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Sept. 14, 2022 - Depositions & Trials

04:49:52

Watch Live: Alex Jones Defamation Trial: Sandy Hook 'Hoax' Lawsuit - Connecticut Trial Day Two

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	Tony Rhineland, did a Tony Patis tell you about the coffee station in Mr. Ferraro's office?
	I haven't yet, but I will read you.
	It's there for you at any time.
	And the unopened package of Oreo cookies.
	Mr. Ferraro opens up.
	It's open.
	No, okay.
	All right, so I did see the memorandum, the brief that was filed.
	On the...with the free speech system and PQ PR document.
	So how do you want to proceed on that?
	So my understanding was the court wanted argument regarding sanctions on that issue.
	I do, but I'm just unclear as to whether that one document that was produced is the document that was referred to?
	It's not the document that was referred to.
	It is, however, responsive to our discovery requests and should have been produced quite some time ago.
	And there's another document that was included that should have been produced.
	I mean, it's a document, I think it's dated 2007. Seven.
	And it was responsive to our initial discovery requests.
	So more of the same, Your Honor.
	And so we definitely need to...
	Sorry, let's address it again.
	The good news is that your jurors were all here early and they're already down and waiting to go.
	And I assume this is something that needs to be addressed now.
	Just one moment, Your Honor.
	Because if not, we can do it when they're not waiting, but I just wasn't sure.
	Well, Your Honor, I think the issue is I don't know what...
	The first witness today is the corporate representative.
	Now, I don't intend to get into anything related to PQPR, but I know the corporate representative is aware of it, and so we need to make sure that the witness is educated and informed about what the scope of any court movements may be on the issue.
	I don't intend to cover it.
	I don't intend to cover it in my cross substitution.
	No, but I'm worried about it coming out.
	Is it in the room?
	I think the court can issue whatever.
	Do you want to just speak to our attorney Pattis?
	Sure.
	May I? Sure.
	And then this way we don't have to keep the jury standing by.
	All right, Your Honor, and then we can take this up at the court's convenience.
	Right.
	Your Honor, we had also...
	- Well, I just wait for Attorney Patis so that he can hear what you're saying, if you don't mind. - We've covered good.
	- Okay, very well.
	Okay, another issue?
	One more filing this morning, Your Honor, a bench brief regarding hearsay coming in through the corporate representative.
	No action by the court is necessary right now.
	Okay.
	All right, any housekeeping matters from your side, Attorney Patis?
	I think there are a couple exhibits that we've agreed to, additional exhibits.
	Tomorrow I'll let Attorney Maddie speak to those.
	All right, can I just see council very briefly?
	I'm sorry, I cut my finger.
	There's a camera there.
	I'm going to the bathroom.
	That's alright.
	So I've already made my fair share of mistakes yesterday, and I know we're all rusty because of COVID, but they got it.
	You're right.
	I know.
	And, you know, we didn't try to process this for two years, and we're going to get off this.
	So you're right.
	Okay.
	I'm exhausted, and it showed, and I apologize, but I didn't mean to intend that to convey disrespect.
	If you're not on your feet with your objections, I'm not going to hear you.
	I don't mean to be like a husband who tunes me out at the time, so I'm just going to say that.
	Well, it's a judge now.
	I'll feel great at home.
	Okay.
	All right.
	Any other housekeeping matters?
	Yes.
	I think the plaintiff are going to submit an amended complaint eliminating what We've drawn counts of defendants and consolidating the three complaints I've reviewed it and I have no objection to it.
	Okay.
	So Your Honor, we can get that filed today.
	Alright, perfect.
	Anything else?
	Nothing from the defense.
	Okay.
	Do we have newly agreed upon exhibits that should go on the record or not?
	I could do that now, Your Honor.
	Yeah, thank you, Ron.
	And there may be more, but what I was able to discuss with Attorney Patis this morning was Exhibit 10 and the sub-clips, which is Shadow Government Strikes Again at Boston Marathon, and then Exhibit 21 and its sub-exhibit And Exhibit 23 in this sub-exhibit.
	And then there are a number of other exhibits, Your Honor, that I may use with the witness as to which there is agreement but have not been offered.
	And I'll just offer them at the time.
	I thought we had an agreement on 43 as well.
	43 as well.
	Thank you.
	All right.
	Some orders.
	Anything else before we bring the panel out?
	No.
	No, you're not.
	Thank you.
	Okay.
	Thank you.
	Thank you.
	Good morning.
	Good morning.
	You all brought some good weather with you today.
	Good morning, everyone.
	Welcome back.
	Good morning.
	Good morning.
	I heard you were all early.
	Love that.
	Thank you for that.
	So we've got a nice start.
	Council will stipulate that the entire panel is present.
	Yes, Your Honor.
	Yes.
	All right.
	Make yourselves comfortable.
	And I would just like to point out that Attorney Ryland is joining the defense table today.
	And I also would like to address One issue.
	I'll wait for Mr. Farah to hand out the no-pads.
	All set?
	Thank you.
	So you will recall from my opening remarks yesterday the procedure that I set out that you should follow if you saw or heard anything of a prejudicial nature or anything that might compromise the proper conduct of the trial.
	I haven't received any written notes from Mr. Ferrara which is the procedure that you should follow.
	You would give him A written note and I would deal with it on the record, so therefore I assume there are no such issues.
	So at any time during the course of this trial, that is the procedure that you should follow.
	I will try to remember to inquire every morning or to raise the issue every morning, but in case I neglect to do so, it's your obligation If any such issue arises, that you give a written note to Mr. Carr so that I can deal with the issue on the record if necessary with council.
	All right?
	So having said that, I think we are ready to proceed, and you plaintiffs may call their next witness.
	Thank you, and good morning, Your Honor.
	The plaintiff's called Brittany Paz. - Good morning, just watch your step when you come up.
	You brought your own water too.
	I did.
	Nobody wants our water on.
	I do.
	I speak to you.
	State your name and slowly follow your last name for the record and your business address.
	Sure.
	My name is Brittany Paz, P-A-Z, and my business address is 4 Research Drive, Suite 402, Shelton, Connecticut, 06484. Thank you.
	You may inquire.
	Thank you, Your Honor.
	Good morning, ladies and gentlemen.
	Good morning, Ms. Paz.
	Good morning.
	You and I have met before at your deposition of this matter, correct?
	Yes.
	Okay.
	And just to orient the jury, you were selected by Alex Jones That's correct.
	Okay.
	Now, I'm sure the juries know what a corporate representative is.
	So let's just go through that a little bit.
	So when a lawsuit is brought against a company like Free Speech Systems, the opposing party has the opportunity to obtain information from that company, correct?
	Yes.
	Okay.
	And one of the ways they do that is by asking the company to designate somebody most knowledgeable within the company to testify about certain topics, right?
	Not necessarily within the company, but designate a person to testify as to topics and be knowledgeable on those topics, yes.
	Okay, and so the company has the ability to select somebody, right?
	Yes.
	Okay, who's knowledgeable about the topics that, in this case, the plaintiffs wanted to ask about, right?
	Right.
	Okay, and those topics, in this case, were Yes.
	There are practices for vetting facts, that kind of thing?
	Yes.
	And he selected you, is that right?
	Yes.
	The plaintiffs had, and no offense here, we didn't select you, right?
	No, you didn't.
	Okay, that's not up to us, that's up to Alex Jones.
	Right.
	And I think you mentioned this in one of your answers is that the idea here is that in order for the plaintiffs and the jury to be able to rely upon information provided by the company, it has to designate somebody who has knowledge about those issues, right?
	Who has, right, who has knowledge but has become knowledgeable on the issues that you're asking about.
	That's correct.
	Right, and obviously we can't have somebody up here who doesn't know anything And the person that the company designates in my right, they have an independent duty to discover the facts so that they can testify under oath about them, right?
	Right, and I did have a duty to become knowledgeable about the topics that were inquired about by the plaintiffs.
	Right, and not just accept what somebody says to Well, as to what the company knows or knew at the time, I did make such efforts to corroborate information from various sources, so yes.
	And it was your duty to do that?
	I thought so, yes.
	And that's because, you know, you wouldn't want just to be the company just parroting To the extent that that was possible, yes.
	I tried to do that.
	Right.
	But Alex Jones is the 100% owner of Free Speech Systems, right?
	Yes.
	Okay.
	And by the way, we've been referring to Free Speech Systems as InfoWars.
	Is that how you refer to it as well?
	I do.
	I refer to them interchangeably.
	I think that's how I refer to it in my internal documents as well.
	Okay.
	But it is officially Free Speech Systems.
	Right.
	So if we refer to InfoWars, for example, you refer to InfoWars or Free Speed Systems refer to InfoWars, what we're talking about is Free Speed Systems.
	That's correct.
	That's the defendant in InfoWars, or one of the defendants in this case.
	Right.
	And so, we presented, we asked Free Speech Systems to select somebody to testify knowledgeably about these issues, right?
	Yes, you did.
	Do you remember when we did that?
	I don't recall the date.
	Would it have been January this year?
	Does that sound right?
	I know that's when I was selected.
	It was in late January.
	Okay.
	When you're testifying here today, and when you testified under oath in your deposition, you're doing that as free speech systems, right?
	Yes, as I sit here today, I am the corporation Free Speech Systems.
	Okay, so if at any point you say to this jury, I don't know, what you're saying is, So, let's talk about how it was that you were selected.
	It's just right that Alex Jones selected you, right?
	I mean, obviously there were discussions that are privileged discussions amongst attorneys who should be selected, and I know that there were issues finding somebody, but ultimately I was approved by Mr. Jones.
	Right, he's the only one within force that would actually have the authority to designate somebody to testify on his behalf, right?
	Right, because he's the one that owns the company.
	Okay.
	So, we don't need to put in what you chose you.
	Right.
	Okay.
	And when he chose you, you said in January of 2022?
	Right.
	It was like late January.
	I can't recall the exact date.
	Okay.
	At that time, you had no substantive knowledge about any of the topics that you were...
	Correct.
	I've never been involved with the company prior to that date.
	I had no involvement with the litigation either here or in Texas prior to that.
	So the answer to my question is correct.
	You had no knowledge when he selected you of any of his topics that you were going to testify about, right?
	Prior to January?
	That's correct.
	And even as of January when you were selected, you were selected the last year of January?
	Right.
	So I didn't begin my review of the material until after I was officially retained to do that, so it would have been sometime in the last week of January that I started review of the material.
	Okay.
	Because you're not an InfoWars employee.
	No, I'm not.
	Okay.
	And what happened was, the last week of January, I'm sure Pat has gave you a call, right?
	Yes, he did.
	Okay.
	And he offered you $30,000 to testify on behalf No.
	So initially...
	Hold on a second.
	When you were deposed in this case, isn't it true that you testified that the last week of January, Mr. Patis offered you $30,000 and you said it was fair and you accepted it?
	No, what I said was...
	Objection.
	That was not the initial number, so no.
	Can she be shown the material that she's allegedly being impeached from?
	I've just asked her at this point whether you testified to that in your deposition, that attorney has offered you $30,000 and that you thought that was fair.
	I don't recall testifying to that because that wasn't the original number.
	But if you'd like to show me, I'd look at it.
	I would be happy to do that.
	But your recollection right now is that that's not the original number?
	That's correct.
	What was the original number he offered?
	So I believe that the original number was 25,000 or 20,000 and then there was further negotiation after that given how much time we thought would be required between traveling down to Texas because there were Texas depositions as well, as well as the depositions here.
	And so there was a back and forth about the number and then the number Finally landed at $30,000.
	Okay.
	But that wasn't the initial number.
	Oh, so the initial number, to your reflection, the last week of January was $20,000 or $25,000.
	Right.
	You negotiated up to $30,000.
	Correct.
	And Alex Jones agreed to pay you that, right?
	Correct.
	Okay.
	And at the time you agreed to pay you that, you didn't know anything about anything leaving And at the time he agreed to pay you that, you knew that you were going to be testifying under oath within a couple of weeks, right?
	Yes.
	I think that the dates in Texas were in mid-February.
	There were two dates, and I wasn't sure about the dates here in Connecticut.
	But you knew that within two weeks, you were going to be expected to testify under oath And I think you would agree with me that that wasn't entirely reasonable to expect you to be overdue, right?
	I think I said that at the deposition, that it was extremely difficult, and I don't think there was a lot of time to get familiar with a lot of the material.
	Right.
	And just so the jury understands how it is that they landed upon you, you're a lawyer, right?
	I am an attorney, yes.
	Okay.
	And your first job at a law school, you were hired by Attorney Patz to work in the department.
	Yes.
	Okay.
	And you worked there for about six years, correct?
	Five years.
	Five years.
	2012 to 2017, 2018?
	So I was hired in November 2012 and I left in January 2018.
	So about five years.
	Five years.
	Then you went off on your own for a while.
	Yes.
	Then you started in another firm, right?
	Yes.
	And the week before he called you up, the last week in January, you'd been let go from your prior firm, right?
	Yes, I had started my own firm the week before.
	And I totally understand, but just to be clear, that wasn't your choice, right?
	And you didn't have another job lined up, but you're going to start your own solo practice.
	Well, I didn't intend to go to another job.
	I intended to be in solo practice.
	Okay.
	But that's when he called you and offered you the $20,000 to $25,000.
	Yes.
	All right.
	And when you agree with me that prior to being retained, Alice Jones had selected a number of people to serve as corporate representatives for him, right? Alice Jones had selected a number of people to serve I am aware there were a couple of other corporate representatives that were designated.
	There were more than a couple, right?
	I think there were at least three in the Texas litigation.
	So there was another one in this case.
	You knew that, right?
	Yes, I do recall there being another one in this case.
	And all of the corporate representatives that Alex Jones had previously designated to testify for him were long-standing employees and employers, right?
	Yes, they were actually employed in various different functions.
	He had a guy named Rob Du, who is one of his longest serving, most senior employees at the time, served as corporate representative, correct?
	Rob Dew did do a corporate rep depo, or a couple, I think.
	And Rob Dew, just to be clear, you've come to learn, is one of his most trusted and most senior employees that enforced, right?
	Objection.
	Objection, Judge Jean.
	That misstates the evidence.
	May I speak to Attorney Manny for a moment?
	You may.
	Objection.
	At the time, Rob Dews served as the corporate representative.
	he was one of Mr. Jones' most trusted and most senior employees, correct?
	I think that's fair.
	I mean, you've read the depositions in this case where Alex Jones' employees have described Rob Dew as his right-hand man, right?
	I have, yes.
	Okay.
	He had Daria Karpova, long-time employee of Free Speech Systems, serve as a corporate representative, right?
	Yes.
	Okay.
	He had Michael Zimmerman serve as a corporate representative and he's a long time head of IT at InfoWars, right?
	I'm not sure what his actual position is but I know that he's been employed there for quite some time.
	And all of these people You were selected, correct?
	At the time I was selected?
	Well, sure, they worked there.
	Right.
	And when it came time to designate a corporate representative for trial in this case, Alex Jones didn't designate any of those people who designated you.
	I think he did it because he had no other choice.
	Well, wait a second.
	Alex Jones is the head of the company, right?
	Right.
	Oh, he could have chose himself, correct?
	Well, I'm not going to go into the internal discussions between counsel, but...
	But you know that because Alex Jones had the authority to select anybody he wanted to represent his company here before this jury, he could have selected himself, correct?
	He is going to testify here, but I don't think for various reasons...
	The strike is non-responsive?
	Some order.
	You're a lawyer, correct?
	Could he have?
	Yes.
	Excuse me, hold on a second.
	You're a lawyer, correct?
	Yes.
	You understand that your obligation here...
	Yes.
	So can we just agree that you'll do that?
	Yes.
	Okay.
	So the question I ask you is to confirm that if Alex Jones wanted to, the gentleman who started this company and has had complete control over it for the last however many years, he could have come and testified to this jury on behalf of this company, correct?
	Could he have?
	Sure.
	All right.
	So, when you were called about this, you never heard of free speech systems, right?
	I don't think I've never heard of it.
	I think, like all of us, we've seen news articles.
	You've heard of InfoWars?
	Right.
	You've never heard of free speech systems?
	Did I know that InfoWars was free speech?
	No, probably not at the time.
	So is the answer no?
	Yes.
	You didn't know anything about his business, correct?
	No.
	You didn't know any employees?
	No.
	You knew nothing about his revenue, correct?
	No.
	You didn't know anything about how he made his money?
	No.
	You heard of Alex Jones, but you didn't really know anything about him, right?
	Right.
	You've never spoken to him?
	No.
	Okay.
	You've never been to the website infowars.com?
	No.
	Or any of his websites?
	No.
	You've never watched the Alex Jones show?
	No.
	Okay.
	You've never watched a single Infowars video?
	No.
	- No. - First, they knew nothing of any substance about InfoWars or Alex Jones. - Prior to being retained, no. - All right.
	And this case has been going on for three plus years by that point, right?
	Quite a few years, yes.
	Now, you said you negotiated it up to $30,000, but then you've been paid more for your preparation for trial on this case, right?
	I did invoice an additional fee, yes.
	And you've been paid?
	No.
	Okay.
	I think what you're expecting to be paid is another $7,500 for your testimony in this case.
	Yes.
	And the fee is just a flat fee.
	You're not getting paid by the hour, right?
	Right, I'm not getting paid by the hour.
	And in addition to...
	Knowing nothing of substance about the company, you didn't have any experience in media, correct?
	No.
	You didn't have any experience in online business?
	No.
	No experience in supplement sales, right?
	No.
	No experience in journalism?
	No.
	You never served as a corporate representative before?
	No.
	And you had two weeks to prepare for your first deposition, right?
	Approximately.
	There is no written agreement between you and InfoWars?
	Right.
	Well, we negotiated the fee, and then I was paid pursuant to those discussions, so yes.
	And who signed the check?
	I'm honestly not sure.
	I don't remember.
	All right.
	I'm sorry.
	It's all right.
	I'll refresh your recollection with that.
	So let's start with the basics about in the works.
	So it's located in...
	Boston, Texas, right?
	Yes.
	You've been down there since you started.
	I did go there, yes.
	You had a deposition down there and you also went to the office?
	Yes, I had two depositions.
	I saw the warehouse and the office.
	And the studio?
	Yeah, I don't think I went back to the studio.
	Oh, you did?
	No.
	And Free Speech Systems is a for-profit supplement sales business, correct?
	Supplements and amongst other products, yes.
	They sell merchandise?
	Yes.
	They sell t-shirts?
	Yes.
	They sell clothing and accessories?
	Yes.
	But would you say 80% of all free speech systems revenue is from supplement sales?
	I mean, I don't know the number.
	I know it's a big part of it, and they certainly started with the supplement sales, so it is a big part of their revenue.
	I just don't, I can't say the number, what the number is.
	You're putting an 80% number on it, and I don't know what that is, but it is a big percentage.
	Well, yeah, I'm asking you, because you're the corporate representative responsible for understanding the revenue to free speech systems, right?
	Correct.
	So let me not put my number on it.
	Let me just ask you to put free speech systems number on it.
	What percentage of revenue to free speech systems is from Alex Jones' supplement sales?
	I can't recall as I sit here today.
	I'm sorry.
	Okay, so you've been deposed.
	Yes.
	You've prepared.
	To the best of my ability, yes.
	You're here as free speech systems.
	Yes.
	Okay, so as the company, right, what you're saying is right now, as you sit here right now, the company does The definite comes from supplements, right?
	I think I said as I sit here, I don't recall.
	If you'd like to show me a document, I'd be happy to review it.
	But as I sit here today, I just don't recall.
	It's not my job to give...
	Make sure you let her finish her.
	Oh, I'm sorry.
	I'm sorry.
	Please finish what you're saying.
	I just said as I sit here today, I just don't recall.
	I think this was a topic in one of the depositions, but I just don't recall.
	Okay.
	But you understand, it's not my job to give you information here today.
	It's your job to give information to the jury, right?
	Yes?
	So I'm just saying, as you sit here right now, Free Speech Systems can't tell this jury, without reviewing something, what percentage of its sales offer something, correct?
	Correct, I just don't recall.
	So, in the...
	I'm sorry, so you didn't see the studio, right?
	No, I think they were on air when I was there, so I don't think I went back to the studio portion.
	What studios does InfoWars have?
	I'm sorry, I don't recall the number. - Here.
	I'm not sure what the number is.
	Can you ballpark it?
	There's a few studios there.
	I just don't know the exact number.
	I can't recall.
	I don't recall the number.
	How many warehouses does free speech systems operate?
	We had, when I say we, I mean free speech.
	Free Speech had the one warehouse, and that's the warehouse that housed all of the products and merchandise.
	Okay, and that's right near the office, right?
	It's very close by, yes.
	And all the products, you're talking about all the supplements?
	Supplements, hats, shirts, etc.
	Orders come in online, they get processed through the warehouse, warehouse packs them up, ships them off, right?
	Yes.
	So, let's talk.
	Let's go to exhibit Oh,
	that's 300. 300. We do like to keep him on his toes, though, so...
	No, no, I... Yeah, that is not full yet.
	Okay, we're gonna...
	It's by agreement, Your Honor.
	No objection to 300, Judge.
	Now, this is coming up here.
	Sorry, if you can just pull that.
	Thank you.
	You'd agree with me that the studio depicted here is actually not the current studio.
	This is one of the other studios, yes?
	Like I said, I didn't see the studios when I was there, but I believe that's accurate, yes.
	Okay, well, I don't want you to guess.
	Have you seen this picture before?
	Yes, I've seen this picture.
	Did you ask anybody at Infoars, hey, is this the current studio?
	Which studio is this?
	I didn't.
	I didn't ask anything specific about this photo now.
	Okay.
	All right.
	Well, why don't we do this?
	Let's pull up.
	Let's put that one to the side.
	Like we'll do this side by side with the exhibit from yesterday that I showed during my opening.
	This is one of the screen grabs for TCAT.
	I'm so sorry if I remember the number.
	Not that one.
	It's something.
	I don't think that way.
	So did you go to the warehouse?
	I did go to the warehouse, yes.
	Now, when we talk about InfoWars and free speech systems, you said Alex Jones is the 100% owner, correct?
	Yes.
	Complete control over the company.
	Yes.
	He has authority over all InfoWars operations.
	Yes.
	He's in charge and everybody answers to him.
	Yes, that is the structure.
	In fact, almost everybody reports to him.
	Yes, the only structure there is is that Alex is on the top and he kind of will filter out what is needed, but you know, to the extent that that actually gets done is the question, I guess.
	So, and you've heard, you know who David Jones is?
	Dr. Jones?
	Dr. Dickinson?
	Yes.
	He's a dentist, right?
	Yes.
	And he's Alex Jones's father?
	Yes.
	Okay.
	And he's been deeply involved with InfoWars since what, about 2012, 2013?
	What do you mean by deeply involved?
	Employed.
	I don't think that he's employed by InfoWars.
	Okay, so does InfoWars know whether he's employed?
	He doesn't receive any compensation from InfoWars directly, so...
	I don't think that he's employed by Free Speech Systems.
	Okay, so let's just see if we can nail this down.
	As of this very moment, right now, can Free Speech Systems testify whether Alex Jones' dad, Dr. David Jones, is an employee?
	Of Free Speech Systems?
	Yes.
	I don't believe he's an employee, so no.
	Okay.
	When was he first employed?
	Of Free Speech Systems?
	Yes.
	I don't recall the date.
	Has he ever been an employee?
	According to my review of the documents, he has not ever been paid by Free Speech Systems, so according to Free Speech Systems, I don't think he's ever been an employee of Free Speech Systems.
	Ms. Paz, you reviewed David Jones's deposition in this case?
	I believe I did.
	I don't recall his exact testimony.
	But I did review it.
	You don't recall his testimony that he did become employed by Free Speech Systems in around 2013?
	I don't recall.
	I'm sorry.
	You don't recall his, an exhibit that he presented to us during that deposition in which he said that he was being paid $400,000 a year?
	I don't recall that now.
	Okay.
	Do you recall the part of his deposition This is what I was trying to get to.
	Do you recall the part of his deposition where he said that Free Speech Systems is a single talent business, that talent being Alex Jones?
	Yes, I do recall that.
	Okay, recall that one.
	And Alex Jones has total authority to hire and fire anybody at Free Speech Systems, correct?
	Yes.
	He has authority to overrule any decision that's made by a subordinate?
	Yes.
	He has total authority over info versus finances?
	Yes.
	He's not accountable to any board of directors or any governing authority?
	No, he's not.
	He has 100% control over free speech systems revenue and how it's allocated, correct?
	Sure, correct.
	And I know you said that you weren't prepared to say what percentage of Infobor's revenue is from supplements, but I think the best you could do is that it's a large majority.
	Yes, it is a very big portion.
	It's probably the majority, probably a significant majority.
	I just can't say the number.
	Okay.
	Now, it does have other sources of income.
	One is advertising income, correct?
	Right.
	And donations.
	Yes.
	Okay.
	So, for example, Alex Jones will say, look, even if you don't want to buy iodine, you can make a donation directly.
	Yes.
	And one of the ways he offers people to make donations is in cryptocurrency.
	Do you know what that is?
	Yes, such as bitcoin, etc.
	Exactly.
	And I had to figure this out myself, but it's not actually cash.
	It's like, it's almost like a stock for an asset, right?
	You give some, and by the way, this is not one of the topics that you have to prepare on, It's not my forte.
	It is a source of revenue.
	I do need to ask you about it.
	It's kind of like a stock or an asset.
	Somebody could give Infowars 500 Bitcoin and it has a value.
	Right.
	I think it has a market value which changes and fluctuates.
	Correct.
	Right.
	Correct.
	And when somebody gives cryptocurrency donations to Free Speed Systems, it actually goes directly to Alex Jones' personal, correct?
	If it's a donation, Bitcoin, I believe so, yes.
	He doesn't tell his audience that.
	Does he tell his audience where it goes or what is being done with it?
	No.
	He doesn't tell his audience that when you donate Bitcoin to free speech systems, it's actually going right to me.
	He doesn't tell them that.
	He doesn't tell anybody where it goes or what he does with it.
	He tells his audience that the donations are going to free speech I don't know that he's said they go to free speech systems.
	You do or you don't?
	I don't know that, no.
	You've been to the Infowars.com website.
	Have I visited it?
	Yeah.
	Yeah.
	There's a donation page where you can donate crypto cards, correct?
	I believe so, yes.
	Yeah, and it says support the Infowars.
	Support Infowars, donate here, right?
	Support Infowars, yes.
	Support the production, support the business, the show, help us stay on the air, that kind of thing.
	That kind of thing.
	Right.
	Except once you donates, it doesn't go to that.
	It goes to Alex Jones, right?
	Well, Alex Jones needs to stay on the air, so...
	I mean, I don't know if that's what he means by it, but that's how it's being advertised.
	But the point is...
	As far as where is the money kept, yes.
	Thank you.
	So the way Free Speech Systems attracts customers for its supplements is by serving them free content, right?
	Like the show and the website.
	And then when they arrive for the content, directing them to the online supplement store, right?
	Right.
	There are various ads and banners on all of the articles, on all of the individual pages, on the videos, and then you click on those ads and that will take you to the InfoWars store.
	Right.
	And that's the business model.
	You come to InfoWars.com where there's the news, right?
	Well, right.
	If you come to the homepage, right, and you can click on various articles from the homepage.
	Right.
	So just follow me here.
	So Alex Jones is a huge audience, right?
	Oh, sure.
	Yes.
	The audience accesses his content either through the radio, and we'll get to that.
	But let's just talk about online first.
	Okay.
	This huge audience accesses his content.
	Including the content that we're here about.
	The content that sits in you, it was a hoax, right?
	Yeah, all the content.
	They do it online.
	That big audience comes to Infowars.com, right?
	Correct.
	Or Band.video, it's a video site, right?
	Right.
	Or in earlier days, Prison Planet TV, right?
	Right.
	Okay.
	PrisonPlanet.com, right?
	Right, there are a few websites.
	News Wars, that's another one?
	Yep.
	Infowars Europe?
	Yes.
	Okay.
	They come to all those websites, and then when they get there, Alex Jones sends them to the store, right?
	Well, and it's not send them.
	You have to click on the ad.
	But yes, there are ads all over.
	You know, on all of the articles, on all of the videos, there are ads all over.
	So, I mean, you don't send them there.
	You have to click on it.
	You have to click on it.
	Right.
	But actually, for Infowars.com, the first thing you see when you pull up the website is an ad.
	You mean when you first go to infowars.com?
	Yeah, like if I type in infowars.com right now and it takes me to the website, the first thing I'm going to see, before I even get to the headlines, let's call them, the first thing I'm going to see is an ad for, just give you an example, super female vitality, right?
	Sure, it's very, very prominent on the very first page of the website.
	Not only is it prominent, you can't even see the first page of the website until you click through that ad, right?
	I'm not sure if you have to click through it.
	I haven't been on the website in a while.
	That's okay.
	Let's probably pull up Exhibit 84.
	This is already in Judge Fultz.
	That's not what I meant.
	I'm sorry.
	Let's pull up Exhibit 85. Thank you.
	86. Here we go.
	Thank you.
	Alright.
	This is what I was talking about.
	So, this is what I was referring to.
	When you come to Infowars.com, this is the first thing you see, right?
	Yeah, it's a pop-up ad.
	It's a pop-up ad.
	Right.
	You don't have to click on the ad.
	You can X it out.
	Right.
	You click the X up in the upper right button, and if you do that, you get to the news.
	Correct.
	If you click on DNA Force Plus, 50% off.
	It'll bring you to the store.
	It'll bring you to the store.
	Correct.
	Oh, yes.
	Most of it.
	So, Your Honor, I'm just going to open the door.
	Is that okay?
	Oh, I'm going to go there next.
	Thank you, Your Honor.
	Sonny getting low So we talked a little bit about I just mentioned the audience.
	I want to talk about that.
	Since the San Diego shooting, Mr. Jones' audience has grown exponentially.
	Is that fair to say?
	Since 2012, yes.
	So there has been an increase in the viewership.
	It's been, at least as Mr. Jones has described it, it's been exponential, correct?
	I think he's used those words, yes.
	Correct.
	And as a result of that growth, Alex Jones and InfoWars have had billions upon billions of social media impressions, correct?
	I'm sure that there have been that many.
	I don't know the exact number, but I'm not going to disagree with you that there's a big social media footprint.
	I talked about this in my opening.
	Objection, Judge.
	It's not evidence.
	Sustained.
	No, no.
	I was just promising because now we're going to show them the evidence.
	So why don't we pull up Exhibit 220.
	Is it just the entire is in the judge?
	Yes, they do not.
	That one's right.
	Okay.
	Now you've reviewed this document before, right?
	Yes, I think I've seen this before.
	So, one of the things that we asked Infowars to give us were all of their social media numbers beginning in 2012, right?
	Yes.
	Now, they didn't give us all of their numbers, did they?
	I'm not sure what was produced, to be honest, and I know that there have been issues with locating material and finding out who has access to certain material and things like that.
	It's back to what I was asking you about earlier.
	You acknowledged that you have an independent duty, did you not, to determine things like Alex Jones' audience size, correct?
	And I did make attempts to do that, yes.
	Okay, and you, because you knew we had asked for all of their social media audience numbers, you asked them to give it to you, correct?
	Yes, I asked for a lot of information regarding social media, and audience size, and financials, and I asked for a lot of material, yes.
	And Alice Jones didn't give you any social media numbers for 2012?
	So I don't think that there's, and no, I didn't receive anything to that effect, and there's a problem as to why that is.
	Well, there's a problem as to why that is.
	You agree with me that Alex Jones was under a legal obligation to produce that type of data for the years that we asked, correct?
	I understand that he is under the obligation to produce.
	And you asked for it, correct?
	I asked for a lot of things, yes.
	And in 2012, you weren't given any social media data for 2012, correct?
	I did not see any data for 2012, no.
	Because you weren't given it.
	I was not given any.
	You weren't given any for 2013, right?
	No.
	Okay.
	And you personally weren't given any.
	Any social media audience figures, correct?
	I don't believe so, no.
	But we have this.
	And so let's take a look at this.
	This is 2015. And you understand this to be...
	Let's just focus on the title there.
	You understand this to be a group report...
	For the year 2015 for all of Alex Jones' social media accounts on Facebook, Twitter, Instagram, and LinkedIn, right?
	That's what it appears, yes.
	Okay, let's go to page two.
	And we're just going to advance through this.
	These are the accounts that it covers, correct?
	Yes.
	Alright, let's go to page, the next page.
	Okay, and let's just pull up the top portion there.
	Alright.
	So this is for 2015, right?
	Alex Jones' and Infowars' social media engagement numbers for the accounts that we saw, right?
	Right, for those particular accounts.
	So in 2015 alone, there were 2.9 billion impressions, right?
	That's what it says, yes.
	That means that on social media, his stuff was viewed 2.9 billion times.
	Viewed.
	Right.
	Impressions and then the engagements are different.
	We're gonna go to that.
	Viewed.
	28.8 million engagements, right?
	Engagements, yes.
	And what that means is they liked it, right?
	Liked it, commented on it, retweeted it.
	Shared it.
	Shared it, right.
	And then there were 24 million link clicks.
	So if somebody sees in 2015, let's say for example, you're aware that in 2015 Alex Jones was repeatedly airing Wolfgang Halbin's trips to Connecticut, right?
	He did a few times, yes.
	He had him on the air, right?
	Yes.
	He had Dan Badandi up here with him?
	Yes.
	Okay.
	And if somebody saw that on social media, that would be the type of link click we're talking about here.
	They clicked on it, right?
	Right.
	So if a link to Hal Biggs' interview was in one of those social media posts and a link to the article or a link to the video and they clicked on that link, correct.
	That's what that means.
	Okay.
	And that's just for 2015. Yes!
	Let's go to Exhibit 228. I believe this is in as well.
	Yes, it is, Your Honor.
	The number on that's here?
	220. Thank you.
	Yeah.
	Actually, I'm going to ask a few more questions about that last exhibit, so let's just take that down for a second.
	And free speech systems actually made social media engagement and audience growth a central pillar of its growth strategy from 2012 on, correct?
	I'm sorry, I don't understand the question.
	Can you repeat it?
	Sure.
	Let's take the evening back a little further on that.
	You'd agree with me that very, very early on, Alex Jones realized the power of social media to spread his content, right?
	Sure.
	That's why he has all those various accounts.
	Well, that's 2015, but he was on social media 2009, 2010, wasn't he?
	Yeah.
	Right.
	And that's just when it was really kind of coming on, correct?
	I had a Facebook in 2005, so I guess I don't know.
	I had one in 2005. And Alex Jones had built a pretty significant social media audience in the early 2000s.
	Fair to say?
	Sure.
	And a central strategy of free speech systems growth was to engage audience on social media, correct?
	Sure.
	And the way that they did that was every time Alex Jones would film the Alex Jones show, the show would be chopped up into clips, right?
	Yes.
	Okay.
	And Alex Jones would personally title every clip, right?
	I don't know if he personally titled all the clips.
	I think producers did have a hand in it as well.
	But I don't know if he personally titled every single clip from two three-hour segments.
	So I don't know that he had a personal hand in each and every one.
	I know he has titled clips.
	So I'm just asking, is Free Speech System's testimony that it doesn't know whether it was Alex Jones' practice to title every clip from his show?
	I don't recall, as I said here today, whether he titled every single clip.
	I know he has done it.
	I'm sorry.
	I'm sorry.
	You do recall Nico Acosta's testimony on this subject, correct?
	He has been deposed, yes.
	Nico Acosta was Alex Jones' longtime producer of The Alex Jones Show, correct?
	Yes.
	Okay.
	And he testified that it was, in fact, Alex Jones' practice to title every single clip from The Alex Jones Show, correct?
	I don't recall.
	I'm sorry.
	All right.
	Well, the jury will see that.
	Sure.
	In any event, every single clip was uploaded to Facebook, correct?
	Every single clip.
	I know a lot of clips were uploaded to Facebook.
	I don't know if every single clip was always uploaded to Facebook.
	I don't recall.
	Let's do it this way.
	Sure.
	The practice at Infowars was to upload every single clip that Alex Jones would clip from I don't recall whether it's every single clip.
	I know a lot of clips have been uploaded.
	But Ashley, that was the practice, wasn't it?
	To upload clips to Facebook?
	Yes.
	And it was the practice to upload clips from The Alex Jones Show to Twitter, correct?
	Yes.
	It was the practice to upload them to YouTube, right?
	Yes.
	It was the practice to upload them to every online platform he had, correct?
	Yes.
	If you go to band.video right now, you can see the full broadcast of The Alex Jones Show, correct?
	Yes.
	And you can see every clip he made of it, correct?
	I believe so, yes.
	And the reason that he did that is because Alex Jones knew that video is the most engaged medium online, correct?
	I don't know how to answer that.
	I don't know what he knows about the videos.
	I know that that's what he does.
	I can't say what he knows.
	I don't know.
	Well, aren't you responsible for knowing what he knows?
	Isn't that your duty?
	My responsibility here was to figure out what free speech systems knew at the time.
	So I wasn't in Alex Jones's head, so I can't say what he thought about videos.
	Did you ask him about his strategy for increasing his audience online?
	I don't recall us specifically talking about that.
	I did have a couple of conversations with him prior to my depositions in Texas, but I don't recall us specifically talking about that.
	Free Speech Systems is aware that video, as a medium, is the most engaging medium online to grow audience, correct?
	I don't know.
	People are most likely to click on it, correct?
	I don't know.
	And Free Speech Systems knows that titling videos in a way that is designed to get attention is another way to get its audience to engage with it, correct?
	Oh, sure.
	Daria Karpova, Mr. Jones' longtime producer, testified about this, correct?
	Yes, I do recall that testimony.
	She talked about clickbait, right?
	Yes, she did.
	Clickbait.
	Clickbait is the way that you title a video to provoke a response in the person seeing it, correct?
	Yes, I believe that was her testimony.
	So like, for example, a headline like, Connecticut School Massacre Looks Like False Flag Witnesses Say, that's clickbait, right?
	It's clickbait in the sense that it would grab somebody's attention, yes.
	And it's clickbait in the sense that it wasn't true, correct?
	I'm sorry, repeat the question, what wasn't true, that title?
	Correct.
	That witnesses say, can you repeat the title?
	Yeah.
	Connecticut School Massacre looks like false flag, witnesses say.
	One of the reasons it was clickbait is because it's attention grabbing.
	The other reason is because it's false.
	Correct?
	Correct.
	Is the reason why it was titled that way and it's clickbait because it's false?
	I don't know how to answer that question.
	Let me break it down.
	Free Speech Systems acknowledges that that headline was false, correct?
	I don't think that we disagree with that there were false statements made in connection with the Sandy Hook litigation or not litigation, I'm sorry, but in connection with Sandy Hook.
	And one of the things that Connecticut School Massacre looks like a false flag.
	Witnesses say it's false.
	I don't disagree with that, no.
	Free Speech Systems doesn't disagree with that.
	Correct.
	Because in that video, there wasn't a single witness who said that it looked like a false flag.
	Correct?
	The video for that particular clip that you're referencing?
	I don't recall the specific clip.
	Would you like us to look at it?
	I don't recall the specific clip as I said here.
	And one of the reasons you don't recall it, and this goes back to your preparation, Well, Alex didn't provide it to me specifically.
	I received it from the attorneys.
	So, Alex didn't give me copies of material.
	I received it from counsel to review.
	Okay, so which lawyer sent you material?
	So the material that I reviewed was in a Dropbox.
	That Dropbox was shared with me by, I believe, our Free Speech Systems attorney at the time was Attorney Blott.
	So I shared the material in the Dropbox from her.
	Attorney Blott.
	Attorney Blott represented Alice Jones in Free Speech Systems.
	In Texas.
	In Texas.
	He has a number of lawyers, right?
	Quite a few.
	And Dino Renal is one of his lawyers, right?
	Most recently, yes.
	Okay, have you talked to him?
	No.
	Okay.
	Mark Randazza is one of his lawyers, correct?
	Yes.
	You've met with him, right?
	No, I don't believe I met with Mark.
	Oh.
	I saw something in your time records that you had a meeting with Mark and Zach.
	Who was that?
	Zach is Attorney Ryland.
	He's sitting right there.
	And Mark Schwartz.
	Okay, Mark Schwartz.
	Yes.
	Alex Jones has been represented by Brad Reeves.
	Yes.
	And Attorney Pattinson, his firm.
	Yes.
	Okay, but it was Ms. Blatt who sent you the material.
	Yes, she had access to the Dropbox.
	And it would only have been Alex Jones who had the authority to decide what to send you, correct?
	Objective calls for speculation.
	No, I was provided with everything that they had in their production, so I don't think anything was withheld from me, if that was your question.
	That is what I'm getting at, because the video Connecticut School Massacre looks like I don't.
	I don't recall.
	I had a handy-dandy note.
	As you recall, I had a hundred pages of notes on the videos that I watched, and I don't have that in front of me, so I just don't recall, as I said here, which videos I watched.
	Okay, and I'm going to show you that testimony.
	Sure.
	But, let me ask this.
	It would have been very relevant to you to have seen the first things that Alex Jones said about the senior shooting, correct?
	Of course.
	And the first things he said about the Sandy Hook shooting are on that video, Connecticut School Massacre Looks Like False Flag Witnesses Say, correct?
	I don't know.
	I just don't know what video we're talking about.
	Just because I don't have my notes.
	All right.
	So I don't recall.
	Just one moment.
	thank you I am moving on Is it?
	Thanks.
	Thanks.
	All right.
	Can we just bring up, just for the witness, please, tip 10 on the deposition.
	This has been marked for ID, Your Honor.
	And I'll figure out what it is.
	Is it on the list, sir?
	Yes, yes, yes, yes.
	Thank you.
	Thank you.
	So, Ms. Pauz, as you sit here today, you don't know at the moment whether you were provided with the very first video that Alex Jones aired on.
	Oh, we can take that down.
	I just wanted to give a witness.
	You recall at your deposition, there was a stipulation about videos?
	Oh, yes.
	There was, yes.
	I'm going to bring below 2.45 just for you.
	Sure.
	Not yet.
	there's nothing there yet yes I see it can we do it just for the witnesses screen please not for every screen do we know how to do that okay go down to exhibit exhibit A please to this I think we should Okay.
	Do you still have that?
	Yes, I do.
	Can you scroll down to Exhibit A?
	Exhibit A, you will recall, Ms. Paz, is a list of videos that you are providing, right?
	Yes.
	Okay.
	Yes.
	And the video, Connecticut's school massacre looks like false flag witnesses say, was not provided to you, correct?
	It's not on this list, no.
	Now I've been told I'm wandering a little bit.
	So I'm trying to get back on track.
	Happens.
	Having looked at that video though, that chart there, that reminds you that the title of that video was Well, as you said, it wasn't on the list of videos that I reviewed, so...
	Right.
	But we talked about it in your deposition.
	We did, yes.
	Okay.
	And Free Speech Systems acknowledges that in that video, not a single witness said that San Diego was a false flag, correct?
	I don't believe so.
	Meaning yes, you acknowledge that?
	Right, right, correct.
	All right.
	So let's go to that exhibit I was trying to pull up for over.
	This is 228. This is going back to our discussion about qualities.
	And the reason we got on that video is because I was, I'm reminding myself now, that the reason we got on that video is because I was talking to you about the different ways that Audience, right?
	And that's how we got on ClickBank, right?
	Okay.
	But what I really want to talk to you about is the audience.
	And so this exhibit 228, you're familiar with Google Analytics, the term?
	Yes, and I've seen this exhibit before.
	This is a program that InfoWars uses to track its web performance, right?
	Well, I know that there's an issue as to whether we actively use this, but it is available to free speech to track this type of information as far as internet traffic.
	Let's just pull it down for a second.
	So, I'm not asking that.
	Your free speech systems?
	Yes.
	We're about to look at an exhibit from InfoWars showing Google Analytics data, correct?
	Yes.
	Does Free Speech Systems use Google Analytics to track its website performance?
	So we talked about this a lot in our depositions as far as whether we...
	I don't want to know what we talked about in our deposition.
	I just want to know yes or no.
	As Free Speech Systems sitting here right now, does it use Google Analytics to track its website performance?
	It is available according to my investigation.
	It does not actively use this information.
	Is that a yes or no?
	No.
	No, I'm confused, Judge.
	I don't mean to be rude.
	It was no to you or no to the question?
	I assume it was no to the question.
	That's what I, I'm sorry, it was no to the question.
	Sorry.
	So Free Speech Systems' testimony here today is that it does not use Google Analytics to track its website performance, correct?
	Correct.
	That's based on my various investigation and discussion with the employees and my review of the material.
	We'll pull up Exhibit 125. Now this is an email from Chris Andrews, right?
	Yes.
	InfoWars employee, correct?
	Yes.
	Sent June 20th, 2014, right?
	Yes.
	To Tim Fruget, right?
	Yes.
	Tim Fruget is Mr. Jones' longtime director of his online business, right?
	He basically runs the online store.
	I mean, I don't know if I'd say long time, but he's come and gone quite a few times.
	But he, at that time, was, yes.
	Okay.
	He's only come and gone once, right?
	Like, he was hired back in 2009, right?
	He was hired back and then he left again.
	Right, but just stick with me now.
	He was hired in 2009. Right.
	Okay.
	He worked for InfoWars all the way through 2019, right?
	Right.
	I don't know the exact date, but yes, he left in 2019. He came back briefly in 2021, I want to say.
	Correct.
	Because he was opposed in this case in 2019. Yes, he was.
	So he is being sent this email by Chris Andrews, right?
	That's what it says, yes.
	This is all four of our websites from Google Analytics.
	These are the updated versions of the others also, right?
	That's what it says, yes.
	And attached are four Excel spreadsheets for different websites owned by Free Speech Systems, right?
	That's what it says, yes.
	One is Infowarshop.com?
	Yes.
	At the time that was Mr. Jones' online store, right?
	Yes.
	Okay.
	He then added infowarsstore.com a couple years later, right?
	Yes.
	There's another one for infowars.com.
	That's the website?
	Yes.
	Okay.
	frithandplanet.com.
	That's another website, right?
	Right.
	And what Mr. Andrews is doing is sending Alex Jones's business director all of the numbers for those websites, of how those websites were performing, correct?
	On this particular date, yes.
	Right.
	And if we scroll down, let's scroll down to Infowars.com for 2011. We talked about this in opening.
	Can we put up both pages, would you mind?
	Oh, great.
	Yeah.
	So, the jury saw these numbers in opening.
	This is basically Infowars.com's website performance for the whole year, right?
	That's what it is, yes.
	208 million page views being sent to the business director.
	I don't know if that was his title at the time, but it was emailed to him, yes.
	Do you want to revise your testimony that you just gave to the judge that Infowars doesn't use Google Analytics?
	No, and if I could expound on that, I would be happy to.
	Well, before you expound on it, why don't you tell me who gave you the information that InfoWars doesn't use Google Analytics? - Thanks. why don't you tell me who gave you the information So I did review, obviously, the various depositions, but I also spoke to Blake Roddy, who is currently employed there, and I did review with him.
	There's a couple of emails to that effect about requests to pull Google Analytics and whether it's done with any regularity or whether it is Can I just stop you there for a second?
	Sure.
	Because I think what I asked you is, who told you that they didn't use it?
	Did Blake Roddy tell you that?
	Yes.
	Okay.
	Blake Roddy told you that they didn't use it?
	His position to me was that they only usually pulled it or would pull it at the request for litigation purposes and sporadically at the request of various people, but it wasn't actively used in the marketing strategy.
	Let's go to 2012.
	I can't see the number on Exeter.
	Number, please.
	Same exhibit.
	Thank you.
	So you're at 2012, right?
	And we went through this in opening yesterday as well.
	You see the total numbers for 2012, right?
	Yes, I do see it, yes.
	Okay.
	286 million page views, right?
	That's what it says, yes.
	Okay.
	And then you see the numbers for December.
	10.6 million sessions, 4.6 million users, 24.9 page views.
	24.9 million page views, right?
	That's what it says, yes.
	You reviewed this exhibit before?
	Can you zoom out on it?
	This is the email that we've been looking at.
	I'm sorry.
	Can you just go to the first page?
	Sure.
	No, that's not the first page.
	This is the email that we just pulled up.
	Right.
	No, I mean the first page of the Google Analytics.
	I reviewed the files that looked like they had the charts on them.
	So I don't recall whether I saw this specifically.
	But I have reviewed various Google Analytics documents.
	Do you know whether they gave this to you?
	I'm sorry?
	Do you know whether they gave this to you?
	I don't recall.
	I do recall seeing various Google Analytics documents, so I don't recall this particular document.
	And the reason I'm asking if they gave you this one is because, let's go back to 2012, or informers.com.
	And let's...
	Is this it?
	Pull up 2012 and 2013. The reason I'm asking you when they gave you this one is because if you look between December 2012 and January 2013, you know there's any shooting out on December 14, 2012, right?
	Yes, I know the date.
	By the way, free speech systems acknowledges now in this courtroom.
	Yes.
	They acknowledge that Adam Lanza is the person who went into the school that day and the only person, correct, and committed that atrocity, correct?
	Yes.
	FreeSview Systems now is saying that to this jury, right?
	Yes.
	If you look at December, you had 10.6 million sessions.
	It goes up to 14.6 in January, doesn't it?
	That's what it appears, yes.
	It appears or it is?
	That's what the document says, yes.
	This is your document, right?
	Free speech systems produce this, yes.
	Okay.
	It goes from 49 million users...
	Well, this one's...
	That's the year total.
	4.6 million users to 6.3 million users, correct?
	That's what it says, yes.
	It goes from 24.9 million page use to 35.7 million pages.
	Right?
	That's what it says, yes?
	And you know that from December 14, 2012, all the way through the end of January, Alex Jones and Free Speech Systems were repeatedly publishing claims that the shooting was staged, correct?
	I believe so, yes.
	And you know from Timothy Fuget's deposition, the business director, that Alex Jones asks him for sales numbers every day, right?
	Yes, he does ask him for numbers regarding how much is in stock, if there's an overstock of particular items so that he- Right, he does get sales numbers, yes.
	Right.
	And you heard Timothy Fruget's deposition that Alex Jones knows what he's talking about on the air when they have a good sales day, right?
	I'm sorry, can you repeat the question?
	Alex Jones knows what he's talking about on the air when they have a good sales day.
	Right?
	You mean if he has a good sales day, it's related to what he's talking about on the air?
	Is that your question?
	I want to make sure I understand your question.
	My question is, you recall Timothy Fruget's deposition, correct?
	I know he testified.
	Yes, and I reviewed it.
	He testified that Alex Jones knows what he's talking about when he has a good sales day.
	Correct.
	He knows what he's talking about, translates into sales, yes.
	And you remember David Jones' deposition.
	David Jones, I know you say you don't know whether he's ever employed, right?
	Right, I don't recall the deposition testimony.
	You don't?
	I don't recall Dr. Jones' deposition testimony regarding the employment.
	Okay, right, right.
	Right, right.
	You recall David Jones' testimony that when Alex Jones has a good sales day, they try and replicate what he was talking about.
	So that they can replicate those sales.
	I do recall that testimony.
	Your Honor, I'm sorry, can you remind me when our morning break is?
	We can have it any time, between now and the next 10 minutes.
	Is this a good time?
	This is a great time.
	All right, so we will take our morning process at this point.
	You'll remember all the rules for conduct that I told you about.
	Ron will collect your notebooks and we will see you in 15 minutes.
	We'll take all the steps.
	Ready for the panel?
	It's her part of the judge's court.
	You can judge to decide then.
	Judge, do you want to wait until the panel comes in?
	It doesn't matter.
	She can wait.
	Yes.
	Yes.
	We've had more rain in the last weeks than we had.
	So much fun.
	Yes, you know, it was funny, I'm dragging it down to the office right there at 5.30.
	I'll be able to get me in suit this case, you know.
	Thank you.
	Thank you.
	Please be seated.
	Give my mental count of 10 to make sure you're all here.
	Council stipulates that the panel is present.
	Will do.
	Yes, Your Honor.
	Okay.
	Thank you, Mr. Foro.
	Can we just figure out the desk tape anymore in the slides?
	Can we fix it?
	I believe so.
	I'll do a bunch of adjustments.
	We can wait and see if we hear it again.
	Judge, may I speak to Mr. Farah before we begin?
	Certainly.
	I've got a bunch of them locked.
	Can you get it open during the lunch break?
	Okay.
	Okay, thank you.
	Thank you, Judge.
	You're welcome.
	Whatever your ready, attorney, I need you.
	I was thinking about the best place to put it so that everybody can see.
	I suppose it would probably be over here so that the defense counsel can see it.
	It's pretty far for the jury.
	It is.
	I guess I could put it up there.
	Let's see.
	I'll figure it out.
	All right.
	So why don't we pull up Exhibit 2015.
	200.
	I got a little nervous.
	That's a full exhibit?
	Yes, it is.
	All right.
	Now, Ms. Paz, this is the same group report, but for the year prior, 2014, right?
	Right.
	That's what it looks like.
	All right.
	Do you have the same response as you did to the earlier one that you don't know if this was provided to you?
	I don't, yeah, I don't recall.
	I'm sorry.
	All right.
	No problem.
	But you'd agree that just like the 2015 report, this 2014 report shows all of InfoWars' social media performance for the year 2014 on those four social media platforms.
	Twitter, Facebook, LinkedIn, and Instagram.
	Right.
	Okay.
	All right.
	Let's go to page two.
	And these are the accounts listed here. - The 100 grand stream.
	I'll count them up.
	I'm not going to ask you to count them up.
	I'll count them up at some point for the jury.
	Sure.
	There's a lot, right?
	There are quite a few.
	And let's go to...
	By the way, YouTube is not here.
	Do you know why?
	I don't know why.
	Well, free speech was de-platformed in 2018, but this is 2014, so I don't know.
	Objection to strike, Your Honor.
	Sustained.
	I don't know.
	Testimony is stricken.
	The jury is disregarded.
	Thank you.
	In 2014, obviously, InfoWars was uploading videos to YouTube every day, correct?
	Yes.
	Okay.
	But it didn't produce any data to us concerning its YouTube page performance, correct?
	Did we?
	No.
	Let's go to the next page.
	Let's pull up not just the top box, but the whole area where there's text.
	You'll recall that in 2015, and I should have started with this one, I'm sorry, but in 2015 the total number of impressions was 2.9 billion.
	I'll take your representation on that.
	I don't recall.
	You don't recall.
	I'll accept that representation.
	Here it's...
	I'll show it to you again.
	Here it's 2.2 billion impressions, right?
	Yes, that's what it says.
	And this is where, at the advice of my co-counsel, I'm going to use this easel.
	All right?
	Because I want...
	Sometimes people feel better about paper versus screens.
	So, here we are.
	So, we're talking about, can you see council?
	Yes.
	Yes, depending on how big the numbers are.
	Now, there are other screens, so you don't have to look at this if you don't want to, but let's talk about 2014. Okay?
	You got 2.2 billion impressions, right?
	That's what this side is.
	All right.
	All right.
	And 7.7 million engagements, right?
	Sure, you can round that up to 7.8.
	Thank you, 7.8.
	10.3 million link clicks, right?
	Yes.
	Now 2014, this was the year that 2014. Yes, that's correct.
	Right.
	Yes.
	And Wolfgang Halbig on the Alex Jones Show called this Indian shooting an illusion, right?
	Did Wolfgang Halbig do that?
	Yes, he did.
	Yeah, and Alex Jones agreed with him.
	Yes.
	Okay.
	He said that the parents should get an Oscar for their acting performance, right?
	I believe he did, yes.
	Alex agreed with him.
	I believe so, yes.
	Okay.
	He said that it had been scripted two plus years in advance, the shooting that is, right?
	Did Mr. Halbig say that?
	Right.
	Yes.
	And Alex Jones agreed.
	Yes.
	And by the way, it wasn't just Mr. Halbig.
	I mean, Alex Jones during 2014 was calling it a fake and a total publicist, correct?
	Yes.
	And during this year, You know that all of those shows and all of those articles lying about Sandy Hook went up on InfoWars social media channels, correct?
	Yes, they did.
	Do you recall Louis Sertuti's deposition testimony?
	I don't think I do, I'm sorry.
	You know who Louis Sertuti is, right?
	I'm terrible with names, so it's not ringing a bell.
	Do you remember the guy's deposition with the long hair who testified about free speech systems' social media operations?
	I don't recall.
	I'm sorry.
	Did you watch the deposition of Infowars social media manager?
	I know I read the deposition of Mr. Roddy and Mr. Zimmerman.
	Aside from that, the other ones I don't recall.
	All right.
	Let me just try one more time, though, Mr. Tookey.
	I take the thing that you don't have a recollection of his testimony that all Infowars articles and videos went up on all of their social media platforms, including all of their San Diego content.
	I don't recall the testimony.
	Okay.
	Is that in fact true, though, that that's what happened?
	That all of the videos go up on all of the social media platforms?
	Clips of them do, yes.
	And all of you do, correct?
	Yes, yes.
	Now, in this year where Alex Jones Total fans, 1.7 million.
	I don't know.
	Do you know what that means?
	I'm sorry.
	The clipboard is in the way.
	Okay, go ahead.
	Do you not have it there?
	I do have it there.
	Which one are you referring to?
	Total fans, 1.7 million.
	Oh, yes.
	I see it.
	And you see that the total followers since the previous date range went up 41%.
	Yeah? - That's what it says, yes.
	- All right, let's go down to the next page.
	Okay.
	Now, you'll see here, this is about message volume, right?
	- Yes.
	- Message volume means messages that InfoWars fans are sending into their social media accounts, right?
	Yes.
	It's one way that InfoWars engages its audience, right?
	One of the ways.
	We're going to hear Alex Jones say, send us your tips, right?
	Sure.
	Okay.
	And you're aware that one of the things that InfoWars You know what that means?
	I recall seeing it saying missions.
	So yes, I know what you're talking about.
	They say to their audience, here's your mission, right?
	Yes.
	Okay.
	And it's another way of engaging their audience, right?
	Right.
	The verbiage is used to take in the audience.
	That's correct.
	Right.
	And one of the ways that Alex Jones did that was by giving his audience a mission to investigate San Diego, right?
	Was that one of the missions?
	Yes.
	I don't recall if it was specifically one of the missions, but he did give out missions.
	I do recall seeing social media posts to that effect.
	Right, and one of the missions, in fact not just one, that he gave out was to investigate San Diego.
	That's an answer, Judge.
	You already said she didn't recall.
	I don't recall specific posts.
	You do recall, though, Alex Jones looking directly at the camera on his show and telling his audience to, "Let's look into Sandy Hook," right?
	I do believe I recall seeing him saying something to that effect.
	Right.
	He said that right after he said to his audience, and I think I can get the exact word, but you tell me, Carmelo, right after he said to his audience, so my heart goes out to the people I see on the news who say they're parents.
	The only difference is I've seen soap operas before, and I know the difference between when I'm watching a movie and when I'm watching something real.
	Let's look into Sandy Hook.
	Do you remember that mission?
	I don't know if he termed it a mission, but I recall him using words to that effect.
	And in this year, the messages that they were receiving from their fans went up 557%.
	Yep.
	On social media, that yes.
	Yes.
	They got emails too.
	Many, many emails.
	Right.
	Alright, let's go to the next stage.
	Ah, okay.
	So now here we're getting into the breakdown of the impressions.
	You see Facebook had 1.2 billion and in Twitter you're at 1 billion, right?
	That's what this says, yes.
	Up 300%, 307% from the year before, right?
	That's what it says, yes.
	Okay.
	Another page.
	Yeah, let's pull up the next two pages side by side, if you don't mind.
	See, this chart's getting a lot of use here.
	All right.
	Okay.
	While we're working on that, I'm going to show you the engagement here.
	Engagement is also up 100%, right?
	Yes, that's what it says.
	And that's what we were talking about earlier.
	Every time an audience member likes something, shares it, reposts it, comments on it, and that type of engagement is what InfoWars was going for, correct?
	Sure.
	All right.
	And they've increased 100% in The year they were having Halio.
	Actually, the first year they had Halio.
	Right.
	They started to have them on that year.
	Right.
	Okay.
	So what I want to do now is go to the page where all the accounts are listed, if you can.
	Turn that year.
	Are you going to use that chart?
	I am for the next one, for 2015, but is it in the way?
	No, it just will all turn this way, but that's all right.
	Oh.
	I'm sorry.
	Sorry, down where they have the logos, down further.
	You know, like where they have the icons.
	Yeah, yeah, yeah, yeah, yeah, yeah.
	Let's get those.
	So these are just the graphic listings of the different accounts here, right?
	So if you went to one of the pages, you'd see the InfoWars report, et cetera, right?
	That's Twitter.
	Down further, you've got the Alex Jones page, right?
	Yes.
	And obviously, the Alex Jones pages dwarfed the other ones in terms of their pilot insights, correct?
	According to this, you mean?
	Yeah.
	Oh, yes, because this is ranked.
	so the others are ranked higher so yes well this is where Facebook starts so like on this side right that's Twitter above right here's Facebook obviously yeah You know, he's way above everybody else, yeah?
	Yes.
	Let's go to 2015. The next one, 2015. Thanks.
	This is 220, Your Honor.
	This is the one we were looking at earlier that I told you I'd show you again.
	- Yes. - I'm gonna lose this again here.
	All right, and let's go to the second page.
	I'm gonna go through all of these.
	Here's the accounts, right?
	Let's go to the third page.
	Okay, and here we are again, and here we have the 2.9 billion impressions, The times this stuff is new, yeah?
	Yes.
	Okay.
	And let's go down and see the growth numbers.
	Yeah.
	So here, fans are up 21% this year in 2015, correct?
	That's what it says, yes.
	Let's go to the next page.
	Here we are again with increasing engagement in terms of messages coming in, up 129% since the previous date range. up 129% since the previous date range.
	In terms of, so the first number, 129% are posts sent and that's messages that InfoWars was sending out.
	Those are those missions we were talking about, right?
	Among other things, but yes.
	And the message they were receiving also of 144%, right?
	That's what it says, yes.
	Okay.
	Let's go to the next page.
	Okay.
	Impressions up 30% over the $2.2 billion, up to Well, let's pull up the Facebook group report for 20...
	I'm sorry, not a group report.
	The Facebook report for 2016. This is in evidence, Your Honor.
	And this is 222. Now, this is just Facebook, right?
	I don't think 222 is in yet, but I don't object.
	It is a full exhibit.
	- Okay, yeah, all right.
	Now this is 2016, right? - The following year. - The following year.
	This doesn't include Twitter.
	This is just Facebook.
	That's what it looks like to me.
	We didn't get Twitter numbers for 2016, correct?
	I don't believe so.
	But anyway, we got Facebook.
	So let's go down to the second page.
	These are the accounts included in the report.
	This isn't all the reports.
	This is Okay, so in 2016, how many impressions were there?
	4.1 or 4.2.
	Billion, right?
	Billion.
	So, Facebook alone in 2016, 4.1 billion, yeah?
	That's what it says.
	That's what it says, all right.
	43 million engagements, 29 million.
	So what we're seeing here, Ms. Paz, is during these three years for which we have data, this is the explanation that you're talking about, right?
	Using Mr. Jones' words, yes.
	And it would be fair to say that Alex Jones had no competitors when it came to social media, online, I'm sorry, what do you mean competitors?
	Yeah.
	In terms of people who were lying about Sandy Hook during this time, right?
	Nobody touches Alex Jones in terms of audience.
	Fair to say?
	Objection, Judge.
	Speculative?
	I don't know.
	I don't know.
	I don't know how to answer that.
	I didn't prepare any information comparing other broadcasts.
	I can only speak for free speech.
	Great.
	Well, then let me ask Is Free Speech Systems aware of any other media personality during this time who was publishing information that Sandy Hook was a host that even comes remotely close to his audience size?
	Like I said, I can't answer that.
	I don't know anything about any other companies aside from Free Speech.
	So the answer is Free Speech Systems is not aware of that, correct?
	The answer is I don't know.
	Free Speech Systems doesn't know.
	That's correct.
	All right.
	Now, correct me if I'm wrong, but during this three-year period, just impressions, and just on some of the social media platforms, there were 9.2 billion impressions, and just on some of the social media platforms, there were Impressions, yes.
	Right.
	I'll trust your math on that.
	Okay.
	Next.
	Next.
	Thank you, though.
	Amen.
	All right.
	Now, while we don't have social media numbers for those earlier years, we did see the Google Analytics, correct?
	For which years?
	We saw them for, I showed them to you for 2011, 2012. Yes.
	And then into 2013. Yes.
	And those Google Analytics numbers weren't social media, they were just InfoWars.com.
	I believe so, yes.
	One question.
	Yes.
	But Infowars produced things called media kits, right?
	Media kits.
	What do you mean by media kits?
	Well, I'll show you.
	This is Exhibit 212, which is in Now, this is a message from Derek at InfoWars.com.
	Do you know who Derek is?
	I know that we had an employee named Derek that I don't believe works there anymore.
	Yes.
	Okay.
	You don't know his last name?
	I don't.
	I'm sorry.
	He was an employee in 2013?
	Yes.
	Do you know what he did?
	I don't.
	Okay.
	What about the people who he sent this to?
	Will at InfoWars and Max at InfoWars.
	Do you know who those guys are?
	I'm sorry, no.
	Okay.
	And you'll see here that there are attachments to this email, media again.
	That's what it says.
	Okay, so what's a media again?
	I don't know.
	Okay.
	Do you know what free speech systems use?
	I don't know what it is.
	I've never seen this before.
	This wasn't given to you?
	I don't believe I've seen this.
	Okay.
	Well, let's take a look at it.
	Let's pull up the attachments.
	Now, what you'll see, Ms. Paz, is that there's a date here, 2013, right?
	That's what it says.
	And it says Free Speech Systems, LLC. Yes.
	And it kind of gives you the topics that this document is covering, right?
	Yes.
	Now, we'll go through the document, but let's...
	If you're looking at this cover page, does this give you a sense that what this is is the type of information that Alex Jones would give to potential advertisers who would pay to place ads on InfoWars.com?
	That's what it looks like.
	Okay.
	And so let's go down.
	And you see there the first line.
	The house that Truth built.
	I see it.
	And you know that Alex Jones, in selling himself to advertisers, but also in selling himself to his audience, tells them that they can count on him for the truth, right?
	I have seen him say that, yes.
	Right.
	You've seen videos where he said, somebody's got to tell you the truth, folks, right?
	Somebody's got to do it.
	I've seen him say words to that effect.
	Yes.
	He actually said that right after he told his audience that Sandy Hook was staged.
	The evidence is overwhelming.
	I've seen him say that, yes.
	He said that in April of 2013, right?
	I don't recall the date, but I know that he said something to that effect, yes.
	You don't recall that it was on the day of the Boston Marathon bombing?
	I don't recall the date, I'm sorry.
	Alright, so let's go down here.
	And what I'd like to do is go down to the second page.
	Alright, now, let's pull up kings of their domains and just pull up the...
	Yeah, okay, that's okay.
	Here he is saying, in terms of web popularity, Infowars.com and PrisonPlanet.com are on top of their class, right?
	That's what it says, yes.
	And this is 2013, correct?
	I think that's the date that was on the document, yes.
	Okay, and it gives the number of visitors to the websites per month, the number of unique visitors per month, the number of 30 million page views per month, right?
	Yes, that's what it says.
	Okay.
	Ms. Potts, isn't this free speech systems using Google Analytics?
	I don't know how they got those numbers.
	Well, we've seen the Google Analytics where these numbers are presented, correct?
	We've seen Google Analytics numbers, yes.
	Where else would they have gotten?
	I don't know.
	But you know that they didn't use them.
	That's what you told the judge.
	I told the court what information was relayed to me that they did not regularly use the Google Analytics in terms of their marketing.
	What you told the judge was, because the judge asked you, is that a yes or a no?
	In response to the question, does free speech systems use Google Analytics?
	She said, is that a yes or no?
	And you said, that's a no, right?
	Right.
	And the reason you think it's a no is because that's what Infowars and Alex Jones told you, correct?
	I don't believe Alex told me that, but I think I said Blake Roddy told me that.
	And it's not true, is it?
	I can only convey to you what I've discussed with the employees and what I've reviewed.
	So that's based on my review.
	Because InfoWars doesn't want this jury to know just how closely it was tracking his audience growth as Alex Jones was saying that Sandy Hook was a lie, right?
	I don't think that's accurate.
	Let's go down to the next page here.
	You don't think that's accurate because somebody told you that?
	Do I think I want the jury not to know?
	Not you.
	Alex Jones.
	Whoever claimed to you they don't use Google Analytics wanted you to say that to the jury.
	Objection, Judge.
	It's speculating.
	Contents of another mind.
	Do I think that Mr. Roddy didn't want me to know that free speech uses Google Analytics?
	Well, he definitely didn't want you to know that.
	That's why he told you that they don't use it, right?
	I don't think that was the reason why he told me that, no.
	Okay.
	Whatever the case is, when Mr. Roddy told you that they don't use Google Analytics, he knew that that's what you were going to come and tell this jury, right?
	Objection, Judge.
	Sustained.
	All right.
	Let's go.
	Let's see here.
	Your Honor, just one moment. - You're done. - One more time, stand still.
	- No, no, which year?
	Oh, okay.
	We were talking about Blake Roddy.
	Okay.
	Now, Blake used to work for Tim Fruget, right?
	Yes.
	So I do believe he worked underneath Tim for a while, and then he took over at a certain point, probably after Tim left.
	So just to make sure the jury knows, because there's a lot of names being thrown around.
	Tim Fruget...
	Prior to when he left in 2019 was Infowar's online commerce director, correct?
	I don't know if he had a title, but he handled the website, so yes.
	And the e-commerce side of the website, so yes.
	So he ran the online store, he tracked the sales, he ran the warehouse.
	The whole...
	You know, revenue generating side of the business, Tim Fruget supervised and reported to Alex Jones, right?
	Sure.
	Okay.
	And Blake Roddy was his subordinate.
	Tim Fruget supervised Blake Roddy.
	Yes.
	Tim Fruget leaves in 2019, Blake Roddy gets promoted.
	Right.
	So those are the guys we're talking about, right?
	Yes.
	OK.
	And what we see here on the top left is what InfoWars is telling its advertisers they're going to charge.
	Yes, that's what that looks like.
	Okay.
	Two dollars.
	What's CPM mean?
	Cost per...
	You know what?
	I'm blanking on what the M is.
	Okay.
	I'm sorry.
	Okay.
	I don't call.
	Okay.
	Basically, they're saying that for every thousand impressions your ad gets, is that what you understand to be?
	You pay us two bucks?
	Right.
	And you pay us, every time somebody clicks on an ad, you pay us 50 cents?
	Right, so there's a difference between impressions and the actual engagement and the cost, right?
	Now, the reality is that InfoWars didn't advertise other people's products very much, right?
	Objection when, Judge?
	2013, what's that?
	I guess I don't know how to answer that.
	You mean if we were advertising, if we were taking money for advertisements, were we actually advertising the products on the store?
	No, no, no.
	I was a bad question.
	I'm sorry.
	What I was saying is...
	Really, almost every product that Infowars advertises on its platforms are its own products.
	In 2013?
	2013. Right.
	And that remains true, yeah?
	Sure.
	Let's go to the 2000 and Okay.
	So you see here, this is the media kit they put out for 2014, right?
	Yes.
	Next year, they're telling their potential advertisers, come advertise with us, right?
	Yes.
	And the main pitch they make to potential advertisers is just how big and engaged their audience is, right?
	Yes.
	Well, right, the purpose of it is to make people want to advertise with the company.
	And the way you do that is by telling the people just how many eyeballs are going to fall on their ads if they advertise with InfoWars, right?
	Right.
	Alright, let's go to the next page.
	Now, I'm going to be honest with you, Ms. Paz, I'm just going to ask you, again, this is the house that Truth built, right?
	I see that, yes.
	You know, if we go to the text, Yeah, it's not words.
	Or maybe Latin words.
	Were they advertising internationally?
	Do you know?
	No.
	You don't know?
	You don't know.
	Okay.
	Let's go.
	Let's go down to topping the charts.
	Okay.
	Okay.
	So on the top there, you have the, again, they're telling their audience just how many million visitors per month, right?
	Yes.
	Okay.
	And they're telling their audience their rankings, right?
	Their website rankings.
	I'm sorry, where are you looking?
	Yeah, when you see topping the charts, holding our own against the mainstream media.
	Okay, I see.
	It's the comparison.
	Yes, I see.
	It's the comparison.
	So you see the six different websites listed there, right?
	Yes.
	And what they're saying is, hey, we're bigger than Glenn Beck.
	We're bigger than Rush Limbaugh.
	We're bigger than Newsmax.
	And we're bigger than WND.com, whatever that is, right?
	Yes.
	Okay.
	They're the biggest, right?
	I guess my question is, I don't know what those numbers mean.
	Maybe zoom out a little bit?
	Well, you know what?
	Yes, go ahead and zoom out.
	But you know that Alex Jones consulted a program called Alexa, right?
	Okay, I see what it is.
	This isn't the Alexa you have in your kitchen where you ask what the weather is going to be today, right?
	This is a website ranking program, right?
	That's the source, yes.
	Right.
	And you know that Alex Jones regularly consulted Alexa to see where Infowars.com was in the world rankings, right?
	I believe he did.
	Yeah.
	And here, as of 2014, in the United States, Infowars.com was the 301st most popular website.
	That's what it says, yes.
	Right.
	Of all the millions of websites in the United States, right?
	That's what it says here.
	Okay.
	And in the world...
	All the websites in the world, InfoWars was 1,222, right?
	Let's get out of this.
	All right, no, no, no, yeah, yeah.
	I think, let's go, I'm sorry, go to the next page please for Tegan.
	Thanks.
	I think it's just more-- Oh, OK.
	So if we go-- yeah, let's go to that page.
	Oh, I'm sorry, the next one down.
	Here, they're just giving pricing out again, right?
	Let's pull up that page, demographics.
	Now, what program was InfoWars using to track the demographics of its audience?
	You mean to create this chart?
	Yeah, yeah.
	Where did these numbers come from?
	I don't know where these numbers come from.
	Okay.
	Do you have any idea how InfoWars.com knows that 60% of its users are male and 40% are female?
	I don't know what information was used to create this chart, so I don't know.
	But one of the topics that you were responsible for presenting sworn testimony to the jury on was exactly this, his audience, right?
	Right.
	Okay.
	And so did you ask, hey, what type of information does InfoWars have on audience demographics?
	I did when we produced the Google Analytics, but as we said earlier about how or when the Google Analytics were used, that was the information that was conveyed to me.
	Is it your understanding that Google Analytics tracks demographics?
	I don't know if it tracks demographics.
	I thought that's what you just said.
	I don't know if it tracks demographics.
	Okay.
	If it does, then here we see another example of...
	Objection.
	Hypothetic.
	Speculative.
	If it does...
	So you asked somebody at free speech systems about if or's audience correct?
	You mean how much how much the audience is and the breakdown of it or just demographics?
	Did you ask, hey, I'm supposed to testify to this jury about enforced audience demographics.
	What do you have on that?
	I believe I did.
	I just don't recall whether I ever received any information on it.
	I don't think I did.
	Okay.
	All right.
	And so when you said There's going to be a jury, and if you ask questions about demographics, can you give me what you have?
	You don't think they gave me anything?
	Right.
	They clearly have it, right?
	Well, I don't know what they had or where they got this from.
	I just don't know where this information came from, right?
	Right.
	But it came from somewhere.
	Well, it had to come from somewhere.
	And they're purporting to their potential advertisers that this is their audience demographics.
	That's what it says, yes.
	But they didn't give you that information.
	Of how they came to those numbers, no.
	Or even that they had the numbers.
	Or that they had the numbers, or where they came from, or if they're reliable, I don't know.
	Okay, all right Okay Let's go to 217 in Orr's Media Kit.
	I'm sorry, Exhibit 2017.
	This will be the 2016 media kit.
	And this is in, Your Honor.
	Council, you mean Exhibit 2017, not 2017.
	Oh, 2017 is a full exhibit.
	Yeah, yeah, yeah.
	OK. All right.
	Now we're in 2016. Same deal, right?
	And there's really just a couple things I want to go through on this one.
	Let's go to the second page.
	Let's go down.
	OK, and how's the truth built?
	We know that.
	Let's go down.
	All right.
	Now let's pull up the bottom part here.
	Yeah, yeah, OK. Now here, this is Alex Jones telling potential advertisers about his reach, right?
	Yes, same as in previous ones.
	Okay, but this is 2016. Right.
	And now he's got 150 affiliate radio stations that the Alex Jones Show is airing to, right?
	That's what it says, yes.
	Okay.
	He's got 40 million page views a month.
	That's what it says, yes.
	Okay.
	And that's just on InfoWars.com, right?
	And I don't know if it also includes Prison Planet and the other websites.
	For that, we have to check the Google Analytics, right?
	YouTube, half a billion views.
	Yes.
	Audio stream, what is that, like podcast?
	I'm not sure if that means a podcast or...
	Streaming of the videos on other platforms if they were posted elsewhere, so I'm not sure if that's what that means.
	You're not sure?
	Right.
	Alright, let's back out of this then.
	Now, there's one thing that I really did want to ask you about.
	Let's go to the next page.
	Keep going.
	Is that it?
	Okay.
	We can take that one down.
	Okay.
	Okay.
	Ms. Files, is one of the ways that Infor's offered people to advertise with them that they would say, hey, we'll add a headline that looks like a news headline to our website?
	But it'll take our reader to buy something in Jerusalem.
	Did they ever do that?
	You mean to craft the ad in a certain way that it doesn't look like an ad?
	It looks like...
	Doesn't look like an ad.
	It looks like an Infowars news headline.
	Oh, I'm not sure.
	I don't know.
	OK.
	Now, all of this audience, all of this audience that we've been talking about, remember when we talked about earlier about the business model?
	Yes.
	Maximize that audience.
	Get them all to the content websites and then send them to the store, right?
	Because if you have billions of audience members, some percentage of those people are going to end up buying your stuff.
	And that huge audience growth translated into hundreds of millions of dollars in sales, correct?
	Over a broad period of time?
	What time period are we talking about?
	Well, let's take 2012 till today.
	2012 to this very moment.
	So in the last 10 years.
	Last 10 years.
	Hundreds of millions of dollars, right?
	I don't know what the exact figure is, but it's quite substantial.
	I don't know if it's hundreds of millions of dollars, but...
	Well, this is kind of important, right?
	Free speech systems revenue.
	You know that you were supposed to talk about it.
	Jackson, Judge, can we have a question?
	You knew you were supposed to talk about this, right?
	Yes.
	Okay.
	And all I'm asking you, I'm not even asking you for a precise number.
	Okay.
	Okay.
	Hundreds of millions, yes?
	I believe so.
	Okay.
	More than 500?
	I don't know the exact number, which is why I said I wasn't sure about the exact number.
	What would you want to look at to figure that out?
	I believe we've produced yearly the revenue from the websites.
	Did you look at them?
	Have I seen them?
	Yes.
	But you don't remember anything?
	The number is off the top of my head?
	Just anything more closely approximated than just hundreds of years?
	I just don't want to guess is my point.
	I don't want you to guess either.
	And as a result of all of that revenue, it's fair to say that Alex Jones has become a very, very rich man.
	Well, Alex Jones owns the company and the website is earning money, but I don't...
	Do you want to talk about the value of the company?
	Okay.
	I can't talk about his personal finances.
	I'm here to talk about free speech.
	Well, didn't you produce at least some evidence concerning his compensation?
	Yes, we produced some evidence as far as his draws from free speech as well as his compensation for the years at issue.
	And you know having reviewed that, that he's become very, very rich.
	I know he's made some millions of dollars, yes.
	Ms. Fox?
	Some millions?
	Some millions.
	Would you like to talk about specific numbers?
	I don't recall the specific numbers.
	Has he made, personally, $100 million?
	I don't know what the number is.
	All right.
	All right.
	So let's do this.
	All right.
	So, Miss Paz, Alex Jones started his, the Alex Jones show, pardon me, a radio show in Austin, Texas, correct?
	Yes.
	20 years ago, something like that?
	Long time ago, yes.
	And shortly after that he formed Free Speech Systems, or InfoWars, right?
	Yes.
	And the reason he formed Free Speech Systems was to create a platform for him to make money off of his radio show, right?
	Well, right, to expand the radio show, to build that brand, build that practice, yes.
	Okay, thank you.
	And he was syndicated across the country.
	We saw the 150 million affiliates, sorry, 150 affiliates.
	Right, on the radio, yes.
	On radio, okay.
	And that's when he started his website, InfoWars.com, right?
	Right, at some point thereafter.
	Okay.
	And Infowars.com started to publish articles, right?
	Right.
	It styled itself as a news website.
	Yeah?
	Yes, yes.
	And he started to sell stuff too, right?
	Not supplements at that time.
	He was selling...
	Objection to which time, Judge?
	I'm talking about the early 2000s when we get started.
	The very early period?
	Yeah.
	So, I mean, at some point they weren't selling supplements when they first got started.
	Right.
	Right.
	But I can't remember the year after that.
	But it was some time later.
	Yeah, so first it was like DVDs he was selling, right?
	Yeah.
	Okay.
	He was selling some merchandise.
	Yeah.
	Right.
	Selling some ads, right?
	Yeah, here and there.
	I mean, nothing crazy.
	And he had a magazine that he was selling.
	He did have a magazine, yes.
	Right.
	I've seen the magazine.
	He had an email newsletter, yeah?
	Yes.
	He started filming his radio show and streaming it to Infowars.com.
	Yes.
	He started building some other websites like Prison Planet TV, right?
	Right.
	PrisonPlanet.com.
	Yes.
	He got on social media as we were talking about, yeah?
	And the whole message, The overarching message that he was sending out to his audience from the very beginning until now is that there is a group of international media, financial, and political elites,
	including in our own government, that are conspiring including in our own government, that are conspiring to establish a global, tyrannical government to enslave and ultimately kill people, right?
	Those are his opinions, yes.
	But he created his brand to broadcast those opinions, yes.
	Well, I'm just talking about this one message, okay?
	I'm not asking you about an opinion because Alex Jones tells his audience that this is in fact the case, right?
	That global elites are...
	Let me read it to you again.
	Sure.
	Okay.
	Alex Jones has conveyed to his audience for the past 20-some years that there is in fact a global conspiracy of international media, financial, and political elites, including our own government, who are conspiring to establish a global tyrannical government to enslave and ultimately kill people.
	Correct?
	He has said that, yes.
	And he hasn't said, hey, This is just my opinion.
	What he said to his audience is, this is in fact happening, right?
	That's what he thinks is happening.
	And that's what he tells his audience to believe, correct?
	Yes.
	Okay.
	And one of the ways he gets his audience to believe that is by telling his audience that he is a journalist, right?
	I know he has said that he is a journalist, and I have talked to him about this particular issue, but he has said it on a couple of occasions.
	Yes.
	A couple of occasions?
	I don't know how many times, but the broad...
	You're on a roll if you're on a court.
	Yes.
	So let's not, let's just say...
	Objection, Judge.
	Can we have a question rather than admonishments?
	Well, I think it is important for...
	Objection, Judge.
	May we have a question rather than argument?
	All right.
	So just to be clear, Alex Jones hasn't told his audience that he's a journalist a couple of times.
	He advertises on his website that he is a journalist, correct?
	I don't recall as I'm sitting here seeing advertisements.
	Alright.
	Well, let's go to that then.
	Do you know which one I'm going for?
	72.
	Number, please.
	72.
	Thank you.
	Now, let's pull this one up.
	This is, and you know this because when Michael Zimmerman was InfoWars corporate representative doing what you're doing now, he testified that this was on InfoWars.com website in 2015, he testified that this was on InfoWars.com website in 2015, correct?
	Yes.
	Yes, I do recall seeing this.
	Alright, and let's go to, let's see if we, I think it's right between the first and second page.
	Do we have it here?
	There he is.
	Syndicated radio journalist and documentary filmmaker, right?
	I see that, yes.
	You can take that down.
	Okay.
	So, in 2015, when his website is getting millions and millions and millions of views, they're seeing that he's a journalist, right?
	That's what that says.
	Right.
	He didn't say it a couple of times.
	He said it every time somebody came to his website.
	Well, I mean, it's on the website.
	Right.
	So, it's however many times it's viewed.
	Well...
	We know how many times the website was reviewed in 2015, right?
	Right.
	Tens and tens and tens of millions.
	Objection judge asked and answered in evidence.
	Yes, we already talked about it.
	Do you agree that's more than a couple?
	I'm sorry, I guess I misinterpreted you when he's saying it versus when it's being published on the website.
	Maybe I wasn't clear.
	I'm sorry.
	Sorry, confusion there.
	Getting back to my question, one of the ways that Alex Jones gets his audience to believe that there is this global conspiracy out to kill and enslave them is by telling them that he is a journalist, right?
	Objection, Judge.
	Asking her to speculate on the contents of another mind and its impact on the listener?
	Is the question whether the purpose, the reason why Alex said these things?
	things I don't know you met with Alex Jones right I did.
	You took notes of your conversation with Alex Jones?
	I did.
	You put in all caps at the bottom of your notes that Alex Jones told you he is not a journalist?
	Yes.
	That was very important for him for you to tell this jury, right?
	It was important for him to get across to me that that's what he thought.
	No, no, no.
	It was important to him that you tell this jury that because he knew that's what you were going to do.
	Objection, argumentative.
	She doesn't know it was important.
	I don't know if he knew I was going to tell the jury that, but he wanted me to understand that's what his position was.
	Well, he's paying you $37,000 to testify here, right?
	I was paid to do a broad array of analysis of the company and to testify in connection with the Texas litigation and hear yes.
	So there's no question that he knew you were going to come here and testify to these people, right?
	Objection, Judge.
	Again, calls for speculation in what Mr. Jones knew.
	He'll testify here.
	He knew you were going to come and testify to these people.
	Well, I'm sure he knew that I was designated as the corporate rep and so that was my purpose, so yes.
	And he wanted you to tell them that he's not a journalist, right?
	That is the sum and substance of what my conversation was.
	But what he tells his audience is that he is a journalist, right?
	Judge asked and answered...
	He has, as we saw in the exhibit, yes.
	And he says that because he wants them to believe what he's saying is true.
	Asked and answered.
	Overruled.
	I can't say it to what is in his mind, so I don't know his purpose.
	He doesn't want his audience to know that he doesn't verify facts that he puts on the air, right?
	He doesn't want them to know that he doesn't do internal research?
	Is that what the question is?
	You know that Alex Jones does not verify the facts he's putting on the air, right?
	If he reads it somewhere, he will just broadcast it elsewhere.
	So he doesn't do any independent analysis of what he's reading elsewhere.
	That's right.
	But he tells his audience that he does.
	Objection is mischaracterizing the testimony.
	Sustained.
	He tells his audience that he does do deep research, doesn't he?
	Objection.
	Same objection as what previously stated.
	Is the question whether he has said that he has done deep research?
	I recall that he has made such a comment on at least maybe one or two occasions regarding Sandy Hook, yes.
	You recall the comment he made where he said, I did deep research and it just pretty much didn't happen, right?
	Essentially, that's what the quote is.
	And that's what he wanted his audience to believe, right?
	That's what he said on that particular occasion.
	All right.
	And when he was telling his audience this claim about that they were under attack, he would latch onto stories in the news to prove he would latch onto stories in the news to prove that to them.
	right?
	That's a lot of what he does on the show.
	Under attack by whom?
	This global conspiracy that's out to kill him.
	Him or everyone?
	Everyone.
	Everyone, right.
	So what he'll do is he'll take a news article, he'll pull it from a list of sources that he uses, and he'll print them out and He has a desktop camera and he'll zoom in on it and he will talk about whatever it was that interested him in the news that day.
	And the idea here is that he'll see something in the news, like let's just take a food shortage.
	You know that Alex Jones has told his audience that this global conspiracy is intentionally manufacturing food shortages to starve them.
	Yes.
	That's what he says.
	That's what he thinks, so that's what he says.
	Ms. Paz, did Alex Jones tell you, I think there are fruit charges happening?
	I did not talk to him about fruit charges.
	So please don't testify as to what he thinks he didn't tell you.
	Objection, Judge.
	- Judge, can we have a question rather than an admonishment? - Well, I would just really do that in the house to say, answer the question that's asked.
	- Okay. - You're not distinguishing between what he said and what he thinks.
	I don't know what he thinks.
	You just know he said that.
	Have I seen him say on videos that there are food shortages being caused?
	I've seen him say things like that, yes.
	And he says there's a food shortage.
	This global conspiracy is out to starve you, right?
	That's what he says.
	And you know he sells that audience food buckets of storable food, right?
	Yes. - It's the best, In any sense, he says, don't let him starve you.
	Buy my storable food, right?
	That's what he says on the videos, yes.
	You know that he's told his audience that One of the ways that the globalists are trying to kill them and starve them out is intentionally polluting the food and water supply.
	I believe he has said that, yes.
	And the way he tells them to deal with that is by buying his water filtration systems, right?
	I believe they are connected to the advertisement for that, yes.
	And those same chemicals, in addition to poisoning the water supply, are sapping his audience's libido, right?
	I believe so, yes.
	And so he sells them to deal with that super-male and super-female vitality in order to fight back and save themselves.
	Right, they're connected to those advertisements for those products.
	And he says to his audience that this global conspiracy has intentionally released pandemics upon them to kill off a significant part of the population, right?
	I believe he has said that, yes.
	Including the COVID-19 pandemic.
	He's said that amongst other things about COVID. And what he's offered his audience as a way to deal with that are immunity boosters.
	Right?
	So that if they buy his products, they could be safe from COVID. That has been intentionally inflicted upon them to kill them.
	He has said those things, yes.
	And in fact, he's received withdrawal.
	And the way he's able--
	By the way, were you here during open stages?
	I was in the building, but I wasn't in the room.
	Were you in the overflow room?
	No.
	Okay.
	Are you familiar with Alex Jones' product, basal beet?
	I'm sorry, I'm not.
	Okay.
	It's like beet juice?
	Okay.
	I don't know.
	Do you know what Alex Jones says about the health benefits of beet juice?
	I don't recall specifically statements regarding beet juice.
	Sorry.
	Do you know what it retails for?
	I don't.
	I can use a drink of bean juice right now.
	And the way, am I correct, that Alex Jones has been able to convince his audience to buy this stuff is by convincing them that he is the only one who's telling that Alex Jones has been able to convince his audience to buy this The truth about this, right?
	Objection as to the forum.
	Judge calls for speculation on the contents of other minds.
	Can you rephrase a question?
	Sure.
	Free Speech Systems agrees that Alex Jones has built a very loyal public, correct?
	Sure.
	Okay.
	A very engaged public.
	Yes?
	Yes.
	His credibility with his audience is central to his ability to sell their products, correct?
	I think he said that too, so yes.
	And that's why he tells them that when they come to InfoWars, he'll give them the truth and nothing but, right?
	I think that's one of his taglines, so yes.
	And he calls his audience truth seekers, correct?
	Yes.
	And even though Alex Jones is not a journalist, he tells his audience that he will deliver them the truth in journalism, correct?
	I think that's also a tagline, yes.
	Do you recall in David Jones' deposition when he was asked, you have a very unique audience that is highly loyal to you and purchases products based on essentially Alex Jones' credibility with them.
	Is that fair?
	Do you recall his testimony was yes?
	I do recall that, yes.
	All right.
	How's everybody doing?
	We want to take lunch at 1, Judge?
	I think 1 to 2.
	Okay.
	Yeah, I'm doing it.
	And not only was he telling his audience that they count on him for the truth, and that he's offering them truth in journalism, but that he would reveal the truth and that he's offering them truth in journalism, but that he would reveal the truth to Okay.
	I believe he said that, yes.
	Because to him, the mainstream, what he calls the mainstream media, they're in on this conspiracy to kill people, right?
	He said that, yes.
	All right.
	Let's play.
	One moment, Your Honor, if I may.
	All right.
	- All right.
	Ms. Paulus, you're aware that on the day of the Boston Marathon bombing, Alex Jones would broadcast, correct?
	Did he broadcast that day?
	Yes, he did.
	And I'm going to play you a clip from Plainish Exhibit 10, which is being admitted as the off-roadcast which is being admitted as the off-roadcast on April 16, 2013.
	This will be Exhibit 10.
	This is the interruption.
	It says the clips are sir?
	Yes.
	Which one?
	Thank you.
	I've interviewed the cops and the people that saw the fence, black and the moms in the city.
	You saw them staged Fast and Furious.
	Folks, they staged Aurora.
	They staged Sandy Hook.
	The evidence is just overwhelming.
	And that's why I'm so desperate and freaked out.
	This is not fun.
	You know, getting up here telling you this.
	Somebody's got to tell you the truth.
	Somebody's got to stand against this penal.
	Somebody's got to do it.
	This is what we were talking about earlier, when Alex Jones was telling his audience that somebody's got to tell them the truth, right?
	Yes.
	This is five months after Sandy Hook, yeah?
	I don't recall exactly when the bombing happened in Boston, but...
	Assume with me that this is April 16, 2013. Sure.
	Okay.
	Five months after Sandy Hook, right?
	Take your representation, that.
	It was five months later.
	Okay.
	They staged Sandy Hook.
	The evidence is overwhelming, right?
	Amongst other events, but yes.
	I'm asking you about Sandy Hook right now.
	Yes, he says Sandy Hook in the video, yes.
	The evidence is overwhelming, right?
	Yes.
	You agree with me that you heard him say also that they staged Aurora, right?
	I did hear that, yes.
	What was he talking about there?
	The shooting at the movie theater at Aurora, Colorado.
	There was a shooting at a movie theater in Aurora in August of 2012, right?
	I don't recall the date of that shooting, but it was prior to this video.
	A few months before San Diego?
	Yeah.
	And you said that was staged?
	Yes.
	Because one of the things that Alex Jones does...
	Is he tells them that these horrible mass shootings are actually hoaxes, right?
	The ones that he mentions there, yes.
	And he tells his audience that the American government is staging these events as a pretext for disarming them, right?
	He has used those, that type of words, verbiage in terms of Second Amendment and Second Amendment rights, so yes.
	Okay, I'm not asking about the Second Amendment, okay?
	I'm telling, I'm asking you to confirm that what he's saying is that these, that the hoax is intended to disarm the American public, correct?
	Objection to the form, Judge.
	Objection to the form, I apologize.
	In this clip?
	No, no.
	Well, let's talk about Sandy Hooker.
	Right?
	Okay.
	He tells his audience over years and years and years that Sandy Hook was a fake hoax event.
	And the reason these evil globalists did it, faked it, is because they wanted to create a pretext for disarm you.
	That's what he says to his audience, yes?
	That's one of the things he says about Sandy Hook, yes.
	And the reason these evil people want to disarm you is so that it's easier to enslave and kill you.
	That's the threat, right?
	That's what he says about various shootings.
	Yes And this strategy of telling his audience that they could count on him for the truth Who's paying off?
	Both in terms of audience growth and in revenue, correct?
	Correct?
	I'm talking about the period, let's say, meeting up to the same issue.
	The strategy related to what?
	I'm sorry, I don't understand the question.
	What we've been talking about.
	This message that he's been pushing out and telling his audience that all these things that they have to fear A, he has remedies for that he'll sell them, and B, he's the only one that'll tell the truth about it.
	That strategy's working for him, right?
	Well, if you're looking at the social media numbers and the visits to the sites, yes.
	But even before Sandy, that was the strategy that was working, right?
	I think it's been the strategy.
	I think it's been his strategy.
	And in 2011, he was profiled in Rolling Stone magazine, correct?
	I don't recall. - Good job.
	I don't know if I... I don't recall.
	I'm sorry as I sit here.
	Do you recall looking at his website where he cites the Rolling Stone article and the comments that we did about him?
	I don't remember.
	Do you know what I'm talking about when I say Rolling Stone article?
	No.
	You don't?
	I don't remember.
	Okay.
	Let's...
	And by 2011, Miss Paz, at least by 2011, Alex Jones knew that his audience could be provoked to violence. - Correct. Alex Jones knew that his audience could be provoked to violence.
	I don't know what Alex knows.
	Free speech systems knew that its audience could be provoked to violence.
	Judge, may we approach?
	Objection, may we approach?
	Yes.
	Is this something we should excuse the jury for?
	Because if it's an objection, it needs to be done on the record.
	Well, if that all these were on the record.
	But I mean...
	It might be brief, I just had a lot.
	Prespeitch systems knew what she was talking about.
	I don't know that the plaintiffs can have it every which way.
	way they found a motion say she can't I hadn't myself It came in last night.
	But my understanding is that the corporations I made my objection and I don't need to argue it at this point.
	but maybe later in the day, Judge.
	Okay.
	Okay.
	By 2011, free speech systems knew that Alex Jones' audience could be provoked to violence, correct?
	I don't know.
	Are you referring to a specific incident?
	Well, I'm getting there, but is your answer, I don't know?
	I don't know what you're referring to okay And one moment 70 where you are Let's just hold off.
	Yes, it is.
	Okay.
	Alright.
	Now, are you familiar with this webpage on Infowars.com?
	It's an About Alex Jones webpage.
	Did you see that?
	Yes.
	And this was...
	In 2016, you recall Mr. Zimmerman's testimony that this appeared on the 2016 website, correct?
	I believe so, yes.
	I do recall that testimony.
	All right.
	And let's go to page, actually, can you go back to page one?
	Okay, I don't want to belabor this point, but in the second paragraph there, it says that he routinely breaks huge stories, it says that he routinely breaks huge stories, right?
	The third full paragraph?
	Yeah, he routinely breaks huge stories.
	That's what it says, yes.
	Right, but he's not a journalist, so that's not true, right?
	Objection, argumentative.
	Sustained.
	Okay, we'll move on.
	Let's go to the next page.
	Next page.
	Okay, so you see here on this webpage about Alex Jones, they reference a 2011 Rolling Stones article, correct?
	I see that, yes.
	Okay, and they describe a quote about Alex Jones in that article, correct?
	Yes, I see that.
	In the first paragraph, right?
	Yeah.
	We can take that.
	And Alex Jones actually was interviewed for that article, correct?
	I would assume so, based on that article.
	Okay.
	And so, when Free Speech Systems published that article, I'm sorry, at least on that website in 2016, it was aware Alex Jones' audience members had been involved in high-profile acts of violence, correct?
	Jack Shin mischaracterizes the event, the item, the exhibit.
	Do you know who Jared Boffner is?
	No, it doesn't ring a bell, sorry.
	Okay.
	Do you recall the assassination attempt on Congresswoman Gabrielle Giffords in Arizona?
	Yes.
	Okay.
	Do you recall when that happened?
	I do not, no.
	Okay.
	And the Free Speech Systems acknowledges that Jared Loughner was a big fan of Alex Jones, correct?
	I don't know anything about him, so I can't say.
	You haven't read that article?
	Now.
	Now.
	I don't know if this would-- it's OK.
	This would be an actual breakpoint.
	I was just thinking the same.
	All right.
	So we will take our lunch and recess.
	We will be back in court right promptly at 2 p.m., so just be sure to report back a few, maybe five minutes or two.
	Remember all the rules of juror conduct that I told you about, and if you leave the building, it is a beautiful day.
	I have to say some of those of you who are going to enjoy the nice weather, at least I'm told it's a beautiful day.
	Just make sure you avoid I'm going to stay on the bench and address something with counsel.
	so we will see you back after lunch and Mr. Farr will retrieve your notepads and secure them.
	Thank you.
	I will clarify that I really don't want routine objections raised at a sidebar.
	I want them We want the objections made routinely.
	If there's an issue where you want to have an opportunity to speak with counsel or each other or the court on some issue, Understood.
	It was more than a one-word one, and I didn't think it was appropriate to raise it in the jury's presence.
	Well, then I also don't have – we really have not moved them very much, so if there is some argument that needs to be made outside the presence of the jury, I'm happy to do that as well.
	Understood.
	Thank you.
	All right.
	So I hope everyone has a nice lunch, and we'll start promptly at 2 p.m.
	All right, please.
	Thank you very much for reading that.
	Oh, Lord.
	So crisp.
	Thank you. - That's actually good.
	- There we are.
	There's still a theme here.
	- Oh, I'm missing. - Yes.
	- Okay, we can answer that.
	- Yes, there's one.
	- One, one, one. - I'm just waiting for that.
	so we're just waiting for one at the jury to return judge while we wait may I return a call on the foyer if I keep an eye on the courtroom sure I do have one
	I have a minor issue though.
	This I would like to talk to the attorneys on the sidebar about briefly.
	Separator?
	Yeah.
	I think it would be a good idea if we had our witnesses put their Apple watches and devices on maybe their payroll.
	So, okay, from this day and age, because it's almost like take out salt for me.
	And so, I'm sure it was nothing but when I see a witness looking and not watch, either, there's no clock in here.
	But I think just as we move forward, does anybody think that's a problem?
	Because I have mine on airplane mode.
	No, you may not be, but we have a lot of witnesses and you just never know.
	My mother calls and texts me all the time, so now it's like, constantly.
	Like, I'm like, Mom, I'm I don't want to make any sense.
	I just want to be looking at it.
	She would probably need to see how much longer it was going to be.
	No offense.
	But I just think it's a little colder.
	No, no, no.
	You know, it's like when my kids take...
	No, no, no.
	I mean, I'm going to get much rest in a week.
	When kids take, you know, exams and things, they have to take them off.
	So I just think with the witnesses ..
	Yes?
	Mr. Coscoff was not suggesting ..
	No, no.
	OK.
	All the fun is ..
	Well, what can I say?
	So can we just suggest, can I make that suggestion as you move forward?
	We'll take care of that.
	Okay.
	So they're going to text you on?
	We are set now?
	Is your certificate here?
	Okay, the juror is on the way down, so it should only be another moment or two.
	Oh, we have to go upstairs?
	Yes.
	Okay.
	We'll be two or three moments.
	but you have plenty of time.
	Thank you, Jay.
	Thank you.
	I think we will.
	So I think we're going to.
	Thank you.
	Just to make help.
	To be clear, take care of the planning purposes, we need to be able to start paying over one and a half an hour in the case, there's not a lot of people to review.
	And if you're just sending out, I don't have any objections or options that I don't have a lot to be correct.
	OK, so we're just going to go on.
	All right, so we're just going to stop 4:30, no matter what.
	Because you're not going to finish me.
	There's some place for that.
	And it will be earlier if you finish.
	So that'll be fine.
	Thank you.
	All right.
	No problem.
	Thank you.
	yes Alright, welcome back.
	Good afternoon.
	I hope everybody having a nice lunch break.
	My mental top to 10.
	Thank you, Ron, for distributing my notebooks.
	And the record will reflect that our jury panel has returned.
	Please be seated, everyone.
	I will share with you some news, like we just had a sidebar.
	We plan on ending today no later than 4.30.
	We went a little late, and it's great to five yesterday, and I told you we usually end around a quarter or five, but we are going to end no later than 4.30 today, just so you know.
	know we'll still take a probably a 10 minute or 15 minutes out in recess but just so you know all right so whenever you're ready council thank you your honor welcome back to Ms. Todd.
	Thank you.
	So when we were talking about the relationship between the content that Alex Jones publishes the audience he builds and the revenue he generates from it right?
	Yep.
	And so it would be fair to say that Alex Jones' customer base is his audience, correct?
	That's correct.
	- Okay.
	And I think we were talking earlier about the social media activities of Alex Jones and Infowars prior to 2012.
	Yes.
	Okay, and you testified that, I think you testified that in preparation for your trial testimony, you actually hadn't reviewed any of the social media data for InfoWars, right?
	Right.
	When I went to review material, I asked for it and I didn't receive anything.
	You didn't receive it.
	Right.
	And I'm not trying to control it.
	I just want to make sure that you don't go beyond the question I asked.
	Sure.
	I'm not trying to be a plight.
	Okay.
	So you haven't reviewed any of it, and we saw that the only data that we presented to you and that were provided to us started in 2014, right?
	Yes.
	Okay.
	And because you hadn't reviewed any data, I think you weren't quite prepared to testify about the extent to which Alex Jones and the boards were using social media before 2012. Jones' deposition that he gave here on this issue, and that is a clip beginning at page 60, line 18 of his April 5th deposition.
	April 5th, 2022?
	Yes, sir.
	- It's just an admission, Your Honor.
	- Oh, okay, sorry. - I'll do it. - Oh, okay. - Oh, okay. okay. - Oh, okay.
	okay. -
	Okay.
	That's okay.
	That's alright.
	Now, Ms. Paz, I'm going to approach you with a page of my outline.
	May I see it, Judge?
	I'm sorry.
	It's OK.
	I have the deposition testimony.
	No, no, no.
	OK, thank you.
	May I approach your arms?
	I'll do this the old fashioned way, if that's all right.
	Refresh my recollection.
	Sure.
	You reviewed his deposition, correct?
	Which one?
	The depositions he gave here in Connecticut.
	I think there were a couple of them, but yes, I reviewed a bunch of his steps.
	Right.
	He sat for deposition over a couple of dates here in Connecticut, right?
	Yes.
	Yes.
	And during that deposition here, he was asked, At least as far as you were concerned, Infowars did try and push its message through as many social media platforms as possible, correct?
	Answer, yes.
	Yeah?
	Yes, that's what it is.
	Okay.
	And then the question was, so in addition to your radio audience and your web audience, you had a significant social media following as well as of the end of 2012, correct?
	And there's an injection.
	We gave the answer.
	The answer, yes.
	We had, I mean, pretty good sized social media thing.
	It wasn't anywhere as big as it has got now, just in total how big social media is, but I mean, we definitely had some audiences that were tuning in and really coming to us.
	That is what those are.
	It is like an advertisement for your show, right?
	That's what it sounds, yes.
	Okay, question, right.
	They see you on social media and then they come to your website, right?
	Answer, yes.
	Right.
	Question.
	They can see a post of an article that somebody has posted on social media and they say, I will go to InfoWars and check it out, right?
	Answer, yes.
	Yes.
	Question.
	And then hopefully when they're at InfoWars, they will buy stuff from you, right?
	Answer, yes.
	Yes.
	And so, based on Mr. Jones' own testimony, it's fair to say that as of the end of 2012, he had a substantial social media following, correct?
	That's his testimony, yes.
	Oh.
	And that ever-increasing audience across all the social media platforms meant ever-increasing profits.
	Yes?
	Yes?
	So we've shown the jury some of these Google Analytics, but because we are going to get into December 2012 right now, I just want to set it up by having Exhibit 120 up again.
	OK, we're good now?
	We'll see.
	That's okay.
	This is Exhibit 120. The jury's seen this before.
	Let's go to 2011-2012 for Infowars.com.
	Here we go.
	Thank you.
	All right.
	So we see here, and we've looked at this before, Just on InfoWars.com, in 2011, Mr. Jones had 208 million page views, yes?
	I'm sorry, which date are we at?
	2011, in the year totals.
	Yes.
	He had 208 million page views, correct?
	Yes, I see that.
	32.4 million users.
	I see that, yes.
	85.1 million sessions, correct?
	Yes.
	Yes, that's what it says.
	Okay.
	And as of the end of 2012, those numbers had increased if you go to the year totals, correct?
	Yes.
	Okay.
	And although we don't have the totals just from January through November, fair to say that as of December 2012, Mr. Jones was again sitting on over a quarter of a billion page views on infowars.com and over 119 million sessions.
	And about 49 million users, yeah?
	Yes, that's what it says.
	And he also had Prison Planet TV and PrisonPlanet.com during that time.
	yes let's pull up exhibit number 60 and believe this is in Yes, it is.
	Okay.
	Okay, let's just pull it up.
	And I showed the jury this in opening.
	This is a still shot of the Alex Jones show as it looked in December 2012, correct?
	Yes.
	That's the studio he was in at that time, yes?
	Yes.
	Okay.
	Much smaller studio than the one he's in now, correct?
	Yes, I know the newer one is bigger.
	And if we go to exhibit 80, this is also in evidence, Your Honor.
	We were talking earlier, you have that one right?
	I don't want to make a mistake.
	Yes, AD is a full of zip, I'm sorry.
	This is a website that he didn't have in 2012, but which he now uploads all his videos to.
	This is band.video, correct?
	Yes, I don't know what date he created this, but he didn't have it then.
	That's right.
	All right.
	The website that served this purpose back then was Prison Planet TV. Right.
	All right.
	All right, let's bring that down, and let's go back to exhibit number 60, please.
	All right.
	Thank you.
	And you see there, Ms. Paz, That this is what Alex Jones looked like when he was broadcasting on the day of the Sandy Hook shooting, correct?
	I do see the date there, yes.
	And the Alex Jones show went on the air at 11 Central, 12 noon Eastern, correct?
	I believe so, yes.
	It's a live show, yes?
	Yes.
	Okay.
	Syndicated out to hundreds of radio affiliates around the country, correct?
	Talking about it this time?
	Yes.
	Well, I'm not sure of the exact number, but many, many affiliates, yes.
	Stream directly to Infowars.com.
	Yes.
	Stream directly to YouTube It's uploaded to YouTube.
	Yes.
	Well, doesn't he stream it back then?
	He was live streaming his show to YouTube.
	Yes I think he was live streaming it and then subsequently uploaded the whole the whole thing to YouTube.
	Exactly So if you want to tune in to Alex Jones live on December 14th 2012 here were your options number one infowars.com Yes number two the radio.
	Yes number three his YouTube page.
	Yes number four Facebook I'm not sure if it was live on Facebook, but he did upload video clips to Facebook.
	Okay.
	So Free Speech Systems doesn't know whether it was streamed live to Facebook at that time?
	I'm not sure if it was streamed live to Facebook.
	Alright.
	And when the show is over, if you didn't catch it, you could go to PrisonPlanetTV.com?
	Yes.
	Or you could go to Facebook where it would be uploaded, or YouTube where it would be uploaded.
	Yes.
	Got it.
	So when he went on the air at 11 Central, 12 noon, that was two and a half hours after the first reports of a shooting at San Diego, correct?
	It was very shortly thereafter, yes.
	First reports of a shooting were about 9.30 in the morning, correct?
	Yes, about that, yes.
	He went on the air and he started talking about it, correct?
	Yes.
	Now, when you were deposed by me in this case and presented as Free Speech System's corporate representative, you had no idea that he had done that, correct?
	Did I know that he was on the same day?
	Correct.
	When I gave the deposition?
	Correct.
	I don't remember.
	I'm not sure.
	Well, they hadn't given you the video, correct?
	We went over that earlier.
	Right, I hadn't seen the video, but I'm not sure whether I was aware that he had been on that day.
	Well, how would you have been aware of it?
	Well, he's on every day.
	No, no, I understand.
	So, he would have been on that day anyway, because he's on every day.
	But I just hadn't seen the video of that day.
	Okay.
	Let me put it this way.
	You've not seen the video, correct?
	Right.
	You had no idea what he said on that day.
	Right.
	You appeared for your deposition to testify about his broadcast about Sandy Hook, and you had no idea what he had said within hours of the shooting, correct?
	Right.
	And the reason you didn't know is because they hadn't given you this video, correct?
	I hadn't seen the video, right.
	If they had given it to you, you would have watched it.
	Of course, I watched all the videos that were provided to me.
	Alex Jones titled this video, Connecticut School Massacre Looks Like False Flag Witnesses Say, correct?
	I believe so, yes.
	We talked about that this morning.
	And the term false flag, is that something you had ever heard of before you became a corporate rep here?
	I hadn't personally, no.
	But when Alex Jones uses the term false flag, it's to describe something to his audience that an event that is not as it seems, correct?
	That is a fair description.
	Right.
	And he's described false flag events as events that are faked, correct?
	Amongst other things, yes.
	Clearly, the Sandy Hook shooting, according to him, was a false flag and that was fake.
	He has said that on numerous occasions, yes.
	And now this was a four-hour segment of his show, right?
	He's on for four hours.
	I think there's two, three-hour segments, or I might be mistaken about that.
	It might be four total hours, right.
	That's correct.
	All right.
	Now, Ms. Potts, I do want to just make sure I'm trying to understand the failings of memory, but the Alex Jones Show is the central issue.
	Right?
	Right.
	Okay, so I do need to know, the jury needs to know, how many hours it's on the air today?
	I think it's two three-hour segments.
	I think that's what it is, but I could be mistaken, so I'm not sure, but I thought it was two three-hour segments.
	Okay, so since you're not sure, you can't testify to it.
	Fair?
	If I could refresh my recollection on that, that would be great, but I'm not sure.
	Just at a minimum, you know he goes on the air 11.
	Yes.
	Oh.
	Now, have you since watched this video?
	I don't have a copy of it.
	You were deposed by me in April, correct?
	Right.
	I don't know if we saw it at the deposition.
	We may have.
	So that's been four months?
	Yeah, I don't recall if we watched it at the deposition.
	Five months, I guess.
	It's been five months since your deposition and you haven't yet watched this video?
	I don't have it.
	They still haven't given it to you.
	Who's they?
	The business that you're here representing?
	I don't have it.
	Okay.
	Well, we're going to play.
	So, why don't we start with exhibit 1B. Yes, I think we talked about that.
	Okay.
	And it's also true that as of the time Alex Jones went on the air within three hours of the shooting, he had done zero to investigate the circumstances of the shooting, correct?
	As of that date, right.
	And as of today's date, Ten years later, Alex Jones has done zero to investigate the circumstances of the San Diego shooting, correct?
	I don't think he's personally done anything to investigate it, no.
	Right.
	Let's play Exhibit 1B, please.
	Now, I've got people calling with all sorts of information on this subject, but get a hold of your cousin when she settles down and get her to talk to us for any other information.
	We need to know, were there any drills that day or the day before?
	Does she know anything?
	Did she have anything about other shooters, or did she never saw the shooters?
	Well, I had to ask them if it was supposedly to, because they have a lot of security at that school.
	You have to ring a doorbell in order to get into the school.
	Yeah, of course, which is another side of that, you know, 20 federal model schools.
	The thing that just scared the daylights out of me, I had to call right away, is I asked them, did they ever train for this?
	And my uncle said yes.
	Within the school years, since September, they have trained for incidents like this.
	Well, that in and of itself isn't the proof of, but they could use a drill to then bring in a patsy.
	It could just be a Prozac kit.
	We'll find out.
	God bless you, sir.
	I appreciate your call.
	Stay in contact.
	Did you hear Alex Jones asking about whether there were any drills?
	I did hear that, yes.
	And the caller didn't say anything about that, right?
	That was Alex Jones, correct?
	He did ask that question to the caller, yes.
	And he talked about there could be a PACSI, because he said they could use a drill to bring in a PACSI, right?
	I heard him say that, yes.
	And a PACSI is somebody who's being framed up for something they didn't do, right?
	That's what it colloquially means to me, yes.
	And that's what he meant.
	Objection, speculation, what he meant.
	She can't testify about the contents of his mind.
	Okay.
	Now, after our deposition, you at least knew that Alex Jones had talked about Sandy Hook on the day of the shooting, right?
	Yes.
	In the five months since, You didn't ask Alex Jones anything about his statements here, right?
	I haven't spoken to Alex in that time period, so I didn't ask him anything.
	You could have, right?
	Objection.
	Could I have called him?
	Assuming he was available and answered, sure I could have called him.
	Or assuming he wanted to tell you anything at all about What he said on the first day of the San Diego shooting, right?
	He could have at any time.
	I'm sure he could have.
	Later in the broadcast, he talks about the Reichstag fire.
	You know what that is?
	I did review some information regarding that because he had mentioned it a couple of times.
	Okay.
	You didn't know what that was before you became a corporate rep?
	No.
	The Reichstag fire is a claim that in the 1930s the Nazis set a fire and blamed it on somebody else in order to seize control, right?
	Yes.
	Let's play Exhibit 1A. I told them to put the news on at the barbershop, and they said, oh, I bet you didn't expect it was an inside job.
	And I said, I'm not saying that it wasn't, but I wouldn't put it past them.
	And they were like, why did they kill innocent children?
	And I said, excuse me?
	I said, abortion, vaccines, and poison in the water.
	These people are safe.
	Yeah, why do you want to blow up the rock stack to get control?
	Why did government stage these things to get our guns?
	I mean, why can't people get that through their head?
	I don't know.
	It's so frustrating.
	I live in New York City.
	We're not even allowed.
	You have to jump over, like, 300,000 just to get a hunting rifle possession permit.
	So here, within hours of the Sandy Hook shooting, Alex Jones is comparing the American government to the Nazis, correct?
	Judge, did that mischaracterize it?
	It mischaracterizes the evidence that goes beyond it.
	My interpretation of that was, that's an example.
	He compared, on the clip that we just saw, the American government being responsible for staging Sandy Hook to the Nazis, correct?
	I don't know if I used the word compare, but he was raising this as an example of false flags.
	Why do governments stage these things to get our guns?
	Why can't people get that through their head?
	That's what he said, right?
	That's what he said, yes.
	Let's play exhibit one.
	Is that one E, sir?
	E. They have hit the ground running in a buildup.
	And I said, this is the attack.
	Look, people have got to find the clips the last two months.
	I said, they are launching attacks.
	They're getting ready.
	I can see them warming up with Obama.
	They've got a bigger majority in the Congress now in the Senate.
	They are going to come after our guns, look for mass shootings.
	And then magically it happens.
	They are coming.
	They've already taken over healthcare.
	The premiums are doubling.
	They're bankrupting that.
	They are already shipped GM to China.
	They are gonna gut this country.
	They're gonna shut down the power plants.
	They're gonna bankrupt us.
	They are re-educating us.
	Just like we were Ukrainians, and they're Russians.
	They want us bankrupt.
	They want the counties and the cities bankrupted.
	What does the new magazine say?
	You can get it by subscribing.
	You can get 12 issues.
	This man wants your guns.
	And I read down here, they're declaring war on the Second Amendment period.
	They are declaring war on the Second Amendment period.
	They are coming Is that the first
	time you've ever seen that?
	Yes, I've never seen that before.
	And he tells his audience that they want to kill this country.
	You heard that?
	That's what he said, yes.
	They want to destroy the Second Amendment.
	They want to gut this country.
	Did you hear that one?
	That's what he says.
	They are coming, they are coming, they are coming, right?
	That's what he said.
	And to Alex Jones' audience of hundreds of millions, he's telling his audience that because he wants them to believe that, right?
	Objection.
	I can't testify.
	The they who want to kill this country, who want to attack the Second Amendment, who want to take their guns, the they are the people who staged this thing, right?
	The people he's alleging staged Sandy Hook?
	Right.
	I think by they he meant the government, but I can't tell from looking at the video.
	And the they...
	The they.
	That he ended up saying stage Sandy Hook were the families you see right here, right?
	I can't say that from watching this video, no.
	Oh, no, no.
	But you know that from watching other videos.
	That he called these families actors, correct?
	I know he has used the term actors in relation to some of the families.
	That they were part of this plot, correct?
	I have watched videos in which that's alleged, yes.
	Right, and so the families that he described as actors and part of this plot are the ones who are trying to kill this country, correct?
	I can't say that from watching this video though.
	You can't say that from watching the video you just saw?
	No, I can't.
	Now at the end he tried to sell a few magazines too, right?
	Yes.
	And he said he had been predicting, and magically it happens, right?
	That's what he said.
	Now, do you know how long the video is of Connecticut School of Massacre looks like false flag witnesses said?
	I don't know.
	May I have just one moment, Your Honor?
	we may be able to reach a step excuse me judge I'm sorry
	okay thank you in your screen here I will represent your honor that what we are now displaying is exhibit one not a clip but the full video Okay?
	And you see there, ma'am, on the screen, that the full length of the video is 50 minutes and one second, right?
	That's what it says.
	Okay.
	And although you don't know for sure how long the Alex Jones Show is, you know that it's...
	At least four hours and maybe up to six.
	Yes.
	Okay.
	And so whatever happened in the other three or five hours or however many hours he was on the air that day talking about Sandy Hook, you don't know, correct?
	Is the question how long was he talking about Sandy Hook?
	No, the question is the only evidence we have of what he was saying on the day of Sandy Hook is this 50-minute video, correct?
	Yes.
	Even though we know he was on the air for at least I don't have access to any of the other videos, so...
	No, no, no, but you know the Alex Jones show is released for...
	I know how long it is, yes.
	Yes.
	All right.
	And it's fair to say that Alex Jones was making these comments as families were rushing to the firehouse to find out what happened, correct?
	Objection argumentative.
	Sustained.
	Okay.
	You already testified that you know the shooting was about 9/30, right?
	Thereabouts, yes.
	You testified that the show started at about noon Eastern, right?
	Yes.
	You know that the firehouse was a gathering place for families to come and find out what was happening, correct?
	I do.
	Did you see Special Agent Aldenberg's testimony yesterday?
	I was in the courthouse, but I didn't watch his testimony.
	Did you watch any coverage of the trial yesterday?
	I may have seen some clips in the news, but aside from that, not really.
	Well, you may have read it.
	I saw a couple of clips.
	Okay.
	And is that because you saw them out?
	Saw them out?
	I'm sorry, what?
	Is that because you saw them out?
	Yeah, I saw out a couple of clips just to see what was happening at the trial.
	I was here, but I couldn't find a seat.
	Okay.
	Did you see any clips of Bill Alderson?
	I think I saw a couple of clips of his testimony.
	Yes.
	Okay.
	And he asked his audience in his video to send in tips, right?
	Yes, I saw that.
	And that's a way to engage his audience.
	Yes?
	To get them involved, yes.
	To get them involved.
	Yes.
	Right?
	To cement that relationship with them, correct?
	Sure.
	To get them invested in what he's doing.
	Sure.
	Right.
	And to do their own investigating.
	Well, if they had information to provide, yes.
	Right.
	And if they don't have information to provide, they can go investigate it, right?
	I know he has in the past said, go and check this out and go investigate.
	He doesn't say it right there, but he has said it, yes.
	Now, on December 15th, what did Alex Jones say about San Diego?
	The following day?
	Yes, ma'am.
	Oh, I don't recall exactly what he said.
	Well, do you know that he said something and you just don't recall it?
	He was on the air that day, and I believe he did talk about Sandy Hook.
	I just don't recall exactly what he said.
	Did you see that video?
	I don't recall.
	Do you think there is a video?
	I don't recall.
	I don't know.
	What makes you think he talked about Sandy Hook on December 15th?
	I don't know.
	I said he was on the air, and so I don't know what he talked about.
	Okay, thank you.
	Okay.
	You talked about Cindy Hook, but what you're saying is, well, actually, Ms. Paz, let me correct you, because December 14th was a Friday, right?
	I don't know.
	I don't recall what day of the week it was.
	Okay.
	We'll step.
	It was a Friday?
	We can agree?
	Sure.
	Alex Jones isn't on the air on Saturdays.
	Objection.
	I mean, objection.
	I don't want to say the obvious, but objection to the form is assuming a fact, not an evidence, that he's not on the air on Saturdays.
	Is he on the air on Saturdays?
	Sometimes I think he is.
	I don't think it's all every Saturday.
	But if this jury wanted to know what Alex Jones said about the San Diego school shooting on Saturday, free speech systems can't tell, right?
	I don't know.
	As I sit here, no.
	And what about on December 16th, the Sunday?
	Alex Jones does have a two-hour show on Sundays, right?
	From 4 to 6?
	I'm sorry?
	From 4 to 6?
	I don't recall.
	I think I did see something about his Sunday broadcast, but I'm not 100% sure, so I don't want to misstate it.
	And if this jury wanted to know...
	What Alex Jones said on December 16th, three days after the shooting, free speech systems can't tell them, right?
	If I didn't watch the video, if there is such a video, then I can't say anything about it.
	How's our chance?
	You're here.
	I don't know is my answer.
	So free speech systems can't tell them, right?
	Correct.
	On December 17th though, just three days after the shooting, what we know is that Alex Jones Published another video that he titled Creepy Illuminati Message in Batman Movie Hints at Sandy Hook School, right?
	Yes, I do recall that video.
	Okay.
	And Illuminati is just another word that Alex Jones uses to describe this global plot of people in the American government and elites looking to enslave and kill the world, right?
	I believe that's accurate, yes.
	All right.
	And what he's saying here There's this movie, The Dark Knight Rises, right?
	Yes.
	Have you seen it?
	I have.
	You saw it in your personal capacity?
	I saw it in my personal life.
	I had watched it when it came out, yes.
	And it was a popular movie.
	A lot of people saw it, right?
	Yes.
	And what he's saying is that the words Sandy Hook appear on a map in the movie.
	And that that was the Illuminati sending an intentional clue that they had staged this, right?
	It was based on an article that Adan Salazar had written, and that was the claim that was in the article, and he was broadcasting it.
	Are you sure it's not the other way around?
	Are you sure it's not that Alex Jones is the one who told Adan Salazar to write the article?
	No, that's not correct, based on my interviews with Adan.
	Okay, well, let's listen to Mr. Jones himself.
	Why don't we play Exhibit 3B?
	That is a full exhibit, Your Honor.
	Thank you.
	But in this case, the globalist will always get something in your face.
	And if the dark night rises, and we're going to put this up on screen, I'll plug the YouTube channel it's on, if you minimize that.
	And then I'm going to get a Don Salazar to do a report on this.
	The only thing you can read on the map from Cybertribe Network from a clip from the film is Shandy Hook.
	And they're talking about how they're going to bring it down there from the dark night rises.
	And again, they ran six months before 9-11, where the government hijacks a jet remote control to blame on Al-Qaeda using a terror drill as the cover.
	That's why the Jumbo Jet in the World Trade Center, so they can attack Afghanistan.
	Sandy Hook.
	Let's go ahead and play what they break down here.
	Here it is.
	Oh, yeah, I'm going to play it on air.
	That's why I was saying we're going to play it on air, the video of it.
	Okay, just whenever you're ready.
	You see him pointing there, right there, by the walkie-talkie.
	Well, let's get a close zoom-up on the shot before he puts his hand on the actual map.
	You see it here.
	What does it say?
	Hook is the only thing that you can read out of the whole map on this particular scene.
	Don't you guys think that's a little strange?
	Look at that.
	Sandy Hook.
	This is the dark night ride.
	Now, you heard there, contrary to your testimony, Alex Jones is telling his audience that he's going to tell a Don Salazar to write an article about this, right?
	I heard what he said, yes.
	And let's just like, just for a second, you know, because you've seen the movie, That Batman is set in like a fictional New York City, yes?
	Gotham.
	Right, but it's based on New York City.
	It is.
	And you know that there is a Sandy Hook, New Jersey, correct?
	I don't...
	You don't know that there's Sandy Hook, New Jersey just south of New York Harbor?
	No, I don't.
	Okay.
	But even putting that aside, as Free Speech Systems sits here today, Free Speech Systems doesn't even know whether this is true or not, that Sandy Hook appeared in the Batman Union, correct?
	That's correct.
	They just slapped a clickbait headline and ran it, correct?
	I think that they actually thought that at the time, based on my interview.
	Oh, I missed what anybody thought.
	Because what Free Speak Systems is telling this jury is that it doesn't even know whether this is true.
	Objection.
	It's argumentative.
	So let's get the question out, and then you can see your objections.
	My question is...
	Free Speech Systems is telling this jury that it doesn't even know whether this is true or not that Sandy Hook appears in the Batman movie, right?
	No objection to that.
	I'm sorry, no objection to that.
	I didn't do any independent investigation into the veracity of this, so I don't know.
	Well, it was your obligation to do independent investigation, correct?
	My obligation was to find out what we knew as a company and what the employees knew as a company during the time period.
	And what you're telling this jury is that having done all that, Free Speech Systems doesn't even know whether this is true.
	Yes?
	I didn't do any independent investigation into it, no.
	Your Honor, may I ask that the court struck a way to answer the question?
	I don't know.
	I didn't do any independent investigation, so I don't know.
	No.
	Free Speech Systems doesn't know.
	But they slapped a clickbait headline on it and ran with it.
	Yes?
	I don't know what you mean by slapped a clickbait headline on it.
	I don't know what you mean.
	Okay.
	This was three days after the shooting, correct?
	I believe so.
	On that same day, Free Speech Systems ran another video called Sandy Hook Mass Media Science.
	Yes, I did watch that.
	It's a blooper reel.
	Yes?
	That's what it says.
	And it's got clips of news coverage kind of merged together, suggesting that there were actors at Sandy Hook three days earlier, and there were certain points where they messed up the script, right?
	That's what the claim was, yes.
	And, haha, Look at this, these outtakes.
	I think that's what the point of the video was, yes.
	Right.
	And do you know whether the funerals have started at Sandy Hook yet?
	I don't know what date the funeral started.
	Okay.
	Let's go to exhibit 61.
	That is a full exhibit, Your Honor.
	Thank you.
	61.
	Correct.
	Now, this is an article.
	You know what?
	Let's just do the headline, please.
	Can you get the date in there, too, if you don't mind?
	I'm sorry.
	December 19th, right?
	Five days later.
	Yes.
	Father of Sandy Hook victim, Seconds before a tear-jerking press conference.
	Do you see that?
	That's what it says.
	And he's talking about Robbie Parker, correct?
	Yes.
	Excuse me.
	Robbie lost his daughter, Emily, in the shooting, correct?
	Yes.
	And the night after the shooting, Robbie was at his church and came out to make a statement about his daughter, correct?
	Yes.
	And the media, huge media, For that, for that statement, yes?
	There were a lot of media there, yes.
	It was recorded.
	Now, you've watched at least some of that statement that Robbie gave, yes?
	Yes.
	I don't know if I watched the whole thing, but I've seen it, yes.
	Let's go down to the bottom.
	Alex Jones gave a statement about this, didn't he?
	You mean aside from this article that we're looking at?
	It's contained in the article.
	Oh, okay.
	Yes.
	Yes, I see it.
	He offers his condolences.
	Yes, ma'am.
	That's what it says.
	Yes.
	He says, it appears that members of the media or government have given him a card and are telling him what to say as they see your reaction to this event.
	That's what it says.
	Now, you've watched.
	At least part of that statement, correct?
	Part of it, yes.
	You didn't watch the full statement?
	I don't think I saw the whole thing.
	Why not?
	There were clips that were aired, I believe, on some of the videos that I was provided, but I didn't go and externally look for the full video.
	The full video wasn't in the material that I was provided.
	So, Infowars never published Robbie's full statement, correct?
	Right, I don't believe the full video was ever put on there.
	I think there was clips of the video.
	But even the part that you saw, can you pull up that statement again if you don't mind?
	You didn't see anybody hand Robbie a card, did you?
	I don't recall ever seeing a card, no.
	Not you don't recall.
	You didn't see it.
	I didn't see a card.
	I didn't watch the entire video.
	Right.
	What you watched is what InfoWars aired.
	Right.
	Right.
	And in what you watched, even in what InfoWars aired, you didn't see anybody give him a card, correct?
	I didn't see a card, no.
	And he said, so this needs to be looked into.
	That's what it says, yes.
	That's an invitation to his audience, isn't it?
	Objection, argumentative.
	I don't know what it is.
	I don't know what he means by it.
	This is like the mission they give people on Facebook, isn't it?
	Objection, argumentative.
	I don't know what he means by it, so I don't know And Robbie gave this statement on December 15th and they act right and I think that's the date, yes.
	So, all the stuff we've just been looking at.
	Creepy Illuminati video, the blooper reel.
	Christie Systems published that after Robbie gave that statement, right?
	I'm sorry, the question was the statement published after Robbie...
	Robbie gave this statement on the 15th.
	That's what it says, yes.
	Right.
	Did Mr. Jones watch Robbie's full statement?
	I don't know what he watched.
	You don't recall his deposition testimony where he said he watched the full thing?
	I don't recall, I'm sorry.
	Did you ask Mr. Jones about this?
	About Robbie Parker?
	Um, I did ask about Robbie Parker.
	That's the only question?
	Yes.
	You asked about Robbie Parker?
	Yes.
	But you don't know whether he told you if he watched the full statement?
	No, I don't know that he told me he watched the whole thing.
	So he didn't tell you that Robbie talked about how his daughter Emily used to like to make people harsh for people to make him feel good?
	You mean if Alex told me that?
	Yeah.
	Alex didn't say anything like that to me.
	Did he tell you that Emily's favorite color was pink?
	She used to always like to wear pink.
	Did Alex tell me that?
	No.
	In the part that you watched, did you hear when Mr. Parker came out of the church, the first thing he did was offer his condolences to everyone involved in the shooting, including the family of the shooter.
	I did hear him say that, yes.
	Do you recognize Mr. Parker in the courtroom today?
	I don't, I'm sorry.
	Robby, would you stand up please? would you stand up please?
	You know that Alex Jones's audience did look into Robby, don't you?
	I don't know what you mean.
	Free Speech Systems is aware that Alex Jones' audience, after being told that Robbie needed to be looked into and the other family needed to be looked into, that his audience started looking into them.
	You know that, right?
	In what way?
	I don't know in what way you mean.
	I mean, started harassing them as actors.
	Let's start with that.
	I am aware that there was some harassment of the families, yes.
	But by Free's View System's audience members, correct?
	By people in the general public, and I'm sure people who have watched the Alex Jones show too, yes?
	Because that's where they would find out that Robbie was an actor.
	Because Mr. Jones told them, right?
	Jackson, argumentative, speculating about the contents of other minds.
	On December 19th, same day Mr. Jones said this needs same day Mr. Jones said this needs to be looked into, Free Speech Systems published another video.
	Sandy Hook second shooter cover-up, right?
	I do recall that video, yes.
	yes.
	Now again, as you said earlier, Infowars had done zero investigation into the circumstances of that, correct?
	Of that particular claim?
	Yes.
	Correct.
	Of course there was no second shooter, was there?
	Is that what it turned out to be?
	That's correct.
	There was no second shooter.
	That's what it was on the day it happened.
	Objection.
	How does she know that, Judge?
	What did they think on the day that it happened?
	Free Speech System's position, as it sits here right now, is that there was one shooter, and that's it, right?
	Of course.
	Of course.
	There was one shooter.
	I think we've accepted that, that there's one shooter.
	Now, let's go to...
	Oh, and then on December 21st, the first creepy Illuminati video had done so well that they went back to it, right?
	Objection, argumentative.
	I don't know if that's the reason why they went back to it, but...
	They published a video called Lower Part of Gotham Renamed Sandy Hook in Dark Knight Film, right?
	Yes, I believe that was by Jakari Jackson, if I'm not mistaken.
	So yes, I did watch that video.
	Let's go to Exhibit 102. Now, we've mentioned Mr. Salazar, right?
	Yes.
	He's the one who, at least Alex Jones told his audience he was going to direct to write this article on the Batman thing, right?
	That's the person he was referring to, yes.
	Now, in this email, we're going to start at the bottom.
	You know how emails work, right?
	If there's an email thread, the first one's at the bottom, and then you have the response, and that's how it goes.
	Okay, so we're going to start at the bottom, and this is December 21st, 2012, right?
	We can go back up to this.
	I know it's...
	Yes, I see the date.
	December 21st, yes.
	December 21st, right?
	Yes.
	Now, let's go back to the first email.
	And this is from Mr. Salazar to Mr. Gonzalez, right?
	Yes.
	Now, Adan Salazar was Infowars employee, yes?
	Yes.
	He still is, correct?
	Yes.
	And he was one of the, quote, writers for Mr. Jones.
	Yes?
	Yes, I think he's still a writer.
	He's still a writer.
	Yes.
	Right.
	And he says to Mr. Gonzalez, hello, Mr. Gonzalez.
	This is one week after the shooting.
	There is a vicious rumor that the date you posted your review of the Sandy Hook lingerie party massacre on your site, a slash above.com, shows foreknowledge or prior planning of the events that have taken place as of late.
	It includes a couple links.
	At first we thought this was surely ridiculous.
	However, we're, InfoWars.com, going to point it out in an article anyway.
	And would like to give you the opportunity to provide a comment.
	That's what it says, yes.
	Did I read that correctly?
	Yes.
	That's a Don Salazar reaching out to somebody who posted a movie review, right?
	Yes.
	Yes, that's what it looks like.
	The movie was the Sandy Hook Lingerie Party Massacre, right?
	Yes.
	You know that was a movie that actually was released in the early 2000s?
	I don't know when it was released, but I know it was prior to this all happening.
	It was some like indie slasher movie.
	Right.
	Right.
	But you don't know that it was in the early 2000s, like years and years before?
	I know it was years and years before, yes.
	All right.
	So Adan says, we're going to publish this, even though we know it's ridiculous, as a way to show that somebody had foreknowledge, meaning Mr. Gonzalez had foreknowledge of the Sandy Hook shooting, right?
	It says it's a rumor.
	It says it's a vicious rumor.
	It says it's a rumor, yeah.
	Right.
	And he says it's truly ridiculous, but we're going to publish it anyway.
	Right?
	That's what it says.
	And Mr. Gonzalez gets back to him.
	Let's go up to the next one.
	You are seriously ill to send me something like that.
	Don't contact me anymore.
	I will report you for harassment, you bunch of weirdos.
	That's what it says, yes.
	Now, you're chuckling, right?
	I spoke to a Don about this, and he thought...
	You're laughing, right?
	I didn't laugh, but I smiled.
	Okay, I thought I just saw you chuckle.
	No, I smiled.
	Okay.
	Did Attorney Patis laugh?
	I chuckled.
	Okay.
	But the reality is...
	That what Adan is doing is putting out to an audience of millions something to tell them that Sandy Hook was staged even though he knows it's ridiculous, right?
	Is that funny?
	It's not, that wasn't the point of the article.
	Objection, harassing, badgering, argumentative.
	Sustained.
	And then what Adan does, let's go up to the next one.
	He forwards it to Louis Sertuki, right?
	That's what it says, yes.
	Louis Sertuki is the social media manager for InfoWars, right?
	I'm not sure.
	Like I said earlier, I'm terrible with names, but I don't dispute that.
	That's who it is.
	Did you meet with anybody who was the social media manager at InfoWars?
	No, and I did not meet with Louis.
	Do you know when Is this ridiculous claim to their millions and millions of viewers?
	I know there was an article written about it, yes.
	Okay.
	Now, after Mr. Jones lied that after Mr. Jones lied that Robbie had been given a car, and appeared to be reading from a script, objection to the characterization of objection to the characterization of the police,
	InfoWars started to go all in on this idea that the parents were actors, correct?
	Objection to characterization.
	Sustained.
	After Mr. Jones' lie, when he said that Robbie Parker had been given a card by the government or the media, InfoWars went all in on calling the parents crisis it.
	Renew my objection.
	Sustained.
	Can you rephrase it?
	I'll move on right now.
	In early January, about two and a half weeks after the shooting, After Mr. Jones had described Mr. Parker as the way we've seen, InfoWars started to really aggressively move on this crisis actors thing, right?
	I believe that he did publish on a number of videos after that this crisis actor theory.
	So, yes.
	You mean lie?
	Objection.
	Overruled.
	Uh, you mean whether Mr. Parker was a crisis actor?
	Oh, no, no.
	You know that Alex Jones said not just Mr. Parker, but a bunch of parents are actors, right?
	That's a lie, isn't it?
	He's used the plural of actors, yes.
	Okay, and that's a lie.
	Yes?
	Oh, they're not actors, correct.
	And let's look at exhibit number 107. I'm sorry, hold on one second.
	I'm not sure this one Yes, I have seen this before.
	I'll offer it.
	I just don't know where it came from, Judge, if it's being offered for the truth and matter assertive hearsay.
	There's actually no truth assertion in the email, Your Honor, and it was produced to us by free speech systems.
	Relevance.
	You can pull it up, please.
	So here we are, three weeks after the shooting, and Adan Salazar three and Adan Salazar is receiving an email from email address mail@crisisactors.org, correct?
	That's what it looks like, yes.
	It says, hello, we need to verify your email address before you can sign in to Crisis Actors.
	Please click on the link below to verify your email address, correct?
	That's what it says, yes.
	And you know that Adan Salazar was asked about this email in his deposition, correct?
	I believe he was, yes.
	And he testified that he wanted to get access to this website because he wanted to I don't recall whether he said specifically that.
	I know that he did say he signed up for this.
	I just don't recall why.
	Well, you talked to Mr. Salazar too, right?
	I did, yes.
	And Mr. Salazar told you that he was looking to support the claim that these families were actors, correct?
	I don't know that he said that to me in so many words.
	I think what he said was...
	If you don't know, you don't know.
	I don't recall that he said it to me, said anything like that to me.
	Okay.
	Now, I think the wars...
	uh sent anybody up here to cover what was happening up here uh if you're referring to mr badandi mr badandi was yes i Mr. Badandi wasn't sent up here yet.
	I'm talking about in these first couple of weeks here.
	Oh.
	Whether during these first couple of weeks InfoWars sent anybody up here?
	I'm not aware of anyone being sent up here.
	- So the board doesn't know? - Correct.
	- In the two weeks after the shooting, there were funerals happening for the victim every day, right?
	Objection.
	Assumes a fact, not an evidence.
	Sustained.
	Do you know that they held funerals for the 26 victims in the two weeks, two, three weeks after the shooting?
	Sure.
	I don't know what days they were held, but yes.
	Some on multiple days.
	I can't say whose funeral was on which days.
	I don't know.
	And during this time period, what InfoWars was doing was hatching this lie about it being staged and about the parents being actors.
	Objection, argumentative.
	Sustained.
	Do we have a sidebar, Governor?
	Thank you.
	Can you repeat this?
	I don't know if it's going to happen.
	I mean, this is the problem I have.
	None of this testimony is strictly speaking relevant to what we're doing.
	And so you'll take the position of why it's somehow admitted is admission because you don't constrict that .
	And I've objected each time you've used a lie.
	I don't know why the court has sustained the objection.
	My objection is that argument is that character.
	And so that is the basis of this objection.
	I don't know why the court is-- I don't mean to be a smart man.
	But that's been the basis of the objection.
	I don't know if I can read the past.
	I don't know if it was a lie before you assume it was a lie.
	Because sometimes it just doesn't.
	Yeah.
	And what happened.
	But we have an assuming that it's a lie.
	For sure.
	No, I understand.
	But did you say that?
	I'm assuming.
	Yes, sir.
	I'm assuming.
	No, no.
	I'm assuming that's what I'm asking.
	What suggested that?
	Oh, no.
	What did you say?
	So I was checking.
	Wait.
	I was getting there.
	I was asking.
	You see it's something like, it was .
	And we objected.
	Because .
	It's not .
	It's a lie.
	And it's .
	And so what I don't want to do is .
	. No.
	It's a .
	When it's established, that's why I'm facing a question.
	I'm just not sure each and every statement is considered a lie.
	And we can't under the law of the case.
	And that's for the judge to decide.
	I feel like you disagree with me.
	They call it.
	I'm just not sure.
	No, no, no.
	I'm just not sure that I agree with that issue.
	You said everything was a lie.
	It was a lie at the time.
	It was other.
	I'm not sure that it's .
	It's clearly material.
	I don't complain that he's .
	That's what we're .
	Those are the most material.
	I don't know that there's ever been any funding of materiality, Because there was never any litigation was the disciplinary default.
	And I'm not sure it goes so far as to transform whatever you choose into a material litigation.
	I think that was a material litigation.
	If you've made that funding, then I'll back it out.
	It's on the record.
	Should we?
	So I think this is probably a good time to take the afternoon break.
	So we will take, let's take a 10-minute break since we're going to end the little roll today.
	Ron will collect your notepads, continue to obey the rules of your conduct, no discussion of anything, any witness, anything that's transpired, nothing at all, okay?
	so we'll take a recess
	Get the panel. Get the panel.
	Get the panel.
	Get the panel. Get the panel. Get the panel. Get the panel.
	I do.
	I do.
	All right.
	Thank you, Maddie, whenever you're ready. whenever you're ready.
	Thank you, Your Honor.
	Ms. Paz, when we left off, we were discussing Adan Salazar's effort to support the claim that parents were actors, correct?
	You mean by signing up for the crisisactors.org or whatever that was?
	I don't know whether that was the purpose, but I know that he signed up for it.
	And from December 14th through January 6th, what was happening was Free Speech Systems was developing this law Developing?
	Is that what you said?
	We've been watching the videos, the articles, the emails, and what we're seeing is...
	Objection judge, who's testifying here?
	What we're seeing is an effort directed by Alex Jones to hatch this lie that the shooting was staged and the parents were actors and that nobody died.
	Correct?
	I think he's said it over the course of many videos after that.
	So, I mean, I don't know if I would say it's hatching, but he has said those things in many of the videos, yes.
	And this is where it began?
	What we've been looking at right here is where it began, right?
	Well began the day of the shooting And the next step they took Was to bring a guy on the air who they knew Was going to say that the parents were actors That's James Tracy, correct?
	Objection.
	There's speculation as to their states of mind, what they knew.
	Overruled.
	Is the question whether they knew James Tracy, what he was going to say before he went on the air?
	They knew he was going to say that the parents were actors, right?
	I believe so, because they had reviewed what he had posted on his site prior to that, so that's accurate.
	And so let's pull up Exhibit 108. That is a full exhibit, Your Honor.
	Thank you.
	All right.
	Um...
	Yeah, just pull up the text.
	Thank you.
	So this is an email from John Bowne, long-time employer's employee, correct?
	That's what it looks like, yes.
	And it's to James Tracy, right?
	Yes.
	And if we go to the second, well let's actually, let's just look at this first paragraph.
	I'm a producer for the Alex Jones Radio Show.
	We are on over 140 stations nationwide with a daily listener base of 3 million, right?
	That's what it says, yes.
	And then it says in the second paragraph, Alex would like to speak with you via video Skype or landline phone, right?
	That's what it says.
	And that's Alex Jones, yes?
	That's who he means, yes.
	The interview would concern this article, which is a link, right?
	Yes.
	And this site, crisisactors.org, right?
	Yes.
	That's the same site that Adan Salazar was looking to register for, right?
	I believe so, yes.
	And this is Alex Jones asking to have this guy on to talk about this, right?
	It says that Alex would like, so...
	And that's less than a month after the shoot, yes?
	That's what it looks like, yes.
	Okay.
	And they ran that interview on January 10th, 2013, right, with Mr. Tracy?
	I believe so, yes.
	January 15th, they published a video that Alex Jones entitled, Sandy Hook AR-15 Host, Still No School Surveillance Footage, correct?
	Yes, I believe I watched that video.
	January 27th, 2013. Alex Jones published a video featuring only him, which he titled, Why People Think Sandy Hook is a Hoax, correct?
	I did watch a video titled that, yes.
	When did you watch that video?
	Where?
	When?
	When?
	It would have been probably sometime in January or February when I was originally prepping for this For the Texas depositions.
	I believe it's on the list of what I reviewed.
	May I just have one moment, Your Honor?
	- - Sure.
	I'm sorry, if you just give me one moment.
	Won't be long.
	I'm going to get to the table.
	Ms. Patis, you were deposed in this case on March 15th and 16th, I think I heard.
	Does that sound right to you?
	Yes, it was in March.
	I don't recall the exact dates.
	And then there were two other dates after that, or one other date after that.
	Sorry for that noise.
	Now, I'm going to show you this if I can find it.
	You know what?
	We're going to do this.
	I wasn't quite ready for this.
	Do you know that this video, "Why People Think Sandy Hook Is the Hoax," one of Mr. Jones' most successful videos?
	Do you know?
	Six months.
	Successful as in?
	Most views?
	Oh, I don't know.
	You don't know that?
	No, I don't know that.
	It was uploaded to YouTube, correct?
	Yes.
	He repeated his claim in here that Robbie Parker looked like an actor, right?
	I don't recall the exact contents of the video.
	I know he's said it on numerous videos.
	I just don't want to make a mistake as to which video.
	I just want to make sure I'm specific as to which video we're talking about and I don't recall if it's in this video Thank
	you Pull up exhibit number 109 109 Yes.
	Thank you.
	Now two days after Mr. Jones ran the video, why people think Sandy Hook is a hoax, let's pull up the bottom email here.
	A gentleman named Len Posner sent an Infowars email address, this email, correct?
	Yes.
	Leonard Posner is the father of Noah Posner, who was murdered at Sandy Hook, yes?
	Yes.
	And he sent it to the writers at Infowars.com, that email address, right?
	That's what it says, yes.
	And that's an email address that people can send emails into that's checked by...
	Infowars writers, correct?
	Right.
	It's one of the general email boxes.
	Right.
	This is the type of email inbox that somebody like Rob Dew would occasionally check, yes?
	Yeah, I think Rob would occasionally check it.
	Adon would occasionally check it.
	Paul Watson?
	Yes.
	Okay.
	And Paul Watson was the editor at large for Infowars.com.
	That was his title, at least.
	At this time?
	I think so, yes.
	Can you read this email for me, please?
	You want me to read it out loud?
	Yes, please.
	Alex, I am very disappointed to see how many people are directing more anger at families that lost their children in Newtown, accusing us of being actors and a number of dots.
	Haven't we had our share of pain and suffering?
	All these accusations of government involvement, false flag terror, new world order, etc.
	I used to enjoy listening to your shows prior to 12-14-12.
	Now I feel that your type of show created these hateful people and they need to be reeled in!
	Lenny Posner.
	thank you Ms Fox and this wasn't one of these emails that just dropped into an email inbox and was never read Actually, Paul Watson read this email, didn't he?
	Yes, I think he responded.
	And you responded to it?
	Yes.
	Let's pull up his response.
	Sir, we have not promoted the actor's thing.
	In fact, we have actively distanced ourselves from it.
	That was not true, was it?
	I think that there were still people at InfoWars actively engaged in the crisis actors line.
	Well, you know that to be the case.
	Well, Adan was still actively engaged in it, so yes.
	Alex Jones!
	Alex Jones had just, the two days before, claimed that Robbie Parker was an actor, hadn't he?
	I don't know the dates, but I know he's consistently talked about crisis actors, yes.
	Right.
	They're not just people.
	We just went through.
	They invited James Tracy on to talk about crisis actors, correct?
	Among other things, but one of the topics.
	Alex Jones on December 19th was suggesting that Robbie was a crisis actor, saying that he'd been given a card, right?
	You mean the date, the article?
	Yes, the article.
	Yeah, it's talked about that.
	Paul Watson.
	Disagree with Alex Jones, continuing to falsely claim that the families were actors and that Sandy Hook was a hoax, correct?
	He did.
	He told me as much when I interviewed him.
	And he told Alex Jones that, correct?
	He did, yes.
	And Alex Jones did not stop, correct?
	Not at that point.
	Well, he's never stopped, has he?
	I think he's reeled it in.
	He did stop for a period of time and started back up.
	Objection judge, he's not been permitted to finish your answer.
	I think he reeled it in at some point.
	He also stopped, he called it a tar baby at various points and so he did direct his writers and his news people.
	Ms. Paz, you're aware that Alex Jones right now is claiming that these families are actors, correct?
	I haven't seen anything right now of what he's saying, so I don't know.
	Did you see Mr. Pattis' opening statement yesterday that these families are exaggerating, even today?
	Exaggerating, what do you mean?
	Did you see what he said, Mr. Pattis?
	I was not here for his opening.
	Okay, so you didn't hear Mr. Pattis call these families exaggerators just yesterday?
	I didn't hear the opening statement.
	Thank you.
	It was bringing the InfoWars' attention that even as of six weeks after the shooting, families were being harassed, targeted as actors, correct?
	Thank you.
	Can I see the first part?
	Let's do that.
	Thank you.
	He does highlight the accusation that the parents are being called actors.
	So yes, he does say that in his email.
	Right.
	And Free Speech System's position is right now, as you testified before the break, that you assume those were InfoWard's audience members, correct?
	Do I assume that the people that were doing this were InfoWars members?
	Did you testify to that?
	I said the general public could have been InfoWars audience members.
	I don't know.
	I don't have enough information to formulate an opinion on that.
	I guess we'll have that read back at the appropriate time.
	And Presbyte Systems had a choice on this day.
	When they We're told by a grieving father that info wars have created these hateful people and need to be reeled in.
	Actually, you used that same term just now, reeled in, didn't you?
	That Mr. Jones had reeled it in?
	Yeah.
	I did use that term, yes.
	Right.
	But on January 27th...
	But they didn't reel it in.
	Because on March 27th, Alex Jones again ran a broadcast.
	With another gentleman, Dr. Steve Pechenek, correct?
	I'm not sure of the date, but yes, I know that there is a video with an interview of Dr. Pechenek.
	And it was titled by Alex Jones, Dr. Steve Pechenek, Sandy Hook Was a Total False Flag, right?
	Yes, I believe that's the title.
	And he had one to say that no children died and that the parents were actors, correct?
	That is what Dr. Pechenek said.
	And Alex knew he was going to say that, yes?
	I don't know if he knew that beforehand.
	Well...
	As soon as Mr. Kuchenek said it on the show, Alex Jones said, oh, I've got to get you back on to talk about this next week, didn't he?
	I think he did invite him back.
	Right.
	And that was April 1st when he had him back on.
	And this, Alex Jones titled himself, Crisis Actors Used at Sandy Hook Special Report, right?
	I believe that is the title.
	And that's where Mr. Jones said Sandy Hook involved the whole group of actors, right?
	Did Mr. Jones say that in that particular video?
	I don't recall I don't
	recall
	I don't recall
	I guess I would term him a...
	How do I put this?
	He wasn't a free speech employee, but he was a person to whom we would provide video equipment and send him on various assignments, and he would then do some reporting that was aired on InfoWars.
	Is it free speech system sworn testimony that Dan Badani was never an employee of InfoWars?
	I know we got into this at our deposition and I think I said I didn't think he was an actual employee, that he was a contractor.
	And I wasn't sure then, and I'm not 100% sure now, but I do believe he was a contractor.
	Okay, so I just want to, I mean...
	I know we talked about it at our deposition.
	I just want to, I'm not asking you to guess.
	I don't want what your best sense is.
	I want to know what free speech system's position and sworn testimony is as to whether Dan Bedondi was ever an InfoWars employee.
	I'm not sure.
	Okay.
	You said you read Alex Jones' deposition?
	Which one?
	In Connecticut?
	I don't believe I've read the most recent one, but I've read probably two or three other of his depositions.
	I know he was deposed in Texas as well.
	Okay.
	Okay, so do you know whether or not you read the deposition that he gave in Connecticut?
	The most recent one I did not review.
	I don't have a copy of it.
	Okay, so you understand that he sat for several days, right?
	Yes.
	It's all one deposition.
	It just happens over several weeks.
	Yes.
	Okay.
	Did you read the first day?
	Do you know what date that was?
	I do.
	I believe it was April 5th.
	Did you read that day?
	Of this year?
	No.
	I don't think...
	I never received copies of his most recent deposition.
	So, Alex Jones is presenting you to testify as Free Speech Systems' corporate representative.
	He offered sworn testimony about the allegations in this lawsuit, and you never read it.
	I didn't have a copy of it.
	I also didn't get a copy of the first two days of my deposition.
	So...
	Did you ask?
	I did ask.
	And they didn't give it to you?
	I was not able to receive it.
	So, if I were to ask you...
	About anything Jones said during the deposition testimony he gave in this case, you can't say anything about it?
	For those two days?
	No, I've not read it, so I don't know what he said.
	And you asked for it, and they didn't give it to you?
	I asked for my depositions, his depositions.
	I hadn't gotten copies of them, no.
	And that's because they didn't want you to know what he said, right?
	I don't think that that's the case.
	Well, when you asked them to send it to you, and they didn't send it to you, did you say, hey, why aren't you sending me?
	No Dambadandi Dambadandi We'll do Dambadandi
	We'll do Dambadandi Yeah, I was just checking the time, that's all If you need to have a time, just ask me, otherwise you can Oh, okay.
	I could probably figure that out.
	Oh, I see it.
	Yes.
	I'm sorry.
	I'm sorry.
	I didn't know if you asked a question.
	You're aware that in November of 2013, 11 months after the shooting, The Connecticut State's Attorney's Office responsible for investigating the shooting released its report, correct?
	Yes.
	That report concluded that 26 people had been murdered at San Diego Elementary School, correct?
	Yes.
	That Alex Jones, I'm sorry, that Adam Lanza was the lone shooter, correct?
	Yes.
	That staff members within the school had acted heroically to save children, correct?
	Yes.
	That EMTs were in the school searching for survivors and trying to treat anybody who might need medical attention?
	Yes, I did see that in the report.
	And on November 26, 2013, Rob Dew, one of Alex Jones' most trusted employees, received a copy of that report, correct? one of Alex Jones' most trusted employees, received a copy Yes, I do believe he was sent it in an email with an attachment.
	Let's look at that.
	Exhibit 112.
	I do not have 112.
	No objection.
	All right, so order.
	An email address changeshorses at AOL.com, right?
	To Rob Dew and Kurt Nimmo, correct?
	Yes.
	Rob Dew, as we said, long-time trusted employee at InfoWars.
	Kurt Nimmo, one of the lead writers at InfoWars, correct?
	Yes.
	Do you know what Alex Jones said about this report?
	Do you know if Alex Jones read it?
	I do not know if he read it.
	I'm not sure.
	Did you ask him?
	I did not ask him specifically about the report.
	Do you know if he received it?
	No.
	Received a copy of it after Mr. Du?
	I don't know.
	I didn't ask him about it.
	Okay.
	So let's go into 2014.
	Actually, you know what?
	Let's pull up Exhibit 120.
	120 is a full exhibit.
	And let's go to 2013, please.
	Okay.
	Is there any way you can pull up 2012 with 2013?
	It's still big enough for people to see.
	Alright, I'll tell you what.
	pull up 2012 first and we're going to do this again
	now the jury's familiar with this by now as are using this pause right?
	yes let's start with Sessions.
	Users.
	Do we have to do this again?
	Objection, asked and answered.
	Repetitive.
	Page views.
	Now this is 2012, right?
	So we're going to do, and we're going to use round numbers.
	Okay, Ms. Fox?
	Sure.
	For sessions, 119 million, right?
	Total, yes.
	I see that, yes.
	Okay.
	Users, 49 million, right?
	Yes.
	Page views, 280, let's say 286, okay?
	Just because that's the number there even though we're not rounding up.
	286 million, right?
	Yes, I see that.
	Let's pull up 2013. In 2013, Is the year we've just been looking at, right?
	The video about crisis actors and James Tracy, yes?
	Yes.
	Why people think Sandy Hook is a hoax, right?
	Yes.
	The videos with Steve Kuchenek, crisis actors used at Sandy Hook, yes?
	Yes.
	All of that.
	So now we're on 2013 here.
	How many sessions in 2013?
	total sessions 179 million how many users 73 million.
	How many page views?
	hundred and twenty seven million this is just on infowars.com right I Yeah, I believe so.
	Not Twitter, not YouTube, not Facebook, right?
	Right.
	Just Infowars.com.
	right now I'm not good at math but at least when it comes to sessions I can tell this is about 50% increase right I'm terrible at math, so I will accept your representation.
	We'll have a calculator to do it.
	Sure.
	There's no doubt in your minds, Free Speech Systems, that this represents a substantial increase in audience size over the year 2012 to 2013 when Alex Jones started calling this thing hoax, right?
	There is an increase, yes.
	And that increase meant that Alex Jones did a lot better financially in 2013, right?
	I'd have to see the numbers for the store.
	Well, you know the trend.
	You've seen the numbers, right?
	I've seen the numbers, yes.
	So you know, without giving it to the penny, that that increase in audience in that year meant that Alex Jones had a much better year financially in 2013. I can't recall the numbers as I'm sitting here, so I don't want to say something and I'm not sure what the numbers were.
	All right.
	So let's go into 2014.
	You're familiar with a gentleman named Wolfgang Howie.
	Yes.
	It came to Alex Jones' attention in the spring of 2014.
	Yes?
	Not originally Alex, but yes, it came to Infowars' attention somewhere in early 2014. I'm just asking about Alex.
	Was Alex aware of him?
	Yes.
	In early 2014?
	Yes.
	And Wolfgang Halbig was a guy who lived in Florida, right?
	Yes.
	Retired?
	Yes.
	I believe so, yes.
	Not a media personality of any kind, right?
	I don't think so, no.
	Just living in Florida.
	Like any other person, right? - Okay.
	I guess I don't know much about him personally, but...
	Yeah.
	Didn't have a show?
	No.
	Didn't have a social media following?
	I don't believe so.
	He had a website.
	Do you know when he launched that website?
	The date?
	No.
	Let me hear more about that one.
	We get Alex's attention that Alex invited him on his show repeatedly to talk about Sandy Hook beginning in 2014, correct?
	Yes, he was on there a few times in 2014 into 2015. He was on from 2014 to 2015, but Alex Jones kept repeating Halbig's lies about Sandy Hook well beyond that, correct?
	He did.
	Now before Wolfgang Halbig was given the InfoWars platform by Alex Jones to speak to his millions and millions of listeners,
	Nobody at InfoWars did anything to look into Wolfgang Halbig's background except to go to a website that Wolfgang Halbig had.
	You mean did they investigate his background other than going to the website and looking at his biography that he posted there?
	Let me ask my question again.
	Okay.
	Nobody at InfoWars did anything to look into Halbin's background other than go to Halbin's own website before they allowed him onto the Alex Jones show to tell lies about Sandy Hook, correct?
	Right.
	That's all they did was look at the website and his biography was posted on the website.
	A biography that he could survive.
	Correct.
	A biography that he could survive.
	The first time Alex Jones had Wolfgang Halbig on was March 14, 2014.
	Correct?
	I don't recall the date.
	I know it was early 2014. You recall that Alex Jones titled that video, Sandy Hook, False Narratives vs.
	Reality?
	I believe that is the title, yes.
	Thank you.
	And on that episode of the Alex Jones Show, I'll tell you what.
	Let's just play.
	Let's play clip two.
	I'm sorry, 15D. This is 15D. That is a full exhibit, Your Honor.
	Thank you.
	And you know what?
	They won't tell me who was in charge on that day.
	Now, that tells me a serious problem because that incident commander was in charge of requesting trauma helicopters.
	I'm 67 years old.
	I've never ever seen a school shooting where we don't get the quickest and the fastest medical help, and there's nothing like We have the videos of them, the same kids going in circles.
	They're not in the building.
	Unmistaken drill.
	And then they just tell them they were all shot?
	I mean, keep going.
	Well, Alex, I mean, for anyone to understand what you and I today are talking about, I got your listeners to pretend that they have a child in that school on December 14th Pretend that you have a first grader, a little girl, a little boy, you love your life, and they don't order trauma helicopters knowing they may be seriously shot, clinging to life.
	And then, why would they not let the paramedics and the EMTs inside the school?
	Now, who made that decision?
	That is just unheard of.
	It's cruel.
	You need to provide medical attention.
	So they overrode the default, they overrode the default, uh, Now, we heard a couple of claims in there.
	One was that there were no trauma helicopters dispatched, right?
	Yes, that's one of Mr. Halbig's, as he claims, 16 points.
	Okay.
	And...
	I guess...
	Mr. Howling and Mr. Jones didn't realize that Danbury Hospital is just 10 minutes from San Diego, right?
	Objection, judge, argumentative, seems like not in evidence.
	How far is Danbury Hospital from San Diego?
	I don't know.
	I'm not from there.
	And Alex Jones said in this video, not Howling, Alex Jones said in this video that you have kids walking around the school in circles.
	A clear drill.
	Did you hear that?
	I heard him say that, yes.
	That was a lie, right?
	You mean was it true whether there were kids walking around in circles?
	Yeah.
	No.
	There were no kids walking around in circles.
	Right.
	And then you heard Helbig say, and there were no ENTs allowed in the building, right?
	I heard him say that, yes.
	And Alex Jones knew that was false, right?
	I don't know what Alex knew.
	Free Speech Systems was aware that was false because they had the report indicating that EMTs were in the school, correct?
	Yes, Rob had the report.
	He sent the report.
	And in the clips you saw of yesterday's testimony, did you see Bill Aldenberg's testimony that when he was in the school securing it, that he saw paramedics in there?
	I don't remember whether I saw that clip of his testimony.
	Let's play 15C please.
	What do you make of the green screen of Anderson Cooper down there on the ground?
	What do you make of the obvious stage interviews and multiple actors playing the part of multiple people?
	I mean, this is undoubted.
	Something's going on.
	So you heard him talk about the green screen there, right?
	Yes.
	And what he's referring to is this interview between a CNN anchor, Anderson Cooper, And Veronique De La Rosa, correct?
	Yes.
	Veronique De La Rosa lost her child at San Diego, didn't she?
	Yes.
	And what Alex Jones is suggesting to his audience is that this interview actually isn't happening in Newtown.
	That there's a green screen behind them and that they're faking where they are, right?
	That Anderson Cooper wasn't there.
	Correct.
	So it was a green screen.
	Did he tell his audience in the clip that you just saw that he was only talking about Anderson Cooper?
	No, but he has said, I think in one of his depositions, that he was specifically referring to Anderson Cooper.
	Right, he said in his deposition that he wasn't talking about Ms. De La Rosa.
	Because he doesn't want this jury thinking, oh, I was calling her an actress.
	I was only talking about Anderson Cooper, right?
	Argumentative, attributing thoughts to his mind.
	I'm not entertaining any objections attorney, Patterson.
	I beg your pardon, Judge?
	I said I'm not going to entertain your objections unless you're on your feet.
	I'm on my feet.
	Objection.
	Putting thoughts into Mr. Jones' mind.
	- Sidebar, please.
	Okay.
	I would never disrespect you like that.
	That was disrespectful.
	You did even stand up.
	You just sort of got up a little bit and hunched over.
	I literally will not, I say it for the record, so we have a good record.
	I will not, I let the last three or four go, but I will not entertain objections unless you stand up.
	I'm not asking for anything that's out of the norm.
	No, you're not.
	I've now lost the question and the objection.
	Thank you.
	So I can play it back?
	No, I think I can get it across.
	You just offered Ms. Paz that Alex Jones offered, for the first time in depositions, in advance of his trial, that when he was referring to this being a fake interview, he was only talking about Anderson Cooper, not Ms. Delarosa, right?
	That's what he said in his deposition, yes.
	He never, ever said that to his audience.
	On the many, many times he claimed that this was a faked interview, and that's one of the reasons this whole thing was a hoax.
	He never claimed that it was just Anderson Cooper and that was De La Rosa, right?
	I don't think he specified either way.
	All he said was that it was a faked interview, right?
	I believe those are the terms he used, yes.
	Okay.
	But even if he now wants to suggest that he was only talking about Anderson Cooper, I guess we're just supposed to believe that Miss Delarosa is just playing along, looking into Blank's face.
	Objection, Judge.
	I don't even know what that is.
	Objection.
	Relevance.
	Argumentative.
	It's not again.
	If Anderson Cooper's not there and Ms. De La Rosa is, who the heck is she looking at?
	I don't know how to answer that.
	I'm not Veronique De La Rosa.
	I haven't spoken to her.
	You heard him say, in this last clip we just in this last clip we just saw, you got multiple actors playing parts of multiple people, right?
	That's what he said, yes.
	And there he's talking about this claim that Bill Oldenburg and David Wheeler are the same guy, right?
	Objection.
	He's speculating.
	I don't know who he's talking about.
	about he doesn't specify it could be to me in here right maybe Objection judge.
	This is argumentative, speculative.
	If she doesn't know, he can't make it up.
	He's a different question, so I'll answer it if she knows.
	Maybe he was saying that Nicole Hockley, Who lost her son, Dylan?
	And Jacqueline Barden?
	Who lost her son, Daniel?
	Maybe they're the same person playing different parts, right?
	Objection, speculative, argumentative.
	Excuse me.
	Objection, speculative, argumentative.
	Do you know the answer?
	I do not.
	Free speech systems just doesn't know who he was talking about.
	I don't know.
	He didn't specify.
	But we know it was the parents, right?
	I don't know that.
	I don't know who he's talking about.
	I have no idea who he's talking about.
	Ms. Pox, is it really your testimony to this jury of all the videos that you've watched and all the testimony that you've already given that when Alex Jones is referring to actors, you don't know whether he's talking about the parents?
	I know he has specifically referred to Mr. Parker as being an actor, and we talked about that, but that is the only person he's ever specifically referred to.
	How do you know that, Ms. Pox?
	How do you know that that's the only parent he's ever specifically referred to?
	When Free Speech Systems hasn't even given you all the videos?
	From what I saw, that's all I saw.
	Right.
	That's all you saw because that's all they wanted you to see, correct?
	I don't know how to answer that.
	I don't think they specifically withheld things from me.
	And you know that.
	Why?
	I just don't think that they purposefully withheld information from me.
	Okay, so they would go in front of an audience of hundreds and hundreds and hundreds of millions of people and claim that parents who lost children were actors, but they wouldn't dare to withhold a video from you.
	Objection, judge, argumentative.
	Now, after Halving came on...
	Actually, you know what?
	Let's play...
	You know what?
	Back up.
	Let's play 15D.
	Same video here, if it's possible.
	It's also a full video.
	Well, the biggest piece of evidence is that Bloomberg had his social network folks ready two days before.
	Oh, absolutely.
	They had the website.
	There were websites up for donations, contributions.
	Perfect.
	This Bloomberg email, we're going to hear about that a lot, right?
	Yes.
	It's an email that Alex Jones repeatedly told his audience, a gentleman named Michael Bloomberg, who's the former mayor of New York City, had sent out, here he says two days before, sometimes he says one day before, by accident, that he jumped the gun.
	And he sent out an email to capitalize on the next school shoot.
	And what Alex Jones is saying is that Mike Bloomberg himself knew that Sandy Hook was going to be faked, but he accidentally sent out this email before.
	And that's one of the reasons we know it was a hoax, right?
	He has said that, yes.
	There is no email.
	Correct, Ms. Paz?
	There is an email, it's just not a characterization as he says it.
	Wait a minute, wait a minute.
	Have you ever seen an email that Mike Bloomberg sent?
	There's an email that I reviewed in the- Can you answer my question?
	Have you ever seen an email that Mike Bloomberg sent?
	I don't think it was specifically by Mike Bloomberg, but it might have been from someone associated with Mike Bloomberg, and I did see something like that in the material.
	I was deposed on this issue.
	Your sworn testimony to this jury is that you saw an email that either Mike Bloomberg sent or somebody associated with him sent.
	You saw the email.
	I'm trying to recall if it was the email or maybe it was an article on...
	A press release, but what I specifically recall seeing in the material was Mr. Bloomberg is a member of a loosely connected...
	Objection, she's not being permitted to answer, Judge.
	I think she is.
	She is not, so why don't we move on?
	I want to ask this question again.
	Is it your sworn testimony that you have seen an email, an email, From Michael Bloomberg or somebody associated with him that Alex Jones is referring to?
	I don't recall if it was an email or a press release or in a news article, but I saw something to that effect.
	so I don't recall if it was specifically an email would you mind we're going to have you back tomorrow would you mind overnight checking all of your materials that you've been given and tomorrow would you please bring in whatever it is that you're referring to Because I'd like to see it.
	I believe I was deposed on this issue either here or in Texas.
	Okay, but I'm asking you, would you please, when you go, when you leave the courthouse tonight, you have access to all the Dropbox materials, right?
	I think I still have access to it.
	Would you please go through them and see if you can find the item that you're referring to and see if you can bring it to us tomorrow, okay?
	I'm going to object to that.
	Would you do that?
	I understand your request.
	I will make an attempt to do that.
	Okay, thank you.
	Let's go to Exhibit 15F.
	I think it was just a planned massive FEMA, Homeland Security.
	I think it was a major drill, portraying as one of the best illusions ever.
	And I think it was trying to create empathy across the country for making us feel bad that so many children were killed.
	And look what happened in Connecticut.
	It worked.
	They're taking the guns away from people in Connecticut.
	And guess what?
	They're just long fighting.
	It's beginning in Connecticut, which is the next state?
	What's the next state?
	All because of Sandy Hook.
	That's right, and then there'll be another shooting, you know, how dare you see it's your fault.
	It's so obvious they're using this disarmament, they admit it, and it's just a total hoax, any way you slice it, and so sloppily.
	Total hoax, that's what he said, right?
	That's what he said.
	Now, after this interview aired to Alex Jones' audience, a gentleman named Robert Heath sent by Don Salazar, a gentleman that we've been talking about, an email, correct?
	Yes, I believe there was an email from a Mr. Heath.
	This is Exhibit 26, your honor.
	I believe it's in evidence.
	Yes, it is.
	Chris?
	You know what, I was referring to the deposition exhibit.
	It's not 26, it's 116. I'm sorry, which is not in evidence.
	And I think there's no objection to it.
	May I speak to Attorney Manning for a moment, Judge?
	No, no, what I'd like to do is just bring it up on the witness's screen.
	Very well.
	We'll do it that way.
	So what you see here, do you have it before you, Ms. Possible?
	Yes.
	Okay, what you see is an email From a gentleman named Robert Heath to a Don Salazar, correct?
	Yes.
	And as we've already discussed, a Don Salazar was a writer at Info Wars.
	Yes.
	And the email is...
	In this email, Mr. Heath is warning Mr. Salazar about Mr. Howe's so-called Hearsay, I don't know who Mr. Heath is, Judge.
	This is offered...
	I'm sorry?
	This is offered to show notice to Infowars and the extent to which they ignore warnings about Mr. Halby's credibility.
	That assumes the truth of the matter is asserted by Mr. Heath.
	I don't know who he is.
	Hearsay.
	I have to avoid so the rejection sustained. - Let me see if I can go a little bit further here.
	You'd agree that, let's look further up at that email.
	You've seen that email after Mr. Heath emails Mr. Salazar, Mr. Salazar responds, correct?
	Yes.
	Yes.
	Mr. Salazar essentially informs Mr. Heath that he's not gonna look into The concerns about Mr. Halliburton's credibility, correct?
	I don't object to the sale.
	It's our portion as an admission applied by client or as agent.
	The only way that the admission is relevant, Your Honor, is if there's context to understand what it is that he was acknowledging.
	Your Honor, you know what?
	We're at 420. I think that you wanted to let the jury go a little bit early today, so maybe we can discuss this.
	It's been a long day.
	All right, so I will stay on the record.
	We will let the jury go for the day.
	I'm not going to.
	Repeat in detail all the rules because I've said them so many times that I know that you know what I'm talking about, but again, just especially avoid any media exposure, change channel, divert your attention, And if you are not able to avoid it, or there are any other issues, you'll follow the procedure that I told you, alright?
	We will start promptly at 10 o'clock tomorrow, so I'll see you then, and the Commissioner Farrell will collect your notebooks.
	Thank you very much.
	May Ms. Paz leave the stand, Judge.
	Judge, the jury's out.
	I wanted to apologize in the presence of Edwin.
	I didn't mean to convey disrespect when I didn't stand before.
	I just lost track of where we were.
	I'm sorry.
	That's fine.
	And please be seated.
	While we're on the topic, I think I would prefer any future use of that board.
	Not to be over there.
	Maybe you can find another spot for two reasons.
	One, I don't really like having the witnesses back to me at all.
	And two, there's no barrier there with the jury.
	And I just think that we want to keep a respectful distance.
	Maybe we can try it out right now if you want to see, because you may use it.
	Again, find a spot.
	I want to make sure Attorney Patis can see it and the jury can see it.
	So do you want to try that now?
	I'll discuss it with Attorney Patis.
	We don't need to waste the force time.
	We'll figure out a good place for it.
	May I speak to Mr. Amanda?
	We may be able to reach an agreement about 116. I think we've got an agreement on 116. The Heath portion is not being offered for the truth of the matter.
	Asserted is my understanding, but rather for the impact on the listener.
	The listener is an agent of my client, and I think that comes in.
	So subject to that limiting instruction, I would withdraw my objection.
	Yes, Your Honor.
	We're offering the exhibit not to the truth of the matter, but to show the impact on the listener, notice to the listener, and any response they made in response I don't know.
	Oh, go ahead.
	I don't know that I would say notice to the listener because that gives the email more credit than it may be due.
	Can you talk about it and give me your proposed language tomorrow?
	Yes.
	I'm sure you can reach an agreement.
	I know we will.
	I do want to tell you that I did think I almost called a five-minute recess because I thought one of the jurors had their eyes closed sometimes after lunch, but it turns out that The juror was taking copious notes, so that was good news.
	I kept looking over there, so that's good news.
	When do we want to deal with the free speech system PQPR issue?
	Tomorrow morning.
	Or now?
	No, not now.
	Thank you.
	All right.
	Anything else besides that?
	No.
	Okay.
	So we are adjourned for the day.

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