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NO. X06-UWY-CV-18-6046436-S
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`ERICA LAFFERTY, ET AL.
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`MARCH 29, 2022
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`ALEX EMRIC JONES, ET AL.
`____________________________________________________________________________
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`NO. X-06-UWY-CV18-6046437-S
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`WILLIAM SHERLACH
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`V.
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`MARCH 29, 2022
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`ALEX EMRIC JONES, ET AL.
`_____________________________________________________________________________
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`SUPERIOR COURT
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`COMPLEX LITIGATION DOCKET
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`AT WATERBURY
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`SUPERIOR COURT
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`COMPLEX LITIGATION DOCKET
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`AT WATERBURY
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`NO. X06-UWY-CV-18-6046438-S
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`WILLIAM SHERLACH, ET AL.
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`ALEX EMRIC JONES, ET AL.
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`SUPERIOR COURT
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`COMPLEX LITIGATION DOCKET
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`AT WATERBURY
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`MARCH 29, 2022
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`MOTION ON CONSENT FOR
`COMMISSION TO TAKE OUT-OF-STATE DEPOSITION
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`Pursuant to Conn. Gen. Stat. § 52-148c(b) and Connecticut Practice Book § 13-28(a), the
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`plaintiffs with the consent of all parties respectfully request that this Court grant a Commission to
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`a competent authority, in the form attached hereto as Exhibit A, to issue or cause to be issued a
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`Subpoena Duces Tecum, compelling testimony and production of documents from Rob Dew. The
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`proposed Subpoena and accompanying production requests are attached hereto as Exhibit B.
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`I.
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`BACKGROUND
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`The Court is well aware of the allegations set forth in the operative complaint. Defendant
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`Free Speech Systems, Inc. (“FSS”), a media company operating in Austin, Texas and controlled
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`by defendant Alex Jones, is one of the corporate loci of the unlawful conduct alleged in the
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`complaint. FSS current and former employees and others who possess relevant information are
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`located in the greater Austin area. This Court has already held that FSS employees and former
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`employees who are not “officer[s], director[s], or managing agent[s]” within the scope of Practice
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`Book § 13-26 may be compelled by subpoena. See DN 343.10 (“The Riley deposition may go
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`forward, but by subpoena.”).
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`II. LEGAL STANDARD
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`The Practice Book provides that discovery “shall be permitted” whenever it is “material to
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`the subject matter involved in the pending action,” “would be of assistance in the prosecution or
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`defense of the action,” or is “reasonably calculated to lead to the discovery of admissible
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`evidence.” P.B. § 13-2. This provision “liberally permits discovery of information material to the
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`subject matter involved in the pending action.” Lougee v. Grinnell, 216 Conn. 483, 489 (1990),
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`overruled in part on other grounds by State v. Salmon, 250 Conn. 147, 154–55 (1999). Under this
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`standard, a plaintiff is entitled to “take the testimony of any person. . . by deposition upon oral
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`examination.” P.B. § 13-26, so long as the testimony is material to the action or would assist in its
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`prosecution, P.B. § 13-2.
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`This legal standard is applicable to witnesses located outside of Connecticut: P.B. § 13-28
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`and Conn. Gen. Stat. § 52–148c create a mechanism by which a party can apply to the Connecticut
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`court for a commission to take the deposition of an out-of-state witness.1 See P.B. § 13-28 (“In
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`any other state . . . depositions for use in a civil action . . . within this state shall be taken before .
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`. . a person commissioned by the court before which such action or proceeding is pending . . . .”);
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`Conn. Gen. Stat. § 52–148c (same).
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`1 Connecticut is not among the 41 signatories of the Uniform Interstate Depositions and Discovery
`Act (UIDDA). 16:16, Foreign Discovery, Trawick, Fla. Prac. & Proc. § 16:16 (2019-2020 ed.).
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`2
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`“Once the commission is granted by the court in this state, a subpoena can be obtained in
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`the proposed deponent’s state to force the deponent to attend a deposition in his state.” Struckman
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`v. Burns, 205 Conn. 542, 552 (1987); see also Milliun v. New Milford Hosp., 310 Conn 711, 719
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`n.7 (2013) (same); Rhode v. Milla, 287 Conn. 731, 743 (2008) (same); Noll v. Hartford Roman
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`Catholic Diocesan Corp., 2008 WL 4635591, at *2 (Conn. Super. Sept. 26, 2008) (Shapiro, J.)
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`(same); Cassinelli Bros Const. Co v. Gray, 1996 WL 278330, at *1 (Conn. Super. May 9, 1996)
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`(Hickey, J.) (same).
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`Texas R. Civ. P. 201.2 provides:
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`If a court of record of any other state or foreign jurisdiction issues a mandate, writ,
`or commission that requires a witness’s oral or written deposition testimony in this
`State, the witness may be compelled to appear and testify in the same manner and
`by the same process used for taking testimony in a proceeding pending in this State.
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`Texas. R. Civ. P. 201.2.
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`III. WITNESS
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`With the consent of all parties, the plaintiffs seek to commission a competent authority in
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`the State of Texas so that a subpoena duces tecum may be served on Rob Dew. According to
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`counsel for the Jones defendants, Mr. Dew has authorized Attorney Pattis to accept service of the
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`proposed subpoena on his behalf. This Court has already once ordered the deposition of Rob Dew,
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`although that deposition was limited to one hour because of its limited purpose in connection with
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`the Jones defendants’ motion to dismiss. Order, Dkt. 234.10, Apr. 30, 2019.
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`From 2012 until recently, Mr. Dew was one of Alex Jones’s top deputies. Mr. Dew had
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`significant responsibilities within FSS, including serving as News Director and the on-air host of
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`The Nightly News with Rob Dew. In connection with those responsibilities, Mr. Dew has, inter
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`alia, (1) published statements referring to plaintiff Robbie Parker as an “actor” and indicating that
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`the circumstances surrounding the shooting “stink[] to high heaven,” see Free Speech, The Alex
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`3
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`Jones Show (Feb. 12, 2015);2 (2) claims to have investigated certain aspects of the Sandy Hook
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`shooting, see Dew Dep. at 51-53 (May 16, 2019) (attached hereto at Ex. C); (3) directed the
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`activities of FSS reporter Dan Bidondi who traveled to Newtown and Hartford to “report” on the
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`activities of Sandy Hook hoaxer Wolfgang Halbig, see email from R. Dew to D. Bidondi, dated
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`July 7, 2015 (attached hereto at Ex. D); (4) participated in FSS marketing and promotional
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`activities, see Dew Dep. at 23-28 (May 16, 2019); (5) testified as a FSS corporate representative
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`in related litigation in Texas.
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`In May 2019, Mr. Dew was deposed for the limited purpose of establishing the scope of
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`materials and information responsive to the plaintiffs’ discovery requests in connection with the
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`Jones defendants’ motion to dismiss.
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`Based on discovery received to date, including depositions of current and former FSS
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`employees, it is apparent that Rob Dew is well positioned to testify concerning, inter alia, (1)
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`statements FSS published concerning the Sandy Hook shooting, (2) any sources FSS relied upon
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`in connection with those statements; (3) any investigation FSS conducted in connection with the
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`Sandy Hook shooting; and (4) FSS’s marketing and promotional activities. In light of this, Mr.
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`Dew’s testimony and materials in his possession are highly relevant and highly likely to give rise
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`to admissible evidence that will assist in the prosecution and/or defense of the case.
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`WHEREFORE, the plaintiffs respectfully request that the Court grant this Motion and issue
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`a Commission in the attached form, thus allowing counsel for plaintiffs or their designee to issue
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`a Subpoena Duces Tecum directed to the witness described herein pursuant to appropriate process,
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`for all testimony and materials relevant to the subject matter of this case or likely to lead to the
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`2 The Jones defendants have stipulated that FSS published this video on or about February 12,
`2015. See Ex. E.
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`4
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`discovery of such relevant information.
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`THE PLAINTIFFS,
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`By:
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`/s/ Christopher M. Mattei
`CHRISTOPHER M. MATTEI
`ALINOR C. STERLING
`MATTHEW S. BLUMENTHAL
`KOSKOFF KOSKOFF & BIEDER
`350 FAIRFIELD AVENUE
`BRIDGEPORT, CT 06604
`asterling@koskoff.com
`cmattei@koskoff.com
`mblumenthal@koskoff.com
`Telephone:
`(203) 336-4421
`Fax:
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`(203) 368-3244
`JURIS #32250
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`CERTIFICATION
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`This is to certify that a copy of the foregoing has been emailed and/or mailed, this day,
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`postage prepaid, to all counsel and pro se appearances as follows:
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`For Alex Emric Jones, Infowars, LLC, Free Speech Systems, LLC, Infowars Health, LLC and
`Prison Planet TV, LLC:
`Norman A. Pattis, Esq.
`Cameron Atkinson, Esq.
`Pattis & Smith, LLC
`383 Orange Street, First Floor
`New Haven, CT 06511
`P: 203-393-3017
`npattis@pattisandsmith.com
`catkinson@pattisandsmith.com
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`For Genesis Communications Network, Inc.
`Mario Kenneth Cerame, Esq.
`Brignole & Bush LLC
`73 Wadsworth Street
`Hartford, CT 06106
`mcerame@brignole.com
`P: 860-527-9973
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`/s/ Christopher M. Mattei
`CHRISTOPHER M. MATTEI
`ALINOR C. STERLING
`MATTHEW S. BLUMENTHAL
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`6
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`EXHIBIT A
`EXHIBIT A
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`NO. X06-UWY-CV-18-6046436-S
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`ERICA LAFFERTY, ET AL.
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`ALEX EMRIC JONES, ET AL.
`____________________________________________________________________________
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`NO. X-06-UWY-CV18-6046437-S
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`WILLIAM SHERLACH
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`ALEX EMRIC JONES, ET AL.
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`SUPERIOR COURT
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`COMPLEX LITIGATION DOCKET
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`AT WATERBURY
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`SUPERIOR COURT
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`COMPLEX LITIGATION DOCKET
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`AT WATERBURY
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`NO. X06-UWY-CV-18-6046438-S
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`WILLIAM SHERLACH, ET AL.
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`ALEX EMRIC JONES, ET AL.
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`SUPERIOR COURT
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`COMPLEX LITIGATION DOCKET
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`AT WATERBURY
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`ORDER OF COMMISSION
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`This matter comes before the Court on the motion of the plaintiffs in the above-captioned
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`consolidated matters for leave of judicial authority and an issuance of an Order for Commission pursuant
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`to Connecticut Practice Book § 13-28(a) for the taking of the deposition of Robert Dew.
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`It is hereby ordered that the motion for issuance of an Order for Commission be allowed and is
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`hereby granted; and, it is further ordered that any appropriate authority in the State of Connecticut or
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`Texas is authorized to issue a deposition subpoena required to compel the attendance of the witness for the
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`taking of said deposition and to produce requested documents.
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`Dated this ______ day of ______________, 2022 at Waterbury, Connecticut.
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`_____________________________________
`Hon. Barbara N. Bellis
`Connecticut Superior Court
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`1
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`EXHIBIT B
`EXHIBIT B
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`PLEASE CONTACT THE UNDERSIGNED TO CONFIRM APPEARANCE
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`TO: Mr. Robert J. Dew
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`188 Southern Sunset CV
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`Driftwood, TX 78619-1501
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`SUBPOENA AD TESTIFICANDUM
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`BY THE AUTHORITY OF THE STATE OF CONNECTICUT, you are hereby
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`commanded to appear the offices of fibercove, 1700 South Lamar Boulevard, 338, Austin, TX
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`78704, or otherwise via remote videoconference, on Friday, April 8, 2022 at 10:00 AM Eastern
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`Time (9:00 A.M. Central Time) or to such day thereafter and within sixty days hereof, to testify what
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`you know in a certain Civil Action pending in the Connecticut Superior Court between:
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`and
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`ERICA LAFFERTY, ET AL.
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`Plaintiff
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`DOCKET NO: X06-UWY-CV-18-6046436S
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`ALEX EMRIC JONES, ET AL.
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`AND consolidated matters. You are further commanded to bring with you and produce at the
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`Defendant
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`same time and place the following: See attached Schedule A for requests for production.
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`To any proper officer or indifferent person to serve and return.
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`Dated at Bridgeport, Connecticut on March 29th, 2022.
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`HEREOF FAIL NOT, UNDER PENALTY OF THE LAW
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`____________________________________
`CHRISTOPHER M. MATTEI
`Commissioner of the Superior Court
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`Schedule A
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`Definitions
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`Please be advised that these Requests for Production use and incorporate the definitions
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`set forth in Conn. Practice Book § 13-1.
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`In addition, for the purposes of these Requests for Production only,
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`“Sandy Hook Shooting” is defined as: the shooting that took place at Sandy
`Hook Elementary School in the town of Newtown, Connecticut on December 14,
`2012.
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`“The plaintiffs in this lawsuit” is defined as: Jacqueline Barden, Mark Barden,
`Nicole Hockley, Ian Hockley, Francine Wheeler, David Wheeler, Jennifer Hensel,
`Jeremy Richman, Donna Soto, Carlee Soto-Parisi, Carlos M. Soto, Jillian Soto,
`Erica Lafferty, William Sherlach, and Robert Parker.
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`“Sandy Hook Hoax Theory” is defined as: Any theory that the Sandy Hook
`Shooting did not happen as is generally accepted, including that it was a
`government conspiracy, scripted, included so-called “crisis actors,” that the Sandy
`Hook Victims did not die, and bases for such theories.
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`“This Lawsuit” is defined as: Erica Lafferty, et al v. Alex Jones, et al, UWY-
`CV18-6046436-S; William Sherlach v. Alex Jones, et al, UWY-CV18-6046437-
`S, and William Sherlach, et al v. Jones, et al, UWY-CV18-6046438-S.
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`“The Texas Lawsuits” is defined as: Neil Heslin v. Alex E. Jones, et al, Cause
`No. D-1-GN-18-001835; Leonard Pozner and Veroniqe de la Rosa v. Alex E.
`Jones, et al, Cause No. D-1-GN-18-001842; Scarlett Lewis v. Alex E. Jones, et al,
`Cause No. D-1-GN-18-006623, Marcel Fontaine v. Alex E. Jones, et al, Cause
`No. D-1-GN-18-001605; Brennan M. Gilmore v. Alexander E. Jones, et al., Case
`No. 18-00017 (D. W.Va.).
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`Unless otherwise specified, the time frame for these discovery requests is
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`December 14, 2012 through and including April 7th, 2022.
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`1. Any and all non-privileged communications to or from Wolfgang Halbig,
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`including letters, memoranda, emails, text messages, SMS messages, instant messages
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`sent and/or received over any social media platform, or other electronic communications;
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`1
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`Schedule A
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`2. Any and all non-privileged communications to or from Daniel Bidondi, including
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`letters, memoranda, emails, text messages, SMS messages, instant messages sent and/or received
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`over any social media platform, or other electronic communications;
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`3. For the period 2015 through February 21, 2022, any and all non-privileged
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`communications to or from the deponent’s uncle, John Dew, including letters, memoranda,
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`emails, text messages, SMS messages, instant messages sent and/or received over any social
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`media platform, or other electronic communications concerning the Sandy Hook Shooting, the
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`Sandy Hook Hoax Theory, the plaintiffs in this lawsuit, this Lawsuit, the Texas Lawsuits any
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`proceeding or hearing of the Newtown Board of Education, Wolfgang Halbig, and/or Dan
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`Bidondi;
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`4. Any and all non-privileged communications to or from Alex Jones, David Jones,
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`Melinda Flores, Lydia Zapata-Hernandez, Anthony Gucciardi, Adan Salazar, Nico Acosta,
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`Cristopher Daniels, Timothy Fruge, Blake Roddy, Louis Sertucche, Buckley Hamman, Michael
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`Zimmerman and/or Owen Shroyer, including letters, memoranda, emails, text messages, SMS
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`messages, instant messages sent and/or received over any social media platform, or other
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`electronic communications concerning this Lawsuit, the Texas Lawsuits, Robert Jacobson, Nico
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`Acosta, and/or the deponent’s termination of employment with Free Speech Systems, Inc.
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`5. Documents sufficient to identify any and all e-mail addresses, cellular telephone
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`numbers, and social media accounts utilized by the deponent.
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`6. Any and all documents concerning the termination of the deponent’s employment
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`with Free Speech Systems, LLC, including, but not limited to, any severance or other benefits
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`provided to you in connection with that termination.
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`2
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`EXHIBIT C
`EXHIBIT C
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`1 NO. X06-UWY-CV-18-6046436S
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`2 NO. X-06-UWY-CV-18-6046436S ) SUPERIOR COURT
` )
`3 ERICA LAFFERTY, ET AL. ) COMPLEX LITIGATION DOCKET
` )
`4 V. ) AT WATERBURY
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`5 ALEX EMRIC JONES, ET AL. ) MAY 6, 2019
` )
`6 _________________________________________________________________
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`7 NO. X-06-UWY-CV18-6046437-S ) SUPERIOR COURT
` )
`8 WILLIAM SHERLACH ) COMPLEX LITIGATION DOCKET
` )
`9 V. ) AT WATERBURY
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`10 ALEX EMRIC JONES, ET AL. ) MAY 6, 2019
` _________________________________________________________________
`11 NO. X06-UWY-CV-18-6046438S ) SUPERIOR COURT
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`12 WILLIAM SHERLACH, ET AL. ) COMPLEX LITIGATION SUPPORT
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`13 V. ) AT WATERBURY
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`14 ALEX EMRIC JONES, ET AL. ) MAY 6, 2019
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`15
` *****************************************************************
`16
` ORAL AND VIDEOTAPED DEPOSITION OF
`17 ROBERT DEW
` MAY 16, 2019
`18
` ***************************************************************
`19 ORAL AND VIDEOTAPED DEPOSITION OF ROBERT DEW, produced as a
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`20 witness at the instance of the Plaintiffs, and duly sworn, was
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`21 taken in the above-styled and numbered cause on the 16th day of
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`22 May, 2019, from 8:35 a.m. to 10:03 a.m., before AMBER KIRTON, CSR
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`23 in and for the State of Texas, reported by machine shorthand, at
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`24 the offices of Ken Owen & Associates, 801 West Avenue, Austin,
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`25 Texas.
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`

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`·1· talk.
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`·2· · · ·Q.· ·Somebody would just have to intuit that Alex wanted a
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`·3· coffee break and then they would just go to the Website?
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`·4· · · ·A.· ·Well, I wouldn't call it a coffee break.· I'd call it a
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`·5· sip.· But yeah.· And then there are other times if -- I think --
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`·6· yeah.
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`·7· · · ·Q.· ·Okay.
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`·8· · · ·A.· ·The process has changed over the years so it's --
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`·9· · · ·Q.· ·I mean, that still occurs, correct?
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`10· · · ·A.· ·Uh-huh.· We still go to the -- we still show the
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`11· Website.
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`12· · · ·Q.· ·Right.· During your time at Free Speech Systems you've
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`13· been personally involved in Free Speech Systems' marketing
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`14· efforts, correct?
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`15· · · ·A.· ·What do you mean by marketing efforts?
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`16· · · ·Q.· ·You know what marketing is, don't you, sir?
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`17· · · ·A.· ·I know what -- I know what marketing is.
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`18· · · ·Q.· ·Yeah.· You've been personally involved in that at Free
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`19· Speech Systems, right?
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`20· · · ·A.· ·In terms of creating commercials or editing
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`21· commercials?
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`22· · · ·Q.· ·Any marketing activity of any kind, you've been
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`23· involved in that at Free Speech Systems, correct, sir?
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`24· · · ·A.· ·I mean, I've made --
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`25· · · ·Q.· ·Yes or no?
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`·1· · · · · · · · ·MR. PATTIS:· If you can answer it with a yes or
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`·2· no.· If you can't, don't.
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`·3· · · ·A.· ·I've been involved with marketing activities.
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`·4· · · ·Q.· ·(BY MR. MATTEI)· Was that hard for you to say that?
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`·5· · · ·A.· ·No.
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`·6· · · ·Q.· ·Okay.· Because you actually swore under oath that you
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`·7· are familiar with the marketing efforts made by Free Speech
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`·8· Systems from 2012 all the way to the current day, correct?
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`·9· · · ·A.· ·Uh-huh.· You're asking me to think about a long time
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`10· period and, I mean, I'm sure -- do you know what you were doing
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`11· in December of 2012?
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`12· · · ·Q.· ·No, but you do, though, because you've already
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`13· testified under oath to that effect.
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`14· · · ·A.· ·Okay.
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`15· · · ·Q.· ·Right?
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`16· · · ·A.· ·What, that I know everything that I was doing since
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`17· 2012?
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`18· · · ·Q.· ·No, that you've been involved in marketing with Free
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`19· Speech Systems and you've been familiar with the marketing
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`20· practices of Free Speech Systems from 2012 to current day.
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`21· Correct?
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`22· · · · · · · · ·MR. PATTIS:· I'm going to object as to form.
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`23· Being involved with and familiar is compound.
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`24· · · ·Q.· ·(BY MR. MATTEI)· Why don't you grab your affidavit,
`
`25· sir?· This is Exhibit 17.
`
`

`

`·1· · · · · · · · ·MR. PATTIS:· Thank you.· Chris, if I may.
`
`·2· Mr. Dew, from time to time you're saying uh-huh or huh-uh.· Say
`
`·3· yes or no so the record is clear, okay?
`
`·4· · · · · · · · ·THE WITNESS:· All right.
`
`·5· · · ·Q.· ·(BY MR. MATTEI)· And if you look at Paragraph 2.· Am I
`
`·6· correct, sir, that you swore under oath that you are familiar
`
`·7· with the marketing efforts made by Alex Jones and the Alex Jones
`
`·8· Show during that time and subsequently, that is, from 2012
`
`·9· onward?
`
`10· · · ·A.· ·Uh-huh.
`
`11· · · ·Q.· ·Right.
`
`12· · · · · · · · ·MR. PATTIS:· That would be a yes.· I don't mean to
`
`13· be rude.
`
`14· · · · · · · · ·THE WITNESS:· Yes.
`
`15· · · ·Q.· ·(BY MR. MATTEI)· Thank you.· And you've been personally
`
`16· involved in standard marketing and analytics regarding product
`
`17· sales and promotions while at Free Speech Systems; is that
`
`18· correct?
`
`19· · · · · · · · ·MR. PATTIS:· That is compound.· I'm going to
`
`20· object as to the form.
`
`21· · · ·Q.· ·(BY MR. MATTEI)· You can answer it.
`
`22· · · · · · · · ·MR. PATTIS:· If you can.· It's two questions at
`
`23· once.
`
`24· · · ·A.· ·If I was involved with majority of what?
`
`25· · · ·Q.· ·(BY MR. MATTEI)· Products sales -- personally involved
`
`

`

`·1· in standard marketing and analytics concerning product sales,
`
`·2· correct?
`
`·3· · · · · · · · ·MR. PATTIS:· Objection as to the form.· It's
`
`·4· compound.
`
`·5· · · ·A.· ·I have not been involved in analytics.
`
`·6· · · ·Q.· ·(BY MR. MATTEI)· You have not been involved in
`
`·7· analytics throughout your time at Free Speech Systems?
`
`·8· · · ·A.· ·Well, what would you define as analytics?
`
`·9· · · ·Q.· ·Do you understand --
`
`10· · · ·A.· ·Looking at a view count on YouTube?· I've looked at
`
`11· view counts on YouTube.
`
`12· · · ·Q.· ·Okay.
`
`13· · · ·A.· ·That's -- that's probably what I did most was look at
`
`14· view counts on YouTube.
`
`15· · · ·Q.· ·Okay.· So that's when Free Speech Systems posts a video
`
`16· on YouTube that has a number of views associated with it and
`
`17· that's what you've done as far as your involvement with
`
`18· analytics, correct?
`
`19· · · ·A.· ·That's correct.
`
`20· · · ·Q.· ·Okay.· So you haven't been involved in any analytics
`
`21· regarding product sales, correct?
`
`22· · · ·A.· ·No.
`
`23· · · ·Q.· ·And you haven't been involved in any analytics
`
`24· regarding promotions, correct?
`
`25· · · ·A.· ·Yeah.· No, I haven't.
`
`

`

`·1· · · ·Q.· ·Okay.· Have you been personally involved in standard
`
`·2· marketing regarding product sales?
`
`·3· · · ·A.· ·In terms of creating, like, which products to put on
`
`·4· sale?· Is that what you're asking?
`
`·5· · · ·Q.· ·I guess what I'm asking you is -- I mean, obviously
`
`·6· Free Speech Systems markets its products, right, the products
`
`·7· that it sells in the store, right?
`
`·8· · · ·A.· ·Uh-huh.
`
`·9· · · ·Q.· ·Yes?
`
`10· · · ·A.· ·Yeah.
`
`11· · · ·Q.· ·It does that in a variety of ways, correct?
`
`12· · · ·A.· ·Correct.
`
`13· · · ·Q.· ·One of the ways it markets its product is that Alex
`
`14· Jones pitches them during a show, correct?
`
`15· · · ·A.· ·Uh-huh.
`
`16· · · ·Q.· ·Okay.· Have you been involved in that particular type
`
`17· of marketing at Free Speech Systems, promoting the products on
`
`18· the show?
`
`19· · · ·A.· ·No.
`
`20· · · ·Q.· ·Okay.· One of the ways that Free Speech Systems
`
`21· promotes its products is that it features them in advertisements
`
`22· on its Website, correct?
`
`23· · · ·A.· ·As a -- yeah, as a graphical ad.
`
`24· · · ·Q.· ·Correct.· Do you -- are you involved in creating those
`
`25· ads at all?
`
`

`

`·1· · · ·A.· ·No.
`
`·2· · · ·Q.· ·Have you ever been?
`
`·3· · · ·A.· ·No.
`
`·4· · · ·Q.· ·Okay.· Have you ever been involved in deciding which
`
`·5· products to feature or advertise on InfoWars dot-com?
`
`·6· · · ·A.· ·No.
`
`·7· · · ·Q.· ·Okay.· Have you -- another way that Free Speech Systems
`
`·8· markets its products is through its newsletter, correct?
`
`·9· · · ·A.· ·I believe there is ads in the newsletter, yes.
`
`10· · · ·Q.· ·Are you involved in that in any way?
`
`11· · · ·A.· ·No.
`
`12· · · ·Q.· ·Okay.· Are there any other marketing activities
`
`13· relating to product sales that I haven't mentioned that you --
`
`14· that you participate in?
`
`15· · · ·A.· ·Editing ads, editing video ads.
`
`16· · · ·Q.· ·You edit video ads that promote products?
`
`17· · · ·A.· ·Uh-huh.· I've done that.
`
`18· · · ·Q.· ·Describe that for me.· What does that involve?
`
`19· · · ·A.· ·Usually taking shots of the product with a voiceover
`
`20· and editing them together.
`
`21· · · ·Q.· ·And -- and how then are they conveyed to the public?
`
`22· · · ·A.· ·That airs during an ad break.
`
`23· · · ·Q.· ·Okay.· And so what you've described is basically a
`
`24· video editing, correct?
`
`25· · · ·A.· ·Uh-huh.
`
`

`

`1 MR. MATTEI: And then we'll come back and let
`
`2 you --
`
`3 MR. PATTIS: Just with Alinor?
`
`4 MR. MATTEI: Just with Alinor.
`
`5 THE VIDEOGRAPHER: Off the record at 9:46 a.m.
`
`6 (Break was taken from (9:46 a.m. to 9:53 a.m.)
`
`7 THE VIDEOGRAPHER: We're on the record at 9:53
`
`8 a.m.
`
`9 Q. (BY MR. MATTEI) Mr. Dew, prior to the break you
`
`10 testified that one of the things you did to independently
`
`11 investigate the Sandy Hook shooting was to listen to recordings
`
`12 of 911 transmissions, correct?
`
`13 A. Uh-huh.
`
`14 Q. Did you do anything else?
`
`15 A. Well, people would send us leads so I'd look at those.
`
`16 You know, email -- email tips. You know, if it was an article
`
`17 I'd print it out, show it to Alex. I mean, the only other -- the
`
`18 only other thing that pops in my head is talking to my uncle who
`
`19 went to some local board meeting they had.
`
`20 Q. Okay. Let me first ask you about these -- these leads.
`
`21 So people would either call in to Free Speech Systems or email
`
`22 tips concerning Sandy Hook, correct?
`
`23 A. If they called I would say they called into the show
`
`24 live.
`
`25 Q. Okay. And did you ever attempt to independently
`
`

`

`1 investigate any tips received by Free Speech Systems concerning
`
`2 Sandy Hook?
`
`3 A. Well, I would say most of the tips were either an
`
`4 article or a video clip somewhere. So, I mean, there is not
`
`5 much -- if -- if the video clip say of the helicopter aerial
`
`6 shots, you know, you look at it, it looks like Sandy Hook school.
`
`7 You assume that that was the day of. There is cops walking
`
`8 around the school. So I don't know how much investigating you do
`
`9 in a circumstance like that. Most of them are either for
`
`10 articles or, you know, like, local newsclips.
`
`11 Q. Okay. We'll deal with those in a second. For tips
`
`12 that were not either article or local -- articles or local
`
`13 newsclips, to the extent you received any of those, did you do
`
`14 anything to investigate any of them?
`
`15 A. I don't -- I don't remember investigating anything that
`
`16 wasn't either an article or a video clip.
`
`17 Q. Okay. With regard to articles and video clips, did you
`
`18 independently investigate the information set forth in any of
`
`19 those?
`
`20 A. Like I said before, if it was -- if it had -- if it was
`
`21 an article that had links you'd drill through the links to see
`
`22 where they went, see if it went to a source document. That was
`
`23 something, you know, we'd look at whether it had a source
`
`24 document or not. So -- and then the video clips were -- were
`
`25 mostly local news coverage that people had clipped out and
`
`

`

`1 either, you know, shot on their TV or clipped it out and put it
`
`2 on social media somehow.
`
`3 Q. And you accepted those video clips for what they
`
`4 purported to be?
`
`5 A. Uh-huh.
`
`6 Q. Okay. And the articles that you received, the only
`
`7 independent investigation you did with the information set forth
`
`8 there was get a primary document was somehow associated with it
`
`9 or linked to it, correct?
`
`10 A. Yeah, and it would depend on what the -- I guess the --
`
`11 what the article was saying.
`
`12 Q. Okay. And you said you talked to your uncle. Your
`
`13 uncle is a retired FBI agent, correct?
`
`14 A. Correct.
`
`15 Q. He lives in New Jersey?
`
`16 A. Correct.
`
`17 Q. Okay. Do you have an address for him?
`
`18 A. Not off -- I don't know it by heart.
`
`19 Q. Okay. All right. You testified that one of Free
`
`20 Speech Systems' goals is to put out -- put out information?
`
`21 A. Uh-huh.
`
`22 Q. Right? Why -- so before I ask you about that. Am I
`
`23 correct that before June of 2018 there were no written
`
`24 journalistic standards at Free Speech Systems?
`
`25 A. I would say that's correct.
`
`

`

`1 Defendants for examination, signature and return to Huseby Global
`
`2 Litigation by June 10, 2019;
`
`3 That the amount of time used by each party at the deposition
`
`4 is as follows:
`
`5 Mr. Christopher M. Mattei - 01 hour(s): 10 minute(s)
` Mr. Norman Pattis - 00 hour(s): 00 minute(s)
`6 Ms. Kristen A. Jakiela - 00 hour(s): 00 minute(s)
` Ms. Claire Pariano - 00 hour(s): 00 minute(s)
`
`7 8
`
` That pursuant to information given to the deposition officer
`
`9 at the time said testimony was taken, the following includes all
`
`10 parties of record:
`
`11 Mr. Norman Pattis & Ms. Alinor C. Sterling, Attorneys for
` Plaintiffs
`12 Mr. Norman Pattis, Esq, Attorney for Alex Emric Jones,
` InfoWars, LLC, Free Speech Systems, LLC, InfoWars Health, LLC and
`13 Prison Planet TV, LLC
` Ms. Kristen A. Jakiela, Attorney for Cory T. Sklanka
`14 Ms. Claire Pariano, Attorney for Midas Resources, Inc.
`
`15 I further certify that I am neither counsel for, related to,
`
`16 nor employed by any of the parties or attorney in the action in
`
`17 which this proceeding was taken, and further that I am not
`
`18 financially or otherwise interested in the outcome of the action.
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`

`

`1 Certified to by me this 21st day of May, 2019.
`
`2 3
`
`7 8 9
`
` _________________________________
` Amber Kirton, CSR
`4 Expiration Date: 12/31/19
` Firm #660
`5 Huseby Global Litigation
` 1230 West Morehead Street, Suite 408
`6 Charlotte, NC 28208
` (800) 333-2082
`
`10
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`11
`
`12
`
`13
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`14
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`15
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`16
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`17
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`18
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`19
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`20
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`21
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`22
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`23
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`24
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`25
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`

`

`EXHIBIT D
`EXHIBIT D
`
`

`

`From: Rob Dew <robd@infowars.com>
`To: Dan Bidondi <truthradio990@hotmail.com>
`
`Subject: Re: BIDONDI- MOS QUESTIONS
`Date: 2015-07-07 06:07:43 +0000
`
`Dan -- The MOSwill be old by the time we canair it
`
`Go to Sandy Hook -- wewill cover that
`
`Rob
`
`no--- Original Message -----
`From: "Dan Bidondi"
`To: "Rob Dew"
`
`Sent: Friday, July 3, 2015 1:37:17 PM
`Subject: BIDONDI- MOS QUESTIONS
`
`Hey Rob, can | do an MOS tomorrow?
`| wanted to hit up the Bristol Day 4th of July Parade,it's the countries oldest and longest running 4th of July Parade celebration.
`
`Questions: Any you want to ad or take out let me know
`
`1- What holiday are we celebrating today?
`
`2- What country did we defeat to gain our Independece?
`
`3- In what year did we declare Independence?
`
`4-Whatis the name of the documentthat was signed on this date?
`
`5- Can you name any of the Founding Father's that signed the Declaration of Independence?
`
`6- According to our Constittution, who gives us our rights?
`A: The Government B: The Military
`C: We The People or D: Obama
`
`7- How many stars are on the flag?
`
`8- How many strips?
`
`9- Islamic Leader Louis Farrakhan recently stated that the American Flag needs to be put down. Do you agree with that or not, your
`thoughts?
`
`10- Whatis your thought about people burning and stomping on the American Flag?
`
`FSSTX-076014
`
`

`

`11- Do you think the Confederate Flag should be banned, and do youthink that banning this flag is an attack on the 1st Amendment?
`
`FSSTX-076015
`
`

`

`EXHIBIT E
`EXHIBIT E
`
`

`

`NO. X06-UWY-CV-18-6046436-S
`
`ERICA LAFFERTY, ET AL.
`
`
`
`
`
`V.
`
`
`
`
`
`ALEX EMRIC JONES, ET AL.
`
`____________________________________________________________________________
`
`NO. X06-UWY-CV-18-6046437-S
`
`WILLIAM SHERLACH
`
`
`
`
`V.
`
`
`
`
`ALEX EMRIC JONES, ET AL.
`
`_____________________________________________________________________________
`
`NO. X06-UWY-CV-18-6046438-S
`
`WILLIAM SHERLACH, ET AL.
`
`
`
`
`
`
`V.
`
`
`
`
`
`
`ALEX EMRIC JONES, ET AL.
`
`
`
`SUPERIOR COURT
`
`COMPLEX LITIGATION DOCKET
`
`AT WATERBURY
`
`
`
`SUPERIOR COURT
`
`COMPLEX LITIGATION DOCKET
`
`AT WATERBURY
`
`
`
`SUPERIOR COURT
`
`COMPLEX LITIGATION DOCKET
`
`AT WATERBURY
`
`
`
`:
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`:
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`:
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`:
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`:
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`:
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`:
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`:
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`STIPUL

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