All Episodes
Previous Next
March 16, 2022 - Depositions & Trials
05:34:18
Deposition of Brittany Paz, Lafferty vs Jones - March 16, 2022
| Copy link to current segment

Time Text
We are now on the record.
Participants should be aware that this proceeding is being recorded.
And as such, all conversation held will be recorded unless there is a request and agreement to go off the record.
Private conversations and or attorney-client interactions should be held outside the presence of the deposition.
This is a video recorded deposition of Bricky Paz being taken by counsel.
Today is Wednesday, March 16th, 2022.
The time now is 10.07 a.m.
EST.
We are here in the matter of Erica Lafferty versus Alex Jones.
My name is Joe Roguso, the videographer on behalf of Usel Support, located at 90 Broad Street, New York, New York.
I am not related to any party in this action, nor my financial incident in the outcome.
At this time, will the reporter Vicky Jesse on behalf of Us Legal Support?
Please enter the statement for more proceedings into the record.
Thank you.
The attorneys participating in this deposition acknowledge that I am not physically present in the deposition room and that I will be reporting this deposition remotely.
They further acknowledge that in lieu of an oath administered in person, the witness will verbally declare her testimony in this matter under penalty of perjury.
The parties and their council consent to this arrangement and waive any objections to this manner of reporting.
Council, if I could have you please indicate your agreement by stating your name and your agreement on the record for me.
This is Chris Maddie and I agree.
Norm Pattis, I agree.
Okay.
And usual stipulations, Council?
Yes, Miss Jesse, Mario Serami's here.
I don't know if you can hear us, but he's in hospital as well.
You need to obtain his agreement.
He just sent a message remotely that his audio isn't working and he agrees.
Got it.
Okay.
So could I ask usual stipulations?
Yes, we actually read.
Go ahead, Norm.
Sorry, Chris.
Yes, and we would like to read and sign, please.
Okay.
And Chris, that's okay with you, obviously?
Yes.
Okay, and Council, can I please ask for your order on the record?
The plaintiffs will do an E-Tran, please.
Paper.
Paper, okay.
Old man style.
All right.
And Mario, did you want to copy as well?
Are we See chat.
OK.
Are we all set?
Ma'am, Michelle, raise your right hand, please.
My name is Vicki Jesse.
Do you solemnly swear that the testimony that you're about to give today will be the truth, the whole truth, and nothing but the truth, so help you, God?
Yes.
Oh, I can't hear you.
Yes, can you hear me?
Yes, there you go.
Okay.
Thank you.
And can you please state your name and address for the record?
Brittany Paz, and my business address is 4 Research Drive Suite 402, Shelton, Connecticut, 06484.
All right, all set.
Okay.
Thank you, everybody.
Good morning, Ms. Paz.
Good morning.
Before we went on the record, you were explaining to me some additional notes that you brought today.
I see them in a manila folder before you.
Am I correct that the notes in that manila folder are the handwritten notes you were describing yesterday that you reduced to a typed document, which has been marked as exhibit 102.
Right, that's correct.
So it sounded to me like you wanted the type notes.
I said I thought that they were at my house, so I went to go look, and everything that's in this paper clip here should be in that document that you just described.
There are two handwritten notes that, as I said yesterday, I didn't, I haven't typed up notes for the last two weeks in that document.
These are just notes of the interviews I did within the last couple of weeks that I didn't get to type into the notes.
So I wanted to make sure that you had all the notes.
Thank you for bringing those.
So what we'll do is we'll mark the manila folder.
I think we're on 105, is that right?
I heard 104.
Okay.
We pre-marked some additional exhibits, and so this is actually going to be 115, and Madam Court Reporter will get you those exhibits that we pre-marked for today.
I'll just know for everybody's reference that they are the largely the financial records that counsel has emailed me over the last couple of days, which we had not yet had a chance to mark.
So I'll take this.
We'll mark that.
Thank you for bringing those.
Sure.
Other than collecting your handwritten notes, did you do anything after the deposition last night to prepare for today?
No.
You didn't review any additional materials?
No.
Okay.
I wanted to start with exhibit number 10, which is a stipulation that all parties have agreed to.
And I'll hand it to you.
I don't know if you've seen that before.
It's captioned stipulation regarding authentication.
Have you seen that yet?
No.
Okay.
Counsel, can I just ask for everybody's agreement on the record that exhibit 10 is the party's stipulation that we've entered?
I mean, can you scroll down?
I'm sure it is, Chris.
I just wanted to see it actually.
Yep.
Chris, if you represent to me, I'll take that as given.
I'm not going to read each and every word in the document.
Okay.
It's the same document.
Yeah, Chris, I agree that 10 is the stipulation.
I think I yes, and it contains the Schedule A. It looks like the death.
It looks like it.
It might not.
I'm not reading every single word.
Okay.
And, Mario, why don't we do this?
Because I do want it to be clear.
Whenever you have a chance during the break, if you could just review exhibit 10 and then we can confirm on the record.
I'm just asking us to do that because the parties haven't signed it yet, but I do want a clear record that everybody's agreeing to this.
Sure.
Do I have it in a searchable PDF format?
We send it to you via link.
So whenever we distributed the exhibits to people yesterday, that's where Exhibit 10 is located.
I would ask for, to make things a little bit faster, Fatika can send it to me in DocX because there's an easier way for me to compare the text.
Because otherwise I have to go through, you know, if I stipulate, Chris, I'm saying I have thoroughly reviewed the document and I know that every single data is identical.
And I'm not ready to stipulate to that without some kind of care.
No, no, no, absolutely.
Please take your time and review it, okay?
It would be faster for TikTok, she may not be able to.
It would be faster for Tika can send me a docx or a raw version instead of the PDF version, because I have tools with which I can compare text, but not PDF costs.
I can compare Microsoft using a Microsoft program documents.
Fair enough.
Fair enough.
Just hold off.
In any event, Ms. Paz, what we've done with the Jones defendants have stipulated to, and this is mainly with respect to the videos that I want to draw your attention, are that the videos that the Jones defendants have been produced to us, there is a stipulation that they are copies of videos that were broadcast or published on or about the dates listed in chart A. And then chart B are videos that we've produced to the Jones defendants,
and there's a stipulation there that those videos were published or broadcast by free speech systems on or about the dates listed there.
Okay.
And the reason I'm showing it to you is because I'm hoping that it may make more efficient our process of going through these videos.
Okay.
Chris Mann, may I speak to the stipulation for a moment?
Sure.
Attorney Paz or Brittany, in paragraph four, you'll see a language at the end, published or otherwise broadcast.
That language was specifically bargained for to accommodate the fact that from time to time they might put something on live stream and then edit it for republication elsewhere.
That was an issue that came up in your interviews with people.
So this stipulation is basically intended to eliminate the need to prove authentication of these documents as something either broadcast or otherwise published on behalf of InfoAward.
Thank you, Chris.
Okay.
All right, great.
So having reviewed that stipulation, am I correct that Free Speech Systems broadcast of the videos both in chart A and chart B, as a matter of practice, would have been broadcast to all of Free Speech Systems radio affiliates?
I believe so, yes.
Okay.
And also uploaded to Free Speech Systems YouTube channels that would have been active at the time?
Right.
Okay.
And then also shared on the various social media platforms that Free Speech Systems owned at the time that the videos would have been broadcast.
I don't know if all of them were published on social media, but I'm sure at least some of them were, so yes.
Was it Free Speech Systems practice during this period to clip various segments of the Alex Jones show for sharing on social media?
Sure, but I don't know if that was done every single day with every single video or every single clip or whole videos versus clips of videos.
You know, so that's all, that's why I'm qualifying that answer.
That's the only reason.
Okay, fair enough.
Thank you.
I want to take a look at your notes.
I'll hand you a copy of 102.
Council, this is 102.
I brought some hard copies today because I thought it would be more efficient, at least of some of the exhibits.
And I believe you testified yesterday that Exhibit 102 represent your notes of depositions and interviews, depositions you reviewed and interviews you conducted, correct?
Right, and also material, other material that I reviewed, so not just depositions.
So I believe I believe I may have notes in here about documents like bait stamps and things like that.
So, but yes.
Okay.
The reason I asked it like that is because it seemed that your notes of your videos review were contained in the other spreadsheet.
Is that right?
Right, the videos, you're right.
So the video notes are in the spreadsheets, but what I'm saying is there might be and probably are other documents that I reviewed that I put notes in here, bait stamps and such like that, not the videos.
Okay.
And were these notes essentially taken in chronological order of the activities that you conducted?
Right.
Okay.
And along the right-hand side of your notes, there are various comments throughout.
Were those your comments that you entered in the document?
Yes.
All right.
And for what purpose did you enter those comments?
Questions that I had, things I wanted to check up on to find out later on or see if I could find it in another place.
Okay.
All right.
So we'll go through that in a little bit more detail.
The list of people that you interviewed at the top, that list is missing at least a few interviews you conducted, right?
I would say it's missing Mr. Fouget, because, like I said, I didn't update this within the last couple of weeks, so it's definitely missing him.
Otherwise, it looks like it looks like everybody else is on there.
The notes that we marked earlier today, which were the notes that make up the handwritten version of Exhibit 102, are different than the notes that you produced for deposition in Texas, right?
You mean these notes, the ones that you gave me copies of last night?
Right.
We had previously marked the notes that were produced in Texas as an exhibit here.
And I understood from your testimony that the handwritten notes you produced today to us were basically transcribed into Exhibit 102.
Right.
The handwritten notes that you produced in Texas, what were those of?
These are also interviews that I did with people while I was there.
I don't know whether I put them into this version of my typed notes.
Okay.
I'm not sure.
I haven't reviewed this in a while, but these are also notes of interviews.
This is kind of just doodles from the deposition when I was in the deposition.
But most of these are notes that I took contemporaneously with my interviews with people while I was in Texas.
All right.
Does exhibit 102 also contain notes of interviews that you conducted in Texas?
May I look at it?
Yeah.
Like I said, I haven't reviewed it in a while.
When was the last time you reviewed this?
It's been a couple of weeks.
I said I haven't updated this in a while.
See, I do notice that there are interviews in here.
So for example, on page eight, this is my interview with Daria.
That is referenced in these handwritten notes here.
I mean, this isn't marked as a page number, but see, they're almost identical.
This page and this typed page.
Hired to do sound in 10, 2015, sound 10, 2015.
So, yes.
How did you decide which notes to produce in Texas?
I produced this whole thing in Texas.
This whole document was in a binder that I produced along with video notes.
So I produced this in Texas.
Along with those handwritten notes, though.
Right.
Well, so what happened was when I was in Texas was it was two days.
I had these notes printed in a binder.
They took the binder and didn't give it back the second day.
So I had my notepad with me.
So I needed my notes.
So I took out my notepad.
So and then they took that and then they marked the notepad, right?
But the notepad you had didn't contain all of your handwritten notes because those you brought with you this morning.
You brought additional ones with you this morning.
Those were already, like I said, typewritten into these notes.
So I had already typed them into the notes and brought those with me in the binder, which they took.
No, no, I understand.
But did I bring those to the deposition?
No.
Nice.
Right, because I had already typed them.
Okay.
So I brought the typed notes.
But hadn't you already typed those as well?
A lot of these look to be typed, yes.
All right.
But you don't know.
I haven't looked through the entire thing, so.
But like I said, you know, just based on page eight, I could recontinue to look through it.
So that was Daria's deposition that I typed.
Then on page 10, these are my typed notes based on my interview with Alex Jones.
Then.
Actually, while you're on that topic, can you just direct me to any notes in exhibit 102?
These are your type notes relating to your interviews with Mr. Jones.
So it looks like page 10 starting with interview with AJ.
Right.
And then how far down?
Back to the next segment, which was Infowars Nightly News with Rob Dew.
That's a summary of a video that I watched.
Okay, so just so sticking on page 10 for a moment.
Sure.
Where you have the header interview with AJ, the notes relating to that interview go from interview with AJ down to the next header, InfoWars Nightly News Robinson.
I'm sorry, let me rephrase that.
Because that paragraph in between in the very middle, that doesn't look good.
It looks like a video, too.
So it really only is those three paragraphs there from Alex tells people to print and rate it to rated broadcasts and response broadcasts.
Okay.
And in this particular note of an interview, is it fair to say that those notes represent all of the notes that you took with respect to one of your interviews with Mr. Jones?
No, I don't think so, because I had two pretty long conversations with him.
Okay.
So this would then just be like partial notes of one interview?
It might, yeah, it might be.
Like I said, there's some more written notes here.
I don't know if they're all transcribed into here, but if I could.
Yep, please do.
Take your time with the type notes and tell me what else relates to interviews with Mr. Jones.
Here we go.
Here we go.
It doesn't look like I typed any of that, so it might have been just handwritten.
Okay, so let's look through your handwritten notes now.
Sure.
And why don't we begin with the notes that you produced in Texas?
Sure.
which, can I just get a reminder of what exhibit that is?
Exhibit two.
Okay, so this is exhibit two here, separately marked in Texas as 18A, B and C. Take a look at these handwritten notes and then just direct me to any notes that relate to your interviews with Mr. Jones.
Sure.
So this entire first page.
Beginning with perfect place to post disinfo.
Yep.
the entire first page the entire second page And the entire third page.
Okay.
Fourth page is fourth, fifth, and six pages looks to be my interview with Kit Daniels.
Alright.
The seventh page looks like my notes on reviews of some of the production material.
The following page and the page after looks to be my doodles and or notes during the Texas depots.
Okay.
The page after that, it says Bob on it.
So this would have been—this page would have been my interview with Mr. Rowe.
This entire following page, I think we talked about this page yesterday.
We did.
This entire page was me talking to Alex.
Can I just ask you one question about that?
Sure.
Does that include the word at the top, "Pass through" with the arrow?
I don't know why I. Yep.
It's one after that.
One after that.
No.
No, we're kind of like 10 pages deep.
This is page two?
No, before that.
Before that.
look at that Right there.
Okay.
So I don't know if it relates to if it's kind of spillover from the prior page with my discussion with Bob.
I'm not really sure what I was talking about with that.
Okay.
I'm not sure what it's related to, so I don't know.
Okay.
But everything below that is definitely Alex.
Okay.
And what about going on to the next page?
So this was my conversation with Melinda, and it does say Moonshine Tavern on it.
So this was when I interviewed Melinda, I was asking, when I was asking her questions, it's that page and the page after.
Yep.
Then the page after that, this is my interview with Adan.
Okay.
So it's that page, the page after, the page after that.
And the page after that.
Okay.
And the page after that.
So Adan's is one, two, three, four, five total pages.
Okay.
And then Daria is one, two, two pages.
All right.
And then there's a blank page.
This, I believe, was my first conversation.
wait one second I believe this was my conversation with Mr. Zimmerman.
What are the words that begin at the top of that page?
It says marketing.
Okay.
Yep.
Thank you.
Then the following page is my conversation with Nico.
And the following page.
And the following page.
So it would be one, two, three total pages.
Okay.
And then the very last page.
I'm not sure about this page because half of it's blocked out, so it's kind of hard to tell.
And that half that's blocked out, that wasn't your doing, that was part of the copying process in Texas?
No, this was done as a result of Attorney Blott's claim that this portion of the material was privileged.
So this is purposeful.
All right.
All right.
So in terms of the handwritten notes contained in Exhibit 2, there are four pages of notes regarding your conversations with Mr. Jones, right?
That's what it looks like, yes.
And then you have the three paragraphs we saw on Exhibit 102.
Right.
Okay.
And I believe it's your testimony that there wouldn't be any additional notes of conversations with Mr. Jones in the handwritten notes you produced today because all of those were reduced to writing.
Right, I believe all of those I put into this handwritten or typewritten document.
Okay.
At least the paperclipped ones.
There are those two most recent ones from those interviews, but those weren't with Alex.
Those weren't with Mr. Jones.
Okay.
So the two and a half hours you spent with Mr. Jones, you took four pages of handwritten notes and included three paragraphs of typewritten notes in Exhibit 102, yes?
Yes.
Okay.
And I did not note that you dated the notes for Mr. Jones' interviews.
Do you have dates of when you interviewed him?
No, but it, as I said yesterday, it would have been during the week that I was there.
I believe I spoke to him the very first full day I was there.
So that would have been Wednesday.
And I'm not sure which of the other days I sat with him.
I'm not sure.
And the half-hour phone conversation you had with him was also when you were in Texas?
Yes.
Okay.
All right.
I want to.
Do we have the depositions?
The corporate repositions.
I think your testimony yesterday, Ms. Potts, was that you had read each of Free Speech Systems' corporate representative depositions that were given in Texas, correct?
You mean the one from Mr. Dew, Ms. Karpova, and I believe Mr. Zimmerman?
There were two depositions given by Mr. Dew as the corporate representative in Texas, and there was one from Ms. Karpova, one from Mr. Zimmerman, and then obviously you've read your own deposition.
Right.
I don't know that I've read two depositions from Mr. Dew.
I think I've only read one deposition.
So as I said yesterday, there's a drop box of material, and there were depositions, there's a folder labeled depositions on there.
Okay.
That may have been my mistake then.
Perhaps I misunderstood, and he testified both in his personal capacity.
And I think that if you're, I don't think he testified as an FSS representative in the summer of 19.
I may be wrong about that, but I thought he was here individually at that point.
But I may be wrong about that too.
Yep.
I'm just going to check as we sit here.
Probably tell you which of Rob Dew's depositions I read, because I think I have notes on it in here.
Okay, and I can hand you two transcripts.
I'm going to hand the witness two exhibits.
One has been marked as Exhibit 7A, transcript of Mr. Dew's testimony on March 15th, 2019, and then 7E, a transcript of Mr. Dew's testimony on November 26th, 2019.
Right, so I could just tell you just by looking at my notes on page 14, the deposition that I read was the 11-2021 deposition.
Okay.
Well, let me hand you exhibit 7A.
Just take a look at that.
Okay.
You recognize this to be a transcript of a deposition given by Rob Dew on March 15th, 2019?
That's what it appears, yes.
Okay.
And if you turn to page four of the deposition, you see where Mr. Dew is asked, Mr. Dew, you are here as the corporate representative for Free Speech Systems LLC, correct?
And he said correct, yes?
That's what it says, yes.
Okay, and so this is sworn testimony given by Free Speech Systems on March 15th, 2019, correct?
That's what it appears to be, yes.
Okay.
You don't dispute that?
No.
Okay.
And then if you look at exhibit 7E, do you recognize that to be a transcript of deposition testimony given by Rob Dew on November 26, 2019 in the Heslin matter?
That's what it appears to be, yes.
Okay.
And if you look at page five of that deposition, Mr. Dew confirms that he's there as a corporate representative for Free Speech Systems.
Do you see that?
Yes, I see that.
Okay, and so this is the testimony of the exhibit 7E is the testimony of free speech systems given in the Hesland matter on November 26, 2019, correct?
That's what it appears to be, yes.
Okay, and free speech systems doesn't just fit that.
No.
Yeah.
And is it your testimony that you have not previously reviewed those depositions?
I think what I said was I only read one deposition and according to my notes it was the 2021 deposition.
Do you know which date that was given?
According to my notes, it says November 2021.
Okay, all right.
So that's the only deposition given by Rob D that you read?
That's right, based on my recollection and refreshing my recollection with my notes.
That's correct.
Okay.
I'm going to hand you 7D.
Do you recognize that to be a transcript of deposition testimony given by Michael Zimmerman on behalf of Free Speech Systems on November 26th, 2019?
It is a deposition by Mr. Zimmerman.
Is this a corporate wrap depot?
Yeah, take a look at page six.
Okay.
Do you see where Mr. Zimmerman acknowledges that he's there on behalf of the company?
Yes, I see that on page six.
And did you review this deposition?
Yes.
Prior to this?
Okay.
And so am I correct then that this is the testimony of free speech systems given in the Heslin matter on November 26, 2019 by Michael Zimmerman?
Yes.
And I'm now going to show you exhibit 7G.
Do you recognize exhibit 7G to be the transcript of sworn testimony given by Free Speech Systems on December 3rd, 2021 in the Consolidated Matters in Texas, Hesland, Posner, and Lewis?
Yes.
Okay, and you've reviewed this prior to today.
Yes, this is Daria's deposition.
Yes, I read this.
Okay.
Ms. Carpova testifying as Free Speech Systems Corporate Representative, correct?
Right.
Okay.
Thank you.
And then I'm going to hand you exhibit 7I thank you.
You recognize that to be a transcript of your testimony that you gave on behalf of Free Speech Systems in Texas on February 14th, 2022.
so That's that's right.
Okay, and there you were testifying under oath as free speech systems, correct?
Right, as its corporate representative.
That's right.
Thank you.
And you reviewed the deposition that you gave following the deposition and submitted an errata sheet, correct?
I reviewed it.
I don't know if the errata sheet's been submitted, but I reviewed it.
But you prepared an errata sheet regardless of whether it's been submitted or not, correct?
I believe so.
I spoke to Attorney Blott about it, so yes.
I also saw it mentioned in your notes.
Yes, right.
All right.
Have you read any of the plaintiff's depositions that were given in this case?
I don't believe I did.
Okay.
Why didn't you?
Time.
I just didn't have time.
I don't know if it was on the material I had access to either.
As I said earlier, I didn't have access to a lot of the Connecticut material on my Dropbox, so that might have been an issue as well.
Did you ask for access to the plaintiff's depositions?
I asked for access to the Connecticut material in general.
Okay.
Specifically, I didn't ask for depositions.
I just asked for access to the Connecticut material.
Okay.
And by that, you meant to include any depositions that were given here.
That was what it meant to me.
Okay.
But you didn't receive any?
No, I didn't.
All right.
And then when you asked for the Connecticut material, you also intended for that to encompass all materials that have been produced by free speech systems to the plaintiffs in Connecticut, correct?
Right, and vice versa.
And any materials that the plaintiffs produced.
That's right.
Okay.
But you haven't had access to any materials that the plaintiffs produced, correct?
No, I didn't, like I said yesterday, I don't have access to any of the Connecticut material.
All right.
When did you first ask for the Connecticut material?
I don't know an exact date, but when I was starting to prepare for this deposition after I left Texas, so sometime thereafter.
When you say after you left Texas, do you mean after that you gave your deposition in Texas?
Right.
Okay.
So did that all happen in one week?
You went down there to prepare and then you were to post at the end of the week?
Well, I had already started to prepare, but yes, I had gone down there to do my interviews to observe the location and to give the depositions.
So that was a week.
Okay.
All right.
And you sat for deposition on one day?
Two days.
Two days.
All right.
And so the interviews that you conducted and the site visit that you conducted were over the course of the first five days?
No, we worked on the weekends as well.
So I was there Tuesday through Sunday.
Tuesday I came in.
So Wednesday, Thursday, Friday, Saturday, and Sunday we worked.
And then Monday and Tuesday we had depositions.
Okay, so five days.
Right.
Okay.
Have you signed the protective order in this case?
I haven't signed anything.
Okay.
Nobody gave me anything to sign.
You weren't given a copy of the protective order.
The Texas materials that you reviewed, did those materials contain any text messages?
I don't remember recall seeing any text messages, no.
Okay.
Did they include any communications sent via free speech systems internal messaging systems?
I don't know that there are any.
Well, this isn't trial, Chris.
I'll withdraw the objection.
I apologize.
I don't recall seeing anything like that.
I don't recall seeing anything like that.
I saw a lot of emails, but I didn't see anything that looked like internal messaging.
You were asked a little bit about this in your deposition in Texas, where you were asked questions about free speech systems use of Slack, for example.
Right.
Right.
And you didn't review any communications sent via Slack, correct?
I didn't have anything like that in the material.
Okay.
And the same is true of any communications sent via Rocket Chat, correct?
Right.
Okay.
The only communications that you had in the material that were given to you were essentially emails sent over InfoWars email system.
Right.
Or, you know, information or emails that were sent to them from outside, but they were emails, that's right.
Okay, thank you.
Yep.
You testified yesterday that when you were reviewing the Texas materials in preparation, I believe both for that deposition, but also for this deposition, the way you searched them was to use search terms in the Dropbox application.
Right.
Okay.
And the search terms that you gave me yesterday that you used were Sandy Hook and How big.
You may have given a couple of others.
What were the search terms That you used?
I believe I used false flag.
I typed in the names of the plaintiffs.
The plaintiffs in Connecticut.
Well, so in preparation, is the question directly related to my preparation for Texas?
No, no, it's just all wholesale?
Whole review.
Okay.
So no, all the plaintiffs.
I did all the plaintiffs.
And when I was preparing for those depositions, I had done those plaintiffs.
And then in preparation for this deposition, I did these plaintiffs.
OK.
I might have done Pachenik's name.
Do you know whether you did that?
I'm not sure.
I might have I might have done Crisis Actors too, but that yielded a lot of unrelated emails.
Do you know whether you did Crisis Actors?
I think I did, and the reason is because I, like I said, in my notes, I had yielded a lot of emails just from the general public about advertisements for crisis actors from the general public.
So I definitely did that, and that might have been it.
And did you review when you searched for those search terms?
Did you then review every document that was returned as responsive to the search?
I might not have reviewed every document related to crisis actors because, like I said, there were a lot of irrelevant emails, but I think I reviewed everything related to the other search terms.
Okay.
And how many documents did that result in you reviewing?
Thousands of documents.
I've reviewed thousands of documents.
I can't tell you an exact number.
Okay.
Did you attempt to track in any way the documents that you reviewed?
So I think I testified yesterday.
I did attempt to put into a spreadsheet what I had reviewed, which I produced to you.
You produced that yesterday, right?
I think it was emailed a couple of days ago.
So I did try to go back and type out the documents that I reviewed.
How did you go about doing that?
I went through some of my notes.
I saw some of the notes that I had reference specific documents.
I went back into the search terms, you know, type in the search terms and typed in those, you know, if whatever document was listed, then I would type that on the spreadsheet.
So I don't think that's an exhaustive list of all the documents I reviewed, but that's how I tried to do it.
Okay.
Okay.
I'm going to hand you exhibit four.
Is this the spreadsheet that you were just referring to that you created to try and list the documents that you had reviewed?
Yes.
All right.
And as I understand it, you compiled this through a combination of documents that you had identified in your notes, and then you reproduced the searches you had previously run and listed the documents that came back responsive to those searches.
Is that right?
Right.
That's how I tried to do this, just because, like I said yesterday, you'd requested it in your Schedule B. So I wanted to try to comply with that.
No, thank you.
I appreciate it.
But you say, and there's an asterisk at the bottom, not intended to be an exhaustive list.
Right, because, I mean, like I said earlier, I've reviewed a lot of documents.
I didn't produce this in connection with the prior depositions.
And I've reviewed a lot of documents.
So I'm not, I don't think that this is everything that I've reviewed, but.
Does this include at least every document that came back when you ran a search using the search terms that you've identified for me?
Oh, I don't know.
There were a lot of documents that came back related to Sandy Hook.
So I don't know if this was all of those Documents.
I did list most, if not all, of the documents that came back related to the principal at Sandy Hook because there weren't a lot.
I think most, if not all, of the search terms for Ms. Soto are on there.
So it might not be all of the search terms.
It's probably not all of the search terms for Sandy Hook because there were way more than this.
Okay, okay.
So fair enough.
So when you ran, when you tried to reproduce the records that you generated as a result of your search, you included some of those in these notes, but not others.
I just don't know if, I just don't know if they're all of them, and I don't think that there are.
Because there were a lot, like I said.
So some of them just didn't make it onto the spreadsheet, right?
Okay.
Correct?
Right, right.
I'm sorry, I did answer.
I don't think you heard me.
All right.
Okay.
Just a shout out to make sure Mario stays awake.
I see him looking mighty relaxed there.
I'm going to ask you to just grab exhibit 10 again.
That's the stipulation.
This one.
Sure.
And you can clear that other stuff out if you want to.
That way.
Just give me a second here.
Okay.
So if you look at the on chart A, do you see a video listed there January 27, 2013, why people think Sandy Hook is a hoax?
Yep.
Okay.
And this is the video that you and I spent some time discussing yesterday.
Right, I think the issue was we weren't sure if we were talking about the same video.
Right, right.
Yeah.
You, you, according to your notes, you had a note that Mr. Dew may have posted this video.
But so what I want to ask you is, I want you to assume with me that this video contains statements by Mr. Jones concerning Bob Jaygo, Bob Jayco's use of a blue screen in his reporting on the Gulf War.
You familiar with that, those statements that Mr. Jones has made on air?
Yes, I think he's made that claim on a couple of occasions.
They're old.
It was like an old video broadcast off CNN.
Yes, I'm familiar with it.
Yes.
Okay.
And the factual claim that Mr. Jones made was that these particular CNN reporters were claiming to be filming from Saudi Arabia, but were in fact filming from Atlanta, correct?
I don't know if it was from Atlanta, but I think that his claim was that they were claiming to be in a war zone and they were using a blue screen to make it seem that they were in a war zone when they weren't in a war zone.
When they were not.
Right.
Okay.
And did you do anything to inquire as to the basis of Mr. Jones's claim to that effect?
I think I talked to Mr. Jones about this and his claim is that he had seen it, that CNN had subsequently admitted to That, in the sense that it was admitted that they had not, in fact, been in that war zone.
Okay.
And when they're saying they, and I understand that you may not be completely familiar with the circumstances of this video, you understood him to be referring to Bob Jayco and one of his colleagues, CNN.
I think, right, I think that's what he meant: that CNN had admitted it.
And did you do anything to, as Free Speech Systems representative, to confirm whether that was in fact the case, that CNN had admitted that the CNN footage aired by Mr. Jones was blue screen footage shot in Atlanta?
No.
Okay.
Is Free Speech Systems testifying today that Mr. Jones' basis for that statement was a subsequent admission by CNN that those reporters had filmed in the United States while trying to appear as if they were filming in a war zone?
I don't know if it was filmed or the claim is that he was filming in the United States, just said it was not in a war zone.
But I think Mr. Jones, I've seen it in other videos, not maybe not necessarily that video, but he's referenced that particular video on a number of occasions.
And he has said on a number of occasions in those videos, they've admitted it.
I know what he said in his videos.
I really want to just focus, though, on what he said to you.
Well, he said the same thing to me, they admitted it.
Okay.
And you didn't do anything to try and confirm it.
No, I didn't verify that.
Okay.
Is it CNN's testimony?
I'm sorry.
Is it Free Speech Systems testimony that that is in fact the basis for Mr. Jones' statement here that CNN subsequently admitted it?
Right.
Okay.
And that's Free Speech Systems testimony because that's what Mr. Jones told you.
Right.
Okay.
I want you to assume with me as well that in this particular video on January 27, 2013, Mr. Jones made the factual claim that multiple people were detained who were in Camo.
Okay.
You mean at Sandy Hook?
Correct.
Okay.
I'm talking about Sandy Hook now.
Okay.
The factual claim Mr. Jones made that multiple people were detained by police who were wearing Camo.
Did you ask Mr. Jones about that claim?
So, yes, so I did talk about that claim specifically.
He's also made that claim in a number of other videos.
The specific claim being multiple people were detained in camouflage at Sandy Hook, right?
So like I said, I don't know if it's multiple people, but what he's referencing, and this is a problem that we've had over the course of the videos, and I flushed this out in my prior testimony as well, is that, so Alex kind of talks very off the cuff.
There is no script.
He's not reading off of a teleprompter.
He's going based off of memory.
So when he's receiving the information and it's coming back out, it may not necessarily be the exact same thing that he heard.
So, and was he going back to verify whether or not this exact thing that he heard is what he's actually saying?
The answer to that is no.
So going back to your specific question about that claim, what he's referencing are the reports from around that day or maybe the day after of helicopter footage of people running around in the back woods behind the school and that there was somebody taken out of the woods in handcuffs and that person was wearing camouflage pants.
So and there was video of a witness who had seen such a person taken out of the woods.
So that specifically is what he's referencing.
So but going back to your question about multiple people, that was an issue that he and I discussed about when he's receiving the information, when it's coming back out, it may not be exactly the same.
Okay, well, so free speech systems then, free speech systems testimony is that the basis for Mr. Jones's statement that multiple people were detained in Camo is twofold.
One, one witness saying that one person was wearing camouflaged pants, and then footage of multiple people in the woods who were not described as wearing any camouflage, correct?
I don't know if multiple people were described as being in the woods.
So if I recall, there was discussion on a couple of these videos about helicopter footage, people running around in the woods and surrounding at least one person in the woods.
So I don't think it's multiple people that were taken out of the woods.
But yes, there was an interview on air with one person who said I saw a person being taken out of the woods in camouflage and handcuffs, and that was the basis of that statement.
Okay, one person, correct?
One person who said that in an interview?
In other words, Free Speech Systems is only aware of a single report that one person had been detained who was wearing Camo, not multiple people, correct?
Right, I believe so.
Okay, and so Alex Jones' statement that multiple people had been detained in Camo is in fact inaccurate, correct?
I think that's a misstatement of, as I said, of that particular information.
It's a misstatement of fact, correct?
I think it's a misstatement of fact, yes.
Okay.
And he also said, and I'll ask you to accept my representation in the January 27, 2013 video, that it includes, that I'm sorry, that people connected to the Sandy Yuck shooting include people who have been coached, people who have been given cue cards, people who are behaving like actors.
Who are the people that he's describing there?
Who are the people who have been coached?
I am not sure.
I can render you an inference, but I don't know if that's what you want.
No, yeah, I don't want that, at least not yet.
Did you ask Mr. Jones who were the people who he was claiming had been coached?
I don't, no, I didn't ask specifically that question, but like I said, if I wanted to make an inference, I think he's talking specifically about the Robbie Parker interview.
Okay.
So he's talking about Robbie Parker?
That's what I think he's talking about.
Okay.
But he says people.
So who else in addition to Mr. Parker?
I don't know.
As far as the coached question, because you broke that down, there were a couple of claims in there.
Right.
So although you didn't ask Mr. Jones who he was claiming had been coached, are you prepared to testify as Free Speech Systems that at least one of the people he was referring to was Mr. Parker?
Yes, I would be comfortable saying that.
All right.
But Free Speech Systems cannot testify as to who else he may have been including in that category.
Right.
And with respect to people who have been given cue cards, is your testimony the same that he is certainly referring to Mr. Parker there, but you can't testify as to who else he may have been referring to.
That's fair, yes.
And you didn't ask him that particular question.
No.
And with respect to people who are behaving like actors, is it Free Speech Systems testimony that he's referring to Robbie Parker?
Yes.
Is he referring to anybody else that you can testify to?
Like I said, I haven't asked, I didn't ask him this specific question, but if I'm making an inference, I believe there was also some discussion in the material, perhaps in the videos, about people bringing coffee to one another.
It may have been Scarlett Lewis.
I'm not 100% sure, but there was some discussion about parents bringing coffee to the scene.
He may have been referencing that as well.
That's all I could recall right now.
Okay.
There may be others, but.
It sounds like, and it sounds like you're not sure whether he would have even seen any footage of people delivering coffee to anybody else as of the time he made this statement.
I don't know, because it was pretty shortly thereafter.
It was only a month later.
Okay.
At least in terms of free speech systems sworn testimony here, the only person free speech systems can testify, Mr. Jones was referring to, who he described as behaving like actors, was Mr. Parker.
There may be others, but as I said, I'm not sure.
They're very well, maybe.
Okay, but you just don't know.
Right.
Okay, fair enough.
All right.
I did want to go back to the April 1st, 2013 video: Crisis Actors Used at Sandy Hook special report.
This is the video we were discussing yesterday involving Mr. Pachenek.
What was the date?
4-1?
Yeah.
Okay.
All right.
Let me just pull up my.
Okay.
All right.
And one of the things that you said yesterday was that Mr. Pachenek's statement that children can die at Sandy Hook was his opinion.
Do you recall that testimony?
Yes.
Okay.
Now, whether children died at Sandy Hook is a matter of fact, correct?
You'd agree with that?
I think so, but I think what he does there is tell the reasons why he thinks that.
Right, so I'm not yet asking anything about why Mr. Pachenek said what he said.
I'm just trying to focus on your testimony that his claim that 20 children died was an opinion.
And I just want to flesh out that idea with you a little bit.
When I just asked you whether or not the deaths of 20 children at Sandy Hook was a matter of fact, you said, I think so.
Were you speaking for free speech systems there?
That's right.
So yesterday you asked me, does free speech accept that 26 children and educators died?
And my answer was yes.
And that's not a free speech systems opinion, correct?
Well, it's the position that we're taking that it is in fact what happened.
So, but I'm not going to speak to Dr. Pachenek.
You know what I'm saying?
I'm not, I don't represent him.
Correct.
But from free speech systems perspective, the fact of 20 children's deaths at Sandy Hook is a provable event, correct?
You mean, is it provable, true or false, whether 26 people are dead?
Yeah.
I mean, you're aware, that's just true, right?
Well, yeah, it's whether someone died or not is a fact that is capable of being proven true or false.
Right.
And in fact, free speech systems, as you're aware, has admitted in this case that 26 people were murdered at Sandy Hook, right?
I'm aware that that admission has been made yesterday.
Right.
And you swore to that yesterday.
Right.
Okay.
And so something like the deaths of 20 children and somebody saying that they didn't die or that they did die is an assertion of fact, correct?
Sure.
Okay.
And so, for example, if I said that Abraham Lincoln is alive and well and living in Bridgeport, Connecticut, that's an assertion of fact, correct?
It's something that is capable of being proven true or false.
Right, exactly.
It's not my opinion.
That's just either that's true or that's not true, right?
Right, but like I said, you know, I can't talk for Dr. Pachenek, but also at this time that this video was put forward, this was prior to the release of the official report.
Right.
It was at an early point in that investigation.
So I think that at that point in time, it's really not fair to say, okay, well, this is a fact that's capable of being proven true or false because it was still an active investigation at that time.
Well, but the event had occurred, Correct?
Just let me finish.
It was a fact as of that moment that 26 people had been murdered, correct?
As per the autopsy reports?
No.
As per reality in the world, as of January, I'm sorry, April 1st, 2013, there were, in fact, 26 people who had been murdered in December of the previous year at Sandy Hook School, correct?
Well, I'm going to object to the form as argumentative.
I mean, how we construct a socially concept, socially, how we construct a consensus about the basis of truth is a profound problem here, so I think this is argumentative in tone.
You can answer it if you understand.
Yeah.
Yeah, please, please tell me whether Free Speech Systems acknowledges that as of April 1st, 2013, 26 people had been murdered at Sandy Hook School in December of the preceding year.
No, no.
Please, can you answer that question?
As of April 1st?
Yeah, as of April 1st, 2013, was it in fact true that on December 14th, 2012, the preceding year, 26 people had been murdered at Sandy Hook?
So I think that, and the answer I'm going to give you is that the coverage that Alex was doing and free speech was doing at that time was to engage people in this conversation.
There were a great deal of people, at least at this time period, who were still debating this issue.
It was something that was actively discussed.
He was getting a lot of commentary on it, emails about it, people who wanted to debate this issue.
So, I mean, I'm not going to say that at this point in time it was something that everyone all over the world and beyond could say that this never happened when there are legitimate debates or what Alex considered to be legitimate debates about these issues, if that answers your question.
Well, it doesn't.
I think what you've done is you've answered a different question.
Let me try it a little bit differently.
Okay.
Free Speech Systems has acknowledged that on December 14th, 2012, 26 people were murdered at Sandy Hook School, right?
Right.
Okay.
They were still dead as of April 1st, 2013, right?
I mean, if they died on...
Yes, sir.
They have been dead for 10 years, so yes.
Right, okay.
That was true on December 14th, 2012, and it's been true every day up until today, correct?
Right, but you can answer the form.
Right?
I think people have the right to debate these issues if they think that there are legitimate issues to debate.
And as of this particular date, Dr. Paganik thought that this was an issue that could be debated, and that was his, and he stated the reasons why he thought what he did at that time.
Right.
Thank you.
If I said to you that, well, we'll come back to that.
Okay.
In the video that we've been discussing, excuse me.
Mr. Jones refers to an interview that Anderson Cooper conducted as having been conducted clearly in front of blue screen.
You're familiar with Mr. Jones's factual claim to that effect.
Is this the claim with Veronique De La Rosa?
Yes, I'm familiar with that.
And he made that claim throughout his discussions on Sandy Hook, correct?
Right, it's in various videos.
It's not just that one.
And Mr. Jones states in different places that it's clearly blue screen that Mr. Cooper is standing in front of, correct?
That was the statement, yes.
By which he meant that Anderson Cooper was presented by CNN as conducting that interview in the town square in Newtown, but in fact was not there.
I think that was the intention of the comment, yes.
And you asked Mr. Jones about that.
I did.
Okay.
And that's what he conveyed to you, that what he was claiming at the time was that Anderson Cooper was not, in fact, at the Newtown public square interviewing Miss De la Rosa, correct?
He still maintains that, yes.
Okay.
I did also ask him to explain to me the difference between a blue screen and a green screen.
What did he say?
He explained it to me, but I'm not really sure.
I can't make the distinction.
I'm not in media, so.
Well, which one was it for him, blue or green?
I think he thought it was a green screen.
Okay.
But I can't tell you why, because, like I said, I don't remember.
I'm sorry.
That's okay.
And even if you did remember, do you think you'd have trouble describing kind of the technical differences?
I would be able.
I would probably butcher it.
Okay.
But Mr. Jones was able to explain it to you.
He did, yes.
I did ask him about it.
And I'm sorry, my memory is going.
He said it was blue or green to you?
Green, I believe it was green.
Green screen, okay.
Although you know that he said repeatedly that it was clearly blue screen on the air, right?
I think he's in various videos, because like I said, he's repeated that claim amongst various videos.
Some of the videos it says green screen, some it says blue.
Sometimes he corrects himself and changes.
I'm not really sure which one it is.
That's why I asked him which one, but when I asked him, he said it was green.
And did he also ask him whether he also that blue screen or green screen was also the backdrop for Miss De La Rosa?
Yes.
And so his comment to me was that he wasn't claiming anything regarding Miss De La Rosa.
It was just for Anderson Cooper that he didn't think Anderson Cooper was where he said he was citing to the nose issue, the disappearing nose, but also that Anderson Cooper is at CNN and CNN is known for having done this in the past, so I suspect that this is what was happening again.
And by that he was their instance of having done in the past was the Bob Jayco Saudi Arabia footage we were discussing earlier, right?
Right, right, right.
Okay.
And so according to Mr. Jones, so according to Free Speech Systems testimony, I just want to make sure I understand it.
Free speech systems testimony is that Mr. Jones claimed that Anderson Cooper was in front of a green screen.
He told you green screen.
He told me green screen, right?
Was in front of a green screen, although he may have said blue at different times.
But not that Miss De La Rosa was in front of any sort of screen, correct?
Right.
When I talked to him, his claims clearly were regarding Anderson Cooper.
Okay.
Does he believe that that interview was conducted at all?
Yes.
I don't think he's disputing that the interview happened.
I think he's just disputing whether Anderson Cooper was where he said he was.
And where was Miss De La Rosa, according to him?
I don't think he disputes that she was where she claimed to be, which was in Newtown or in front of, I can't remember which building they were in front of.
Okay, all right.
I don't think he disputes that.
I think he's just disputing where he was.
Okay.
And so his claim is that Ms. De La Rosa was interviewed remotely by Mr. Anderson, who was in some other location while she was in the town square.
Right.
Okay.
And that's what he told you.
right.
And you testified a little bit about this in Texas.
The origin of that claim, as I understand it, is a video that Mr. Dew pulled from the internet.
Is that right?
I'm sorry.
You mean the video of the interview?
Right.
The video that Mr. Jones watched in order to form the basis for his conclusion That Anderson Cooper was in front of a screen was a video that Mr. Dew had pulled from the internet, correct?
Yes, I think so, if I recall correctly.
All right.
Right.
Did you ask Mr. Du about that?
I don't remember.
Okay.
But Free Speech Systems testimony today is that, in fact, Mr. Anderson Cooper did conduct that interview using a blue or a green screen behind him, correct?
No, my testimony is that's Mr. Jones' opinion as to what he observed.
Okay, so free speech systems can't testify as to whether that is a fact or not.
Right.
I haven't done any independent research on it.
Okay.
Okay.
Why didn't you?
Because it's an opinion.
He looked at it.
He said, in my experience and what I've seen in my experience, this is what I'm observing and this is what I think based on what I'm observing.
Okay, so when Mr. Jones said that's clearly blue screen.
Right.
Free speech systems position is that he wasn't making an assertion of fact.
No, it's his opinion based on what he's seeing on the screen.
Okay.
And did he describe for you why he thought that?
Yes, I think I already testified to this, the nose disappearing and also the fact that they have done it in the past.
So those two things formed the basis for his opinion.
Did you present him with the evidence that the plaintiffs in Texas had collected from a former FBI agent who concluded that the distortion Mr. Jones was seeing was the result of video compression?
No, I haven't, I didn't talk to him about that.
But I think I saw it in the material.
But you didn't do anything as Free Speech Systems to investigate whether that is in fact the case?
No.
Okay.
I want to ask you about this claim that Mr. Jones made repeatedly that in this video and in other videos that former New York Mayor Michael Bloomberg had sent an email in advance of the Sandy Hook shooting to, I guess, others involved in the gun safety movement to get ready.
And Mr. Jones's claim that that was evidence that the Sandy Hook shooting was staged.
You're familiar with the claim, correct?
And did I describe the claim accurately?
Yes.
All right.
Did you ask Mr. Jones about that?
Yes.
And he told you that he had seen that email, right?
So based on my...
Did Mr. Jones tell you that he had seen an email from Mike Bloomberg to the effect that I just described?
I believe what he said was he saw an article that described the email, and InfoWars did report on such a thing.
Okay.
So Mr. Jones told you that he saw an article.
I believe that's what he said to me.
I'm not sure if he saw the actual email, but there was an article.
Well, what did he say about that?
Did he see the email or not?
I'm not sure if he saw the actual email, but he saw reporting on the email.
Did you ask him whether he had seen the email?
I don't remember if I asked him if he saw the actual email.
I know we talked about the article that he saw.
Did he show you the article?
I've seen the article.
It's in the material.
It's in the material that you saw in Texas?
Yes.
Who published the article?
So the article was actually published by InfoWars, citing to another article as is common amongst in InfoWars.
And so, but like the other claim, this is another claim where Alex has taken in information and when it comes out, it's not exactly the same.
So the article was in connection with the Aurora, Colorado shooting.
And so Michael Bloomberg is a part of this loosely connected affiliation of governors or mayors rather who are anti-gun or pro-gun control.
And so in the wake of the Aurora, Colorado shooting, Michael Bloomberg sends out this email basically saying, like, you know, this happened.
It's inevitable.
It's going to happen again.
For the next one, Let's be prepared for our messaging, essentially, but it was not the day before or a few days before.
When was the Aurora, Colorado shooting?
I believe it was like in August before.
August 2012?
Right, before.
So it was months before.
Okay.
And Mr. Jones claimed that the Aurora shooting was staged as well, correct?
Oh, I don't know.
You don't know that he claimed the Aurora shooting was staged?
I don't know.
Okay.
Are you saying Free Speech Systems doesn't know?
I don't know.
I didn't review any material regarding the Aurora, Colorado shooting, so I can't say.
Okay.
Well, I just want to.
Okay.
That wasn't within my purview.
All right.
So going back to this article, as I understand your testimony, Free Speech Systems published an article in which it described an article that had been published somewhere else, correct?
All right.
And when did the article that Free Speech Systems publish come out?
I don't know the date.
It probably would have been close to the Aurora, Colorado shooting.
All right.
And that article cited another article that described an email Mr. Bloomberg had sent soon after the Aurora shooting.
Right.
Okay.
And Mr. Jones, over the course of his coverage of Sandy Hook, am I correct, repeatedly misrepresented the fact as to when that email had been sent, correct?
Right.
It wasn't the day before or a few.
I think sometimes he said the day before, sometimes he said a few days before.
So it was not a few days before.
And there's no question that Mr. Jones was citing that particular email as evidence for his claim that Sandy Hook had been staged, correct?
Right.
So his interpretation of that email was that they knew about it beforehand.
That Mike Bloomberg knew about it, and in Mr. Jones' words, jumped the gun.
Right.
Right?
Because what he was really saying was that this email was drafted before Sandy Hook and was planned to be sent out after the shooting, but it had been sent early by mistake, correct?
That's what he means when he said jump the gun.
My interpretation of it was that they knew about it beforehand and let's get our messaging together because this is going to happen.
So I don't know if it necessarily means what you're saying, so I'm not sure.
I don't know.
Okay, all right.
In other words, and sitting here today, Free Speech Systems is not making any claim that the email sent by Mr. Bloomberg was in any way evidence that he was aware the Sandy Hook shooting was going to happen, correct?
I don't, no, I don't think Michael Bloomberg was aware of it.
No.
Free Speech Systems doesn't think that.
No.
Free Speech Systems doesn't think Michael Bloomberg was involved in staging the Sandy Hook shooting, correct?
I don't have any information to suggest that he was.
Okay.
Nor did Mr. Jones, right?
Like I said, I think the purpose of him citing that email was regarding the messaging as far as get my message across regarding gun control.
But you're right when he says that he misrepresented the timeframe, and I think the timeframe is important because of the claim that he did, if he did it the day before, it makes it more likely that it was a false flag operation, which is what the claim was.
Thank you.
If you look at the video listed there, April 16th, 2013, shadow government strikes again at Boston Marathon.
Do you have that on your list?
I'm sorry, what was the date?
This is April 16th, 2013.
That may be on chart B. I'm referring to existing.
Yeah, I just want to make sure I read it or I watched it.
So April 2013.
What was the title?
Shadow Government Strikes Again at Boston Marathon.
You said it's on Chart B?
I might not have reviewed it because, like I said, I don't have reviewed it.
Okay.
So I don't think I reviewed it.
All right.
It's not on my list.
Do you recall Ms. Karpova answering questions about this in her deposition?
This may have been one of the videos that she was shown on a break.
I'm not sure if it was this particular video.
But sure.
Okay.
Leave that there.
Let me ask you about Wolfgang Halbig, all right?
Mm-hmm.
You did not speak with Mr. Halbig in preparation for your work as Free Speech Systems corporate representative, correct?
Right.
Okay.
Why did you not?
He's not an employee.
He's never been an employee.
He was a guest on the show.
His opinions are his own.
I represent the company.
I didn't think it was necessary.
Okay.
In our notice of deposition, we asked the company to produce a representative who could speak about the different sources of information that Free Speech Systems relied on in its publications regarding Sandy Hook.
You agree with me that Mr. Halbig was one of the principal sources that Free Speech Systems relied on, correct?
Yes.
And even though he was not employed by Free Speech Systems, you interviewed plenty of other people who are not employed by Free Speech Systems, correct?
No, I interviewed people who either are currently or have been employees or contractors of Free Speech Systems.
But not current employees.
You represented people who are not presently employed.
I'm sorry.
You interviewed people who are not presently employed by Free Speech Systems.
Sure, but they were employed at the relevant time periods of this lawsuit, so I thought it would be relevant to talk to them.
But if Free Speech Systems was going to be prepared to talk about the sources that it relied upon in its statements about Sandy Hook, wouldn't it be important to have a conversation with one of the principal sources?
Not necessarily.
I think I have all the information that I needed based on the videos that I watched.
Okay.
Did you ask to speak with Mr. Halbig?
Ask him?
You mean ask Mr. Halbig?
Did you ask anybody to speak with Mr. Halbig?
No, I wouldn't even know who to ask.
Okay, did anybody tell you not to speak to Mr. Halbig?
No.
Okay.
So speaking with Mr. Halbig was never even a thought that occurred to you?
No.
Okay.
Chris, we're getting objection.
We're getting some double negatives.
I know you're going to want to use that potentially for different purposes, so I object to the form.
Okay.
There's a double negative.
Thank you.
I'll ask again.
Did it ever occur to you to speak to Mr. Halbig in connection with your engagement as Free Speech Systems corporate representative?
You mean did it occur to me as in did I think about it?
Yeah.
I didn't think I needed to.
Okay, so you thought about it and concluded that it wasn't necessary.
Right.
Did you discuss that thought process with anybody?
and Did you ask anybody whether it was a possibility that if you wanted to talk to Mr. Halbig, You could.
No.
I don't even know if anybody has his contact information.
Nor did you ask?
Nope.
Okay.
Am I correct that prior to February of 2014, Free Speech Systems had no awareness of who Mr. Halbig was?
That's fair.
Okay.
Beginning in the late winter, early spring of 2014, am I correct, that Alex Jones repeatedly invited Mr. Halbig on to his show?
Yes, I think he did.
That wasn't the first interaction with free speech, though.
Right.
It happened before.
The first time Mr. Halbig appeared on any free speech systems programming was with David Knight in February of 2014, right?
Programming, yes, but I believe Adan Salazar's article came out before that.
You're talking about the article Mr. Salazar wrote detailing an interview that Mr. Halbig gave to the American Free Press, correct?
That's correct.
I think that's how he came into the purview of others at Free Speech, was that particular article.
Nobody had heard about him before that.
Right.
Okay.
And Mr. Knight has Mr. Halbig on in February of 2014?
14, right?
So he had seen the article, saw the interview.
Well, and then.
Did you speak with Mr. Knight?
I spoke to Adan.
Okay, you didn't speak with David Knight?
I did not speak to David.
So you don't know what David Knight saw of Mr. Halbig's or what Mr. Let me withdraw that.
You have no idea whether David Knight did any vetting of Mr. Halbig, correct?
I don't know if David did any vetting, but in my conversation with Adan, Adan's position was this article is how this came into David Knight's purview.
Adan had done some basic background information.
I believe it's in my notes of my conversation with him.
Usually what they only do is they ask for like a CV from a person.
They don't do very much else aside from just verifying this person is who they say they are.
So basically.
I'm going to get into that process.
Sure.
I will get into that process.
I just want to focus for a moment just on David Knight.
Yeah, no, I don't think David Knight did any individual vetting of him because I think Adan had already done some basic information when he wrote the article.
Okay.
So David didn't do anything else.
So let's just, let's just, for David Knight, Free Speech Systems testimony is that it is not aware of any vetting that David Knight did with regard to Wolfgang Halbig.
Right.
Thank you.
Now, you read Mr. Salazar's deposition, correct?
Right, and I interviewed him.
So, um...
And Mr. Salazar, when Mr. Salazar, how did Mr. Salazar learn about the American Free Press interview?
Did he tell you that?
May I check my notes?
Yes.
'cause I think it's in here.
So in my notes, it doesn't say how he found that article, but it just discusses that he had seen that article, The American Free Press, with the radio with the interview embedded Posted on the internet, so I don't know how he found it or how it came to his attention, but then he subsequently wrote an article based on that interview, and he transcribed the interview.
Right.
Just give me a moment here.
I'm sorry.
Okay.
What did Mr. Salazar tell you he did to, if anything, to look into Mr. Halbig's background after reading the article describing his interview in the American Free Press?
So, according to my notes.
Can you tell me where you're looking at your notes?
If you don't mind, oh, sure.
I mean, obviously, they're not page, they're not page.
No, I think I remember where it's on the second page of my notes from my interview with him.
Got it.
And it's at the top of the page.
This is the article.
So the note says 218-14, so that's the date of his article.
Yes.
Mr. Salazar told you that he did a brief investigation into Halbig's background.
Right.
And did he describe anything that that entailed?
So I asked him, and I also asked Nico, who scheduled him for his very first interview.
And basically, the brief investigation into background generally that they do is asking for the person for their CV and then just verifying their presence on the internet to make sure they're a real person because sometimes people create false identities on the internet.
So aside from doing those basic things, they don't do anything else, investigation into background.
And that was true with respect to what Mr. Salazar did for Mr. Halbig, correct?
That's what it sounded like to me, right?
Mr. Halbig had provided a website that he was associated with in his American Free Press interview, correct?
Yes.
It's called SandyHookjustice.com.
Yes.
And Mr. Salazar visited that website simply to confirm that Mr. Halbeck was associated with it, correct?
Right, I think that there's also on that website a background summary of Mr. Halbeg, or at least there was at one point.
Do you know that to be the case?
Are you testifying to that?
I think I saw it.
So I think that on the website, if you go to that website, there was a section on the website with Halbeg's background information.
Do you know if that was true in February of 2014?
I know it was true when I saw it, but I don't know if it's true back then.
What did you see?
I saw a section on the website of his background information.
Well, when you say website, you didn't go onto the internet to find sandyhoakjustice.com.
Did I go to his website?
No, I think it was in the material that I was providing.
So it was a printout or PDF of something that purported to be the website sandyhoakjustice.com.
Right.
And on that PDF, you saw some information relating to Mr. Halbig's bio, right?
Right.
Mr. Salazar didn't tell you that he saw that, right?
Oh, I don't know whether he saw it or not.
But if he went to that website, if it was there at that time, he would have seen it.
I don't know if it was written at that time.
You're not testifying as Free Speech Systems under oath as to what Mr. Salazar saw on that website, right?
No, I don't know if he saw it on that website.
All Free Speech Systems knows is that Mr. Salazar visited the website.
Yes, he did visit the website.
And all he told you that he did when he did that was confirm that Mr. Halbig was associated with the website, correct?
Or did he not even tell you that we're going to be able to do that?
I don't know.
I don't know.
You know that?
All he said was: I did a brief investigation to his background, which is what I wrote.
So I don't know what that entailed.
But generally speaking, like I said earlier, that's what they did.
Okay, fair enough.
And I agree that that's generally what they did.
That's what Mr. Acosta testified to in his deposition.
But I do want to make sure I understand whether you can testify today that that is in fact what Mr. Salazar did with respect to Mr. Halbig.
Did he in fact go to the Sandyhookjustice.com website?
I think he said he went to the website, but I don't know what he saw there because, as you said, I don't know what was on there at the time he saw it.
I just wanted to make clear because you testified a moment ago that all he told you was that he did a brief investigation and then said that normally that would entail going to the website.
And I just want to make sure that I understand whether you're saying that Mr. Salazar told you he went to Sandyhookjustice.com or whether you're inferring that that was included in what he described to you as a brief investigation.
I mean, I could be misunderstanding the article or misremembering the article, but I believe he said in the article or cited to that website in the article.
So he did visit the website.
I just don't know what he saw when he got there.
Fair enough.
Right.
So I can testify that he went to the website.
Based on what?
That he told you that?
Or that you saw it in the article?
I saw it in the article.
Okay, right.
So Mr. Salazar did not tell you that he went to the website.
What he told you was he did a brief investigation.
Brief investigation.
Okay.
And then you're also testifying that the website was listed in the article Mr. Salazar wrote.
Right.
So he would have gone to it because he listed in the article.
Okay.
But you can't testify to that under oath that he actually went to the website.
You understand how that's a little bit of an inference you're making?
I understand what you're saying, but they don't put links in there to websites that they don't visit.
Well, but.
Because it's a source.
But, Ms. Potts, I understand what you're saying, and perhaps that follows with common sense, but you really can only testify as to what was told to you.
Right.
He didn't say that directly to me.
Okay.
And Nico Acosta, when you talked to him, did Nico tell you anything he did with respect to Mr. Halbig?
I did speak to him about the booking of Mr. Halbeg.
So, yes.
Okay.
And am I correct that Mr. Acosta did not do any vetting of Mr. Halbeck's background?
Yes, and I could tell you why.
Okay.
Well, I think he testified to that.
I just wanted to confirm that Free Speech Systems testimony is that Mr. Acosta did not do any vetting of Mr. Halbeck's background.
That was the sum and substance of what he conveyed to me in our conversation, so yes.
And that's your testimony here today.
Yes.
Thank you.
All right.
Am I correct that other than what Mr. Salazar described to you, Free Speech Systems is not aware of anybody else?
I'll wait for you to finish.
Thank you.
Go ahead.
Okay.
By the way, are you writing notes to my attorney?
Yep.
Okay.
The reason I ask is because you took some notes during your Texas deposition.
No, I'm not taking any notes because they didn't like my doodles there, so I'm not doing that here.
Am I correct that other than what Mr. Salazar did, nobody else at Free Speech Systems did anything to vet Mr. Halbeck's background, correct?
I think that's fair, and I think it kind of fell into this hole as to the reason why that happened, which wasn't usually the course of what happened.
But yes.
Okay.
All right.
One more like.
Thanks.
Sure.
Do you need a minute to talk?
Okay.
When was Mr. Halbig's first appearance on the Alex Jones show?
On the Alex Jones show.
It appears...
So he was on for the first time on 220, which I believe we said is the David Knight show.
And then he was on again on 314, 2014.
Bless you.
Thank you.
Okay.
When you talk to, I think you testified to this, but I just want to make sure it's clear.
Am I correct that free speech systems strike that?
When free speech systems has a new guest on, the typical practice is to just confirm that that person is who they say they are, correct?
And get their basic information like a CV, but yes.
Part of the typical practice is to get their CV.
Right.
Okay.
Who told you that?
When I talked to Nico, I believe that's what he conveyed to me, that he would do this basic vetting of people and, like I said, make sure that they are who they say they are.
But he didn't do that with Mr. Halbig.
Well, Mr. Acosta testified in this case, correct me if I'm wrong, that he did nothing to vet Mr. Halbig other than confirm that he was associated with a website.
Yeah, I think we just said that.
He didn't vet him at all.
Right.
Right, I said that.
And didn't Mr. Acosta testify here that that was in fact the standard practice for him?
For him?
Yeah.
To do what?
To do nothing other than to confirm that the person is who they say they are.
I thought that he had told me in our conversation that he got their CVs, but if I can go back and look at my notes from my conversation with him, I can just make sure.
Okay.
Okay.
So on the second page, he talks, I talk to him a little bit about, so this is my notes regarding Nico on the second page of the notes.
This is the one that starts with the line up to host to vet sources.
Right.
So then so the next block of text would say, it says, the name comes up, they look up the what, he looks out the website, he provides it to Alex.
Alex makes the ultimate decision.
There's a pre-booking procedure where they either verbalize or per print articles of the person.
And I think that's what he described in his testimony as his business.
He goes to a website, confirms that the person's associated with it, and then Alex makes a call about whether to have him on.
Right.
And then on the first page, he talks about pulling a bio at the bottom of the first page.
So there would be a folder for guests with bullet points and sections with the biography, photo, articles.
So let me see if I can just summarize what, according to Mr. Acosta, at least, and then I'll ask you if that's Free Speech Systems testimonial.
That Mr. Acosta, first of all, was the producer for the Alex Jones show, right?
Right.
Okay.
And he was responsible for booking guests on that show.
Right.
And that was true for the entire timeframe we're discussing here from the late 2012 onward to about 2018.
Is that right?
Right.
I think he worked there until May of 2018.
Okay.
And so he was responsible for booking guests.
Right.
Okay.
And his typical practice would be if a name came up, he would confirm that that person was associated with a particular website that they claimed to be, and then he would give it to Alex to decide whether to have that person on, right?
Am I right so far?
I'm going to keep going, but am I original?
Yes, and then if Alex decided that he wanted the person on, Nico would try and get a bio so that Alex could describe the person on air.
And if there were any articles that Alex wanted to, that Alex might want to review with that person, he would print those out, right?
Right.
And he put together a folder of that person with that material in it, right?
He didn't have any responsibility at all for vetting any aspect of a person's bio.
No, he made clear, and I say this, it's up to the host to vet the sources.
So he made that clear in our conversation.
Thank you.
Right.
And with respect to Mr. Halbig, that's exactly what Mr. Acosta did.
Right?
I don't even think he put together this folder.
So his position to me was that he assumed that he'd already done these things with Mr. Halbig because he already made the decision.
Alex let him book his own guests and so he just set up that booking process.
But I don't even think he made this folder.
I don't want to let Nico book his guests.
Not Nico.
I'm sorry, did I misspeak?
Alex decided who no, no, no.
I think I misspoke.
So Alex at the time was letting David book his own guests.
David Knight.
Right.
So he, if David wanted this person on the show, he assumed it was okay and it was already vetted.
I don't think that Nico even put this folder together on Mr. Halbig.
Fair enough.
Right.
That's what I want to make sure.
And not having put the folder together and not having seen Mr. Halbig's bio, Mr. Jones made the decision to bring him on his show, right?
After David had already brought him.
Right.
Okay.
All right.
I don't know if this is a good time to break, but I would like a potty break if we can.
So why don't we go off video for a second at least?
We are off the record.
The time is 11.54 a.m.
ESD.
We are now on the record.
The time is 11.58 a.m.
ESD.
I'll just pause continuing with some questions concerning Mr. Halbig.
The day after Mr. Halbig appeared on the Alice Jones show for the first time, am I correct that Free Speech Systems received an email from a gentleman named Robert Heath encouraging Free Speech Systems to check Mr. Halbig's credentials?
I think I recall this email.
So yes, I think it's in our emails, yes.
Okay, so this, why don't we pull up, if we could, please, exhibit number 26.
I'm sorry.
Yes, exhibit number 26.
Thank you.
Do you have that in front of you, Ms. Paz?
Yes, I've seen this email.
You've seen this before?
Yes.
And the first email in the thread is from Robert Heath to writers at Infowars.com, correct?
Yes.
Okay, and that's actually sent on March 14th, 2014, right?
That's what it says, yes?
That's the day of Mr. Halbeg's appearance, correct?
That's what it appears, yes.
And what is Mr. Heath write?
I'm not really sure who Mr. Heath is, but Mr. Heath sends an email to one of our general email boxes saying you would be well advised to check Wolfgang-Halbeg's credentials, best wishes, Robert Heath.
Okay.
And Mr. Salazar responds to Mr. Heath that very day and asks him what Mr. Heath means, correct?
That's what it looks like, yes.
Okay.
And he also says your email is much too vague to follow up on, correct?
Yes.
Did you ask Mr. Salazar about this email exchange?
I don't recall if I asked him about this email exchange in particular.
I might have asked him if he had any awareness about Wolfgang-Halbeg's background.
But I don't know whether I asked him about this specific email.
Okay.
And I just, I do want to, I see sometimes you struggling to remember what may have happened, and so you kind of will think out loud and say, I might have done this or I might have done that.
I just want to make sure that to the best you can, please only testify as to what you are comfortable testifying to under oath, okay?
So it sounds like your testimony is that you don't know whether you asked him about this email or not.
Right, I'm not sure if I asked him specifically about this email.
Fair enough.
But I don't think there was a response to it.
I think that's the end of the email exchange, as far as I've reviewed in the records.
Okay.
Did you do anything to try and figure out who Mr. Heath was?
No.
All right.
But in any event, am I correct that Free Speech Systems did nothing to check into Mr. Halbeg's credentials in response to this initial email from Mr. Heath?
No.
Adan clearly asks what he means.
And that was his way of checking into this allegation.
Okay.
And there was nothing left.
You're saying that now, but you didn't ask Mr. Salazar about that.
I don't remember whether I did or not, but the email clearly says, what do you mean?
The email says, what do you mean?
Right.
Separate from responding to Mr. Heath's email, am I correct that Free Speech Systems didn't do anything independently to check Mr. Halbig's credentials in response to Mr. Heath's email?
Not that I'm aware of, no.
Okay.
And I take it that you asked about, I mean, while you may not have asked about this particular email, you did ask about any further efforts to check into Mr. Halbig's credentials, right?
I believe I did.
I think Daria testified to this too in her deposition.
That there weren't any.
Right.
So let's take that one down.
now on the the marsh um well let's let's bring up exhibit number 27 okay Do you have an exhibit before you from Robert Heath associated with the same email address to Adan Salazar, now the next day?
Okay.
Yes, you see that?
I do.
And can we scroll down to the bottom?
You see that this email is in response to Mr. Salazar's email that Mr. Heath's email had been much too vague to follow up on.
Right, right, I see that.
The testimony that you just gave a few minutes earlier, in which you said that you didn't think there was any further emails, was incorrect.
I don't think I saw that the next email exchange.
So I think what I saw was just the two one back and forth.
I didn't see the second one.
And you presumed from that that there had been no further emails.
Right, because it looked like the end of the communication, but I see that there looks like there was one more.
And I take it as possible that you may have just missed this email in the production you were given, or it's possible it wasn't even in the materials you were provided.
Right, I don't know which.
I can't say.
Looking at it now, if you could go up, am I correct that Mr. Heath actually does get back to Mr. Salazar with specific concerns he's raising about Mr. Halbig's credentials, correct?
That's what it looks like.
And specific concerns he's raising about Mr. Halbig's credibility based on what Mr. Heath claims are his own efforts to look into Mr. Halbig's background?
That's what it looks like.
Okay.
And Free Speech Systems did nothing in response to this particular email to check further into Mr. Halbig's credentials, correct?
I don't believe so.
In my conversations with Mr. Dew, they get emails like this frequently, not just about Mr. Halbeg, but about many of their guests.
So there were other emails that Free Speech Systems received in addition to this one questioning Mr. Halbig's credibility.
That's not what I said.
I said other guests they frequently get emails such as this about their guests.
Did they get any others about Mr. Halbig?
Oh, I don't know.
Like I said, I haven't seen this particular email exchange, but in my conversation with Rob Dew, he says things like this aren't uncommon.
Right.
Because they have a lot of people on their show who aren't credible, right?
That's not what I said, sir.
Okay.
But, and your Free Speech Systems is not prepared to testify today as to whether this is the only email they received questioning Mr. Halbig's credentials, correct?
I don't know whether it is or isn't.
I don't have any more.
I don't have any information to suggest one way or another.
I don't know.
There might have been others you missed in addition to this one?
I don't know.
Um...
Did Mr. Salazar get back to Mr. Heath after this?
I don't know.
Okay.
In this particular email from Mr. Heath, he informs Mr. Salazar of Mr. Halbig that he can find no trace of Mr. Halbig except in connection with his current activities on Sandy Hook, correct?
That's what the email says.
And Mr. Heath says, for example, I cannot find him on the list that exists of expert witnesses of which he has categorically stated he was one concerning Columbine, correct?
That's what it says.
Right.
Mr. Jones himself has asserted on his show that Mr. Halbig was at Columbine, right?
I believe he has.
Yeah.
Bottom of the email, Mr. Heath says if he, referring to Halbig, was using a pseudonym, that could explain it.
But why would someone looking for transparency do that?
What if he drags everybody along the line of no deaths, which Alex rightly didn't commit to?
Would not all the questions and doubts be illustrated to the public as just another crazy conspiracy theory if it was exposed that definitely there were in fact deaths and that Halbig was a con man?
Did I read that correctly?
Yes.
Notwithstanding this particular email, Mr. Jones had Mr. Halbig on repeatedly after this initial appearance on March 14th, 2014, correct?
I Yes, he was on a few other times after that.
And Mr. Jones, on this particular Date described Mr. Halbig as a top consultant, correct?
On which date?
on March 14, 2014.
I'm just going to look at my notes from that video.
I love you.
Okay.
So, what was the question?
I'm sorry?
On this particular appearance, Mr. Jones described Mr. Halbig to his audience as a top consultant, correct?
Yes, in the very beginning, he listed his credits.
So the credits that they pulled for Mr. Halbig.
You know, and I wanted to ask you about that because earlier, I think you testified that it was your understanding that Mr. Acosta had not pulled a bio as he normally would and put it in a folder for Mr. Jones.
For Mr. Knight, is what I said, because initially the initial appearance was with Mr. Knight.
Right.
Mr. Acosta wasn't a producer on that show.
He booked Mr. Halbig for Mr. Knight's show.
Mr. Acosta told you that?
Yes.
So in my notes for him, he just basically said, just go back through my notes.
so This has me wishing I had numbered these.
Okay.
So right.
So he said if David wanted a book, assume he is already vetted.
And I think that there were emails from Nico to Mr. Halbig trying to set up that first appearance with David Knight.
So Nico booked it.
Okay.
But it, so in any event, with respect to Mr. Halbig's first appearance on the Ellis Jones show, Free Speech Systems testimony is that he had some information about Mr. Halbig's bio in front of him, correct?
And that's what he was referencing when you referred to him as a top consultant?
Right.
He clearly, in this video, my note, according to my notes and my recollection, is he listed his credits from the very in the very first part of the video.
And Free Speech Systems doesn't have a record of what Mr. Jones was referencing, correct?
You mean if there was, like, for example, if there's a folder?
No, we don't keep that.
Okay.
All right.
And Mr. Jones referred to him in that particular appearance as having had a long career as a state police officer.
Is that right?
Right.
He was citing to his credits, right?
Okay.
Well, do you know that?
Does Free Speech Systems know that Mr. Halbig was only a Florida State Trooper for a year and for a decent part of that was a probationary officer?
Oh, I'm not sure.
Free Speech Systems isn't aware of that?
I don't know.
Okay.
It'd be fair to say that if Mr. Halbig's career as a state trooper lasted one year, that that wasn't a long career, correct?
I don't think that's long, no.
Okay.
On this particular first appearance on March 14th, 2014, am I correct that Mr. Halbig referred to the Sandy Oak shooting as a drill portrayed as one of the best illusions ever?
If Mr. Jones said that?
Mr. Halbig.
Mr. Halbick said that.
Yes, I think he does say that he thinks it was a drill.
That's right.
And you didn't inquire of Mr. Halbig to assess what he meant by that, correct?
I didn't speak to Mr. Halbig, but he cites to why he thinks these things in this interview.
He talks through his 16 points.
You're reading your notes here.
Right.
He talks through his 16 points in this video, and he talks about why he thinks it's a drill.
Now, in 2014, throughout 2014, separate from Mr. Heath's warning about Mr. Halbig's credibility, Free Speech Systems had independent reason to doubt Mr. Halbig's credibility, correct?
I don't know what you mean.
Mr. Halbig started sending voluminous emails to free speech systems throughout 2014, correct?
Yes, he would send many emails copying many people on the emails.
Throughout 2014.
Yes.
And am I correct that those emails were crazy in nature?
So when I talked to Nico, he just want you to what you talked to Nico about, okay?
I just want you to answer the question that I asked you.
Am I correct that Free Speech Systems agrees that throughout the course of 2014, Mr. Halbig was sending crazy emails to Free Speech Systems?
Yeah, I'll check that to the form on that as well.
Can you answer that?
I think that they, pursuant to my conversations, had gotten more and more disturbing as time went on.
But as Nico described to me, most, if not all, of his emails after a certain point were not being read.
Okay.
So I appreciate that.
And I'm going to ask you about emails he sent throughout his career as a guest on Free Speech Systems, but I'm focusing just now on 2014, and I'm going to ask my question again: Does Free Speech Systems agree that throughout 2014, Mr. Halbig was sending emails that Free Speech Systems perceives to have been crazy to Free Speech Systems?
I think they had gotten progressively more and more out there as time went on.
He got crazier as time went on, right?
As time progressed.
But the initial period of time in 2014 was also a time where he was sending emails that Free Speech Systems perceived to be crazy, correct?
I don't know that that's the case early on.
Okay, well, you testified to that effect in Texas, did you not?
In Texas, what I said was very similar to what I said here: the emails got progressively crazier as time went on.
Correct.
And then you said that that included the period of 2014, correct?
Well, 2014 was really the only time he was on the air.
So do you want to maybe track that testimony about whether 2014 was the only time he was on the air?
I would like to refresh my recollection as to what my testimony was.
I'm going to have that here.
I'm going to hand you your deposition from Texas.
There you go.
I'm handing you exhibit number 7i.
Would you turn to page 182?
Thank you.
Starting on line, are you there?
Yep.
Starting on actually, why don't we start on page 181, the last line?
Referring to Wolfgang-Halbig, question, because he's kind of crazy, right?
Free speech systems.
I think that his email communications got more and more bizarre as time gone went on.
Question, so we answer.
I think that was the word that Nico used, was bizarre.
Question: Hold on.
You've read a lot of Wolfgang Halbig emails.
I'm taking it.
Answer, I did, yes.
Question: So you've read emails from him like in 2014, and you've probably read emails from him up in 2017, right?
Answer, yes.
I read a lot of emails.
Question: Are you going to tell me that the emails he sent in 2014 are any less crazy than the emails he sent in 2017?
Answer, I think they've gotten crazier.
Question: Okay, but we can both agree that there are plenty of emails he sent in 2014 that the company did in fact read and thanked him for.
Sure.
Question: That are crazy?
Answer, yes.
You gave that testimony, correct?
Right.
Okay.
So there were plenty of emails that Mr. Halbig sent to Free Speech Systems in 2014 that the company read and thanked him for that were crazy, right?
Sure.
The ones that they read.
They did respond to some of those emails.
The answer was sure, right?
Sure.
Okay, thank you.
In addition to the emails it was receiving from Mr. Halbig, it was contacted.
Free speech systems was contacted in December 2014 by a gentleman named Keith Johnson, who detailed additional warnings about Mr. Halbig, correct?
I don't remember.
Why don't we pull up exhibit number 30?
Do we have it?
I'm sorry, I'm not seeing it.
Okay.
This is an email dated December 12th, 2014, just shortly before the two-year anniversary of the Sandy Hook shooting, correct?
Yes, I have read this email.
It's on my spreadsheet of things that I reviewed.
Did you review this before your Texas deposition or after?
I think I read this before my Texas deposition.
Okay.
And so you'd agree with me that in this particular email, Mr. Johnson is sending Rob Dew a series of concerns that he has about Mr. Halbig's claims concerning Sandy Hook, right?
That's what it appears to be, yes.
Okay, well, I mean, that's what it is.
You've read it before.
Yes, it's an email from Keith Johnson, and he's conveying what he thinks to Mr. Dew.
And he's indicated that he's rebutted all of Mr. Halbig's so-called 16 points, correct?
Well, I don't know about all of them, but at least some of them.
Okay, and he's pointing out gaps in Mr. Halbig's resume, correct?
Yes.
Okay.
In fact, with respect to the part of his resume that Mr. Halbig claims, in which Mr. Halbig claims he was a consultant on Columbine and a homicide detective, Mr. Johnson says both claims are false and that he can prove it, correct?
I'm sorry, where are you on the email?
If you look down towards the bottom of where it currently appears on the screen, Mr. Johnson is informing Mr. Dew that he can prove that Mr. Halbig's claims to have been a homicide detective and a consultant on Columbine are false, right?
That's what he says.
He says that he's documented multiple lies that Mr. Halbig has told, correct?
That's what it says.
Okay.
And he's exposed intentional manufacturing of evidence by Sandy Hook conspiracy theorists, correct?
That's what it says.
All right.
And this was received by Rob Dew, Free Speech Systems News Director, in December of 2014, correct?
Yes.
All right.
All right.
Why don't we take our lunch?
Can we be back at back at 1255?
Save ourselves five minutes?
Sure.
Is that okay?
Yeah.
Yes.
If you want 12.30, that's, or if you want one o'clock, we can do one o'clock.
We'll do our best to be back.
All right.
Thanks, everybody.
Appreciate it.
We are all the record the time is 12.21 p.m.
EST.
We are now on the record.
The time is 12.58 p.m.
EST.
Ms. Paz, after receiving the warnings about Mr. Halbig's credibility that we were just discussing, I think you testified that Mr. Jones continued to have Mr. Halbig on his show, correct?
Yes, he was on after these emails, yes.
And during those appearances, Mr. Jones would promote Mr. Halbig's website, Sandy Hook Justice, correct?
Yes, I think every time Mr. Halbig was on, there was a link, his link to sandyhookjustice.com was put on the screen.
And Mr. Jones also informed his audience that there was a link on Mr. Halbig's website where they could donate money to support Mr. Halbig's activities, correct?
Yes.
And Mr. Jones encouraged his audience to give money to Mr. Halbig, correct?
I don't know about, I don't know if he encouraged it, but he definitely advertised it there for them if they wanted to.
You don't recall seeing a video in which Mr. Jones encouraged his audience to support Mr. Halbig financially?
Could you point me to a specific video?
Sure.
Well, I mean, I think you just testified that you don't think Mr. Jones encouraged his audience to do that.
I said I don't, I'm not sure if he encouraged.
I know he definitely advertised it and says, here, if you want to give.
I'm not sure if he, I would use the word encourage, but if you could point me to a specific video, I'd be happy to look at it.
Do you dispute that he encouraged his audience?
I don't know.
If you could point me to a specific video, I could do that.
I will do that.
Perfect.
He also encouraged Mr. Halbig to go to Newtown, did he not?
Encouraged him to go to Newtown?
I don't know if he encouraged him to go to Newtown.
I think Mr. Halbig was already going to Newtown.
Okay, so I just want to be clear.
Is Free Speech Systems testimony that it doesn't know whether Mr. Jones encouraged him to go to Newtown or it does know?
If you want to point me to a specific video that you're referencing, I'll be happy to look at it.
But as I said here today, I don't know that he encouraged him to go to Newtown.
I think he was already going to Newtown and he was already doing his own investigation.
Okay, so but just to be clear, Free Speech Systems doesn't know whether Mr. Jones encouraged Mr. Halbig to go to Newtown, correct?
Right.
If you want to point me to something to look at, I'd be happy to look at it.
But that's right.
But without, I mean, based on everything you've reviewed to date, right, Free Speech Systems doesn't know whether Mr. Jones encouraged Mr. Halbig to go to Newtown.
Based on the material that I've read, Mr. Halbig was conducting his own investigation.
Okay.
So yes.
Okay, Ms. Paz, I do just want you to answer my question.
I didn't ask what Mr. Halbig had done.
All I asked you to do was to please give a clear answer, one way the other, if you can, about whether Free Speech Systems knows or doesn't know if Mr. Jones encouraged Mr. Halbig to go to Newtown.
Can you answer that question?
I think as I said earlier, if you want to point me to something specific, but as I said here today, I don't know whether he encouraged him.
To my knowledge, what I've reviewed is he was already doing his own investigation.
That's my answer.
So I said I don't know.
If you want to point me to something specific, I'd be happy to look at it.
So you don't know?
I said it three times.
I don't know.
Thank you.
And when was the last time anybody employed by Free Speech Systems had contact with Mr. Halbig?
You mean whether anybody has spoken to Mr. Halbeck?
I don't mean that.
I mean when was the last time anybody employed by Free Speech Systems had contact with Mr. Halbig?
By contact, do you mean him sending us emails or us responding to emails or someone speaking to him on the phone?
I just want to make sure I understand what you mean by contact.
All of the above.
I don't know if he continues to send emails to free speech.
He may.
I asked you, I didn't ask you whether he's doing it right now.
I asked you when was the last Time anybody employed by Free Speech Systems had contact with Mr. Halbig.
And I'm trying to answer your question because if you mean by contact that he's reaching out to free speech, he may in fact still be doing it and I don't know.
Okay.
But if you mean who has spoken to him or sent him emails, I don't know.
It's been a long time, especially because his programming on here was a pretty discreet period of time.
So nobody's reached out to him.
Are you just guessing about whether it's been quite some time?
I'm not just guessing because.
Well, let me ask you about Mr. Dew.
When was the last time Mr. Dew had any direct contact with Mr. Halbeg?
I don't know a date.
I can't tell you a date.
Was it within the last year?
I don't know.
Do you know anything?
Do you have any information that would allow you to answer that question?
When I spoke to Mr. Jones, his position was that Mr. Halbeg's appearances and involvement with free speech was a very distinct period of time, and then after that time period, there was no real involvement with Mr. Halbeg anymore.
And that was corroborated by Nico when I talked to him about the various emails he was receiving from Mr. Halbeg as well.
Nico hasn't been employed by Free Speech Systems in four years, right?
Since 2018, right?
So he would have no idea whether anybody's had contact with Mr. Halbig in the last four years, right?
Up to 2018.
Okay.
So and I know you just described for me what Mr. Jones told you.
Right.
But I'm interested in whether you, as Free Speech Systems representative, can testify one way or the other as to when the last time anybody employed by Free Speech Systems had contact with Mr. Halbig?
I don't know.
Okay, thank you.
Did you do anything to look into that?
Aside from reviewing material and speaking to the people, no.
Okay, and so nothing in your interviews or anything we reviewed gave you sufficient information to answer that question.
No, I've just testified to all the information that I was able to gather on that particular topic.
Okay.
Did you read Mr. Bedanti's deposition?
I don't believe so.
It wasn't on the list of depositions I reviewed.
Okay.
Okay.
You have still exhibit 10 in front of you.
I want to direct your attention to a video published by Free Speech Systems on March 14th, 2014, called Sandy Hook False Narratives.
Do you see that?
Which chart is it on?
That is on chart A. Chart A. So which date?
March 14th, 2014.
Yes, I believe I reviewed this.
Yes.
Yes.
Let me, if I can, just pull up my notes on it.
This is Mr. Halbig's first appearance on the show.
We were talking about this earlier.
Okay.
Okay.
And during that video, Mr. Jones states: we've got people clearly coming up and laughing and then doing the fake crying.
Yes.
Right.
And who's he talking about there?
The Robbie Parker interview.
So he's talking about Robbie Parker.
Right.
And who, in addition to Robbie Parker, is he talking about?
I think he's just talking about Robbie Parker.
Okay.
So when he says we've got people clearly coming up, obviously that suggests multiple people, right?
No, not necessarily.
What's the singular of people?
He could say we have people.
What's the singular of people?
I think it's a turn of phrase.
What's the singular of people?
Person.
Thank you.
The multiple of a person is people, right?
It is a turn of phrase.
Okay.
Well, I know it's a turn of phrase.
It's a word, right?
People has a meaning that means multiple persons, correct?
Not in this context.
It's a turn of phrase.
Does Mr. Jones decide the definition of a word depending on how he's using it?
Projection is one.
As I've said, it's a turn of phrase.
So when you read this, when Free Speech Systems reads this sentence and it says, we've got people clearly coming up and laughing, its testimony is that Mr. Jones is just talking about one person.
Yes.
Even though he says people.
Yes.
He's not intending to convey to his audience that there were multiple people clearly coming up and laughing by using the word people.
I don't think so, though.
Okay.
When you say I don't think so, you mean Free Speech Systems doesn't think so.
Brittany Paz might think so, but free speech doesn't, right?
I don't think it's relevant what I think.
I don't either.
Guys, I need you to slow down just a little bit.
You guys are going way too fast.
And then when he says doing the fake crying, he's again referring to Mr. Parker.
Right.
And nobody else.
Right.
And he says, we've clearly got people where it's actors playing different parts of different people.
Who are the actors he's talking about?
I don't know.
Well, is Mr. Parker one of them?
I don't know.
You didn't ask Mr. Jones about that?
Not specifically, no.
Okay.
But what Mr. Jones there is conveying is that there are actors, multiple, right?
Actors.
That seems to be plural, yes.
Okay.
And the actors that you're not able to identify were playing different parts of people, right?
That's what it seems to say.
I mean, I can make an inference as to what he's talking about, but I'm not sure, so I don't want to do that.
Fair enough.
But he's, having reviewed the video, you know that he's talking about Sandy Hook shooting.
Sure.
The whole video is about Sandy Hook, so yes.
Okay.
And you read Miss Karpova's testimony regarding this video, correct?
I read the deposition.
Yes.
And in that deposition, Free Speech Systems admitted that there was no basis for Mr. Jones saying that there were clearly actors, right?
I don't recall.
You don't disclute that, though.
I just don't recall either way.
If you want to show me the transcript, I'd be happy to look at it.
I'm going to make a lot of the ingredients.
I'm going to make a lot of the ingredients.
Do you know what the source was for Mr. Jones' statement that they had clearly people clearly coming up and laughing and then doing the fake crying?
We've clearly got people where it's actors playing different parts of people.
Do you know what the source of his knowledge was for making that statement?
Well, it appears there's a couple of claims in there.
I would break it down into a couple of claims.
And I think we said earlier the source of the crying is the Robbie Parker interview.
The fake crying.
The fake crying.
That's how he describes it.
That's fake crying is the Robbie Parker interview.
And just be clear, you referred to the interview.
Mr. Parker didn't give an interview, right?
It was a press conference in which he made remarks.
He made a statement.
That's right.
Okay.
This is the day after the shooting.
Right.
Okay, that video.
Right.
Okay.
Go ahead, please.
And I think the second part of that, we had already said I'm not sure what the source of that statement is, and I could make an inference, but I don't want to guess.
Fair enough.
And in this same video on March 14th, 2014, Mr. Jones says the good news is that most people I've seen don't believe Sandy Hook.
Do you recall that?
just give me one second just to review my notes I don't have that exact statement in my notes, but I'll accept your representation that he says it.
He does say other things, as well as: I pray to God that I'm wrong about this.
I'm just asking you.
But I'm not sure if he says that exact statement.
So as you sit here today, obviously you wouldn't be able to testify as to what he meant when he said it's good news that people don't believe Sandy Hook.
Right.
All right.
And in this video, Mr. Jones also says that we want to send, maybe even I'll go, we want to send reporters up there, Wolfgang, with you.
Yes.
You recall that?
Yes.
All right.
And did you talk to Mr. Jones about whether he actually considered going up to Newtown?
No, I didn't talk to him about that.
I do know that Mr. Halbeck had asked that he go, and he never actually did go.
But I didn't ask him why that was.
But at least Free Speech Systems acknowledges that as of March 14th, 2014, Mr. Jones was aware that Mr. Halbig had been to Newtown and was going to be going back.
Right.
Okay.
Let me direct your attention to a Mark, I'm sorry, May 9th, 2014 video.
That's exhibit 55, which I can't get in.
There we go.
It should be on chart A. Okay, I think I reviewed this one.
This is the Board of Education meeting.
Vedanti goes up with Mr. Halbig?
Yes, yes.
I did see this.
So, am I correct that Mr. Halbig was going to a Newtown Board of Education meeting, correct?
My notes say that it's the FOIA hearing.
Right.
That's incorrect.
Have you watched the video of Exhibit 55?
So there were two FOIA hearings in 2015, and then in 2014 is when Mr. Halbig goes up to Newtown.
The FOIA meetings are in Hartford.
The Board of Ed meeting is in Newtown.
This is a Board of Ed meeting.
I'm just trying to jog your memory here.
Okay.
I mean, I can't put that in your head, so I'm just wondering if, having reviewed these videos, that rings a bell to you, that the May 9, 2014 broadcast is a broadcast depicting Mr. Halbig's visit to Newtown, the Newtown Board of Ed.
I do know he went to Newtown, and I do know this is a video of him in Newtown, not in Hartford.
So, yes.
Okay, you'll accept that this was a board of ed meeting.
Right.
All right.
And Free Speech Systems sent Dan Badanti to cover that, correct?
Yes, I believe he did.
Mr. Dew specifically directed Mr. Badanti to Go to Newtown to interview Mr. Halbig and to cover the Board of Education meeting, correct?
Yeah, I think there's an email where asking him to go to Newtown to cover that, so yes.
And Mr. Bedandi was a contract reporter for Free Speech Systems at the time?
Yes.
And Mr. Dew informed Mr. Halbig, pardon me, that Free Speech would be sending Mr. Badondi to cover it, correct?
Did Free Speech inform Mr. Halbeg that they're sending Badondi?
Rob Dew, yeah.
So Rob Dew, on behalf of Free Speech Systems, communicated with Mr. Halbig about the fact that Free Speech Systems would be sending its reporter?
Oh, I don't know.
Maybe they did.
I just don't know.
Okay.
Did you ask Mr. Dew about the extent to which he coordinated Bedondi's trip to Newtown with Mr. Halbig?
Did you ask him anything about that?
What do you mean the extent to which it was coordinated?
Halbig was going, and so Rob asked Badandi to cover it.
Right.
How did Rob know Halbig was going?
Oh, I don't know.
Okay.
You didn't ask him any questions about that?
I don't think I asked him about that specifically, no.
Okay.
So as you sit here today, Free Speech Systems isn't able to testify about whether Mr. Dew had any communications with Mr. Halbig in advance of this, in advance of the Newtown Board of Ed meeting?
No, there may be emails, but I'm not aware of them as I sit here.
and And Mr. Bedanti met up with Mr. Halbig in Newtown, correct?
Right.
And Mr. Halbig, Mr. Badondi, knew how to link up with Mr. Halbig because Mr. Dew provided him with that information, correct?
I don't know.
Okay.
And Mr. Bedondi accompanied Mr. Halbig to various other locations in and around Newtown before the Board of Ed meeting, correct?
I believe they went to United Way together as well on that same trip.
Mr. Badondi went with Mr. Halbig to the United Way charity offices as a Free Speech Systems reporter, correct?
Right.
And Mr. Halbig had a confrontation with Newtown police outside the charity building, correct?
Well, I don't know if I would call it a confrontation, but the police were called and Mr. Halbig had a conversation with them, yes.
Mr. Halbig was trying to get into the office, correct?
Well, he had gone there and he had asked to be let in.
The employees said no.
The police were called and he wasn't trying to force his way in, if that's what you're asking.
How do you know that?
I don't think there was any allegation that he was trying to force his way in.
I'm asking you how you know that Mr. Halbig didn't try to force his way in.
I watched the video.
It didn't appear to me on the video that there was any allegation that he was trying to force his way in.
So you watched it.
Which video did you watch?
I believe it's the video that Free Speech posted that our camera crew captured.
Okay.
So who was doing the camera work for Mr. Bedondi on that trip?
I don't know the name of the person who did that.
Also working on behalf of Free Speech Systems?
I believe so.
Okay.
Kevin LaPrade, was it?
I don't know.
Okay.
So Mr. Bedondi, accompanied by a Free Speech Systems cameraman, went to United Way charity with Mr. Halbig and shot footage to air on Free Speech Systems, right?
Right.
And that video you watched, at least didn't appear to you that Mr. Halbig was trying to force his way in.
Right.
But you're not aware whether there was other activity that was not depicted there in which Mr. Halbig was trying to force his way in?
I'm not aware of any material that would suggest he was forcing his way in.
Okay.
Other than the fact that the police were called?
That does not suggest that someone was trying to force their way in.
So, no.
Does it suggest to you that the employees felt they needed to call the police?
Yes.
and in addition to...
Right.
And on that same trip, Mr. Halbig went to a Newtown firehouse, correct?
I don't know.
I didn't see any footage to that effect, so I don't know.
All right.
And you didn't ask anybody about that?
No.
You've never seen any footage of Mr. Halbig at the Newtown firehouse?
No.
All right.
Are you aware of a confrontation Mr. Halbig had with a Newtown fire personnel at any time?
I don't believe so, no.
Okay.
I'm not saying it didn't happen.
I just don't know.
Free Speech Systems just isn't aware of it.
Is Free Speech Systems aware of whether Mr. Halbig went to the St. Rose of Lima Church in Newtown?
Yes.
Okay.
On this particular day, right?
I don't know if it was the same day, but one of the trips he made up there, I know he went.
Okay, and for what purpose did Mr. Halbick go there?
I don't know exactly, but it was something to do with he was claiming that there were some people there that were connected to the Sandy Hook shooting and he wanted to go there to talk to people there.
Okay.
So I don't know the specifics as to his claims regarding that particular location.
Does Free Speech Systems know anything about the connection between St. Rose of Lima Church and the Sandy Hook shootings?
I don't know that there is a connection.
I don't know what his claim as to the connection was.
Okay, so Free Speech.
It was his claim.
Free speech isn't aware that funerals for some of the people who were killed at Sandy Hook were held at St. Rose of Lima.
I believe that's accurate.
Okay.
Did I just refresh your recollection by suggesting that?
Okay.
That's a fair assessment.
All right.
Having refreshed your recollection, does that provide you with any other recollection about why Mr. Halbig was going there?
I really don't know what his claim was regarding that.
Was Mr. Badandi with him?
Yes, I believe so.
All right.
Again, acting in his capacity as a contract reporter for Free Speech Systems.
Yes.
Okay.
Now, in this particular broadcast, you're aware that the Board of Ed meeting occurred on May 6th, 2014, but this video aired on May 9th, 2014.
Is that your understanding as well?
I'm not sure about the dates.
I mean, I could tell you when it aired just based by looking at this, but I'm not sure how long before the footage was taken.
Okay.
And in this video, do you recall Mr. Halbig stating that the Connecticut State Police had sent police officers to his house in Florida?
I think he's made that claim a couple of times.
Okay.
But yes.
He's made it different ways.
He has.
Right.
So, and Free Speech Systems aired each of the different iterations of that claim, right?
I believe so, yes.
Yeah, so one of the claims he made, at least in this video, was that the Connecticut State Police had sent police officers to his house, correct?
I think his claim has been that the Connecticut State Police asked Florida state troopers or sheriffs, I think he used the word sheriffs because they have sheriffs down there to come to his house, inquire as to whether he has a gun, inquire as to whether he has future plans to come to Newtown, and I guess to inform them if he had any plans to come to Newtown.
And you gathered all that from a video that you watched, right?
I don't think it was necessarily one video.
I think he said it a couple of times.
And this is what I'm trying to do.
I'm trying to get at because he has made different claims about the circumstances of police coming to his house.
We'd agree on that.
How are they different?
Well, you're aware that in this particular video, He said that the Connecticut State Police sent police officers to his house, right?
Okay, I don't have that exact quote in front of me, but I'm taking your representation.
Yes.
And am I correct that Free Speech Systems didn't do anything to investigate the accuracy of that claim?
That's correct.
Okay.
And separately, Mr. Halbig has stated that the Newtown Board of Education sent police officers to his house.
Are you aware of that?
I don't know if he said the Newtown Board of Education.
You're not aware of that.
I'm not sure.
Okay.
If he did say that, that the Newtown Board of Education sent police officers to his house, Free Speech Systems did nothing to corroborate whether that was accurate, correct?
If he said that, I don't know, but no, we didn't do anything to investigate that.
And if Free Speech Systems was aware of the two different claims, one being that the Connecticut State Police sent police officers to his house, one being that the Newtown Board of Ed sent police officers to his house, that didn't raise any suspicion in Free Speech Systems' mind that the claim may not be accurate, correct?
Well, we don't investigate people's claims, so we wouldn't have done anything.
If you have a guest on that comes on one day and says X about an issue and then says Y about an issue, you don't attempt to interrogate whether why there's a discrepancy.
No, not necessarily, no.
And not in this case.
Right.
Okay.
On this particular day, Free Speech Systems published a claim by Mr. Halbig that paramedics and EMTs were not allowed inside the school to treat children, correct?
Yes.
Okay.
That obviously was a false claim, correct?
I think subsequently in the Sandy Hook report, it made it clear that the paramedics were on scene.
So, right.
Didn't the Sandy Hook report come out before this?
I think it did.
I think it came out at the end of 2013.
Right, we discussed this yesterday.
Right.
In November of 2013.
Right.
And that report makes clear that paramedics in emergency response were inside the school to treat children, correct?
Right.
Okay.
And so this claim was false, right?
This claim by Mr. Halbig is not accurate, yes.
Right.
And Free Speech Systems knew that at the time because Mr. Dew had read the report, correct?
Mr. Dew read the report.
I don't know whether Alex had read the report.
But you testified earlier that you don't know even today whether Alex ever read the report.
I don't know, right?
Nor do you know whether Mr. Badandi did.
I don't know why he would have read the report, but I don't know whether he did or didn't.
Okay.
And is Free Speech Systems aware of the basis for Mr. Halbig's claim, inaccurate though it was, that no paramedics or VMTs were allowed in the building?
I believe he had stated the reason why he thought that.
I think that he had cited to ambulances being at the end of the drive and not being allowed at the property.
But it may have been something that he was saying regarding photographs that he saw, but I think that may have been the basis for that claim.
When I hear you describe that, I see you kind of searching your memory, and I know you've looked at a lot of stuff.
It sounds to me when you give that answer that, you know, respectfully, you're not sure whether that was in fact the basis and that you're prepared to testify to it.
He's cited to that particular thing numerous times, meaning the paramedics, and every time he's cited to that particular claim, he's also, in almost the same breath, said about the ambulances being at the end of the drive.
So I think that's his basis, but like I said, I can only say what he says in the videos.
Right.
Right.
Okay.
So fair to say that apart from what Mr. Halbig says in any video, Free Speech Systems has no information About what the bases for his claims were.
Well, right.
Apart from what he says in these videos, we didn't go investigate his claims at all.
So, whatever he says, these are his opinions, and we've broadcast them in the sense that you can make your own opinion either way.
These are his opinions, and here they are.
Ms. Powell, respectfully, it's not an opinion to say that no EMTs were allowed in the school.
That's a statement of fact, correct?
These are claims that he's making, and they're his claims.
And he stated the reasons why he thought it.
That's right.
So, two things I want to just make sure I button up here: one is free speech systems has no information other than what Mr. Halbig stated during his appearances as to what the bases for his statements are, correct?
Yes.
And two, his statement that EMTs were not allowed in the school is a statement of fact that was false, correct?
I think it is a statement of fact, and he is a statement of fact, but he said why he thought it.
So these are things that he was saying and trying to support, and he stated his reasons in support.
Now, you don't actually remember.
Do you remember whether he did that in this video, whether he stated his reasons in support?
I don't know if he did it in this particular video, but he's gone on about his quote: 16 points at very I said this in my other deposition.
He's expanded those over time.
There's at various points more than 16.
He also says in this video that they had sent police officers to his house not once but twice.
You recall that?
Let me review my notes.
I don't know if I wrote that down.
OK.
I don't have that in my notes, so I don't know.
Okay.
All right.
Let's go to the May 13th, 2014 Exhibit 56 Bombshell Sandy Hook Massacre was a DHS illusion.
Do you have that?
Yes.
All right.
This should be on chart A. Again, I have it.
Okay, thank you.
This was footage from Mr. Jones' show, correct?
Yes.
All right.
All right.
And in this video, Mr. Jones says, among other things, the whole thing, you've got him jumping the gun.
I mean, I think that's really big.
That Bloomberg was saying, get ready the day before.
Get ready to fundraise on mass shootings, you know, on your mark, get set, boom, pull the trigger too early, had a false start.
Didn't you blue me?
Right?
Mr. Jones said that, yeah?
Yes.
And what he's claiming there, again, as we discussed earlier, is a, what he's conveying to his audience is that Mike Bloomberg sent out an email the day before preparing to fundraise off the Sandy Hook school shooting that he knew would happen the day after, right?
Yeah, I think we talked about this.
I think we talked about this earlier.
And that was false that Mr. Bloomberg had done that, correct?
It was not accurate that that email was sent two days before.
And it was not accurate that it had anything to do with the Sandy Hook school shooting, correct?
Well, it had to do with shootings in general, but whether it was regarding specifically the Sandy Hook shooting, no, it couldn't have been specifically the Sandy Hook shooting.
And it didn't constitute any evidence at all that anybody had foreknowledge that Sandy Hook would be staged, correct?
Well, I think that's an opinion based, it's an interpretation and his opinion on that particular email.
Does Free Speech Systems think that it's reasonable That an email that Mike Bloomberg sent after the Aurora shooting months earlier about the Aurora shooting is evidence that Mike Bloomberg knew the Sandy Hook school shooting would later happen?
I think.
Objection is to form.
That's argumentative.
She's a spec witness, not an opinion witness, and precluded from drawing inferences before.
So I object as to form.
is what Mr. Jones said about well, you've already testified that what Mr. Jones said was inaccurate.
Is Mr. Jones's am I correct that what Mr. Jones is doing here is conveying to his audience that Mr. Bloomberg's email is evidence that Mike Bloomberg knew Sandy Hook was going to be staged?
Objection as to form?
Is the email is the email evidence that he knew about it?
That's what Mr. Jones said.
Beforehand.
Yeah, I think that's what his opinion on that email is, his interpretation of it, yes.
Right.
Mr. Jones also says refers to kids going in circles.
You're familiar with this particular claim of Mr. Jones, is correct?
Yes, he said it in a few videos, not just this one.
He suggested to his audience that video footage showed children going in circles around the Sandy Hook school and that was evidence that Sandy Hook was a drill, correct?
Whether it was a drill or staged or some combination of that, but yes.
Okay.
Well, a drill is nobody dies, right?
I don't know that that's accurate.
Okay, well, let me ask you.
I mean, Mr. Jones uses the term drill repeatedly in referring to Sandy Hook, right?
He has used the term, yes.
Okay.
And when Mr. Jones says drill in regard to Sandy Hook, he means that a government agency was doing a drill and that nobody was killed, correct?
No, I don't think that's what he means.
Okay.
And does it mean then when Mr. Jones uses that term, does it mean that people were in fact killed and killed by the government?
Objection.
Can I ask his objection, please?
Norm Penns.
Anyhow, I don't think it has anything to do with whether or not children died.
Okay, did you ask Mr. Jones about that, what he meant by drill?
I don't think I asked him specifically what he meant by that.
Okay, all right.
I mean, did you ask him at all what he meant by the term drill?
I don't think I did, no.
All right.
He would know what he meant, right?
Sure.
Okay.
But with respect to kids going in circles, okay, what was the basis for Mr. Jones's statement that children were going in circles around Sandy Hook school?
I think that this came from an issue where the children were perhaps at the firehouse, but I think he had seen or he remembers recalling seeing photographs of children walking in a line, kind of holding each other.
And it appeared to him as if they were walking in circles.
That may have been photographs from the fire station, the firehouse, not at the school.
I think there was an issue about that distinction.
Are you summarizing statements he made to you about this particular claim, or are you simply recalling what he did on the air?
I'm recalling what he did on the air in various videos.
Like I said, he's talked about this numerous times.
But you did not ask him specifically about his claim that kids were going in circles.
No.
How does Free Speech Systems now know that the only footage he showed in support of his claim that kids were going in circles was actually of the firehouse, not of the school?
I'm not sure.
I may have read something about it.
Okay.
I'm not sure.
But Free Speech Systems is prepared to concede that the only video that Mr. Jones ever showed to support his claim that kids were Going in circles around Sandy Hook Elementary School was in fact of the firehouse.
Yes, I think that's accurate.
And in fact, when he showed that video, Free Speech Systems had edited the video to make it appear that the children were going in circles, correct?
No, I don't think that's accurate.
That video wasn't edited at all when I don't know that we edited it.
Okay, so Free Speech Systems doesn't know whether it edited the video of children purportedly going in circles.
No, I don't know that we edited it.
Okay.
Who would know that?
I don't even know if Alex would know that.
Probably one of the producers, but generally those videos they would pull from another article, but I don't know where they pulled that video from, so I don't know who edited it.
I don't know if it was already edited when we got it or if we edited it.
I just don't know.
But you know it was edited.
I don't.
I don't know.
Okay.
I don't know where the video came from.
Did you testify in Texas in regard to a video published by Free Speech Systems purporting to show children going in circles as follows?
Question: All right.
I'm having a bit of the same struggle I'm having with Ms. Carpova's deposition, which is that, like any good lawyer, I come into this case, and there's honestly, there's a lot of things I don't know.
There are a lot of things I don't know, but more than average on a case that I don't know.
But there are a lot of things I do know, all right?
And one of the things is that that video did not come from the news media, all right?
That video, as I think you saw in that video, is very edited because it starts having the people go back and forward, back forward, back forward, all right?
And then it says in titles on the video, going in circles, all right?
Somebody made that video.
Answer, somebody edited that video.
Did you give that testimony?
Sure.
Okay.
And so.
I don't know who.
I don't know where the video came from.
I have no idea who.
And I think that's what I said in the testimony.
I don't know where it came from.
Correct.
You don't know where the video came from, but Free Speech Systems is prepared to acknowledge that the video it showed purporting to show children going in circles had been edited.
Well, I think it definitely is clear that it was edited because there was writing on it.
So somebody had to have added that writing on it.
So I don't know what extent it's edited.
I don't know what its original form was.
I don't know anything about the editing.
And you don't even know what Free Speech Systems edited it.
That's correct.
I don't know.
All right.
Let's go to May 14th, 2014.
And this is a video.
It should be on chart A, Ms. Paws.
Sandy Hook red flags ignored by the Newtown School Board.
Do you have that?
Yes.
All right.
This is a video you reviewed.
Yes.
There's a claim in this video that the Sandy Hook Elementary School had the highest levels of lead paint, PCP, and contaminated groundwater, correct?
Those are some of Halbig's claims, yes.
Mr. Halbig made those claims and Free Speech Systems published them, correct?
Yes.
And is Free Speech Systems aware of whether any of that is accurate?
No, as I testified earlier, we didn't do any research into his claims.
Okay.
Mr. Halbig stated in Free Speech Systems published his claim that 27 people had been declared legally dead within eight minutes, correct?
Yes, he said that a number of times.
Right, and that was not accurate, correct?
I think what he's referring to there, and he's cited it a few times.
Let me just stop you because that's non-responsive.
Sure.
The claim that Mr. Halbig made that 27 people were declared legally dead within eight minutes wasn't accurate, correct?
I think it's inaccurate, but I think what he was really referring to is the footage that was coming out early in the day about how many people were killed before everything was official, if that makes sense.
So there was.
It's hard to make sense of what Mr. Halbig says.
That's true.
Okay.
But are you, when you're describing, when Free Speech Systems here is describing what it believes to have been Mr. Halbig's rationale, are you taking that from videos you reviewed?
Right.
So from the videos that I reviewed, what he appears to be talking about is when you watch the initial news coverage of when he watched it or when anyone watched the initial news coverage and as is the case with any event or mass event, you know, people come on and give statements as everything is happening.
And so it would have been, you know, statements either by law enforcement or whoever giving updates to people as the day progresses.
I don't think that they were legally declared dead within eight minutes, but I think what he's referring to, like I said, are those broadcasts basically with people giving updates saying, here's what we think people are shot, here's how many people we think, that kind of stuff.
So a lot of what you were just saying right now appeared to me to be kind of your own personal interpretation of what Mr. Halbig may have said, and I want to be clear about what it is that Mr. Halbig said on the air to support this particular claim that the victims were declared legally dead within eight minutes.
And as you sit here, can you remember specifically what Mr. Halbig said on the air about his claim that the victims were declared legally dead within eight minutes?
I think he says at some point that he...
Okay.
Yes, I think that in one of these videos, I'm not really sure which, he says something to the effect of eight minutes in after the shooting is declared, after shots fired, he specifically references shots fired and the time of shots fired, and then how eight minutes later somebody's getting on to say X number of people are dead.
So he says that in one of these videos, but like I said, he's made that claim quite a few times.
Okay.
And Free Speech Systems acknowledges that it was not accurate.
Right, it's not legally accurate that they were legally declared dead eight minutes later, right?
Well, it's not accurate at all.
Right.
I want to ask you about the article Mr. Salazar wrote.
FBI says nobody killed at Sandy Hook.
You're familiar with this article.
I'm going to make a lot of the ingredients.
This was published by Mr. Salazar, I'm sorry, by Free Speech Systems on September 24th, 2014, correct?
I believe so, yes.
You asked him about this?
Yes.
And Mr. Salazar claims that he received a tip from an unknown person about this, right?
I think that that's what he said, and I did record it in my notes.
Well, that reminds me, actually, did you record any of your interviews with anybody at Free Speech Systems?
You mean audio recording?
Yeah.
No.
Did you memorialize them in any way other than your notes?
No.
Okay.
Did anybody that you're aware of?
Not that I'm aware of.
Okay.
And in his article, Mr. Salazar claimed that the FBI had reported in its 2012 statistics that nobody had been killed in Newtown in 2012, correct?
Yes, I think the article was that he went to the FBI.gov crime statistics for that year, scrolled down to Newtown, and there was a zero there for homicides for the year 2012.
This is what he said to you now.
You're telling me what he said to you?
Yes.
Okay, this is not what's in the article.
This is what he said to you.
He didn't say anything in his article about scrolling down, right?
No, I don't think he scrolled out.
He did post a copy of the table in the article.
Partial copy, right?
Yeah, I don't think it was, well, it couldn't be the whole copy just because there's dozens and dozens of towns.
So he screenshotted the section of Newtown and put that table in the article.
So I'm not asking you right now what the article says.
We have the article.
You've read the article?
Yes.
Okay.
Mr. Jones has discussed the article on his show?
Yes.
Okay.
But the headline of the article in so many words is that the FBI reported that nobody died at Sandy Hook in 2012, correct?
I think it's FBI says no one killed at Sandy Hook.
Yes.
Okay.
In 2012.
Yes.
All right.
And that, of course, wasn't true.
Right.
The FBI did report homicides in Newtown in 2012, correct?
Well, the problem was, according to that data, I don't know anything aside from what's in the article and in that table.
You didn't review the FBI statistics from 2012 in preparation for your testimony?
You mean did I go to the FBI.gov website?
Yeah.
No, I didn't go to the FBI.gov website.
I know what happened with the article.
Why didn't you?
Because I reviewed the material that was provided to me.
I didn't do any external research.
But okay.
But I mean, in your role as a corporate representative, don't you have an independent duty to discover the truth about the claims that Free Speech System has made?
Isn't that why you're here?
I think why I'm here is to report on what Free Speech knows.
Okay.
So if Free Speech knew it at the time, I don't think it knew it at the time because I think it knew what was in the article.
But Free Speech Systems now knows, right, that the FBI did report homicides in its 2012 statistics that Mr. Salazar cited.
I'll take your representation that it did.
I didn't do, like I said, I didn't go to the FBI.gov website.
Okay.
Okay, so as you sit here today, you have not information sufficient to testify as to whether the FBI statistics in 2012, in fact, did report homicides in Sandy Hook.
Right.
I thought you testified earlier that you knew that they did.
What I think I said in my earlier deposition was that the table that he posted in there had an asterisk and was qualified.
And if you scrolled all the way down, which he didn't, there was a reason as to why the number there was zero.
Because it was reported elsewhere.
That's correct.
Right.
And you read Mr. Salazar's deposition?
Yes.
Okay.
And you saw in Mr. Salazar's deposition that the FBI statistics, as they say, are drawn from statistics reported by the state of Connecticut, correct?
Right.
And that's clear in the material that Mr. Salazar viewed at the time, correct?
If that's what he said at his deposition, that's what he said.
All right, Free Speech Systems doesn't know that.
Apart from what he says in his deposition, no.
Okay.
But somehow you know that Mr. Salazar scrolled down but didn't scroll all the way down?
That's what he relayed to me in my conversation with him.
Okay, and in doing so, he was explaining why it was that he missed the fact that the FBI did report homicides in Sandy Hook.
Right, but had reported it someplace else, not necessarily there.
Him saying that if he had scrolled down just a little bit further, he would have discovered that, correct?
He would have seen the asterisk, right?
And of course, he would have never published the article.
Right.
Right.
As it stands, though, he did publish the article, correct?
Yes.
Okay.
And Mr. Jones highlighted the article on his show.
Yes.
Okay.
And Free Speech Systems is aware that, according to its own records, that article is between the years 2012 and 2019 is the article that was the third most popular article on Infowars.com that people landed on when they visited the site.
You know that, right?
I did review Google Analytics.
I'm not sure if it was the number three landing page.
I have seen Google Analytics, but I just don't recall.
Okay.
I mean, there have been a number of different spreadsheets showing Google Analytics data.
Do you recall seeing a document printed from Google Analytics showing that Mr. Salazar's article, FBI says nobody killed at Sandy Hook, was the third most popular landing page, article landing page during the time period, 2012 to 2019?
As I said earlier, I saw Google Analytics.
There were thousands of landing pages.
I don't recall whether that was the number three landing page.
Okay.
You saw Google Analytics print out that showed thousands of landing pages.
Right.
So it would have every landing, every article, every link to a video, every they all have their own unique landing pages.
So they would all, I saw a document with thousands of landing pages.
Some of and they were ranked.
You're correct.
I just can't recall whether that article was the third most visited landing page.
Thank you.
We go to the video of the Alex Jones show from September 25th, 2014.
This should be in chart A, Ms. Paz.
This is the show that Mr. Jones did the day after the article was published, correct?
Are we on the Sandy Hook red flags ignored by Newtown?
No, Sandy Hook deaths missing from FBI reports.
Oh, okay.
Let me just flip there.
Sorry.
Okay.
Maybe this one up.
Thank you.
Ah, here we go.
It's on the first page.
Okay.
Sorry, what was your question?
Yeah.
I just wanted to ask you to confirm that Mr. Jones highlighted Mr. Salazar's article regarding the FBI says no one killed at Sandy Hook on this particular episode of the Alice Jones Show, correct?
Yes.
And Mr. Jones titled that segment for upload, Sandy Hook Deaths Missing from FBI Report, correct?
Yes.
Okay.
Can we pull up the Google Analytics exhibit?
I don't know what it's numbered.
It's not numbered anything yet, so we can do 116.
Okay, we'll do 116.
Do you have it there in the folder?
You see it?
Okay, thanks.
This will be 116.
And Council, this has been an exhibit in other depositions.
What is it again, Chris?
This is the Google Analytics listing of landing pages between 2012 and 2019.
We do call it 116, sir?
Yeah, that's what it'll be.
Thank you.
Do you have it?
Oh, yeah.
Oh, it's up.
Great.
Sorry, I haven't seen it.
Is this, do you have this before you exhibit 116, Ms. Paz?
Yes.
Is this the document you were referring to earlier as the document you saw listing Landing pages for Infowars.com.
Can you scroll down?
This is only one page.
I think I said earlier.
Is there any way to make the type a little larger, Chris, or is this as good as it's Is that a little better?
I'll live.
It's not my depot.
I can read the transcript later.
Sure.
As I said earlier, what I saw had thousands of landing pages.
This is only one page.
It only goes to like, I don't know how far down it goes, but I saw something like this.
Okay, all right.
And at least according to this exhibit, you'll see that the do you know what the slash in the first listing represents?
Yes, that's the homepage.
That's infowars.com.
Right, so this is all infowars.com and then other landing pages on infowars.com.
So that's the homepage.
Right.
So the most popular way that people enter during this time period, which was 2012 sometime in 2019, the most popular way that people accessed the Infowars.com site was Infowars.com.
Right, they went there first.
The second most popular was the page at Infowars.com with the Watch Alex Jones show.
Right.
That's how it works.
And if you look here, am I correct that there are three pages specific to articles here in the top eight sites, correct?
The most popular.
So out of the, you mean out of the first top eight, whether, which ones are articles?
Right.
Okay, so number four appears to be an article.
I'm not sure what number six is because it says other.
Number seven appears to be an article.
Number eight appears to be an article.
Number eight is Mr. Salazar's article.
FBI says no one killed at Sandy Hook, right?
Right, that's what it looks like.
Okay, so assuming other is not an article, Mr. Salazar's article over the course of those seven years was the third most popular article that served as a landing page for people coming to Infowars.com, right?
As far as rankings, that's what it appears from the Google Analytics statistics.
Which are maintained by Free Speech Systems?
Well, we have access to it, so yes.
Okay.
And Google maintains it.
Google runs the world.
We've had a lot of, there's been a lot of discussion in this case about that.
But according to this document, of the people who landed on Mr. Salazar's article, 2.2 million plus were new users.
That is new visitors to Infowars.com, right?
Oh, you mean the under new users column?
Yes, we do.
Yes, that's what it appears, yes.
Okay.
And during this time period, people were accessing this particular article both directly and through links on social media, correct?
I mean, I can't tell from looking at this article how they're accessing it.
Okay.
Does Free Speech Systems know whether the article, FBI Says No One Killed at Sandy Hook, was shared across Free Speech Systems social media platforms?
I don't know.
I don't know the answer to that.
Who would know that?
Mr. Shirtuki?
I'm not sure.
Whoever was posting Tower's social media accounts at that time.
Do you know who that was?
No.
I'm sorry.
Do you know who Mr. Sertuki is?
I haven't spoken to him.
I'm not really sure who he is.
Okay.
Sorry.
All right.
We can pull that down.
Thank you.
Alright.
On December 12, 2014, Mr. Jones welcomed Mr. Halvey back onto his show for an anniversary edition of the Alex Jones Show, right?
Are you referring to 12-12-2014 Sandy Hook film censorship efforts backfire?
No, I'm referring to the broadcast entitled The Ultimate Sandy Hook Debate as the Second Anniversary Looms.
Oh, okay.
One second.
Which date was that?
I'm sorry.
December 12th, 2014.
Do you have that?
That should be in chart A. 12, 2014.
So on your exhibit 10, the 12-12-2014 video is titled Sandy Hook Film Censorship Efforts Backfire.
There's not another one for that date.
Sorry, I don't have it in front of me.
Oh, yes, it is.
Sorry, it's on the second page.
Okay, so let me just see if I can pull that one up.
Because I did review that, yes.
Mr. Balmer, when we were concrete, can you just tell me anything about what it's going to do with the moment?
Well, I think we did that as 116.
Thank you.
Yep.
Okay.
So yes, there was a debate.
Okay.
And Mr. Halbig was a participant, right?
Yes, Mr. Halbig and Keith Johnson.
Right.
And Mr. Dew hosted this.
Yes.
Okay.
And on this appearance and on other appearances, Mr. Halbig made the claim that one of the reasons Sandy Hook was a hoax was because it was in such deplorable and toxic condition that nobody would have been attending school at that time, correct?
That was his claim, yes.
And he made this claim in this particular appearance and referenced Don Hawksbrung, correct?
I don't know if in this particular video he makes that reference to the principal.
I know in subsequent places he may have said that the principal, I think he said the principal was female.
I don't think he knew her name and she would never have allowed her school to be in such deplorable conditions or something to that effect.
But I don't know if he said it in this particular video, but he has said something to that effect.
I'll represent to you that in this particular appearance, Mr. Halbig referenced Ms. Hawksbrung by name.
Free Speech Systems knows that Don Hawksbrung was the principal of Sandy Hook Elementary School, correct?
Yes.
And that she was murdered there while protecting children in her care, correct?
Yes.
And Mr. Halbig on this particular episode, after having claimed repeatedly that Sandy Hook was a hoax, said of Ms. Hawksbrung, Don Hawksbrung, who supposedly was the principal and was shot on December 14th, 2012, I can tell you this with certainty, being a female school principal, Don Hawksbrung would have never, ever in her lifetime have allowed her school to look so filthy and so deplorable.
She would have never allowed her school to become a toxic waste dump, exposing every one of her children and school staff members to serious lifelong health risks.
The doors are rotten.
It's filthy.
They've got mold, mildew.
Look at the outside.
It's deplorable.
Mr. Free Speech Systems broadcast those comments by Mr. Halbig on that day, two days before the second anniversary of the shooting, correct?
Yes, those are his opinions on how the school looked at that time.
He'd never visited the school, correct?
I don't have any information to suggest that he's ever been there.
I believe he cites to photographs that he believes supports those opinions.
Free Speech Systems, as of this time, had no reason to believe Mr. Halbig had ever been to the school, correct?
I don't have any reason he's ever been there to know he's ever been there.
But the reason Free Speech Systems is aware that he made this claim in support of his assertion that Sandy Oak was a hoax, that being a toxic waste dump of a school, would not have been open and therefore children would not have been present and therefore the shooting didn't occur, correct?
Am I aware that he's made these claims?
Free Speech Systems understands that the reason Mr. Halbig was making this particular claim about Sandy Hook School being a toxic waste dump was to show that the school was not open and the shooting was a hoax.
I believe that that was part of the reason why he mentioned that particular issue to begin with, so yes.
And Mr. Jones has repeated the claim that the Sandy Hook Elementary School was not open in the year prior to the shooting, correct?
He has said that the school wasn't open, but I don't think he's ever subscribed to this ideology or opinions on the state of the school.
Well, his are you prepared to testify to that?
That Mr. Jones has never commented on the condition of the school?
I don't recall him commenting on it.
I know he has commented on the school not being open.
But specifically the condition.
Specifically the condition, I don't recall him saying that.
So Free Speech Systems cannot testify today, one way or the other, whether Mr. Jones ever commented on the condition of Sandy Hook School.
Right.
If you want to point me to a video, I'm happy to look at it, but that's right.
And with respect to the claim that the school was not open, Mr. Jones was, was Mr. Jones relying on Mr. Halbig for that claim when he made that claim?
I think that the reliance on that claim, and we went through this in my other deposition, and I believe that Alex has testified to this issue as well as to where the source of that claim was.
And I think Daria may have testified to it in her deposition as well, but the source of that claim when Alex was talking about it was the website, the school website, and time machine, the time machine, as being the source of his claim that the school was not open.
I recall.
I recall your testimony about that.
I'm going to ask you about that.
And so let's just be clear then.
Mr. Jones, over the course of several years, repeatedly asserted that the Sandy Hook Elementary School had been closed in the time prior to the shooting, correct?
Yes, he said it a few times, yes.
He said that a few times, and each time he said it, the basis for his statement to that effect was the Wayback Machine purporting to show web traffic to a certain website, correct?
Right.
He never relied on Mr. Halbig's similar claims as to why the school was likely closed.
Right.
Well, the source of Halbig's claim is the condition of the school.
I don't think that in Mr. Halbig's broadcasts he mentions the Wayback Machine ever.
Okay.
Mr. Jones had his own independent basis for saying that the school was closed.
Right.
Which, of course, was false.
Free Speech Systems acknowledges.
That the school was open?
The school was open, correct?
Right, yes, it was.
It was open consistently from every year from, let's say, 2000 to 2012, Sandy Hook Elementary School was open and kids were enrolled and attending, correct?
The school was open, yes.
Okay.
So when Mr. Jones made the claim several times that the school was closed, it was inaccurate and it was based according to Free Speech Systems on a Wayback archive of a website.
Right.
So that's where the source of that knowledge was the Wayback Machine website, right?
And Mr. Jones got that.
He didn't go out independently and go check the Wayback Machine, did he?
I don't know.
We talked about this at my last deposition.
You said I don't know.
So I don't know whether he got there, is my point.
Fair enough.
And you didn't ask him.
No, I know he ultimately did visit or had showed on his screen a Screenshot of the Wayback Machine.
So he did broadcast that in one of his, at least one of his broadcasts.
He put it on the screen.
He didn't prepare his own screenshots, did he?
Somebody else would have done it.
No, he would ask his producer to do that for him.
So is he pulling that for himself?
No, he would have said, I want this, pull it for me.
But Free Speech Systems, as it stands here, as it sits here today, has no idea how Mr. Jones came to learn of any sort of Wayback archive associated with a website.
How did it come to his attention?
No, I don't know how it came to his attention.
No.
Okay.
You're aware that Jim Fetzer in his book, Nobody Died at Sandy Hook, referenced that same Wayback archive.
Are you aware of that?
Yes.
Okay.
Have you read that book?
I did not read the whole book.
I skimmed through it.
But you're not prepared to say whether Mr. Jones got it from him.
I am prepared to say he didn't get it from him.
Mr. Jones clearly indicated he did not read that book.
He does not even like Jim Fetzer.
According to him and my conversations with other people, he did not get it from there.
Okay.
I mean, Mr. Fetzer was in contact with Rob Dew and other Free Speech Systems personnel during the time period we've been talking about, right?
Yeah, he very well may have been, but that doesn't mean that Mr. Jones was.
Mr. Fetzer asked Alex Jones to promote his book, Nobody Died at Sandy Hook, correct?
Oh, I don't know.
I don't know if he asked Mr. Jones anything.
I know they didn't really have a range.
Many speech systems doesn't know whether Jim Fetzer asked Free Speech Systems to promote his book.
I don't know that.
Okay.
And Free Speech Systems is unaware of communications that Rob Dew had with Mr. Fetzer about the book.
I don't recall reading anything like that, but I might have seen it.
I don't know.
All right.
Is Free Speech Systems aware that the website as to which the Wayback Archive purported to show no activity was not a website associated with Sandy Hook Elementary School?
I don't know.
Just going to ask you about another video published on December 12, 2014.
Sandy Hook film censorship efforts backfired.
Do you recall this?
This is the independent media documentary we were talking about a little bit yesterday.
We had some confusion.
Let me just pull that up.
Ah, here we go.
This is the video yesterday.
I think where you were suggesting that, according to your notes, may have been published on January 27, 2013.
We have a stipulation now that it was published on or about December 12, 2014.
I have that in my notes.
Oh, you do?
Yeah.
Well, that would have saved us a lot of trouble yesterday.
Well, because the difference, that's why I asked for the ID number, because the ID number is really how they save everything.
So this ID number is 4T8 underscore W yada yada yada.
Can we skip out those ID numbers actually?
Sure.
Are those the numbers associated with the YouTube upload of those videos?
You know what?
I'm not sure.
I don't know where that tracking is.
I'm sorry.
Okay.
All right.
In any event, on December 12th, 2014, Mr. Dew hosted two people who claimed to be documentary filmmakers, correct?
Yes.
And they were not identified by name during the broadcast, correct?
Right.
They chose to stay anonymous.
Do you know if their identities were known to Mr. Dew?
I don't know.
Okay.
So as far as Free Speech Systems is concerned, Mr. Dew may have had these people on his guests without even knowing who they were.
Sure.
Okay.
All right It's 215 we were started back at one right.
How you doing you all right?
I can use a potty break.
Okay.
If that's okay.
Yeah, you want to say five ten minutes?
Is that okay?
Great.
All right.
Thank you.
We are off the record.
The time is 2.16 p.m.
EST.
We are now on the record.
The time is 226.
Ms. Paz, I want to go back to the emails we were discussing earlier between Mr. Heath and Mr. Salazar.
You recall these emails in which Mr. Heath was raising concerns about Mr. Halbig's credentials.
His initial email, Mr. Salazar responded that it was too vague to follow up on.
And then Mr. Heath sent a subsequent email and your testimony was that you had not previously seen that second email from Mr. Heath, correct?
Yeah, I don't recall having seen it.
Okay, right.
Is that up on the screen for you now?
Yes.
All right.
If we look at page three of your type notes of exhibit 102, you'll see a note after exhibit 17 where you note, received email advising to check Halvig's credentials March 14th, 2014 to writers at infowars.com.
Adon responded asking for more specifics and then the person replied.
This suggests that you had, in fact, previously reviewed the second email from Mr. Heath, correct?
I think, yeah, so this is from my notes from Daria's deposition.
And what this says to me is that I don't know whether I had reviewed that email, but I reviewed the deposition and they had talked about it there.
So I don't know whether I saw the email or I just saw them talking about the email.
Okay.
So I don't know if that's what that means.
So your prior testimony that you had not seen the email may be inaccurate.
You just don't know whether you saw it.
I don't know whether I saw the actual email.
What this means to me is I saw her testifying about it in the deposition.
Okay.
Regardless of whether you saw the email or not, you were at least aware of it, correct?
Sure, according to my notes.
And you made a note to yourself to ask whether it was ever followed up on who saw this besides Adan, correct?
That was my note, yes.
And so did you ask Adan Salazar what he did in response to the second email from Mr. Heath?
I don't remember if I asked him.
Okay.
I'm not sure.
At least from your notes, that's what you intended to do, correct?
Well, I made myself a note to ask.
So.
And if here, I'll just grab it.
So if we look at your handwritten notes that you produced today, What page was that?
Okay.
So if we're looking at your handwritten notes, we just brought them up.
These are the notes you produced today.
There's a note which I believe corresponds to your type notes here in which you say, don't know if Adan followed up.
Ask Adan, right?
Right.
So that's specifically related to that section of Daria's testimony around page 202.
She's testifying as to this particular email chain.
Right.
And ask Adan.
Right.
So, my question to you is: you made a note to yourself to ask Adan whether you followed up on Mr. Heath's second email, but as you sit here today, you can't remember whether you did or not.
Yeah, I don't remember if I did or not.
Okay.
If it's not my notes about my conversation with him, then I don't recall.
All right.
All right.
Thank you.
When we left, we were talking about Mr. Dew's hosting of two purported documentary filmmakers who had made a documentary about Sandy Hook.
What was the title of that documentary?
I believe it was We Need to Talk About Hook.
Maybe we need to talk about Sandy Hook?
What I have written here is that we need to talk about Hook.
Okay.
That's what it says.
Have you watched that documentary?
No.
I watched this video on the interview, but I didn't watch the documentary now.
Okay.
And Free Speech Systems actually published the documentary on its website, correct?
Yes, I believe it did, yes.
And the reason it did that is because the documentary had been pulled down from other websites where it had been published, correct?
I don't know if that was the only reason, but it was a reason.
That was one of the reasons, right?
The documentarians wanted to make sure people saw it, and because people were having trouble seeing it as it was being pulled down, they asked Free Speech Systems to publish it, correct?
Sure.
And Free Speech Systems agreed to do that.
Yes.
And Free Speech Systems was aware that the reason it was being pulled down is because of the inaccurate claims it was making about Sandy Hook.
I don't know if it was aware of the reasons it was being pulled down, but I think they knew it was being pulled down.
So your testimony is that Free Speech Systems was unaware of why this documentary was being pulled down from other places on the Internet?
I think what I said was I don't know if they were aware of why it was being pulled down.
Right.
So Free Speech Systems doesn't know whether it was being pulled down because it contained inaccurate information about the Sandy Oak shooting.
I just don't know either way, right?
Okay.
And before agreeing to publish the video, did Free Speech Systems do anything to investigate why it was being pulled down from the rest of the Internet?
No.
One of the claims of these.
Does Free Speech Systems know the identities of these documentarians today?
I don't know who they are, no.
Okay.
So one of the claims that these anonymous documentarians made on this particular day was that memorials had been set up in honor of the victims of the Sandy Oak shooting prior to the shooting itself, correct?
I think that was a claim specifically related to Ms. Soto, but yes, it was a Facebook, Facebook memorial page.
Yes.
So the claim was that was the claim that Vicki Soto, by the way, do you know who Vicki Soto is?
Yes, she was one of the teachers.
She was murdered there.
Yes.
And her mom and three of her siblings are plaintiffs in this lawsuit.
Are you aware of that?
Yes.
And are you aware that Vicki Soto was murdered as she was trying to protect the children in her care?
Yes.
And according to the anonymous documentarian that Free Speech Systems hosted, somebody associated With Ms. Soto had published to Facebook memorials to her death before she died, correct?
That's the claim that they were making, yes.
Okay, and the claim, the reason that they were making that claim was evidence that Ms. Soto hadn't died at all, correct?
I don't think that that's accurate.
I don't think that's the reason for that, no.
What's your basis for saying that's not the reason?
I don't think that just saying this was published the day before the shooting ipso facto means she didn't die.
Well, first of all, Free Speech Systems has no idea, number one, whether that's true or not, right?
That a memorial was posted to Facebook in honor of Vicki Soto prior to her death.
No, Free Speech didn't investigate that claim at all.
Does Free Speech System today maintain that there was a memorial set up on Facebook in honor of Vicki Soto prior to her death?
I don't know one way or another.
I didn't look into it anyway.
Okay, so Free Speech Systems today doesn't know whether a memorial in honor of Vicki Soto was set up on Facebook prior to her death.
I think that I saw some documents.
I saw some documents related to why they were making this claim as to the date.
What documents did you see?
I want to say I saw an article about it.
And it wasn't just these people that were citing to this particular issue.
Hang on a second.
Right.
Okay.
The question that I've asked you is whether free speech systems can testify today whether there was a Facebook memorial set up for Vicki Soto in honor of her death prior to her death.
And my testimony is that this is not just based on this particular individual.
There were also other articles that were making these claims.
I'm going to move to that.
And so I didn't.
Yeah, I'm just going to move to strike that.
I'm just going to stop.
I'm just going to stop responding.
Thank you.
So let me just have my question read back again.
The question I asked you is whether Free Speech Systems can testify today whether there was a Facebook memorial set up for Vicki Soto in honor of her death prior to her death.
I don't know.
Okay.
And I believe you testified earlier, though it may have been in the middle of one of your answers that Free Speech Systems did nothing at the time it aired this nor since to investigate that question, correct?
Right.
But But when the anonymous documentarian made that claim in this video, Mr. Dew agreed with it, correct?
I don't know whether he agreed with it.
I don't have any notes about that, so I don't know.
Okay.
If it's in the video, it's in the video.
Okay.
And so you wouldn't know to the extent Mr. Dew agreed with the proposition that a Facebook memorial had been set up in advance of the shooting.
You don't know what the basis for his agreement would have been.
You mean the basis for why he would have done that?
Claimed that I don't know whether it's based solely on the documentary or based on the articles that he had read, because as I was trying to say earlier, there are some articles that are in the possession of free speech noting this particular issue as well.
So it could have been a combination of those.
You don't know.
Or it could have been something completely different, right?
I don't know what else it would have been, but.
Because you shouldn't ask Mr. Dew.
I didn't ask him specifically about that, no?
Or at all.
I didn't ask him about it.
No.
Um Um So I want you to go to a video published December 28th, 2014.
This would be on chart B, titled Air Asia Jet Missing.
I'm sorry, could you please repeat the title?
Air Asia Jet Missing.
Did you review that video?
Okay.
You're familiar with Mr. Jones' statements that the Sandy Hook shooting is a giant hoax and a total hoax, correct?
Yes.
You're aware he made those statements.
Yes.
Okay.
And you've seen that in videos.
Yes.
All right.
And if you go to on chart B of Exhibit 10, the January 13th, 2015 broadcast, did you review that video?
January what?
13th, 2015.
No.
Okay.
But you're aware that Mr. Jones has made statements on the air that Sandy Hook is a synthetic, completely fake with actors, in my view, manufactured, correct?
I've heard him made those opinions on the Arias.
Okay.
And when Mr. Jones said Sandy Hook is a synthetic, completely fake with actors, that's one of the instances you testified earlier in which Mr. Jones was asserting that nobody had died there at all, correct?
No, not necessarily.
Okay.
Do you know or don't know?
No.
It's no, that's not what it means.
Okay.
Based on my conversations with him, that's not what he's claimed on the whole, so no.
Okay, but that's what he was claiming there.
No.
But that's not what he was.
There, when Mr. Jones says Sandy Hook is a synthetic, completely fake with actors, in my view, manufactured, what he's really saying is that 26 people were murdered there.
That people were murdered there or weren't murdered there?
You tell me.
I want to know what your question is.
Objection.
Well, is Mr. Jones, when he says Sandy Hook is a synthetic, synthetic, completely fake with actors, is he saying that 26 people were murdered or not?
Objection.
I don't think he's referring to whether people were murdered or not.
I think he's saying that.
Well, you say you think.
What are you basing this on?
A conversation with the people?
Conversations with Alex based on his comments on the whole.
I've had a couple of conversations with Alex, and that's not what he was saying there.
I don't think he was referring to the deaths of the people at all.
Okay, well, who are the actors?
Well, we went back, we talked about this earlier today.
What I'm asking about this one, this one in January of 2015.
Who are the actors here?
Well, we talked about earlier today.
I'm not really sure who he's referring to as actors, so I don't remember.
But you're sure he's not saying that nobody died.
You're sure of that.
But you don't know who he's referring to with actors, right?
I'm not sure.
And I don't want to make an inference, as I said earlier.
Right.
And when he says it's completely fake, what is he saying is fake?
What he's saying is fake is in the sense that he believes, in his opinion, that it was set up by the government.
So the government murdered 26 people?
That it was set up that way, not necessarily that nobody died.
Okay.
Maybe people died, maybe people didn't die.
Is that what you're saying?
Well, I think he said over the course of a few videos where he's not sure either way, and he's not taking a position either way.
He said that a few times.
But as you testified earlier, he has also said that nobody died there, right?
Once or twice, yes, but on the whole.
But this isn't one of those times.
This is a different time.
Right.
He doesn't say there that nobody died.
He just says it's synthetic, completely fake with actors and manufactured, right?
I believe that's a direct quote, yes.
Okay.
And when, and free speech systems can't say who he's referring to when he says actors, right?
I think that's what I said.
I don't want to make an inference.
I can make an inference if he'd want me to, but I don't want to do that.
Okay, but he also says, I couldn't believe it at first.
I knew they had actors there, clearly.
But I thought they killed some kids.
And it just shows how bold they are, that they clearly use actors.
I mean, they even ended up using photos of kids killed in mass shootings here in a fake mass shooting in Turkey.
So isn't Mr. Jones suggesting here that while he previously may have thought some kids died, he now is stating that none did, that it was completely fake?
I'm not sure.
I haven't reviewed this video.
I think I already said that, so I'm not sure how to answer that.
Okay.
So maybe Free Speech Systems isn't in a position to answer any questions about that video today.
Is this still the video on January 13th, 2015?
What's the title of the video?
Ron Paul, Kurt Haskell.
Yeah, I don't think I reviewed this video.
I mean, I'll double-check, but.
All right.
Oh, here we go.
It is.
It's on my very last page.
I reviewed the transcript of this because I didn't have the actual video.
Okay.
So it's on pretty much like the last couple of pages of my notes here.
Okay.
So the question was.
The question I just asked you was whether Free Speech Systems isn't really in a position to answer any questions about this video because you haven't reviewed it.
But now you're saying that you read it.
Yeah, I read the transcript of it.
So I don't have any question pending right now.
Okay, go ahead.
Let me ask you, You had not reviewed the transcript when you spoke with Mr. Jones, correct?
This particular transcript?
Right.
I don't think so.
I think I read this recently.
All right.
Because I didn't have the video, but I was able to find the transcript.
So if you look at the video published on February 12, 2015, this should be in Chart B, free speech.
SH Victim Dies Again in Pakistan.
Okay.
Yeah, that you don't happen to know if it has an ID number, do you?
Nope.
I know of that broadcast.
I'm not sure if I reviewed the video because it doesn't have an ID number on it.
So let me see if I have it on this list.
All right.
I'm not sure.
I'm not sure if I reviewed it or not, but what's your question?
I'm familiar with the claims made in that, in the article.
You're familiar with Mr. Dew's claim about the actor father who comes out and gets into character?
Yes.
Okay, the actor-father that he's referring to is Robbie Parker, correct?
Yes.
And then Mr. Dew states in that video, and then he's totally sad, crying, and he was cracking jokes right before that's an actor, that's an actor.
He's talking about Mr. Parker.
Yeah, that was Mr. Dew's opinion.
And one of the reasons you know he's talking about Mr. Parker is because they were airing footage of Mr. Parker's press conference, correct?
Yes, I believe so.
Okay.
And All right.
Just trying to get my notes organized here.
In 2014, did Free Speech Systems receive an email from Mr. Halbig attached to which was a photograph of the Sandy Hook choir performing at the Super Bowl?
I believe so, yes.
I think I've seen something like that.
And the photo was annotated by Mr. Halbig, correct?
You mean the names that are superimposed on the photograph?
This is the photograph you've seen, correct?
Yes.
I don't know if he superimposed those names, but he did attach a photograph with names superimposed over the photo.
And in doing so, Mr. Halbig was informing Free Speech Systems of his claim that the children who had been purportedly murdered at Sandy Hook were actually alive and had performed at the Super Bowl as part of the Sandy Hook Choir, correct?
I think that's the claim he was making.
Okay.
And he conveyed that to Free Speech Systems?
Via email.
I'm not sure if anybody read it or responded to it, but it's in our material, yes.
Nico didn't respond to it?
I'm not sure.
You don't recall seeing an email in which Nico responded referencing the Super Bowl?
I don't remember.
Free Speech Systems can't testify as to whether anybody saw that, correct?
I don't know.
If you want to show me a document, I could review it, but I don't remember as I sit here whether anybody responded.
That claim in which Mr. Halbig sent a photograph of children just two years after the shooting, in which he claimed that same children who had died were alive and appearing in the Super Bowl, was a claim that Free Speech Systems could have easily investigated if it wished, correct?
I guess I don't understand your question.
Could we have?
Sure.
But would we know?
I mean, that seems like an easy thing to debunk, right?
Look at the picture and figure out whether any of those children were children that were murdered, right?
I don't believe we ever aired that particular claim of his.
I didn't ask you whether you aired it.
So why would I investigate if I wasn't going to air it?
Well, you might be interested in assessing whether somebody you had on repeatedly was making an insane claim that children who had performed in front of an audience of millions were in fact the same children that had been killed two years earlier.
But that didn't occur to Free Speech Systems, correct?
Speculative might.
I don't think we would be interested in doing that because by that time he wasn't even coming on the show anymore.
In 2014, when he sent that photograph?
Well, you just said by that time he wasn't coming on the show anymore.
So what's on my phone?
I thought it was possible.
I thought you said 2015.
That's what I thought you said.
So I thought, that's what I thought you said.
I thought he sent that Super Bowl picture in 2015?
I'm not sure.
I thought that's what you just said.
Okay, but if it was sent in 2014, he absolutely was on the show after he sent that photograph, right?
I don't know when he sent the photograph.
I'm telling you, if it was sent in 2014, he absolutely was on Free Speaker System.
He was on in 2014, yes.
And in 2015 he was on, wasn't he?
He was on regarding the FOIA hearings in 2015.
Right.
Right.
So I don't know when the email was sent.
Um...
Let's go now.
Did Mr. Jones do deep research on Sandy Hook?
Jackson.
Jackson has the form.
I know he has said he did deep research.
Did he say that to you?
I know he said it in the videos.
Did he say it to you?
I don't think he said it in my conversations with him, but I've seen him say it in the video, in one video.
So is Free Speech Systems prepared to testify here today that Mr. Jones did deep research on Sandy Hook?
Objection.
I don't know what he did, what he would term deep research.
Okay.
So no.
Okay.
You familiar with the video Free Speech Systems published on March 4th, 2015?
This will be in chart A, new bombshell Sandy Hook information inbound.
I'm sorry, what was the date?
March 4th, 2015.
March 4th, 2015.
Yes.
And you're familiar that in this video, Mr. Jones said that the Sandy Hook school had received a failing report and did not had received a failing report in reference to the condition of the school.
You're aware of that?
You're asking if Mr. Jones said that or Mr. Halbig said that.
Yeah, I'm asking whether Free Speech Systems is aware that in this video, which you reviewed, correct?
Yes, I did.
I'm reviewing my notes right now.
Mr. Jones indicated that prior to the shooting, Sandy Hook School had received a failing report and then was suddenly reopened.
Uh...
School suddenly reopened and then tore it down.
School is filthy, right?
These are repeating Mr. Halbig's claims.
So yes.
Okay, but what about Mr. Jones saying that the school received a failing report?
I don't have anything in my notes about failing report.
I mean, I'll accept your representation.
That's what was said.
I don't have a direct transcript of it right in front of me.
Earlier you testified, I think, that Mr. Jones, you were not, Free Speech Systems was not aware of Mr. Jones ever commenting on the condition of the school, correct?
Yes, I didn't remember whether he had said anything about the condition of the school and whether it was dirty or not.
Okay.
And I take it that Free Speech Systems testimony now is to the extent Mr. Jones made statements concerning the condition of the school, he was relying exclusively on Mr. Halbig.
Right, he was referring to the claims that were being made by Mr. Halbeg.
Well, you didn't ask him about this, did you?
I didn't specifically ask him about it, but that's what he was basing his opinions on.
So he's saying, but these are, you say, opinions.
Mr. Jones is the one who's saying that the school received a failing report, right?
Well, Mr. Jones is repeating what Mr. Halbig was already saying about whatever failing report it is.
I don't know what report he's making, but a school being dirty or not dirty is an opinion statement.
So Free Speech Systems has no idea what report Mr. Jones was referring to, right?
I don't know what report he's referring to.
Okay.
Mr. Jones also says during that broadcast, they bring in actors to break down and cry, right?
actors.
Again, using the plural.
The same actors to break down and cry, I think is the quote.
Is that what you're referring to?
Yeah.
Okay.
Yes, I see that.
Actors.
Who's he referring to there?
I don't know.
He doesn't say.
Okay.
And he says they used the same actors as different people.
Do you recall that?
My notes in this segment just say maybe they're real parents or whatever, but when you have someone who is smiling, who is laughing and smiling, that seems to be a reference to the Robbie Parker interview.
As far as anything other than that.
I just want you to, what I'm asking you is whether you recall in your review of this video that Mr. Jones said that they had used the same actors as different people.
My quote that I wrote down is a very important thing.
I asked you what you recall.
I'm not asking about your quote that you wrote down.
So what I recall is based on my notes to refresh my recollection, which is it says, same actors to break down and cry and it's stupid, so stupid to use the same actors.
So that's what I recall as to the quote.
Okay.
So that's not what I said, right?
So you don't recall.
I'm exactly the same.
You don't recall what I said.
Right.
Okay, appearing there.
And so you're not in a position to say who Mr. Jones was referring to when you described the same actors as different people.
Right.
Okay.
Was Mr. Parker playing different characters?
I don't know.
He doesn't say specifically.
Okay.
Was an actor playing the role of David Wheeler and Bill Aldenberg?
He doesn't ever reference those people.
Okay, so Free Speech Systems doesn't know if that's who he was referring to?
I don't even think he knew of those people.
BECAUSE HE NEVER EVEN MENTIONED THEIR NAME.
Hold on a second.
Free speech systems testimony is that Mr. Jones was never aware of who David Wheeler was?
I don't know if he knew anybody's actual names aside from Mr. Parker.
You just said you don't know whether.
But before that, you testified that Mr. Jones didn't know these people.
So what I'm trying to understand is from Free Speech Systems perspective, okay, can Free Speech Systems testify one way or the other whether Mr. Jones was familiar with an individual named David Wheeler?
I don't think he knew anybody's name.
And the reason why I say that is because when I spoke to him, he even said, I didn't know any of these people's names.
So he never mentioned anybody's name, so he wouldn't have known any of these people's names.
Well, he didn't actually mention Robbie Parker.
Except for Robbie Parker, because he specifically mentions his name in connection with that statement.
He certainly knew Don Hochsbrung because Mr. Halbig had mentioned her name with him, correct?
I think he did mention, yes, the name once on one of his interviews, maybe twice.
But in his statement to you that he knew you would repeat in your sworn testimony, he said to you that he didn't know any of the names of my clients, correct?
I think what he said to me was he had never said any of their names before.
Okay, well that's different than whether he knew them or not.
I don't know what he said.
I just ask you to be precise in your testimony as Free Speech Systems.
Okay?
If in fact Mr. Jones had told you that he had never said any of their names, that's false, correct?
He had said their names on the air.
He had said Robbie Parker's name on the air.
Right.
And Mr. Halbig had said the principal's name on the air.
Okay.
So Mr. Jones' statement to you that he had never said my clients, any of the victims' names on the air, is inaccurate, correct?
Judge.
I don't think that that's accurate.
So he never, I don't think he ever said anything about the Wheelers.
I think the only people he mentions are Robbie Parker, and he does speak about Mr. Posner a few times.
He had that interview with Veronique De La Rosa, so he acknowledges those things.
But aside from that, With Mr. Wheeler and the other plaintiffs, his position was that he didn't even mention their names.
I don't want to get too bogged down in this.
Sure.
But you've said a couple of different things about what Mr. Jones told you about these people.
So I just want to now make clear.
Did Mr. Jones tell you that he didn't know the names of any of the victims?
Not any of the victims, no.
Okay.
Did he tell you that he didn't know the names of some of the victims?
Yes, because he said he'd never even used their names before.
So some of them are not.
Okay, but that's different, as you all know.
Whether he used their names is different from whether he knew their names.
I don't know what he knows.
Okay.
So Free Speech Systems does not know and cannot testify as to whether Mr. Jones knew any of the names of the victims other than the ones he mentioned on the air, correct?
Other than what he says on the air, that's right.
Okay, thank you.
Did Mr. Jones tell you that he had never mentioned any of the names of the victims on the air?
Most of them, aside from the ones that he has already mentioned, that we talked about.
So he said I never mentioned most of the names on the air.
That's what he said to you.
Most?
Yes?
I think so.
I think that's an accurate description of our conversation.
Yes.
So Mr. Jones conveyed to you that he had never said most of the victims' names on the air.
Aside from the ones that we've already talked about, right.
Okay.
Yeah.
You were the notice of deposition asked that you be prepared to discuss Free Speech Systems closed captioning system and transcripts that were generated from it, correct?
I did see that on the notice, yes.
Okay.
And are you prepared to discuss that?
I'm prepared to discuss the inquiries I made about it, yes.
Okay.
First of all, tell me during what period were closed captioning transcripts created for the Alex Jones show?
So based on my communications, I did email Daria and she did put me in contact with CJ, I believe.
It was a very short period of time, maybe 2015 to 2016.
Okay.
And I did try to ask Mr. Rowe if he could pull any of our accounting to see who we paid for that, but he couldn't pull that information.
So I don't know the name of the company that did that for us.
So you emailed Daria?
I emailed Daria.
From what email address?
From my email address.
Which is what?
Brittany at pazlawllc.com.
Who else did you email with at Free Speech Systems?
Regarding this?
Regarding this issue?
Well, no, altogether.
I've not previously heard that you emailed with people.
Well, I mean, I had to communicate with people.
You've not previously testified that one of the ways that you communicated with people at Free Speech Systems was by email.
You didn't ask.
I'm asking now.
Okay.
So who did you communicate with by email?
I think I emailed Melinda.
I think I've emailed with Mr. Rowe.
Well, he's a contractor, but I think I've emailed with Mr. Rowe.
Had a couple of Zoom interviews set up via email with Rob Dew and with Mr. Watson.
I've previously testified to that.
I've spoken to counsel via email.
I spoke to Daria via email.
Okay.
We asked for any and all non-privileged communications sent or received by you in your capacity as a designee, and we've not received the emails that you've just been referencing.
Did you retain them?
I have my emails.
Okay.
So, Council, those should have been produced.
So will those behavioral?
My attention lasts for a minute, Chris.
I'm sorry.
What are we talking about?
Ms. Paz has testified that she communicated with Free Speech Systems employees in connection with her work as the corporate representative.
And those emails have not been produced, and we haven't received a privilege log pertaining to them.
So, we're going to need to have those.
I'm going to have to explore that.
I don't have anything to contribute on that.
You're certainly entitled to them, and we will deal with that after the depot, Chris.
Thank you.
I just ask that you preserve those, please.
All communications.
Thank you.
Sure, I still have them.
Did you communicate with anybody via text message?
I don't know.
I'd have to look through my email, my text messages.
Okay.
I don't know.
To the extent you did, you've not deleted any text messages, correct?
No.
Okay, so those are preserved on your phone.
Right.
I don't delete text messages ever.
That's not true of everybody at Free Speech Systems.
All right.
I kind of forgot where I was.
I could say objection, but Touche might be more of a question.
That was in jest.
That was in jest.
Yeah, that was not a question.
Okay.
Pardon me.
All right.
So I was just trying to remember where I was when we got off on the emails.
I was asking you, I was trying to ask you about the closed captioning transcripts.
Right.
All right.
And it sounds like free speech's testimony here today is that it is not sure when it first started creating closed captioning transcripts.
Is that correct?
No.
Based on what I've been able to ascertain, it started probably in 2015, but only lasted about a year.
But my contacts were just not sure what the name of the company was, but it was short-lived.
It was only for about a year.
Okay.
All right.
So the answer to my question is that Free Speech Systems sworn testimony is that it started creating transcripts of the Alex Jones show sometime in 2015.
That there were transcripts in that time period and then started.
I think, yes, from what I was told and my contacts in the company, that's what my information was.
Okay.
2015.
Okay.
So somebody told You that Free Speech Systems started creating closed captioning transcripts sometime in 2015.
Right?
That somebody is Daria Karpova.
No.
That somebody is who?
CJ.
CJ Who.
Well, we're going to give you the email so you could look in the email.
I don't know his last name.
I don't know his last name.
Who's his position?
I'm not sure.
Daria Karpova told you to contact him.
Yes.
So you don't know who he is or his position at Free Speech Systems, but whoever he is, he told you that Free Speech Systems started creating closed captioning transcripts of the Alex Jones show in 2015, sometime in 2015, right?
Yes.
Okay.
And that's Free Speech Systems testimony today.
That's the information that's available to me today, yes.
Okay.
Well, I mean, you know, we're kind of running into a little bit of the problem we had yesterday, which is it sounds like you personally, Brittany Paz, are not totally confident in that testimony.
And so you don't want.
It's not that I'm not confident.
I can only convey to you what's been conveyed to me.
Right, but you have to convey to you what I'm conveying.
But you have an independent duty as Free Speech Systems Corporate Representative to inform yourself as to the answer to this question.
And to the extent you have done that, that information has come from CJ.
Yes.
But you're not obligated as Free Speech Systems Corporate Representative to testify under oath that that is in fact the case.
But I do need to know one way or the other whether that is Free Speech Systems testimony that it started creating closed captioning transcripts in 2015.
Is that Free Speech Systems testimony?
Based on the information that I have, yes.
Okay.
And Free Speech Systems is not aware how long it continued to create closed captioning transcripts.
No, I think what I said was it was about a one-year period.
Okay.
Which is what was conveyed to me.
Okay, so the best that Free Speech Systems can testify to is that from sometime beginning in 2015, for about a year, closed captioning transcripts were created at the Alex Jones Show.
Right.
Okay.
And Free Speech Systems used an outside vendor to create those transcripts?
I don't know who was used, so I'm not sure.
No, no, yeah, I'm not asking you for the identity of the vendor, but there was an outside vendor who was used.
That's what it sounds like to me, yes.
That's what it sounds like.
Well, because here's the problem is that I don't know the identity of who it is, so I can't say I don't know.
And I'm trying to say I don't know, and you're trying to ask me a question about whether or not that person tells you I don't know.
I'm perfectly happy for you to say you don't know whether an outside vendor.
Chris, may I have a moment with Attorney Paz?
I'm in an awkward position where I think I have an answer that she doesn't.
And, you know, and so may I have a moment with her?
Well, I. I'm trying to get, I'm trying to make this into a meaningful discovery enterprise.
Yeah.
Sure, yeah.
Okay.
I mean, I'm going to ask her about the conversation.
Norm, if you're going to give her information, I'm going to ask her where the information came from.
And I don't think you can.
I don't think there's a way to do this that obviates the attorney client that sidesteps that.
Just two minutes, please.
I'm really shining.
Yeah, I'll leave the room and you guys can have the room.
Okay.
Would you like me to go off the record and you?
Thank you.
We are off the record the time.
It's 3.14 p.m.
We are now on the record at times 3.18 p.m.
Okay.
Ms. Paz, we took a short break so that you could consult with counsel.
And Council and I have since had a discussion about he and I communicating directly about this issue of the closed captioning.
But I did just want to wrap up that particular area of examination.
Based on your inquiry at Free Speech Systems, I take it that the information you have available to you today is that Free Speech Systems utilized an outside vendor to create closed captioning transcripts, but at this time, you are not aware of who that is.
Right.
through your conversations with Free Speech Systems employees.
Right.
Okay.
Other than the fact that there was a closed captioning system in place from sometime in 2015 to sometime in 2016 using an outside vendor, are you prepared to testify in any other respect about those closed caption transcripts?
No.
Okay.
all right We may be able to get that coffee.
Please give me one second here.
All right, why don't we do that now?
Why don't we take five to ten minutes?
People can stretch and get coffee and then we'll come back for the remainder.
Yep.
We are all the record.
The time is 3:20 p.m.
We are now on the record.
The time is 3:33 p.m.
All right.
I want to ask you about Dan Badanti.
Bye.
Have you read Mr. Bedanti's deposition?
Yeah.
Um...
Mr. Badanti was a source of information for Free Speech Systems concerning the Sandy Hook shooting, correct?
I don't know if he was a source of information.
I know he was contracted to do some work on Sandy Hook, but so the answer is: Free Speech Systems doesn't know whether he was a source of information for Free Speech Systems on Sandy Hook?
I don't think he was a source.
No, I think he was reporting on it.
Okay.
So I don't think it's accurate to call him a source.
What are you basing that on?
Because his role was to, or the role that we had him playing in connection with Sandy Hook was to go and report on what Mr. Halbig was doing.
So I don't.
Who told you that?
It was just based on my review of the material.
Okay.
When you say the material, you're referring to the Texas documents that you were presented with?
Right.
And the videos.
And the videos in which Mr. Bedanti appeared.
Right.
And you inferred from your review of the Texas materials and the videos you reviewed that Mr. Bedanti was not a source of information for Sandy Hook concerning Free Speech Systems concerning Sandy Hook?
When you say source, it means to me that he's an originating place of information.
Is that the way you're using it?
Well, he was interviewed by Mr. Dew about what he learned concerning Sandy Hook, correct?
He was interviewed by Mr. Dew in connection with his attending the FOIA hearings.
So I don't know necessarily that he was a source.
Okay, I mean, look, if free speech, I'm just asking whether Free Speech Systems considered him a source for information or not.
I think he was a contracted reporter.
I don't, like I said, I don't, I wouldn't call him a source.
All right.
Can you bring up exhibit number 12?
Okay.
Have you previously seen the email before you?
I'm not sure.
I don't know.
I may have, but I'm not sure.
All right.
And am I correct that the email is from Truth Warrior with an email address of truthradio990 at hotmail.com?
That's what it appears, yes.
Okay.
Does Free Speech Systems know that that's Dan Bedanti's email address, right?
I think so, yes.
I think it is, yes.
Okay.
I mean, are you hedging on that, or does Free Speech Systems in fact know that?
Yes.
Thank you.
And he's emailing Rob Dew, John Bown, CJ, and Chris Alanis, all InfoWars employees, on December 17th, 2012, correct?
That's what it says, yes.
This is just three days after the shooting, right?
That's what it looks like, yes.
Okay.
And are you familiar with the YouTube link that he provided there?
No.
Okay.
But in this email, fair to say, Dan Badanti is providing information to Free Speech Systems about the Sandy Hook shooting, correct?
It says Dan Badanti, a number of dots, Sandy Hook pointed out in Batman movie, exclamation point.
That's what it says.
Right.
And free speech systems, and you're not prepared to testify about what it is that Mr. Badanti was communicating about?
I can say, based on what I'm reading, is it says that they're talking about the issue that Adan wrote about the name Sandy Hook appearing in the Batman movie.
So that's what it appears to be.
Do you know if this email was sent before or after Mr. Salazar published that article concerning the Batman movie?
I don't recall the date of the Batman movie, the Batman article being published.
I do remember in our conversation with Adan, he did say he got a tip about it.
I don't remember where he said the tip came from, but he said he got a tip.
Okay.
You're telling me that, but to be clear, Free Speech Systems is not testifying that this particular email was the tip that prompted Mr. Salazar to write that article.
Right, I don't know whether it's the tip, no, because I don't think Adan remembered based in my conversation with him.
Okay.
So having being uncertain as to whether or not you've ever seen this email before, are you prepared to testify that this is an email in which Mr. Badandi is sending information to Free Speech Systems about the Sandy Oak shooting?
I don't know what's in that link, so I can't say.
Can you pull up exhibit number 23, please?
Okay.
This is again an email from Mr. Badanti to Rob Dew, correct?
That's what it looks like, yes.
And dated October 23rd, 2013?
That's what it looks like, yes.
Okay.
And Mr. Badandi writes to Mr. Dew, guy I know who filmed Sandy Hook School recently, correct?
And then he includes a link.
That's what it looks like, yes.
Okay.
And so Mr. Bedandi here is informing Mr. Dew that somebody he knows had recently filmed the Sandy Hook school, correct?
It looks like he's citing to an article and giving the link to the article and possibly the guy he knew wrote the article, but I don't know.
I've never seen this email.
So I don't want to say either way.
You personally have never seen it.
I have never seen this e-fod.
Are you willing to, are you going to stand on your previous testimony that Dan Badanti was not a source of information for Free Speech Systems concerning the Sandy Oak school shooting?
This does not say to me that he is a source.
This says to me that he's providing tips and information to look for other information, so that does not mean he's a source of information.
Okay.
So a tipster is not a source?
I don't think so, no.
I think you testified yesterday that Dan Badanti was never employed by Free Speech Systems.
Is that right?
I know he's been a contractor for a long time, but I don't know whether he was actually employed there at any point in time.
Yesterday you testified that he wasn't.
I don't think he was.
I know he's been a contractor for a long time and then wasn't.
I mean, this is sworn testimony, right?
You're under oath.
So yesterday you testified that he was never a free speech systems employee, did you not?
I don't remember, maybe.
Probably.
I don't recall.
Well, is that true that he was never a free speech systems employee?
I don't believe he was, but like I said.
I'm asking you as free speech systems.
Objection to the form.
She's answering.
I said I don't recall.
Well, hang on a second.
This is the issue we had yesterday.
No, I agree, Chris.
I think that you can say if she doesn't, I mean, there's a way around this.
No, there is.
I think it needs to be either free speech systems can testify that Mr. Badandi was previously an employee or that he previously was not an employee.
But what if, and this is a very important question.
Hang on a second.
No, no, hang on a second.
No, no, we're not going to.
You and I are not going to have colloquy about this right now in front of the witness.
No, we're not in front of the witness.
We're not.
So if you want to take a break and excuse the witness, we can do that.
Oh, okay, that's fine.
Fine.
We are off the record.
The time is 3.43 p.m.
We are now on the record.
The time is 3.47 p.m.
All right, Ms. Paul, I think what I'm actually going to do is just rely on your testimony from yesterday concerning Mr. Badandi's employment status at Free Speech Systems.
Okay.
The...
You did testify just a moment ago before the break that Mr. Badanti had been a reporter for a long time at Free Speech Systems.
When did he first become a reporter?
I know I talked to people about this.
I definitely spoke to Rob Dew about this, but as I sit here today, I can't recall.
It might be in my notes, but I'm not sure.
Basically, what Rob's position was that he was kind of in and out of the good graces, so to speak.
I think that's the term he used.
But in my conversation with him, I can't recall how long he had said it had been.
Okay, so as you sit here today, you can't offer testimony as to when Mr. Badandi started as a reporter for Free Speech Systems, correct?
Right.
Okay.
You're aware that Mr. Bedandi did reporting for Free Speech Systems in connection with the Boston Marathon bombing, correct?
Yes.
Okay, so that was at least as of forgive me, but I think it was April 2013, was the Boston Marathon bombing.
Yes.
So Free Speech Systems can say that at least as of April 2013, Mr. Bedandi was serving as a contract reporter for Free Speech Systems, correct?
At least, yes.
Okay.
And Mr. Bedandi had been furnished with, furnished by Free Speech Systems with a microphone for that purpose, correct?
Yes.
And a microphone shield identifying him as an InfoWars reporter, correct?
Yes.
As well as a press pass identifying himself as a Free Speech Systems reporter.
Yes.
And a camera had been provided to him by Free Speech Systems to assist him in his reporting for Free Speech Systems, correct?
Right.
Okay.
And Mr. Jones, Alex Jones, that is, authorized Mr. Bedandi to work as a reporter and to be equipped in that way as a reporter, correct?
Right.
Okay.
And did you see any videos of Mr. Jones's coverage of the Boston Marathon bombing?
Aside from the videos that I saw in connection with this case, I don't think I saw anything in connection with Boston, so no.
Well, with respect to the videos that you reviewed in this case, do you recall any segments of those videos in which Mr. Jones discussed the Boston Marathon bombing?
Oh, in which he discussed it?
Sure.
I mean, as you could tell, you know, a lot of his things, he goes back and forth between a variety of different topics.
So a lot of these videos aren't solely about Sandy Hook.
He will mention other things such as 9-11, the Boston Marathon bombing.
So, sure, yes, he's mentioned it in some of these videos.
Pardon me.
And Mr. Jones has claimed in the videos you've seen that the Boston Marathon bombing was staged, correct?
I don't know if he claimed it was staged, but I know he was definitely claiming there were inconsistencies and highlighting some issues he thought should be discussed.
I don't know if he called it staged.
Sure enough.
So you don't know whether Mr. Jones has referred to the Boston Marathon bombing as having been staged.
Right.
All right.
And you don't know whether he's referred to the shooting at the Aurora Movie Theater in 2012 is staged, correct?
Same as answer as before.
I don't know if he's used the word stage.
I know he has talked about it in connection with the shooters' mental health issues and whether he could have done such a thing given his issues or whether he was, I think he might have used the word Patsy.
I don't know if he used the word staged though.
Okay.
Do you know if Mr. Jones believes that the Aurora movie theater shooting was in fact staged?
I don't know what his opinions are on the matter, no.
Okay.
Free Speech Systems is aware that when Mr. Bedandi accompanied Mr. Halvig to the Newtown Board of Education meeting in May of 2015, that Mr. Bedandi addressed the Board of Education that Mr. Bedandi did?
I don't know.
I haven't seen footage of that.
I don't think I saw any footage of Mr. Bedandi speaking to the board.
Okay, so Free Speech Speaker?
I saw Halvig speaking to the board.
Free Speech Systems does not know whether Mr. Bedondi addressed the board correctly.
I don't know.
Okay.
Would that have been appropriate behavior for a Free Speech Systems reporter to take an active role in addressing the board that they were there to cover?
I think it's the position of free speech that all of its people that work there have their own opinions on matters and are encouraged to speak their minds.
So I'm not prepared to say that it was inappropriate if it did in fact happen.
So I think it's encouraged to speak for people to speak their minds there.
Let me see if I can just, if I can get a clear answer on that.
If Mr. Badandi was at the Newtown Board of Education as an InfoWars reporter for the purpose of covering that hearing and he personally addressed the board, would that be appropriate behavior for an InfoWars reporter under those circumstances?
And as I said, I'm not prepared to say it's not appropriate.
Free Speech Systems doesn't have a view on that.
Right.
Okay.
I'm not taking, yeah, we're going to take a position on that.
Um...
Following, in June of 2015, Mr. Free Speech Systems sent Mr. Badandi to Hartford to report on a Freedom of Information Commission hearing concerning Mr. Halbig's Freedom of Information requests, correct?
Yes.
And Mr. Badandi went with a Free Speech Systems contract camera operator, correct?
Yes.
Okay.
And that was Kevin LaPrade, correct?
I'm not sure of the name of the person who went, but it was our camera person.
The battery on this computer is low.
The battery is low.
Why don't we?
Ah.
Oh, that's a simple, simple solution.
Thank you.
Thank you.
Okay.
Yes.
Thank you, Pratika.
That hearing of the Freedom of Information Commission was Mr. Bedandi's report of that hearing was broadcast by Free Speech Systems on June 3rd, 2015, correct?
If I could just, I'll check the date.
It may have been, uh...
The first FOIA hearing, I believe, was 5.
Oh, wait.
Let's see.
What was the date?
I may have been mistaken about that.
Sure.
Let me try that again.
Okay.
Free Speech Systems broadcast coverage of the Halbig FOIA hearing on May 29, 2015, correct?
May 29, 2015, yes.
Okay, you have that.
Yes.
That's in chart A. Yes.
All right.
Something weird's happening in my computer.
And Mr. Badandi sent Mr. Dew the raw footage.
Excuse me.
Mr. Badandi sent Mr. Dew the raw footage that he and the Free Speech Systems cameraman had taken during that hearing, correct?
I don't know, and I don't know if it was edited before Rob got it or if we edited it, so I'm not sure if he sent us the raw footage or he edited the raw footage.
So I'm not sure.
All right, let's pull up Exhibit 32.
Do you have that email before you?
Yes.
Have you previously seen this email from Dan Badondi to Rob Dew?
It does not look familiar.
No.
Okay, so Free Speech Systems, do you see how Mr. Badandi is appearing to send links to video content to Mr. Dew?
That's what it looks like, yes.
All right.
And the final link being a link that purports to be of a length of one hour and 40 seconds, at least one hour and 40 seconds, wherein Mr. Badandi is telling Mr. Dew that at that point in the video you will see that woman hand the lawyer a check saying something about the Board of Education?
That's what it says, yes.
Okay.
And that was drawn from a Ustream channel that Mr. Badandi utilized, correct?
That's what it looks like, yes.
Okay, and Mr. Dew had told Mr. Badandi to send him the Ustream footage, correct?
I don't know.
I don't know what he told him to send him.
All right.
Or how he told him to send it to him.
I don't know.
Okay.
That's something Mr. Dew would know, correct?
I would say so, yes.
Okay.
But you did not ask Mr. Dew about that, correct?
No.
Okay.
And you have reviewed previously the broadcasts that were aired on June 4th, 2015, titled Official Claims DHS Involved in Sandy Hook.
And July 8th, 2015, the fight for freedom of information in Sandy Hook.
Yes, I reviewed both of those.
Those are Exhibits 73 and 76 here.
Have you reviewed the raw footage that Mr. Bedanti sent Mr. Dew?
I haven't reviewed anything that's not on these videos and these ID numbers, so no.
I don't know that we retained the raw footage.
Okay.
Why don't we show, pull up exhibit number 34?
Actually, before you do that, I'm sorry, Pratika, before we do that, let's pull up exhibit number 73 first.
Yeah, oh, yeah, please start playing them.
Thank you.
Welcome back to the Infowars Nightly News.
We're joined right now by our news director, Rob Dew.
And you have some Sandy Hook updates for us right now.
I understand this is the second Freedom of Information Act hearing on Sandy Hook, yet they still refuse to release the documents that were requested by Wolfgang Halvig.
What's going on?
Well, it seems to be a lot of the, I guess, the strategy they're using is saying documents don't exist.
So there's porta potties that are there, but there's no documents of the city ordering them or paying for them.
There's an electronic sign there that says everybody must check in, yet there's no check-in log.
So if there's a sign flashing that says everybody must check in, you would think there would be a check-in log where people are checking in.
Does that make sense?
Kind of makes sense to me.
Why you would bring a giant road sign there that says everybody must check in and then not have a log stating who checked in.
Agreed.
All right.
So who put that sign there?
Who paid for that?
Well, yesterday during the hearing, it came out they had one of the town, they call him the selectman, it's actually an older lady, and she says, we don't have any of that information at all.
And so the lawyer goes, well, who put that sign up there?
She goes, Homeland Security, I think.
Actually, said it was Homeland Security.
So then that is a bigger ball.
Thank you.
So you're aware that Mr. Dew here is describing the footage that Mr. Badandi and the cameraman got as a result of their coverage of the hearing in Hartford, right?
Right.
Which video is this ID number?
This is 73.
Oh, ID number.
This is 13 underscore BW SBY.
Okay, yeah, I got it.
Okay, so you've reviewed this.
Yeah, I did.
You're aware that during this video, Mr. Badandi ends up playing the footage from Mr. Badandi, correct?
Okay.
Mr. Kitty, you might have asked that wrong.
I think you said Bedandi twice.
Thank you, Mario.
I'll strike that question and I'll try and ask it again.
During this particular broadcast, Mr. Dew published Mr. Badanti's footage from the FOIA hearing, correct?
yes, I think he published clips of it.
Clips of it, right?
Clips, right?
He didn't publish the full thing.
No.
Okay.
Um all right.
Um why don't we pull up exhibit number 34 clip one, please?
Okay.
You can pause this just for a second.
Do you recognize exhibit 34 as part of the footage that Mr. Badanti took during his coverage of the FOIA hearing?
I've never seen this, no.
You've never seen this?
I don't think I've ever seen this.
Okay.
Why don't you keep playing it?
Can you pause it for a second?
Do you recognize the gentleman in the blue shirt who's who's following the gentleman in the suit?
In the blue shirt?
Yeah.
You mean who's following him?
Yeah.
I think that's Mr. Badanti.
Okay.
Yes.
Sir, are you putting into your retirement 12 hours ago?
Wow, retirement, huh?
You guys trying to cover up Sandy Hook?
Retirement, huh?
Wow.
The truth's coming out.
We know you guys are corresponding with the police.
You're going to have an eye to speak to us.
Good time for retirement.
Good time for retirement.
Who's saying good time for retirement?
I don't know.
As I said, I don't recall seeing this portion of the video.
Okay.
So I don't know.
Okay.
You don't know if that was the cameraman that Mr. Badanti brought with him?
No, I don't.
Okay.
Keep going.
Seeing this line, folks, right here, we've got this Sandy Hook police chief right here putting into his retirement person.
He's not answering the questions and he's leaving the retirement, huh?
Trinity Frank, do you know about the police chief putting his retirement 12 hours ago?
How do you guys feel like part of a massive no-roll?
How do you choose from seeing those?
There you've seen it live, folks, right there.
You've seen people defending purpose.
He's blocking out the path on the stairs.
This is all...
Get out of the building.
Can you stop for a second?
When Mr. Badanti said he's defending criminals, who's he referring to?
I don't know.
As I said, I've never seen this before.
And I would recall if I saw it, because I just saw someone I knew in there.
So it would definitely stick in my memory if I saw this.
Right.
And so Free Speech Systems doesn't know who Mr. Badanti was referring to as criminals in that photo, in that video.
Okay.
Okay.
What's this going to do right now?
He's the...
Criminal.
Criminal.
He's walking on the path down the walkway.
And this thing of...
Yeah.
Could be corrupt.
Piece of shit.
Can you pause that for a second?
Did you hear somebody just use profanity directed at the individual who is walking in front of them?
I did.
Okay.
Do you know who that is?
No.
Okay.
You don't know if that's Free Speech Systems camera operator?
I don't know.
Go ahead and continue.
Retirement, huh?
Trading, please.
Are you trying to cover up Sandy Hook?
We know you have communication with the helicopter.
That's a protocol, sir.
I'm a pilot myself, so you're not holding nobody.
Oh, thank you.
Pause for a second.
You recognize that that was Mr. Bedanti who said I'm a pilot myself.
Yes, I heard him say that, yes.
Does Free Speech Systems know if Mr. Badanti's a pilot?
I don't know, no.
Free Speech Systems doesn't know.
Right.
Go ahead.
You people going to jail.
You want to.
Can you pause for a second?
When Mr. Badanti says you people are going to jail, who's he referring to?
I don't know.
Okay.
Let's go to clip two.
This is 30.
Yes, thank you.
This is exhibit 35.
Thank you.
Will!
I'm coming.
I'm gonna get that check on T. Retirement.
Law.
That's great.
Hope you enjoy that retirement.
Sir, are you retiring due to the fact that Sandy Hooker was a cover-up?
Sir, you watch around the police, Chief of Sandy Hooked down, Newtown, Connecticut.
He's covering up cooperation.
They had communication with the helicopter, the lying on the stand.
That's perjury, sir.
Keep puzzled.
Did you hear Mr. Badanti just say that the chief of the Newtown Police Department had lied on the stand and committed perjury?
I heard that claim, yes.
Okay.
Now it was Dan Badanti who said that?
It appears so, yes.
Okay, go ahead.
You know what perjury is?
You got nothing to hide to speak to us, sir?
Yeah, if you've got nothing to hide, just speak with the lawyers, speak with us.
you're a public official Sir, you know you're living around the air, right?
You've got nothing to hide to talk to us.
Who was home with the last security doing that?
I'll come in jail for a minute.
Pause for a second.
Did you hear Mr. Bedanti just say, have fun in jail, criminal?
I think that's what he said, yes.
Okay, and he was saying that to the chief of the Newtown Police Department.
That's what it looks like.
Okay.
Go ahead and continue.
Go to jail, criminal!
How come with your retirement?
And you serve defending criminals.
How do you feel about that?
This is the exact person that they would hire to represent criminals, folks.
Pause for a second.
Do you know who he's referring to there?
To this gentleman?
Yeah.
I think this gentleman is one of the attorneys.
And Mr. Badanti is telling this person who he refers to as out of central casting as defending criminals, correct?
That's what it appears.
And which criminals is Mr. Badanti referring to?
You mean defending criminals, who he's defending?
I'm not sure who he's referring to.
I mean, I could make an inference.
He had just called the Newtown police chief a criminal.
Well, I'm just asking.
I don't know who he's referring to now.
Okay, I mean, as Free Speech Systems watching the footage of a Free Speech Systems reporter, I'm asking you whether Free Speech Systems knows who he's referring to as criminals, and your testimony is you don't know.
No, I've never seen this.
I'm not sure.
I'm not sure.
She's being asked to draw an inference, which is prohibited in some contexts and not others.
No, no, I'm not asking her to draw an inference at all.
I'm just asking her whether.
That's inferential.
He said the words did she hear that.
That's obviously not a form objection, but I'm asking.
I'm responding with the comment you made.
Objection as to formal retreat.
I'm asking Ms. Paz, I'm not asking you to read Mr. Badanti's mind.
What I'm asking you is whether, in your capacity as a free speech corporate representative, Free Speech Systems knows who Mr. Badanti was referring to as criminals.
No, I've never seen this video.
I've never spoken to Mr. Badanti.
I don't know what it was in his mind at the time, so no, I don't know.
Okay.
And you didn't read his deposition?
No.
And you didn't ask that?
You didn't ask Mr. Dew about this.
About this particular video footage?
Correct.
No.
Or about Mr. Badanti's activities as a reporter on this day on behalf of Free Speech Systems.
I did talk to Mr. Badanti about his behavior this day.
I hadn't seen this video footage, but I think that Mr. Dew did convey to me that he found certain of this activity to be problematic.
Mr. Dew had seen this footage, correct?
I don't know what he saw or didn't see.
I haven't seen this footage.
Okay, well, I'm asking you.
You've just testified that Mr. Dew told you that he found some of Mr. Badanti's conduct on this day, I think in your words, problematic, correct?
Is that what you just testified to?
I think that was what was in my conversation with Mr. Dew, yes.
Okay, so Mr. Dew informed you that he found some of Mr. Badanti's conduct problematic on this day.
Did you ask him what in particular was problematic about how Mr. Bedanti conducted himself?
I don't think we went into specifics like that, no.
Okay, all right.
Go ahead and continue playing it.
We hope truth is coming out, you people going to jail.
You can smile all you want, you're going to jail for it.
oh you're going to credentials dan badani info was dot com the number one alternative news source in the world right on the way live right on here nobody has to say about different criminals So we know you're lying.
Chief Lyon stands you had your posse there sitting there whirling while it's the right to people.
Well, you can't answer wonderful things.
Why won't the videotapes watch?
The truth will be revealed, always is, my man.
Why did you deny the Holocaust pilot be there twice when he was subpoenaed?
You have no authority to dismiss him from the state.
Now, after now, your testimony is that you've never seen any of the footage we've just played in any of the videos you've reviewed?
I don't recall seeing any of this.
There may have been a clip of the attorney getting into the car.
Very, very short clip, brief.
But I definitely did not see this entire thing.
This is the first time I'm seeing this.
Right.
But this is the first time you're seeing it personally, right?
You're not testifying that this is the first time anybody at Free Speech Systems has seen this footage.
Right, I don't know if anybody else has seen it, but I personally have not seen it.
But are you comfortable testifying?
You know what the term B-roll is?
Oh, sure.
Sure, I understand the term.
You know, sometimes Mr. Jones will show video during the course of his statements that plays while he's talking, but that the sound of the video itself isn't up.
It's only his sound, and people just see the video.
Right.
Right.
And you've seen several videos that you've reviewed in which the video footage we've just seen is published without the sound, correct?
You mean this entire video?
No, I didn't say the entire video.
I said you have seen videos that you've reviewed during the course of your role as corporate representative in which this video footage is, some of this video footage is played, correct?
The only portion I recall seeing, as I just said, is perhaps this lawyer getting into a car, but you're right, there's no sound, but it's very, very short, a second or two.
So that's the only portion of this I recall seeing.
You're not certain whether longer excerpts of this video would play this B-roll.
You just don't know.
I only recall seeing what I just said, I recall seeing.
And Free Speech Systems today doesn't know whether the footage we just showed was in Free Speech Systems' possession at the time they aired their coverage of this hearing, correct?
Do you understand the question?
Yes, you're asking me if the entire what we just viewed here was in Free Speech's possession at the time they aired the other footage.
I don't know.
Mr. Badanti continued to work as a reporter for Free Speech Systems after this date, correct?
What was this date?
So, this was June 4th, 2015.
He may have.
There was some point in time after this, but I'm not sure when that he was asked to return all of his equipment, but I don't know.
I'm going to ask you about that.
Right.
What I asked you about was whether Mr. Bedanti continued to work as a reporter for InfoWars after this date.
Like I said, I don't know the exact dates of when he was asked to turn in, so I'm not sure.
Do you know whether he continued to work as a reporter for Infowars after this date?
I'm not asking you right now how long he worked for a reporter, when that stopped.
I'm just asking whether after this date, free speech systems can testify as to whether you continue to work as a reporter for them.
I'm not sure, like I said, as to the timeframe, so I'm not sure.
Okay, so Free Speech Systems is not in a position today to testify as to whether Mr. Badanti worked as a reporter after June 2015, correct?
Right, because I'm not sure of the date, so that's correct.
At this time, Mr. Bedandi had a YouTube channel that was hosted by Free Speech Systems, correct?
I don't know.
Okay.
And Free Speech Systems was aware that Mr. Bedondi promoted himself on Twitter as being associated with Infowars, correct?
yes.
Mr. Jones is aware that Mr. Bedondi had been sent up to Connecticut to cover Mr. Halbig's activities, correct?
I'm sorry, was who aware?
Alex Jones was aware that Mr. Bedondi had been sent up to Connecticut to cover Mr. Halbig's activities, correct?
I don't know because Mr. Dew sent him, so I don't know.
And Mr. Dew was the news director at the time.
So I don't know if Mr. Jones was aware.
Did you ask Mr. Jones that?
I didn't ask him specifically.
No.
Are you aware that Mr. Jones said on the air that he knew that they had sent a reporter, Dan Badondi, up to Connecticut?
Which video are you referring to?
I'm not referring to a specific video.
Okay.
When did he say it?
I'm asking you.
I don't recall.
Okay.
If you could point me to a specific place to refresh my recollection, I'm happy to look at it.
Why don't we play the July 7th, 2015 video exhibit 75, retired FBI agent investigates Sandy Hook?
Mega massive cover-up.
What was that exhibit number?
So, yeah.
We have questions.
Let's start with at 235.
I had missed this episode of the nightly news back on June 4th.
And then again, last week when you did an update.
And then I heard you talking about it yesterday.
I knew that we'd sent our reporter Dan Badondi there for days to cover the city council hearings about it and the fact that they're stealing.
So does that refresh your recollection as to whether Mr. Jones knew that Free Speech Systems had sent Mr. Badandi up to Newtown for days to cover the city council hearings.
Yes, I mean, what it sounds like is he it doesn't say whether he knew beforehand or after, but it says he knew that he had gone.
So that's what that means to me, at least.
So, yes, it does refresh my recollection.
Okay, so Mr. Jones knew that Free Speech Systems had sent a reporter, Dan Badondi, up to Newtown for days, correct?
That's what he said.
That's what it says, yes.
Yeah, okay.
You don't have any reason to doubt that, do you?
That he knew.
It doesn't say when he knew it, but it says he knows.
Okay.
At least as of this video, he knew.
Right, at least as of 7-7, which was about a month after.
Okay.
And you didn't ask Mr. Jones about that.
Did you ask Mr. Jones about Mr. Bedondi at all?
I don't remember whether we spoke about Mr. Bedandi.
I spoke with Rob about Mr. Bedondi.
Okay, I just asked you about Mr. Jones.
I don't recall whether I spoke to Alex about Mr. Badandi.
I'll see.
Thank you.
Okay, why don't we pull up exhibit number Mr.
Jones covered or made statements concerning Rob Dew's uncle, correct?
Do you know who Rob Dew's uncle is?
Yes, so Mr. Dew's uncle surprisingly appeared.
I just asked him.
I know who he is, yes.
Do you know his name?
I can't remember his name.
He probably said it on that segment.
Right.
And Mr. Jones made a claim on the air that, and in the headline of the video, that Rob Dew's uncle was investigating Sandy Hook, correct?
I believe the title was Retired FBI agent investigates Sandy Hook, mega massive cover-up.
And that's the title of the video that Mr. Jones selected, correct?
Yes, I think he did, yes.
And then on the air, he said that Mr. Dew's uncle was investigating Sandy Hook, correct?
It said he went to the FOIA hearing to investigate Sandy Hook.
No, no, wait a second now.
I asked you, I didn't ask you about whether Mr. Jones said he went to the FOIA hearing to investigate Sandy Hook.
In fact, I don't think that's what he said.
I'm asking you whether Mr. Jones said that Rob Dew's uncle was investigating Sandy Hook.
Just pull up my notes.
The uncle investigates is investigates Sandy Hook.
Yes, that's in my notes.
Mr. Jones claimed on The air that Rob Dew's uncle was investigating Sandy Hook, correct?
Investigating Sandy Hook, yes.
Okay.
And have you talked to Mr. Dew's uncle?
No.
Okay.
Mr. Jones said on the air that the reason Rob Dew's uncle was investigating Sandy Hook is because current FBI employees had reached out to him and told him he should investigate it, correct?
Thank you.
I'm just reviewing my notes.
No, what it says is, I'm asking whether you recall seeing video broadcast by Free Speech Systems in which Mr. Jones claimed that current FBI employees had contacted Mr. Dew's uncle to tell him he should investigate Sandy Hook.
Do you recall seeing that video footage?
No.
All right.
Is it true that current FBI employees reached out to Mr. Dew's uncle to tell him he should investigate Sandy Hook?
I don't know because I don't know that that's the claim that was made.
Okay.
Well, regardless of the claim that it was made, you don't know whether that happened.
Free Speech Systems doesn't know whether that happened, correct?
No.
Okay.
And Free Speech Systems does not know what the basis was for Mr. Jones saying that, if he said it if he said it, because I don't know whether that was said, then I don't know what the basis is.
It says my interpretation or my interpretation.
I didn't ask that.
And there were multiple videos in which Mr. Jones discussed Rob Dew's uncle and his investigation into Sandy Hook, right?
I think he might have mentioned it in other videos aside from this video.
Right.
So, yes.
Okay.
Did you ask Mr. Dew at all about his uncle?
Yes, I did.
We did talk about this in the conversation I had.
Yes.
Okay.
And did Mr. Dew tell you that his uncle had been prompted to investigate Sandy Hook because then FBI employees had reached out to him to tell him to do that?
No.
What he said was his friends, he had friends that had told him that he should check it out, which is what my notes say to you.
Mr. Dew told you that his uncle's friends had told him to check it out.
Okay.
Which didn't say anything about whether they were FBI officials.
Right.
All right.
And did Mr. Dew's uncle's investigation go beyond his attendance at that FOIA hearing?
I don't have any information to suggest he did anything else other than attend this hearing.
Meaning Free Speech Systems doesn't have any information that his investigation lasted beyond his initial appearance there, correct?
Right.
And his activities there were limited to just observing the FOIA proceeding, correct?
Right.
He observed the FOIA hearing.
Right.
He didn't ask anybody any questions, correct?
The uncle?
Yeah.
No.
Okay.
Mr. Jones had referred to Mr. Dew's uncles as working at a security firm, correct?
You mean whether Mr. Dew's uncle worked at a security firm?
Mr. Jones had stated on the air that Mr. Dew's uncle worked at a security firm, correct?
If I could just review my notes.
So I don't recall anything about a security firm, so no.
Okay, so Free Speech Systems is not in the position today to testify about the security firm that Mr. Jones claimed Mr. Dew's uncle worked at, right?
I don't know if that claim was made, so no.
Okay.
Okay.
Oh.
You reviewed Mr. Dew's testimony.
Well, let me ask it.
I'm getting confused.
I think earlier in the deposition, you testified that you recalled reading Mr. Dew's testimony from 2021, correct?
Yes.
Okay, but you did not review his 2019 depositions as corporate representative.
I don't think I did, no.
Fair enough.
You reviewed Mr. Jones's testimony in this case.
I'm sorry, in the Texas case, right?
You reviewed all three deposition transcripts?
Yes.
Okay, you recall his testimony on March 14, 2019, that Mr. Badanti was not working for Free Speech Systems when he went to Sandy Hook.
I don't recall if you want to refresh my recollection.
I would take a look at it.
I don't remember.
Well, when Mr. Badanti went to Sandy Hook, he was doing so on behalf of Free Speech Systems, correct?
Yeah, I think there's emails to that effect sending him there, so yes.
Okay.
You recall Mr. Jones' statements on air concerning photographs of Noah Posner that appeared in Pakistan following a mass shooting there, correct?
Yes.
I think that was an article Adan wrote.
Well, I'm talking about Mr. Jones' statements on air about it.
I'm not talking about Mr. Salazar's article.
Okay.
It was another one of Mr. Salazar's specials, wasn't it?
Yes.
And Mr. Salazar wrote that, well, I'll strike that.
Mr. Jones stated on the air that it appeared somebody who had been killed at Sandy, somebody who was reportedly killed at Sandy Hook, had again been killed in Pakistan, correct?
Can you point me to which video you're talking about?
So I can refresh my I just I'm not sure, so I would like to refresh my recollection by looking at my notes.
Do you recall in even general terms what Mr. Jones said about that photograph of Noah Posner?
I recall that he was referring to the article that Adan wrote, but I don't remember specifics as to what Mr. Jones said, which is why I'd like to refresh my recollection.
Um...
Why don't we switch gears for a second?
It is clear to me that we're going to have to come back for the third day.
We're not going to do that this week or next, but we're going to have to come back.
So I wanna switch gears here for a moment and go to some of the...
Some of the other issues.
All right.
We asked that Free Speech Systems produce a representative to testify concerning any demographic information collected by Free Speech Systems or conveyed to Free Speech Systems by a third party concerning its audience.
Are you prepared to testify about that today?
I did make some inquiries into that to prepare for this, yes.
Okay.
And so what during the time period 2012 through today, what efforts did Free Speech Systems make to track demographic information of its audience?
So the answer to that is not much.
Based on my conversations with Tim Fruget and Mr. Roddy, there wasn't any regular tracking of demographic information either on social media or elsewhere.
There was a period of time where Mr. Hammond was working directly with Alex and he may have requested to pull some information on an irregular basis, which Mr. Fruget would then produce to him, but on the whole, nothing was ever done with that information.
So based on my conversations with the employees, it doesn't appear to me that there was any regular tracking of the demographic information.
Let me, I guess, back up and ask a different question.
From 2012 through today, did Free Speech Systems have available to it, had it wanted to access it, demographic information concerning its audience?
Was it available?
Yeah.
You mean on various websites, Google Analytics and such?
I don't know.
Hang on a second.
I mean at all.
Was it available?
Sure, it's available.
Which applications did Free Speech Systems use to collect that demographic information?
Jackson.
Well, as I previously indicated, it was available.
I don't think they were actively collecting anything, but if I could review my notes from my conversations with Mr. Fruget, maybe I could better answer this question.
Okay, if that's possible.
Before you do that, I just have you review your notes on this question, but regardless of whether anybody at Free Speech Systems actively tracked the information or regularly tracked the information, information concerning the demographics of its audience were available to Free Speech Systems throughout the time period we're discussing, correct?
Sure, it's available.
Okay.
What type of demographic information was available to it?
I don't know.
I'd have to check my notes.
Okay.
And you also have to check your notes to figure out which applications or tools Free Speech Systems had available to it to check that information if it wished, correct?
You got to check your notes for that?
Right.
Okay, why don't you go and do that?
Can I have the manila folder, please?
Thank you.
Would this be—oh, this would not be in your written notes because this is the— Right.
This is the— Right.
This was the last couple of weeks'worth of conversations that I had with people.
Okay.
Okay, so based on my notes with my conversation with Mr. Fouger, the demographic information that they were able to get came from Quantcast.
So that's where they got that information.
And how long was did they have an account with Quantcast?
I don't know because I don't, according to Mr. Fruget, they had never pulled information from there prior to Mr. Hammond requesting him to pull this information from there in 2014.
He reiterated to me that it was never done before, and that was the first time anybody had ever asked him to do it.
So prior to that, he was unaware of anyone having done it before.
What is Quantcast?
It's an internet web trafficking website.
And free speech systems paid to have a Quantcast services, correct?
I don't know if it was paid for.
So, no, I don't know that.
We could check the, you could, you have access to the ledgers.
It would probably be in the ledgers if it was a paid-for service.
So we would have paid for it.
It would be in the ledgers.
So you're saying you're referring me to other documents that you have you reviewed those documents?
Have I reviewed the entire ledger for a 10-year period?
No, I haven't.
Who's best positioned within Free Speech Systems to discuss this demographic data that was available to it?
In what context?
Well, it seems obvious that Mr. Fouget or Mr. Roddy would know more about this than you do, right?
Well, Mr. Fouger, I don't think that's accurate.
Mr. Fruget didn't know very much about it at all.
All he conveyed to me was he pulled information from this on this one particular time.
It wasn't something that they had ever done before.
He only did it because Mr. Hammond asked him to do it, and he never did it again.
What, if anything, did you do to confirm whether what Mr. Fruget was telling you was accurate?
So I did speak to Blake after I spoke to Tim, and Blake confirmed, I asked him about Quantcast.
It's in my notes here.
He said they still have it, but they only use it when they're asked to pull things off of it for discovery purposes for the litigation.
The data retention is two years and they don't actively use it.
So it was confirmed by Blake.
Okay.
And you think you know more about that than either Blake or Mr. Fruget?
Well, I got my information from them and I conveyed to you all the information that appeared to me that they have on this issue.
So I don't think they have any more information than I do.
Okay.
Well, have you reviewed Mr. Fouget's deposition?
I don't think so, no.
Okay.
And for what purpose did Buckley Hammond request demographic data in 2014?
I asked him that why he would ask him to do that because there was that email.
You asked Mr. Fouger.
I asked Mr. Fruget that because there was that email, the 12-15-2014 email.
And he said he didn't ask why.
He just asked him to do it, and so he did it.
And you didn't ask Mr. Hammond that either?
I did not contact Mr. Hammond.
I don't think he's associated with free speech anymore.
Why didn't you contact him?
Why didn't I contact him or attempt to contact him?
Yeah.
Well, in my conversation with Tim, it seemed to me that Mr. Hammond didn't want to be involved anymore, and so he wasn't really responding to requests to participate.
Mr. Fruget told you that Buckley Hammond was not responding to requests to participate.
Right.
Who had made those requests of him?
I don't know.
Because Mr. Fruget, he's been there for quite some time.
He left and he came back.
He's still there now.
So Tim's position is that Mr. Hammond does not want to be involved.
But you didn't ask him what the basis for that view was.
I don't know what's going on internally between them.
I know Mr. Hammond is related to Alex in some way.
Okay, so.
So I don't know what's going on between them.
The reason that you chose not to contact Mr. Hammond is because Mr. Fruget told you that he didn't want to be involved.
Right.
Okay.
Did you review the transcripts that were produced in this case, the closed captioning transcripts that I asked you about earlier?
I haven't reviewed any closed captioning transcripts.
No, I haven't seen anything in what I was provided to review like that.
Okay.
You were asked, or Free Speech Systems rather, was asked, to present a representative who could testify concerning all transcripts produced in response to the plaintiff's request for production that were served in this lawsuit.
And your testimony is that you can't testify regarding that because you haven't even seen one, correct?
Regarding the closed captions?
Yeah.
Right, I haven't seen any closed caption transcripts.
I've read other transcripts of videos, like video transcripts and such, but I haven't seen any closed caption transcripts.
Who created the transcripts of the videos that you reviewed?
It looks like Falzerano reporting.
A court reporting service.
That's right.
Okay.
And who arranged for Falzerano reporting to have those transcripts created?
I don't know.
Okay.
We received a document, I think, to facilitate your testimony about topic number three with the email addresses and cell phone numbers for a list of individuals.
Do we have that exhibit?
We can go off the record.
Norm, unless you want to put this on the record as discussion about what we're going to do now.
No, why don't you and I try to continue to narrow issues?
I mean, you know, I think that, you know, Chris, somebody asked me in connection with the case whether there were time limits, and I said I thought under Connecticut it was reasonable.
But I recall somebody timing a deposition at some point.
And I'm not looking to litigate that way, but is there an order on the amount of time that is reasonable?
I mean, I think given the complexity of the case, I don't think I might quibble with how much time you spend on the videos, but it would be just that, a quibble.
How much more time do you think you need?
And refresh my recollection, is there a limit that the court has imposed on how much time we should spend?
No, the court has not set a limit on depositions.
And as far as how much time I have left, depending on the emails I get, definitely not a full day.
I do expect that Attorney Sarami may have some questions.
I have about hour and a half, maybe two.
Yeah.
Maybe one depends, but one to two hours.
So maybe another day, maybe another.
Some of my questions might prompt Chris to ask another half hour.
Right.
Yeah.
So, you know, I mean, I think we made good progress today.
I certainly have not, I've made a conscious choice not to show a bunch of videos.
Yeah, I get that.
I don't want to sound like I'm quibbling.
Yeah, no, I am, but not the major way.
I mean, I think compared to the amount of time was required in Texas to depose the number of corporate representatives down there, I think we're probably going to come in well under that.
But I need at least, you know, obviously we need to come back.
And I would offer to do it, you know, the week after next, and we can do it inside the scheduling order.
When does the scheduling order expire?
31st.
Well, I see.
So, yeah, okay, I'm looking at a calendar.
Here's the problem.
I have, Chris.
Do you guys want to be on record for this?
I don't think we need to be on this.
If we have an agreement that we're going to come back, we should put that on the record, though.
So here's the problem I have, Chris.
I have Zach, who's sitting right there, has been picking, we started picking a jury.
We're two or three days, or maybe four in now.
It's a criminal case, and it's been pushed back a week because of the evidence, because of the scheduling difficulty we had last week to accommodate this case.
But we're set to begin evidence in Danbury on the 29th.
And, you know, I'd like to have the 28th to just kind of review my notes.
So that's going to be a bad week for me.
I'm reluctant to seek more relief from the scheduling order because of the expert issue we talked about.
But if we needed another week and you feel we needed cover, I'm not going to claim the scheduling order if you want to come back the week of April 4th.
But if you feel we need to cover the record, you know what I mean?
I would propose we seek one more week for purposes of Ms. Paz's deposition.
Okay, I am certain that whatever remains in Ms. Paz's deposition will not delay our disclosures.
So look, do we need to go to the court and ask for time or can't we just agree to do it?
I'd be more than happy to agree, but in the past, she has wanted us to seek court approval for that.
Well, that's true, too.
I remember that was one of my first exposures to this file.
We reached some sort of agreement, or prior counsel did, and she was pretty angry about that.
I recall that.
Well, here's what I thank you for reminding me.
I would propose that we seek relief through February, excuse me, through April 8th.
And then, because candidly, my availability is going to be dictated by the criminal trial that takes place the week of the 28th.
And I expect it to be done that week.
So what do you think about that?
Yeah, I don't have a problem with that.
So why don't we put that on the record now?
And then, yeah, we'll just file a motion on that.
Well, I mean, and I guess we should ask Attorney Paz.
I mean, Brittany, are you available the week of April 4th for another day?
Are you even there?
I'm here.
I have I know you're not greeting his enthusiasm, but How long do you know me, Norm?
A little while.
So the week of April 4th, I have some court.
I have some court obligations on that Monday and Wednesday.
But it doesn't appear that I have anything currently scheduled, the 5th, 7th, or the 8th.
Chris, could we make an agreement for a date certain of the 7th?
I have a trial starting the 8th.
So I would rather not do the 7.
Yeah, I hear you.
It's not a big No, you should.
You should not.
You have a trial.
I can do it the 5th or the 6th.
What days were you available, Brittany?
I could do...
So, I mean, I could theoretically go to court.
If you're saying it's not a full day, I could go to court and then come here after.
So, Chris, I would be most comfortable if we could do the 6th, because I think, you know, it's a sex one case, not a lot of witnesses, but a little bit of DNA stuff and a preliminary challenge.
You know, the fifth seems tight to me.
The sixth seems more reliable.
If it's okay with you, Mario, it's fine with me.
Yeah, it's okay.
That's okay.
So you have court at like 9, and then you'll come here after that.
Right.
So I have court at 9.
I mean, I don't know how long it's going to take, but I mean, I could come thereafter.
How long do you think you'll be?
I mean, if I get here for like noon, is that okay?
I mean, look, we could just say we'll go till we finish on the 6th.
I mean, I don't.
But you've got kids.
It's kind of hard for me to do that.
But so, so, I mean, the court is in Waterbury, so it's A drive from here, so even if I left there by a little 11-ish, I won't get here until like Zach, are we gonna be done on the 5th?
Can Cameron cover it on the 5th?
I don't know if we're gonna be done, Norm.
I would think so.
I would think so, and I certainly would hope so.
I think it's going to take about four or five days.
I think we could make arrangements, and Chris brought up some.
Maybe Cam could cover it if we're not available.
Yeah, why don't we do it on the fifth then, Zach?
Yeah, I mean, Chris, I'm sorry.
All right, and Camario, if that works for you guys, because that way we get a whole day.
The fifth is fine, too.
I can do the fifth or the sixth.
It's fine, really.
All right.
So why don't we put that on?
I've been rolling.
Oh, has the court reporter been taking this?
I believe so.
We didn't hear a definitive stop, so I don't stop unless I hear a stop.
Okay, fair enough.
We're going four or five.
Yeah, to recap, we have an agreement that we'll seek an extension from Judge Bells for purposes of taking the remainder of this deposition on April 5th.
All right.
Close up the video recorder.
Yes, we can.
▲
Export Selection