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Sept. 16, 2022 - Depositions & Trials

04:28:56

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

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	Okay, so we are now on the record.
	Game 4 of the Lafferty versus Jones matter.
	Good morning everyone.
	If council could please identify themselves for the record.
	Good morning, Your Honor.
	Chris Maddy, I'm half of the place.
	Joined by my colleagues Alamor Sterling and Josh Casco.
	Good morning, Your Honor.
	Good morning.
	Good morning, Your Honor.
	Good morning, Judge Norm Taddis.
	I've got John Blutz here with me again today.
	Good morning.
	So, we are going to take up an issue, correct?
	Yes, Your Honor.
	I think that would be helpful.
	Okay.
	We expect to finish with Ms. Paz sometime this morning.
	We filed a brief a day or so ago relating to the scope of cross-examination given that Ms. Paz is a corporate representative and presented by the defendant.
	We wanted to advise the court and advise the defense counsel of our view that because she has testified quite clearly The defense cannot, through her, offer substantive testimony based on hearsay.
	The reason that we raise this is because we obviously have concerns that we've already raised concerning nullification and other matters, and so we just want to be very, very clear that, as far as we're concerned, there's very little of substance that Ms. Paz would be Most of what she said were admissions.
	Correct.
	We offered them as admissions.
	I understand.
	And so we wanted to raise that for the court so that we can have an understanding of exactly what's going to be happening and perhaps an offer of proof as to what, if anything, Ms. Paz is actually competent to testify to in the defense case.
	And I would just add that the defense had the option of presenting a witness who could testify to certain matters based on personal knowledge if they had wished.
	Daria Karpova, a longtime employee, was presented as a corporate...
	I thought she was on the witness list.
	She is.
	She's not going to be called here because the defense could not present her live in our case.
	But she was presented as a corporate representative in Texas, in the Texas litigation, and was permitted to testify to certain things on...
	I'm sorry.
	I'm not understanding.
	So why can't she be called here if Attorney Pattis wanted to call her?
	Because under our agreement in the bankruptcy court, if the defense was going to call any witnesses, they had to make them available to testify live in the plaintiff's case if we wished.
	Ms. Karpova was not made available to testify live.
	And so… I can't speak to that.
	Pardon me?
	That's not my agreement or issue, but okay.
	Yeah, I mean, we would have been willing to call her had she been able to testify live.
	The point is that free speech systems as a defendant here could have presented anybody to testify as a corporate representative and somebody who had personal knowledge.
	They chose not to do that.
	They also chose to refuse Ms. Haas' requests to give her certain information so that she could testify competently.
	And it appears, based on her testimony, that they lied to her about the use of Google Analytics.
	And so it seems to us that they have presented somebody as a corporate representative for very, very strategic reasons.
	And so they shouldn't be permitted to take advantage of that by offering otherwise inadmissible testimony to her.
	All right.
	So I think, as I'm understanding it, Attorney Pattis, the issue is inadmissible hearsay.
	It's our view.
	And then any number of occasions asked to opine, not as Ms. Potts, but as free speech.
	And I objected any number of times on relevance, competence, speculation on the ground.
	I just want to make sure I understand.
	So I thought we were talking about not relevance, that the issue that the plaintiff was raised was inadmissible hearsay.
	Not relevance, not competence, nothing else.
	I'm setting that up, the argument, Judge.
	I didn't take it as a motion to eliminate it.
	It was a bench memo.
	I thought, you know, okay, bench memo.
	Submit a bench memo.
	Great.
	But I'll construe it as a motion to eliminate it.
	Our position is that experts are akin, or excuse me, that corporate reps are akin to experts, and they are asked to assume the position of the corporation in the courtroom.
	As this court knows, corporations are legal fictions.
	They can't manage.
	I'm just going to ask you because I won't forget.
	So is there any case law that supports that statement that corporate representatives are experts?
	Because if there is any, I need to review it.
	I am unaware of that.
	Didn't see any.
	Didn't see any to the contrary.
	But this court knows that corporations Exposition that came,
	if any, The
	The witness's personal knowledge goes to the weight of the evidence, not its admissibility.
	And it seems to me that in this case, the plaintiff's elected to elicit and to impeach a defendant, in this case, through its corporate rep, asking if it was its position as the corporate rep that X, Y, or Z was the case.
	I think within the scope and limits of that, I am permitted to ask her why she has that opinion and what it's based on.
	Does she carry a revised?
	I expect there will be more cross-examination today.
	As a corporate rep, are you saying?
	I've tried to object that a corporate rep can't say anything.
	corporation can't speak.
	It exists, no more exists than does the state of Connecticut.
	It exists for purposes of administrative convenience, but it speaks through its officers.
	And if a party elects to call an officer and treat that officer, and treat the abstraction as a person through the officer, they waive the right to complain about what that officer says when they're asked about things clearly within the scope of what they inquire on.
	So, Attorney Maddy, on the one issue, the minor issue that was mentioned, when Attorney Tavis just said that he wants to inquire about what she looked into to prepare, what she researched, that kind of thing.
	That you don't have an issue with.
	I think if he asks her, who did you speak to, What conclusions did you personally draw as a result of the collection of evidence that you reviewed?
	That is very much expert testimony about corporate practices We didn't ask for her opinions.
	We asked her what the fact was.
	Any number of times, actually, remember, Judge, Ms. Paz said, I can't speculate as to what was in his head.
	So she was called here to testify about what the corporation can state as a fact or not a fact.
	And all of that was based upon a lack of personal knowledge, but only on what she gained by virtue of hearsay conversations she had.
	And so, you know, the...
	Well, it wasn't all gained by way of hearsay conversations.
	Was it?
	Well, I suppose other than her review of videos.
	She reviewed videos?
	She reviewed documents, I thought?
	She may have reviewed some documents.
	And if Attorney Patis wants to present her with a document that she reviewed, it's not at all clear from her testimony what documents were made available to her.
	And I think all she can testify to is the contents of the document.
	So, you know, what we can't have here is a situation where Ms. Paz is kind of holding forth about her views of how free speech systems works, and it's a very chaotic environment, and Alex Jones, you know, kind of operates on the fly, and all of that.
	So, that's...
	So, Attorney Maddie, if Attorney Paz wanted to...
	To obtain the position of free speech systems along the lines of how you elicited their position.
	How would he do it?
	Well, to call it a position, Ms. Haas is not here to take a legal position.
	She's here to assert facts.
	I thought you had asked her several times what is free speech's position on whether Sandy Hook happened and what is free speech's position on whether You know, whatever it was.
	And I thought that she testified.
	I don't understand.
	Is it your position that now Attorney Paz can't cross?
	How would it ever-- It is my position that to the extent Ms. Paz formulated any position based on information provided to her by others, that is hearsay.
	I think Attorney Matti's proven my argument with his argument.
	They called free speech, asked her as free speech.
	I think she's entitled to testify as free speech.
	I don't think what I'm entitled to do is to say-- when Alex said, whatever.
	When the grass was green, I don't think I get to say what else did he say about the grass.
	I think that's correct.
	Excuse me.
	Excuse me.
	What about this decorum rule, Judge?
	I didn't cut him off.
	I just realized that.
	I'll have a sidebar please I should ask So I thought you were past this.
	Oh, Your Honor, I just...
	No, no, you interrupted.
	Yes, I apologize.
	No, I really...
	I apologize.
	I just realized that she was here for the first time.
	No, no, I mean they're cutting each other off.
	Do I not control?
	I'm sorry, I lost my camera.
	No, you both did it.
	Do I not control the proceedings good enough?
	Would you do this in front of Judge Ford?
	Do you remember Judge Ford?
	I probably would have, and I probably would have gotten in more trouble than I have here.
	Right.
	He wouldn't be offering a call?
	Well, can you just please forgive him?
	Can we at least let you stop doing that?
	Please?
	Okay?
	Got it.
	Okay.
	Now, I don't know.
	If you'd like to turn in a positive step out, that's good.
	I think, I didn't think he did either.
	I invited the order that I would have none.
	Would you like me to?
	Yes, please.
	Okay, so we'll do that and then we'll go back.
	As I was saying, I'll wait for attorney Pons to be real long.
	Attorney Maynard approved by argument with his, And so I have nothing further to say.
	Anything further, Attorney Maddie?
	You didn't need to hear anything more on the expert analogy, did you?
	No, absolutely not.
	So I think, I can't see issuing a blanket ruling now, but certainly if she has personal knowledge based on her Oh, personal review of a document or a video, that's one thing, but if she is basing anything on inadmissible hearsay, then it just doesn't come in.
	It came in, a lot came in on Attorney Maddie's examination, an admission of a party opponent, and that's not the case here.
	So I think she'll be able to offer some testimony, and certainly if she If she put forth a position of free speech system and it's not based on hearsay, then I think that that's perfectly fine.
	If it is based on hearsay, that's a different issue.
	So I think we have to see what different areas we're talking about.
	Okay?
	Got it.
	All right.
	When would you like to deal with the issue of the every day I bring it up and every day we punt?
	Free speech systems and PQPR. Mr. Friar told me that we think that maybe the witnesses will end today at 3 or 3.30 or so.
	So that's what I got second hand.
	May I speak to Attorney Van Huston?
	Absolutely.
	Thank you.
	Attorney Ferraro was correct.
	It appears that Attorney Pat has been playing some more videos during his pause that are fairly lengthy.
	Just too long.
	So when I gave her on that testament, I didn't realize the cross would go that long.
	Yeah, yeah.
	I mean, it's also, I don't know if you want to end early, but we can think about it.
	It all depends on how.
	Well, I don't want to end.
	I don't want to bring a jury in front.
	No, but I will not be a police.
	It's been a long week since I'm driving to New Jersey.
	I responded this morning to a memo I saw yesterday, and quickly I would like an opportunity to think about it a little more.
	I mean, I gave an over the one that was filed regarding enforcement of orders, a claim that I argued no location to report this file on the 15th.
	I got in early this morning to crank out a response.
	You don't have to do that.
	No.
	What about the children?
	We have a couple more.
	Oh, please.
	Why not?
	No.
	No.
	Yes.
	Yeah.
	We could play it.
	Yeah, I do vote.
	But I would be happy not to vote.
	I wasn't entirely clear with attorney Maddie yesterday because I expected an hour and a half and then I'm thinking about it overnight.
	I gave my heads up this morning about the videos.
	- All right, I think we probably would all prefer not to go to 4:30, 4:40, sure.
	How about that?
	So getting back to when are we pumping again or when do we wanna do the FSS PQPR issue?
	You can take it up now.
	Well, I should have been a little clearer.
	I want to do it not to inconvenience the jury.
	We can, you know, we can do it either at the end of the day, we can do it, we could come in Tuesday and do it at 9.45 if you want.
	I just don't want to do it when the jury's waiting.
	I just didn't know when we needed to decide it on.
	Given what Trini Patterson said he expects to do across on this pause, I suppose, so long as she doesn't...
	Say anything on the remainder of my direct, we probably don't need to do it.
	I have no intention to get into that area.
	If it changes, I'll report, but I don't...
	Sure.
	So, Your Honor, then could we do it late this afternoon?
	I think we do need a ruling.
	All right, so why don't we tentatively plan on doing it at the end of the day, tentatively, and if not, we'll do it Tuesday morning, 945. How's that?
	Perfect.
	You can take the papers from our perspective.
	That's all I have to say.
	Do you want an argument on it?
	Yes.
	Okay.
	Okay, I think we're ready for the panel.
	Thank you.
	And while we're waiting to bring the panel out, I will just remind everyone that in accordance with judicial branch policy, only those entities who have been specifically authorized to film only those entities who have been specifically authorized to film or otherwise record or photograph the proceedings are permitted to do so.
	If anyone violates the policy, your device will likely be confiscated by me, and you may be removed from the courtroom or courthouse.
	So please just obey the rules.
	Good morning.
	Good morning.
	Welcome back.
	Good to see everyone.
	Good morning.
	Thank you.
	Welcome back, everyone.
	Good morning.
	Good morning.
	Please be seated.
	We'll get you your notebooks.
	And counsel stipulates that the entire panel is present in the jury box.
	Yes, Your Honor.
	Alrighty.
	I know you have been a very conscientious jury here on time.
	By the way, we actually started at 10. We had some legal issues to address and some motions to argue, so we're sorry we got a little bit of a late start.
	We are very grateful that you're so punctual every morning, after every break, after lunch, so that we can move smoothly and efficiently.
	Ron has not advised me of any written notes, so I assume that everyone has been able to comply with the rules, avoid any media coverage, and is not concerned with any issues related to the contact Conduct of the proceedings, but if something does arise at any time, please make sure that you let Mr. Flora know so that we can immediately address it.
	All right.
	Thank you.
	Attorney Maddie, whenever you're ready, please pause.
	You may let the stand or you remain under oath.
	Of course.
	And while you're making yourself comfortable, just as a reminder, I did tell everyone, I believe I told everyone during jury selection and Maybe even the first day that September 30th, which is a Friday, right, Mr. Farrell?
	Yes, Your Honor.
	We will not be in session, so that will be a shorter week for you.
	That'll be a Tuesday, Wednesday, and Thursday.
	I think that's the last week of the month.
	But so just for your planning purposes, that week not only will you have Monday off, but you will have Friday, September 30th off, okay?
	You may inquire whenever you're ready.
	Thank you.
	Good morning, ladies and gentlemen.
	Good morning.
	- Good morning. - Good morning. - Yesterday, Ms. Paz, we started in March of 2014, when Mr. Hodden was first invited on the Alex Jones Show, correct?
	Yes.
	And we continued all the way through the end of 2016 and ended the day yesterday with a broadcast that Alex Jones made which he called Correct?
	Yes, I remember.
	And did you acknowledge that, notwithstanding the title, that actually wasn't his final statement on San Diego, correct?
	He has mentioned it after that, yes.
	Okay, all right.
	And he continued into 2017. On April 22, 2017, he broadcast a video that he titled, Sandy Hook, Vampires Exposed.
	You familiar with that video?
	I am.
	I don't recall the date, but I do recall that title, yes.
	Would it be helpful to have that chart just up for you so you can confirm the date?
	Yes.
	Yes.
	Why don't we bring up that chart that's been reviewing to check the dates just for her please.
	You had that before you had it.
	I do, yes.
	So what date was it again?
	I'm sorry.
	Yep, this would be April 22nd, 2017. Can we scroll down?
	Thank you.
	Yes, I see it.
	That's the correct date.
	Okay.
	And in this video, do you recall yesterday when I showed you, I believe it was the final statement on Sandy Hook, there was a segment of that video where Alex James was trying to convince his audience that they should believe Sandy Hook was fake, in part because CNN had faked its location.
	Do you recall that?
	That was one of the reasons listed in that video, yes.
	Right, right.
	And there was an article that went up Yes, that was one of the clips that was played.
	And I asked you the question whether or not what he was saying was that those two female reporters had been at Sandy Hook claiming to be in different locations, but they were actually in the same location.
	I think your response was, I don't know what location he was talking about, right?
	Right, I don't think he says that in the video, and I didn't ask him specifically.
	Okay, so I'd like you to pay special attention to that issue as you watch this first clip.
	this will be 36A, Sandy Hook vampires exposed. - Here's my message, and I'm gonna give it a bit more from Megyn Kelly, Chelsea Clinton, and all these other and I'm gonna give it a bit more from Megyn Kelly, Chelsea Clinton, and all these I'm not trying to get out of this alive, dumbasses.
	I'm not trying to get out of this a winner in your system.
	I'm here to bring you down.
	I'm here to make you pay for the wars and the lies and the corruption and the Clinton Foundation and all of it.
	That's why you keep missing the main calculation.
	I am a precision-guided heavy munition coming in on top of you.
	I'm here to stand up for the innocents.
	I don't like you.
	I don't like you getting away with what you do.
	You make me sick.
	So I hit the barbler and everybody else comes in over me.
	Have you seen what we've done on top radio now?
	Sounds just like me.
	Ms. Paz, what I actually want to ask you about in the clip we just saw is Mr. Jones' reference to himself as a precision-guided heavy munition.
	Did you hear that?
	I heard him say that, yes.
	And he's referring to himself as a weapon of war, correct?
	I don't know what he means by that.
	Okay, but you do know what the words precision-guided heavy munition is, right?
	I know it is a weapon that is traditionally used by the military, but I don't know how he's using it in this context.
	I didn't know what he means.
	I didn't ask him specifically about it.
	And then you heard him say, I'm going on the barbed wire and everybody else has come in after me, correct?
	That's what he said, yes.
	And he's referring to his audience there, isn't he?
	Subjection judge asking the comment on the contents of another mind.
	I don't know what he means by it.
	He doesn't say specifically.
	Let's play the second foot.
	This will be 36 feet, please.
	And they have guns that they're calling out.
	Then they're pulling guns out of cars.
	They're finding people in the backwoods that are dressed up in SWAT gear.
	And that's on helicopter footage.
	And they say it never existed.
	And they later admit it does.
	And then the school was closed until that year.
	And then the video is all running and falling apart.
	Nobody's even in it.
	The kids are going in circles in and out of the buildings with their hands up.
	And then they never called rescue shoppers.
	I mean, exactly.
	This is just repeating some of the same things we're going to help with.
	Correct.
	So this is April 2017, correct?
	Yes, I believe that's the date we said, April 22nd.
	May I have just one moment, Your Honor?
	Take your time.
	Oh, I'm told that I originally said 37 and I met 36a.
	This is why I was confused.
	Ms. Pazza.
	Oh, we saw the wrong video?
	No, I apologize.
	36A, Sandy Hooking of Vampires Exposed, okay?
	Okay, this is what I wanted to play when it came to the two female reporters that I first mentioned, okay?
	Okay.
	All right, let's play 36A, thank you.
	So here are these holier-than-thou people.
	When we question CNN, who supposedly is at the side of Sandy Hook, and they've got, in one shot, leaves blowing and flowers that are out.
	You see the leaves blowing and they go, they glitch.
	They're recycling of the green screen behind them.
	You've got, who's the female lawyer used to be on CNN?
	Fake southern accent, whatever.
	She's on there with cars driving in a cul-de-sac in circles, and you see it's the same cars going in circles.
	And then we've got Anderson Cooper, famously, not just with the flowers blowing in effect, but when he turns, his nose disappears repeatedly because the green screen isn't set right.
	I'll accept it right there.
	Did you hear the part where he was talking about the female lawyer with a fake southern accent?
	Yes.
	You know that to be Nancy Grace, correct?
	I'm not sure what her name is.
	I don't watch CNN, but I'll accept that's who it is.
	No, no, no, but you understand, you saw the article that we reviewed yesterday, right?
	Yes, I saw the clips.
	Okay, so is it clear to you now that when he was referring to that article, he was referring to those two reporters being in the same location at Sandy Hook?
	Same objection, speculation, contents of another mind.
	That's not clear to me by that clip.
	He seems to be talking about the Anderson Cooper interview.
	He says clearly a site at Sandy Hook.
	Then he's talking about that separate video footage with the two ladies from CNN. It's hard to tell if he means that they're the same thing in the same place.
	He never says.
	So I can't tell.
	I'm sorry.
	I didn't get you.
	That's okay.
	It seems to me he's talking about two separate things, but he doesn't specifically say that they're the same in the video.
	Let's pull up Article, this is Exhibit 65. I already know this.
	I do not have 65 as a full exhibit.
	Oh, it's agreed to.
	this previous-and-day read.
	I don't have that, but I won't have Jack.
	Okay, do you see this article?
	CNN anchors fake a satellite interview in the same parking lot?
	Yes.
	Okay, this is published May 9th, 2013 by InfoWars?
	That's what it appears, yes.
	Okay, and if we go down to...
	No, no, you can stay up there.
	I'm sorry.
	We go down to this third paragraph.
	Tricky.
	CNN. Very tricky.
	We understand, though, when a major crime story like the Cleveland kidnapping breaks, you have to send Nancy Grace.
	However, since Nancy Grace is a poorly medicated vengeance demon who's always just a bad morning away from ending up on her show, you always send in a real anger with whom she can correspond.
	That's what it says.
	All right.
	And so this article, published May 9th, 2013, It was referring to some claim about reporters being in Cleveland, not Sandy Hooker, correct?
	That's what it looks like, yes.
	So later in 2017, you can pull that down.
	Alex Jones gave an interview to Megyn Kelly, correct?
	Yes.
	Megyn Kelly is a fairly famous media personality, yes?
	Yes.
	She once worked at Fox, she later worked at NBC. Yes.
	And Alex Jones agreed to give her an interview, yes?
	He did.
	And before that interview aired, he became very unhappy about what was going to be aired, correct?
	That's a very brief way of saying it, but yes, he was not happy with the interview that was aired.
	And in particular, he wasn't happy with how he claimed the interview was presenting his claims about San Diego.
	Is that fair?
	That was one of his problems with it, yes.
	He had many, many problems.
	He was very upset.
	He was very upset about it, yes.
	And so he went on the air to talk about that, right?
	He did.
	And I think that's what he, part of what he was doing in that video we just saw where he said, here's my message to Megyn Kelly, Chelsea Clinton, and all these sea hags of the new world of order.
	I'm not trying to get out of this a lie.
	That may have been.
	What was it or not?
	I don't know.
	I didn't specifically ask him, but he does mention Megyn Kelly.
	Okay.
	Well, that exhibit 37 is actually entitled, Alex Jones Warns Megyn Kelly, Exposes Psychological Warfare Operation, correct?
	Yes, I think that might have been the video where he addresses the interview.
	When did the interview happen?
	I can't recall the date, I'm sorry.
	You knew I was going to ask you about this, right?
	Yes, I just cannot recall the date.
	Can you recall the month?
	I'm sorry, I don't.
	All right.
	In any event, what Mr. Jones did is he took to the airwaves to complain about it.
	Yes?
	Yes.
	OK, let's pull up.
	39. 39.
	That's a full accent.
	Yes, yes.
	One moment, Your Honor.
	Take a try.
	All right, I'll take a try. All right.
	I'll take a try. All right.
	All right.
	so so
	One of the individuals who gave an interview in connection with that Megyn Kelly broadcast was a gentleman named Neal Heslin, correct?
	Yes, I believe Mr. Heslin did give an interview.
	Neal Heslin is the father of Jesse Lewis who was murdered at Sandy Hook, correct?
	Right.
	And during that interview with Megyn Kelly, Mr. Heslin said that after the shooting, And that his child had a bullet hole through his head, correct?
	Yes, I believe he said that.
	And after that interview, Infowars ran a video entitled, Zero Hedge Discovers Anomaly in Alex Jones' Hit Peace, correct?
	Yes, I believe that's the title.
	And that video was hosted by Owen Schroer, correct?
	It was, yes.
	Owen Schroer is the gentleman who, Another broadcast that comes on right after Alex Jones, correct?
	Yes.
	He reports directly to Alex Jones, correct?
	As does everybody, yes.
	Let's play exhibit number 41. That is a full exhibit, Your Honor.
	Thank you.
	And for the record, Your Honor, this video was broadcast, and you can look at your chart if you'd like, Ms. Paz, June 26, 2017. So folks, now here's another story.
	You know, I don't even know if Alex knows about this, to be honest with you.
	Alex, if you're listening and you want to, or if you just want to know what's going on, Zero Hedge has just published a story.
	"Meghan Kelly fails to fact check Sandy Hook's father's contradictory claim in Alex Jones' hit piece." Now again, this broke, I think it broke today, I don't know at what time, but featured in Meghan Kelly's expose, Neil Hesslin, a father of one of the victims, during the interview described what happened at the day of a father of one of the victims, during the interview described what
	And basically what he said, the statement he made, fact checkers on this have said cannot be accurate.
	He's claiming that he held his son This is not possible.
	And so one must look at Megyn Kelly and say, Megyn, I think it's time for you to explain this contradiction in the narrative.
	Because this is only going to fuel the conspiracy theory that you're trying to put out, in fact.
	So, and here's the thing too.
	You would remember, let me see how long these clips are.
	You would remember if you held your dead kid in your hands with a bullet hole.
	That's not something that you would just misspeak on.
	So let's roll the clip first.
	Neil Hesslin telling Megyn Kelly of his experience with his kid.
	At Sandy Hook Elementary School, one of the darkest chapters in American history was a hoax.
	I washed my son.
	I buried my son.
	I held my son with a bullet hole through his head.
	Neil Hesman's son, Jesse, just six years old, was murdered, along with 19 of his classmates and six adults, on December 14, 2012, in Newtown, Connecticut.
	I dropped him off in 904. That's when we dropped him off at school with his book bag.
	Hours later, I was taking a muck a body bag.
	Okay, so making a pretty extreme claim that would be a very thing vivid in your memory, holding his dead child.
	Now here is an account from the coroner that does not cooperate with that narrative. - We did not bring the bodies and the families into contact.
	We took pictures of them Of their facial features It's easier on the families When you do that There is a time and a place for up close and personal in the grieving process.
	but to accomplish this we felt it would be best to do it this way and you can sort of you can control the situation depending on your photographer.
	I have very good photographers.
	It's going to be a month to have been able to actually see her.
	Well at first I thought that and I had questioned maybe wanting to see her.
	Okay, so just another question that people are now going to be asking about Sandy Hook, the conspiracy theorist on the internet out there that have a lot of questions that are yet to get answered.
	I mean, you can say whatever you want about the event.
	That's just a fact.
	So there's another one.
	Will there be a clarification from Heslin or Megyn Kelly?
	I wouldn't hold your breath.
	So now they're fueling conspiracy theory claims.
	Unbelievable.
	We'll be right back with more.
	Ms. Paz, the first thing I want to ask you about is, the entire source for what Owen Schroeder just did there was an article by zero hedge, right?
	Right.
	Zero Hedge is a website, correct?
	It is a website.
	And it runs articles with anonymous authors, correct?
	Sometimes they're anonymous.
	I don't think they're always anonymous, but...
	What's your basis for saying that?
	I don't know anything about Zero Hedge, so I can't say that they're always anonymous.
	I don't know anything about it.
	I think you just testified that you don't think that they're always anonymous.
	So, which is it?
	Do you know or you don't know?
	I don't know that they're always anonymous.
	Okay.
	You knew I was going to ask you about this video, correct?
	Yes.
	You knew I was going to ask you about Zero Hedge, correct?
	Well, I don't know anything about Zero Hedge.
	I don't represent Zero Hedge, so I can't testify as to Zero Hedge.
	I can testify as to the article that he was citing, but...
	Let me see if I can ask my question again.
	Sure.
	Objection, Judge.
	She wasn't finished answering his question.
	I think she was.
	You knew I was going to ask you about Zero Hedge, yes or no?
	About the company Zero Hedge?
	About the website?
	How it operates?
	Let me ask you again.
	Objection.
	You knew I was going to ask about a zero hedge.
	One second, please.
	I'll drive.
	I didn't scan.
	You knew I was going to ask about a zero hedge yesterday.
	I knew you were going to ask me about these articles, yes.
	There's one article, yes.
	Zero Hedge is a source that InfoWars will routinely use, yes, but I don't know much about the website Zero Hedge.
	Let me just see if I can ask you my question again.
	I can tell that this might be difficult.
	Objection.
	Strike.
	I'll strike that.
	Listen to the question.
	And answer the question that's asked, not the question that you want to answer.
	Answer the question that's asked.
	Did I know that you were going to ask me about Zero Hedge?
	I didn't think that I would have to answer questions about the website Zero Hedge, so no.
	So Free Speech Systems came in here today knowing that I was going to ask about this video, knowing that It relied upon a Zero Hedge article for the claim that Neil Hessling was lying, and you don't know anything about it, about Zero Hedge.
	I'll renew my objection to free speech.
	There's a corporate rep here.
	Free speech is here that's different.
	Objection, relevance, speculation.
	I think I will sustain the objection if we can move on.
	You know that the author of the article That Free Speech Systems was relying on was anonymous, correct?
	For this article, yes.
	And you know that the videos that Mr. Schroeder showed in this of the medical examiner, Dr. Wayne Carver, Yes.
	And it was cut off for the purpose of lying to the audience about whether or not parents were allowed to come into contact with their children, correct?
	I can't testify as to the reason why it was cut off.
	Okay, so free speech systems here today to testify about this video that showed a video of Dr. Carver cut off cannot tell this jury why it was cut off.
	Same objection, Judge.
	Speculation.
	I don't know why because I can't say...
	That was a yes or no question.
	And my answer is I don't know.
	The answer is you can't tell this jury why it was cut off, correct?
	That's correct, yes.
	He also showed a video at the end of another couple, correct?
	A couple that lost their child with Sandy Hook.
	Yes.
	That video was cut off before it ended, correct?
	It was cut off, yes.
	Why was it cut off?
	Same answer, I don't know.
	Free speech systems doesn't The medical examiner's
	statement, if it had been allowed to continue, would have confirmed that after the children were identified, the parents were allowed to see their children.
	Do you know that?
	Yes, I know that there is a longer piece of that interview.
	And that that's what it shows?
	Yes.
	But Free Speech Systems chose to cut the video off there, correct?
	it was cut off yes no one sure said I guess we're not gonna hear any explanation for mr. Hessler on this right
	I don't know if he said it like that, but he said maybe we have clarification from Mr. Heslin and or Megyn Kelly.
	I think that's what he said.
	And Free Speech Systems chose to run this video to retaliate against Mr. Heslin for having cooperated in Megyn Kelly.
	Same objection stand here.
	I can't testify as to why he ran it.
	I know Owen was deposed on this issue.
	Excuse me, so you don't know?
	If your question was, if it was retaliatory, no, I can't say whether it was retaliatory.
	You met with Alex Jones, correct?
	I did.
	You met with Owen Schroyer, correct?
	I don't think I was able to speak to Owen while I was there.
	I don't recall speaking with Owen.
	I read his deposition.
	How many on-air hosts does Free Speech Systems have?
	We have Mr. Knight, we have Mr. Dew, we have Mr. Schroyer, we have Mr. Jackson at one point.
	David Knight was fired two years ago, wasn't he?
	Right.
	I mean, during the time.
	Honestly, right now.
	Oh.
	Honestly, I'm not sure right now.
	But he doesn't work there now, Mr. Knight.
	So, how many on-air hosts does Three or four?
	Is that a guess?
	I'm not sure.
	Three or four.
	So Free Speech Systems, coming here to testify, can't tell this jury how many on-air hosts it has.
	The objection is to the form.
	Overruled.
	Three or four.
	Okay, who are they?
	Mr. Dew, obviously Alex, Owen's still there, and maybe one other.
	Just pause.
	Mr. Dew no longer works for free speech systems, does he?
	I don't think he works there currently, but he was...
	Excuse me, did you have an objection?
	She's not finished.
	I think she was finished.
	I don't know.
	I think she was finished.
	I wasn't finished.
	Okay.
	Well, we'll move on to the next question.
	But I think what you're doing is not answering the question.
	Oh, okay.
	I'm trying to answer his question.
	When I was there and I interviewed...
	I just want to please understand whether you can tell this jury how many on-air Then you said, I'm not sure.
	Then you went back to three or four.
	I asked you to name them.
	You said Alex.
	You said Rob Du.
	Do you agree with me Rob Du is not employed by free speech systems right now?
	Yes or no?
	Yes.
	Okay.
	So Rob Du is not an honor host, right?
	Objection.
	That's argumentative that he made.
	Overruled.
	Right?
	Presently?
	Yes.
	No.
	Okay.
	So you got Alex.
	You got Owen, right?
	Right.
	Who else?
	I'm not sure.
	People come and go a lot, so I'm honestly not sure as I sit here.
	So the only on-air hosts that you're sure about are Owen Schroer and Alex Jones, correct?
	Those are the ones I'm sure about, yes.
	Okay.
	And you knew that you were going to be asked about this video with Owen Schroyer, correct?
	Yes.
	There are only two on-air hosts that you know of, right?
	Presently, yes.
	And you decided not to speak to one of them, right?
	It's not that I didn't decide not to speak to him.
	It just wasn't available to happen for whatever reason.
	I can't recall.
	You testified on the first day here, man, that you have an independent duty.
	When you're coming here to testify under oath before this jury to find out what you need to find out to speak on behalf of the company, correct?
	Yes.
	You were given Owen Schroeder's phone number, weren't you?
	Yes, I believe I had his phone number.
	Did you call him?
	I did not call him, no.
	Okay.
	Your call broadcast on October 26, 2017.
	I'm going to bring up the chart for Ms. Paz, please.
	Thank you.
	What was the date?
	October 26th.
	Okay.
	Yes, I see it.
	Okay.
	It's another video in which Mr. Jones talks about Sandy Hook, right?
	Can I have it back up?
	I'm sorry.
	The title is JFK assassination documents to drop tonight.
	Full show.
	But I do believe he's mentioned Sandy Hook in that broadcast.
	Let's play clip for you.
	Actually, Your Honor, we offer 43A, please.
	It's not yet in evidence.
	It's a full clip.
	Oh, okay.
	Got to get better at that.
	Sorry, Attorney Ferraro.
	That's why we have Mr. Farrar here.
	Gerald Salenzi is going to be hosting the third hour today, and then we're going to have Anthony Cooney in the fourth hour.
	I was thinking, you know what?
	Just let him have the hour.
	I want to be here, but I'll just interrupt the whole time, so he'll be here.
	I'm going to get to some of your calls, and then come up in a few minutes.
	We'll get to a breakdown with Salenzi on what he's going to be covering in the next hour.
	Top trends forecaster.
	But look at this article that was on Infowars.com a few days ago.
	I read, I made the cover, and then I heard Leanne McAdoo during the break.
	A lot of our radio ads aren't radio ads.
	They're just one-minute little information news pieces.
	It's something we do.
	We just change things up.
	And I've forgotten in the documents, the CIA visited Lanza and reportedly recruited him about a year before the shooting.
	I mean, they bulldozed the house to get rid of it.
	I don't know what really happened with Sandy Hook.
	We looked at all sides.
	We played devil's advocate from both sides.
	But, I mean, it's just phony.
	It's a $3 bill with the CNN doing fake newscasts, blue screens.
	I mean, Nancy Grace got caught doing it.
	Anderson Cooper.
	I mean, that is just crazy.
	That's the kind of stuff that I read on Infowars.com that I don't even get to.
	Phony is a $3 bill.
	We've heard that before, right?
	He's said that quite a few times.
	And the records, the records that you referenced that the CIA had went to Adam Linentz's house, what records are you talking about there?
	Jackson reads speculation, contents of another mind.
	I don't know, he doesn't say.
	He doesn't say there, but he must have said to you when you interviewed him, right?
	He did not say that when I interviewed him.
	No And that was October of 2017 Yeah Yes, I think that's the date.
	Nearly five years after the shooting.
	He's still going at it, isn't he?
	This is almost five years later, yes.
	Now, Ms. Paz, you can take that down.
	Thank you.
	Right.
	And it produced something, yes?
	Right.
	There were a number of videos that the plaintiffs had to find on their own, correct?
	I believe that's right.
	Including a whole number of videos that Infowars did produce to us, correct?
	I'm sure that's accurate, yes.
	And as we've gone over before, Infowars has no idea how many videos and articles it published concerning Mr. Jones' lies about San Diego, correct?
	Do I know whether there is a specific number?
	Is that the question?
	No.
	Okay.
	The question was, you testified earlier that InfoWars has no idea how many videos or articles it published about Mr. Jones's lies about Sandy Cook.
	You testified to that, correct?
	Right.
	Thank you.
	But one of the things that Free Speech Systems maintains are radio logs, correct?
	You mean like show logs?
	The logs of the shows?
	Radio logs.
	That's what they do.
	They were produced as radio logs.
	Okay.
	Yes.
	And radio logs are basically outlines of the show.
	Yes?
	Right.
	It's kind of like minutes for the show.
	What is spoken about at what time.
	It makes it easier to find things later.
	It doesn't really give you the substance, but it gives you the topics.
	Correct.
	And InfoWars doesn't have radiologs for all the years, but it had some.
	Yes?
	Right.
	I don't think they had started making those until later, so they didn't always make those.
	Why don't we pull up Exhibit 50, and let me just confirm the transfer of that.
	That's already in.
	50 is an explosive.
	It is.
	And you know, have you seen this before?
	Lord.
	I have not seen a summary chart.
	I'll represent to you that this has been admitted as a chart of all Sandy Hook related broadcasts as described in radio logs for which there are no videos.
	So all of the videos that we've seen about Sandy Hook, they're not on this.
	Okay.
	This is a summary chart just for radio logs showing that Sandy Hook was talked about, for which no videos have been produced.
	Okay?
	Okay.
	Let's go to the first page.
	The first date there, what do you see, Ms. Paz?
	April 8, 2013.
	Let's just scroll through.
	Let's go.
	What's the last date there? - Okay.
	October 4th, 2021. About eight years?
	After Sandy Hook?
	Is that the question?
	No, no.
	These broadcasts about Sandy Hook cover about eight years, do they not?
	From 2013 to 2021. Okay.
	And if the jury wanted to see any of these videos, they can't because InfoWars didn't produce them, correct?
	Well, I can't say whether we have them or not, but they were not produced.
	Whether we have them is different, but...
	Well, if you have them, they should have been produced, right?
	I can't say that we have them, but they have not been produced, correct?
	I want to pull up Exhibit 2016, please.
	216, I'm sorry.
	That is a full exhibit.
	Agreed.
	If you recall, Ms. Positive, we've looked at this exhibit before.
	This is the media kit for 2014, right?
	Yes, I remember.
	And this is the one with the language that neither one of us could understand.
	Oh, yes.
	Let's go down.
	I think so.
	Right.
	But there is a part here that I did want to look at here.
	You see kings of their domains down here, right?
	And then I want to look at that topping the charts section here.
	All right.
	Now we looked at this a little bit before.
	Yep.
	And the point of this media kit is to show potential advertisers just how dominant information Right, this is why you should want to advertise here.
	Right, because Infowars and PrisonPlanet.com are significantly bigger and more popular than the other websites listed, correct?
	Right.
	And the third website listed is GlennBeck.com, right?
	Judge Ashton answered, we did this yesterday.
	That's what it says.
	And GlennBeck...
	Is also a media personality, right?
	I believe so, yes.
	Quite conservative, correct?
	I don't know a lot about him, but I believe he is a conservative commentator.
	Okay.
	Similar to Rush Limbaugh.
	Similar to Rush Limbaugh, correct?
	Correct.
	Rush Limbaugh at one time was a very popular and widely listened to radio host, correct?
	Right.
	I don't know if he's still on the air.
	He might still be on the air.
	Also very conservative, yes?
	Sure.
	Both men considered fairly controversial and provocative, yes?
	I mean, I don't know a lot about them, as I said, so.
	Okay.
	And as far as Free Speech Systems knows, neither one of them said a word about Sandy Hook, correct?
	I don't know the answer to that.
	I don't know if they've ever spoken about Sandy Hook.
	I don't know.
	Okay, so as you see here right now, Free Speech Systems has no basis to say whether or not they've ever said a word about Sandy Hook, correct?
	No, I don't know anything about their shows.
	What about Newsmax?
	Do you understand Newsmax via Newsmax.com is a website and Newsmax itself is a news company?
	Yes.
	A news company that's considered fairly conservative.
	Yes.
	Do you have any idea whether Newsmax has ever said anything about St. Joe?
	I don't know.
	I don't know anything about Newsmax.
	I can get out of that.
	Now, let's go to...
	I want to go back to Dan Badandi.
	Okay.
	Now, Dan Badandi is the gentleman who was chasing down and harassing the lawyer for the town of Newtown and the chief of police for the town of Newtown yesterday, right?
	You saw that video?
	Yes.
	This is the gentleman who the jury heard was described laughingly by Mr. Jones as the Kraken, correct?
	Correct.
	When we send Dan Badandi on a mission, we say release the Kraken.
	He has said that, yes.
	And after Mr. Badani sent that footage into InfoWars, they had him on for an interview, correct?
	After, oh yes, they did, correct.
	They had him on to talk about what he had done on the sidewalk there, right?
	They did, yes.
	All right.
	One moment, Your Honor.
	You've reviewed a video in the past called Fight for Freedom of Information at Sandy Hook.
	Bye.
	Yes, I believe so.
	And this is an interview that Rob Du, then employed by InfoWars, did with Dan Benandi about his coverage of the FOIA hearing?
	Yes.
	This is going to be 478, Your Honor.
	That is going to have a full exhibit, Your Honor.
	Is it late addition?
	May I speak to attorney management?
	Certainly.
	Thank you.
	I don't know that I want to necessarily agree with that issue.
	I didn't see the pleading last night that it was in there.
	You know, I mean, I didn't see any, the thing in that, if you file something in court.
	Do you want to recess so you can watch it?
	No.
	I'm happy to recess.
	It's a long video.
	I don't know if it's going to be serious.
	OK.
	I don't want to tell you that I get mine.
	I don't think there are two points on the exhibits, four, some, three, and four that I can't read.
	And now this memorial about what they may have.
	I don't think there's any additional things.
	This is it for the place.
	OK.
	I won't-- I'll withdraw this.
	Do you want to put your desk on for him to sit?
	No.
	I don't mean it.
	I know what it is.
	I'm just more concerned about the tip of the iceberg.
	Got you.
	so no objection?
	Correct.
	All right, well, what's the best?
	We knew that.
	Ms. Posner, do you remember when I was showing you the Glenn Beck and the Rush Limbaugh and the Newsmax, right?
	Yep.
	They never said that Sandy Hook was a hoax, did they?
	I'm sorry?
	They never said Sandy Hook was a hoax.
	I don't know if they did or didn't.
	I don't know anything about them.
	They never said it was fake?
	I don't know.
	They never said it was synthetic?
	I don't know.
	They never said nobody died there, did they?
	I don't know.
	They never called these families actors, did they?
	I don't know.
	Why don't we pull up?
	This is July 8, 2015.
	We're going to play that clip.
	Okay, clip.
	For the second hearing, you actually tried to question Chief Kehoe.
	He, I guess, recently resigned, like maybe announced it the day before.
	What was your impression of his body language and how he wanted really nothing to do with it?
	He seemed to be afraid of it at that point.
	Oh, yeah.
	I mean, from the first hearing to the second hearing, I mean, he was just quick answers.
	He looked like he didn't want to be there.
	He wanted to get the hell out of there.
	And of course, a resignation comes in the night before the hearing.
	And that's the first question I hit him with.
	Is it about him to resign?
	Why are you resigning?
	Then, of course, I called him all the way out and tried to get answers on him.
	Of course, the state police actually grabbed him to put him in the state police car to escort him to his car.
	Yeah, the lawyer seems to have a vested interest in keeping whatever narrative they want to push going.
	We're running with charities.
	He rides his bike for these charities.
	He founded one of them, Team 26 from Newtown.
	How has he been?
	Have you, did you try to interact with him at all during these hearings?
	Yeah, so when I went after Ronnie Frank, I mean, I was just asking him questions, just regular questions.
	He did not want to answer.
	So he's looking at my question, trying to figure out who I am.
	I told him, hey, we're here to expose corruption.
	And this guy fits Yeah,
	and he seems to have more of an interest in stalling the proceedings and objecting So they had Mr. Vanondi back on, right?
	Yes.
	They obviously seen the footage.
	They aired it, correct?
	Yes, they were airing pieces of those footage.
	They had him on to call the town lawyer.
	Free Speech Systems, the company you represent, had him on to call the lawyer for the town of Newtown, somebody representing corruption, correct?
	That's what he says.
	Somebody had a central casting, correct?
	That's what he said.
	Just another actor, right?
	I believe that's what he said.
	Now, when InfoWars was sued, Alex Jones got very nervous about his relationship with Dan I don't know.
	Now, you've never read Alex Jones' depositions that he gave in Connecticut, did you?
	Right, I think we went over this yesterday.
	But you did read a deposition that he gave in Texas, correct?
	I did.
	And you read Alex Jones' false testimony that the last thing Dan Badandi ever did for InfoWars was cover the Boston Marathon bombing in April of 2013, correct?
	Jackson, the form argumentative assumes a fact, not an evidence.
	Did he testify that Dan Badandi didn't work with InfoWars after the Boston bombing?
	Let me ask you my question again.
	Okay.
	Mr. Jones testified, falsely, that the last thing Dan Badandi ever did for InfoWars was cover the Boston Marathon bombing, correct?
	I don't recall the testimony.
	If you'd like to show it to me, I'd be happy to look at it.
	Let me see if I can get you to recall just the basic fact.
	You do know that Alex Jones testified in Texas?
	Yes.
	You know that he testified about Dan Badandi?
	I do.
	You know that he testified about the timing of when Dan Badandi was last associated with InfoWars, correct?
	I believe he did, yes.
	And you know that he said that the last time that Dan Badandi was associated with InfoWars was the Boston Marathon bombing, correct?
	I don't recall.
	Okay, so that's the one thing you don't recall about.
	I just don't recall the specific testimony.
	I apologize.
	We'll bring that up for you a little bit later.
	Sure.
	You know, though, that that's not true, correct?
	That he worked for InfoWars after the Boston bombing?
	Right.
	Oh, right.
	Well, this is after the Boston bombing.
	Correct.
	He worked for InfoWars into 2016, correct?
	um i'm not sure the exact date that they severed the connection but um he was a contractor after that so yes you don't know when the last time he actually did anything for enforce was i can't recall the exact date no it was 2016 though so that's somewhere thereabouts yes right right because he was thrown out of a political rally and uh and finally they decided not to use him anymore right yes there was an issue and he was asked to return all the gear and stuff but After
	Alex Jones was deposed in Texas, you're aware that Dan Bedondi went on a podcast and said that Alex Jones had lied about what he did for it.
	Um, if he went on his own podcast?
	He went on a podcast and said that Alex Jones had lied about his relationship with Dan Badandi, right?
	I have not heard any of Mr. Badandi's podcasts.
	And you know, well, but you know that as Free Speech System's corporate representative, don't you?
	Objection, form, foundation.
	Corporations don't know things, Judge.
	Your Honor, the speaking objection should stop it.
	Thank you.
	Based on your investigation.
	I have not reviewed any of his podcasts, so I don't know that.
	No, you haven't reviewed his podcast, but you've spoken to people at InfoWars who know that Dan Badani went on a podcast and said that Alex Jones had lied about their relationship.
	I don't think I had any conversations with anybody about Mr. Badani's podcast.
	And that after Alex Jones became aware that Dan Badani was concerned, Alex Jones called him, correct?
	I don't know.
	Have you reviewed Mr. Badani's deposition?
	I don't know.
	I don't recall reviewing his deposition.
	I don't recall.
	Sorry.
	Are you aware that Alex Jones called Dan Benandi in the presence of a lawyer to speak with him?
	I am not aware of that, no.
	Are you aware that Alex Jones apologized to Dan Badani and invited him down to Texas for dinner?
	No.
	And put him on the phone with a lawyer?
	No.
	Do you know who that lawyer was?
	no are you aware that when damn bennati received his subpoena he sent some text messages to rob duke Did Mr. Badani text Mr. Dew?
	Yes.
	I'm not aware of text messages.
	I haven't seen them.
	Are you aware that Rob Dew texted him back?
	No.
	So you haven't seen those text messages?
	No.
	Do you know what happened to him?
	No.
	But one can understand why Alex Jones wouldn't want his jury to know that Dan Badani was associated with him, right?
	argumentative speculative let's go to exhibit 182 remember Steve Kachinic Yes.
	Steve Pachenik is the gentleman that Alex Jones invited on in the spring of 2013, so a few months after Sandy Hook, to say that the parents were crisis actors and the children were actors.
	Yes?
	That's what he said on the video, yes.
	Okay.
	And before we pull it up, I just want to make sure it's a full exhibit.
	It is a full exhibit.
	Agreed.
	Okay.
	Exhibit 182 has been admitted as a text message, Ms. Paz, between Alex Jones and his producer, Nico Acosta.
	And I want you to look at this first part here.
	This is a text message from Alex to Nico.
	Bullets flew for four minutes as armed deputy waited outside.
	It's a link, right?
	Yes, that's what it looks like.
	This is, by the way, February 23rd, 2018, right?
	That's what it says on the desk.
	Five years after Steve Pachenik was on the show claiming that the parents and the children were actors, yes?
	Five years after, Mr. Pachenik was on, yes.
	Okay.
	And who's coming on, according to Nico, on February...
	Just the blue ones, please.
	That's fine.
	Who's coming on, according to Nico, on February 23rd at 2018?
	It says, Syrian girl at noon, doctor.
	DR period, I assume, means doctor.
	Pachenik at 1 p.m.
	and Doug Hagman doing fourth hour.
	Okay.
	And so, in 2018, Alex Jones was still having Steve Pechenek on the show, right?
	That's what it looks like.
	He was on before that, too.
	Had you ever seen his text message before I just showed it to you?
	No.
	Have you looked at any of Alex Jones' text messages?
	I have not seen any of Alex's text messages.
	Why not?
	I don't know.
	Did you ask for that?
	I don't think I specifically asked for text messages, no.
	What did you specifically ask for, other than his deposition and your deposition?
	I asked for all of the depositions.
	I did ask for access to all of the Connecticut Discovery.
	I know that there was an issue getting access to the Connecticut Discovery, but I did ask for it.
	Okay, so let's go one by one.
	You asked for a copy of all depositions, right?
	Right.
	Okay, you just testified you don't know if you read Tampa Dona's, right?
	Yeah, I don't know.
	I'm not sure.
	Did you know whether it was given to you?
	I don't recall.
	It might have been amongst the Texas material, so I did have access to a drop box of Texas.
	Okay, so then it may not have been in that material.
	I don't know.
	I don't recall.
	Okay.
	So as you sit here right now, you asked for the Dan McNoddy deposition, but you have no idea whether you received it.
	Well, I asked for all of the depositions, so that wouldn't necessarily include that.
	And you said you asked for all the Connecticut discovery material.
	That means the material that InfoWars produced to our plaintiffs here in Connecticut, correct?
	Correct.
	And when you were deposed by me earlier this spring, you couldn't say whether you reviewed any of it, correct?
	The Connecticut discovery?
	Right.
	Right, correct.
	There was an issue with getting the access to the Connecticut discovery.
	But, the fact of the matter is, when you showed up for your deposition, you couldn't say that you'd reviewed any of the discovery that had been produced in Connecticut, correct?
	Correct.
	So, we saw Kuchenich, Hibidani.
	Let's pull up Exhibit 191, please.
	This is already in evidence.
	You remember I was asking you yesterday...
	That's not actually...
	Oh!
	I thought we offered it yesterday.
	Just let me check one second.
	I want to make sure I'm not okay.
	Sorry, I had the wrong one.
	My mistake.
	204. This should be in the heavens.
	204 is the full exhibit.
	Agree on 204. All right.
	Now, you remember I was asking you yesterday when Rob Du had most recently communicated with Wolfgang Halvig, right?
	Yes, I remember we talked about this.
	All right.
	So if we go down here, this is November 17, 2020, right?
	That's what it says from Rob at his personal email.
	This is two years ago.
	Rob using his personal email.
	You know Rob Dew was an InfoWars employee at this time, correct?
	At that time, yes.
	Yes.
	Can you read it, please?
	Hey, Wolfgang.
	Great talking with you today.
	Please don't mention anything about the federal court move.
	We do not...
	We do not many to tip anyone off.
	Inaccurate phrasing there.
	Also, please send me the three names from UDEPO list and any including information.
	Thanks, Rob.
	Right.
	You think you probably meant to say we do not want to tip anyone off.
	We do not.
	Right.
	He probably said many instead of want.
	Now, you've never reviewed this email, I take it.
	I've never seen this, right?
	Okay.
	But you do know that there was a point while this lawsuit was pending where Infowars tried to remove the case to federal court.
	Do you know that?
	Yes.
	Okay.
	And it was right around this time, wasn't it?
	I'm not sure the time period.
	And what Mr. Halbig, I'm sorry, what Rob Dew, one of Mr. Jones' top employees, is doing is sharing information about this lawsuit that he doesn't want Wolfgang to share with anybody else, correct?
	He's saying please don't mention anything about federal courts.
	So it sounds like they had talked about federal court.
	Right.
	In whatever conversation he's referencing.
	Right.
	And then he's asking him to send in the three names from Halbig's depot list, right?
	Right.
	That might have been referencing the list of people that Mr. Halbig wanted to depose.
	And this is two years into this case, correct?
	Right.
	This case was filed in 2018. When did Mr. do next talk to Mr. Halbig?
	I don't know.
	I haven't seen this email, so I don't know if there's any after this.
	Well, let's go up and see.
	So Wolfgang responds, right?
	That's what it looks like, yes.
	So let's just chart this out real nice.
	Let's go down to the bottom.
	Great talking with you today, right?
	So there's a phone call, yes?
	It doesn't say how they spoke, it just says that they spoke.
	Might have been FaceTime, might have been Skype, right?
	Might have been text, it might have been email, it might have been...
	I don't know.
	He said great talking to you, didn't he?
	I don't know what that means.
	It could mean a lot of things, so it just means to me that they communicated, I don't know how.
	Okay.
	But anyway, he follows up with an email, and then Wolfgang emails him back, right?
	That's what it looks like the next day.
	And he's giving him suggestions for who Infowars, the company you represent, should depose in this case, isn't it?
	Seems to be in response to his request to send me your list of people you want to depose.
	So these are the people that Mr. Halberg would like to depose.
	And he says, have Alex demand under the CT Freedom of Information public record request a copy of the Connecticut State Trooper 1 helicopter radio transmission.
	You see that?
	I do see that, yes.
	Did Alex do that?
	Do you know?
	I'm unaware of any FOI requests that Alex has filed.
	Okay.
	Okay.
	exhibit before we pull it up.
	I don't believe this is yet in evidence.
	Why don't we pull it up just for Ms. Paz, please? - Number, please.
	One onion.
	Ms. Paz, you testified yesterday that Paul Watson Was the editor of InfoWars website back in 2013, correct?
	Yes, I believe that's what he did at that time.
	And he's still associated with InfoWars, is he not?
	Yes.
	And the text message that you see here is a text message that Paul Watson sent to Alex Jones in April of 2020, correct?
	No objection to its admission in full check.
	Yes, April 2020. That's what it says.
	Have you seen this text message before?
	No.
	I'll offer it, Your Honor.
	No objection.
	That was 198, Your Honor.
	Thank you.
	Let's pull up just a first...
	There you go.
	So this is a text message from Paul Watson on April 6, 2020. He sends Alex Jones a screenshot of an article on Infowars.com, right?
	That's what it looks like.
	Right.
	It's hard to see.
	And the headline says, a little bit's cut off, but see if you'll Accept this.
	This is how it looks to you.
	Staged.
	Video shows hospital using dummies in ER for coronavirus footage.
	Right?
	That's what it looks like.
	It is a little bit cut off, but that's what it looks like.
	Okay.
	And obviously in April, COVID had just hit within the last couple of months, right?
	Right.
	And what Alex Jones was telling his audience was, number one, the globalists had released COVID upon them to kill them.
	Yes?
	Are you asking me about the coronavirus footage?
	I'm asking you about, generally, the claim that Infowars put out that coronavirus was intentionally released by the United States government to kill people.
	I haven't reviewed anything related to COVID coverage.
	So, I mean, I'm generally aware that he covered the COVID-19 pandemic.
	Did I just describe what he said accurately or no?
	You don't know?
	I just don't know because I haven't reviewed the COVID coverage.
	That's fine.
	In any event, Paul Watson sends Alex Jones this text message and what does it say?
	This is a video of a medical student training to intubate.
	Makes us look ridiculous, suggesting this means COVID is fake.
	Sandy Hook all over again.
	Go down to Mr. Jones' response.
	What does he say?
	He responds, I get it, and then he posts a few hours later a video on ban video, or he texts him and link to a ban video.
	Actually, I don't think it's a few hours later.
	If you look, ma'am, it's the next day, isn't it?
	Oh, yes, you're right.
	I'm sorry, it is the next day.
	This is a video of a medical student training to intubate.
	Makes us look ridiculous, suggesting this means COVID is fake.
	Sandy Hook all over again, and Mr. Jones says, I get it, right?
	That's what it says.
	Do you know that that article that Mr. Jones said he understood it was ridiculous remained on InfoWars' website for two years?
	I don't know anything about that article.
	Is it a good time for a break, Your Honor?
	I think so.
	Alright, so we'll take our 15-minute learning recess.
	Ron will collect your notebooks.
	You will, of course, continue to obey the rules of juror conduct and we will be back in session at 1145 promptly.
	Have a nice break.
	Before the jury returns, I've made my colleagues aware of this.
	And these proceedings are being televised, and apparently Wolfgang Holbeck is watching these, and he has left an unusual message on my client and my representative's phone.
	And I know he's been flooding the court with complaints of the feeling that he's being defamed in these proceedings.
	Attorney Pettis, when you say the court, I'm not aware of anything personally.
	The clerk has forwarded me Have you received any communications that you didn't mention?
	I think all we have received is what was forwarded to us by.
	Which I have not seen, because it has not been forwarded to me, and I don't need it forwarded to me.
	Thank you very much.
	Okay, so no room.
	Are we ready for the panel?
	Okay.
	Okay.
	Yeah.
	Okay.
	Okay. Okay. Okay. Okay. Okay. Okay.
	Okay.
	Welcome back.
	Hope everybody had a nice break.
	All right, the record will reflect that the entire panel has returned.
	Please be seated.
	Whenever you're by the attorney, that is.
	Thank you very much, Your Honor.
	Welcome back.
	We've kind of gone through the videos.
	We've gone through the summary chart videos of 2021. And really, I think it's fair to say that ever since 2012 and right up until the present day, InfoWars is aggressively trying to build its audience, correct?
	You mean over the last 10 years, is that the goal of the business?
	Sure, yes.
	That is the goal of free speech is to grow its viewership, expand, things like that.
	And I don't want to retread all of this, but the whole idea here is the more people putting their eyeballs on Infowars content, whether it be on social media or the website or anywhere else, the more people can get funneled to the store to buy stuff, right?
	Yes, that's the business model, essentially.
	Let's take a look at exhibit 183, not yet in evidence, so please just pull it up from this pod.
	And please let me know when you have it for you.
	Sure.
	Yes, I see it.
	Okay.
	And you see that this is an email regarding an affiliate one-sheet dated April 2nd, 2018. See that?
	Yes.
	Okay.
	And this affiliate one sheet relates to InfoWars audience numbers.
	Yes?
	Can I see the whole email, please?
	Thank you.
	Okay, yes, the radio audience numbers Through the radio affiliates, yes.
	And there's some other numbers on there as well, right?
	There's some...
	There's some...
	There's some YouTube information as well as some other things, yes.
	I'll offer it, Your Honor.
	Can I see the top of it, please?
	No objection, Judge.
	All right.
	I'll accept it.
	All right.
	So yeah.
	So this is an email between several InfoWars employees April 2, 2018, correct?
	That's what it looks like, yes.
	Who's Scott Bronson?
	I'm not sure.
	I didn't speak to Mr. Bronson.
	You don't know what position he has?
	I'm not sure, no.
	What about Mr. Castaneda?
	Do you know what position he has?
	Sam, no.
	John Hanson?
	No.
	Let's pull up the body of the email.
	Here we go.
	It says, Robert, here's the information we want to put on the affiliate one sheet we spoke about on Friday.
	Any questions, feel free to ask John or myself.
	The affiliate one sheet is the audience numbers Alex Jones sends to new radio stations to get them to carry his show.
	Yes.
	So it's a one-page information about the show to provide to other stations.
	Right.
	Right now, I think he's got more than 200 affiliates around the country, right?
	Right.
	I'm not sure the exact number, but it's something to that effect.
	It's about that?
	About, yes.
	Okay.
	And if we go down to item number two, market reach and stats, there it is.
	The 200-plus AM FM stations, right?
	That's what it says, yes.
	Six million daily listeners, yes?
	That's what it says, yes.
	Okay, and with respect to YouTube, 2.3 million subscribers.
	Yes.
	1.5 billion views, yes?
	Yes.
	And it says, Alex is the number one guest on the Joe Rogan podcast of all times, over 5.5 million views, yes?
	That's what it says, yes.
	Okay.
	And did you recall that when Bill Aldenburg testified, he testified that one of the reasons Alex Jones is so powerful is because he has these platforms.
	She wasn't in the room, she's testified.
	No, she wasn't.
	She watched clips, I think, Jeff.
	I'm not sure whether I watched that clip or not.
	You don't recall?
	I don't recall, yeah.
	All right.
	Sorry.
	That's okay.
	And then it goes from radio to YouTube to Infowars.com, and here it's providing some of those data points we saw from Google Analytics yesterday, right?
	11.2 million visits?
	Yes, I see that.
	Okay.
	3.5 million uniques, yes?
	3.4 million, yes.
	Thank you, I'm sorry.
	That's okay.
	25.7 million views, and this is all in the last 30 days from when this email was sent.
	That's what it says, yes.
	Okay.
	Yes.
	Then there's some audience demographics breakdown here.
	That's what it looks like.
	They break it down along gender lines, age lines, educational level, racial lines, and income, correct?
	Yes.
	Okay.
	Then you go down further.
	And Mr. Jones also, and I don't think we've mentioned this before, can be reached through satellite TV, right?
	That's what it says on here, yes.
	And you know that to be the case, right?
	I think it's on some channels there, yes.
	Okay.
	I'm good on the radio.
	Streaming audio and video, this is where he's talking about his podcasts, right?
	That's where he would have talked about podcasts, yes.
	Right, so like the Alex Jones show, The War Room, another way you could get it was because they would just take the show, turn it into a podcast, load it up on wherever you get your podcasts, as they say.
	Sure, right.
	We can get out of that here.
	Alright, thank you.
	Now I want to take you forward to, I believe, we wanted to do 180 to 190. Oh no, I'm sorry, 190. Not yet in evidence, why don't we just pull it up for I see it.
	This is an email from a gentleman named Tom Pappert, yes?
	Yes.
	He's an InfoWars employee?
	Yes.
	What does he do for them?
	I'm not sure what his title is.
	Do you know what his responsibilities are even though you don't know his title?
	He was involved with the marketing but as far as what he did for that I'm not sure.
	And you're getting that just from having read his sign-off there, his signature, right?
	Correct.
	Okay.
	And he's sending this out to Lisa at EverydayMedia.com.
	Yes?
	That's what it says, yes.
	All right.
	So my name is Tom Papert, and I work with InfoWars.
	I was referred by Dan Clayton Luce at HenryUSA.
	We would be a great fit for Henry, and I'm interested to see if we can find a way to start a relationship.
	What's Henry USA? Henry is a gun manufacturer.
	Okay.
	Would it be fair to say that what they're looking to do is to have Henry USA start advertising its products with InfoWars?
	That's what it sounds like from this email.
	Okay.
	And as a way to kind of induce that, he says the Alex Jones has 6 million daily radio listeners, about 900,000 online TV viewers, not including our over-the-air and cable affiliates, and receives about 45 to 50 million visitors per month.
	That's what I said, yes.
	Okay.
	And then he attaches a rate card and demographics.
	And this was in November of 2019, wasn't it?
	That's what the date says, yes.
	All right.
	And why don't we pull up exhibit number 41?
	I believe this isn't as full, but I just asked.
	It is a full exhibit.
	- All right, so why don't we pull up exhibit 471?
	- Oh, I'm sorry, I thought you said 41. - Oh, hold on. - 471?
	- Yes, sir. - That is not a full exhibit. - All right, I think this is agreed to as I mean, no objection.
	- I don't remember what it is, it wasn't on your reading list.
	Thank you, sir.
	No objection, Judge.
	All right.
	Now, this is an email from Gabriella Tolentino, Infowars employee.
	Yes?
	Yes, I see it.
	And she's sending this directly to Alex Jones, correct?
	Yes, that's what it looks like.
	AJ76 at alexjones.net, correct?
	Yes.
	And you know that that's the email address that he uses?
	I know that's his email address.
	Let's start to scroll through this.
	It says attach an updated version for IW. That's InfoWars Social Media, correct?
	Yes.
	As it stands today, Ms. Paz, InfoWars has a vast network of social media platforms it's on, correct?
	It's on many platforms, yes.
	Let's go to page two.
	Cover page there, InfoWars Social Media Reconnaissance Report, February 2021, right?
	I see it, yes.
	Okay, and if we go to the last sentence there of that paragraph, the following report details the results of current social media recon of InfoWars and Alex Jones 2021, right?
	That's what it says.
	All right, so let's just start scrolling through here.
	So here we have, these are all the different social media platforms that he's on, right?
	Yes.
	Okay, and all of the content that Free Speech Systems pushes out, just what we've been discussing during the time frame that we were previously focusing on, goes to all these social media platforms, right?
	Right, so I don't know when we would have set up these particular platforms.
	I don't know if it was around the same time period, so whenever the videos with Sandy Hooks started, but generally speaking, if we had the platforms, all of our content gets uploaded to all of the platforms.
	Right, and the idea there is you just want to reach as many people as possible.
	Correct.
	So it's Mines, Gab, MeWe, let's just keep scrolling through here.
	Telegram, Parler, VK, Subscribestar.
	We'll just scroll down so people can see.
	I'm not gonna make you count these all up, Ms. Paz, okay?
	PolitiChatter, Trumpbook, MAGAbook.
	Let's keep going.
	Just keep going.
	Hold on here.
	So now we're seeing some live stream platforms, right?
	Yes.
	Twitch, Vimeo, DLive, Trovo, et cetera?
	Right.
	And this is in addition to him streaming live to his own website, band.video?
	Correct.
	And infowars.com, yes?
	Correct.
	Okay, we'll keep going down.
	Text message alerts.
	Okay, so this is another way that Alex Jones reaches his audience.
	He'll send people who have given him his phone number text messages, right?
	Right.
	If they sign up to receive the messages, then there's a program that he can automatically send the text messages to subscribers.
	Similar to his daily email newsletter.
	Right.
	That we talked about earlier.
	Right.
	How many people have signed up to be contacted by text by Alex Jones?
	Sorry, I don't know the number.
	Okay.
	Let's keep going down.
	Here's his podcast, right?
	You can pick them up wherever.
	Right, that's where it's available.
	Okay, got it.
	Right.
	Okay.
	And then just all the links if you want to click, right?
	Right.
	Okay.
	And all of this audience growth has led to ever greater financial success for Owl & Stone, correct?
	Yes, I mean during this time period the sales have increased, so yes.
	And one of the ways that Alex Jones keeps track of, you can take that down, keeps track of just how well the sales have increased is by getting daily sales reports from Mr. Fruget in the past, correct?
	Right.
	He gets them daily, maybe not daily, but almost every day.
	He wants to see it every day.
	He does.
	And so when Tim Fruget, just remind everybody, Mr. Jones is a long time business director, was business director, he'd be sending him daily sales reports every day, right?
	Right.
	And he'd have sales over Infowarsstore.com, yes?
	Right.
	And like how many units were moving, meaning top selling supplements for that day.
	Right.
	Okay.
	So why don't we pull up Exhibit 195 and we'll go to page 25. I don't believe there's...
	I think these are already in.
	195 is a full exhibit.
	I'll represent to you, ma'am, that these are text messages between Tim Fouget and Alex Jones.
	And what I want to do is just pull up, if we could, Yeah, pull up just the bottom there with the date.
	There we go.
	Alright, so we see here on January 27th, 2020, Tim Fruget is sending Alex Jones a text message at 7.49pm.
	He says, we are at 205,000 right now.
	You understand that to be for the day, right?
	Correct.
	And just on Infowarsstore.com, right?
	He doesn't say where the numbers are from, but...
	I don't know by looking at this text message.
	And it says the newsletter is performing great right now, right?
	Yes.
	And what that means is they've sent out an email earlier in the day in which people could click on it and come to the store and he's saying that email is really generating a lot of revenue for us.
	Right.
	Okay.
	And he says hopefully it will continue through the evening, right?
	That's what it says, yes.
	Okay.
	And then he tells them 110,000 gross sales in food equates to almost 70,000 in pure profit.
	Right?
	That's what it says.
	And 2020 got better for Mr. Jones as it went on, correct?
	How do you mean?
	I mean those daily sales really started going up, didn't they?
	Oh, I don't recall.
	I would have to look at the numbers.
	Alright, well why don't we do that?
	Why don't we go to page 32. Tim Fruget, again, giving his daily reports here.
	The jury may remember this from opening, where in late February, Alex Jones reaches out at 7.02 a.m.
	in the morning on February 26th, right?
	See that?
	Okay, yes, I see it.
	Just wondering how money dollar we're.
	Yeah, and right before that he had said, I know it's early.
	Okay.
	But 7 a.m., he's reaching out.
	He wants to know what's going on, right?
	That's what it says, yes.
	And Tim Frugier says, we ended up about $810,000 yesterday, right?
	That's what it says.
	It's going to take me a bit to calculate what percentage of that was food.
	Obviously, percentage of food is important because we saw that profit margin, right?
	Right.
	I don't know if that's the reason why it's important or they were just trying to monitor whether it's something they wanted to continue, increase sale of, just monitor how it's doing.
	Exactly.
	Right.
	Because Alex Jones decides what sales he's going to run, right?
	Correct.
	What's working, right?
	Correct.
	He thinks about what he wants to talk about to figure out what's going to sell well, yes?
	Correct.
	And he goes, it's going to take me a bit to calculate what percentage of that was food, but it's looking like $650,000 to $700,000 in food sales.
	We are already over $100,000 today at $645,000 this morning.
	Crazy, right?
	I see it, yes.
	Alex Jones gives a thumbs up.
	He gives a praying emoji and a thumbs up.
	And then a ghost emoji.
	What's the ghost mean?
	It's just a ghost with a tongue sticking out his tongue.
	And an eye patch.
	I don't know if that's an eye patch, but it's just, I don't know.
	Just having fun.
	It's a cute emoji.
	And this actually, this kind of rate of revenue has continued to increase, even since 2020, correct?
	Did you actually, in fact, not an evidence?
	I think that the daily sales fluctuate a lot.
	So if you want to look at annual sales, I think that's a little bit more helpful, but sales in general have increased.
	But daily sales will fluctuate.
	Right.
	And just recently, is it fair to say that InfoWars is doing just about a million dollars a week in revenue?
	Well, I'm sorry.
	I can't recall the exact number.
	You mean presently?
	Yeah, presently.
	I don't know the number.
	I'm sorry.
	You don't?
	No.
	Okay.
	You're not aware whether Free Speech Systems has made any representations that it's doing about a million dollars a week?
	I don't know if I'm allowed to make reference to the other proceedings.
	Well, no.
	I'm not asking you about any other proceedings.
	I'm asking you whether you're aware that Free Speech Systems has represented that it's doing about a million dollars of reference a week.
	I don't know what the dollar figure is.
	I know that there are representations that are being made as far as the income that the company makes.
	What the number is, right?
	I don't know what the number is.
	Okay.
	And I think a lot of what you said is that free speech systems Alex Jones decides what's going to make him some money and covers topics in order to make that happen, right?
	Objection, compound...
	I'll withdraw it.
	Alex Jones talks about things in the news that he thinks are going to drive revenue, yes?
	He talks about things in the news that he finds interesting.
	I'm going to ask you to just answer the question.
	She's answering?
	She's not answering the question that was asked.
	Do you need to please that?
	No, I don't.
	Is that the sole reason why he says things that he says?
	No, but is that a reason?
	Sure.
	You know what question is.
	Objection, badgering.
	So is he saying things for revenue?
	Ma'am, I think the judge wants to have a word.
	Don't speak when I'm speaking.
	Sure.
	Do you need the question for your back?
	You need to answer the question that was asked, not the question you want to answer.
	Would you like the question for your back?
	I can have that done because you've made several efforts and you're not answering the question that was asked.
	If Attorney Maddie could just repeat it.
	No, no, it's kind of what I said.
	Do you have the question or do you I believe, can I ask what the question was, if it was, did he do it?
	We'll have the question feedback.
	Sure.
	Take your time.
	You know what, Your Honor, I think I can do it a little bit faster, because I think we've covered this.
	Okay.
	Just pause.
	Just wait till you get back on the mic.
	I'll withdraw that.
	Thank you.
	Do you remember?
	I think it was Tuesday.
	I forget which day it was.
	Maybe Wednesday.
	We talked about how Alex Jones covers things like increased radiation in the news so he can sell iodine.
	Remember we talked about that?
	Sure.
	Okay.
	He talks about food shortages being inflicted on the world so he can sell storable food, right?
	Compound, Judge?
	Oh.
	Does he talk about food shortages and then plug an ad for food?
	Yes.
	He talks about chemical pollutants being used to decrease human libido and depopulate the world, and so he can sell super-male and super-female.
	Yes.
	And he's been talking about this trial this week Because he thinks that's going to make him money, correct?
	I don't think that that's the reason, but...
	You've been watching the show this week?
	Have I been watching the show?
	No, I don't generally watch the show.
	Okay, so generally though, what Mr. Jones does is he's trying to attract audience so that he can send them to the store, right?
	That's the business model we've been talking about, yes.
	And the way he's been attracting audience this week, while we all have been here, is by talking about this trial, correct?
	Attraction, facts not in evidence, she doesn't know.
	Sustained.
	Okay.
	Well, let me show Council exhibit 479. May I approach your honor?
	You may.
	See that?
	I do.
	Do you see Mr. Jones' logo for band dot video in the corner?
	I do.
	Do you see Bill Altenberg depicted in that picture?
	I do.
	Do you see lettering placed in the lower left-hand corner of the screen that says, Alex Jones, Kangaroo Court, watch day one?
	I see that, yes.
	I'd offer it.
	It's not self-authenticating.
	Objections.
	Ms. Paz, you recognize this to in fact be a screen grab of footage that Mr. Jones played earlier this week, correct?
	She said she hadn't seen it, Judge.
	I've never seen this, and I haven't seen the show, and I haven't reviewed it, so I can't say what this is.
	Okay.
	Mr. Jones and Free Speech Systems, as far as you know, is the only company that controls the band.video platform, correct?
	As far as I'm aware.
	And you see that logo right on there?
	In the upper right-hand corner?
	Yes, ma'am.
	I see it.
	Okay.
	I'd offer it your honor.
	Judge, you're not self-authenticating.
	Sustained.
	Has Alex Jones been calling this trial and came to report this week?
	She's speaking for Free Speech Systems and she can have that information without having watched it.
	I don't know who she's spoken with or what she's done by way of her investigation.
	I haven't spoken to anybody this week, so I don't know.
	Has Infowars been calling this trial a kangaroo court?
	I don't know.
	Let me show you 477. This is 477 ID.
	What do you see there?
	What do you see there?
	Do you want me to describe it?
	I do.
	I would object to describing a document, not an evidence.
	Let me start this way.
	Look at the very bottom of that picture.
	Do you see a website address there?
	I see a website address, yes.
	What's the website address?
	www.infowars.com slash post slash watch dash highlights dash from dash the dash alex dash jones dash handy hook dash kangaroo dash court hearings and you recognize that to be a website It looks like it's part of that website.
	Right.
	And it depicts...
	Judge Bellis, does it not?
	Objection.
	The document is not an evidence.
	No foundation to discuss it.
	You could ask for what it depicts.
	What does it depict?
	It looks like that's what it depicts.
	Well, you're sitting right next to Judge Bellis.
	That's what it looks like.
	Okay.
	And that was published on InfoWars page according to that URL address, correct?
	Objection.
	It's not self-authenticating, Judge.
	I don't know, aside from looking at the URL. Okay.
	Well, your free speech system's ready.
	You know that that's an InfoWars URL, right?
	It looks like a URL. I don't know anything about this.
	I haven't asked anybody and I haven't talked to anybody about it.
	But the words on the bottom that you just read, if someone were to click on that link, it would take them in, correct?
	I don't know.
	I haven't clicked on the link.
	Yeah.
	Does it say www.infowars.com?
	I read it.
	Does it say www.infowars.com?
	That's what it says.
	Okay.
	You know that's your website address, pre-speech system, right?
	That is the website address, yes.
	If somebody clicks on it, that's where they're going to go, right?
	If they go to infowars.com, yes.
	Okay.
	And then infowars.com has a number of subpages, correct?
	Yes.
	It's got a videos page, yes.
	Yes.
	It's got a news page, right?
	Yes.
	It's got a video page, right?
	Yes.
	Okay.
	And if you go to infowars.com and any of those subpages that are listed out further in the URL, it's going to take you to an infowars.com webpage, correct?
	Yes, but if you're asking me, is this there?
	I don't know because I haven't looked for it.
	I'd offer it, Your Honor.
	No foundation.
	world let's publish this Is it worth taking this trial seriously?
	I'm sorry, I don't know how to answer that.
	Me as free speech, I'm taking it seriously.
	I've been here for three days, so yes.
	You're personally, Ms. Paz, you're taking it seriously.
	No.
	Is the company that you represent that Alice Jones has 100% ownership and control over, is it taking it seriously?
	Objection Foundation.
	Hold.
	Free speech is taking it seriously, as I've sat here for three days, so yes.
	Well, you had to be here, right?
	They paid you $37,000 to be here, yes?
	You were under subpoena to be here, weren't you?
	I'm under subpoena.
	Okay.
	If you didn't show up here, you would have been in quite a bit of trouble, correct?
	Sure.
	Okay.
	So you have to be here, right?
	I'm asking about info orders.
	On scale 1 to 10, how seriously is InfoWars taking this trial?
	Check your digits.
	I don't know how to answer that.
	Oh, you got ten options.
	One through ten.
	Ten.
	It's serious to me.
	Well, Ms. Paz, if it was that serious to you, I think you would prepare a little bit more, don't you?
	I prepared how I was able to prepare.
	And I don't think we should blame you for that because, as you said, you asked for everything and you just didn't get it, did you?
	I did not get everything that I asked for that is correct.
	And you know the plaintiffs haven't gotten everything they asked for either, right?
	I'm aware that there have been issues regarding the discovery.
	Yes I'll be brief
	I think it's still Good afternoon You are the corporate representative That is my role here.
	Yes I was.
	You were paid $30,000 initially?
	Yes.
	You were initially offered $20,000 to $25,000?
	Yes, that was based on our conversations, yes.
	And then you negotiated yourself a higher rate?
	I did, yes.
	And you asked that it be supplemented?
	I did.
	Why?
	At the time, what I did was I tried to figure out how much time it would take to review the material and do the depositions.
	I did do two days of Connecticut deposition and then there were requested, I believe, two more days.
	And then it was going to be clear that I was going to be called to testify here today, and so as much time as I had spent on it, it was clear to me that the retainer needed to be replenished.
	You were initially retained to serve as an expert in Texas?
	The corporate rep in Texas, yes.
	Because Mr. Jones, Your Honor?
	I think we maybe should do a sidebar.
	Should we send this one in Texas?
	Yes.
	There she goes.
	Excuse me, did I say expert?
	You sure did.
	And I'll withdraw that.
	And I mean, it wasn't intentional.
	I mean, what kind of game?
	I will withdraw.
	I will withdraw.
	and she was the corporate government. - I'm not getting a medication.
	I'm not getting a medication.
	- Okay, I'm just worried about that social media crowd.
	- I disagree because an issue has been made by the .
	I disagree. - What is it?
	- You will retain the issue of the corporate .
	And I apologize to you.
	Of course I will.
	What did you do in terms of that preparation?
	How much time did you spend in your career for a deposition?
	How much time did that go?
	in the course of the interview.
	What's wrong with this?
	There's nothing more.
	Try all the time.
	One more.
	I'm getting to take care of her.
	Oh, she won't do this.
	She won't do this.
	She won't do it.
	I know, but I'll wait.
	This is just my head.
	It looks so fantastic.
	It's all right.
	I know.
	I know.
	I'm taking the call.
	Yes.
	I'm not going to get in front of you.
	If you want to take care of your lunch break - Yeah.
	I think I've been doing this for decades.
	I kind of think I know what I'm doing. - Thank you. - I'm told I misspoke.
	Yes.
	You are not an expert in this case.
	No, I think in my reply though I did say I'm the corporate rep.
	Well, my mistake and I apologize to the court counsel and to the jury.
	When were you first retained to serve as the corporate rep in Texas?
	It was sometime in late January of this year.
	And did you work with a lawyer by the name of Jacqueline Blot?
	Yes.
	Were there Was the work that you did in preparation for serving as a corporate rep in Texas related to the Sandy Hook shootings?
	Yes.
	There was a Sandy Hook litigation in Texas as well.
	And was there overlap in the work that you did as corporate rep in Texas and in Connecticut?
	There was.
	There was some additional material that wasn't relevant here that was relevant in Texas, but there was overlap, yes.
	When did you first speak?
	And I don't want you to tell me what anyone told you.
	All of these questions are going to be your communications or attempts to communicate with others.
	Okay.
	When did you first speak with Attorney Blot?
	It might have been sometime like maybe January 30th, 31st, last week in January, first week in February.
	And did you subsequently travel to Texas to prepare to testify as a corporate rep in the Texas case?
	I did, yes.
	When did you travel to Texas to begin to prepare?
	So I had already begun reviewing material prior to that, but the depositions were scheduled, I believe, February 13th and 14th, and then I was there almost the entire week prior.
	Between the time that you were first retained and the time you traveled to Texas, how much time did you spend reviewing material?
	I spent a lot of time reviewing material.
	I spent a lot of time watching videos, taking notes on the videos.
	I did have access, as I said earlier, to the Dropbox material.
	In the Dropbox material were depositions, there were emails, the company emails, there were a lot of other documents associated with The financials of the company, etc.
	So I spent the weeks prior to traveling down there, reviewing the material in the Dropbox, as well as videos, and then I traveled to do my observations, so to speak.
	Can you estimate how many emails you reviewed?
	I definitely did not review all the emails.
	There were many, many thousands of emails.
	So I was asked this question at my depositions too.
	I did try to narrow my focus of the email review just to make sure I was reviewing what was relevant.
	Objection, Your Honor.
	Non-responsive.
	A hold.
	And what topics were you reviewing or were you preparing to testify on?
	I was preparing to testify as to the Sandy Hook shooting.
	So I tried to narrow my focus on Newtown, Sandy Hook, names of plaintiffs to try to – names of Mr. Halbig, for example, just to narrow my focus on what I thought would be most relevant.
	There was a lot of spam and email in there and such.
	And you mentioned that you, did you review court pleadings and so forth?
	It's such as the complaints.
	I did read some the complaints.
	I did read some interrogatories, admissions, things like that.
	When you went down to Texas to prepare to testify as the corporate rep in the Texas depots, did you go to the Infowars facility or campus?
	Yes, I was there.
	Describe.
	So when you walk in, it's a little maze-like.
	You have to have key cards and you walk through doors to get to other doors.
	It's kind of...
	Boxes everywhere.
	There's papers lying around everywhere.
	There's really no kind of rhyme or reason to the layout that I could see, but people were kind of spread out.
	One side of the building was kind of administrative and then the other side was where the studios were.
	Different sides of one building or separate buildings?
	I want to say I walked through an area to get to another side, but I wasn't in the studio, so he showed me where the studios were.
	So it might have been a separate building.
	I'm not sure.
	There was no receptionist there, was there?
	Oh, no.
	There was nobody there to greet you.
	There's no phone system in the building where people can call one another, is there?
	No, there's not.
	And there were somewhere between 60 and 80 employees at that time, correct?
	I believe that's correct.
	that's in your efforts to determine who did what to whom did you find out that they even have a flowchart an organizational flowchart They did not.
	How difficult was it for you to get answers about the questions on your market?
	Objection, Your Honor?
	Sustained.
	Did you make efforts to address, you were asked questions by Attorney Maddie about your duty?
	Yes.
	To inform yourself, correct?
	Yes.
	Did you take that duty seriously?
	I did.
	Did you have difficulties performing that duty?
	I found it to be difficult, yes.
	What was difficult about it?
	I found it difficult to find out, like if I had a question, to whom I should direct that question, who was responsible for answering that question.
	If there was a person responsible for answering that question, if that person was there during the time period of this litigation, if information had been conveyed from the old person to the new person, most people would not know who To talk to, most of my inquiries were...
	Sustained.
	Okay.
	Without an organizational flowchart, how did you make determinations about who to talk to and when?
	I would start with a person that I thought should be responsible for such a thing, and then I would ask them, and that person would either tell me whether they were or were not, and try to direct me elsewhere.
	Relying on what they said, would you go elsewhere?
	Yes.
	How many times would you go through that process, speak to somebody who thought you'd have an answer, be directed to someone else, and in the end not get any information that you were looking for?
	It was quite a few times.
	It was often.
	Did you hear the name Mark Enoch while you were there?
	I did.
	He was a lawyer initially in Texas?
	One of.
	And you heard the name T. Wade Jeffries?
	Yes.
	He was another lawyer?
	One of.
	There was a guy named Brad Reeves?
	Yes.
	Another lawyer?
	Another.
	And they'd replaced one another, Seriata, correct?
	One after another?
	Yes.
	There was another lawyer involved, although not appearing, Jay Woolman?
	Yes.
	Mark Randazza.
	I'm objecting to meeting.
	I'll allow it.
	If you get the case, I'll get it.
	I'm sorry, what was the question?
	And then ultimately, Ms. Blatt was replaced as well, correct?
	Yes, she was my primary point person while I was there, but then after I left, she was subsequently replaced.
	Were you called upon to testify in a trial in Texas?
	No, I never testified in Texas.
	Did you, in this call, simply for a yes or no, did you have any communications with Federico right now involving this case at any point?
	No, I've never spoken to him.
	Now initially, one of the reasons you wanted to supplement the retainer is nobody really talked to you about being a corporate rep in Connecticut when you first appeared in Texas, correct?
	That's one of the reasons.
	I only thought it was for Texas.
	When you came into Connecticut, you testified that you were aware of other lawyers involved in the case, correct?
	Yes.
	Jay Woolman?
	Yes.
	A fellow named Robert Barnes was at the periphery of it for a while?
	Yes.
	I got involved?
	Yes.
	And you and I had worked together?
	Yes.
	You left and went on to another firm?
	I left, I went on my own, and then I was at another firm.
	And when that didn't work out, you went on your own?
	Yes.
	And I called you and I said, I hear you're looking for work, correct?
	Yes, you heard I had left and knew I would be available.
	Based on your review of the material that was made available to you, had other InfoWars employees served as corporate rep in either Texas or Connecticut?
	Yes.
	Who?
	I'm aware that Daria had previously testified as corporate rep.
	I know that Mr. Dew has.
	I believe Mr. Zimmerman has on another topic.
	There may have been another.
	As part of your work preparing for this case, did you review the depositions of them that had been broadcast online by Texas Council?
	I did.
	Sustained.
	Do you know whether they were willing to serve again?
	That calls for yes or no.
	I do know.
	And were they willing?
	No.
	Sustained.
	Move to strike.
	It's ordered.
	Respond to strike and injury or disregard it.
	Okay.
	Have you received harassing emails and texts in the course of your testimony in this case?
	Objection, Your Honor.
	What does this have anything to do with the jury?
	Part of the reason for the fee is the difficulty of the work and the collateral consequences that come of doing it.
	Sustained.
	Sustained.
	I do not have that as a full exhibit.
	That's why I said just Ms. Paz.
	that I'm sorry I could have been more clear that's a stipulation that the parties entered into Oh, I don't see it yet.
	Oh, I'm sorry.
	Sorry.
	I don't have a screen here.
	I see it, yes.
	And you've referred to it any number of times?
	Yes.
	You've referred to it to refresh your recollection about dates?
	Yes.
	And topics of videos?
	Yes.
	How many videos are on that list?
	Do you want me to count them?
	Well, or estimate them.
	If you can tell Ron when you need to scroll down.
	Yes, can we scroll down, please?
	Wait, wait.
	It shouldn't be up.
	That's been offered, has it?
	No, I said there's a possible-- I'm sorry.
	Can you-- Can you-- Sidebar, please?
	You did say that.
	Thank you.
	I didn't realize he couldn't, so I might die a little bit.
	Okay, that's fine.
	Well, what's the issue?
	She does not want to come.
	I don't know what somebody can do.
	What?
	I don't know what somebody can do.
	Ron can do it.
	They control the controls, which if who does what?
	No, no, excuse me.
	My courage is here for that purpose.
	My understanding is that Ms. Sheshadri controls who has access to it.
	She can give it over to everyone.
	You know what, Chris?
	We won't wait yet and ask for a courtesy and work this out a little.
	And I'm not going to get a personal comment.
	I'm ready to proceed. - I'd offer 245 as a judicial admission.
	It's a stipulation between the parties.
	No objection.
	Some order.
	We do need some assistance, Judge, if they'd be so kind of to push the switch.
	He's got it.
	And the stipulation that was just entered as evidence, you can accept it, but you decide what weight to give it.
	And where are we at now?
	245, if that could be displayed, please. - Thank you. - Can we go back to the top of that, please, John?
	And I said Ron before.
	I apologize, Ron.
	I forgot we couldn't do it.
	Can you read that stipulation, attorney Paz, in case it's too small for the jury to see?
	Sure.
	It just says, stipulation regarding authentication.
	And this is the list of the videos.
	OK. And what does it mean to stipulate regarding the authentication of something?
	You're a lawyer?
	I am a lawyer, yes.
	It means that Free Speech agrees that these are the videos that were produced by the company at this particular date.
	These were the titles.
	And it also lists the unique name.
	It's a combination of letters and numbers that it was saved under.
	Can we go to the second page, please?
	The third page?
	Well, let's go back to the second.
	The Jones defendants do not dispute that all videos produced by the plaintiffs to the Jones defendants listed in chart B are true and accurate copies, videos that FSS publishes or otherwise broadcast on or about the dates.
	That's what it says, yes.
	Can we go down one page, please, John?
	Not all of these videos, you've not reviewed all of the videos in this courtroom in this trial, correct?
	In the courtroom, no.
	If we go down to the next page, please. Same with this list.
	You've not reviewed all of these in this courtroom in this trial, correct?
	Right.
	We've not spoken about all of these videos in the court, correct?
	Next page, please.
	Next page.
	Now we're on B. Same question as to this.
	You've not booked at all of them, correct?
	In court, no.
	In fact, some of them just say untitled broadcast in the middle of the page 11, 17, 2016. You don't even know what that is.
	I don't know.
	Next page.
	And then there's a...
	Did you say something?
	I didn't say anything.
	Oh, I thought it was okay.
	Deep State launches martial law through judicial tirade, 11-16-2020.
	Do you know what that video was about?
	I do not.
	You can take that down, John.
	Now, Um, I do have records, so I don't want to miss...
	Can you estimate without the records?
	Sure, probably about maybe 40 hours just watching videos and taking notes on the videos.
	And how many hours I mean, I know how many hours I've spent total in connection with the case.
	I didn't really break it down that way.
	I don't want to guess.
	Do you think you overcharged in this case?
	No, I don't.
	Do you think you undercharged?
	I don't want to say I undercharged, but I don't think I overcharged.
	Can we watch Exhibit 45, please?
	This is a video entitled, Democrats File Suit to Overturn 2016 Election as Megan Kelly Reopens Sandy Hook Wounds.
	Hold on, I'll pull one over here, I'll just...
	45 is a full exhibit.
	And Mr. Paz, I'm going to show you two exhibits in full.
	You've seen a lot of clips here, correct?
	Yes.
	Mr. Jones talks about a lot of things other than Sandy Hook, correct?
	He does.
	This is clip 45. I'm sorry, is this a clip or an exhibit?
	It's an exhibit.
	Excuse me.
	Can we not show this part of it?
	It's getting too busy.
	I can't, I don't know how to do that.
	I don't either.
	It's on.
	and then maybe once he gets there we can put it up because it's we're not in a rush we have plenty of time can we just approach it
	certainly thank you so i just want to say one thing before you raise your issue they want me to figure it out and tell me what i can do
	what i can do to make it um i'm going to say easier on you but just smooth things over to make it easier i knew so that there's not the so i don't have to deal with the sniping it's much better than i'm using it No, but do you know what I mean?
	Like, what I can do to help you so that we don't have that.
	Just think about it.
	I don't need any extra.
	It's a new chapter in therapy.
	It's a new thing.
	Just think about it and we'll talk about it before lunch.
	What I can do to help you.
	Maybe take some of the caffeine out of the coffee.
	No, she can't.
	Can you hear?
	What I understand, I'm trying to have a few years away.
	I don't know.
	Make sure you see the scope.
	I'm going to check those beyond the scope.
	That's not the most part.
	The video is how long.
	About 50 minutes.
	You know, here's the problem.
	No, no, go ahead.
	Go ahead.
	The judge wanted us to do it.
	They have represented three times, if you follow an expression, the evening in your opening, that Alex Jones thinks that there is a conspiracy of government.
	I'm just trying to do it, Jeff.
	I don't care what was said in the opening.
	I care about the evidence in the case.
	So what people said-- Should we do this without hearing?
	No.
	I think we should-- Getting close to .
	It's hard for the monitor to do it.
	Let's just do it.
	Why do we have to come up here stereophonically?
	Who's going to speak for the audience?
	Hm?
	Who's going to speak for the audience?
	OK.
	I'm going to let them go to one single ..
	All right, so we have some issues to discuss.
	So we, I, have made your decision.
	Not everyone agrees with it.
	To let you go for an early lunch and we will stay on the record and continue with our issues.
	So, Mr. Ferraro will Stand far as your notepads.
	I know, I have faith in you, that you will continue to obey the rules of your conduct.
	We will start promptly at 2 p.m.
	And I hope everyone has a nice lunch, and I hear the weather's nice, so hopefully you at least get a little pressure and get to enjoy the weather.
	And if you do that, just be careful, as I say every day, to avoid contact.
	I see everybody's wearing their handy-dandy little stickers there, so hopefully people will know to avoid it as well.
	So we'll see you at 2. Is it necessary for Ms. Paz to leave the courtroom?
	should probably be excused we'll see you at 2 a.m. all right so um i think we left off that uh attorney pavis
	you were looking to play the 50 minute video exhibit 45.
	Yes.
	Yes.
	We left off already.
	You know, this video was not played at all during Ms. Pattinson's direct.
	It was not played at all.
	So our first objection is that it's beyond the scope of the direct.
	Our second objection, though, is that- Well, can I just ask for- I have no idea.
	So it's just for ID, or is it a full exhibit?
	It's a full exhibit.
	Okay.
	By agreement.
	And what's it about?
	I don't know if it's beyond the scope because I don't even know what it's about.
	Do I have to watch it first?
	Because I could do it over lunch.
	You may want to.
	But it relates to Megyn Kelly reopening old Sandy Hook wounds, Democrats filing suit to overturn the 2016 election.
	I think it is within the scope of the evidence, and I know you don't want to hear about the opening statement, that has been offered by the defendants thus far.
	If you could just keep your comments to the I am.
	To the actual evidence in the case.
	On two occasions when—excuse me, I cut you off.
	No, that's right.
	Go ahead.
	I'm listening.
	On two occasions when Agent Aldenberg testified, Mr. Maddy went out of his way to use this following locution in its almost exact And Mr. Jones, you know, believes that there are petals, the notion that there is, and this is the quote that's almost exact, a conspiracy of global elites and business leaders in governments, including people in our government, he said breathlessly, on several occasions.
	Then there has been testimony about Megyn Kelly, his reaction to Megyn Kelly.
	They offered a video clip in which Mr. Jones referred to, and I want to Find the language.
	To Chelsea Clinton and another Democrat, I believe, as a sea hag.
	These items have been sea hags for the New World Order.
	It was Chelsea Clinton and Megyn Kelly as sea hags for the New World Order.
	He grouped them together with the Clinton Foundation.
	And this was in the clip involving his being a precision-guided heavy munition coming in on top of you.
	I hit the barbed wire, everyone comes in over me.
	These items have been offered in isolation to the jury to suggest that this represents some sort of modus operandi of Jones to operationalize his people as against Sandy Hook and others.
	My view is that taken in isolation, they mischaracterize the man and make a caricature of a person who has far more to say than things about Sandy Hook.
	I am aware of the court's prior rulings with respect to the motions in limiting and would have On them would have trimmed its exhibit list and its presentation of evidence to avoid opening the door to these topics.
	However, it is my view that they have done so.
	And to alert the court, there are two other exhibits that I'll seek to show just to get all these out at once so we don't have to do them over and over again.
	I will be offering the Megan Kelly profile under exhibit 40, which is not a full exhibit.
	I guess it's not in for identification, but it's on the list.
	And I won't be offering that for the truth of the matter that Ms. Kelly profiled, but for its impact on free speech systems.
	Clearly, that's a door that has been opened in the course of the plaintiff's examination.
	Finally, we will offer, and then I do mean finally, Judge, the full 222, oh no, it's not 222. Actually,
	I'm not going to offer 222. That's not a video.
	So that's my offer as to the videos, Judge.
	So you have 45, which is 50 minutes, you said, and then 40. Which is approximately the same.
	I won't watch the whole thing.
	I'll stop it at some point, but I don't gauge whether the jury still has any interest or not.
	But I believe that the door has been opened to both of those.
	Timeliness objection.
	I feel like Gilligan on Gilligan's Island.
	We just endured almost three days of repetitive examination of Ms. Paz.
	I will be done within two hours.
	Can you give me a summary?
	I'll hear regarding the objections, but can you summarize in your own words what 45 and 40 are?
	So, Mr. Jones, should he testify?
	Well, in fact, other exhibits that are in full and haven't been played by the plaintiffs, at least not yet, are Alex reacting to the Megan Kelly interview.
	I just want to make sure I don't lose this.
	I'm sorry.
	No, I'm not understanding.
	On your cross, you want to play Exhibit 45, which is around 50 minutes, and then you want to play 40. So what I'm just trying to figure out, because I haven't seen them, so I don't know if it's beyond scope.
	I don't know anything about these exhibits.
	So if you could just sort of in your own words sort of.
	They're classic Alex Jones doing exactly what Mr. Matty said he did, which is taking on what, you know, there's another reference in another video today to the deep state and to his belief, which is core to who he is.
	So can we break it down to exhibit 45?
	Contains all of that.
	His views of the deep state, his commentary on other things, support for the notion that Mr. Matty raves, that he believes that there is a global elite comprised of business, financial, and governmental interests, including people in our government, who are out I want to, as Mr. Maddy put it on two occasions in the jury's presence, enslave us and kill us.
	That's a little bit of an overstatement.
	Certainly Mr. Jones believes that we the people are about to be enslaved by globalists, and certainly he believes that globalists want population reduction.
	I'm not interested too much in his beliefs as Opposed to what these exhibits that you're offering?
	They illustrate these points, and I want the jury to see them in their context.
	And Exhibit 40, which is?
	The Megyn Kelly interview.
	Okay, tell me about that.
	So, Mr. Jones, there was some testimony about his reaction to Megyn Kelly.
	They offered a video of his responding to Megyn Kelly and Chelsea Clinton, that she hangs the new world order.
	And I've I believe even offered an exhibit and had Attorney Paz read the headline about Megan Kelly.
	I'm not sure they read the headline about reopening the wounds, but Megan Kelly's use of Sandy Hook has come up.
	Mr. Jones's contention is that this crisis was largely done until it was reawakened by Megan Kelly.
	This is his contention, Attorney Paz is in Exhibit 40?
	because I thought this was the...
	This is the Megyn Kelly interview, but because it has been referred to as an item not in evidence, I want the jury to see it so they can evaluate the plaintiff's characterizations of it.
	And that's where his position that he was referring to.
	Right, right.
	All right, now I'm on.
	Okay.
	All right.
	Attorney Natty?
	The 50-minute...
	So I think in order to assess the scope of objection, Attorney Patterson's representation said, They did it to Big Five, simply a demonstration of Mr. Jones's belief.
	To me, it's not sufficient assurance that a 50-minute video is not going to cover things that are prejudicial, that are hearsay, that are totally off-topic, that are controversial and provocative and likely offered to support the information That Mr. Pattis made in his opening statement.
	All right, so let me ask Attorney Pattis about that, because I agree that this is likely to happen.
	How are we, I thought this was something...
	They're full exhibits.
	They marked the exhibit.
	I agree to it.
	How do you say my exhibit is unduly prejudicial?
	He, eyes wide open, said, you want this?
	I said, sure.
	40 is a full exhibit, too?
	Yes.
	No, no, 40 is not.
	But 45 is by agreement to full exhibit.
	All right.
	But it still needs to be played for a relevant purpose to the appropriate witness.
	And so what we're seeing here is I asked Ms. Paz to confirm what It was published,
	apparently, in 2018, in which Mr. Jones talks about God knows what for 50 minutes as reasonable and within the scope on that limited and narrow issue, especially because you can see from the headline, Judge, that he's talking about overturning the 2016 election,
	just from the title, an obviously controversial topic that we did not go into I'm stunned that my adversary can say he doesn't know what's in an exhibit he offers.
	But here's what I don't know.
	I know that the election is beyond the scope.
	How do I... You're giving me a...
	I didn't offer the exhibit.
	I didn't elicit testimony about Hillary Clinton as a sea hag.
	Attorney Pattis, I'm just trying to figure out if this is beyond the scope.
	I don't remember...
	I agree with you.
	Anything about overturning the election?
	So if you're offering the whole entire 50 minutes, I don't see how we handle this on the spot.
	Because there are certainly parts of it, maybe all of it, maybe most of it, I don't know that are going to be beyond the scope.
	So I'm just not...
	I don't know that that's...
	I mean, obviously the court will make that determination, apparently.
	Well, I'm not sure I can make that determination.
	I don't...
	I have other things to do at lunchtime, so if you're now asking me...
	Under business is what I mean, actually.
	No, I understand that.
	So, I don't...
	My claim is that when they offered through exhibit I can't remember the number now.
	It was the 420, 36A, references to Chelsea Clinton, make it clinic, sea hags at the New World Order, Alex demonizing the Clinton Foundation, together with the comments that Mr. Maddy has raised in the jury's presence through Oldenburg,
	and in a sneering, in my view, tone about Alex believing that there is a global conspiracy I mean, I didn't put that in front of the jury.
	And if that's not opening the door, I don't know what is.
	So here's what I would suggest.
	I'm going to sustain the objection to playing the whole 50 minutes, but certainly if you want to, during lunch, pinpoint some parts of this 50-minute Exhibit 45 that I can look at and determine whether it's within the scope or not, but we have to Pinpoint what that is, or it's going to be all afternoon of...
	Well, I mean, whether it's all afternoon, Judge, I didn't...
	This examination went on for days.
	I understand that.
	They put it on a day.
	I understand that.
	That's my whole thing.
	All right, so now Exhibit 40 is this Mary Cowley interview for 15 minutes.
	Okay, do you want to be heard on that, Attorney Maddie?
	Yeah, I think what Attorney Patis wants to do is put in the entire 17-minute NBC profile It's full of, including Mr. Jones' own hearsay that they want to offer for the truth of the matter.
	He's interviewed in it.
	It deals with other issues in which he's been involved.
	It deals with his affiliation to Donald Trump, obviously another attempt by Attorney Patis to reject politics into this case.
	It deals with other allegations against Mr. Jones related to Chobani and others.
	And it is just full of hearsay and self-serving.
	It's just inadmissible.
	Well, it's not.
	He, meaning Attorney Matti, at about 1025 this morning, was asking questions about an interview with Megan Kelley, about giving her an interview.
	He wasn't happy with the interview and the claims involving Sandy Hook.
	I didn't put Trump into the case.
	He came in through one of their own exhibits just this afternoon or earlier this morning.
	So, yes, I have a motive.
	You know what I want to argue.
	I showed you in my opening.
	I've been transparent about that from the get-go.
	But I believe that the door has been opened to that, and you don't get to just give a whiff and then say, well, doesn't this smell?
	Without showing or letting the jury smell it for themselves.
	And if it's only 17 minutes, that's a lot longer.
	All right, so I had written down 15 minutes.
	I thought it was longer.
	All right, so it's 17 minutes?
	Can you pinpoint any part of that?
	The whole thing.
	There's no hearsay issues in that?
	In your mind?
	I'm not offering it for the truth of the matter asserted, but for Mr. Jones's state of mind.
	Mr. Matty's direct question was, he wasn't happy with how the interview made claims regarding Sandy Hook.
	We're not here to litigate the truth of the matter as to Sandy Hook.
	We're here to litigate whether Mr. Jones caused discernible, and in the cut proclaimed, ascertainable economic harm to the plaintiffs, and thus far there's no testimony of that.
	And second, we're That's why we're here.
	Most of what we saw in the last two days really pertained to a punitive damage phase, trying to light the jury up.
	And it's consistent with the improper purpose of the plaintiff's opening statement, which is we have to stop Alex Jones.
	That's no part of a compensatory damage claim.
	So I'm not – by not – we may have a disconnect on what the plaintiff has to prove here.
	You can challenge the extent of the damages, but I think you just said that he has to prove causation.
	No, I didn't.
	If I did, I misspoke.
	The extent of the damages is clear, Judge.
	Maybe I misunderstood.
	Attorney Maddy?
	Your Honor, what I heard Attorney Paddis say is that it's being offered for the That's number one.
	I believe what Attorney Pettis is suggesting is that it is Alex Jones's state of mind in reaction to how his views about Sandy Hook were characterized in the Megyn Kelly video is relevant.
	Number one, let's just assume that that's what he's offering it for.
	Obviously, then, only the segments about Mr. Jones's statements on Sandy Hook would be offered for that purpose.
	The statements that he makes about Sandy Hook have nothing to do with his state of mind in reaction to the Megyn Kelly interview.
	Those are statements that were made during the interview.
	So they say nothing about what his state of mind was in reacting to it after the fact.
	The statements he's making during the interview are statements both about Sandy Hook and other things, which we didn't offer, which would be offered for the truth of the matter, and would be here saying it can't be offered in the defense case.
	Judge, it's a full exhibit, so let's not open that floor here.
	It is not.
	I didn't ask about the interview with Megyn Kelly.
	The plaintiffs did.
	And so they, you know, they come in here and they tiptoe around things.
	They put a full exhibit in.
	They open the door.
	And then when I say, let's look behind the door, they say, oh, no, we can't do that.
	That's ridiculous.
	Okay, turn pat.
	So I'll look at that since it's 17 minutes.
	minutes how would I do that wrong all right all I'll look at that over lunch Anything else?
	Nothing from the defense judge.
	So I'll just see you on the sideboard.
	I have comments to all of you.
	Oh, shit.
	So just to get back to the personal sniping, what can I do to get that out of the picture?
	Because, you know.
	I was singing your kumbaya.
	No, but I'm not.
	Listen, I don't want to deal with it.
	Let's be honest.
	I feel like I don't want to deal with the spike tip.
	I feel like I'm doing something wrong.
	Because I find it very unprofessional myself.
	I have been maligned continually through this case for purposes claims that I've not had a good faith basis to do this.
	There have been motions for sanctions at the drop of the hat.
	Everything has been an emergency.
	I came here to fight for Alex Jones.
	And I just had enough of the condescension.
	I'm talking about the side horses sniping in front of me, the way that you're going after each other.
	That is not necessary.
	So what can I do to stop the strain?
	Are we anti-coblip for all of us?
	Can you not strike anymore?
	Because I don't know that I'll have the patience to deal with it.
	The good news is, I don't think it's going to be that long.
	Do you agree?
	I do.
	We had a conversation yesterday.
	And your comment about Mr. Gillis, is he not testifying?
	I don't understand.
	I thought you said something if he testifies.
	I don't know whether the plaintiffs will in fact call I mean, we have an agreement to produce it.
	When is that?
	Next week.
	And the judge, of course, you seem to perhaps be unaware of an agreement that was reached in the bank.
	Yeah, three days.
	Somebody told me about it.
	So it is available Tuesday, Wednesday, and Thursday, and longer, if necessary, if we start within that period.
	There was...
	I'm just checking those.
	But I mean, I'm not going to hold you to the date.
	I don't care.
	I want to end the trial.
	I just don't know whether the plaintiffs will call them.
	I can imagine a universe in which they don't.
	Texas counsel would be very effective by not calling Mr. Jones and making the last witness.
	So getting back to the knots, I think.
	What's the answer?
	Josh, call on you.
	I don't want any.
	We don't need any sniping.
	There should be no sniping?
	I'm willing to extend the hand.
	Because I'm not sniping, am I? I'm not going to.
	Judge, I may or may not have views about some of the rulings and decisions you've made related to this case, and I'm not calling her, okay?
	But I'm not sniping at you, and you shouldn't be sniping at me.
	So sniping at this.
	Comments that the court had made me to the president prior to a hearing without, like, sniping.
	Sniping in this case.
	I thought it was okay.
	I'll slip it over to something like that.
	I'm not sniping.
	But she said she had him tonight.
	Well, I'm not sniping at this here, so why not?
	You're not here because we're complaining about the sniping judge.
	Just get on the table.
	So I will look at the events that's not like an offer.
	Because I think I just say what they have to say without having each other in front of me.
	If you want to do it somewhere else, then you can do that.
	But just don't do it with me.
	How about that?
	Chris, let's take the anti-Mediterranean.
	You can shake my hand.
	Okay.
	All right, guys.
	Have a nice lunch.
	We'll take a recess.
	All right.
	So, Ron, you're going to get me that?
	Yes, Your Honor.
	Well, I didn't put it together.
	I am going to sustain the objection.
	and I think we're ready for the panel To it in whole or in part, Judge?
	Well, it was offered in whole, and that's how I'm going.
	Okay, then I would renew my offer, and I'd like to make some supplemental remarks that did not appear to me at the time.
	Well, you mean further argument on something that I move on?
	In support of what I'm going to be offering.
	Okay, well, tell me first what the offer is so I can...
	Our claim is that with respect to Exhibit 222, which is the 2016 set of metrics on page views and whatnot, this was offered midday and mid-morning on the second this was offered midday and mid-morning on the second day of trial.
	And the claim was that Alex had called that exponential growth.
	The plaintiffs walked away from that in subsequent examinations and didn't visit 2016.
	And I think the reason for that is they may have realized that's the year that the Megan Kelly interview talked about the reasons for that exponential growth, which was Donald Trump.
	SO, WE'RE GOING TO BE ABLE TO And they have claimed, in this very unusual cutback case, As to the corporate rep, that Alex sows fear to make money.
	And that is their cut for claim.
	There's not a claim about a particular product.
	May I finish this?
	I just want, I'm not, it's going to be lost on me if I don't ask you a question.
	It's going to get lost on me if you ask too many.
	Well, we'll get back.
	We can play it back.
	So Exhibit 222 is a full exhibit.
	Correct.
	And you want to examine Ms. Paz on it?
	No.
	I'm saying that in terms, it's the And to be honest with you, because I try to be, it's also a segue into a motion to ask you to reconsider, because I think that by putting, by calling into question the business practices and saying that it's not genuine, that what my client says are lies for the sake of profit, they beg the question of whether he speaks the truth as he sees it and makes money to support that.
	And that is his defense here, as to the cut book claim.
	Because there is no case in Connecticut that supports what they're attempting to do here, which is to basically stop a man from speaking, as they said, because of the content of his speech under guise of a cut book claim.
	But this isn't hearing the damages.
	And I understand you're going to make a motion at the appropriate time.
	But our defense is we concede – well, we don't concede, but we accept for purposes of law of the case your ruling that causation is established.
	But it's abundantly clear that the plaintiffs have to prove the extent of their damages.
	And we've briefed that, including our most recent brief this morning.
	And we believe that arguing exaggeration on behalf of the plaintiffs is consistent.
	And as a matter of right, it's something that we get to do should they elect to call any plaintiffs as witnesses.
	Now, they can choose not to do- When you say they're arguing exaggerating, you're talking about the extent of their damages.
	Your claim is that they are exaggerating their damages.
	For political motives.
	And that we are entitled, if they testify, to explore that because motive, interest in the outcome, and bias is never collateral.
	And so the accusation in the pleading of the 15th was that I was trying to nullify or otherwise ignore this court's order.
	I'm not.
	I'm trying to cross-examine the plaintiffs within the meaning of what cross-examination means.
	And while accepting for the law of this case the threshold question of damages, We want to put before the jury reasons they may have exaggerated.
	Right.
	But we're talking about Ms. Paz, you were talking about Exhibit 222. And what I'm saying is they put that in front of the jury.
	We didn't.
	And what that exhibit I can't remember if it's clicks or not, 42 million engagements, or 29.3 likes.
	And they did this in the context of looking at the growth from 14, 15, and 16, and then spent days with this jury going through the videos that were demonstrated about Sandy Hook to support the claim that this was done for the purpose of driving that exponential growth.
	So can you tie this up now?
	Yes.
	So Divit 222, this witness.
	They then...
	They then solicited testimony about the interview with Megyn Kelly and Mr. Jones' reaction to it.
	They have put before this jury the theory that Jones merchandises fear for the sake of making a buck.
	Our claim is that he recognizes the fear of the people and makes a dollar to support that claim.
	We didn't raise this cut book claim.
	They did.
	And we think that these videos support our defense.
	So you're back to now the Megyn Kelly video that I already rolled on?
	Absolutely.
	And we ask you to reconsider because we think on the law of this case, I don't want to try the case again.
	And so they've solicited testimony about his reaction to the video.
	They've called him a liar any number of times.
	We had a scorecard going in the case before he ruled that the law of the case was that he lied.
	It was up to 80, 90 times.
	So Ms. Paz testified as to his reaction to the video, yes?
	Yes.
	And what did she say?
	I'll refer to my notes.
	Not happy with how the energy was reflected him in Sandy Hook.
	Then there was a claim that Mr. Jones showed only part of an interview with Mr. Heslin, that somehow they had manipulated this video to serve their own purposes.
	And I want the jury to see what was on Megyn Kelly.
	And I want the jury to draw its own inferences, not argumentative inferences, about whether, in fact, Mr. Jones misrepresented anything.
	And I think the Megyn Kelly interview is 17 minutes.
	The other one I reviewed, by the way, I was wrong about the 50. It's about 19 minutes.
	These are both squarely within what has been presented by the plaintiffs.
	And what's more, Judge, you know...
	So you're offering the Megyn Kelly interview to...
	Completeness.
	To show that he was right to be unhappy?
	To show several things, that there was more, we didn't introduce the 16 metrics in this case, they did.
	And here was a widely broadcast interview that was wildly controversial, that is replete with Trump's support of him.
	And I would say that there were many reasons to be just unhappy.
	And that there were misrepresentations about it.
	Misrepresentations in the video.
	Right.
	Okay, but the free speech system's testimony was that he was unhappy.
	Judge, look, here's I'll make, if the court persists in the ruling, I'll make a motion, which I'm sure will be denied for a mistrial, and here's the reason for it.
	I've marked as a court exhibit, I think it's 671, a closing, an opening statement that I gave today, or I didn't know if I'd be able to give in the course of this case.
	And it was clear to me that exaggeration and motive was our defense.
	I didn't know that I'd get to give it, so I printed it out so that if you stopped me, I could mark it for identification.
	But my view is that the door was opened.
	And then I was lulled into believing that we were going to be able to try these issues when the plaintiffs who objected to every single exhibit that I offered, offered several hundred exhibits themselves that contained this material.
	How can this not be?
	And so any claim that it's hearsay, Any claim that there's some sort of evidentiary foundation has been waived by the offer.
	What I'm trying to do is defend Alex Jones and his contention.
	The contention I told the jury.
	He's an angry populist who, as Mr. Matty has said to several witnesses, believes there's a global conspiracy to enslave people.
	It may not be a belief you or I share, but you can't use a Kutka statute to silence a person from unpopular speech.
	And that's what they're trying to do here.
	And I'm pretty confident on my odds in the appellate court, but the odds then will be a retrial.
	We want to try this case once.
	That's the reason that we stipulated to withdraw the stay in free speech systems in the bankruptcy matter, so that we wouldn't have successive trials.
	We didn't want Jones to have to go to trial in free speech.
	We just want this jury right now to decide the issues that the plaintiffs frame.
	And we think that this material is clearly responsive and within this vulgar case.
	All right, Attorney Maddy.
	Your Honor, am I arguing on the motion?
	Do you want a motion for reconsideration here?
	Okay, well, let me say what I think I heard.
	What I think I heard was, Attorney Maddy started talking about 222, which is the 2016 social media metrics.
	And I think what he was saying was the new reason he's offering the court for why the Megyn Kelly video is relevant is because it suggests that whatever bump in social media traffic may have occurred in 2016 is due to Trump.
	And if that's the case, it's hearsay.
	That Mr. Jones' new popularity in 2016 was due to Trump.
	That is hearsay.
	It cannot come in for that.
	They're offering an out-of-court video for the truth of that matter.
	So that's what I heard him arguing on the motion for reconsideration.
	I didn't hear anything new in the argument about why Mr. Jones' Statements, out-of-court statements about Cindy Hook should be admitted now.
	What we know he said in that video was essentially he was mischaracterizing what he had previously said.
	Things like, I didn't say that or I didn't say that.
	Also hearsay statements that are being offered to this jury to show them Mr. Jones never said these things.
	Not only is it hearsay, but it also offends the default ruling ethic.
	So, nothing I have heard suggests that anything about this video is admissible under the rules of evidence.
	But, Judge, they waive the hearsay objection by offering.
	I mean, how do you offer an exhibit and then make the video?
	Oh, the Macon Kelly thing, but I'm talking about Macon Kelly.
	How do you, you know, how do you offer something and then claim it's hearsay?
	How does that work?
	I'm sorry, I understood 45 was withdrawn so that people could review it to assess...
	And I'm reviewing that motion to address it on a seriatic basis, but as to 40, we say we will complete this tragedy.
	All right.
	so I am going to deny the motion and we can get the jury.
	Well we still have the other exhibit judge and if you're not going to permit all as to 45 I would.
	I thought I rolled on one before lunch and I just rolled on the Megyn Kelly one.
	I thought you were going to look at 45 at lunch.
	That was the shorter one.
	Did I miss that?
	I looked at the Megyn Kelly one.
	I ruled on the other one before lunch.
	And then there was a third one, but then you didn't pursue it.
	And the rulings during the cross-examination of this So no part of 40, which is previously been admitted, can be gone over with attorney's office?
	You offered it in its entirety, and that there was – Just for the record, Governor, exhibit 40 is not full of – 45, excuse me.
	45 is the one that is admitted, and you had talked before break, you said if they might look at it over recessed in certain parts.
	But I'm not – right, so I'm – before lunch, sustained the objection on the entirety of the 50-minute video.
	I haven't, I haven't changed the ruling.
	And this is now, of course, we're talking about during the, during your examination of Ms. Paz.
	And the basis of the ruling, Judge, just so I understand it for the record, it can't be hearsay because they, it's an all exhibit.
	I think we're ready for the jury.
	My record needs to be complete, Judge.
	The basis for upholding that objection is We're ready for the jury.
	That's not a legal basis, Judge.
	May I have a ruling that the appellate court can understand?
	There was an objection, and I sustained the objection.
	But there was no legal basis stated.
	I'm entitled to that under the practice book, and you should deny the motion on that grounds alone.
	It's insufficient for somebody to stand up.
	They're supposed to provide me with notice so that I can respond.
	I believe that he argued it for 20 minutes, and I think the record is clear, Attorney Paddock.
	He said hearsay, but it cannot be.
	And if it's not clear, if it's not clear, Wouldn't be the first time.
	And you'll move for an articulation, and I'll articulate when I'm directed to by the appellate court.
	I understand that there will be an appeal.
	I assume there will be.
	Well, maybe not.
	We might win.
	There may be an appeal.
	There may not be an appeal, then.
	But I assume there will be an appeal.
	May I just make one comment here on it?
	I suppose so.
	I just hate to keep this jury waiting, because they're so prompt.
	Just very quickly, the objection we made to 25 Right.
	And I said three times that for the purposes of this witness during this examination, the objections are sustained.
	I don't know how many more times I have to say it, right?
	No more, Judge.
	I got it.
	I did just want to add, obviously, Attorney Pettis is pretty easy to the 222 witness pause, but I just wanted to renew my concern about offering any sort of hearsay testimony about Which is not based on any personal knowledge she may have.
	I think we clarified that on the sidebar.
	I think that ruling is on the record, and I'm sure that Attorney Pettis is on top of that.
	I have no doubt.
	Okay.
	Let's get it.
	John, can you get rid of it?
	Can you get rid of it?
	Thank you.
	Oh, yes, please.
	Thank you.
	Judge, I'd like to thank the good folks at Costco.
	We had a miscommunication about your order.
	It was my understanding that the items that we were given would be the exhibits prepared and ready for presentation of the jury.
	I'm told that the Costco firm did not take that to mean that they were going to give me marked exhibits, and therefore my written exhibits aren't marked.
	So they've provided me with one to you today.
	Thank you.
	I may have stand over here so I can see the...
	And Judge, are you able to see?
	I'm good, thank you.
	Okay, I can see you from here, thank you.
	Whenever you're ready, Attorney Pettis.
	Thank you, Judge.
	John, can you pop up 2.22, please?
	Too good.
	Can you scroll down a page?
	Another page.
	And I don't think we have the ability to blow things up on my side of the aisle.
	Ms. Paz, do you have a screen in front of you there?
	I do.
	You were asked questions about this on direct examination, correct?
	Yes, I remember.
	And you talked about the Total fans, and I don't think we ever did get an answer about what the fans were, but presumably that's a good thing.
	They increased by 57.8%, correct?
	That's what it looks like, yes.
	And I think you testified in response to a question from Attorney Maddie that Mr. Jones was regarded as, I don't remember the exact words, but he appeared to be pleased by that increase as you understood it.
	Sure.
	And that represents a substantial increase over 2015, which was 2.1.
	I'm showing you a chart that you were previously shown in the course of your examination, correct?
	Yes.
	And Mr. Maddy took numbers for a variety of documents and talked about the number of impressions and so forth over this three-year period, correct?
	Yes, I remember.
	And we noted a steady increase from 2014 in 2.2 billion to 2015 in 2.9 million to 2016 in 4.1 million, correct?
	Billions, yes.
	earlier showed you exhibit 245 and can we take another look at that please John can you shut it off for a second here and this may not bear an exhibit tag judged for reasons I've previously stated the we'll take care of that at the break
	All right, we're good.
	can you please display 245 and this is the list of stipulations regarding videos that were provided that the parties agreed to in anticipation of trial Right.
	Could you review all the videos there?
	I think we talked about how some of the videos, I didn't even know what they were in the list.
	Correct, correct.
	But I think I reviewed all of the ones in Schedule A. If you want to scroll down, I can just tell you for sure.
	Exhibit A, rather.
	rather.
	And while she does that, Judge May may approach on a legal issue?
	I have a way of coffee for lunch break at your suggestion to keep the caffeine down.
	I'd like permission to ask two questions.
	Did you notice any topics in your review of those that stood out?
	In other words, Trump and Clinton and so forth.
	order but I think the record is she saw that if she saw did she see these topics reflected in those videos videos videos did she did she know this cover what 2016 was Was it a presidential election?
	Did she see coverage that Donald Trump is?
	How extensive was it?
	She'll say whatever she wants.
	Did you see mention how coverage of the race against Hillary Clinton?
	Yes.
	How extensive was it?
	She'll say whatever she wants.
	I haven't prepared this or scripted this, but I think on this record those are fair questions.
	So you're going to answer what the topics were in 2016?
	Right.
	I think that's a lot of things for me.
	And she can read off the exhibit and what the topics were in 2016 without summarizing the video.
	If she's going to ask her to read that title, I think she'll read it.
	No, I get to read her.
	I just want to ask those two questions.
	I think the foundation is right.
	No, I think you can ask her.
	OK. Read off.
	Maybe you want this, but not someone.
	I'm going to have your objection.
	The question is, what generally were the topics in these videos?
	No, that's not the question.
	Right?
	No, I'm confused.
	I thought you just said, I can't.
	Yeah, but you asked.
	She can read off the document evidence.
	Okay.
	But then if she doesn't recall it, I can't have the right to show them.
	I'm not trying to resume the system.
	I'm just trying to work the rules to my client's advantage here.
	And it seems to me that if she says, I can't recall, then I get a right to show it to her to refresh her recollection, because the rules on refresh recollection are, you can do anything you want.
	I can't bring a pizza.
	Right here.
	If you show her a video title and you say, what would that video about?
	If she gives it a title, what's that?
	You can't show her a video in the presentation.
	Correct.
	Correct.
	So here's what I would say.
	I claim surprised by this term.
	I had my opening marked for the court exhibits so the court could be developed by credibility for itself.
	I made the arguments that I had to make.
	Given the exhibits that were offered as full, I claim surprised.
	I'm going to want to do a supplemental brief on the motion and limiting that I filed this morning.
	I'd like to do that this afternoon and get some rest of this weekend, because we're going to run into this over and over again.
	Really?
	Yeah.
	Yeah.
	OK.
	I play a surprise.
	I have my adversary objecting to exhibit the key offer.
	This has never happened to me in 30 years.
	That's a definition.
	That's a definition.
	We already addressed that.
	I'd like to brief this further.
	And I've got a request to charge on what they do.
	Well, we could move that date, but you could brief it further as we move forward, but I don't want to add this thoroughly.
	But I'm taking the decision.
	The issue that he raised was, Is the law involved in this question?
	That she'll say that I don't recall that video, and then I'll show it to her, and then she'll say it.
	And I think on this foundation, I have the right to put that on.
	So what you're proposing to do is ask her about the specific video that the court has already ruled.
	You cannot pull it without her.
	If this exam is the scope, and ask her what was it about?
	Yeah, because the court rules that the exhibit didn't come in in its entirety, and all I care about You're
	not going to be done with her anyway.
	I mean, there's no Because I claim surprise, given the way it came.
	I'm just trying to figure out what this is.
	Maybe I just have never understood what the surprise is.
	I'm going to talk about hope.
	I'm sorry.
	I get that.
	I don't care.
	I just care about the memo.
	I got the memo on that one.
	But with respect to the case that's been put on, and I objected throughout him, correct, that, you know, I'm compound racist, and he does this to inspire us to make a buck.
	They're two separate questions.
	They were often put together.
	The cut of the claim is that he needs to be stopped because he markets fear But I claim surprise because It's
	a high school projection.
	But secondly, I just want to make this clear, since I have that gesture as part, that when in the AG state, they get out of the AG state, they stop from the line, and everything else.
	And that's what the case is.
	They stop from the line.
	They stop from the line.
	It's not put out of place.
	It's not put out of place.
	It's going to be anything like that.
	And so I just want to prove that this is an ongoing, you know, kind of issue as to what's called by the AG.
	That's what it is.
	But that was an improper argument in the context of a compensatory hearing of the AG.
	But here's what I say about loving and watching evidence.
	And whatever objections were made, I mean, if people objected, they objected, and if they did it for a job just please know what the evidence is that's right i don't have a problem now with ending like at 3 30 today okay okay and then if you want to brief it talk to each other thank you for your patience
	can we see 222 again and can we go down on one page well down another page okay here we are as free speech systems
	do you have an explanation for why the page views increased in 2016.
	objection here's it sustained Now you spent how much time on the campus at Free Speech Systems in Austin?
	I was there for, I think I was there from Tuesday through Friday during, or maybe it was Wednesday through Friday doing interviews.
	And Saturday we were also doing interviews for half the day.
	And then the following Monday and Tuesday were the depositions.
	How much time did you spend with Alex Jones?
	I met him once at free speech.
	We talked for, I don't know, maybe 45 minutes or an hour or so.
	I recall speaking to him on the phone.
	And other than that, I have not spoken to him since.
	How long was that personal meeting?
	I think it was about 45 minutes, an hour.
	I don't have the question I'm I'm sorry.
	Me neither do I. Me neither, but I'll think of one.
	That time you talked to Alex on the phone, how long did that last?
	The phone conversation?
	Well, it was with counsel, so...
	I'm only asking, not asking what you talked about.
	Okay, sure.
	Maybe 20 minutes, 30 minutes, if that.
	So you've got about an hour with him?
	Personally, in person, about an hour.
	And in person and on the phone, the cumulative amount of time?
	Oh, cumulative, maybe a total of an hour and a half total.
	Based on your observations of him, in other words, how he responded to you as you spoke to him and what you heard on the phone, did you feel you had his complete and undivided attention?
	No, it was difficult to talk to him and get him to focus.
	Without saying what he said why do you reach the conclusion that it was difficult to get him to focus if you can do it If I would ask him a question he would kind of go on into Whatever he wanted to talk about instead of what the specific question I asked him about was
	I would try to redirect him to my specific question and he would kind of just throw his hands up in the air and continue along the lines of what he was already talking about.
	You testified earlier about the business of FSS and what you thought it was involved in.
	As its corporate representative, how do you describe the business of free speech systems?
	I don't think it is.
	I understand that the business of free speech systems is to produce the Alex Jones Show.
	It is essentially a one-man operation in that sense.
	He is the talent and was the original talent, and so the business is to produce the show.
	And you mentioned before there were 60 to 80 employees.
	Thereabouts at various different points, it's fluctuating.
	Did they have a personnel manager that you could go to find out who had what job?
	There wasn't anybody with that specific title, so the answer to that is no.
	The closest person that I tried to ascertain was a lady named Melinda.
	However, I believe she's really a bookkeeper, but she operated in that type of function, but there was nobody with that set job description, no.
	In the course of your observations there, were you on campus on days they produced the Alex Yes.
	And were you made aware at any point that there were editorial meetings that were convened to decide what would be covered?
	When I was...
	Based on your observations?
	I think you can answer based on your observations.
	Okay, did I observe any editorial discussions?
	I did not know.
	And did you find anything in the records that suggested there was an editorial function in the building?
	No, I didn't You were asked questions you were asked several questions in direct exam of about whether free speech uses Google Analytics and Yes, I recall those.
	And in spite of being shown, a number of exhibits That was the position that was conveyed to me.
	That's correct, yes.
	That they would use the Google Analytics in order to decide what to write?
	No.
	Do you have any reason to believe that ever occurs, Dominic?
	Objection is sustained.
	Is that why you kept answering they don't use Google Analytics by saying no?
	Right.
	You were asked questions about various logs that would record what was displayed when and where.
	Do you recall that?
	I'm sorry, can you repeat that?
	You were asked questions about the various logs and what was displayed or sent out to the world and when.
	Right, right, yes.
	At any point while you were at Free Speech Systems, did you see a record of what was completely produced from 2012 to the present?
	No.
	Did you see anything at all like that?
	No.
	Did you meet anyone who had a function?
	That would be to keep those records.
	Oh, okay.
	Nobody had a function.
	Do any of us really?
	No, I didn't.
	You met with Blake Roddy?
	I did.
	And he was an e-commerce individual?
	Yes.
	And you mentioned that you also spoke, I believe, to Tim Fruget?
	Yes, I spoke to Tim on the phone, and I believe I had another conversation with Blake on the phone as well.
	But did you ever meet Tim?
	I did not meet Tim, no.
	You mentioned that you traveled to the warehouse.
	I did.
	And you said the warehouse wasn't far from the studio or the business offices?
	No, it was like under 10 minutes.
	It was a large building?
	Yes.
	About the size of maybe three, three and a half football fields, correct?
	Sure, it was big.
	And you saw in that that they had a series of people, 10 to 12 At any given point, whose job it was to send out an email in response to orders, correct?
	Yes, I did. - Alex Jones didn't I did. - Alex Jones didn't serve as corporate representative on his own behalf.
	No, he didn't.
	Do you know why?
	Objection, Your Honor.
	Sustained.
	Do you think Alex Jones would have been a good corporate representative?
	Objection, Your Honor.
	Sustained.
	Do you know whether Alex Jones has ever testified as a corporate representative on his own behalf?
	I don't know whether he has.
	You were asked some questions about Aidan Salazar and something called Crisis Actors.org.
	Yes.
	What is crisisactors.org based on your investigation?
	Objective, Your Honor.
	Here, sir.
	Based on your account.
	What is it?
	From my understanding from just the review of the material is that it provides notifications if There's some type of listing for actors or crisis actors if there was a need for one.
	So if FEMA wanted to do a drill and they needed people to pretend they were injured, they could call them?
	Correct.
	Based on your observation of the records there and the material that you were able to review, did you see any indication that crisis actors responded to Salazar?
	I'm sorry, I don't understand.
	Do you see any records that crisis actors responded to aiding Salazar?
	Oh, after he signed up?
	No, I didn't see anything like that.
	You were asked questions about Dan Badandi appearing at a Freedom of Information Commission in Connecticut, correct?
	Or a Freedom of Information Commission hearing in Connecticut, correct?
	Yes.
	And you saw videos of that, correct?
	Yes.
	And you recognized those videos to You're standing at 30 Trinity Street in Hartford, correct?
	Yes.
	And the Freedom of Information Act is an act that permits the public to request information of a government agency, correct?
	Objection here on?
	Sustained.
	Did you do any inquiry of Mr. Helbig to find out what he wanted there?
	I did not review any of the materials that he submitted, so he submitted his own FOIA request and we didn't have anything to do with his submission, so I didn't review any of the material.
	Did you ever speak to Wolfgang Halbig?
	I have not.
	Did you ever try to speak to Mr. Halbig?
	I did not, no.
	This calls for a yes or no.
	Has Mr. Halbig tried to speak to you?
	He has.
	Most recently, while you were on the stand this morning, you lit up your phone.
	He did call me this morning, yes.
	Do you have any reason to believe that Mr. Hulbig currently has an association with InfoWars or Alex Jones?
	I don't know.
	Your Honor, let me have a sidebar.
	Sure. Sure. Sure. Sure. Sure. Sure. Sure.
	I think that there should be an instruction here, instructing the jury that that is the case given the testimony of the Justice Department.
	I think that's different than saying that as a result of it didn't evolve, we can't get tested.
	I didn't ask the question.
	I only asked.
	Does he still think it's in the looks of the problem?
	The answer is I don't know.
	No, no.
	I think he just asked, do they have any current associations?
	Do they have any current associations?
	Okay.
	Have they both heard and she goes, I don't know.
	I think she said no.
	I may be wrong, but not even one way.
	We both heard and we were.
	She said I don't.
	Are you moving on with that?
	That would be a good instruction to give him a financial.
	I am.
	I am working on the question I wanted to ask.
	I can't ask.
	So I think that you should put that in your proposed charge.
	Are you going to use this?
	No. H.C.
	All I can do.
	You were shown a video of the Dondi at the FOIC, and there was a banner on it, truthradioshow.com.
	Do you know whose banner that was?
	I'm not sure.
	And John, can you take that down?
	what's up there may have a moment judge can we see 183 again that is a full exhibit your honor thank you
	you should have down for a second
	thank you thank you thank you thank you thank you thank you thank you thank you thank you thank you
	All right.
	All right.
	It's up there.
	Take your turn.
	And can you blow up the text up the top there, John?
	All right.
	All right.
	This was an email that was sent from Scott Bronson, InfoWars employee, correct?
	Yes.
	To Robert Castaneda, correct?
	Yes.
	Another InfoWars employee.
	Yes.
	And to John Hanson, another InfoWars employee, correct?
	Yes.
	The first line says, Robert, here's the information we want to put on the affiliates one sheet we spoke about yesterday.
	I think you testified this morning that this was prepared in anticipation of soliciting advertising, correct?
	Um, I think what we said was the one sheet was for, to send to other radio affiliates.
	Right, and if there's any questions, feel free to ask John or myself.
	Thank you.
	And it's in three boxes of information, network overview, correct?
	Right.
	For the last 20 plus years, Alex Jones stood alone voicing the questions of the ignored, the forgotten, and unappreciated, correct?
	Yes.
	Did you reach any conclusions based on your review of the material that you saw down there, whether that's what Alex was doing in his mind?
	With the help of experts, whistleblowers, and insiders, Alex no longer stands alone.
	Did I read that right?
	Yes.
	He now has a vast network behind him.
	Did I read that right?
	Yes.
	With a range of guests like Ted Nugent.
	Who's Ted Nugent?
	I'm actually not sure who he is.
	Roger Stone?
	He's a media personality.
	Megadeth frontman David Mustaine?
	I don't know who that is.
	Director David Lynch?
	He's a director.
	Blue Velvet?
	I'm sorry?
	I don't know.
	Mike Judge?
	I don't know who that is.
	From Charlie Sheen's famous Tiger Blood rant to Donald Trump promising, I won't let you down, Alex.
	Your reputation is impeccable.
	I see that, yes.
	Alex Jones and Infowars is Infowars is no longer on the fringe.
	We are now the leaders in the new wave of media, correct?
	Yes.
	And can you go to the top of that, John?
	2018, that was written, correct?
	Yes.
	And you previously testified about noting the increase in page views from 2014, 15, and 16, correct?
	Yes.
	To your knowledge, did an event take place in 2016 involving Asked the court to take judicial notice that he was elected president in 2016. And you're objecting on relevance?
	Your Honor, I just think that what Jim Pattis is doing is quite transparent to try and get around the board.
	I don't think so.
	I think I'm well within the record.
	I'm going to have the jury step out for a minute or two so we can argue this.
	I should leave the part as well, Your Honor?
	I think that's probably good.
	Yeah, that's right.
	All right, turn to the PC.
	Wait, can the attorney pop you out of the room first, Judge?
	Yes.
	Oh.
	Sorry.
	Your Honor, I noted my concern at the outset of the oral argument.
	I said, "I remain concerned that Attorney Pattis is going to try and elicit hearsay testimony about the reason for this spike was.
	You looked at him and you said, he knows my orders.
	I don't think we're going to have that.
	And then three minutes ago, he asked the precise question.
	We all understood he was prohibited from asking, which was, Ms. Pattis, do you have an understanding as to what caused this fight?
	He then is going back to it now and has asked her, basically, by presenting the name Donald Trump in an exhibit, coming back to her and saying, what happened in 2016 was passed.
	So, what Attorney Pattinson's doing is, first of all, was frontally violating what we all understood he wasn't supposed to do there.
	And then when you sustained his objection, going back in a circuitous way, pulling up this to try and make the same point to the jury.
	And it was improper.
	There's nothing circuitous about using-- the objection was scope.
	So I found an exhibit today used.
	I found an exhibit that they read to the jury.
	I then used the demonstrative aid that they showed to the jury.
	I then showed the jury what they used to create the demonstrative aid.
	I asked her about this.
	I asked her whether the president was elected in 2016.
	I got an objection.
	I'm asking the court to take judicial notice about it.
	It is for the jury to draw reasonable inferences from the evidences.
	This is not evidence I produced in violation of a court order.
	If they were serious about these claims, they wouldn't have offered this.
	And it's not my responsibility to try their case for them or to anticipate their objections.
	This is fairly within the scope of what Attorney Paz was testifying about this morning.
	No, no it is not.
	There was no testimony at all, nor has there ever been that we have elicited about the 2016 election.
	There has not been.
	He's not wrong.
	No, but the jurors, I mean, he said the jurors are permitted to use their common sense, and the instruction is there are two types of evidence, direct and circumstantial, and you can draw any reasonable inference from circumstantial evidence.
	If it's too dangerous to tell the jury that a president who they introduced evidence about and has said flattering things about Donald Trump, apparently if it's too prejudicial to have them take judicial notice of civics facts...
	What are we doing with this jury?
	We've been treating them like a bunch of missiles.
	I just don't see how this is entirely...
	Well, I'll stand by my argument.
	My view is it's within the scope of the evidence presented, and because the jurors are entitled to use their common sense and draw every reasonable inference, this is not outside the scope.
	And I would renew my request to have the court take judicial notice of the fact that Donald Trump was elected president in 2016.
	So I will sustain the objection.
	It's all right.
	And the record will reflect.
	The entire panel has returned.
	Please be seated.
	I will give you thank you for your patience.
	If I forget to say it, please know that we are very grateful for your patience.
	And just so that you know, we are planning to let you go at 3.30, so it's just a little bit after 3 now.
	And we have some motions that we're going to argue, so we'll stay a little longer, but just around another In your review of Info4's emails, did it appear that people there were familiar with the normal customs of English language commas, periods, and so forth?
	You mean emails from the general public?
	No.
	The internal emails among people that didn't move forward.
	No, there was a lot of grammatical misspellings, mis-punctuation, so no.
	In the email that we've been looking at, Durant to Donald Trump promising, quote, I won't let you down now if your reputation is impeccable, end quote.
	When you reviewed that, did you attribute any significance I know what that's referring to.
	I've seen that statement before, so yes.
	Without telling us what you saw before, what significance did you attribute to those quotation marks?
	That it was a quote?
	From?
	From Donald Trump.
	may we see 471 please yes yes
	yes yes yes yes yes
	yes yes yes yes
	yes yes yes yes yes yes
	yes 471 I can't find 471. Alright, we'll move on.
	471 was a video, a recent addition to the exhibit list involving a social media report I believe for 2021 and in that email there was reference to Infowars being purged,
	the purge of Alex Jones.
	Do you recall seeing that email?
	I think so, yes.
	Based on what you have read from the records in the InfoWars Complex, not what anybody told you, but what you read and saw, the emails that you reviewed for this trial, do you have any idea what the purge that Alex Jones refers to?
	Sustained.
	Based on your review of the records, did Mr. Jones lose social media platform in the period 2016, 17, and 18?
	Yes.
	Did Donald Trump have videos taken down from sites such as YouTube in 2016 and 2017 based on what you saw?
	Objection, Art?
	Sustained.
	Now, you weren't asked many questions about Infowars finances.
	Were you given access to records involving its finances?
	Yes.
	And who did you speak to when you wanted to learn about Infowars finances?
	I just want their identities at this point.
	All of the people I've spoken to?
	Yes.
	Okay, so initially when I went down to Texas, I spoke to a gentleman named Bob Rowe.
	And most recently, I've spoken to Mark Schwartz.
	Who is Mark Schwartz?
	Your Honor, can you please stop by, please?
	Certainly.
	Thank you.
	This is well within the scope of direct.
	She was asked about this cash flow, and she said, I'm not sure I can ask.
	I can answer where these numbers come from.
	And I think they would choose as to what is this.
	What does it mean?
	Because he has to be a question.
	Right now, I'm asking you why.
	To the degree that they want to argue that, of course, I don't know if they're going to argue to this jury, they seem to be trying to argue punitive damages in a compensatory damage case.
	I think the jury is entitled to know that the Alex Jones Company Just out of curiosity, what are you going to do, move on?
	Yeah, absolutely.
	There's no point in that question.
	There's only one point, and it's in the proper one.
	So, sustained?
	I don't think so.
	I think the question was...
	Well, I'll be honest with you.
	I think it's in the briefing.
	No, I don't.
	Okay.
	If you're stopping in, we'd like to keep going to pause.
	The request will be to put on if this is traveling.
	We're not staying expected to go on.
	If you don't mind going past the briefing.
	You want me to talk and give me a proposal, but I just told you, and I'll leave it.
	Right, exactly.
	I'm going to be hours with my, if it's based on the .
	Right.
	Right.
	Well, you know, they have the ones that you're talking about, you're an expert.
	Yeah.
	I just don't want to go.
	Okay. - Talk and give me a proposal.
	and get me a proposal.
	Thank you.
	I'm not going to go past 3.30.
	What's the answer, folks?
	Did you forget?
	What's their answer?
	I didn't hear anything.
	Can I-- can you tell me what your proposal is?
	It's in your response, which-- Okay.
	And we're gonna let our jury go every third as promised.
	Should I, I didn't, I asked for a sidebar before, may I object now to that question or does the jury pass gonna move on?
	I think the court sustained the, I mean if you didn't it sure looked that way.
	I thought it was caught on the sidebar, your objection is sustained.
	Thank you.
	You offered testimony about Tim Fruget.
	Yes.
	Do you know whether he is a current Infowars employee?
	He's not.
	You were asked questions about daily sales reports that Fruget offered, or created, correct?
	Yes.
	Was there a file somewhere of all those daily sales reports?
	No.
	And I don't know if I asked this, did they even have a server that everybody had access to in that building?
	I didn't see one.
	But yet you saw a number of emails that came from the Infowars server.
	I did, yes.
	You were asked questions about Henry USA. I remember, yes.
	And Henry USA, you told us, was a gun manufacturer?
	I think that's what it is, yes.
	And you spoke about a second gun manufacturer that Infowars solicited business from, and I don't recall its title.
	Do you?
	I'm sorry, I don't...
	What was their, based on the records that you observed, what was their advertising based on, or where were they soliciting ads from?
	The time period?
	Fair enough.
	From 2013 to the present.
	And if that's too broad a period to be meaningful, tell me.
	When you say they soliciting, you mean free speech?
	Okay, I mean generally the base which they are soliciting from are conservative listeners and people who are interested in conservative politics and gun owners would tend to be interested in such a thing.
	Mayor, was that your response to a question about advertisers?
	I asked about the advertising base.
	Oh.
	You were shown an exhibit, I think it was 216, which was one of their media kits, and media kits I think it was 216, which was one of their media kits, and media kits were things that were prepared annually to solicit I believe so, yes.
	They referred to themselves as kings of their domain, correct?
	Yes, I think in multiple of those, that's how they...
	And ranked themselves in a Well,
	Al is not cooperating, Judge.
	Let me move on without it.
	Your Honor, there's a whole bunch of material being displayed that's not in that that's on the screen.
	Oh, sure.
	Can we shut that down?
	No problem.
	Sorry about that.
	You said you didn't know much about Glenn Beck?
	Not really, no.
	Do you know that he's a conservative talking head?
	I think he is, yes.
	I've never listened to his show.
	Did you know that Rush Limbaugh is dead?
	I didn't know that.
	Did you know that when he was alive he was a conservative talking head?
	I did know that, yes.
	And you were asked about, oh, I can't remember, One American News, and you described that as a conservative outlet, correct?
	There's no question about American News.
	I thought there was.
	Newsmax.
	Newsmax.
	It was Newsmax, yes.
	That's a conservative about that, correct?
	yes I'm here we got it up thank you WMD calm you know what that is WMD no Okay.
	But is it fair to say that in this chart, what they were doing is they were situating themselves among other conservative outlets to say to advertisers, hey look, come to us, we'll get you a bigger bang for your buck.
	That's what the intent appears to be.
	You were never able to speak to Owen Schroyer?
	No, I didn't speak to him, no.
	How many times did you try?
	I don't think I called him.
	Why not?
	Time.
	For the most part.
	Is he a defendant in this case?
	He...
	I think he's a defendant in the Texas cases.
	You were shown emails from Paul Watson, in particular an email at 160, that Watson was opposed to the lies of Sandy Hook.
	At three years, this is how my adversaries characterized him, three years after shooting, you know, there was another email, correct?
	I remember those emails, yes.
	And you mentioned that Anthony Cacciardi was an employee?
	Yes.
	In fact, he was a consultant and not a direct employee.
	Does that refresh your recollection?
	I'm not sure if he was an employee or a consultant.
	I'm sorry.
	I don't know.
	No one at InfoWars had any idea how many times they had uploaded material either in whole or in part regarding Sandy Hook.
	Sustained.
	You are unable to determine based on your review of the records how many times InfoWars Right.
	Did you contact YouTube?
	No.
	Do you know, as you sit here today, whether YouTube destroyed those records?
	Do you know?
	I don't know.
	I don't know if they still have them.
	I have just one minute, Judge Judge Emerson.
	I'm scanning my notes.
	take your time please now you in your review of the records at InfoWars did you find a copy of the state's attorneys report mr. Sedensky's report I believe I saw a copy of it.
	Yes.
	And Mr. Sedensky, just so the jury knows, he was, at least at that point, the head prosecutor in Danbury.
	Yes, he was.
	And the state of Connecticut is divided into what are known as judicial districts.
	Yes.
	Steve was the top prosecutor in the judicial district of Danbury.
	Yes.
	And he was asked to compile and did compile a lengthy report about what happened at Sandy Hook.
	Yes.
	And that report appeared how many months after the shooting?
	I want to say it was about close to a year later.
	Where was that copy of the Sandy Hook report when you saw it?
	I recall we saw the email with the link to it.
	I don't know if the link worked, if it was a link that you would be able to click, or if the report was just amongst the documents.
	I don't recall which one I saw.
	In your review of the files, you've seen videos of Alex sitting at a news desk, correct?
	Yes.
	And behind him was a The testimony that on the table in front of him there would be a series of printed out news stories?
	Yes.
	Do you know what, did InfoWars have a practice of saving the stories he commented on on an individual day?
	You mean the papers?
	Right.
	No, they didn't.
	Do you know what, based on your review, based on your time down there, did they just throw them away at the end of the day?
	Basis.
	Basis.
	Very good.
	I didn't say that.
	I said basis.
	Basically, yeah, they just threw it away.
	Any filing system down there relating to the editorial function?
	No, not that I could discern.
	Any library of videos?
	Their library was YouTube.
	Anyone tasked with the responsibility of keeping a complete record of what they said, when they said it, and who they sent it to?
	No, at some point they made an attempt to...
	Objection, Your Honor, for your sake?
	Based on the records you reviewed, were you able to determine whether they ever made such an effort?
	They made an effort at some point.
	They started making an effort by making the logs, but aside from those logs, no.
	And you went down there looking for that stuff?
	I did.
	With Attorney Blot?
	Yes.
	Nothing for judgment.
	Don't worry about that.
	There was one other question I had, Judge.
	I'm sorry, may I?
	I think so.
	I think at 477, that's an exhibit that was offered today.
	Can we put that up?
	Yes, 477.
	Judge, we're going to need assistance on that.
	That's a late addition.
	May we ask our colleagues?
	What is it that we're being asked to do?
	Can you call up 477?
	It's a late addition, if you don't mind.
	You have to do that tonight.
	Thank you.
	That's a full run.
	Today.
	We can display it if you'd like, please.
	Definitely.
	I think there was some writing at the top of that when I first saw it.
	No, it was not a bid with anybody.
	Okay.
	You've not seen this before today?
	No.
	Based on your observations down there, do you believe that Alex has contempt for courts?
	Objection, Your Honor.
	But in the videos you reviewed, the documents you read, do you believe he has contempt for the American court system?
	Objection.
	Sustained.
	Do you believe, Mr. Jones believes, that there is a crisis of legitimacy in this kind of reaction?
	Objection, Your Honor.
	Sustained.
	Nothing further.
	Your Honor, just for Ms. Paz and counsel, we're going to display 480.
	Thank you.
	I don't think I've seen this one yet.
	Ms. Paz, do you see 480 for you?
	I do, yes.
	Okay, do you see a Bates number at the very top?
	Oh yes, I see this.
	Okay, and that Bates number starts with the letters FSS, correct?
	Yes.
	It stands for free speech systems, right?
	Yes.
	You've seen many, many documents with that prefix and number after, right?
	I've reviewed a lot of material that have a Bates stamp that starts FSS and other numbers after.
	Right, and when Free Speech Systems produced documents in this case, it identified documents by including a Bates number so that everybody could track what documents were being produced.
	Correct, right.
	And looking at that document there, that is a organizational chart that Free Speech Systems produced in this case, correct? - Objection, when?
	And when was it created, Judge? - I'm asking the witness.
	This is Free Speech Systems witness. - I don't know when it was created, but it appears to have a bait stamp on it.
	Right.
	I'd offer, Your Honor.
	Foundation, when?
	You know, Ms. Paz, that this was, because it has a bait stamp, the number of free speech systems with the bait stamp, or that it was produced in this case, correct?
	It has a bait stamp number, so it was produced.
	Yeah.
	Go offer.
	Foundation, what period, when?
	Look at the bottom tab, Ms. Post.
	Do you see that there are several years there with organizational charts for several years?
	I see dates at the bottom.
	What are the dates you see?
	I see 2012, 2014, 2015, 2015, 1, 2 in parentheses, 2016, and 2017. Okay.
	I'd offer your honor as organizational charts of free speech systems for those years.
	Hearsay, Judge.
	We don't know who created it.
	We can see it was given up, but was it a consultant?
	On our testimony, it's not.
	There's no foundation.
	Okay.
	Would you please pull up the exhibit, please, Patika.
	Thank you.
	Ms. Potts, you testified, I think it was in the first five minutes of your testimony, you testified that there are no organizational or flowcharts of free speech systems, correct?
	I've never seen this before.
	Right, right.
	But you didn't testify I don't know whether there are any flowcharts or organizational charts.
	You testified there are none, correct?
	I did not see any.
	Right.
	No, I understand that you didn't see any, but if you didn't see any, then it would seem that the accurate testimony would be that you don't know if there are any, right?
	Well, I don't know if this was produced in preparation for the litigation, so I don't have anything to suggest that there were, and nothing in my review suggests that there were.
	Okay.
	So that was my testimony.
	Okay, but you acknowledged that you didn't review every document that was in your Dropbox, right?
	This was not in my Dropbox.
	How do you know?
	Because all the information that was in my Dropbox had Texas bait stamps on it.
	I see.
	This is going back to you saying you couldn't even tell whether you reviewed any documents in Connecticut, right?
	That's correct.
	Right.
	But if it was produced in Connecticut, it was produced by Free Speech Systems lawyers, correct?
	One of the lawyers.
	Right.
	Whomever that was.
	Right.
	Well, and Mr. Pattis has been a lawyer for how long?
	I'm not sure when he started, but sometime.
	Okay, well, he was the lawyer back in 2018, correct?
	Objection.
	It's not true.
	As I said, I don't know the dates.
	What about 2019?
	I'm not sure when he was retained.
	Okay, all right.
	But Mr. Pattis, free speech systems lawyer, stood up here after this document had been produced by his client, and the first question he asked you was whether there were any flow charts or organizational charts, right?
	I heard the question.
	And you said no, right?
	Based on what I had reviewed, I hadn't seen anything like that.
	And he didn't correct you, did he?
	I don't think so.
	Okay.
	Well, let's go to 2017. Do we have that up?
	Do you see that?
	The flow chart?
	Yes, I see it.
	Okay.
	And who's at the very top of free speech systems?
	Alex.
	Right.
	Okay, and then you have right below in a box titled Executive Admin.
	What's that name?
	Dr. Jones.
	Okay, so that's David Jones, right?
	Right, that's David.
	Alice's dad?
	Right.
	Okay, and then next on the list is Tim Fruget, right?
	Underneath Sales and New Product Advertising.
	Yes, I see it.
	Okay, right.
	And do you know who Patrick is?
	I don't.
	Okay, do you ever speak to somebody named Patrick Riley?
	I don't think so.
	You know who that is?
	Okay.
	No.
	And then you come down, on the left side here on finance, there's Lydia, right?
	At the top of the finance department?
	Yes.
	That's Lydia Hernandez?
	Yes, she's not there anymore.
	Right.
	And below her is Melinda, and that's the Melinda who you were just talking about earlier.
	Right.
	And you said, in response to one of Mr. Pattinson's questions, there's no HR person that you know of, but that Melinda kind of does that role, right?
	Kind of.
	I believe she's a bookkeeper, but kind of.
	Okay, okay.
	And then going down further, if you can kind of just pull it out a little bit, Pratika.
	Thank you.
	Okay.
	There are a series of departments that are listed out there.
	You have personal assistant Stephanie on the left.
	That's Mr. Jones' personal assistant.
	Yes?
	I'm sorry, where are we looking?
	I'm sorry, it's a little bit confusing.
	I'm kind of in column H here, where you see personal assistant on the left-hand side.
	Oh, okay, I see it now, yes.
	Is that Alex Jones' personal assistant?
	I'm not sure.
	And then over here you have households, Sarah and Samantha.
	Yes.
	Those are two household employees for Mr. Jones?
	Yes.
	Are they paid out of the company?
	I don't know.
	Okay.
	And then we're looking at these departments down here.
	If we just read left to right, we have procurement, inventory, right?
	Yes, I see that.
	Operations, yes?
	Yes.
	IT? Yes.
	You have a programmer, correct?
	Yes.
	You have graphics design, correct?
	Yes.
	Writers, editors, moderators, yes?
	Yes, I see that.
	Okay, and you see production over here?
	I see that, yes.
	Okay.
	Now, Ms. Paz, I know that you at different times haven't been sure which depositions you read, but did you read Kit Daniels' deposition?
	Did I read Kit's deposition?
	I may have.
	I know I spoke to Kit.
	But you don't recall whether you read his deposition or not?
	I don't recall if I read his depo.
	Okay.
	Well, Your Honor, we made a deal with the jury here.
	It's 3.30, so I don't want to keep anybody past where we are.
	I do have more redirect, but we'll just finish that up on Tuesday.
	I think that's a good idea.
	Thank you.
	So, we are not going to see you until Tuesday.
	You now have three days to make sure that you avoid any and all media coverage of this case.
	And, of course, three days where you cannot give in to any temptation that you might have to go online, look anything up, or anywhere else.
	So no research, no media coverage, and no discussing anything that's transpired Friends, or if you go to work on Monday, anyone ever.
	Alright, so I know you'll honor those rules.
	I hope you have a wonderful weekend, and Monday we will see you Tuesday.
	We will plan starting right at 10. Reminded
	me at 3.30.
	I lost track of the time, and I did promise them 3.30, and I did not.
	I wanted to keep my word.
	I just received some criticism from my team and branding too early, so I appreciate you saying that.
	Well, no, once I tell them, I want us to keep our word.
	So we have the issue.
	We haven't taken our afternoon recess yet, so I don't know how.
	I'll talk to Mr. Ferraro and our monitor in a second, but don't we want to deal with the For the 10th time, the FSS PQPR issue.
	Is this a good time?
	This is a great time.
	All right, so just give me one moment, please.
	not a monitor.
	Can I get just, can you give me an idea of how long you think the argument will take?
	I just, I don't, I want to.
	We didn't have our afternoon break.
	If it's going to be short, I think we could probably skip it and just end for the day.
	But if you think it's going to be a longer argument, then we have to take an afternoon recess.
	You're right.
	I don't think this is long.
	Attorney Patis?
	I don't know what you're going to say.
	I told you earlier I rely on my papers.
	So unless something surprises me, I'll agree.
	Okay, so why don't we try to see if we can do it and then adjourn for the day.
	So this was originally our motion to propel.
	The spreadsheet, excuse me.
	I'm back on the last motion, Your Honor.
	Right, and just so that I don't miss anything, I'm going to follow the same exercise.
	If you could just give me the name, date, or entry numbers, and I want to get it from both sides so that I have everything.
	Okay, that is gonna take a moment, Your Honor.
	Okay.
	I had the original motion for order at 926, I think.
	Okay.
	I have the document.
	Okay.
	That's correct, Your Honor. Your Honor.
	Sorry, I'm not standing.
	Motion for order at 926. And then I think I have Attorney Pattis, your brief, just give me one second.
	At 982, filed on September 14 or no?
	Yes?
	Okay, and are those the only two documents that I'm looking at?
	No, Your Honor, there's a reply brief at document number 942. Yes, I see that.
	948, September 2nd.
	Then, Your Honor, you entered an order permitting an affidavit to be filed.
	And I'm just looking for the docket number of that order.
	And that order permitted the docket affidavit to be filed, I believe it was Thursday of last week.
	that's correct all right is that everything No, Your Honor, then the affidavit was filed eventually.
	That was filed on September 14th.
	That's the one that I referenced, 982. So clearly I'm going to consider it even though it's sleep.
	It's not a problem.
	That's understood, Your Honor.
	And that is actually the reason why we need to have arguments.
	Because so where this started was that there was testimony from Lydia Hernandez, Free Speech Systems accountant.
	And from Alex Jones regarding the existence of a management agreement between PQPR and free speech systems.
	And what this goes to, I know Your Honor has heard argument before about PQPR, but the dispute between the parties is that the defendants claim that PQPR is an actual independent entity.
	The plaintiffs disagree with that for a number of reasons, including the fact that the best evidence we have so far shows that PQPR is wholly controlled by the Jones family, has no employees,
	and revenue that is supposedly And so what was produced,
	that memorandum of understanding that was all redacted?
	So that, Mr. Schwartz's affidavit indicates that, in his understanding, that's not a memorandum between the two companies.
	So he says, in other words, that's not it.
	And the other thing that is attached to his affidavit, and this is, so he produced two things attached to his affidavit?
	Yes.
	The first is a 2007 document concerning free speech systems corporate organization.
	That document is responsive to discovery requests that we made in January of 2019. So that has never been produced to us before.
	This is more of the same in terms of shortcomings in production.
	Then turning on to what was attached at the end of the document, Mr. Schwartz's affidavit, the current CRO, says that's not, in his understanding, a memorandum of...
	I'm going to get my...
	Yeah, it's not a management agreement.
	That's what he says.
	So what is given to us is a document that should have been produced.
	I mean, that final attachment exhibits...
	But his affidavit says he doesn't think there's a management agreement.
	Your Honor, it does say that he doesn't think there is any management agreement based on review of the files, but the overall picture is that there is testimony that there was.
	There's more documents that were withheld.
	And once again, we're in a position where we were trying to take discovery on this issue, and we just don't have the full record to work with.
	How could we cross-examine witnesses on the existence of On their claim that this entity exists without these documents.
	I understand exactly what you're saying, but wouldn't this require an evidentiary hearing?
	How do we know that Ms. Hernandez was not referring to the Memorandum of Understanding or Mr. Jones?
	I mean, it might actually be that there is no management agreement in existence, correct?
	It is possible that there's no management agreement, but the difficulty here is, look how far we are.
	We're just finding documents that were not disclosed to us previously.
	This just can't be happening in the middle of trial.
	And yet it is.
	And yet it is.
	And so we've been prejudiced on the exploration of this question about whether PQPR actually exists as an independent entity.
	There's no question about the prejudice based on this record.
	Right, so essentially Mr. Jones and Ms. Hernandez testified to the existence of a management agreement, but Mr. Schwartz couldn't find one.
	Mr. Schwartz indicates he couldn't find one.
	Right.
	Mr. Schwartz then gave additional documents.
	That should have been, I understand that should have been produced, wasn't produced, but so what you have is Mr. Schwartz saying, I can't find it, but you have Mr. Jones and Ms. Hernandez testifying that there was a management agreement.
	That's correct.
	Attorney Pattis?
	The best thing that's happened to me in the three years that I've been in this case, in spite We're trying to create some internal management accountability.
	It took months to get that done.
	I would be in a better position for a management agreement because that would support an independent relationship between the two things.
	Frankly, the plaintiffs are better off without one.
	That supports their argument that they're not suffering these things.
	I think this goes to its weight rather than its admissibility.
	If the court wants to have an evidentiary hearing, I think for lay people, the difference between a management agreement and a memorandum of understanding might not be that significant.
	As to the claim that we should have produced it a long time ago, yeah, we should have.
	You've heard a little bit about the situation down there.
	You'll do what you're going to do.
	I'll rely on my papers.
	I'm just trying to figure out, Mr. Pattis, why should...
	Because I've heard your arguments, I listen to your arguments, I read what you file, and there's a picture painted of, you know, sort of a lack of record-keeping and structure and And it seems almost like the defendants are asking to benefit from that.
	Let me just finish.
	What I have is Mr. Jones, who is in charge, and Ms. Hernandez saying that such a document existed.
	And not surprisingly, poor Mr. Schwartz comes along and can't find it.
	All I can say, Justice, is if you think getting ourselves into a default position benefited us, we see the world differently than I do.
	The failure to provide simple answers to simple questions on a consistent basis from one month to the next in the same case has been my client's undoing.
	You gave me the opportunity to get an affidavit.
	I got it.
	It speaks for itself.
	I would ask the court to not enter additional sanctions.
	At some point, the plaintiffs should be required to prove their case on the merits.
	From the day I got involved in this case, everything was an emergency.
	This had to be done in a hurry, and there's been a false sense of urgency attending this case from day one.
	We're here now.
	I actually don't think the plaintiffs are prejudiced by this.
	this, I think they'd be prejudiced if I came up with a management agreement that tended to show independence.
	In fact, I now have somebody who's looked and he says there isn't one.
	Whether his opinion, I don't think he can have an opinion that this is what the declarants were talking about, meaning Mr. Andes and Mr. Jones.
	I think it's supposed to weigh better than that.
	Well, I'm just sort of left to guess as to whether Mr. Jones or Ms. Hernandez was in fact, they were mistaken and they were actually looking at the MOA instead of a management agreement they were mistaken and they were actually looking at the and I shouldn't be left in that position.
	I'm not going to rule today.
	It's late in the day.
	What are the plaintiffs asking for?
	I'm not saying you're getting it.
	I just want to know what you're asking for.
	May I respond briefly to what Attorney Pettis said?
	Sure.
	Your Honor, there has been sanction after sanction after sanction, and the notion that non-compliance It just makes no sense at all.
	And I just want to say that there's no suggestion that it's attorney tax.
	Your Honor, that is correct.
	That is correct.
	So, what we are requesting, Your Honor, is the response to what we were precluded from taking full discovery on, which is what we're requesting as that the defendants be not permitted to argue or present evidence.
	That PQPR is a distinct entity from free speech systems.
	What we were trying to explore is their claim that those are separate entities and so what they should be prohibited from doing is claiming that they are separate entities.
	Alright, so I will Take a look at it over the weekend.
	Anything further?
	All right, so Attorney Pat, as you wanted, some additional briefing.
	I don't want to be, and I've got a very busy Monday, but I'll make time with other matters, you know, a lot of other matters.
	So if you can just tell me.
	Give me a time so I can go in.
	I'm sorry additional-- Mays being to the attorney and Sterling?
	Oh, my gosh.
	Not a message.
	The claim is this was filed by the defendants yesterday.
	I responded this morning given some of the rulings and the evidentiary issues.
	I'd like to add two or three pages to make a better record.
	Your Honor, I think it would make sense for us to respond in writing to what the defense filed today.
	I think that might be helpful to the court.
	So with the court's permission, we'll also file something on that issue.
	Okay, can you do by noon?
	Yes.
	Okay, very well.
	Is that it?
	Yes.
	All right, have a nice weekend, everyone.

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