information?
	Yes.
	Okay.
	Mr. Halbig in this email states: Nico, the picture of the Sandy Hook Elementary School choir is one of the keys.
	Other pictures are great for discussion.
	These are the CT crime pictures, Wolf.
	Have I read that correctly?
	Yes.
	Okay.
	Nico responds and says, Got the Super Bowl picture.
	Thank you for sending.
	We will be calling you on Skype at 1 p.m. Eastern Time.
	How long will you be available for the interview today?
	Thanks, Nico.
	Have I read that correctly?
	Yes.
	Okay.
	And then the final email says, as long as you and Alex can put up with me, Wolfgang.
	Read that correctly?
	Yes.
	Okay.
	Does this help you refresh your memory about what the Super Bowl picture is?
	Are you asking me personally right now?
	If you can answer either on behalf of the company or you can answer on behalf of yourself, let me know.
	Either way.
	If the Super Bowl picture wasn't produced by the company, then we don't have a record of the picture.
	Personally, I over the years, I've seen, I might have seen a Super Bowl picture.
	Okay, let's find out.
	It's out of 25.
	It's out of 25.
	All right, I'm going to show you a market as Exhibit 5.
	You can take a look at that picture for me.
	Thank you.
	Do you see at the bottom corner where it says FSSTX.0476?
	Yes.
	Okay.
	Have you seen this picture before?
	Personally, I have not.
	Okay.
	This was a document, though.
	You can tell from the number at the bottom that was produced by the company, correct?
	Yes.
	Okay.
	Can you read what it says at the very top of the picture, the white text?
	Ten Sandy Hoe children found alive and well.
	Okay.
	Does the company now admit that this picture is outrageous?
	projection form.
	This picture was produced by a guest we've had on the show who thought it was relevant material.
	Okay.
	We don't tell our guest what to say or what not to say.
	Now, this is something that Nico thanked Mr. Hobbit for, correct?
	Thank you.
	Sure, it appears so.
	Okay.
	Does the company see when the company, in its editorial discussions, is discussing things like this, right?
	When you have employees of the company discussing a picture of a Super Bowl choir, which is being contended to be the pictures of dead children who are actually alive, does the company have an opinion sitting here today about whether those editorial discussions were responsible or not?
	objection form The expert guest that we had on the show, Wolfgang Halbeck, thought that it was an appropriate supplementary material to bring to the interview.
	With all the information that we had on Wolfgang Halbeg regarding his extensive bio and knowledge in the subject matter that he was going to be discussing, we had no reason to believe that this would be an inappropriate picture.
	If that's something he wanted to bring to the interview and talk about, he's allowed to do that.
	we allow that with every guest When Infowars has a source, like Mr. Halbig is going to bring him on, and Alex Jones is going to repeat the things it says.
	Let me back up.
	You'll agree with me.
	Alex Jones has frequently repeated the things Mr. Halbeck has claimed without Mr. Haubeck even being on the show.
	Right?
	Mr. Halbeck was a subject matter expert.
	So Alex would defer to his opinion.
	Sure.
	And one thing that you agree with me that the company, when having its editorial discussions on Sandy Hook, needs to do is to continually assess and reassess the credibility of the experts it's relying on, correct?
	We did not, we do not have editorial discussions regarding Sandy Hook, nor did we ever have them.
	And to the best of our knowledge, this was the foremost expert on the matter of school shooting, school safety at the time.
	And we did our best to bring the top person in the business to state his opinion on the subject matter.
	Who vetted Wolfgang Haubig's bio and background?
	Who did that?
	This is specifically vetted.
	I'm not sure who vetted.
	Okay.
	Since Nico was the producer, he probably was the person who vetted.
	All right, so when InfoWars was assessing Wolfgang Haubig's credibility and whether he should be somebody who should be relied on to an expert, one of the pieces of information that they had in order to make that credibility assessment was this picture of a Super Bowl choir that Wolfgang Haubeg was contending was actually secretly the murdered children of Sandy Hook who aren't actually killed.
	That's one of the things that InfoWars had in its possession to assess his credibility, correct?
	I wouldn't say so.
	From this exchange, it appears that this is a supplementary material that Wolfgang wanted to have for the interview.
	His bio, his credentials, is an entirely different thing from the materials that he wants to bring to talk about.
	Well, what I'm saying is if there's an expert and you've been relying on him, guy supposed to be a school safety shooting expert, whatever it is, right, and you're relying on him, and then just hypothetically, that person just starts saying absolutely crazy things.
	And it's pretty clear they're going off their rocker.
	Maybe they were even credible at one time, but suddenly they start saying a bunch of crazy things.
	To the company, when it's deciding whether to put stuff on about Sandy Hook, it needs to, it should consider whether what the things its expert is saying are crazy, correct?
	Well, if he's the expert on the subject matter and who knows a lot more on the subject than any of us working at Free Speech Systems, it would Be reasonable to believe that we would want to listen or consider what the information that he's bringing.
	What exactly in Wolfgang Haubig's history and expertise makes him an expert that you should defer to on whether this picture of the Super Bowl choir is actually pictures of children who were murdered?
	Well, that's a good question.
	That's why I brought his bio, which I would like to read.
	You just like to read it into the record or what?
	Yes.
	And the reason that we brought him on the show is for his long credential of being an expert on school shootings, on school safety.
	Does he have credentials in the photographic forensic analysis of potential murdered children who are actually being used as crisis actors?
	I don't know that specific credentials.
	Okay.
	You personally, sitting here, you looking at this.
	This is crazy, right?
	I'm not here to talk about my personal opinion.
	I'm asking you, though.
	Yeah, you are.
	Objection form.
	Yeah, this is crazy, right?
	Objection form.
	Don't answer that question.
	Yeah, are you instructed or not to answer?
	This was produced by a rational, sane human being.
	That's not what you asked for the first time.
	Let me do that question.
	Will you admit, sitting here right now, this was not created by a rational, sane human being?
	Or are you going to tell this jury that this is created by a rational, sane human being?
	I don't have an opinion, a personal opinion on it.
	So you see this picture, and then trying to determine whether it was created by a sane, rational human being, you look at it and go, I have no strong feelings either way.
	Correct?
	I'm not a psychiatric medical expert to determine who is sane and who isn't.
	Is this the kind of picture that if somebody gave to you that you would say, this is a person that I think is trustworthy and credible?
	Is that something you would say?
	It depends where I'm at, what information I have.
	We're talking the date 2015 where Wolfgang Haubig came on the show.
	Judging from this conversation, I don't know what Nico looked at or knew about what Wolfgang was going to talk about or bring on the show.
	So if from the workflow that we have, if a guest sends me material that they want to discuss and this guest has long credentials in the subject matter that they want to talk about, then I would thank them for sending me the information, just like Nico did.
	I don't see anything wrong with that.
	You would, if somebody sent you this while you were doing reporting, you would thank them for it?
	I don't know.
	It depends on the circumstances.
	Okay, well, the circumstances.
	It wasn't there when Nico was having this exchange, what information he had at that time.
	Well, I'm asking you, what if you had this information?
	A picture that says at the top, 10 Sandy Hook children found alive and well, and then the Super Bowl choir in front of millions of people.
	Would you look at that and go, man, I'm glad that he sent me that?
	Personally, I would rather think that those kids were alive than having because the tragedy of kids being murdered for no reason,
	the innocence of those children who didn't deserve that kind of fate, I would hold out hope to the last bit of my soul hoping and praying that that picture was that that was something that be possible for those kids to be alive.
	So if you think about it, from your point of view, if you think about it, if the parents, if my clients saw this picture, they should give them a lot of hope, right?
	They should react really positively to this with a lot of hope inside, right?
	Objection form.
	Is that what you're saying?
	I'm not those parents.
	I'm looking at it as an outsider.
	And I would much rather, and I don't know a person with a heart who'd rather think, who would rather believe that the kids are dead versus that the kids might be alive.
	I would say it's reasonable for a person with a heart to have that sort of optimism as I'm sure Alex wanted to believe that those kids, if there was any possibility that the kids were not dead, then he was going to grab onto it because that's a much better proposition to have in your heart and mind than to realize that they were.
	So, Alex Jones, according to how the company views things in terms of your Sandy Hook coverage, Alex Jones said the kids didn't really die and they were really alive in part because he has such a big heart and a lot of hope and optimism.
	Correct.
	Objection form.
	There was nothing in your mind, in the company's mind, nasty, vindictive, negative about any of these statements about the kids still being alive, right?
	Objection form.
	Absolutely not.
	Okay.
	Was it would it be responsible journalism to show this picture to millions of people?
	projection form.
	Responsible journalism is the ability to dig for information and present it in a truthful way to the audience and let them be the judge of that information.
	As long as the information is truthful, to the best of our knowledge, that's what responsible journalism is, and that's what you did.
	So if you were to show this picture to millions of people, the picture that says 10 Sandy Hook children found alive and well, has a bunch of names superimposed on them, that'd be good journalism, right?
	Objection form.
	Again, I already answered that this was a supplementary material that the expert guest wanted to show and send us, and it was appropriate for us to,
	I'm not sure if it was shown on screen or not, but we, as a company, we didn't, I don't believe we censored anything that Wolfgang wanted to say, Go ahead, go ahead.
	go back to our petition there, exhibit one.
	Is that exhibit one?
	I'm sorry.
	I didn't.
	Is it might be two?
	Yeah, exhibit.
	Okay, so can you look at exhibit two for me and go to paragraph 29.
	Paragraph 29 talks about one of the videos discussed in topic number one, correct?
	Mr. Ms. Prepova, I'm just asking you, does paragraph 29 contain a video that you're supposed to talk about under topic number one?
	Yes.
	Okay.
	That video is December 27, 2014, entitled Lawsuit Could Reveal Truth About Sandy Hook Massacre, correct?
	Yes.
	What lawsuit is being talked about?
	I don't know for sure.
	Well, at least this one we're lucky because I do.
	Do you know Wolfgang Halbig sued Leonard Posner that they were in lawsuit together?
	Yes.
	Okay.
	You understand the company was helping Wolfgang Halbig raise money to use in court against Mr. Posner.
	know that?
	Not sure the details of the raising of the money for Mr. Halbig's lawsuit.
	Can you repeat that for me?
	I'm sorry.
	The reasoning?
	Is that what you said?
	What was your question?
	My question is: the company was helping Wolfgang-Halbeck raise money to use in court against Mr. Posner.
	Correct.
	Yeah.
	The company doesn't have details in terms of the said money being raised for court.
	I think wouldn't the more accurate answer be you, Daria Karpova, does not know if the company has information relating to whether they were raising money for Wolfgang Halbig's lawsuit?
	If the documents regarding that weren't produced by the company, then the company does not know because it didn't keep the record.
	Do you know if any such records exist?
	I might have.
	It might have been part of the review documents that I've looked at.
	I'm not sure.
	Well, first of all, we know that you didn't know that this video referred to that lawsuit.
	You didn't know what lawsuit it was.
	So we also, I would take it, no, you haven't done any research to determine what that lawsuit is or anything about it, right?
	I haven't reviewed that lawsuit, no.
	anything that has to do with what this video said about the lawsuit right I mean, if you ask me specifically, because you're saying anything, if you ask me a specific point that I may or may not recall.
	What truth about the Sandy Hook massacre could this lawsuit reveal?
	What did the video have to say about that?
	Well, based on the quotes here in this paragraph, you know, the truth would be something to do with it not being the way the mainstream news reported.
	Okay.
	Help me understand.
	The lawsuit could reveal something that's different than the mainstream media.
	That's your answer?
	Is that am I understanding?
	It's different than what the mainstream media finally reported about the incident.
	So I believe it took a year for Connecticut, State of Connecticut, to release the final report on the event.
	What does that have to do with the lawsuit?
	I'm confused.
	What's the lawsuit having to say?
	I'm asking me what it could have been.
	So that truth might have been something that contradicted the report that the state of Connecticut had issued.
	You have no idea, do you?
	You say might.
	You don't have any idea.
	Yeah, we don't have a record of that.
	Yeah, and when you got this petition and you read it and you saw there was a video entitled Lawsuit Could Reveal Truth About Sandy Hook Massacre, you did nothing to figure out what that lawsuit was or what it could reveal, did you?
	I don't know.
	No, not specifically.
	Okay.
	That video also you'll see in the last line, the plaintiffs allege that the video says that the event was undertaken as a satanic ritual by global elites.
	Do you know if that's accurate?
	Not that you know if the claim, in other words, do you know if it's accurate that that was said in the video?
	I have no reason, the company has no reasons to believe that that wasn't said, and on that point I would say that that is a commentary and opinion of Alex Jones at that time.
	Wait, wait, wait, hold on.
	How do you know Alex Jones said that?
	I mean, you didn't watch the video, right?
	Not recently, no.
	Okay.
	And it says the video also featured claims.
	It doesn't say Mr. Jones said that, does it?
	It does not.
	And you're not going to be able to offer me any helpful testimony about that, are you?
	You don't know who said it or who researched it, right?
	Sorry.
	Judging from the paragraphs it mentions, Mr. Jones is the only one who's mentioned in this paragraph regarding the video.
	It doesn't mention any other guests, which is why I would infer that the claims are made in the video are made by Mr. Jones.
	Which is to say, you don't have knowledge.
	You're making a guess.
	Not specifically, correct.
	Okay, thank you.
	Can you go to paragraph 34?
	You see, that talks about a December 29th, 2014 video entitled America the False Democracy, correct?
	Yes.
	Okay.
	You see where it says Mr. Jones stated that he did deep research?
	Yes.
	Did Mr. Jones do deep research or was that false?
	If he said that he did deep research, then he must have done deep research.
	Because everything Alex Jones says is true.
	He does not lie on error, correct?
	He believes everything he says.
	That's...
	do you see where it says the general public doesn't know the school was actually closed the year before Yes.
	You can't tell me the company source on that, can you?
	I couldn't, Okay.
	Do you know what employee researched or vetted that claim?
	I wouldn't know at this point, no.
	Okay.
	Can you even affirm for me that that claim was vetted in any way before it hit Infowars' public broadcast?
	We relied on the expert guest to provide that.
	Right, and you've already testified you don't know who vetted Wolfgang Halbig, correct?
	Don't know for sure, but I already said that as producer, Nico must have done that.
	And you don't know what Nico did to vet him, correct?
	You have not spoken with Nico?
	No.
	You know how to get in touch with him?
	Correct?
	I have last known contact information.
	Did you try?
	No.
	You see where it says they had kids going around in circles in and out of the building as a photo op?
	Yes.
	Yeah, do you know the company's source on that?
	I believe it should be Well, it's interesting, you know, because have you watched Alex Jones deposition?
	The first one I took?
	Parts of it.
	Okay.
	Did you watch the part about the kids allegedly going in circles around the video with the building?
	Have you seen that?
	I don't remember that specific.
	Okay.
	See, because here's the thing, and I'm just, again, to try to make sure that you're answering questions that you know the answer to.
	We already know where that one came from.
	We had a deposition, and we put the video up, and there's kind of an infamous YouTube video made by just some random YouTuber, some conspiracy person.
	And it's called the Going in Circles video.
	Now, it's actually not Sandy Hook Elementary at all.
	It's a firehouse down the street.
	It's not kids going and out of the building, but it's actually adults and young teenagers.
	But there's this video of this circle of people who are going from the front to the back.
	And we've talked about all this in deposition.
	It comes from a YouTube video.
	It doesn't come from Mr. Halbeck.
	It doesn't come from Mr. Fetzer.
	It doesn't come from any of these people.
	But when you sit here and you say, well, I can infer it came from Mr. Halbig, you can allow for me the possibility that those answers aren't correct, right?
	Well, you can also infer that the source for the video was either Mr. Halbeg or you Fetzer, as you just mentioned.
	You probably know where the video came from.
	You don't know, do you?
	No, you don't know.
	You don't know.
	Right?
	Just as you don't know.
	Right, so we're just all speculating here today, right?
	We have no idea what's going on.
	It does appear so.
	Yeah, it does appear so.
	Objection to the sidebar.
	I'm not going to try to get sidebars admitted, Brad.
	You know that if you're not.
	I don't care.
	Let me tell you.
	Stop abusing the witness.
	If you think I'm harassing this witness too much considering the quality of testimony and the respect we've been given, then you can call the court or stop this deposition right now.
	Otherwise, I don't need the interruption of the flow of the deposition.
	During this time, this time being 2014, December 2014, so even in 2015, during this time...
	Did I hear you say Infowars has never had editorial discussions on Sandy Hook?
	Correct.
	Okay.
	That's not true, though, right?
	People inside Infowars have talked about Sandy Hook from an editorial standpoint a lot.
	Correct?
	Objection form.
	During this time, people inside of Infowars were using the term crisis actor to describe the events of Sandy Hook, correct?
	I don't have any record of that as a company.
	You've never seen a document in the case where people inside of InfoWars were using the term crisis actor.
	Correct?
	As it pertained to Sandy Hook?
	Sure.
	In editorial discussions?
	I don't recall right now.
	So for instance, one thing, okay, first, yeah, let's go back for a second.
	What's an editorial discussion?
	Editorial discussion would be an internal conversation about what type and information of information angles to go with live on air or website or anywhere else.
	In five years of covering Sandy Hook, nobody at Infowars ever had any conversation like that.
	Correct?
	That's what you're saying?
	Wait, repeat that question, please.
	In the five years that InfoWars covered Sandy Hook, nobody had a conversation like that ever.
	Is that what you're testifying to?
	In terms of editorial discussion with the staff, the company doesn't have record on that that I can recall.
	In 2015, at some point before these lawsuits were brought on, Alex had told the staff to halt the potential discussion about Sandy Hook on air.
	Granted, Sandy Hook was a tiny, tiny, tiny, tiny, tiny percentage of the information, the news, commentary, opinions that's covered on the show.
	I mean, a tiny percentage.
	Because what you what these you guys are trying to make it sound like that's all the InfoWars has been talking about for five years, and that's not the case at all.
	Sandy Hook, again, takes a fraction of a percent of the information that we had covered.
	And at some point in 2015, Alex decided that it wasn't a good idea because of all the controversy that's going on.
	I don't know what his opinion, I don't know where he was basing his opinions on, but at some point he decided that it wasn't a good direction to continue to comment on Sandy Hook.
	And that was before you guys even brought any of the lawsuits.
	Okay.
	Do you know what question you're answering?
	You asked me about the editorial discussions with Sandy Hook.
	And there's never been any, and was that your testimony?
	So am I understanding that it's no, there has been?
	I just clarified on what I said by there not being any and what happened in specific point with specifically Alex Jones saying that he does not want to see any reporters discuss Sandy Hook anymore.
	Okay, so let's let's unpack all of that.
	First of all, Mr. Jones putting a ban on future Sandy Hook materials going on there.
	When did that happen?
	Sometime 2015.
	So it wasn't actually a real ban, was it?
	Because there's a lot of InfoWars stuff about Sandy Hook after 2015, isn't there?
	Objection form.
	Right?
	Not a lot, no.
	As I just said, Sandy Hook takes a fraction of the information that we cover.
	Okay, so yeah, let's go to that one.
	What did you look at to come to that conclusion?
	My experience at the company, The Daily Show.
	How many videos do you think Infowars made about Sandy Hook?
	A fraction of all the videos that we produce.
	How many?
	Projection form.
	Don't know the Exact number.
	What fraction do you know?
	I mean, I don't.
	I'm trying to understand if you understand that it's a tiny fraction, right?
	What number would constitute a tiny fraction?
	Like, what ballpark are we talking about?
	How many videos did it listen?
	Well, you have to separate the videos and the broadcasts.
	During the four-hour broadcast, Alex may mention, might have mentioned Sandy Hook for a few minutes during the four-hour period of the show.
	When you're talking about the videos that get posted to the website from that particular show, I don't know how many videos could be produced from that.
	It depends on the show.
	I've been trying to find out for 10 years.
	Today, you can't help me with that, can you?
	Well, I believe the videos have been produced in the Connecticut case and other promotions.
	Why do you, so you know, I know why you believe it, but I can't ask about that.
	Never mind, don't worry about it.
	Can you give me top 38?
	Oh, Ms. Carpova, talking about editorial discussions.
	Let me give you a hypothetical.
	Let's say you've got an InfoWars producer, editor, somebody in that kind of role.
	And he's talking to another producer, an editor, in that kind of role.
	And he says to him, hypothetically, hey, look, these people we're relying on for Sandy Hook coverage, God, they're not good.
	These people are not reliable.
	Man, I think we've got a big problem.
	That's an editorial discussion.
	That would be if that happened, right?
	ejection form.
	If it's a conversation between two employees, I'm not sure how to classify that.
	I mean, two editors having a discussion about the material they're covering and the reliability of their source.
	That's almost the definition of an editorial discussion, isn't it?
	Objection form.
	Well, a company-level editorial discussion or department-level would infer that the particular decisions that come out of the discussion are implemented as policy on something.
	Let me just ask you this: if there were conversations between editors having editorial discussions about whether the sources they were using for Sandy Hook were reliable or not, are those discussions you're prepared to talk about today?
	I have no knowledge of those discussions.
	So I take it by that same token.
	You have never seen any documents in which one editor or high person in Infowars, a writer, editor, or let's say editor, producer, is talking to another management-level employee and saying, I'm really worried about our Sandy Hook sources.
	You've never seen any documents like that.
	Not specifically like that, no.
	Thank you.
	Can you hold on?
	Okay, there it is.
	Can you send something to Sonia to print?
	give me one second i'll send it to you
	okay I'm going to show you what I've marked exhibit six.
	You'll see down at the bottom right-hand corner there's a label on it that says FSSTX075327.
	Yes.
	Okay.
	Up at the top, you see that this is an email from Nico to Rob Dew?
	Yes.
	Okay.
	You see what the subject is?
	Yes.
	Can you read it for me?
	Ebola Sandy Hook crisis actor clips attached.
	As of this date, 2014-10-19, that's the date of the email?
	Yes.
	As of this date, employees inside of Infowars, such as Nico were engaged in discussions with another employee, like Rob Dew, using the term crisis actor in relation to Sandy Hook, correct?
	I don't see any discussion being held here.
	I mean, he wrote the words, Ebola Sandy Hook Crisis Actor clips attached.
	That's a statement, right?
	That is a statement that could have been the names of the clips.
	No, the attachments have the names of the clips, don't they?
	It's got a PDF and it's got a name, doesn't it?
	Yes, but one has nothing to do with the other.
	Who knows, right?
	You never looked at the attachment.
	Well, here's what I can tell this is.
	The subject matter has to do with the clips, with earlier clips that must have been attached for the names of the clips.
	The attachment here, the way the email system works is that if you reply to an email, it will keep the same subject, but you can reply with another attachment or an entirely other conversation and will still keep that subject if you don't start a new email thread.
	So if you just reply to a subject of an email as a thread, even if your attachment have nothing to do with the subject matter, that's a possibility here.
	And the subject will say read, R-E, right, with a colon after it, right?
	If it's a reply.
	Right.
	Sometimes.
	Okay.
	So would it be your contention that, look, despite there being the word crisis actor in this email, that's not like something Infowars employees would joke with about each other.
	Right?
	No.
	That would be extremely inappropriate to make jokes about Sandy Hook crisis actors to like laugh it up about that.
	That would be inappropriate, right?
	In what context?
	For your employees, let's say you have managerial responsibilities, right?
	Okay.
	Let's say you found out that two of your subordinate employees were trading emails back and forth joking about sacrificing Sandy Hook crisis actors.
	Would you find that inappropriate?
	Objection form.
	Or are you okay with that?
	injection form It's a hypothetical situation.
	It would have to be, I would have to be there, look at the conversation, look at the circumstances.
	I can't just give you a blanket statement.
	Right, so if I was one of your subordinates and I came to you and I said, hey, look, Ms. Garpova, I don't want to be a tattletale, but I overheard some employees and they were making jokes about sacrificing Sandy Hook crisis actors.
	And I think that's messed up.
	And can you do something about that?
	Would you say, I'm sorry, I don't have enough information?
	Or would you do something?
	Jack in form.
	Probably do something that would brought to my attention in this direct kind of way.
	Okay.
	Would it make a difference whether that person was related to Alex Jones?
	No.
	Okay.
	Can you go to paragraph 36 of Exhibit 1?
	I'm sorry, excuse me, I keep doing that.
	Can you go to paragraph 36 of Exhibit 2?
	Okay, you see here this talks about a March 4th, 2015 video entitled New Bombshell Sandy Hook Information Inbound.
	Yes.
	What was the bombshell information?
	The bombshell information was the new statement, information that Mr. Halbick had brought on during that show.
	That's what I can infer.
	Which is what?
	What's the bombshell?
	Sorry, I wouldn't know the details of it.
	So, when you had this video to try to figure out what was the sourcing and the research that went into it, you don't even know what the bombshell information was that's described in the title of the video, correct?
	Well, any new information would be bombshell, so just because it says bombshell, there might have been a lot of information in that video, which there's no way I can remember what was in that video exactly.
	Well, I mean, it's not a matter of you not remembering, you never watched it, right?
	Not recently, right?
	And so, and you didn't do anything to try to get prepared on it for this deposition, right?
	You haven't read any documents about this video.
	No, and you haven't talked to any employees about this video.
	No.
	Have you tried to talk to Mr. Halbeck about this video?
	No.
	Okay.
	You go to paragraph 38?
	Do you see where it says a July 7th, 2015 video titled Government is Manufacturing Crisis?
	Yes.
	Okay.
	Do you see where there's a quote there that says, if they did kill kids, they knew it was coming, stocked the school with kids, killed them, and then had the media there, and that probably didn't even happen.
	You see that quote?
	Yes.
	Okay.
	What does stock to the school with kids mean?
	Do you know what that means?
	Well, just judging on common sense here from the sentence, that would probably mean the kids were in the school.
	They were put in the school.
	By who?
	Do you know?
	Whoever was involved in the operation.
	What do you mean by operation?
	What is that?
	Well, Mr. Jones is talking about Sandy Hook was staged, so the staged operation would make sense.
	The stage operation of Sandy Hook.
	That's what I mean.
	So the idea here is there was a school and it was empty, didn't have students going to it, and then it was some nefarious actors arranged for children to be put into the school for the purposes of killing them.
	Am I understanding this correctly?
	From what I can tell here, it's either the kids were put in an empty school or the school was filled with more kids than there normally are in school.
	And you don't know which one, right?
	No.
	Yeah, this looks like Alice Jones' opinion commentary.
	And you don't know what it was based on, right?
	Okay.
	Okay.
	Right?
	Not in details, but most likely based on all the information that he had acquired and reviewed at that point.
	That was his honest opinion.
	Again, you're guessing, aren't you?
	There could have been, before he made this statement, a very specific video he's referring to, or a very specific piece of evidence, and you don't know that, do you?
	The company doesn't have a record of that because we don't keep such records.
	Wait a second.
	The company has the video, doesn't it?
	Right?
	Yes.
	So you could have watched the video and determined if he was referring to something specific, couldn't you?
	Well, you This quote from Alex to me sounds like an opinion.
	But again, that's your guess, right?
	Yes.
	Okay.
	If there was an employee who had researched some material, who had brought it to Mr. Jones for this video, you wouldn't know that, would you?
	You would have no ability to tell me that.
	Based on my educated guess, this wouldn't be the case in a statement like this.
	Again, you're just guessing, right?
	There is no.
	It is possible, right?
	That somebody could have brought Alex Jones some material that caused him to say this thing, right?
	That's possible.
	Very unlikely in This particular video.
	Right, but I'm asking you to testify what you know is true.
	And you don't know, do you?
	I'm testifying to what I think I know to the best of my ability in good faith.
	Well, right, I know you're guessing because you want to give me an answer, and I appreciate you trying to give me an answer.
	But I want to make clear that you had information you could have looked at and you did not look at it, correct?
	Some of the gaps, in other words, the video.
	You could have looked at the video and you did not, right?
	There were a lot of videos, and there's no way I could remember all these details.
	Let's see if we can get a little bit of a video on the videos.
	Let's put it this way.
	When the company knew that it had to produce testimony about these videos in the planet's petition, the company did not feel it was worthwhile to have employees review, watch, catalog, and figure out what was said and make that available to you, correct?
	The company believes that I have sufficient knowledge to testify regarding these matters.
	Okay.
	Let's go ahead and take a break.
	Okay.
	Okay, time is 1:38 p.m.
	We are on court report, are you ready to?
	Yes, I'm ready.
	All right.
	Okay, time is 2:56 p.m.
	We are on.
	All right, can you pull out exhibit two for me again?
	And let's go to paragraph 39.
	You see, this is talking about a July 7th, 2015 video entitled Retired FBI Agent Investigate Sandy Hook Mega Massive Cover-Up?
	Yes.
	okay that retired f_b_i_ agent that's rob news uncle Yes.
	Do you see in this claim where it says the ambulances came an hour and a half later that that was claimed in the video?
	do you see where it says that?
	So second sentence.
	You see that sentence?
	Yes.
	Okay.
	What was your source on that?
	Previous discussions with Halbig analypogenic.
	You guessing on that, or do you know that for a fact?
	I don't know the portfolio.
	Right, you were guessing because that actually came from Mr. Fetzer.
	That's in his book, Nobody Died at Sandy Hook.
	So can I just admonish you one more time?
	Can we please not guess during this deposition?
	It's okay to say I don't know.
	You can say the company knows.
	Here's the answer.
	The company doesn't know, or I don't know if the company doesn't know or doesn't know.
	But your guesses are not what we need today, okay?
	Yes.
	Okay.
	Do you see where it says DHS an hour and a half later with a time stamp put up signs saying sign in here?
	Yes.
	Do you know where that came from?
	No.
	They had a statement that said they had porta potties being delivered within an hour and a half.
	Do you see where it says that?
	It's also in that first paragraph?
	Yes.
	Do you know where that came from?
	No.
	In the third paragraph, first sentence, do you see where it says we have the emails from the city council back and forth in the school talking about it being shut down a year before?
	You see that?
	Yes.
	Do you know if those emails actually exist?
	Let me rephrase that.
	Do you know if the company, does the company know if those emails actually exist?
	No, it doesn't.
	Do you know what the company source was saying that was?
	No.
	Okay, can you move on to paragraph 44 for me?
	Do you see it talks about a November 26th video, November 18, 26, entitled Final Statement on Sandy Hook?
	Yes.
	okay do you know the claims that were made during that video I'm familiar with the video.
	Okay.
	In that video, do you know about the claim made in that video that the Sandy Hook Elementary School website had no internet traffic for three, four years before the intervention?
	Yes.
	Okay.
	Do you know where that came from?
	Yes.
	Where did that come from?
	The Wayback Machine archive for the website, the school.
	Okay.
	And where did Mr. Jones get that?
	The Wayback Machine.
	Do you know if you got that from Mr. Fetzer?
	Don't know.
	Do you know if that's in Mr. Fetzer's book?
	No.
	Okay.
	you go to paragraph 54 for me You see there it's talking about an April 22nd, 2017 video called Sandy Hook Vampires Exposed?
	Yes.
	You understand that that is the video that Mr. Posner and Mrs. De La Rosa based their defamation claim on?
	Did you know that?
	Okay.
	Did you know that?
	When preparing for this depot, did you know that?
	Yes.
	Okay.
	Did you watch that video?
	I mean, unless you've watched it in the last couple hours, you haven't watched it, right?
	For this deposition?
	I'm familiar with the video.
	Did you watch it in preparing for this deposition, though?
	Yes, I believe so.
	Okay.
	When did you watch it?
	Earlier today.
	Earlier today, when?
	During the break.
	Oh, so during the break, when it became apparent that you hadn't watched these videos, you went and tried to watch this video?
	Yes.
	You didn't watch the whole thing, though, did you?
	No.
	Because it's a 45-minute video, right?
	It's a lengthy video.
	Yeah, so you didn't watch this video?
	You watched pieces of this video, correct?
	Correct.
	How many pieces did you watch?
	How many minutes total did you watch of this video?
	Did not count.
	So you have no idea sitting here today how long it was?
	When it was just a couple minutes ago?
	I did not count the amount of minutes I watched.
	Okay.
	Was it more than five minutes?
	Not sure.
	Okay, so you just watched a video within the last 20 minutes, and you're not sure if you watched more than five minutes of it, correct?
	Objection four.
	Is that correct?
	I didn't time the amounts of minutes I watched.
	So that is, but I'm not asking you the exact time or if you timed it.
	I'm saying do you know if you watched more or less than five minutes?
	I believe more.
	Okay.
	Do you think you watched more than 10 minutes?
	Not sure.
	Okay.
	You understand that that video, did you watch a part in that video where they talked about the police finding people in the backwoods dressed up in SWAT gear?
	I recall seeing that.
	Just a few minutes ago?
	Yes.
	Okay.
	And do you know where the company got that claim?
	As far as the company's understanding, it's based on the previous videos that were watched by Alex and statements that were made by Halbig.
	So that's talking about, you're talking about the prior videos we've been talking about today in this petition?
	Correct.
	The ones you don't know the sources for.
	Correct?
	Correct.
	Okay.
	You understand that in that video, Mr. Jones claimed the school had been closed for years?
	Did you watch that part?
	Yes.
	Okay.
	Where did you get that information?
	Mr. Halbeck.
	Okay.
	Can you go to paragraph 55 for me?
	Do you see it talks about a June 13, 2017 video entitled Media Refuses to Report Alex Jones' Real Statements on Sandy Hook?
	Yes.
	Is that another one you were just showing it during the break?
	Yes.
	Okay.
	Is it fair to say that what happened is that every video past this in the petition that you went and tried to watch a little piece of it before you came back into this room?
	Objection form.
	This video I watched in its entirety.
	Okay, so when did you watch that?
	During the break.
	Okay.
	And do you remember how long that video is?
	Around 20 minutes or so.
	Okay, so you have a copy of it here in the building?
	Yes.
	Correct?
	Okay.
	tab 48.
	Is that in the No, okay, it goes.
	There's 49.
	There we go.
	Is this it?
	I'm sorry.
	What was that?
	Is this it?
	Yeah.
	There's my pen.
	Pass me a pen real quick.
	if you don't All right, Mr. Poof, I'm showing you what a Marx's exhibit seven.
	You recognize that now, I would assume?
	Yes.
	Okay, what is this?
	What are you looking at, Ryder?
	This is an excerpt from Zero Hedge article.
	No, like, where does this come from, this picture?
	Where does it come from?
	This is still from a show.
	Do you know what show?
	Not specifically.
	It doesn't have the date here.
	Okay, it's the one you just apparently watched a couple minutes ago.
	You don't remember seeing this?
	Not this part specifically.
	Okay, so you maybe didn't even watch this part of the video.
	I watched the video.
	I don't remember this specific.
	Okay, a large portion of that video is Mr. Jones going over these questions.
	Do you remember that?
	From the video you just watched?
	Yes.
	Okay.
	All right.
	So you do remember Mr. Jones talking about these questions?
	Yes.
	All right.
	I want to ask you about a couple of them.
	When it says, why does the Sandy Hook Elementary School website have zero traffic for four years, that's not true, correct?
	The company admits that's not true.
	Objection form.
	Correct?
	This is a statement.
	This is a question that Alex had at the time.
	Right.
	And he's making a statement, isn't it, isn't he?
	Right?
	He's saying that the school had no website traffic for four years.
	Correct.
	Right.
	That's not true.
	Correct?
	The company admits that's not true.
	Objection form.
	It was true according to the source that he had.
	What do you mean it was true according to the source that he had?
	What does that mean?
	He was referring to the Wayback Machine of the traffic recording from the website.
	And that's not true, correct?
	Well, it's not true.
	The school website did not have zero traffic for four years.
	That's not true.
	The company admits that's not true.
	correct
	Again, Alex Jones is asking the question based on the source he was showing in the video Of the Wayback Machine that lists the traffic being zero for four years.
	Okay, first of all, his source, then, let's just go through it this way.
	His source was wrong.
	Correct?
	The company admits that.
	Mr. Halbig is wrong about that.
	Objection 4.
	correct right
	The company admits that Alex Jones believed that there was zero traffic for four years, which was the source at the time.
	You understand that's not my question, right?
	I just want to make sure, do you understand the question?
	Repeat the question.
	Sure.
	Mr. Jones's source, Mr. Halbig, was wrong about there being zero traffic for four years to the school website.
	correct traction for and Yes.
	Do you see down the second to last bullet point it says why didn't they let paramedics and EMTs into the building after 27 children were declared dead in eight minutes?
	Do you see that?
	Yes.
	Literally nothing about that statement is true, correct?
	Okay, it's informed.
	Thank you.
	That was Alex's understanding at the time based on the claim made by Halbig.
	Okay, and you're positive, you're testifying under oath that Mr. Halbig made this claim and not somebody else.
	You know that for a fact?
	Okay.
	Yes.
	Okay, Mr. Fetzer didn't say that?
	That's not a Mr. Fetzer claim?
	Mr. Fetzer could have said that, but there was also statements made by Halbig.
	Okay.
	It's true, the company admits it's true that Mr. Jones understand, you refer to it as Mr. Jones' understanding of what his source said.
	You now admit, the company now admits, it's not true.
	Correct?
	Paramedics were in that building.
	Right?
	Correct.
	Okay.
	It's also true that 27 children didn't die.
	Correct?
	Correct.
	Okay.
	And they weren't declared dead in eight minutes, were they?
	That's not correct.
	The company admits that?
	Correct.
	Okay.
	I'll talk to you about that one.
	That's an interesting document.
	Can you go to paragraph 61 for me?
	May I add on the previous statement?
	These questions here are questions, they're not statements.
	All right, so let me ask you this, Ms. Karpova.
	Right.
	If I say you beat your newborn baby, that's a statement, right?
	And that'd be like a false statement, right?
	Right.
	Okay.
	If I say to you, Ms. Karpova, why do you beat your newborn baby?
	Have I made a statement?
	Well, you're asking, well, I mean, it could be, in this case, yes.
	Right, and so when Mr. Jones asks, why were no paramedics allowed in the building, he's saying no paramedics were allowed in the building, correct?
	Correct, and he's basing that on reports that he's read and seen.
	Right, that are wrong.
	The company now admits are wrong.
	Right, okay.
	You go to paragraph 61 for me now.
	Thank you.
	This talks about an October 26, 2017 video called JFK Assassination Documents to Drop Tonight.
	Is that another one that you just looked at at the break?
	Yes.
	Okay, how much of that did you watch?
	Oh, that's a long video.
	I watched parts of it.
	You understand that that doesn't help me, right?
	That's not helping me understand what you've watched.
	You understand that?
	I understand that.
	Okay, so when I'm asking you the question, it's an hour-long video, isn't there?
	Maybe it might be a full four-hour episode.
	Do you know?
	Don't know the exact time stamp on that, but I know it's a long video.
	How did you decide what part of it to watch?
	I skimmed through it.
	So you just randomly pick some places to watch?
	No, not randomly.
	How would you know to what parts to go to?
	How would they not be random?
	Do you have a document that tells you what's in the video?
	I just know based on the time segments where to go in the playhead.
	Okay.
	All right.
	See the part about the CIA visiting Landa and recruiting him?
	Not on the petition, in the video you watched.
	It's in the petition.
	I'm asking if you saw it in the video.
	Yes.
	You did see that part?
	Yes.
	What was the company source for that?
	Again, that was based on previously sourced information with Alex from his guests as well as other reports.
	Ms. Karpova, no, it was not.
	And please, can you stop guessing?
	Because I need you to understand, if you watch that video, you understand that this video was done because a new set of documents was declassified by the FBI on that date.
	And Leanne McAdoo did a report on Infowars talking about those documents.
	It didn't come from Mr. Halbeck.
	The testimony you gave is just not correct, is it?
	Objection form.
	She didn't say anything about Mr. Halbick.
	All right, let me address your objections.
	this didn't come from prior videos did it Or do you know?
	The company believes it did come from previously sourced material.
	Okay, so when I talk about Leanne McAdoo doing this report on the documents that were declassified on that day on October 26, 2017, do you have any idea what I'm talking about?
	Is that new information to you or do you know what I'm talking about?
	I have some information about it.
	And you understand that from Ms. McAdoo's article that the allegation was made that the CIA tried to recruit Lanza.
	Did you know that?
	I cannot tell for sure.
	You cannot tell for sure if you knew.
	Is that what you're telling me?
	I mean, you either knew or you didn't, right, Ms. Karpova?
	This thing I just told you about Leanne McAdoo, did you know it before I told it to you?
	The specific part about inferring that for those documents that were dropped that she was talking about do not recall the specific part about that CIA visits, Adam Lanza, and recruited him based on those documents.
	How long, okay, so you were watching this video, right?
	In the break.
	How long was Mr. Jones talking about Sandy Hook in that video?
	How much total footage do you think you watched About Sandy Hook in that video?
	Not sure.
	Would you say it's less than two minutes?
	Okay.
	No.
	You think that Mr. Jones talked about Sandy Hook for more than two minutes in that video?
	I'm not sure exactly how long.
	Okay.
	You understand it was, I'm just going to represent to you, it's an extremely brief conversation.
	What?
	Mentioning Ms. McAdoo's article.
	And do you remember Mr. Jones saying, well, you know, sometimes I don't even see what's out there on Infowars.com.
	I didn't check.
	And somebody had to tell me about this article, and it was a total surprise to me.
	Do you remember him saying that?
	Yes.
	Okay.
	So we can agree that the source for this video is the article that he's talking about that he just looked at, correct?
	Um...
	Um...
	I'm sure that article was a source for him in some of the statements that he made.
	Well, I'm asking you about the statement that the CIA recruited Lanza, which you said came from prior videos.
	But that's not true because that piece of information was in that released report that day, correct?
	Or do you know?
	I do not know.
	Okay.
	Give me top three.
	Yeah.
	Wait on, let me see.
	Is it the two?
	No, next one, I'm sorry.
	What?
	That's weird.
	It's the final report.
	Oh, is it A Sheeta?
	I see.
	I've forgotten.
	Ms. Carpo of Hengi would have marked his exhibit 8.
	You're going to see that this is a document marked FSSTX-075755.
	Yes.
	This is a November 26, 2013 email.
	You see that?
	Yes.
	Do you know who changes horses at AOL.com is?
	I do not.
	Okay.
	Rob D is Rob Dew, right?
	Yes.
	Kurt, who's that?
	Cardinemo.
	Okay, and what's his position at this time?
	He was a writer.
	Okay.
	You see where it has a link here to this, the subject says check out Sandy Hook final report?
	Yes.
	And then there's an underlined hyperlink that says Sandy Hook final report in the body of the email?
	Yes.
	So the company will admit that it has been provided information of the final report as early as 2013, correct?
	Yes.
	So the final report provided from the state of Connecticut, correct?
	From the Connecticut State Police, correct?
	Do you know that that's who issued it?
	Yes.
	Okay.
	Give me tab four.
	and go ahead and get tap 5 ready too So three, four, she did not do these great.
	Yes, that.
	then the next one too I'm putting this email in front of you now that I've marked as exhibit 9.
	Do you see that?
	Yes.
	Okay, it is marked FSSTX-075999.
	Is that correct?
	Yes.
	Okay.
	And from what you can see here, this is another communication with Rob Kurt, and this changes horses at AOL.com person, correct?
	Yes.
	Okay.
	And in here, what is being Provided, what Rob is attempting to get is a copy of the Sandy Hook 911 tapes, correct?
	May I have a second?
	Yeah, go ahead and redeem it.
	Ooh.
	Okay.
	Okay, so this is an email in which Rob Dew is attempting to get the 911 tapes?
	Yes.
	Okay.
	And that was on December 5th, 2013?
	December 4th, I believe, says here?
	Oh, okay.
	I think there's another, let me see.
	Yeah, the email from the changes horses persons from the 4th, and then the email from Mr. Dew is from the 5th, correct?
	Okay.
	Mr. Karpova, I've given you an email which I've marked as exhibit 10, labeled at the bottom, FSSTX012708.
	Is that correct?
	Correct.
	Okay.
	You'll be looking here.
	Before we get into this email real quick, you would agree with me that the InfoWars website occasionally requires moderation.
	You understand what I mean by that?
	Yes.
	Okay.
	Occasionally in the company's editorial discussions about Sandy Hook, the company would have to decide whether certain material was appropriate to leave on the InfoWars website or take it off the website, correct?
	objection form.
	The website gets moderated for spam, as far as I know, in the comments.
	Okay, well, let's take a look at this email because it's not about spam.
	Okay.
	This email, the original message is from Matt at Infowars.
	Who is Matt W?
	Matt Weber.
	Okay, what was his job title in 2014?
	Assistant producer.
	Okay, what about Louis S?
	Who's that and what's his job title?
	Writer.
	Okay.
	So Matt writes to Louie and says, Hello, Louie, can you do me a favor?
	Just got a phone call from my friend Johnny Walker.
	Some people are posting some bullshit about how he was involved in the Sandy Hook shooting last year, including some personal stuff about John.
	They did the thing about a year ago.
	Apparently, there are more than one Johnny Walker in the world.
	Last time it involved going through his Facebook page and pointing out friends with Jewish names and things like that.
	John is a character who was not even in the Sandy Hook time zone.
	If you see it, could you take care of it for him?
	Thanks, Matt W. That's what the email says?
	Yes.
	Okay.
	The reply from Louie says, the site has been acting weird and not letting me search.
	If he can give me an article or a username involved, let me know.
	Otherwise, if I see it, I will get on it with a winky smiley face, correct?
	Yes.
	Okay.
	This email was sent on May 15th.
	Well, the two emails are May 14th to May 15th, 2014.
	Correct?
	Yes.
	Okay.
	So the company can admit that a friend of an InfoWars employee named Mr. Walker got tied to a Sandy Hook allegation, according to Matt.
	Correct?
	Correct.
	Okay.
	And so Matt and Louie were okay with deleting the stuff about Mr. Walker.
	Correct?
	As a comment being posted that misidentifies a person.
	Right.
	Yes.
	But since my clients weren't friends with anybody at InfoWars, they couldn't get similar comments removed from the Infowars forums, could they?
	Objection form.
	What you're referring to is a public case.
	This is a private person who gets misassociated with the event.
	Cindy Hook was a public story.
	So you think all the parents are fair game?
	Objection form.
	People asking questions, having discussions.
	That's what's called free speech in the public case.
	You think telling lies about people and saying they're a crisis actor and their kid didn't exist, is that free speech?
	Objection form.
	If it's false, is that free speech?
	In Infowars' eyes?
	If it's something that's knownly false, we don't allow that.
	We do, to the best of our ability, allow truthful comments only.
	Mr. Posner asked y'all to stop posting these kind of comments, didn't he?
	Objection form.
	Say that again, please.
	Mr. Posner asked InfoWars to stop hosting comments like this on its website about him, right?
	Are you referring to a specific document?
	Mr. Posner?
	I've got a few in mind, but I was wondering what you knew about if the InfoWars.
	One of your topics is the knowledge of the plaintiffs, right?
	Correct, but you're asking me to comment on a specific post regarding Mr. Posner that he asked to be renewed.
	No, I'm asking you in general, like not for anything specific.
	Do you know, sitting here today, if Mr. Posner has asked the company to remove content about him from the InfoWars website?
	Yes, and as far as I know, that's been done.
	Wait, when Mr. Posner complained, you think Infowars did something about it?
	Well, are you referring to which state are you referring to?
	I'm asking anytime.
	What are you referring to?
	I don't have a record.
	I don't have a record of that information.
	Well, what were you referring to?
	When you said yes, we did take care of it.
	What are you talking about?
	I was referring to the previous comment that I made regarding Alex Jones requesting that the on-air personalities would not make comments regarding Sandy Hook.
	Okay, so from your point of view, is what you're telling me, is that at some point Mr. Jones put a ban on Sandy Hook materials on air, and you believe that was in response to Mr. Posner asking him to do that?
	In part.
	All right.
	Why do you think that?
	what information do you have that made you think that Or are you speculating right now?
	It was companies understand companies understanding that there were questions and controversies involved in the case and Mr. Posner was unhappy with the coverage.
	No, Alex Jones made the decision to not continue with the said coverage.
	So his YouTube channel wouldn't get deleted, right?
	That's why he did it, right?
	Section form.
	No, we had no idea that the channel would be deleted.
	That came as a surprise.
	You know Mr. Jones did a video on February 15th, 2015, about Mr. Posner.
	You know that, right?
	Don't have the video in front of me.
	But I mean, you know that happened.
	You know Mr. Jones went on air, complained about the Honor Network, and the complaint that they made to YouTube, said that they were an anti-free speech system, an anti-free speech organization.
	Correct.
	Put Mr. Posner's address on the air with a map.
	You know that happened, right?
	I don't recall that specific part.
	You don't know that part of this lawsuit?
	You're asking me about the video.
	I mean, that's what I'm asking you.
	You understand InfoWars took Mr. Posner's address, put it on air to its viewers.
	You know that, right?
	Traction form.
	Or do you not know that?
	I do not have the record of it right now.
	Okay.
	Mr. Posner.
	Yeah, question.
	Yeah, I know that's coming.
	You know who Dan Bedondi is, right?
	Yes.
	Okay, he's a reporter working for Infowars who was sent to Connecticut multiple times, right?
	In some capacity.
	What capacity?
	What do you mean?
	What does that mean?
	Reporter.
	He went there as a reporter, right?
	There's no reason to qualify that.
	InfoWars sent them there as a reporter to cover Sandy Hook, right?
	I don't have a record right now as to how much of his work was done on his own volition as opposed to InfoWars giving him the directions to do that.
	I think it was a combination of that.
	Weren't you personally involved right after getting sued of trying to get all the documents together about Mr. Ben Dondi, when his invoices were, when he was fired?
	Wasn't that you?
	No.
	Okay.
	If somebody was to represent that was you, they would not be being accurate.
	I'm sorry.
	If someone was to represent that you were the person who went and got all of Neek Halbig's, excuse me.
	Someone was to represent that you were the person who went and gathered up all of Mr. Bedondi's invoices, tried to figure out why he got fired after being sued in 2018.
	If somebody was to say you were the person who did that, they wouldn't be accurate.
	They would be mistaken.
	Junction form.
	In editorial discussions about Sandy Hook, how did InfoWars feel about Dan Badondi's reporting in Newtown?
	The company doesn't have records of that.
	So you didn't go pull any documents.
	I understand that.
	So is your answer for me?
	I can't tell you.
	I don't know.
	I don't know how the company felt about it.
	Is that your answer?
	Yes.
	Okay.
	There were people who were working with Dan Badandi at that time, correct?
	I mean, there were people inside of InfoWars who communicated with Dan Bedondi about his assignments, right?
	Okay.
	They knew what he was doing in Sandy Hook, right?
	To some degree, yes.
	Okay.
	There are people who watched his reports.
	Yes.
	Somebody watched it before you put it on the air, right?
	Yes.
	Okay.
	So there are people currently employed by Infowars who probably have a pretty good understanding of how the company in its editorial discussions felt about Dan Badanti's reporting.
	You would agree with me about that?
	Objection form.
	I would have to see specific conversations if there's a record of conversations.
	Well, look, you know that Rob Dew was in touch with Dan Badondi and sent him down to Connecticut.
	You know that, right?
	I know Rob Dew has had conversations with Mr. Bedondi.
	And he didn't give you any information about Mr. Bedandi before this deposition, did he?
	He did not.
	Okay.
	You know, Mr. Jones has seen Dan Badanti's videos from his reporting, right?
	Like he aired them during the episodes he was hosting, right?
	Okay.
	Mr. Jones might have some feelings about what Mr. Bedandi did, right?
	He might.
	Yeah, but you aren't going to be able to tell me any of those, are you?
	I wasn't asked to provide that information.
	Okay.
	Mr. Bedondi is a person who has definitely come up in editorial discussions about Sandy Hook, correct?
	Objection form.
	Defined editorial discussions there, as far as we are understanding from the previous definition of that word, of that concept, no.
	Well, I'm assuming that you know what editorial discussions mean because nobody asked me that they thought that they didn't understand what that meant.
	And are you telling me right now you're not sure what editorial discussions mean?
	No, we already gone through this, but I answered you what an editorial discussion was.
	Right, and so we know that when editors and producers were talking about Sandy Hook, they were making decisions about things like whether to send Dan Badanti there, right?
	That's a decision they made, correct?
	A decision could have been made by one person upon which that was the sole responsibility to make that decision.
	But we don't know, do we?
	We have no idea in that editorial discussion about Dan Bedondi and his coverage.
	We don't know.
	So I'm telling you there's no Record of it if it was a specific person, like you mentioned, Rob Dew, who sent him there, or there was a combination of people.
	I, the company has no record of that.
	It has employees who know it, though, doesn't it?
	No, what?
	Employees who personally dealt with Dan Badondi.
	You're not one of those people, though, right?
	No.
	Okay, but there are people who personally dealt with Dan Badondi.
	Yes.
	You didn't talk to them about their editorial discussions about his reporting, did you?
	No.
	Okay.
	Can you give me time six?
	Thank you.
	MOS.
	Yeah.
	That's your pen again too.
	I'm going to show you to Mark as exhibit 11.
	You'll see that this is also a document that was produced without a number at the bottom of the page.
	Do you see that?
	Yes.
	Okay.
	But what we're looking at here, this appears from the formatting and the names involved and everything about it.
	This appears to be a document that existed in InfoWars email system that was produced to us in this lawsuit, correct?
	Yes.
	Okay.
	So what you'll see in the bottom email, and I want to give you a chance to read it really quick, but this is when he says, hey, Rob, is Dan Badondi talking?
	Hey, Rob, can I do an MOS tomorrow?
	Before we go into anything else, an MOS is a man on the street.
	Yes.
	Okay.
	And that's a sort of interview where he might just go out and try to talk to random people.
	Yes.
	Okay.
	So I want you to just, because I think you may want to, just go ahead and read that email real quick.
	It's not real well into what we're going to be talking about, but you can take a chance to read it.
	Thank you.
	Thank you.
	Okay.
	Okay, so and then what we see basically here is just some proposed questions that he wants to ask random people on the street, right?
	All right, and and in the follow-up email from Rob Dew, he doesn't want Dan to do that, right?
	Correct?
	Right, it's going to be old by the time they can air it, correct?
	Yes.
	Okay, so he says go to Sandy Hook, we will cover that, correct?
	Yes.
	Okay.
	So it was an intentional choice by Mr. Dew to want to get Dan Badanti to go to Sandy Hook.
	Correct?
	Yes, because it was in the news and the nature of the beast, so to speak, in the news, the 24-hour news cycle expires really fast.
	How was, excuse me, I'm sorry.
	How was Sandy Hook in the news on 7-7-2015?
	What had happened that would put it in the news?
	Don't have the record of that right now.
	Right.
	So you don't know that it had anything to do with it.
	Sandy Hook has been in the news despite the fact that Alex have not mentioned it in years and it keeps being put in the news as if Alex is the one who is the purveyor of the Sandy Hook news, the Sandy Hook, and him talking about the parents, yet it's the mainstream media who keeps mentioning the parents and tormenting the parents and the entire situation.
	When you say purveyor, when he's saying go to Sandy Hook, we will cover that.
	Infowars is being the purveyor through almost almost three years after Sandy Hook is being the purveyor of Sandy Hook coverage, correct?
	No.
	What is that then?
	Is he saying that we're going to cover it and not air it?
	He intends to put whatever Dan Badanti does on the air, correct?
	It depends if the report is good or not.
	And then again, in answering this question, you speculated out of thin air that there was something going on around January 7th, 2015 that put this in the news.
	That made it timely.
	But that was pure speculation.
	You have no idea what that might be, correct?
	That's the nature of our news.
	That's how we do news.
	If there's something in the news, then we will cover it.
	Yeah, y'all were going to make news.
	Do you understand that?
	You were sending Dan Badanti there to Wolfgang Haubick.
	Do you know what they did there?
	No.
	Give me time.
	Seven?
	Okay, let's get ten.
	I'm trying to get us out of the building.
	Yeah, I don't know.
	What's wrong?
	Yeah, I don't know.
	Let me show you what I marked as Exhibit 12.
	This is an email you received, correct?
	Yes.
	Okay, I'm going to go through the email with you really quick.
	Now, you'll notice at the bottom here we have a Bates number.
	It says Hesslin 19-4651-000661, correct?
	Yes.
	Okay, now one of the problems you're going to see in this document is that, unfortunately, the way your former attorneys decided to produce it, it cuts off.
	You notice how that line cuts off there at the end.
	We can't read what that long line says, right?
	Right.
	Okay.
	I'm going to try to do my best though, okay?
	And what we have here is that we have.
	All right, what we have here is from TruthRadio9990 at hotmail.com.
	And this was something sent to Rob Dew at Infowars, right?
	Right.
	Okay, and so we have this email here from Dan Badondi stating, someone you may want to get in that documentary on Sandy Hook.
	And it says forward, Dan, Alex announced that he is going to do a Sandy Hook doc film.
	Sheila Matthews, who you met in Hartford at a Halbig hearing, is a friend of mine who lives in the next town, and I'm going to guess that says over.
	And we don't know what it says after that, but then it says, Sheila asked me to provide you with her telephone number.
	It gets a telephone number, right?
	Right.
	Okay.
	And then Rob sends it to you.
	And this is April 24th, 2018, correct?
	Correct.
	And he says, if Alex wants to go the Sandy Hook route, he may want to get this lady on.
	Correct?
	Yes.
	Okay.
	So this is just shortly after the company was sued, right?
	Yes.
	That's why he wants to make this documentary, right?
	I'm not sure the exact reasons for Alex wanting to do a documentary.
	What is the Sandy Hook route?
	What is that?
	The way we do, since Rob is recommending a guest for the show, that would be Alex's decision if he wanted to have this guest on or not.
	Well, I think you know that the Sandy Hook route is about how he was going to respond to this lawsuit, whether he was going to make this documentary film.
	You understand that?
	Objection form.
	I think that's your conjecture.
	I'm asking you, that documentary film, that was made in response to this lawsuit.
	That's what he was planning on doing.
	I don't have a record of a documentary film on Sandy Hook.
	Do you understand that immediately after this lawsuit was filed, that Alex Jones was talking about making a documentary that proved it was all fake?
	Did you know that?
	That's a conjecture, too.
	We don't know what the documentary film he wanted to do was about.
	Well, I'm asking you.
	That's what I'm saying.
	I'm asking you.
	Wasn't it about Sandy Hook being fake?
	There were never editorial quote discussions about what was going to be in the film.
	When he sent you a subject line, it says Badondi, Sandy Hook documentary.
	What did you think that meant?
	No, you were asking me about what was going to be in that Sandy Hook documentary.
	And I answered you that there was no discussions of specific topics of the Sandy Hook documentary.
	Right.
	So now I'm asking.
	It could have been about anything that had to do with Sandy Hook.
	Whether Alex was trying to present his case, or it's just, again, I don't want to speculate.
	I understand.
	That's the answer to your last question.
	My next question is, when Rob Dew sends you an email that says Badondi, Sandy Hook documentary, what did you think that meant?
	I don't understand the question.
	When you get an email from Rob Dew, it's part of your job duties to understand your employees communicate with you, right?
	Yes.
	All right.
	So when you got this email, did you just not pay attention to it, or did you form an opinion about what it's about?
	No, I don't think you understand how the production works for the company.
	So I'm trying to explain to you.
	This looks as if Rob Dew is suggesting a guest for the show.
	Well, the show is not a documentary, right?
	The documentary is something separate from the show.
	The subject matter is for the previous email, not the email that's.
	This is a forwarded email to me with information about the guests that's being discussed in the previous email.
	I don't see where there's any talk about a guest.
	Can you point me to where there's a guest?
	Sheila asked me to provide you with her telephone number.
	Sure.
	Is she going to be a guest?
	What tells you here she's going to be a guest?
	It says right there.
	Where?
	Where does it say again?
	Sheila Matthews, who you met in Hartford at Halbig hearing, is a friend of mine who lives in the next town over.
	Maybe he just wants her to talk to him.
	Maybe Sheila Matthews has some information that would be a bombshell for the Sandy Hook documentary.
	So I'm trying to clarify to you because you don't seem to understand how the operations work.
	I'm telling you, the reason Rob Dew is sending me this email is to consider this guest in case Alex wants to have her on the show.
	There's no talk of the show here.
	Let's talk of a Sandy Hook documentary.
	Hold on, let's back up for a second.
	Let me just go ahead.
	Please let him ask you the questions and answer them to the best of your ability, please.
	Okay.
	Thank you.
	When this is talking about, let's talk about informers and how it works, right?
	Because I better get that cleared up because I don't know how it works.
	But there's a show called the Alex Jones Show.
	Right?
	Yes.
	There's also a show called The War Room of Owen Shore.
	Yes.
	There was a David Knight show at one point, right?
	Yes.
	There is also, though, an entirely different department of people who work on things like documentary films.
	Somebody like Rob Jacobson, right?
	That was one of his jobs.
	And he doesn't work on the show, right?
	He didn't do show work.
	He did documentary work, correct?
	Not on a regular basis, I would say.
	Okay, so you understand that there have been documentary films made by Alex Jones.
	Yes.
	They're not his show, are they?
	No.
	Okay.
	So when you're telling me in this email that there is talk of a guest on a show, there's no talk in this email from Mr. Bedondi about a guest or the show, is there?
	There's talk about a documentary, right?
	And somebody he may want to talk to.
	Yes, he may want to get this lady on.
	Now that's what Rob is saying, right?
	Rob is saying he wants to get this lady on.
	Get her on what?
	On the show.
	Where do you get that from?
	That's how we communicate.
	All right, well, so she's not going to be in the documentary?
	I have no idea if she was going to be in the documentary.
	The email is subject line Sandy Hook documentary.
	I already explained that point.
	Okay, so despite the fact that it's emailed Sandy Hook documentary, despite the fact that Dan Bedondi said that Alex Jones announced he is going to do a Sandy Hook documentary film, you insist this email is about the show.
	Objection form.
	Is that your testimony?
	The guest that's mentioned in the email with the subject matter Sandy Hook documentary to Rob Dew includes the information about a person that has to do in some way with Sandy Hook.
	Rob Dew looks at that email, he forwards me the email with the subject matter.
	It's going to be forwarded the way it was sent to him.
	He's sending me this information so that I can take a look at the guest that's being suggested that I can run this guest by Alex and find out if Alex wants to have this guest on the show or not.
	Tell me what you did to figure out who this guest was and how to pitch it to Alex.
	I have no recollection of this guest whatsoever because I, from you're asking me in my capacity as a producer for this specific email?
	I'm asking you about actually editorial discussions of Sandy Hook, so I'm actually asking you as the comments.
	There was no response to this email that I provided.
	If Rob Dew was sending to you a source from Dan Bedondi, the truth warrior, we can be fairly certain that that guest was going to support the idea that Sandy Hook was fake, right?
	That's a fair assumption?
	Objection form.
	Don't answer that question.
	Why not?
	Because that's extremely misleading.
	That's not a proper basis to object to Waxer.
	Go read the rule.
	Madam Corporaporter, can you read my question back?
	You just said my base is not proper.
	If Rob Dewe was sending to you a source for Dan Bedondi, the truth warrior, could you be fairly certain that that guess was going to support the idea that Sandy Hook was fake, right?
	That's a fair assumption.
	Have her answer the question or I'll move for sanctions.
	I will.
	I will move to compel that answer.
	That if you're having her not answer that question, it's very clear what you're trying to hide.
	I want her to answer the question.
	I don't appreciate the threats when I'm.
	It's not a threat, Brad.
	It is a threat, and I don't really appreciate it.
	You know what?
	Look at where we are in this case.
	Go ahead.
	If you know the answer to the question, proceed with answering the question.
	I get sent a lot of guests on a daily basis.
	There's no way for me to know this specific guest would be pro-Sandy Hook conspiracy theory or the official version.
	Because if you've watched other videos of Alex Jones, he would have people on the show who would disagree that it was staged.
	And he allowed that debate.
	Even Wolfgang Haubig was on the show at the same time with a person who disagreed with him.
	And that was a debate.
	And Alex allowed both sides to be public with their statements.
	Okay, first, that happened once, correct?
	There's never been any other debate or guest who supported the idea that Sandy Hook was real, correct?
	Alex, multiple times, have said that he didn't know what exactly happened in Sandy Hook, that he believed that the kids died, but that there was a cover-up.
	He said it multiple times, and he said it was in the public's best interest, in the best interest of those children, to find out the exact truth that happened and how those kids died.
	Yeah, that doesn't answer the question of whether more than one debate with guests who supported Sandy Hook being real.
	That's a whole bunch of stuff about what Alex Jones said at some point that you think he said.
	I'm asking you who said that.
	That's not the question, though, Ms. Garpova.
	The question is, was there more than one debate with a guest who supported the idea that Sandy Hook was real?
	Has that ever happened other than the one time that they brought Keith Johnson on and railroaded him with Wolfgang Haubig?
	Objection form.
	Ever?
	From my recollection as a producer, there have been callers calling into the broadcast that were allowed to state their opinions that were disagreeable with Alex Jones.
	That's not a guest, though, is it?
	If a caller is being allowed on the show.
	You know what a guest is.
	That's not a guest.
	That's not somebody who's been booked to come on the show.
	Right.
	There is never, other than Keith Johnson, when he was brought in with Wolfgang Haubig, there has never been a person who's been a guest on the show who said that Sandy Hook was real.
	Correct?
	Yes.
	Additionally, when it comes to Dan Badondi, you may not know what other guests may have said.
	You may not know whatever.
	But you know Dan Badondi believes Sandy Hook is fake, correct?
	The company knows that.
	Dan Badondi had questions about Sandy Hook just like Alex, just like other reporters.
	When you say questions, when Dan Badandi does stuff like chase people down on the street and yell at them, these are the people who covered up Sandy Hook.
	They're criminals.
	You're all going to jail.
	Do you think those are questions?
	Do you believe that?
	Objection form.
	On what topic of the depot notice is this covered?
	We're in editorial discussions about Dan Badondi, which is and I'm also, Brett, she's copied on that email.
	This is personally to her.
	understand that?
	I'm asking you.
	You already have a running objection to it all.
	You've asked the company.
	So I'm allowed to reiterate that.
	And you have a running objection on every one of those.
	That is a misleading question that you're going to ask her what the company believes whenever you know that that is outside the scope.
	And I just did.
	And it's running some pretty good.
	Great, well, I objected anyway, so go for it.
	If you have a problem with me reasserting my objection, despite having a right one overall, I have a problem with you asking a misleading question asking for the company's position on a person when that's clearly not covered by the scope of these deposition topics.
	With someone who is here to testify on the topics on behalf of the company.
	There's a misleading way to approach the questions with this witness.
	You know what Dan Badanti believes about Sandy Hook, don't you?
	You personally, Daria Caprova.
	I do not.
	You don't know?
	I personally do not.
	No, as an InfoWars producer here to testify as behalf of the company, you also didn't do anything to prepare to know what Dan Badanti did, right?
	That's not part of the topics you were asked to talk about today.
	I know Dan Badanti had questions and believed that there was a cover-up in the Sandy Hook case, which he did his hardest trying to investigate as a good reporter would.
	You were testifying here right now, Dan Badanti is a good reporter.
	Is that what you're testifying to?
	Insofar as him trying to investigate what happened and find the truth, that's what a good reporter is supposed to do.
	You've seen any videos of Dan Badanti in Connecticut and what he did?
	You ever watched him?
	Not recently.
	You might not be the best person to qualify to talk about whether Dan Bedondi was a good reporter in Newtown, are you?
	Objection formed.
	That's not what she said.
	That's what I'm asking her a question, Brad.
	I'm asking you, you may not be the best qualified person to talk about what Dan Bedanti did in Newtown, correct?
	You, Daria Caprovo, InfoWars employee.
	My definition of a good reporter is somebody who seeks the truth and is going to great lengths in order to find it.
	So you don't, you, but you can admit to me right now, you don't know what Dan Badanti did in Newtown.
	Specific actions, I don't know, but you just mentioned what.
	Do you know about St. Rose of Lima Catholic School in Newtown?
	What Dan Bedondi and Wolfgang Hobby did there?
	Not off the top of my head.
	Okay.
	Show me top 43.
	Yeah.
	Shoni owner of Marx's exhibit 13.
	Do you recognize that?
	I haven't seen this document before.
	Okay, so you understand that, like we were talking about earlier, the company has produced sets of documents and pieces over the course of three years, right?
	Yes.
	Okay.
	I'll represent to you that, like, what you're looking at right now, you'll see FSSTX-082669.
	Okay?
	Yes.
	Which would represent to you that this is the 82nd,669th page that InfoWars has produced in this lawsuit.
	I'll represent to you this was produced to me extremely recently, like within the last little bit.
	And you understand that InfoWars was ordered to produce analytics about their website, right?
	Yes.
	Do you know anything about what was produced?
	Do you know What analytics were produced to the planners?
	Website traffic?
	Right.
	I mean, obviously, that's what analytics are.
	Do you know what actual analytics, where they came from, what was produced, any of that?
	It came from the IT department with the software they use for analytics.
	Right, this isn't an InfoWars document, right?
	This was not, this document was not generated using InfoWars stuff, InfoWars products or InfoWars.
	I'd have to talk to IT about that.
	So you don't know the origin of this document, right?
	I do not.
	I believe, and I was hoping I could ask you about this, because you're supposed to testify about the documents that you produced.
	And I know, look, there's been a lot of documents, but I was hoping maybe the ones that were just produced, we could talk about.
	But I think this is a Google Analytics doc from Google.
	Do you know if I'm right or wrong, or do you not know?
	I don't know.
	Okay.
	From what it looks like to me, I can't, you see, there's a date up at the top that says January 1st, 2012 to June 16th, 2019?
	Yes.
	Okay.
	That looks to be a period, a period of time in which this analytics were collected.
	Do you have any reason to dispute that?
	No.
	Okay.
	So what we have here is you see how we have a column of pages that list for each of these URLs the total unique page views of that URL?
	Correct.
	Okay.
	Now you'll notice that some of the, on this list here, it goes through one, this is just the top 20 for the website.
	You'll notice that some of them have what I would call landing pages that aren't specific to a certain story.
	For instance, infowars.com/slash category, infowars.com/slash watch Alex Jones show.
	You know what I mean when I say that?
	Yes.
	Okay.
	And so none of those URLs are associated with a specific story, correct?
	Correct.
	The first URL that we would see that's associated with a specific story is a URL titled Graphic, Shocking, Complete Video Shot from Virginia Gunman's Point of View, correct?
	Yes.
	Okay, and the unique page views for that article shown on this document is 4,265,000, correct?
	Correct.
	Okay.
	If you look at the very next entry that is a story, right, that would be number 13, correct?
	Because number 8, 9, 10, 11, and 12 are not stories.
	Correct.
	Correct?
	Okay.
	And so number 13 is Boston bombing culprits found, correct?
	Correct.
	Okay.
	So number 14 is FBI says no one killed at Sandy Hook, correct?
	Correct.
	And that shows a unique page views of 3,301,616 people, right?
	Yes.
	Okay.
	So from this analytics chart, we can determine that for that time period of January 1st, 2012 to June 16th, 2019, the story FBI says no one killed at Sandy Hook was the third most popular site in unique page views on the entire InfoWars website.
	The company would agree with that?
	Question form.
	Which story again?
	Number fourteen would be the third most popular story in terms of unique page views ever published on the Infowars site during that period of time.
	According to this graphic, yes.
	Okay.
	45?
	I'm sorry, 47 landing pages, is that what you got?
	I'm sorry, 47 landing pages, is that what you got?
	I'm sorry, 47 landing pages, is that what you got?
	I mean, does this, if we can go back to this previous graphic real quick, it does provide other information like How long people were on that page, the bounce rate.
	So I'm not an analytics expert, so, but I think that information is important as well, other than the unique page views that you attracted attention to.
	Objective is non-responsive.
	I'm going to show you what I've marked as exhibit 14.
	You'll see this is a similar chart, right?
	Same date range: January 1, 2012 to June 16th, 2019?
	Yes.
	Okay.
	Now, this talks about landing pages.
	Do you see where it says that in the top left corner under the words analytics?
	Okay.
	Now, here we also have landing pages and numbers of sessions, correct?
	Yes.
	Okay.
	Now, on this one as well, for this type of analytic charts, in terms of sessions on InfoWars, number eight, FBI says no one killed at Sandy Hook, is the third most popular story in terms of sessions on InfoWars, correct?
	Thank you.
	Yes.
	Okay.
	Now, in terms of session duration, do you see where it says average session duration?
	Yes.
	Okay.
	Now you see where it says FBI says no one's killed on Sandy Hook.
	You have an average duration of just under a minute, right?
	Yes.
	But if you look at number 11, Saudi Arabia has 100,000 empty air-conditioned tents that can house 3 million people yet has taken zero refugees.
	The average session duration there was 16 seconds, right?
	Correct?
	Yes.
	And for other landing pages, say number nine, listen on the internet, you got an average duration of four minutes and 28 seconds, right?
	Yes.
	When someone clicks on the listen on the internet link, that typically means you're going to listen to the radio broadcast, right?
	Yes.
	That's kind of expected they might be on there a few more minutes than just reading a story.
	That's expected to InfoWars?
	projection form.
	isn't it I'll come back to that too bad.
	We'll save now.
	Correct?
	What was the question?
	not a corporate can help me out here that question back Just one second.
	No problem.
	No rush.
	Okay, it's kind of expected they might be on there a few more minutes and just reading the story.
	That's expected in InfoWars.
	When people go to a stream to listen to the stream, it's expected that they would be listening to the stream as opposed to reading an article.
	Okay.
	Has InfoWars, when making its editorial discussions and decisions about the Sandy Hook coverage, has it ever attempted to use its Sandy Hook stories and videos in a strategic way to attract viewers?
	No.
	Okay.
	The idea that we would make some video uploads about Sandy Hook as a strategic measure, that's not something that would be a part of InfoWars editorial discussions.
	Never.
	Never.
	Okay.
	Give me time 18.
	Mark, we've been going for a while.
	I'll go ahead and ask your question about after this exhibit.
	We take a break, please.
	Yeah, I think we can do that.
	Obviously, I don't want to keep these people here past 5:30, but I think I can do that, so it shouldn't be a deal.
	I'm hoping we can do that.
	Okay.
	I'm going to show you what I've marked as exhibit 15.
	Can you tell me who at the top here?
	Well, actually, let me start at the bottom.
	At the bottom corner, you see there's a mark that says FSS TX-076069, correct?
	Yes.
	Okay.
	Now, can you tell me first, let's just look at the top of the email.
	Who is Darren?
	Darren McBreen.
	His title in 2015, do you know?
	Editor.
	Okay, and Rob Dew, we've talked about, correct?
	Yes.
	Louis S. We've talked about, right?
	Yes.
	Okay, the next other person that's on here is Travis Knight.
	Do you know who that person is?
	Yes.
	Okay, and do you know what their job position is?
	Editor.
	Okay.
	And then this email is being sent from Louis S. to Travis Knight, Rob Dew, and Darren.
	And the subject is video files for Facebook upload on September 24th, 2015.
	That's correct?
	Yes.
	Okay.
	He asked them, can I get these video files for future strategic Facebook uploads, correct?
	Yes.
	One of the files that he is asking for is why people think Sandy Hooks is a hoax, correct?
	Let's see.
	Yes.
	Okay.
	So we can tell from this email, and then Darren follows up and says, any luck finding these, correct?
	Yes.
	We can agree from this email that editor Darren and Louis S. were attempting to use a video about Sandy Hook being a hoax as a future strategic Facebook upload, correct?
	It's one of the video, one of the videos out of eight videos that he's requesting.
	Sure, so it is one of the videos being used for a future strategic Facebook upload, correct?
	Objection form.
	Yes.
	Okay.
	Can you go to tab 19?
	Let's look at that.
	Yeah, let's go ahead and take a break.
	All right.
	Any time is 4.08 p.m., we are off.
	Time is 4.17 p.m.
	your arm Skirpova I'm handing you what I'm marked as exhibit 16.
	Alright, down at the bottom is labeled FSS TX-079546, correct?
	Yes.
	Okay.
	And this email was sent on April 16th, 2015?
	Yes.
	Okay.
	We talked about Louis S. Yes.
	And we've talked about Leanne before.
	She's Leanne McAdoo, right?
	Yes.
	Okay, she's an InfoWars reporter.
	She was, yes.
	She was.
	Okay, at the time of this, were they both reporters, editors?
	What were they?
	Both who?
	Both individuals on this email.
	Lewis, I think it was uploader, editor.
	Leanne was a reporter.
	Okay.
	This is a subject list called playlist ideas, correct?
	Yes.
	Importance was labeled high, correct?
	Yes.
	The playlist ideas that are listed in this video, I'm going to read to you, okay?
	Vaccines already up.
	Let's stop there.
	When it says already up, would it be your assumption from seeing documents at Infowars, meaning that that playlist has already been created and is currently up on the internet?
	Yes.
	Okay.
	Then it says Police State, InfoWars Health, Alex Jones Show, Second Amendment, Rance, Celebrity, Border, TSA, Geoengineering slash Chemtrails, GMO, Resistance, Boston Bombing, Sandy Hook, Victories, Winning, Good News.
	Correct?
	Yes.
	Okay.
	So from this list of playlist ideas, we know that Sandy Hook was one of the ideas for playlists that was being proposed inside of InfoWars during editorial discussions.
	Correct?
	Connection form.
	One of many ideas for the YouTube playlists.
	No, I understand.
	Look, I can completely understand that when I ask a question, you want to push back and give information you think is going to be helpful.
	I get that.
	I know that there are other.
	We just read them all.
	We read all of these topics here.
	But in a very simple statement, we can understand that Sandy Hook was one of these playlist ideas, correct?
	Well, I'm just trying to be more accurate because you're trying to present more of a skewed point to misrepresent How our operations work.
	So I'm trying to clarify that Sandy Hook was among the topics for playlists that they were in the process of organizing a YouTube channel for.
	Yeah, and one of the things you wanted to have on that YouTube channel, or at least one of the things that the company did through its editor, Louie, here, is they wanted to have a playlist about Sandy Hook.
	This is relevant in point of 2015.
	Right, because according to the company, two and a half years after Sandy Hook, it was still a relevant thing to talk about, right?
	The videos were archived.
	They wanted to class to categorize them for, yeah?
	Okay, I didn't ask how the videos were categorized.
	Didn't ask any of that.
	All I asked was: the company believes, when it was doing its discussions on Sandy Hook, that Sandy Hook, two and a half years after the shooting, was something that needed to be covered in the news.
	What discussions about Sandy Hook?
	The editorial discussions you've had in the company about Sandy Hooks.
	The different topics.
	There's no discussion of Sandy Hook.
	I know that.
	I'm asking you about the editorial discussions in the company.
	Your position is for the company that in its editorial discussions that it came to the conclusion that two and a half years after the shooting, Sandy Hook was a relevant topic to be talking about on InfoWars.
	Correct?
	It is one of the topics for playlists in this email.
	I'm not asking.
	Can you take that email?
	See that stack of exhibits you have right now?
	Can you put them aside just out of your view for just a second?
	Okay, now, editorial discussions inside of InfoWars.
	Infowars made the decision that two and a half years after the shooting, that topic was a relevant thing to be talking about on their news broadcast, right?
	Again, I would have to refer to the YouTube channel with the playlist of Sandy Hook.
	I'm not, Ms. Pervova, I don't know if I can make this any more clear.
	I'm not asking about the playlist anymore.
	Correct.
	All right, I'm not, we're done with that document.
	We're talking about something totally different.
	I don't care what happened in terms of the YouTube playlist.
	What I'm asking about is when InfoWars was making editorial discussions about Sandy Hook, part of those discussions included the conclusion that two and a half years after the shooting, that event was a relevant thing to be talking about on InfoWars.
	Correct?
	Objection form.
	False, because I already answered that question.
	We did not have editorial discussions about Sandy Hook.
	Okay.
	We've seen a couple emails here today with people talking about how InfoWars should cover Sandy Hook, right?
	Correct?
	There were a few emails mentioning Sandy Hook.
	That's not what I asked you, Ms. Karpova.
	Can we go back to those emails and I'll Okay.
	And I'm asking you, in your recollection of what we've spoken about here today, we've had people talking about how Infowars should cover Sandy Hook.
	Do you remember that email from Mr. Badondi that was forwarded to you?
	Yes.
	That was a discussion about how you should cover Sandy Hook, wasn't it?
	No.
	Wasn't it a discussion with Rob?
	Didn't you tell me that Rob Dew was making a recommendation that this is somebody Alex should have on the show about Sandy Hook?
	He didn't say he should have it.
	It was a proposed guess.
	Right, so we're having some discussions about who should be on the show.
	Maybe we should have this lady.
	That was a discussion that you were actually copied on, correct?
	Yes.
	Okay, so we can drop this idea, can't we, that there were no editorial discussions?
	Because we've seen one that you were included on, right?
	Now that I'm looking also at this previous email that we've discussed, it says video files for future strategic Facebook uploads.
	I just want to be clear that I think what you're referring to as a strategic upload refers to some kind of marketing scheme for Sandy Hook analytics videos.
	What this refers to is a almost like an auto post that is scheduled for future uploads.
	Objection non-responsive.
	Let's go on to talk about Wolfgang.
	Haubig, would you mind opening up your blue folder for me?
	You see that article on top?
	Yes.
	That's something you brought today, and you were talking about how much you were talking about, like you wanted to read it today, right, to talk about Wolfgang's qualifications?
	Yes, his bio, specifically.
	Right, his bio.
	Okay.
	So this article that you've brought is what you believe you is.
	Let me ask you this.
	Is that something that InfoWars had before you went and looked for it for your deposition, or is that something that you got for your deposition to help you acquaint yourself?
	The latter.
	Okay.
	So before this deposition, InfoWars did not have this document in its corporate files?
	Correct.
	So files that I looked through that I searched for Halbeck's bio, I could not find anything, as well as seems like he's been memory-holed on the internet as well.
	So that's the only article that I could actually find in an archive mode where it actually listed his bio.
	Did you go try to search Wolfgang Halbeck on Google?
	Did you do that?
	Yes.
	Okay, and so when you say he's been memory hauled, I take it you're ignoring the dozens of mainstream articles about Wolfgang Halbig.
	You don't want to use the mainstream article.
	I'm talking specifically his bio and his credentials have been memory hauled.
	Okay.
	There are mainstream articles that talk about Wolfgang's credentials or his alleged credentials, right?
	Did you see any of those?
	I've looked at many of them and I did not see an actual biography of his accomplishments.
	Okay.
	I've not seen.
	Except for this article, which is why I printed it.
	So you brought us instead this Exhibit 1F written by Dr. Eowen.
	Do you know who that is?
	I do not.
	I didn't bring it for the author.
	I brought it for the bio that is included in this article.
	Right, so you got to, one thing you probably need to do, wouldn't you say as a producer of a journalistic organization, particularly when dealing in a lawsuit like this and coming to testify, is you should probably try to figure out the veracity of the bio being provided to you.
	Right?
	Do you have any faith, sitting here today, that the information contained in that article is accurate?
	Yes, because even the people who disagree with Wolfgang-Halbig admit that he has a lengthy bio that's impressive.
	Who said that?
	I've read it in different articles when I was searching for his bio.
	I thought you said his bio has been memory hold.
	Well, exactly.
	They failed to mention his bio, but they do acknowledge that he's got an extensive bio if that bio is covered accurately.
	But I could not find the actual bio because the bio was not included except for this article.
	You think it's covered accurately there?
	That's what you think?
	Yes.
	Okay.
	And the person who wrote that, Dr. Eowen, do you know who that is?
	No.
	He doesn't have a last name, right?
	I do not believe that's the person who wrote this article.
	Go back and look at the first page.
	No, no, no.
	I understand that the article was posted by the said Dr. Ewen.
	The bio that's been screenshotted here, it's not even typed, it's screenshotted from somewhere else.
	From where?
	I do not have the source, the exact source where it was printed from.
	You have no idea where it is.
	But like I said, people who disagree with Halbig and who criticize him admit that his bio is impressive.
	I'm still waiting to see that.
	Do you have any information you can point me to that?
	Anybody you say who's an opponent of Albig who admits that he has an impressive bio?
	Yeah, I would have printed those documents if that's what I thought I needed for you, but to my satisfaction, I did the research and to my satisfaction, this bio checks out.
	Let's talk about what satisfied you, which is apparently a screenshot that you cannot identify where it came from, printed in an article by Dr. Eowen, who did you who, first of all, that's let me pull this question back.
	Did you know Dr. Eowen wrote chapter two of Jim Fetzer's book, Nobody Died at Sandy Hook?
	Did you know that?
	No.
	Okay.
	Do you know what Fellowship of the Minds is?
	No.
	Okay, go to the last page of your article there.
	Do you see actually the second to last page?
	You'll see the very end of the article.
	Do you see where it says who Dr. Eowen is?
	Who does it identify him as?
	The editor of Fellowship of the Minds.
	Okay.
	You know about Mr. Fetzer being involved in Fellowship of the Minds?
	No.
	That has no real relevance to why I brought this article.
	Right.
	So in other words, just like in normal InfoWars practice, if you find the information you're looking for, you don't really care where it came from, right?
	Objection form.
	No.
	But you don't care who this person's author is, do you?
	You didn't care to find out.
	No, I. The value of this article is in the opinion of the writer.
	The writer has included the bio that was taken from another source.
	Which we have no idea what it is.
	So wouldn't you say hole, we can't find it.
	The official Wolfgang Halbig's website is no longer.
	I'm sure it was there, it was posted there at some point.
	Yeah, I'm sure Wolfgang Halbeg has said a lot of things about his credential.
	Do you think they're all true?
	Do you think Wolfgang Halbig is a reliable source about his own credentials?
	He's responsible for making sure that the claims for our guest are all accurate.
	They're responsible for providing their bios.
	Thank you.
	let's look at uh...
	you get out there Okay.
	One thing you can agree is that free speech systems help Mr. Halbig raise money, correct?
	i don't have any record of that You know if there are any documents produced in this case like that?
	Let me pull that back.
	Have you seen documents in this case relating to whether or not InfoWars helped fund Mr. Halbig?
	Not that I can recall off the top of my head.
	Okay.
	Yeah, I'm going to skip that because of that.
	tab 23.
	At some point, there was a discussion inside InfoWars.
	I don't know who had it, but I'm going to go ahead and assume there was a discussion inside InfoWars about whether we should be using Wolfgang Halbeck as a source.
	You acknowledge that?
	ejection form.
	Or did that discussion never happen?
	yes later Years later, there were questions that arose about credibility of Halbig.
	When?
	I don't have the exact date for that.
	Look, here's the thing.
	Just over the years, things have come up that...
	I don't have the exact things for you.
	Okay.
	So you're able to, you brought me from Fellowship of the Mines and the guy who wrote Nobody Died at Sandy Hook, you brought me a bio.
	But in terms of what facts y'all came up with that were bad against Halbig, you can't point me to any of those, right?
	At the time, we had no reason to believe that Mr. Halbig wasn't who he said he was in his bio.
	His bio was not being questioned by anybody out there.
	Company, for instance, let's put it this way, right?
	Wolfgang gives you his bio, it looks pretty good, you go with it.
	But what if somebody, if somebody had come to the company and said, hey, watch out, y'all really need to look out for Wolfgang Halbig and his credentials.
	I don't think they are what he says they are.
	I think you should doubt them.
	If the company got a message like that, would it have done its due diligence and tried to figure out if Mr. Halbig was really qualified?
	Objection form.
	Hypothetical?
	Sure.
	Yes.
	Yes.
	Okay.
	But because that didn't happen, your testimony is here today.
	The company had no reason to go double check Wolfgang Halbig's credentials.
	Well, you know, you're talking about after the fact, when Wolfgang Halbig was a guest on the show and he provided his credentials.
	Right.
	There was nobody At the time, who was coming out and saying do not have this guest on.
	Right, right.
	So, in other words, your testimony is in the absence of anybody doing that, right, Infowars really didn't have a reason to go double-check his credentials, right?
	The company's general guideline for a producer is to spot check the biography.
	Give me tab 36.
	We're going to do that before we do this.
	Thank you.
	Thank you.
	Where is the second page of this?
	Is there not another page of this?
	Hold on, I may have to have that printed.
	Oh, gosh, darn it.
	Hold on.
	What tab did that come out of?
	I'm sorry.
	Okay.
	Brad, just so I don't have to slow down.
	Can I just confer with you on this document?
	Okay, so we have a document here, and we don't have the second page, but that's the second page.
	And I can print that little part out, or I can just read it to her, and we can agree to put that in in a second.
	I don't know what you want to do.
	I can take a break and print it a few more times.
	Well, how about if will you show?
	Yeah, yeah, I'm going to show it to her.
	I'm going to give her my computer.
	Exactly.
	Read it to her and show her.
	In other words, the document that I'm going to show her is just the computer copy.
	Yeah, that's fine.
	Okay.
	All right.
	I'm going to go ahead and mark this.
	Can you tell me?
	Can you show me the last exhibit I put in front of you?
	Not the folder.
	Okay, thanks.
	Okay, I'm going to give you this for this stack, but I'm actually going to show it to you by PDF, okay?
	And the reason I'm going to show it to you by PDF is because it cuts off.
	And it has this little part right here.
	So what I'm going to do for you is I'm first just going to bring this up, okay?
	So that you can see the last part, okay?
	Okay.
	All right.
	And that's what's on that page.
	And so I want to read this together, the second page of exhibit 17 for you.
	And you'll notice we'll have to scroll up to see who wrote it, right?
	You don't know who Robert Heath is, right?
	You don't know who Robert Heath is, I would take it.
	No.
	Okay.
	But he's writing to the writers at Infowars.com?
	Yes.
	Subject is Wolfgang Haubeg?
	Yes.
	Date is March 14th, 2014?
	Yes.
	Okay.
	Down here at the bottom, we see this document is marked FSSTX-040803, correct?
	Yes.
	Okay.
	Mr. Heath writes, Dear sir and madam, you would be well advised to check Wolfgang Hauberg's credentials.
	Best wishes, Robert Heath.
	I read that correctly?
	Yes.
	Okay.
	Now I'm going to give you this.
	This is the remainder of the document.
	Yeah.
	The person who replies back is Adon, correct?
	Yes.
	Adon Salazar is a writer at Sandy Hook.
	Adon Salazar is a writer at Infowars, correct?
	Yes.
	Adon Salazar has worked on Sandy Hook coverage for Infowars, correct?
	Yes.
	Okay.
	Adon Salazar writes and says, Robert, thanks, but what on earth do you mean?
	The guy seemingly has credentials up the wazoo.
	Your email is much too vague to follow up on.
	Thanks, Adon.
	Did I read that correctly?
	Yes.
	Okay.
	I'm going to read this next part of the email.
	And it says, dear Adnon, and he's got his name wrong, right?
	Right.
	Okay.
	He says, thank you very much for your attention and reply.
	Yes, he, quote, seemingly, unquote, has many credentials.
	But do you know that from any other source than he himself?
	I really hope he's genuine and that I'm Just being paranoid and wasting your time.
	But if you tried looking him up in Google as I have, I don't know, but doubt whether it would make a difference that I'm in the UK.
	But I use Google as worldwide.
	I can find no trace of him, except in connection with his current activities on Sandy Hook.
	For example, I cannot find him on the list that exists of expert witnesses, of which he has categorically stated he was one, concerning Columbine.
	I cannot find any reference to him prior to 2012 as a school safety expert or as a school principal.
	As a comparison, all the teachers or head teachers and principals that I know can easily find prior to 2012 the same for a sample of the professionals I know.
	I tried the same sort of search for random people I do know who have a much lower profile C V than Halbig and get many results for them.
	As you know, if one is, for example, on a committee, no matter how small or local, and the meetings of a mean and the minutes of a meeting are online, you will find your name very quickly on a simple name search, especially if it is an uncommon name.
	I can't find a trace of him.
	And he has an unusual name, which should make it easier.
	I will look again now and spend more time and try to be more resourceful in finding him in any context prior to 2012.
	If he was using a pseudonym, that could explain it.
	But why would someone looking for transparency do that?
	What if he drags everybody along the line of quote, no deaths, unquote, which Alex rightly didn't commit to?
	Would not all the questions and doubts be illustrated to the public just as another crazy conspiracy theory if it was exposed that definitely there were in fact deaths and that Halbig was a con man?
	Again, sorry to waste your time if I have.
	I will look again.
	Best wishes, Robert.
	I've read that correctly?
	Yes.
	Okay.
	And from what we can tell here from this email, this appears by our you have no reason to dispute that this is a genuine and accurate email that came from InfoWars files, right?
	Yes.
	All right.
	Do you know if he was an expert at Columbine?
	Do you know if that's a lie or not?
	I don't know.
	Okay.
	Is there a follow-up from Adam?
	I don't know.
	I don't know.
	I will answer you.
	I told you I was going to answer questions for you today.
	I'll answer you that one.
	I don't know.
	I'd love to know.
	donut During the time that InfoWars was relying on Wolfgang Haubeg, let's actually, let's establish that time period, if you wouldn't mind.
	We understand that claims made by Wolfgang Haubeg were being published on Infowars in 2014, correct?
	Yes.
	Claims made by Wolfgang Haubig were being published on Infowars in 2015, correct?
	Yes.
	2016, correct?
	That's what you told me about that final statement video, right?
	When we talked about that earlier?
	Yes.
	Okay.
	2017, right?
	Sandy Hook Vampires Exposed, correct?
	Yes.
	Halbig stuff in there.
	So during the time 2014 to 2017, when InfoWars was publishing Wolfgang Haubig's claims, InfoWars had received information that Haube was directly harassing the victims of the tragedy.
	Correct?
	projection form.
	Is there a document that you're facing?
	I want to know what you know about it.
	Do you know if the company was aware that Wolfgang Haubig was harassing people, directly harassing people, anywhere between 2014 and 2017?
	No.
	You don't know, right?
	Okay.
	I want to show you what I have marked as exhibit 18.
	Do you see at the bottom of that page there is a Bates number that says FSSTX-039550?
	Yes.
	Correct.
	Alright.
	Now we can see this is an email from Wolfgang Halbig, right?
	Yes.
	Okay.
	Do you know why Infowars has this email?
	May I read the email?
	Yeah, go ahead and read the whole email and we'll talk about it.
	Thank you.
	Okay.
	Okay, so first of all, how does the company feel about this email?
	Objection form.
	What's your objection?
	Well, vague.
	How does the company feel?
	Sure.
	No problem.
	That's good.
	Yeah, how does the company feel about this email?
	Mr. Haubig is asking, seems to be concerned for the well-being of this child.
	Thank you, Ms. Carpova.
	Let me actually, I want to read this email into the record so we can talk about it.
	Okay.
	Mr. Haubig writes, Michelle, how could you and your husband, as responsible parents, even allow your precious child, Josephine, to attend that filthy and deplorable-looking school on December 14th, 2012?
	The school, as you must know, is and was a toxic waste dump, as reported by the environmental consultants who requested more money from city of Newtown leaders for demolishing the school and transported all the high levels of lead paint, high levels of asbestos, and especially the high levels of PCPs and the groundwater at Sandy Hook out of state.
	Josephine, your child should have expected more from you before that tragic day as a parent.
	You are supposed to protect her from serious lifelong health risk when you send her to that school every day.
	Why would you as a parent and all those other parents who supposedly lost a child to gunfire allow their children as you did to serious toxic waste?
	This all unfolded before the first shot at that school even occurred.
	Did you not see the filth and deplorable conditions when you went to that school or are you blind?
	I do not understand unless you explain it to me and the world why you and your husband failed Josephine, who was a non-verbal child as you stated and depended on you for her safety.
	She needed you to protect her from all the serious health risks that you sentenced her to on a daily basis.
	Now you talk about school security.
	You have got to be joking.
	You have all these experts on your staff who are now part of your conspiracy.
	They should be ashamed of their actions in supporting you.
	A mom puts her own child at risk on a daily basis, is now the expert on school security.
	I look forward to meeting you one day when I can take your deposition, not about the shooting, but why you and your husband failed Josephine by sending her to that filthy and deplorable school with all that toxic waste.
	We call this child endangerment when you know of the danger that you expose your child to serious lifelong risks.
	You must have known without a doubt because the pictures do not LI, which I assume is why.
	You put her life in serious risk every day knowing how filthy and deplorable that school is.
	I am enclosing photos that you must recognize since you took your child to school and having a child in special needs, you would expect a school environment and school climate that allows children to learn and teachers to tech, which I believe is teach, right?
	Please explain to me if you can why a school principal Dawn Hopspring would allow her school to be so filthy and deplorable looking.
	There is not one female elementary school principal in the country that would allow her school to be that filthy and deplorable, both inside and outside, and most of all, allow her school to become a toxic waste dump, placing every child and her school staff in serious lifelong health risks.
	Right?
	All the pictures are taken by the major crime squad from the Connecticut State Police.
	Please respond since you are now the expert on school security.
	Wolfgang W. Haubig, www.sandyhookjustice.com.
	I read that correctly.
	That's one of the interpretations.
	I mean, the inflections that you put on the email could be read in a completely entirely different way.
	A lot of different ways, right?
	Right.
	yes I want tab 40.
	Awesome.
	Yeah, that's not the easiest.
	No, this is.
	I'm sorry.
	I want.
	Is tab 40.
	Is that that after tab?
	No, that's 39, and then there's not a 40.
	What not?
	And there's nothing before that one?
	There's 37, 38, 36.
	That is weird.
	Okay, hold on one second.
	I don't know where the heck that is.
	Because I know I saw this picture in the notebook, too.
	That's what's weird.
	Yeah, right?
	Okay, cool.
	That's it.
	Okay, yeah, let me see that one.
	I don't know what happened.
	That's okay.
	We'll put 40 back.
	No, I'm going to.
	We'll be going to the next one.
	Yeah, so just leave that one out.
	Okay.
	Maybe I'm going to put in front of you what I've marked as exhibit 19.
	We're going to read that together.
	Do you see at the bottom, it says FSXTX-051348?
	Yes.
	Okay.
	So I'm going to go from the top here.
	This is an email from Wolfgang Haubeg, correct?
	Correct.
	And it's to a lot of people, right?
	Yes.
	Okay.
	Do you see, and I'm going to have to try to help you point on my document.
	But do you see about right in here?
	Do you see some Infowars emails addresses?
	Do you see where it says Nico?
	Yes.
	And all that?
	Yeah.
	Okay.
	Now I want to go down to the date.
	Oh, actually, let's talk about the subject line.
	It says, anyone needing the addresses for a visit to welcome them to Florida, please call.
	And this was a great day for me.
	Who says that you cannot catch a big fish in Florida?
	I read that correctly?
	The words are correct.
	Okay.
	The date is March 21, 2017, correct?
	Yes.
	This is one month before InfoWars aired the April 22nd, 2017 video, Sandy Hook Vampires Exposed, correct?
	Correct.
	And that's the video we just talked about: that heirs claims by Wolfgang Haubig, correct?
	Yes.
	Okay.
	So I'm going to read you this email and we'll read along together.
	Let me try to be a little more flat in my affect here.
	Thank you.
	Nick and Laura Phelps did a great job acting in Newtown, Connecticut on December 14th, 2012.
	I visited their home today at 1924 West Dover Reserve Boulevard, Windmere, Florida, 34786, thanks to Lieutenant Van Gailey telling me during my wellness check of Nick and Laura Phelps that they no longer live in Newtown, Connecticut, and they are now Richard and Jennifer Sexton.
	Guess what?
	He is totally right.
	And can you believe it that my Newtown police department guided me in the right direction?
	They have a beautiful home with a three-car garage.
	They were not home today, but the good news was that the three adult females, moms, with their children standing outside their homes, observed me and wanted to know what I was doing.
	It is spring break for Orange County, Florida schoolchildren.
	I showed them this picture and told them that I did not want to go to the wrong house to surprise Nick and Laura from Newtown, Connecticut, aka Richard and Jennifer Sexton today.
	It took a few minutes for them to look at the pictures and then they asked why I wanted to speak to them.
	I told them that I have been in Newtown and wanted to surprise them since they now live in Florida.
	They asked for my name, which I gave them as Wolfgang W. Haubig.
	They told me how I knew them and I told them that they have been on the national news and so I wanted to meet them again.
	Our conversation was all about Newtown, Connecticut.
	So she said, Do you mind if I text her?
	I said absolutely not.
	Waited about 10 minutes only to learn that they did not know me, which surprised me.
	They verified the pictures and why she would text them about Newtown, Connecticut, and that someone from there wanted to visit if they were not, if they were, if they were not Nick and Laura Phelps, now Richard and Jennifer Sexton.
	At first I did not want to enter since it is a gated community, but several people told me just to go on in there is no security guard at the gates.
	If there is CCTV, they will see me being told to go in, and that is the only reason, or I would have not entered.
	Or I would not have entered.
	Now, who says that law enforcement does not know what they are doing?
	Thank you, Connecticut Police Department.
	I read that accurately.
	The words, yes.
	Okay, can you was that can you can you give me some guidance on how I should do the inflection for the future?
	Just regular text, not pretending to be some kind of movie character or a 13-year-old teenager arguing with his brother.
	Okay.
	I try to do it as robotically as possible.
	Okay.
	I can read it for you if you want.
	No, that's okay.
	I want you to flip the page over.
	You see that?
	Yes.
	Read that part for me, the big white part at the top.
	Sandy Hook hoax actors.
	What does it say at the bottom?
	Playing the part of Cleave's strigging parents.
	How does the company feel about this email?
	I have no feelings on this email.
	Wolfgang Haubig did his own investigation.
	That email doesn't creep you out?
	You personally?
	Objection form.
	I'm creeping out the way you're reading it, yes.
	Done creepy out to Wolfgang Haubig showing up at these people's houses and describing their three-car garage and all that stuff.
	Accusing them of being people they're not actually are.
	that doesn't have any strong feelings one way or another on that?
	Traction form.
	Correct?
	Are you asking my personal opinion?
	Yeah, your personal opinion.
	Strikes me as a passionate man who's doing an investigation, something he believes in his own heart and wants to get to the bottom of.
	thank you miss carpova Okay, I am...
	I'm going to throw you in front of put this document I'm putting in front of you now.
	I'm marking it as exhibit 20.
	Let me see if I can read this one any better.
	We're looking at Free Speech Systems Texas-053016.
	Is that correct?
	It's written by Wolfgang Haubig.
	Yes.
	Okay, first person it's to is Lenny Posner?
	Yes.
	Okay.
	I'm going to read you this email.
	Actually, let's if you'd flip the page for me.
	And do you see how there's some more from Wolfgang Haubig right there?
	Yes.
	Okay, so I want you to flip back and you'll see at the bottom email it says from Wolfgang Haubig.
	Yes.
	And again, there's a bunch of other people he's sending this to?
	Yes.
	Okay.
	And then if we flip over onto the back, I can read this, okay?
	And the subject says forward clear no wires helicopter view.
	Yes.
	The email says the shadow shows an 1145 a.m. time period.
	Just do not know the date question mark.
	Yes.
	And then it says flag at half mast who ordered that question mark?
	Yes.
	Only the governor can do that and he has not even addressed the national news media, correct?
	Yes.
	Okay.
	Turn the email over.
	You see there's another email from Lenny Posner right after that?
	Yes.
	I'm going to go ahead and do inflection on this because he's my client and I know how he said this when he said that.
	It says, can you please go fishing or play bingo?
	That's what it says on the page?
	Yes.
	Okay.
	And the next email it says, Posner, I love this picture, don't you?
	This is not December 14th, 2012.
	So what date did they practice for killing 20 children and six school staff members?
	Practice makes perfect, they say, what is the name of the police officer who shot all those people inside the school on December 14th, 2012?
	Dr. Wayne Carver has already been on site.
	So was Mandefranonia, who was arrested that day and let go.
	No yellow warning tape on that huge sinkhole.
	And when Rosen gets interviewed on that December 14th, 2012, there is a yellow emergency tape around the sinkhole.
	Only television magic can make that happen.
	Wolfgang, I read that email correctly.
	Yes.
	This is something that Infowars had in its corporate files, correct?
	Yes.
	And in fact, if you look at the last email address at the top of the page, it says robd at infowars.com, correct?
	Yes.
	One of the other emails you'll see in the last line of the two list is inpattis at pattislaw.com, correct?
	On the two line up at the top of the page, the last line of the two line.
	Did you see inpattis at pattislaw.com?
	Yes.
	That's the company's lawyer, correct?
	Yes.
	Was that the company's lawyer at the time?
	Don't know.
	Okay.
	Okay, we're going to.
	Only got about 30 minutes.
	So I'm.
	I can just want to clarify these kinds of emails that are being sent to people is something that Halbig sends on a regular basis and they're not read by Infowars staff.
	Okay, so the source that you were relying on a month later, the emails he's sending to the company were ignored, correct?
	Well, we have a lot of emails, and the ones that have this many addresses in the two lines in CC usually go to spam, so they're not even noticed.
	You don't know that that went to spam.
	You don't know that, right?
	I know that these types of emails go to spam.
	They weren't addressed to just one specific person.
	So if I have an email with all those twos on it and it's replied to by InfoWars people, that'd kind of be inconsistent with that.
	If they were replied to by an Inforce person, yes, but this one isn't replied to by an enforced person.
	Right, but we know they're not going to spam because y'all regularly communicate with Wolfgang Halbig when he does this, right?
	Do you agree with that or do you not agree with that?
	Because the email that is responded to is addressed to specific people.
	I'm not asking about that email.
	I'm asking when InfoWars communicates, has regularly communicated with Wolfgang Halbig on emails that copy it's on a people like that.
	That's something that's happened quite a bit at Infowars, correct?
	I haven't seen that.
	Okay, so when in terms of trying to get acclaimed with the documents that the company has produced today, you didn't see any of those documents, right?
	Where an InfoWars personnel, a specific person from Infowars is responding to a mass email like this.
	I do not recall seeing that.
	Okay.
	Let's talk about really quick.
	Oh man, there is.
	Can you tell me how much time we've used?
	Yeah, one second.
	A little over four hours.
	Okay.
	Okay.
	One of the things you're supposed to testify today about is the company's knowledge of the plaintiffs, correct?
	Yes.
	Okay, the company knew about Leonard Posner within weeks of the shooting, correct?
	Let's withdraw the question back up.
	Have you seen the email Leonard Posner wrote to the company weeks after the shooting?
	Have you seen it?
	I don't have that recollection of it.
	So in terms of trying to get up to speed on the company's knowledge of the plaintiffs, in terms of complaints Leonard Posner may have made to InfoWars, you haven't seen those, have you?
	I haven't seen the email that you're talking about.
	Right.
	Yeah.
	You know that both Paul Watson and Alex Jones worked on responses to send to Leonard Posner?
	Have you seen those?
	I've seen, like I said, a lot of documents.
	I'm not asking.
	So that's what I'm asking you, is when you got prepared to talk to me about the company's knowledge of the plaintiffs, you haven't even seen the correspondence that InfoWars has had with that plaintiff, right?
	I have not.
	Throw the rest of that away.
	You don't deny Mr. Posner complained to Infowars about its coverage within weeks of the shooting, right?
	You do acknowledge that.
	The company acknowledges that.
	Company has that knowledge.
	Or do you not know if the company has that knowledge?
	I don't have the specific dates at this complaint.
	So you can't tell me today if in 2013 the company knew who Leonard Posner was?
	You can't tell me that.
	company have knowledge of plenty of us i'm going to show you something You understand that the company produced documents from its own corporate files, right?
	Yes.
	Okay, and you understand that some of those document requests asked for documents about my clients, right?
	Yes.
	Do you know who my clients are?
	Can you name them?
	I have four clients.
	Do you know who they are?
	Yeah, it's on the notice.
	I know, I mean, from memory, you don't.
	You've got to pull this up, right?
	Yes.
	Okay.
	So now you can see that, right?
	It's on there.
	Okay.
	So you understand that InfoWars produced documents about each of those four clients.
	Yes.
	Are you generally familiar with what documents they produced as it relates specifically to those four clients and what InfoWars knowledge is?
	There's not a lot.
	Yes.
	Okay, do you see?
	Consursory knowledge of Leonard Posner and no knowledge of the other people.
	Okay, so you do know that documents were produced that relate to Leonard Posner.
	I was given specific documents that relate specifically to Leonard Posner.
	You understand that?
	I don't have a list of specific documents for you right now.
	Okay.
	Actually, when I say Inforce produced documents, that's not accurate.
	Inforce produced a document to me very, very recently.
	Okay.
	Okay.
	about Have you ever seen that?
	You seen that before today?
	I have not.
	Okay.
	So in terms of the document, the single document that was recently produced to me about Leonard Posner, you've never seen it.
	And this is the single document.
	That's it.
	No.
	Okay.
	You see where it says FSXTX-8085544?
	Yes.
	Okay.
	You don't know what this is, do you?
	If I wanted to ask you, what is this?
	You couldn't tell me.
	Just like a background information?
	Right, I mean, I can figure that out, right?
	Like, we can look at the top at the table of contents right here, and it says for license investigator purposes only.
	Do you see where it says that?
	Yes.
	And then you see where it says Leonard Posner comprehensive report?
	Yes.
	Do you see where it has all these entries about all this information about Leonard Posner?
	Yes.
	This is a lot of knowledge that the company has in its possession concerning Leonard Posner.
	You'd agree with that?
	Yes.
	Okay.
	And some of the information that the company has about Leonard Posner and its knowledge include his possible relatives, right?
	Do you see that down near the bottom of the list?
	Yes.
	And possible likely associates and possible associates, right?
	Yes.
	Okay.
	And like, for instance, if we go to, do you see where it says page 66 for possible relatives?
	can you flip to page 66 in that document for me This is a bunch of people's personal information, isn't it?
	Yes.
	And you can't tell me why the company has this, can you?
	I don't know.
	So when it comes to testifying about the company's knowledge of Leonard Posner, which you can now see, is extremely extensive.
	You're not prepared to testify about that today, right?
	Objection 4.
	Well, the company was asked for the knowledge of the plaintiffs.
	Linny Posner's a plaintiff, right?
	This is what they've produced about the knowledge of the plaintiff.
	Right, I understand that.
	I asked for a request of production for documents.
	Then I asked for your testimony.
	Part of the reason I asked for your testimony and the knowledge of the plaintiffs is because you produced to me, your company produced to me 187 comprehensive background report on Leonard Posner, and I wanted to know why.
	And I wanted to ask questions about that document.
	I wanted to know what was inside of it.
	I wanted to know the information that the company had and what they did with it.
	You can't answer any of that, can you?
	Well, this just looks like a typical investigation report on a person.
	You have no idea where it comes from, do you, Ms. Korpova?
	None, right?
	This is a document that you were provided by the company, correct?
	Yeah, where'd the company get it?
	Do you know?
	So you don't know, correct?
	You're talking about specific people?
	No.
	Do you have no, let's make this really clear.
	You have zero knowledge about this document.
	None whatsoever, correct?
	No, other than it's being an investigation report on Leonard Posner.
	Which you have seen now.
	Background information.
	Which you have now seen for the very first time.
	Yes.
	Correct?
	Okay.
	What about Scarlett Lewis?
	Do you know what the company has in terms of information about Scarlett Lewis?
	No.
	Do you know what information the company has about Neil Hussin?
	No.
	Do you know what information it has about Veronique De la Rosa?
	No.
	Okay.
	And let me make sure I'm clear about this.
	When you say you, that's you personally, Daria Kapova, don't know.
	So in other words, the answer to the question on the company is: you, Daria Kapova, don't know what information the company has on any of those people.
	No, the company doesn't have information on either of those people other than the documents that have been provided to you.
	Okay, so that's what I'm asking you.
	What does the company know?
	Do you know what the company knows about?
	There's a document that was provided to you.
	Okay.
	That was provided to me in response to a request for Leonard Posner.
	Right.
	I'm asking you about Neil Hesslin.
	What does the company know?
	Other information on other plaintiffs the company does not have.
	Are you sitting here and telling me today that the company hasn't produced documents on this, folks?
	No, the company has no knowledge.
	Okay.
	So InfoWars employees weren't researching materials about Mr. Hesslin?
	There's no records of any employees researching things like that.
	Yeah, there are.
	Unfortunately for you, Ms. Karpova, there definitely are.
	That's just, I'm moving off of this topic because there's obviously nothing that's going to be accomplished here, and we're running out of time.
	What did you do to determine the total audience reach of the videos and plans petition?
	What would you do?
	There's no way of finding out that the total each of the audience because the YouTube channel was deplatformed as well as other media that the videos could have been posted on.
	We have a view count on videos on band.video, but that just tells you how many times the video was watched, how many people watched it.
	In terms of videos being shared by other people, there's no way of figuring out what the reach for that is.
	How many Infowars is currently broadcast on over 200 radio stations, correct?
	Around there.
	Okay.
	What did you do to go find out their viewership and audience for those dates?
	There would be no information.
	How do you know that?
	Who did you ask?
	How many of those radio stations did you make requests to?
	I didn't.
	Okay.
	Did you do anything to figure out what those radio stations' audience ship was at the time those videos were broadcast?
	No.
	Okay.
	At the time of the videos described in the plaintiff's lawsuit, how many over-air the air television stations from 2013 to 2018?
	Don't have the exact number.
	So if I wanted to establish what the audience reach was of over-the-air television broadcasts of InfoWars, you can't help me with that.
	Because you don't even know how many there are in terms of over-the-air air television, right?
	The topics asked for specific videos and the reach for those videos.
	And those videos were broadcast on over-the-air television, right?
	I would say during...
	Some of the videos could have been posted as standalone videos.
	A lot of kuds in this room.
	We don't know, do we?
	Right?
	So we know, one thing we do know is at least some of them were broadcast over-the-air television, right?
	Yes.
	Okay.
	There's no way for you to tell me anything about that, is there?
	No.
	You didn't do anything to try to figure that out, did you?
	I did the best I could.
	How many cable packages was Infowars carried on between 2013, 2018?
	That wasn't part of the question.
	I could have found that information for you from an affiliate relation person.
	Part of Infowars audience reach is the people that it reaches over cable packages, right?
	Objection form.
	Isn't that true?
	That is a very specific question pertaining to a department, particular department, that would need to be.
	And you didn't go do that?
	No, that wasn't in the scope of the.
	So in terms of the audience reach of these videos that was reached on any cable packages, you don't have any information on that for me today.
	No.
	Okay.
	How many OTT services?
	First of all, you know what an OTT service is?
	What is it?
	Over the top.
	Okay.
	Over the top systems.
	On the box systems?
	Okay.
	Like, I think one example might be like Roku.
	Okay.
	That would be an example of an OTT system.
	Infowars has frequently promoted that it's on multiple OTT systems, right?
	The company would have no, the company would keep no track of those kinds of views.
	But you don't know if that information is accessible, do you?
	There's no information for that.
	Well, let's first figure out the first thing that I might need if I'm going to try to figure out what the audience reach was, which is how many OTT packages is InfoWars included on?
	I would have to go back and check on that.
	So in terms of the audience reach of the audience that was reached through those OTT packages, InfoWars has no information to offer me today.
	Correct?
	Okay.
	ZeroHedge is one of the sources for company Sandy Hook information.
	Yes.
	Okay.
	You understand that in Neil Hesslin's defamation case, this court ordered InfoWars to respond to discovery about ZeroHedge.
	Do you know that?
	Okay.
	Okay.
	Do you know that that discovery was never responded to?
	Okay.
	Okay.
	So in terms of the documents produced by the company and process planning's discovery requests, the company admits that it refused to answer discovery about ZeroHedge.
	That's true?
	Well, that means we have no documents for that.
	I don't think that's what that means.
	I think if you want to say that's what that means, it would actually be answering the question and saying we Have no documents.
	But you understand that Infowars never answered those requests.
	Did you know that?
	Objection form.
	Were you aware of that?
	The company did the best to provide all the documents requested.
	And we have provided hundreds of thousands of pieces of documents.
	So the best the company can do is you take it that not answering the questions themselves is the best the company can do the company did their best Same deal with iBankcoin.com.
	That's a source for InfoWars Sandy Hook video, isn't it?
	Okay.
	Yes.
	No discovery has ever been answered on iBank coin, right?
	The company doesn't have any information.
	I highly doubt that, Ms. Carpova.
	One of the articles that was relied on for Owen Shore's video about Mr. Heslin in June 2017 is an iBank coin article, right?
	I was showing as well as Owen uses multiple articles from websites.
	And do you think there's nothing in InfoWars files relating to iBank.coin?
	Is that your testimony today?
	Define Inforce files.
	Do you know what I mean when I say InfoWars files?
	Do you not know what I mean?
	InfoWars maintains files, right?
	Correct.
	Right, so it has documents.
	Sure.
	All sorts of things.
	Pamphlets, star charts, runes, blockchains, diagrams, pictures, all sorts of things are in InfoWars corporate files.
	Isn't there something on iBankcoin.com in InforWars files?
	Or are you saying there's not?
	If it weren't produced, I feel like there isn't.
	Okay.
	You know, Dr. Wayne Carver is, right?
	The name sounds familiar.
	All right, that's also in Owen Shore's video.
	Debbie, did you watch Owen Shore's video about Mr. Hessler?
	I have, yes.
	Okay.
	Is that one that you watched in the break, or did you watch that before?
	I've watched it before.
	Okay.
	Dr. Wayne Carver's medical examiner in Sandy Hook.
	Company has documents on them, doesn't he?
	All the documents that we have, we have produced.
	You know Corey Sklenka is, right?
	No.
	Okay.
	Corey Sklenka is an associate of Wolfgang Helbig, who was a co-defendant with InfoWars in the Lafferty suit.
	Does that refresh your memory on who Corey Sklenka is now?
	No, not really.
	Okay.
	You would admit being a co-defendant with Corey Sklenka and the Lafferty suit.
	The company possesses documents about Corey Sklenka, correct?
	Objection form.
	Nothing to do with the Texas cases here.
	It has to do with the documents produced in response to our discovery requests and our discovery requests for Corey Sklenka, which you would know if you ever answered.
	Okay.
	Brett, this is the most disrespectful deposition I've ever been in.
	We've been in two depositions where you presented the same, your company's presented the same kind of opponent who didn't know anything about what was being on these topics.
	And now for you to come in and object to topics about I'm asking about documents produced to my discovery request and you tell me Corey Sklenka isn't responsible for this case.
	Both of you all need to get up to speed on what this case is.
	Excuse me.
	First of all, I am objecting on the basis of you asking about the Connecticut litigation.
	I'm not saying you have any, I'm not objecting to you asking any questions about your discovery requests.
	Second of all, no one is trying to be disrespectful here.
	She's doing her best job and I don't care whether you think she isn't or not and I don't really care what your personal opinions are on her or not.
	If you have a problem with it, which I'm sure you obviously do, you're going to try to do something about it.
	I know I'm going to, Brad.
	And I want you to maintain for the record that everyone here has been working as hard as they can to actually get you answers that you want.
	And I'm sorry that out of the hundreds of thousands of pages of documents that you're asking about specific ones that she doesn't have the exact answer to.
	You haven't produced hundreds of thousands of pages.
	Okay, man.
	You know what?
	I don't answer discovery, Brad.
	So if you're going to sit here and lecture me.
	I would like you to show me the ones you're saying have not been responded to.
	What's that?
	Which ones are you saying have not been responded to?
	You haven't responded to the Posner discovery in any shape or form.
	And have I been compelled by a court order to actually respond to those documents?
	Because I got defaulted, but I haven't actually seen a motion to compel.
	Right, and I'm proving all that up right now.
	I understand that.
	But I'm unclear on if I'm defaulted on it, and I'm unclear of the obligation to actually supplement it.
	But if you want to ask me to do that, then I'll do that.
	I'm not asking that at all.
	I'm asking her directly that they haven't produced me documents to my discovery request.
	And I want them to admit that they refused to answer them.
	And you've just kept interrupting me about it.
	Okay, well, I'm sorry, I didn't mean to interrupt you.
	I apologize.
	That's not my intent.
	And go ahead and answer the question to the extent you can, please.
	Right.
	The company does possess documents about Corey Sklinka that would have been responsive to plaintiff's discovery requests, and they refused to provide them, correct?
	That's not correct.
	The company has provided all the information they have.
	That's Brad, do you want to warn your witness?
	Or do you need to consult with her outside or something?
	Because that's not a true, that's a false answer, and I don't want to get into that area.
	I need an answer to this question, and that's like I don't know if you want to go talk to her or something.
	I'm trying to make this easy for you.
	Let's take a minute and let me confer with her and then come back to it.
	I'll tell you what, let's put that question at the pin at the end because I wanted to get out of here at 5:30 for these people.
	And the latest we can say is 6, and that's still not going to give me enough time.
	But let me get to the rest of these questions, and then if you let me have you confer with her so I can ask her that question at the end.
	You're aware of a film that the company hosted about Mr. Posner called We Need to Talk About Sandy Hook.
	Do you know what that film is?
	No.
	Okay.
	Do you know who Independent Media Solidarity Group is?
	No.
	Okay.
	Okay.
	Okay, the company is aware of other parents who lost children at Sandy Hook besides my four clients.
	Correct?
	I don't have a document listing their names.
	Right, but you know there's other parents, right?
	Yes.
	Okay.
	The company possesses documents about some of those parents.
	Again, the answer is the same.
	The company did their best to provide the documents they had.
	Okay.
	So in terms of whether InfoWars has been requested to produce documents about other parents in the Posner case, you wouldn't know whether those documents have been produced or not, Again, the answer is the same.
	Okay.
	Can you give me tab 44?
	Yep.
	Brad, this is an Excel spreadsheet you produced to me.
	Okay.
	I printed it as a PDF.
	I have made two alterations to the document, which I think will be for your benefit.
	I have put confidential attorneys eyes only at the top.
	Okay.
	i have labeled the base number of this spreadsheet and i have added a zero zero one two page numbers on just make it easier for us to work with Are you familiar with the documents produced by the company in response to the plaintiff's request regarding revenue data for the company?
	No.
	Okay.
	Well, I don't even know why I'm showing you this, but whatever.
	Sigh
	I'm going to show you what I've marked Exhibit 21.
	This is marked as FSXTX-086589.
	Do you see that?
	Yes.
	Okay.
	So you've never seen this document before, right?
	No.
	Okay.
	I was produced this.
	It's not labeled on anything, but from what it looks to me, that's what it is.
	As you see, there's a date column, right?
	There's some orders, right?
	Yes.
	Sales items, correct?
	Yes.
	Sales total?
	Yes.
	Invoiced?
	Yes.
	Refunded?
	Yes.
	Sales tax?
	Yes.
	Sales shipping?
	Yes.
	Sales discount?
	Yes.
	Canceled?
	Yes.
	Okay.
	My assumption would be that this document is providing sales revenue information statistics from the Infowars.com store.
	Do you know if that's accurate?
	Yes.
	Okay.
	Can you flip to the last page for me, which actually would be on the back of the last page?
	So you can just turn the document over.
	Do you see how there's a column that says total?
	Yes.
	Okay.
	So this document reflects that during the period of this document, that the total amount of sales revenue from InfoWars in the Infowars.com store is $165 million, $237,142, correct?
	Yes.
	Here we go.
	Tap 45 I'm sorry, tab 46.
	Let's skip that.
	You can just pull that out and get it out of your way if you need to.
	Sean, you have marked as exhibit 22.
	Have you ever seen that document?
	I have not.
	Okay.
	It says your Amazon services seller central, am I correct that InfoWars sells products on Amazon?
	Yes.
	Okay.
	Can you flip to me to the page labeled, and it's look at the Bates number, the red number down here in the bottom?
	Can you go to 575?
	All right.
	This document, which is labeled FSSTX-086575, is that correct?
	Yes.
	Okay.
	This document appears to me to reflect that InfoWars made $1,355,000,664.30 in revenue from Amazon and paid $421,973.69 in expenses.
	Is that correct?
	It appears so from this document, yes.
	Would that be consistent with your understanding that Infowars is doing about a million dollars of a year in sales every year on Amazon right now?
	No.
	From my understanding, the Amazon account I'm not having.
	Okay.
	InfoWars sells things on eBay, too?
	Don't know about that.
	Okay.
	When was the date?
	I'm talking about now efforts the company made to preserve evidence in this case.
	Do you know when the first litigation hold letter was sent out to Infowars employees?
	There was a letter sent out.
	Yes.
	Do you know when the first litigation hold letter was?
	Oh, the date?
	Yeah, when it would happen.
	I don't know.
	Do you know who sent it?
	Tim Fruger.
	Okay.
	And what did that letter say?
	Do you know?
	It requested the employees to search their archives for anything having to do with Sandy Hook and to preserve all the documents from that point on.
	You're aware, have you been, have you read the deposition of Michael Zimmerman?
	I have not.
	Okay.
	Were you aware that during Mr. Zimmerman's testimony we confirmed that in response to Mr. Fruget's request to all the employees, not a single document returned a single not a single employee returned a single document.
	Were you aware of that?
	I wasn't.
	Okay.
	If I was to, it's my understanding that Tim Fruget sent out this letter sometime in 2019.
	Does that conflict with what you know or do you not know?
	I do not know for sure, but I believe that letter was sent out as soon as the request was made.
	The litigation.
	Excuse me, say that again.
	Whenever it was requested for the discovery, it did.
	Well, that would make sense because the discovery in this case was put off until Spring of 2019.
	Didn't really start in earnest until then.
	But you understand the company had been sued back in April 2018, right?
	Yes.
	So it'd be fair to say that for almost a year, InfoWars took no action to preserve evidence from those employees.
	Well, they weren't requested to.
	Really?
	You sure about that?
	You sure?
	Well, the request for discovery was made in 20 years.
	Has the company ever received any correspondence from the plaintiffs saying please preserve evidence?
	Do you know?
	I don't have any documents on that.
	Okay.
	So in terms of getting ready to testify about efforts made to preserve documents, you have not seen any correspondence from the plaintiffs or their counsel asking to preserve documents.
	I have not.
	Point number five has anything to do with efforts made by the company to preserve potential evidence.
	Right, and here's what I'm getting at, Ms. Karpova, is that I want to know when the plaintiffs served a request to preserve documents back in April of 2018, one, if you have seen it, and two, if the company actually did anything.
	And from what I understand, you had never even seen that correspondence, right?
	I haven't.
	Okay.
	Infowars LLC, is that a subsidiary of Free Speech Systems?
	No.
	Okay.
	Is that something you're stating from something that you know personally or something somebody told you?
	You don't have to tell me anybody anything told you or who told you or what that.
	I'm just, is that your personal knowledge or is that something you did preparing for the deposition?
	That's both.
	Okay.
	Okay, so if somebody was to say that InfoWars LLC is a subsidiary of free speech systems, they would be incorrect.
	You're confident of that?
	Yes.
	Okay.
	InfoWars LLC is a holding company, correct?
	InfoZL LLC is a InfoWars LLC is a single member company owned.
	I'm not asking how many people own it or how many members they're asking.
	I'm asking is it a holding company?
	Backup.
	Do you know what a holding company is?
	I'm not sure.
	Okay, all right.
	Objection form.
	I don't even know what you mean by holding company.
	Well, InfoWars sure does.
	Okay.
	As far as I don't know what.
	You put it in a pleading, Brad.
	I'm talking about what you mean by that.
	I'm asking what you mean by that.
	I want to know what Infowars means by that.
	Okay.
	And I'm really kind of shocked because that isn't a pleading.
	Okay.
	You know what Rocket Chat is, right?
	Yes.
	Okay.
	Company still using that?
	Yes.
	Do you know when Rocket Chat was searched?
	No.
	Okay.
	Do you know when it was preserved?
	No.
	Okay.
	What about Yahoo Messenger?
	Do you know when that was used?
	that used during the events of this lawsuit Don't don't know.
	Okay.
	What about Slack?
	Was Slack used during the events of this lawsuit?
	Since 2013?
	I'm not sure.
	Okay.
	was any efforts made to preserve any messaging systems like slack Don't know for sure.
	Okay, what about things like Basecamp?
	Do you know what Basecamp is?
	Yes.
	Okay.
	Whereas anything done to preserve Basecamp?
	I don't know any Basecamp associations with Infowars.
	Okay.
	Let me ask you this, does Infowars, have they used Basecamp?
	Have employees used that to communicate with each other?
	No.
	Not that I know of.
	Okay, not that you know of, right?
	I've never heard of Basecamp being a communication platform for Infowars employees.
	I hadn't either, and it was strange because we requested, obviously, requested and asked for it.
	What are your communication platforms and whatever?
	That's a whole nother story.
	But I recently got produced a document from Paul Watson that talks about his Basecamp communications with another employee.
	And I'm just wondering when News Basecamp used.
	you aren't familiar with Basecamp?
	No.
	Okay.
	So by the same token, if there were any efforts made to preserve Basecamp messages, you don't know what those steps were.
	Okay.
	Okay, when it comes to the videos that were...
	Yes.
	Efforts were made to archive all the videos requested, yeah.
	Currently, InfoWars does not have access to all the videos it made about Sandy Hook, correct?
	The videos which were deleted.
	We couldn't locate, yes.
	Yeah, okay.
	what efforts were made to preserve those videos before The videos that were available were preserved.
	The videos were not, that were not.
	I'm talking about when you had them all, back when you still had them all.
	Okay.
	But from the time you were sued, let's stop for a second just to make sure you understand this.
	You understand that the time the videos were lost when they were deleted, that was after Infowars had already been sued.
	You get that?
	Okay.
	Okay.
	So during the period which InfoWars had been sued, up until the point its videos were deleted, what steps did InfoWars take to preserve those videos?
	We didn't anticipate for the YouTube channel to be taken off offline, and our archiving platform was a YouTube channel.
	Okay.
	So in terms of what you did to preserve it, the only thing you did to preserve it was just leave it on YouTube, correct?
	Yes.
	Okay.
	All right.
	I do want to ask this question, and I'll circle back to it.
	And if Brad, F5, after I ask this, you want to take your witness out and talk to her before answering the question?
	I normally would obviously not be okay with that, but in this specific situation, I would.
	Which is there were documents requested from the company relating to Corey Sklenka.
	InfoWars refused to provide those documents, correct?
	I don't know that to be the case.
	Okay.
	So in other words, let me put it this way.
	You sitting here right now do not know whether InfoWars produced documents relating to Corey Sklenka or whether it answered discovery relating to Corey Sklenka.
	Correct.
	Whether they refused to produce the documents.
	The company has not refused to produce any documents that they had.
	Okay.
	I mean, you understand that if a court order orders you to order answer discovery and it never gets turned in, nobody ever answers it, you understand that I could construe that as refusal, right?
	My understanding, the documents were produced.
	Okay, so from your, and let's make that, that maybe is what we need to get at.
	From your understanding, Daria Kapova coming into this deposition today, your understanding is that documents relating to Corey Sklenka have been produced?
	Again, I already said the documents that the company had in possession were produced for discovery purposes that were requested.
	So in other words, from what you understand to be the discovery situation, there should not be, it should not exist that there are documents produced in the Connecticut lawsuit about certain topics that were also requested in Texas but weren't produced in Texas.
	That situation should not exist.
	Okay, so it again, please.
	Sure.
	Let's imagine for a second that there were documents produced in Connecticut and those same documents were produced in Texas but not were requested in Texas but not produced.
	You're saying that situation should not exist because Inforce has produced everything.
	I don't know.
	Okay.
	Let me take a break real quick, Rob.
	5.36 p.m. offer times 5.41 p.m.
	We are on.
	Ms. Garpova, I wanted to go back to one of the things you testified about.
	I had asked you if you had ever seen any documents in which InfoWars editorial staff was making the assertion that the sources that they were relying on for Sandy Hook were unreliable.
	And I remember you telling me you don't think you've seen any documents like that, right?
	I have to look at the document.
	Yeah, so that's what I want to see if you've seen.
	So I'm going to show you this.
	I've marked this as exhibit 23.
	At the bottom corner, it says FSSTX-027766.
	Is that right?
	Yes.
	Okay.
	And this is Paul Joseph Watson, is who it's from at the top, correct?
	Yes.
	Buckley, that's a relative of Alex Jones, correct?
	Yes.
	Okay, he worked at the company?
	Yes.
	He had a managerial role?
	Yes.
	Okay.
	Paul Watson, at this time, was he the head editor at InfoWars in 2015?
	He was an editor.
	Okay, he was the chief reporter at this point, though, wasn't he?
	Yes.
	Okay.
	Subject is re-Sandy Hook.
	You see that?
	Yes.
	Date is December 19th, 2015?
	Yes.
	Okay, I'm going to read this from the bottom.
	On December 17th, Paul Joseph Watson wrote, sent this to Alex.
	This Sandy Hook stuff is killing us.
	It's promoted by the most batshit, crazy people like Rince and Fetzer, who all hate us anyway.
	Plus, it makes us look really bad to align with people who harass the parents of dead kids.
	It's going to hurt us with Drudge and bringing bigger names into the show.
	Plus, the event happened three years ago.
	Why even risk our reputation for it?
	Next, Buckley responds: I agree with you 100%.
	We think it hurts our credibility significantly.
	I'll do what I can to head it off as much as we can.
	What was the latest incursion?
	I missed it.
	Paul Joseph Watson writes back.
	Adam, and I believe that may be a Don, maybe a typo.
	Yes.
	Wrote another article implying that the Posner guy's son didn't die.
	I think Alex had it out with him and put a ban on future Sandy Hook stuff.
	Have you ever seen that document before?
	I haven't seen this document.
	No.
	Okay, now you were aware, I believe.
	Is this what you were referring to when you said Alex Jones put a ban on Sandy Hook stuff?
	Yes.
	Okay.
	And that didn't stick, did it?
	Well, what I can say regarding that is Alex allows different opinions on the platform.
	Paul had a different opinion.
	Alex had a different opinion.
	Everyone was that was people were still talking about there were opinions on both sides, so there wasn't a specific question isn't about who could say what or any of that kind of stuff.
	My question is simply this.
	If Alex Jones put a ban on Sandy Hook in December of 2015, it didn't last.
	It didn't stick, right?
	We've talked about videos, multiple videos after this date about Sandy Hook.
	Well, I believe Alex was the subject of the matter in those videos.
	He was the one providing commentary on them.
	You remember watching Owen Schwarz's video about Neil Husson?
	Right, and what was the data man?
	That was 2017.
	That didn't stick, did it?
	Correct?
	It appears that Owen had an opinion about it, yes.
	Okay.
	You think anybody else said anything about Sandy Hook?
	You've seen Rob Dew say things about Sandy Hook after 2015 on Infowars, right?
	You just watched Sandy Hook Vampires Exposed.
	He was talking in that, wasn't he?
	Yes.
	Okay.
	This email where Paul Watson says it's promoted by the most batshit, crazy people, like Rince and Fetzer.
	Does the company agree with Mr. Watson's position or does it disagree with Mr. Watson's position?
	That's Paul's opinion.
	I know that.
	does the company agree with it or not?
	At this time, it appears that Fetzer and Rinz would be very questionable source of information.
	him hitap to others.
	Sorry, I might have to do this.
	Can you give me Tab 35?
	Is it in there?
	Did we pack it?
	Oh, we already packed it up.
	Okay.
	In fact, I'm just going to ask you a question about this.
	Do you remember right after the suit happened, Nico sent you blog material from Jim Fetzer?
	Do you remember that happening?
	After which?
	After this lawsuit.
	A couple months after this lawsuit from Nico.
	Yeah, summer 2018.
	Okay.
	Do you remember Nico sending you blog material from Jim Fetzer for you to look at?
	Specifically, remember email, but if you want to show it to me.
	I'm trying to, we got to get out of here, unfortunately, I think.
	But I'm just wondering if you had remembered that.
	In other words, let me put the question this way.
	That's true.
	Sure.
	Let me put the question this way.
	In 2017, did the company believe that Jim Fetzer was a reliable source of information?
	At that time, there was controversy regarding that individual.
	In 2017, InfoWars published a video by Owen Schroyer that relied on Mr. Fetzer, correct?
	Objection form.
	Okay.
	That's true.
	If you're telling me that, I'd have to.
	I'm actually.
	No, you need to tell me, Ms. Karpova, because you're here to talk to me about the sourcing and researching and planning its petition of those videos.
	Is that one of the videos you watched?
	When you took the break?
	Yes.
	Okay.
	I've seen that video before.
	Of course, so, yeah, you know you're going to testify about it.
	My question is, that was in 2017.
	It relied on Jim Fetzer.
	He had material from Jim Fetzer, correct?
	I don't know where Owen got that material.
	Okay.
	If Owen, and so given your previous answer, given that there was some, InfoWars was aware that there were some issues being raised with Mr. Fetzer's credibility, that happened in the exact same year that Owen published his video in 2017, right?
	So if Owen relied on, if it did happen, that Owen's video contains material from Mr. Fetzer, it was done so at a time where InfoWars knew there were issues regarding his reliability, correct?
	Yes.
	Okay.
	Thank you, Ms. Carfov.
	That's all I have for you today.
	Are you passing right now?
	Yeah.
	Or today is 5.48 p.m.

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