Depositions & Trials - Deposition of Brittany Paz, Lafferty vs Jones - March 15, 2022

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March 15, 2022 - Depositions & Trials

04:38:51

Deposition of Brittany Paz, Lafferty vs Jones - March 15, 2022

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	Yes.
	We are now on the record.
	Participants should be aware that this proceeding is being recorded and as such all conversations held will be recorded unless there is a request and agreement to wealth the record.
	Private conversations and or attorney client interactions should be outside the presence of the deposition.
	This is the video recorded deposition of Brittany Paz being taken by counsel.
	Today is Tuesday, March 15th, 2022.
	The time now is 10.04 a.m. in the Eastern Time Zone.
	We are here in the matter of Erica Lafferty versus Alex Jones.
	My name is Joe Raguso, the videographer, on behalf of U.S. Legal Support, located at 90 Broad Street, New York, New York.
	I am not related to any party in this action, nor am I financially interested in the outcome.
	At this time, I'm with a reporter, Victoria Stockman.
	On behalf of U.S. Legal Support, please swear in the witness.
	Please first ask if for deposition stipulations.
	Yeah, so we have been doing throughout this case the usual Connecticut practice book stipulations and in particularly that all objections except those as to form and as to motions to strike are preserved until the time of trial.
	Everyone else okay with that?
	Great.
	We'd like the opportunity to read and sign please.
	Usual steps to find.
	And it's my understanding, counsel, that although Attorney Ryland is here in the room today, that it's Attorney Pattis that's going to be defending the deposition.
	Is that right?
	Yes, it is, Chris.
	I couldn't be present physically in Connecticut.
	However, in the event that the documents are shown to the witness, Attorney Ryland, we'll book with them and if necessary, I'd ask for an opportunity to confer with him briefly off the record.
	Sure, and we should be able to, I mean, our plan is to display any documents that we're presenting to the witness on the Zoom so that people should be able to look at them in real time as well.
	Thank you.
	All right.
	Everybody ready to get going?
	Yes.
	All right.
	Hold on, let me just swear in the witness.
	Yep.
	And everybody stipulates that I can't swear the witness remotely since I'm also remote from the witness?
	Yes.
	Yes.
	Okay.
	Ms. Paz, if I can have you raise your right hand, please.
	Do you solemnly swear and or affirm, as the case may be, that the statements you're about to make will be the truth, the whole truth, and nothing but the truth, so help you God, or under penalty of perjury?
	I do.
	Thank you.
	If I can have your name and do you want a business address, counselor?
	Sure, I can put my business address on the record.
	My name is Brittany Paz, PAZ, and my business address is 4 Research Drive Suite 402, Shelton, Connecticut, 06484.
	Thank you.
	Thank you, Counselor.
	It's all yours.
	Thank you.
	Good morning, Ms. Paz.
	Good morning.
	My name is Chris Manati.
	We've never met before, correct?
	I don't remember us ever meeting.
	Okay.
	I'm an attorney with Costco, Koscoff, and Beter.
	I represent the plaintiffs in this matter against Alex Jones and the corporate entities that he controls along with Genesis Communications.
	Do you understand that?
	Yes.
	Okay.
	And I understand that you are here today for a deposition as the corporate representative of Free Speech Systems LLC.
	Is that correct?
	Yes.
	All right.
	Now you are a Connecticut resident?
	Yes.
	Okay.
	And an attorney admitted to practice in Connecticut, correct?
	Yes.
	But you're not here in your capacity as an attorney this morning?
	No.
	All right.
	And you have no affiliation with Free Speech Systems other than having been retained to be its corporate representative in this case.
	That's right.
	You've never been employed by them?
	No.
	You've never represented them as a lawyer?
	No.
	Okay.
	And let me ask you this.
	Prior to being requested to serve as Free Speech Systems Corporate Representative, had you ever heard of InfoWars?
	Sure.
	You had.
	Had you ever listened to InfoWars?
	No.
	Okay.
	Had you ever heard of Alex Jones?
	Sure.
	Okay.
	Had you ever listened to him?
	No.
	Had you reviewed news coverage of Mr. Jones?
	I don't think so.
	No.
	Were you familiar with this lawsuit?
	I knew about the lawsuit, yes.
	Okay.
	Now you previously were employed by Attorney Pattis' law firm, Pattison Smith, correct?
	Yes.
	When were you hired by Attorney Pattis?
	I believe it was November 2012 when I passed the bar exam and then I left employment there in January 2018.
	Okay, so that was your first job as a lawyer out of law school for the first six years of your career?
	That's right.
	Working directly for Attorney Pattis?
	Yes.
	All right.
	And then when you left Mr. Pattis's law firm, where did you go next?
	I was out on my own.
	I was a solo practitioner for about a year.
	And then after that, you joined the Rowan law firm?
	Right.
	Okay, so that was about 2019?
	Right, January 2019.
	And when did you, I understand that you recently left the Rowan law firm?
	Yes.
	And when was that?
	January.
	When was the official date that you resigned from the law firm?
	January 21st, I believe, was my last day.
	And what were the circumstances of you separating from that law firm?
	I believe it was a financial issue.
	On whose part?
	On the firm's part.
	Okay.
	And what do you mean by that?
	I mean, I think the firm had an issue paying my salary.
	Okay, and so they had to let you go?
	Right.
	Okay.
	And that was on January 21st.
	Had you been contacted about the possibility of serving as a corporate representative in this case prior to that?
	No.
	When did you first receive contact about the possibility of serving as a corporate representative?
	It was sometime in late January.
	It was after I separated, so maybe sometime the following week.
	I don't think I was officially retained until last week in January, first week in February, so like the 30th or the 31st.
	Prior to separating from the Rwane law firm, did you have notice that that was likely to be happening?
	No.
	Okay, so that came as a surprise to you?
	Yes.
	And did you have any plans as to how you were going to generate income as an attorney?
	No, I just thought I would go back out on my own.
	I had done it before, so I'd do it again.
	Okay.
	And had you done anything or have you done anything at this point to incorporate a law firm for yourself?
	And when did you do that?
	Almost immediately after separating from Rowene's office.
	What did you do to affect that?
	I filed papers with the state to incorporate my law firm.
	I have a business address.
	I have a business phone number.
	I changed all of my addresses with the state with the like my juris numbers and stuff like that.
	Do you know when you did that?
	When you filed that paperwork with the state?
	It would have been almost immediately after separating from Rowen's office, so late January.
	And what's the name of the firm that you've started?
	Paz Law LLC.
	Does it have a website?
	Not yet.
	My website is not active.
	I do have a URL, but it's not connected to a website yet.
	Are there any other employees of POS Law?
	No.
	Okay.
	When you were contacted, who contacted you about serving as a corporate representative?
	Attorney Pattis did.
	Okay.
	And how did he contact you?
	I believe he called me.
	And when did you agree to serve as a corporate representative?
	It wasn't immediately.
	He had asked me to do it.
	He asked me to think about it.
	He asked me to speak to the attorney down in Texas to get some more information about it.
	That took a few days, maybe a week, to do.
	And then there were some discussions about my fee.
	And then by the time all that had happened, it was late January.
	So it was around January 30th, 31st, something like that.
	Okay.
	And when you say he asked you to speak to the attorney down in Texas, is that attorney Blott?
	Yes.
	All right.
	And you understand that she represents Alex Jones and defendants associated with him in litigation in Texas, correct?
	Right.
	And you were retained to serve as a corporate representative for Free Speech Systems and Infowars LLC in Texas, correct?
	Right, because there were depositions that were forthcoming down there first.
	So those depositions were, I believe, February 14th and 15th.
	So you understood when Attorney Pattis contacted you that you would be serving both as a corporate representative in connection with the Texas litigation and as a corporate representative here in Connecticut?
	Yes, he said I need somebody to be a corporate representative and I assumed that that's what it meant.
	Okay, all right.
	When you initially signed on to be a corporate representative, did you know that you would also be sitting for a deposition in the Connecticut cases?
	I don't think he said anything specifically about that to me until I was already in Texas.
	Okay.
	But I mean I assumed it.
	You did?
	Okay.
	So you negotiated your fee in anticipation of serving as a corporate representative in both cases?
	Right.
	Okay.
	And that fee, as I understand it, is $30,000?
	Yes.
	Do you have a written agreement or engagement letter with Attorney Pattis' law firm?
	I do not.
	Okay.
	Do you have any written agreement of any kind?
	No.
	Okay.
	Did you ask for one?
	I believe I sent an email to Attorney Blatt asking for an engagement letter, but I don't think she ever sent one.
	And have you received the $30,000 fee?
	I have been paid, yes.
	Okay.
	You received that in advance of your testimony in Texas?
	In Texas, yes.
	And who was the payor on that check?
	You mean who was it?
	Who signed the check?
	Yeah.
	I believe Mr. Jones signed the check, but it was a free speech systems check.
	It was a free speech systems check that Mr. Jones signed.
	Right.
	And did you receive that check before having ever met with Mr. Jones?
	I'm not sure when I met with Mr. Jones.
	I know that I received the check prior to the 14th.
	I'm just not sure if I had already met with Mr. Jones yet.
	Because I arrived in Texas to start interviewing people the week before the deposition.
	So I had already started meeting with people and I believe I met with Alex the first full day I was there.
	What was the basis for the $30,000 fee?
	You mean how did I come to that number?
	Yeah.
	Initially Attorney Pattis made an offer.
	I had thought about how much time I thought it would take to review the material and do the depositions.
	And so I thought that given the amount of time it would take, that would be a fair number.
	How did you know how much time it would take?
	I didn't.
	I had to guess.
	I had to talk to Attorney Blott.
	That was part of the reason why I talked to Attorney Blott how much information was there, how long these videos were, how many videos there were to review to try to estimate how much time it would take.
	Okay, and what was your estimate as to how much time it would take?
	I thought it would probably take around 100 hours.
	It's taken more than that, but I thought it would probably take around 100 hours to review everything, to watch the videos, to go through the relevant material.
	Although I don't think that anyone could go through 80,000 plus pages of material, but I thought it would take around 100 hours.
	When you say 80,000 plus pages, where are you getting that number from?
	Based on my conversation with Attorney Blott and Attorney Pattis, the representation to me was that that was the amount of material that was in the production.
	Okay, the production to whom?
	To the plaintiffs.
	In which case?
	In all of the cases.
	Okay, so your understanding is that 80,000 pages of documents have been produced to the plaintiffs who I represent here in Connecticut?
	In all of the cases.
	Okay, but I'm just talking about in Connecticut.
	I don't know specifically in Connecticut.
	Okay, so when you say all of the cases, what do you say?
	Okay.
	Right.
	Is it your understanding that the plaintiffs have received 80,000 documents or that in total 80,000 documents have been produced to all plaintiffs but that you don't know how many were produced here versus how many were produced in Texas?
	I'm sorry, I don't understand the question.
	You indicated that it was represented to you that 80,000 documents have been produced to the plaintiffs.
	I think what I meant is that free speech has produced 80,000 pages.
	It's free speech's position that we have produced that much material.
	I don't want to speak to what you have or haven't received, but it's free speech's position that we Have produced that amount of material.
	And I'm asking to whom have you produced it?
	I don't know.
	Okay.
	So when you were estimating the amount of time that you would have to spend, you understood that 80,000 documents have been produced and that that was the universe of documents that would be available to you for to review, correct?
	That was my understanding.
	Now, of course, you haven't reviewed 80,000 documents, correct?
	No.
	Okay.
	I'm not even close, right?
	I don't think I have reviewed 80,000 pages of documents.
	No.
	Could you even estimate how many pages you have reviewed?
	I've definitely reviewed thousands of pages of documents over the time I've reviewed this case, but I mean, I can't give it a specific number.
	Okay.
	And I'll ask you a little bit more about that review process.
	And so you anticipated that it would be about 100 hours.
	You've indicated you spent more than 100 hours.
	Right.
	Have you tracked your time?
	I have, yes.
	Okay, how have you done that?
	I have a file management software called CLIO, and I tracked my time on my file management software.
	Okay.
	And have you prepared a document from CLIO memorializing your time for production here today?
	You mean have I exported it out of CLIO?
	Have you brought with you?
	I have not, no.
	Have you brought with you any document showing how much time you spent?
	No.
	Okay.
	How much time have you spent?
	I think the last time I checked my time, it was around 150 hours.
	Okay.
	And since your deposition in Texas, how much time have you spent preparing for this deposition?
	It's been about 50 hours.
	So after the deposition in Texas, I continued to review material, continued to update my spreadsheets.
	I had to also review my depositions down there, speak to counsel, that kind of thing.
	So an additional 50 hours.
	Okay.
	And prior to your deposition in Texas, how much time did you spent preparing in this case?
	It was about 100 hours.
	So you spent about 150 hours all told, correct?
	Total, yes.
	Have you had discussions about an additional fee?
	No.
	Okay, do you anticipate doing that?
	No.
	Okay.
	You see, you brought a binder with you?
	Is that right?
	Okay, and what's contained in that binder?
	These are my notes that I think we've previously emailed to you in my spreadsheets.
	Do you mind if I take a look?
	Sure.
	We'll mark this as exhibit 101.
	And for the record, I'll just describe that there are tabbed spreadsheets, those tabs you created, Ms. Paz?
	Yes.
	and there's also a yellow legal pad with handwritten notes.
	Looks like two and a half pages of handwritten notes.
	Is that right?
	Are these all the handwritten notes you've taken in connection with your work in this case?
	In the whole case, no.
	Yeah.
	Okay.
	Where are the other handwritten notes?
	So I had, at the last deposition, transcribed all of my handwritten notes and typed them up, and then those were taken and marked as an exhibit down in the Texas case.
	So most of my notes are there.
	There's like 30 pages maybe of notes of my interviews with people, notes on some material that I reviewed.
	Those are just notes from my conversation with Mr. Row specifically related to the questions at your deposition notice regarding financials.
	So those were him explaining the documents to me so that I could testify to them.
	but that's what those notes are.
	So your testimony is that you have about 30 pages of handwritten notes that are in Texas that you did not?
	They're typed notes.
	So I transcribed my handwritten notes to Typed written notes, and so the typed pages are about 30 pages.
	Okay, and what about the original handwritten notes themselves?
	Where are they?
	I'm not sure.
	They might be at my house.
	I'd have to look.
	Okay.
	I don't know.
	I don't know where they are right now, but I could look for them.
	Well, you received a notice of deposition directing you to produce all notes that you've taken.
	Well, I had typed my notes, so I typed my handwritten notes.
	So there's a notice of deposition request that you only produce your type notes?
	I can produce my handwritten notes.
	Okay.
	But like I said, I typed them.
	Well, I'm asking you, where are your handwritten notes?
	I think they're at my house.
	Okay.
	And those are notes of all interviews that you conducted?
	Not all of them, but most of them, and then also some of my notes on some of the documents.
	Okay.
	And your testimony is that you transcribed those notes verbatim into a typed document?
	Right.
	And is that contained in this binder?
	No, I didn't type the notes.
	I didn't print the notes, I'm sorry.
	Okay.
	They're not in the binder.
	Okay, so those are just the spreadsheets.
	So what I understand you to be saying is that you have a 30-page typed document that is a verbatim transcription of handwritten notes that you have taken regarding your interviews and document review, correct?
	Right.
	And neither the typed document nor the handwritten notes are being produced today.
	Is that correct?
	I think I emailed the 30-page document to Attorney Pattis at some point previously, but they're not in that binder.
	Okay.
	And you don't know whether they've been produced to us?
	I don't know.
	What you have in the binder are spreadsheets that you created.
	Is that right?
	Yes.
	alright.
	Let's see.
	So we'll get an exhibit sticker.
	And what I'll ask Ms. Paz if it's okay with you and counsel before we leave today, we'll just scan in this as exhibit 101 so that you can retain the original.
	Great.
	You indicated that the two and a half pages of handwritten notes that are contained here relate to a conversation you had with Robert Rowe?
	Yes.
	Okay.
	And when did that conversation take place?
	Oh, you know, I'm not sure of the exact date.
	It would have been within the last two weeks, though.
	What was the purpose of that conversation?
	to prepare for the deposition.
	And did you speak with him in connection with a specific topic that was described in the notice of deposition?
	Yes.
	Which topic was that?
	If I could see the deposition notice, I can tell you exactly which ones, because it was more than one.
	Okay.
	I will bring that up for you.
	Would it be fair to say that although perhaps I'm not describing the topics verbatim, that the topics you were to discuss with Mr. Rowe had to do with compensation paid to Mr. Jones, Kelly Jones, David Jones, as well as the transactions between PQPR and Free Speech Systems?
	Right.
	Okay.
	There's a third page of notes here that appears to say Barden at the top, along with a quotation that appears to say world's worst cut and paste job.
	Is that right?
	Yes, I think that last, it's like a half a page.
	Yeah.
	That's some of the some documents that I had reviewed, but those are unrelated to Mr. Rowe's conversation.
	So what does this relate to, this half page here?
	Some of those might be some document reviews that I was going through.
	I had even written some of the bait stamps down, I believe, that I was reviewing at the time.
	But I think that that refers to a couple of the articles.
	So let me hand this back to you so you can reference it if you need to.
	Yep, sure.
	cough Testing testing testing
	testing Now do you have any, in your current practice with Paz Law, do you have any clients yet as part of that practice?
	Yes.
	Okay, how many?
	A little over 30.
	Okay.
	Some of those were brought with you from your old practice.
	Right.
	And when you left Rowan Law, what was your salary?
	My salary was $90,000 a year, plus I was a partner, so bonuses as Attorney Rowan would meet them out.
	Okay.
	And on average, what percentage of your base salary would the bonus constitute?
	Oh, there was no way to track that.
	It would be based on Attorney Rowan's analysis of how good a quarter we had, and maybe he would give everybody an extra few hundred dollars here, a couple of thousand dollars there.
	So it wasn't anything regular like that.
	But in addition to that, I would get a percentage of whatever cases I originated.
	Understood.
	And you indicated that you were a partner.
	Did you have an equity stake in the firm?
	No.
	Okay.
	How would you describe, prior to being retained in this case as the corporate representative, how would you describe the extent of your knowledge concerning free speech systems?
	Very minimal.
	Okay.
	You certainly had probably never even heard the term free speech systems, correct?
	I don't think so.
	Maybe I had read an article or two that had mentioned it, but it is fair to say I had minimal interaction with the company.
	Okay.
	Other than Mr. Alex Jones, you had no idea of anybody else who was affiliated with the company, correct?
	Yes.
	Okay.
	And you probably thought of Mr. Jones's organization as Infowars, to the extent you thought of it at all, right?
	Sure.
	Okay.
	But you now know that Free Speech Systems is the corporate entity for Mr. Jones' media organization, correct?
	Yes.
	All right.
	Now, you understood when you were first retained here that you would be asked to testify under oath on behalf of the company, correct?
	Yes.
	So as you sit here today, you are offering the sworn testimony of free speech systems, correct?
	Yes.
	And you're presumed to have all knowledge reasonably available to the company, correct?
	To the extent that it's possible, yes.
	And I take it, and you said this a couple times, that you just don't think it's possible within the timeframe that you've been retained for you to familiarize yourself with all the information that's reasonably available to the company, correct?
	Well, it's not just that.
	There are also issues with how the company is structured and run that makes it difficult as well, but that's one of the reasons.
	One of the reasons is just that there's no way somebody in your position with minimal knowledge of the company beforehand could come to enough information to be able to answer the questions within the topics in the notice of deposition, correct?
	I don't think that that's a fair assessment.
	I think I can accurately answer the questions that you've noticed.
	Okay.
	Chris, may I intervene for a second?
	Sure.
	I was surprised to hear Attorney Puzz say that she had sent me notes.
	I checked my emails.
	I missed them, so I just forwarded 25 pages of type notes to you, Eleanor, and to me arriving by email if they haven't already.
	So excuse me, I'm sorry for intervening, but I wanted to let somebody know to look for them, right?
	Thank you.
	So, in your view, you think that you are in a position today to testify to all the information reasonably available to the company under oath, correct?
	Yes, I think that I'm in the best position to answer these questions.
	Of anybody employed by Free Speech Systems?
	I think that's accurate, yes.
	Including Mr. Jones.
	I think that that's accurate.
	And you've come to that conclusion based on a week that you spent down there in Texas, correct?
	Right.
	Okay.
	And even though Mr. Jones started this company over 20 years ago, right?
	Yes.
	And there have been employees of his that have been employed there for 10 years or more, correct?
	Oh, I don't know.
	I know people come and go a lot, so there seems to be a lot of turnover there.
	So I don't know that it's accurate that he has long-standing people there.
	He did at one point, but like I said, they come and go.
	your testimony is that the company doesn't know whether or not other than mr jones anybody has been employed there longer than 10 years I don't know if anybody stay there right now has been there longer than 10 years.
	And when you say I, let's just be clear.
	You're the company, right?
	You're sitting here as Free Speech Systems, correct?
	Right.
	Right.
	And so Free Speech Systems testimony here today is that it does not know whether any current employees of Free Speech Systems other than Mr. Jones have been employed there longer than 10 years, correct?
	I don't know.
	I don't know how to answer that question.
	Well, the answer is either you know or you don't know.
	I don't know.
	Okay.
	But notwithstanding the fact that you don't know that, that doesn't change your view that you are the best person to testify about free speech systems operations, correct?
	No, it doesn't change it.
	And prior to your retention in this case, did you have any expertise in media?
	No.
	Journalism?
	No.
	Do you have any expertise in marketing?
	No.
	Do you have any expertise in advertising?
	No.
	Did you have any expertise in e-commerce?
	No.
	Or accounting?
	No.
	Did you have any expertise in corporate finance?
	No.
	And you had no prior experience with any aspect of free speech systems business, correct?
	Correct.
	Okay.
	And you can't tell me how many pages you reviewed of the 80,000 that were made available to you?
	I think I provided a spreadsheet of, and I tried to go back and put in the spreadsheet what I had reviewed because I didn't prepare anything for the last deposition that I did, so I did try to go back and make a list of things that I had reviewed.
	So I believe you were emailed that.
	But aside from that, I can't give you an exact number of how many pages I reviewed.
	So there's a spreadsheet that you prepared after your last deposition in which you tried to recreate the documents that you had reviewed?
	Well, I received your depot notice and the depot notice, Schedule B specifically asked for it, so that's why I created it.
	Okay.
	But that spreadsheet that you created is your best effort to list the documents that you have reviewed, correct?
	Right, but it's like it's not an entire universe of everything that I reviewed, but what I did review is on there.
	There probably are more.
	Okay.
	How did you decide which documents to include in that spreadsheet?
	As I was going back to review material in preparation for this deposition, if I saw that I had reviewed it in the past, I put it on that document.
	And I also remembered all the depositions that I reviewed, so I put those on the document as well.
	As part of your engagement in this case, have you had any discussions with Attorney Pattis about receiving future referrals of cases for your law practice?
	No.
	Do you expect that to happen?
	No.
	Okay.
	And you, of course, agreed to serve as a corporate representative for free speech systems voluntarily, correct?
	Sure.
	Nobody's making you do this.
	No.
	Okay.
	You yourself have affirmatively chosen that you want to represent Alex Jones in his business, correct?
	As it's as the corporate representative?
	Yeah.
	Okay.
	And you understood when you were retained that there would be a broad range of topics that you would have to educate yourself on, correct?
	Yes.
	Okay, and I take it from your testimony here that you believe it's reasonable that someone with no prior knowledge of free speech systems to obtain all the information, assimilate it, and testify in this period of time.
	I'm sorry, can you repeat that?
	You think it's reasonable that somebody in your position who had had no prior knowledge of free speech systems organization or operations to obtain the information that you've obtained, assimilate it, prepare yourself to testify under oath within the timeframe that you have?
	I didn't say it was reasonable.
	Well, I'm asking you.
	You think it's unreasonable then?
	I thought that probably somebody who was more directly related to the company should do it, but I think that for a variety of reasons that couldn't happen, they needed a corporate representative, and so here I am.
	Okay, so your testimony is that it would have been more reasonable for somebody who is a long-standing connection to the company to serve as the corporate representative, but for reasons that you've not yet described, that was not possible.
	That's your understanding.
	It wasn't possible, that's right.
	It wasn't possible.
	And according to whom was it not possible?
	According to my discussions with counsel.
	Okay.
	Now you're aware, of course, that the company has presented corporate representatives for deposition, correct?
	Yes.
	Michael Zimmerman has served as a corporate representative.
	Yes.
	Rob Dew has.
	Yes.
	Daria Karpova has, correct?
	And each of those individuals have been employed by free speech systems for a significant period of time, fair to say?
	Sure.
	Okay.
	Those are the type of people who you would expect would have the knowledge to testify about free speech systems operations, right?
	Well, I've reviewed their depositions, and I think it was clear that there wasn't preparation done or it wasn't done appropriately.
	And also, I don't think that anyone or them specifically are willing to do it again.
	So, again, no other options.
	So, here are.
	Is Mr. Jones not willing to do it?
	I think that there were discussions that are privileged about whether or not Mr. Jones should do it.
	Well, I'm asking you, and counsel can feel free to assert a privileged objection if they wish.
	I'm asking the company here whether Mr. Jones was willing to serve as its corporate representative.
	know whether he was willing or not Mr. Jones authorized you to speak on his behalf.
	Chris, can you repeat that quickly there was interference?
	Mr. Jones.
	Do you mind if you go off the record real quick?
	I just had something that interference as well.
	Sure.
	I apologize.
	I lost you as well Mr. Maddie.
	can you guys still hear us Can you guys hear us?
	A lot of interference.
	A lot of fonts in here.
	It sounds like someone is in a wind tunnel.
	We are off the record.
	The time is 10.40 a.m.
	EST.
	We are now on the record.
	The time is 10.41 a.m.
	EST?
	alright
	I think the question I was going to ask you, Ms. Paz, before we went off the record, was that was to confirm that Mr. Jones has personally authorized you to speak on his and Free Speech Systems behalf, correct?
	Yes.
	Okay.
	And you know, obviously, that you couldn't testify here on behalf of the company without his authorization, right?
	Right.
	Okay.
	And how much time have you spent with Mr. Jones?
	I spoke to him on the phone once, and I believe I met him twice while I was in Texas, maybe an hour each time.
	An hour each time in person.
	Right.
	And how long did you spend with him on the phone?
	Maybe a half hour.
	Okay.
	And who was present in your meetings with Mr. Jones?
	Counsel.
	Which attorneys?
	Attorney Blott.
	Okay.
	And maybe the tax attorney.
	I can't remember his name, Dustin.
	I can't remember his last name.
	Okay.
	There was a tax attorney present?
	Yeah, Dustin.
	I can't remember his last name.
	Is that first or last name, Dustin?
	That's his first name.
	Okay.
	Assist, it's Dustin Wittenberg, W-I-T-T-E-N-B-E-R-G.
	That's it.
	He might have been there for one of the meetings.
	And did anybody participate remotely in those meetings?
	No.
	Okay.
	And what about in your call with Mr. Jones?
	Who participated in that call?
	Counsel.
	Attorney Blott?
	I believe it was Attorney Blott and Attorney Pattis.
	And you made notes of each of those conversations?
	I don't know if I made notes about my phone conference with him, but the notes about my meetings with him in person are in my typewritten notes.
	Okay.
	Which were transcribed from your handwritten notes.
	We'll see you next time.
	alright So I want to ask you about the 80,000 documents that you had access to, right?
	How would you access those documents?
	So I don't know how many documents were actually on the Dropbox that I had access to.
	I mean, I didn't count them.
	So there was a Dropbox that I was given access to, but I believe that there were only Texas material on there.
	I didn't see anything with Connecticut Bait stamps on them.
	They all had Texas BAIT stamps on them.
	Okay.
	So backing up for a second, initially you were informed that there would be about 80,000 documents within the universe that would be available to you, correct?
	That's what my understanding was.
	And that was from Attorney Pattis.
	And my conversations with Attorney Blott.
	Okay.
	Between Attorney Blott and Attorney Pattis, who represents the Texas defendants.
	Well, Chris, I want to assert the privilege on our communications with her.
	I mean, I don't want to drive too broad a point on this, but I'm going to assert the privilege as your communications with the corporate rep its counsel.
	Okay.
	You understood that there would be 80,000 documents available to you to review, correct?
	That's what my understanding was.
	You were then provided with a Dropbox link, correct?
	Right.
	And that Dropbox link contained a database of documents, correct?
	Right.
	You don't know how many documents were in there.
	I didn't count them.
	No.
	Okay.
	I don't know how many documents.
	And your understanding from your review is that those were documents that were produced to the plaintiffs in Texas, correct?
	Right.
	You did not review any documents that had a base stamp that indicated to you that those documents had been produced in Connecticut, correct?
	Right.
	So, in connection with my preparation for today's deposition, I did inquire as to whether I could review that material.
	And I think that there is an issue related to counsel or prior counsel here getting access to that material.
	But I did inquire, but it wasn't possible for whatever reason.
	And if I guess maybe Attorney Pattis can.
	Well, I've had a conversation with Attorney Powell.
	Well, I don't know what I know.
	I want to know what you know.
	I think that there was an issue regarding Attorney Woolman giving us access to some material, and so I was unable to review that material.
	Okay, and the material you are testifying you are unable to review to review are all materials that were produced to the Connecticut plaintiffs, correct?
	I have not reviewed anything that has a Connecticut bait stamp.
	So, to the extent that the material was produced in Connecticut, I'm assuming that they were also produced in Texas and vice versa.
	So, but I can't confirm that.
	Well, actually, you testified in Texas, did you not, that it was your understanding that different materials had been produced in the two different sets of cases, correct?
	I think what I said was I didn't know what was produced where, and there have been discovery issues that I'm aware of in both jurisdictions, and plaintiffs in both jurisdictions have stated that they hadn't received material.
	But it's Free Speech's position that we've produced all of the material that's available to us in both locations.
	So, as I said in that deposition, same thing I'll say here: I don't know what you have here versus what there is there, but our position is we've produced it all in both places.
	You can see how that's a little bit confusing.
	Where on the one hand you say our position is we've produced everything, on the other hand, I don't know what has been produced here versus what's been produced in Texas.
	Do you understand why that's confusing?
	It's kind of objectionable.
	Can I answer?
	Oh, of course, yeah.
	I don't think it is, and the reason is because I know that there have been claims made by the plaintiffs.
	I believe in both jurisdictions that there is missing material, but as I've stated, it's our position that we've produced everything that we have.
	Okay, and it's your testimony today that your assumption is that you have not reviewed, well, your assumption is that the material that you reviewed in the drop box was produced in Texas, but you cannot say whether it was produced in Connecticut, correct?
	Well, I don't know because it only has a Texas bait stamp.
	So, you just don't know.
	I don't know, right?
	So, as you sit here today, you have no idea whether you've reviewed material that has been produced to the Connecticut plaintiffs, correct?
	I don't know.
	Okay.
	What you do know is that the materials you reviewed all had Texas bait stamps on them.
	Yes.
	And no Connecticut bait stamps.
	Right.
	Okay.
	When did you get access to that drop box?
	It might have been either right when I was retained or shortly before.
	And how are the documents arranged?
	So there's a little bit of disorganization.
	While I was reviewing material, they were actively trying to reorganize it.
	But there was, as they reorganized it, they did try to reorganize it by plaintiff, but there mostly was just one big discovery folder with all of the documents that had been produced and no real rhyme or reason to it.
	So I did try to narrow my focus by entering some search terms just to try to direct my attention to what would be relevant or what would be mostly relevant.
	But the organization on the Dropbox was a little lacking.
	Were they organized in a database or were they just individual files?
	You mean individual like folders?
	I mean like you say that you use search terms.
	Right.
	So what was the program you were in where you were entering search terms to Okay.
	And the documents were or were not organized in folders within the Dropbox?
	They were in folders, but some material wasn't where it was supposed to be.
	Like for example, they did have folders for each plaintiff, Texas plaintiffs.
	They did have folders for each of those, but most of the in the folders weren't discovery.
	It was mostly pleadings.
	And so there was really mostly discovery in a folder labeled discovery, I believe.
	So most of it was just all in there without rhyme or reason.
	So to narrow my focus, I had to use some, I had to use search terms.
	Okay.
	And what search terms did you use to try and find documents that were most relevant to your own task?
	I did try to use search terms for the plaintiff's names, Sandy Hook.
	I believe I used Halbig.
	I believe I used False Flag.
	There may have been one or two others just to try to narrow the focus of my search.
	Did you keep a list of the search terms you used?
	No, I don't have a list.
	I'm sorry.
	all right Why don't we take a look at exhibit number one?
	This is the notice of deposition.
	Just tell me when you get it on your screen.
	going to try and present most of these electronically Do you have that before you?
	Yes.
	Okay.
	And this is a documentated March 11th, 2022, right?
	Yes.
	But you've seen prior versions of this.
	Yes, I don't think I've seen this particular version.
	I might have seen the one prior.
	You probably haven't because you know that this deposition was originally scheduled last week.
	You had some unforeseen scheduling conflicts, so we had to move it.
	It was originally scheduled for the 8th and then the 9th, and then prior to that.
	So fair to say, you saw this document, although it's not dated, although perhaps not dated March 11th, soon after you were retained, correct?
	I believe the first time I saw a depot notice for a Connecticut deposition was the week that I was in Texas.
	And it was a version of this.
	It might not have been the same version, but that's the first time I believe I saw a depot notice for this depot.
	And when was that week that you were in Texas?
	I was there from the 8th to the 15th.
	So the Tuesday to the Tuesday.
	Of February.
	Of February.
	All right.
	So you've had the notice of deposition.
	I'll represent to you that other than the Schedule B, which requested that you bring your notes, the topics are the same as would have been in the original notice you received in February?
	I just, with one exception, I think there was one notice that I saw that had an added number 11 was added.
	Why don't we go down to the topics?
	Because I think the first one I noticed I had notice of, there were only 10.
	Okay.
	Well, in any event, if you look at this notice, if you look at the topics here in Schedule A, 1 through 11, you believe you're prepared to testify under oath in response to questions on those topics, right?
	Yes.
	On behalf of the company?
	Yes.
	Alright.
	So let's talk about, let's see.
	you testified that you took about well you took handwritten notes by the way how many pages would you say are the handwritten notes that are at your house?
	Oh I don't know.
	Okay.
	I have very large handwriting as you can see so that they were reduced to about you said about 30 pages right?
	Right probably maybe a little bit less but around there.
	Okay so since we've been here Attorney Pat has sent us an email with a document and so why don't we pull that up and that'll be exhibit 102.
	so Okay.
	Do you see that document before you?
	Yes.
	All right.
	And does this appear to be the transcribed notes of yours?
	Yes.
	When did you first start working on this document?
	Very shortly after I was retained.
	So first week in January first week in February.
	Okay.
	And when did you most recently work on this document?
	If you could scroll down to the end, I'll...
	You're referring to the handwritten notes?
	Right.
	These handwritten notes, I never transcribed onto this, which is why I brought this.
	So just for the record, you're referring to the handwritten notes containing Exhibit 101 relating to your conversation with Mr. Bro.
	Right.
	Okay.
	So why don't we scroll down to the bottom of this document to see if Ms. Paz can tell us when she most recently worked on this?
	Okay, so it's probably been maybe two weeks or so because this goes through some of my review of my deposition from the Texas case because it's talking about the errata sheet.
	So it's probably been maybe two weeks since I worked on this.
	Okay.
	And are you able to tell from this document notes that you made since your deposition there?
	Oh, I don't think I dated, I don't think I dated it, but this last page of notes are notes that I made after my deposition down there.
	Let's scroll up to page 24 and see if you can tell from that whether any of those notes were also made following your deposition.
	It looks like this page is material and notes that I made in preparation for the Texas deposition.
	Okay.
	So going back down to page 25, I take it that your testimony is that the portion of notes starting with errata for 21422 depot is probably where you started taking notes following your deposition, right?
	No, I had read David Jones's depot after that and then Alex's depot from November 2019.
	There was one deposition, one of Alex's three depositions that I hadn't read, so I went back and I read it.
	So most of this page is in preparation for today.
	Okay.
	Now, as of your Texas deposition, I understood that you had read only one or two depositions that had been given here in the Connecticut case, right?
	One or two.
	No, so I had read, I had read Mr. Jones' depot.
	I had read Mr. Daniels' depot.
	I believe I read Mr. Salazar's depot.
	Then that might be it.
	Okay.
	So, Mr. Jones, you're referring to Alex Jones?
	Yes.
	Okay, you know, he has not been deposed in Connecticut.
	Oh, okay.
	He had three depositions, and I read two of them, but I had missed one, so I went back and read the last one.
	Okay, so the only two depositions that were given in Connecticut that you had reviewed as of your Texas deposition were Kit Daniels and Adan Salazar?
	You know what?
	I'm not sure who has been deposed where.
	So I also read Blake's deposition.
	It might have been here.
	I also read...
	I assume that testimony was true, correct?
	Right, well what I'm saying now is I don't, I don't, I'm not sure as I sit here whether they were taken in Texas or here.
	Does that make sense?
	It does, that you don't know, but your testimony in Texas was that you knew that you had read one to two that were taken in Connecticut.
	Right.
	So which ones were those?
	Kit Daniels, I definitely read his, and I'm not sure which other one I read.
	Fair enough.
	Now, since that deposition, have you read depositions that were given in the Connecticut case?
	Yes, so I read, and like I said, I'm not sure if Dr. Jones' depot was here or down in Texas.
	It might have been here.
	So I've read Dr. Jones' depot.
	I definitely read Mr. Salazar's depot.
	Like I said, I'm not sure if it's here or there.
	I read Mr. Zimmerman's depot, but like I said, I'm not sure if it's here or there.
	And that might be it.
	Okay.
	So since your Texas deposition, you've read three additional depositions, Dr. Jones, Adan Salazar, and Michael Zimmerman, correct?
	I think I had already read Mr. Zemmerman's depot.
	I don't think I've reread it.
	I think I read it for the Texas deposition.
	So I think I had already read that.
	Mr. Zimmerman was deposed in Texas.
	Okay, so like I said, here's my problem is that I'm not sure where they've been deposed because some of them have been deposed multiple times in both jurisdictions.
	So I'm not sure.
	Like I know Blake has been deposed here and he might have been deposed in Texas as well.
	So I'm not sure where the depositions are is my point.
	But what I'm asking you is whether you can testify as to any depositions you've reviewed.
	And let's, by the way, put aside where they were given.
	What depositions have you reviewed since you gave your deposition to Texas?
	Oh, so you mean in the last month?
	Yeah.
	So I read that last Mr. Jones, Alex's deposition that I hadn't read because there were three and I only read two.
	I read Dr. Jones' depot.
	I read Kurt Nimmo's depot.
	And I believe I read Adon's depot because I hadn't read that before.
	And so that's it.
	And the only depositions that you made notes about were Dr. Jones's and Alex Jones's correct?
	No, not necessarily.
	So this last paragraph down here, just looking at my notes, I'm talking about Adan Salazar's article.
	Those are notes that I took when I was reading that deposition.
	They are.
	That you took that last paragraph, you made a note while you were reading his deposition?
	Because I remember they talked about that article.
	So that's a note that I would have taken then.
	Which article?
	Quote: Sandy Hook victim dies parentheses again in Pakistan.
	Okay, so your understanding is that he was asked about that in his deposition?
	I believe so.
	Okay.
	Well, was he or wasn't he?
	It's my recollection as I sit here.
	Okay.
	And so you believe that this paragraph had to do with that portion of the deposition as you were reviewing it?
	I think so, yes.
	Okay.
	You didn't take any notes about, and this is the only note you would have taken from Mr. Salazar's deposition?
	That's what it appears, yes.
	Okay.
	Well, these are your notes.
	That's what it appears, yes.
	Okay.
	When you say that's what it appears, that suggests to me that you're not sure.
	No, I'm sure.
	I mean, I'm reading, I'm looking at my notes, and that's the note.
	Okay.
	From your review of his deposition.
	Right.
	Okay.
	You didn't take any notes concerning Blake Roddy's deposition, correct?
	I don't think so.
	No.
	You didn't take any notes concerning Kurt Nimmo's deposition?
	No.
	Okay.
	So if we can go, do you have a list of all the depositions you reviewed anywhere?
	I think on the spreadsheet that I prepared in connection with today, I did list deposition transcripts that I reviewed.
	It might not be a complete list, but there's a list on there.
	So your understanding is that a spreadsheet has been produced to us.
	Yes.
	And that that spreadsheet contains depositions that you reviewed, but you can't testify as to whether it's complete.
	right okay we'll bring that up in a minute In addition to Alex Jones' interview, who else did you interview in connection with your preparation in this case?
	When I was down in Texas.
	At any time.
	So I had a Zoom interview with Rob Dew prior to going down to Texas because he was not going to be available.
	I interviewed Alex as I previously stated.
	I interviewed Melinda.
	I interviewed Daria.
	I'm going to stop you just so we can be clear here.
	Sure.
	You interviewed Melinda Flores.
	Yes.
	And Daria Karpov.
	Yes.
	Both of whom are current employees of Free Speech Systems.
	Yes.
	Okay.
	And you interviewed Rob Dew by Zoom?
	By Zoom, yes.
	Okay.
	Is he currently employed by Free Speech Systems?
	He's a contractor.
	Okay.
	He had previously been employed.
	Correct.
	Okay.
	When did he separate from the company as a full-time employee?
	I don't recall.
	It was in the past year.
	Okay.
	Continue.
	I interviewed Mr. Rowe, Robert Rowe.
	I interviewed Adon Salazar.
	I interviewed Kit Daniels.
	I had a telephone conversation with Kurt Nimmo.
	I had a Zoom meeting with Paul Watson.
	I spoke to Blake Roddy on the phone, and I spoke to him in person when I was there.
	I met the warehouse manager.
	Her name is Kelly.
	Do you know her last name?
	I'm sorry, I don't know her last name.
	I said you met her.
	Did you interview her?
	Well, I mean, I don't know if we call it an interview.
	She showed me the warehouse.
	We talked about how operations ran so that I could understand how that worked.
	Did you make notes of that interview?
	No, I don't have notes of that.
	Then I also spoke on the phone with Tim Fruget.
	And that might be it.
	Well, is it it or isn't it?
	As I sit here right now, that's, I think it's it.
	Okay.
	You also interviewed Nico Acosta, didn't you?
	No, I don't think I could get him on the phone.
	You know what, I don't remember.
	I'm not sure.
	Okay.
	I don't remember me.
	Oh, actually.
	I'm sorry.
	May I have one minute?
	Okay, so I think I did speak to Nico, but I didn't speak to Kurt.
	That's who I didn't talk to, Kurt.
	I couldn't get Kurt.
	I couldn't speak to Kurt.
	But I spoke to Nico on the phone.
	Right.
	You're right.
	Okay.
	Who else?
	I think that's it.
	Okay, do you have a list of the people that you interviewed?
	If you scroll up.
	This is on exhibit 102?
	Yes.
	to just the first page.
	So, right, you're right.
	Nico Acosta is on there.
	Is this the list of all the people you interviewed?
	With just the addition of Tim Fruget, because I had spoken to him last week or the week before, and I hadn't updated this.
	Is that the only person you interviewed since your Texas deposition?
	No, I also spoke to Blake on the phone again.
	Okay.
	And so you've had an interview with Blake Roddy, and you've had an interview with Tim Fruget since your Texas deposition.
	Right.
	And as I previously testified with Mr. Rowe as well to talk about the information in the depot notice.
	He's listed here as Co., but you mean?
	It is a typo, yes.
	And did you make notes of your conversations with Tim Fruget or Blake Roddy?
	I don't believe so.
	No.
	How did you decide who to interview?
	In preparation for the Texas depot or today?
	Both.
	I tried to speak to people who I thought would have relevant information so that I could prepare myself about how the company works, how it's structured, and answer the information and the questions in the depot notices.
	Okay.
	And the only source of information you'd have had to be able to assess who to interview came from counsel, fair say?
	You mean how did I make, how did I know who to interview?
	Yeah.
	They made suggestions as to who I should interview.
	Right.
	I mean, before you started this, you had no idea who Rob Dew was, right?
	Well, right, but I would want to speak to him anyway because he's in the videos.
	So they wouldn't have had to suggest that to me.
	I would have wanted to talk to him anyway.
	Right.
	Right.
	And Mr. Halbick is in the videos too, right?
	Right.
	Did you attempt to speak to him?
	No.
	Okay.
	Even though you know how to contact him, correct?
	Why would I know how to contact him?
	Well, your free speech systems.
	Is it your testimony that Free Speech Systems does not have contact information for Wolfgang Halbick?
	We're not in contact with him.
	That wasn't my question.
	I don't know if we do or don't.
	I haven't made an attempt to contact him.
	Okay.
	He's not a free speech employee.
	Okay, so, well, neither is Nico.
	Not anymore, but he was.
	Right.
	Right.
	And neither is Rob Dew, correct?
	He's still a contractor there, but no, he's not.
	And Michael Zimmerman is not employed by Free Speech Systems, correct?
	Right.
	All right.
	Kurt Nimmo is not employed by Free Speech Systems, right?
	Not anymore.
	Okay.
	So, obviously, the fact that Mr. Halbig is not employed by Free Speech Systems had nothing to do with why you didn't try to reach out to him, correct?
	No.
	Objection argumentative, you can answer.
	No.
	And as you sit here today, Free Speech Systems can't testify as to whether it has Mr. Halbig's contact information?
	No.
	Okay.
	Did you inquire?
	No.
	Personally.
	You didn't inquire?
	No.
	Okay.
	So you had no desire to speak to Mr. Halvick?
	Um Um And what about Dan Bedante?
	Did you make any effort to speak with Dan Bedanti?
	No.
	Okay.
	He was in the videos that you reviewed, right?
	A couple of them, yes.
	Yeah.
	And he was a reporter for Free Speech Systems, correct?
	He was a contractor.
	He was a reporter, correct?
	He was a contractor.
	So Free Speech Systems position and testimony is that Dan Bedanti was never a reporter for them?
	He was a contractor.
	Okay, do you understand my question?
	I understand your question.
	He was never employed by Free Speech Systems.
	Every once in a while, he would do some material, and Free Speech would either choose not to air it or choose not to air it.
	Sometimes Free Speech had sent him to a place to get a video, but otherwise, he was never employed there.
	It's your testimony that Mr. Bedanti has never been employed by Free Speech Systems.
	To my knowledge, no, he's been a contractor.
	And that's to the company.
	Free speech systems.
	Free speech systems sworn testimony is that Dan Benanti has never been employed by Free Speech Systems, right?
	I believe he's an independent contractor.
	I need you to just, and you're an attorney, Ms. Paz, so I need you to just answer the question I ask you.
	The question I asked you was, "Am I correct that Free Speech Systems'sworn testimony is that Dan Bedondi has never been employed by Free Speech Systems?" Yes.
	Okay.
	And is it free speech systems testimony that Dan Badandi has never worked as a reporter for free speech systems?
	And is it free speech systems?
	I'm sorry, can you repeat the question?
	Has Dan Badandi ever worked as a reporter for Free Speech Systems?
	I believe he did work as a contracted reporter.
	Okay.
	So that's a fair assessment.
	And it's a fair assessment because Mr. Jones, Alex Jones, has referred to him as a Free Speech Systems reporter, correct?
	I believe he has, yes.
	He's referred to him on air as a free speech systems reporter.
	Yeah.
	Right?
	Yep.
	And a wild man, right?
	I don't know if he said wild man, but I've heard him refer to him as a reporter.
	Right.
	Okay.
	So it.
	Fair enough.
	And you chose not to attempt to interview Mr. Bedanti, correct?
	Yes.
	Did you make any effort to interview Lydia Hernandez?
	No.
	Do you know who Ms. Hernandez is?
	I believe she was previously employed as either accounts receivable.
	She used to work to QuickBooks, but I think she's the predecessor to Ms. Flores, but I spoke to Ms. Flores.
	Okay.
	So you know that Ms. Hernandez was an accountant at Free Speech Systems, correct?
	I don't know if that was her title, but I know she was Melinda's predecessor.
	Okay.
	Do you know she's been deposed in this case?
	I'm not sure.
	But you didn't make any effort to speak with her?
	No.
	Did you make any effort to speak with David Jones?
	No.
	David Jones, do you know what his position was at Free Speech Systems?
	The objection to the form seems to pack that in evidence.
	Currently?
	At any time.
	He doesn't work for Free Speech Systems right now, does he?
	I don't believe he does.
	Okay.
	He was previously an employee, right?
	I don't know.
	I'm sorry.
	I don't know if he's ever been on the books.
	I'm not sure.
	Did you make any effort to speak with him?
	No.
	Okay.
	All right.
	So Free Speech Systems is a for-profit media company, correct?
	Yes.
	Okay.
	It's owned 100% by Alex Jones.
	Is that right?
	Yes.
	And Mr. Jones has 100% control over how its revenue is allocated, correct?
	Yes.
	Okay.
	And Free Speech Systems owns a number of media assets, is that right?
	I don't understand the question.
	Free Speech Systems owns a number of websites, correct?
	Yes.
	It owns band.video.com, right?
	Yes.
	It owns Infowars.com?
	Yes.
	It owns newswars.com, right?
	I'm not sure.
	Okay.
	And Free Speech Systems also owns a number of programming properties like the Alex Jones Show, correct?
	Yes.
	The War Room with Owen Schroyer.
	Yes.
	Okay.
	And it also owns other live programming, correct?
	Yes.
	All right.
	It owns and publishes articles on its website, Infowars.com, correct?
	Yes.
	And on newswars.com, correct?
	Like I said, I'm not sure about NewsWar.com.
	Okay.
	And the articles that it publishes includes both original articles that Free Speech Systems employees author, correct?
	What do you mean by original articles?
	Articles that Free Speech Systems employees author.
	Yes.
	Okay.
	And also it links to other articles on other websites, correct?
	Right.
	Okay.
	And what is the strike that the Alex Jones show is broadcast daily via radio, correct?
	Yes.
	Okay.
	And does Free Speech Systems know what Mr. Jones' current weekly radio audience is?
	Just on the radio?
	No, they broadcast on a number of different radio stations.
	So there's quite a few, but there's really no way for free speech to tell how many people it reaches on a daily basis.
	I talked to Alex about this, and his position is that it's free to air and it's on the airwaves and anyone can listen to it.
	So he doesn't know how many people actually are reached by it on a daily basis.
	How many stations, radio stations, broadcast the Alex Jones Show?
	I don't know the number, I'm sorry.
	Okay.
	And Free Speech Systems can't testify as to what its weekly radio audience is.
	No.
	What about on the website?
	And let's just stick with Infowars.com for a moment.
	How many unique visitors are there on Infowars.com per week?
	If you could show me the document, I could testify to it as more accurately, but I can't say that from memory.
	Okay.
	I'm sorry, does Free Speech Systems have a social media presence?
	You mean on like Twitter and Facebook?
	No, I mean any social media platforms.
	I believe they do have at one point they may have been kicked off at now, but at one point they did have social media presence.
	What social media platforms does Free Speech Systems currently have accounts on?
	Currently?
	I'd have to check to see if they're still active.
	I'm not sure.
	Okay, so your testimony today is that Free Speech Systems doesn't know any social media platforms on which it has current accounts, correct?
	I don't know which ones are current.
	That's right.
	Do you know of any that are current?
	I don't want to say without checking, so I don't know.
	Okay.
	Well, what would you check?
	I'd have to check to see if the social media platforms are active.
	How would you do that?
	Try to log in or ask somebody to try to log in.
	But without knowing what accounts to log into, how would you know what to log into?
	That's what I'm saying.
	I don't know, so I can't testify to it.
	Okay.
	So if you were to check, you'd have to ask somebody at Infowars, right?
	That's right, and you haven't done that.
	No.
	Okay.
	Does Free Speech Systems have an email list?
	You mean an email subscriber list?
	Yeah, yeah.
	I believe we do, yes.
	Okay, how many people are on that email list?
	Oh, I don't know.
	Okay.
	Does that go out daily?
	I don't know how often it goes out.
	So as you sit here today, I take it you're not prepared to testify about Free Speech Systems audience size in any respect, correct?
	Right.
	Okay.
	All content published by Free Speech Systems is free, correct?
	Right.
	Okay.
	And Free Speech Systems on Air Star is its owner, Alex Jones, correct?
	It's star?
	Star.
	Star, yes.
	Okay.
	And he has complete creative control over what's published by Free Speech Systems.
	Is that correct?
	You mean by the other hosts and written content on the website?
	Correct.
	I wouldn't say complete control.
	I think that based on my interviews, it's been conveyed pretty much universally that everybody has freedom to write what they want and to go on air and talk about what they want within some parameters, but I don't think he has universal, exclusive iron fist control over that content.
	No.
	Mr. Jones, if he wanted to, could decide what gets published and what doesn't, correct?
	If he wanted to?
	Yeah.
	Sure.
	Right.
	He is the only person within the organization that has authority to either approve something for publication or preclude it for publication, correct?
	No, I don't think that's accurate, especially now.
	So I think post these lawsuits, there was a little bit more of an effort to monitor some of the things that were being published.
	So like for example, in my conversations with Kit Daniels, he makes sure there's an editing, you know, there's a process by which there's circulating of articles to make sure they're appropriately backed.
	Or I know that, especially after the Fontaine issue had happened, to make sure that if there is an accusation against somebody for criminal issues, that that is appropriately sourced.
	So there is some supervision there as far as what should and shouldn't be published.
	Yeah, I'm going to ask you about policies, but right now I'm just asking you about Mr. Jones's authority.
	Okay.
	There's no question that if Mr. Jones wants something published, it gets published, correct?
	Sure.
	And if Mr. Jones doesn't want something published, it doesn't get published.
	I think that my issue here is that I don't think he's monitoring what is getting posted before it's getting posted.
	So if there is something that is posted that he doesn't like, he'll talk to somebody and say, hey, you know, I didn't like this or don't do this in the future.
	Perhaps he pulls it.
	But that doesn't happen very frequently.
	So I don't think there is a process by which he's telling people, don't do this, don't do that.
	There was a time after Sandy Hook happened and then the lawsuit, not maybe before the lawsuits, but he did ask people to stop talking about Sandy Hook.
	So there is some control that he is exerting over the writing process and the production process.
	But for the most part, I think it's pretty lax there as far as what people want to say they could write about and they can produce.
	Okay, well, let me put it this way.
	To the extent it's lax, that's because Mr. Jones allows it to be lax, correct?
	Sure.
	Right.
	And if Mr. Jones saw something that was published that he didn't want published, he has the authority to take it off, right?
	Sure, he has the authority.
	And so you don't disagree with Rob Dew's testimony as a corporate representative in Texas that any information that goes on the air is vetted by Alex, correct?
	Vetted by him?
	Yeah.
	Free Speech Systems has previously texted, testified Under oath in Texas, that any information that goes on the air is vetted by Alex Jones, correct?
	I don't think, I don't know that I would agree with that.
	Okay, so Free Speech Systems today doesn't agree with the testimony it gave in Texas that all information that goes on the air is vetted by Alex Jones, correct?
	The reason why I wouldn't agree with that is just because as I've talked to all of those people we already described, the position has been that if people want to talk about something or say a show, they're doing a show that particular day, they decide what they want to talk about and they pull that material and then they go on the air.
	So I don't think it's accurate to say like, for example, if there is a show that's being produced that particular day, Alex isn't the host, that he has pre-reviewed all of the things that that host is going to talk about.
	He has prevented everything that host is going to talk about.
	So no, I don't think that's accurate.
	Okay.
	And how long has Rob Dew worked at Free Speech Systems?
	I don't know how long he's been there.
	He's been there a while.
	Right.
	I mean, he's Alex Jones' before he left to become a contractor.
	He was really Alex Jones' right-hand man, right?
	I don't know that I would describe him as a right-hand man, but he worked there for a while, yes.
	Did anybody describe him to you as a right-hand man?
	Not using that phraseology.
	Okay.
	I mean, are we going to have a dispute about whether Rob Dew was one of Mr. Jones' most trusted employees?
	Or more committed.
	I can't answer that.
	Free speech systems can't answer that?
	No.
	Okay.
	It's an opinion.
	So your testimony is that when Mr. Dew testified under oath in Texas that any information that goes on the air is vetted by Alex Jones, that Free Speech Systems now rejects that testimony?
	If that's what the testimony was, then I don't think it's accurate.
	Okay.
	And when Mr. Dew testified that Alex Jones has full control of what airs, was that accurate?
	He testified to that on behalf of Free Speech Systems as well.
	He does not previously review what was going on air, so no.
	Okay, so, but the question I asked you was whether Mr. Dew's testimony that Alex Jones has full control of what airs was accurate or inaccurate?
	I don't think it's accurate.
	Mr. Jones is responsible for all policies and practices, correct?
	Ultimately, yes.
	And he sets the corporate culture at Free Speech Systems?
	Yes.
	And his team takes his lead on what should be covered, correct?
	I think that's fair.
	I think there's obviously an understanding that there's an ideology and to stick within that ideology.
	That basic ideology is that is Mr. Jones's worldview that an international group of money interests are trying to bring about a new world order that establishes a tyrannical global government to strip away individuals' liberty and enslave the world, right?
	I don't know if I would phrase it like that, but sure.
	That's accurate, right?
	I don't know if I would phrase it like that, but sure.
	Okay.
	It might be one of other things.
	For example, they also focus on Second Amendment rights.
	We understand that the Second Amendment is well, actually, I think she did finish her answer.
	I asked her whether that was the ideology, and she said that you might not phrase it that way, but sure.
	But you understand that the...
	It's a question for the president, but I think you should be going to finish.
	But I couldn't, Chris, I don't want to make this into a thing between lawyers.
	Yeah, well, I'm not withdrawing the question, but let me ask you this about the Second Amendment.
	Is it your understanding that the reason that Free Speech Systems advances a pro-Second Amendment agenda is so that the populace can be armed against this tyrannical global government that Mr. Jones sees coming, correct?
	No, I think that I think he sees the Second Amendment as an individual liberty.
	Talk about the Second Amendment with him?
	Have I asked him specifically about this question?
	No.
	No, you asked him about the Second Amendment.
	Have I talked to him specifically about the Second Amendment?
	No, but this is the first time.
	He hasn't told you what he thinks about the Second Amendment.
	It's based on my review of the material.
	And your review of the material tells you what about Mr. Jones' view of the Second Amendment?
	that he believes it's an individual liberty.
	Now, through the publication of all of this free content across all of Free Speech Systems platforms, Free Speech Systems has built an audience of approximately 135 million people, right?
	I don't know what the number is.
	I can't subscribe to a number.
	Did you review Mr. Jones's testimony in Texas that he estimates Free Speech Systems audience to be about 10% of the English-speaking world?
	I've had conversations with Mr. Jones about that.
	Did you read his deposition testimony where he testified under oath that he estimated free speech systems audience to be about 10% of the English-speaking world?
	I don't recall, but like I said, I see.
	So you don't recall reading that deposition testimony?
	I don't recall that specific statement in the deposition.
	That's all I asked you.
	Do you disagree with that as free speech systems?
	No.
	Okay.
	And so do you have a reason to dispute here today as Free Speech Systems that the approximate audience for Free Speech Systems is about 135 million people worldwide?
	I don't know the number, so I don't know whether to agree or disagree.
	Okay, so you don't dispute it?
	I don't know either way, so it could be or it couldn't be.
	Okay, Free Speech Systems just doesn't know.
	And it's never charged any of those individuals to view any of its content, correct?
	Right.
	But that audience is extremely financially valuable to Free Speech Systems, correct?
	In the sense that they buy product?
	Sure.
	I mean, Free Speech Systems customer base is its news audience, correct?
	I wouldn't call it news, but its audience that is listening to it ultimately buys products on the website for its website sales.
	So, yes.
	So, whatever we call the content that Free Speech Systems pushes out, the audience for that content is its customer base for the nutritional supplements and other products it sells on the stores it operates, correct?
	Right.
	Okay.
	And so people come for the content, which is free, and then pay for the products, right?
	If they want.
	Right.
	And the products that it sells to its audience are dietary supplements, right?
	Yes.
	Storable food?
	Yes.
	Okay.
	Other types of merchandise.
	There's a lot of merchandise, yes.
	I was in the warehouse.
	A lot of various different types of things.
	Okay.
	Of course, you know that the overwhelming majority of sale proceeds stem from the sale of supplements, correct?
	Yes, that is a big seller.
	And those products are sold on InfowarsStore.com, right?
	Yes.
	Which is heavily advertised on the Infowars.com website?
	Yes.
	They're also sold on the Infowarshop.com, right?
	I believe so, yes.
	And Amazon, correct?
	Yes, it is on Amazon.
	And eBay.
	I'm not sure about eBay, but it is on Amazon.
	And Free Speech Systems advertises those products for sale to its audience across all of its platforms, correct?
	You mean online and on video?
	Yeah.
	Yes.
	So like all of its live programming, they advertise for its products, right?
	Yes.
	They have advertisements all over the Infowars.com website, correct?
	Yes.
	In fact, like the landing page when you go to the Infowars.com website is an advertisement to buy its products, right?
	Yeah, there's like banners and ads and stuff to click directly to the store.
	That's right.
	Okay.
	Does it advertise anywhere other than its own platforms?
	Could you be more specific?
	Yeah.
	Does it pay to advertise anywhere else other than on properties it controls?
	I believe so.
	If I Could refer to my notes.
	This is one of the topics that I believe I spoke to Mr. Rowe about.
	So there were some advertising payments that we made, and I believe we did produce these spreadsheets advertising payments to other companies and then advertising payments that we received from other places via income.
	So I think we provided that information on the spreadsheets.
	I designate this portion of the deposition attorneys only confidential, as it's insofar as it contains pre-speech systems relationship with third parties and advertising and revenue and so forth.
	Okay, yeah.
	I'm not going to ask Attorney Pattis at this point about the identities of any third-party advertisers or the amounts paid.
	So I'm just not going to do that.
	Again, Chris, I get that.
	I just didn't know.
	Yeah, yeah, no, fair enough.
	Why don't I do this?
	Why don't I, if you want to, when I get to that, I will let you know before I start asking those questions so that you can designate it confidential.
	That's fair.
	No, I really didn't mean to be disruptive.
	I thought we might be going from generals to particulars, so I'll withdraw the objection and stand for you here.
	Okay, all right.
	So speaking only generally, Free Speech Systems does pay for advertising on third-party owned properties, right?
	Right.
	Okay.
	But in essence, the company attracts a customer base with its free news.
	Let me withdraw that because I know you're going to quibble with me about the word news.
	But free speech systems.
	I just lost everybody.
	Hold on.
	Hold on.
	I just lost you.
	I lost the audio.
	I will show that because I know you're going to.
	Well, it's withdrawal.
	Oh, okay.
	Strike that question.
	I'll start over.
	Can you hear me now?
	Yes, I can.
	Thank you.
	Yes, sir.
	In essence, Free Speech Systems business model is to attract a customer base with its free content and then to sell them products when they get there for it, correct?
	I think that's accurate, yes.
	Okay, that's how the company makes money.
	Right.
	Right.
	Okay.
	The more people come to Infowars.com, the more people go to the store, the more people buy stuff.
	Right.
	I mean, it's not just more people in quantity.
	It's also, a lot of it is the same people keep coming back.
	So it's not just, you know, you keep getting new people.
	A lot of it is the same people keep coming back to repurchase.
	Although you've seen some of the Google analytics for audience growth from 2012 on, correct?
	Yes, I believe it is.
	And the audience has grown each year, correct?
	I believe it's grown, yes.
	The more people that are coming to the website, Infowars.com, the more people are buying stuff, right?
	Well, that's assuming it translates into purchases, but the website traffic is increasing, yes.
	And you know that revenue has increased as well during that time.
	I'd have to review the numbers.
	I'd have to review it.
	Okay, so as Free Speech Systems sits here right now, it's not able to testify as to whether revenue has increased from 2012 onward.
	I don't know as I said.
	I'm not speaking of Mirman's argumentative.
	I think she wanted her recollection refreshed and objection as to former argumentative.
	If you could show me a document, I'd be able to testify accurately to it.
	I just, as I sit here right now, I don't recall.
	Right.
	And that's all I'm saying.
	Is that as you sit here right now, without the benefit of any document, you can't testify even generally that free speech systems revenue has increased from 2012 on.
	Right, I just don't recall.
	Okay.
	And did you talk to Mr. Fruget about that?
	Did I ask Mr. Fruget about whether about revenue?
	About whether revenue did?
	No, I didn't ask him that.
	Did you read his deposition?
	I don't recall.
	I don't think I read his deposition.
	I spoke to him on the phone, but I don't think I read his deposition.
	Let's talk about this distinction that you've made a couple times in the deposition so far, which is, as I interpret it, a resistance to describe what InfoWars does as news publication.
	Okay.
	Did I sense that correctly?
	That's fair.
	Okay.
	And so InfoWars does not, and when I say InfoWars, let's also kind of just make this clear.
	I may at times, throughout the deposition, refer to Free Speech Systems as Infowars.
	I know what you're talking about.
	Right.
	Free Speech Systems essentially does business through the brand of InfoWars, correct?
	Right.
	Okay.
	And so sometimes when we talk about all of free speech systems media platforms or properties, we kind of can group them under the umbrella of Infowars, right?
	Sure.
	I'm going to try and use the Free Speech Systems designation because that's the corporate entity.
	Right.
	But we can use those terms interchangeably, right?
	That's fair.
	That's fine.
	So you have.
	I take it that free speech systems testimony is that it is not a news organization, correct?
	That's correct.
	It does not disseminate news.
	That's correct.
	Okay.
	And it is not engaged in the practice of journalism.
	That's correct.
	Okay.
	It does not participate in the independent discovery or verification of facts, correct?
	On the whole, yes, that's correct.
	Okay.
	And when you say on the whole, you mean that it wouldn't be fair to say that what Free Speech Systems does is independently verify facts, correct?
	That's correct.
	It doesn't do that.
	No.
	And I think I've previously testified to this.
	98% of what they do is pungentry or commentary on the news.
	But that was in the Texas deposition, which I know you read.
	You did testify to that.
	I did read it.
	In fact, you testified to that repeatedly.
	I believe you testified that Free Speech Systems is not doing independent researching and not really engaging in 99% of the time in journalism, right?
	I think I said 98.
	That was the number that Alex gave me.
	You did say, you said 98 at certain points, and then you said 99, and then I saw that you corrected the 99 in your errata and made it 98.
	I think it might have been a misstatement or whatever it was, but 98 is the number that Alex used in my discussions with him.
	Right, right.
	And when he said 98%, what he was saying was that 98% of the time they're just not engaging in journalism.
	Right.
	So they're not journalists, right?
	That's right.
	Right.
	They're not doing any independent analysis or any independent journalism, right?
	Right.
	They're not investigating events, right?
	Independently themselves?
	No, they're not.
	And they're not investigative reporters.
	No.
	Okay.
	They're just simply not practicing journalism, correct?
	In their opinion, no.
	That's not the business model.
	Well, not opinion.
	I'm talking about free speech systems is just not practicing journalism, right?
	That's the company's position, yes.
	Right.
	And in fact, I think you testified that free speech systems has no responsibility for anything they put on the air that they didn't write themselves, right?
	Right.
	So the position is that the people who are making these assertions and free speech systems is commenting on that reporting, those people who are writing that article, that piece, whatever it is, that person is responsible for doing their own vetting.
	Right, exactly.
	So as I understand your testimony in Texas, and when I say your, I mean free speech systems, testimony is that if it publishes the statements of any third party, that it has no responsibility for whatever it is they may say or write, correct?
	Right.
	We're reporting on somebody else's reporting.
	We're commenting on somebody else's reporting.
	So that person is writing this article, they're making whatever assertions they're making in that article, and the host or whoever or the writer pulls that article and says, oh, this person wrote this.
	This is what this person is saying.
	Here's the link to this article.
	Right.
	And that's not just true of articles.
	It's also true of guests they may have on the air, right?
	Right.
	A guest may come on the air and free speech system may publish that person's remarks, but free speech systems has no responsibility for what they may say or publishing what they say, correct?
	Right.
	So if they have a guest on the show, I think they'll know the topic on which that person is going to talk about, but it's not scripted, so they're not going to know exactly what that person is going to say before they come on the air.
	And they take no responsibility for whatever they may say, correct?
	Right, it's that person's assertion.
	Right.
	And the same is true in an article that either that Infowars publishes that quotes a third party, correct?
	Right.
	They take no responsibility for the accuracy of that quote, correct?
	No, if somebody else is reporting.
	And if they well, you say somebody else is reporting.
	I mean, Free Speech Systems doesn't even know if the information that they're publishing from third parties is reporting based on anything, correct?
	I wouldn't say that.
	So generally, based on my conversations with everybody, it's their practice to glean information or gather information from a list of sources.
	That list of sources will vary from host to host on the show.
	And those sources are sources that they have found to be reliable in the past.
	So they're not just pulling things from the dregs of the internet.
	They feel that these particular sources are sources that they have found to be reliable in the past.
	What you're describing right now is the process at the outset of every live show where a host collects articles printed from various sites on the internet, correct?
	Right.
	That's the process you were just describing.
	Right.
	You weren't describing anything associated with articles published on Infowars.com, right?
	No.
	So the articles, there are a few writers, three or four maybe writers, and those writers will similarly pull information off the internet, but I don't think that they have a list of sources that they use.
	Right.
	And everything we've been describing just now in terms of the Free Speech Systems testimony that it's not engaged in journalism and that it's not responsible for what it publishes from third parties, that's been true from 2012 right up through today, correct?
	Yes.
	Okay.
	And the process you were describing just now, where hosts will collect articles or content from different websites, that process has been in place from 2012 onwards, correct?
	Yes.
	So go ahead.
	And your testimony is that the articles that hosts pull before their shows are sourced from what they have concluded are reliable sources and not, to use your words, the dregs of the internet, correct?
	Right.
	I think that that list has changed over time.
	So in my conversations with, I'm not really sure who I had this conversation with, but essentially it might have been Nico who testified, or not testified, but spoke to me on the topic of Alex's sources.
	And so he said that, you know, back when he worked with Alex, that list was much shorter.
	It's grown since then.
	It's changed.
	So that list is permeable in the sense that it's not static.
	They may reassess their opinions on certain things over time.
	So is it fair to say that because Free Speech Systems does not engage in journalism or independent verification of facts, that they don't have policies for vetting information that they publish, correct?
	Right.
	I don't, no, there's no policy for vetting information there.
	Free speech systems does not Verify any info it republishes from third parties, correct?
	Just with one caveat, I would say that's accurate.
	I believe that the unspoken policy for the writers is that they have more than one source for a particular piece of information so that it should link to more than one different place.
	And so when they circulate their material amongst the group to check, they're just checking for spelling errors and grammar, but they're also checking to make sure that there's more than one source for the information generally.
	That was a practice.
	When I spoke to Kit, he informed me of that, and he said that he believed it was the practice when Mr. Nimmo was also there as well.
	Okay.
	You read Mr. Salazar's deposition, correct?
	Yes.
	He did not testify that he was required to have two sources of information for anything that he published.
	No, he didn't.
	But in my conversation with him, he said that he thought it was the practice as well.
	But also, I will say that a bunch of Mr. Salazar's Sandy Hook reporting did not adhere to that practice.
	But there's nothing in writing.
	Right.
	There's nothing in writing.
	There's no policy.
	Mr. Jones has never articulated that, correct?
	No, that's not this business.
	It doesn't reduce very much to writing.
	Right.
	And in fact, even Mr. Salazar and Mr. Acosta, both of whom were employed by Free Speech Systems for a long period of time, testified that Free Speech Systems does not verify any information that it republishes from third parties, correct?
	No, they don't.
	They don't verify it, no.
	And Free Speech Systems does not verify any information that's conveyed by guests, correct?
	That's right.
	Okay.
	And it doesn't vet sources of information, correct?
	What do you mean sources?
	Like if there is a particular person that's making a claim and to vet that person, is that what you mean?
	Correct.
	Right.
	Right.
	They don't do that.
	No, so if there's a guest, usually what they'll do is they'll have that guest send their CV.
	But aside from that, no.
	They don't have any policies to ensure the reporting of accurate information, correct?
	There's no written policies, no.
	There's no policies of any kind, correct?
	To ensure the accurate reporting of information.
	Aside from what I've already testified to about the standard practice of the writing?
	Well, I think what you called it was an unspoken practice.
	Right.
	That with respect to articles authored by InfoWars writers, they are required to have two sources.
	Right.
	That's what you call an unspoken policy, correct?
	That was their understanding of what was required.
	Did you say that was Kit Daniels' understanding?
	And Adan, I believe, also said the same thing.
	Adan said that to you in your interview with him?
	I believe so.
	Okay, that's not noted in your notes, correct?
	I don't know.
	I'd have to look through my notes.
	Let's go down to page 25.
	It's not, that's based on Adan's depot, his note, the notes of his conversation.
	I don't know the notes of my conversation with him if those are in here.
	I see.
	Okay.
	So maybe we'll go through those.
	I read your notes.
	All of these?
	I read these, and it does not appear, at least from my recollection, that you noted that Mr. Salazar told you he believed that an unspoken practice was to have two sources of information.
	Okay.
	But aside from that unspoken practice, which applies only to the Infowars.com written work, there are no policies to ensure the accurate reporting of information, correct?
	No.
	Okay.
	There's no supervisory structure to check for accuracy in reporting.
	Is that right?
	We're getting a couple double negatives.
	Sure, let me rephrase it.
	I want to rephrase the question before the last one because I think your answer is not what you suspect it is, right?
	Okay, well, I can go back to that.
	So, Ms. Paz, am I correct that Free Speech Systems does not have any policies to ensure the accurate reporting of information?
	Am I correct about that?
	I guess I don't understand.
	Obviously, there's no written policies, but I think that in an attempt to have accurate reporting of information after the lawsuits, KIT made that requirement to have multiple sources of information when there's a criminal accusation.
	Is that what you're referring to?
	When you say the policy, because I am familiar with that, that in 2018, I believe, there was a written policy that if free speech systems is going to accuse somebody of a crime, that it needs to be approved by somebody other than the writer, right?
	Yes.
	Okay.
	That only went into effect in 2018, correct?
	Right.
	In response to the Fontaine case.
	Right.
	Okay.
	So prior to that, there was no supervisory, am I correct, that there were no policies to ensure the accurate reporting of information at free speech systems?
	So there are no written policies there, as I'm sure you're aware.
	But based on my conversations with them, the practice regarding the writing of the material was there's the group of writers.
	The group of writers would circulate their writings to each other to ensure that, like I said, there's multiple sources, you know, typos.
	There's also the head writer, who at the time I believe was Mr. Nimmo, but after that was Mr. Daniels, they could go into WordPress to check these things to make sure that there were multiple sources of the information.
	But aside from that, no, there's no additional vetting.
	So like I said, they have these lists of sources.
	These are the sources that they found to be accurate or that they found to be reliable.
	And then the writers have that process that they go through.
	So Mr. Salazar did not testify in his deposition, am I correct?
	That he circulated as a matter of practice his articles to other writers on the team.
	He did not testify to that, correct?
	I don't think he said that, no.
	In fact, he testified that there was no process for him to do that, correct?
	I don't know if he testified that there was no process, but like I said, based on my conversation with him, that was what was relayed to me.
	On your conversation with Mr. Salazar?
	In my conversation with Mr. Salazar, yes.
	Just within the last couple weeks.
	When I was down in Texas.
	Okay.
	I met with him in person.
	All right.
	You'd agree with me that there's no supervisory structure to check for accuracy in reporting at free speech systems, correct?
	You mean to make sure that the information that they're citing to is accurate?
	Is that what you mean?
	To check to see if the source that they're citing to is accurate.
	I'm saying, is there any structure, supervisory structure, wherein a supervisor is responsible for checking the accuracy of reporting?
	But they're not reporting.
	Okay.
	Is there any, they're not reporting, right?
	No, they're commenting on a news article that they saw.
	So, like I said, 98% of what they do is this commentary, so there is some reporting there.
	Like, for example, what Dan Vadandi was doing, that was reporting, right?
	That's not on the whole vast majority, the very vast majority of what they do there.
	Okay.
	So are you putting aside whether you want to call it reporting or anything else?
	There is no supervisory structure in place to ensure the accurate reporting of information, correct?
	No, because they're just commenting, so no.
	Okay.
	And there's no standard for the publication of material at free speech systems.
	Is that correct?
	I don't understand what you mean by that.
	They don't have any standards within free speech systems for what they publish or don't publish, correct?
	I still don't, I guess I still don't understand the question.
	Standards meaning you shouldn't publish certain things because it's not reliable.
	Is that what you mean?
	I mean, well, you're sitting here as free speech systems.
	So let me just ask it this way.
	As free speech systems corporate representative, can you articulate any standard that free speech systems adheres To in its publication of material.
	I think that's a little broad of a statement, but like I said, they have sources that they consider to be reliable in the past, and so they will look to those sources for future material.
	So if that answers your question.
	It doesn't.
	Okay, your question is very broad, so I don't understand it.
	Okay.
	Do you understand what a standard is?
	I do understand what a standard is.
	Okay.
	Does free speech systems have any?
	As to which material to cite?
	As to which material to publish.
	Whether it publishes the piece of material article that they were writing and whether this article is good enough to publish.
	Is that what you mean?
	Well, let me ask it again.
	You understand what a standard is?
	Okay.
	Does free speech systems have any standards governing what it publishes?
	Yes or no?
	I don't, I don't, I think it's an overly broad question, so I don't know how to answer it, but I don't know, I guess, is the answer.
	Okay.
	Office, it's been about two hours.
	Can we take a break at some point, or at any point that's natural for you?
	Yeah, I appreciate that.
	Let me just take a lunch break.
	Yeah, give me just a few more minutes.
	Yeah, no, I mean, I just said it was waiting until noon to say something.
	Yeah, thank you.
	Am I correct, Ms. Paz, that the reason that free speech systems doesn't have the types of policies or practices we've been discussing is because free speech systems doesn't consider such policies to apply to its work.
	Oh, you mean journalistic standards?
	What do you mean by that?
	Well, all the standards that we've just been discussing.
	So, for example, vetting procedures, right?
	Standards for publication of material, supervisory structure, independent verification of facts.
	Free speech systems does not have policies or practices like this because it is not practicing journalism, correct?
	I think that's fair.
	And so it does not consider such policies or practices to apply to what it does, fair to say?
	For journalistic standards, yes.
	And that's what you testified to in Texas, right?
	Right.
	Okay.
	I think what you testify to is those standards just don't apply, right?
	For what you would normally think of when you think of someone who is engaged in journalism, like the New York Times, that's accurate, yes.
	It's not the New York Times.
	It doesn't apply to free speech systems.
	That's not what it's doing, so yes.
	Okay.
	When you say it's not what it's doing, it's not engaged in journalism, and so you shouldn't consider any sort of policies relating to the verification of accuracy to apply to it, correct?
	Right.
	Okay.
	But free speech systems does, in fact, report facts to its audience, doesn't it?
	What do you mean?
	I mean that free speech systems conveys facts to its audience, doesn't it?
	It conveys opinions to its audience.
	I asked about facts.
	I don't know what facts you're talking about.
	Can you be more specific?
	I'm talking about any facts at all, an assertion of truth.
	Doesn't free speech systems publish facts to its audience?
	It will publish articles to its audience.
	I asked about facts.
	I don't know how to answer it.
	If you want to be more specific, you reviewed Michael Zimmerman's deposition, didn't you?
	Okay.
	Michael Zimmerman testified as Free Speech Systems corporate representative that Free Speech Systems reports facts to its audience.
	I think.
	So when Free Speech Systems was sitting for that deposition, it didn't have any trouble acknowledging that.
	Do you?
	What it means.
	If I'm going to object, you can answer.
	I think what it means is it is reporting something, it is commenting on something that somebody else has conveyed as a fact.
	So in the sense that, here, I'm showing you, this is in the news cycle today.
	This is an article that was published.
	These are the facts that are presented in this article, right?
	So it is, I guess, in the sense that it is presenting somebody Else's reporting as a fact, then sure, yes?
	I would agree with that.
	I didn't mean about somebody else's reporting.
	Although you're right, it does do that.
	It presents other people's statements as fact, correct?
	Yes.
	And then it conveys its own facts to the audience, correct?
	Mr. Jones conveys facts to his audience every day, doesn't he?
	I mean, can you be more specific?
	I don't know what you're referring to.
	Hey, Chris, can you get me on camera so I can see your facial expressions and how this is because I need to get a tone of no I'm not I'm sitting where I'm sitting Mario the so your testimony is that you can't camera so it faces you your testimony is no I'm not going to do that right now your testimony is that you can't answer whether or not free speech systems conveys facts to its audience I just think in general you're talking about a very general overly
	broad statement, and I can't answer that without more specificity.
	It's a very broad question.
	Is Alex Jones a journalist?
	I don't think so, no.
	Okay, it's a free speech system.
	So I need to make a note on the record, I just need to make a note on the record that this is a hot contested series of questions.
	I'm requesting to see the non-verbal because that's why we have a video deposition.
	I was assured that I would be able to participate by video.
	And I'm not able to see the non-verbals, and I'm
	I'm concerned about the tone this deposition at this point which may not be apparent from the mere written words as they appear on the transcript and that's why I need to I need to make that note on the record thank you free speech systems position is that mr. Jones is not a journalist correct right okay it would not be accurate to refer to him as a journalist correct no okay and it would not be accurate to refer to free speech systems employees as reporters correct
	I don't think so, no.
	Okay, and it would not be fair to describe what free speech systems does as journalism.
	I don't think so, no.
	That would be misleading, correct?
	Is it misleading to refer to them as journalists?
	Yeah.
	Sure.
	Right.
	Because they're not.
	I don't think they're journalists, no.
	Okay.
	When you say "I don't think" free speech systems.
	Free speech's position is that they're not engaged in the practice of journalism.
	It's not only his position, it's his sworn testimony, right?
	Right.
	Okay.
	And yet, free speech systems has presented itself to its audience as a news organization, correct?
	What do you mean?
	I mean, free speech systems has described itself as the most important news organization in the world, correct?
	I think that that's accurate as far as their description.
	And free speech systems has said that it is engaged in the practice of journalism to its audience, correct?
	I don't know about that.
	I'm not sure.
	Okay.
	So free speech systems isn't sure whether it's ever told its audience that it is engaged in journalism.
	I don't recall.
	Yeah, I don't know.
	Okay.
	Has free speech systems ever told its audience that it has teams of reporters?
	I think Alex may have made a statement like that.
	And free speech systems has told its audience that it breaks stories through its reporting, right?
	I don't know what you're referring to specifically, so I don't recall that specific statement.
	Okay.
	And Alex Jones'studio is intentionally designed to convey the appearance of a traditional news studio, right?
	That's argumentative objection to the form.
	I don't know what you mean intentionally conveyed.
	It's broadcasting video, so it has certain requirements.
	It needs to be set up a certain way so that it can be broadcast.
	Let me pull up exhibit eight.
	I don't know what you're referring to.
	Do you have this exhibit eight before you, Ms. Paz?
	Yep.
	if um we scroll down to the third paragraph do you see there um where mr by the way there's been testimony from mr zimmerman that this uh was published on Free Speech Systems website.
	see there where Mr. Jones refers to himself as a syndicated radio journalist.
	I see that paragraph, yes.
	Okay.
	Free Speech Systems doesn't dispute that it promoted Mr. Jones as a journalist on its website, correct?
	I don't dispute.
	Objection is her data on this.
	This has been testified to by Mr. Zimmerman as having been published on its website between 2012 and well, I can't remember exactly when he said it ended, but you have to check Mr. Zimmerman's deposition on that.
	Yes, sir.
	What was the question?
	Oh, you answered it.
	Oh, I did?
	Okay.
	Yeah.
	I believe you did.
	I mean, the question was that Free Speech Systems doesn't dispute that it has promoted Mr. Jones as a journalist on its website, correct?
	This article was published on the website, yes.
	This is not an article.
	Well, it's on.
	Can you scroll up?
	I'm sorry.
	Sure.
	It was published on Infowars.com.
	Right.
	Right.
	Okay.
	Promoting Mr. Jones as a journalist, yeah?
	It's promoting the Alex Jones show, yes.
	And him as a syndicated radio journalist, yes?
	That's what it says.
	Okay.
	And you've read, and in fact, Free Speech Systems promoted Mr. Jones as a journalist on its website from 2012 until even this day, correct?
	Oh, I don't know.
	Free Speech Systems doesn't know that.
	I don't know if it's doing it today.
	I have no idea.
	Okay.
	You read Mr. Dew's deposition in this case on March 15th, 2019, right?
	Yes, I did.
	Okay, you saw that he described himself under oath as a journalist?
	He may have.
	Okay.
	You saw Ms. Karpova describe what Free Speech Systems did as, quote, responsible journalism?
	I don't remember.
	Okay.
	You saw Mr. Schroer.
	Did you read Mr. Schroeder's deposition?
	Yes, I did.
	Okay.
	And Mr. Schroer testified that he considered himself to be a journalist, correct?
	I don't remember, but I know Mr. Schroer has also done some journalism in the sense that he went to do some individual reporting.
	So at times, he has done engaged in journalism.
	Okay.
	Why don't we pull up exhibit number 86?
	I'm presenting to you, Ms. Paz, a video that was uploaded to Infowars.com on April 20th, 2018.
	I have to be.
	And if we could go to 716, And before we do that I'll just ask you Ms. Paz, did you review exhibit 86 prior to today?
	I don't know.
	Okay.
	Where is this from?
	Where is it from?
	You don't know if you've reviewed it.
	I don't know.
	Okay.
	So why don't we play this starting at 716?
	So they saw that as weakness in the media because I'm a real journalist and they know full well.
	So I don't get equal time on Anderson Cooper or on Megan Kelly or.
	So, did you see there Mr. Jones describe himself as a real journalist?
	I heard it.
	Okay.
	That's not true, right?
	It's free speech's position that is not engaged in journalism.
	Okay.
	And so, it's free speech systems testimony that its owner, Mr. Jones, is not a real journalist, right?
	He may engage from time to time in pieces of journalism.
	Like I say, 98% of what we do is not journalism.
	Well, so if 98% of what Mr. Jones does is not a journalist, so 2% maybe.
	Okay, so 2% of the time he's a real journalist?
	Sure.
	Is that Free Speech Systems testimony?
	That 98% of the time what we're doing is not journalism.
	Okay, and I think you testified earlier that given that 98% of the time that's not what you're doing, that wouldn't be fair to describe what you do with journalism, right?
	Right.
	So it wouldn't be fair to describe Mr. Jones as a real journalist, right?
	Objection argumentative.
	I mean, I've been through this.
	I don't mean to be tedious, Chris.
	I'd renew my request for a break at some point.
	We're almost there.
	No.
	Thank you, sir.
	It's not accurate, correct, to describe him as a real journalist.
	No.
	I answered.
	I guess maybe I phrased it incorrectly.
	We're getting into that double negative.
	Free speech systems testimony is that Mr. Jones is not a real journalist, right?
	No, I said it three times.
	No, that's not your testimony, or yes, it is.
	No, he's not a real journalist.
	Thank you.
	And are you aware whether Mr. Jones has recently promoted himself on his website as a journalist?
	Am I aware?
	No, I don't know.
	Okay, let's pull up exhibit 99.
	99?
	Yeah.
	Turn him out of here.
	We use the rushroom really quick.
	This is my last bit.
	Okay.
	Okay.
	And then we can take a lunch break if you'd like.
	But that wasn't a video play.
	Okay.
	Okay.
	Sorry.
	This is exhibit 99.
	I'll represent to you, Ms. Paz, that well, have you reviewed Exhibit 99 before?
	I don't know what this is.
	I've never seen it.
	Okay.
	Let me go and play it.
	Alex Jones is a greatest.
	He has been so canceled.
	Alex is right about far more than he's wrong.
	How much heat have you gotten for being friends with him and having him on the show?
	A lot, but I don't pay attention.
	Okay.
	I just, I can justify it.
	I'll tell you, that guy is right about a lot of shit.
	He's a wild entertainer and a brilliant man.
	Isn't he fancy?
	No one is perfect.
	I've known Alex for like more than 20 years.
	I've hung out with that guy.
	We've been hammered together so many times.
	It's like it's that is the most misunderstood guy on the planet.
	Alex has been right on for over a decade.
	Shout out to Alex Jones.
	We love you.
	Alex Jones is a journalist and member of the media.
	End of story.
	Recently, many of the biggest tech companies joined in a coordinated effort to censor content from broadcaster Alex Jones.
	There's a reason why the mainstream media calls a guy like him a bomb thrower or a conspiracy theorist because they're in fear of the truth that he does actually bring out.
	Why are the most powerful companies in the world suddenly so threatened by an independent radio show host in Texas that they're willing to lose business in order to make him shut up?
	He runs a media organization.
	And so when the January 6th committee subpoenas him, they are basically violating our First Amendment protections.
	The Department of Justice says not only is it investigating what happened inside the Capitol, but the conspirators and instigators who may have started this whole thing.
	Now the committee has decided to shut down one of the most popular journalists on the right, Alex Jones.
	Yes, journalist.
	The House Committee investigating the deadly assault on the U.S. Capitol.
	So, Ms. Paz, have you ever seen this video before?
	No.
	Okay.
	So you're not aware whether this was posted by Darren McBreen to the Infowars.com website just within the last several weeks?
	No.
	Okay, but you did see in there free speech systems republishing others' claims that Mr. Jones is a journalist, correct?
	That's what it says.
	Okay.
	Okay, why don't we take a break?
	And since I kept people, How long would you like to take either Ms. Paz or Madam Court reporter?
	This could be a lunch break.
	It's probably the best time to take it if we're going to take one.
	I don't take a position on that, but Chris, I would like to talk to you briefly over the lunch break.
	If you can give me a call on my cell, it doesn't intrude on your lunch.
	Mary?
	Sure.
	How long would you like?
	I don't want to, you know, take too long.
	Until 1.
	Yeah, I don't want to take too long so that we're here too late.
	We're probably going to be here tomorrow.
	So you can take kind of, if you want to take 45 minutes for lunch, go ahead.
	Okay, thanks.
	We are off the record.
	The time is 12.16 p.m.
	EST.
	We are now on the record.
	The time is 1.12 p.m.
	EST.
	Hey, Chris, before we go back to recording testimony, in the event that we sit again tomorrow, is it foreseeable that we'll go past one?
	I don't know the answer to that.
	Can I ask, is Zach had a 2 o'clock court appearance where a plea deal might be able to be struck?
	If we have to cancel that appearance, we will.
	If there's any way of telling.
	I would hope not, but I'll certainly have a better sense of that at the end of the day.
	Okay.
	Yes, sir.
	All right.
	Thank you.
	you all from your note.
	Thank you.
	Okay.
	Is it ready?
	We're on the record.
	Oh, we're on.
	Okay, great.
	Okay, welcome back, Ms. Paz.
	Did you get lunch?
	I did.
	Thank you.
	When we left for lunch, we were discussing, among other things, Mr. Jones' statement to you that he is not a journalist, correct?
	Right.
	Okay.
	And your testimony here that he is not a journalist, correct?
	That Free Speech Systems is not engaged in the practice of journalism.
	Right.
	And as the owner of Free Speech Systems and its main star, Mr. Jones is not a journalist either.
	I believe you testified to that already, correct?
	Right.
	I think I testified 98% of what we do is not journalism.
	There is a small percentage of what is done that could be termed journalism, but a vast majority is 98% is not journalism.
	And Mr. Jones gave you that number, 98%.
	He did, yes.
	And what did he, did you ask him what he based that 98% on?
	He based the 98% on.
	And the answer is yes, I did.
	And the answer to how he based it is just based on how he got his business started.
	In other words, how he started out a show business, what he's been doing for the duration of his career, and just what the company does for the most part, which is commentary.
	So his position is that I started out in this business doing this type of thing, and that's how I built this business to be.
	So that's why he got this 98% number.
	Okay, so that, as I understand it, that number is not based on any sort of assessment he did of their coverage, correct?
	Oh, you mean like, did he do an empirical study and break down numbers and things like that?
	No, he didn't do anything like that.
	It's just his estimation as to what the purpose of the company is.
	Okay.
	So if I understand you correctly, what Mr. Jones told you is that the purpose of the company is not to be a journalistic organization.
	What he conveyed to me was his position is that they are engaged primarily in commentary and punditry, punditry.
	Understood.
	And I'm still though trying to understand where this 98% number comes from.
	And if it's just that Mr. Jones kind of pulled that out of the air as a shorthand way of saying that they really don't do journalism, that's fine.
	But I just need to know what you know about that.
	And what you described to me is in response to the question that you asked him, he kind of described for you the history of the company.
	But my question is, what is that 98% based on?
	Well, I think probably what you said is accurate In the sense that he pulled the number out based on what he thinks the company is and what it was built to be, but he didn't do any empirical study to come to this number.
	There's nothing empirically supporting a 98% number, if that's your question.
	In other words, neither he nor anybody else at Free Speech Systems actually looked back at the coverage they've done to determine this was journalism, this wasn't journalism, correct?
	No, no, they didn't do that.
	Right.
	And so having given you the number of 98% of what they do isn't journalism, you've come to testify here today under oath on behalf of Free Speech Systems that they do not practice journalism, right?
	On the whole, yes, 98% of what they do is not journalism.
	And, you know, you kind of go back to that on the whole as if, like...
	I'm not sure if you have a question pending.
	I'm referring to your prior testimony in Texas, where you testified under oath Free Speech Systems is not practicing journalism.
	And again, the company's position is that it does not engage in journalism.
	And then again, Free Speech Systems is not engaged in journalism.
	And so I'm wondering if that was based on Mr. Jones's statement to you, correct?
	Right.
	Okay.
	And he knew when he told you that that you would be testifying under oath to that effect, correct?
	Yes.
	Okay.
	And so when he communicated to you that Free Speech Systems is not engaged in journalism, he knew that you would be conveying that to me and that that would be conveyed to a jury, correct?
	Well, I'm going to object as to form.
	That's speculative, but I'll object as to form.
	You can answer.
	I'll withdraw.
	Mr. Jones understood the purpose of your interview, correct?
	Yes.
	And the purpose of your interview was to prepare you for your sworn testimony.
	Yes.
	On behalf of the company.
	Yes.
	And so when he conveyed that to you, he understood, of course, that you would be conveying that under oath, correct?
	I have objection as to form speculative contents, but other mind.
	You can answer.
	I don't know what he thinks, but I'm sure that he understood the purpose of our conversation to be that I was going to convey that information here.
	And did you consider, and you've done that.
	You've conveyed that under oath here.
	Okay.
	How did you decide that that statement that Free Speech Systems does not engage in journalism was in fact the truth that you would be willing to swear to today, given some of the other testimony by Free Speech Systems employees that they are in fact journalists?
	Well, so based on my communications, it wasn't just with Alex, but with other people employed for free speech, the vast majority of the communications that I got is we are engaged in commenting on things that other people publish.
	So for example, when I spoke to Kit, he outlined how the process by pulling this information off of the website, off of websites, and commenting on these things.
	Sorry.
	My watch.
	I lost my train of thought.
	So yeah, so commenting on other things that are posted on other people's websites such that he found certain material that was published, like for example by Adon, to be outside of what is normally published.
	It is abnormal.
	It's not the sort of thing we usually do.
	So certain of those articles, like the Batman article and things like that.
	So it wasn't just Alex that conveyed this to me that we're not engaged in the practice of journalism.
	On the whole, when I spoke to other employees, their position is that we're commenting on other articles that are out there in the world.
	I want you to tell me who other than Alex Jones said to you that they are not engaged in journalism.
	So when I spoke to Kit, he made that pretty clear to me.
	Well, let me just.
	Sure.
	Okay, you're saying he made it clear.
	Yes.
	Did Kit Daniels tell you that Free Speech Systems is not engaged in journalism?
	Well, I don't think that he would be able to make that comment on behalf of free speech.
	So he did not say that.
	Well, he can't say those words because he can't comment on behalf of free speech?
	Ms. Paz, is it your testimony that Mr. Daniels was limited in what he could say to you in terms of his view of the work of Free Speech Systems?
	My view is that he can't comment and take a position on the company because that's not his position.
	So let me go back to my question to you.
	Sure.
	Did Mr. Daniels tell you that Free Speech Systems, as far as he is concerned, is not engaged in journalism?
	In his opinion, he didn't believe it was engaged in journalism.
	So did he say that to you?
	I don't know if he used those exact words, but his position was some of these articles were outside of what was usually done there.
	I'm not asking about other articles.
	Sure.
	Okay, I'm just asking you, in as simple terms as I can put it, to tell me what Kid Daniels said to you about whether Free Speech Systems is engaged in journalism.
	And what I understood you to just say is that you cannot testify that he said that to you, correct?
	I don't know what exact words he used.
	I can't say what exact words.
	But you can't testify that he even conveyed in substance to you that Free Speech Systems is not engaged in journalism.
	That's not accurate, no.
	He conveyed that in substance to you.
	Okay.
	Who else?
	I don't.
	I don't think, I don't know if anybody used those exact words to me.
	So I'm not asking you about exact words.
	I'm saying what other people that you interviewed can you testify under oath, advised you that free speech systems does not engage in journalism?
	I think Kit and Alex might be the only ones that I spoke to directly to say that in some substance.
	Fair enough.
	And then you also had at your disposal the testimony of Rob Dew, correct?
	You reviewed his testimony.
	Yes.
	And you saw that he testified under oath that he wears a journalistic hat, correct?
	I think that's one of the things he said, yes.
	Okay.
	And you reviewed Ms. Karpova's testimony in which she, sitting as Free Speech Systems corporate representative, said that Free Speech Systems engaged in responsible journalism, correct?
	Didn't we go over this already?
	I think we already testified to this, yes.
	Okay.
	And you reviewed Mr. Schroer's testimony in which he said he considered himself to be a journalist, correct?
	I read the depot, yes.
	And you've just seen before the break Mr. Jones telling his audience on air that he's a real journalist, correct?
	I saw it, yes.
	Okay.
	And you saw another video that I represented to you had been published by Free Speech Systems just within the last few weeks referring to Mr. Jones as a journalist, correct?
	In which other people referred to him as a journalist?
	I saw the video, yes.
	And which was published by Free Speech Systems?
	I don't know if it was published by Free Speech.
	Okay.
	Why don't you assume that for me?
	And so having seen all that, you've made a determination to testify under oath in accordance with what Mr. Jones told you, correct?
	As I've testified earlier, a vast majority, 98 or so percent, is not journalism.
	So that is the testimony, yes.
	Okay.
	And so you've chosen to discard the other evidence that you've been presented with from the sworn testimony of Free Speech Systems employees that they are in fact engaged in journalism in favor of what Mr. Jones told you, correct?
	No.
	You haven't done that?
	No.
	Okay.
	So you accept as true their testimony?
	I accept as true that a small percentage of what we do may be termed journalism, as I testified earlier, but a vast majority is not journalism.
	Okay.
	Being that 98% that Mr. Jones gave you?
	Yes.
	Okay.
	Or so.
	I think that's what you said.
	Or so.
	Like I said, I don't think that that's an empirical number that he came up with.
	That's just the number he gave you to testify to, right?
	That's the number that's his opinion as to what they do and how much they do it.
	And now Free Speech Systems sworn testimony.
	Right.
	Okay.
	When did Free speech systems first publish any information concerning the shooting at Sandy Hook?
	Probably the next day or the same day.
	It was very shortly after.
	Do you know?
	I could review my notes.
	The first video that I have here is dated 12-17, but I believe there was commentary before that.
	So it was very shortly after.
	Okay, but I'm asking you as Free Speech Systems corporate representative, can you testify today concerning when Free Speech Systems first published information concerning the Sandy Hook shooting?
	Very shortly after.
	Okay.
	What does that mean?
	It means either the same day or the next day.
	You don't know which?
	I don't.
	Okay.
	And what are you basing that on?
	That it was either the same day or the day after?
	Based on the material I read, I believe that there were articles that were published either the same day or the next day.
	But as I said, the videos that I have date from 12-17, so at least from 12-17.
	What are you referring to?
	These are my notes.
	This is the first page of my notes, which is the spreadsheet of the videos that I reviewed.
	And it has upload dates on them.
	But these upload dates are dates that it would have been uploaded to YouTube.
	So sometimes they're not necessarily the air dates.
	And the Council, do you know if the spreadsheet that she's referring to has been produced to us?
	I thought I saw something with 12-17 as well on it as well.
	Can you check exhibit A of the things in our circulation, Chris?
	I'm just operating from remembering your thinking by your question.
	I'm sorry.
	I'm sorry to refer you to a document, but I believe that's where I saw that date.
	Okay.
	I will check again, excuse me, while I go off.
	Norm, it's one of the three documents I sent yesterday.
	Okay, so let me see if you mind if I just grab it for a second.
	All right, this is a spreadsheet that has been marked as part of 101.
	And this particular spreadsheet, Ms. Paz, did you create this?
	Yes.
	And this is a list of videos that you have reviewed?
	Yes.
	Is this the entire list?
	I think that there are more just because some, and I'll explain why.
	The reason is because some of them, the videos, I don't actually have the videos.
	And so I read transcripts of the videos.
	There are transcripts, but I don't have a copy of the actual video.
	And some of them are saved twice under different video names.
	So I may have watched another version of the video, but.
	How would we find out if you've watched all the videos in this listed here?
	I've watched all those videos yesterday.
	Correct.
	Yes.
	And what you're also saying is that you may have watched other videos in addition to these.
	And so what I'm asking is, how would we determine that?
	So all of the videos that I watched, I summarized in the second spreadsheet.
	That's the picture.
	That's a longer document, yep.
	Okay.
	And so that pink and orange spreadsheet may be more inclusive than this initial one.
	Right.
	So on the pink and orange spreadsheet is the first video, according to that, that you reviewed the one on December 17th, 2012?
	These are not in chronological order.
	These were just, I reviewed them, how they were saved on the Dropbox.
	So they weren't saved in any chronological order on the Dropbox.
	So I just summarized them as I watched them.
	These are not in chronological order.
	So these notes are not helping you to determine whether or not you reviewed any material published by Free Speech Systems prior to December 17th, 2012.
	No, I think that no, I don't think that's accurate.
	I think that the videos that I reviewed, all of them were 12, 17, 2012, and after.
	Right, and so I'm trying to understand in response to the first question I asked you, which is when did Free Speech Systems first publish material concerning Sandy Hook, whether you're able to answer that question either based on your knowledge as Free Speech Systems corporate representative or the notes that you brought with you?
	I take it that the answer is you don't know.
	No, I don't know.
	These notes are just based on the videos.
	They're not based on the published material.
	So I think they're, as I said earlier, I think I read articles that were published very shortly after, maybe the next day or the day after.
	I understand you're kind of saying, I think I may have done this.
	They may have been published here, but I'm interested primarily in what your sworn testimony can be as to what you know.
	Right.
	And what I understand you to be saying is that as you sit here today, you don't know when Free Speech Systems first published material concerning the Sandy Hook shooting.
	Is that correct?
	Right.
	Okay.
	It appears, based on your notes, that the first video you reviewed that they may have published concerning the shooting was uploaded on December 17th, correct?
	Of 2012?
	Right.
	Uploaded to YouTube, right?
	THAT'S WHAT I WANT TO DO.
	Did you review a video published by Free Speech Systems as far as you know on strike that?
	Did you review a video published by Free Speech Systems on December 12th?
	I'm sorry, strike that as well.
	What I'm trying to ask you is whether you reviewed a video entitled Connecticut School Massacre Looks Like a False Flag published December 14th, 2012.
	I don't know.
	Do you have an ID number on it, like our ID number?
	Because that's how we saved those videos, and those titles may not necessarily be the same titles that they're saved as in our system.
	Right.
	But you don't have any video on your list publishing.
	On that date?
	No, there's no upload date like that.
	Okay.
	And so you're not aware if Free Speech Systems published that video, correct?
	I don't know because I don't know the ID number, so I don't know.
	Okay.
	And so if, in fact, Free Speech Systems published a video on December 14th, 2012 concerning Sandy Hook and made, and Mr. Jones made claims in that video, you're not in a position to testify today as to what the bases for those claims were, correct?
	No, because I don't have the ID, so I can't look it up.
	And because you just don't know whether you saw the video or not?
	I don't know because I don't have the ID.
	I may have watched it.
	I just don't know because I don't have the ID.
	What ID are you referring to?
	So we save our videos under an ID number.
	It's a combination of letters and numbers, and that's how they're saved in our system.
	It's not saved by date.
	It's not saved by title.
	So when you say a date and a name, that's not how it's saved in our system.
	And maybe it have a different title, or it may have a different upload date, or it may have been a clip that was uploaded, and it's a smaller portion of a larger video.
	So I don't know what you're referring to.
	Well, you knew that you would be asked questions today about statements that Free Speech Systems published concerning the Sandy Hook shooting, correct?
	Right.
	And you knew that one of the issues that you'd be asked about is how soon after the shooting Free Speech Systems started making such statements, right?
	I knew you were going to ask about the statements we've made, not necessarily how soon after, but I knew you were going to ask that.
	So does free speech systems, well...
	Did you do everything that you could do to identify any statements that Free Speech Systems published concerning the Sandy Hook shooting?
	Objection is to form I'm not sure what you mean.
	I reviewed the materials that were available to me.
	Well, you obviously didn't go find those videos yourself, right?
	No, I testified earlier.
	Everything that what I reviewed was made available to me on a Dropbox.
	Okay, so those videos were sent to you?
	They were on the Dropbox.
	Okay, and those are the only videos that were available to you.
	These were the, right, these were the videos that were available on the Dropbox, right?
	Those videos listed in that spreadsheet you're referencing.
	Right, between the two spreadsheets.
	All right.
	And you're not prepared to talk about any other videos other than the ones that are in your spreadsheets, right?
	In my spreadsheets, yes, amongst the two spreadsheets.
	That's right.
	Okay.
	Separate from the videos, do you, from your own review of the videos, does Free Speech Systems have any information is prepared to testify to today concerning statements that Mr. Jones made on the day of the shooting?
	Apart from the videos?
	Yeah, I'm just asking you to put aside the video.
	Right.
	If I just asked you, as Free Speech Systems representative, whether Mr. Jones made any statements on the day of the Sandy Hook shooting, your answer is you don't know, correct?
	Right.
	So as a result, of course, you don't know what the bases for any of those statements might be, if he had made them correct?
	On the day of?
	Correct.
	No.
	Or on the day after, correct?
	If you could point me to something.
	No, I'm not completing anything.
	Right, just based on my recollection.
	I don't, I'm sitting here right now, I don't recall anything, reading anything like that.
	But I may have, so if you want to show me something.
	So as it stands, you know that the shooting occurred on December 14th, 2012, right?
	Right.
	Free Speech Systems acknowledges that 26 people were murdered, correct?
	Yes.
	Okay.
	By Adam Lanza, correct?
	Yes.
	All right.
	And for the days December 14th, 2012 through December 16th, 2012, you're not prepared to testify today concerning any information published by Free Speech Systems concerning the Sandy Hook shooting, correct?
	Like I said, I may have read some material, but as I sit here today, I don't recall.
	So no.
	I don't recall.
	Well, you don't recall, which means you can't testify to it.
	Right, I can't testify to something I don't recall.
	Right.
	Right.
	So for the period December 14th, 2012 through December 16th, 2012, Free Speech Systems is not prepared to offer any testimony concerning anything it published during that period about Sandy Hook, right?
	If you'd want to show me some documents, I would be happy to testify as to the documents, but as I sit here with my recollection, no.
	Okay.
	Meaning your recollection being Free Speech Systems, right?
	You understand it's not my job to give you information.
	I understand that I'm a human, so I can't recall tens of thousands of pages of documents, and I don't have it in front of me.
	So if you'd like to show me something, I'd be happy to look at it.
	But Ms. Paz, I'm not asking you to report to me about tens of thousands of documents.
	Okay.
	I'm asking you about the three days after the Sandy Hook shooting and whether or not you as Free Speech Systems Corporate Representative can say anything at all about any information Free Speech Systems may have published during that time about the Sandy Hook shooting.
	I'm not, and by the way, I appreciate the situation that you're in.
	I don't want you to feel defensive about that fact.
	How much that comes up?
	But you are bound to tell the truth about it.
	And so what I'm asking you is to confirm what appears to be the case, which is that Free Speech Systems is not prepared to testify today concerning any material it published between December 14th, 2012 and December 16, 2012, about the Sandy Hook shooting, correct?
	And I've answered your question.
	As argumentative, and I think she's fairly made a request.
	If you're aware of something you want her to comment on.
	No, that's that's not no.
	I've tendered my objection.
	I'm not argumentative or credit.
	Well, she hasn't answered the question.
	I have answered it.
	I answered it a couple of times.
	No, what you've said is, I can't recall.
	That's what you've said.
	You said I can't recall, as I sit here right now, whether any such information was published.
	And all I'm asking you is to confirm that that means that Free Speech Systems, as it sits here right now, isn't aware of any information that was published during the time period December 14th, 2012 through December 16th, 2012, about the Sandy Hook shooting.
	I didn't say I wasn't aware.
	I said I don't recall three times.
	You are aware of some.
	I said I probably may have read some articles that were published, but I do not recall.
	I've answered it three times.
	So you don't know, right?
	I don't know yet.
	And so you can't testify.
	I can't testify to something I don't know.
	That's right.
	Right.
	Thank you.
	So you can't testify about any statements before the video in your spreadsheet, right?
	Objection mischaracterizes the prior testimony, but again, objection is to the forum.
	Objection.
	Ms. Paz?
	I believe I've already asked you.
	If I asked you a question, if I asked you, Ms. Paz, what did Mr. Jones say about the Sandy Hook shooting on December 14th, 2012?
	Your answer is, you don't know, right?
	Right.
	I don't recall as I'm sitting here.
	Not you don't recall.
	You don't know.
	Well, argumentative.
	That suggests, Ms. Paz, that you at one time knew the answer and you simply forgotten.
	And so my question as Free Speech Systems designee is: okay, so the answer is, as you sit here right now, is you don't know whether Mr. Jones said anything on December 14th, 2012, right?
	Do you know or don't you know?
	Mr. Manny, I've said I don't recall three times because I said I've reviewed many documents and I reviewed a lot of articles and I don't recall as I've sit here today.
	If you'd like to show me a document, I'm happy to look at it to refresh my recollection.
	Was it important to you to know whether or not Mr. Jones said anything about the Sandy Hook shooting on the day it occurred?
	He said a lot of things.
	He said a lot of things over a course of a few years.
	Was it important to you to know whether Mr. Jones said anything on the day of the shooting?
	Was that important to you in your work as a Free Speech Systems Corporate Representative?
	Sure.
	So it was important to you, but not important enough for you to remember, right?
	Sure, Jack.
	Objection, argumentative.
	Seriously?
	I don't think that requires an answer.
	Well, it does.
	I think it's kind of...
	I've answered your question at this point.
	What did Mr. Jones say about the shooting on December 15th, 2012?
	I'm going to refer to my prior answer.
	Which is what?
	Which is that I do not recall.
	What did he say on December 16th, 2012?
	I'm going to refer to my same answer.
	Free Speech Systems doesn't recall.
	I don't recall, yes.
	um um What did putting aside what Mr. Jones may have said, what did Free Speech Systems publish on December 15th, 2012 concerning the Sandy Hook shooting?
	Same answer.
	You don't recall.
	Right.
	And you don't recall what it published on December 16th, correct?
	2012?
	Same answer, yes.
	Okay.
	On December 17th, 2012, Free Speech Systems published a video about the Sandy Hook shooting, right?
	Yes.
	And that video was titled Creepy Illuminati Message and Batman Movie Hints at Sandy School, Sandy Hook School.
	Sorry, well, sorry, sorry.
	Say that one more time.
	Because I had a little.
	Say it again.
	Video was entitled.
	Sorry.
	Yep.
	The video was entitled Creepy Illuminati Message and Batman Movie Hints at Sandy Hook School.
	Okay.
	And you reviewed that video, right?
	Yes.
	Alright.
	Oh, before we get to that, between the date of the shooting, December 14th, 2012, and December 16th, 2012, what did Free Speech Systems do to investigate the circumstances of the shooting?
	Investigate?
	I don't think they did anything to investigate.
	Did free speech system, you don't think, or...?
	And what, if anything, did they do during that three-day period to acquire any information concerning the shooting itself?
	You mean aside from reading the news articles?
	I'm asking for your testimony.
	I mean, I'm not aware of anything aside from reading news articles and soliciting, maybe soliciting comments from the general public.
	I don't think they've done anything, like I said, to investigate.
	Who told you that they read news articles in that three-day period?
	Specifically in the three-day period?
	Yeah.
	Well, generally, from the date of the shooting, the coverage was, like I said, because I had, I don't remember the specific articles, but generally the news coverage was the shooting, it happened on this date, be prepared for, you know, certain politicians to try to put forth gun control initiatives.
	And so that was generally right after the shooting, the coverage from InfoWars.
	Yeah, Ms. Paz, I asked you who from Free Speech Systems informed you that they read articles about the shooting in the three days after it occurred.
	Oh, I didn't ask anybody that specific question.
	Just based on the coverage that I read through and the material, that was what the coverage for InfoWars was during that time period.
	Ma'am, you've already testified that you have no idea if InfoWars covered it during this time period.
	That's not what I said.
	I said I didn't recall the specific articles that I read.
	No, what you testified to was that you had no recollection of anything that Free Speech Systems published in the first three days after the shooting about Sandy Hook.
	So I just want to make clear here, because you're under oath, and so the question that I asked you was initially.
	You're not changing the form, you're changing the predicate.
	No, I'm not changing the predicate at all.
	We've been through this.
	The transcript is what it is.
	But Ms. Paz, Ms. Paz, after we got through that last section, I asked you whether anybody at Free Speech Systems did anything to investigate the circumstances of the shooting in the first three days following the shooting.
	And I believe your testimony was no.
	And then I asked you whether anybody at Free Speech Systems did anything at all to learn about the shooting during that three-day period.
	And your testimony was they read articles, right?
	And then I asked you who read articles.
	And I've yet to receive an answer to that.
	Did anybody who you interviewed in preparation for your testimony today tell you that in the three days following the shooting they did anything at all to educate themselves about the event itself?
	Did anybody tell you that?
	Are you saying read about what happened or investigate?
	I just want to make sure I understand your question.
	What I'm asking you is whether anybody at Free Speech Systems did anything during the first three days following the shooting that you're aware of to inform themselves about the circumstances surrounding the shooting.
	And I believe I testified earlier that immediately after the shooting, wedding
	there was discussion on InfoWars about the shooting the coverage was what it was I don't know what they had reviewed to come to those opinions when they made those broadcasts and I didn't talk to them specifically about what they had reviewed in those three-day periods but but Ms. Paz you've already testified that you don't know whether there was any discussion on InfoWars about the Sandy
	shooting in the three days after, right?
	No, that is not what I said, sir.
	You keep mischaracterizing what I said.
	Okay, so then tell me, tell me, what was published in those first two days?
	I just said I can't specifically point you to a specific article, but I am aware that within a day that they were talking about the shooting, that was the very first thing I testified to.
	Who was?
	I think you're mischaracterizing the testimony here, sir.
	Who was talking about this idea of shooting?
	I can't recall who exactly it was.
	Okay, so then how do you know that?
	I just can't point you to a specific article, but I know based on my conversations with Alex that the conversations about Sandy Hook did begin immediately after the shooting.
	And the content and character...
	Who participated in those conversations?
	May I finish my answer?
	The content and the character of those broadcasts or articles or the conversations surrounding Sandy Hook immediately thereafter were about Second Amendment and gun control and that how there was going to be a push then thereafter to have this gun control narrative.
	What is your next question?
	So the initial coverage that you've just been describing...
	Mm-hmm.
	Okay.
	Is it your sworn testimony that that coverage occurred prior to December 17th?
	Yes.
	Okay.
	But you can't cite a particular article, right?
	Right.
	Or a particular video, correct?
	Yes.
	Okay.
	And you don't have any specific recollection as you sit here of any of that coverage?
	You just are testifying that it occurred?
	Yes.
	Okay.
	And that's based on a conversation you had with Alex?
	Yes.
	Okay.
	Now, you did not review Lydia Hernandez's testimony, right?
	Right.
	Did you ask anybody...
	Well, is free speech systems aware of raucous laughter that occurred in the studio on the day of the Sandy Hook shooting as news was coming in about it?
	No.
	The objection is to the forum.
	It's a corporate entity.
	No.
	Free speech systems is not aware of that.
	No.
	Okay.
	Now, on December 17th, 2012, this is just five days after the shooting, right?
	December 17th, yes.
	And as a...
	14th, Chris, we keep making it at the 12th.
	I thought it was 12, 14th.
	12, 14th.
	Of course, you're right.
	That's my sleep.
	Three days.
	Three days.
	Thank you.
	My math is terrible, too.
	Thank you.
	So is mine.
	So is mine.
	Thank you for...
	clearing that up am I correct that during this particular broadcast on December 17 2012 Mr. Jones said about the Sandy Hook shooting that they were staging it in the in the video titled Creepy Illuminati Message in Batman movie is that is that the video you're talking about Elliott let me just pull up my notes
	that.
	Okay.
	And the question is whether.
	Did Mr. Jones claimed in that video on December 17th, 2012, that they were staging it, referring to the Sandy Oak shooting?
	Uh...
	Yes, I think what he said was he had a gut feeling about it and that basically something didn't feel right with it, inferring that it may be staged.
	Well, he didn't say it may be staged, correct?
	He said they're staging it, right?
	I don't have a direct transcript in my notes, so perhaps.
	so free speech systems doesn't know as it sits here today whether mr jones said on the air on december 17 2012 that they're staging it referring to sandy hook right I don't know whether that's a direct quote, no.
	Did you talk to Mr. Jones about that statement?
	About that particular video?
	No.
	About the statements he made in that video.
	You did not.
	In that particular video, I spoke to him about the content as a whole and some specific statements that he made.
	But regarding this particular video, I don't know that I spoke to him regarding every video specifically, but I did ask him about the statements that he's made in the videos.
	Okay, I'm asking you specifically, though.
	About this video.
	About the statement that he made on December 17th, 2012, in which referring to the Sandy Hook shooting, he said they're staging it.
	And what I understand your testimony to be is that, A, you don't know if he said it, right?
	I don't know if that's an exact, exactly what he said in this particular video.
	Okay, and you don't know what the bases for him having said that were, correct?
	Well, he says in the video, I have a gut feeling and I can't control it.
	So is Free Speech Systems testimony that Mr. Jones' basis for saying they're staging it, if he did say that, was a gut feeling?
	That's what it says in my notes.
	I asked you what your testimony is.
	That's right.
	Your testimony is that Free Speech Systems' basis for publishing Mr. Jones' statement that they're staging it was his gut feeling, right?
	That's what the representation in the video is, yes.
	I know that's the representation in the video.
	I watched the video.
	I'm asking you what your sworn testimony is.
	My sworn testimony is what is in the video.
	He didn't say in his video what the bases were for his statement that they're staging Sandy Hook.
	But if what you're saying...
	Are there any other bases?
	Not that he says in this video.
	Are there any others that you can tell me?
	Excuse me, this is the court recorder speaking right now, and I apologize, but as Mr. Pattis was objecting, then Mr. Matty, you started to speak over him, and then I missed part of the objection.
	And then Mr. Matty, I think you were asking a question, but I didn't hear any of it because you both cut each other off as you were both speaking at the same time.
	So I have, he didn't say in his video what the bases were for his statement that they're staging Sandy Hook, answer objection to form.
	He did, and then everybody started talking at the same time.
	So I apologize for that, but when people talk at the same time, you're cutting each other off.
	No, I think you got Mr. Pattis' objection.
	And so my next question is, other than Mr. Jones's gut feeling that the Sandy Hook shooting was staged, is Free Speech Systems aware of any other bases for his statement at that time?
	And at this Particular time for this video?
	Yeah.
	No.
	Okay.
	Now, part of what Mr. Jones covered in this video was another video suggesting that the term Sandy Hook had appeared in a Batman movie, right?
	Yes.
	And he said during this video that he was going to ask Adan Salazar to do a report on that, right?
	I think at that time Adan had already done that article.
	He had already written an article.
	Does free speech systems know that?
	Um...
	I can't remember the date that that article was published because this was 12-17, 2012, but I believe that in my conversations with Adan, Adan had received a tip on that.
	He thought it was interesting, just the name connection, and he had done the written piece.
	And then this video happened.
	So I think that the article came first.
	Okay, so that's your testimony, that the article that Adan Salazar wrote concerning the Batman-Sandy Hook connection preceded this broadcast, correct?
	Right, I think so, yes.
	Are you prepared to swear to that?
	One of the things that we're getting into here is, first of all, the disadvantage that you're at having to testify about all these things and wanting to be careful, but also our need to get clear testimony on the record as to what the company knows, doesn't know.
	Okay?
	So I want you to be careful, obviously, but I want you to say, if you don't know whether Adan Salazar published that article before this video, you need to say that.
	Because it's not good enough to say, I think it may have, at least for purposes of our record.
	I don't, so when I spoke to Adan, Adan's position was he was not told to write that article by Alex.
	That article was written based on a tip that he got elsewhere.
	So if Alex says in this video, I'm going to have Adan write an investigation or whatever it was he said about this issue, my conversation with Adan was he wasn't told to write it by Alex.
	It was a tip that he got somewhere else.
	All I'm asking about right now is the timing of it.
	Right?
	And I want to make sure that you're comfortable with the testimony you've given, which is that the article Adan Salazar wrote concerning the Batman Sandy Hook shooting was published before this video on December 17th, 2012.
	I don't know the exact date of the article.
	So you don't know?
	I'm not sure, right?
	Okay.
	Now, the article that Mr. Salazar did write, regardless of when it was published, am I correct?
	That it the purpose of the article was to suggest that somebody may have had foreknowledge about the Sandy Hook shooting because the term Sandy Hook appeared in the Batman movie in a map that was depicted.
	No.
	That wasn't the purpose.
	No.
	Based on my conversation with Adan, he just thought that it was interesting.
	He got a tip and he thought that the names being in the video was interesting.
	So I don't think that's accurate.
	Okay.
	And so it was really just a point of interest with no particular suggestion that motivated Mr. Salazar to write that article.
	Right.
	Okay.
	And so then when he later posted the article to his social media account referring to the coincidence as fishy, that wasn't suggesting anything concerning the nature of the coincidence either, correct?
	Posted to where?
	His social media?
	His social media?
	I can't testify as to what he posted to his social media.
	Okay.
	Free Speech Systems isn't aware of that.
	No, he posted it to his social media.
	I mean, Free Speech Systems is aware that its employees posted Infowars content to their social media accounts, correct?
	Sure, to their personal.
	They were encouraged to do that, right?
	I don't know if they were encouraged, but they could.
	The objection as to the form there is that they're individual or free speeches, it's ambiguous.
	all right Prior to publishing his article, Mr. Salazar's article on the Batman-Sandy Hook connection, did he do anything at all to investigate the circumstances of the Sandy Hook shooting?
	Of the shooting itself, or of the videos, not the videos, I'm sorry, of the Batman movie.
	No, of the actual shooting.
	Oh, I don't know.
	Okay.
	Let's go.
	Did Free Speech Systems receive any information that Adan Salazar's claim that Sandy Hook had appeared in the Batman movie was in fact not accurate?
	I'm sorry, is your question, has Free Speech received any information that that article isn't accurate or the information contained in that article isn't accurate?
	Yeah, we can start there.
	Is that the question?
	I just want to make sure that you're not sure.
	That is the question.
	Let's do it that way.
	At the time it was published?
	No.
	Okay.
	So Free Speech Systems did not receive any information at the time the article was published suggesting that Mr. Salazar's claims were wrong?
	No.
	How do you know that?
	Because I'm not aware of any such information.
	And I talked to Adan about the article and how he sourced the article and how he prepared writing the article.
	And so I don't think Free Speech was aware of anything to the contrary.
	Okay.
	Can you pull up exhibit 11, please?
	Do you have an email before you, Ms. Boss?
	Do you see that?
	Yep.
	Okay, this is an email sent from an individual named Matt Hundley to writers at Infowars.com.
	And the subject is Dark Knight Rises Sandy Hook reference, correct?
	That's what it appears.
	Okay.
	Dated December 17th, 2012, right?
	That's what it appears, yes?
	Can you read that email?
	Allowed?
	Yeah.
	Team Alex's Sandy Hook reference in the Dark Knight Rises in the Dark Knight is a hoax.
	It doesn't appear in the film.
	Just a heads up.
	Thank you for your service, Matt.
	Okay, so the testimony that you just gave under oath was incorrect, correct?
	No, not necessarily.
	I think based on my testimony in the Last deposition, which I know you've read, is that many of these email addresses were not being monitored.
	This is a general email address to writers at Infowars, so I can't say whether anybody saw this.
	Well, I didn't ask whether anybody saw it.
	I asked whether Free Speech Systems received any information that the claims Mr. Salazar made in his article were incorrect, and you said I've never seen this.
	You've never seen this, right?
	And you have no idea whether somebody looked at this, correct?
	I don't know, right?
	That's what the basis for my testimony was: I don't know if this came to anybody's attention.
	Okay, so now Free Speech Systems testimony is that it doesn't know whether or not Free Speech Systems received any information questioning the claims in Mr. Salazar's article, right?
	I don't know if they were aware of it.
	Do you know if it's if you're not accurate either?
	Right?
	Does Free Speech Systems know whether Adan's article that the Sandy Hook, the term Sandy Hook appeared on a map in the Batman movie?
	Do you know that?
	I didn't do any independent research into it now.
	Free Speech Systems, I'm asking.
	Does Free Speech Systems know whether the article published by Mr. Salazar at this time claiming that Sandy Hook had appeared in the Batman movie is accurate?
	I don't have any reason to believe that it's not.
	I don't know who eatmorezombies at gmail.com is.
	I'm asking you, yes or no?
	Was Mr. Salazar's article that the term Sandy Hook appears in the Batman movie accurate?
	I don't know whether it was or wasn't.
	I'm going to make a lot of the ingredients.
	On the same date, on December 17, 2012, did...
	Well, back that up.
	Okay.
	Did Free Speech Systems ever publish anything suggesting that the connection Mr. Salazar found between the Sandy Hook shooting and the Dark Knight film was more than a coincidence?
	I'm sorry, can you repeat that?
	Yeah.
	Did free speech systems ever claim that the purported connection between Batman and the Sandy Hook shooting was more than a coincidence?
	I don't recall.
	I don't recall anything like that, but I don't recall.
	Okay, so you can't testify one way or the other?
	No.
	Okay.
	Did you review a video called Father of Sandy Hook asks, read the card seconds before tearjerking press conference?
	Do you have the ID number?
	I hate to ask.
	These are your ID numbers, right?
	Yeah, my ID numbers.
	Okay.
	Do you have them?
	You don't have them?
	Or do you have a text?
	I don't have them in front of me.
	Yeah, December 19, 2012.
	And Mr. Maddie, I'm sorry, can I have the name of that one more time?
	Father of Sandy Hook asks, read the card seconds before the tear-jerking press conference.
	Thank you.
	That sounds familiar.
	The ones that I have upload dates on that date are titled something different, though.
	So they may be the same video, but I'm not sure.
	So the upload dates on 12-19, 2012 are Sandy Hook Father Remembers Fallen Hero and Sandy Hook Second Shooter Cover-Up.
	Okay.
	So that's why I asked for the ID number, just to make sure we're talking about the same video.
	But It sounds familiar.
	Let's take a look at exhibit 14, please.
	Do you have Exhibit 14 for you, Ms. Buzz?
	Yes.
	Okay.
	This is an article that Free Speech Systems published on December 19th, 2012, right?
	Yes, it looks like it is.
	Okay.
	And there was a video embedded in this article, correct?
	I don't know.
	I don't see that here.
	Okay.
	You mean the full press conference can be viewed here?
	Is that what you're talking about?
	I'm asking you whether when Free Speech Systems published this article, there was a video embedded in the article.
	I'm not sure.
	Okay.
	And so you have no idea then if there was a video that was embedded in the article, what it was, right?
	I don't know.
	All right.
	It looks like it's the full press conference, but I can't tell by looking at this.
	You don't know.
	Do you know whether Free Speech Systems ever aired some or all of Mr. Parker's press conference the day after the shooting?
	I believe I have seen parts at least of Mr. Parker's press conference, yes.
	Okay.
	Meaning you saw that Free Speech Systems had published it.
	Right.
	Okay.
	Not necessarily on this article, but in other places.
	Okay.
	Right.
	So you can't testify here today whether on December 19th, 2012, Free Speech Systems published some or all of that press conference, right?
	Well, I can tell by looking at this article that it was because it says the full press conference can be viewed here with a link.
	So I can just by looking at this.
	You're prepared to testify under oath, just looking at this document, that there was a particular video embedded in this article?
	The representation is that the full press conference can be viewed here.
	Okay.
	And so your testimony then under oath is that, yes, there was a video embedded in this article and it was the press conference of Mr. Parker that he gave the day after his daughter's shooting, right?
	Based on this article, right.
	Okay.
	And that video...
	Well, let me ask you about this first of all.
	Do you see the statement from Alex Jones there at the bottom of the article?
	Yes.
	Okay.
	And this is the statement that Mr. Jones published shortly after the shooting.
	You don't know when exactly, right?
	I'm sorry, when was the statement?
	The question is?
	When did he publish that statement?
	It's published with this article on December 19th.
	Right.
	Do you know if he published it at any point before that?
	Oh, I don't know.
	Okay.
	And Mr. Jones says that it appears the members of the media or government have given him a card.
	He's referring to Mr. Parker there, right?
	Right.
	Okay, and what was Mr. Jones' basis for saying that either the media or the government had given Mr. Parker a card?
	Based on the video that says that has Mr. Parker say, I believe he said something to the effect of read from the card in the video.
	Have you watched that yourself?
	I watched, I don't think I watched the entire press conference, but I watched a clip of the press conference where he's speaking to some people behind him, which may or may not be his family, and then he turns to the cameras and then says something to the effect of read from the card or a question about whether he should read from the card.
	But did Mr. Jones tell you that that's the basis for his statement or are you just intuiting that?
	I'm saying what I viewed as a part of the video.
	You viewed that?
	I watched that video.
	But you don't know why Mr. Jones said that it appears the members of the media or government have given him a card.
	He's commenting on that video.
	He's commenting specifically on that video.
	Okay, that's your testimony under oath?
	Yes.
	Okay.
	And specifically your testimony under oath is that Mr. Jones was referring to what you claim was Mr. Parker's question about a card, right?
	Well, it's not my claim.
	That's what Mr. Jones' opinion basing of viewing that video was.
	Mr. Jones told you that he heard Mr. Jones say something about a card.
	Or Mr. Jones told you that he heard Mr. Parker say something about a card?
	He's referenced that a few.
	It's not what he told you.
	He didn't tell me that specifically.
	It's just based on my review of the material.
	He said that a few times based in the videos, he's referenced this particular video a few times.
	Okay.
	And he's spoken about Mr. Parker's reaction, his opinions about the reaction, and his opinions about what is said.
	Okay, so what I understand your Free Speech Systems testimony to be is that based on its review of other videos Mr. Jones has done, it believes that the basis for him saying that it appears the media or the government have given Mr. Parker a card is Mr. Jones's opinion that Mr. Parker said something about a card.
	I guess I don't understand the question.
	He's commenting on the video.
	This whole article is a comment on that video.
	I watched the video.
	You know that you watched the video embedded in this article?
	I don't know if it's the same video, but I've watched the video of Mr. Parker's interview.
	Ms. Paz, you have no idea what video was embedded in this article, right?
	No, it says specifically what video is embedded there.
	But you didn't view it, right?
	I viewed the video of Mr. Parker's interview, so no.
	Ms. Paz, are you prepared to testify under oath today that you watched the actual video that was embedded in this article when it was published?
	I didn't click on this link, so I don't know.
	So the answer is no, but I'm telling my testimony is he is commenting on that particular interview, and I'm answering your questions based on that particular interview.
	You mean the press conference Mr. Parker gave?
	That's correct.
	Okay.
	Mr. Jones never saw anybody hand Mr. Parker a card, right?
	Was he handed a card?
	Mr. Jones never saw anybody hand Mr. Parker a card.
	He's not saying he did, but no.
	Doesn't he say it appears that members of the media or government have given him a card?
	Given him a card and handing him a card are not the same thing.
	Did he see anybody give him a card?
	I didn't see anybody give him a card.
	Did Mr. Jones?
	I don't know what Mr. Jones saw.
	Well, I'm asking you.
	You don't know what Mr. Jones saw, right?
	I'm not Mr. Jones, so no.
	Right.
	And you had a chance to ask him about this, right?
	I've asked him about his opinions on that interview.
	Did you ask him about this particular statement?
	Why did you say it appears media or government have given him a card?
	Did you ask him about that?
	Did I ask him that specific question?
	No.
	But like I said earlier.
	The answer is no.
	Okay.
	And so you don't know whether Mr. Jones saw anybody give Mr. Parker a card, right?
	I don't know what Mr. Jones saw.
	Okay.
	And you don't know what Mr. Jones heard about this, right?
	No, I don't.
	No, I'm not Mr. Jones.
	Okay.
	And as far as Free Speech Systems goes, it has no information in its possession at all that anybody, media or government, ever handed Mr. Parker anything, correct?
	Handed him?
	No.
	Okay.
	And you have no information of any kind in your possession that anybody from the government or the media said anything to Mr. Parker about his comments after the shooting, right?
	All I know is what he said in the video.
	By he I mean Mr. Parker, in which he said read from the card.
	Your sworn testimony.
	That's all I, and I believe that what is Alex is referring to.
	Free speech systems sworn testimony is that Mr. Parker said read from the card.
	I believe that's what I saw on the video.
	Did you read Mr. Parker's deposition?
	I did not read his deposition, no.
	Okay.
	But free speech systems sworn testimony is that Mr. Parker said, read from the card.
	I watched the video and I believe that's what I heard on there.
	But that's what Mr. Jones's opinion about the interview was.
	And if Mr. Parker had a card, Free Speech Systems testimony is that it must have come from the government of the media, right?
	It's his opinion that it appears that this happened.
	So it's Alex's opinion.
	Right.
	Right.
	From nothing other than having looked at a video that you yourself don't know which video it was, right?
	Betterness to the form.
	I don't know what video is specifically embedded here, but it appears that he is referring to that interview.
	Okay.
	What were the, do you see at the first sentence there?
	It says, as unexplained factors in the tragic Sandy Hooks school shooting continue to surface, what were the unexplained factors?
	At this point in time or on the whole?
	Well, when it was published.
	I don't know what claims were specifically being aired around this time.
	They were talking about the potential for there being second shooter around this time, people being taken out of the woods around this period of time.
	Ms. Paz?
	Yes.
	So I think that that might be what they were referring to.
	You don't know, right?
	You can't testify under oath what they were referring to with respect to that.
	Well, it's not listed here, so I can't say specifically, but around that time period, I can testify as to the issues that they were raising at that time period.
	So it's important to talk about that.
	You just testified that the only video that you're aware having been published by Free Speech Systems as of this time was the December 17th video, right?
	No, that's not correct.
	There were other videos that were published on that 12.
	Are you prepared to testify whether in those videos anybody said anything about the unexplained factors referenced in this article?
	I don't know specifically what factors they're referring to because it's not listed in it.
	Thank you.
	Thank you.
	All right.
	Let's see here.
	Where are we?
	All right, why don't we take a 10-minute break or more if you need?
	Mr. Parker.
	The lady room.
	We are off the record.
	The time is 2.21 p.m.
	ESD.
	We are now on the record.
	The time is 2.36 p.m.
	ESD.
	Going back to exhibit number 14, this is the article published on December 19th, 2012.
	I understand that Free Speech Systems.
	Can I see that on my screen?
	Yep.
	Okay, thanks.
	Okay, go ahead.
	I understand that Free Speech Systems testimony is that Mr. Jones, well, first of all, you did not ask Mr. Jones what the basis for this particular statement in this article was, correct?
	Which statement are we referring to, the unexplained factors or the given him a card?
	The paragraph in this article that starts statement from Alex Jones.
	Am I correct that you did not ask Mr. Jones what the basis was for this statement as it appeared in this article?
	No, I didn't ask him about this particular statement.
	Okay.
	And so Free Speech Systems cannot testify as to what the basis for this particular statement was, correct?
	I don't think that that's accurate.
	As I've said earlier, the basis for the statement is stated right there in the statement.
	It's a statement on Mr. Parker's interview.
	But Ms. Paz, you're not here speaking for yourself.
	You're not here to testify about what you yourself think or can intuit from a particular document.
	You're here to relate the knowledge of the corporation.
	And what I'm asking you is free speech systems, not Brittany Paz, but Free Speech Systems cannot testify today what the basis, based on information obtained from Mr. Jones, what the basis was for his statement as it appears in this article, correct?
	Back in as to the form, this corporation can't testify at all.
	That's not a form objection.
	So go ahead.
	The same answer that I just gave is that this article is clearly making a comment on this interview, and this statement is a comment on that interview.
	An interview that you haven't seen?
	I testified earlier that I had seen it.
	So no, that's not accurate.
	Ms. Paz, I thought you testified that you'd never, you could not testify whether you'd seen the video that was embedded in this article.
	Sir, you keep making these distinctions, but I just testified earlier.
	I have seen this press conference.
	You're asking me if I can testify to you that that is the exact thing that is linked there, and obviously I can't, but if your question is, have I seen that interview?
	The answer is I have seen that interview.
	No.
	What I said was that what you've tried to do is testify as to what Mr. Jones, the video that Mr. Jones saw, right?
	But you don't know what video he saw when he made this statement because you don't know what video was embedded in this article, correct?
	I don't know what video is embedded in this article, no, but like I said, the full press conference, he has aired it numerous times, and that's what he saw.
	And he's made it.
	Your sworn testimony is that Mr. Jones has aired Mr. Parker's full press conference?
	He has not aired.
	Excuse me.
	Excuse me.
	You just testified that Mr. Jones has aired this press conference several times.
	And the reality is that Mr. Jones, as far as you know, has never aired Mr. Parker's full statement to the press following his daughter's shooting, correct?
	The full?
	The full one?
	No, he's never aired the full one.
	Right.
	So he hasn't aired Mr. Parker's full statement to the press several times.
	He's never aired it, correct?
	The full statement?
	No.
	Thank you.
	I'm sorry if I could just hear the full answer again because there was an objection.
	I said the full statement.
	Did you see this?
	I said the full statement?
	No.
	Thank you.
	Now the video that was embedded in this article was uploaded to YouTube, correct?
	Well, I thought we just established I don't know exactly what's embedded here, so I don't know how to answer that question.
	Well, you can answer it as Free Speech Systems, whether Free Speech Systems knows or not.
	Was the video that was embedded in this article uploaded to YouTube?
	As I said earlier, I can't say what was embedded here, so I can't say.
	You don't know?
	Right.
	Thank you.
	Free Speech Systems doesn't know.
	I'm going to go to the next video.
	Can you pull up exhibit number 13?
	Do you have exhibit 13 before you, Ms. Paz?
	Yes.
	Okay.
	This is an email from Aaron at Infowars.com.
	Do you know who that is?
	Yes, he's one of the writers.
	What's his last name?
	Dykes.
	And Jonathan at info at Infowars.com is John Bown, right?
	I'm not sure.
	Okay.
	And this is an email sent by Aaron Dykes to other InfoWars employees on December 19, 2012, right?
	That's what it looks like, yes.
	And can Free Speech Systems confirm today that the YouTube link contained in this email is in fact the video that was embedded in that video?
	I don't know.
	I'm sorry, the video that was embedded in that article.
	In the previous article that we talked about, I don't know.
	Okay.
	Free speech systems doesn't know.
	I don't know.
	I was under the impression that Attorney Pattis and you were discussing these authentication issues, but I don't know is the answer.
	I can't say.
	Okay.
	I didn't ask you an authentication question.
	So I asked you whether or not Free Speech Systems could confirm whether the link, YouTube link, listed in this email was the link to the video that had been embedded in that article.
	And Free Speech Systems testimonies it doesn't know?
	I don't know.
	Okay.
	You pull that down.
	Did you review a video published on January 4th, 2013 by Free Speech Systems entitled Callers React to Foreign Media Pushing Total Gun Confiscation?
	January what?
	4th, 2013.
	I don't have a video like that on my list, no.
	Okay, so Free Speech Systems did not review that video in preparation for his testimony today?
	No.
	And so Free Speech Systems is not prepared to testify concerning any of the claims made in that video?
	Now.
	Okay.
	Can you pull up Exhibit 21, please?
	Did you have an email before you is exhibit 21?
	Yes.
	It's an email from Rob Dew to Aaron Dykes, correct?
	That's what it appears to be.
	He's forwarding an email that he received with the subject crisis actors website, correct?
	Yes.
	And this is January 6th, 2013?
	Yes, it's a forwarded message from December 21st, forwarded on January 6th, yes.
	Right.
	Have you ever seen this email before?
	I've seen many emails like this, but this particular email, I'm not sure.
	When you say you've seen many emails like this, what do you mean?
	I mean, there were dozens and dozens of emails from the general public about advertisements for crisis actors.
	Here, heads up, they're having simulated drills on this day.
	I've seen dozens of emails like this.
	Okay, this is not an email from the general public.
	This is an email from Rob Dew to Aaron Dykes, right?
	No, it is a forwarded email from John Tata Hayes, who I'm not sure who that is.
	Your testimony is that this is not an email from Rob Dew to Aaron Dykes that I showed you?
	Sir, I'm looking at a forwarded message.
	The initial message is from someone who is not in the company to Rob.
	Right.
	Who then Rob subsequently forwarded on to another person?
	Correct.
	Yes.
	So Rob Dew forwarded this email to Aaron Dykes.
	Yeah.
	Have you seen dozens of emails between InfoWars employees about crisis actors?
	I don't know necessarily between crisis, between employees about crisis actors, but I've seen many, many emails like this from the general public.
	I understood that testimony.
	I'm asking you, as you sit here today, have you ever reviewed this email before?
	I don't know.
	Okay.
	Maybe.
	Okay.
	And you're not in a position to testify as to why Rob Dew sent this email concerning crisis actors to Aaron Dykes on January 6th, right?
	No.
	Okay.
	Did you ask Rob Dew about that?
	About this particular email?
	Okay.
	Can you pull up exhibit 19 please?
	Okay.
	Do you have an email from crisis mail at crisisactors.org to Don Salazar on January 6th, 2013, the same date?
	Yes.
	Have you seen this email before?
	It doesn't look familiar.
	No.
	Okay, so Free Speech Systems can't offer any testimony today about this particular email, correct?
	I mean, I could testify as to what it appears to be, but I've not seen it before.
	No, no, what I mean is, I mean, I can read this email just as well as you can.
	But what I'm saying is Free Speech Systems can't testify at all today concerning why it is that Mr. Salazar received this email, correct?
	I mean, I can just by reading the email.
	It says he signed up for this particular service.
	So it's an email confirmation.
	So Free Speech Systems is prepared today to testify that Mr. Salazar attempted to sign up for access to the crisisactors.org website?
	That's what it appears to be.
	Well, I know what it appears to be.
	I'm asking whether Free Speech Systems is going to offer that sworn testimony that Adan Salazar attempted to register to gain access to the crisisactors.org website in January 2013.
	All I could testify to is to what's in the document.
	I can't testify to anything else.
	Okay.
	So, to be clear, Free Speech Systems cannot testify as to why Adan Salazar was receiving this email, correct?
	No.
	Okay, you can pull that down.
	Did you review a video published January 7th, 2013, January 27, 2013, titled Why People Think Sandy Hook is a Hoax?
	Yes.
	Let's see.
	You reviewed Ms. Karpova's testimony concerning this video?
	may I just have a moment to just pull up my notes Okay, what was your question?
	You reviewed Ms. Karpova's testimony concerning this video?
	Yes.
	We are aware that Free Speech Systems has previously testified that it could not say who researched this video.
	What do you mean by who researched the video?
	I'm asking you whether you're aware that Free Speech Systems has previously testified that it did not know who researched this particular video.
	Are you aware of that?
	I think that Daria testified to that, yes.
	Okay.
	What Daria did as Free Speech Systems.
	Right.
	Thank you.
	And did you ask Mr. Jones specifically about this video?
	I asked Rob Dew about this video.
	Did you ask Mr. Jones about this video?
	I did not ask Mr. Jones about this video.
	Just please try and answer the question I asked you.
	I didn't ask you about Mr. Dew, did I?
	Did I?
	No, but he didn't host the videos.
	Did I ask you about Mr. Dew?
	No.
	Thank you.
	Objection.
	There's no one hectoring like that.
	Nobody's hectoring.
	I'm just trying to make sure that we can get answers to the questions that I ask.
	So I just want to state that I recognize Chair Attorney Pattis' view and perception.
	Ms. Paz, your testimony here is that the January 27th, 2013 video, Why People Think Sandy Hook is a hoax, was hosted by Rob Dew?
	So according to my notes.
	Ms. Paz.
	Excuse me, can I answer your question?
	I'm trying to answer your question.
	So based on my notes, what I wrote in my notes was that Rob Dew had done this segment, why people think Sandy Hook is a hoax.
	So the answer is yes.
	Okay, so Free Speech Systems testimony is that Rob Dew, not Alex Jones, Appeared in this video.
	That's according to my notes.
	I'm not asking you about your notes.
	I'm asking you about free speech systems testimony.
	Okay?
	We are entitled, my clients are entitled to free speech systems testimony.
	That's what you're here to give.
	Okay?
	I have your notes.
	I can read your notes.
	What I don't have is free speech systems testimony.
	And so what I'm asking you is: is it free speech systems testimony that Rob Dew appeared in the January 27, 2013 video, not Alex Jones?
	And as I stated earlier, I can testify as to my recollection based on my notes, and that's what is in my notes.
	So that's my recollection based on what is in my notes.
	So that's your sworn testimony as free speech systems representative, correct?
	That Rob Dew appeared in this video, not Alex Jones.
	Like I said, my testimony is that that's what my notes say.
	So I don't have any independent recollection as I sit here now.
	I'm reviewing my notes.
	Okay, so now your testimony is you don't know who appeared in this video.
	Objection?
	No.
	Her testimony hasn't changed in the three times she's answered the same question.
	Okay, let me ask it a different way.
	Does free speech systems know?
	Can I ask you to stop looking at your notes for a second?
	Sure.
	Thank you.
	Does free speech systems know who appeared in the video, why people think Sandy Hook is a hoax, published January 27, 2013?
	Yes or no?
	Objection to form.
	Can I ask you to stop looking at your notes?
	I'm going to rely on my previous answer.
	Which is what?
	Which is that based on my refreshed recollection based on my notes, my notes say it's Rob Dew.
	I don't, I know what your notes say.
	Sir, I don't, I'm answering the question.
	It's not going to change.
	My answer is not going to change.
	No, you're not.
	You're not answering the question.
	I did answer your question.
	Can I see your exhibition?
	No question.
	Can I see your exhibit?
	Ms. Paz.
	Does Free Speech Systems know who appeared in the video, Why People Think Sandy Hook is a hoax, which was published on January 27, 2013?
	Does it know?
	Objection.
	I'm going to refer to my previous answer.
	Okay.
	You haven't answered that question yes or no?
	So yes or no?
	I'm going to instruct the witness not to answer any question again.
	Okay, let's get Judge Bellis on the phone.
	Farewell.
	We'll take a break.
	Should I take a break of record?
	Yeah.
	We are all for record the time is 2.54 p.m.
	EST.
	We are now on the record the time is 2.58 p.m.
	EST.
	Are you familiar with the claims made in the January 27, 2013 video Free Speech Systems published called Why People Think Sandy Hook is a Hoax?
	Yes, I am, if I could have my binder back.
	Sure.
	Thank you.
	Okay.
	Okay.
	The individual who published statements in that video stated in that video that people in connection with the Sandy Hook shooting had been coached, correct?
	I'm sorry, can you repeat the question?
	Sure.
	Yep.
	In the video that Free Speech Systems published, the claim was made that people in connection with the Sandy Hook shooting had been coached, correct?
	So this was an interview with people who produced a documentary in Independent Media Solidarity.
	And the claims were that people were behaving like actors.
	It looked like an inside job.
	Ma'am, I don't know if they use that exact terminology that you just stated.
	Are you reading from your notes?
	Yes.
	Okay.
	And so these are, you don't have an independent recollection as you sit here today with this particular video.
	Is that fair to say?
	Not every single thing that was said in every single video.
	There's something like 35 hours or more of video.
	I just asked you about this video.
	I have my notes on the video, and I didn't.
	My question is: do you have an independent recollection of this video, separate and apart from your notes?
	I know what the video is about.
	My separate recollection is I know what the video is about.
	Okay.
	And you believe that this was a video hosted by Rob Dew in which he interviewed two documentary filmmakers, right?
	That's what you believe this video to be on published on January 27, 2013?
	So January, my notes from January 27th, 2017.
	I'm not asking about 2017.
	Oh, 2013, I'm sorry.
	Is the title is why people think Sandy Hook is a hoax.
	The hour ID number is TM5Z and a bunch of other numbers and letters thereafter.
	And based on my notes, this is a discussion of that documentary.
	Right.
	So that's correct.
	Okay.
	And you just refreshed your recollection from your notes, fair to say?
	Right.
	Okay.
	If I take a look at your notes again, if you don't mind.
	Take this back.
	Take a look at your notes again.
	Okay.
	Let's play exhibit.
	So, As of January 27th, 2013, so about six weeks from the date of the shooting.
	Uh-huh.
	Had anybody at Free Speech Systems attempted to contact any of the victims of the shooting?
	I don't believe so.
	I don't have any information to suggest that they did, so no.
	The answer is no.
	Right.
	Had anybody at Free Speech Systems attempted to contact any extended family of any of the victims?
	Up to that date?
	Yeah.
	I don't believe so.
	No, I haven't seen anything like that.
	So the answer is no.
	Right.
	Had Free Speech Systems attempted to contact any school administrators about the school shooting?
	I don't believe so, no.
	Had Free Speech Systems attempted to contact any local law enforcement concerning the school shooting?
	I don't believe so, no.
	Had Free Speech Systems attempted to contact anyone involved in the arrangement of funeral services for the victims?
	I don't know.
	I don't think so.
	I haven't seen anything like that, but I'm not sure.
	Okay, so the answer is that Free Speech Systems doesn't know whether any of its employees had attempted to contact anybody involved in funeral arrangements, correct?
	Right, I don't know.
	Okay.
	had free speech systems attempted to contact any local press who were reporting on the shooting I don't believe so, no.
	I haven't seen anything like that.
	So the answer is no?
	No.
	Had anybody at Free Speech Systems attempted to reach anybody associated with Adam Lanza?
	I don't believe so, no.
	I haven't seen anything like that.
	Okay.
	So no.
	Had anybody at Free Speech Systems gone to Connecticut?
	Up until January 27th?
	Right.
	Now.
	So I want to try and clear some confusion up because I think you're incorrect.
	I don't think that the documentary, the Rob Dew interview was January 27, 2013.
	But I also don't want to just be able to confirm that.
	So why don't we take a 10-15 minute break and we'll see what we can do here.
	We are off the record.
	The time is 3.06 p.m.
	EST.
	We are now on the record.
	The time is 3.18 p.m.
	EST.
	All right.
	Ms. Paz, when we left.
	Yes.
	I was trying to get some clarification on the video that you reviewed that Free Speech Systems published on January 27, 2013.
	I want to bring up a document that we received last night.
	This will be Exhibit 103.
	I'll bring it up for you as well.
	Do you recognize this spreadsheet?
	Yes, I think that's a copy of the spreadsheet that I have here.
	This is the spreadsheet that you were referencing earlier, correct?
	Right, right.
	All right.
	And on this spreadsheet, you'll see if I can get it right, on row nine.
	Do you think we can print a little larger, or is that as good as it's going to get?
	I don't know if that's any better, but if there's a way, Pratika will find it.
	The video that I was trying to ask you about is listed here on row 9, correct?
	Why people think Sandy Hook is a hoax?
	Yes, yes.
	Okay.
	That's what I was referring to.
	And you made this spreadsheet yourself, right?
	Yes.
	Okay.
	And in the column that you labeled claims made in video, you have SH documentary, quote, I clearly believe from the evidence people were killed.
	And then you have sourcing done by Dew and Jones, right?
	Yes, that's what it says.
	And you were also previously referring to some other notes in which you said that, according to your notes, Mr. Dew hosted this particular video, correct?
	Right.
	And that you believed that this was where Mr. Dew was publishing information about the documentary, correct?
	Right, the Sandy Hook documentary that was made by Independent Media Solidarity.
	Right.
	Right, right.
	Now, if you go down further to row 22, do you see there you're describing a video published on December 12, 2014, and in the notes there you have Rob Dew Independent Media Solidarity Documentary?
	Yes.
	Let me just pull up the specific notes for that one.
	if i could is it okay if i refresh my recollection on that one ah
	so Okay.
	Go ahead.
	So my question is: do you think, do you recall two different videos that Rob Dew made with the independent media solidarity producers?
	So that video, the one on 12-12, 2014, the one that has the 4T8 ID number, that is also talking about the documentary Independent Media Solidarity.
	So it could be that it was published in two different places, or it was published as having two different ID numbers.
	But according to my notes and me refreshing my recollection through my notes, that article or video under that ID number 4T8 talks about that documentary, independent media solidarity.
	And so you don't think, well, all right.
	Let me show you what we've marked as exhibit 47.
	Why people think Sandy Oak is a hoax?
	And you tell me whether you think.
	Did you say 47, Chris?
	Yeah.
	Go ahead and play that.
	These are aerial pictures here in Harris County, Texas, as we have been watching the better part of this last hour.
	North Harris can.
	Have you watched this video before?
	Can I see how long it is?
	Does it show?
	17 minutes.
	Okay.
	I'm told it's 17 minutes and 30 seconds.
	Why don't we play a little bit more and see if that helps you?
	This is on lockdown.
	This is an active situation.
	We are not showing you live pictures because Because of what we may possibly see.
	The corporate state-run media calls anybody the questions.
	Leave.
	Have you seen this video before?
	I don't know.
	It doesn't really look familiar to me.
	So that's why I asked in the beginning about if you had the ID number, because I'm not sure if it's the same video that I have on my list here.
	So I'm not sure is the answer.
	Okay.
	Right.
	And so Free Speech Systems is not prepared to testify today as to whether it ever published this video, correct?
	Yeah, I'm not sure just because, like I said, I don't have the ID number of what this video is.
	Okay.
	And so whatever claims Mr. Jones makes in this particular video, you're obviously not prepared to testify about today, correct?
	Because you don't even know if you've ever seen it.
	Right.
	Okay.
	Thank you.
	You can pull that down.
	Did you make any effort to speak with Steve Pachenek in preparation for your deposition today?
	No.
	You've never spoken to him before?
	And Mr. Pachenek appeared several times on the Alex Jones show and other Free Speech Systems programs, correct?
	Yes, I believe before and after Sandy Hook.
	And he appeared after Sandy Hook several times for the purpose of discussing Sandy Hook, correct?
	Yeah, two or three times.
	And during those appearances, Mr. Pachenik said, among other things, that there wasn't kids who were killed at Sandy Hook, correct?
	He did.
	Okay, and Free Speech Systems published that statement, correct?
	On the video interview, yes.
	And published it onto Infowars.com, correct?
	Okay.
	And then uploaded that to YouTube, correct?
	Yes.
	Okay.
	And that was a statement that Mr. Pachenek made in March of 2013, correct?
	If I may just look at my notes.
	Yes, I believe he said that on 3-27, 2013, and he said Sandy Hook was a false flag and that kids didn't die.
	You think that happened on March 27th or March 7th?
	The date that I have upload date title, Dr. Steve Pachenek, Sandy Hook was a total false flag.
	That was on 327.
	But it looks like he, yeah.
	327.
	He was on several times, right?
	He was on a couple of times.
	He also said it again on 4-1, but 327 and 4-1.
	Fair to say, as you sit here today, Free Speech Systems doesn't know how many times Mr. Pachenek appeared on the air and stated that no children died at Sandy Hook.
	It was either two or three.
	Okay.
	Two or three.
	You can testify to that.
	Yes.
	Okay.
	And Free Speech Systems repeated those claims in articles it published in which it referred to Mr. Pachenek's statement that no children were killed, correct?
	It republished Mr. Pachenek's opinion, correct?
	Okay.
	Well, when Mr. Pachenek says no kids were killed, that's an assertion of fact, right?
	I think it's his opinion based on what he sees, so I think it's his opinion.
	Well, you didn't talk to Mr. Pachenek.
	I didn't.
	Right.
	So Free Speech Systems did nothing to investigate Mr. Pachenek's claim that no children were killed there, correct?
	I watched the videos in the videos.
	No, no, no, I'm sorry.
	At the time.
	Oh.
	Free Speech Systems did nothing to investigate that claim, correct?
	Oh, no.
	I mean, he had been previously on the show.
	I think that he and Alex had a prior relationship before this, so he had him back on after Sandy Hook to put his opinions on the air.
	I'm asking you specifically, and see if you could just focus on my question, whether Free Speech Systems did anything to investigate Mr. Pachenek's claim that no children were killed at Sandy Hook, yes or no?
	No, nobody knows what he was going to say before he got on.
	I didn't ask whether they knew what he was going to say.
	I asked whether anybody at Free Speech Systems investigated his claim to verify it that no children were killed at Sandy Hook.
	Well, if they didn't know what he was going to say, how could they investigate it?
	Is that a no?
	No, right.
	Okay, they didn't.
	Nor did they investigate it after the fact.
	No, it's his opinion.
	Right, okay.
	And the, and Mr. Jones referred to Mr. Pachenek's statement that no children were killed at Sandy Hook as amazing info, right?
	I don't think that he was referring specifically to the claim that no children died, especially because Alex specifically did not endorse that statement.
	Was Alex Jones ever said that nobody died?
	In that particular video, did Alex Jones ever say nobody died?
	Yeah.
	He may have said it in one or two of the videos.
	I'm going to ask you whether he may have.
	Did he or didn't he?
	I think he does say it in one or two of the videos.
	Free Speech Systems acknowledges that Alex Jones said nobody died at Sandy Hook, at least once, maybe twice.
	Right.
	Correct?
	Yes, but what I'm saying, if you'd let me answer the question.
	All I want to know is, in answer to my question, whether or not Free Speech Systems' testimony is that Alex Jones said that.
	I think the witness can answer the question.
	Excuse me.
	Excuse me.
	Mario, excuse me.
	You asked me previously if Alex endorsed or otherwise go ahead.
	What I said was, did Alex Jones refer to Mr. Pachenek's statement that no kids died at Sandy Hook as amazing info.
	And I think Free Speech Systems' testimony just now was you didn't think that's what he was referring to, correct?
	That's correct.
	And if you'd let me finish my statement, the reason why I think that what I'm asking you now is to confirm that Alex Jones has said on the air that nobody died at Sandy Hook.
	And I believe Free Speech Systems testimony is that he has said that, correct?
	I believe he said it in one or maybe two videos, so yes.
	Thank you.
	And after Mr. Pachenek said that no children died at Sandy Hook, he was invited back on to again discuss Sandy Hook, correct?
	Yes, he was invited back on on 4-1.
	So three or four days later.
	Right.
	And in fact, Mr. Jones wanted him on for the full hour after Mr. Pachenek made the claim that no children died at Sandy Hook.
	Mr. Jones invited him back on for the full hour, right?
	Well, just to be clear, Steve Pachenek said a lot of things in that interview.
	So it was a very long, and at some point Alex had to cut him off because he talks a lot.
	So that could be a reason why he wanted him on for the full hour.
	But yes, he did invite him on for a full hour.
	I feel like in that statement just there, you were kind of just spitballing about why Alex Jones may have cut him off.
	Did Alex Jones, when you interviewed him, tell you anything about this particular interview with Steve Pachenek?
	Oh, I didn't ask him a specific question about Steve Pachenek interview.
	Whether Jones said anything to you.
	I didn't ask you.
	What do you asked him?
	I asked you whether Alex Jones said anything to you about this interview with Mr. Pachenek.
	No, I didn't ask him specific questions about that.
	So Free Speech Systems doesn't know why Alex Jones may have cut him off in your view, right?
	He didn't tell you.
	I watched the video.
	I saw him being cut off.
	So that's based on your personal knowledge, right?
	Right, because I watched the video.
	All right.
	But regardless of why Mr. Jones, how Mr. Jones may have ended the interview with Mr. Pachenek on March 7th, he wanted him back for the full hour after he made the claim that nobody had died at Sandy Hook, right?
	Yes.
	Okay.
	And Mr. Pachenek obliged.
	He came back, right?
	so And when he came back, he came back on April 1st, and Free Speech Systems published a video of that interview as well that Mr. Jones conducted with Mr. Pachenek, right?
	Yes.
	And it titled that video, Crisis Actors Used at Sandy Hook Special Report, right?
	Yes.
	Okay.
	And that video was also uploaded to YouTube, correct?
	yes
	And in that video, Free Speech Systems again published Mr. Pachenik's statement that there was no killing at Sandy Hook, right?
	Yes, Dr. Pachenek does say that again.
	Yeah, in fact, he says that the kids were never killed and were never present, correct?
	I believe so, yes.
	Right.
	And certainly as of that time, when Mr. Pachenek came on a second time, Free Speech Systems was fully aware of the statements he was likely to make regarding the Sandy Hook shooting, correct?
	Yes, I believe Alex was debating him on that issue.
	did Mr. Jones tell you he was debating him?
	Did Mr. Jones tell you he was debating Mr. Pachenek yesterday?
	Tell me, no, he says it in the video.
	That's all I asked.
	So you think Mr. Jones told him in the video that I'm debating you?
	He says clearly in the video, why do you think that?
	I get they do false flags, but how do you get kids didn't die?
	So he was trying to have a debate with him or a discussion with him about why he thought what he thinks.
	Mr. Jones never said to Mr. Pachenek, I'm debating with you, did he?
	He didn't use the word debate.
	But you just testified under oath that he did.
	Didn't you just say that?
	What I said was I think that he was trying to ask him what the source of his opinion was, and that to me is the definition of a debate.
	So he asks him, quote, I get they do false flags, but how do you get kids didn't die?
	Okay.
	And so you agree with me that Mr. Jones did not have Mr. Pachenek on for a debate, correct?
	Whether the purpose of the interview was a debate?
	Oh, I don't know whether the purpose of it was a debate, but I think that he asked that question to debate the issue with him.
	Okay, so your view, Free Speech Systems view, is that on April 1st, 2013, when Mr. Pachenek came on, Mr. Jones was debating Mr. Pachenek.
	That's Free Speech Systems testimony?
	Again, I'm going to rely on my previous answer where he did not use the word debate, but he clearly wanted to have this discussion with him about why he thought what he thought.
	Right.
	And of course, Mr. Jones has already stated at this point to his audience that they staged Sandy Hook, correct?
	I don't know if he's, by that point, he's outright said it was staged.
	I think that the coverage up to that point was mostly Second Amendment issues.
	There may have been some things that were highlighting some inconsistencies that they were talking about.
	So I don't know that he had clearly said by this point it was staged.
	So when Mr. Jones published a video that he titled Crisis Actors Used at Sandy Hook Special Report, that's what he was conveying to his audience with that title, that crisis actors were in fact used, right?
	Are you referring to the 4-1 2013 video?
	That's the video that was titled Crisis Actors Used at Sandy Hook, correct?
	Right, that's Dr. Prochanek's opinion that crisis actors were...
	Oh, we title the videos.
	Oh, I don't know who picked the title for this particular video, but generally if it's Alex's video, Alex would pick the title.
	Right.
	Right.
	Well, so when you say you don't know, you mean Free Speech Systems doesn't know who selected this title?
	As I just testified, generally if it was Alex's video, Alex would pick the titles.
	So is it Free Speech Systems testimony in this case that Alex Jones picked that title?
	Just your phone.
	I haven't asked him about specifically this title, but as I indicated, Alex would pick the titles of his videos.
	I'm just trying to, you know, you need to testify.
	One way or another.
	Either you don't know, either Free Speech Systems doesn't know who titled that video, or it does know, and it was Alex Jones, or it was somebody else.
	So I'm just asking you.
	I'm asking you what Free Speech Systems general practice was.
	I'm asking you whether Free Speech Systems can testify today as to who titled the video that.
	I don't know.
	You don't know?
	Fair enough.
	Free Speech Systems is willing to testify that the general practice is that where Alex Jones was creating a video on his show that he would then title the clips for upload to YouTube, right?
	Right.
	Okay.
	And Free Speech Systems can't offer any testimony today about what the bases for Mr. Pachenek's statement that no children were killed at Sandy Hook were, correct?
	Well, I could cite to what he says in the video because he bases, he states why his opinions are what they are in those videos.
	So free speech systems could restate what Mr. Pachenek says in the video.
	Right.
	But you haven't, Free Speech System hasn't inquired of Mr. Pachenek in connection with this litigation what the bases were for that statement.
	Yeah, I've already said I haven't interviewed him.
	I'm going to put it in the middle of the day.
	Did Free Speech Systems publish an article on January 8, 2013 featuring Jim Tracy?
	You said January 8th.
	Is this the one titled Professor Claim Sandy Hook Massacre?
	MSM Misinformation?
	I can't answer your question.
	I'm just asking you what okay well I have I have a video but it's not the same date that's why I'm asking a video asked you about an article oh an article I don't I don't know I may have read an article I read the video regarding Mr. Tracy but I don't recall the article okay so Free Speech Systems isn't prepared to testify about any article that it published on January 8th 2013 concerning Jim Tracy correct as I indicated earlier I've read through a lot of documents
	I may have read it.
	If you want to refresh my recollection, I'm happy to look at it, but I don't recall as I'm sitting here whether I read it.
	Do you recall whether anything like that was even published on January 8th?
	An article about James Tracy?
	Yeah.
	I believe that we did publish a article.
	Okay.
	Do you recall when?
	I don't recall when, no.
	Okay.
	Do you recall what that article said?
	No, I don't.
	Okay.
	So you're not prepared to talk about that article because you don't recall what it said, right?
	Well, as I said, if you could refresh my recollection, I'd be happy to talk to you about it, but as I sit here today, no.
	Okay.
	And did free speech systems embed a video in the article it ran concerning Jim Tracy?
	I don't know.
	Okay.
	So I see we have five minutes before we're supposed to call in.
	I'm going to mute myself and call in if you guys want to continue.
	I think that, you know, since she testified that she did not know whether she had seen the video that I showed her, I think that that actually obviates the issue now.
	So I think we're fine.
	I think that she would have said if we got on the phone with her.
	She's in corporate, you know, you obviously have a corporate representative on the stand or under oath.
	The corporation can't speak.
	It picks its people through whom it speaks.
	She is testifying.
	From time to time, she has not had a failed recollection.
	And there have been occasions, even recently, where when she said she can't recall, you'll say, well, then you can't testify because you don't know.
	And I think there's a difference between refreshed recollection and even past recollection recorded.
	And I think she's entitled as a witness, even if she's a person testifying for a corporation, to avail herself of those moves if requested.
	And so my position in the rift that led to our request for a judicial thing is, in my impression, the plaintiff's counsel is being unfair to her by insisting on standards that really aren't applicable to it.
	Actually, you know what?
	I'm glad you mentioned that, Norm, because I think this is going to come up again.
	actually let's let's let's keep this so we can get some guidance from the judge on this very issue over and over my issue is that you're there's a you're asking her to testify what the company knows and i know i think she can only testify as to anything that regards her person to her personal knowledge.
	I don't think any other evidence is competent.
	So I don't think she can say the company knows.
	She might say people at the company knows, or I believe, you know, they're, but she can only testify to things that she actually knows or about inferences that she's making based on that personal knowledge.
	Mario, I have to tell you, Mario, I think your inference is based on what she knows.
	You're absolutely incorrect about the purpose of a corporate designee deposition, Mario.
	So I encourage you to take a look at that rule.
	But let's get on with Judge Bellis because I do think it's important for us to.
	So are we calling individually from our devices or do you have something there?
	Yeah, we'll have to call in, I think, individually, right?
	It's not going to call you on mute or not.
	Oh, we can put her on speaker.
	Do you want us to step out?
	Yeah, you should step up.
	That was all on the record, by the way.
	Did we ever stop the video record?
	Well, that's fine for the record.
	That's fine.
	So, Chris, do we need to dial in ourselves here?
	I think actually they're saying that we can do it from here.
	And would you like me to keep the video record going right now?
	No, no, you can take it off.
	Okay, we are off the record at 3:43 p.m.
	ESC.
	We are now on the record.
	This time is 4:37 p.m.
	Yes.
	Just pause.
	When we last broke, I asked you to excuse yourself from the room, correct?
	Yeah.
	Okay.
	And I did that because you knew that we were calling Judge Bellis to get her to rule on a disputed issue regarding your testimony, correct?
	Yes.
	As an attorney, of course, you know that it's standard for witnesses to be excused from a proceeding where a judge is considering their testimony, correct?
	Yes.
	And that's so as to prevent the witness from gaining any unfair advantage from overhearing what might be happening during the conference, correct?
	Sure.
	And you excused yourself from the room, correct?
	Yes.
	And then while you were outside, am I correct that you leaned towards the door with your ear next to the door in order to overhear what was happening?
	I was sitting on the couch and I could overhear, yes.
	Is it your sworn testimony that you did not lean toward the door?
	I did lean toward the door.
	Yes.
	Let me finish my question.
	Is it your testimony that you did not lean toward the door with your ear next to the door?
	I just said I did lean towards the door, yes, to hear it.
	And you weren't sitting on the couch when you did that, you were standing, correct?
	I think I started out sitting and then I stood.
	Okay.
	And that was to get see if you could hear any better, right?
	Sure.
	Okay.
	And you did that so that you could overhear the status conference with the judge, right?
	Sure.
	Okay.
	And you did that as an officer of the court, correct?
	I'm not here in my capacity as an officer of the court, so no.
	You understand, do you not, the impropriety of trying to gain an unfair advantage in a deposition after you've been excused from the room so that the parties can discuss something with the judge?
	I don't think I did it to get an unfair advantage, but I acknowledge that I was at the door, yes.
	You think it was appropriate for you to try and listen in to a court conference that you've been excused from for the specific purpose of overhearing what was going on?
	No.
	It was inappropriate, right?
	Yes.
	Why did you do it?
	I was sitting at the couch and I could hear.
	Why did you lean up against the door specifically for the purpose of overhearing?
	I don't know how else to respond except that I did sit at the couch and I could hear.
	And I'm just asking you why you did that.
	So that I could hear.
	You took affirmative efforts to hear, correct?
	Well, I was sitting at the door and I could already hear.
	And then rather than excuse yourself knowing that that wasn't something you were supposed to be hearing, you leaned closer to get a better listen, right?
	Right.
	Right.
	And how long did you do that for?
	I don't know.
	I don't know how long we were out.
	I wasn't timing myself.
	Okay.
	Did you get to listen to most of the status, most of the conference?
	No.
	I went to the bathroom.
	I came back.
	You were in here for a while.
	So a few minutes, you would say you were overhearing?
	Possibly.
	Okay.
	And you're not willing to tell me why you did that?
	This is Norton.
	Is it necessary?
	You've got your record.
	I already testified.
	Is it necessary to know at this point?
	Well, I just haven't heard why she did it.
	What she said in response to that question.
	Is this reasonably calculated to yield the discovery of admissible evidence?
	I do think that this bears directly on the witness's credibility.
	Would you reconsider that, please?
	Just tell me why you tried to overhear.
	So I could hear.
	But why did you want to hear?
	So I could hear and know what was happening.
	I don't know why.
	I can't answer that.
	I'm sorry.
	Okay.
	Okay.
	Going back to the January 27th, 2013 video, why people think Sandy Hook is a hoax.
	Okay.
	So which free speech systems employees appeared in that video?
	Would you be able to direct me to the ID number for the video that you're referring to?
	No, I don't.
	Those are free speech systems ID numbers.
	Right, the combination of letters and numbers.
	Let me see if I can do that.
	Do we have that one?
	Probably on this one.
	Okay.
	So I have an ID number that may help you.
	Yep.
	36_TM5ZDO-IGE I don't have anything like that on my list.
	So if that's the ID number, then that's not the same video that I reviewed.
	Okay.
	And so at least with respect to a video with that ID number, that is not a video that you reviewed.
	Right, right.
	So Free Speech Systems is not prepared to testify as to anything concerning the video assigned that ID number, correct?
	Alright.
	Going back to the video entitled Crisis Actors Used at Sandy Hook Special Report that was published on April 1st, 2013, correct?
	You familiar with that video?
	Yes, the one with Dr. Prochenic.
	Now, during that video, Mr. Jones said that it's just all clear scripting, correct?
	Let me just, if I can, refresh my recollection with my notes because I did watch that video.
	Okay.
	What was your question?
	I'm going to move on to a different question.
	You have your notes before you?
	About that video, yes.
	Okay.
	Mr. Jones stated during that video that All the people that look and act like actors, right?
	Sigh
	Sorry, let me just review my notes.
	I didn't write down that specific comment, but I recall a comment like that.
	Okay.
	So Free Speech Systems acknowledges that during this particular video, Mr. Jones referred to people associated with the Sandy Hook shooting as people that look and act like actors, correct?
	Yes, I think that he had that opinion at that point in time.
	Yes.
	I'm not asking about what his opinion was right now.
	I'm just asking you about whether Free Speech Systems acknowledges that Mr. Jones said of people associated with the Sandy Hook shooting that they look and act like actors.
	Did he say that?
	Oh, right here.
	My notes say a whole group of actors, is I think what he said.
	Okay, well, I didn't ask you about that.
	And so I asked you whether or not Free Speech Systems can confirm that in referring to people associated with the Sandy Hook shooting, Mr. Jones said that they are people that look and act like actors.
	I don't, like I said earlier, I don't have that specific statement in my notes.
	So I don't know.
	Okay, so Free Speech Systems doesn't know whether he said that, correct?
	Okay.
	Okay.
	You didn't ask Mr. Jones specifically about that statement, correct?
	For this particular video, no.
	Okay.
	Did you review a video published April 9th, 2013 titled Obama Gun Grab PSYOP?
	April what?
	4th.
	I'm sorry, April 9, 2013.
	I don't have anything that is titled anything like that.
	Do you have a ID number?
	I don't have an ID number.
	Okay, then I don't know.
	Okay.
	Did you review a video published April 16th, 2013, titled Shadow Government Strikes Again at Boston Marathon?
	Do you have an ID for that one?
	I don't.
	I don't have anything.
	Wait, one second.
	I don't have anything around that date or with that title on my list.
	So unless I have the ID number, I don't know.
	Okay.
	Did you review Ms. Karpova's testimony about that video?
	I reviewed her deposition, and I think that this was, was this part of the video that she was shown during a break?
	She was shown a video during a break.
	I remember that.
	It might have been this video.
	Okay.
	Well, let me ask you whether you recall specifically Ms. Karpova's testimony about this particular video.
	I remember that she testified about it.
	I don't know, I don't recall as I'm sitting here what exactly she said.
	Okay.
	All right.
	When did Free Speech Systems first have access to a copy of the state's attorney's office report on Sandy Hook?
	I believe it was in an email exchange.
	I can't, off the top of my head, tell you the date, but I recall seeing an email exchange in which it was emailed to, I believe, to Rob Dew directly.
	Okay, let me show you exhibit 24 and see if this is the email you're referring to.
	here.
	Okay.
	Do you have an email before you dated November 26, 2013 from changeshorses at AOL.com to Mr. Dew and Mr. Nimmo?
	Yes.
	Okay, is this the email you were referring to?
	I believe so, yes.
	It looks familiar.
	And so you see what appears to be a link there saying Sandy Hook final report?
	Yes.
	And so Free Speech Systems testimony is that that was a link to the state's attorney's report on Sandy Hook?
	I believe so, yes.
	I think it was also forwarded or Rob also replied to this email.
	There's more to this email chain.
	Okay.
	And so when you were referring to an exchange of emails, you were referring to Rob receiving a copy of the report, correct?
	Right.
	And then him acknowledging that in a subsequent email?
	I believe so, yes.
	I have a recollection of that.
	Okay.
	Okay.
	And others within Free Speech Systems, in addition to Kurt Nimmo and Rob Dew, had access to the report as well, correct?
	Oh, I don't know.
	Okay.
	I know that Rob had it.
	I don't know what he did with it once he had it.
	Okay.
	Well, and you know that Kurt Nimmo had it as well.
	Right.
	Because he's copied here.
	Right.
	But Free Speech Systems isn't aware whether Rob Dew disseminated the report to anybody else at Free Speech Systems.
	That's right.
	Okay.
	Did Alex Jones read this report?
	I don't know.
	Did he ask anybody to summarize it for him?
	I don't know.
	Did he express any interest in it in any way to anybody at Free Speech Systems around this time?
	Not that I'm aware of.
	Okay.
	Meaning Free Speech Systems isn't aware of it.
	Right.
	Okay.
	Does Free Speech Systems agree that the findings of the Sandy Hook report refute factual claims that Free Speech Systems had published at this point about Sandy Hook?
	Could you be more specific as to which claims?
	Sure.
	The claim that kids didn't die at Sandy Hook is refuted by this report, correct?
	Oh, yes.
	Okay.
	The claim that crisis actors were involved in Sandy Hook is refuted by this report, correct?
	I think that the claim regarding crisis actors, I don't know that it's really, it's addressed by this report.
	Okay.
	So I don't think so, no.
	So free speech systems testimony is that the report of the state's attorney's office does not undermine any claim that crisis actors were involved in that event.
	Well, I'm going to object as to the form.
	The prior testimony was refuted, undermined, I don't, that may be a distinction without a difference, but they are different questions.
	Go ahead, you can answer.
	Undermine or refute?
	I just said undermine.
	Undermine.
	I think that the claims regarding crisis actors are regarding, you know what?
	Not to my knowledge, no.
	Okay, okay.
	So Free Speech Systems testimony is that the Sandy Hook report does not undermine any of the claims it had made to this point about crisis actors being involved in Sandy Hook.
	Right.
	Okay.
	And does Free Speech Systems agree that the report of the state's attorney's office on the Sandy Hook shooting refutes that there any suggestion that there was overwhelming evidence that the shooting was staged?
	Does the report refute whether the shooting was staged?
	That's the question?
	No, the question is, to the extent prior to the report's release, anybody at Free Speech Systems had said that there was overwhelming evidence that the shooting was staged, does the report refute that claim?
	I don't know.
	Okay.
	Does the Sandy Hook report refute the claim concerning Mr. Salazar's and Free Speech Systems suggestions that there was foreknowledge of the shooting by somebody associated with the Batman movie I think I testified earlier that I didn't think that that's what the article suggested so no okay did the to the extent anybody with free speech systems claimed that the Sandy Hook
	shooting was an inside job prior to the release of this report.
	Does the report in any way refute that?
	I don't know.
	As Free Speech Systems corporate representative, have you read the report?
	Yes, I read it.
	When did you read it?
	I read it before my Texas deposition.
	a month ago a little over a month ago did you ask mr. Dew about the report he and I spoke for around two hours I don't recall us talking about the report show
	you exhibit number two.
	I'm sorry, the exhibit number again?
	Two.
	Two.
	Thank you.
	Do you have two before you?
	Yes.
	Okay.
	Okay.
	These are your handwritten notes, correct?
	Could you scroll down?
	Yes.
	These are the notes that you believe are at your house, right?
	Yes.
	These have not been produced to us by free speech systems.
	We obtained these as a result of their production in Texas.
	Okay.
	And you'll see that's why there are exhibit stickers marked there.
	Yes.
	They were marked as exhibit in one of my depositions there.
	And so having looked through these notes, I know only very quickly, these appear to be the same handwritten notes that you presented at your deposition in Texas, correct?
	Right.
	Okay.
	All right.
	I just asked if you could bring them in tomorrow so that we can have our own copy.
	Well, if they're there, that means they have them.
	So I don't have it then.
	Oh, you think you left your notes there.
	I assume that these had just been scanned by them.
	No.
	They have them then.
	So I brought out a binder.
	So I brought out a binder.
	And I think they took the entire binder.
	So they may have the entire packet of notes.
	Okay.
	So those are original, like they marked the originals, right?
	Right.
	And then they took them as exhibits.
	That's why the exhibit sticker is on there.
	Okay.
	So I think they have them.
	Okay.
	Counsel, did you receive a scanned copy of these once they were marked?
	I will double check tonight, Chris.
	I don't recall doing so, but I also missed the 25 pages of type notes.
	So if possible, let me check tonight.
	Okay.
	If we just go down to page two.
	Can you tell me where your notes of your conversation are?
	or conversations with Alex Jones begin could you scroll up all right and down can you go to page three Okay.
	down more.
	So it looks like the second page is mostly Alex, but I'm not sure.
	There may be more after that because I spoke to him a couple of times.
	Okay, we'll go through that in a little bit more detail tomorrow.
	And maybe what I can do, Ms. Paz, is I'll print these off so that you can review them so that we can be more efficient about it tomorrow.
	Sure.
	But at least with respect to page two, your testimony is that these are notes reflecting at least one of your conversations with Mr. Jones, correct?
	That's what it looks like, yes.
	Okay.
	And if you go towards the bottom of the page, you see down there, not engaged in journalism with not in all caps and underlined, correct?
	Yes.
	And that's what you took from your conversation with him?
	Yes.
	And then you also have down here a star, which I read as an asterisk, rather, and I read that as saw Halbig on CNN recolumbine, right?
	Yes.
	And there's a word kind of right underneath that.
	What's that word?
	Okay.
	I hate to say that I can't read it.
	Okay.
	I can't read it.
	Okay.
	Did Mr. Jones tell you that he had seen Mr. Halbig on CNN discussing the Columbine massacre?
	That's what that note says, yes.
	Okay.
	Do you recall him telling you that?
	I wrote it down contemporaneously with my conversation.
	Okay.
	And did he, when did he tell you he had seen that?
	He didn't say when.
	Okay.
	He just said he saw it.
	Okay.
	So it was just in my conversation with him, I recall seeing Halbeg on CNN talking about Columbine, and so I wrote it down.
	But you can't say whether he was referring to something he had seen in 1999 at the time of the shooting or something he had seen more recently.
	Right, I don't know when he saw it or what he saw.
	Well, it's five o'clock, so why don't we stop for the day now, and we will come back tomorrow.
	Is that all right with everybody?
	It's weird.
	10 o'clock?
	I'm just going to tennis.
	Yeah, 10 o'clock.
	The status conference is tomorrow, right?
	I thought it was today.
	We messed that up.
	It is tomorrow.
	Mario was correct.
	And as long as you guys are okay with it, I'm inclined to just send Ron an email saying that we don't think we have anything that needs discussing.
	And in light of the deposition, we'd rather not.
	Should we go?
	I'll treat it.
	I am going to file.
	Oh, yeah.
	I don't think anybody with mine could file the motion to withdraw.
	I have a draft that I was hoping something might change, and it's not going to change.
	I'm going to file that, and I'm going to get a date on that.
	You know, that's all, but that's what I'm going to be doing right now.
	You're going to file it today, Mario?
	Yeah.
	So we just need a briefing schedule on it.
	I don't think I'm, well, okay.
	If you're going to represent to me that you're not going to file a brief on it, I will carry that to the court.
	Well, why don't we do this?
	Is it possible, Mario, for you to do that with the court, come a little bit late to the deposition?
	I don't think that'll take long, and Alanor will cover that on our end.
	Yeah, so what I was planning on doing was having the audio of the deposition so I could follow along.
	Yeah.
	And in an ear piece for myself while I was talking to the court so that I could be in two places at once because I saw that.
	Having done that in this case once and made a spontaneous eruption that appeared on this record but was really directed elsewhere, I don't address it.
	It's taken.
	Everybody's taken.
	It's not very bad.
	Thank you.
	I'm going to leave.
	Normally, there's someone from your office who you can join in this conference tomorrow so we can get the couple.

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