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Feb. 14, 2022 - Depositions & Trials

06:25:37

Deposition of InfoWars Corporate Representative Brittany Paz - February 14, 2022

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Time	Text
	This is the deposition of Brittany Paths.
	The date is February 14, 2022, and the time is 9.06.
	May swear in the witness.
	Thank you.
	Thank you.
	Ms. Pauze, please raise your right hand.
	Do you swear or affirm to tell the truth, the whole truth, and nothing but the truth, so help you God?
	Yes.
	And before we get started, I'd like the record to reflect that I'm handing Mr. Bankston a check, which represents the amount of the sanctions and the amount of $19,000-plus, plus dollars and also that the deposition is being taken pursuant to the protective orders entered in these causes of action.
	All right, ma'am.
	Can you tell us your name?
	Sure!
	My name is Brittany Paz, P-A-Z.
	You are not an employee of Mr. Jones of Free Speech Systems?
	No, I was contracted to be their corporate representative in connection with these depositions.
	Excuse me, sorry.
	You've never been an employee of Mr. Jones of Free Speech Systems?
	I am currently contracted, but am I on the payroll?
	No, I've never been an employee.
	Alright, you understand the difference when I say an employee versus a contractor, right?
	Yes.
	You've never been an employee?
	No.
	Okay.
	You're an attorney, right?
	Yes.
	You primarily practice criminal defense in Connecticut?
	I do.
	You represent any of the defendants as an attorney?
	No.
	Have you ever represented any of the defendants as an attorney?
	No.
	Mr. Jones' company decided to hire you to testify as if you were the company itself, correct?
	Yes.
	When were you selected to act as Free Speech Systems' corporate representative?
	Um, I think that I was officially hired, uh, the last week in Feb- uh, I'm sorry, excuse me, the last week in January, first week in February.
	So, January 31st, February 1st-ish, that week.
	It's been about two weeks.
	When you say officially, and let me back up, you understand there was a designation filed designating you as the corporate representative, and I think that was last week?
	Maybe Wednesday?
	Are you aware of that?
	I don't know when it was filed.
	I didn't file it.
	As far as an official selection, that was done well before that.
	I wouldn't say well before that, but it was done before that if it was filed last week.
	Right, so a few weeks before that, at least.
	Not a few weeks.
	I've only been the Corporate Rep for two weeks.
	I think as of today, it's been two weeks.
	Okay, you've had two weeks.
	Okay, yeah, that makes sense because you said January 31st, February 1st.
	I think that was a Monday, January 31st, so that probably was the day when everything got finalized.
	Is February, I'm sorry, January 31st, February 1st, that time period, is that when you began your preparation?
	Yes.
	Prior to that time, you had no meaningful knowledge regarding any of the topics you're here to testify about.
	No.
	So everything you're going to testify about here today is because someone either told it to you or because you read it in a document, right?
	Or watched videos, yes.
	Okay, or came out of a video.
	Yes.
	For this deposition, because this is how we've been talking about it in Discovery, I want you to conceptualize a document as not just written things, okay?
	And I'd like for our discussion for you to conceptualize it as Do you have any special expertise or credentials in news media or journalism?
	No.
	Do you have any special expertise or credentials in corporate finance?
	So not just typewritten documents.
	And so when I say documents, I want you to think about the universe of things that you may have drawn information from.
	Does that make sense?
	Sure.
	OK.
	You have any special expertise or credentials in news media or journalism?
	No.
	Do you have any special expertise or credentials in corporate finance?
	No.
	Do you have any special expertise or credentials concerning the practices and protocols and information technology?
	No.
	Okay.
	So I've had depositions before, and I think as an attorney, you're familiar with what a deposition is.
	Okay, I've had corporate representative depositions before where sometimes I've had an attorney who's represented the company for a long time, so they have a lot of knowledge.
	Or I'll have a former employee who no longer works for the company come testify because that person has a lot of knowledge.
	Or I might have an expert in a certain field that that corporate representative is supposed to testify and they come in to testify about it.
	So for those areas I'm usually pretty understanding why the person is here.
	For you, what I want to ask you is I'm just trying to figure out how you got selected.
	And is it just that you're an attorney that Norm Pattis knows, or do you have some sort of special expertise outside of criminal law that makes you well-suited for this deposition?
	I think the reason why I was selected was that there needed to be a person to represent the company who had broad knowledge of the topics that are listed in the deposition notice.
	I think you've previously deposed a couple of people that did not have that knowledge.
	The reason for that being that the company is just not structured that way, with one person having singular knowledge about everything in the company.
	And so I think they needed somebody who had the time and ability to familiarize themselves with that information, and that was me.
	Okay.
	And when you say there was nobody they were looking at to select for this deposition who possessed that broad knowledge, you don't possess it either, correct?
	Or did not, at least as of February 1st?
	I didn't as of February 1st.
	No, but as I sit here today, I believe I do.
	Okay.
	How much money total will you be paid in connection with being InfoWars corporate representative in this case?
	I've already been paid, but my fee was $30,000 plus costs.
	Okay.
	How'd you arrive at that figure?
	That was an internal discussion, just negotiation between myself and the company.
	When you say negotiation, can you explain that?
	Did you offer a figure and they counter-offered?
	How did that work?
	No, I think I was offered a figure to start and then we went from there.
	What do you mean you went from there?
	What does that mean?
	I mean there was a starting number as many negotiations go.
	Can you tell me what that starting number was?
	I think the number was 25 and then I just negotiated a little bit higher, 30.
	Okay.
	And that number was negotiated and finalized before you did any work?
	Yes.
	Have Alex Jones or any company related to Alex Jones paid you for anything else?
	Other than my testimony for this deposition?
	No.
	Do they plan to?
	I think I may be representing the company up in Connecticut for the corporate rep deposition.
	I believe that's going to be sometime in March.
	But aside from that, no.
	Okay.
	Now you understand you're a fact witness, right?
	Yes.
	You understand that payments to such witnesses must be carefully circumscribed.
	Do you know what I mean by that?
	Can you... Sure.
	Circumscribe means to do an action carefully to ensure that it fits in with relevant rules, regulations, and standards.
	You understand that payments to you must be carefully circumscribed, right?
	Sure.
	Okay.
	You understand you have professional responsibilities as an attorney that may affect how much you can and cannot be paid for fact testimony, right?
	Um, I don't think that I'm acting here in a capacity as an attorney, so I don't know that I would agree with that.
	Ah, so let's put it this way.
	In other words, because you're not representing anybody, you just happen to be an attorney, you don't think you have the same professional responsibilities you would have in your attorney work as you do sitting in that chair right now?
	I don't have certain ethical responsibilities to the client.
	I think my only real obligation is to testify accurately and truthfully as any witness.
	Okay.
	Can you tell me everyone you talked to for this deposition to prepare?
	I'm going to object to the extent that it's asking you to identify attorneys who are retained by any of the defendants.
	Go ahead.
	You can answer.
	Sure.
	So I spoke to numerous employees of Free Speech.
	I spoke to Mr. Jones.
	I spoke to Melinda.
	I believe her last name is Flores.
	I spoke to Mr. Daniels.
	He goes by Kit.
	I spoke to Adon Salazar.
	I spoke to Bob Coe, I think he's a consultant with the company.
	I spoke to Daria Karpova.
	Who else did I speak to?
	I spoke to a lot of people.
	I feel like I'm missing somebody.
	Oh, I did speak to Mr. Watson over in London via Zoom.
	I spoke to Rob Due via Zoom also, because he wasn't available while I was here.
	And I think that might be it.
	Oh, no, no, I'm sorry.
	I also spoke to Nico Aguilar on the phone.
	That might be it.
	Okay.
	Now, you have listed here, in addition to Mr. Jones, numerous employees.
	Yes.
	Or former employees, in the case of one.
	And Nico's not an employee, correct?
	No, he's not.
	Okay.
	And you started by saying that you spoke to numerous employees.
	And I want to make sure that these are the employees.
	There are no other employees.
	I'm just trying to make sure I didn't miss anybody.
	I know.
	I think that's a...
	Okay.
	When you said Bob Coe, you mean Robert Rowe, an accountant?
	Yes, Robert Rowe.
	He's not, I don't believe he's the accountant for the company though.
	I believe he's a consultant.
	What do you mean?
	How's that different?
	I mean that we have someone that is an official accountant for the company that prepares our tax returns.
	So he's not, he does not do those functions.
	Okay, well I've seen like a UCC financing statement with His accounting company have listed on it?
	Have you seen that?
	Uh, maybe.
	Okay, so maybe he is the company's accountant, right?
	I don't know.
	I don't think he's the company's accountant.
	I think there's a Mr. Love.
	Love?
	He's the company's accountant.
	Okay.
	So you don't know why Rob Rose's name appears on the financing statements?
	I don't know what, why that would be, but I don't think he's the company's accountant.
	Okay.
	And did you talk to the company's accountant?
	I did not speak to Mr. Love, no.
	OK.
	To prepare for this deposition, did you review every document produced in this litigation?
	Every single document?
	No, I didn't review every single document.
	I don't think it's possible to review every single document.
	Well, I certainly would agree that it's not possible for one person to do it within the time period of this deposition, right?
	Yes.
	It would take multiple people to do that.
	I think for the purposes of this deposition, if you'd like to go through the universe of documents that I did review, I'm happy to do that.
	That's not what I'm asking you.
	Okay.
	What I'm asking you is if someone wanted, or if a company Wanted to prepare itself for this deposition by reviewing every document produced in this litigation.
	One person in two weeks could not do that?
	One person in two weeks could not do that, no.
	And the company did not undertake steps to make sure that multiple people reviewed all of those documents, correct?
	I was the only person that was retained to do that.
	So you had told me that you basically could give me a universe of the documents you did review?
	Yes, I can try to undertake that if you'd like me to do that now.
	Why don't you do that now?
	Sure.
	So at first I wanted to just make sure that I reviewed the videos that we had on the Dropbox.
	So the videos that were produced in connection with The discovery as well as review those for the source material.
	I also reviewed articles that were published by the company that were produced in connection with the discovery.
	I reviewed most if not all the depositions that have been conducted in connection with this litigation.
	I reviewed the documents that were admitted as exhibits to those depositions because I felt that those would be probably the most relevant Documents to hone in on.
	I also reviewed a lot of emails, although I don't think anybody could review all the emails.
	A lot of them are like unopened emails and emails from the general public, but I did review a lot of emails.
	I also reviewed the filings in connection with the plaintiff's complaints.
	And I think that's it.
	Okay.
	When you say complaints, down here we call the lawsuit petitions, down in Texas.
	Is that what you mean, those petitions?
	Yes.
	In Connecticut we call them complaints.
	Yeah.
	So I have videos on Dropbox, I have articles, I have depots, I have the exhibits in those depots, some universe of emails, and then the petitions.
	Yes.
	Okay.
	When you talk about that universe of emails, how many documents are we talking about?
	at least thousands.
	Some of them are duplicates, though.
	So it's really hard to say how many documents, but, you know, the bait stamps, so they're all bait stamped.
	They have individual bait stamps, but a lot of them are duplicates.
	How did you select which documents you wanted to review in terms of emails?
	Good question.
	So what I did was I did a search to try to hone in what I was focusing on.
	So I did a search for things that, documents, I'm sorry, that would have the plaintiff's names on them.
	I did a search that would have Sandy Hook in them.
	Some of those documents don't really pertain to Sandy Hook.
	Like, so for example, some are just on general gun control.
	Some are on other shootings.
	Some are on Other events that were ongoing in the country, but I did try to hone my search to documents specifically related to the Sandy Hook litigation.
	Okay, so when you did a search for Sandy Hook, which returned the phone book in this case, how did you, did you review every document that had Sandy Hook in it, or did you select some sub-universe of documents that had Sandy Hook in it?
	So, like you said, it did return a lot of documents, so I tried to review as many of those, like lay eyes on as many of those documents as I could.
	Just randomly?
	No, as time was available, I would review documents.
	So is your question whether I got through all of those documents?
	I probably did it.
	Right.
	How many do you think you did?
	Thousands.
	Thousands of documents?
	I've reviewed thousands of documents.
	You have any idea sitting here today about how many pages of documents have the word Sandy Hook in them?
	I can't give you a number.
	I don't remember the number.
	Would you dispute with me if it's less than 30,000 pages?
	If I reviewed 30,000 pages?
	Is that what you're asking me?
	No, I'm asking you if it returns 30,000 pages.
	If you would dispute with me that the word Sandy Hook appear in about 30,000 pages.
	No, I probably wouldn't dispute that, no.
	Let's talk about everything you actually physically did.
	I want to know the times of it.
	So in terms of reviewing documents, how many hours did you spend reviewing documents?
	I think total review of everything, is that also including the discussion, the interviews I've had with everybody?
	No.
	Okay, so total review of documents, I'd probably estimate I have about 70 or 75 hours.
	All told, I probably have, you know, between interviewing people, I probably have over 100 hours of review.
	Okay, well let's talk first about the Documents of 75 hours.
	When did you do that?
	When?
	Between the period of January 31st when I was retained and this morning.
	I was reviewing documents this morning.
	Alright, so in terms of interviews, did those happen before the document review or before some of it, after some of it?
	Like, give me the order on that.
	I think they've all been done simultaneously.
	So I didn't arrive here until Tuesday night, so interviews didn't really start until Wednesday.
	So I was doing interviews from Wednesday through Saturday.
	Okay, so if you started, let's say you did an interview Wednesday.
	Let's talk about last Wednesday for instance, right?
	This past Wednesday?
	Sure, okay.
	Let's say you interviewed somebody that day.
	And then you reviewed documents you said even this morning, right?
	Yep.
	And maybe last night too?
	Yes.
	Okay, so if you hit a document last night and it involved one of those people that you interviewed, you didn't go back and interview them about whatever you saw in that document, right?
	You mean did I re-interview them?
	Correct.
	No.
	Okay.
	How many hours did you spend watching videos?
	Watching videos, plus taking notes on the videos and the sourcing, probably about 35 hours.
	Okay, when you said you watched videos on Dropbox, okay, you have an understanding of what those videos were?
	Like, do you know, well, let me put it back this way.
	One of the things you're asked to do is to prepare for all the videos that are mentioned in plaintiff's petitions, correct?
	Uh, yes.
	So I did try to locate all of the videos that are mentioned in the petition.
	Okay, were you able to do that?
	Not all of them.
	Okay.
	I don't think some of them are available just due to the deplatforming.
	So I don't know that we have a couple of them.
	It's interesting because I got all of them.
	One of them that I know that I couldn't find was the video specifically relating to the addresses and the map of the honor, the location of the honor company.
	That was one of the ones I couldn't find.
	Were you aware that the last corporate representative, Daria Karpova, she was shown that video?
	She was shown the video?
	Or you showed her the video?
	I didn't show it to her.
	I don't know.
	In terms of preparation, you don't know what Ms.
	Karpova did to prepare?
	I read her deposition.
	Well, let me make sure I get an answer to the question.
	Do you think that means you know what she did to prepare?
	I don't think she did very much to prepare, to be honest.
	I don't think she did either, but I do think Brad Reeves showed her some videos.
	Do you know about that?
	I don't know what Brad Reeves showed her, no.
	Okay.
	I haven't spoken to Mr. Reeves.
	OK, so we've got the docs and documents and the videos.
	Then you read depositions.
	Do you count that in your time in document review, or is that something separate?
	No, I think that's document review.
	Okay.
	And then that also includes the exhibits of that deposition, right?
	That's correct.
	Okay.
	And then another thing you did is the complaints.
	You read the, I mean, the petitions.
	Yes.
	Right?
	And that's also in your document review number?
	Yes.
	Okay.
	And then you did interviews.
	Yes.
	Tell me how long you spent doing interviews.
	Between Wednesday and Saturday, I was at InfoWars, at the primary location at InfoWars, all day, every day, Wednesday through Friday, and then we interviewed Mr. Watson for an hour on Saturday.
	So I spend a great deal of time Wednesday through Friday interviewing people.
	So it's Wednesday, Thursday, Friday.
	You spend a full workday?
	Full workday.
	Actually, I don't think we left until after 7.
	It was a long time.
	Okay, so what I was going to say is 3 times 8 is 24, so that'd be 24 hours spent interviewing, but you think you probably spent a little more than that, right?
	Let's call it 30.
	I saw it 30.
	Does that sound right?
	Let's say 25 just to be safe because I don't know if it's 30.
	Because some of those hours were also, you know, Viewing the location.
	Viewing documents.
	Pulling documents.
	Discussions.
	Privileged discussions with counsel.
	You know, some of it isn't full work days, full of interviews.
	Sure.
	Okay.
	When you say viewing location, do you mean the actual premises of InfoWars?
	That's correct.
	Okay.
	When you talk about meeting with counsel, are there additional hours or is that included as part of your interview time?
	Um, I think the... No, it's not included with the interview time, no.
	Okay, how much time did you spend talking to counsel?
	With Attorney Blott, you mean?
	No, I mean any attorney.
	Uh, okay.
	So... Maybe a few hours?
	Okay.
	Which attorneys did you talk to?
	Um, I spoke to Attorney Blott, and I spoke to... His first name is Dustin.
	I'm so sorry, I don't remember his last name.
	I know who you're talking about.
	And then I spoke to Attorney Pattis in Connecticut.
	Those the only three?
	Yes.
	I'll ask you about a gentleman you may not know.
	He's an attorney.
	Do you know a gentleman named Eric Taub?
	I've heard the name.
	I've not met him or spoken to him.
	Okay.
	Have you talked to Mark Randonza?
	No.
	Or Jay Woolman?
	No.
	Okay.
	Okay, so what we've described is time reviewing documents, time reviewing videos, time doing interviews.
	Is there any other time that you contend that you spent preparing for this deposition?
	No, I think that covers it.
	Okay.
	What is the first, when is the first time that the company did something to preserve potential evidence?
	Um, I think that this was probably sometime after the lawsuit was filed.
	Although I can't give you a specific date, I have interviewed employees as to when they became aware of when there was a spoilation letter.
	and unfortunately nobody has any knowledge of receiving such a letter, so I can't really pinpoint a date when that happened, although I, in connection with my interviews, have tried to ask ascertain what was done to try to get access to the YouTube videos that were lost as a result of the deplatforming, which happened prior to the lawsuit.
	I believe they hired some company to help them do that, but I'm not really sure what the dates are.
	All right.
	A lot of things I want to ask you about there.
	Sure.
	First, the deplatforming, that happened before the lawsuit?
	According to Mr. Jones, that happened in 2017.
	Okay.
	It actually didn't.
	So the deplatforming if Mr. Jones' stuff happened kind of as a result of this lawsuit?
	Mm-hmm.
	Happened actually like in August 2018, months after the lawsuit.
	You didn't know that?
	I didn't know that.
	Okay.
	Second, when you say that nobody knows when a spoliation letter is sent out, are you talking about a spoliation letter, like an evidence preservation letter from the plaintiffs, or are you talking about a letter inside the company?
	No, I'm talking about a letter that was received from you and your clients.
	Nobody has that?
	No.
	Okay.
	Nobody has any knowledge of receiving that.
	Nobody asked Mr. Taub for it?
	The company is not aware of a spoliation letter.
	I didn't ask that.
	And you know that you're an attorney, right?
	And I kind of expect that from certain witnesses to like evade the very question that I'm asking.
	But you know I didn't ask that question.
	You asked, has anybody in the company talked to Mr. Taub about the spoliation?
	I have not talked to Mr. Taub about it.
	Okay, again, has anybody in the company I'm not aware of anybody being aware of this spoilation letter or speaking to Mr. Taub about it.
	Anybody that I interviewed about this letter, nobody is aware of it.
	Did you make any efforts to determine who represented the company at the time the suit was filed?
	We had a number of attorneys, so I think that Mr. Taub represented the company at that time, but if he had that letter, it was not conveyed to the company.
	Ms.
	Paz, I'm not asking you any of those things.
	I'm not asking you what Mr. Taub did or anything of that.
	I'm asking you if you undertook any efforts to determine who represented the company at the outset of the suit.
	I think I answered that.
	I think I said I think Mr. Taub represented.
	I don't want to know the answer to the question.
	I want to know did you undertake efforts to find out?
	I've spoken to the employees of the company, I've spoken to Mr. Jones, I've spoken to the attorneys, and it's my understanding that Mr. Taub represented the company at that time.
	In other words, okay, so here's what I'm asking.
	When you spoke to members of the company, was one of the things that you wanted to get from them in terms of information, hey, who was representing you at the time the suit started?
	Sure.
	Okay.
	So once you had that information, you didn't talk to Mr. Taub?
	I haven't talked to Mr. Taub.
	He doesn't represent the company anymore.
	When you say the company doesn't represent the company, he doesn't represent Free Speech Systems?
	Not anymore, as far as I know.
	Okay.
	He does perhaps represent other affiliated businesses?
	Do you know anything about that?
	I don't know.
	And does he represent Mr. Jones?
	Do you know that?
	I don't know.
	Okay.
	So, first of all, when we talk about a spoliation letter, you haven't laid hands on that, right?
	No.
	Okay.
	What about a litigation hold?
	On?
	First of all, do you know what a litigation hold is?
	Inside of a company.
	You mean on the documents?
	On anything that's produced inside the company?
	Not produced per se.
	I'm saying that at some point in... First of all, you're not a civil attorney.
	No, I'm not.
	And I don't practice here either, so you may use different terms here.
	Okay, a litigation hold is a common term in civil law that when a company gets sued, it needs to undertake steps to notify everybody within the constituent organization that documents need to be preserved.
	Do you understand that?
	Yeah.
	Okay, when did that litigation hold happen?
	You mean the notification, I just want to make sure I understand the question, the notification that once the company was sued, notification to employees of Free Speech to preserve any relevant material.
	Yes, except one caveat, which is that may have occurred before suit because the company may have anticipated litigation before suit.
	So that may have occurred before suit, I don't know.
	I don't think that any such efforts were made before the suit.
	Can you tell me when it did happen?
	It would have been sometime after the suit.
	I'm not sure exactly what date.
	Okay.
	And you know that doesn't really help me at all, right?
	I know it doesn't, but I'm sorry, I can't, I'm not going to make a guess.
	Okay.
	And you've reviewed the depositions in this case?
	Yes.
	Most of them.
	Here's the problem I'm having, Miss Paws, because I really wanted to talk to you today a lot about preservation of evidence, right?
	Really, that's something I wanted to talk to you about.
	And the question of when it started, in terms of litigation holding, I didn't think it was going to be a difficult question for you to answer since Mr. Zimmerman testified to it.
	I thought we'd be able to jump right in because you'd know that.
	But in terms of whatever Mr. Zimmerman said about when the company issued a litigation hold, in terms of his deposition, you don't know that sitting here today.
	I believe I reviewed Mr. Zimmerman's deposition.
	I think Mr. Zimmerman's testimony was specifically related to the website and the website analytics.
	Okay, you believe his testimony wasn't about litigation holds or preservations of evidence?
	Most of what I recall about that deposition was about Google Analytics.
	Alright, so you don't know anything about a 2019 letter from Tim Fruge?
	I don't, I'm sorry.
	Okay.
	Or any of his testimony about what he told employees to do in terms of evidence preservation in that letter?
	I have not seen that letter.
	Okay.
	That's unfortunate.
	Can you tell me Can you at least tell me everything Free Speech Systems did to preserve evidence?
	If you can't tell me when they did it, can you tell me what they did?
	Sure.
	To my knowledge, I think that there were efforts undertaken to produce all of the emails that were given.
	There were certain search term parameters that were given to the company to search the emails.
	There were certain parameters done to try to access the videos such that We could access the videos.
	And I believe I testified earlier that there was a third-party company that was helping with that, although I'm not sure what the name is.
	I think Attorney Block could probably get that information for you.
	I think that as far as social media goes, I think that the testimony previously has been that that information can be accessed through Twitter.
	Do you also want to know about the finances of the company and the documents related to the finances?
	Or are we just now in the universe of emails, articles, and videos?
	Let's deal with that first answer first, because what I heard you talking about is there were efforts to make to search for the emails, yes, and efforts made to access the videos, yes, right?
	And these sound to me like things that were done to attempt to locate documents for production in the lawsuit, right?
	What I didn't hear is about any efforts to preserve documents before that happened.
	In other words, you understand if I'm going to go search for documents to produce them, it's important that I preserve those documents before that happens.
	You understand what I'm saying?
	Well, I do understand what you're saying and I don't think that there's been any deletion of any of that information.
	So, I mean, once they were required to be produced and we did the search through the databases, I don't have any reason to believe any of that information was deleted.
	Okay.
	Do you have any idea when InfoWars email server was secured and preserved in its current state?
	As far as a date?
	No, I don't.
	I don't know the date.
	Let's just, let me do a little testifying for you, and you can take my representation or you can leave it, right?
	But from what I understand from Mr. Zimmerman's testimony, from the company's discovery answers, no efforts are made to look for any documents to do these things you're talking about.
	Search for emails, search for videos.
	None of that was done until February 2019 when discovery was ordered in the Lewis case, all right?
	And what I'm wondering is, is if between April 2018 and the following year, in February 2019, If there was an employee who had an email on the InfoWars email server and it was personally incriminating to them, there is nothing stopping them from taking that email off the server before that search happened, right?
	I don't think that that's accurate.
	I think it would still have been in a deleted email box.
	So I don't think that that's accurate.
	And I don't want to agree or disagree with the dates, because I don't know the answer to it.
	Sure.
	So, I mean, if those are your representations, that's fine.
	But I just don't know.
	But I don't have any reason to believe that somebody deleted it off of the server, and then I wouldn't still be able to access it.
	Well, if there have been no efforts to preserve anything, then we don't know.
	You wouldn't have any basis to know whether something's been deleted or not, right?
	I think we produced a lot of things that were in deleted folders and spam boxes, so I don't have a reason to believe that there was anything that was deleted.
	Alright, you have no special expertise in IT, we've talked about that.
	No, I don't.
	Alright, and so if somebody like Mr. Zimmerman, who has a bunch of expertise in IT, wanted to get an email off that server, you don't doubt that that could be possible, right?
	You don't have enough information sitting here today whether to know that is possible or not.
	I'm sorry, is the question whether, does Mr. Zimmerman have the ability to get emails off of the server?
	More specifically, that you don't possess the knowledge to know whether he does or not.
	I don't think that's accurate.
	I think he can get information off the server.
	I don't think you're understanding the question.
	Okay.
	My question's not whether he can get information off, like you're talking about pulling it off so he can produce it.
	I'm saying he wants to get rid of it.
	I'm saying he wants to delete it and make sure nobody ever sees it.
	Oh, you mean... He can do that.
	Oh, I don't know.
	I don't know the answer to that.
	I'm sorry. - So it would be fair to say your testimony here today is that you don't know if anything has been done to preserve the emails on the Infowars server before the time it was that they were to produce those documents.
	I don't know the time period, no.
	And more than that, you don't know, beyond time period, you don't know that anything was ever done to preserve the emails themselves.
	Right?
	Aside from pulling them off the server, No.
	Right, well I understand, and this is again something you may not know about, or that I expect you to know about, but in February 2019, an entire mirror image copy was like a backup, a secure backup was created of the email system.
	Do you understand how that process works?
	I know that it can be done, yes.
	I don't know the technologicals of how it's done, but I do know it can be done.
	And before I just told you that, you didn't know it happened, right?
	I didn't know the date that it happened.
	Okay, but you did know that there was a mirror copy made of the entire email server?
	Okay, that would be an effort to preserve the emails, right?
	Yes, I just don't know when it was.
	Okay.
	Alright, because I know that you don't know when it was.
	I just want to make sure, now that you've told me that there were efforts made to preserve the emails, do you know of anything else that was made to preserve anything?
	Aside from the emails?
	Can you be more specific as to what you're talking about?
	I'm saying that I asked you here to testify to me about Infowars' efforts to preserve evidence, and so far I haven't heard anything.
	And I'm wondering what was done following suit to make sure that potential evidence was available for use in this lawsuit.
	I think part of the issue here, and I just want to, if I can go back a little bit to talk about the employees that I interviewed, is the structure of the company.
	And that's probably the problem that we're getting into, and it's my issue as well of getting this information, is that there is no one person at the company that's designated to do such things.
	There are different departments and one department does not have any communication with another department and that's just based on my interviews and observations over the last couple of weeks but so essentially if there were documents that were produced by one department They have their own specific policies and procedures and ways they do things there as far as preservation of what they do.
	For example, production.
	The production department may produce, on a daily basis, news articles that they print out for the hosts.
	Those particular news articles that they print out for the hosts, those are not retained.
	Those are shredded and they get rid of it.
	There is no retention policy for those documents.
	There's also no retention policy for like initial video clips.
	So like the final product, so if you're interested in video clips or raw footage of things before it was cut into a finalized version, those things aren't saved either.
	So there's no, in any individual department, there's really not a retention policy like that to retain those types of documents.
	So if that's what you're interested in, nobody's really retaining those documents themselves.
	As far as the emails go, there's Mr. Zimmerman, who is the IT person, and he handles things related to the website.
	There's also a separate person that handles information in connection with PQPR, which is a separate company.
	For the sales end of things.
	And those things are all separate too.
	These are all separate departments that really aren't talking to each other.
	So I think that was a bit of the difficulty that we're having in answering your specific question.
	If that makes sense.
	It does.
	Objection non-responsive.
	If there was a person at Free Speech Systems in charge of preserving documents for this litigation, who had that as part of their duties.
	You haven't spoken to that person.
	There is no such person.
	So if Mr. Frugier, Tim Frugier, you know who that is?
	I've heard the name.
	Okay, you haven't spoken to him.
	I have not spoken to him.
	So if that person was the person who was in charge of preserving documents for this litigation, you have no information from him.
	I don't know that that's accurate.
	Just based on your representation.
	In fact, let's go ahead and get that question.
	I think that's a better way to ask that question.
	If Tim Frugier had any involvement or management of the preservation of documents involved in this case, that is information you don't have, whether that's true or not.
	Right.
	OK.
	When it came to time to produce documents in this lawsuit, who was responsible for searching the company's email server?
	Um, I think that would have been Mr. Zimmerman who would have done the search.
	When I talked to Mr. Zimmerman, um... Did I put him on my list earlier?
	You did not.
	I'm sorry.
	I did talk to Mr. Zimmerman.
	Let's add him.
	Let's go ahead and make sure before we go on any further.
	Is there anybody else we need to add?
	What I don't want to be happening is coming to other questions and going, oh no, actually I can answer that question because here's this other person I talked to who I never told you about.
	I understand.
	I'm doing my best here to remember everybody I spoke to.
	Do you have any notes on who you talked to?
	You know, I did have it in my notes, but unfortunately I didn't print that page.
	That page is missing.
	So I did not print that page.
	I did write it down, but it's not in my notes for some reason.
	But I did speak to Mr. Zimmerman.
	I'm sorry, can you repeat the original question?
	I believe what you answered, he was the person responsible for searching the email server?
	Yes, and I think he testified to that as well at some point.
	Now, when it came to anything besides emails, besides the stuff that came off the email servers, when it came to documents that may have been on any individual devices among any individual employees, who was responsible for collecting those documents?
	You mean like the work computers?
	Sure.
	I think that that would have fallen in IT, so I think Mr. Zimmerman would have done that as well.
	Okay, do you remember actually him testifying that it was actually the individual employees, that he didn't do that at all?
	I don't remember, I'm sorry.
	Okay.
	So, because I wanted to ask you about this idea that free speech systems just left it up to complete individual employees to go search their individual systems and return their documents, and you aren't going to be able to talk about that process?
	Um, whether or not the individual employees had gone through their devices themselves.
	Are we including their phones, their personal phones?
	Sure.
	Okay, I know that they went through their personal phones themselves.
	Um, but as far as their work computers, I'm not sure.
	You're not sure if that happened?
	No, I think it happened, but I don't know whether they did it or Mr. Zimmerman did it.
	Oh, okay.
	Because see, here's the problem that I have, is I have the testimonies that the employees did it, or Did it, quote unquote.
	And that not a single document, not a single employee, single one of them, returned a single document.
	Does that sound accurate to you?
	I don't think it's outside of the realm of possibility just given what I know about how the company operates.
	But that would just be total inference on your part.
	You don't have any first-hand information about whether any employees returned any documents in the search for documents in this case.
	I believe that it's true that they did not return any documents on their work computers.
	So I believe I read that.
	But again, I don't think that that's out of the realm of what is normal given the structure and the way the company operates.
	You think for how this particular company operates?
	Yes.
	It's very unusual for a company who's been sued It needs to preserve and produce evidence to just tell every individual employee who might be involved in that malfeasance to just go look for documents themselves.
	That is unusual, right?
	It's not how I would have done it.
	Okay.
	Now, you were talking earlier about document retention, but there is a document retention policy at InfoWars, right?
	I don't think that's accurate.
	You understand that there are messaging systems which have been used inside InfoWars other than email, correct?
	Yes.
	For this deposition, did you search those systems or have someone search them for you?
	Did I personally?
	No, I've relied on what's been produced already in the document production.
	Ah, I got you.
	So anything that you looked at was already produced a long time ago?
	I don't think that's the entire universe of what I looked at.
	So I definitely have updated financials so that I could I speak to them at the deposition.
	I have updated information as far as, you know, employees who work there, didn't work there.
	So there are documents that I review that aren't in the production.
	So I don't think it's the entire universe.
	Let's stick to those messaging systems.
	Let's stick to messaging systems used inside of InfoWars that are not email.
	Okay.
	In terms of those documents.
	Anything in the history of this litigation, are there any documents produced from those systems?
	From systems other than email?
	You mean whether they were produced?
	I know that Alex has produced A lot of documents.
	And I know that there was a time that they stopped using specific platforms.
	Like, so for example, Yahoo Messenger they had used at a point in time and then they stopped using it.
	Slack as well they stopped using.
	So as far as the time period for those, I'm not really sure whether those were produced because they stopped using them.
	Well, I mean, InfoWars is to this day using like RocketChat, right?
	Um, I don't know if they're using it to this day, but I think that it's has been used prolifically.
	All right.
	So let's go back to the question I asked was, have there been any documents produced from any messaging system that isn't email?
	I don't know.
	Okay.
	And then as far as for this deposition, when you had topics to go prepare for, if there is any information that's in any of those systems, you didn't go look for it for this deposition.
	I did not know, personally.
	Nobody in the company went and searched through those, right?
	For this deposition.
	For this deposition?
	Correct.
	I don't know.
	I don't think so.
	Okay.
	So you mentioned that you're aware of what Rocket Slack is.
	Yes.
	I mean, I'm sorry.
	I said that because Rocket Chat is what I meant to say.
	Rocket Chat, yes.
	Rocket Chat is like a self-hosted version of Slack, right?
	You understand that?
	I don't know how it works, to be honest.
	Okay.
	I'm not that technologically savvy.
	Okay.
	And RocketChat was used, I mean, I say to the present day, and you may be right, maybe they stopped using it yesterday, but throughout the events since they've been sued, the company has been using RocketChat.
	You mean 2018 forward?
	Correct.
	I do believe that in the period after 2018, they were using RocketChat.
	Okay.
	Okay, were those logs preserved? - I'm not really sure.
	Were they searched ever?
	Here's the problem I have with that specific question.
	Depending on the agreement with those particular servers, for example, I know that Slack doesn't save all of the chats unless you pay them monthly.
	Some of these are free free plans and then it'll only save up to a certain period of time and then to go back to way prior chats, you would have to reach out to Slack itself in order to get those documents.
	So I don't know that the company has access to those things going back that far, just because I don't think that...
	What do you mean that far?
	2018 was four years ago.
	So I don't know that they can go back four years in their chat logs.
	Okay, here's what I'm really asking.
	The company was sued in April 2018.
	Sure.
	Alright, so let's go to May 2018.
	The company had possession of whatever the rocket chat logs were in May 2018, right?
	For what time period?
	For May 2018.
	For that month?
	Sure.
	Sure.
	And were anything done to preserve that?
	I don't know.
	Okay.
	So another messaging system that was used was, so we talked about Rocket Chat, right?
	Another messaging system that was used was Slack.
	And do you know when the company stopped using Slack?
	Honestly, I'm not sure.
	It was a while ago.
	It's been a while.
	They have not used Slack in a long time.
	What does that mean?
	I don't know what a long time means.
	Within the last couple of years.
	Okay.
	What about since they've been sued?
	I'm not sure.
	Okay.
	And I take it then you don't know if Slack has been preserved?
	As I said, I don't think Slack, the way that their plan worked, I don't think you can go back that far.
	So like, for example, say we were sued in 2018.
	we were sued in 2018.
	It really only, you can only go back a week or so in the chat logs.
	Are you, when you say you can only go back a week or so in the chat logs, what are you basing that on?
	I have experience with Slack.
	I've used Slack in my professional life, so I know that unless you pay for a plan, you can't go back to your entire universe of conversations.
	They're not preserved.
	Okay, because one thing I'm having some confusion on is because we have a pleading in this case from Council of Record in this case that says the Slack logs were preserved.
	Okay.
	Do you know if that's accurate or not?
	I don't know.
	And I don't know what time period that would be from.
	Okay, and then you also said something about, like, you would have to reach out to Slack to check on this information.
	Has that ever been done?
	I don't know if Slack even preserves that information, to be honest.
	Well, you're the one who said you would have to reach out to Slack.
	Yep, to find out.
	Did the company ever do that?
	I did not do that, no.
	I'm not asking what you did.
	I'm asking what the company did.
	I don't know.
	Okay.
	You know what wire is?
	A messaging system called wire?
	I've heard of it.
	Oh, was that preserved?
	I don't know.
	Was it searched?
	I don't know.
	I think you'd have to ask Mr. Zimmerman that.
	He's more technologically available for it.
	Well, here's the thing, Ms.
	Paz.
	I did ask Mr. Zimmerman about it.
	This is the fifth time I've tried to take this deposition.
	Right?
	And I did try to talk to Mr. Zimmerman.
	That didn't work so well.
	Try to talk to Mr. Dew.
	Try to talk to Mr. Karpova.
	So in terms of- Miss Karpova.
	Miss Karpova, so if you are going to be referring me to other people who've already been deposed, I don't care about what they say that I need to talk to them.
	I'm here to talk to you.
	And from what I hear you saying, is that you don't know the answer to that question.
	I don't.
	Okay.
	Do you know anything about Base Camp?
	Do you know what Base Camp is?
	No.
	Okay, so Infra Wars employees, you don't know if they've used Base Camp to communicate about stories in Sandy Hook.
	I don't know.
	Okay.
	So have you read just the depositions in this case or have you read testimony taken up in Connecticut?
	I've read one or two of the depositions in Connecticut.
	I don't think I've read them all.
	Okay, well here's the thing.
	Has Mr. Salazar testified up in Connecticut?
	I did not read his deposition.
	Okay, well he testified that they talked by base camp and I'm just wondering has there been any effort to find those conversations?
	I don't know.
	You've never reviewed any conversations that are base camp messages?
	No.
	Okay, do you know who Kurt Nimmo is?
	Yes.
	Okay, Kurt Nimmo was deposed in Lafferty.
	Do you understand that?
	Sure.
	Did you read his deposition?
	Uh... I don't remember.
	I might have, but I don't remember.
	Alright, well just exhibit eight, I'm sorry, exhibit thirteen to Kurt Nimmo's deposition on page 103 of his Lafferty deposition.
	There's a question and answer exchange I want to ask you about, and the question is, would it be fair to say that Plaintiff's Exhibit 13 is a base camp message from Paul Watson?
	The answer is right.
	Then the next question is, and it's warning, quote, be careful to avoid stuff about crisis actors and claims that stories were published the day before the event.
	This is radical, this info.
	And I'm curious because I don't have any base camp messages.
	I certainly don't have that one.
	I haven't seen that message.
	That's going to be my question.
	No.
	You have not seen this message about crisis actors on Basecamp that's being referred to in Mr. Nimmo's deposition?
	No.
	If that document does exist, it's not something that was provided to you?
	I haven't seen it.
	So Kurt Nimmo, you understand he's...
	Tell me who he is.
	Well, I know who he was because he's no longer employed by the company, but I think that in a relevant time period, I believe 2018 and prior, he was the head writer at InfoWars.
	Did you talk to him?
	I was not able to locate him.
	He's not a current employee.
	But I did make efforts to try to find out his current information, but we were not able to talk to him.
	What do you mean you tried to find out his and make efforts?
	I just, I wasn't able to reach out to him.
	He was deposed in Lafferty.
	Everybody has this information.
	Okay, but I tried to reach out to him.
	Wait, hold on.
	Let's make sure I understand this.
	Sure.
	Because I thought you just said that you couldn't find his information.
	I think what I said was I tried to reach out to him.
	Okay, because we're going to maybe need to stop at a break and go look at what was said on the court reporter here because I thought what you were saying is you were unable to locate his contact information.
	I don't know that I was unable to locate it.
	I think that we tried to How did you try?
	Reach out to him.
	By phone.
	Okay, so if I go talk to Kurt Nimmo, he's gonna have a phone record of an InfoWars number or your number calling him.
	I don't know.
	Well, I mean, if your testimony's truthful today, that would be the case, right?
	I didn't... I wasn't able to get in contact with him.
	I'm not... I'm asking... That's not what I'm asking you.
	I'm asking, did you call him?
	I called a lot of people.
	I think I did try to call him.
	Okay, so... But your testimony would be... I didn't speak to him, though, no.
	Your testimony is that either you or somebody at Infowars called him for this deposition.
	I know we tried to get his contact information.
	I asked Melinda for his contact information.
	She didn't have it.
	I don't know whether I called him and left a voicemail and he didn't pick up.
	I know I haven't talked to him, so I'm not honestly sure.
	Okay, so I just want to make sure, when you say you're not honestly sure, you are sure you haven't talked to him.
	I am sure I haven't talked to him.
	What you're not sure of is if you've tried to talk to him.
	I know I asked for his contact information, but I'm not sure if I actually called.
	Okay.
	So let's, before we go on any further.
	- Sure.
	- Are there people you tried to talk to and couldn't other than Kurt and Emma?
	- I think Kurt was the only one.
	Okay.
	Most people were pretty responsive.
	Okay, you don't remember leaving voicemails for anybody else?
	I left a couple of voicemails for Nico.
	He returned my call though, and we did speak.
	Okay.
	We went back and forth with Mr. Watson.
	There was a time difference there, but ultimately we were able to speak.
	Just talking about people you tried to but couldn't?
	Yeah.
	I think Kurt was the only one.
	Okay.
	Okay, do you know what Pigeon is?
	Not the bird?
	No.
	Okay, Pigeon's a messaging communication system.
	Did you know that was used inside of InfoWars?
	I don't know.
	Okay, you didn't make any efforts to go find anything from Pigeon?
	No.
	You don't know if anything was preserved from Pigeon?
	I don't know anything about Pigeon.
	Okay.
	There are text messages between employees talking about Sandy Hook.
	That was something that's happened over the years, right?
	I'm sure it has.
	Okay.
	Did you do anything to try to figure that out?
	If there were any?
	If the employees produced any, or if it actually existed?
	Let's do a big one so you can give me the whole answer.
	Sure.
	Which is, did you do anything to verify, one, whether any such text messages currently exist and are available to you, two, whether they ever existed, and three, if anything was ever done to preserve them?
	I think that when the lawsuit happened and when we got notice that we needed to preserve these things, we asked the employees to go through their cell phones to find any information.
	And if there was, they were given to us and then we gave them to our attorneys.
	Why do you think that?
	Why do you think the employees were told that?
	Who told you that?
	Um, I don't want to say anything that's privileged, guys, because I had a number of conversations with counsel.
	Okay.
	Well, I mean, let's do it this way.
	We know it's not a document because you don't have a litigation hold.
	You don't know when that happened.
	No, I don't.
	I don't think it's a document.
	Okay.
	And so we know, I mean, at least I know you didn't talk to Tim Pruge, right?
	No, I didn't.
	All right.
	So where does this information come from?
	The idea that, that, yeah, I mean, I mean, if you're just gonna have to say counsel, you can say counsel.
	I think it came from counsel.
	So I don't want to talk about my conversations.
	And you've never talked to any employees about any other text messages?
	No, I don't think that's accurate.
	So when I spoke to Rob Dew, I had a long conversation with Rob Dew.
	He and I talked about him looking through his phone and things like that.
	So I don't think that it's accurate that the employees didn't talk to me about it.
	Okay.
	In terms of what was done, To preserve cell phone messages, text messages, or who produced them, or what may exist.
	You don't know that.
	I think in terms of what was done, the employees were asked to review their phones.
	And again, you have no personal knowledge of that, and no information from any employee that says that that happened, right?
	That's not accurate.
	Okay, which employee told you that there were directions made to search their phone?
	As I previously indicated, I think I spoke to Rob Due about it, and I think Rob Due indicated he searched his phone.
	I get that you testified that Rob Due said he searched his phone.
	Yep.
	I'm asking you about conversations about the company's instructions to employees about their phone.
	Oh, I don't know.
	Did Rob Due tell you anything about that?
	Oh, I don't know.
	Have we talked about all the applications and messaging systems that InfoWare's employees have messaged each other on?
	In terms of preserving documents?
	Did we talk about Yahoo Messenger?
	Yes, you briefly talked about that.
	Okay.
	Slack.
	I think that's it.
	Okay.
	Now, Mr. Jones' text messages, when were those preserved?
	I don't know.
	When were they searched?
	I don't know.
	You know about Ms.
	Williamson's, the New York Times reporter's text to Mr. Jones that she sent to us?
	Do you know anything about that?
	No.
	Okay.
	One of the things you didn't review for this deposition is any of the briefing on plaintiff sanctions, correct?
	I did not know.
	Okay.
	There was a lot of documents on those.
	You don't know any of the issues that plaintiffs raised in terms of why previous depositions have been adequate in this case?
	I know that there was an issue, there were issues related specifically to Ms.
	Karpova's deposition and Mr. Due's deposition which was part of the reason why I was retained.
	But aside from that, no.
	Okay.
	Like, in terms of specifically, what was wrong with those depositions?
	You're not real up to speed on what we said about that, right?
	Um, I know that there were issues related to the inability of Mr. Du and Miss Karpova to testify intelligently as to the material in the videos and the sourcing done for those videos, because nobody had re-watched those videos.
	Made sure to undertake an effort to do that.
	But as I indicated previously, I don't know that it's really possible for a person to review every single piece of paper in two weeks' time.
	I agree.
	So to that end, I think that I tried to hone in on the things that were most important.
	So I did try to address some of the things that were wrong with the last two depositions that were done.
	All right.
	One of the things that went wrong with the last two depositions were done was testimony about the preservation of documents.
	And one of those had to do with Mr. Jones' text messages, which you don't know when they were preserved or when they were searched.
	I'm sorry, I don't.
	Okay.
	And, for instance, one of the things that was... Let me ask you this way.
	Do you believe Mr. Jones has produced all of his text messages relating to Sandy Hook that he had in his possession after the anticipation of litigation?
	And here's the problem with that is that I don't know what he has on his phone because I don't know what if anything would have been on the phone at that time period.
	And the only reason why I say that is I know that he's got new phones, so he doesn't have access to anything that's on prior phones.
	Or he wouldn't have anything that's for prior phones.
	I'm sure that if he, well actually I don't want to say that because I'm not sure, but in any event, like I said, I don't know when he would have gotten a new phone such that he would have access to those messages.
	You read Mr. Jones' November 2019 deposition?
	I read the March 2019 deposition.
	I don't think I got to the November one.
	Okay, because see Mr. Jones testified something totally opposite of what you just said, which is that he got new phones.
	But they have the same SIM card and off of cloud storage and he doesn't lose text messages.
	Okay.
	Do you have any reason to dispute that?
	No.
	Okay.
	And so are you aware that I possess a text message that was sent to me from 2019 that says Sandy Hook in it and discusses Sandy Hook sent by a New York Times reporter.
	Do you know I have that message?
	No, I don't.
	Okay.
	I haven't reviewed any text messages.
	Okay.
	So in terms of why I have that message and why Mr. Jones didn't produce it or why it wasn't preserved, you don't know the answer to that question.
	I don't.
	Can you summarize for me what the company knows about Neil Heslin?
	Could you be more specific?
	No.
	Not now.
	Can you summarize what the company does know?
	I mean, let me put it this way.
	Neil Heslin.
	The company has no relationship with Neil Heslin.
	Right?
	Correct.
	Nobody at the company has ever met Neil Heslin.
	I don't believe so.
	Doesn't transact any business with Neil Heslin.
	No.
	Shouldn't have a ton of information about Neil Heslin.
	Right?
	Um, I don't know that that's accurate.
	I'm sure that in relationship to the litigation, certain documents may have been produced.
	I haven't produced anything.
	No, by the company.
	The company may have produced documents or my attorneys may have produced documents.
	I don't know.
	That's what, okay, you don't know what the company may have or may not have produced about Neil Hussle?
	Before or after the litigation?
	Both.
	So before the litigation, I don't think that the company had much, or if at all, information about Neal Heslin.
	Okay.
	What about after?
	After, I am aware that there was some information about some legal issues that he may or may not have had in Connecticut.
	You mean after the lawsuit was filed, somebody went and found out about that?
	I believe so.
	Okay.
	Prior to this lawsuit, In terms of its Sandy Hook coverage.
	Has the company ever done any research on Neil Husson?
	I don't believe so.
	Again, one of the things I want to make sure that you haven't one of the things I want to make sure that you haven't reviewed is the Back up.
	Yeah, okay.
	One of the things you haven't reviewed is the plaintiff has submitted various exhibits in support of his sanctions for Ms.
	Karpova's deposition.
	Did you know that?
	I didn't review that sanctions motion.
	Okay.
	Do you have exhibit stickers?
	Okay.
	Can you mark this as one and give it to the witness?
	Can you give me a moment to grab that?
	Absolutely no problem at all.
	Thanks.
	Alright, Ms.
	Paz, I've handed you what's been marked as Exhibit 1.
	Do you see this email here from David Knight?
	Yes.
	Do you understand who David Knight is?
	I believe that he was a former host.
	Okay.
	Do you know why the night of June 19th, 2017 might be important in this case?
	No.
	Okay, well that's the night that Mr. Hesslin appeared on Megyn Kelly's show.
	Do you understand what that appearance was?
	Okay.
	Yes.
	Okay.
	So that's the night, as the night that Mr. Hesslin appeared on Megyn Kelly's show, Mr. Knight is emailing himself articles on Mr. Hesslin's past, isn't he?
	That's what this document is.
	Okay.
	Let me show you.
	Can you mark that as two?
	Or I got it.
	Gave me some stickers.
	I've marked that as exhibit two.
	That's also from the same day, right?
	It's from the next day.
	Is that really, is that the 20th?
	It's the 9th, one is the 18th and one is the 20th.
	19th, sorry.
	19th, okay.
	And so this one is titled, Connecticut Carrie Releases the Troubled Past of Neil Hesselin, right?
	It's a link to an article that, or I'm assuming is an article, but that's what it says.
	I was actually talking about the subject line of the email.
	That's what it's titled, right?
	Yes, I think that's the Name of the story and the link that's in the body.
	Probably the headline of that story.
	Yes, that's what it looks like.
	So here we have Mr. Knight.
	Also on the other email that you're looking at, do you see a different email address, Seek the Truth?
	Are you talking about Exhibit 1?
	Yes.
	Yes.
	Okay, and that's also another InfoWars employee, right?
	You know what, I'm not sure.
	Okay.
	You know who Dan McBrain is?
	Yes.
	So what we have here is, contrary to what you had believed, prior to this lawsuit, the company had indeed been conducting research on Neil Husson.
	Um, I don't think that that's an accurate statement.
	I think that, as you represented, this is the day that he went on Megyn Kelly, so it would have been in addressing that interview, which I believe that interview was directed at The company, well Mr. Jones maybe individually, but generally at the company.
	So, I don't know that the right way to describe what you see here is we were conducting research on an individual for no reason.
	Oh, I'm not saying for no reason.
	I 100% know the reason.
	Okay.
	Mr. Hesslin got on Meg and Kelly's show and said some bad things about Infowars.
	Said that Infowars was saying things that he wished they would stop saying.
	And then as the next thing that happens, from Mr. Knight's point of view, is he goes up and digs up dirt on Mr. Hesslin, right?
	I mean, that's what's happening here, right?
	Um, I don't know that he dug it up.
	I think he sent himself an article.
	You have no idea how he got it, do you?
	It says he sent it to himself.
	Right, but where did he get the article?
	I mean, he put the... I know that he put a link in an email to himself and sent it to him, but we don't know how he got that link, do we?
	I don't know how he got this link, no.
	You haven't talked to Mr. Knight, have you?
	I've not spoken to him.
	He's not a current employee.
	You didn't even try, did you?
	I didn't try to talk to him, no.
	Okay.
	And so, this, interestingly enough, I asked Ms.
	Karpova this... You read her deposition, right?
	Yes.
	Okay, I asked her the same question.
	Has the company ever done any research on Neil Husson?
	She told me the same thing.
	No, it's never done any research on Neal Husslein.
	And I told her, oh, unfortunately, yes, it has.
	When you read that, did you go try to find out if the company had ever done any research on Neal Husslein?
	I wouldn't consider this doing research on Neal Husslein.
	Okay, well, that's where we disagree.
	But in terms of did you go to try to find out if the company had ever tried to get any information or had been exchanging with itself any information about Neal Husslein?
	Um, aside from speaking to the individuals I've already said I spoke to and doing the searches on the Dropbox for the production, no.
	Well, I mean, that's a good point, right?
	If you searched every document with Neil Husson's name in it, these documents would have come up, right?
	I think I did see these.
	Okay.
	Tell me all the sources of information for InfoWars knowledge about Neil Husson.
	I'm sorry, can you be more specific?
	I can't.
	No.
	No.
	The company had got information about Neil Husson.
	Some of it which it put out into the world on its videos.
	And I asked you to get prepared on the company's knowledge of the plaintiff.
	I want to know all the sources of information about Neil Husson.
	Some of the documents that were returned in my search were things that other people send to us.
	So like, I'm sure you know that many of the emails are thousands and thousands of emails from the general public.
	Some of them send information to InfoWars, to general InfoWars mailboxes that may or may not be monitored.
	I can't say whether that is in the company's knowledge because, like I said, nobody was really reviewing those with any regularity.
	I see what you're saying that these obviously were in David Knight's purview because he sent them to himself.
	But aside from those, I don't think that I saw anything else.
	I did see, like I said, he had some legal issues in Connecticut.
	Okay, here's what I'm not understanding.
	InfoWars has made multiple videos about Neil Husslein, right?
	I mean, you're being sued for two of them.
	Right?
	When you say multiple, I don't know how many you're referring to, but I don't know how, I don't think that there are a lot of videos specifically naming Neil Husslein.
	Okay, well let's just go with two.
	Sure.
	Alright, let's talk about the two that they're being sued for.
	Yes.
	You know those two videos exist.
	I do.
	You know there are sources of information about Neil Husslein in those videos.
	Yes.
	Where did it come from?
	You mean where were they sourced from?
	Yeah, I want to know every piece of information about Neil Husslein that the company put on the air, where did it come from?
	Um, I know that Owen Schroyer's video was specifically sourced from that article.
	I believe it was from Zero Hedge.
	So that was a source of that particular video.
	And I think that that source came from iBankCoin, if I'm not mistaken.
	Then the Megyn Kelly interview.
	Thank you.
	Okay.
	I think I already said I was aware of his legal issues in Connecticut.
	But that may have been sourced from these articles.
	I'm not really sure what the original source was for those.
	Like his legal troubles in Connecticut.
	Okay.
	And as far as documents I reviewed, I think that's probably it.
	What about Mr. Fetzer?
	Mr. Fetzer's book, you mean?
	Not necessarily.
	Mr. Fetzer... Anything from Mr. Fetzer about Mr. Husson?
	I don't think that Mr. Fetzer was very involved with the company or with individuals inside the company and the reason why I say that is because based on my conversations with Mr. Jones and Mr. Watson, Mr. Fetzer was not really on friendly terms with Mr. Jones and Mr. Jones's position is he really didn't use Fetzer as a source So, Mr. Jones' position is also he didn't think he read the book that Mr. Fetzer has produced?
	So whether or not it's in the company's materials, it may be in the materials, but I don't know that it was ever reviewed by anybody, I don't know that it was ever in the company's purview in any way.
	You watched Owen Shore's video, right, about Neil Husson?
	Yes.
	That video quotes Mr. Fetzer.
	For the sources in the claim, it quotes him, right?
	You mean in the video regarding the Megyn Kelly interview?
	Whether Mr. Hesson held his son or not.
	Right.
	That all comes from Mr. Fetzer.
	It's quoted in the video.
	Do you not know that?
	No.
	The source of that video is the Zero Hedge article that I just referenced.
	Actually... And so that may have been quoted from the Zero... Zero Hedge may have used that as a source.
	But I'm not aware of Owen using that as a source.
	It's... It's shown on... Like, right... That's the thing that's shown.
	Is Mr. Fetzer says blah blah blah.
	Right, but I think that the source that Owen got it from was Zero Hedge, not from directly from Mr. Fetzer.
	Do you see what I'm saying?
	Sure, I mean, we could just keep cycling it.
	It could be, I bank coin, gives it to zero heads, give it to somebody, give it to somebody, give it to somebody.
	Right.
	And then when you put the article in, it's Mr. Fetzer says X, Y, and Z. Right.
	Mr. Fetzer's being quoted in that video, right?
	I think the only reason why he was quoted is because it was quoted in the original article.
	That was the source that Owen used.
	So I don't think that, if you're asking me whether Owen went to Mr. Fetzer as a source, or went and read his book, or went and read any, independent research into Mr. Fetzer's information that he had available to him.
	I don't think that that is what happened.
	I think what happened was, as is typical in the company, is that he woke up that morning, there were sourced of a bunch of material that was produced to him that morning, that morning, that Zero Hedge article was produced, and that was the entirety of the source material that he used to produce that video.
	Right, so he gets the Zero Hedge article.
	Yes.
	Somebody said, hey, you should look at this.
	And he looks at this, and he sees Mr. Fetzer says blah blah blah, and he says, I'm gonna put this on the air.
	Right?
	The source in the Zero Hedge article.
	Right.
	Whatever the source that Zero Hedge had produced.
	Right, because Zero Hedge is not a... That's not a person, right?
	No.
	That's a completely anonymous blog, right?
	I don't think it's a blog.
	Alright, I don't know what else it would be.
	What else would it be?
	Um, I think that the point of Zero Hedge is that it accumulates articles from all kinds of different sources, so it's an accumulator.
	Alright, so who wrote the article on Zero Hedge?
	Where does it come from?
	That article, I believe, was originally sourced from my bank coin.
	Well, the article is written by Zero Point Now.
	Do you know what that is?
	No.
	Okay.
	Does the company contend that Mr. Hesselon is a gun regulation advocate?
	At what point in time?
	Any time. - I'm not really sure how to answer that.
	Okay, so the company does not know if Mr. Heslin is a gun control advocate, gun regulation officer?
	I'm not sure as I sit here today, no.
	So if that is knowledge the company has about the plane, if you wouldn't be prepared to speak about it today?
	Right.
	Are there any people from whom the company received information about Scarlett Lewis?
	I'm sorry, can you repeat that?
	Yeah, are there any people from whom the company received information about Scarlett Lewis?
	I don't know.
	Do you have a document that you could show me?
	No, I mean, part of it is because I want to know what I haven't been shown.
	Because this company has not at all cooperated in good faith with Discovery.
	So part of the reason I have you here is for you to tell me.
	So has, is there anybody in the company who's gotten information about Scarlett Lewis?
	I don't know.
	If you could show me a document, that would be helpful.
	But as far as my communications with the people in the company and what I've done, my due diligence to testify here today, nobody has, is aware of any aside from what's been produced.
	What do you mean aside from what's been produced?
	What has been produced?
	If there's anything that's been produced, I don't think that there's anything regarding Ms.
	Lewis.
	Okay.
	I have not, I don't think I've seen anything.
	Let me, let's go back.
	Part of your job today was to get prepared on the company's knowledge of the plaintiff.
	Right.
	Do you feel like you've done that for Scarlett Lewis?
	I feel like I have asked the employees what, if anything, they had for the plaintiffs, and their response to me was that they didn't have anything.
	Okay, have you read out every document with Scarlett's name on it?
	I did a search in the Dropbox material that we have.
	That's not what I'm asking though.
	Did you read every document with Scarlett Oos' name on it?
	I don't know that I've read every single document.
	Okay.
	So you'll concede to me sitting here today, there are possibly documents in this case that have even been produced that have Scarlett's name on them that you may have not read.
	That's what you're telling me?
	Perhaps.
	Okay, so in other words, when you did a search of documents for Scarlett Lewis.
	Were you searching the entire production?
	Did you have a capability to search the entire production?
	I have a capability of searching the production on our Dropbox.
	I understand that there have been some issues regarding the various attorneys and what's been produced where.
	But it's my understanding that from the company's perspective, we've not ever used Ms.
	Lewis's name on the air.
	Oh, I don't doubt that.
	So we don't have, when I asked people what if anything they have have or produce on Ms.
	Lewis, and if they told me that they don't have anything, that makes sense to me because I don't think they've ever used her name.
	Wouldn't it not make sense to you though after you read Ms.
	Karpova's deposition and you saw emails from Wolfgang Halbig directly harassing Ms.
	Lewis?
	Wouldn't you think then, oh maybe there are documents with Ms.
	Lewis's name on them?
	I mean, there may very well be missed documents, but that doesn't mean that it was in the company's knowledge.
	Many of those documents, after a certain point, were not being opened.
	Okay, so from your standpoint, because you don't know whether certain documents were opened or not, you just ignored them?
	No, that's not correct.
	Okay, so you knew the company possessed documents with Scarlett Lewis' name on them, right?
	Sure, there's some emails, but I don't know whether they were ever in the company's knowledge as far as information that was provided by an outside source.
	Mr. Halbig, I know Mr. Halbig has sent a variety of emails and copied numerous, numerous people.
	They read like spam.
	And when I talk to various employees, their position is at a certain point, they stopped opening his emails.
	Wonderful.
	When you say you're not sure if the documents we talked about in Ms.
	Karpova's deposition are in the company's knowledge, they're in the company's knowledge now, aren't they?
	Now they are, yeah.
	Right.
	Okay, so when I serve you a notice of deposition for the company's knowledge of the plaintiffs, do you see a time limitation on that?
	No, I've reviewed a lot of emails.
	I've seen some of the emails you're referring to.
	You mean like the emails from Halbig to Ms.
	Lewis, Halbig to various other victims in the Sandy Hook massacre.
	I've seen those emails.
	That's okay.
	So going forward in this deposition, when I ask you stuff like, can you tell me the people who have provided information that now consists of the knowledge that the company has about this individual like Ms.
	Lewis, I want you to tell me about documents like that that you know about.
	Instead of telling me that there aren't any documents, right?
	What I want to know is, other than Mr. Halbig then, because you've seen that one now, where has the company gotten information about Scarlett Lewis?
	As far as what's been-- I guess I don't understand the question.
	So, when you say where we have gotten information from Scarlett Lewis, you mean is this information that we have sourced on her?
	Like we've gone out into the world to try to find?
	Or this is just information that people are giving us at any point in time?
	Let's talk about what knowledge means, just for a minute.
	Because I want to make sure you understand what this topic means.
	When it says the company's knowledge about the plaintiffs, you would agree with me that there's various ways that a company can acquire knowledge about an individual.
	Sure.
	It can go get that knowledge.
	It can go out and like go to the library and start looking stuff up, right?
	Sure.
	Somebody can send it an email.
	Sure.
	Somebody can watch a video.
	You mean if I went out and I saw a video and I was like, okay, here's a video of Ms.
	Lewis, here's a video of Ms.
	Heslin?
	Sure.
	Yeah.
	Somebody outside the company could have a phone call with the company and tell them something about Ms.
	Lewis.
	Sure.
	Tons of different ways we get information about Ms.
	Lewis.
	Sure.
	I want to know about all of them.
	Okay.
	So when I say, where did the company get any information that it currently possesses about Ms.
	Lewis and any knowledge that it has about Ms.
	Lewis, I want to know everybody.
	Where did it get that information?
	Aside from what we see in the emails, I think that the company only has information that has been provided to them through outside sources, but like I said, I don't know that anybody really paid any attention to it.
	Okay, outside what we see in the emails.
	What do we see in the emails?
	The emails that we were talking about earlier, about Mr. Halbig sending her emails.
	I'm not asking if they did research.
	We just talked about that.
	We literally just talked about that.
	Any other individuals, other than Mr. Halbig, has ever given the company any information?
	Oh, I don't know how to answer that, sir.
	Random people could have sent emails into the email server.
	Absolutely they could have.
	Random people from all over the world could have done that.
	They absolutely could have.
	And I don't know how to answer that.
	The company does.
	The company cannot name every name, specific names, of the people who have sent emails.
	Why not?
	Why can't it do that?
	Why can't I here tell you of random names of people that may have sent emails?
	Sure, you could have written them down, couldn't you?
	It's not physically impossible at all, is it?
	I did not do that.
	that.
	Okay.
	Okay.
	You see what I've marked as exhibit three?
	Yes.
	You see it has FSSTX04... I'm sorry, 043896?
	Yes.
	Okay, that's a company that's been produced out of the company's corporate files?
	It appears to be.
	Why does the company have this?
	What is this?
	I don't know.
	Okay.
	This is... Do you know who this is pictures of?
	No.
	Okay, that's Scott Lewis.
	Um...
	Do you recognize where this top picture is taken?
	Do you understand what this picture is?
	You mean the top right-hand corner?
	I'm sorry, no, in the top left.
	The top left-hand corner?
	Do you know where that's taken?
	No, sir.
	Okay.
	I don't know how the company came into possession of this.
	Do you know about Scarlett Lewis and the coffee?
	Do you understand what I mean when I talk about Scarlett Lewis and the coffee?
	Um, I believe that I read somewhere that there was something, um, about Ms.
	Lewis or someone connected to Ms.
	Lewis going to get coffee for some people that were on scene of the shooting that day.
	Alright, so that's some knowledge that somebody gave the company about Ms.
	Lewis, right?
	Or at least that it thinks that it has about Ms.
	Lewis, right?
	Um, I think that that was in the news cycle around that time.
	So I think that that's what the source of that information was.
	Maybe it could be the email where Wolfgang Haubig was harassing Ms.
	Lewis.
	Could it maybe be that?
	Like I said, I don't know that anybody had ever read that email.
	Did you check?
	Did I check about that specific email?
	No.
	So in terms of whether the company was aware that Wolfgang Haubig was harassing Ms.
	Lewis, you don't know?
	As far as a time period, I know that after I'm sorry, so let me just go back.
	When I spoke to Nico about Mr. Halbig and his communications with Mr. Halbig, getting him on the show and things like that, pretty much his point of view that he stopped looking at Mr. Halbig's emails after He stopped coming on the show.
	So... And then Rob Dew was reading the generalized email boxes for a period of time and then stopped because it was taking up too much time.
	So I can't say after the time period he stopped appearing on the show whether anybody was reading his emails anymore.
	And you can't say when he was harassing Miss Lewis, can you?
	I don't know that, no.
	Okay, so it very well could have happened before he got on the show.
	I don't know.
	Or during the time he was on the show.
	He was on the show for a pretty discreet period of time.
	What time do you think that is?
	Uh, he came into the company's purview in early 2014 and then he appeared on the show through mid to late 2015 and then he hadn't been on the show.
	Okay.
	And then the information that Mr. Halbig gave the company.
	You understand that Mr. Halbig gave the company various claims about Sandy Hook that he said were true?
	You mean his 16 points?
	A lot more than that, but sure.
	He adds to them periodically.
	But if that's what you're referring to, yes, I'm aware of them.
	And the company kept broadcasting that well into 2017.
	I don't know that I would agree with broadcasting.
	We'll talk about that later.
	Sure.
	Let's put a pin in what InfoWars may have been doing in videos in 2017.
	We'll come back to that.
	Sure.
	Does the company contend Ms.
	Ms. Lewis is a gun regulation advocate.
	Lewis operates a non-profit organization.
	I believe I did read some material in the discovery materials that she operates a non-profit for school safety.
	Does it have anything to do with guns?
	I guess that depends on what school safety means.
	And you don't know, do you?
	You don't know what the Jesse Lewis Choose Love movement does or advocates, do you?
	Um, I don't know what she says it advocates for, but I know that there are different interpretations as to what school safety means.
	Okay, but I just want to put this really clear because you seem to be trying to insinuate that there is a potential interpretation of Miss Lewis' charity that it is gun regulation related in some way.
	Is that accurate?
	I don't know, but what I'm saying is she operates a non-profit.
	That non-profit has a goal and a stated directive, and however anyone wants to interpret that is a matter of opinion, but she operates a non-profit charity.
	I get that.
	Does the company contend she's a gun regulation advocate?
	I guess that depends on someone's definition of what school safety means.
	That's why I'm asking what the company contends.
	Does the company contend that she is a gun regulator?
	She could be.
	Depending on someone's opinion.
	I'm not asking someone's opinion.
	I'm asking the company's opinion.
	Does the company contend she's a gun regulation advocate?
	She could be.
	I'm not asking if she could or might be.
	Who knows?
	Whatever.
	I don't want information.
	I want, does the company contend that she is?
	In the opinion of individual people that work for the company, she could be.
	That's my response.
	So they don't know, is what you're saying?
	That's not what I'm saying.
	Well, could does not imply knowledge.
	What I'm saying is that there are different people there that work there that have their own individual opinions, and the company isn't a person, right?
	It needs to have opinions, though, and you need to testify to it.
	That's a murky area.
	And the reason why I think that's a murky area is because these are individuals, they have their own specific opinions.
	Everybody's opinions are different.
	Like, so for example, there are people within the company that are way more into or have bigger or, I don't want to say bigger opinions, but have more opinions on Sandy Hook than others, right?
	So we could agree that One person may want to cover a certain angle of Sandy Hook that another person may want to cover.
	as interested as somebody else in the company.
	One person may want to cover a certain angle of Sandy Hook that another person may want to cover.
	That is within their discretion and their opinions as writers and as hosts.
	So, I mean, personally, am I sitting here today saying that she's a gun control advocate?
	No, but what I'm saying is I think that the hosts and writers at InfoWar, in their opinion, could interpret that as being gun control advocacy.
	Do they?
	Individually, as individual writers and individual hosts, I can't testify as to what they think.
	Alright, let's just testify then to what the company thinks.
	Sure.
	Is she a gun control advocate?
	Does the company contend that?
	Before you answer that, you understand I'm going to trial.
	I need to discover what the company is or is not going to argue about these plaintiffs, what knowledge it has, what its contentions are.
	I think it's fair, don't you think, that if the company is going to contend Scarlett Lewis is a gun advocate, I get to know that, right?
	I think it is a reasonable interpretation of the non-profit.
	that she could be a gun control advocate.
	And if a host or a writer wanted to argue that from that angle, I think it's a reasonable interpretation of that activity.
	Of the activity of her charity?
	Yes.
	Teaching emotional intelligence to children in schools?
	If that's what it does.
	Okay, so first of all, let's start here.
	You have no idea what Ms.
	Scarlett Lewis' charity does, right?
	I have not done any independent research on her charity.
	Okay, so in terms of asking What the company contends Ms.
	Scarlett Lewis does with her charity, in terms of what its advocacy is, the company has no information.
	Right?
	I know what she says it does.
	Okay, what does the company know that Ms.
	Lewis says it does?
	What she says it does is advocate for safe space for children to express themselves emotionally.
	Okay, how could that be gun control advocacy?
	Like I said, it depends on the opinion of the person.
	And you were the one who said it could be.
	So tell me how.
	How?
	How can school safety be construed as gun control advocacy?
	Teaching children emotional things.
	How does that work?
	If that's in fact what it does.
	I don't know.
	You're the one who just told me that you said that's what she did.
	What I told you that is what she says her company does.
	I don't know whether that is an actual statement of fact.
	There might be something surreptitious that Scarlett Lewis is actually up to.
	She might not be telling the truth about what her charity is.
	That's the point.
	I don't know.
	I haven't done any research into her company.
	Okay.
	Got you.
	Got you.
	Now I get it.
	I'm sorry.
	I was having trouble because I was thinking that the company's knowledge about what Ms.
	Lewis does, you were taking Ms.
	Lewis at her word, but because the company can't verify that and has done nothing to verify that, you can't say.
	That's right.
	Got you.
	Alright.
	Is this a good time for... Oh, you have water.
	I would just like another water.
	Yeah, you need a, well hold on.
	Yeah, can we take a potty break?
	Yeah, because we got a good, this will work.
	Is this a good break?
	This is fine, yeah.
	I had a few things I wanted to ask you, but I'm not going to push on you.
	10:38, off the record, don't read your microphones, please.
	Thank you.
	Yes, I would have forgotten.
	We are on the record at 10:49.
	Ms. Lewis's charity, the Jessie Lewis Choose Love Movement.
	Did you review any documents about that organization?
	No.
	When I talk about H-O-N-R, Honor, you know what that is?
	What does the company believe that is?
	I believe that's a company that is run by Mr. Posner and the goal of that company is to take what it believes is misinformation off of the internet.
	Okay, let me just correct you going forward just so you'll know going forward it's Posner, Mr. Posner.
	Okay.
	The company agrees that it has publicized information about Mr. Posner and Honor, right?
	About Mr. Posner individually?
	Sure.
	And Honor.
	Both of them.
	I agree that the company has published information about Honor and it may be Mr. Posner in connection with his relationship with Honor.
	Well, it's published things for Mr. Posner, right?
	Not Honor.
	Like Mr. Posner's email address.
	Let's put that on air, right?
	As far as its connection to Honor?
	I believe so, yes.
	No, Lynn Posner at gmail.com.
	You mean his personal email address?
	Perhaps, I'm not sure.
	Well, you've watched that episode, right?
	You know what I'm talking about?
	Yes.
	Okay.
	The company agrees its employees researched business filings related to Mr. Posner.
	Are you referring to a background check?
	No.
	Okay, I don't know that there was any independent research done as far as the company.
	I know that there was a discussion about the P.O.
	box at U-Haul that was associated with the company.
	I don't remember seeing any records relating to the filings of the company.
	You've read all the articles that were produced, right?
	You told me that.
	Yes, I've read the articles.
	So you've read the articles the company wrote about Leonard Posner?
	Yes.
	Okay.
	And in those articles, there's an article that links to his business filing, right?
	Oh, okay.
	I don't remember.
	You wouldn't dispute that, though.
	You don't know what I'm talking about?
	I don't remember.
	Okay.
	You understand what I mean when I talk about independent media solidarity?
	Yes.
	Okay.
	Can you describe to me what Independent Meteor Solidarity, sometimes called IMS.
	Can you describe to me what that is?
	I'm aware that there was a documentary that was produced by that company, well, I don't know if I would call them a company, but they're a loosely collected group of individuals that produced a documentary about Sandy Hook.
	I believe that was sometime in early 2014.
	And then that Rob Dew, I think, did a show interviewing Anonymously, the people that were involved in that production.
	Okay.
	That film, just for your reference, that's We Need to Talk About Sandy Hook.
	Yes.
	Okay.
	And you've read the articles about that film?
	Yes.
	Okay.
	You understand that that's the source of the controversy between Mr. Posner and the company in terms of YouTube strikes?
	Sure.
	Okay.
	You would agree with me that it regards the sourcing of the videos in plaintiff's petition, IMS was a source for some of InfoWars' Sandy Hook coverage?
	Which videos?
	You tell me, any of them?
	Were they a source for any of them?
	No, I think the only real source for any of the videos was that video that Rob Do did interviewing Independent Media Solidarity.
	Alright, well, you know the video we were talking about with the P.O.
	box and the addresses?
	Sure.
	Okay, they were on that video too, right?
	Who?
	Independent Media Solidarity?
	Yeah, Gust.
	They were guests on that video?
	I don't recall, I'm sorry.
	Giving out information about Mr. Posner?
	You don't remember that?
	That I.M.
	Esten?
	I don't recall.
	Okay.
	So I take it you haven't tried to talk to those people?
	No, I did not.
	Those people are not associated with the company.
	I get that.
	Believe me, I understand that.
	What I'm saying is those people... Let's put it this way.
	If those people were quoted In the February 12, 2015 video that's in Plaintiff's Petition, if that is the case, that they are quoted in there and talk in there and provide information about Mr. Posner, whatever they had to say, you don't know right now, right?
	No, I don't know.
	I mean, whatever they had to say, that was their sourcing.
	So we were just reporting on their sourcing.
	I get it.
	Okay.
	So in terms, so if those people are quoted, and appeared and talked and gave information about Mr. Posner in the February 12, 2015 video.
	One thing we can agree with is you haven't spoken then to everybody who was quoted in that video, if they did appear, right?
	No, I didn't talk to the people quoted in the video.
	Okay.
	You're familiar then, the article I'm actually referring to, maybe this will help us with our timeline, you said early 2015.
	I actually know there's a December 9th, 2014 article called Internet Censors Viral Sandy Hook Truth Documentary.
	So, would you agree with me that this is probably in the end of 2014?
	2014 or 2015?
	I'm sorry.
	2014.
	Right, that's when the video was hosted by InfoWars?
	Um, I could check my notes on that, but I thought it was in the beginning of 2014.
	Rob Doo did a, um, We Need to Talk About Sandy Hook segment, which was the title of the documentary.
	Maybe on the next break, check your notes to refresh your memory.
	Sure, sure.
	Because it was December 9th, 2014.
	Okay.
	Um, and you have an awareness that the company actually hosted that video for distribution, right?
	What do you mean by hosted it for distribution?
	It has a YouTube channel.
	Company does, right?
	It did.
	Okay.
	And at that time, the company hosted that video.
	You mean it... I apologize.
	The company you're talking about, Free Speech Systems?
	What other company would I be talking about?
	She's here to testify for them.
	Yes, I'm talking about Free Speech Systems.
	So you mean it republished the documentary on our YouTube channel?
	Yeah.
	Is that what you mean?
	I mean it was a source for distribution was that it was hosted on the InfoWars YouTube page.
	Correct?
	I know that there were links to, and this is common whenever the company covers a story or pieces of information, that what they will do is will link to that source.
	So that makes sense, that it would be linked to our articles, it would have been published in Mr. Do's broadcast to show them the viewership, the source of the material.
	That's not what I mean actually.
	Okay.
	What I mean is that Independent Media Solidarity was having some trouble keeping its video up online and InfoWars agreed to distribute and host the video on its own YouTube page.
	Do you understand that?
	I don't know that.
	Okay, and that was the first copyright strike that Mr. Posner got against the company.
	That was where that all started.
	You didn't understand that that was the first use of the drug?
	I understand that that is an issue that he's raised in his petition, but what I guess I'm having a problem with is the terminology you're using is agreeing to host it.
	So what the company does is takes a piece of information that is in the media and it will see what is newsworthy.
	In the position or in the case of Independent Media Solidarity, this video had been viewed many millions of times and it came to the company's attention because of how many views it was getting.
	And so that's how it came into the purview of the company to begin with.
	And then once it comes into the company's purview, what will happen is they will want, you know, whoever, whatever host it was, in this case it was Rob Dew, will want to do a segment on it.
	And then we'll publish how to get access to the information to the viewership.
	So that's the only problem I'm having is just your terminology.
	Say hosting, right?
	Yes.
	Okay, gotcha.
	Definitely got you.
	Alright, so what I want to do is I want to show you a document but unfortunately the way it's been produced makes it pretty unreadable on this page.
	So I'm going to enter this into the record and then I'm going to show it to you electronically.
	You understand what I mean?
	Yes.
	You see because here's an article and unless you've got a really good magnifying glass you are not going to be able to read this.
	I'm not going to be able to see it.
	So what we're going to do is we're going to put this in the record and then hopefully we're going to be able to get to the court reporter a much more readable copy of this.
	But luckily this is a video that, I mean an article that's produced that we all have.
	So here's the copy.
	You'll be able to see the headline.
	And I just want to show you just the beginning of this article.
	So first I'm going to mark this as Exhibit 4.
	And can you look at that and you can see the headline at least, right?
	You can read that part of it.
	Yes, I can see the headline.
	Okay, and that headline is Internet Sensors Viral Sandy Hook Shroof Documentary?
	Yes.
	Okay, now I want to show this to you electronically and I'm going to give you my screen here because it's a touch screen so you can just scroll it, okay?
	And I'm just going to come over here so I can show it to you and you see there's the same article?
	Yes.
	Okay.
	Now what I want to show you here is if we go down here and I want to read these first few paragraphs.
	And I'm going to read these to you, okay?
	And you can tell me if I've read them correctly.
	Last Monday, an organization known as the Independent Media Solidarity released an epic documentary entitled, We Need to Talk About Sandy Hook, which they hosted on their own site as well as YouTube.
	Within hours of the video's upload, it was well on its way to going viral.
	However, its success was short-lived.
	Shortly after InfoWars began hosting the video, the following Tuesday morning, it was suddenly removed from YouTube due to a copyright claim by Lenny Posner.
	I read all that correctly?
	Yes.
	Alright, so while you may have a problem with my terminology of InfoWars hosting the video, InfoWars doesn't have a problem with that terminology, correct?
	Um...
	So, this article was written by Mr. Salazar.
	Okay.
	So... Mr. Salazar, that's the terminology that he used.
	I don't know that the company would necessarily endorse that terminology, but...
	Well, it published this, didn't it?
	It did publish this, yes.
	Okay.
	So I want to read a little more of this article, okay?
	Sure.
	And I want, right here, we have some areas.
	And you see how there's some highlighted areas?
	Yes.
	Okay.
	What it basically is, is that any time that there's a highlighted area on a sentence, I would like you to stop at the end of the highlight because I want to ask you a question about it.
	But do you think you could read us what we see here in the article right here?
	Just the highlighted portions?
	No, no.
	Actually, go through the whole part, but just at the end of the highlighted portions, if you can stop because I'm going to want to ask you a question.
	Posner is reportedly the parent of one of the children supposedly killed at Sandy Hook and is an outspoken critic of people who claim the shooting to be a stage event.
	It is no... Oh, you want me to stop?
	Yeah, so that first sentence there where it says that Posner is reportedly a parent of a child who supposedly died at Sandy Hook.
	Yes.
	The company now admits there's no reason to say that.
	He is a parent of a child who died at Sandy Hook.
	That's correct.
	Okay.
	Can you keep going through the article here?
	It is noted in the documentary that he is also the chairman and CEO of Traxware, a company that specializes in the removal of internet slander, internet defamation, mugshots, defamations of character, and online public records.
	This guy's, quote, this guy's company would come in handy to any Sandy Hook hoax perpetrators with prior convictions, YouTube researcher, Mr. Stosh 314 states in the film, quote, he would ultimately remove any negative associations from the internet.
	Could he be hanging around online bloggers and researchers for the purpose of protecting the Sandy Hook parents?
	End quote.
	Okay.
	And in that section right there, where it's talking about Mr. Posner's business, right?
	And how he could be helping Sandy Hook hoax perpetrators, right?
	The company admits that that was reckless speculation it was publishing, correct?
	Is publishing this person's reckless speculation.
	Does the company agree with that or not?
	No, that looks like that person's opinion.
	Correct.
	And the company was publishing, right?
	That.
	He's quoting someone else's opinion.
	Correct.
	That person's opinion that he is quoting and that the company decided to publish and give to its viewers, the company now admits that that opinion was reckless speculation.
	Does it admit that or not?
	No.
	Okay.
	The company does not believe that was reckless speculation.
	No.
	Can you read the last part of it for me?
	This last paragraph first?
	Sure.
	After InfoWars swapped out the video for an alternate copy, the video was again pulled, this time, quote, due to a copyright claim by Honor Network.
	There's a misspelling in there.
	End quote.
	A group which seeks, quote, to bring awareness to hoaxer activity and to criminally and or civilly prosecute those who wittingly and publicly defame, harass, and emotionally abuse the victim of high-profile tragedies and or their family members.
	End quote.
	Honor Network is apparently also linked to Posner.
	Okay, and then you see where it says also linked to Posner, there's an internet link there, right?
	Apparently also looks like a link.
	The words apparently and also.
	I think, actually, if you just do this.
	Oh, okay, the whole thing looks like a link.
	Yeah, okay.
	So there's a link there directing their audience that says Honor is apparently linked to Posner.
	I don't know where that link leads though.
	I don't either.
	I was going to know.
	That's why I wanted to ask you.
	What information did the company have about Mr. Posner being linked to Honor?
	I don't know where that links to, so I don't know how to answer that.
	Okay, so when you saw this article and saw that the company was disclosing information, not merely about Mr. Posner's personal business, but about the non-profit charity front that he started to keep his name out of things, when you saw that they were disclosing that, did you follow up on this in any way to figure out what was going on?
	I don't know that that links to personal information about Mr. Posner.
	So I can't answer that.
	I wish you could.
	I wish I could do but unfortunately I can't.
	All right we'll move on to something else.
	Thank you.
	Now you're into the hunt.
	How does the company today feel about the fact that it was disclosing this kind of information about a Sandy Hook parent to the public, to millions of people?
	How does it feel about that?
	I think that Mr. Posner is an activist in many ways.
	I think that his company is engaged in political speech, and I think his company is a public company that could be commented on publicly.
	What politics?
	What do you mean politically?
	What's the ideology of Mr. Posner?
	Of honor?
	Sure.
	The company's position is that he's engaged in anti-First Amendment activity.
	Thank you.
	Now, were there any communications between Mr. Posner and the company?
	I am aware that Mr. Posner had reached out to the company and was responded to by someone who works with Mr. Jones.
	Wait, okay, so when did that happen?
	Unfortunately I don't recall the year but I do recall that Mr. Posner wrote an email basically expressing that he was at one time a fan of the show, that he was upset as to the coverage of Infowars about the tragedy and that he wanted to speak to Mr. Jones directly.
	I think one of his assistants responded directly to him saying You know, Mr. Jones is really sorry for your loss.
	Will you be able to meet, talk to him at a specific time?
	Mr. Posner responded saying, I don't want to go on the air.
	And the response to that was, no, Mr. Jones is available at this time.
	And I don't know that that conversation ever happened, but there was a discussion about trying to get the two of them to connect on the phone.
	Wow, okay.
	I haven't seen that.
	So I know about a 2013 email, right, that I thought you were talking about, which is Mr. Posner writing in and complaining, and then Mr. Watson replying to him saying, Sir, we haven't done the whole actors thing.
	I'm aware of that too.
	And so then you think there's another... There is another one.
	There's trying to set up a phone conference between Mr. Posner and Mr. Jones?
	Yes.
	Okay.
	It was in the production that I read.
	Okay.
	And then do you think that that, that was a series of communications there off that complaint where Mr. Posner said he was a fan and isn't anymore.
	Do you think that's the only communications the company's had with him?
	Uh, I'm sure there are others.
	That's the one that I recall specifically.
	Alright, well I'm trying to find out if there are others.
	Okay, that's the only email I recall.
	I don't think that they ever touched base on the phone, but there was a discussion back and forth about trying to schedule one.
	Alright, years later, are there any other communications with Mr. Posner?
	I don't think so.
	Okay, what did you do to find that out?
	I reviewed the material that we already discussed.
	I spoke to Mr. Jones about it.
	Mr. Jones wasn't aware of any other direct communication that he had with Mr. Posner.
	I talked to the other people that we already spoke about.
	So if the company in this case has produced emails between Mr. Posner and Rob Due a couple years later in 2015, that's not something you've seen?
	I'm sorry.
	Let me pull that back.
	If the company has produced documents from 2015, years later, of Mr. Du and Mr. Posner corresponding, you wouldn't be prepared to talk to me about those today.
	I'm just trying to recall if I had seen emails like that.
	I don't recall.
	If you have copies of them, I'm happy to look at them.
	I don't recall, as I sit here right now.
	Okay.
	Mr. Posner started all of this by privately complaining to Infoworks, right?
	He did.
	He was polite about it, wasn't he?
	I believe so.
	Okay.
	And then he complained again this time to YouTube in 2014 regarding this documentary we're talking about right here, right?
	The Sandy Hook viral documentary that's talked about in that article, right?
	I know he complained to YouTube.
	He made a copyright claim.
	Okay.
	And then that video came down, right?
	I believe so, yes.
	Okay.
	And you understand that the following month, InfoWars wrote an article and made a video about Noah Posner.
	Do you know about that?
	Which video are you talking about?
	Yeah, so if I ask you about the whole thing about Noah dying in Pakistan, do you know what I'm talking about?
	Yes.
	Okay.
	So, that was called Sandy Hook Victim Dies Again in Pakistan, right?
	I believe again is in parentheses.
	Sure.
	Yes.
	Okay.
	Well, let me do it this way, just so we can kind of like, just like, Sandy Hook Victim Dies, and then there's a parentheses, again, in Pakistan.
	Yes.
	Right, okay.
	The company can understand why that headlining is very upsetting, right?
	To Mr. Posner?
	Sure.
	I can understand why that's upsetting to Mr. Posner.
	You can understand why it's upsetting to me, right?
	I can understand why it's upsetting.
	You can understand why it's upsetting to pretty much any decent person, right?
	I understand why it is upsetting.
	Okay.
	And the company understood that.
	I understand that.
	The company understands that now as we're sitting here, yes.
	Okay, let's do that.
	That's great.
	I appreciate that the company understands that sitting here now.
	On January 2, 2015, when it published it, the company knew that that would be upsetting.
	So, to understand just how that article came to be sourced and came to be, we could talk a little bit, I don't know if this is the time you want to do that, talk a little bit about how the articles in general come to be.
	But that article, I believe, was written by Mr. Salazar, and as I said, there are certain people in the company that are more interested in this topic, that time were interested in this topic more than others.
	Mr. Salazar, I think, has made it clear that he was one of the people that were more interested than others.
	The company's position was, you know, within some loose parameters, write what you want to write, you know, so they would go and source things from the current day's news.
	On this particular occasion, Mr. Salazar viewed some footage of a – I want to say it was a protest in Pakistan following a school shooting there, and it was a BBC News correspondent article with video that he linked to his article.
	And that has since been edited to take out the section that he was relying on regarding that particular claim, but more specifically it was the reporter from BBC walking past a wall of pictures, I think you know what I'm talking about, the wall of pictures, and
	I don't know if we want to call him by his first name, but essentially Noah's photo was on that wall.
	And that correspondent represented that these were the victims of that particular tragedy.
	He also sourced that material from some Facebook posts that were on the school's Facebook page.
	And from there, wrote that article.
	So as far as the question goes, the title The reason why, again, is in parentheses, is because of the confusion, or perhaps mistake, that these other news articles, these other news sources were making as the representation of that particular photograph being in Pakistan at that time.
	I think that's why, when I said it's in parentheses, I think that's why it's in parentheses.
	Okay, objection non-responsive.
	Do you know what question you were just answering?
	You asked me about the title and whether or not the company knew at the time the title would be upsetting.
	Bingo.
	Okay.
	So can we get back to that?
	No, the company didn't know it would be upsetting and I just explained the reason why because the reason it was in parentheses was to make sure that it was understood the purpose and the content and the position the article was making at the time.
	Okay.
	Mr. Posner had previously Made the company aware that these sorts of coverage was upsetting to him, right?
	Yes.
	Okay.
	A month later, so hold on, and I want to make sure I understand this.
	Kind of the position is here on this, Mr. Salazar was really interested in Sandy Hook, basically able to publish whatever he want.
	So when we see a Sandy Hook victim dies again in Pakistan, that's not Mr. Jones.
	That's Mr. Salazar, right?
	Yes.
	Okay.
	Mr. Jones doesn't necessarily endorse that, is what you're saying?
	That's correct.
	Okay.
	Great.
	And you remember about a month after that happened, that January video about Sandy Hook victim dies again in Pakistan, then, and a month later, Mr. Jones made a video heavily about Mr. Posner after Mr. Posner got that video removed.
	You remember that?
	Uh, if you could let me know which video we're talking about?
	Yeah, that's February 12, 2015.
	It doesn't have a title.
	I was actually hoping maybe you could tell me.
	Does it have a, um, well the company uses a bunch of, um, a combination of letters and numbers.
	If you could tell me the... No, I don't know the production.
	Okay, what's the date?
	Uh, February 12th, 2015.
	Just to help you, it's the video we've been talking about with the PO Box address.
	Oh, you know what?
	I think I said early on in our conversation that I didn't see that video on the Dropbox.
	I saw the article, but I didn't see the video on the Dropbox.
	I think we talked about that early on.
	Wait, what article?
	The article that talks about the U-Haul and the map.
	I'm pretty sure there was an article about it.
	You have an article about that?
	I thought there was an article.
	I thought I saw an article about it.
	I thought we talked about it.
	Okay.
	I don't think I saw that video.
	That goes along with the February 12, 2015 show?
	February 4th, you said?
	12th.
	12th.
	Yeah, I don't have that as been reviewed by me, the video.
	That's the video I couldn't see.
	Okay, so when you found out that you didn't have any documents about that video, I mean, I'm sorry, when you found out that you didn't have that video to review, did you go look for any documents about that video?
	I did, so that's why I said I'm pretty sure I saw an article on it.
	Okay.
	No, I meant about the video, not maybe an article.
	Oh, no.
	So I did try to reach out to... We have somebody that is trying to help us find documents.
	So there's, as you're aware, there's various litigation in multiple states, and various things have been produced, and I'm not really sure where they were produced.
	So I did try to... We have, or had at one time, a liaison trying to help me out with that.
	I did ask him to try to find it for me, and he wasn't able to locate it.
	Okay.
	I need to note for the record that we have actually just been joined by my co-counsel, William Ogden, also representing the plaintiffs.
	I'm just praying.
	Pauls, I've handed you what I've marked as Exhibit 5.
	I take it you've never seen this document before, right?
	May I just have a minute?
	Mm-hmm.
	I guess I should figure that out.
	Oh, it's double sided.
	OK.
	No, specifically this document, no, but I am aware that the company does produce daily logs of the show.
	Okay, and you didn't look at them?
	Not all of them.
	We do three three-hour segments, and they're all broken down into these individual segments, which are then produced into video clips.
	So that would have been hundreds of videos or hundreds of logs so to speak.
	There's about 20 individual videos identified in the Plaintiff's Petition?
	20 different dates?
	Dates, right.
	So there's about 43 or 45 videos that I watched.
	That's not all in the Plaintiff's Petition though, right?
	No, but the entire universe of Sandy Hook videos is probably about 43 videos or 45 videos, something like that.
	Well, we're going to need to talk about what that number is.
	We'll talk about that later.
	Sure.
	But when you discovered that you did not have access to the February 12, 2015 video, you did not go get the daily show log for the February 12, 2015 video, correct?
	No, I didn't.
	I don't think I reviewed it.
	So you see how it has up here in giant red letters, do not upload any video or show to YouTube?
	Yes.
	You can't tell me anything about that, right?
	I don't know why that's there.
	Yeah, I wanted to ask you about that, and that's not something you can tell me.
	I don't know, unfortunately.
	I'm sorry.
	And so you wouldn't know who put that there?
	I don't know.
	I think that generally speaking, just based on my conversations with Daria-- Well, hold on.
	Can I stop you before you answer that question?
	I just know who produces these documents in general.
	Right, but I want to caution you not to make guesses or inferences based on-- No, I don't know.
	I want you to talk about what you know.
	I don't know who produced the specific video but based on my conversations with Daria the assistant producers started Producing these these types of logs to make it easier to try to find video clips Later on because she she said it's like finding a needle in a haystack It was ultimately, you know, they were saved on a drive, but there was no real way to search for those clips.
	And so, you know, if one of the hosts said, hey, I want to find this clip, nobody would really know on what day.
	So they started producing these logs to make that easier to see what people were talking about on a specific day.
	But as far as which producer produced this, which assistant associate producer produced this, I don't know.
	So you don't have any idea of what employees played what role in this show?
	I know a producer would have produced this, an associate producer would have produced this.
	I'm sure a producer would have been involved.
	Right, right.
	Okay, but no, my question is you don't know what employees played any particular roles in the creation of this video.
	As far as this video, so the video, as just looking at the document, I could tell you who played a role in producing, in the production of the video.
	So Alex Jones hosted it, and Rob Dew and David Knight were also co-hosting it.
	Right, I can read the document.
	Right, and then it's also citing to a Don Salazar's article.
	Sure.
	But I mean, in terms of who produced this, we don't know.
	Produce the document or the show?
	The show.
	Well, you mean the employees that were working on that particular day?
	Yeah, I want to know who the producer is.
	You don't know, do you?
	Um, I could tell you who was working on this particular day as a producer.
	Is that, like, you have a document of that?
	I think you requested for us to try to find out who was working on each particular day.
	I know what I requested.
	I'm asking do you have a document of it?
	Right.
	I think that we've made that determination.
	I'm not asking if you made a determination.
	I'm asking do you have a document of that?
	I can, if I could consult with counsel, because I think that... Oh, hold on.
	I don't want you to consult with counsel about whether you can answer that question.
	I just don't have the list on me right now, but I believe that we have a list of who was working on this show on that particular day.
	Alright, that's the same thing Ms.
	Kharpova told me.
	Exact same thing.
	Okay.
	And then she didn't have a list to give me.
	Are you telling me right now?
	I think Attorney Blatt's going in her bag.
	If you want to mark it.
	I do.
	Okay.
	I'm going to mark both pages.
	We'll put them together.
	Okay.
	I'm going to call this six.
	I'm going to hand this to you to just, first of all, if you can verify it to me.
	This is the list that you created.
	First of all, what is this?
	So, in response to your request as to who had been working on the days that various videos in the petition had been produced, the company went back into its records and searched, essentially searched its internal records to determine who was working on those particular days.
	Okay.
	Who prepared this list?
	You know what, I'm not 100% sure who prepared it.
	Did you get it from council?
	I got it from council, so I don't know who prepared it.
	Okay.
	Can you hand me it back real quick because I don't have a copy of it.
	I need to kind of look at it.
	And I'll hand it back to you for this question.
	One, two, three.
	OK, what I'm seeing here is lists of names for 10 different videos.
	One, two.
	1, 2, 3, 4, 5, 6, 7, 8, 9.
	That's what it looks like, yes.
	Okay.
	Alright, so those are the days you can tell me when people were working?
	Yes.
	Okay.
	So if there were videos that didn't happen on that day, you can't tell me who was working those days?
	No.
	I know there are other videos aside from these particular videos, because like we said, there are 40-something videos, maybe 45 videos.
	Well, there's certainly some in plaintiff's petition, right?
	Yes.
	And then part of that was you were to get up to speed on the employees who were involved in those videos, right?
	I know that we are talking currently about this February 2015 video.
	I'm just asking you... That's on here.
	Yeah, you were asked to get up to speed on who was involved in the videos in Plaintiff's Petition, right?
	Right.
	I don't know these dates offhand.
	I don't know if these are the dates of those particular videos.
	Well, one thing we know for certain is it's not all of the videos in Plaintiff's Petition, is it?
	I don't know.
	I didn't produce this, so I don't know the answer to that.
	Alright, can I see that again?
	Sure.
	OK, so when you got these documents here of who was working, somebody gave these to you.
	Yep.
	Did you inquire if these are all the videos in the plaintiff's petition?
	No.
	I don't know who produced that.
	Okay.
	What do the highlights mean?
	I don't know.
	I did not highlight them.
	Okay.
	So you didn't ask what these highlights mean?
	Right?
	No.
	Okay.
	Well, I noticed there's one day for, so I got like one day here.
	We got September 25th, 2014, and I'm seeing about a dozen people on here.
	Um, and then I see like 12, 27, 2014.
	There's only one name.
	Do you know what that is about?
	May I see it?
	Yeah, sure.
	Was he the only guy working that day, or what's going on there?
	I don't understand why there's just one name.
	That means to me that based on our records, that's all we know about who was working that day.
	So, you know, part of the problem that I was indicating earlier, and I know that it may not make a whole lot of sense because you look at a media corporation like, you know, CNN, and they have very, very intricate records, and they have very intricate procedures and policies.
	I've spent a lot of time in the last week with this company and it's not that way.
	So there are not a lot of records.
	There aren't a lot of communication between departments.
	So, you know, generally speaking, in the event that there were people working like in production in one department, Sometimes we just wouldn't know in another department.
	In all likelihood, what happened with these records was that our HR person went through and tried to figure out who was there that day.
	That doesn't mean she went to the production department and personally questioned everybody, and I certainly didn't do that.
	Were you here on this day, this day, this day, this day?
	You know what I'm saying?
	I do.
	I believe Melinda did that, to the best of her information, tried to get these lists, but like I said, Because they don't talk to each other, the different departments, and there's no real records as to who's checking in and checking out on a various day, it's hard to give a definitive answer as to who was there that day.
	What I'm trying to get at, though, is I understand you're telling me a lot of stuff about why things are hard, all this sort of stuff.
	What I'm trying to get at is some of these entries have a ton of people's names, like a dozen names.
	Right.
	And some of them only have like one or two.
	And from what I understand you're saying is you were making certain inferences about why that's true.
	I think the reason... You don't know why that's true, you're just making inferences, right?
	Well yes, I think the reason why that is is because that was the only information Melinda was able to source for those particular days.
	Did you talk to her about this list?
	I didn't talk to her about this list specifically, but I've spoken to her about, you know, why there aren't many documents.
	Okay, can I see that real quick?
	OK.
	OK.
	So do you know what Nico Acosta did for this video?
	For this 2015 video?
	Um, Nico Acosta did the programming for Alex Jones, the Alex Jones show.
	Okay.
	So his job was to coordinate guests such that there were guests available and to, you know, do the basic scheduling for that day.
	So that's what his role would have been.
	I noticed that David Knight and Travis Knight are both on this list on this video.
	Um, David Knight.
	Yes, I think David Knight per exhibit five was one of the hosts.
	That's one of the people you didn't talk to, right?
	I did not talk to David, no.
	He's not a current employee.
	I understand he's not a current employee.
	I get that.
	Josh Owens, he's on this list, right?
	Yes.
	I'm just going to show you Josh Owens is on this list.
	Yes.
	Do you speak to Mr. Owens?
	No.
	Mikael Phelan's on this list, right?
	Sure.
	I don't have a copy of it in front of me.
	I'm just reading it.
	What did Mr. Thalen do with this video?
	I don't know.
	Okay, we're not getting anywhere with that.
	I can give that a court order.
	I just want to clarify, just because they're on this list doesn't mean they had anything to do with this video.
	In fact, somebody would have to go check with them to figure out if they did have something to do with that video, right?
	Right.
	This is only the list of who was working that particular day.
	That doesn't mean that they sourced this, that they had anything to do with this particular video.
	I understand that completely.
	Sure.
	Let's, um, can you go back to this document here that is... Sure.
	Exhibit 5.
	Exhibit 5.
	Okay, so we talked about the first page really quick.
	I talked about this red part here.
	Yes.
	But now I want to go to page two.
	So that's actually going to be on the reverse side.
	Sure.
	Okay.
	And we'll see here it talks about hour number one, right?
	Yes.
	And then you see segment number one, right?
	Yes.
	And then it says right there, mystery, Sandy Hook victim dies, parentheses, again, close parentheses, in Pakistan.
	Yes.
	Right?
	Okay.
	So this was a show Mr. Jones was doing, right?
	He was the host of the show, yes.
	So Mr. Jones kept saying that Noah died again in Pakistan even though the company knew Mr. Posner was distressed by it, right?
	I don't know that he said Noah died in Pakistan.
	I think what he was saying was here is an article that we wrote and here's a cut to the BBC footage and Noah's photo is in that footage.
	Well, what I want to get to is, we had talked earlier about how that article was just Mr. Salazar, and that's not necessarily Mr. Jones endorsing this or anything, but here's Mr. Jones literally reading that same headline on his show, right?
	He's reading a headline that was reported by somebody else, yes.
	Well, no, I mean, we understand Mr. Salazar doesn't do, he doesn't report or publish anything.
	Free Speech Systems publishes things, right?
	Well, he is a writer for Free Speech, so yes, Free Speech publishes it.
	I'm just trying to, is there any reason why the company's trying to disclaim responsibility for what Mr. Salazar wrote?
	No, he wrote it.
	Right, and the company published it.
	And the company published it.
	And then Mr. Jones came on again, right?
	Right?
	Right? - What do you mean, he came on the show?
	Right, Mr. Jones came on the show and published that headline again.
	He published the headline, yes.
	Sure.
	So Mr. Jones did that even though he knew it would cause Mr. Posner distress.
	I don't know that he knew that it would cause Mr. Posner distress.
	Well, first of all, we know that the company sitting here now understands that that headline would have caused Mr. Posner distress.
	Right.
	But Mr. Jones didn't understand that?
	I don't know if Mr. Jones personally had any involvement in those emails that Mr. ... because Mr. Jones doesn't have an email address.
	I'm sure you're aware of that.
	Yes, he does.
	Well, he doesn't use email.
	Let's put it that way.
	Okay.
	I mean, again, Miss, I'm very concerned that you would sit here in testimony under oath and tell me Mr. Jones doesn't have an email address because he absolutely does.
	He does not use his email.
	Okay, so let's try to say that instead of the thing that wasn't true.
	Sure.
	So, he doesn't use email.
	The emails that we were referring to earlier on about Mr. Posner communicating his displeasure with the coverage were not responded to by Mr. Jones.
	They were responded to by other people.
	I don't know what Mr. Jones knew or didn't know about Mr. Posner's communication of displeasure at this point in time.
	Because you didn't read his deposition right where he talked about it, right?
	But assuming that, I will also say that this is not altogether uncommon where you source another article and publish the article, I don't know that necessarily this is an adoption by Mr. Jones of what the content of the article is.
	No, you, okay.
	Actually, I was about to say, well, you know it is because you watched the video, but you didn't watch the video.
	No, that was the one, that was the video I, uh, well, no, no, this video?
	Let me, I'm sorry.
	Yes, I didn't watch this video.
	Okay, because Mr. Jones says in this video that either the Pakistan thing is fake or the Sandy Hook thing is fake.
	One of these has to be fake.
	Do you know he said that?
	I don't know.
	I didn't watch that video.
	Okay, well.
	Alright.
	You testified that Mr. Jones didn't have any involvement or have any knowledge of the communications of Mr. Posner?
	I said I didn't know.
	Did you ask him?
	I'm trying to remember my conversation with Mr. Jones.
	I don't think we talked about that.
	Okay, so in terms of what knowledge Mr. Jones has about Mr. Posner and what he's told the company, you didn't talk to Mr. Jones about that?
	No, but as you said, he's been deposed, so... Sure, and one of the interesting things about that is, do you think there's any testimony in there about him?
	In these communications?
	About?
	Mr. Jones not only being aware, but being involved in these communications.
	Oh, I don't know.
	Okay.
	Yeah, can I understand which depositions Mr. Jones you read?
	I know he's done a few, so... He's done three.
	Right, so I read the most recent one, which was in December, and I read the March one, but I don't think I read the March 2019 one.
	Okay.
	But I don't think I read the third one.
	one.
	OK.
	If you look at segment two, down at the bottom, it says it again, right?
	Mystery Sandy Hook victim dies again in Pakistan.
	Yes, I see that.
	Okay.
	And there's some Sandy Hook commentary.
	Do you see where it says that?
	Oh, right above that?
	Yeah.
	Yes.
	You're not able to talk to me about what that commentary was?
	No.
	Okay.
	It says he showed a copyright claim document on camera.
	Do you know what that refers to?
	Um, I think it probably refers to Mr. Posner's attempts to get videos removed.
	Are you, do you know that?
	Or is that just kind of something you're thinking might be true right now?
	I think that that's what's true.
	But have you done anything to figure that out?
	No.
	So that document, and actually, can you go ahead and flip the page again for me now?
	On the first page?
	Yeah, now we're going, no, now we're going to the one that says 924.
	So let's keep going.
	It'd be the next page.
	Do you see the base number 924?
	Yes.
	Okay.
	And on this page on segment four, it also talks about showed copyright claim document on camera?
	Yes.
	Okay.
	If this is the complaint or some sort of complaint from Mr. Posner, you haven't done anything to locate it or figure out what it is?
	No, but what this means to me is that during this segment, he showed the actual document.
	On his document camera?
	On his document camera.
	On his desk camera.
	Right.
	Exactly.
	He did.
	Let's go to the next page.
	See the page and it's base number 925?
	Mm-hmm.
	Okay.
	Do you see segment 4?
	Yes.
	It says Honor Network physical address discrepancies slash donations.
	Do you see where it says that?
	Yes.
	What did the company mean by physical address discrepancies and donations?
	Um, I think... First of all, let me ask you, let me go back.
	Sure.
	Have you undertaken any steps to understand what the company, before coming to this room, what the company meant by Honor Network physical address discrepancies and donations?
	Yes, so when I spoke to Rob Due, I did speak to Rob Due about the claims that were made in connection with Mr. Posner and his, and the video, I believe it's this video, about the address.
	And I think this was when we had the discussion about his U-Haul address.
	And I think at the time the problem was that they didn't understand that the U-Haul has P.O.
	boxes.
	And so they were wondering why the address, the official address, would be at a U-Haul.
	Really?
	And that's what they're talking about with the physical discrepancy.
	That's the discrepancy?
	I think that's the discrepancy.
	When I talked to Rob Dew, that was his understanding.
	Well, you know he identified a UPS store.
	You remember him identifying a UPS store?
	I thought it was a U-Haul store.
	He did that too.
	Do you know anything about the UPS store?
	No, I don't.
	Obviously it's not.
	Even somebody like Rob Do knows there's P.O.
	boxes at a UPS store.
	I can't testify as to what Rob Do knows.
	You certainly didn't ask him, did you?
	I didn't ask him, no.
	How did they know that was where Lenny was picking up his mail?
	How did they know that was his address?
	Um, you mean where did they get that address from?
	Sure.
	Well, when I asked Rob, I did ask Rob Du that question and his information was that when he did a search on the Honor Network, that address came up as a mailing address.
	Okay, so he did some research into the issue.
	I think he looked for the Honor Network, because the Honor Network was being, was engaged in getting information taken off of the YouTube page, so it led him to looking into That particular organization.
	Those are those anti-First Amendment activities you referenced earlier, right?
	That's correct.
	Okay.
	When it says there next, the Honor Network group going after the Second Amendment, what does the company mean by that?
	I think that the opinion was that the Honor Network in addition to this First Amendment activity is involved in Second Amendment activity.
	What do you mean?
	Okay, first of all, did you talk to Rob Dew about that?
	Is that something you talked to him about?
	Rob Dew... I don't know if it was in my conversation with Rob Dew or with Mr. Jones, but I think that the general understanding is that the Honor Network is engaged in that type of political speech for First Amendment speech and Second Amendment.
	Second Amendment.
	Second Amendment's about guns, right?
	Yes.
	Okay.
	And so you're testifying here is the company's understanding.
	Is that the Honor Network engages in Second Amendment activities?
	What activities is it related to the Second Amendment?
	So this goes back to, this circles back to the conversation we were having about Ms.
	Lewis as well, about individual people's opinions about the things that companies are engaged in or the activities that they're engaged in.
	So it's not, for example, it's not the company's position that Ms.
	Lewis is engaged in anti-gun control stuff.
	Individual people in the company may interpret her associations as such, right?
	And I think that that is what is being discussed here.
	You know, Rob Due and David Knight are on the show, and Rob Due, you know, as I said, Mr. Due was one of those people that were more interested in Sandy Hook than others at the company, and I think it's Mr. Due's opinion that the Honors Network was engaged in Second Amendment activity.
	What facts is that based off of?
	Do you have any idea?
	I can't testify to Rob Due's opinions.
	I don't know, in all honesty.
	Yeah, because I'm trying to figure out how this got on air.
	How it got on air that InfoWars told its audience that Lenny Posner was coming after the Second Amendment.
	I want to know how that happened.
	That's an opinion statement.
	It's an opinion statement based on Rob Due's opinion and possibly David Knight's opinion.
	Possibly, but we don't know.
	Possibly, I don't know, but it's an opinion statement.
	Sure.
	And so what I asked you to be prepared for was the company's knowledge of the plaintiffs.
	And I'm assuming that any opinions the company has about the plaintiffs are informed by what knowledge it has about the plaintiffs.
	Certainly the company is not going to make opinions based on no knowledge.
	You understand what I'm saying?
	Well, the company's opinions and the individual host's opinions are two different things.
	Absolutely.
	And that's why I've also asked you about sourcing and research for the plaintiff's petition.
	So that's why I want to know Rob Due's opinion and I want to know the company's opinion.
	And I've testified that I believe Rob Due's opinion is that they are engaged in this type of activity.
	And I'm asking you, what knowledge was ever researched or does the company possess about Lenny Posner that would support that opinion?
	I don't know what Rob Dew based his opinion on.
	Like I said, I didn't watch this particular video.
	And in terms of the sourcing or research that went into making this statement, you don't know that either?
	No, because I didn't watch the video.
	And let's make it clear, you didn't just not watch the video, you didn't review any documents about the video, right?
	Um, aside from this, what you've produced to me right here, um, and, oh, well, actually, no, that's not, that's not 100% accurate, because I did review this Sandy Hook victim dies again in Pakistan article.
	But aside from those things, I'm not aware of any other documents that exist.
	Okay.
	Can you summarize any other information the company has about Mr. Posner?
	Has, as we sit here today.
	I have seen a background check that was produced in the production.
	Okay.
	Tell me about that.
	Where did that come from?
	You know, interestingly enough, I cannot determine where that came from.
	That's less interesting than you might think.
	Okay.
	No, so when you say you can't determine where it came from, let me back up because I may have started at a bad place.
	Sure.
	When you understood that that background report exists, what did you do to find out where it came from?
	So, I have spoken to Mr. Jones.
	I've spoken to Mr. Due.
	I've tried to go through the production material and the emails to find out if it was produced in an email.
	I don't see it connected to an email.
	Mr. Jones is not aware of where it came from.
	Mr. Due is not aware of where it came from.
	I can speculate, but I don't want to do that because I don't honestly know where it came from.
	I do know it is amongst the materials in the production, but I can't testify as to when or how it came to be there.
	Well, somebody put it in there, right?
	I don't know how it came to be there.
	Well, I know that.
	I know you don't know that.
	But somebody put it in there, right?
	It had to have gotten there somehow.
	Yeah, exactly.
	So somebody had to have This year, because this is when it was produced.
	Wait.
	Oh, I don't know.
	I can't.
	You don't know when it was produced?
	I don't know when it was produced and I don't know when it came to the company.
	So I don't know if it was produced, if it came into our attention this year.
	I don't know.
	Okay.
	Attorney Block, can you give me another water, please?
	Thank you.
	So, I know you can't talk to me about what you talked to them about.
	Hold on, hold on, let me get the whole question out here.
	In fact, preface, we just talked about you talking to a couple people, Mr. Dew, Mr. Jones, about this background report.
	And I know you can't talk to me about the substance of conversations you've had with attorneys, but considering that attorneys were the ones who are the last person in the chain of custody who gave it to me, have you talked to attorneys about where this came from?
	You can't indicate whether you have spoken to attorneys, but not conversations you've had with them.
	I have spoken to attorneys about where it could have come from, yes.
	Okay.
	As not any descriptions of those discussions, but it's fair to say that after the conclusions of those discussions, you were not able to give me any information about where it came from.
	That's accurate.
	Okay.
	Okay.
	Oh,
	and if I may, I guess I should say there are two background checks that I saw in those productions relating to Mr. Posner.
	One is longer and one is shorter.
	I'm pretty sure, and I think I know where the shorter one came from.
	I believe that was produced in connection with a lawsuit that Mr. Halbig and Mr. Posner have.
	Okay.
	And somehow that came to be in our documents, whether Mr. Halbig emailed that to us or whatever.
	But I believe the allegation is that, at least Mr. Posner's allegation in connection with that lawsuit, That Mr. Halbig produced that background check.
	I believe it's 99 pages or 100 pages long.
	It's like a shorter background check.
	Sure.
	So I did see both of them, but the longer one, I am not sure.
	I can't testify as to where that came from.
	Okay.
	I know you don't know where you came from, but do you know who found it in the files?
	I don't know.
	Do you know where it resided in Infor's files?
	No, and that's the interesting part is I tried to determine if it came to us in an email or if it came to us in some other fashion and I can't find the origin.
	Okay.
	Okay.
	What do you mean?
	Got you, got you.
	Alright.
	So we had the first background report that I was talking about with Ms.
	Karpova, the big one, right?
	But I want to talk to you about the second one you've talked about, the shorter one.
	Sure.
	That one from Mr. Halbig, who saved that?
	How did that get saved?
	What do you mean, how did it get saved?
	First of all, where did it come from in Forrest Files?
	Do you know that?
	I believe it might have been in an email, but in all honesty, I'm not 100% sure.
	We did not produce it.
	So we didn't ask for it to be produced.
	I think it was sent to us.
	I'm just not sure how.
	How do you know it was sent to you?
	Because I think that it originated with Mr. Halbig.
	How do you know that?
	Because it was in with... So there are a bunch of emails, at least in our production, related to Mr. Halbig's litigation with Mr. Posner, which is not connected to this case.
	It appears that he And I don't know if you see that Mr. Halbig emails very numerous people in a lot of his emails.
	Sometimes.
	So it appears that he has sent to us a lot of the information concerning that litigation, and in the materials that are in our production, there were a bunch of litigation materials connected to that case.
	And I think it was in there.
	I also saw some email chains between Halbig and Mr. Posner about this particular background check.
	Okay, so when you say you think it came from the litigation, that's because it was in proximity, physical proximity in the production to documents that related to that litigation?
	Right.
	Alright, you understand with me though, you've gone through, I hope, enough InfoWars documents to know that there's not really much of a rhyme or reason to the order of those documents.
	I see that.
	Right, so there could be just random documents thrown into the middles of other places.
	So I'm wondering, why do you think that that's from the litigation if you've never run down the email?
	The reason is because some of those emails, communications between Mr. Halbig and Mr. Posner and Mr. Halbig and Mr. Posner's attorney relating to that litigation is specifically referencing that background check.
	Okay, but all you know is that something went on between Posner and Halbig.
	And so you assume that that document that you have must have come from that, right?
	There's nothing you've done to independently run down and read this document?
	I haven't independently verified it, no.
	And I don't see the actual email that it's connected to.
	Okay.
	This brings me to my next point.
	Is InfoWars new about the legal action between Mr. Posner and Mr. Halbig, right?
	Well, this goes back to issues relating to not opening Mr. Halbig's emails.
	So, I mean, as I sit here now, yes, I am aware of it because I've reviewed the production.
	But at the time, I mean, pursuant to my conversations with numerous employees, his emails were not being opened.
	There are, okay, let's, oof.
	First of all, there are other places the company could get information about that lawsuit other than Mr. Halvig, right?
	Sure, you can do a Google search on it.
	So let me ask you that.
	Has the company gotten information from anybody else about that lawsuit?
	No.
	Okay.
	Do you think that or do you know that?
	I'm trying to see, have you verified that?
	I don't see anything in the production that would have indicated that we did any independent research on that, but I didn't talk to anybody relating to that specific litigation.
	My information on that litigation just comes from the production.
	Okay.
	Well, let's look at something in there.
	Okay, you read, Ms. Colbert?
	Karpova's deposition, right?
	Yes.
	So you saw the discussion in that deposition about Mr. Halbig and Mr. Posner's lawsuit, right?
	Is this the one in Florida?
	Yeah, that lawsuit would have been in Florida.
	Okay.
	So you did know things about that from Ms.
	Karpova's deposition?
	Yes.
	So you know that the answers you just gave about people not giving in for any information to the company about those lawsuits, that's not right.
	That was discussed in Ms.
	Karpova's deposition, right?
	What are you referring to?
	I'll give it to you.
	Sure.
	Since we'll go through that again.
	Uh, what exhibit number are we on?
	Six.
	Let's go to seven.
	Okay, this is an exhibit that I assume you've read from Ms.
	Karpovas.
	Oh no, it would be six.
	I'm sorry.
	Because we are on five.
	Yep.
	Okay.
	I'm going to hand you exhibit six.
	We've got six already.
	Where's six?
	I marked it down on my sheet that you admitted in exhibit six.
	Oh, okay.
	I'm sorry.
	You're right.
	Okay.
	They were out of order.
	Okay.
	This is a document that was read verbatim in Ms.
	Karpova's deposition.
	Are you familiar with this document?
	Before you... What?
	Let me... Can I read it?
	You may.
	Okay.
	Okay, so this is a document that, contrary to your last answer, is somebody from outside the company giving the company information about Wolfgang Haber's legal action, right?
	That's what appears, and I did read this in connection with Ms.
	Karpova's deposition.
	I understand that.
	Doesn't really match your testimony, though, does it?
	I disagree.
	So, the company receives a lot of emails like this about, not just about Halbig, but various people that we either have calling in on the station, or various people that we're reporting on, or commentators, or whatever the case may be.
	This document is very common.
	This type of thing would be common, and when I asked Mr. Du about not only this document, but I believe there's one or two other comments from other people about Mr. Halbig's credentials, whether anything was done or conveyed to anybody else internally about it, and the answer is no.
	So I agree with you that this was forwarded to somebody, but I don't think that anybody would have necessarily followed up with it.
	Does that make sense?
	So Nico is a producer, right?
	Was he a producer?
	I think at that time.
	Right.
	So I think, well I think his more specific job description, even though there's no official job descriptions, was that he was the person who was coordinating the Alex Jones show.
	But yes, so I see that it was forwarded to Nico.
	No, actually it wasn't.
	It was sent from Nico.
	Oh yes, I'm sorry.
	From Nico to Rob.
	Yes, you're right.
	Okay, to Rob Dues, Nightly News Director.
	I don't know that that's his title, or was his title at the time.
	So this looks like it was sent to General Mailbox, Media Contacts at InfoWars.
	Right.
	And then it was being monitored and forwarded along to Rob.
	Whether Rob saw it or did anything with it, I don't know.
	We know Nico saw it.
	We know Nico did something with it.
	Nico saw it, right.
	And he did something with it.
	Aside from forwarding it to Rob?
	Well, that's something, isn't it?
	Well, it forwarded it to Rob.
	And then told him, here are some comments on Halbig's last interview.
	Right, Nico doesn't control the content of anything that's done on air, or never did.
	Okay.
	What I'm trying to get at, this is an internal editorial discussion about Mr. Halbig's appearance on the show.
	No.
	Can you tell me why you would take issue with that?
	Because I don't agree with the term editorial discussion.
	And I don't know whether there was an actual discussion.
	Okay, yeah, so let's go ahead and break that down first of all.
	He's making some comments here to Rob and directing him to see those comments.
	He's saying, hey, look, here's some comments from Albig's last interview, right?
	It's not telling him to look at it.
	It's just, here, some comments on Albig's last interview.
	It's not telling him to do anything with that information.
	You just said it's not, it's not telling him to look at it.
	Do you think that's a forthright answer?
	It says some comments on Halbig's last interview.
	It's not telling him whether to do anything with it or anything like that.
	I'm not saying about whether to do it.
	You know that he intended him to look at it, right?
	And I'm asking her, do you think that answer was reasonable?
	Yes, I do.
	Okay.
	What is an editorial discussion?
	Um, your definition of editorial discussion or mine?
	Absolutely not mine.
	No, yours, because you were the one who didn't object to these topics and then told the court you were going to go get prepared on them.
	I want to know what you say editorial discussion is.
	The company doesn't really adhere to the term editorial discussion, which is why I said I didn't agree with the term.
	So, I mean, in terms of editorial discussions as a big media company would term it, the company doesn't really engage in editorial discussions.
	So there's no daily group roundtable as to what we should cover and what we shouldn't cover or how we should cover it or how we shouldn't cover it.
	So that's why I don't agree with the term.
	So when it comes down to that topic, editorial discussions on Sandy Hook, I would take it that would have been the easiest topic for you to prepare for because there are none, right?
	We don't have, that's correct, we don't have editorial discussions.
	There's no such thing as an editorial discussion.
	That's what Ms.
	Ms. Karpova told me to, so I'm glad you all are on the same page there, that you are going to go with that.
	Before this lawsuit, okay, hold on here, hold on.
	In terms of the company, I believe what you testified for me or others is notwithstanding that email we just saw, which for instance you say there was no directions to do anything and nobody may have followed up on it or anything.
	The company did not take an interest, any sort of specialized interest, or publish any information about The lawsuit involving Mr. Halbig and Mr. Posner.
	Is that what you're saying?
	I haven't seen any information published about that particular lawsuit.
	Have you watched the March 4th, 2015 video with Mr. Halbig?
	That was in the plaintiff's petition.
	Let me see.
	What date is that?
	March?
	March 4th, 2015.
	And you don't know the ID number for that?
	No, I don't.
	I got a title for it, but I don't... Do you know what the title is?
	Uh, New Bombshell Information Inbound?
	Okay, yes.
	So, March 4th.
	I did, yes, I did review that.
	Alright, what's that bombshell information?
	You know what that is, right?
	So, just for reference, the company's ID number is underscore seven I B five W K U L B Y. Okay.
	So if I could just go to my notes regarding that.
	And at some point I ran out of tabs, so.
	I'll get you on the lunch. - I got a major word or something.
	Oh, awesome, dude.
	Thank you, man.
	Thank you.
	Okay.
	Sorry, I just want to go through my notes, and I ran out of tabs, so I apologize.
	It's all right.
	We'll take as long as we need.
	Sure.
	Yes.
	Yes.
	Okay.
	I found it.
	Thank you.
	Okay, so now we're talking about the March 4th, 2015 video with the new bombshell information inbound.
	Yes.
	You know what the bombshell information is, right?
	Yes.
	That's the subpoenas in that lawsuit with Mr. Posner and Mr. Halbig, right?
	Just let me review my notes for just one second.
	Sure.
	No, well-- I mean, I'm quoting you a question and answer, They asked... So, and here's the problem.
	There are subpoenas that were also issued in connection with the FOIA litigation, which is not the same thing as the Florida litigation.
	And so they...
	I thought, my understanding was, they were talking about subpoenas relating to the FOIA case.
	Maybe we'll pull up that video again.
	But I could be mistaken.
	Yeah, because, I mean, what happens in that video, I'll just tell you, is he says, asking what the bombshell information is, and he says about the subpoenas, and he's talking about Mr. Posner's lawsuit, and then he says, and also I got this other stuff going on up with the FOIA stuff too, so that's real interesting too.
	Right, we did discuss on many occasions, in multiple videos, the FOIA litigation.
	I think it was over like three hearing dates.
	Right, but what I'm asking is the bombshell information here is that he had served as subpoenas to Mr. Posner.
	So, I don't recall, in my notes, just based on my notes, I didn't write down the name and I don't know if the name of the case was ever specified, but like I said, there was a lot of litigation and that's what they were talking about was the subject of it was that subpoenas had been issued.
	Alright, but I'm not sure which case is my point.
	For these notes that you're taking about these things Mr. Halbig was talking about that Infowars was putting on the air, did you talk to Mr. Halbig about them?
	No, I have never spoken to Mr. Halbig.
	Did you try?
	No.
	Okay.
	Why was the company interested in the legal action between Posner and Halbig?
	Why?
	I think during this time period, it was in the coverage of – it was – this time period simultaneously was the time period that the FOIA hearings were happening or going to happen.
	And what usually we do as far as the – what is in the news cycle, we talk about what's in the news cycle.
	And so this would have been something that was in the news cycle.
	Mr. Posner's lawsuit was in the news cycle?
	I don't know.
	Alright, so I'm not asking you about the FOIA stuff.
	I get why they were interested in the FOIA stuff.
	The FOIA stuff was in the news cycle.
	Right, well, yeah, I mean, I'm not sure, when you say news cycle, what does that mean, that FOIA stuff was in the news cycle?
	So, um, when I say news cycle, that's a good question, so, um, news cycle means that, um, they source every day from a variety of different places, um, and so every day they will Who was in the news cycle?
	Who was covering FOIA besides InfoWars and Dan Badondi?
	You mean another news source?
	They'll source various news sites.
	They'll source social media as to what's trending on social media.
	And then they'll decide what is trending in the news cycle.
	Who was in the news cycle?
	Who was covering FOIA besides InfoWars and Dan Badandi?
	You mean another news source?
	Yeah, how did it get in the news cycle?
	I don't know which source are you referring to.
	Are you referring to like a news media source or one of the sources that they are sourcing for their information?
	No, I mean you say they were discussing it because, FOIA, because it was in the news cycle.
	Right, it was relevant at the time because it was something that they had seen in the news cycle.
	Where did they see it?
	I don't know, I'm not sure.
	Alright, because I... They don't mention it in the video.
	There's no reporters at that FOIA hearing besides Dan Badondi and Mr. Halbig's there.
	Along with his lawyer.
	I'm just trying to understand who's covering it.
	But that doesn't mean it's not in the news cycle.
	That doesn't mean that there's not internet chatter about it and that was a source of what they found to be trending.
	So just because there wasn't a newspaper article there doesn't mean that it wasn't trending on the internet or trending in social media or something that an interest was put forth in some way.
	Let me make sure.
	Do you have any idea sitting here today whether it was trending on social media or is that just a theoretical popularity?
	This particular article?
	No, I don't.
	All right.
	So when you say they were covering FOIA because it was trending in the news cycle, you have no idea if that's true.
	I'm saying that this is our general procedure as how things are covered.
	Right.
	But you don't understand how they covered FOIA, right?
	The FOIA hearings?
	Yeah.
	How it came into their purview?
	Uh-huh.
	I don't know.
	Right.
	And so if Mr. Halbig was communicating with Niko or anybody else about how to set this up and make this happen, you haven't seen any of that.
	Um, no I don't think that's accurate.
	So I do know that they were in communication about coordination of getting him onto the air.
	I do know that.
	Okay.
	Alright.
	But that would have only have happened if somebody had made a determination that this was relevant or worth talking about.
	And then also caveat to that is these are based on whoever is interested in it at that time, right?
	Well, we've gotten a lot of why they might be interested in the FOIA hearing.
	Yes.
	And we know that they sent a reporter up there, Halbig went up there.
	We know all that.
	What I'm interested in is why is the company interested in that Florida lawsuit between Mr. Posner and Mr. Halbig, which has nothing to do with the FOIA.
	Why is it interested in that?
	So at this point in time, Mr. Jones references specifically the copyright claims that were going on for YouTube.
	So it was interested in the actions that Mr. Posner was taking.
	He specifically references the copyright claims in that video.
	And so, that particular aspect of it, I think, would have made Mr. Jones continuing to be interested in it.
	Okay.
	So, we can agree that the company was, to some extent, following that lawsuit?
	Sure, to the extent that Mr. Halbig came on and talked about the subpoenas that were being issued.
	And to the extent that Niko was sending information to Rob Due about the lawsuit?
	I don't know that Rob had ever read it, but it is in the company's email, so yes.
	Right.
	And I mean, Nico certainly read it.
	We know that.
	It appears so.
	And was interested enough into it to turn it on over to the nightly news director, right?
	I don't know what his policies and practices are regarding forwarding information.
	I don't know if he just forwards everything regarding a particular guest.
	He knew that Rob would have been interested in that particular guest and so forwarded it.
	So I don't know what his policy is.
	And you didn't ask to find out what that policy was, right?
	I didn't ask him that, no.
	Now, before this lawsuit was filed, the company knew that Mr. Posner was being harassed by Mr. Halbig, right?
	I'm sorry, repeat the question?
	Yeah, before this lawsuit was filed, the company knew that Mr. Posner was being harassed by Mr. Halbig?
	I don't know that, no.
	Because I think we talked about earlier, I don't know at what point anybody became aware of what he was doing just because they stopped reading his emails.
	Because he's kind of crazy, right?
	I think that his email communications got more and more bizarre as time went on.
	I think that was the word that Nico used, was bizarre.
	Hold on.
	You've read a lot of Wolfgang Haube's emails, I'm taking it?
	I did, yes.
	So you've read emails from him like in 2014 and you've probably read emails from him up in 2017?
	Yes, I've read a lot of emails.
	Are you going to tell me that the emails he sent in 2014 are any less crazy than the emails he sent in 2017?
	I think they've gotten crazier.
	Okay.
	But we can both agree that there are plenty of emails he sent in 2014 that the company did in fact read and thanked him for that are crazy.
	Um, yes.
	Okay.
	And you understand InfoWars, of course...
	You may not know if they're even aware of them, but they produced emails where Mr. Posner was being harassed by Mr. Halbig.
	We have produced those types of emails, yes.
	Okay, but you sitting here today don't even know if the company even knew about them, right?
	At the time, no, I don't know.
	Okay.
	We know about them now, obviously.
	Sure.
	Sure.
	When'd you find out?
	Find out what?
	When the company found out that Mr. Halbig was harassing Mr. Posner.
	I don't know.
	Hmm.
	I'm not sure if they reviewed the emails as a result of this lawsuit going back.
	But as I said, he stopped coming onto the air.
	It was a discrete period of time, and then he wasn't on the air anymore.
	And then there weren't any real communications with him.
	Hmm.
	Hmm.
	All right.
	Does the company contend Mr. Posner is a gun regulation advocate?
	Hmm.
	Did we talk about this?
	We haven't talked about Mr. Posner yet.
	Mr. Posner individually or in his connection with the Honor Network?
	Or both?
	Let's do both, sure.
	I think that that would be an accurate description.
	I think the company does make a claim that he is a advocate in connection with the First Amendment and the Second Amendment.
	Okay.
	Does the company have any facts, any evidence, any knowledge whatsoever that Mr. Posner has ever said a word publicly, ever, about guns?
	I don't know the answer to that, but also there is, I mean, I know that they're divorced, but his ex-wife has made some comments and political activism regarding gun control.
	Come on, you know that's not relevant to my question.
	I know it's not.
	You have to know that.
	I mean, look, I know you're not an uneducated witness.
	You're a lawyer.
	You're an attorney.
	And when I sit here and I ask you, does the company have any evidence that Mr. Posner has ever said any information about guns, and you start speculating about what his ex-wife said?
	I'm not speculating.
	I've reviewed documents about that, but I understand your question.
	Let's put it this way.
	No, and I don't think you do, because what I'm asking you is you start giving me information speculating about what Mrs. Posner's statements at some point in her life reflect on what Mr. Posner may or may not be in terms of a gun regulation advocate.
	You know that's not relevant, right?
	I don't think that it's not relevant, but I think that in connection with Sandy Hook and the Second Amendment, Honor specifically, I don't have any information as I sit here today about Second Amendment.
	First Amendment, yes.
	Second Amendment, I don't have any information as I sit here today.
	Well, we just talked about, you had told me that the company had reason to say In the February 12, 2015 video that Honor was engaged in anti-Second Amendment activities.
	You remember us talking about that?
	That's not what I said.
	What I said was Mr. Due had an opinion about that that he aired and that was his opinion.
	Alright, so here's what I'm trying to get at.
	What facts inform that opinion?
	And as we talked about earlier, I told you I didn't know that.
	Okay, but the problem is that I believe that you testified that the company just now Does interpret it in a way that Mr. Posner is a Second Amendment advocate?
	Does it or doesn't it?
	I mean, that's what I'm trying to get at.
	Like I said, I can't point to any specific material as I sit here today regarding the gun control aspect of it.
	Okay.
	Has your husband ever said anything you don't agree with?
	My husband?
	- Yeah, objection, argument. - Do you think you should be held to have participated in everything that your husband said?
	No.
	Okay.
	You know what information the company has on Veronique De La Rosa?
	As far as Ms.
	De La Rosa goes, I am aware of The comments that she made in connection with gun control, in connection with her son's funeral, and the governor, I believe, attending the funeral.
	I believe there was also an interview, and aside from that, I don't think I'm aware of anything else.
	How did you, what did you do to find out what the company knows about Ms.
	De La Rosa?
	As we discussed earlier, I did do a search in the documents that were produced.
	I did talk to Mr. Jones about Ms.
	De La Rosa.
	So when you search, you just search for Veronique De La Rosa?
	Yes, or Posner, I don't know what name it would be under, because I wasn't sure when their divorce happened, so... I'm going to correct you once again, that's Posner.
	Oh, I'm sorry, Posner, yes.
	Right, their names are Posner.
	So I, like I said, I didn't know when their divorce happened, so I didn't know which name she was using.
	Okay, and did you find any documents?
	Aside from the documents that we listed.
	What do you mean the documents you listed?
	What does that mean?
	I mean the information in connection with her statements at the funeral and gun control.
	You saw some documents about that?
	I want to say I saw an article about it and then the interview.
	What are you talking about?
	She did an interview?
	Was that the interview with Anderson Cooper?
	She's done an interview with Anderson Cooper, yeah.
	That's the only interview that I've seen.
	You saw that?
	Yes.
	Okay, where'd you get that video?
	I believe that was a video that we had posted and was referenced numerous times by Mr. Jones on the show.
	No, no, I understand Mr. Jones many, many times has posted a video of the last five seconds of that interview with no sound where Mr. Anderson Cooper's head is turning and his nose disappears, right?
	Yes.
	But there's nothing, Miss Delarose isn't talking in those, right?
	No, no.
	It was mostly just shots of Anderson Cooper.
	Right.
	So how did you see the interview?
	I don't think I watched the entire interview.
	I think that's the entirety, my knowledge, is just what was posted about that interview.
	I don't understand, Ms.
	Paz.
	There's nothing about guns.
	I mean, Ms.
	Del Rosa isn't talking.
	So how do you understand what she said?
	I'm sorry, I don't understand the question.
	When Miss De La Rosa's featured on Infowars and all these videos of Anderson Cooper's nose disappearing, she's not talking.
	Right, but the topic of that conversation, it was related to Anderson Cooper's coverage of the shooting.
	Sure.
	Right.
	So how do you know she was talking about guns?
	I think that that was what was represented as the topic of that interview.
	Represented by who?
	By the media.
	I think that's the reason why it was covered.
	Look, I know you don't have any personal knowledge.
	You had nothing to do with this thing until two weeks ago.
	So when you come in here and tell me that Ms.
	De La Rosa was talking about guns in an interview, where did you get that?
	As I said, I think that was the topic of the conversation of the interview.
	I know you're saying that.
	Yes.
	Where did you get that piece of information?
	From the videos that I watched.
	All right, so what video does that come from?
	I don't understand.
	It comes from the videos that were produced by Infowars.
	Okay, so at what point did you see Ms.
	De La Rosa ever talking about guns?
	Did I personally watch the entirety of that video, that interview?
	That's not what I'm asking, actually, because now you're telling me that you got this information Not from the interview itself, which I believe you told me you watched, and then actually we just saw the... No, I watched the video of Anderson Cooper.
	That's what I watched.
	Right.
	So, now you're telling me that somehow you got it from the InfoWars videos that Miss De La Rosa was talking about guns.
	Where did you get that?
	No, what I said was that the reason that interview was covered was because the topic of it from Anderson Cooper's Who said that?
	Who said that the topic of Anderson Cooper's interview from that perspective is gone?
	That's what I understood that the topic was.
	I don't, I'm not asking you what you understood.
	I'm wondering how did you arrive at that understanding?
	And I testified my basis for my conclusion was watching the videos that Infowars posted.
	The InfoWars videos.
	Yes.
	Alright, so let's talk about those videos.
	Sure, which videos?
	What part of those videos, any of those videos, anything from any of those videos, who said or what part of it did you glean from that that interview was about guns?
	That was the reason why that was being covered.
	I don't, you've got to understand there's a disconnect here.
	I don't understand the disconnect.
	I 100% understand your testimony that you believe, based on some information you saw, that that topic of that interview was about guns.
	I understand that completely, 100%.
	That for some reason or another, an interview that you knew nothing about two weeks ago, you now believe has something to do with guns.
	And I'm trying to figure out what, and I know you say that because it came from the videos, and I'm trying to figure out what in those videos at any point led you to the conclusion that Ms.
	De La Rosa was talking about guns.
	And again, I'm going to testify, and I understand you don't understand my answer.
	I can't help you understand it other than to say that I watched the videos, that it appears that the purpose and reason why Mr. Jones wanted to cover it was because that interview was based on that topic.
	Again, is this something you're getting from something Mr. Jones said?
	Something Ms.
	De La Rosa said?
	Something another person said?
	I don't understand where this is coming from that you just say, I watched these videos and now I understand the purpose of that interview was about guns.
	Objection.
	Do you know what person that comes from?
	Do I know what person it comes from?
	Yeah, why you believe that.
	In other words, the information, who it came from, that that's why you believe that.
	Like I said, it would have been in the videos, so if the particular video was being hosted by Mr. Jones, he thought that that video was relevant for that purpose, so it probably came from Mr. Jones, just based on the videos.
	Okay, wait, how do you know what Mr. Jones thought?
	Is this something you got from an interview with him, or something you saw in the video?
	No, I'm just, like I said, the totality of my knowledge is based on the videos.
	Okay.
	And so that video itself, do you remember any specific things Mr. Jones said in that video about nuns?
	Which video?
	Because he talks about that interview a number of times.
	I don't know.
	You're telling me that's where you came from.
	Well, so he talks about, well, most of the subsequent information that he talks about is just about Anderson Cooper.
	the nose disappearing.
	But as far as the first time that he references that video, mostly what he talks about is the nose disappearing, but I think the reason, like I said, the topic of it, that's the reason why he covered it.
	- She doesn't know. - Yeah. - Do you recall any Infowars videos that you've watched during this litigation?
	Sure.
	In which you have seen Anderson Cooper talking about guns?
	No, just because I think that the videos that they posted didn't have any sound.
	The purpose of showing the video and the argument that was made of the video was that his nose was disappearing and Alex's opinion that it was green-screened or blue-screened, I can't remember which.
	But no, I don't think that Anderson Cooper had any audio.
	Or my client, right?
	You've never heard Veronique de la Rosa speak, I would take it.
	No, I've never heard her speak.
	Okay.
	Now, Mr. Jones' position about what that interview was for, being gun related or whatever, is that a factual claim or is that an editorial opinion?
	What do you think that is?
	You mean, is it Mr. Jones' opinion?
	It's tough because I don't really know what you're drawing this from still, so I'm going to say, whatever information it is that you're drawing that Free Speech Systems put in a video that makes you think that that interview is about guns, is that a fact or an editorial opinion that you're drawing that from?
	Well, so, I don't know that I would necessarily term it as an editorial opinion, but I think that, broadly speaking, the company's coverage of Sandy Hook was surrounding gun control and how in the aftermath of the tragedy there was a push for gun control.
	So, That underlying coverage would inform that opinion.
	I don't know that I would necessarily term it editorial discussions or opinions.
	Sure.
	Based on what the company knows, okay, again, talking about what it knows about, well, first of all, before we move on from Veronique, I just want to make sure, and I may have gotten confused, in terms of documents that you have reviewed relating to Veronique de la Rosa, that's pretty much limited to the InfoWars videos?
	Do you have written documents you reviewed about Vera Newt?
	I don't recall.
	Like I said, I've reviewed a lot of documents, so I don't recall.
	Based on what the company knows, based on its knowledge of the plaintiffs, does the company have any reason to contend that any of these parents have been faking their level of distress over Infowars actions as it regards Sandy Hook?
	No, I think there is a distinction between distress related to the shooting and distress related to the coverage, which should be litigated.
	But also I think there's a distinction which probably should be made between InfoWars airing other people's coverages and then the original source of the coverage.
	Are you saying that as a matter of the company's personal opinion or is this the company's legal opinion?
	I think it's a legal opinion as to much of the sourcing.
	I can object to the extent that you're getting into any conversations you've had with any of the attorneys for Mr. Jones, Infowars, Free Speech Systems Inc.
	or Mr. Shor.
	That's tomorrow, I think.
	Kathy Daniels not an attorney.
	The original sourcing of the...
	But they are defendants in this lawsuit for which she's here today.
	Yeah, but if she had conversations with an attorney about Kit Daniels or anything that related to attorney-client privilege, I would be equally privileged in this case.
	And you know that.
	Come on now.
	Is that basically the... The sourcing, the original sourcing of the materials, so like for example free speech systems position is that it is a blogger, it is a punditry, it's commentary.
	We're not doing independent resource resourcing or research and we're not really engaged ninety nine percent of the time in journalism so the original sourcing of these materials is another person is a third party person. - What are you talking about right now? - Oh, we'll talk about that later.
	So I guess the question is to what extent those people are responsible for their opinions unassociated with free speech.
	Gotcha.
	So if Wolfgang Haubig's on air, it's the company's position that maybe it doesn't have any responsibility for what Wolfgang Haubig says.
	That's correct.
	We'll see how that goes.
	Based on what the company knows, does the company have any reason to dispute that these parents' grieving process of their children has been impacted by Infowars' actions as it regards Sandy Hook?
	I think it's subject to the same answer for my last question.
	But, I mean, in other words, that's what I'm trying to kind of follow up on here.
	As I understand, you think there may be distinctions that need to be made about grief that was caused directly by the shooting itself and maybe things that were said afterwards, right?
	And that there may also need to be distinctions about who said it.
	Maybe it was third parties.
	Maybe it was InfoWars.
	And I get that those distinctions exist.
	But notwithstanding those distinctions and whatever slices need to be cut out of this pie, you will agree with me that these parents' grieving process has been affected by what InfoWars did about Sandy Hook.
	By what InfoWars did, by what other people who are posting on the internet did, by any other third party, any other news media coverage.
	Yes, I'm sure it has.
	Not just InfoWars.
	Not just InfoWars.
	That's correct.
	Can you tell me another major media organization who has covered Sandy Hook from the same perspective as InfoWars, i.e.
	saying that my clients are fake?
	Do you know anybody else who's done that?
	Other news media organizations have covered it.
	I don't know necessarily from the same perspective.
	Well, I mean, you're saying that there's other people who are responsible.
	There are other people's opinions that have been talked and discussed.
	I just saw an article yesterday that is still claiming that Sandy Hook didn't happen.
	And this article was not amplified in any way by InfoWars.
	So these people are still out there and you can Google search it and it will still come up on a Google search.
	You're aware enough to realize that if somebody was writing about Sandy Hook being fake today, There is a substantial likelihood that they were influenced by Infowars coverage.
	That's a possibility, right?
	It's also a possibility they're doing their own independent research.
	It also is a possibility they're basing their opinions on Halbig's.
	It's also based on somebody else.
	I don't know where their information is coming from.
	And if they based it on Halbig, there's a substantial possibility they know about Halbig because of him being brought to public consciousness through InfoWars.
	That's a possibility, right?
	I don't know how it's being brought to their consciousness.
	Exactly.
	So what I want to get to is, can you name me everybody else who's, like, I mean, I think you've acknowledged, That some of the impact on the grieving process of my parents came from InfoWars.
	Can you tell me everybody else who needs to be blamed?
	Whoever's doing their own individual reporting on the issue.
	So, for example, like I said, I saw an article that was written yesterday.
	Much of the opinions that were written in that article, it was like 150 pages long, had nothing to do with anything InfoWars had ever talked about.
	Really?
	Right.
	So they're doing their own independent, I don't want to call it research, but their opinions are based on things that are not connected in any way to this.
	Okay, can you produce that for me?
	Do you have that article you saw?
	We can email it, I'm sure.
	Okay, I just want to make sure it's a thing that you could find again if you needed to.
	Sure.
	Okay, and your representation is, you read all 150 pages of that?
	I did not read all, I scanned it.
	So like, for example, some of it was in there was based on a lawsuit Mr. Posner filed against Mr. Fetzer in either Wisconsin or Michigan.
	I'm not really sure which state.
	For defamation, I don't believe we've ever covered that defamation suit in any way.
	She also cites to some other photographs that I don't think we ever covered.
	So, those are things that really are not being advised by us.
	They're getting it in other places.
	When you say InfoWars, you do not believe has covered the Fetzer vs. Posner defamation suit.
	The one that was what, was it Wisconsin?
	I don't know that we've covered it in any substantive way.
	Like I said, Fetzer really wasn't... I want to make that distinction.
	You don't know, right?
	I've not seen any material that shows that.
	If you want to show me it, I'd be happy to look.
	Right, and that's what... I don't need to show it to you.
	Sure.
	Because I don't want to get into that.
	What I want to make sure I understand is that you don't know if InfoWars has covered that.
	I don't believe it's been covered.
	In other words, I've not seen any information to that effect.
	Okay.
	And I want to make sure from this last question we talked about on the grieving process, because I know you're making a distinction that other people may be responsible too, the company does not dispute that it bears the company does not dispute that it bears some responsibility for the impact that it had on the grieving process of these families.
	I don't know that I would necessarily agree with that.
	Okay, but you did agree that InfoWars, its coverage, did impact that grieving process.
	You just don't think they have any responsibility for it, right?
	That's correct.
	If, over the course of years, InfoWars is telling the world that Sandy Hook is fake, and that controversy stays alive, does the company understand that it might be hard for my clients to have closure on the death of their children?
	I don't think that, and maybe we need to talk about what fake means.
	So when you said fake, does that mean children didn't die?
	Does that mean it is a fake plant?
	What does fake mean?
	No, I get what you're saying.
	I do.
	And let's just go ahead and make sure we both are on the same page.
	I don't think we do need to split a lot of hairs about what fake is or is not.
	And would you agree with me that the reason that we don't need to do that is because many, many times people on Infowars, including Mr. Jones, have unequivocally said that Sandy Hook is completely fake, totally synthetic, manufactured.
	You agree with that?
	I agree.
	Those are direct quotes on Mr. Jones's opinions, yes.
	So, let's go back to the question, because now we both understand and we both agree that many, many times it was said on InfoWars that Sandy Hook was totally fake.
	And if that's a true thing, if that's the reality, that that was said many, many times, the company can understand that if that keeps the controversy alive, my clients might have a hard time having closure on the death of their children, right?
	And here's the problem that I'm having is I think that the distinction is important because I think there is a big difference between saying something is synthetic in the sense that it could be a false flag, a government operation, is not the same thing as saying your children did not die.
	Very, okay.
	Let's make it really clear then.
	Let's make sure we're really on the Because we talked about, yes, they did say it was totally fake, totally manufactured, right?
	But that may mean, according to you, that kids could have died or they may have not died.
	He said that numerous times.
	Right.
	But we both know that numerous times he said kids did not die.
	We know that, right?
	I don't think that I agree with that statement.
	I think numerous times he's questioned some anomalies, or what he viewed as anomalies, numerous times he did say I think kids died.
	Maybe on one or two occasions he's like oh maybe I'm not sure if it if they did or didn't die I'm not sure I can't make a decision either way but I think that upon review of the videos I think that Mr. Jones his opinion was that on the whole children died.
	Okay.
	Alright.
	Well probably what we're going to need to do after the break because I didn't plan on showing you videos today but I did not think that there would be any resistance to the idea of Mr. Jones saying yep I used to think kids died but nope they sure didn't.
	I didn't think there'd be resistance to that idea.
	So we may need to watch some videos on that.
	Like I said, I think there is one video clip, and I think it's in...
	I might want to say I can review my notes.
	There's one video clip where he does say that direct quote, but there's numerous other quotes where he says, I believe kids died and I or and or I'm not sure whether kids died, but something smells funny or look at this issue or look at that issue.
	So I think there is one video clip where he says that, but on the whole numerous other times, that is not what the coverage was.
	He said in other videos there are pictures of kids they said that died that are still alive.
	Right?
	Can you point me to the video?
	I will.
	We'll get there.
	I'm just wondering if you know it right now.
	Off the top of my head, no.
	- No. - Okay.
	Let's take a break.
	You need a lunch?
	Yeah, that would be nice.
	Nice.
	Okay.
	12.34 off.
	1.45 on the record.
	One of the things we talked about right before you left is that you saw an article recently saying that Sandy Hook was fake.
	You remember that?
	Yes.
	And you told me that you wanted to make sure it was clear that InfoWars didn't amplify that article.
	Yes.
	But InfoWars, by that answer, I take it you understand, InfoWars does amplify things said by other people about Sandy Hook.
	Amongst other things, but yes.
	And that's a choice InfoWars makes of who to amplify and who not to amplify, correct?
	Yes.
	Okay.
	Have you ever been in a deposition before?
	You mean have I taken one or have I given one?
	Ever been in a room where a deposition was happening?
	Yes.
	Okay.
	Um, are those, did you, have you taken criminal law depositions or been present for civil law depositions?
	There's no such thing as a criminal deposition, but yes, I've been in civil depositions.
	We have them here in Texas actually.
	Oh, we don't have any in Connecticut.
	Not allowed to take criminal depositions.
	Okay.
	Have you ever been in deposition representing somebody in a civil deposition?
	Yes.
	Okay.
	So you've done some civil work, I take it?
	Yes.
	Okay.
	How long have you practiced?
	This is my 10th year.
	Okay.
	Have you ever been a corporate representative before?
	No.
	I assume that you have a written agreement for your work in this case?
	You know what?
	I don't think I ever actually got a written agreement.
	I don't think I signed an agreement.
	Okay.
	Do you have an invoice?
	That I sent to the company?
	Yeah, I believe so.
	Okay.
	So in other words, the amount of money you were paid was documented at some point?
	Yes, through my internal documenting system.
	I use Clio.
	Okay.
	Now, you understand there's a protective order in this case?
	Yes.
	And I haven't seen a signed protective order acknowledgement from you.
	Have you done that?
	I've not been prior to one, but I'm happy to do it.
	Okay.
	But in other words, before being exposed to my client's confidential information, you didn't sign a protective order?
	No, I haven't signed anything.
	Okay.
	Can you give me, where's my boat?
	Oh, it's my backpack.
	I know.
	Oh no, that's the notice, dude.
	Nope.
	Okay, so the first thing I want to put on the record is that you have given me this notebook, right?
	Yes.
	I have marked it as Exhibit 8.
	You see that right there?
	Yes.
	Okay.
	From what I'm able to tell, this notebook contains a couple of things, and one of the things it seems to contain is a chart of videos that you've reviewed, right?
	Yes.
	And some notes you've taken on that?
	Yes.
	There also seem to be some notes you've taken on interviews and depositions and various things like that?
	Yes.
	And then there seemed to be a lot of tabbed pages with base numbers codes on them for videos, right?
	Right, that's generally my expanded notes on the videos.
	So the first chart you're referencing is like my reference chart and then the spreadsheet with the tabs that you're referencing, those are my more in-depth notes on the videos.
	Did you make this?
	Yes.
	OK.
	I'm going to-- oh, you need to see that.
	Yeah.
	Right here.
	He's got this video.
	It's 2013.
	It's a Polish boy.
	Oh, good point, man.
	That's strange.
	Okay.
	Let me just get that out of the way right, actually, because we're going to start talking about some videos.
	Do you see a video on here that starts with professor claims?
	Yes.
	Okay, and then I see you've taken some notes over to the side, right?
	Yes, like I said, this is just my basic bullet point clip of what that video is about, and then I have more in-depth notes later on.
	Okay, and so one of the notes that you've taken on that video.
	First, can you tell me the date on that video?
	1-10-2013.
	Okay, and then you have some notes in there about Owen Troyer?
	Yeah.
	Can you tell me what that means?
	It might have been Owen was either in that video or did the interview.
	Or something to that effect.
	Or maybe it was the source for the information or something?
	No, I don't think it would have been the source.
	It would have been the person who was doing the video.
	But I could be mistaken on that.
	Can I check my more in-depth notes on that video?
	Let's see.
	Yeah, so for that video, I have the reporter as Owen Schreier.
	Okay.
	And his source was James Tracy and his website.
	Okay.
	And various other sources.
	I'm a little concerned about that answer.
	Okay.
	Because Owen Schreier didn't start working at InfoWars until 2016.
	Okay.
	Did you know that?
	I did.
	So you know what, it might be a typo on my part.
	Okay.
	I reviewed that video pretty early on, so I might have gotten him mixed up with somebody else.
	But you see, where I have, it's Reporter.
	And that's where I would have put the name of whoever was hosting that particular video.
	So it probably is just a typo on my part.
	Or a mistake.
	Yeah.
	It's not accurate, in other words.
	No, you're right.
	It's not accurate.
	OK.
	So just from off the bat, we can say we know at least some of the information in this chart is not accurate.
	Well, I made this chart.
	It's a hundred pages long in the last two weeks.
	So... Yeah, I mean, look, I agree with you.
	So I did my best, and there might be some typos in there, and there might be some errors.
	Yes, there might be.
	Let me just make sure we're clear going forward in this conversation, because I understand the situation you're in.
	And let me make sure I make it very clear to you as an individual that I 1,000% agree with you that asking one person to create all of this is pretty unreasonable.
	I agree with that.
	Okay?
	But what I'm asking you is, because you were just the one person who had to somehow assimilate all of this information, there's going to be mistakes in there.
	Oh, of course.
	Okay.
	Now let's talk about... I'll give you a stapled copier.
	This is going to get messy.
	Oh, and this goes in your binder in the front.
	Okay, and then I am marking... This will be Exhibit 9.
	Exhibit 9.
	I've handed you Exhibit 9, which is a file stamp copy of Neil Heslund's original petition and his intentional infliction of emotional distress case.
	That's something you've reviewed, right?
	Yes.
	I've seen this.
	Or actually, no, go ahead.
	You can hang on to that.
	OK, can you go to paragraph 61 for me?
	Okay.
	So what we're going to do is work backwards in time from recent videos to older videos.
	And part of the reason we're going to do that is because there's going to be some things that we talk about in these recent videos that are also talked about in the old videos But in other words, once we cover a topic, we won't have to repeat it for the later videos, okay?
	So that's why I'm doing it in that direction, is I'm going backwards.
	So for instance, there may be things I ask you about in this video that are also talked about in this video, but hopefully if we can get the source first here, we won't have to repeat them again.
	You understand what I'm saying?
	Because I think you'll agree with me that some of the factual assertions made about Sandy Hook have been made repeatedly in several videos, right?
	Yes.
	Okay.
	So let's talk about this, and you see there in paragraph 61, It talks about an October 26, 2017 video that was entitled, JFK Assassination Documents to Drop Tonight.
	Do you see where it says that?
	Yes.
	Okay, have you watched that video?
	If I may check my notes.
	No, it's not on the list of videos that I reviewed.
	Okay.
	Probably because the main source, not source, but the main topic of this particular video is JFK and the documents that were released in a declassification by the government, I believe.
	How do you know that?
	Just by the title.
	Okay, so you know that's the title.
	Yeah.
	But you don't know that's the main topic of the video.
	You don't know that, right?
	I know they did covering of these particular documents, the JFK documents.
	How do you know that?
	Just by being familiar with some of the things that the company has talked about in the past.
	From interviews, you mean?
	From interviews, from looking at the website, from reviewing the materials that I've read.
	I just haven't watched this particular video.
	Okay, so you've gone to the website and seen things about JFK on the website?
	Not about JFK, just things that they've covered in the past, like the documents that we've reviewed that we've also, that we've talked about, that we've reviewed.
	No, I'm trying to understand how you know the main topic of this video.
	I just answered that I read the title of the video.
	Okay, that's what I want to know.
	It's from the title, you're assuming that the title describes, and again, this is generally how titles work, I think you'd agree, right?
	That that's like a main idea or a main thesis?
	Yes.
	But sometimes things don't always follow intuitively at InfoWars.
	You'd agree with that?
	That titles don't always necessarily reflect... Sure.
	I mean, and there's a lot of reasons for that.
	Generally, you know, Alex comes on the air and I don't think he even really knows what he wants to talk about.
	He'll have a general idea of what he wants to talk about.
	And then he'll go into a tangent on something else and then maybe for one or two minutes talk about a completely unrelated topic and then switch back to the general topic.
	So when I say that the general topic of this particular video is JFK assassination documents to drop tonight, that's the general topic.
	And he may have talked about other things unrelated to that topic in the video as a tangent and then re-circled back.
	As I said, the general topic.
	Okay, so is the reason you didn't watch this video is because it had a different general topic and you didn't think it was really about what we were talking about today?
	I did not see that particular video on the Dropbox.
	I reviewed all the videos that were on the Dropbox.
	Let's talk about this Dropbox.
	Is this something the company maintains?
	So I think we talked about a little bit how there's been some issues with production versus here, production in Connecticut.
	There's a bunch of cases.
	So we've had a lot of trouble figuring out what has been disclosed in the various cases.
	And we've been trying to maintain a general one source of information.
	It's in the process of being reorganized.
	So, if it wasn't on the Dropbox, I couldn't find it.
	Okay.
	Do you know if the company has this video?
	That I don't know either, because I know that some of the videos that are alleged in this petition were produced by the plaintiffs, because we didn't have them.
	So I don't know if we have this video.
	What did you do to try to find out?
	About this particular video?
	I did not ask anybody about this particular video.
	Okay.
	You read Ms.
	Karpova's deposition, right?
	Yes.
	She watched this video, you know that, right?
	Um, in preparation for the deposition?
	Absolutely.
	Well, I wouldn't necessarily describe it as preparation.
	I would describe it as she got kind of caught having not watched anything, and then during the break attempted to prepare herself.
	I think that was my recollection, too.
	I don't think she watched the entire video.
	I think she watched clips of the video on a break.
	I think she skimmed through it, yeah.
	Right, I think that's what her testimony was.
	I think with Ms.
	Karpova, her being a producer, she's familiar enough with the standard format of the show that she can kind of skim through and know where topics start and stop.
	And so I think she was able to skim through it.
	I don't know if that's the case.
	I think that that's the point of them making those notes was to know where things were in particular productions just because they were having problems with that.
	Like what segment was what they were talking about and what segment.
	That's the reason why they were producing those logs.
	So I don't know if she can tell just by looking at a video where certain statements would appear in a video unless she had reviewed the logs.
	Yeah, I agree.
	I definitely agree with that.
	So in terms of whatever claims are made in this video about Sandy Hook that the plaintiffs are talking about, or actually just any claims about Sandy Hook, those aren't going to be things you can talk to me about today, right?
	I can talk to you about some specific allegations, like for example, this claim that they bulldozed the house and got rid of it.
	That's not a claim that was just made in that video.
	I'm sure that it was made in other videos.
	So I've watched other videos that have contained this particular claim of the house being bulldozed.
	Would you like to talk about that?
	Yeah, where does that come from?
	This house being bulldozed?
	Sure.
	You mean where did Alex Jones get the belief that the house was bulldozed?
	Right.
	I believe that there were property records that had indicated that the house was bulldozed.
	Have you seen those?
	I have not seen the documents, no.
	Have you tried to locate them?
	No.
	Okay.
	I don't think they were amongst the documents that the company has.
	All right.
	Do you understand the story that was, that this, okay, so this video covers a story by Leanne McAdoo.
	Do you understand that story?
	Sure.
	Okay.
	You know who Leanne McAdoo is?
	Yes.
	Okay.
	She's somebody whose work is featured in this video.
	Yes.
	Okay.
	You talked to her?
	No, I didn't.
	You tried to talk to her?
	No, I didn't try to talk to her.
	Okay.
	Do you know what employees researched or vetted the information that was being produced in that video?
	Well, hold on.
	Let me make sure.
	Sure.
	Because that's a bad question because we both can agree you don't really know all the information that was in that video.
	In this video, no.
	But, you know, like I said, just from the title, it's not really clear that that was the main focus of that video.
	I'm 100% sure that there was no main focus of that video.
	Because like you say, the idea of Alex Jones having a cohesive main topic is sort of silly.
	That's not what he does.
	That's simply not the protocol or format of what he does on air.
	Right.
	But we know for 100% sure that Sandy Hook was discussed in this video.
	Oh yeah, I'm sure he discussed it and I'm sure, I mean I'm not disputing that these statements were made in that particular video.
	They were also made other places too.
	And you would think that plaintiffs have a right to ask about that and how that happened, right?
	But you sitting here today don't know all the claims about Sandy Hook in that video.
	In this particular video, no.
	But like I said, these statements were made in other videos.
	Okay, hold on.
	I want to make sure, because I know what was said in that video.
	I know very well what was said in the video.
	And there are many things said in that video that were never said in any other video.
	And so when you say that all the claims in that video were made in other videos, you can't verify that, can you?
	No, that's not accurate.
	So, for example, this claim, phony as a $3 bill, Just looking at my notes, I see that that almost exact statement, tell us why this appears to be phonier than a $3 bill, was made in new bombshell Sandy Hook information inbound in that 7ib video we talked about earlier.
	Sure.
	No, no, and I understand there are going to be things in that video that's said for.
	In fact, that's how I prefaced this entire discussion.
	I'm saying you're going off of what you're reading right there in the petition, right?
	Going off of what?
	When you say, for instance, when you just talked about the house being bulldozed, or fake as a $3 bill, you're reading that out of plaintiff's petition.
	Well yeah, I read the statements, right?
	You don't know what else was said about Sandy Hook other than what was in that petition.
	For this particular video?
	No.
	For JFK assassination documents to drop tonight?
	No.
	No you don't, okay.
	Well let's move on that from the video then.
	Oh wait, actually, do you know what employees were involved in creating that video?
	Um, unless it's on that list that we've previously marked.
	Do you want to... Yeah, let's take out that list.
	Yeah, take out that list.
	Tell me if it is.
	- It is. - So this is exhibit six, October 26th, 2017.
	No, that's not one of the dates that's on here.
	So, in other words, you won't be able to tell me what employees were involved in creating this video?
	No, these dates go from 2013 through 2015.
	Correct.
	So, one of the most recent videos in Plaintiff's Petition, one that was published mere months before Mr. Jones was sued, that's not part of the information you secured about what employees were involved in creating it, right?
	I don't, like I said, I don't know if we even have this video.
	I'm not asking you about the video and if you were able to find the video.
	I'm asking you about a different topic, which is the employees involved in making that video.
	Oh, no.
	If it's not on that list, I don't have it.
	Okay.
	Let's go to paragraph 59.
	Okay.
	You see, that talks about a June 26, 2017 video entitled, Zero Hedge Discovers Anomaly in Alex Jones Hit Piece.
	I don't know the title of the video just by looking at paragraph... Is it 59?
	I'm sorry.
	Yeah, you're right.
	It doesn't have the title in that paragraph.
	You're right.
	Okay.
	But you... In other words, this may help you.
	This is the video that Mr. Hessel is suing the company for defamation about involving Newton Owens Schroyer, in which Mr. Schroyer claimed that he couldn't have held his child.
	You understand what that video is?
	Yes, I did watch that video.
	Okay, you watched that video.
	Okay.
	Do you know what employees were involved in creating that video?
	Sure, let me just... If I may look at my notes.
	Uh, ju ju ju ju.
	Oh, I mean, I'm sorry.
	Are you asking me whether there were, like for a list of employees for that video?
	I want to know, for that employee, every employee who was involved and what their role was.
	I don't know what the answer to that question is.
	All I can know as far as the sourcing, I think we already talked about the sourcing material, but if you're asking me, every single person that worked on that particular day, if it's not on this list of Exhibit 6, I don't know.
	That date is not on these lists.
	Okay, so when you had this video to get prepared for, and you knew you'd have to be prepared on the employees who were involved in it, what did you do to make sure you were prepared?
	To talk about that video?
	I'm prepared to talk about the sourcing of the video, which I think we already talked about.
	And when we spoke to Melinda, we tried to have her pull as much as possible the information for the people that were working that day, which was not an easy task for her.
	And she put together that document because she was the one that was reviewing the records.
	But as far as other people that were working on that video, I mean the content of the video, if you're asking the sourcing for the video and all that kind of stuff, all the other stuff, like who was the producer for that, they wouldn't have had any involvement regarding the content of what's on that video.
	So like the production manager that was doing the video or doing the sound or whatnot, they don't have any involvement in that.
	So when I talk to production and people, Um, involved in the production, my understanding from talking to them was that the host sources their content, they pick what they want to talk about, and then the producers get them the information that they request as far as video clips.
	And then the host is the one that does the sourcing.
	Okay.
	So that's just based on my conversations with how they do things.
	But from my understanding, production doesn't have any involvement in the content.
	Okay.
	So I would take it if you were going to try to figure out what went on in this video, a person you might want to talk to is Owen Shroyer.
	I read his deposition, yes.
	Did you interview him?
	I didn't talk to him.
	I don't know that he was available.
	I can't remember.
	Okay, but you did read his deposition.
	I did.
	Alright, the reason I'm troubled is because he testified to the exact opposite of what you said.
	He said that he'd had nothing to do with picking the story or sourcing it or anything.
	That somebody on production staff, one of the producers of the production staff, got that material, researched and sourced it, and gave it to him and he just read it on the air.
	Do you think he's wrong?
	I don't think that's what the context of his testimony was.
	The context, I believe, of his testimony is that every day, and this is not just for Owen, but for any host, Is that the associate producers put together a print-off of whatever sources that host likes.
	So, for example, Alex has a list of sources that he gets printed out on a daily basis.
	Owen has a list of sources that he uses.
	The producer is the one that provides all this material and says, here, this is the material that's off the list that is your list.
	And then the host reviews that material and decides what he wants to talk about.
	Alright, we'll leave that right there.
	Alright, and in terms of who those associate producers were... On that particular day, no.
	But again, it would just be pulling the information off of the internet based on their list.
	What do you mean a list?
	What does that mean?
	So, like I said earlier, each of the hosts has a list of sources that they pull from.
	So, Zero Hedge is a source that is on that list that they pull from, and so they'll print off the articles for them off of that list.
	So what I'm trying, I think I hear, is that it's like just every day Owen wants everything that was on Zero Hedge printed and brought to him?
	Right.
	All the articles that were on for that day.
	Okay.
	And then he'll filter through that and decide.
	Okay.
	Do you know what was done to research or vet this information before it was put on the air?
	To vet the information that was in the Zero Hedge article?
	And everything that Owen said, too.
	Can you be more specific about what he said?
	Absolutely not.
	Okay, well those are two separate questions.
	So the information in the Zero Hedge article would have been vetted by Zero Hedge or whomever produced the article.
	And as far as sourcing for the video that was used in that article, the source was the video that was on Zero Hedge.
	Okay, so let's first Okay.
	Let's first start with the things that were in the Zero Hedge article were vetted by Zero Hedge, is that right?
	Or whoever produced that article.
	Okay.
	And do you know who that is?
	I think it was, I think originally we, I think we talked about this.
	It came from iBankCoin originally, and then it was picked up by Zero Hedge.
	So whoever produced it would have been iBankCoin originally.
	Just to help you out.
	Zero Point Now writes for both iBank.
	He reposts his articles.
	They're just posted in both places.
	It's not like there's a guy at a thing called iBank Coin and then Zero Hedge was like, wow, we saw that, we picked up.
	I just want you to know for your benefit, Zero Point Now is the author of that article and he's the author of it at iBank Coin too.
	Have you talked to Zero Point Now?
	No.
	When you say that Zero Hedge vetted that, I take that to mean InfoWars did nothing to vet that before it was put on the air at InfoWars.
	InfoWars used that article as a source and quoted to that source.
	I think you know that's not what I'm asking.
	It is what you're asking.
	I know that, I understand they quoted it as a source.
	I understand it was on the video.
	I'm trying to understand that one of two things happened.
	One is that Owen Schroer or whoever got it was handed a video or handed this document And gone, all right, let's put this on the air.
	And nothing was done internally into InfoWars to verify the factual accuracy of the things being said in that article.
	Or two, there were steps taken by InfoWars to make sure that the things said in that article were true before they got put on air.
	No, InfoWars, the company relies on the reporting done by other news sources to vet their information.
	Is Zero Point now a news source?
	It's a source for their information, so it's on the list of sources that they use to get information from.
	Is it a news source?
	I don't know if you'd call it news, but it's a source.
	I'm bringing up that word because you said news source, so I'm trying to figure out if that's... It's a source of, it's on their list of sources that they pull from on a daily basis.
	It's my understanding that ZeroHedge is like an accumulator of other various sites.
	So it's like they're citing to a variety of other places, and that's why they're using it as an accumulator of sorts.
	Okay, just because we may talk about ZeroHedge more.
	ZeroHedge is not like Reddit or an aggregator or a new site, or Drudge or something like that, right?
	You know who Tyler Durden is?
	No.
	Well, but I know Drudge is an accumulator, right?
	Yes.
	So, like, you may know Tyler Durden.
	He's the main character in Fight Club that Brad Pitt played.
	Oh, yeah!
	That's the name of the person who runs Zero Hedge.
	Okay.
	Or at least what they call themselves.
	Okay.
	And that person writes articles for Zero Hedge.
	And then there's other contributors, like Zero Point Now, and they write for Zero Hedge, right?
	Okay.
	So, what I want to make sure that you understand is that this wasn't something that Zero Hedge aggregated from anywhere.
	This was something Zero Hedge wrote.
	You understand that?
	Okay.
	So, as far as the person, the source that was quoted here, InfoWars, for this deposition, did nothing to try to talk to them or get any information from them?
	To talk to someone at Zero Hedge?
	No, I did not.
	Okay.
	By the same token, any of the videos that were used by Mr. Shorter in that broadcast that came from Zero Hedge or are alleged to have come from Zero Hedge, you've done nothing to track down those videos?
	The one that was on the Zero Hedge article and then was subsequently re-aired on InfoWars?
	See, I can't make that representation because the Zero Hedge article, none of those videos actually work in them.
	They were all removed a long time ago.
	Okay.
	So when you say that those videos in Mr. Schroeder's video I'd like very much to verify that.
	I'd like to know where they came from.
	And I think I do have an answer for that, just based on my conversations with various people in the company over the last week, which is-- and I don't know that Owen really knew it either in his deposition, because I believe you asked him that question, and he wasn't sure. because I believe you asked him that question, and he But the source of the video was the Zero Hedge article
	They did not, because I asked, you know, I interviewed and asked video people, I was like, all right, well, did you guys cut this video?
	Because at some point they have the whole video of Wayne Carver, but they didn't use the whole video and then cut it.
	The video that they got was from that article.
	It was already pre-cut.
	They didn't do anything to cut that video.
	Who told you that?
	I believe that information came from, it was either Daria or it wasn't Owen because I didn't talk to Owen.
	Um, oh no, you know who it was?
	When I spoke to Rob Due, Rob Due told me that that's where it came from.
	Rob Due wasn't involved in making this video, right?
	I don't think he was, but at the time I want to say he was the He was a supervisor, but you know they don't have titles there, but he was overseeing all in.
	I don't know what you mean.
	Rob Doo definitely has had titles.
	I think he gave himself a title, but nobody there really has an official title.
	Okay.
	And so Rob Doo Does he know firsthand that those videos were taken, unedited, from the Zero Hedge site?
	Or is that his guess based on how he thinks things work inside the company?
	No, when I asked Rob, Rob was sure that that's where it was from.
	I mean, I'm not understanding how he would know what went on in that room that day.
	I don't know either.
	I'm not... I wasn't... Okay.
	But I did ask Rob and that was his answer.
	- Okay. - Can you tell me, okay, so these list of sources that are M4s chooses to amplify, so these list of sources that are M4s chooses to amplify, Well, chooses to source from, but yeah.
	What's your problem with the word amplify?
	Isn't that the word you used earlier?
	So my problem is that even if an article is being sourced from these places, they're not amplifying every single article that is being sourced from these places.
	They're being printed and presented to the host, and then the host is choosing from amongst those.
	Okay, so instead of me saying that the sources that are amplified, when I say that there's a list of sources Who's, some of the articles from those sources are amplified.
	Yes.
	Right?
	Who makes the decision, who made the decision here that Zero Point Now or Zero Hedge was a reliable place to be getting information from?
	So, you mean, in general, is there some company rule as to which sources are reliable and which sources are not reliable?
	Not really a rule, but just anything that's ever done.
	So these are sources that are generally trusted by the hosts.
	These lists, so to speak, of sources change over time.
	So like, for example, when I spoke to Nico, Nico's position to me was Alex's source list was Shorter than it is now.
	When I talk to Daria, he has a list of sources like seven or eight long.
	So it evolves over time, and ultimately, the information that is preferred comes from the host.
	So the host would choose which sources they like to get information from.
	Like other hosts, such as Mr. Knight, According to Daria, he didn't have a list that they produced for him on a daily basis.
	He would just, he would himself read the news, read the internet, and send to her already, I want you to print this and be prepared to talk about this on my show.
	So, ultimately the list is made by the host.
	Okay, so the, so the kind of short version for this particular Video.
	For this particular video, who decided that it would be reliable?
	The answer to that is Owen Shorter.
	Yes.
	Okay.
	Jim Fetzer's quoted in this video?
	Yes, to the extent I believe that it's quoted in the original article.
	Okay.
	And I think we've already covered this, but you didn't speak to Mr. Fetzer, right?
	No, I did not.
	You didn't try to speak to Mr. Fetzer.
	No, I did not.
	Okay.
	Owen had made some sort of judgment, you would agree with me, that it was appropriate to rely on Mr. Fetzer's conclusions about this, right?
	Which conclusion are you talking about?
	The conclusions made by Fetzer in the June 26, 2017 interview.
	Which, can you please specify the conclusion you're talking about?
	Yeah, I mean, I can go ahead and pull everything Fetzer said, but you understand the point of that video, right?
	I understand the point of the video is that there's a claim that was made by Mr. Heslin in the Megyn Kelly interview that he held his son and had a bullet hole in his head, and then there was a cut to the clip
	of Mr. Carver's interview, which wasn't a whole contextual comment by Dr. Carver, and then the comment that was made was, these two things are inconsistent, which is it, essentially.
	Is that, and that is what you're representing, is the comment attributed to Mr. Fetzer?
	I want to make sure that Yeah, and I think you've mostly got it.
	I think where the little bit left is the conclusion of where you reach from those is that Mr. Hessel's version of events cannot be accurate.
	I disagree that that's what the purpose or conclusion that was conveyed by Mr. Schroeder.
	I'm not, that's not what I'm saying.
	I'm saying by Mr. Fetzer.
	Oh, okay.
	Well, if that's what Mr. Fetzer was concluding, that's not what Owen Schroer concluded in his video.
	Okay, Mr. Schroer, let's go ahead and get to Mr. Schroer.
	He literally said in this video that Mr. Hesselin said he held his kid.
	Now, according to fact checkers, that is not possible, right?
	According to this video by Dr. Carver, I think that's a fairly good paraphrase.
	two things cannot both be true.
	Can we get a clarification?
	I don't think we're gonna get a clarification, but can we get a clarification either for Mr. Heslin or Megan Kelly?
	And then he said, I doubt that's gonna happen or something to that effect. - I think that's a fairly good paraphrase. - Right. - I think you did a good job there.
	In other words, at some point when coming to his decisions about what he was gonna put on the air, Mr. Sawyer had to decide that Mr. Fetzer was an okay thing to be sharing with the InfoWars audience, right?
	I think he made a decision that the report on Zero Hedge was an okay thing to be sharing with the audience.
	Right, and that contains Jim Fetzer's conclusions, right?
	It contained information in there and quotations from another person, yes.
	Yes, so by logical extension, by the way the rules of logic works, if Mr. Schroyer decided that that Zero Hedge article was appropriate to share, which communicates directly information from Mr. Fetzer, then he also decided that it was appropriate to share with his audience the information that Mr. Fetzer was communicating, right?
	Is this a question that you're asking me whether he made a determination as to the credibility of Mr. Fetzer?
	Is that what you're asking?
	I think I asked appropriate.
	Yeah, but you're not making him make a credibility determination?
	When you say appropriate, what do you mean by appropriate?
	Okay, so how does InfoWars decide what's appropriate to share in terms of sources?
	Are you asking what is reliable as a source?
	If that's one of the things that InfoWars cares about in determining whether a source is appropriate, then yeah, I'd expect that to be in the answer.
	So I think that that just has to do with the relationship with, you know, the prior history of the particular source.
	So if that particular source has been credible in the past, for example, Zero Hedge, they have reported on Zero, they have re-reported, I should speak, on Zero Hedge articles in the past.
	Those have seemed to be reliable, so they would continue to rely on it in the future.
	Same thing for Mr. Fetzer?
	I don't know that they've ever really amplified Mr. Fetzer's information.
	Really?
	Certainly you've seen discussions about Mr. Fetzer, right?
	I have seen discussions about Mr. Fetzer.
	And about how Infowars was relying on him?
	I don't think he was being relied on to a very high degree.
	I don't think that that was a big source of their information.
	And the reason why I say this is because first, when I talked to Mr. Watson, Mr. Watson made clear that There was no good relationship at the time between Alex Jones and Mr. Fetzer.
	They did not like one another.
	Right.
	Second is, you know, in my conversations with Alex, he had never even read Fetzer's material.
	I don't even think he knows what's in there.
	I agree.
	So I don't know, I don't think that it's accurate to say that Mr. Jones relied on Fetzer in any real meaningful way.
	Okay.
	This is where I'm maybe getting caught up is the real meaningful way.
	Because, to me, I can understand what you're saying if you say, I don't think they relied on him a bunch.
	But you would agree with me that there are multiple videos we're going to be talking about today where the assertion of fact comes directly from Mr. Fetzer.
	Mr. Fetzer was never a guest on the show talking about this particular issue, but I do see in some of the videos that he is quoted as a source amongst other sources.
	See, this is where I'm really drawing a problem is because there has been criticism inside the company for relying on Mr. Fetzer as a source, right?
	For Sandy Hook.
	And you're referring specifically to an email that Mr. Watson has promulgated, and I know which email you're talking about, and I specifically asked about that email, and his position is that he understands Mr. Fetzer wasn't being relied on to any real degree.
	He knows Fetzer was not being relied on that heavily.
	There were other people that were listed in that email aside from Fetzer.
	Jeff Rentz, right?
	Right.
	Actually, you probably didn't rely on Jeff Rentz much at all, did you?
	I don't even see that man referred to much in the material.
	Yeah, it was more Fetzer.
	I mean, like I said, I don't even see Fetzer referred to much in the material.
	I understand that Mr. Watson did that email, but as far as the video goes, he's not on a lot of the videos.
	Do you think that's the only criticism for Mr. Fetzer inside the company?
	Is that email that you saw?
	That's the only email that I can recall at this point.
	And certainly when reviewing the production, you saw the volume of emails from Jim Fetzer?
	I know Jim Fetzer sent a volume of emails.
	I can't speak to whether they were read by the company for the same email, for the same reason as Mr. Halbig.
	Right, because after a guy sends you maybe your sixth, eight-thousandth, twelve-thousandth email, you start just ignoring it, right?
	Maybe even before that.
	Maybe before that.
	Maybe even before that.
	That's why I'm saying, I understand that he sends emails, but I don't know that anybody really read it or responded to it or anything like that.
	So, well, first of all, did you ask anybody if they had ever looked at Mr. Fetzer's emails?
	So, um, I talked to Mr. Jones about Mr. Fetzer and Mr. Jones's position is he didn't really, he didn't rely on Mr. Fetzer.
	All right.
	Uh, let's see here.
	You would agree with me that by June 26, 2017, the company had-- in other words, before this video, prior to this video on June 26, 2017, that discusses information from Mr. Fetzer, the that discusses information from Mr. Fetzer, the company had in its possession,
	an extremely large volume of emails from Mr. Fetzer, which clearly reveal to any rational person that Mr. Fetzer is not mentally balanced, correct?
	- Are you asking whether they're in our possession?
	- Yes.
	- Yes, they're in our possession, they're on our email survey.
	- And you never read them. - I can't answer as to whether they were ever read.
	Unless there's something forwarding it from somebody else, or there was a response to it in any way.
	But generally, what he does is, and what I saw is what he does is he copies very many people in his emails.
	I think you're thinking of Mr. Halbig, actually.
	He, I think he had a bunch of emails copied to random people as well.
	Did he?
	Okay.
	But, I mean, I could be wrong, but in any event, like I said, unless, if it's to either a general mailbox, like InfoAd or Writer's Ad, InfoWars, but even specific emails, like to Nico, they're not, they weren't responding or monitoring his emails.
	See, and I think what you just testified is you don't know if they read the emails.
	I don't know if they read them.
	I don't know if they read them, but what I'm saying to you is when I spoke to Nico, his position is I didn't even bother responding or even reading these emails because I knew he wasn't going to be on the show.
	It wasn't relevant to me because unless I need to book them to be on the show, I don't pay attention to these emails.
	So, and I think we already know that Mr. Jones doesn't pay attention to the emails, so in all likelihood, nobody was reading those emails.
	And before his information was used on June 26, 2017, nobody read those emails, to your knowledge?
	Not to my knowledge.
	Okay.
	But if somebody had, if somebody had taken the effort before putting Mr. Fetzer's stuff on the air in 2017, of reading those emails, they would have come to the conclusion that Mr. Fetzer is not a well man.
	You would agree with that?
	I mean, I think that that's kind of speculation at this point because nobody, I don't think anybody read the emails.
	Have you?
	Read those emails in the production?
	I've read some of his emails.
	Yeah, they're not good, are they?
	No, they're not.
	They're not a man who's not... My mom used to say, not with a full deck.
	You know what that means?
	I do know what that means.
	I don't think he has a full deck.
	I don't want... I mean, again, I'm not trying to get InfoWars to give psychological opinions or whatever, but if InfoWars had read those emails, and now you as the corporate representative who's had, they would understand that is not a good man to be relying on, right?
	I think it was more so they were relying on the Zero Hedge reporting more so than Mr. Fetzer.
	I'm saying if they had.
	If they had.
	I'm saying if they had, I can't answer that because it's speculating, but what I'm saying is even if someone, just for example, I'm a criminal defense attorney and you know this, right?
	I have people that are not operating with full decks.
	They have psychological issues.
	That doesn't mean that everything that they say is false.
	It just doesn't.
	It's hard to pick and choose what is false and what is not false.
	However, I would say that the reliability of Mr. Schroer is not on Mr. Fetzer.
	It's on the reporting of Zero Hedge.
	You understand what I'm saying?
	Zero Hedge would have, in publishing the article, would have vetted the claim.
	Would they?
	How do you know that?
	Because InfoWare's entire premise is, it's just commentating.
	Like I said, it's like a citizen blogger, commentator, pundit, whatever.
	So we're not doing independent Independent analysis or independent journalism.
	I'm not investigating these things.
	We're not investigative reporters.
	So we're pulling other articles from the internet.
	Those people are writing their articles.
	We've seen that those sources have been reliable in the past and we are relying on those people to vet their own sources.
	If they don't vet their own sources, that's on them.
	That's correct.
	Not InfoWars' hands clean for anything they put on the show that they didn't themselves write, is what you're saying?
	That's the position.
	Okay.
	Let's go to paragraph 55 of that exhibit.
	Do you see a video discussed on June 13th, 2017?
	Yes.
	That's entitled, Media Refuses to Report Alex Jones' Real Statements on Sandy Hook.
	Yes.
	And you've seen that, right?
	If I could just go back to my notes.
	I've got a number on that, if it'll help you.
	Yeah, just give me one second.
	It's fine.
	The date is fine.
	- Same.
	Yes!
	Okay.
	Fantastic.
	Let's see here.
	This is 9?
	Is that where we're at?
	Thank you, sir.
	10.
	10.
	Do you recognize this from the video?
	Yes.
	Okay.
	So this is a screenshot from the June 13th, 2017 video.
	And you understand that at one point in the video, Mr. Jones puts this list up that contained his questions on Sandy Hook, right?
	Yes.
	So this is, this is just to make sure where this is the one, the video that's in response to the Megyn Kelly interview.
	It's actually not in response, it's more pre-emptive.
	He had already done the interview, but it hadn't aired yet.
	That's right.
	He knows it's coming out.
	Let me just, if I can, I'm going to go to my specific information cap, too.
	Okay.
	Yeah.
	Sorry, this is where I ran out of tabs.
	At some point we will get to where I didn't run out of tabs.
	- Okay. - Deat.
	June 13th.
	Well, that'll save some time.
	Okay.
	No.
	Okay.
	Here we go.
	Okay, you ready to talk about this one?
	Yes.
	Okay.
	So, what I have in front of you, again, that we had talked about with some questions that Mr. Jones has, that he put up under his What Alex Jones Really Believes video.
	Yes.
	Okay.
	So, the first question that we see is, why does the Sandy Hook Elementary School website have zero traffic for four years?
	You see that?
	Yes.
	Alright, you know where that comes from.
	Yes, I believe that the topic, the source for that particular contention was the Wayback Machine.
	Alright, so is it your, so your, first of all, are you saying InfoWars went and figured this out?
	Went to the Wayback Machine and came up with this theory on its own?
	Oh, you mean where is the original source for this belief?
	I'm not sure, but I know that we have amongst our documents a printout from the Wayback Machine, so at the very least, if it wasn't originated here, it was checked into, because we have the Wayback Machine.
	I believe he even put that on...
	If it wasn't in this video, it might have been in another video.
	He did like a screenshot, like a desk cam to the Wayback Machine.
	Desk cam of this Wayback Machine stuff?
	Yes.
	Where does that come from?
	Where did he get that?
	You mean where did he get the idea to go there?
	I don't know.
	I don't think he didn't go there.
	I'm sorry?
	He didn't go there.
	That picture, I know where that picture's from.
	Okay.
	Okay, so I'm trying to figure out if you know where that picture's from.
	All I can testify is to the document that I saw from the Wayback Machine.
	Okay.
	That's a chapter in Jim Fetzer's book.
	Did you know that?
	Okay.
	I did not know that.
	He wrote a book called Nobody Died at Sandy Hook.
	You know that?
	I know.
	He wrote a book, yes.
	Yeah, and the whole Wayback Machine thing that is totally false and not real.
	Okay.
	Comes from Jim Fetzer.
	You didn't know that?
	I didn't know that.
	Okay.
	I didn't go to the Wayback Machine myself to check.
	Well, yeah.
	I mean, you wouldn't know.
	How would you even go there?
	I mean, what would you look up?
	I don't know.
	I didn't go to check it out myself.
	All I saw was the document from the Wayback Machine.
	That's all I saw.
	You just saw that there was something from the Wayback Machine, which is shown in the video.
	They show a picture of it.
	Yes.
	And you did nothing to follow up to figure out where that came from?
	Aside from looking at the document that was produced as the source, no.
	Okay.
	And so you didn't ask anybody about this claim?
	About the Wayback Machine?
	I asked Alex Jones and Alex Jones' contention is that he saw it on the Wayback Machine.
	I think he test... I don't know.
	I'm pretty sure he testified to it.
	I think you're maybe thinking of Ms.
	Karpova said that.
	Yes, she did.
	You're right.
	She just said the Wayback Machine.
	The Wayback Machine.
	Like as though that's a source or something, right?
	But what I was trying to figure out... Well, I mean, it is a source.
	Whether it's an accurate source or not is up for debate, but it is a source.
	All that means is where does this information come from as far as you're aware of it.
	Yeah, but what I'm getting at is that screenshot?
	Yes.
	Isn't it just a screenshot of the webpage, the Wayback Machine?
	It's a screenshot of some stuff, some various stuff from the Wayback Machine.
	Somebody put that together.
	I don't know who put that together.
	Okay.
	And so if it was Mr. Fetzer, you wouldn't know anything about that?
	I don't know.
	Okay.
	Several reports of other shooters dressed in camouflage who fled into the woods, one of whom police allegedly detained.
	Where does that come from?
	What are those reports?
	Actually, there were a few reports.
	So, on the day of the shooting, and this is pretty common when there are active shooter events, for there to be incoming news or breaking news that maybe not necessarily won't be accurate that particular time, but would be
	Checked later on and maybe clarified but on the day of the shooting Mr. Jones did Cut to a couple of different sources for this claim the first claim Being that there was some helicopter footage of someone running around in the woods.
	He did cut to that footage there were also a couple of other art of news sources that
	That cut that listed possible second shooter Then there are also there was a in there was a interview with a person on the scene who says that he Saw someone being taken out of the woods dressed in camouflage and handcuffs And he cut to the video footage of that particular individual, okay So let's talk about this first one, this helicopter footage.
	Yes.
	You understand there's helicopter footage of some people in the woods and the police questioning them?
	Um, whether that particular person was questioned, I don't know, but the purpose of that footage was just to show that there were people chasing someone else in the woods.
	So... Okay.
	Those, those though, that video comes from well into the afternoon, well after the shooting, right?
	Did you know that?
	I know there is a time stamp on the video, yes.
	Okay, and so if you were to see that, and because those are reporters, is what that is, there's some reporters who started walking into the woods.
	If there's a video that's taken hours after everything's all over and there's all sorts of media all over the place, that's not a second shooter, right?
	I don't, well first of all, I don't know if that person that was running and being chased in the woods was a reporter.
	There were also some secondary reports of an off-duty SWAT officer that was found in the woods.
	I don't know if that's the same person.
	So, yeah, there could be any number of reasons why someone's running around in the woods.
	You're saying a SWAT officer was detained in those woods?
	So I think that after those articles, not articles, but reports of a possible second shooter and this person being taken out in handcuffs because of the video footage and the question of there being a potential shooter, it came out somewhere that there was an off-duty SWAT officer that was in the woods at that time.
	Have you been able to find that?
	The reports of that.
	Any of these?
	Yeah, that's in the disclosures.
	But I will say, I mean, I lived in Connecticut.
	What does disclosures mean?
	What do you mean?
	I mean, it's in the discovery material that I was reviewing, that I reviewed.
	It's in one of the documents.
	But also, I just will say that was pretty common for that day.
	I mean, I lived in Connecticut.
	The SWAT teams from all over the state were called in.
	So it wasn't really something that was out of the realm that it would be a SWAT officer out there.
	You're just speculating on that.
	I'm not, I know that... Based on your own personal life of what you think goes on in law enforcement, but you cannot tell me if there was a single person on scene that day dressed in SWAT gear, can you?
	Actually, yes I can.
	Okay.
	Just because we pointed to the evidence that was in the record of a person who was taken out of the woods in SWAT gear and secondly, there was a statement put out that there was an officer, an off-duty officer taken off the property.
	So, no.
	Right, so he's not in SWAT gear.
	I don't know whether he was in SWAT gear.
	Do you think SWAT officers walk around off-duty geared up in SWAT material?
	Depends.
	Does it?
	Yeah, it does.
	Never mind, that's ridiculous.
	Let's go to the next question here.
	Why were port-a-potty sandwich fruits, drinks, and chips brought and set up for people at the crime scene to eat inside the school?
	What's the source for that?
	So, I think that the source of this in just my discussions with all the various employees were this was one of, or maybe two, of Halbeck's 16 questions that he asked and that he found to be quote-unquote anomalies in his opinion.
	Okay, so how do they know that's Halbig's stuff?
	Is it just his personal knowledge of the employees you talked to?
	Is that what you're saying?
	How do I know this is Halbig's stuff?
	Yeah.
	All of these questions, these particular questions, really didn't appear until Halbig's first interview.
	And Halbig's first interview, he does go over these particular allegations.
	Okay, so let's stop talking allegations plural, because we know number one allegation about the Wayback Machine.
	Halbig's never said anything about that.
	No, I'm talking about, we're still on the same bullet point, but the reason why I'm breaking it up is because, I don't want to write on this, this is an exhibit, but Porta Potties, he made one allegation, I don't know if you've read Mr. Halbig's 16 points, but he breaks these down into separate points.
	One was the porter potties.
	Another was the sandwiches and fruit drinks that were brought in for the officers and eaten at whatever point in time he was claiming.
	And then there was a separate one where he was saying that people were eating lunch inside the school amongst the crime scene.
	Okay, and InfoWars just took Halbig's word for this, right?
	He was the source for those particular claims.
	InfoWars has done absolutely nothing to verify any of that claim beyond just listening to Halbig.
	No, there's been no independent research into those claims.
	InfoWars has never seen a video of anybody eating food inside the school or anything like that?
	I, uh, no.
	To my knowledge, I don't think there's ever been any video footage from the inside of the school.
	Okay.
	Um... As far as the porta-potties, InfoWars never did anything to verify when those showed up, right?
	No, I believe that was the subject of Mr. Halbig's FOIA requests, and then those were covered in subsequent broadcasts, his attempts to get that information.
	You know InfoWars has made attempts to secure the dash cam cameras of the police cars that were sitting in the parking lot?
	Has InfoWars?
	Honestly, I don't know.
	I know Halbig has.
	I know Halbig went up and did a FOIA request and he was disclosed that information.
	Well, maybe not disclosed, but he was given the opportunity to view the dash cam footage.
	Rob Dues also talked about the dash cam footage, right?
	He has, yes.
	So InfoWars knows that there's a video recording of everything that shows up into that parking lot?
	I don't want to say everything.
	Dashboard cam does not capture everything, but there is dashboard camera footage of the parking lot.
	Dash cam footage might have trouble detecting a mosquito showing up in that parking lot, right?
	Well, I'm not talking about mosquitoes, sir.
	I'm talking about angles.
	I don't know if it picked up the entire parking lot.
	Not every car at that time had dashboard camera footage.
	Now body camera footage is very prolific, but at that time I don't think anybody had body camera footage.
	So when I say I don't know if it captured everything, I don't know what the angles of those dashboards, the dashboard cameras are.
	So I'm not talking about mosquitoes.
	I'm talking about angles and whether it captured the entire parking lot.
	And the company doesn't know any of that either, right?
	No.
	Never tried to find out, right?
	No.
	As I said, we didn't do any independent research into this.
	Let's go to the next one.
	Sandy Hook father Robbie Parker getting into character.
	That's an allegation from Inside Infowars, right?
	That doesn't come from any source.
	That's just Mr. Jones and Mr. Do saying they believe Robbie Parker looks like an actor.
	So, yes, I think that originally this is an opinion of the video that they viewed of Mr. Parker before giving that interview.
	I believe it was the same day.
	And I'm sure, as you know, Mr. Du is a, or was, a theater major.
	And so in his opinion, based on his studies, when he saw that video, he believed it was getting into character.
	What does the company believe was happening there? .
	On that video?
	Uh-huh.
	I mean, this goes into the distinction we've been talking about, about how individual people in the company have their own positions, but the company does not have a position on that issue.
	I don't have an opinion on whether that was getting into character.
	How does the company feel about Mr. Jones and Mr. Ducey in that?
	I think that that's their opinion and they're entitled to it.
	No, okay.
	I can understand.
	That's what the company may feel about their right or their ability to say it.
	Does the company have an opinion on what they said?
	On whether or not this was getting into character and whether it was nice?
	No, not necessarily that so much.
	Not so much the accuracy, but sort of like, is the company proud of that?
	Am I proud of the... What Mr. Jones and Mr. Dew said about Mr. Barker?
	Is the company proud of that?
	I don't think the company takes a position on it.
	It's an opinion that belongs to two individual people.
	And the company doesn't have a belief that it's getting into character, but it's based on their opinion.
	Who owns the company now, again?
	Alex Jones owns the company.
	He's an individual, though.
	So, does the company feel embarrassed by what Mr. Jones or Mr. Deuce said about Mr. Parker?
	No, I think it's an opinion.
	Does the company feel any remorse about what Mr. Jones or Mr. Dew said about Mr. Parker?
	Remorse?
	Do I think that the company feels bad that Mr. Parker was upset about the coverage?
	Sure.
	But as far as the statement, it's an opinion and it could be drawn from, you know, it is an opinion that could be drawn from what you see on that video.
	Okay, so in other words, the company may have a greater latitude in terms of what it may think is appropriate or not appropriate or what it may be embarrassed of or proud of or remorseful for.
	It may matter whether the thing being said is a fact or an opinion, right?
	Sure.
	Okay.
	So there are this particular thing, you can say, for instance, this is not something that's, this is a personal viewpoint.
	I saw that and it looked, this is how it looked to me.
	So that's clearly an opinion, right?
	Yes.
	Okay.
	There are other things Jones and M4s have said about Sandy Hook that are not opinions.
	They are very much statements of fact.
	You would agree with that?
	I would agree that they have stated pieces of information that have been gleaned from other sources and taken those as fact.
	Well, let's go back to the Wayback Machine thing.
	Yes.
	They're not repeating anybody's words there, according to you.
	That's the sources of the Wayback Machine.
	They said that.
	InfoWars said, this is what the Wayback Machine says.
	I think we said, I'm not really sure how that came to their attention, I'm not sure.
	But I know that he put that screenshot on his camera.
	And I've never tracked down that screenshot or where it came from?
	I don't know where the screenshot came from.
	An FBI crime stat which says no murders occurred in Newtown in 2012.
	That's a piece of InfoWars independent research, right?
	Nobody else researched that?
	Yes, so that was, I did speak to our staff on this particular claim.
	So this is a source that was actually sourced from the FBI.gov website, a screenshot of which was put onto and attached to the article.
	It was written by Adan Salazar.
	I think he was deposed in connection with this article.
	Not here.
	Just wanted to make sure you understand.
	Not in Texas.
	Yeah, you're right.
	It was in Connecticut.
	And so essentially what happened with the article and it was not reported from another source.
	So it was original reporting in the context of Mr. Salazar because it was not found from another source.
	He went to the FBI.gov and he saw this and then the problem with the number, it does say zero for Newtown for 2012, but the problem for the article... Does it or does it say that for Newtown Police Department?
	If you'd let me finish, what it says is the FBI.gov stats is per town, not per department.
	So per town, Newtown says zero, but if you scroll to the very bottom, like at the end of the list of towns, there's an asterisk that says the state police do not report to the FBI.
	So that is the source of the confusion, so to speak, or the error for that particular stat.
	But it does say, if you scroll down to Newtown, It does say zero, but he didn't scroll all the way down the page to see the asterisk.
	And honestly, I don't know the answer as to why the state police don't report to the FBI.
	Every other department individually reports to the FBI their statistics.
	Okay.
	Just to make sure that you're not putting things on the record that are evidence.
	Sure.
	They absolutely 100% do report to the FBI.
	There's actually a 500-page report that that chart is generated from, has departments from every department in Connecticut.
	Has for the Connecticut State Police list the 27 children murdered at Sandy Hook has an asterisk saying these are the 27.
	I just want to make sure you understand.
	Okay, at the bottom of that article, not the article, but at the bottom of the FBI.gov, all that's really in there is the asterisk.
	It does not include state police statistics.
	That's all it says.
	Right.
	So he would have had to go and research the reason why that the state police did not report for those particular numbers and things like that.
	Or he would need to pull up the document referred to on that chart, the UCR.
	You know what the UCR is?
	Right, but what I'm saying is he didn't scroll all the way to the bottom.
	No, but up at the top of the document, where it says that these figures all here come from the UCR.
	He never went and got the UCR?
	No.
	All he did was look at the chart, saw the Big Fat Zero, and then reported it.
	And we talked about how this didn't come from anybody else.
	This was independent research done by InfoWars on Sandy Hook, right?
	Right, that was a report that he did not get from someplace else.
	Apparently, as far as I know, it was something that somebody had seen.
	He might have gotten a tip on, you know, hey look, this looks weird, go check it out, and saw it, and then he reported it on himself.
	That's Augusta.
	No, that's when I talked to Adan.
	That's what he told me, that he got a tip.
	So maybe he got a tip.
	No, he got a tip.
	And I mean, if you're asking me, he went just randomly to the FBI database because he wanted to check.
	No, he got a tip.
	Hey, check this out.
	This looks weird.
	And he looked at it.
	Who tipped him out?
	So that's a source of confliction, I'm not really sure.
	So he said he thinks that Mr. Daniels tipped it, but Mr. Daniels said he doesn't recall ever tipping him out on that.
	So in all honesty, I'm not sure where that tip came from, but Adan's position is that it was a tip.
	But one thing we do know is InfoWars does do independent research, investigative journalism into Sandy Hook.
	I would say that, on the whole, the answer is no.
	These are very out-of-character articles that we do not usually publish.
	So there were a couple here that Adan did that, as I said earlier, Adan was more into this than most of the other people involved in InfoWars.
	And so he did a couple of independent pieces that really were out of the realm of what is usually done.
	By the company.
	So like, for example, he did that Batman article.
	I don't know if you read that one.
	I know about that one.
	Right.
	So he got a tip from somebody on social media and saw that it was like, oh, OK, wow, that looks pretty cool.
	And he did this dive into, you know, the three Batman movies and then what that area was called in the comics.
	And then he wrote that article.
	So that was independent reporting on his part.
	It's really not The usual piece that the company would do.
	When Adan got tipped off that the appearance of the name Sandy Hook on the Dark Knight map could suggest predictive programming that suggests foreknowledge of the Sandy Hook attack being staged by globalist Illuminati types, he thought that was cool.
	Does he think it's cool?
	Is that a question?
	No, did.
	He did.
	He did think that was cool.
	Are you asking me whether he did think that?
	That's the word you used.
	I'm just trying to confirm it.
	I know.
	I think that what he thought was interesting and cool was that, oh look, here's this common denominator, not a common denominator, but look, Sandy Hook is referenced here and it wasn't referenced in the first video.
	And then he was interested because he thought that the names and the commonality between the names was cool.
	He did a similar article about a slasher thriller I'm about to ask you.
	Sandy Hook too, which he just found to be interesting just because of the name commonality.
	But as far as the other things sourced in there, I don't know that he thought that was cool, but the name commonality I think he thought was cool.
	Let's take a detour over to the slasher film.
	Sure.
	Sandy Hook Lingerie Party Massacre.
	Yes.
	Okay.
	You've read documents about that?
	I believe I read the article and I spoke to Adon about it, yes.
	And you got emails that you sent to people about it, right?
	He did tell me he reached out to the producer of that video.
	Have you seen those emails?
	Those have been in deposition before.
	Yeah, I don't know if I've read the specific emails.
	I may have, but I just don't remember.
	I know they exist, though.
	I'm just trying to remember if you remember Don saying to that person who ran that horror slasher movie blog, we know this is ridiculous, but we're going to run it anyway.
	Do you remember him saying that to him?
	I don't dispute, I don't remember in all honesty, but he could have very well said that.
	All it is is just an interesting commonality between the names, that's all.
	Well actually no, Mr. Salazar wrote an email to the guy who ran that blog basically accusing him of foreknowledge of the Sandy Hook attack, didn't he?
	Oh I don't know, I didn't read any email like that.
	So you don't remember, you didn't read an email back from the guy at the horror blog telling me don't ever contact me again you bunch of weirdos?
	No, I didn't read any email like that.
	When I spoke to Adan, Adan's position was that he received a response back from the producer that he had received a lot of communication about the name of the video following Sandy Hook and that he wanted to be left alone and he thought it was ridiculous.
	Okay.
	This next statement on the chart here that says, why didn't they let paramedics and EMTs into the building after 27 children were declared dead in eight minutes?
	Where does that come from?
	So this is another of Halbig's 16 points, and it's not just one point, it's a couple of points he breaks it down into.
	So he breaks it down into one, why didn't they let paramedics and EMTs in the building, and two, children were declared dead within eight minutes.
	Okay.
	So the source, the original source of that is Mr. Halbig.
	InfoWars did nothing to check that, right?
	No.
	Because we know paramedics and EMTs were let in the building.
	They were.
	I did read the portions of the final Sandy Hook report.
	That's something InfoWars had in its possession that Rob Dew went out and got in 2013, right?
	I don't know if he went out and got it, but it was sent to him.
	It was in an email chain.
	He did receive it.
	Yeah.
	Yes.
	And he's actually talked about it with other people?
	I don't know if he talked about it with other people, but I know they had it.
	The next one is, why was Adam Lanza's home burned down by the bank?
	Where does that come from?
	This might be a mischaracterization of the claim that Adam Lanza's house was bulldozed.
	I don't think it was burned down, but I think it's the claim, this goes back to that claim that the house was taken down.
	Alright, I understand we know about something from property records or something about bulldozing, but what I'm wondering is how do we get to burned down?
	That's why I'm saying I think it's a mischaracterization of that same claim.
	That the house is no longer standing.
	Mischaracterization by Jones himself.
	That it was burned instead of being bulldozed.
	Sure.
	That's what I'm trying to ask.
	That's Mr. Jones who did that.
	It's not somebody else who was responsible for telling Jones that it was burned down.
	No.
	Mr. Jones just mischaracterized it.
	Right.
	I think that it's a mischaracterization of the fact that the house is no longer standing.
	It wasn't necessarily burned down.
	Okay.
	Can you go to, in your petition, can you go to paragraph 54 for me?
	Sure.
	Let's just do a couple of others and then we'll take a break if that sounds good to you.
	Sure, I could use the bathroom.
	That would be great.
	Let's get through this one here.
	This is Sandy Hook Vampires Exposed on April 22, 2017.
	You're familiar with that video, right?
	Yes.
	Let me just go back to my chart.
	And I'll just ask you while you're looking because I'm sure you'll pull it up.
	You did watch this video?
	Yes, I remember watching this video.
	Okay.
	Yes, Sandy Hook Vampires Exposed, yes.
	Okay, so this video repeats a bunch of things said by Mr. Halbig.
	You'd agree with that?
	Yes, just give me one second while I can pull up my detailed notes on that video. just give me one second while I can pull up Okay.
	What was your question?
	First of all, I was wondering, is there any particular significance to the orange and yellow on these charts?
	That's just to differentiate between where it ends, where one video ends and one video begins, so I can easily see where the notes for one end and one begins.
	Okay.
	The question was, this video has a bunch of stuff from Wolfgang Haubig, a bunch of different claims from Wolfgang Haubig that are being repeated in this video.
	Um, so this is, if I recall correctly, this was an extremely long video.
	There are a lot of things that were talked about in this video, but some of the things that are in this video, for example, they also talk about Pizzagate, Iraq, children dying in Iraq, WMDs, you know, there's a lot of things that are talked about in this video.
	It's a long video.
	Right.
	So, but yes.
	How long are InfoWars videos usually?
	Well that depends because Mr. Jones is going to do, he'll do a three hour, three three hour segments and those will be broken up sometimes into shorter clips or sometimes it'll be just kept as longer clips.
	So like some of these videos were two hours long.
	Okay this one, what are we, do you think this is one of those?
	I think this was a very long video.
	I think it may be less than half that, actually.
	I don't think it was two hours, but it was a long video.
	Right, I think it's actually about 39 minutes.
	No, it's longer.
	So I have notes up here, for example, 59 minutes, 60 minutes.
	It's at least an hour long.
	Let's see.
	So, see this one, we have it as, we have saved it as a video file.
	A video file that we have is I'll read to you the name.
	R-U-N-1-J-K-A-H-W-T-X-L.
	And that video file was an hour long.
	So, you know, it may be accurate that there were some clips that were shorter that you may have access to, but it is a part of a larger video file.
	Okay, well, I'm not sure I have that.
	Excuse me, sorry, the volume's on.
	Okay, so is your understanding that this came out of a larger four-hour video?
	I don't know if it was four hours, but this clip, that particular clip, that, or not, I don't want to say clip, but that particular segment for, let's see, I'm sorry, I lost my place.
	April 22, 2017.
	No, no, I'm just looking for the title.
	So, Sandy Hook Vampires Exposed.
	What we have for that title is this longer, one hour long video.
	Okay, well what I'm trying to understand is that some videos, for instance, Owen Shroyer's little five minute video about Mr. Heslin.
	Yes.
	That's a clip from a full episode of the Alex Jones Show.
	It's a four hour show.
	There are other videos here.
	For instance, the video we just talked about, what Alex Jones really believes about Sandy Hook, that wasn't from an InfoWars episode, right?
	Because that's just recorded inside of Mr. Jones' home.
	You understand?
	You know what, I'm not 100% sure on that.
	I'm sorry.
	But in other words, there are some times where you might make a little special video just inside his home, might be a few minutes long.
	Sometimes they're going to come from a full info or show.
	Sometimes you might make a special video.
	Like I have a special video about Russiagate and it's 20 minutes long.
	Yes!
	This video, does this come from an Alex Jones show?
	Because I'm trying to find the full video.
	Yeah, so like I said, our full video, it looks like it was from a full show and it was more than an hour long.
	It was at least an hour long.
	My notes go up to an hour.
	Well no, that's what I'm trying to get at.
	An episode of the Alex Jones Show is four hours long.
	So does this come... There are three hour segments.
	So there are three hour segments.
	Do you mean all three hour segments?
	There are three three hour segments?
	No, I mean in general, including the pill stuff, where they're selling the pills and going off on that.
	You start watching an Alex Jones episode, it's four hours is the amount of time that passes when it signs off.
	Oh, okay.
	So the way that the files are saved by the company, they're not saved in four hour chunks like that.
	So this particular video file that has this particular title, Sandy Hook Vampires Exposed, on this date, that's our Uh, our name for the document, and it's not four hours long.
	Do you possess, does the company possess the entire episode of the Alex Jones Show on April 22nd, 2017?
	I possess this, this, this video, uh, under that name, you know, the R-U-N, uh, name.
	It's not four hours though.
	The thing is, is, yeah, the name Sandy Hook Vampires Exposed, for instance, is a YouTube title.
	Right.
	And that's not going to be... No, but it's the date of that video.
	It's the same date.
	Correct.
	Right.
	You're 100% right on that.
	And in fact, what's weird about the InfoWars thing, for instance, the Element Explorer video is June 26, 2017.
	That actually didn't happen that day.
	That was actually an Alex Jones episode from June 25th.
	Right.
	Those were the upload dates.
	Right.
	So what I'm trying to figure out is someday there was a full episode of the Alex Jones Show, which included all these comments that are now in Sandy Hook Vampires Exposed.
	Does the company have that full episode?
	Because we know this video is not the full episode.
	Right.
	So the video that I have, it's definitely longer than the video you have.
	If you say it's only 40 minutes long, this video that I have for that title on that date is definitely longer than that.
	So I don't know if you don't have this length of the video and it can be produced to you, that's fine.
	No, what I'm saying... But I don't know if your question to me is, do I know whether this is the full Alex Jones show?
	I don't know.
	Well, we know it's not though, right?
	Because Alex Jones show isn't just an hour long.
	I don't know, in all honesty.
	And like I said, this video, this is how it's saved on our system.
	Okay.
	We've talked, I think, about one of the claims in this video, which is that the police found people in the backwoods dressed up in SWAT gear.
	Does the company contend that that is true?
	I think that he was specifically referencing the issue that we were talking about earlier about the individual that was pulled out of the woods and put into the back of the police car and he was wearing SWAT gear.
	So that was the basis for that particular claim.
	Is that true?
	There is video of an interview with a person who says he saw a person being taken out of the woods in SWAT gear.
	Really?
	Yes.
	Okay.
	Have you seen that video?
	I have.
	Okay.
	So if I needed that I could get a copy of that?
	It's in the videos that I watch.
	So there's a witness who was there at Sandy Hook that day He was interviewed by the media.
	Because here's the thing, I know about a witness.
	I know about a witness who's on video who's talking about a gentleman named Chris Mandafronia.
	Chris Mandafronia is a Sandy Hook parent who came to the school that day.
	He was actually there to help his daughter with a gingerbread house project.
	And then he was arrested in the parking lot.
	He wasn't in the woods or anything.
	This is not the same thing.
	And Mr. Mandefronia was wearing camo pants.
	So what I'm wondering is, I'm trying to figure out, because I feel like after three years I know a lot about Sandy Hook coverage, and the idea that there was a witness in the parking lot that day or something who was talking to the news media and said somebody was arrested in SWAT gear is totally new to me.
	And so if that video exists, I want to try to be able to figure out where it is.
	And so do you know what, was it in an episode that you saw that?
	Yeah, so it's in one of these videos.
	I don't know if it's in my clipped notes.
	I think that Alex did a-- he did a show that was something to the effect of-- the title was--
	New York Times makes odd claim or baffling claim about the second shooter and it might have been in there, but he's shown this clip a number of times on a variety of different episodes.
	I've seen it multiple times on multiple videos where he cuts to an interview done with a person By a news organization who was there saying he saw a guy get pulled out of the woods, he was wearing camouflage pants, he was in handcuffs.
	He's saying it wasn't me, I didn't do it, and they put him in the back of a police car.
	Okay, hold on, because now we're back to camo pants.
	Yes.
	Right?
	Not SWAT gear.
	Well, I think SWAT gear, you know what, let me just think about what he said.
	Please do.
	I'm not sure if he said SWAT gear or camouflage pants.
	Okay.
	But that is the direct source of that information.
	So it's very possible that Mr. Jones saw an interview about Chris Mandafronia, a Sandy Hook parent, being briefly detained by police, who happened to be wearing pants that were camouflage, which is pretty common in the Sandy Hook area.
	I don't, you know what, I don't know and the reason is because there is also the reference to the off-duty SWAT officer that I had been seeing also in here who was never really identified or he might have been identified and I just don't know his name.
	But so it may have been that as well.
	But those two pieces of information in connection with his interview, that's the source.
	It's also possible that Mr. Jones' claim about somebody being dressed up in woods and SWAT gear is simply Mr. Jones conflating and confusing, mistakingly, all these different separate ideas.
	Right?
	Mandafronia, the reporters in the woods, all of this could just be conflated by Mr. Jones to just carelessly say somebody was arrested in Swagier.
	You would agree with that?
	Um, no, I think that the video, I think that the question that he was asking was, I've seen these sources say someone was pulled out of the woods and someone was arrested.
	We've not heard anything about this person.
	Why haven't we heard anything about this person?
	I think that there is a legitimate source, a question as to whether or not a person was pulled out of the woods and why and who this person was.
	And that was his question.
	Because I don't recall a question.
	What I recall him saying, I have it written down here, police found people in the backwoods dressed up in SWAT gear.
	That was one of the anomalies that he is pointing to as why he was questioning the Sandy Hook story.
	So he was pointing to those sources.
	Right, that's not a question, right?
	That is, here is an anomaly.
	Yeah, this is an anomaly, this is something that I think should be answered.
	It's an anomaly.
	What needs to be answered?
	We know the answer.
	Who is the person in the woods that was taken out of the woods?
	Got you.
	Okay.
	So the question is, who is this man in SWAT gear who was arrested?
	Who is the person that was taken out of the woods?
	Yes.
	In SWAT gear, right?
	So like I said, I don't know the exact quote and whether it was SWAT gear or camouflage, but the interview with the person that he was citing said one or the other and I'm not sure.
	Well, see, here's the thing.
	When I deposed Mr. Jones in the deposition you did read, there was a big discussion of, do you think that somebody wearing camo pants is SWAT gear?
	This was discussed at length for a good period of that deposition, how those two things are not the same.
	And Mr. Jones agreed those are not the same.
	They're not the same, no.
	He's not talking about the guy in camo pants.
	I don't know that he's not talking about the guy in Hamilton.
	So quite similarly, and I've seen this by Mr. Jones a couple of times, and this is something that he tends to do, which is, this is not a scripted proceeding, this is something he's just thinking out loud, it's coming out as the thoughts are coming, and sometimes he's conflating certain things.
	So like this is a perfect example of, did Adam Lanza's house burn down or was it bulldozed?
	So these are something that is maybe not exactly what was said.
	Maybe it wasn't swakier, maybe it was camouflage, and it came out when he repeated it as swakier.
	But that doesn't mean that the two things he's talking about are different.
	He might have just characterized it differently and it wasn't the same term that was used.
	Does that make sense?
	Sort of.
	Did he ever correct himself?
	On the issue of... Saying that the police arrested somebody in SWAT gear.
	Did he ever make a correction as to whether it was camouflage or SWAT gear?
	No, I don't think he ever restated the camouflage versus SWAT gear issue.
	And the reason Mr. Jones might get things wrong like that, saying that a parent in camo pants was in SWAT gear, or that a house that was bulldozed was burnt down, is because he's not particularly careful with the facts he puts on air.
	You'd agree with that?
	I wouldn't say that he's not careful.
	Like I'm saying, there's no teleprompter.
	It's not previously scripted.
	He comes in in the morning and is just talking.
	And these are his unfiltered opinions based on what he remembers or recalls about certain things.
	So, you know, you and I are lawyers, so obviously we know words matter, and so we try to the best of our efforts to use specific words by specific people, but he's not an attorney.
	And so he's just off the cuff saying what he remembers of that source, and what he remembered of that source was he remembers somebody in swakir.
	It may have been instead camouflage pants, but that doesn't change the fact that there was somebody taken out of the woods On that particular day in handcuffs that a witness saw and that there was a question about whether there was a second shooter.
	Okay.
	I want to make sure that I have you because now you've basically just stated that as fact and I want to make sure.
	Stated what as fact.
	I want to know the difference between these two things.
	If it is fact or if there's just a report.
	You seem to claim that Mr. Jones said that he saw reports of someone saying that someone was arrested in the woods, brought out in handcuffs from the woods.
	Right?
	In handcuffs, in SWAT gear, pants, or whatever it is.
	Are you saying that that happened?
	That there was that witness?
	No, that the company is saying that that happened?
	I saw that video, yes.
	Okay, I just want to make sure that's where we're at.
	When you say that, you know, we're lawyers, we know that words matter.
	Media organizations should know that too, shouldn't they?
	I think that the problem that The plaintiffs have is that this is not a large media organization.
	And I know you see that there's a lot of disorganization.
	There's a lot of things that weren't done probably as they should have been done.
	This was a organization that was put together by someone who got his start in like access, like, you know, as a, as a commentator, he started out with like five people in an office, and then it's expanded.
	And I don't think he ever knew how to do that appropriately.
	Like, I know a lot of lawyers, for example, that really only want to practice law and don't understand the business aspect of practicing law.
	And so are really, really great attorneys but are really bad business people.
	And I think that's what you see here.
	I think that this is an organization that grew really quickly from a person who didn't have a lot of savvy as to the business aspect of it and then found that he had some issues that he had to take care of later on.
	Well, I want to make a distinction between the business aspect of it and the journalism aspect of it.
	Mr. Jones was very savvy on the business aspect.
	Do you agree with that?
	No, I don't agree with that.
	Okay.
	Well, now you've got a man who, like you say, started with five people out of public access, and he created a media organization that's pulling in tens of millions of dollars in years in revenue.
	You agree with that?
	I don't know if it's tens of millions of dollars, but he does pull in revenue from the sale of some products, yes.
	Okay, well you read Ms.
	Karpova's deposition and you say you understand that between 2018 and 2016, the company generated $165 million in revenue, right?
	Whether the revenue is based off of the... I'm sorry, what was the number you said?
	$165 million.
	Between what years?
	- Between what years? - 2016 and 2018.
	2016 and 2018.
	- Let me just review what numbers. - I mean, we had the spreadsheets in front of her That's what she testified to.
	Yeah, I think that was the testimony based on our QuickBooks accounts.
	Is that correct?
	I don't think that was a QuickBooks account.
	I don't remember.
	But in any event, I think that, no, I don't agree that the business end of it is run particularly well, if that's the question.
	Man, I'd hate to see one run poorly, because that sounds really good to me.
	I mean, I don't make that kind of money, but that does sound great to me.
	It sounds good on paper, but when you look to the nitty-gritty of it, there's not that kind of money there.
	We'll talk about that tomorrow.
	Sure.
	Let's put that opinion on that.
	You would agree with me, though, that for an organization that's generating that kind of revenue, Mr. Jones is not operating the journalism aspect of that business on a level commiserate with the responsibility that would be owed by a business that large and with that large of a viewership.
	Do you agree with that?
	No, because we're not practicing journalism.
	See, Mr. Jones says you did, right?
	Like you read his deposition, he says this is journalism.
	No, what he said was I am a pundit, I am a commentator, and a vast majority of what we do is not journalism.
	I may do journalism sometimes, it's not mostly what we do.
	98% of what we do is commentary and is punditry and is basically a blogger commenting on other things we see.
	It is not journalism.
	Okay.
	I mean, I'm having a problem because multiple people have testified to me that they do journalism.
	And now you're telling me that it's 98% of the time they don't.
	Actually, I've read a few of the depositions.
	In fact, I've read Mr. Watson's deposition where he was quite clear that he was not a journalist.
	That's an interesting one.
	Mr. Watson's is super interesting because that one did, that one surprised me too, because Mr. Watson testified that Mr. Jones doesn't have journalistic ethics because he doesn't feel he needs to abide by those ethics because he's not doing journalism.
	Would you agree with Mr. Watson's conclusion?
	Um, I think that Mr. Watson, what he was saying was that because we do not practice journalism and we're commentating, that those rules don't really, aren't, aren't something that they should be aware of or should be practicing just because we're not practicing journalism.
	So I don't think it's accurate to say, oh, well, he doesn't think he should abide by these rules, and these are rules he should be abiding by.
	I don't think that's an accurate characterization of what Mr. Watson said.
	Well, Mr. Watson directly testified that TOR should be held to a lower standard because it's not a, I believe what he said, mainline journalism operation or middle-of-the-road journalism operation.
	I don't think it's lower standards.
	I just think those particular journalistic standards don't apply.
	Okay.
	So, Mr. Jones doesn't have to be as careful as other media organizations because the nature of what he does isn't careful, it's punditry, right?
	It's punditry, yes.
	Okay.
	When you say that he doesn't have to follow those rules, by rules one of the things you're referring to is the sort of traditional checks and balances on truthfulness, right?
	That are found in journalism.
	I think if you're a journalist and you're doing an investigative reporting, you check your sources and vet your sources.
	I think that the model, the business model of free speech is that they are relying on the source that they are pulling from to vet their own sources.
	Okay, I get what you're saying.
	All right.
	Let's go to paragraph 44.
	Is this a good time to introduce the lady room?
	Yeah, let's do it.
	Okay.
	Let's do it.
	Thank you.
	We're on the record at 333.
	Alright, I want you to go now to paragraph 44 of that petition.
	Sure.
	Okay.
	And that talks about a November 18, 2016 video called Final Statement on Sandy Hook.
	Okay, let me just go there.
	I do recall seeing that video.
	November, what date did you say?
	Eighteen.
	Eighteen?
	Okay, the date is just not in the petition.
	Okay, yes.
	Okay, so first of all, did you watch that video?
	Yes.
	Okay, so there's been some discussion, and me and Mr. Jones have talked about this in Deposition 2, of a Bloomberg email Where Bloomberg allegedly sent an email the day before Sandy Hook telling us people get ready for the next 24 hours for a big event.
	Yes.
	I've been trying to figure out where that comes from.
	Can you tell me?
	So, as best as I can see, but let me pull up my handy dandy notebook and I will tell you specifically.
	Alright, so MWUD.
	UD.
	Okay.
	Okay.
	Let's see.
	If I hadn't run out of tabs, this would have been easier.
	So I apologize.
	I'm going to do this.
	I'm going to do this.
	I'm going to do this.
	So I think this is another, as far as I can determine, because I did try to look into the source of that claim.
	As far as I can tell, just based on my interviews with, oh here it is.
	As far as I can tell, based on the context of that statement and me speaking to Mr. Jones, that email or a reference to an email is based on Mayor Bloomberg at the time was in this kind of coalition of other mayors that were for gun control so to speak.
	I believe the Aurora shooting was very close in time to the Sandy Hook shooting and essentially there was an internal communication between the Bloomberg Uh, people just in connection with that coalition, um, just telling his people to get ready for the next whatever the next event is, because another event is going to happen at some point.
	And let's be ready to put forth our, you know, be ready to run with it when it happens.
	As far as it being the day before, I, or a representation about the email going out the day before, I don't see that there's any way that that email went out the day before, or if it went out the day before.
	I don't know when that email went out.
	But that's what he's referencing.
	Okay, so everything you just told me is just what Mr. Jones told you?
	Right.
	I've not ever laid eyes on such an email.
	I don't recall seeing any such thing in the production.
	So based on my communications, that's what it is.
	And it very well may be another example of, like, for example, in Exhibit 10 where you're seeing house burned down versus it was bulldozed.
	There's this internal email, and he's representing that it was the day before when, honestly, I'm not really sure when it was or How far in relationship it was.
	You don't even know there was an email.
	I don't know where he saw that.
	No, I don't see the document that he sourced.
	You don't have anything else to give me other than basically what Mr. Jones said on the show, right?
	Same stuff.
	As far as that particular claim, yes.
	Yeah.
	Mr. Jones had told me he could find this for me.
	I have not been able to locate anything like that.
	Okay.
	What did you do to try?
	I asked Mr. Jones.
	I have spoken to other people, like I said earlier, the other employees that I spoke to, and I've looked through the documents that have been produced.
	Did you read the article Aaron Dykes wrote about this?
	I may have.
	I don't know.
	Honestly, I read a lot of documents.
	All right.
	Well, because, I mean, at one point Mr. Jones is discussing this whole thing.
	He puts up an article on InfoWars, which I don't have, which isn't available anymore.
	Okay.
	But it's an article from Aaron Dykes.
	Um, and apparently talking about this Bloomberg stuff.
	And I'm wondering if that didn't get in your notes somehow.
	Um, if I may just look at my notes.
	Sure.
	So no, I don't have anything like that in my notes.
	But I do recall him mentioning a Bloomberg email.
	At various points he has termed that email as the day before.
	Sometimes he's said a different time period.
	But as far as that particular email goes, I don't have a copy of it.
	When you just said he, you're referring to Mr. Jones, not Mr. Dykes?
	Right.
	Okay.
	You understand who Aaron Dykes is, right?
	Yes, but I have not spoken to Mr. Dykes.
	Okay.
	That's one of the things I wanted to ask you about.
	Mr. Dykes, during a substantial period of Sandy Hook coverage, was one of the primary writers at Enforce, right?
	He was a writer.
	I don't know if he was a primary writer.
	Okay.
	I don't think he was in a supervisory position, if that's the question.
	Enforce doesn't have titles.
	They don't have titles, but that doesn't mean there's not a person that's in a supervisory position, like Kurt Nimmo was in a supervisory writer position in that time period.
	Okay.
	And you don't think Aaron Dykes was?
	I don't think so.
	I think in that time period, Kurt Nemo was the, in that supervisory position.
	What makes you, what makes you think, who'd you talk to about Aaron Dykes?
	What do you mean talk to him?
	I mean, you had to come up with, you didn't, before this deposition, you didn't know Aaron Dykes from anybody on the street.
	And now you're telling me he's not a supervisory person.
	So who did you talk to?
	I didn't talk to anybody about Aaron Dykes.
	I talked to people about who was in a supervisory position during that time period.
	And I was informed it was Kurt Nemo.
	Well, there were other people during that time period who had supervisory positions too, right?
	In other departments?
	In writing.
	As far as I know, Kurt Nemo was the one that was in the supervisory position in this time period.
	Okay.
	He left around 2018, at which point Kit Daniels became the person in that supervisory position.
	Well, you remember Kit Daniels testifying that Michael Thelen was the person in charge of fact-checking at InfoWorks from 2014 to 2018.
	Fact-checking?
	He was the editor, the supervising editor who checked other writers' work.
	So fact-checking, I don't agree with that.
	I don't know if that's what he said, but there is nobody that checks facts like that.
	During this time period, as well as now, currently, the general rule is to make sure that your article has more than one source.
	So there is checking of the articles to make sure that they're appropriately backed, but I don't want to say that they are fact-checked by anybody.
	So, for example, now my conversation based on Kit Daniels' interview with him is basically they write the articles in WordPress and the supervisor whoever that is does have access to review that material prior to but as far as quote fact-checking I don't think that they're doing that I think they're doing it to make sure that the article is appropriately sourced but they're not necessarily fact-checking okay you know who Melissa Melton is right
	I'm sorry I don't that's Aaron Dykes wife she She was also a writer at Infowars during this time.
	Okay.
	I mean, in other words, what I'm saying is Aaron and Melissa are the source of a lot of the early Sandy Hook stuff, right?
	The early Sandy Hook stuff?
	Yeah.
	How early are you talking?
	Well, I mean, let's go ahead and just talk it anyway from the day of Sandy Hook till about... Let's go ahead and do it from the day of Sandy Hook till about two years out.
	You would agree that Melissa Melton and Aaron Dykes were a source for a significant amount of that material?
	I don't think so.
	Here's my concern and here's what I think.
	A lot of this material, like I said, is just reposting of other articles that are already out there.
	Sure, there are articles on Sandy Hook that they were reposting.
	So, at any given day, the writers are putting out dozens of articles a day, and most of those articles, like we've said, are not original content.
	Most of those articles are, I saw another article in CNN, I saw another article on Drudge, I saw this article, and then resummarizing it, maybe putting our spin on it or our opinion in there, but ultimately it's a report on another article.
	So, if she was, Melissa, was doing that between when Sandy Hook happened and 2015 or 2016, sure.
	I'm sure that's, she was one of the writers.
	If she's one of the writers, that's what she would have been doing.
	Okay.
	So, Aaron Dykes, Melissa Milton, two people you haven't spoken to, right?
	I have not spoken to them, no.
	Michael, Mikael Phelan, you haven't spoken to him either.
	No.
	Okay.
	Let's talk about in that article, I mean in that video in paragraph 44, the statement that the school was shut down, that's what the records show.
	What records are being referred to there?
	I'm sorry, which paragraph are you referring to?
	I'm referring to the final statement on Sandy Hook, which is paragraph 44.
	Right.
	It's a November 18th, 2016 video.
	One of the statements of fact in there was the school was shut down, that's what the records show.
	What are the records that he's talking about?
	Which allegation?
	Which paragraph is that allegation in?
	I'm not even positive it's in the petition.
	Well, that's what I'm asking.
	I'm sorry.
	I don't know that that is made in that video, but I will review my notes and we will see.
	Okay, so, in this particular video, there appears to be, um, there's a bunch of claims made in this video.
	Indeed.
	One of which appears to be that the school was shut down, and again, he shows the website to that school, and it's traffic from 2008 to 2013, and then cites the Wayback Machine.
	No, I know that happens in the point of the video, is that the school has no internet traffic.
	Yes.
	I'm talking about later in the video, Mr. Jones says, and that school was shut down, that's what the records show.
	That's what the record he is referring to as the Wayback Machine.
	Well, he refers to in other videos that we're going to talk about, he refers to emails between the school board and the school, showing that the school was shut down.
	Those are the records, right?
	I don't know that from this video.
	That's not in this video.
	Okay, well I guess we'll have to get to it when we get to that in another video.
	Right.
	The other one is the infamous video that Mr. Jones shows of kids going around in circles around the building.
	You know the video I'm talking about?
	I believe it's mostly what he's referring to is some photographs, but I think there is a video of kids in a parking lot that he refers to a few times.
	There are a couple of photographs.
	A parking lot?
	Not of the school?
	I don't know where it is, and I think Mr. Jones says that.
	Well, that's what I wanted to know.
	Right.
	I don't think Mr. Jones knew if it was at the school or if it was another location, because I know there was an issue about the firehouse as well.
	Yeah, well, he said it was the school.
	We know that.
	I think he believed it was the school.
	Right.
	Okay.
	So that video and that allegation that there were kids going around in circles around the building, where did he get that video?
	Where did he get that allegation?
	From that video that he saw.
	Right.
	That's what I'm saying.
	Where's that video come from?
	That's a video that he would have found on the news that was reported in the news cycle around that particular time.
	So that's his opinion based on what he was seeing.
	So if he's seeing this video and he thinks it looks like kids are walking around in circles, that's his opinion.
	Alright.
	I'm having a bit of the same struggle I'm having with Ms.
	Karpova's deposition, which is that, like any good lawyer, I come into this case, and honestly, there's a lot of things I don't know.
	There are a lot of things I don't know.
	More than average on a case do I don't know.
	But there are a lot of things I do know.
	And one of those things is that the video did not come from the news media.
	That video, as I think you saw in that video, is very edited, because it starts having the people go back, forward, back, forward, back, forward.
	And then it says in titles on the video, Going in circles, right?
	Somebody made that video.
	Somebody edited the video.
	Yeah, I don't know the answer to that.
	Right.
	There's a source of this.
	Somebody took a piece of footage that they saw and edited and tried to make it seem like this was supporting the conspiracy of Sandy Hook.
	And then Mr. Jones or somebody at InfoWars saw that and started using that on their show.
	I want to know where it comes from.
	I don't know the answer to that.
	Okay.
	And as far as trying to hunt down that video, you didn't do anything to try to hunt down where that allegation comes from.
	As far as I know, Mr. Jones saw a video and that was what he was basing his opinion on.
	If he saw the edited version of the video, and that's why he was basing his opinion on it, I don't know.
	But I don't know where the edited version came from.
	Right, we know it didn't come from the news though.
	I don't know where he saw it originally, so I can't say.
	So it could be the same thing as the judge report.
	So the judge report had that edited video of Dr. Carver's interview.
	I don't know if it came from somewhere like that.
	I don't know where he saw this video or if he saw it edited.
	I just don't know.
	Let me just stop for a second, because you said the Drudge Report had an editor.
	Oh no, it's Drudge.
	It's zero point now, I'm sorry.
	Zero now.
	I'm at zero, Hedge.
	I misspoke.
	For this video, the final statement on Sandy Hook, can you tell me what employees were involved in making, researching, producing this video?
	Well, as far as making and researching it, Mr. Jones researched this video, so his position, so let me just see my notes, final statement on Sandy Hook.
	Okay, so based on my conversations, it was researched by Rob Dew and Mr. Jones, but as we discussed earlier, as far as researching the videos, the host's research The content for the videos and the producers don't have say in the content of the videos.
	So, I mean, I could check the document that we produced earlier as far as whether Melinda did a research for who was working that day, but again, these are not the people that would have been involved in the content.
	Well, here's my problem.
	So I know that you don't know... It's not on this.
	Okay, so you don't have a list of employees who were involved in the video?
	For that day, no.
	Okay, so if I wanted to know every employee who was involved in that video and what their specific roles is, that's something you can't tell me?
	No.
	Okay.
	In terms of all of the things, who edited, who created the screenshots, who put all the stuff together that went up on the screen in front of Mr. Jones, we don't know that.
	Well, Mr. Jones, there was the video clip.
	So in that particular video, he had put up on the screen the video clip of the witness regarding the second shooter.
	So I know that there was a question you had asked earlier where this video from this witness was.
	So this is shown in that video.
	OK, I'll go check that.
	Then there's a CBS News clip from John Miller reporting for CBS regarding the second shooter.
	So there was a CBS broadcast.
	Stating second shooter.
	He put that on the screen.
	There was a clip of Obama giving a press conference after Sandy Hook because he has this claim about fake crying and Obama was fake crying regarding the children.
	So he put up the clip of Obama's press conference.
	He put up the clip of Robbie Parker.
	He put up the clip of Lieutenant Vance regarding misinformation.
	He put up some clips from the FOIA hearing.
	He put up the Wayback Machine.
	Okay, Mr. Jones didn't put up any clips.
	He doesn't actually do that.
	No, the producer.
	So like we discussed earlier, he would tell his producers, I have clips for this, go find it.
	And so Mr. Jones would be responsible for saying, I want these clips.
	And they would just pull them.
	That's what I want to know, right?
	Right.
	It's because I don't know where that thing comes from with the kids going around in circles.
	I want to find out where it comes from.
	Oh, I don't know where the, like I said earlier, I don't know where that originated from.
	I know you don't.
	Right.
	So it's not useful to talk to you.
	I want to know who I should be talking to.
	Who's the producer?
	The producer for that?
	Honestly, I don't have that.
	Let me see.
	So for that day, it would have been in 2016.
	I mean, Daria would have been there during that time period.
	Well, we know from her testimony that she wasn't the one, right?
	Right.
	I don't think she was the one.
	Okay.
	Alright, well let's go on to the next video.
	Let's go to paragraph 38.
	Sure.
	You see a video there from July 7th, 2015 entitled, Government is Manufacturing Crises.
	Right?
	- Okay, let me just go to my July 7th. - I believe you're gonna find two different videos Let me know which one you're referring to.
	I have the video Retired FBI Agent Investigates Sandy Hook Mega Massive Cover-Up.
	That's the next paragraph.
	We'll talk about that.
	Right, but I don't have in my chart the one before that.
	Okay, so the video that's identified in Plaintiff's Petition called Government is Manufacturing Crises, you haven't watched that?
	I don't, no, I don't have it on my list, so no, I didn't watch it.
	Okay, so as far as the claims made in that video, if there are any claims that are in that video that are unique to that video, you can't speak about them today, right?
	No.
	Okay.
	But I can, I can talk about the other ones.
	Honestly, if you, let's just stick with this video.
	Sure.
	Right?
	There's no point in asking you any questions about this video.
	You didn't even watch it.
	I didn't watch that particular video, no.
	Let's move on to the next one.
	Paragraph 39.
	You say you do have a copy of this video.
	July 7, 2015.
	Retired FBI agent investigates Sandy Hook mega massive cover-up.
	Yes.
	Who's the retired FBI agent?
	Rob Dew's uncle.
	Did you talk to him?
	No.
	Did you try to talk to him?
	No.
	Okay.
	It says the ambulances came half an hour later.
	Do you have a source on that?
	Let me just pull up my notes on that.
	JCO.
	And I'm going to ask you for the deposition tomorrow if you can make sure.
	I'll get you some tabs if you need them, if we can tab up everything that you're going to be using tomorrow.
	Thanks.
	Just so we can maybe get you on your flight.
	Sorry, I don't have a printer at the hotel, so I was relying on some other people to print it out for me.
	And didn't have enough tabs.
	I'm going to use the paper.
	Ah, here we go.
	Okay, I'm sorry, what was your question?
	I don't even remember.
	Ambulance came half an hour later.
	What's the source on that?
	So according to my notes, this is a broadcast that Rob Dew and Alex Jones were talking about the FOIA hearings.
	And they go through Halbig's 16 questions and why the official story doesn't add up.
	So these are one of Halbig's 16 questions.
	The ambulances came an hour and a half later is one of Halbig's 16 questions.
	Is that your testimony?
	Well, like we talked about, they've expanded over time.
	Sometimes there's 20-something questions.
	It started out as 16 questions, but he's expanded those over time.
	So if I go and I look through Halbig's stuff, I will find him somewhere saying the ambulances came an hour and a half later?
	I think what he says is the ambulances were not allowed through, that it was blocked, and that the ambulances were not allowed up to the school.
	So I think that was his conversation regarding the ambulances.
	Okay.
	When they say DHF an hour and a half later with the time stamp said put up signs saying sign in here, that's from Mr. Badondi going up to that hearing and reporting on it, right?
	No, that's originally from Mr. Halbig.
	So Mr. Halbig produces this photograph and says, where did this sign come from?
	And made a representation that it was taken an hour and a half after the shooting.
	And then he submitted some FOIA record requests to the town as to where the sign came from.
	So again, this is another one of Mr. Halbig's 16 questions.
	Right, well what I'm saying is Dan Bodondi went to to Connecticut with Mr. Halbig.
	He went to the FOIA hearings, yes.
	Right, and did reporting on the ground from the FOIA hearings.
	He covered the FOIA hearings.
	One of the things that Mr. Badondi told the company in his reportings is that Mr. Halbig was able to prove that DHS approved this sign-in sign and put it out in front of Sandy Hook.
	No, that's not what he said.
	He said at the second FOIA hearing, what came out at the FOIA hearing was that the town does not have any records relating to this sign.
	And then the questions were, how could it be?
	Where did the sign come from?
	And then the town disclosed that they believe that the Department of Homeland Security had ordered that sign and that's why they had no records.
	Right.
	So that's where the origin of that statement came from.
	Right, so that's not something that came out of Wolfgang Haubeck's 16 points.
	That's something that came out of the FOIA meeting that he participated in.
	That DHS ordered that sign?
	Sure.
	Yes, that came from the FOIA hearings.
	Right, and that was reported to InfoWars by Dan Badondi.
	Yes, he videoed it.
	Right, and Dan Badondi covered Multiple times went up there with Wolfgang Haberg to Connecticut, right?
	Well, he lives up there.
	He lives, I want to say, in Rhode Island or something.
	He doesn't live very far.
	He doesn't live here.
	But yes, he did go there with Wolfgang Haberg.
	That's all I'm asking.
	He went to multiple trips.
	And I know you want to try to say, well, look, it wasn't that big of a deal because he lives right next door to there.
	And I know you throw in a little advocacy like that.
	But I'm just trying to ask you simple questions.
	And I'm going to tell you, if you want to make that plane flight, those kind of answers are not going to help you.
	I'm just trying to help you out because if you want to make that plane flight.
	No, I'm saying this takes longer time.
	This takes more time when you add in an answer to a question that I'm not asking.
	When all I'm asking, the very simple thing I'm asking, is did Dan Badondi go multiple times to Newtown?
	And you start going off to me about, well, yeah, you know, he lives near there and all this sort of stuff.
	You know I don't care that Dan Badondi lives near Newtown.
	All I'm trying to confirm is a very simple fact so I can have it for the record.
	Did Dan Badani go multiple times to Newtown?
	I'm not threatening you in any way.
	I think he went two or three times, yes.
	All I'm trying to communicate to you is the more times we have answers that don't match up to what we're talking about.
	Talking about Leonard Posner's ex-wife and what she believes and things like that.
	Anytime we do that is time that I would not otherwise be spending with you.
	And I just want you to understand that we're on the same page that way.
	Because I do want to get you on that flight.
	I don't want to be the reason that you're not on that flight.
	And so that's what I'm trying to tell you right now.
	And I promise you, because I know that came out of your mouth, it is not in any way a threat to you.
	I really do want that to happen.
	Because I don't want to be here late tomorrow.
	Believe me, I've got better places to be.
	Dan Bodondi, who's done multiple reports with Wolfgang Haubig from Newtown, reporting on that FOA process that has made it into InfoWars videos, have you spoken to Dan Bodondi at any point?
	No.
	Did you try to speak to Dan Bodondi?
	No, he doesn't work for the company.
	Is that the reason you didn't speak to him?
	Because he doesn't work for the company?
	No, that's not the reason, but he doesn't work for the company.
	And he doesn't... I don't think he's associated anymore with the company.
	You spoke to Nico?
	I did.
	Okay.
	I just want to make sure.
	Nico doesn't work for the company?
	Not anymore, no.
	So the idea of whether or not Dan Badondi works for the company is irrelevant to whether you talk to him, right?
	That isn't what decided whether you were going to talk to him.
	No, it's not.
	OK, again.
	Yeah.
	This is the video I wanted to put a pin in earlier.
	This is a video where Mr. Jones said, we have the emails from the city council back and forth and the school talking about it being shut down a year before.
	What is he talking about?
	Is this the video where we're still on the same video?
	On paragraph 39.
	Okay.
	So here, and I think this is another example of the characterization of a certain piece So I think that what he's referring to here is also specifically one of Halbig's claims that
	Mr. Halbig has some emails that are not necessarily confirming that the school was closed, but emails relating to the condition of the school and his requests in connection with the condition of the school, because certain reports have to be generated by certain times.
	And in his opinion, those documents You don't even know that there's emails.
	wasn't functional because those reports were not produced by the school or by the town this is what you think that that's what it appears to be referencing in here but again it's it is not emails confirming that the school was shut down you've never even you don't even know that there's emails have you seen these emails I've seen discussions from mr. Halbig Wait, let me just go back.
	So, Mr. Halbig requested, put in a bunch of FOIA requests.
	Some of those FOIA requests included requests that are in connection with an environmental study done at the school.
	Those environmental studies in his research opinion estimation based on his research of the legal regulations up there is that those records need to be produced within a certain period of time.
	And the fact that the school did not have any such records responsive to that request show the school was not in operation.
	Again, that isn't the same thing as there's emails being back and forth.
	And I agree with you, I've not seen any such emails.
	But I think that it's relating to those That is the inference you've been able to make?
	Yes.
	Just by what you think you know about Mr. Halbig and what his claims were, right?
	Not just about that claim, but about the things that Mr. Jones is saying in this video.
	Okay, and so you were able to arrive at that inference?
	Right.
	Without ever having to see the emails or anything like that?
	I'm not in possession of any such email like that.
	I have not reviewed any, seen any emails in the production like that.
	Okay, and you didn't talk to Mr. Halbig, right?
	No.
	Let's talk about paragraph 36.
	March 4th, 2015.
	You see that?
	Yes.
	New bombshell information, Sandy Hook information, inbound?
	Yes.
	We've talked a little bit about this video before, so we already know the guest was Wolfgang Hauwig.
	Yes.
	You've watched this video.
	Yes.
	Have not spoke of Mr. Hauwig.
	No.
	Okay.
	Have you reviewed documents about the sourcing of this video?
	Yes.
	Let me just... Okay, here we go.
	7IB.
	Oh yeah, this is the one.
	We already talked about this video.
	We have talked about it a little bit.
	I'm wondering what documents you've reviewed to about the sourcing of this video.
	I'm wondering what the answer is.
	Okay.
	Sourcing of this video.
	I don't want to know the source of different claims.
	I want to know first, what documents did you review about the sourcing of this video?
	So the sources that are specifically cited in this video, there's a couple of articles, well first there's Mr. Halbig's website, he posts up there, SandyHookJustice.com, then there's an article on InfraWarsNation all over the world, admit to false flag terrorism.
	Then there's another article, six-year-old child suspended for making gun shape with hand.
	Then there's another article, InfoWars article, shooter James Holmes and DARPA weird science.
	Then there's some cuts to news footage about the man in the woods.
	And then most of the sourcing here are things that are how big a saying.
	Okay.
	So first of all, of all those documents you just listed off to me, you reviewed all those documents?
	Have I read each and every one of these articles?
	I'm not sure that I've read each and every article.
	That was what my question is.
	Sure.
	I know you wanted to tell me what was sourced and all of this sort of stuff, a different question.
	I just want to know what documents, physical documents, relating to this video you've reviewed.
	Okay.
	And honestly, I don't know whether I reviewed all, I read each and every source.
	Okay.
	And you certainly didn't contact each and every source, right?
	No.
	Okay.
	And then a lot of these claims come from Wolfgang Haubig, right?
	Right.
	Have you reviewed any documents about the booking process for Wolfgang Haubig for this particular show?
	You mean how did he come to be on the show that particular day?
	And what materials did he provide the company prior to his booking about this booking?
	Anything like that?
	Okay, and that's a good question.
	So I did do interviews with Nico about how When guests are booked on the air, the procedure by which that happens, and whether after that anything else subsequently happens as far as resourcing their material.
	So usually how the process goes is the person host, I should say, will go and say, I want to bring this particular person on, and then Nico or whomever the person in charge there is will pull some information about the person just to basically verify this person is the person they say they are.
	Because they do have people that pretend to be other people, aren't real people, there's fake Facebook pages, I mean you know how that goes.
	So they will pull some information off the internet to just verify this person is in fact who he says he is.
	Provide that to the host.
	The host will make their own determination as to whether they want this person on the air or not.
	And then the person will just be booked.
	So Nico essentially was just the liaison.
	As far as how Mr. Halbay came to become a guest, essentially Mr. Salazar wrote that article in early 2014.
	It was an article about Mr. Halbig being quote-unquote threatened.
	By the police.
	And that came to the attention of Mr. Knight.
	Mr. Knight reached out to Nico to say, I want to book this person.
	At the time, Mr. Knight had the authority to book his own guests.
	Now that's not the case.
	Well, he's not there anymore, but now that's not the case.
	And so Nico proceeded to just pull some basic information about his website, about Mr. Halbig's website.
	Okay.
	so that it can be put onto the broadcast when it's done during the interview.
	Okay.
	And that's pretty much how Mr. Halbig came to be a guest.
	Now, after that, he's already a guest, and so there's not anything else done after that to either pull more material from him or anything like that.
	Okay.
	So in terms of what information Mr. Halbig provided the company that prompted his booking on this show on March 4, 2015, you haven't seen anything like that.
	All right.
	On this particular show?
	For that video.
	No, as far as it appears, it appears that Mr. Jones is talking about the issues specifically related to the copyright claims on his YouTube page, and that may have been the impetus, but I don't know for sure.
	Again, here's another strange one for me because I was in Ms.
	Karpova's deposition.
	There's a document discussed in her deposition, that's emails between Mr. Halbig and Nico, about this show.
	To book his show?
	Yeah, and the materials that Mr. Halbig provided.
	Have you not seen that?
	I saw an email that doesn't have any documents attached.
	Is that the email that you're referring to?
	Nope.
	I saw one email like that, but like I said, it would have been at the behest of the host, so Nico isn't the one that would say, okay, well, I want to get Mr. Halbig on.
	I don't know what prompted that series of emails.
	You know what I mean when I say the Super Bowl picture?
	Yes, I know the Super Bowl picture.
	Alright, you know that was provided to the company, right?
	For Mr. Halbig?
	Yes.
	For this episode.
	That picture was not aired on this video.
	I didn't.
	I never said that.
	It was provided to the company, but it was never used.
	And the company thanked them for it, right?
	If that's what the email says.
	Right.
	Okay, so what we do know is that before Mr. Howbig was put back on the air, you had an InfoWars person, the person who's responsible for getting the guests set up and coming on the show, had been directly provided a copy of the Super Bowl picture.
	I don't agree with your phrasing.
	I'm sorry.
	I think what you're saying is that Nico requested documents and that he provided them and he thanked him and he reviewed what was attached prior to thanking him as if he was actually going to use these documents.
	And I don't know that that was the case.
	I would like to know.
	I don't think that that was the case, especially because it wasn't used.
	I don't know that Nico reviewed those documents.
	I've got to make this real clear for you and that this is going to be true tomorrow too.
	I'm not terribly interested in answers that start with, I don't think, or I think, or it might be, or it could be, or my assumption is, or my inference is.
	Going forward, I'm not interested in those answers.
	What I want you to tell me, if you can testify to today, is that prior to this episode, that there were communications between Nico and Mr. Halbig that included the Super Bowl picture, and you did not review them before coming to this deposition.
	I reviewed the email with the Super Bowl picture.
	I've seen that.
	But any other emails besides that, I don't know if I've reviewed anything like that.
	If you could point me to it and I could look at it, maybe I could testify a little bit better, but as I sit here right now, I can't recall.
	I brought you here to point me to things.
	I'm tired of pointing you to things.
	Sir, there's a hundred thousand plus documents.
	Yeah, so maybe you shouldn't have been the only designee.
	I'm sorry, but... A sorry's not going to cut it.
	I can tell you that.
	Ms.
	Blunt knows what's coming up and it's not an apology.
	That's not what's happening.
	Okay.
	But I understand, I completely sympathize with you.
	Like I've said before, I understand that as you as one person, no way you can answer all these topics.
	There is no way you can possibly assimilate all of this stuff.
	Do you agree with that?
	Is there a question?
	I just asked her one.
	Does she agree with that?
	Yeah, that's a question, Jacqueline.
	I can't cite to a specific page based on a hundred thousand pages of documents.
	It'd be impossible for you to do that.
	It's not possible, humanly possible.
	Right, for one person to cover any number of this stuff.
	I don't think so.
	Right.
	Let's talk about paragraph 35.
	Yeah, you're right.
	Let's talk about paragraph 35.
	Do you see paragraph 35?
	Yep, February 12, 2015.
	You don't need to go looking because you haven't watched this one.
	Okay.
	So this is the video we discussed earlier about Mr. Posner.
	Do you remember us talking about a video about Mr. Posner and his address?
	Yes.
	Okay, and so this is a video One of the things, we had just talked about how it is difficult if not impossible for you to testify about the broad depth of all of these things, but it's certainly impossible to testify about this video if you haven't watched it, right?
	I don't have this video, so no, I can't testify as to it.
	Yeah.
	And you don't know the title of it, do you?
	Because I've been trying to figure that out.
	No, I don't.
	Okay.
	Do you know that there are people interviewed on that show who gave information about Mr. Posner?
	I don't know anything about the video, sir.
	Okay, have you reviewed any documents about the video?
	Aside from my conversation with Mr. Du about the video, I don't recall seeing much in the production, but if you can direct my attention.
	Are we on 11?
	Okay.
	Can you tell me if you've ever seen that before?
	Okay.
	I'm going to make a little bit more of a cup of tea.
	Yes.
	You talked to Dr. Jones?
	No.
	Dr. Jones, unfortunately, is not a good source of information.
	What do you mean by that?
	I mean that he has some medical issues that makes his memory a little poor.
	Okay.
	So it wouldn't have been a very productive conversation.
	When did he leave the company?
	Um, that I, that I do not know.
	Very recently, right?
	I don't know.
	I know that he still has ownership interest in the, uh, in PQPR, but aside from the ownership interest he has in PQPR, I don't know when he left free speech.
	In fact, because of the circumstances of this lawsuit and what it may mean, It was advantageous if Mr. Jones no longer worked for the company.
	You would agree with that?
	No.
	I don't know that Mr... I don't know what Dr. Jones would have to do with that at all.
	Really?
	When Mr. Jones is the owner of the entity where all the money is being put?
	All the money is not being put into free speech.
	That's exactly what I mean.
	He's not... I'm talking about David Jones.
	You mean Dr. Jones?
	Dr. Jones, yes.
	So your question regarding Dr. Jones is what?
	Right, that it's important, it is useful, it is advantageous for him to no longer work for free speech systems given the consequences of this potential lawsuit.
	I don't know that that's true, no.
	Okay.
	Do you know who Mr. Enoch is, talked about in SEMA?
	I think that was one of our attorneys at the time.
	Okay, and then They're talking about an apology that should be made part of a landing spot in public relations.
	Do you know what apology they're talking about?
	No, not specifically.
	I know Mr. Jones has done a number of apologies.
	Maybe that's one of the ones they're referring to, but I'm not sure.
	Okay, so again, I'm going to ask you some statements about this video.
	I know you've already told me you don't know anything about it, so I don't expect anything, but I need to ask these.
	When Mr. Jones said, is Honor partnered with Fox on their fraud on the First Amendment, do you know what he meant by that?
	Is Honor the company partnered with Fox?
	No, I don't know.
	They said on that episode it was a felony to release birth certificates or death certificates.
	Do you know about that claim?
	I don't know about that claim, no.
	Okay.
	And so you haven't talked to anybody or done any research to figure out where that came from, right?
	No.
	I would think if you don't know the claim.
	I don't know what he's referring to with that claim, so I really can't speak to it.
	Okay.
	There's a part on that show where there's a guest on the show, an Independent Media Solidarity member, who says, Lenny, your day is coming, my friend.
	It is coming.
	And Mr. Jones replies, they made a major mistake involving us.
	And then the person says, go after them, Alex.
	Crush them.
	And then Alex says, I'm not somebody to mess with.
	Okay?
	You've never seen that, right?
	I've never seen that, no.
	By the same token, well, you've already told me there's no editorial discussion, so I don't know exactly how to ask this, but were there any kind of discussions in the family about saying that stuff to a Sandy Hook parent?
	The stuff I disquoted?
	What do you mean in the family?
	I'm sorry, let me rephrase that question.
	Were there any discussions inside the company about saying that kind of stuff to a Sandy Hook parent?
	No.
	Does the company right now Feel that it was appropriate to threaten him in front of millions of people.
	I don't think that that's a threat.
	Yeah, okay.
	When I...
	Can you go to paragraph 35?
	30 for me.
	30?
	3-0?
	30, 3-0?
	Mm-hmm.
	Okay.
	That is December 29th, 2014, America: The False Democracy.
	Have you watched that video?
	I might have it as a different upload date.
	And the reason why I say that is because, and I don't know if you have our ID on it, because I have a couple of videos around that date.
	One second.
	Right, right.
	Yeah, it might be saved under a different name.
	But I remember seeing those, or hearing and watching those particular statements by Mr. Jones.
	I don't understand.
	What name?
	So around the same time I have videos on 12-12, two videos on 12-12, and then I have videos on 12-16, 12-27, but no videos specifically on 12-29, and that could be that just they were uploaded on a different day.
	So, but like I said, I recall watching seeing these particular statements.
	Well, as you may, as I'm sure you recall, Mr. Jones repeats himself quite a lot, so I don't have any way to verify.
	I mean, I guess right now the answer is you don't know if you've watched this video.
	I don't know, just because, you know, the way that you are, in your petition, referencing videos is not the way internally we reference videos.
	Okay.
	So... Alright, well, let's skip that video, I guess.
	Well, we could try to talk about it.
	I'd rather not waste our time.
	Can you go to paragraph 25?
	Sure.
	Do you see the September 25th, 2014 video?
	In fact, I'm sorry, the video before that too, just to make sure I have it on the record, you don't know who worked on that video.
	What video before that?
	The one that you don't know if you've watched it.
	The one from December 29th.
	You don't know who worked on that video?
	Who worked on it?
	No, I could review the document and see if it's on there.
	Let me just check.
	So... I'm looking at Exhibit 6.
	So on 12... 27... Oh, 12-29, yes.
	So this document does have a list of all of the people working on 12-29-2014.
	So this document does have a list of all of the people working on 1229-2014.
	Okay, so that would be a different day than 1227.
	Do you also have a listing for 1227?
	This is your...
	Paragraph 30 says 1229.
	I know.
	And this says 1229.
	So there is another separate list for 1227.
	That's what I'm asking.
	So in other words, the video that you thought you may have watched that was that video that's on 1227, it's not.
	There's a different list for that.
	There's two separate lists here.
	1227 and 1229.
	Gotcha.
	So watching the 1227 video does not necessarily mean you've watched the 1229 video.
	Right.
	I'm just not sure that they're the same video or if they're different videos.
	I'm not either.
	I don't know either.
	But yes, I can tell you who's working on 1229.
	Can I see that list real quick?
	Sure.
	Well, on 1227, that's the day we only have one name, right?
	Right.
	Okay.
	Alright, well, let me start asking you about some of these people later, I guess.
	We'll do that all at one time.
	You can go ahead and have that back.
	Alright, so here we are again at paragraph 25, which is September 25th, 2014.
	Alright?
	You with me so far?
	Yep.
	Okay, the title of the video is Connecticut PD has FBI falsify crime statistics.
	Alright?
	Yep, I see it.
	Can you explain what that refers to?
	What's that title mean?
	That is specifically referencing that article that Adan wrote regarding the FBI crime statistics that we've previously talked about.
	Well, no, I understand the article.
	There's an article much later than this called, nobody, FBI says nobody died to send you it.
	You understand that?
	Okay.
	And do you know when that article was?
	When did Adan write that article?
	Yeah.
	Cause this is in, I mean, I'll tell you, it's in 2015.
	Okay.
	So this is before that.
	And I don't understand what the Connecticut PD would have to do... Well, I don't know which police department they're referring to there, but... What do you mean, Connecticut PD?
	There's no such thing as Connecticut PD.
	I guess not, right?
	Like, I don't know what... So yeah, I don't know either.
	Can you help me?
	I don't know anything about this.
	That's what I'm trying to figure out.
	So let me just go to my notes and see if I watched it.
	So September 24, 2014.
	So, on September 25th, 2014, which may very well be the same video, because like I said, these are just being uploaded on different dates.
	These are our upload dates.
	So, our title that we have here, I don't know where this title came from.
	Connecticut PD has FBI falsified crime statistics.
	The title I have here is Sandy Hook Deaths Missing from FBI Report.
	Okay.
	And Jakari Jackson did that segment, and he was talking about the FBI crime statistics.
	They were the same crime statistics that were being discussed in that article by Adan.
	A figure, I guess, I know he doesn't have a title, but like, I'm going to call him a reporter.
	Are you okay with me calling him that?
	Sure, sure.
	Jakari is a reporter who was active at InfoWars over most of the years that we're talking about here, right?
	Yes.
	Okay.
	Have you talked to him?
	No.
	Okay.
	Let's go ahead and go to paragraph 17.
	Sure.
	Sure.
	Okay.
	That one has a video that's April 16th, 2013, entitled Shadow Government Strikes Again.
	You see that?
	Yes.
	Alright, did you watch that video?
	just give me one second okay so So again, this is another thing where it's the videos that we have, there's a different date.
	So the date that's in this, in the petition is April 16, 2013.
	I have, I have a one dated 4-1-2013.
	I have I have one dated for 1/2013 that was a interview with dr. Pachanik right it might it might be the same video or it might be a different video I I I really don't want answers about if it might.
	I don't.
	But like I said, our internal system is saving them in different ways than you're mentioning them.
	And they're also not full videos.
	Shadow Government Strikes Again may be the title of a clip, but it's not the entire broadcast.
	And so the way we're saving it is not the same.
	I get that, but we don't know, do we?
	I know.
	I mean, but if you have the whole show, or if it's in the production, I mean, we've produced it.
	Is it the same?
	Do we know?
	I don't know if it's the same because your date is not the same date that I have.
	Right.
	And it also might not be the same date because this is a clip.
	Maybe.
	Being cut from the original show.
	Maybe.
	Maybe, right?
	You don't even know that, do you?
	Ms.
	Paz.
	Do I know what you're referencing here?
	No, no.
	You don't even know whether this is a full clip or a full episode.
	You don't know that.
	Well, this, I don't know, and the reason is because that's not how we maintain our videos.
	Like, how you're referencing them here is not how we save them.
	Okay.
	I mean, so, at the end of the day, we don't know if you've watched this video, right?
	I don't know.
	I can tell you about the video that I watched that was uploaded around this time period and if it's the same video.
	No, because we really need to make sure on the fifth time I'm trying to take this deposition that we're actually talking about what we need to talk about.
	So I don't want you to guess about what video might be this video and let's talk about that.
	I don't want to do that.
	Right.
	So the easiest is we don't know if you watched this video.
	I don't know if it's the same video that you're referencing, no.
	You know who Buckley Hammond is?
	Um, yes.
	Okay.
	I did not speak to him, though.
	You should have, shouldn't you?
	Shouldn't that be somebody you speak to?
	I don't know that he's with the company anymore.
	I don't think that matters.
	Right, but, like I said, there's only so much time in a day, so I did not speak to him.
	You would understand that he is, according to Mr. Watson, testified to this during these events we're talking about.
	One of the two most senior people at InfoWars.
	You know that?
	Um, well, so Mr. Watson is a correspondent and he's a consultant, so he really doesn't have...
	that much say in the operation or day-to-day and he's not even in the country he's on the other side of the world but Mr. Hammond I think was a direct liaison with Mr. Jones and his position was that to speak to Mr. Jones it would be easier to go through Mr. Hammond because of his access to Mr. Jones so I think that's probably a more apt way to describe it not that he was a senior person there Okay.
	Well, I'm going to go with Mr. Watson because he works there.
	He doesn't work there.
	He's a consultant.
	We'll see about that.
	But when I talk about the batshit crazy email, you know what I'm talking about?
	Yes.
	Okay.
	Because I know there's a lot of emails in this.
	I'm not just saying there's an email that's batshit crazy.
	There's a lot of those.
	I'm talking about there's an email that specifically uses the phrase batshit crazy.
	You know what I'm talking about?
	Yes.
	Mr. Watson used it.
	Okay.
	And Mr. Hammond's on that email, right?
	I think he's copied on that email, yes.
	He actually responds, too, doesn't he?
	Yes.
	And he talks about steps that he wants to take.
	In his opinion, that he thinks should be taken, yes.
	Okay, who's the other person on the email, do you know?
	I don't recall, I'm sorry.
	Anthony Gucciardi.
	You know who that is?
	Not off the top of my head.
	Okay, he's the other person.
	He's of the two most senior people at the company, right then, that Mr. Watson is testifying about.
	He's the other one.
	Did you know that?
	Again, I don't just agree with the way you're characterizing them as senior people.
	Well, let's go ahead and just try to do it this way.
	Both Buckley Hammond and Anthony Gucciardi are management-level employees at InfoWars when they were there.
	You agree with that?
	To the extent that there was management, I don't know that there was such a structure there.
	Well, we've already talked about that.
	You've already told me that people had supervisory powers at InfoWars.
	There were people who supervised specific departments, yes.
	And these people supervised quite a few people, didn't they?
	I don't know who they supervised.
	That's troubling.
	You haven't spoken to Buckley or Anthony, right?
	No.
	And haven't made any efforts to speak to either one of them?
	No.
	Buckley wouldn't be hard to get a hold of because that's Alex's cousin, right?
	I don't know if he is or isn't.
	Alright.
	Let's do it right now.
	Perfect time. - 4:31 off.
	On the record, 4:47.
	Okay, I had asked you earlier if you had talked to Jakari Jackson, and I know you said no.
	Right.
	Did you try to talk to Jakari Jackson?
	No.
	Okay.
	Darren McBreen, that's another person you didn't talk to, right?
	Right.
	Did you try to talk to Darren?
	No.
	Okay.
	Mr. Jones, very recently, and we actually, this was in a court hearing, we played this, talked about his archivist.
	Do you know who I'm talking about?
	Mr. Jones, there was a clip we played in the hearing.
	And we actually played it in Mr. Jones's deposition, too, I believe, that Mr. Jones says, I have an archivist on staff.
	He does incredible work.
	He should be paid about $100,000 a year.
	Instead, he's only paid $20,000 a year, which is a terrible shame.
	But I don't understand it because Mr. Jones is the one who pays him.
	But he says the guy is like a bloodhound and can find anything.
	Do you know who he's talking about?
	I'm sorry.
	I don't know who he's talking about.
	OK.
	I don't either.
	All right.
	I don't know.
	Do you know if an archivist existed in Four Wars?
	I don't have any reason to believe that, but I mean, he may be referring to a third-party company, but I've not been able to find anyone at InfoWars that has such a job.
	Okay.
	And I noticed you said, for instance, Mr. Jones himself, or really the company itself, really isn't in the business of research, right?
	They're a punditry company, right?
	Yes.
	So Mr. Jones hasn't done research on Sandy Hook, right?
	I think that he, in the sense that he's seen other things in other places, he does use the term research, but as far as verifying what he's seeing, no.
	But when he's informing his own opinion on something, he may call it research.
	But that goes back to, you know, Mr. Jones has a lot of Okay.
	So I mean, in other words, it might be to say that he did research in a more casual way than what we would normally think of as research.
	He does more casual stuff, but he's not out there doing deep research.
	He's not doing deep research, but when he's saying research, I think what he means is that he is looking at the things that we are referencing and that he's using that to inform his opinion.
	But no, he's not doing investigative research.
	Okay, I want to, and I'm just gonna use this to mark where it is on the page, basically.
	Right around here.
	That area of the page.
	Do you see where it talks about a paragraph 30?
	Somewhere in there?
	See a line that starts a paragraph 30?
	Yes, so these are my notes.
	Right, and part of your note says that Mr. Jones represents that he did deep research.
	Correct?
	That's what he says in that video.
	I quoted the video.
	Okay.
	Can you... Actually, let me see that page again.
	I'm sorry.
	See, I did watch the video.
	There's one.
	Yeah.
	Um.
	Wow, yeah, that's one that you didn't seem to think you did watch, did you?
	Right, that's what I'm saying is that I think that, you know, the issues that we have is just the naming of the certain videos and how they're saved.
	Doesn't seem to be an issue at all here.
	It says 122914 video, America the false democracy.
	Right, but what I'm saying is that's not how it's saved in our documents.
	It might have been the title of the video once it was played, but it's not how it's saved.
	Do you see a reference to page 97?
	- Did you see a reference to page 97?
	- Not bad, but I got time. - One second. - You'll see a list of page numbers Yes, yes.
	I think this was the deposition.
	Yes, that's Ms.
	Karpova's deposition.
	What I want to ask you about is you have a note written down there and it says, Alex said these kids didn't die because he has a big heart and he wanted to hold out hope they weren't dead.
	That was the company's testimony from Ms.
	Karpova, correct?
	That is Ms.
	Karpova's testimony.
	And that's the company's testimony, right?
	She was a representative at the time of the company, so yes.
	Does the company still stand by that testimony or does the company think maybe it should change that testimony?
	I think what I said earlier was that a vast majority of Mr. Jones' opinions as broadcast were that, I don't know if kids died, I'm not sure, I don't know enough to inform that opinion, but this may be a false flag operation.
	Maybe the government was involved, that kind of thing.
	I don't know what she's referencing here.
	I think what she's saying and what the context of that is, is that if he said kids didn't die, this is the reason why he said it.
	That's what I took that to mean.
	And he did say that, right?
	He did say kids didn't die.
	I can reference... Multiple times.
	I don't know about multiple times, but I do know of at least one time that he said kids didn't die.
	But on the whole, more times than not, he said he didn't know whether kids died.
	That's... I mean, good for him, right?
	He should be saying, like, that's... If that's our floor, whew!
	You know what I mean?
	Like, does that... Let me ask you this question.
	Is it the company's position that its non-defamatory statements cancel out its defamatory statements?
	The company's position is that that is an opinion.
	Ah, okay.
	Well, it's not the court's position, so that's a good thing.
	Let me actually take you back.
	I believe you did watch the video and I didn't get the chance to ask you about this.
	On September 25th, 2014, on paragraph 25, the one we were talking about, Connecticut PD has FBI falsify crime statistics.
	I'm sorry, which paragraph? 25.
	Okay, yes?
	One of the claims in that video was there are photos of kids who are still alive that they said died.
	What photos are being talked about here?
	What was Mr. Jones talking about?
	This is in that broadcast, the September 25th, 2014?
	- June 25th, 2014? - Yep. - Is this one of the ones I said I didn't have that exact date?
	I think that might be... Uh, maybe that's why we didn't get to cover that.
	Right.
	I think you're right.
	I think that's the one where I don't know if I watched it, just because the dates are not the same.
	Yeah, I didn't, you're, you're 100% right.
	I didn't update my own notes.
	Okay.
	That's my fault.
	Okay.
	So that's that one we can't talk about.
	Um, let me... Can you go to page 14 of your notes?
	of your notes?
	Sure.
	Okay.
	At the very bottom of the page, who is identified as researchers?
	This is my notes about Rob Dew's corporate rep deposition, and in his deposition he was asked who researchers were, and he named a few names.
	Okay, can you tell me what those names are right there?
	Darren McBreen, Nico Buckley-Hammond, and Darren does graphics.
	Okay, so let's first start with those three people.
	The only person you talked to there was Nico.
	Right?
	Yes.
	Didn't talk to Buckley?
	I don't, no, I didn't.
	I don't think I talked to Buckley.
	Didn't talk to Darren McGreen?
	No.
	Didn't try to talk to Darren McGreen?
	No.
	Okay.
	There are some other people that he keeps listing?
	Are those more researchers?
	No, I think that that part of the deposition he moved on and he just started listing No, maybe that wasn't even him.
	It was you.
	You had asked about a number of different people in the deposition.
	That's why there were question marks.
	So, no, those are not researchers.
	Okay.
	Or he named as researchers.
	Okay.
	Let's talk a little bit.
	Have you reviewed any documents that set forth a figure for InfoWars audience size during any of the times relevant to this lawsuit?
	So, as far as the audience size, and I'm aware that there was, that's one of the topics that we need to discuss today in the deposition regarding the audience size, and based on my conversations with Mr. Jones, it's really not possible to accurately state what the audience size is for a variety of reasons.
	A, not only is he on a bunch of stations, but You know, he's on the internet and it's free to air and everyone over the world can broadcast it.
	So, I mean, if you want to see what his reach is, I mean, the whole planet is the reach.
	I don't think that there really is a way to narrow that down in any real fashion.
	Okay.
	That wasn't the question I asked.
	The question I asked was, have you reviewed any documents that set forth InfoWars total audience size?
	And I'm going to take it by your answer that the implication is there, no, you have not.
	I don't think there are any documents that exist like that.
	Yeah, there are.
	There are Google Analytics about the website and the website traffic.
	I've reviewed those, but aside from that, I don't... If I was to tell you that there were 8.1 million unique viewers in January 2017, would you know if I'm right or not?
	Are you talking about the Google Analytics?
	Nope.
	I don't know the answer to that.
	I reviewed the Google Analytics.
	If I told you that there were 46.3 million global views in January 2016, would you know if I'm right about that?
	I wouldn't know if you're right about that.
	That's before the company started using Google Analytics, right?
	I don't know the answer to that, but just because those are the number of views doesn't mean that's the number, the audience size.
	I know.
	I mean, I need to start asking questions about that, but you haven't seen this document.
	And I'm guessing... I don't know what you're referring to.
	And I'm about to tell you that you understand Mr. Daniels had his deposition taken in Lafferty, right?
	Yes.
	Okay.
	Exhibit 6 to Mr. Daniels' deposition is an email from Kit Daniels to Patrick Riley.
	You know who Patrick Riley is?
	I'm not sure.
	Okay.
	Mr. Daniels was writing an email to Patrick Riley to set forth for Mr. Riley's request to provide him with copy to give him the audience figures for InfoWars.
	And that email from June 28, 2017 in the Lafferty deposition Talks about 8.1 million unique viewers in January 2017 and 46.3 million global views in January 2016.
	You've never seen that document, right?
	No.
	And I don't want to speculate as to what's in it.
	I definitely don't want you to do that.
	And if that document exists, in fact, you don't know what viewership it's describing.
	Whether it might be viewers of the live show, whether it might be visitors to the website, whether it might be YouTube views, whether it might be drawn from whatever source, you wouldn't be able to testify about that.
	No, because I don't know what document you're talking about.
	Now in terms of talking to Mr. Daniels, did he ever mention that he was working on documents that have audience size in them?
	No, and that's not really his job description.
	So what did you do exactly to determine what audiences were reached by the videos and plaintiff's petitions?
	So I reviewed the Google Analytics data, and I spoke to Mr. Zimmerman about how to read that data.
	And I spoke to Mr. Jones as how to try to narrow down the number of people that are viewed, or reached rather, by his broadcasts.
	But I think that that's the universe of what I've reviewed.
	And so the Google Analytics, that would tell you visitors to the InfoWars.com website, right?
	Yes.
	That would not tell you anything about any of the viewers to any of the other ways that InfoWars videos are distributed, right?
	I'm sorry, I don't understand.
	Well, you understand InfoWars videos are distributed far more ways than just on the InfoWars.com website, right?
	Yes.
	Okay.
	So those analytics don't tell you anything about how many people saw those videos, right?
	No.
	All it would show is the number of clicks that articles on the site would Sure.
	All that would show is the number of clicks that the website would have.
	Right.
	And that doesn't even track the number of viewers of the live stream on the website, right?
	If you click on the live stream, you don't get independent numbers for that, right?
	I don't think that's accurate.
	I think if it has an InfoWars URL, I think that it tracks the live stream.
	You're right, you're right.
	Okay, so if you click InfoWars.com slash watch, you'll hit the live stream.
	Right.
	But you cannot tell for any particular video, because each of the... So for any day that I want to watch InfoWars, I'm not clicking on a link that's unique to that date.
	I'm just clicking on the live stream, right?
	The answer to that, I think, is that it depends.
	For example, some of these videos are embedded in certain articles.
	If it is embedded in an article, it would have an InfoWars URL.
	Some of these videos we had stored only on YouTube.
	If those YouTube links aren't there anymore, it would not be possible to track it.
	to the extent that those links were embedded in videos, in articles, I'm sorry, then I would be able to track those particular articles and the tracking and the traffic to those articles.
	Did you do that?
	I think what Mr. Zimmerman did and produced was he produced the website traffic and all of the landing pages and which URLs were related to Sandy Hook and whatnot.
	And you did that.
	Is that something you've reviewed?
	I did see in the production many thousands of landing pages associated with the website and not including, not just Sandy Hook, just all of the landing pages.
	No, what I'm trying to figure out is did you take that information, that raw data, and attempt to do anything with it?
	No, I just reviewed the raw data.
	I talked to Mr. Zimmerman about it.
	I looked at some of the landing pages associated with Sandy Hook to see what their website traffic was.
	Okay.
	Do you know who Scott Bronson is?
	I'm sorry, no.
	And maybe you'll correct me on this because I'm going to use a title, right?
	And I know they don't have them.
	But Scott Bronson is the Affiliate Relations Manager at InfoWars.
	Did you know that?
	I don't know that.
	Do you know what the Affiliate Relations Department is?
	No.
	You know Ms.
	Karpova testified about the Affiliate Relations Department.
	Do you remember that?
	I'm sorry.
	Do you remember that Ms.
	Karpova said in order to answer my questions about dissemination of the InfoWars videos, where they were, what audiences they reached, she would need to talk to Affiliate Relations.
	Do you remember her testifying that?
	I don't know if by affiliate relations she means the IT department.
	I don't know.
	I don't know what she's terming, what she's referencing there.
	She's referencing Scott Bronson who runs the affiliate relations department for Infowars Affiliates and that's somebody you've never spoken to, correct?
	I have not spoken to him, no.
	Okay.
	You know what GCN is?
	I'm sorry?
	GCN?
	Mm-hmm.
	You know what that is?
	Yes.
	Okay.
	And so can you tell the ladies and gentlemen in the jury what GCN is?
	What do they do?
	You know, I don't want to misstate it, so I'm not that educated on it to verbalize it that way.
	Are you able to verbalize it at all?
	Like, do you have any even rough idea what GCN is?
	I just don't want to misstate what it is, because I'm not 100% sure.
	I mean, like, you... I want to know what your understanding is, even if it's wrong.
	Do you understand that?
	Like, what do you understand GCN to be?
	Like I said, I'm not sure, so I don't know.
	Do you know what it has to do with?
	What's this associated with?
	Is it associated with videos?
	I thought it was associated with IT, but I could be wrong, which is why I didn't want to say in the first place, because I'm not 100% sure.
	IT meaning the management of technology inside of InfoWars?
	Okay, that's definitely not what GCN is.
	Do you know who Ted Anderson is?
	No.
	Okay, Ted Anderson runs GCN.
	GCN is a syndicate, like GCN is where all of InfoWars Radio is, well maybe not all of it, but a very large substantial component of InfoWars Radio is through GCN.
	Do you know that?
	No.
	Okay, Genesis and Ted Anderson are co-defendants in Lafferty.
	Okay.
	Did you know that?
	I'm not sure.
	Okay.
	The GCN network, they possess information about where InfoWars shows are broadcast on radio, right?
	Or do you know?
	I don't know.
	InfoWars has in the past relied frequently on GCN for audience data, right?
	Or do you know?
	I don't know.
	Do you know in 2017 or any of the times relevant to this lawsuit, do you know how many radio stations InfoWars was carried on?
	I don't know the number.
	Do you know how many over-the-air television stations?
	No, I don't know the number, and it's changed over time, too, so... Do you know the max that it ever was?
	No.
	Can you even ballpark it?
	I don't know.
	I mean, you have no idea.
	Do you even know if InfoWars has ever appeared on over-the-air television?
	I don't understand the question.
	Okay, do you know what over-the-air television is?
	Let's start there.
	You mean, is it being broadcast not just on the radio, on TV?
	I don't think it's being broadcast on TV, no.
	So I'm not...
	Unfortunately.
	But the problem is when I've spoken to Mr. Jones about this, he doesn't, so, and I understand what you're saying about GCN, but I don't, when I spoke to Mr. Jones, they're not keeping track of this data in any real way, so I don't know that GCN does this.
	It's based on your representation, like I don't know.
	Over the years, InfoWars has frequently published GCN audience data on its website, hasn't it?
	GCN data or InfoWars data?
	GCN.
	I don't know that that has anything to do with InfoWars viewership data.
	That's where InfoWars show is played, GCN.
	That's a network.
	It's a radio network.
	Okay.
	So it does have something to do with InfoWars.
	Okay, but it's... Never mind.
	I'm sorry.
	I forgot to say, you don't have any idea about GCN?
	I don't know, right.
	Right, okay.
	How many cable packages has InfoWars been carried on?
	I don't know.
	How many OTT services?
	I think Mr. Jones testified to this.
	I mean, he was on Roku, but then he was taken off of Roku, so at various points in time there were different OTT services.
	That's why I got you here today.
	I know what he said.
	Right.
	And he said several of them.
	And apart from what he knows, I don't know anything else apart from what he knows.
	And you didn't do anything to find out?
	No, I asked Mr. Jones and that was what he knew.
	You asked Mr. Jones how many OTT services they were on?
	Right.
	I talked to Mr. Jones about it, and apart from his knowledge on the issue, I don't know.
	And you did not talk to anybody else but Mr. Jones about what OTT services they're on, right?
	Right.
	Okay.
	How many satellite services?
	I don't know.
	Is that the same answer, that the only person you asked was Mr. Jones?
	Generally, when I spoke to Mr. Jones on this topic, his position was he doesn't know and there's really no meaningful way to understand what the reach of the viewership is.
	Satellite services?
	There's no way to know how many satellite services InfoWars is on?
	I don't know the answer to that.
	Okay.
	Certainly you didn't do anything yourself, other than us, Mr. Jones.
	No.
	And did you ask Mr. Jones specifically about satellites?
	About satellites?
	No.
	I just, we had a general conversation about his viewership and how we could go about calculating in some meaningful way the viewership and it's just, he's not keeping track, it's not something he's keeping track of.
	He didn't tell you to go to affiliate relations?
	No.
	How many shortwave stations are InfoWars carried on?
	I don't know.
	You understand that it is carried on shortwave, correct?
	I don't know.
	Okay.
	Worldwide Christian Radio, do you know anything about that?
	No.
	Okay, so Worldwide Christian Radio might have viewership data on what is received for InfoWars programming on WWCR.
	Do you admit to that?
	I don't know.
	Because you don't know what WWCR is, right?
	I don't know what they have.
	It's not something that we have.
	I know that!
	Hmm.
	You don't know necessarily what you have, right?
	I know what's been produced and what's in the documents and what we've asked to... You don't know what's in the documents.
	You haven't reviewed every document, have you?
	I haven't reviewed every specific document, but I did try to make an effort to testify cogently on the eight topics that were notified in this deposition.
	I get you.
	You made all the effort you could.
	I did.
	You were in a tough spot.
	I don't doubt that.
	I don't doubt that at all.
	And I'm sure you worked as hard as you could.
	I'm positive of that.
	But what I'm trying to get at is, sitting here today, You don't know the answer to these questions about these things, and you did no independent research.
	I did no independent research, no.
	Aside from what was already in the documents, no.
	Okay, so for instance, InfoWars collects sales data.
	Well, PQPR collects sales data.
	It's available to InfoWars.
	It is available.
	A hundred percent.
	And Mr. Jones can have the, I mean, I don't want to play the shell game here.
	It's not the same company, but it is available, yes.
	Yes.
	A hundred percent available to him.
	All right.
	That means it's available to you, right?
	The sales data, yes.
	Okay.
	That sales data, what have you done with that sales data?
	So I have made an attempt to find out the sales data.
	So I did go to the warehouse and reviewed the warehouse and, well, looked at the warehouse and spoke to the warehouse person, as well as we have a person named Blake, and I think he's been deposed.
	He is in charge of the warehouse and the sales end of it.
	Okay.
	So in 2015, We changed our programming.
	So from 2012 to 2015, we can pull the number of clicks per article.
	So for a certain article, say it's a Sandy Hook article, if there was an ad in that article, which most of the articles have ads in them, we could tell who was redirected from the website based on a click from that ad to the store.
	Okay.
	We can't tell the conversion rate whether anybody purchased anything once they were redirected from that ad on that article to the store.
	But we can tell how many times somebody was redirected from that page to the store.
	Post-2015 through present, we can tell how many times a person clicked on an ad in an article, in a specific article, was redirected to the store and had purchased something from the store.
	Okay.
	So what I want to ask you is, what steps did you undertake, if any?
	I understand that you found yourself in a situation where you had an absence of data on audience reach.
	Yes.
	I'm wondering, as maybe a workaround, did you go try to use the sales data in any way to try to cross-reference that or create some new data set that could help you inform the audience size of InfoWars?
	I don't think there's a way to do that, just because the only real thing that informs is who's clicking on most particular articles from the website.
	It's not telling me how the person ultimately gets to my website.
	So it's not telling me they were redirected from another source to the website.
	It's just telling me, you're now at the website and you've clicked this ad on this particular article and you're being redirected.
	So I don't think there's a way to extrapolate that.
	The other thing InfoWars keeps track of is everywhere it sends products.
	I'm sorry, what do you mean?
	Well, the product's got to get to the customer somehow, right?
	I think PQPR maintains records of the customers and where their products are being sent once they're ordered.
	Did you get those records?
	No, PQPR is not free speech.
	Free speech maintains those records.
	You mean the records of specific customers?
	Yeah, where it went.
	Where you ship stuff to.
	No.
	And so if there's any data there that could perhaps be useful or manipulated in some way to help us understand better audience reach ideas, that's not something you undertook to do?
	No, I don't have the names and where these products are being shipped.
	Perfect, okay.
	So what I could say is how many total orders were placed on a particular day, Like, for example, if a video was uploaded on a particular day, how many orders on that day.
	stuff like that.
	But one of the things we can say is that you did not yourself.
	I just want to make sure I understand the things you did, right?
	You did not yourself attempt to take any sales data, order data, request things from PQPR and use that in some way, I mean I'm just spitballing here, to try to create an audience statistic or any sort of information informing audience reach.
	I mean, I don't know that that can be done.
	I don't either.
	But I don't know, yeah, but did I do anything to try to do that?
	No, I didn't.
	I'm not suggesting that, I'm just asking if that happened or not.
	No.
	No.
	OK, did you review any organizational chart for the company to tell you how it was structured?
	OK.
	As far as reviewing a chart, no, I based my conclusions on the organization of the company based on my conversations primarily with Melinda.
	Okay, well, the reason I'm concerned is because I requested an organizational chart and I didn't get one.
	Okay.
	And then, surprise, surprise, Lafferty Deposition, Kurt Nimmo, Exhibit 7 is an organizational chart of the company with everybody's roles and what they do, and I'm wondering if you've ever seen that.
	I don't recall seeing that.
	When you say roles and what they do, you mean free speech and which departments there are and who works in each department and who is headed to each department?
	No, I don't recall seeing that.
	I'm sorry.
	Okay.
	So in terms of seeing the company's business structure, if there does exist in Plaintiff's Exhibit 7, in the Lafferty Deposition of Curtin MO, an organizational chart of the company, you didn't review that in trying to get ready for this topic?
	No.
	Can you describe to me what InfoWars LLC is?
	InfoWars LLC I don't think actually conducts any business.
	I think it's just a holder.
	I think all of the business is conducted through free speech.
	You think that?
	Actually, I know that.
	All the business is conducted through free speech.
	I don't think InfoWars does any actual business.
	InfoWars LLC.
	Don't think it does.
	It doesn't.
	Free speech does all of the business.
	Let me put it this way.
	If you are saying to me right now, I know InfoWars LLC has never done any business, you'd be the first person who'd be able to tell me that.
	Is that what you're telling me today?
	I don't know whether it's ever done any business.
	I could tell you now it doesn't do any business.
	No, I want to know for the entire dependency of the suit, did it do any business?
	I don't know how long that it's been, but I can tell you right now it doesn't do any business.
	Okay.
	I mean, like, for instance, when I first brought this, you know, years ago, InfoWars LLC is the entity listed on the InfoWars website.
	InfoWars LLC is the entity listed on the Terms of Use for the website.
	Do you know anything about that?
	So I know that there's been a lot of entanglement between the various LLCs, and there's been efforts undergone to make everything more clear and structured and organized.
	But that's been in the last handful of years, so I don't know how long InfoWars has not been conducting any business for.
	I know that it's not being conducted now under InfoWars LLC.
	So we can say now you understand, right now you understand what the relationship between InfoWars LLC and Free Speech Systems is, which is nothing really because InfoWars doesn't do anything, right?
	Right.
	But in terms of what it used to be during the periods of some of this lawsuit, what the relationship between Free Speech Systems and InfoWars LLC is, that's not something you're prepared to testify.
	I don't know about that, no.
	Can you tell me when it was the first time in the company that an employee expressed there was a problem with InforWars coverage of Sandy Hook?
	Could you be more specific?
	No, I want to know.
	I mean, I want to know any time this has happened.
	I would assume that that's something that... I'm sorry, like I said, I've reviewed a lot of documents, and if you can redirect me to a specific point in time, then that would be... No, because I want something... Here's the problem.
	So much of what you're telling me is, well, if you can just point to the discovery we've already given you...
	The discovery we've been repeatedly sanctioned for.
	If you can point to that discovery, I can testify.
	My purpose here is not to deal with that discovery.
	I'm here to find out what still exists that wasn't produced, that hasn't been done.
	The company's position is that we've produced everything that we have.
	Whether you have that or not, the company's position is we have produced everything that we have.
	Okay, so since you now have that universe to deal with, can you tell me when was the first time that a person inside the company expressed a problem with InfoWars' coverage of Sandy Hook?
	I don't know, because like I said, I've reviewed a lot of documents.
	Okay, can you tell me, maybe you can't tell me the first time, but do you know Do you know who was the first person?
	I don't know who the first person was.
	I know we've talked about Mr. Watson, who had an issue.
	I know that... I can't remember his name.
	He was deposed.
	He was a former video person.
	He was with the company for a long time.
	I know that he had expressed some concern.
	But aside from those two people affiliated with the company, I don't know that I can specifically reference Well, I was hoping to talk about discussions... Jacobson.
	I'm sorry.
	That was his name.
	Jacobson.
	Okay.
	I was hoping to talk about discussions inside the company, the various discussions that have happened where people raised problems based on Sandy Hook.
	You're not totally up to speed on those discussions, I would take it.
	I think that you're assuming there were such discussions aside from the two that I've mentioned.
	I am.
	And I don't believe that there have been.
	Based on my conversations with the people that work there.
	And the selection of documents that you chose to review out of the entire documents, right?
	You didn't see that in the selection of documents you reviewed?
	No.
	I saw Mr. Jacobson's deposition and I saw Mr. Watson's email.
	Let me rephrase that again because that's what I'm trying to get at.
	Other than the two things that you just mentioned to me, those two discussions, You didn't come across any other discussions in the limited set of documents you reviewed?
	No, there was nothing else in the documents, but there was also nothing else in the conversations that I had with InfoWars employees that would have led me to believe there were other such discussions.
	Do you find those to be credible people, your interviews with them?
	Do you think you can rely on those interviews alone, or do you think they need to be fact-checked?
	Knowing what you know now about InfoWars, what do you think?
	I mean, I think I was tasked with interviewing people, and I did that.
	I think you were actually tasked with trying to come up with all information that the company had reasonably available to it.
	And I want you to know, I want to ask you, do you think just simply interviewing some of these employees, knowing what you know about them now, do you think that's good enough?
	Or do you think you should be looking at all the information the company has?
	I did look at all the information.
	You didn't read all the documents, ma'am.
	I can't read 100,000 pages plus of documents.
	Then you did not do that, right?
	I did a search for the topics that I was trying to testify cogently on and I did not see anything else in the documents that were produced that were available to me that relate to that specific type of information.
	Let's go back.
	All the documents were available to you.
	When you say documents that were available to you, you're talking about the limited set that was provided or that you somehow created.
	All the documents were available to you, right?
	The documents that are in the Dropbox, you mean?
	No, I mean every document that's been produced in this case is available to you.
	See, and that's another issue that we are having, just because I know that there are documents that are produced in the Connecticut case, there are documents that are produced here.
	I don't know what universe, if any, those documents overlap.
	But, like I said, the documents that are on the Dropbox, that were in production, I did search terms for those.
	And also the interviews.
	When I talk about interviews, there really aren't other conversations between people that of people raising concerns.
	So like, for example, Mr. Jacobson in his deposition specifically references a conversation with Adan regarding a conversation they had in his office.
	I asked Adan about that conversation.
	I asked how that came to be, what was the content of the conversation.
	I confirmed that that conversation happened.
	There was a dispute as to the context of the conversation.
	But that's in any conversation with a person, there's gonna be three sides to every story, so that's not surprising to me.
	to me.
	I'm going to leave all this for you.
	All right, so you know we've got -- let me just ask you this.
	This lawsuit, which is now heading to trial, is going to be in front of a jury.
	The question of the plaintiff's compensatory and punitive damages.
	That's what we're facing right now.
	And I'm wondering, going into that process, does the company understand what it did wrong?
	I understand that there's been a default judgment, which is, I don't I think the same thing as morally doing something wrong or legally doing something wrong.
	I guess that's what my question is.
	Let's do it all.
	Okay.
	So is your question whether the company thinks it's legally responsible?
	Let's start there.
	No.
	Okay.
	How does it feel morally?
	Does it understand what it did wrong?
	I think that there are different opinions within the company as far as the coverage.
	I think Mr. Watson made that clear, that he felt one way about the coverage.
	Mr. Watson's not in the company.
	Mr. Watson is a consultant.
	He sent those emails about his feelings.
	I'm sorry, I don't mean to interrupt you here, but you made a big point of telling me.
	That no, he's not an employee.
	He's not an employee.
	And when I said, "I'm going to trust him because he's inside the company," he knows.
	He told me, "Uh-uh, he's a consultant.
	He doesn't know.
	He's outside the company." That was about the structure of the company.
	Okay.
	Those were the questions regarding the structure.
	But now when it's convenient for the company that Mr. Watson is a source of information, now he is part of the company.
	No, we've cited to an email, and you've relied on an email Mr. Watson has written.
	He had an independent opinion about the content and how it was being portrayed, and that was his opinion as a consultant.
	We were referencing earlier the business structure and whether he had anything to say about the business structure of the company.
	I think those two things are different.
	Well, I don't want to know about consultants.
	You want to know about just employees?
	No, I want to know about the company.
	The company has an opinion.
	The company is a separate thing from its employees.
	The company has subjective beliefs.
	And I want to know what they are.
	I don't know if the company takes a position on the morality of the statements.
	Thank you.

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