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Oct. 6, 2022 - Depositions & Trials

04:48:04

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

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	Good morning, Your Honor.
	Good morning, Marshal.
	Good morning, Your Honor.
	All right, we are here in Lafferty v. Jones, week four, day 15.
	If Council could identify themselves for the record, please.
	Good morning, Your Honor.
	This is Maddie, joined by Alamor Sterling and Josh Koskoff on the half of the month.
	Good morning, Your Honor.
	I'm going to get with Norm Pat tonight, Zach Ryan with you this morning.
	Good morning.
	All right, so I want to see what we need to do before we bring the jury out.
	I have 11 issues that I want to go over with the charge.
	None of them are really major and I did lose sleep over the jury verdict form so and I did see the plaintiff's motion and I am going to readdress it because I would say first of all that the The verdict form that I got included language that I had not intended to include.
	I had said, and I know we did it off the record, which is probably the only thing we've done off the record, as to each count.
	And I think you added more language than that, but I want to readdress it anyway because I'm just not comfortable with it.
	So do you think that we should maybe take 15 minutes, try to go through the issues with this draft?
	Before your close?
	If they're going to materially change anything, yes, but if not, I'm here to go.
	And I don't know about the verdict form, if you need that.
	I defer to counsel.
	Can I speak to Attorney Maddie?
	Yeah, or we could just take 10 minutes and see if we wrap it up.
	I mean, I really want to defer to you because I know you're ready to go and you're close.
	Your Honor, whether it's now or 10 minutes from now, I think I'd prefer, especially if these are issues that everybody's thinking about, I know we briefed it, to see if we can just resolve that.
	Why don't we put, Ron, let me know in 10 minutes and let's see where we are because I don't want to keep them waiting too long.
	So I'd like to go over my minor issues first.
	So that you're not surprised when you're reading along that I'm saying something a little different and then if anyone else had any corrections to the charge and then we'll do the verdict form, okay?
	Your Honor, while you do that, since Attorney Sterling is taking the lead for us on the charge, would it be okay if I just caucus with Ms. Ashadri while you do that?
	I don't see why not.
	Thank you.
	Alright, so my first change, since I think I had started off with role of judge, role of jury, And you guys switched it around and put hearing and damages first, which is fine with me.
	I'm simply going to move the first sentence that starts, ladies and gentlemen, of the jury under role of judge, role of jury, and I'm going to start with that sentence.
	Just didn't flow because I was taught.
	Do you understand what I'm saying?
	No objection.
	Yes, Your Honor, no objection.
	The second issue...
	Is on page four.
	I don't recall, listen, you can refresh my recollection, but I don't recall entering, admitting any evidence for a limited purpose.
	Did I? I objected to an email that a free speech employer responded to on the grounds of hearsay and that item was offered for contact on the listener.
	You're correct.
	I'll leave the sentence in.
	So I had a little trouble with some of the formatting because it was still a draft, but on page six.
	This is the corporation or other entity charge?
	Yes.
	That was acceptable language?
	Yes.
	Okay, then we can move on.
	Page eight.
	The second sentence?
	Yes.
	That's acceptable language, Attorney Pattis?
	I thought we bargained hard for that.
	Yeah, yes.
	Okay.
	Page 13, the use of deposition.
	I thought we said that since I said it so many times that we weren't going to charge on it again.
	Do you want me to leave it in?
	Take no position on it.
	It doesn't matter to me either.
	Your Honor, I thought use of depositions was, oh no.
	Sorry, on page 13?
	Page 13. Hold on.
	Use of depositions?
	Do you want it in or not in?
	We take no position, Judge.
	I can just leave it in.
	it doesn't matter.
	Page 15, first sentence under clause of action, I didn't understand it. first sentence under clause of action, I didn't understand it.
	Can we reword it?
	that is just a little easier to follow.
	How about the defendant?
	The defendant had been found liable for the following violations of the plaintiff's legal rights.
	I mean, maybe they each defended each plaintiff.
	Maybe that's what, the defendants We have been found liable for the following violations as to each plaintiff.
	Is that what you said?
	Violations of the plaintiff's legal rights or violations as to each All right, so why don't we just go with this?
	The defendants have been found liable for the following violations of the plaintiff's legal rights, okay?
	Could we say, Your Honor, of each plaintiff's legal rights?
	That seems to work.
	Attorney Pattis, you're on board.
	I thought it was fine and it was just a little awkward, So
	the only question I had on page 24 is the use, and I know we went over this and we were okay with it, but in light of the verdict form, I'm not sure we need to say non-economic damages.
	I'm just thinking that we say, instead of saying non-economic, last sentence on page 24, instead of saying non-economic damages are monies awarded as compensation, Something along the lines of the compensatory damages that you are addressing or considering?
	Because we're saying non-economic damages and usually on averted form you'll see economic damages, non-economic damages.
	We don't have that on averted form and it's just confusing.
	Why not just eliminate the term non-economic and make it start with damages?
	It's in the compensatory damage and structure.
	But it's confusing as you go on in the sentence if you just say damages.
	All right, so why don't I say the compensatory damages that you are considering here, okay?
	Okay.
	Page 27, the last sentence, I just added in a couple words.
	So you should include both damages for invasion of privacy and damages for other emotional distress suffered in your award.
	Of emotional damages, so I just added that just so you know, so you don't think I'm reading it wrong.
	Page, we're almost there, page 29. Your Honor, we had an issue on page 28. On my copy, it's on the bottom of the page.
	Nominal damages may be awarded because you find, and we think it should be if.
	I agree.
	Yeah, I do too, actually.
	Okay.
	Mark the date and time.
	Yeah, we didn't agree with you.
	I just wanted to make a buck in here in the end.
	Well, if attorney cops got some white doors, I'll change mine.
	All right.
	So page 29.
	Can you read the last?
	So the last sentence, Adam, at a minimum, I'm going to change to Adam, minimum.
	Each plaintiff is entitled to nominal damages of at least one dollar I like that sentence better, but the sentence before that that says to summarize, can you both sides read that and tell me if that's correct?
	If that's the language you agreed on?
	I had, my draft had a lot of scribble scrabble on it, on that area, and I just...
	Can I just speak to the attorney?
	It starts to summarize, so...
	Yeah.
	Your Honor, our proposal had been to take that sentence out.
	We thought it was...
	Confusing because it's going back to this idea about the difference between defamation and defamation per se, which isn't in the case.
	So the sentence that says, to summarize, delete it?
	Yes.
	And then just continue on, you may award punitive damages?
	Yes.
	All right, I think that's what we did because of...
	It is what we did.
	My notes reflect it.
	Yeah, my notes had it crossed out too and so on.
	Yeah.
	Well, thank you, Your Honor.
	My scrivening wasn't perfect.
	You did the heavy lifting on it, so thank you for that.
	All right.
	Under suggested amount of damages, I'm going to add a phrase, and that is permitted under our law.
	So the first sentence of that is going to read, in closing argument, if Council does do so.
	In closing argument, Council mentioned some formulas or amounts that might figure in your verdict.
	And that is permitted under our law.
	I am going to add that if it is argued by either side.
	Thank you, Your Honor.
	And then, Paige, this is my last issue before the verdict form.
	I'm going to add a phrase when we're talking about the jury asking for playback and such.
	Something along the lines, if you need to re-watch any video exhibit, please follow the same procedure because I didn't know you were putting chips in or something.
	We don't have a machine in the jury room.
	So that if they want to watch a video, they'll send in a note.
	And then I don't know if Mr. Farrar talked to you about this.
	He had a really good idea.
	Thank you, Mr. Farrar.
	At least I thought it was a good idea of like a sheet that you look on for the plaintiffs of all the listed exhibits so that if they want to get to something because they have so many, they can just look at the cover sheet and get to it quicker.
	No objection.
	Okay.
	No objection, Your Honor.
	All right, so Mr. Farrarar, when that's done, you'll give it to Council and we'll obviously have you look at it before we send it into the jury room.
	Okay, so The last and certainly not least thing is the verdict form.
	I did lose sleep over it but here we are.
	So I'll briefly hear from the plaintiff but I just have to say I did not intend to include the cause of action language.
	I just wanted to add the as to each But I am reconsidering whether the rest of that phrase and your verdict must be unanimous as to each cause of action should stay in because I do think it is confusing and once I reread the whole charge I don't think it's a good idea, but I'm going to hear both sides on it.
	Unless this is something you want to take up after you close.
	No, I think we need to do it now, Judge.
	Okay, absolutely.
	Thank you, Your Honor.
	You're not the only one who lost sleep over this one.
	I have my six-point argument, but I'll be brief.
	And we don't...
	As written currently, is consistent with the law or the law of the case, and it definitely conflicts with the charge.
	I think the court seems like may have – Your Honor may have figured that out also last night, but I know we did.
	The court's been telling the jury from the beginning of jury selection that it's their job to determine the extent of damages only, not what caused them.
	Not whether they resulted from violation of cut-bow or defamation per se, or intentional infliction of emotional distress, or false light, invasion of privacy.
	We, at least on the plaintiff's team, do not understand the charge – what's written.
	We don't understand what we are asking the jury to do.
	And of course, I suspect that our confusion is shared, at least in whole or in part, by the court.
	And the jury, quite frankly and simply, should not get an instruction to do something that the lawyers themselves do not understand and that the court and the lawyers find to be Uh, just two more, three more quick points.
	So your proposal is to delete the entirety of the language?
	It is, Judge, because I think that's the, it's consonant with, with the law and it's, and the charge.
	And, you know, with word of worms, less, because less is, is more if it's straightforward.
	Uh, I would just add my other We could probably expect a question about what it means, but even if we didn't, then we'd have to quite wonder exactly what they did with the language, since we can't really seem to understand what it asks of them.
	But I think the court's there already.
	I think that is pretty much it, in light of what the court has indicated.
	I have more, but I think I was more speaking against.
	All right.
	Attorney Pattis?
	I'm relying on language primarily from the state lead, Mephoshvili, which dealt with the question of specific unanimity and how to treat it with respect to the self-defense charges.
	And I realize this isn't a criminal case, but the analogy I think is apt.
	In State v.
	Mancoshvili, the Supreme Court held a specific unanimity charge as to the elements of self-defense was not required because that was not part of the state's case in chief.
	It was an affirmative defense, and the jury could mix and match its votes.
	Under the law of self-defense, there are four factors that people consider.
	If the jury finds unanimously that the state has rebutted it, there's a conviction.
	And the jury need not agree on all four elements.
	And the reason for that is it's an affirmative defense.
	We lost the right to present any defenses as a result of default, and we're here under a regime in which the plaintiffs have to prove such damages as they can obtain beyond nominal.
	And so although there's been a default as to liability, it remains the plaintiff's burden to prove the extent of damages.
	And so from our view, State v. Meckler-Feely is powerful authority in this instance, and we think that there needs to be unanimity as to the account.
	Otherwise, we'll be left wondering how the jury arrived in a complete summit.
	Sorry, I think we really just need to pull up this case if we're going to be arguing from a dissent.
	We didn't even hear it.
	Would counsel please restate the case and maybe give us the side?
	It's state versus...
	I'd like to just argue this case.
	This was decided yesterday, but if the court's going to reconsider, fine.
	State versus Mekoshvili.
	M-E-K-O-S-H-E-I-L-I.
	It's a Connecticut Supreme Court case that was decided within the last three weeks.
	I know it because I already did it.
	Well, this, I mean, I'm trying to read it on the fly here, Judge, but I think, you know, there is a clear distinction right off the top in that, and Mr. Pat has identified this, one deals with the liability of a criminal defendant, the liability, you know, No, I have to say, I don't need...
	To hear anything else.
	I agree with the plaintiffs on this.
	It was not good the way that we left it.
	I did lose sleep over it.
	So I am going to strike that language.
	I understand, Attorney Pettis, that you will take exception with that, as is your right.
	However, I would consider, and we don't have to do it now, if we can come up with some appropriate language to add to the charge a sentence or two to clarify I'll consider it.
	We don't have to do it now.
	All right, when I'm going over the verdict forms, I could perhaps remind them that they need to be unanimous on their determination of the amount of damages, but it's not something that needs to be done now.
	Your Honor, can we circle back and just for clarification, do you want to do that after we are, now that we have that settled, I think that's alleviating to the plaintiff.
	So, do you want us to circle back on the language now?
	You can reach a consensus or if either side wants to propose a sentence or two to add to the charge when I'm describing the jury verdict form or discuss it.
	Okay, well, maybe we can discuss it.
	We understand that we don't agree, but maybe we can discuss it at a break and say...
	That's what I'm saying, after you close.
	And it may be that no additional language is added.
	Attorney Patis may propose a sentence or two that's acceptable or...
	That makes sense to the court, even though you may not agree, but let's leave it there so we can get cracking.
	All right, any other housekeeping issues?
	Nothing for the defense, Judge.
	Okay.
	And just as a – Ron, you can get the jury.
	Folks in the gallery, in accordance with judicial branch policy, there are no photographs or filming permitted unless you have been Specifically authorized to do so.
	Also, triple check everyone and make sure any device is not going to sound.
	There will be repercussions if any device goes off during any of Council's closing arguments.
	So please triple check.
	Thank you.
	Good morning.
	Good morning, everyone.
	On this sunny Thursday, we had some good weather today.
	Please be seated.
	Council will stipulate that the entire panel has returned promptly on time and in good cheer as always and we're very grateful for that.
	So at this point, as I promised, we are going to turn to the closing arguments of Council.
	You'll note, you will not have your notepads for the closing argument because it is not evidence, nor will you have your notepads later on in the day when I give you the charge of the law.
	Okay?
	So you'll just Uh, give your attention to Council, starting with Plaintiff's Council, whenever you're ready, please.
	Take your time.
	Ron.
	Do you want time reserved?
	Oh, yes, yes.
	Um...
	Beg your pardon?
	Okay, Mr. Farrer, you're on top of that?
	Yes, sir.
	Right?
	whenever you're ready counsel thank you very much good morning everybody very happy to be able to have this opportunity to speak with you this one And I know that the families that you see here who have been here every day are very, very grateful to you for your attention and your concern throughout these weeks.
	I think we've seen just about every aspect of the human experience that I'm displaying in this corner for the past several weeks.
	And if you're like me as you've been listening to the testimony, there may be moments where you found yourself drifting to thinking about your own things, your own experience, what's important to you in your own life.
	And in opening statements, I told you that you had everything you needed to make your decision in this case because you're human beings.
	You understand what that means.
	to understand what's important in your life.
	Your parents, your children, your grandchildren.
	How you spent your time building a life for yourself, an identity.
	And there's some very basic principles that I think all of you understand.
	That you learn as kids, teach your children, teach your grandkids.
	Things that you know even though all of you are in different stages of your life.
	Tell the truth.
	Don't hurt.
	Especially when you're down.
	Stand up to bullies.
	Bullies won't stop, especially if being bullied makes them very, very rich.
	All of these things, if you know, But there are some things that you probably learn.
	Things that I didn't even appreciate until I sat through the testimony, and that is how far and wide and deep a lie can spread.
	Especially when it has the machine behind it to push it for years and years.
	In fact, parts of American life that are difficult to comprehend.
	You heard about an organization that was set up for that purpose.
	For the purpose of spreading lies like that as far and wide as possible.
	Why?
	Because the more people see it, the more people come to the website, the more people have it at the store, the richer you can see.
	Thank you.
	And we're going to talk about all of that, but what I want to start with and just acknowledge is what we saw in this courtroom yesterday.
	Which is that the lives that started on December 14, 2012 are continuing to this very day.
	In two months it will be ten years Ten years since these families lost their loved ones.
	And even now, even now, he's still doing it.
	I just want to give you a sample of this.
	Why don't we go ahead and play just a clip from what Mr. Jones said within hours, hours of a shooting.
	They have hit the ground right They've got a bigger majority in the Congress now and the Senate.
	They are going to come after our guns, look for mass shootings.
	And then magically it happens.
	They are coming.
	Two years later...
	It's the same thing.
	And by the way, you've seen it.
	You've seen dozens of these.
	I'm going to show you a chart of all the different times over the years Alex Jones was pushing this lie.
	You've seen dozens of them, but just let's go to two years later, January 13, 2015.
	Yeah, so Sandy Hook is a synthetic, completely fake, with actors.
	Synthetic, completely fake, with actors.
	Now you've heard September 29, 2022. It is synthetic as hell.
	You saw that video yesterday.
	It's all made up.
	Now that I see how rigged this trial is, it's as synthetic as hell.
	You saw the video where he said, not only is the trial rigged, the jury's rigged.
	All of you.
	The judge is a tyrant.
	That's what he does.
	Why?
	Because he knows he needs to maintain his credibility with his audience because they're everything to him.
	And we are nothing to that.
	So let's start from the beginning.
	You heard this testimony.
	You had millions of listeners by the time you were 24, right?
	Yes.
	And you were the beginnings of a media empire, right?
	Yes.
	This is the early 2000s.
	Mr. Jones starting to build methodically that audience, that audience that would come to him for the message that he spread on InfoWars.com, that message being that there's a conspiracy, a global plot out to that message being that there's a conspiracy, a global plot out to A global plot out to get you, to enslave you, to kill you.
	People in power out to get you.
	And it's such a convenient message for him to send because every day he's got something new.
	Something new to share with the people that are coming to him about how they know that this is true.
	And he starts to build Infowars.com, PrisonPlanet.com, PrisonPlanetTV, the centerpiece It was perfectly situated to take advantage of the way stuff spread on social media.
	So he has Facebook, all those Facebook accounts, Twitter, YouTube, millions of views, building and building and building this organization to spread this message.
	Remember what it was, the message.
	This is Alex Jones' testimony.
	And the message that you convey to your audience and have conveyed for the last 20-some years is that there's a group of international media, financial, and political elites that are conspiring to establish a global tyrannical government to enslave and ultimately kill people.
	Yes.
	Now, to you and me, Let's play just a sampling of the way he conveys this message, including on the day of the shooting.
	They are coming.
	They've already taken over health care.
	The premiums are doubling.
	They're bankrupting that.
	They're already shipped GM to China.
	They are going to gut this country.
	They're going to shut down the power plants.
	They're going to bankrupt us.
	They are re-educating us.
	Just like we were Ukrainians and they're Russians.
	They want us bankrupt.
	They want the counties and the cities bankrupted and federalized.
	The feds themselves run by globalists.
	What does the new magazine say?
	You get it by subscribing.
	You get 12 issues.
	This man wants your guns.
	And I write down here, they're declaring war on the Second Amendment period.
	They are declaring war on the Second Amendment period.
	They are coming after They're going to kill America.
	There is a war.
	You hear him talk about this a lot.
	Info wars.
	Everything's a war.
	And I'm going to show you a video later of him talking about how he hits the barbed wire and his arm comes in after him.
	And then, a couple weeks later, as he's pushing, as he's pushing that every single person Who's brought this lawsuit is an actor.
	This is what he's saying to his audience.
	I guarantee you they're getting ready for false flags.
	All the signs are there.
	And they're going to blame it on us.
	And we've got to instantly come out and not take the guilt they put on us.
	Minute one, when they blame us, we've got to go, well, hey, you did it then.
	And they go, how dare you?
	Well, you're saying we did it.
	No, we don't believe a thing you say.
	You did it.
	They'll go, well, that's outrageous.
	You did it.
	You have the history of staging stuff.
	You did it.
	You're the suspect.
	You're the suspect.
	You're the suspect, government.
	You're the foreign bank run collaborators.
	Get out of our country.
	Get out.
	Do you understand how dark it is?
	How far down the line we are?
	How late it is?
	You're the suspect.
	You're the suspect.
	Five years later, it's the same Do you remember what Mr. Watts said about the importance of message?
	Fear, anger, demonization.
	That's the message.
	And who is he demonizing?
	Who is he saying are the enemies of America that his audience is at war with?
	These people.
	And his audience gets it.
	And he tells them that he's the one they can rely on.
	Infowars is the house that truth builds.
	The front line of truth journalism.
	Remember, Ms. Paz was up here and said, the one thing that Alex Jones told her in however many minutes he gave her was that he's definitely not a journalist.
	Now why was that not working?
	Because he doesn't want you to think, he doesn't want you to hold them accountable for what he says.
	But what he tells his audience is that they can count on for the truth.
	The truth in journalism.
	The Alex Jones show The House of Truth bill.
	This presence along with hard-hitting content and the courage to speak the truth is everywhere.
	This is Alex Jones.
	Right after he says, they staged Aurora, they staged Sandy Hook, the evidence is overwhelming.
	They stay sandy hooked.
	The evidence is just overwhelming.
	And that's why I'm so desperate and freaked out.
	This is not fun.
	You know, getting up here telling you this.
	Somebody's got to tell you the truth.
	Somebody's got to stand against these people.
	Somebody's got to do it.
	What did that kind of message and that kind of fomentation of anger and rage and distrust mean for him?
	What did that mean?
	His dad told you.
	And I'm going to skip to the middle of his answer here.
	But in reality, it has to do with the fact that our customers are so loyal to us that they believe in what we're doing to such a degree that if we say something is good for you and it's a good value, they're going to buy it and buy a lot of it.
	the audience that he was building.
	That's the profit that he was seeking in the run-up to San Jose.
	And he told us in his deposition, Mr. Jones, it would be fair to say that you expect among the millions of your listeners, many will believe that you are telling them the truth, right?
	Yes.
	And sometimes that truth that you tell them is pretty horrifying, correct?
	Yes.
	Free speech systems, you know what is that?
	It works.
	Question, this message that he's been pushing out and telling his audience all these things that they have to fear, A, he has remedies for that, he'll sell them, and B, he's the only one that will tell them the truth about it.
	That strategy's been working with him, right?
	Answer?
	Well, if you're looking at the social media numbers and the visits to the sites, yes.
	And he knows.
	He knows darn well.
	Well, he's not going to be able to do that.
	kind of danger this represents for people who keep tolerance.
	Because in 2011, he gave an interview with Rolling Stone and this is what he said.
	Some unstable people are drawn from the bright flame of enlightenment.
	That is so-called conspiracy culture.
	Some trees are going to become uprooted in a storm like this.
	He's the one doing the including.
	He's the one exploiting his audience and their fears and creating the storm.
	And so by the time December 2012 rolled around, this is the organization that he was sitting This is an organizational chart.
	You may remember when this came up.
	Because it was very, very important for the defense to try and suggest to you that this is just some fly-by-night operation.
	Alex Jones just gets up there and there's no rhyme or reason to any of it.
	It's very important for them to try and tell you that none of this is calculated.
	They're not out to make money.
	And they even ask their own corporate representative, there's no organizational chart, is there?
	No, I haven't seen one.
	I get up here and I show you the organizational chart.
	I show you the organizational chart that Infowar's own lawyer had seen.
	Because this is what an organization looks like that's ready to pounce, that has all the tools in place, all the people in place, ready to go.
	And if you look at the numbers that they provided from January 2009 to November 2011, 106 million users.
	678 million page views.
	So when you're thinking about the impact of what Mr. Jones said on the day of the shooting and the weeks after, understand that this is the audience that he was telling understand that this is the audience that he was telling it to.
	That's what he was doing.
	That's what he was doing.
	He was getting ready.
	He was waiting for an opportunity.
	But what about these families?
	What were they doing?
	They were just living their lives.
	They'd never heard of Alex Jones.
	This is the Parker family.
	Robbie graduated, become a physician assistant, to work in the NICU.
	They're going to move to Connecticut.
	They got a job where you could train in the NICU because you wanted to take care of some babies.
	Three little girls would come to San Diego to start a life.
	Robbie had been on a mission to Brazil as a young man, as part of his Mormon faith.
	You remember he courted Alyssa and she didn't even realize it.
	He was hanging outside her softball games.
	She thought they were friends.
	She was clueless to the fact that Robbie was trying to court her.
	Why did we go through all these stories?
	I'm going to go through a little.
	Why did we spend so much time?
	Because we wanted you to see that while these weren't real people to Alex Jones, they were real people.
	They had real stories.
	They had been building real lives.
	They had real identities that really mattered.
	The Wheeler family.
	And in May, Francine and David.
	They moved to Sandy Hook about five years before both Francine and David, more so David who struggled, trying to be an actor in New York, Francine, born singing.
	They met, David said, "When I met through the scene, and I realized I wanted to be with her, I saw green lights all the way down." Ben.
	Went to Starbucks with his mom that morning.
	I want to be an architect and a paleontologist because Nate wants to be a paleontologist.
	And I love you, and I love you, Mommy.
	The Barden family.
	Now, the Barden family gets two photos because I had to include the bank.
	And I didn't want to weed Jackie out.
	Jackie, the night of 10 children, Irish immigrants used to run around the A&P while the Bible was working at night.
	Mark, a guitarist.
	Mark worked nights.
	Jackie worked days.
	But what Jackie told you is we thought that was best for our kids.
	Mark spent so much time, she was a little envious of that.
	He has to go get the time.
	Daniel tucked his books under his pillow and we get such a kick out of his mom pretending that she didn't know and then finding him when she told him that it was pillow.
	And he wanted to walk.
	James and Natalie were the bus stop.
	And he wanted to walk.
	And he wanted to walk.
	The Richmond thing, Aviel.
	Aviel's got her hair back here, but if you remember, she did that crazy hair.
	A little touch of mischief here in the story after she had a candy in her mouth that she wasn't supposed to, but her cheeks all bulged out, and her mom just let her, because she spoiled her.
	These are real people, real families, just going about their lives.
	The solar family.
	Vicki stomping around on the second floor to irritate her sisters and her brother getting ready for work that morning.
	She left Christmas music in her car.
	And you saw the pictures of her dressed up all crazy with her hair hot, because all she wanted to do Who is care for and inspire and teach those kids.
	And when she got to school, she had spilled a little coffee on herself and Donna helped her clean it up.
	And Donna, the matriarch, had all her kids in her house, the nurse, the olden girl, the olden girl, and Bill Oldenburg is a hero.
	Wanted to be a police officer.
	Put himself in harm's way.
	Went to the school that morning in such a rush he didn't even get his equipment.
	He comes into this courtroom.
	He doesn't sit with the families because he doesn't feel worthy.
	Bill and Mary.
	Bill.
	The way he talks about marriage is moving. .
	All she was doing was waiting for her kids.
	Don't worry.
	Dawn Bookfairy.
	Dawn, who was so determined and feisty that as a result of her own persistence, there's a Naugatuck high school girls track team even today.
	Dawn, Dawn, who met with Ian Hockley when he came to Sandy Hook, and all he had to do was meet her to know how much she cared about the kids in her classroom and in her school.
	And she's the reason they wanted to be at Sandy Hook.
	Fiercely devoted to her daughters, along with Mary Sherlack, confronted the shooter that won't die, saving children.
	The Hawk we knew.
	Dylan, moved from England.
	Nicole was finally going to be home, take a step back, be part of the community, spend time with the kids, dealing with autism.
	But I had a great accomplishment that morning.
	First time he finished his vitamins.
	He was so proud that he had done something that his mom was hoping he would be able to do.
	He was so proud.
	Let me just go back.
	These memories, right, that we spent a long time talking about.
	These are the same experiences that all of you might have on any particular day, right?
	Francine, you know, Ben, close the door!
	Jackie.
	Heating up Daniel and Herod, all these little memories.
	They're just day-to-day.
	They might seem mundane, but after what happened, they're so important.
	They're so important.
	It's what they have.
	Yeah.
	But as these families were living out their daily lives, Alex Jones was readying to pounce.
	And I want to play you this because this articulation of what he is and What his audience does in response to him perfectly encapsulates what he was about to unleash on these families on December 14, 2012. That's why you keep missing the main calculation.
	IMA precision Have you seen what we've done on talk radio now?
	Sounds just like me.
	That's what happened.
	He was a precision, guided, heavy munition.
	And when he took the stand here, I told him, you put a target on their backs.
	And that's exactly what he did.
	And he knew that his army was coming after him.
	And this, I'm going to show you here, just in case you've forgotten what this timeline was like in the first month after shooting, what Alex Jones did.
	I'm going to show you what he did.
	This is the anatomy, the birth of this lie that continues to this day.
	He goes on the air.
	Within hours.
	These families hadn't even left the firehouse yet.
	Connecticut school massacre looks like false flag witnesses say.
	Brittany Paz acknowledged that was false.
	Now I want you to remember this too.
	They didn't give us this video.
	Why?
	Just like they didn't give us financial data, they didn't give us analytics, We want you to know just how deliberate this was.
	We had to get this on our own.
	You know what else they didn't give us?
	What he did the next day, the 15th.
	We have no video from the 15th, but we know they put up Robby's statement immediately after he gave it to the firehouse.
	Because Rob do told you.
	When we saw Robby Parker, we put that on the air immediately.
	That's the next step.
	The 17th, Alex Jones tells his audience, they're doing it, they're doing it, they're staging it.
	On the 17th, they run San Diego MassMedia outtakes and bloopers.
	On the 19th, he puts out a statement lying about Robbie Parker and saying this needs to be looked into.
	On the 20th, they run again this story that, hey, San Diego was planning They don't even know if it was in a Batman movie.
	That's how callous.
	That's how callous they were.
	But how important it was to them to start getting this lie going.
	Getting it going.
	The next day, the 21st, do you remember this?
	Don Salazar sent some guy to some movie review.
	We thought this was surely ridiculous.
	However, we're going to point it out in an article anyway.
	That's the week.
	That's the first week.
	And sure enough, as soon as he did, everyone else came coming in over him.
	The threats.
	The harassing.
	The fear.
	The allegations of actors.
	When.
	Every single one of these families were drowning in grief. - And Alex Jones put his foot right on top.
	More of it.
	More of it.
	January 6th, Don Salazar trying to sign up for a crisis actors website.
	And they're having a professor on who's saying that crisis actors are involved.
	Alex Jones, in this email, wants the guideline to talk about crisis actors in January.
	Another one.
	January 10th.
	Another one.
	Ending on January 27th is the first six weeks why people are in San Diego's house.
	And finally, Of
	course not.
	But Alex Jones was set up for it.
	Look at this.
	You saw this at opening.
	Look at what this did for him.
	From December to January.
	Sessions up 38%.
	Users up 36%.
	Pageviews up 43%.
	I just want to go back to this for a second.
	Because you remember the testimony we heard about spice.
	About how to try to emulate it.
	This is Alex Jones seeing in real time that this is working.
	It is working.
	And he doesn't care what's going on over here.
	Just like he doesn't care what's going on in this world.
	It's working for me.
	And you saw all the videos in 2013.
	But in November 2013, 11 months after, the state's attorney who investigated this goes to this report.
	In force has it.
	The police testified, yeah, that report establishes 26 people were murdered.
	At the school.
	It's real.
	They know.
	Remember this testimony from Radu?
	As you sit here today, you have no recollection of having read the state's attorney's report of his investigation on the circumstances surrounding the city of shooting, correct?
	Correct.
	Don't you think that that would have been a source of information that you would have wanted to consult if you were interested in the facts and circumstances surrounding the shooting?
	Objection. Objection. Objection. Objection. Objection. Objection. Objection. Objection. Objection. Objection. Objection. Objection. Objection. Objection. Objection. Objection. Objection. Objection.
	Objection. Objection. Objection. Objection. Objection. Objection. Objection. Objection. Objection. Objection. Objection. Objection.
	I don't know what I was saying at the time.
	Thank you.
	Except that's not true.
	We know exactly the difference.
	We know exactly the difference.
	They were thinking dollar signs.
	Look at this.
	From 2012 to 2013, this is what happened to their lives.
	Any care what the reports say?
	Any care?
	Any care what was happening to these families?
	In fact, the harassment, the engagement of their audience, that was a good thing for them.
	That was part of their method.
	Do you remember Clint Watts, The Four M's Messenger Method?
	The importance of that engagement, the importance of whipping up their audience, the importance of showing their audience the kind of viral confrontation that was so valuable to Alex Jones.
	Thank you.
	They're trying to take care of their surviving children.
	They're mourning the loss of their mom, wife, their sister, trying to get through this.
	And Melissa Parker described it as an assault.
	An assault.
	And that's exactly what it was.
	And I just, I want to go through this example.
	Because I think it crystallizes that slide that we just looked at, the audience growth.
	It crystallizes the way that pushing up that line in January worked for them.
	Do you remember this?
	I remember during this, I was up here the whole time.
	The FBI says no one killed in San Diego.
	Now, this is September 2014. It's alive.
	New speech systems came up here and admitted, oh, no, no, that was, that was alive.
	Yeah, no, the FBI did report people had been killed in San Diego, of course.
	But they published this article, because imagine how they can breathe life into this thing.
	This is two years after the shooting.
	Two years after.
	A year after And look at what happens.
	Look at the payoff.
	The payoff.
	The spike.
	And look at these, this to me, the importance of social media the way he was doing it.
	You remember this?
	September 23rd, most of their traffic, before the article comes out, most of their traffic is coming directly, right?
	People are coming to the website.
	Only 24% Are coming through social media.
	They publish this article and look what happens.
	The percentage of traffic coming to their website through social media doubles.
	Doubles.
	Then it goes up again on the third day, 66%.
	It's taking off.
	It's a lie.
	It's a lie that nobody died, that the children didn't exist, that these families weren't real.
	It's a lie.
	But it's working.
	Look at the audience increases.
	And remember that these Put the money.
	Put the money pouring in.
	Go from 14,000 in a day on just one store website, remember, to 232,000.
	Remember Tim Fouget, your e-commerce director, you have this transcript.
	This is the one I think where Jeff Bell's pointed out that my voice is a little Look at what he said.
	So if we scroll down to the period of time we were just looking at, where there was a spike in traffic to Infowars.com, and we scroll down to the same date range, the third week, September 24, team, you can see, can you not, at the beginning of September 24, that that is a two-day spike in revenue.
	I mean, there is a spike, yes, I agree with you.
	And when you are having your daily call with Alex Jones, and you see a spike in revenue like, Why
	would he let these families try to heal and move on with their lives?
	This is why.
	His dad.
	Okay, are you aware whether Free Speech Systems collects data concerning when, during an Alex Jones broadcast, it has no sales activity?
	Only in the sense that if there have been days when we had extraordinarily good sales, someone will say, what was Alex saying when that happened?
	So we like to emulate spikes now.
	You know all this, but it's right there.
	Look at this.
	This article.
	Of all the tens of thousands or however many pages they created during the seven years, FBI says nobody killed at Sandy Hook.
	You'll see this exhibit.
	It's eighth on the list, but it's like the third article.
	The third most popular article in that whole time.
	There's like the landing page, the homepage, and everything else.
	But in terms of the way people access the website, this is the third most popular article during that time.
	Now, I want to talk to you a little bit about the method.
	And the reason I'm doing all this is because I want everybody to...
	It's one thing to be instructed, as the judge instructs you, that Alex Jones was the cause of all this.
	It's another thing to see.
	It's one thing to be told These were real.
	And it's another thing to hear it from their own voices about their experience.
	So when Attorney Patis comes up here and says, why did they spend all this time talking about Alex Jones?
	Because you need to see it.
	You need to understand the cruelty of this.
	And the method that he used is the engagement of his audience.
	Send tips.
	Right?
	It is happening.
	They want to kill America in 2013. That is their goal.
	That is what they want.
	They are moving to do it.
	Send your tips to RealLogians on Twitter.
	Tell me what you think.
	Comment in the articles.
	I'll be reading what you're saying.
	We'll have more reports Sunday 4 to 6 and more reports tonight on the IP News 7. The week of the shooting.
	It appears that members of the media or government have given him a card and are telling him what to say as they steer reactions.
	This needs to be looked into.
	I have no philosophy.
	This is a way of getting his audience involved.
	Look into it.
	Look into it.
	I asked Robbie, did you get looked into?
	This needs to be investigated.
	As he showed Robbie coming up in slow-mo.
	You know, one of the things that really ticked me off this trial.
	Was when Brittany Paz told you that they never even heard Robbie's full sailor.
	They never even heard him.
	They didn't hear him talking about his daughter, Emily.
	Why?
	Does anybody who sees that know They
	were a prop that he played over and over and over again.
	Even last week, you saw the video yesterday, he couldn't leave him alone.
	The camera hands to Robbie Parker, shaking with emotion in the presence of Anything else you want to tell us?
	I mean, you're really doing a great job and you're another example of how we're going to defeat Matthew
	Mills showed up as the Soto family was trying to honor Vicky, waving a picture at them, claiming that Vicky was fake, that they were fake.
	Remember when Matthew Mills said Alex Jones, hey, I got a couple of other things I'd like to infiltrate.
	I'll talk to you about them off air.
	But this is what he highlights because it's valuable to him.
	You haven't seen this before.
	This isn't evidence.
	Do you remember Wolfgang Halbig coming up and being confronted by the police?
	He heard this.
	Let's call him.
	When you get in my face.
	I didn't know your face.
	Are you walking from there?
	I'm not walking towards you now.
	I'm standing there.
	Are you walking towards me?
	Okay.
	I used to be a police officer.
	Show me some respect.
	How about the same?
	I will.
	When you start showing me something, I'll start showing you something.
	I can see it.
	Right?
	I can see it.
	Very polite, very courteous.
	That's fine.
	That's the way I operate.
	I'll have no problems.
	Right?
	Okay.
	That's Wolfgang.
	What about another of these uprooted trees that Alex Jones liked to praise?
	Do you know what we privately say about Badani when we say you want to mention?
	What?
	Release the Kraken!
	This is what happens.
	This guy here is somebody on a central cast, and I'm telling you, this is the exact person that they would hire to represent criminals, folks.
	The Sandy Hope Truth is coming out to the people who go to jail.
	You can smile if you want to go into jail to fraud.
	All right, here we go.
	credentials, damn but not infowars.com, the number one alternative news source in the world.
	Matthew Mills, you're the rest.
	What's happening, Matthew?
	Can you see it?
	He's telling his audience, he's signaling to his audience, this is what he likes.
	Thanks.
	This is what I want.
	And so if children were lost in San Diego, my heart goes out to each and every one of those parents and the people that say they're parents that I see on the news.
	The only problem is I've watched a lot of sub-rockers and I've seen actors before.
	And I know when I'm watching a movie, I know when I'm watching something new.
	Let's let this hand you up.
	Let's let this hand you up.
	Just think about this.
	This is 2016. You know what happened to Francine?
	2016. She's at a conference for She's there to counsel other mothers and be counseled.
	And a woman who had lost her son just three weeks before, somebody who would be the last person you would think would have anything but He
	comes out.
	Somebody's following there.
	Puts a business card on his windshield wiper with Robbie's face on it.
	People in the Parker's church.
	Matthew Sogo goes to college.
	His professor takes a survey of the class.
	How did you just concede?
	Alex Jones penetrated American society with this lie in a way that they can't escape from.
	And how did he do it?
	By telling his audience over and over and over again that they should investigate it.
	And praising them when they take action, including two weeks ago.
	Alex Jones went on the barbed wire and everybody else came in after him right to Waterbury, Connecticut.
	And he commended them.
	This is the bravado.
	This is America.
	This is Texas.
	This is freedom.
	This is Christianity.
	This is resistance.
	My forebearers, Talk tyranny.
	We're incredible people.
	And I will live up to their measure.
	And you will as well.
	So don't ever, as dark as the hour is, and as out of control things are, don't you ever not realize how important you are and what you've done with your word of mouth and your ashy.
	And I'm talking to people that went to that puppet courthouse in Connecticut.
	You can put info or stickers up everywhere.
	Please, Angie.
	It worked.
	Take a look at this chart.
	Remember what Clint Watts says, one of the things that you have to do if you really want a lie to take hold and repeat it over and over and over again.
	Now, we didn't get videos.
	We've shown you a couple dozen videos, but you know we don't have all the videos.
	But what we did get were these lies, these radio lies, where we were able to tell that they were talking about CCO.
	Look at this.
	Look at this reputation.
	Rouget would tell him, "Hey, whatever you did, it worked." And the audience he was building, look at this, just on social media.
	Look at this.
	Look at this.
	Just on social media along.
	YouTube.
	Just link for watch.com.
	And he acknowledges it.
	You know that during the years, let's just say from 2012 onward, Mr. Jones' social media audience expanded dramatically year over year over year, correct?
	Yeah.
	As we've been talking about throughout this deposition, that expanded audience, that expanded Now,
	Brittany Paz came up here, if you remember, and I think it's pretty clear that she wasn't going to say anything that they didn't want her to say, or that they didn't prepare her to say.
	It seems like a long time ago now that she testified.
	It was a time where Hollywood felt like her testimony would never end.
	I take responsibility for some of that, I guess.
	She testified that although she didn't see all of the sales, Ms. Paz was willing to say they made a billion dollars.
	If that's what she came up here prepared to say, I think it's more or less than that.
	We don't know how much they made.
	No idea.
	I'm just going to tell you that it could be 500 million, it could be a billion, it could be 5 million.
	Whatever it was, it was extremely valuable to Mr. Jones.
	It provided him all the incentive he needed to do what he did to his families.
	We know that in 2020, he had a pretty good day, $810,000 in a day.
	You can do that math.
	Of course, he's telling them every day.
	So, let me ask how much time I have to spend here.
	53 minutes.
	Thank you, Attorney Patis.
	Yes.
	I want to talk to you about damages.
	First, I want to talk to you about defamation.
	and slander per se.
	You've just seen evidence.
	You've seen across these four weeks of defamation on a historic scale.
	10 years, targeted to people who are in their most vulnerable moments.
	And the judge is going to instruct you on what this is, but I just want to give you an example.
	Because defamation, why do we have something called defamation per se?
	Basically means that if someone lies about you in a way that's important to you, whether you know about it or not, no matter how many people they tell it to, that is a harm.
	That is a harm that they can seek to redress by coming to a jury to restore their character and their reputation.
	Because when a lie is told about somebody, It's harmful to our society.
	It's harmful to them.
	So let me just give you an example to make this real.
	And I'll make myself an example.
	Let's say I'm a dad, a family man, kids, and all I care about is being a good dad.
	Waking up with them, coaching the teens, helping them get their homework, being home on the weekends.
	That's what matters to me.
	That's my identity.
	That's my sense of self-worth.
	When I see my kids be good, kind, happy kids, that makes me feel good.
	That's what I want to be known for.
	And let's say that somebody out there, for whatever reason, decides to lie about He says in school, bruises.
	They're scared.
	That's a terrible lie.
	And let's say he just tells one person.
	Just one person.
	The law says that I can come into this courtroom and ask a jury to restore my reputation, my character.
	Reputation is just another word for character.
	What it is that is most important to you, your identity.
	And I want you to ask yourself, that happened.
	Just one person.
	And I came in here and I told you to please, please hold that person accountable for the harm that they caused me.
	I want you to think about what that might be like.
	What kind of verdict would be reasonable in a case like that for just one person?
	I don't know.
	Pick them up.
	Fifty thousand, ten thousand, a thousand, a hundred bucks.
	Pick them up.
	That's what we're talking about, okay?
	That's defamation per se.
	I'm going to go.
	Now I want you to keep that number in mind.
	Keep that number in mind as you realize that what Alex Jones did That's
	six years between 2012 and 2018 on Twitter, Facebook, and YouTube alone.
	550 million times.
	And it's not just one person who said it about.
	It's 15.
	Think about that.
	Whatever number you had in your mind, me, they'll lie about me to one person, multiply it by 550 million, and then multiply it by 15.
	Because the judge is going to instruct you that your job is to award fair, just, and reasonable damages.
	Thank you.
	Nothing more, but nothing less.
	Nothing less.
	And if you thought it was reasonable in your own mind for a guy like me, who'd been lying about once, to be awarded whatever the number is, then that's reasonable for them 550 million times a minute. then that's reasonable for them 550 million times a minute.
	And you may say, "That's astronomical." It is.
	It is.
	It's exactly what Alex Jones set himself up to do.
	That's what he built.
	He built a lie machine that could push this stuff out.
	You reap what you sow.
	You reap what you sow.
	And you might think, you know what?
	You reap what you sow.
	That's not enough.
	We know 550 million is just a fraction of how many people actually get that.
	But that's the number we were able to present to you Because they didn't provide us with all the information.
	But when you think about the scale of the definition, you're being instructed on how to think about it.
	Remember the lie I told you about?
	The lie that somebody is actually an abusive father, that's bad.
	That's bad.
	But what about the lie he said about them?
	They faked their six-year-old and seven-year-old's death.
	Thank you.
	They fake their sisters, they fake their wife's death, they fake their mom's death.
	They're actors.
	They're part of a plot.
	They're part of a plot to take your rights away.
	If you're just one uprooted tree in Mr. Jones' audience, it's been coming for years, they're These people who are just normal people become their enemy.
	They start to haunt them.
	That's the scale of the definition here.
	It wasn't just about some The loss of a child.
	It went to the heart of who they are.
	That's defamation.
	So that's a baseline.
	That's a baseline.
	The second component of damages you're going to be asked to consider has to do with emotional distress.
	I want to read to you to you a section of instructions that Jeff Ellis will give to you.
	In assessing the invasion of the plaintiff's privacy
	and their emotional distress damages, you may consider that it is already established that the defendant's conduct was extreme and outrageous.
	Indeed, in many cases, the defendant's extreme and outrageous conduct is clear evidence that emotional distress existed.
	This gets back to why I spent so much time talking about how reprehensible and outrageous what he did was, because you know The duration of the conduct.
	The defendant's conduct in spreading the statements and their actual spread.
	The harassment the plaintiffs endured.
	The plaintiffs' fear of harassment.
	The nature and duration of the invasions of the plaintiffs' privacy.
	The nature and duration of the plaintiff's emotional distress, including future distress.
	Isn't that what you heard about?
	This is the part of the case that only you as a group of people can really understand what they've done.
	Thank you.
	Francine and Mark both told you that But dealing with this,
	dealing with lies and harassment, even as you're preparing to bury your child and your mom or your sister, You
	should believe she's going to be killed to this day, sleeping with a mace, a knife, a nice little bed.
	Mark Barton, scanning, constantly scanning who might be approaching.
	Jennifer Hensel always looking at her backseat.
	Erica Lafferty receiving Threats to rape her.
	She's moved five to six times in ten years.
	She's on the run.
	The Parker family, on the run.
	How can this be?
	Their lives go shattered on December 14, 2012, when Alex Jones has made it so they can't escape.
	They can't escape.
	Soro children, in their own town, What that means.
	And let me just end with Robby and listen.
	One of the things that Robby said that stuck with me ever since he told me was the shame and the guilt he feels.
	Because if he just hadn't done that, if he hadn't made that statement, trying to human javis the doctor of the world, He
	told you that the worst part about this is the guilt he feels.
	Because if he had just put on his equipment, just put on his vest the right way, maybe David and Eli would have had to do this.
	Because these people are struggling for answers.
	Why?
	Why?
	They're good people.
	These are good people.
	And what happened to them is not right.
	It is not right.
	And it's going to be your job to make sure that Alex Jones, who has refused to even come to this courtroom to see the testimony, these plans to understand the harm he has caused, that he gets these plans to understand the harm he has caused, that he Thank you.
	It is your job to make sure he understands the extent of the wreckage he has caused.
	Because you know damn well he doesn't get it.
	He should.
	He should get it.
	Do you remember this?
	She brought a lawsuit for defamation while this lawsuit was pending.
	He himself recognizes that the words are so obviously hurtful that they require no proof.
	No proof.
	No proof.
	That they caused injury in order for them to be actionable.
	And what was this harm?
	This catastrophic damage that Alice Jones suffered.
	A tweet with 20 retweets and 37 likes.
	Oh, he gets it.
	He gets it.
	But he doesn't care.
	And this is just getting back to Clint Watts, $550 million.
	I wanted to show you this testimony.
	I'm sure you remember it.
	But when you compare that to the 20 tweets and Alex Jones, give me a break.
	But you know, Alex Jones is a victim, isn't he?
	But here's how you know why it's so important Why you have an opportunity to do something as representatives of this community.
	Because I had Elvis Jones on the stand, and I said, you're going to do it again, aren't you?
	This is a few weeks ago, and look what he is doing.
	Look what he's preparing his audience for.
	What is he conditioning them to?
	Which things is he going to hit the barbed wire and be a precision guide ammunition on next?
	Do you think he takes any of this seriously?
	What do you think it means when he tells his audience that Joseph Ellis is a tenant?
	You think they know what that means?
	Think they get it?
	I am so sick of the new world order.
	I am so sick of this cult of psychopaths.
	I am so sick of their lies and their fraud.
	I don't believe anything they say.
	And I apologize for nothing I've ever done because I did it all from a place of purity and I've been 98% accurate.
	Okay.
	at the top, sitting as dead kids.
	Families for weeks on, never said their names, never even talked about them, all made up.
	And it's like, oh, my kid died, oh, and Alex Jones caused it, and it just, it's all laughing.
	You're like, oh my God, Jones, you're under such attack?
	We better not be like you.
	I'm under attack because I expose these people.
	I'm just going to be completely honest.
	I totally enjoy it.
	I mean, I've reached that point of real peace where I'm just at peace with this.
	I enjoy it now.
	I don't even know what to say about it.
	I really don't.
	Except that one thing is Christmas to me.
	He's signaling that everybody is going.
	He is going to do this.
	He enjoys it.
	Think about the calisiness that's required, the cruelty that's required to say something like that.
	After these families have been here for weeks.
	Tell me about the most intimate five parts of their lives.
	Explaining to you what they've been through.
	Who they are.
	Take it down.
	But even though he wasn't here and he didn't see it, he doesn't care.
	You saw it.
	You saw what he did.
	You saw it.
	They're going on ten years.
	Ten years.
	Ten years of defaming these families.
	And it's not stopping.
	You remember Bill Oldenburg's testimony?
	He was talking about how it's going to keep going.
	He said, it's not speculative.
	And you know it's not.
	It's going to keep happening and keep happening.
	Francine, Nicole, They're surviving children.
	To know that they may be confronted just as they have been.
	Not even to protect them.
	Why?
	Because this lie is out there pushed by Alex Jones.
	So it's not just damages for the emotional distress they've suffered these 10 years.
	It's going to keep happening.
	So after you've considered The damages for defamation, per se, if you consider the emotional distress they've gone through, make sure you remember that this is going to be a problem.
	And this is their one chance, and your one chance, your one chance, to render a verdict on just how much devastation happens Genesis.
	It's been a real privilege for us to represent these families.
	I can't tell you how fortunate and lucky we are.
	And I think it's a real privilege for you to, to be in this position.
	You represent this community.
	What will you do?
	Will you render a verdict that finally forces Alex Jones to truly understand?
	just how devastating his conduct has been.
	Because that's the only way, that is the only way, he will stop.
	What will our community's birth to be on what's happened here?
	We saw you.
	I want to thank you very, very, very much.
	Thank you.
	Thank you.
	All right, so we are going to take our mid-morning recess, which we all need to put in the staff, We're going to come back right at 5 of 12 to continue.
	It'll be Attorney Pettis' turn next.
	I know you know the rules of juror conduct.
	Again, not a word about anything that you just heard.
	Anything else directly or indirectly connected with anything to do with this.
	I am going to stay on the bench.
	I have a housekeeping issue to deal with.
	So, Mr. Farr, if you could take our jurors and we will see you at 5 of 12. Please
	be seated.
	I know, Attorney Pettis, I was going to let you make the decision as to whether you wanted to go before the break, but I actually need a break, so I take blame.
	But there was also one thing, and I imagine Attorney Maddie was not in the room.
	Attorney Pettis had asked on the record, of course, whether I had any issues with him reading from the charge, any part of the charge, and I said my preference was Was that it not be done.
	I assume you weren't in the room.
	Not a problem.
	But I just wanted to let Attorney Patis know, in light of Attorney Maddie reading from the charge, obviously you're free to do so as well.
	I may in one section then with your permission.
	Absolutely.
	Okay.
	I'm sorry, I was not here for that.
	I understand that, but I just wanted to make sure that it was fair to Attorney Pettis, which is another reason I thought, let me take the break now in case you needed to tweak anything.
	Thank you.
	But I really did need a break, too.
	All right, so we'll take our morning recess.
	Mr. Farrar, can I sit in for a moment, please?
	Have a seat.
	Depending on how long Attorney Pagas goes, Attorney Maddie has how much time left?
	41 minutes.
	The staff is willing to take a later lunch hour, so I'll see how it goes, see what happens, and I can even ask the jury, you know, make sure that it's all right with them.
	Do you want me to try to do that, depending?
	They've gotten used to the schedule.
	I think I should be done by one or another.
	Okay.
	Wait now.
	Oh, it's already 12.
	So if you want to break it one, I mean, I want to play beat the clock and stretch it.
	No, no, I know, but I hate to interrupt you.
	All right.
	Just one thing from us, Your Honor.
	First of all, Attorney Koskopf will be doing the rebuttal, and do you have any objections?
	Attorney Koskopf will be handling those as well, and I think you wanted to add something.
	Oh, no, I thought you were asking if you wanted to go all the way through the rebuttal.
	I don't think, I, look, I didn't have the right time.
	Do you want me to tell you when it's 1 o'clock, or how do you want to handle it?
	I could just say whenever is a good time for you.
	I don't want to cut you.
	I don't want to be looking at my phone, which has got my clock on.
	So I can tell you.
	Sure, and then you'll find it if it needs to be after 1.
	If you need to go to 110 or something, because you're in the middle of a certain, that's fine.
	I've already cleared it with the staff, is what I was saying.
	Okay.
	All right.
	Thank you.
	Thank you.
	Welcome back, everyone. - Good.
	we go.
	Please be seated.
	The record will reflect that the entire panel has returned.
	Just for your planning purposes, we will take our normal lunch hour.
	We may go a few minutes late, depending where we are in the argument, but we will definitely have a solid hour for lunch.
	Okay?
	All right?
	Attorney Pavis, whenever you're ready, please.
	It's still morning.
	Morning.
	Morning.
	In many decades and hundreds of trials of doing this, I've never been prouder to be a lawyer than I am right now.
	And you're thinking, why?
	Because I believe in the rules of law.
	And the rule of law is under attack in this country.
	Some people believe it.
	Mr. Jones believes it.
	I'm here to defend Alex Jones.
	I'm here to defend free speech systems.
	In my opening statement, I began, and I'm going to read it because I wrote it then because I was worried I'd forget it.
	We live in times of deep political division in this country.
	One of the issues dividing us is guns, their possession, their use, and their control.
	The divides are deep, even dangerous.
	Don't let anyone tell you this trial is a means of addressing gun violence.
	They're political divisions.
	We're not here to make political statements, to reform the world, to take a stand against extreme speech.
	This trial is not a cultural moment.
	We are here because on another date and at another time, a court held Alex Jones with free speech systems liable for harming the plaintiffs.
	You are forbidden to speculate why that happened.
	Your only job here is to determine how much damage my clients caused each plaintiff, and then to assign a dollar value to suffering.
	The case comes down to money.
	How much money will each plaintiff get?
	We're asking you here to follow the law, and nothing but the law.
	Wait, before you play that.
	You will have in your jury deliberation room exited books, and you will have the documents that have been introduced, and you'll have pages that reflect videos.
	You've not been shown all of the videos in this case.
	You've been shown the videos the plaintiff selected that most proved their points, and they've been able to argue a straw man.
	Alex Jones did all of this, all of this, To set up the Sandy Hook families.
	He put a target on their back.
	And he monetized it.
	That's what you were told.
	I'm going to show you this exhibit.
	It takes about 19 minutes to play.
	It's exhibit 45. Zach, please press play.
	Watch this.
	As all of our hardcore listeners know from their own research, This country is in the middle of a civil war against globalist forces that are openly trying to stop the populist Americana new renaissance that we are attempting to bring back into play.
	Free market, true open societies versus globalism and corporate crony capitalist tyranny.
	We have an overload of news and information obviously today.
	We have Democratic Party throws a new giant temper tantrum because their Russia investigation has come up 100% high and dry.
	They've now thrown a new giant temper tantrum to restart another fake investigation, this time a shivel one, so they can continue to say there's an investigation over Which is gigantic.
	Making all sorts of claims of the criminal activities that went on with Trump, WikiLeaks and the Russians with zero, not one scintilla of evidence.
	Amazing.
	The Russians did not hack the DNC, it was leaked out of the DNC. We know from the files, released that have digital coding on them, that they were downloaded Two years ago.
	You understand folks?
	Six times the fastest connection, still four times the fastest connection today.
	It was downloaded at point blank range, just like Snowden did in Hawaii inside the big NSA center.
	It was downloaded at point Well, that's back in the news again today.
	Unbelievable disinformation.
	But notice, what did Trump say here in the campaign?
	He said, I don't know if the Russians are who else.
	Might be some fat guy in his mother's basement, for all I know.
	You can ping off anywhere in the world.
	There's no evidence it's Russia.
	But as he said, but if it is the Russians, release it.
	It's about what's in the WikiLeaks.
	Not about changing the subject as they always do.
	Into who released it?
	What about all the crimes?
	And I heard Owen Schroer did a great job yesterday during the broadcast when I took time off with some family.
	Said that today on the war room, he's gonna spend an hour, maybe spend the whole three hours, getting into the WikiLeaks and the top 100 WikiLeaks and then you calling in and mentioning what WikiLeaks you think are most important.
	Just like they hammer all this fake Russiagate stuff constantly, we should be hammering the Bonifides The bones, the guts, the reality of what is in those things and all the other leagues that they don't even deny are real.
	Sensational crimes, sensational pay to play from the Russians and the communist Chinese and all these big foundations.
	Billions of dollars going to Hillary, hundreds of millions from the Russians.
	Yeah, they can give money to the Secretary of State to then give them a third of our uranium.
	They did it.
	Absolutely.
	Do the Russians want to get our secrets and get our industry?
	Absolutely.
	That's what we do to them.
	The point is, is that the traitor is Hillary.
	So, you got the Democratic Party files monster temper tantrum because as I said last week and this week, the wheels came off six months ago with a fake Russian investigation, but now it's really come up dry.
	It's moved on to the Arab Emirates, and it's moved on to all these other places.
	So we're going to be getting into some of that as well.
	This really shows how desperate they are.
	You know, Matt's a great producer in there, and he's really hopping mad over this Megyn Kelly thing and other stuff.
	He's just like, you've got to cover this today, Alex.
	It's one of the top stories in the country.
	Every channel is lying about you, local, radio, TV. There's like 20 minutes of news clubs attacking me.
	I can't get to it.
	It's just all lies, folks.
	But I'm gonna try to go to some of it.
	But here's the bottom line.
	The media brings up Pizzagate and then misrepresents what I've said to beat me over the head and drag me to the mud.
	And then say that I need to be banned off the air.
	They bring up Sandy Hook and say that I say nobody died when I never said that.
	I played devil's advocate.
	They took it out of context.
	Megyn Kelly plays clips that are about Hillary being responsible for thousands of dead children in the middle-aged.
	She edits that and then plays it, when she was at Fox News, saying that I was saying Hillary was killing kids in a basement.
	So the defamation is that they continue to bring up these cases, never letting me drop them.
	I don't think anything was going on at that pizza place.
	We investigated it.
	We walked it back.
	We've clarified.
	I'm done talking about it.
	Just take it off the screen.
	It overshadows all the real stuff going on that I've got stacks of in mainstream news here.
	And then you've got Sandy Hook where we talk about the police stand down.
	We talk about the men in the woods with guns that were on the news on helicopter shots.
	We said there's anomalies here.
	And then some of the people thinking it was a total hoax began to think I was covering it up.
	And I went, wait a minute, I'm not covering anything up.
	And I'm done with this tar baby about a year into it.
	That's four years ago.
	And I constantly say, mass shootings really happened.
	The government's staying down at Sandy Hook.
	They stand down in Florida.
	They try to take me off the air, take me off YouTube, saying I said nobody died in Florida.
	You know I didn't do that, and they're liars.
	So then they get...
	Three of the parents of the poor little children that died when another Prozac kid with a gun went and killed him and got the gun illegally.
	And the media exacerbates it.
	They bring it up and they say Alex Jones is attacking these families when it's the media dragging this out every week of every month for the last five years saying this.
	The media never covered me in Sandy Hook at first.
	But they saw when I said, I think people died there, because Paul Watson totally convinced me.
	I was just asking questions and Paul got mad at me about this.
	And I've been on record for four years about that.
	I respect Paul.
	And so a lot of my listeners got mad at me saying, oh, you're covering it up.
	So they saw that as weakness in the media because I'm a real journalist.
	And they know full well.
	So I don't get equal time on Anderson Cooper or on Megyn Kelly or any of these programs.
	And they get these people up there And they say that I'm bringing this out and I'm victimizing them.
	Megyn Kelly called me in April of last year, early April.
	She said, I want to come to town.
	Well, you heard it.
	I secretly recorded it.
	And I said, listen, I'm not getting into Sandy Hook or Pizza Gate.
	She goes, oh, no, I'm not going to get into that.
	No, no, no.
	It's all about you and your custody battle and how interesting you are.
	You're such a man.
	I want to watch dinner with you and, man, you're really, you know, all this other stuff.
	I recorded the first part, she was saying how good looking I was, stuff in the car.
	I was driving to work one Saturday.
	I said, let me call you back in five minutes.
	Because it was like, oh, you're just so manly, you're so, and I was like, you heard some of it.
	Once I got here, I recorded the, you know, what was going on was I didn't even have a recording app on my phone.
	I have a voice memo thing, but it doesn't record phone calls.
	So I had to get another company phone and then record it.
	And I knew the total setup that I'm like, oh, really?
	Tell me about how sexy I am again, sweetheart?
	So you can read it.
	Alex Jones, Megyn Kelly, full interview leaked.
	You can go read that, listen to it, see it.
	So I'm saying, I will not talk about Sandy Hook.
	Do you understand, honey?
	Oh, yes.
	Then she has the bold cojones.
	To go on her TV show yesterday morning with some of the parents and say, isn't it horrible?
	He keeps bringing it up.
	Isn't it horrible?
	He's sending crazy people to attack you.
	I'm not covering it.
	I'm not bringing it up.
	I'm telling Megan Telly.
	I don't want to talk about it.
	She's here a year ago in the eight hours she interviews me to edit together.
	And I keep saying, I think Sandy Hook happened.
	Well, why'd you say this?
	Why'd you say that?
	I said, well, I questioned some of it, what was going on early on because of anomalies and a stand down.
	Adds that together to reissue it and put it out.
	The woman is the consummate snake.
	She is a, in my view, a corrupt, evil, lying lawyer, masturbating as a journalist who is a monster, affront the truth, who wants to create a chilling effect to shut down alternative information news because her ratings are in the toilet, all the rest of MSM. Stop victimizing the people of Sandy Hook and the people of Pizzagate.
	Stop it!
	So, Donald Trump's been in office less than a year and a half, and like Lazarus, America has crawled out of its tomb, economically, culturally, Lazarus has a heartbeat.
	He looks like hell, smells bad, but he's on the mend.
	And the Vanshees, the vampires, are going into connection fits of intimidation, of bullying, of just going wild.
	And a lot of Americans are saying, I'm going to keep my head down and see who wins this.
	You're not Americans if you do that.
	America is America because we had guts.
	We stood up.
	The whole world, every major historian said, we were smart, hardworking, and Maynard in hell, stubborn like a mule, didn't back down.
	That's what built it.
	That's why, on average, we've got all this wealth.
	It's because we're not easy to push around.
	Well, I see myself as a throwback then.
	But America was the vanguard, the cutting edge.
	We're not going Remember that headline, in fact, type that in, it's from CNN. Obama founds legal group to stop Trump agenda.
	Didn't say Russia, to stop Trump.
	They developed a little breadcrumbs to put out the new fake suit and the Democratic Party with all its money gets behind it.
	To crush these individuals, you talk about Federal Elections Commission issue, they shouldn't be able to do that.
	Should the Republicans be able to fund all these people?
	So they can defend themselves?
	Oh no!
	Democrats will say, no, no, no.
	We can use our money to sue you, the deep state, but you can't use any government money to stop us.
	Robert Stowe is the next segment, but let's get back briefly to Megyn Kelly.
	I may just play a few minutes of this though.
	It really is hard to watch.
	CNN, NBC, all of them are in the tank.
	They admit that.
	And they're doing everything they can To try to shut down liberals, conservatives, you name it.
	In fact, there's a big hubbub on the internet today that all of these mainline Democrats who are very, very popular but have their own shows like Jimmy Dore and others.
	CNN is now pushing to have them block their monetization taken and to have that removed.
	Now CNN admits a month ago they've been lobbying to have us removed.
	What we've said to try to set the case for that.
	So they defame us and they try to silence us so they can tell lies about us and no one can respond.
	Just like I got hundreds and hundreds of media requests saying, what is your statement?
	What is your response on Monday?
	And I sent the media a video response And still, for days after days, they say, oh, Jones didn't respond.
	Jones didn't respond.
	Megyn Kelly at least said, oh, he did respond on his YouTube.
	Lady, I got on an airplane and come up there and got in the studio with you and the father of one of the victims.
	I just said, sir, I've been saying for years that I'm sure people died there.
	And I never said for sure nobody died.
	I said that I played devil's advocate and said I could see why some people don't believe the government because it's a lot about babies and incubators.
	But it's been edited and then it's brought back up like I'm bringing it back up.
	I'd say, Megan, you told me before you came here we weren't going to get into Sandy Hook.
	But then you got into it and then you say I'm a horrible person bringing it back up.
	You're the horrible person.
	Ladies and gentlemen, I am not going to be a statute in the law.
	They want the Alice Jones statute to preemptively ban people and preemptively ban questioning public events.
	They don't want you to question their narratives when they put out their narratives of chemical gas attacks and three times it turns out to be the rebels.
	We're not sure this time, it's still up in the air.
	But they have the motive.
	And Senator Paul and all these other generals said that Assad doesn't have the motive and the rebels have been caught staging stuff before and they've been putting out fake videos of gas attacks and admitting it's fake.
	I mean, this is getting crazy.
	And what does it say in internal Google documents from a year ago?
	We want Joe shut down because he changed the narrative on Syria chemical attacks being staged.
	They don't want me here, so you don't have a voice, so we can talk about this.
	There's another article on Infowars.com.
	CNN associates Infowars with Pedo Channel in bid to shut down its competition.
	And hundreds of liberal channels that are popular, but that are independent and anti-war, they're being shut down.
	They're being blocked.
	And the left is so upset that people like Jimmy Dore has left the Young Turks, and he's more popular than them now, and that they want him off the air.
	That's what this is all about.
	I've invited Jimmy Gore on the show.
	Doesn't matter, we disagree on 80% of stuff.
	We agree, and he points it out, that they're shutting down conservatives and liberals that are non-interventions.
	CNN, and compares this to Nazis and pedophiles in the same newscast.
	I've got a lawsuit.
	I've got a real defamation suit.
	Because this stuff is causing damage with advertisers openly saying they're saying this so we lose advertisers.
	You understand what we're saying here?
	They say, Malice LeFour thought didn't do harm.
	They compare us to pedophile sites, white supremacists, who by the way have a right to operate, I don't agree with them, they have a right, pedophile sites don't.
	And then say we should be taken down.
	That's all in a CNN report last night.
	This group that forced fiends itself to you at hotels and bars and restaurants and train stations and bus stations and That you just can't get away from.
	It's like syphilis or gonorrhea or herpes.
	It won't go away.
	It's just always there like a cold sore coming up.
	CNN is raping this country.
	Raping the First Amendment.
	And it's all part of this big deep state constellation attack that's going on.
	Let's play some of this.
	This is Megan Kelly.
	Father of slain Sandy Hook first grader Alex Jones must come clean on his life.
	So They accuse me of being a liar and calling them liars in the suit.
	It was filed in Travis County on Monday.
	They say also that I must do a retraction and I refuse.
	They sent the letter last Wednesday.
	It had months for me to do an apology or retraction, but I can't apologize or retract something I didn't do.
	Then they instantly file it, say that I'm not apologizing, say that I'm saying nobody died, And then saying, why won't he go away?
	Why won't he stop saying and stop bullying us, Alex?
	Well, my audience knows what really happened.
	This is worldwide news from Australia to Taiwan to England.
	Sandy Hook father hauls out all his shows on Megyn Kelly.
	It's amazing.
	Megyn Kelly had like a vampire.
	Has been on this story and bringing it up and misrepresenting what I've said to hurt me.
	And she brings the pain up to the families again.
	And I'm sure they're smart people, these families.
	You know, they don't want this pain to their family and the memory brought up.
	I'm not bringing it up.
	Except when they're in the news and the media is there saying, I've said things I didn't say.
	So I'm going to ask the families to actually look at what I've said.
	And to come on this show.
	But you notice, I'm not invited on any of these shows.
	It's all gotta be one-sided so that Megyn Kelly can lie to everybody.
	Roger Stone's coming up.
	I'm gonna probably put on the end of this some of the clips, but it's just insane.
	I probably should shoot a whole special report on this Megyn Kelly thing.
	Because they're the ones bringing it up.
	They're the ones misrepresenting and saying I am.
	It's total and complete fraud from the media.
	We are here for a hearing in damages, and the law limits what I can and cannot argue.
	I'm not arguing that this is a political case.
	I showed you that exhibit so that you recognize some of the clips and snips you saw.
	You see them in contact.
	And does that really sound like the kind of man who put a target on the family's back?
	Does it sound like somebody who sat up at night deciding, I can monetize the family's grief?
	If it sounds that way to you, then you'll do what you think is appropriate.
	You will see a series, and you have in this trial seen a series of videos, small segments of larger videos.
	They're like 1A, 1B, 1C, 1E. If you're in the jury room and you want to see the truth, the whole truth about Alex Jones, ask to view a couple of those videos.
	Zach, can you show us one E? This is the attack.
	Look, people gotta find the clips the last two months.
	I said they are launching attacks.
	They're getting ready.
	I can see them warming up with Obama.
	They've got a bigger majority in the Congress now and the Senate.
	They are going.
	Look for mass shootings.
	And then magically it happens.
	They are coming.
	They've already taken over healthcare.
	The premiums are doubling.
	They're bankrupting that.
	They're already shipped GM to China.
	They are gonna gut this country.
	They're gonna shut down the power plants.
	They're gonna bankrupt us.
	They are re-educating us.
	Just like we were Ukrainians.
	And they're Russians.
	They want us bankrupt.
	They want the counties and the cities bankrupted and federalized.
	The feds themselves run by globalists.
	What does the new magazine say?
	You can get it by subscribing.
	You can get 12 issues.
	This man wants your guns.
	And I break down here, they're declaring war on the Second Amendment period.
	They are declaring war on the Second Amendment period.
	They are coming after our Second Kill America in 2013. That is their goal.
	That is what they want.
	They are moving to do it.
	Send your tips to Real Alex Jones on Twitter.
	Tell me what you think.
	Con-- You've seen that video any number of times.
	Twice now this morning.
	And how many times during trial?
	I don't know.
	Take a look at one while you're deliberating and ask yourself whether that's the conduct of a person who put a target on the back of families he'd never met.
	He was reacting.
	He told you from the stand.
	Mr. Matty asked him, you care about your integrity more than anything, don't you?
	No, he said, and I'll do my best Alex impersonation.
	I care about smashing the globalists.
	They ridicule that.
	That's their right.
	There's a larger context for the speech than the speech has been presented to you here today, and it's in evidence.
	All you have to do is look at it.
	They're all plaintiffs' exhibits.
	They're not my exhibits.
	They picked and they chose what served the narrative, their narrative.
	All of us, I think some of you are a little bit younger, all of us recall where we were the morning of December 14th, 2012. And you heard news that you just couldn't imagine to be true.
	I was pacing the halls of another courthouse on the other side of the state awaiting a verdict in yet another case.
	And I thought, my God, how can this be?
	Children murdered in a school.
	My first reaction was fear for my client.
	It was a murder case.
	I wondered whether the jury would hear that and hold the gun against it.
	I'm old.
	My kids are gone.
	My thoughts didn't turn to them.
	Mr. Jones' first thought turned to his narrative, the deep state.
	Mr. Matty showed a statement that he made about a global conspiracy of We want to control, enslave, and kill us.
	There's a crisis going on in this country.
	I led my opening statement with it.
	I give it to you now.
	Are these the words of a man who, for the sake of a dollar, targeted these families?
	Or are they the words of a man who's lost trust in our basic institutions?
	Over the portal, the doorway of the United States Supreme Court are the following words.
	Equal justice under law.
	Equal justice under law.
	Every person in this country accused of anything has a right to come into this courtroom and rely upon the rule of law as a defense.
	And every person, at least in most cases, has a right to come to a jury and ask the jury to evaluate the case under law.
	Mr. Jones is doing that.
	Did he take the stand and say, in your presence, in the presence of Judge He has his reasons.
	They're not for you to consider.
	Did he stand in this courtroom and go toe-to-toe with Attorney Maddie when Attorney Maddie launched an assault on him?
	That seemed to be a little bit more than was called for.
	Yeah.
	Called him an ambulance chaser.
	He said, you know, nobody complained about others when they did similar things.
	That was an ugly display.
	I'm not sure why it happened, but it did.
	But you saw it.
	And I was reminded of the words of Aristotle, and what Aristotle said by anger, and I'm going to read it so I don't get wrong.
	I might be Greek, but I'm not as smart as he was.
	Anyone can become angry.
	That is easy.
	But to be angry with the right person to the right degree and at the right time and for the right purpose and in the right way, that's not within everyone's power and it's not easy.
	I would suggest that a good part of the plaintiff's lawyer's case in this matter was an effort themselves to chin up anger.
	Because this is a hearing of damages.
	And the angrier you get, You're sort of like a pinball machine.
	Put enough anger in here, pull the lever, and maybe all that money they talked about will pop out.
	It's not the law.
	The judge will tell you the law, and if I misread this, listen to the judge.
	Under the rule of compensatory damages, the purpose of an awarder I'd ask you to take that to heart, because right now I'm under that portal.
	Equal justice under the law.
	I'm pleading my case for what might be the most unpopular man in Connecticut, if not America.
	And I'm not apologizing for it for one moment, because I trust you.
	I trust you.
	I trust you.
	I trust each and every one of you.
	We've sat through a veil of tears in Could not help but to have disturbed your sympathy.
	Could not help but to give you a bias against Alex Jones.
	The judge will tell you, sympathy, bias, and emotion don't play a role in a hearing in damages.
	I didn't write the law.
	I'm a lawyer.
	You must follow it.
	You must follow it.
	How much damage is really proven in this case?
	They've given you some numbers.
	I'm not going to comment on their numbers.
	Well, I said that and now I'm getting ready to do so.
	They've given you some numbers and they've given it to an estimate and basically said it's up to you.
	Now it is.
	But they didn't talk to you about everything you're going to be asked to decide.
	And I want you to ask yourself, why?
	Who's in it for the money here?
	Who's in it for the money here?
	I'm not going to pick on the plaintiffs.
	You notice I hardly questioned any of them.
	I'm a father too.
	I cannot fathom the grief that these people have endured in the loss of their child.
	You heard gripping testimony.
	They lost their grip on the world.
	I could go moment to moment and I tried not to think beyond the next step because I did not know what would happen.
	I lost my moorings.
	They lost their hearts, a part of their soul.
	Alex Jones didn't I've never heard the name from the plaintiff's lawyer.
	Adam Lanza did that.
	Alex Jones reacted from afar because he thought it was another sign of his conspiracy and the judge will tell you that as a result of a ruling on another day, Jones knew it to be a lie.
	That's what the judge will tell you.
	But you will evaluate the evidence in this case and reach conclusions about how persuasive the case that the plaintiffs put on is.
	That's your job.
	Not mine, not theirs.
	Now when you go back into the jury room, you're going to be shown a form, a verdict form, and you're going to be asked plaintiff by plaintiff to make decisions about a dollar amount to give them for damage to their own defamations, slander damages, a dollar amount for emotional distress.
	And suggestions were made about how to arrive at that sum.
	Depend, you know, 550 at a minimum, 8 point something billion, I think, is what it comes to, multiplied times 15.
	It would take a person earning $100,000 a year, hundreds of years, to make $550 million.
	Where did that number come from?
	And what didn't the plaintiff's lawyers tell you?
	They told you you're the conscious of the community, you know, hold out, accountable, make a point.
	they never talked about the damage that he actually caused these folks under this in this hearing of damages.
	You heard from no physician You saw no medical bill.
	You heard nothing about a lost wage.
	No receipt for anything has been put before you.
	You'll have some anecdotal evidence in the form of affidavits in the jury room.
	They may have bought a security system, but they're not asking for economic damages.
	They're asking for damages for their distress.
	And from the plaintiff's perspective, you can't get enough.
	You have to do this, they told you in opening statements, to stop Alex Jones, but that's not why you're here.
	You're here to award a fair, just, and reasonable amount.
	And I can see some of you looking at me with some skepticism and thinking, eh, what do you call a lawyer at the bottom of the ocean a good start?
	No.
	I am here to vindicate the promise of equal justice under the law for a despised human being.
	And there is no place on earth that I would rather be than right here, right now, with you, urging you to According to law, you make the world a better place.
	You, as jurors, are the hope of our community.
	In a time of deep divisions and anger and the sort of stuff that you see Alex talking to his millions of people on the air, you get to speak truth to rage, you get to speak truth to power, you get to speak truth to plaintiff's lawyers.
	Here's what they didn't tell you when they were asking you to pull the casino lever on money.
	You also get to decide a simple yes or no question here.
	should Alex Jones pay punitive damages.
	Why didn't they leave that out, do you suppose?
	I'm going to tell you, I've got my lunch.
	There's no money in that.
	The money the judge will tell, punitive damages, is an award of attorney's fees and costs.
	That's not going to be 100 million, 200, I don't think.
	There are a lot of lawyers here from that firm, some at the table, some in the audience.
	It's not going to be $100 million.
	So they gin up the compensatory damages number and say, give us all you can imagine.
	It's up to you.
	You decide.
	Is $550 million the minimum?
	Maybe $8 billion is the maximum?
	You decide.
	And do it as the conscience of the community to send a message and so forth.
	That's what punitive damages are for.
	The judge will tell you there's a difference between compensatory and punitive damages.
	If you think Alex Jones deserves to be punished, Let's take a look
	Take a look at the evidence that you were shown.
	I'll be honest with you.
	I'm not going to say much about the planes.
	Again, I remind you, I didn't cross-examine.
	What do you say to a woman who loved her child?
	We had hours of what amounted to memorial service here.
	The memorial service, perhaps, the group of them never got to have for their children in 2012. And the portrait that emerged is that these were the luckiest children alive.
	They were much loved, doted, cared for, and their parents wanted nothing more than to be good parents for them.
	And then according to the plaintiff's theory, within hours he heard about this and he reached the conclusion, I must target them for work.
	That's their claim.
	But they produced what I assume is the best case they could marshal.
	The very best case they could marshal.
	I admit to you, they're lucky they're here on a hearing in damages.
	Let's talk about their evidence.
	And you heard about it this morning.
	Mark Mills, remember him?
	He's the guy who, in February of 2014, crashed a Super Bowl press conference.
	9-11 was an inside job by the government.
	Alex admired that.
	He talks.
	Gee, we should talk later.
	Matthew Mills turns up at a Soto road race, and they want you to believe Alex sent him.
	Turned up in November of 2015. How many months later?
	They didn't have to put on evidence of disordering or any damages, but they elected to put it on, and I think I'm within my rights to comment on it.
	As to Wolfgang Halbig and Dan Badandi.
	Is there any evidence that they ever visited a family member?
	A business card on a windshield would put it there.
	Alex Jones didn't invent the internet.
	Alex Jones didn't invent the divisions in this country.
	Even Clint Watts had to acknowledge the following.
	You'll remember Clint.
	He's the guy who went to West Point, then did a breach in the FBI, and then went somewhere else, went back to the FBI, and now formed a consulting firm.
	And Got paid $925 an hour to come here and tell us about messenger, medium, and method.
	And he talked about fear.
	And I asked him about the relationship between fear and anger, and he really couldn't comment on that.
	But I did follow up with another question.
	Mr. Watts, were you saying that Alex created this fear in people, or was he responding to fear that was already there?
	and he couldn't say.
	I thought Watts' testimony was amazing, frankly.
	Thank you.
	Watts is a social media expert.
	He got his chops studying Al-Qaeda, he told you.
	And then once Al-Qaeda was struggling with He also said he offered his services to others, to businesses.
	To understand how social media could yield networks.
	How social media could yield influence in the world.
	And he never really took a position on what he thought of Alex Jones.
	Is Alex Jones a terrorist?
	He died.
	Or is Alex Jones a businessman who kept his business afloat by appealing to the fear of people he saw in the world for the reasons that you saw on exhibit 45?
	This is not a case about politics.
	I remind you about that.
	And it's a case about how much money will compensate the plaintiffs.
	You saw videotapes, ugly videotapes, and you'll see them again in your bubble, I suspect, of Alex taunting Robbie Parker.
	And your heart went out to Robbie Parker, as did mine.
	He is a good and decent man.
	He did not deserve any of this.
	You heard testimony about emails.
	You heard testimony about comments on memorial pages.
	Just a few that were apparently on Earth last month.
	You didn't see these emails they received.
	You didn't see the letters they received.
	You didn't see the notes left on the door.
	One of them was down in North Carolina and somebody said, do you go to church?
	I was inspired to be flip and use humor.
	You know, was it a Satanist?
	No, that's Alex's fault.
	No video clips of the harassment, no police reports, no law enforcement officers, no court records about what happened to Mr. Mills after he was arrested, what he was arrested for even if he was convicted.
	No one to corroborate the plaintiff's complaints but themselves, one after the other.
	And it all started to sound the same.
	And what you'll find is it was an average of 27 minutes in each plaintiff's testimony before they got to Alex Jones.
	And they always skipped over the day.
	And there was a highly stylized presentation of the evidence.
	It sounded the same witness by witness by witness by witness by witness and it was always the same sort of complaints.
	And it's all Alex's fault.
	Alex invented fear.
	Alex invented anger.
	Alex invented what's wrong with this world.
	Kill Alex and we'll all live happily ever after.
	Do you believe that for one moment?
	No doctors, bills, reports.
	Very few mentions of treatment.
	Bill Oldenburg, the FBI agent, said he went to get EAP treatment, employee assistance treatment, or talk to somebody for six hours or so after the shooting, or six sessions or so, rather.
	Sometimes in the mail, on the phone, sometimes in the person.
	Ten years later, he did it again.
	And his complaint is that he's He's a hero.
	So was every other law enforcement officer that went there that day.
	None of us would want to walk into that veil of trauma, not for one moment.
	I thought Watts' testimony was interesting in another way.
	I asked him, "Mr. Watts, you've read Shoshana Zuboff's book, The Age of Surveillance Capital." No, I haven't.
	You haven't?
	No, no, but I know what surveillance capital is, he said.
	And we talked about it.
	It's the marketing of our worst emotions, usually by social media companies, so that they can get data about us to manipulate us and sell us things.
	That doesn't make me, Alex, a conspiracy theorist.
	That's the reality of where we're living right now.
	That's why there's so much debate about social media.
	No lawyer in Connecticut or anywhere can walk into this courtroom and expect anything but scorn, and I will be attacked by Mr. Pascalt in his rebuttal to me.
	It will be Mr. Pettis that, Mr. Pettis this, all in an effort to gin you up and get you angry.
	It doesn't mean a thing here for the plaintiff's lawyers if it doesn't go ka-ching.
	So I'm going to just, just one moment please.
	Attorney Pettis?
	Yes, Judge.
	I'll move on.
	No.
	Stop the clock.
	I won't use your time on this.
	Please refrain from any further personal attacks or comments about the plaintiffs' lawyers or their law firm.
	It's highly improper.
	Let's move on.
	Let's talk about the plaintiffs' case.
	I don't want to hear it again.
	Yes, Judge.
	I'm not Alex Jones.
	I don't hold this judge in contempt.
	I believe in equal justice under the law.
	But I also believe in your unique powers and urge to use common sense and to evaluate the evidence in this courtroom and to evaluate the proceedings in this courtroom.
	I'm not asking you to endorse Alex's decision to erupt at the end of what I would call a vicious riff in cross-examination.
	I'm not asking you to excuse his decision not to come back to court.
	He believes it's a rigged system.
	You heard him say it.
	He believes you're great.
	You know better.
	Each of you knows better.
	and you will restore some confidence in some people, including viewers, by returning a calm and dispassionate verdict.
	It's not as though Mr. Jones didn't turn up to this trial at all.
	My recollection is he was cross-examined for the better part of a day.
	A day.
	The plaintiffs could have asked him anything they wanted.
	I think.
	I would have objected, certainly, if I thought it was objectionable.
	They never asked him about his net worth.
	They never asked him what expenses he took to operate his place.
	They never asked him what it would cost to run an organization with 70 people.
	They never showed him an organizational flow chart that turned up somewhere from someone through my office that no employee in that firm ever said they saw.
	Objection.
	The jury's memory has served them.
	It's a single talent business, the father told you.
	It all revolves around Alex Jones.
	I told you in the opening statement, he's a Dennis the Menace type character, a whirlwind of activity.
	You saw it in this courtroom, you saw it on the videotapes.
	Not everyone's cup of tea, but millions of people are tuning into him, and they're tuning out of what he calls mainstream media.
	Why?
	People have lost confidence in public institutions.
	The way this case broke, because it's a default, because of the various rulings from the court, I can't say much more than I've said to poor Alex Jones.
	But when I am attacked by Mr. Koskoff, be assured that there are things I wouldn't say if I couldn't.
	I'm going to have to trust you, as Mr. Jones will, the community will, and everyone will, to follow the law and render a verdict in this case that gives Mr. Jones fair, the plaintiffs, rather, in this case, fair, just, and reasonable compensation.
	You consider emotional distress under the court's instructions, reputational harm under the court's instructions, and then a yes or no question Punitive damages under the guise of compensatory damages.
	Simply not your role.
	May I have one moment, Judge?
	I just want to take one look at my notes on the opening arguments to see if there's anything that I need to address.
	There is.
	You were shown social media impressions.
	And Mr. Watts has claimed that there were lots of them, 550 million.
	Have any of you ever visited a website that you like?
	Do you do it more than once a year?
	Do you do it more than once a day?
	I mean, they said 9.2 billion impressions over a three-year period.
	That's more people than are alive.
	Are they claiming millions from another planet looked at some of Mr. Jones' things?
	You just can't unpack these numbers in a sensible way.
	And they had the opportunity to do so.
	It was their burden of proof.
	You look at the engagements growing and Zach, I'm going to need you to show us exhibit 183.
	This is a plaintiff's exhibit.
	They're talking about, I gather, what they're going to do to get ads.
	For the 20 plus years Alex Jones has stood voicing the questions of the ignored and forgotten and the unappreciated.
	And with the help of experts, whistleblowers, and insiders, Alex Jones no longer stands alone.
	He now has a vast network behind him with a wide range of guests like Ted Nugent, Roger Stone, Megadeth frontman David Mustaine, director David Lynch, and Mike Judge.
	From Charlie Sheen's famous tiger blood rant to Donald Trump's promising, I won't let you down, Alex.
	Your reputation is impeccable.
	Alex Jones and Infowars is firmly rooted in American culture.
	Infowars is no longer on the fringe or now one of the leaders in the new age of media, or the new wave of media.
	I read you that.
	It's in evidence.
	It's not my exhibit.
	You've already seen it.
	And you see this chart when they were trying to show you that Alex does everything for the sake of a buck, and they showed his numbers grow from 14 to The man who said, I won't let you down, Alex.
	I'd like to...
	Sustained.
	This is not an action to compensate the folks at Sandy Hook for the loss of her children.
	Alex Jones is not Adam Lanza.
	This is not an action to compensate Ms. Hensel for the suicide of her husband, Jeremy Richmond.
	There's been no evidence about the cause of that.
	This is not an action to make a political statement to silence Alex Jones, no matter how satisfying that might feel to you or to the plaintiffs, and perhaps to others.
	I suspect Alex Jones will never be silenced.
	He's a mad prophet, warning of a dystopia to come, like the protagonist in Orwell's 1984, Like Aldous Huxley in Brave New World, when he talked about Soma, and if we could just drug ourselves into compliance, we'd accept any direction.
	Like Margaret Atwood in The Handmaid's Tale, where she talked about how a patriarchal society would use women as nothing other than breeding machines.
	There have always been mad, creative geniuses in the world who feared what was to come, and they speak loudly, and we have choices about whether to listen.
	But nothing in their speaking gives them the right to hurt others, and I'm not suggesting they do.
	I'm simply suggesting to you that if you fairly, calmly, and dispassionately look at the evidence in this case, you'll see that although it's a hearing in damages, it's a hearing in damages for an extraordinary purpose.
	Consider.
	You saw one evening.
	They're coming.
	They're coming.
	They're coming for our guns.
	It's an attack on the Second Amendment.
	I had one of the family members up.
	I believe it might have been Mr. Wheeler.
	He watched the video, still couldn't tell us what he thought Alex's position was.
	People are filling in for the President and giving a national address on gun control.
	They can't have feelings about what Alex knows about guns.
	Nobody heard of Alex until somehow in 2018 they all got together somewhere and decided to sue him.
	Objection.
	Jeremy Richman told you why he took action against Alex.
	Jeremy Richman is deceased.
	Thank you.
	You're exactly right.
	Robbie Parker told you why he took action.
	Parkland shooting.
	I would suggest, and I'm going to be Did they exaggerate some of the harm here?
	For the sake of politics, for the sake of guns, and the desire to make sure that this never happens to someone again?
	That no one else ever loses a child?
	Yeah, it makes you uncomfortable when I say that.
	I see you looking away.
	But it's a fair question, and it's one you have to wrestle with.
	Because otherwise, where was all that moment of proof about the The
	law requires that you serve equally, coolly, dispassionately to evaluate the evidence and render a fair, just, and reasonable verdict.
	I'm going to end this with what I call the trial law It occurs.
	It leads to justice, and it restores my soul and the soul of the community.
	Your soul.
	Yea, in this case, it's never been truer than this case.
	Yea, though I walk through the valley of the shadow of death, I will fear no evil, for the jury will fear me.
	It's judgments and good sense that say that they will comfort me.
	The court prepares a table for me in the presence of my enemies.
	I will be shrouded in justice.
	My cup runneth over.
	And mercy, perhaps, goodness, mercy, perhaps justice, will follow me all the days of my life.
	And I will dwell in a court forever, but maybe not.
	Thank you.
	My time here has ended.
	It's probably the one soon in life in general.
	and then you get to 70s, there's no wonder.
	Thank you for your kind attention.
	I beg you, follow the law in this case.
	Put aside passion, prejudice, and sympathy.
	When I'm attacked, I warned some of you during jury selection.
	It's not a popularity contest.
	Yeah, they're nicer guys.
	Okay, I get that.
	But in the dark night of the soul, when they come for you, All right, so we're just coming around to the lunch hour.
	We will take our hour and lunch.
	We'll start up again at 2 p.m.
	for the plaintiff's rebuttal, which I understand Attorney Koskoff will present, and then we will turn to the charge, which I will give you on the law to apply.
	But one thing I do feel compelled to say, this is a civil case.
	I do not like to interject myself or interrupt counsel.
	Certainly, you saw that I did interrupt Attorney Pattis.
	I just want to assure you, so that you're comfortable, that the court will not tolerate any personal attacks on lawyers, which is why I interrupted Attorney Pattis.
	Certainly, the evidence can be commented on and arguments can be made, but there will be no personal attacks on Attorney Koskoff or Attorney Patis or any lawyer in my courtroom, it's my job to control the proceedings, rule on objections, and so I will continue to control the proceedings along those lines.
	All right?
	So with that, I will send you off to lunch.
	You'll continue to obey the rules of juror of conduct.
	Maybe you can get some fresh air.
	looks nice out there and I will see what to and I'll remain on the bench.
	Thank you.
	Thank you.
	I'm just not sure what to say, Attorney Pettis, because I've never heard the comments about the personal attacks along those lines, and I did interrupt your close and make comments.
	I would entertain some further language if either or both sides wants to submit something In the charge if anyone thinks it's necessary.
	Understood.
	Thank you, Your Honor.
	Okay, so I will see everyone at 2 p.m.?
	Your Honor, before we recess, may I ask one question?
	Sure.
	Would it be possible to see a final copy of the court's charge?
	I'm working off of a redline copy, and I just want to make sure that when the court reads it that I know what's coming.
	I'm working off the same copy, so nothing I can share because it's literally my handwriting at this point.
	I'm going to order a transcript, so we'll have that.
	I appreciate that, Judge.
	And could we also perhaps see a copy of the final verdict form before?
	If I can open what you sent me, I'm simply going to go into that document and delete the language.
	If I can open it, if I can't open it, I'm going to let you know, and I may look to you to do that.
	Okay, Your Honor.
	- All right, we'll take the recess. - Right then, and then it's recess until 2:00 a.m. - Second. - So my thought process was to and then it's recess until 2:00 a.m. - Second. - So my thought process was to finish up with the closing arguments, then We can go.
	I know there were a couple issues Ron just told me with the verdict form, and I had a couple minor things with the charge I wanted to go over, but we can do that during the break.
	That's perfect, Your Honor.
	Thank you.
	Okay.
	Well set?
	Yes, sir.
	Oh, and did Ron, did you have any exhibit list?
	I did photoshoot with the exhibit list that we intend to give the jury so that they could check it in case there was any errors.
	So if you could look at that when you can.
	Thank you.
	Thank you. - Thank you. - There we go, please be seated.
	Counsel will stipulate that the panel has returned.
	Yes.
	Yes, Your Honor.
	All right.
	Make yourselves comfortable.
	And Attorney Pascoff, whenever you're ready to return.
	Thank you, Your Honor.
	Welcome back to lunch.
	That was dark.
	There was some darkness that came over this courtroom.
	Wasn't it?
	Prophet, what is it?
	The shadow of death and Aristotle.
	It was sort of biblical.
	And I forgot what we were here for, for a minute.
	And I'll tell you what, you know, whenever you get attacked by the other lawyer, which is something I try to practice not to do, you know one thing.
	They have nothing substantive to tell you.
	They have no case.
	Because why would you spend the precious time that we have together attacking another lawyer on something that's totally unrelated to the case, right?
	And the other reason I am not going to engage in that is because I didn't hear what he said.
	So I might have fought back, but I just didn't hear what he said.
	But I wouldn't fight back anyway, because these families have come for a long, it's been a long odyssey, a long odyssey to get to this point, to be standing in front of you, sitting in front of you and sharing all that with you.
	And I don't want to cheapen this and play into this InfoWars Connecticut, what is that, Real Housewives of whatever?
	InfoWars Connecticut courtroom style, something like that.
	Because that's what they wanted.
	They want to get into an attack, a verbal assault, so that you can say, well, these people just are divided.
	I'm not really that interested in what he said about me.
	But he did mention Dennis the Menace.
	I don't know how old, I mean, I don't know how exactly old you are, but I look at you and I think there are at least 50% of people who have no idea who Dennis the Menace was.
	And I'm just wondering if the other 50% do or if this says more about me than The reason why you're getting characters, I will explain it to the younger generation maybe later, but the reason why you're being told about Dennis the Menace and about this being such a slipshot operation is because it's unfathomable that a grown man could have done what Alex Jones has been doing for the last ten years
	and continues to do.
	It's unfathomable.
	And in fact, some of you had heard, I think, of Jones, if I'm not mistaken, when we talked to you on tree selection, and you heard about the Sandy Hook thing.
	You didn't know much about it, of course, but I remember a bunch of you saying, why would anybody do that?
	Why would anybody do that?
	Right?
	Well, I don't think you'd be asking that question anymore, because you know exactly why I did it.
	And this idea that he's some kind of lovable, cartoonish character is really insulting.
	It's really insulting to these families.
	And you know what?
	Let me tell you about Dennis the Manus, though.
	I'll tell you what he wasn't.
	He wasn't somebody who prayed in the aftermath of shattering loss for his own money.
	He wasn't someone who...
	He lied and spread slanderous lies about people.
	He was lovable.
	He'd get into trouble and he'd break the neighbor's window.
	And he's appealing to those of you who know Dennis the Menace because he's looking for one person, one person, because he knows there's no chance that you all six would ever agree with the defense in this case.
	So he's just looking for one person to hook.
	But he miscalculated how much I know about Dennis and Dennis.
	And you know what else about Dennis and Dennis?
	He was a child.
	He was a kid.
	He was a kid.
	And there's nothing childish or funny or accidental or cute or comical about Alex Jones and what he did to his families.
	And that is an incredible, disrespectful thing to suggest.
	The other thing you may have noticed is this.
	We're not talking about politics.
	Let's get politics into the case part of the defense.
	Again, because there's no substantive, legitimate defense.
	The only chance is that you are the type of people who just lose who you are out of political zeal.
	The us versus them.
	The kind of climate that we are also sick of.
	We're also sick of it.
	That this beautifully united jury, these members of the community that Chris talked about, Let me see if I can tempt them and throw a little bit of red meat out to the Republicans or to the Democrats.
	Throw Trump out and see maybe the Democrats will run out of here with their hair on fire.
	Throw Hillary out and then watch, then sit back and, you know, let's have popcorn and watch everybody dissolve into the lesser versions of ourselves.
	Right?
	Why else Why else, after your hearing time and time again, this is not a political case, why would he bring it up again?
	That's why.
	Because there's one thing that is beautiful, I think, about a jury.
	It requires a unanimous verdict.
	Which means, despite everybody's superficial or Legitimately felt feelings about politics and about, I don't know, issues, guns, climate change, I don't know, COVID, whatever, that it requires a unanimous verdict.
	Because what happens, and in this case, more than any case that has ever been in the state of Connecticut, is that it needs to get past that layer that we live in so often in our lives.
	And get to who we really are, the ties that bind us together.
	He wants to rip apart those ties, which are the best part of you and the best part of the families and the best part of all of us.
	And he wants to drive a wedge through you.
	That's why you heard about politics.
	Divide and then disarm this obviously predatory human being.
	Who preys on people at their worst times and uses the deaths of, even the deaths of children, for his own gain.
	Does that sound?
	The answer's no here.
	Does that sound like a Dennis the Menace cartoon strip?
	What an insult.
	What an insult to all of us.
	And the biblical using I had to ask you.
	I know I've heard it many times in my life.
	But, you know, this shadow of death, it's a very serious biblical allegory.
	You know, it's serious.
	What is it doing in this courtroom?
	What is Alex Jones?
	A false prophet?
	If he's a prophet, he's a false prophet.
	And there are some biblical characters that you could equate Alex Jones to, but we don't need to go there.
	He comes in at a time when we are most divided.
	He reaps, he takes, but he never gives.
	He never gives.
	In our lifetimes, at the end of our lives, I've often thought about this.
	You have like a ledger, right?
	It's like your bank account.
	Your bank account of taking and giving.
	And everybody, except for a rare few individuals, none of whom are in this courtroom, and I suspect even my doctor, sir, Mr. Patis, is more of a giver than they are takers.
	And so at the end of your life, you end up with a net giving.
	Because we like to think of ourselves as givers.
	That's the best part of us.
	But there are a few people, if we're all on a little bit of the side of giving, there are a few people who take so much and never give, and they balance it all out.
	They balance it all out, right?
	Because takers tend to take everything.
	They're avaricious, right?
	And they don't conceive of giving.
	It's a socio, I mean they're sociopaths, right?
	I know you guys got this.
	You guys got this case.
	You're ready.
	I know you're ready.
	But I still have about 30 minutes.
	Okay?
	And Chris use up so much of the time.
	And I just want to point out, he misspelled slander.
	It's not sland.
	It's slander.
	Terrible.
	I had to find something wrong with this final.
	Oh, I'm going to show you my notes here.
	Okay, so I do want to cover a few things that were brought up.
	The idea that you need to see, have heard from a therapist, so that a therapist could get in the way between these families and your observations of them.
	Imagine that.
	I put up a therapist.
	You know what they would say?
	Why didn't we hear from the families?
	Why didn't we hear from them?
	They put on a hired gun, right?
	That's the way it works.
	And if you think about distress, if you think about our inner lives, right?
	And when we're suffering from some sort of grief or distress, and you reach out, right?
	That's what you're supposed to do.
	You're supposed to reach out to a friend, to a parent, to your spouse, to a community.
	And when you do that, it's somebody that you trust, right?
	Now, generally speaking, you don't reach out to juries.
	Because look around you.
	This is not a very intimate situation, is it?
	But in real life, when we're talking about what makes us us, those inner damages, we reach out.
	And we do it with our voices.
	Right?
	When you are having some difficulties, as we all have, and you contact a friend or something, and they say, come on over.
	Tell me what's going on.
	You sit We're not really that much closer.
	And you talk.
	You talk.
	Your friend doesn't say, I need some documentation.
	I'm suspicious.
	Right?
	Let me see some bills from your therapy.
	Hmm.
	That's not the way it works.
	There was no wall.
	No wall.
	Between you and your years of wisdom, common sense, knowledge of what makes us all human, and these incredible people, there was no wall.
	And if you think that we were going to let Alex Jones dig in to their therapy records, then you don't understand the type of protection that these people need to get.
	Doug in.
	How quickly would they have made into InfoWars app to malign these people?
	What a disgrace.
	I mean, it's just, I don't, you run out of adjectives, and I don't want to take that from you.
	I want you to understand it.
	I want you to feel how terrible, what terrible things you've learned, but I don't want you to stop at what terrible things you've learned, because I want you to see, hear, and feel what wonderful things you've learned.
	Because what this case proves is that while there are some really bad people out there who take and take and take, there are some really, really, really great people out there.
	In fact, most people are really great people.
	And, you know, you're going to be getting to a verdict in this case if I ever stop talking.
	And the case, I'm sure, has taken a lot out of you guys.
	It's really hard because you see these extremes.
	You saw the worst, and you saw the best, and it's heartbreaking.
	And it's heartbreaking to see the worst, to think that people could do this thing.
	It's terrible.
	It's a terrible feeling.
	So after the verdict, take some time for yourselves to wash this off, to work through it, to process it.
	It's too much for people to handle.
	The other false kind of context that you got was, well, where are the other videos?
	Didn't we show you enough videos?
	Didn't we show you enough?
	I mean, I thought, I was like, I think the jury gets it.
	Do you really think that we have to show you more videos?
	Or were you really thinking, I get it, I get it, I get it.
	I mean, and by the way, think about it this way.
	Forget about this case.
	Suppose the New York Times ran an article that said, Sandy Hook parents are fake.
	They're frauds.
	They fake the kids at their death, their kids' death, and the kids never existed, right?
	And it was one article, and I don't know how long the New York Times is, but it's one article.
	The New York Times comes in and says, well, What about this article on the weather?
	This article on the presidential election?
	What about this?
	We didn't say anything about the families there.
	Okay.
	You don't get the exception.
	And the fact that there are a lot of other articles in there that don't completely slander and destroy and defame and demonize human beings who lost their kids is not a defense to the fact that you put something in there.
	So we could have sat here and watched thousands of hours of Alex Jones and probably found maybe 500 that he doesn't talk about, maybe more, I don't know.
	And we might have even found some of Jones's telecasts where he didn't lie, but was actually telling something that could be argued to be the truth.
	But if my recollection is correct, They accused us of not showing you enough videos.
	Did they show you any videos?
	When did they show you any videos in their defense?
	They showed you one video just now, and I honestly had no idea why.
	But apparently it was to make this argument, and also because I think Hillary's name was mentioned.
	They love Hillary.
	This is an us versus them thing, remembering their lives.
	But what they don't count on is that you all understand.
	And when you came in here, you came in from different backgrounds.
	I bet you're a little anxious, quite frankly.
	I was a mess when I walked in here, so I can't imagine what you guys were like.
	And you didn't know each other.
	You didn't know each other's background or politics or how they felt about, I don't know, COVID or something.
	But you look and seem much more comfortable now because, you know, those ties I find are really important.
	And...
	And this us versus them that has been perpetrated.
	You know, the only two times in my life that I remember getting jolted into that realization suddenly that we are all in this together, only two times that I can remember, because we've been divided for a while, it's getting worse, but two times.
	9-11, right?
	Remember 9-11?
	And we were jolted to remembering that we're human beings first.
	That was number one.
	And number two was Sandy Hook.
	And you know what?
	For Alex Jones, those were the best two days of his life.
	Those are the best two days of his life.
	I don't even know how much I have to tell you, but Alex Jones is a liar.
	You get that, right?
	This idea that he is even a conspiracy theorist is a lie.
	He's not a conspiracy theorist.
	When it comes to the truth, Alex Jones is nothing but an arsonist.
	He sets fire to the truth, and he spreads that roaring fire immediately from his place in Austin, up to Connecticut, to Washington, Right?
	Robbie?
	Remember Carly going with her husband down to the military base?
	All of that hate, all of that fire, that fire spreading in an instant.
	550 million oppressions.
	And that was the tip of the iceberg.
	That is a dangerous and influential person.
	A person like that could do such A person with that much influence could do so much good.
	And the one thing I wasn't sure about was it's really hard, and Chris mentioned this, it's really hard when you watch Alex Jones and you look at him and you think, this guy's a liar.
	He's an angry man.
	He's just a narcissist.
	He's all these things.
	What's really hard, I find, is this idea of why would anybody listen to him, right?
	You have to take a leap intellectually because it doesn't make sense to any of us that this man could be influential.
	But the numbers don't lie.
	And it's really important that you remember that your feelings about Alex Jones and how he doesn't influence you don't translate into understanding the degree of harm he can do, has done, and will continue to do until he's stopped.
	And when I say stopped, I'm not saying punish him for this, because Mr. Pattis mentioned, no, no, no, don't punish him for this.
	Recognize the damages of these people fully, fully, okay?
	We don't need to punish Alex Jones.
	We need to, in only one sense, you have to punish him with the truth of what he's done to these families.
	And that you do by compensating the families.
	Defamation, sland, ur, per se.
	The idea that lies are not accepted in our society, and there are all kinds of lies.
	A really bad lie is actionable, even if it's about a really bad person.
	And we know that from this case, because Alex Jones alleges he got slandered by the Young Turks, even though Alex Jones did send us a server with child pornography, and that's all the Young Turks said.
	Remember, Chris got into it with him.
	I mean, Chris gets into it, like he says.
	And so what the Young Turks were saying was actually true, but that didn't stop Alex Jones from suing the Young Turks.
	And we respect the ability of everyone, from the best of us to the worst of us, to be able to sue over this idea of being slandered.
	But the judge is going to tell you that character matters in assessing damages.
	Let me take it out of this case.
	Charles Manson.
	Most people are at number eight.
	If somebody slandered Charles Manson, he was one of the worst people.
	He was up there.
	But if somebody sued Charles Manson, Charles Manson could bring a case.
	But he'd be getting on more of the dollar side.
	He'd be making a point.
	Because it's important to police this aberration.
	Why?
	Why?
	Because lies get people killed.
	Lies cause genocides.
	Lies cause terrorist bombings.
	Lies cause people, cult followers, to drink poison.
	And lies cause people to harass other people, to threaten other people, to harm other people, and even to kill other people.
	And that is going to happen.
	We don't know when, but that is going to happen at some point.
	I want to talk about this idea just to show you-- so I want to go back to the law for a second because I got a little heated there.
	When you start something and it spreads, OK?
	Press that out.
	This is a marker.
	I've lost the marker.
	Thank you.
	Let's go.
	All right.
	This has got to be somebody playing a trick on them.
	Is it a market that opens?
	This is really important because the judge is going to tell you that Alex Jones is responsible, despite all the things that the defense counsel said that were objected and sustained.
	He's responsible for everybody, right?
	And the judge is going to tell you that.
	But let me just show you something that helps you understand that a little bit.
	Here's Alex Jones, right?
	He sits on top.
	There are some other crackpots out there, right?
	How big, some of the other people.
	We call them, I don't know if that's their official title, crackpots.
	Think of them as cells, right?
	Like your terror cells, whatever.
	I'm not trying to make that analogy too much, but basically they're free.
	They can't access this network.
	They can't access this potent network.
	And they need a person at the center.
	And that person for these people is Alex Jones.
	So you see that some of the other people call in, but those people don't have the influence that Alex Jones does, and we went over and over and over again.
	As soon as it hits this superhighway of spreading, of him setting the truth on fire and maligning people, it goes out to millions and millions and millions of people.
	Even before the internet, Mark Twain said, A lie travels halfway around the world before the truth is putting its pants on.
	That was even before Dennis the Dentist.
	So if it happened back in Mark Twain's day by postal service or whatever, you know it happens now.
	And if you are going to enrich yourself with this antisocial, I can't run out of adjectives, predatory behavior, And you have no holds barred?
	You know that you benefit from this.
	So if your conduct is wrong, it's going out to more and more people.
	And Clint Watts told us about how people are moved to do things that they wouldn't otherwise do with this kind of messaging.
	You've seen it over and over again.
	I think you get it with all these different factors working.
	We're human beings, and we think of ourselves as a fault, and we usually are.
	But we are still very susceptible to do things that we wouldn't otherwise do based on this kind of repetitive thing.
	And Clint Watts said, Time.
	Occurring over time makes a big difference.
	2012, 2013, 2014, 2015. Constantly reinventing, igniting that fire.
	Maybe during that time Alex Jones saw the fire die down at Sandy Hook and he needed a cash infusion, right?
	So he would light it up again.
	Why on earth would you talk about Sandy Hook at all after the police report came out?
	That ended the news on Sandy Hook.
	It didn't end the news for these families, because they live it every day, but it ended the real news.
	But he kept talking about it.
	Time, and then of reach and volume.
	That all goes into your determination on damages.
	I do want to say, these families, I have to ask you to take this very, very seriously.
	Please, please do not include in your award a single dollar because you feel sorry for these families.
	I don't care how beneficent you think that is.
	They don't want it.
	I mean, they appreciate it, but honestly, they don't want it.
	They don't want it.
	These families have had almost 10 years of sympathy.
	It hasn't all been these attacks.
	They've had 10 years of sympathy.
	They don't want it from a jury.
	They spoke to you because they wanted you to understand what Alex Jones did to them.
	There are harms.
	Each one sat here and did that.
	And we want to know, when you come in with that verdict that gets Alex Jones to understand that he's done when it comes to this conduct because of a harm it's caused, we want everybody in America to know you didn't include a single dollar for sympathy.
	I am serious.
	I don't know how I'd find out.
	But we want to bring your humanity to the table.
	The judge is going to tell you this is very important.
	We don't try cases to machines.
	And that's what I was talking about before.
	There is a difference between rank sympathy and understanding you're all experts in the emotional lives we have inside.
	You do need to apply that, and you need to have some degree of empathy, but not sympathy.
	Because Alex Jones, even right now, I didn't hear defense counsel say what Alex Jones thinks these damages are worth.
	And we know what the answer is.
	Zero.
	Alex Jones doesn't think anything of these people or these damages.
	He is the victim.
	The thing you just showed, that proves something that we really haven't been talking about much.
	Alex Jones is the real victim here.
	It's not the witch he unleashed on them, it's the witch they unleashed on him.
	I mean, would you expect anything else actually from them?
	And very...
	I want to talk about, oh, and the punitive damages thing, that's too sidetracked.
	It's just a check mark.
	We would like Alex Jones to pay the fees and costs of this case, and we would just ask you to check that.
	But this is where you're speaking to the family, okay?
	Defamation, slander per se, and the judge will talk about that when there are good people involved, and the lie is terrible, I'm paraphrasing, because the court appropriately is the one who's going to give the obstruction, and that's a third rail that I will never cross, but you'll hear that where you have the Charles Manson type that maybe get like Nothing but making a point.
	You have the super opposite of that, where you have substantial damages when something's done to good people who have good character, right?
	And I want to...
	Chris talked about character, and it's really important.
	Of course it's important because you need to know, is this somebody...
	Judges are going to say about credibility of witnesses, and you're experts in...
	In judging whether somebody's being open and honest with you, right?
	We try to do that.
	We spend our lives developing this skill.
	We know when somebody, most of us know, when somebody's giving us the runaround or something.
	So that's why it's like, here we are.
	You needed to see that because I knew, Chris knew it, we all knew it, they were going to make this argument.
	This argument that they were, this is just the Sandy Hook hoax 2.0 in this courtroom.
	So you needed to judge these people's character.
	And we are part biological, inherited from the characters of our parents, and part self-made, right?
	We're some combination.
	And you heard both parts here.
	Because I knew that this man, who represents Alex Jones and is doing the best he can, was going to come up here and work on your skepticism and cynicism.
	But I didn't think that anybody, any human being, could listen to these people like we all heard them and actually still accuse them of being actors who are faking their entries for political reasons.
	I didn't think that was possible, that any human being could have experienced what we all experienced and accused these decent family people Of still being actors and yet that's exactly what what defense counsel just did.
	That's exactly what he did.
	Let's not talk about defense counsel.
	The argument is that these good people have come up here and Spilled their guts to you.
	What was, as you know, very difficult, but which he made them comfortable enough to do.
	And each one of them was actually faking.
	Because when you accuse somebody of exaggerating their injuries for political purposes, you are accusing them of being a liar.
	And if you don't want to use the word liar because you want to So, in this case, you guessed it.
	About these families who have endured, first of all, nobody deserves this.
	The fact that they lost their children and their loved ones and their mother and their sister makes it that much worse, but nobody deserves this.
	And so in the case that for 10 years of them being accused of faking an event for political purposes, To take away people's guns, their defense is they are faking their testimony for political purposes to take away people's guns.
	This is InfoWars 2.0.
	And you are nothing but, I mean, according to InfoWars, you are part of the rigged hoax.
	So am I, so is everybody on the plaintiff's side, so is the judge.
	And you know they're talking about monetizing something.
	Did you see the video that they made of Chris?
	Who's in the casino, Mr. Jones?
	Who's cashing in their chips?
	And you heard about the plaintiffs not filing for a certain date?
	Well, can you really blame them for taking their time and not wanting to just jump into this?
	And having to go and have the support to do this as a whole.
	You think if one of these plaintiffs got up and did this, they would be ripped apart.
	They'd probably have to have 24-7 bodyguards like Mr. Jones does.
	The common man.
	With 24-7 bodyguards in his private jet.
	Coming to Connecticut where everybody's a billionaire.
	I don't know how I end up there.
	Right?
	And what is this man doing in our state?
	Why is he poisoning our well?
	Why is he poisoning our neighbors and our friends?
	And why is he poisoning our families?
	And why is he poisoning these families that we all care about?
	Because we're all from Connecticut and we're all in this together.
	Why is he doing that?
	And where is he?
	Where's Alex Jones?
	He spent more time outside, you heard, on press conferences, getting publicity and driving site traffic to his site, and the steps of this courthouse, than he did listening to his families.
	In fact, he could have spent a second outside at a press conference, and that would be more than he listened to these families and what he did.
	He is, he was, you'd see him in court once.
	What a What a terrible thing not to sit and listen to what you've done, even if you want to defend yourself.
	What a cowardly thing, right?
	It's cowardly.
	It's just cowardly.
	All right, I'm going to end on a nice note.
	This is so, you know, this part of it is just, it tears you apart, doesn't it?
	This us versus them.
	They're still in it.
	The they that are exaggerating without hearing exactly who, what are they exaggerating, why.
	It's very toxic.
	And it's really sad.
	But I want to conclude on this.
	And that is the jury and what is good about us.
	And I gather that whatever was said about me was an attack on, I guess, lawsuits maybe, but I'm not sure.
	But anyway, uh-oh.
	Okay, I've run out of poster boards.
	This is a good sign, though.
	Because if I don't have a poster board, it means it has to end sooner.
	Okay, so...
	You've got five minutes left.
	Verdant.
	Verdant.
	That, I know a few Latin words.
	Verdict, you know what that means?
	To speak the truth.
	Think about that, to speak the truth.
	There's never been a case where the word verdict gets more perfectly than this case.
	For 10 years, Alex Jones has not been speaking the truth about the families, about the event.
	Okay.
	For ten years, he hasn't been speaking their truth at all.
	And he doesn't have to.
	He's not required to speak their truth.
	But don't malign their truth.
	Don't stop their truth.
	Don't deny their truth.
	You lose somebody, the only thing you have is that.
	It's your ability to control the truth.
	You're grabbing something.
	You're just grabbing for something, aren't you?
	You just need it.
	You need a lifeline.
	You need the truth more than you ever need it.
	And so what I'm asking for, for these plaintiffs, these friends, these incredible people who did nothing to deserve any of this, who never maligned this man, Who he profited from?
	I'm asking you to restore that truth.
	and take it back.
	Okay.
	Oh, actually, there's one more thing else.
	That would have been a nice place to end.
	But I just want to say one other thing, which is you're going to have a lot of numbers, okay, to go through because of the way 15 plaintiffs...
	And what I want to say is, on behalf of families, work together.
	Don't...
	I mean, you should stick to your...
	You know, if it's work together to resolve, because I don't want you all to get hung up on whether it's this or that.
	The families want a verdict.
	They don't want to do this again, okay?
	So listen to each other, work together, be united.
	Remember the better side of the equation, the good side, the side we're proud of, okay?
	Thank you.
	All right, so we are going to take a 10-minute afternoon recess now.
	We have some minor things to do.
	So you'll continue to obey the rules of your conduct.
	We'll see you at five minutes of three.
	Then you'll come back.
	I'll instruct you on the law and just about ready to start deliberating, but you'll wait until I give you the green light on that, okay?
	In the meantime, no discussion about anything that you've heard, and we'll see you in 10 minutes.
	Thank you.
	Personal attacks?
	Nothing from the defense, Judge.
	No, Your Honor, I accept that.
	Thank you.
	All right, so I have a couple minor things.
	What I'd like to do is give us five minutes for a bathroom break when we're done here.
	So I just, I have, I think, four or five minor things.
	Page eight of the charge, and I asked this before.
	I'm going to ask it again.
	Are we saying what it says, that they are the same entity?
	I went over this this morning, and everyone agreed to the language again, but I... Thought we took the language out that they are the same.
	You know, Judge, I'm of two minds about it because I'm sorry, I should stand.
	I apologize.
	I'm of two minds about it.
	We took it out earlier.
	I didn't object this time.
	I would ask that it be taken out.
	I don't know what effect this might have on collateral proceedings in Texas.
	And that's my only concern.
	Well, we took it out.
	Your Honor had ruled on it before from my perspective.
	So I'm not going to re-argue our position on that.
	I think my objection is preserved.
	But I also understand that the charge should be consistent.
	Right.
	So that's why I asked this morning.
	We had taken it out in the other line.
	It says it here, so I think it needs to come out.
	But when I asked this morning, everyone told me it was okay.
	So, let's see.
	I think we can just say, in this case, the court has determined that Free Speech Systems LLC and Alex Jones both are responsible.
	That's right.
	Okay.
	For the actions and statements of the employees of Free Speech Systems LLC, correct?
	Yes.
	Okay.
	Yes.
	Your Honor.
	Just give me one split second.
	I'm sorry.
	of course yes um Just below that, there is a sentence that begins under Connecticut law.
	Yes.
	If you keep going down about two lines, there's a phrase, just as the broadcaster had said them.
	It should be just as if the broadcaster had said that.
	Correct.
	Okay, thank you.
	All right.
	The missing information we're leaving in, correct, on page 10?
	Which page, Judge?
	10.
	Yes, Your Honor.
	That was a new addition from the supplementals.
	I had one note there.
	I was not sure where to put it.
	We didn't have an agreement about where to put it.
	That seemed like a reasonable place.
	I think that seems to make sense.
	I thought we decided to put it in there.
	I may misrecall.
	I thought we had decided to put it in that location right here.
	I think we talked about it, but we never confirmed it.
	It looks to me like it fits there.
	Yes.
	You agree?
	Yes, without waving my objection.
	I understand.
	All right, I think on page 15, the insert, the date on which the plaintiffs filed this case should read, the date on which the plaintiffs filed this case and the the date on which the plaintiffs filed this case and the timing of the lawsuit is irrelevant to your considerations, and you should not consider that in any way in determining the damage of this
	We object to that language as a whole, but if you're going to put it in, that makes sense.
	Well, I think in light of the closing.
	Well, it was referred to by Attorney Koskoff as well.
	So I'm not sure.
	But in any case, I've got my objection.
	It's preserved.
	Thank you, Your Honor.
	We think that's an improvement.
	Then I have a question because I crossed out so much.
	page 29 so we have the last sentence is at a minimum each plaintiff is entitled to nominal damages of at least $1 and are we leaving in the sentence there you may award punitive damages as a matter of discretion or did we agree to take it out in that location I think it should be there.
	Your Honor, I do too.
	Okay then.
	Good thing I asked.
	Second time we agreed.
	Okay.
	Yep, I just, just give me one second.
	Yep.
	I had a note on the next sentence, Your Honor.
	Yes.
	And my note was just that the court was going to think about it, and I didn't know where the court landed.
	At a minimum, each plaintiff is entitled to nominal damages of at least $1.
	Okay.
	Your Honor, I have something on the next page.
	I do as well.
	So I actually have two more suggested amount of damages.
	Did I already mention?
	I did, I think.
	Yes.
	The insert in that is permitted under our law.
	Did I mention that already?
	Yes.
	Okay.
	And then On page 37, before I get back to you, Attorney Sterling and then Attorney Pattis, should I add in a sentence where it says, we'll now go over the verdict form, and that's where we talk about it being unanimous?
	Should I mention that each line must be filled out?
	I don't think we say it on the form.
	I think, I don't...
	If it comes back without a line filled out, the court can just send it in.
	But it seems to me there's no, I mean, why not say it?
	I think I'm going to say it so that they put whatever it is, whether it's $1 or more, I think they need to know to fill out each line.
	All right, so Attorney Sterling, you have something, then we'll turn to the verdict forms and then turn to Attorney Patterson and verdict forms.
	So what page?
	I do, Judge.
	On the cut but charge, which starts at page 29, but this is actually page 30, Okay.
	I have, so one small change is the third line down.
	It says, because the business conduct was immoral.
	I think it should be there, T-H-E-I-R. Agreed.
	The other issue is a little more substantive, Judge, which is that we had proposed a cut for liability charge and a cut for damages charge, parallel to The way that we've handled all the other causes of action.
	Our cut the liability charge didn't make it into the court's charge, and I'm not sure whether that was intentional or not, so I wanted to raise that.
	We didn't raise it before.
	No, Your Honor.
	I mean, the objection is preserved because we filed it, but in the event that it was an oversight— We didn't discuss it, though.
	I think it was an oversight.
	Can you talk to Attorney Patis about it?
	I have not spoken to Attorney Pattis about it.
	I mean, I think we can solve it with one sentence.
	Why don't you see if you can talk to Attorney Pattis.
	That was an oversight, and I don't think we picked up.
	We didn't discuss it during our charge conferences.
	I know that.
	Thank you.
	We don't have agreement on it.
	What I'm asking the Court to do is just give a summary of a few of the allegations in the complaint.
	So, may I read it to the Court?
	Or the other thing is I can approach and share the written charge with the Court.
	Do you have an extra copy?
	I don't.
	Why don't you just tell me what it is first?
	Okay.
	It says, in this case, it has been established that the defendants violated the Connecticut Unfair Trade Practices Act by engaging in an unfair course of business conduct that was predicated on damaging the plaintiffs, specifically by profiting from defaming and slandering the plaintiffs and invading their privacy in order to increase their audience size and generate sales of products for profit.
	All of that comes out of allegations in the complaint judge.
	And what part of that do you disagree with?
	All of it.
	There's never been a finding about what allegations were material, and there have been suggestions along the way that all of the complaints So,
	Your Honor, that's not, I mean, we looked at these cases, right?
	The court will remember The cases that we cited with regard to proximate cause.
	We cited Ritchie v.
	Main Street.
	We cited the Connecticut Supreme Court case.
	So where we say in this charge now at the top of page 30, therefore it has been established by the court that the defendants engage in an unfaite trade practice because their business conduct With respect to, can we add in just a brief phrase, was immoral, unethical, oppressive, or unscrupulous?
	Because we don't put any basis at all, just as their business conduct.
	I mean, that's actually broader than narrowing it down.
	Exactly.
	So I think it should be tied to the allegations of the complaint.
	Well, not all of them.
	Can I see?
	Can you just can I just briefly see what you have here?
	Thanks.
	So I don't have a problem with adding in because their business conduct was predicated on damaging the plaintiffs and was.
	And I understand you'll take an exception to that attorney.
	Pattison, apparently you might take an exception to it as well.
	So my job is done before the recess.
	Oh, we have to go over to the form.
	So I just, all I did was take what you had sent and delete the Added in paragraphs.
	Are there mistakes somewhere else?
	Your Honor, just rolling back the tape, I do need to take an exception to the omission of the petition.
	I understand that, and we'll do it after the charge, along with any clarifications or corrections.
	Yes.
	And I understand Attorney Pattis will also take an exception, so you'll both be taking an exception.
	So we'll be in agreement again.
	There we go.
	Okay.
	And, but there is one more issue with the charge.
	Yeah.
	Oh, okay.
	Before we go to the verdict form.
	Yeah.
	This is on page 32, and I have reviewed this with Attorney Pettis.
	This is by agreement?
	Yes.
	Okay.
	So this is in the punitive damages charge.
	On page 32. Correct.
	Where it says, the second line down, a willful and malicious injury.
	It should be harm.
	Yes.
	and going down about four lines, the intentional injury aspect may be satisfied if the resultant, it says bodily harm, it should be harmed. - If the resultant is harmed.
	Okay, anything else?
	No.
	Attorney Pallas, do you have anything else with the court?
	No objection.
	So the verdict form?
	Without waiving prior objections, it's fine.
	Did you have problems with the verdict form, Attorney Sterling?
	I didn't change a thing except take out the paragraphs we added in yesterday.
	Okay.
	I just, I wanted to make sure I was, yes.
	No, I've been through it.
	It looks fine.
	Thank you, Judge.
	- Yes, . - Oh, we do need that.
	All right, we will. - I don't know if it needs to be at each page or just at the last page. - No, just at the end. - Great.
	Okay, I will do that over the break later.
	Let's just keep it under five minutes.
	All right?
	Take a brief recess.
	Good afternoon.
	Please be seated.
	I was wondering, Council, since the form is so long, might it be a good idea to ask the foreperson to initial each page?
	Yes.
	Yes, Judge.
	Thank you.
	So, how many pages do I refer to?
	I'm going to just handwrite them.
	This is page 18, then.
	all right so I'm gonna just you just get me just what I just said
	so so
	Okay, thank you all for setting.
	Okay, thank you. thank you.
	Okay. Okay. Okay. Okay. Okay. Okay. Okay. Okay. Okay.
	Okay. Okay. Okay. Okay. Okay. Okay. Okay. Okay. Okay. Okay.
	Okay. Okay.
	Welcome back.
	Seat back, everyone.
	Please be seated.
	Okay. Okay. Okay. Okay. Okay.
	Council stipulate that the entire panel has returned.
	Yes, Your Honor.
	Thank you.
	I'm comfortable.
	So ladies and gentlemen of the jury, you've listened to the evidence and to the arguments of council, and it now becomes my duty to instruct you concerning the law of the cases.
	And I apologize, but I must read most of this because it becomes somewhat technical in places, and it's very important that I not miss anything.
	But before I do that, I would like to thank you, ladies and gentlemen, for your attention.
	Throughout the trial, I noted that you have all been paying very close attention to everything that has gone on here.
	You've been unfailingly on time and even early for all the breaks and for each morning, and for that we are all very grateful.
	As I instructed you before the start of evidence, generally a civil trial such as this has two issues, liability and damages.
	As you will recall, here you are tasked with addressing the issue of damages, as the court previously determined that the defendants are liable.
	As a result, this trial focused on damages.
	As I previously instructed you, you are not to speculate as to why the court previously determined that the defendants were liable, but you are simply to accept it as a given and focus on the amount of damages to be awarded and the degree of the defendant's wrongdoing.
	The plaintiff's burden at a hearing in damages, such as this, is to simply prove that the damages claimed is properly supported by the evidence and to prove the extent of the defendant's wrongdoing for purposes of punitive damages.
	You as the jury and I as the judge have two separate functions.
	It is your function to find what the facts are in this hearing in damages.
	With respect to the facts, you and you alone are charged with that responsibility.
	My function is to instruct you as to the law to be applied to the facts that you find in order to decide this case.
	With respect to the law, what I say to you is binding upon you, and you must follow my instructions.
	I do not have any preference as to the outcome of this case.
	I have not meant to convey by facial expression or tone of voice or in any other way at any time during the trial any preference or inclination as to how you should decide the facts, and you should not make any such interpretations.
	If in my instructions to you, I refer to one party more than the other, or do anything in your mind that suggests a preference for one side or the other, it is not done on purpose.
	My task has been to apply the rules of evidence and to instruct you as to the law.
	It is for you alone to decide on the amount of damages in this case.
	It is your duty to follow my instructions and conscientiously apply the law as I give it to you to the facts as you find them in order to arrive at your ultimate verdict.
	If you should have a different idea of what the law is or even what you feel it ought to be, you must disregard your own notions and apply the law as I give it to you.
	The parties are counting on having their claims decided according to particular legal standards that are the same for everyone, and those are the standards I will give you and that you must follow.
	If what counsel said about the law differs from what I tell you, you will dismiss from your minds what they may have said to you.
	You must decide this case based only on the law that I furnished to you and on the basis of all the law as I give it to you, regardless of the order of my instructions.
	You must not single out any particular instruction or give it more or less emphasis than any other, but rather must apply all of my instructions on the law that apply to the facts as you find them.
	You are to determine what the facts are by careful consideration of all the evidence presented and based solely upon the evidence.
	Giving to each part of the evidence the weight you consider it deserves in reaching your ultimate conclusion.
	When I say evidence, I include the following.
	Testimony by witnesses in court, including what you may have observed in any demonstrations they presented during their testimony.
	Testimony by witnesses by way of the reading of transcripts or the showing of videotapes.
	Exhibits that have been received into evidence as full exhibits, including any pictures or documents that are full exhibits.
	The testimonial evidence includes both what was said on direct examination and what was said on cross-examination without regard to which party called the witness.
	The following are not evidence, and you must not consider them as evidence in deciding the facts of this case.
	Opening statements and closing arguments by the attorneys.
	Questions and objections of the attorneys.
	And testimony or exhibits that I instructed you to disregard.
	Additionally, testimony that I told you was to be used only for a limiting purpose is not evidence for any other purpose.
	Your duty is to decide the case based on the evidence of the witnesses in court along with what has been admitted into evidence in this courtroom only and not on any other information about the issues that was not presented into evidence in this courtroom.
	It is my right to make comments to you on the evidence but where I do that Such comments are merely to suggest to you what point of law or what controversy I'm speaking about.
	If I refer to certain facts or certain evidence in the case, do not assume that I mean to emphasize those facts or that evidence and do not limit your consideration to the things that I may have mentioned.
	Likewise, you should attach no importance to it if I should mention one party more than the other.
	If I should overlook any evidence in the case, you will supply it from your own recollection.
	If I incorrectly state anything about the evidence in relation to what you remember, you should apply your own recollection and correct my error.
	In the same way, what any of the lawyers may have said in their respective summaries to you as to the facts or evidence in the case should have weight with you only if their recollection agrees with your own.
	Otherwise, it is your own recollection of the facts and evidence which should have weight in your deliberations.
	Please understand that your decision must not be reached on the basis of sympathy for or prejudice against any party.
	The parties come to court asking simply for a cool, impartial determination of the disputed issues based on the facts and the law.
	That is what they are entitled to, and that is how you should approach the decision of this case.
	You have heard that one of the parties in this lawsuit, the Defendant Free Speech Systems LLC, is an entity created by the law.
	All parties are equal before the law.
	The mere fact that one of the parties is a natural person and one is a creation of a law should not play any part in your deliberations.
	You must treat all parties in an equal and unbiased fashion.
	I instruct you that Free Speech Systems LLC is owned, controlled, and operated by Alex Jones, and it is employed to hold and generate revenue for him.
	I further instruct you that under the law applicable to this case, Alex Jones and Free Speech Systems are legally responsible for each other's wrongful conduct and are each responsible for the entirety of the harm to the plaintiffs in this case.
	You will recall the testimony of Brittany Paz, the corporate designate of free speech systems.
	When asked to do so, corporations are required to designate an individual to testify for them.
	The opposing party has no say in who that person is.
	The corporation here It is given notice of the topics on which testimony is requested.
	It then chooses its designee, and it is required to provide that designee with all the relevant information necessary to speak for it on that topic.
	Because it is important that the corporate designee be prepared to testify accurately, a corporation has the right to produce different designees for different topics.
	The corporation has an affirmative obligation to educate its designate as to the matters regarding the corporation.
	Even if the documents are voluminous and the review of the documents would be burdensome, the corporation is required to have its designate review them in order to testify.
	Under Connecticut law, a corporation is generally responsible for the actions of its employees.
	In this case, the court has determined that Free Speech Systems LLC and Alex Jones both are responsible for the actions and statements of the employees of Free Speech Systems LLC. Under Connecticut law, when a broadcaster invites others on his show with whom he expects will make false statements, The broadcaster is responsible for those false statements, just as if the broadcaster had said them.
	You have heard evidence that the defendants invited guests onto their broadcasts, and those broadcasts falsely stated that the plaintiffs are actors and that the Sandy Hook shooting was a hoax.
	These guests included Steve Pezesnik, James Tracy, Wolfgang Halbig, and others.
	I instruct you that it is established that the defendants are legally responsible for the statements of these guests on InfoWars.
	There are, generally speaking, two types of evidence from which a jury can properly find the truth as to the facts of the case.
	One is direct evidence, such as the testimony of an eyewitness.
	The other is indirect or circumstantial evidence, that is, the inferences which may be drawn reasonably and logically from the proven facts.
	Let me give you an example of what I mean by direct and circumstantial evidence.
	If you're looking out a third floor window and you see smoke rising outside the window, that's direct evidence that there's smoke outside.
	It is also circumstantial evidence that there is a fire of some sort below the window.
	As a general rule, the law makes no distinction between direct and circumstantial evidence but simply requires that the jury find the facts in accordance with a preponderance of all the evidence in the case, both direct and circumstantial.
	Thus, both direct and circumstantial evidence are permissible evidence, and each type should be treated equally.
	In your consideration of the evidence, you are not limited to the bold statements of the witness, that is, the exact words that they use.
	On the contrary, you are permitted to draw from facts which you find to have been proven such reasonable inferences as seem justified in the light of your experience.
	While you may make inferences and rely on circumstantial evidence, you should be careful not to resort to guesswork or speculation or conjecture to determine the facts in the case.
	While the plaintiffs requested all Sandy Hook videos broadcast by the defendants and all analytics regarding Infowars social media, website and marketing materials, and financial data, The defendants did not produce complete information in response,
	and as a result, the plaintiffs had no ability to present the missing information to you.
	The credibility of witnesses and the weight to be given to their testimony are matters for you as jurors to determine.
	However, there are some things to keep in mind.
	It is the quality and not the quantity of testimony that controls.
	In weighing the testimony of each witness, you may consider whether the witness has any interest in the outcome of the trial.
	You should consider a witness's opportunity and ability to observe facts correctly and to remember them truly and accurately, and you should test the evidence Each witness gives you by your own knowledge of human nature and the motives that influence and control human actions.
	You may consider the reasonableness of what the witness says and the consistency or inconsistency of his or her testimony.
	You may consider his or her testimony in relation to facts that you find to have been otherwise proven.
	You may believe all or Part of what a witness tells you, some of what a witness tells you, or none of what a particular witness tells you.
	You need not believe any particular number of witnesses, and you may reject uncontradicted testimony if you find it reasonable to do so.
	In short, you are to apply the same considerations and use the same sound judgment and common sense that you use for questions of truth and veracity in your own daily lives.
	While most of the witnesses whose testimony has been presented to you were here to testify in person, the testimony of some witnesses were presented to you by the showing of videotapes of questions asked and answered given by those witnesses under oath at an earlier time.
	Testimony that is presented in this matter.
	May be accepted or rejected by you in the same way as the testimony of witnesses who have been physically present in court.
	You should disregard any objections that you heard made in those depositions and you may consider the responses.
	We have had in this case the testimony of one expert witness, Mr. Clint Watts.
	Expert witnesses, such as engineers or doctors, are people who, because of their training, education, and experience, have knowledge beyond that of the ordinary person.
	Because of that expertise, our law allows expert witnesses to give their opinions.
	Ordinarily, a witness cannot give an opinion about anything, but rather is limited to testimony as to the facts and that witness's personal knowledge.
	Here, an expert witness has given opinions.
	However, the fact that a witness may qualify as an expert does not mean that you have to accept his opinion.
	You can accept those opinions or reject them.
	An expert's testimony is subject to your review like any other witness.
	In considering an expert's opinion, you should consider the expert's education, training, and experience in the particular field, The information available to the expert, including the facts the expert had and the documents available to the expert,
	the expert's opportunity and ability to examine those things, the expert's ability to recollect the activity and facts that form the basis for the opinion, and the expert's ability to tell you accurately about the facts, activity, and the basis for the opinion.
	You should ask yourselves about the methods employed by the expert and the reliability of the result.
	You should further consider whether the opinions stated by the expert have a rational and reasonable basis in the evidence.
	Based on all of those things, together with your general observation and assessment of the witness, it is then up to you to decide whether or not to accept the opinion.
	You may believe all, some, or none of the testimony of an expert witness.
	In other words, an expert witness's testimony is subject to your review like that of any other witness.
	The defendants have been found liable for the following violations of each plaintiff's legal rights.
	Defamation, intentional infliction of emotional distress, False light invasion of privacy and violation of the Connecticut Unfair Trade Practices Act.
	I will define each of these shortly.
	It is your duty as jurors to determine the extent of damages.
	You should award those damages you find to have been proven by a preponderance of the evidence and as I further instruct you, your award must be fair, just, and reasonable.
	The date on which the plaintiffs filed this case and the timing of the lawsuit is irrelevant to your consideration and you should not consider that in any way in determining the damages in this case.
	As I have instructed you, the court has determined that the defendants are liable for having intentionally inflicted emotional distress on each plaintiff.
	Four elements must be shown to establish intentional infliction of emotional distress.
	These four elements thus have been established.
	One, the defendants intended to inflict emotional distress where the defendants knew or should have known that emotional distress was the likely result of their conduct.
	Two, that the conduct was extreme and outrageous.
	Three, that the conduct was the cause of emotional distress experienced by the plaintiff.
	And four, that the emotional distress sustained by the plaintiff was severe.
	It is established that the defendants inflicted such emotional distress on the plaintiffs.
	As I have instructed you, the Court has determined that the defendants are liable for having invaded the privacy of each plaintiff by placing him or her in a false light before the public, by publicizing material about him or her that is false,
	And it's such a major misrepresentation of his or her character, history, activities, or beliefs that a reasonable person and the plaintiff's position would either be expected to take serious offense or be justified in feeling offended or aggrieved.
	Thus, these three elements have been established.
	One, that the defendant's publicized material or information about each plaintiff that That the defendants either knew that the publicized material was false and would place the plaintiff in a false light or acted with reckless disregard as to whether the publicized material was false and would place the plaintiff in a false light,
	and three, that the material so misrepresented the plaintiff's character, history, activities, or beliefs that a reasonable person in the plaintiff's position would find the material highly offensive.
	It is established that by their conduct, the defendants deprived the plaintiffs of their privacy by casting them in a false light before the public, as I have described.
	The court has determined that the defendants are liable for defamation.
	The defendants are liable to the plaintiffs in this case, and it does not matter to their liability whether or not Alex Jones singled them out by their individual names.
	Defamation is false communication that tends to harm the reputation of another person, to diminish the esteem, respect, goodwill, or confidence in which the plaintiff is held.
	To deter third persons from associating or dealing with him or her, or to provoke adverse, derogatory or unpleasant feelings or opinions against him or her.
	Certain defamatory statements, whether orally or in writing, are considered to be so harmful in and of themselves that the person to whom they relate is entitled to recover general damages for injury to reputation without proving that any special or actual damages were caused by the statements.
	The law conclusively presumes that there is injury to the plaintiff's reputation.
	A plaintiff is not required to prove that his or her reputation was damaged.
	The plaintiff is entitled to recover as general damages for the injury to his or her reputation and for the humiliation and mental suffering caused.
	In this case, the court has determined that the defendants defame the plaintiffs by accusing them of faking their children's death, being crisis actors, and fraudulently misrepresenting themselves to the public at large.
	I hereby charge you that causation of the plaintiff's damage is already established.
	Under Connecticut law, the defendant's conduct is a proximate cause of an injury if it was a substantial factor in bringing the harm about.
	In other words, if the defendant's conduct contributed materially and not just in a trivial or inconsequential manner to the production of the harm, then the defendant's conduct was a substantial factor.
	That standard has been met here.
	Causation of harm has been established by virtue of the court's prior rulings to the satisfaction of the law.
	That is, it has been established in this case that the defendants approximately caused harm to the plaintiffs by spreading lies about the plaintiffs to their audience and the public, by urging their audience and the public to investigate and look into the plaintiffs and to stop the people Supposedly behind the Sandy Hook host,
	resulting in members of the defendant's audience and the public cyberstalking, attacking, harassing, and threatening the plaintiffs, as you have heard in the evidence in this case.
	In sum, it has been established that the defendants cause harm to the plaintiffs in all the ways I just described.
	The defendant's statements and conduct cause reputational harm to the plaintiffs, invasion of privacy, and emotional distress.
	The extent of the harm is what you will be measuring in your verdict.
	The cause of the harm is not in question.
	Although the court has already determined that the defendants are liable to the plaintiffs, I must still instruct you on the burden of proof in a civil case such as this. I must still instruct you on the burden of proof In order for you to award more than nominal damages, a plaintiff must satisfy you that his or her claims of damages are more probable than not.
	You may have heard in criminal cases that proof must be beyond a reasonable doubt, but I must emphasize to you that this is not a criminal case and you are not deciding criminal guilt or innocence.
	In civil cases such as this one, a different standard of proof applies.
	The party who asserts a claim has the burden of proving it by a fair preponderance of the evidence, that is, the better or weightier evidence, and must establish that more probably than not the assertion is true.
	In weighing the evidence, keep in mind that it is the quality and not the quantity of evidence that is important.
	One piece of believable evidence may weigh so heavily in your mind as to overcome a multitude of less credible evidence.
	The weight to be accorded each piece of evidence is for you to decide.
	As an example of what I mean, imagine in your mind the scales of justice, Put all the credible evidence on the scales, regardless of which party offered it, separating the evidence favoring each side.
	If the scales remain even, or if they tip against the party making the claim, then that party has failed to establish that assertion.
	Only if the scale is inclined even slightly in favor of the assertion may you find the assertion has been proven by a fair preponderance of the evidence.
	The rule of damages is as follows.
	Insofar as money can do it, a plaintiff is required to receive fair, just, and reasonable compensation for all harms and losses, past and future, which are approximately caused by the defendant's wrongful conduct.
	As I have already instructed you here, it has already been established that the defendant's wrongful conduct approximately caused harm to each plaintiff.
	Under the rule of compensatory damages, the purpose of an award of damages is not to punish or penalize the defendants for their wrongdoing, but to compensate the plaintiffs for their resulting harms and losses.
	You must attempt to put each plaintiff in the same position, as far as money can do it, that they would have been in had the defendants not engaged in the wrongful conduct.
	Our laws impose certain rules to govern the award of damages in any case where liability is proven.
	To recover more than nominal damages, a plaintiff has the burden of proving that the amount of damages claimed is derived from the harm suffered and is properly supported by the evidence.
	You may not guess or speculate as to the nature or extent of a plaintiff's Losses or harms, your decision must be based on reasonable probabilities in light of the evidence presented at trial.
	Harms and losses for which a plaintiff should be compensated include those they have suffered up to and including the present time and those they are reasonably likely to suffer in the future as a proximate result of the defendant's wrongful conduct.
	In your consideration of future damages, you should consider the probable length of the plaintiff's lives.
	This may be proven through standardized mortality tables and evidence of a plaintiff's age, health, physical condition, habits, activities, and any other factor that may affect the duration of their life.
	According to the standardized mortality tables, The plaintiff's life expectancy is the following number of years from today.
	Bill Altenberg, 27 years.
	Jacqueline Barden, 28 years.
	Mark Barden, 23 years.
	Jennifer Henzel, 28 years.
	Ian Hockley, 28 years.
	Nicole Hockley, 33 years.
	Erica Lafferty, 46 years.
	Robert Parker, 39 years.
	William Sherlock, 19 years.
	Harley Soto Parisi, 53 years.
	Donna Soto, 22 years.
	Jillian Soto Marino, 48 years.
	Matthew Soto, 52 years.
	David Wheeler, 21 years.
	And Francine Wheeler, 29 years.
	Bear in mind, these figures are only estimates of a plaintiff's length of life based upon statistical data, and it is just one element to consider in determining a plaintiff's life expectancy.
	You may find that a plaintiff will live a longer or shorter period of time based upon your assessment of all the evidence regarding a plaintiff's condition and the circumstances of their life.
	Once the plaintiffs have proven the nature and extent of their compensable harms and losses, it becomes your job to determine what is fair, just, and reasonable compensation for those harms and losses.
	There is often no mathematical formula in making this determination.
	Instead, you must use human experience and apply sound common sense in determining the amount of your verdict.
	The compensatory damages that you are considering here are monies awarded as compensation for non-monetary losses and harms which the plaintiffs have suffered or are reasonably likely to suffer in the future as a result of the defendant's wrongful conduct.
	They are awarded for such things as mental and emotional pain and suffering, and loss or diminution of the ability to enjoy life's pleasures.
	As I have told you, it has been determined that the defendants violated the plaintiffs' privacy by casting them in a false light and also inflicted emotional distress on the plaintiffs by their extreme and outrageous course of conduct.
	It is your role and your role alone to determine the amount of damages due to each of the plaintiffs.
	The plaintiffs are entitled to be compensated for the harm to their privacy interests In being placed before the public in an objectionable false light or false position.
	They are also entitled to recover for any and all additional emotional distress damages.
	In assessing the invasion of the plaintiff's privacy and their emotional distress damages, you may consider that it is already established that the defendant's conduct was extreme and outrageous.
	Indeed, in many cases, the defendant's extreme and outrageous conduct is clear evidence that emotional distress existed, the duration of the conduct, the defendant's conduct in spreading the statements and their actual spread, The harassment the plaintiff endured.
	The plaintiff's fear of harassment.
	The nature and duration of the invasions of the plaintiff's privacy, including future invasions.
	The nature and duration of the plaintiff's emotional distress, including future distress.
	The plaintiff's testimony concerning their damages.
	Invasion of privacy and emotional distress may be inferred from all the circumstances as they are proven to you.
	The invasion of privacy and emotional distress for which a plaintiff should be compensated include what he or she has suffered up to and including the present time and what he or she is reasonably likely to suffer in the future.
	You must attempt to put each plaintiff in the same position, as far as money can do it, that he or she would have been in had the defendants not acted wrongfully.
	As far as money can compensate the plaintiff for such damages and their consequences, you must award a fair, just, and reasonable sum.
	You simply have to use your own good judgment in awarding damages in this category.
	You must use all your experience Your knowledge of human nature, your knowledge of human events, past and present, your knowledge of the motives which influence and control human action, and test the evidence in the case according to such knowledge and render your verdict accordingly.
	The damages I have described for you in this instruction are called emotional distress damages.
	You should include both damages for invasion of privacy and damages for other emotional distress suffered in your award of emotional distress damages.
	In this case, the court has determined that the defendants accused the plaintiffs of faking their children's death, being crisis actors, and fraudulently misrepresenting themselves to the public at large.
	The law presumes that there is injury to the plaintiff's reputations.
	A plaintiff is not required to prove that his or her reputation was damaged.
	The plaintiff is entitled to recover as general damages for injury to his or her reputation and for humiliation and mental suffering.
	In determining the amount of general damages to a ward for the injury to a plaintiff's reputation, you should consider what reputation the plaintiff had when the statements were made.
	You should consider all of the circumstances surrounding the making of the statement.
	We may also compensate the plaintiff for damages that he or she will likely incur in the future.
	These damages can include additional damage to his or her reputation that occurs as a result of the bringing of this lawsuit.
	Each plaintiff has suffered a violation of his or her legal rights entitling him or her to at least Nominal damages.
	Nominal damages may be awarded if you find that the defamatory material is of an insignificant character or because you find that a plaintiff had a bad character so that no substantial harm has been done to a plaintiff's reputation or there is no proof that serious harm has been done to the plaintiff's reputation.
	If, on the other hand, you find that the defamatory material is of significant character or because you find that the plaintiff had a good character, so substantial harm has been done to the plaintiff's reputation, or you find there is proof that there is serious harm done to the plaintiff's reputation, then you may award substantial damages.
	You may award punitive damages as a matter of discretion.
	At a minimum, each plaintiff is entitled to nominal damages of at least one dollar.
	The court has determined that the defendants are liable for violating the Connecticut Unfair Trade Practices Act, a Connecticut law commonly known as CUPA. Therefore, it has been established by the court that the defendants engaged In an unfair trade practice because their business conduct was predicated on damaging the plaintiffs and was immoral, unethical, oppressive, or unscrupulous.
	Damages due to the defendant's violation of the Connecticut Unfair Trade Practices Act are included in the other damages measures that I am describing to you and you will not assess them separately.
	In closing argument, counsel mentions some formulas or amounts that might figure in your verdict and that is permitted under our law.
	I caution you that figures suggested by counsel do not constitute evidence.
	It is up to you to decide what fair, just, and reasonable compensation is, whatever you find that figure might be, regardless of amounts that may have been suggested by counsel in argument.
	In addition to seeking compensatory damages, the plaintiffs seek an award of punitive damages, which in Connecticut are limited to attorney's fees and expenses.
	Punitive damages may be awarded if you find that the defendant's actions in this case were willful, wanton, or malicious.
	A willful and malicious harm is one inflicted intentionally without just cause or excuse.
	Willfulness and malice alike import intent.
	Its characteristic element is the design to injure either actually entertained or to be implied from the conduct and circumstances.
	The intentional injury aspect may be satisfied if the resultant harm was the direct and natural consequence of the intended act.
	Wanton misconduct is reckless misconduct.
	It is such conduct as indicates a reckless disregard of the just rights or safety of others or of the consequences of the action.
	These damages, however, are not awarded as a matter of right, but rather as a matter of discretion to be determined by you after you consider all the evidence.
	If you determine they should be awarded, then I will determine in a separate hearing after this trial ends, and based on evidence concerning the plaintiff's attorney's fees and litigation costs, how much that compensation will be.
	If you determine they should not be compensated, then I will enter nominal damages of $1 in this category of damages.
	You are to determine whether the plaintiff should be compensated for attorney's fees and costs by considering the extent to which you find the defendant's conduct is outrageous, the degree to which you find the defendants were recklessly indifferent to the rights of the plaintiffs, or intentionally and wantonly violated their rights.
	Whether you will award the plaintiff's reasonable attorney's fees and costs in an amount later determined by me, or whether you will award the plaintiff's only nominal damages is a matter for your sound discretion.
	Now, as I told you at the beginning of the trial, the notes you may have taken are simply aids to your individual memory.
	When you deliberate, you should rely on your independent recollection of the evidence you have seen and heard during the trial.
	You should not give precedence to your own notes or to any other juror's notes Over your independent recollection of the evidence because, as we all know, notes are not necessarily accurate or complete.
	Jurors who have not taken notes should rely on their own recollection of the evidence and should not be influenced in any way by the fact that other jurors have taken notes.
	Your deliberation should be determined not by what is or is not in your notes, but by your independent recollection of the evidence.
	If you have a question about any particular testimony, you may ask that it be read or played back to you from the official record, so there is no need to rely on notes.
	Each of you has taken an oath to return a true verdict according to the evidence.
	No one must be false to that oath, but you have a duty not only as individuals but also collectively to express your views to the other jurors and to listen to theirs That is the strength of the jury system.
	Each of you takes with you into the jury deliberation room your individual experience and wisdom.
	Your task is to pool that experience and wisdom in considering the evidence.
	You do that by giving your views and listening to the views of others.
	There must necessarily be discussion and give and take within the scope of your oath.
	That is the way in which agreement is reached.
	You must not discuss this case unless all members of the jury are present.
	We will take the usual breaks and the lunch recess, but you must not discuss the case in twos or threes during those breaks.
	You can deliberate only when all six of you are together and only in the jury deliberating room.
	And this is important.
	We have had cases that had to be retried all over again because this rule was violated.
	So please be very careful not to discuss the case with your fellow jurors, except when all of you are deliberating together and you are in the jury deliberating room.
	When you have reached a verdict, You will knock on the door and Mr. Ferraro will alert me.
	When you are told to enter the courtroom, the foreperson should sit in the first seat in the first row.
	When the jury is asked if it has reached a verdict, the foreperson should respond.
	Mr. Ferraro will then hand the verdict form to me and the verdict will be read twice to you.
	You will each be asked to respond whether it is your verdict as a check that the verdict is in fact unanimous.
	You should not At that point, expect me to make any comment about your verdict.
	It has been my task to rule on issues of evidence and to instruct you on the law.
	It is your task to decide the case, and I will leave that strictly up to you and make no comment on what you decide.
	It is, of course, merely the division of duties and not any lack of appreciation of your efforts that keeps me from commenting on your decision.
	At this time, ladies and gentlemen, I will explain the verdict forms to you and then you will be escorted to the jury deliberation room.
	You should not begin your deliberations until the exhibits and the verdict forms are delivered to you by Mr. Ferraro.
	This will occur after the lawyers have had an opportunity to check that all the exhibits are present and to tell me if they think that any different or additional instructions to you are necessary.
	I will recall you to the courtroom if I conclude that further instructions are needed.
	When the exhibits are delivered to you, your first task will be to elect a foreperson who will serve as your clerk.
	After you have received the exhibits and then elected the foreperson, you will begin deliberating.
	If you have questions during your deliberations, the foreperson should write the jury's question on a sheet of paper, sign and date it, and knock on the door.
	Mr. Ferreira will then bring the question to me, and I will respond to it in open court.
	It may take a few minutes to assemble the staff before you are brought to the courtroom to hear the response.
	Please try to make any questions very precise.
	We cannot engage in an informal dialogue and I will respond only to the question on the paper.
	If you need to have any testimony or any part of my instructions played or read back, you'll follow the same procedure.
	On a sheet of paper, specify what it is that you want to hear as precisely as you can.
	For example, if you know that you want to hear only the direct examination or only the cross-examination of a particular witness, specify that.
	Otherwise, we will have to repeat the whole testimony.
	Also, if you need to rewatch any video exhibit, please follow the same procedure.
	We will now go over the verdict form.
	Each line must be filled out, and the foreperson When you've reached a verdict, should initial each page of the verdict form and sign and date the last page.
	Your verdict must be unanimous.
	There is no such thing as a majority vote of a jury in Connecticut.
	Rather, you must all agree on the verdict.
	No one will hurry you if you are not able to reach a verdict today.
	You will resume your deliberations tomorrow.
	You may have as much time as you need to reach a verdict.
	And at this point, I will have Mr. Ferraro escort you to the deliberating room.
	Please be seated.
	So when I get home tonight and my husband wants to know why I don't want to talk, I have some witnesses here.
	I'm all talked out.
	Any clarifications, before the exceptions, clarifications or corrections?
	And then we'll do the exceptions.
	Attorney Pattis?
	No, Judge.
	Judge Sterling?
	Okay.
	Do you want to have me discharge the alternates now and send in the exhibits in verdict form?
	And then we can put the exceptions on the record just to get things moving?
	Yes, sir.
	It makes sense.
	Your Honor.
	Yes, sir.
	Just in terms of the alternates, since we're heading potentially into the weekend.
	I am.
	I'm going to instruct them not to discuss, and they might need to be recalled.
	Yes.
	So we thought what we would do is we would take out the alternates We have three alternates.
	And when you bring them in here, then you can send in the exhibits and the verdict form and the exhibit list.
	So, councils are ready.
	Oh, look at you.
	Council's already reviewed all the exhibits and the summary?
	Yes.
	Okay.
	Just bring the alternates in the mail.
	But what I want you to do is sort of send them in, bring them, where are the exhibits?
	Oh, there.
	While I'm discharging them, can you drop off the exhibits?
	Okay.
	That would be nice.
	Thank you.
	I'm going to send you home.
	Thank you.
	Normally, when a trial ends, I have an opportunity to Speak with the jurors at length, but in this case, obviously, no verdict has yet been returned.
	So I'm not going to discuss this matter with you at all for the following reasons.
	Under Connecticut law, if one of the When the principal deliberating jurors becomes unavailable to deliberate due to illness or an emergency or for any other reason, the court has the option of calling upon one of the alternates to join the jury and take part in the deliberations.
	This very rarely happens, and hopefully it will not happen in this case.
	But if one of the deliberating jurors must be excused, then one of you will be needed to fill in for them.
	The alternate who would be asked to serve would be chosen by lot in a purely random fashion.
	That person would be instructed, and indeed the whole jury would be instructed, to start deliberations over from the start in an attempt to reach a verdict.
	Obviously, if any of you were to talk about the case with anyone, or read or research or investigate the case, or in any way expose yourselves to any information or opinions about the case, that would destroy your potential utility as a deliberating juror.
	In other words, if you expose yourself to anything at all relating to the case, you could no longer serve as a juror in the event that you are needed.
	Because we do need a jury of six to reach a verdict, this would represent a tremendous waste of resources.
	Therefore, I repeat to you the instruction that I've given you all throughout the trial.
	Do not read about the case, talk with anyone about the case, research the case, or expose yourself to any media coverage of the case.
	Do I have your promises that you will continue to abide by these instructions when you leave the courthouse?
	Yes.
	Once a verdict is returned, you will then be free to discuss the case if you choose.
	But whether you choose to do so is entirely up to you.
	So on the way out, please give Mr. Ferraro your phone number at home or work or any cell phone number that you can be reached on short notice if your service is needed or if you would like him to call you when a verdict is reached so that he can tell you what the verdict is.
	And once again, on behalf of the attorneys, And the parties, I want to thank you for your service.
	I know that you are probably disappointed in having sat through the entire trial without the opportunity to deliberate and reach a verdict, but without your presence and involvement and willing to serve and keeping that door open for everyone, the trial never could have proceeded as smoothly as it did.
	So thank you.
	You are free to leave and you'll give Ron your So before we get to the exceptions one question that I did have was so we'll greet them in the morning we'll let them go at the end of the day and I was thinking
	Do you want me to bring them out tomorrow before lunch and when they return and what about breaks?
	What's your preference?
	I think whatever you think is best to manage their time, Judge, and to manage their comfort is fine with us.
	Alright, so my thought was we would greet them in the morning, you know, just ascertain that they had no exposure or anything like that and maybe You know, at the end of the day.
	I'm not sure because they may want to go for an earlier lunch.
	There's nothing that stops them from taking an earlier lunch or a longer lunch.
	Do you give them the option to report 9, Judge?
	Or will we ordinarily begin at 10?
	It's ordinarily at 10. I mean, I could ask them.
	I could have Ron ask them if they would prefer to start at 9. Is that what your preference is?
	I just raised it.
	I realize I've seen courts do it either way.
	It gets more out of the day that way.
	Yeah, I think whatever the jury's, if you want to give them that option, whatever their preference is, it's fine with us.
	Why don't we give them the option if they want to come in at 9 or 9.30 tomorrow?
	Sure.
	I think that's not a bad idea.
	All right, so why don't we cover the exceptions whenever you're ready.
	Your Honor, for the plaintiffs, as the Court is aware, we submitted preliminary charges, supplemental charges.
	There were exceptions taken during the course of the charge conferences.
	The only thing I would re-emphasize is our objections to the portions of the charge concerning nominal damages and the omission of portions of our cut of charge that we discussed today.
	But otherwise, I'll stand on the objections that we have made part of the record.
	I have one piece of housekeeping, which is we had I had sent to the court by email various draft charges.
	I thought that those should probably be marked as court exhibits, just to keep our record clear.
	Do you agree, Attorney Patis?
	No, I have to object.
	Do you have hard copies of them?
	I don't have hard copies, but we can take care of that.
	We'll get that into the record.
	Can you do that and show them to Attorney Patis before we mark them as court exhibits, and then we'll mark them as court exhibits, certainly.
	Thank you.
	Okay, Attorney Patis?
	I've made exceptions at various points in our preliminary discussions.
	My only additional exception is by way of a preliminary request to charge, dated September 19, 2022, I requested permission to argue nullification under Article I, Section 6 of the State Constitution, which I think permits nullification for the jurors to have the right to determine law and facts in any prosecution or indictment for libel.
	So I take it For one last time, you mean?
	We haven't had one today.
	What's a day without a sidebar here?
	So do I have your consent to have Ron just go in and...
	Tell them that they can discuss what if they want to come in you or I don't know if you were here if they wanted to come in for 9 or 9 30 tomorrow instead of 10 have them discuss it and um that's fine okay they don't have to let us know right away and then I'm going to bring them out on it What
	are you guys telling me?
	Oh, it's not just a...
	You're actually...
	because I just keep in.
	Can you just pronounce it?
	Or do you just pronounce it?
	Aren't you going to run that code?
	Oh, okay.
	Well, so you're not going to read that code.
	Of course we're going to read that code.
	That's what we intended to do all along.
	I'm going to read that code.
	That's what we intended to do all along.
	Okay, so if you talk and whatever you agree is fine with me.
	Do you have anything else?
	Are you going to brief it or just brief it?
	Just brief it?
	I don't really care.
	We'll talk about that.
	I did have a question, though, to prolong the sidebar.
	When the jury comes back, I assume you want somebody from each team here and in the courthouse waiting for the jury to come back.
	How much time will you give us to get our clients here?
	Because I don't know that they're all going to be waiting around the courthouse.
	Yeah, yeah.
	Not for questions.
	No, no, no, not for a vertical.
	How much money do you want?
	Well, it kind of...
	You'll be, right?
	You're going to have a few blocks.
	I think 50 is...
	Is there any chance we could get a waiting?
	Could we have one of the courtrooms we've been using for lunch during the day or no?
	All right.
	Okay.
	All right.
	Well, we can talk about that with the trade for all, but I think 15 minutes notice should be okay for us to get- For a verdict, not for a court.
	For a verdict.
	Yeah, yeah, yeah.
	If the only, I don't mean to be presumptuous, if you have a second circuit on Thursday, if you mind, maybe, I don't think I'll use.
	I guess I'll have to have somebody else here all day.
	Marie?
	You told them that they can talk to each other and let us know if they'd like to come in or even like a nightclub.
	Oh, yeah.
	Sorry.
	You don't have to go to the crossings.
	I'm not.
	Right.
	And they'll tell you every day.
	That'll be your first decision.
	Okay, anything else?
	Thank you very much.
	All right, we'll take a recess.
	Okay.
	You want to be at the jury?
	Yes, Your Honor.
	Okay.
	Thank you.
	Mrs. Ellis.
	How are you today?
	Thank you.
	I can't.
	I actually.
	Yeah.
	I don't know if you're going to change your seats now.
	What are you going to do?
	Three and three.
	We're proceeding.
	Council will stipulate that our jury of six has returned.
	Yes, sir.
	Alright, so I understand that you have agreed, reached your first unanimous agreement to start at 930 tomorrow.
	So we will greet you in the courtroom at 930 and then send you back to your deliberations.
	I am not going to go through all the details again because I know you know how it's more important than ever that you insulate yourselves from any media coverage, anyone who's interested, and put the blinders on so that we don't have any issues.
	But if something happens, you'll give Ron A note and we will address it no problem.
	Okay?
	So with that we're going to let you go for the day.
	It's been a long day.
	We'll see you right at 930 tomorrow.
	I'll greet you in the morning and then we'll send you back to do your work.
	All right?
	Safe travels.

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