1

5 SELECT COMMITTEE TO INVESTIGATE THE

6 JANUARY 6TH ATTACK ON THE U.S. CAPITOL,

7 U.S. HOUSE OF REPRESENTATIVES,

8 WASHINGTON, D.C.

10

11

12 DEPOSITION OF: ALI ALEXANDER

13

14

15

16 Thursday, December 9, 2021

17

18 Washington, D.C.

19

20

21 The interview in the above matter was held at Room 5480 O'Neill Building,

22 commencing at 10:07 a.m.

23 Present: Representatives Lofgren, Schiff, Aguilar, Raskin, Cheney, and Kinzinger.

 2

2 Appearances:

4 For the SELECT COMMITTEE TO INVESTIGATE

5 THE JANUARY 6TH ATTACK ON THE U.S. CAPITOL:

7 INVESTIGATIVE COUNSEL

8 RESEARCHER

9 CHIEF CLERK

10 RESEARCHER

11

12 STAFF ASSOCIATE

13 SENIOR INVESTIGATIVE COUNSEL

14 SENIOR INVESTIGATIVE COUNSEL

15

16 For THE WITNESS:

17

18 PAUL D. KAMENAR, ESQ.

19 1629 K Street, NW.

20 Suite 300 Washington D.C. 20006

21

22 JOSEPH D. MCBRIDE, ESQ.

23 MCBRIDE LAW FIRM, PLLC

24 99 Park Avenue, 25th Floor

25 New York, NY 10016

 3

2 Mr. - The time is 10:07 a.m. Good morning. This is a deposition of

3 Mr. Ali Alexander conducted by the House Select Committee to Investigate the January

4 6th Attack on the United States Capitol, pursuant to House Resolution 503.

5 At this time, I would ask the witness to please state your full name and spell your

6 last name for the record.

7 The Witness. My chosen and professional name is Ali Alexander. Ali is spelled

8 A-1-i. I was born Ali Akbar, A-k, Bas in boy, a-r.

9 Mr. And what name would you like for us to use today for the

10 purposes of this deposition?

11 The Witness. Mr. Alexander. I appreciate you guys.

12 Mr. - No problem, Mr. Alexander.

13 So this will be a staff-led deposition, and members, of course, may choose to also

14 ask questions throughout this deposition. In the room today you have myself,

15 investigative counsel, senior investigative counsel,

16 , the parliamentarian.

17 And then members, we have Ms. Zoe Lofgren and Mr. Adam Kinzinger.

18 Under the House deposition rules, neither committee members nor staff may

19 discuss the substance of testimony you provide today unless the committee approves

20 release. You and your attorney will have the opportunity to review the transcript.

21 Before we begin, I'd like to describe a few ground rules. We will follow the

22 House deposition rules that we provided to your counsel previously. Under the House

23 deposition rules, counsel for other persons or government agencies may not attend, and

24 you are permitted to have an attorney present. I would like to note for the record that

25 what was previously presented to Mr. Alexander's attorney as exhibit 1 is the subpoena
 4

1 for Mr. Ali Akbar, Mr. Ali Alexander, which is dated October 21, 2021. You are here for

2 this deposition pursuant to that subpoena. The House deposition rules are included in

3 this exhibit, which is exhibit 1, and were previously provided to you and your counsel.

4 At this time, would counsel please state their name for the record?

5 Mr. Kamenar. Yes. Paul Kamenar, K-a-m-e-n-a-r.

6 Mr. McBride. Joseph Daniel McBride, M-c capital B-r-i-d-e. Good morning.

7 Mr. - There is also an official reporter transcribing the record of this

8 deposition. Please wait until each question is completed before you begin your

9 response. And we will try to wait until your response is complete before we ask our

10 next question.

11 The stenographer cannot record nonverbal responses such as shaking your head.

12 So it is important that you answer each question with an audible verbal response. If I

13 notice you're using a nonverbal response, I may ask you to clarify it with your words on

14 the record.

15 We ask that you provide complete answers based on your best recollection. If

16 the question is not clear, please ask for clarification. If you do not know the answer,

17 simply say no.

18 You may only refuse to answer a question to preserve a privilege recognized by

19 the select committee. If you refuse to answer is question based on privilege, staff may

20 either proceed with the deposition, or seek a ruling from the chairman on that objection.

21 If the chairman overrules such an objection, you are required to answer the question.

22 I also want to remind you it is unlawful to deliberately provide false information to

23 Congress. Since this deposition is under oath, providing false information could result in

24 criminal penalties for perjury and/or providing false statements.

25 Do you understand that, Mr. Alexander?

 5

1 The Witness. I do.

2 - Would you please stand and raise your right-hand to be sworn in?

3 [Witness sworn.]

4 - Can we please confirm that no one in the room is recording other

5 than the official reporting of this deposition?

6 Mr. Kamenar. No.

7 The Witness. We're good.

8 M r . - Thank you.

9 Logistically, please let us know if you need any breaks or would like to discuss

10 anything with your attorney, Mr. Alexander, and we will go on recess so that you can do

11 so. There also may be several people asking you questions here today, including the

12 members. If you don't understand the question from them as well, just simply ask for

13 clarification.

14 Now, Mr. Alexander, I understand that you prepared an opening statement. If

15 you could like it enter that statement into the record, the select committee can

16 accommodate that and we have previously marked it as Exhibit 41 in your binder.

17 Would you like to also give a statement, provide a statement verbally?

18 The Witness. Yes, I would. I got my final statement this morning so.

19 Mr. - Would you like to enter that it into the record in lieu of what has

20 been previously marked as Exhibit 41?

21 The Witness. Absolutely.

22 [Alexander Exhibit No. 41

23 Was marked for identification.]

24 Mr. Can you please provide that to us and to the court reporter?

25 The Witness. Yes.

 6

1 [Alexander Exhibit No. 42

2 Was marked for identification.]

3 Mr. - Mr. Alexander, as this was not a congressional hearing, witnesses

4 are not invited or entitled to deliver an opening statement. However if you with like to

5 deliver a brief statement on the record, we will allow you to do so now.

6 The Witness. I would like to.

7 Mr.- Thank you. Proceed.

8 The Witness. Good morning, Chairman Thompson, members of the committee,

9 and committee staff. My name is Ali Alexander. With my today are my legal counsel,

10 Joseph McBride, Paul Kamenar, and unfortunately Baron Coleman who has been

11 corresponding with you could not attend

12 I want to be crystal clear at the outset, I had nothing to do with any violence or

13 law breaking that happened on January 6th. I had nothing to do with the planning of

14 violence. I had nothing to do with the preparation of violence. I had nothing to do

15 with the execution of violence.

16 Any suggestion to the contrary is factually false. Anyone who suggests that I had

17 anything do with the unlawful activities of January 6th is wrong. They are either

18 mistaken or lying. Period.

19 It is not uncommon in the aftermath of historic chaos and disruption to look for a

20 bogeyman. After all, someone must be held accountable, right? As an Arab man and a

21 Black man, an American, it is common for people who look like me to be blamed for

22 things that we did not do. On top of that, my birth name can sound scary to the

23 uninformed and uneducated. It has often been used as a weapon against me by both

24 the left wing and the right wing. Ali Abdul-Razaq Akbar, someone with that name, that

25 terrifying must have done something wrong, right?

 7

1 Again, I want to be perfectly clear. I did absolutely nothing wrong. I don't hide

2 from who I am. I'm the American Dream. My mother was a Black mother in Section 8

3 housing. My father was an Arab man who disappeared when I was just 2 years old.

4 About 15 years ago or so, I was arrested on two different occasions for petty crimes.

5 won't re-litigate the merits of those offenses in this short time, but two arrests in your

6 early twenties as a Black man often sets people back, so far back, that they never again

7 find firm footing upon which they can succeed.

8 I managed to collect those two criminal charges as I was just starting out as an

9 adult. I had every reason to fail in life, but I refused to fail. My faith in Christ refused

10 to allow me to fail.

11 Instead, I worked to change the system people insisted was supposed to hold me

12 down. I got involved in politics and started putting together coalitions, rallies, raising

13 awareness for a variety of candidates and causes I believe in. I went from riding in the

14 back of a cop car as the accused to advising the Presidential administration on criminal

15 justice reform.

16 I used a silhouette of my most tragic youthful mug shot on a T-shirt to raise money

17 for fatherless Black boys. Boys who were growing up like me. I've hosted hundreds of

18 rallies with millions of participants in all 50 States, not one single rally, to my knowledge,

19 has ever turned violent, not one, never. That's not a coincidence. I demand

20 nonviolence at my events. I demand it nonviolence among my membership and

21 leadership. I demand it nonviolence among my associates.

22 My leadership and I work closely with law enforcement at every event to ensure

23 peace and order. We obey rules and commands, we treat officers and officials with the

24 respect they deserve. Those principles were not compromised on January 6th. In fact,

25 I stated on numerous occasions that I support the production of legislative solutions and
 8

1 recommendations on how to best avoid future collapses of civil order and violence at the

2 Capitol. I've stated on numerous occasions that I support the work of law enforcement

3 agencies to prosecute those who committed violent acts on January 6th.

4 There are a number of videos of my associates and me arriving at the Capitol on

5 January 6th, after the violence had begun, but early in the stage -- in the early stages of

6 law breaking. And those videos our group can be seen working with officers to try to

7 end the violence and law-breaking. We can be seen yelling and screaming at people to

8 stop trying to breach the Capitol, and to stop violent law-breaking in general. I believe

9 those videos have been provided to the committee. If they have not, we'll happily share

10 them.

11 While I was actively trying to deescalate events at the Capitol to end the violence

12 and law-breaking, it is my believe that this many have not been a problem had the

13 Women for America First leadership at the Ellipse event not intentionally removed

14 instructions from the program that were supposed to be included to provide clarity on

15 exactly where to go following the Ellipse event, and that was to Lot 8, the north side of

16 Capitol Grounds, where we had a permit.

17 When I protested the removal of these instructions, I was barred from

18 participating as an organizer or speaker at the Ellipse event that preceded the Capitol riot.

19 Ultimately, I became just a VIP guest at the Ellipse event. As a result, civil authority

20 collapsed before the Ellipse rally was even over, this is well-documented before I arrived

21 and before my event was ever scheduled to begin. I want to clarify, my permitted event

22 at Lot 8 never took place on the northeast side of the Capitol Grounds. The quote, "One

23 Nation Under God" event that Stop the Steal did not start the chaos. The chaos was

24 well underway before our event was scheduled to begin. We never held our event, we

25 weren't allowed to.

 9

1 In closing, I want to reiterate my efforts to comply with the committee's

2 subpoena. Over the past few weeks, I've spent more than 80 hours personally searching

3 through my archives, looking for relevant and responsive documentation to the

4 committee's request. I have probably spent another 120 hours preparing for your

5 answers over the past 3 weeks. And I've hired attorneys and computer consultants to

6 be as responsive as possible, to provide as much as I can find within the short amount of

7 time that I had to produce documents.

8 We have submitted hundreds of pages of documents representing thousands of

9 records, emails and texts, even though much of what is sought over is not pertinent to

10 the committee's purpose, or in some cases, subject to privilege. I did all this despite not

11 being accused of a crime. I did all this despite being a private citizen with constitutional

12 rights protecting me from unreasonable searches and seizures without a warrant entitling

13 anyone to the documents in some cases, I voluntarily provided. It has prevented me

14 from working. It has preventing me from sleeping at times. And it has been extremely

15 difficult and burdensome, but I am here to do the patriotic thing voluntarily.

16 If this committee thinks of anything I haven't turned over to which you believe I

17 have access to, I ask that you please let me know and how much refresh my memory.

18 receive, at times, hundreds, or even thousands of texts, or emails a day. I appear at all

19 hours of day and night on media and social media and do interviews, livestreams, and

20 chats. I can't possibly remember everything I've seen, everything I've heard, everything

21 I've read or said.

22 I went from living the American Dream to experiencing an American nightmare,

23 where my for my skin color, my birth name, my party affiliation, who I voted for in 2024,

24 my ability to earn a living, my belief that Christ is king, and a concerns about election

25 irregularities have been weaponized against me. But I can assure you I have you nothing
 10

1 to hide because I have done nothing wrong.

2 We may disagree politically, they call politics a contact sport after all. But at

3 heart, we're all Americans. We stand before God and our fellow man in a great social

4 contract where we promise to do the best to get it right. May God have mercy on us

5 and us peace for how we treat each other at times in the world of politics.

6 I thank you for your time. I look forward to answering any questions you have.

7 And one thing I'd like to add is while America is divided on many issues, at the end of the

8 day our First Amendment rights to assemble to protest, whether on the right or the left,

9 should be protected and should be protected by this body. To prevent future unlawful

10 activity which is the goal of this committee, whether from those who stormed the Capitol,

11 or those abortion rights activists who stormed the Supreme Court, or blocked Justice

12 Kavanaugh's confirmation, or BLM rioters, that is a matter of law enforcement, not the

13 suppression of free speech and assembly. Thank you.

14 Mr. Thank you, Mr. Alexander.

15 Before we get into the questions, I would like to note for the record that I will be

16 referring to exhibits throughout the questioning here today and it won't be in a

17 sequential order. There is premarked in your binders, so I will be referring to a different

18 documents throughout the day. I just want to make everyone I might start with Exhibit

19 26, I might go to Exhibit 2, but they have all been premarked and have all been provided

20 to you in your binders here today.

21 Mr. Kamenar. Thank you.

22 EXAMINATION

23 BY
24 Q So Mr. Alexander, let's start with Exhibit 26, let's start there. I'll give you

25 time to flip to that exhibit. And I want to orient you a little bit. Let's go to the evening
 11

1 of January 5th. And can you go to page 211, there's Bates numbers in the bottom

2 corner.

3 Mr. Kamenar. Exhibit 26?

4 M r . - 26. Yes.

5 Mr. Kamenar. Is that the one with the --

6 Mr.~ That's correct. That's correct. Page 211.

7 BY

8 Q So this is the evening of January 5th at approximately 7:19 p.m., you text a

9 Ms. Liz Willis, what appears to be an itinerary for January 6th. You said "Ellipse," then

10 the "U.S. Capitol. Trump is supposed to order us to the Capitol at the end of his speech,

11 but we will see." So on January 5th around this time, just walk us through what events

12 you planned to attend on January 6th?

13 A I'm sorry. Can you repeat that?

14 Q At this time on January 5th, that evening, walk us through what your plans of

15 what events you were going to attend on January 6th?

16 A The first thing I want to state it is 7:19 p.m., I'm trying to place myself. A

17 great deal of my actions are captured on video, so I wouldn't rely on memory to tell me

18 where I was texting this reporter. So Liz Willis is with RSBN. She's a reporter asking

19 about logistical information to the best of my knowledge.

20 Q I'll make it a little easier then --

21 A Can I --

22 Q Oh yes, you can finish.

23 A Just for clarification, I don't know that this is 7:00 p.m. -- 7:19 p.m., it looks

24 like it could be a.m. because --

25 Q Okay. Sorry about -- so 7:19 a.m. So the day before January 6th, what
 12

1 were your plans for January 6th? What events were you going to go to?

2 A From what I recall, January 6th was about attending the Ellipse event at 6:00

3 or 7:00 a.m. to help guide VIPs to try to figure out when my speaking slot was going to be,

4 to make sure they had control of all that media, et cetera. So I don't know when I

5 arrived, but it was certainly early. And to the best of my memory, it was certainly, you

6 know, before 7:30 or 8:00, but these text messages will probably provide a better

7 accounting of that time.

8 And again, on January 5th thinking about what am I expecting to do on January

9 6th at the conclusion of the President's speech, you know, he's going to keynote it

10 obviously, we were going to exit and then go to Lot 8 where we had a permit for a

11 coalition called "One Nation Under God," Stop the Steal was the funder of it; Stop the

12 Steal was the main organizer of it, but it was a religious and political thing. We

13 exhausted all of our other political options and left it up to Congress. And so, that is my

14 awareness.

15 And what I want to convey to the committee is that you don't tell the President

16 when to stop speaking. So while a lot of us may have said, Oh, this would be beautiful if

17 it ended at 12:30, it could have ended at 1:00 or 1:30 and that would affect the lot 8

18 event. So anyway, I think to the best of my recollection, on January 5th, the only two

19 events I'm planning to attend are the Ellipse event, and then the Lot 8 event, but I'm

20 aware of, like, a dozen -- nearly a dozen other events happening within proximity and

21 others. And it's not foreign that people would pull me aside and ask me to attend

22 something.

23 Q Thank you. And just to clarify, when you say Lot 8, where is Lot 8?

24 A Lot 8 is, and this is a ser -- it is kind of -- it's not embarrassing, but just to

25 show you how kind of -- I've worked in politics a long time, but I've tried to avoid D.C., is
 13

1 my best understanding is that Lot 8 is on the northeast side the Capitol Grounds. So it is

2 not the Capital Plaza, it is not the Capitol Building, it is the northeast side the Capitol

3 Grounds.

4 In many of my text messages I think I'm referring to as south. And so I think that

5 my attorneys have tried to provide clarification and correspondence, but I'm not -- I think

6 that happened, but --

7 Q But just to be clear, your plans on January 5th for the next day is that you

8 were going to the Ellipse and then you were going to go to the Capitol Grounds. Those

9 are the two events?

10 A I can't recall anything outside of those two permanent events.

11 Q Okay. And on January 5th what were your expectations for the attendees?

12 Where were they going to go on January 6th? Where did you think the

13 participants -- what events were they going to go to?

14 A You're ask -- well, to be honest, I couldn't -- you know, I want to speculate

15 with you, but I'm being asked to recall about what I thought on January 5th, and that's 11

16 months ago. And, you know, out of an abundance of caution, I don't want to give you

17 false testimony, so while I'd like to engage on speculating with you, the text messages

18 probably provide more information than I could 11 months later.

19 Q So let's do that then. On the same page in your same text with Ms. Liz

20 Willis, you say, "Trump is supposed to order us to the Capitol at the end of the speech,

21 but we will see." So your expectation is you were going to go from the Ellipse and by

22 "us," the attendees, to the Capitol, correct?

23 A The Lot 8 event followed the Ellipse event schedule-wise. And there is -- I

24 don't know what the perimeter was, in November it was something, in December it got

25 wider, and then in January, you know, the D.C. authorities made it even wider. The only
 14

1 way of getting from one physical location to another is to walk over, and so that's that.

2 Q So just to confirm, you were going to attend the Ellipse, and the attendees

3 and you were going to walk over to the Capitol Grounds following it?

4 A Or use a golf cart.

5 Q Or use a golf cart?

6 A Yes.

7 Q But travel, travel from the Ellipse to the Capitol Grounds?

8 A Yeah. I mean, I didn't have access to any other means of transporting

9 myself, to my knowledge.

10 Q So I want to go back to something you said a little earlier, I guess on the 5th,

11 you believed you were going to be a speaker at the Ellipse on January 6th?

12 A Absolutely.

13 Q And why did you think that you were going to be a speaker at the Ellipse

14 event?

15 A I think my text messages and email correspondences that I have provided to

16 the committee represent -- unfortunately, I'm watching it be debated in the press and on

17 Twitter, but contemporaneously it wasn't a debate. I'm talking with a Trump campaign

18 staffer, the representations that are being made to me are contemporaneously being

19 proven true. There was some suspicion among some of my associates that, no, no, no,

20 we're being played. But that's not -- I didn't see any evidence of that. And I had heard

21 that there was some people who didn't want me to speak, but that's not the

22 representation from the Trump campaign official that I got. And so, I can attest that my

23 text messages, my emails, and the fact that I showed up that early attests to the fact that

24 I, 100 percent, believed, you know -- again, I'm recalling something 11 months later, but

25 that I was the speaker at this event.

 15

1 Q Who--

2 A And --

3 Q Okay.

4 A I'll just provide some more rope. But, you know, even evidenced by this is

5 a -- [Link] ran a story saying I was a speaker. And I don't know when that article

6 came out and I didn't talk to Breitbart about that article, so I had every belief to believe

7 that I was a speaker at the Ellipse event.

8 Q Who was the Trump campaign staffer that you were just referencing?

9 A The Trump campaign official that I was just representing was Caroline Wren.

10 Q Who is Ms. Caroline Wren?

11 A Caroline is a political consultant. She, you know, I don't know like, you

12 know, what her official titles were. I knew that she was a fundraiser. And I knew that

13 she either had the Trump campaign, or PAC, or we all -- I work in politics, I guess you guys

14 work in government, but when we say someone works for something, we could be talking

15 about a larger collection of entities, whether it is, like, a joint fundraising committee, or a

16 PAC, or a campaign. So during it, Caroline Wren was working with the President's son

17 and Kimberly Guilfoyle to do fundraising, and was the person who initially reached out

18 and said she reached out on behalf of, let's call it Trump world, and wanted to unite these

19 events.

20 Q What role did Ms. Wren represent to you? What was her role that she

21 represented to you? Did she say I'm part of the Trump campaign?

22 A That was 12 months ago -- or that was, like, 11 months and 2 weeks ago or

23 so. So I wouldn't be able to recall specifically. What I believe, you know, based off my

24 best recollection that I colloquially called her in my internal communications with people

25 and on conference calls and stuff like that that she was with the Trump campaign. So I
 16

1 can't -- if I said something else, you know, that's possible. If it was more detailed,

2 but -- but just on the record.

3 Q So just, it was your understanding at this time in January that Ms. Caroline

4 Wren was part of the Trump campaign. Is that fair to say?

5 A What's fair to say is that Caroline Wren represented greater access to the

6 decision makers in Trump world, in Trump world it could be the RNC, it could be the

7 Trump campaign, it could be the joint fund raising committee, with any number of

8 entities. And again, just out of the abundance of caution, because you know, I wasn't

9 asked to volunteer my testimony. I'm here under subpoena. And I know you guys

10 have got a job do. And I know that there's been some, you know, adversarial

11 accusations about me, but you know I would love to nail it more down for you, but I think

12 that's what I can give you.

13 Q So it was Ms. Wren who asked you to speak at the Ellipse on January 6th, to

14 the best of your recollection?

15 A To the best of my recollection.

16 Q Okay. You mentioned that Ms. Wren worked with President Trump's son

17 and Ms. Kimberly Guilfoyle. Can you please elaborate more on that working

18 relationship for us?

19 A No. But if you have a specific question, I couldn't because I wasn't with

20 them.

21 Q What did she represent to you. How was she working with the President's

22 son and Ms. Kimberly Guilfoyle?

23 A Well, what's been widely recorded is that she works in a fundraising capacity

24 officially with Kimberly Guilfoyle. And I think it was either RNC part-time and Trump

25 campaign part-time or something like that, you know, consultants we're allowed to have
 17

1 a lot of hats. But, you know, you have like different guidance memos and firewalls. So

2 if I represented anything more to you, I would be speculating. But -- and then obviously,

3 as I understand the President's son, you know, was at a lot of these events. I don't know

4 that he was a contractor getting paid for his work. He's obviously a surrogate for his

5 father.

6 Q Which son, just so we're clear?

7 A Donald Trump, Jr.

8 Q So I just want to make sure I'm understanding this correctly. You

9 understood Ms. Wren's role with Ms. Kimberly Guilfoyle and Mr. Donald Trump, Jr. based

10 upon public reporting. Is that true?

11 A We certainly had a conversation about it.

12 Q Okay.

13 A But I can't recall it 12 months later.

14 Q Got it.

15 A I'm sorry.

16 Q Oh, no worries. No worries at all.

17 So in your view, who was in charge of the January 6th event at the Ellipse? For

18 example, was it Stop the Steal? Was it the White House? Was it Women for America

19 First? Who was in charge of that event?

20 A Could you clarify what you mean by in charge?

21 Q Who was responsible for the decision making of the January 6th event at the

22 Ellipse?

23 A You know, I've done 15 years of political organizing, and I've been doing

24 events since, I think, 2010, I think 2010. I did help the RNC in 2008, but -- I don't want to

25 be coy, but coalition-type events, the decision tree it really depends on what silo of the
 18

1 event you're kind of talking about, what aspect you're talking about.

2 Different people have different expertises, different people have different

3 personalities, different people are in a different pecking order in life, you know. And

4 so -- so again, if you ask me, your first question is, who was in charge, it would be

5 speculative for me to say something. And it would be a characterization that is

6 subjective, and probably categorizes more than what you guys should actually want.

7 You guys should want a more detailed probing into the event, and a general answer like

8 that I don't think would -- it would just require my speculation and not serve the purpose.

9 Q So on the morning of January 6th, who did you understand made the

10 decision that you would not speak?

11 A I'm trying to relive that moment real quick.

12 Q Take your time.

13 A So here's my best memory, if I could walk you through it. I arrive to the

14 Ellipse event in a golf cart, permitted golf cart. There is feuding at the VIP tables.

15 have a very strong personality, and on line, I represent myself very aggressively. But

16 anyone who knows me, knows that I'm generally a peacemaker, a dealmaker, a coalition

17 builder. And I bring a variety of people together, and there's press reports that accuse

18 me of, like, even of White supremacy and stuff like -- it is frankly bizarre some of the

19 things I get accused of because I'm actually a big tent guy.

20 And so, I remember helping to contribute to squash that beef. And I did so with

21 my reputation as the founder of Stop the Steal. So that's the authority I was using.

22 And so, in a situation like that, imagine this, there are people who have physical

23 badges. Okay, so is that person in charge? There is a decisionmaker somewhere.

24 There is someone who gave them the badges. And then there's me, you know, who is

25 saying, I really don't care right now, this needs to work this way.
 19

1 Anyway, I wanted to describe that microcosm event to you so that you could

2 understand what would take place when we finally got into the rally. So we got through

3 the

4 Secret Service. They are running the metal detectors. We walked through a muddy

5 field. We walked past the press. And then the VIP seating section I can't recall, but I

6 want to recall. I don't know when, because I went out and in several times, but there

7 might have been a hold-up initially again, because people are trying to decide is this the

8 Stop the Steal event? Is this the Women for America First? Is this a Trump event? Is

9 this a TP USA event? You know, and this is a lot of egos and personalities.

10 Anyway, as we make it through there, I immediately make a Bline towards the

11 front to see if there's a seating chart, because the seats that you can immediately see

12 there is no seating chart. When we walk up there we finally see a seating chart, and I'm

13 really happy with my seat, obviously. You know, and then I find Caroline Wren to thank

14 her. And ask her when I'm speaking. And she said, don't get me started. And that's

15 what I recall her saying. That's my best recollection. And I said, that's not an answer.

16 And I actually need an answer because I'm going to go speak. And I haven't prepared a

17 speech, okay? None of my speeches over the 60-plus days of Stop the Steal, to my

18 recollection, were prepared, none of them, okay. And the Ellipse wasn't going to be any

19 different. And because I wanted more people to speak from the Stop the Steal coalition

20 I actually was going to take 3 to 5 minutes.

21 So then I'm informed that the police were called on Caroline Wren by Tyler

22 Kramer, and this is -- you guys haven't asked this, and my lawyer is probably, like, what

23 are you doing, but I'm thinking, this is kind of a brain fart moment. This is a Trump

24 campaign official, wearing Trump gear, who is the only reason this event exists, and has

25 done great work, and has been a peacemaker, and delivered on the goods. She
 20

1 delivered the President, you know, that's a big, that's a big deal. And you're telling me

2 that a PAC or a (c)(4) or whatever of people who I have been friends with, you know, prior

3 to November for a decade through, you know, thick and thin, that they called the police

4 on her. Okay. I'm trying to figure out why are you still here? What authority do they

5 have to call the police? I do know the permit's in their name, but that's is kind of like a

6 placeholder. And what does Don, Jr. think about this? What does Kimberly think

7 about this, you know?

8 And so a -- so I'm trying to figure out whether I'm being played by Caroline, or

9 whether I got, you know, screwed over for lack of a better term by Kylie and Amy Kremer,

10 because they are the permit holder and they have a legal -- so the National Park Service

11 has a legal obligation to service the name on the permit.

12 And so, I actually press her for more answers, because I need to figure out what

13 the heck is going on because there's a lot of people who look to me to tell them what

14 then they are going to. Activist Scott Pressler and other people. And so, again, my

15 best recollection from an event that's 11 months ago, but this was obviously a moment

16 that really pissed me off. And, you know, it is kind of playing itself out now.

17 So then she proceeds to tell me that the National Park Service or police or

18 whatever got called, they showed up, they did try to kick her out. They decided not to,

19 and that she was avoiding it. And it is probably best just to be a team player, Ali. And I

20 felt taken advantage of. And not by Trump, and not by the Trump campaign, and not by

21 Caroline. It just looked like more drama. And, you know, I said, Well, what about my

22 other speakers? Because I can understand if somebody has some personal vendetta

23 against me, what about the others? And I was told, no, we have no control. So then I

24 say, okay, well if it this is kind of a federated decision-making process -- and I hope in this

25 answer you can see why I didn't invade your previous answer. I am just describing like
 21

1 this is how events go. It is very hard for people to believe that, but my story establishes

2 that this is true.

3 So when I tried to go backstage, this guy in military boots and all this other stuff

4 who has a Women for America badge on him -- America First blocks me. He's, like,

5 you're not going out there, Ali. I'm, like, how does this dude know my name, but a lot of

6 people know he my name. But he said it with a personal, you know -- it was almost like

7 this had been prepared, you know.

8 And so, that let me know that I did not get screwed over by Caroline, that this was

9 something that happened in the last minute. Where it happened, I would just have to

10 figure out in the months or weeks later. My answer is going long, isn't it? So -- so

11 yeah, I think that answered your question.

12 Q We'll come back to a little later when we get to the day of January 6th. But

13 sticking with the evening or the day of January 5th, in that same message, to Ms. Willis

14 you say Trump is supposed to order us there. Order us, it refers to the Capitol complex

15 after the speech at the Ellipse. Was this -- did you come to this understanding through

16 Ms. Caroline Wren? Is that who told you that?

17 A That was -- that was -- that was 11 months ago, I couldn't tell you how

18 exactly I came to that understanding. It is obvious -- I can tell that you Liz Willis is a

19 good journalist. I'd have no reason in this text message at 7:19 a.m. to lie. And I do

20 know that I'm obviously pretty busy at this moment firing off a text and hoping that it

21 that it gets through the condensed cell tower, you know, there's a lot of people there.

22 And so, you know, during these things you're chattering with a lot of people so.

23 Q So you don't know how you came about telling Ms. Willis that Trump was

24 supposed to order us? You don't remember how you came to that conclusion?

25 A Eleven months later with the specificity that is required when swearing
 22

1 before God under oath, no.

2 BY

3 Q May I just ask, Mr. Alexander, was there anyone other than Caroline Wren

4 who you were talking to at the time who claimed to be speaking on behalf of the White

5 House that you can remember whether about this or any other aspect of that event?

6 A Oh man, that.

7 Q On behalf of the White House.

8 A Well, you said White House, and I haven't said White House at all.

9 Q On behalf -- replaying what the President's plans were.

10 A There was a lot of chatter and in these situations, sometimes you'll hear

11 something third party and it is credible and sometimes not. And, you know, as a

12 professional in this space, somebody -- what I will say is unique about Donald J. Trump to

13 politics is everyone thinks they are his adviser, that everyone thinks they know exactly

14 what he's saying. It has been very widely reported that -- that, you know, the last thing

15 said in his ear is the thing he'll do. And, so, if I gave you a specific answer, it wouldn't be

16 doing you justice or me justice. My main point of contact with what I'm calling Trump

17 world was Caroline Wren regarding what I consider the scope of the committee, and

18 that's January 6th.

19 Mr. Kamenar. That's all.

20 Mr- I would like to note for the record that Mr. Kinzinger has left and

21 that Mr. Schiff has joined the deposition.

22 BY

23 Q So going back to January 5th, when you are thinking about the plans, after

24 leaving the Ellipse, where were the attendees supposed to go on the Capitol complex

25 Grounds?
 23

1 A Nowhere, anywhere and everywhere. And I would say, you know,

2 supposed to -- these are adults, and there are, I think, a dozen events happening in D.C.

3 The only reason I'm aware of this again is because a lot of people and a lot of chatter are

4 talking to me. There's Lot 8 this, that's my event obviously. There's Lot 9. And the

5 U.S. Capitol Police represented to my consultant that there was an event at 9, 10, at 11,

6 and then I heard something was adjacent like a medical freedom rally or whatever. And

7 so, could all of the attendees, were they supposed to go anywhere? No. Did we want

8 some attendees to attend Lot 8? Absolutely. But it was our understanding that

9 obviously all of those people could not fit on Lot 8. Lot 8 has a -- we are in a 3-D world.

10 Q Let's go to your event on Lot 8 at the Capitol Grounds. Who was supposed

11 to speak at your event on Lot 8?

12 A Well, I think for the purpose of this deposition, we should clarify just to do

13 the record justice that it wasn't an event, that it was a planned event, that it was an event

14 that was supposed to happen. It is an event that was prevented from happening.

15 When you get a permit from the U.S. Capitol Police, they say that they will provide you

16 barricades and protection. We got neither one of those. And that's the not the fault

17 of U.S. Capitol Police, but we weren't provided either one of those. Okay.

18 So there was no way our event was going to be able to take place. And then,

19 obviously, there's everything else that was happening. So, but who did I plan to, you

20 know, speak at the Lot 8 event? Some of those people were at the website that you

21 guys infamously have. And others of those had expired because the event moved. So

22 the original Lot 8 event was scheduled for like 7 -- not 7, 9 a.m. or something like that.

23 And when the Ellipse event emerged, we moved that event to whenever Trump

24 would be done speaking. And the best guess we could have was 1 o'clock, because

25 that's when Congress was, you know, constitutionally ordered to gavel in in their joint
 24

1 session.

2 So I couldn't -- I can't recall all the speakers. I'm trying to be -- you know, I'm

3 trying to provide the record and y'all, the committee, with as much an information as I

4 can. Obviously, the Members of Congress were no longer going to be able to speak,

5 because they were in session. But the original plan was that they would be able to

6 speak if there was no Ellipse event.

7 Q So what Members of Congress were originally supposed to speak at your

8 event?

9 A I can say with certainty one name, and that's, you know, Representative Paul

10 Gosar was going to speak if the event was happening at 9 a.m. or whenever, whenever I

11 said it was starting. And what happens is that a variety of people, like, for example, you

12 know, there's a Pennsylvania radio show host Rose Tennent who is very close friends with

13 Representative Mike Kelly. And so, what I would say is I didn't talk to Representative

14 Mike Kelly, and I didn't talk to his staff. And I didn't get a confirmation. And I didn't

15 even know that he's on the website. And I probably shouldn't be volunteering

16 information.

17 But what I am saying is that I try my best to represent things that are true. And

18 things get updated or moved and that's been butchered in the press. I actually think

19 that this committee, you know, obviously is going to understand a truer version of events

20 than has ever been reported, and that's unfortunate, because a lot of people are taking

21 even deepfakes, or photoshops, or real images online and saying this didn't happen or

22 this, this. And it is like, well, things were moving all the way up until the morning of

23 January 6th when my speech is canceled.

24 So, you know, Dr. Paul Gosar was certainly scheduled to originally speak, but no

25 Member of Congress was going to be able to speak because they were in joint session
 25

1 afterwards. And so different Stop the Steal organizers confirmed different Members of

2 Congress. And if someone made a representation to me that someone was going to

3 speak then, you know, I definitely authorized that we could post them on the website.

4 Q So going back to Mr. Gosar -- and by the way, I need to note for the record

5 that Mr. Kinzinger has rejoined the deposition.

6 So going back to Mr. Gosar, who did you coordinate with to have him originally

7 speak at your event? I understand the plans charged, but who did you coordinate to

8 have him there when you were planning the event?

9 A That was probably his -- could you repeat the question?

10 Q Who did you coordinate with when you originally were planning the event at

11 the Capitol Grounds to have Mr. Gosar speak?

12 A I believe I was coordinating with his chief of staff. It's possible -- I know

13 that I met one or two other staffers in Arizona, but obviously, you know, as is

14 constitutionally permitted, Dr. Paul Gosar and I share political beliefs about election

15 irregularities. And he had been a friend to the movement and, you know, he is a stellar

16 dude, and so, yeah.

17 Q So when you say Mr. Gosa r's chief of staff, are you referring to Mr. Thomas

18 Van Flein?

19 A Yes. And my answer was conditioned on a couple of other things, but yeah.

20 Q Did you ever speak to Mr. Gosar directly about your plans to have him speak

21 on January 6th?

22 A I don't recall.

23 Q And just to be clear, there were no other members of Congress that you

24 were communicating with about speaking on January 6th, only Mr. Gosa r's staff?

25 A I don't believe that's what I said. I said who I could tell you with 100
 26

1 percent certainty was Representative Gosar. And that there was a coalition effort to

2 recruit several members and get them confirmed for the original Lot 8 event which was

3 supposed to take place in the morning there was no Ellipse rally.

4 Q So with 100 percent certainty you only recall reaching out to Mr. Gosa r's

5 staff for the January 6th event?

6 A That's the only specific name I can recall right now. Yeah.

7 Q Thank you.

8 So let's stay on January 5th --

9 A Can I insert something in the record to help?

10 Q No, I will keep asking the questions.

11 Oh, also, did you ever talk to Mr. Anthony Foti, F-o-t-i, from Mr. Gosa r's staff?

12 A That name doesn't ring a bell.

13 Q So let's stay on January 5th. Did you speak to Ms. Guilfoyle, Ms. Kimberly

14 Guilfoyle on January 5th?

15 A Yes.

16 Q All right. When did you talk to her, approximately? Was it afternoon,

17 morning, evening?

18 A I believe it was the evening.

19 Q And how did you talk to her, was it in person, was it over the phone?

20 A Phone.

21 Q And what did you discuss with Ms. Guilfoyle on January 5th?

22 A On January 5th, it was a surprise phone call. It wasn't one I requested, it

23 wasn't planned. And I remember being thanked for making voting rights and election

24 integrity key issues for the Republican Party. I remember back and forth about the

25 Georgia election. And I'm pressing my memory right now -- it really was a thank-you
 27

1 call. And that -- I believe it was mainly a thank-you call.

2 Q Did she call you?

3 A I received the phone call.

4 Q And it was Ms. Gui --

5 A I believe, I believe, I believe.

6 Q Fair enough. And it was Ms. Guilfoyle, it wasn't Ms. Caroline Wren,

7 correct?

8 A It was on Caroline Wren's number.

9 Q Okay. So Ms. Kimberly Guilfoyle called you on January 5th, and the phone

10 call came through with Ms. Caroline Wren -- with Caroline Wren's phone number?

11 A Yeah -- so, so to be deadly accurate -- is so Caroline, or Kimberly, called me

12 from Caroline's phone. The representation is my phone says Caroline Wren.

13 Q Okay.

14 A And I answer it. And I can't remember if Caroline, you know, says, here's

15 Kimberly, or if it just was Kimberly.

16 Q Fair enough. And you all didn't discuss anything, any plans for January 6th

17 during this phone call?

18 A I've provided the committee to -- with my best recollection of that brief

19 phone call. It was a thank you call.

20 BY
21 Q Do you know where they were at the time, Mr. Alexander?

22 A I don't recall knowing where they were at the time.

23 Q Have you ever spoken to Ms. Guilfoyle before that day?

24 A If I did, it had been in passing.

25 Q Did she give you any sense of what the President's mind set was going into
 28

1 January 6th?

2 A Everything that I recalled about that thank-you call, the thank-you call that

3 she gave me, I've provided to you.

4 M r . - Do any of the members have any follow-up questions for

5 Mr. Alexander.

6 Mr. Kinzinger. No questions here from Kinzinger.

7 Mr. Schiff. No questions from Schiff.

8 Ms. Lofgren. None from me.

9 Mr. - Do any counsel have any follow-up questions?

10 Mr.- No.

11 BY
12 Q So we've been going about an hour now, do you want to take a comfort

13 break?

14 A Sure.

15 Q We will be on recess for 10 minutes.

16 [Recess.]
 29

2 [11:12 a.m.]

3 Mr. - A l l right. Go back on the record now.

4 The time is 11:12 a.m.

5 BY
6 Q So, Mr. Alexander, as we move on to the next sections, I do appreciate the

7 color you're providing us. If you could just answer the question first and then provide

8 the color afterwards, that would be greatly appreciated. And, again, we do appreciate

9 your answers here today. But, yeah, just help this move along a little faster.

10 So let's go to January 6th now. All right? So, we've moved on from January

11 5th. For January 6th, Mr. Alexander, you understood that on January 6th Congress

12 would certify the electoral college, making Mr. Joe Biden the country's next President,

13 correct? That's what was going to take place that day?

14 A No, that is not my understanding.

15 Q So why were you protesting on January 6th then? Why was that day

16 special?

17 A Because I understand that there was going to be an attempt that would

18 likely be successful in certifying the electoral college, but that the Constitution allows a

19 protesting of that vote so long as it has a single member from each Chamber. The

20 Democrats did this in 2017 and in 2001, and it was the first time, to my knowledge, that

21 we Republicans were going to attempt the same thing.

22 And I had supported Senator Ted Cruz's proposal that we take 5 or 10 days to

23 review the process, but I support Congress making a decision. But to say that it

24 was -- that it -- that it was constitutionally required to go through on that day, that's not

25 what the Constitution says.

 30

1 Mr. I'd also like you to know that Mr. Aguilar has joined the

2 deposition.

3 B

4 Q So going back to what you said, if the certification of the electoral college

5 was successful, Mr. Joe Biden would be sworn in as the next President. Is that correct?

6 A No, that's not correct. And I'm -- I'm not a lawyer, but I've read the

7 Constitution. And -- but that's not -- that's not a correct reading of the Constitution.

8 Q So we start on the morning of January 6th, right? And you tweet, "First

9 official day of the rebellion." And this is exhibit 11, if you want to turn to that in your

10 binder. What did you mean by this tweet?

11 A This graphic on page 11, I'm going to have to add some color here. This

12 graphic on page 11 looks like a screenshot. I can't authenticate it because I don't have a

13 Twitter account, and it looks like y'all did not retrieve this from Twitter. So you

14 retrieved it from, you know, wherever.

15 What -- if I sent this at 3:13 a.m., so before I was going to sleep on the 6th, then,

16 you know, it's color. I'm a political personality. It's legally permissible speech. And it

17 certainly, you know, would not be illegal activity that I would publicly be tweeting about

18 prior to legally permitted events.

19 Q No one's saying that it's illegal. I just want to understand what you meant

20 by it.

21 A Yeah, and I wish what I understood. But what I understand today is that

22 that is a colorful language that you find on MSNBC or Fox News.

23 Q Do you recall tweeting, "First official day of the rebellion," on January 6th?

24 A No, I don't specifically. But this is believable.

25 Q Do you recall on January 5th at a rally leading chants of "victory or death"?

 31

1 A This is a quote from a very famous political document called the Travis

2 Letter. And I was quoting Alex Jones, quoting it because a lot of his audience was there

3 the night of the 5th. I love history, and I'm a Texan. This is a very famous Texas

4 political history moment at the Alamo.

5 America's full of quotes like this that emphasize one's values, that one values

6 liberty more than having longevity as life as a slave. This is the history of Americans and

7 American descendents of slaves, my ancestors. This echoes the Gadsden flag, quote,

8 "Join Or Die," "Give me liberty or give me death," by Patrick Henry, the Magna Carta,

9 Harriet Tubman's own words, Malcolm X, Martin Luther King, our Founding Fathers and

10 Mothers. And it was said in this context. The Travis Letter is out of the Alamo. No

11 one was talking about winning or overthrowing the Mexican Government, which is where

12 this quote comes from. They just refuse to be prisoners.

13 I don't believe in unjustified violence. I went out of my way to talk about that or

14 being an aggressor. I never believe in being the aggressor. No one was talking about a

15 violent overthrow of the United States Government that night or day. Again, this quote

16 is just a popular quote on Alex Jones' lnfowars show. His audience made up, I think,

17 about a third of our rallies -- I talked about this internally -- and would often use quotes

18 from popular personalities.

19 So this was Alex -- this was me quoting Alex Jones, quoting the Travis Letter from

20 1836. No one went there was committed to violence, or we wouldn't have had permits.

21 Q So let's go back to exhibit 26, page 270. You've already briefly discussed

22 Mr. Thomas Van Flein, who we've established is -- was Mr. Gosa r's chief of staff. And I'll

23 give you a second to get to the page.

24 A Thank you. You say this was --

25 Q Page 270.
 32

1 Mr. Kamenar. Can you find it?

2 Mr. McBride. Yes.

3 Mr. Kamenar. There it is.

4 Mr. McBride. The last page.

5 Mr. Alexander. Oh, it's literally the last page. I'm sorry.

6 BY

7 Q I'll direct you to, like, the top half of the page. And you're talking to

8 Mr. Thomas Van Flein. It looks like at 5:44, you are asking: "I'm hearing there's a

9 signing of the document or whatever."

10 What petition or document are you referring to here? And I'll give you a chance

11 to read through it, but I just want to understand. What document is this?

12 A Okay. Hold on. I don't know. I honestly don't know. I mean, I wish

13 there was more context here. The objections are getting signed. Signature instead of

14 autopen. So certainly nothing on my end.

15 Q You were asking about it. That's why we were trying to figure out what

16 document it was. But you do not recall?

17 A I do not recall. I don't recall.

18 Q Okay. On the same page, it looks like at 5:48, you asked Mr. Van Flein, "If

19 We can send an email to the entire House Freedom Caucus, that they all need to be at

20 The Ellipse. POTUS wants force."

21 How did you come to this understanding that POTUS wants force?

22 A Well, in reading this and knowing that this is a message that I would send,

23 when you're talking about -- when you're talking about, whether it's sports or events,

24 you're talking about coming out in full force. You're talking about participation. You're

25 not talking about violence, and you're not talking about Star Wars.
 33

1 But -- so, I think what I was attempting to do here was to get a chief of staff of a

2 member to talk to other staff in getting their physical presence to the morning rally prior

3 to, again, a joint session that was supposed to start at, you know, 1:00 or whatever the

4 Constitution provides.

5 Q Okay. So I'm more interested, though, in the actual POTUS wants force.

6 How did you know that President Trump wanted force?

7 A Well, I'd appreciate my words being repeated back to me with the context

8 that I just gave them which is, you know, participation. So out in full force, you know,

9 this is POTUS wants force. You know, you don't call the members of Congress to come

10 out in forceful violence. That would be silly. Okay?

11 So if you're -- if the question is actually, you know, how did I come to the

12 understanding that the President wants as many Republican Members of Congress to

13 watch the rally that he was going to speak at, I couldn't tell you. But it seems obvious in

14 repeating it back to you.

15 Mr. For the record, Ms. Cheney, the vice chair has joined this

16 deposition.

17 BY

18 Q So just to be clear, you didn't hear specifically from anyone on the campaign

19 or the White House that President Trump wanted force from the House Freedom Caucus?

20 A Well, again, I just want to reiterate for the third time that force means

21 coming out in full force. It's a common term used in events, in organizing, in sports, in

22 all kinds of things -- I say this with complete conviction -- and that you don't call Members

23 of Congress to come and watch a bunch of speeches and intend, you know, anything, you

24 know, anything crazy, you know.

25 And so, I don't know how I came to this. If the committee could provide other
 34

1 text message that preceded this that talk about the same thing, then I'm happy to review

2 those and then try to contextualize it. But I think, again, it's very obvious that the House

3 Freedom Caucus was, like, the conservative wing of the conservative wing. And having

4 them all at The Ellipse rally to hear the speakers that preceded the President was

5 important to all of us. And I think it's, you know, the logical course of action.

6 Q Yeah, so it's interesting because you're focusing on the word "force." I'm

7 focusing on "POTUS wants." Help me understand that part. How do you know what

8 POTUS wants?

9 A I'm sorry.

10 Q How do you know what POTUS wants?

11 A Because he tweeted as much.

12 Q Got it. Thank you.

13 So you went over this a little bit earlier. But so after you left the hotel, by the

14 way, where were you staying when you were here for the January 6th event? What

15 hotel were you staying at?

16 A I believe I was staying at the JW.

17 Q Okay. So walk us through the morning. How did you get to The Ellipse?

18 What time did you leave? What time did you arrive? Just walk us through that.

19 A I don't know the times. The times would be better represented by the text

20 message.

21 Q Approximately. Or just give us a lay of how your morning went.

22 A I really wish I could. That seems overly broad. You just showed me a text

23 message, or you just showed me an alleged tweet that I sent at 3-something a.m.

24 didn't even have an awareness until now, again, if the tweet is real, that -- that I went to

25 bed after that time. It seems like I needed more sleep than that. So, so if I
 35

1 sought -- the question just seems way too broad. And I'm happy to drill down on any of

2 the specifics around the events that you guys are investigating.

3 Q Let's walk through it then. So you stayed at the JW Marriott here in

4 Washington, D.C. Is that correct?

5 A Yes, sir.

6 Q You went to The Ellipse the morning of January 6th?

7 A Yes, sir.

8 Q Did you go anywhere between -- in between going from the JW Marriott to

9 The Ellipse?

10 A I don't believe so.

11 Q Okay. So when you arrived at The Ellipse, did anyone let you in? How did

12 you get into the Ellipse?

13 A I provided for the committee maybe 15 or 20 minutes ago my best

14 recollection of how I entered and what was happening at the VIP section, and I'd refer to

15 that.

16 Q Did Ms. Wren escort you in, or were you able to still walk through the

17 security?

18 A I do not remember Ms. Wren letting me in. And, again, in my retelling of

19 my best recollection of the story, I had to actually retrieve our badges using my

20 reputation alone. And then I believe I saw Caroline ultimately, you know, 20 or 30

21 minutes later, after we made it through Secret Service, metal detectors, through the

22 swampy mud fields and then up to the VIP-seated section.

23 Q Okay. Did you have a security detail with you on January 6th?

24 A Yes.

25 Q Do you recall who was part of your security detail?

 36

1 A Not specifically, but generally, it would have probably been multiple layers.

2 I do know that the Oath Keepers provided me two gentlemen, and I do not recall their

3 name. And I don't even know if those two gentlemen were assigned to me or my overall

4 party. But I had multiple layers of security, and those were volunteers really.

5 I had a paid security, a gentleman, a security gentleman named Patrick. And I

6 don't know his last name, but he's an African immigrant. And -- but, again, you know, I

7 probably assigned him to somebody else. In these type of situations, you know, you

8 welcome help from police officers and veterans and great Americans like that, first

9 responders. But sometimes you also get paid security, too. So --

10 ~ Can I jump in for one second?

11 ~ Please.

12 BY-:

13 Q A moment ago you said that some of your volunteer security detail was

14 volunteers. Is that you saying that you did not pay those individuals, that they worked

15 for free?

16 A I don't recall ever paying the Oath Keepers. And I don't recall that being a

17 part of any of their arrangement of how they, like, volunteered their services for security.

18 Now I don't know if we provided them, like, hotel rooms or food or water or anything like

19 that. But, you know, I've never written a check to the Oath Keepers to the best of my

20 knowledge.

21 Q Who would know if you provided them with hotel, water, or food or any of

22 the things you just listed?

23 A I wouldn't know. We -- everybody was -- everybody was volunteering.

24 Everybody was doing the best that they can. If these text messages represent

25 something, then I can work to verify that but.

 37

1 Q No, no. I'm just saying a moment ago when you said, "I don't know if we

2 would have provided," who was the "we"?

3 A We being Stop the Steal.

4 Q Okay. And you said you paid an individual named Patrick for security.

5 A Uh-huh.

6 Q Do you remember Patrick's last name?

7 A No, I don't.

8 Q Do you know how you paid him?

9 A No, I don't.

10 Q Do you know who would have known how he got paid?

11 A Unfortunately, no, I don't. You know, I have -- I was -- I was very -- I don't

12 want to say I was never alone. But to the best of my recollection, I didn't have a

13 moment to be alone. And, so, I delegate tasks to people based off availability or

14 expertise or a combination of both.

15 It's very likely, you know, he's a -- he's, again, I believe he's an African immigrant,

16 you know, specializes in security. And he's, you know, strong and doesn't talk too much.

17 So, you know, I could see -- I could see, you know -- I just wouldn't know.

18 Q Well, what I'm trying to figure out is it sounds like you or your

19

20

21
-
organization -- and I'm sorry. I didn't realize you

-
It sounds like you or your organization paid for a security detail, and I'm trying to

22 figure out who would have been responsible for coordinating the payment of that?

23 A Yeah, and I just told you I -- there are so many people in my nexus, both

24 physically and assigned tasks, that -- that, you know, it -- I wouldn't know any specific

25 person.
 38

1 BY
2 Q And we'll get back to security a little later.

3 So I want to keep moving through the day for January 6th. And I want to direct

4 you back to exhibit 26 again, and we're going to be referring to exhibit 26 throughout

5 today, specifically page 241. It's near the back, and I'll just read it out loud as you go

6 there.

7 But at 10:02, Mr. Roger Stone texted you, "As I expected, no speaking spot. No

8 VIP entrance for any of my people."

9 And you replied, "I understand the funder of today's event is not happy. I never

10 thought it was real. Time to sue."

11 So as you read through it, I just -- can you help me understand what role

12 Mr. Stone might have played in planning the events on January 6th?

13 A Roger's not a planner. He's a speaker.

14 Q Okay.

15 A He's -- I don't even know how old he is, but I think above 70.

16 Q Okay. Were you responsible for coordinating him as a speaker on

17 January 6th?

18 A He had an aide coordinating all of his activities.

19 Q What organization was responsible for coordinating Mr. Roger Stone as a

20 potential speaker? Was it Stop the Steal? Women for America First? The White

21 House?

22 A I couldn't tell you. He's -- he's a personality unto himself. And, like I said,

23 he's internally booked. So he handles that within his own, you know, nexus.

24 - Who was the aide you were referring to?

25 Mr. Alexander. Her name, I believe her name is Kristen. I've only met her once,
 39

1 and I couldn't even tell you her last name.

2 B

3 Q In this text you also say, "The funder is not happy." Who's the funder?

4 A I think you're mistaken. I didn't say that.

5 Q Okay. Who was your understanding of who the funder was for

6 January 6th?

7 A I don't know that there was a singular funder of January 6th because I didn't

8 deal with any of that, any of the funding for The Ellipse, you know, not like staging

9 equipment or anything like that. And, you know, contemporaneously I don't know.

10 But, you know, reporting, public reporting now, you know, points to a Florida-based

11 woman. And that could have been who he was referring to.

12 Q And when you say, or when it said "time to sue," who are we talking about

13 suing there?

14 A Probably Women for America First.

15 Q And what was going to be the basis of suing Women for America First?

16 A That we had folded our Lot 8 morning event into The Ellipse. And there

17 was all this pretense that, you know, Roger Stone is the gentleman who came up with the

18 phrase Stop the Steal. I have, you know, this gentleman's agreement with him that I

19 have a perpetual use of the license. And -- and they got up there and lied to the crowd

20 and lied to the Nation and that we were deprived of participating in our other separate

21 event so that they could fold us into this. It seemed like a claim to me that I wanted

22 lawyers to look at.

23 Q When you say "fold us," who is "us"?

24 A The whole One Nation Under God Coalition that Stop the Steal was a part of.

25 Q Who's in charge of the One Nation Under God Coalition?

 40

1 A Like many political functions and groups, you know, in this business, it's an

2 impromptu coalition based off of a need. And you see this a lot around like the

3 ObamaCare issue. Or, you know, on the left and on the right you'll -- you know, we've

4 had impromptu coalitions around, like, the estate tax, the death tax we call it.

5 So One Nation Under God is, like I said, Stop the Steal paid for all the staging and

6 equipment. But because it wasn't exclusively political, and it was also religious and we

7 were doing prayers and the blowing of the shofar and it was a very Judea-Christian event,

8 and that that was going to be the real focus. I even talked about changing hearts and

9 minds.

10 So we were seeking a political legislative remedy from the outside. It was very

11 spiritual thing, and so we had to call it One Nation Under God because there's a bunch of

12 Christian groups that didn't fit into Stop the Steal. Some Christian groups did, but not all

13 did. Some Jewish groups didn't fit in there, and we wanted their participation.

14 Q While you were at The Ellipse, did have you any interactions with Secret

15 Service?

16 Mr. Beyond the magnetometer-type stuff.

17 Mr. Alexander. Could -- could we specify what interactions mean?

18 BY

19 Q Did you talk, communicate with any Secret Service agents after getting into

20 the magnetometer?

21 A Communicate. Verbally, I don't know.

22 Q You don't recall?

23 A I don't recall, you know, verbally communicating the way you're defining it

24 to the Secret Service.

25 Q And, correct me if I'm wrong, but did your personal security detail go with
 41

1 you to The Ellipse?

2 A I don't believe so, to the best of my recollection --

3 Q Okay.

4 A -- because, you know, as Secret Service was letting myself and Mr. Alex Jones

5 out, we couldn't take everybody. And so, I think I sacrificed my security so that I could

6 use his security.

7 Q Okay.

8 A And -- and we were really close to not even being allowed to take his

9 security. So I -- that's why I say I don't think so. But that's to the best of my

10 recollection. But it would be -- I would be hard pressed to say yeah, my -- you know,

11 they were added to this train of people that Secret Service allowed through a special exit.

12 Q Did you receive any pins of any nature from Secret Service?

13 A No.

14 Q Okay.

15 BY
16 Q Just it so's clear, you were talking about exiting the event with your security?

17 A Exiting The Ellipse --

18 Q 1know.

19 A -- while the President was speaking.

20 Q I hear you.

21 Did you bring your security into the event with you to the event?

22 A I believe so. They -- I believe so. Like I said, I usually have, like, different

23 layers of, like -- I won't call them aides -- like helpers and security and I know I would have

24 had to take some security with me in a golf cart to The Ellipse and they would have

25 entered with me. But because I was running errands in and out, or I was shoving people
 42

1 to go into the Ellipse event while I handled drama, you know, at the VIP ticket table, you

2 know, I couldn't nail it down, but it's likely.

3 BY

4 Q Do you recall any of your security having any issues getting into the event

5 through security?

6 A My security?

7 Q Uh-huh.

8 A A lot of people --

9 Q I mean yes.

10 A A lot of people had a lot of people had a lot of issues, and I worked to

11 resolve some of those issues. But my security? None that -- anybody who arrived with

12 me got in.

13 Mr. Alexander. Okay. Before I move on to the next part of the day, do any of

14 the members have any follow-up questions? Seeing no response from the members,

15 did any counsel --

16 Ms. Lofgren. I don't.

17 M r . - Oh, sorry. Ms. Lofgren?

18 I just wanted to say I don't.

19 Mr. Okay. Thank you, Ms. Lofgren.

20 Do any counsel have any follow-up questions?

21 Mr. - Just to be clear, Mr. Alexander, did anybody else accompany you to

22 The Ellipse when you came over from the hotel that you remember, security aside?

23 Mr. Alexander. I don't know who all I took with me. I know that we had, like I

24 said, a golf cart.

25 Mr. Sure.
 43

1 Mr. Alexander. And -- and, you know, I just always -- I always had, you know,

2 rotating different helpers or aides with me. And so, you know, I couldn't -- if I

3 speculated on a name, it would be just pure speculation.

4 BY

5 Q So earlier you mentioned that when the President speaks, it's on, like, their

6 own schedule. I'm paraphrasing. Like you can't control when the President speaks.

7 Is that -- am I capturing that properly?

8 A Yes. Or when he stops.

9 Q Right. So did you leave The Ellipse before President Trump had finished

10 speaking?

11 A Yes. And that's, you know, been widely captured by media and attested to

12 by myself.

13 Q And why did you leave before President Trump finished his speech?

14 A We left The Ellipse early because we were requested to by Ms. Wren and her

15 aide -- and/or her aide. And it was a whole process that we were aware could happen,

16 and so it was happening. And I don't know if the process took 5 minutes or 15 minutes,

17 because there's a lot of back and forth. The President's speaking. I'm sitting. We got

18 200 media behind us. How do you get up while the President's talking in a discreet

19 way? And the answer is you can't.

20 And, so, we were requested that, because people were leaving the overflow, that

21 there probably should be some leadership toward the Capitol, and that Alex Jones and

22 myself should be the people to help to, you know, lead that overflow crowd that was just

23 starting to leave.

24 Q And this was communicated to you from Ms. Wren?

25 A Or her aide.
 44

1 Q Or her aide. Okay.

2 And do you know who Ms. Wren or her aide was receiving this request from?

3 A No, not specifically, no.

4 Q Did Ms. Wren escort you out of The Ellipse?

5 A She was part of -- she was a part of -- she was a part of the people who

6 walked me and Alex Jones and whoever else we had with us out a special entrance, yeah,

7 exit.

8 Q And when you left the special exit, where were you heading?

9 A Well, we needed to regroup. So we actually stopped for 5 minutes to

10 regroup.

11 Q Where did you stop?

12 A We stopped right outside where we were let out at the fence. And then

13 we -- we -- I think, some of Alex's cameramen met us, you know. So they had ran out

14 the exit and ran around and met us, or something like that. And they were there to film

15 us, and I'm actually very grateful that all of my actions were filmed so that my attention

16 to nonviolence and to actually participate in deescalation was chronicled.

17 But we ended up stopping again at the Freedom Plaza type of area, and Alex gave

18 an impromptu speech. And the goal of this was to have people, you know, what they

19 call in media a B-roll shot, you know, walking behind him. And so -- and I was using his

20 security. So there I am, you know, stuck in the security bubble.

21 Q Just going back really quickly, do you know who Ms. Wren's aide was?

22 A I don't recall her name. She was a very nice person.

23 Q Okay. So it was a woman. That's what you recall?

24 A Yes.

25 Q Okay. And you said that Mr. Jones stopped and gave an impromptu
 45

1 speech. Where was the speech given?

2 A At Freedom Plaza, at the corner of, you know, what we refer to as Freedom

3 Plaza.

4 BY

5 Q Did the Secret Service ever tell you before you left The Ellipse anything

6 about you walking to the Capitol?

7 A I've already testified that I don't recall any verbal communications with the

8 Secret Service.

9 Q With yourself. Did you hear them tell anyone else you were with or

10 communicate with them, like Mr. Jones, about the march to the Capitol?

11 A Well, walked over to the Capitol. Did I overhear Secret Service talking?

12 No. I mean, they're professionals. I don't hear their conversations.

13 Q You just used the word "walked" to the Capitol instead of "march." Is there

14 a difference between those two words in your mind?

15 A I think I -- you know, sometimes there is and sometimes there isn't. And

16 I'm not assuming anything in what you're saying, but I definitely want to clarify what I

17 intend. And, so, in the event space there can be. But in the colloquial space, no, there

18 is no difference.

19 Q Okay. And on the website that your organization put up, it said, "March to

20 the Capitol after The Ellipse event," right?

21 A Yeah.

22 Q Okay. Yeah is yes?

23 A I think so.

24 Q Yes. And so to your knowledge, based on what you observed on

25 January 6th at The Ellipse, did you ever see Secret Service communicate with anyone in
 46

1 your group about your movement from The Ellipse to the Capitol?

2 A Secret Service escorted us out. And so, you know, you know, I don't want

3 to get in word games. But, you know, there was, you know, there was a decision made.

4 It had to go this way. The reason why I said I don't know why whether it took 5 minutes

5 or 15 minutes for Alex Jones and myself to decide when to leave is because what I was

6 told was happening is we were basically negotiating how many people could exit, you

7 know, with Secret Service. And so, you know, that conversation was handled on the

8 Trump world side.

9 Q So that's about the logistics of exiting The Ellipse?

10 A Yes.

11 Q Okay. Did you understand there to be any communication to you about

12 the President's intention after he was done with his speech coming from either the

13 President or Secret Service?

14 A The --

15 Q The President.

16 A The President's intention?

17 Q Correct. About whether to walk to the Capitol at that time.

18 A You'd have -- you'd have to ask him.

19 Q So did you know anything at that time about whether he would be coming

20 with you or coming up to the Capitol later?

21 A I'm not privy to any of the internal conversations that Trump had with Secret

22 Service.

23 BY

24 Q This is actually a perfect segue. Can you go to page 170 on exhibit 26?

25 And it's page 170. And this goes to point about whether President Trump
 47

1 was going to march to the Capitol.

2 At 12:19 p.m. you ask Ms. Wren -- so I'm assuming this is after you've left The

3 Ellipse -- if POTUS is walking and for her to give you an update every 5 minutes. So at

4 12:19 p.m. on January 6th, was it your understanding that President Trump was going to

5 come to the Capitol?

6 A One, I really appreciate you pointing out this text. This is helpful. It's also

7 helpful that I use the word "walking," and you characterized it as marching before you

8 read out the quote.

9 And my understanding is informed by a lot of things, you know, my race, my faith,

10 my profession. And professionally, I'm sorry to bore you guys, but professionally, in my

11 interactions with observing Secret Service over the years, observing Democrat nominees

12 and Republican nominees and Presidents is, something like that's just not allowed to

13 happen.

14 But I do know that we live in interesting times. And if it were to happen, I would

15 like an advance notice. And, again, I'm sorry. I saw the faces, but I'm sorry if my

16 answer is weird. Trying to be helpful.

17 Q So based upon this text, you were asking Ms. Wren, because you presume

18 she would know if President Trump was going to walk to the Capitol?

19 A She was physically at The Ellipse, and I wasn't.

20 Q All right. So when you left Freedom Plaza, did you start heading straight

21 toward the Capitol complex?

22 A Can I note for the record? Just -- well, no I'm sorry. What was your

23 question?

24 Q When you left Freedom Plaza with Mr. Jones, did you start heading towards

25 the Capitol complex?

 48

1 A We started heading towards Lot 8 where we had a legally permitted event,

2 that direction.

3 Q Before arriving at Lot 8 on the Capitol complex, were you aware that

4 individuals had begun to breach the Capitol?

5 A What's the origin?

6 Q I'm asking. So as you're walking towards the Capitol complex, were you

7 aware while you're walking that individuals had started to breach the Capitol grounds?

8 A These terms are very specific, and I take this issue very seriously. So I

9 wasn't aware that anyone, and I'm still not aware, that anyone breached the Capitol at

10 that time. I was aware that there was chaos, confusion, and mayhem that I did not like,

11 did not approve of, and that we started in a sprint until Mr. Jones could not keep up and

12 to try to deescalate the situation which is represented by these text message.

13 Q Approximately how many people were with you as you were walking to the

14 Capitol?

15 A You know, I don't know. I was concerned about my persons. I was

16 concerned about getting there to deescalate. First we were getting news updates.

17 Arizona, Mike Pence this, it was all political. And then first time I see, you know, a

18 struggle between a law enforcement officer and an individual, I was like, okay, I need to

19 get there as a human and stop whatever's happening because this is stupid. And so -- so

20 that's my understanding.

21 Q So is it fair to say that there was a large crowd of people around you all as

22 you and Mr. Jones were going to the Capitol?

23 A If you could be specific.

24 Q Just give me an order of magnitude. Give me an order of magnitude.

25 Was it 100 people? Was it 200 people? Was it two people? How many folks were
 49

1 around you as you were walking to the Capitol?

2 A I'm not sure, but that's probably captured better on video than any verbal

3 testimony I could give here today.

4 Q And you were saying that you were trying to get to the Capitol complex to

5 deescalate. Can you help me understand that assertion with the fact that you were

6 walking to the Capitol, chanting things such as "Stop the Steal"? So help me

7 understand. Like you're getting to deescalate, yet you're leading the crowd in a chant of

8 "Stop the Steal."

9 A Stop the Steal is a legally permitted, First Amendment chant in the same way

10 that Black Lives Matter is, in the same way that so many other political issues are.

11 And I just want to say I kind of -- I kind of resent, kind of offended by the, you

12 know, the implication that you can't yell, "Stop the Steal." This was a movement that

13 had 500 events, and all were peaceful. And yelling, "Stop the Steal," is about election

14 integrity. And yelling, "Stop the Steal," even when we did the Jericho March with the

15 Christians, before a broader, you know, theft in a spiritual sense. And you'll see her

16 12:56, I said we are deescalating. Before this, I talked about deescalating.

17 So my -- so by chanting political phrases, we are gathering people to us. It is a

18 tool of rhetoric and of speakers to use to get attention so that we can then move people

19 where they belong.

20 Q So once you arrive at the Capitol complex, what did you observe?

21 A If you could be specific, it seems overbroad to me.

22 Q Once you get to the Capitol, what do you see?

23 A I see people.

24 Q What are those people doing?

25 A Some people are filming. Some people are walking. You know,
 50

1 there's -- there's -- the crowd gets dense. And, again, I can't see the conflict, but I

2 already known about it minutes prior, whatever, from Twitter or a text message.

3 Q So when you got to the Capitol, did you see any of this conflict that you just

4 mentioned? Did you see it --

5 A No, I actually just said I didn't see it because the crowd was so dense toward

6 the fronts.

7 Q Got it.

8 A But they were in a spot they shouldn't have been in. I saw no barricades.

9 I saw no police officers. And I were like -- and I was, like, what the hell are people doing

10 on the inauguration side? We hadn't been there in December. We hadn't been there

11 in November. Stop the Steal had never been on the inauguration side. So who

12 directed these people? Who pushed these people here? Who let these people in?

13 Where were the barricades? Those were the first questions that popped in my head

14 when I'm observing this dense situation in the context of a text message that I received

15 about conflict.

16 Q So going back to exhibit 26 on page 170, you there? I just want to make

17 sure you're there.

18 A Yes, sir.

19 Q Ms. Wren says to you, "I think you should leave. This will come down on

20 you hard." Help us understand why this would come down on you hard.

21 A I was the guy who started Stop the Steal as a protest movement, which is

22 separate from people chanting it, which is separate than the origin of the phrase. So I

23 led an organization, and she -- it looks like out of concern that the media would

24 characterize what happened there prior to me getting there as my fault and other

25 activists' fault. But I, you know, because this is a text message from one person to
 51

1 another, I think she's talking about, like, it's going to be blamed on Trump. It's going to

2 be blamed on everybody. I'm concerned about you. You know, you should leave.

3 This looks like it's escalating.

4 And I really want to point this out for the record. This is extremely important.

5 I'm on the ground. Most of the time my cell phone signal is jammed. I am less aware

6 of the events that are going on than people who are watching TV and getting detailed

7 views of what's going on.

 52

2 BY
3 Q Staying on exhibit 26, if we could go to page 242 -- and we're just trying to

4 get a better understanding of the events on that day by using these text messages.

5 A I can appreciate that.

6 Q So page 242, you text Mr. Thomas Van Flein, who we've already established

7 is Mr. Gosa r's chief of staff. "I think you and your staff should maybe leave. This is hell

8 out here." Why did you think Mr. Gosa r's staff should leave?

9 A For the same reason that Caroline Wren thought I should leave. Well, she

10 thought I should leave for my safety, and because, you know, people would try to blame

11 me and other activists and the President. But I was very concerned, again, with these

12 text messages that I got that were either tweets or pictures of conflict. I had never seen

13 anything like that. I'd never seen anything like that. People were scaling the wall like

14 Spiderman. I've never seen anything like that. Nothing like that's ever happened at a

15 Stop the Steal rally, still to this day.

16 And so I was very concerned about my friend. I knew a lot of people in Congress.

17 I wouldn't want them hurt. So I said I think you and your staff should maybe leave.

18 Now in retrospect that's stupid because where were they going to go? But remember

19 I'm seeing one picture, one tweet. I think it's happening on one side, a side that no

20 one's authorized to be on. And I'm just, like, I'm just thinking about lives and people.

21 I'm not thinking about my event. My event's already ruined. I can't have it. I'm

22 concerned about people.

23 Q So you thought Mr. Gosar and Mr. Gosa r's staff was in danger?

24 A I thought that they could potentially be in danger at some point if this

25 escalated. I was, like, there's no way this escalates because surely police will put
 53

1 whatever's happening down or whatever. I never got close enough to see what -- so,

2 you know, these iconic pictures we see now, I didn't see any of that. But I was, like, if it

3 goes there, if that's actually happening, if people -- if what people are saying is true, then,

4 you know, people need to get the heck out of there.

5 Q So you just are describing the environment of what you were seeing on the

6 ground.

7 A As best as I can.

8 Q As you recall, and I appreciate that. I appreciate it.

9 Around this time do you recall tweeting, "#occupyDC. Remain peaceful in rally.

10 Sources are telling me we're going to try to use two hours per State."

11 A No, not around that time. In fact, that happened prior.

12 Q Okay.

13 A And so we were talking about -- we were talking about Senator Ted Cruz and

14 Congressman Paul Gosar and, like, Jody Hice and a couple of others were going to protest

15 Arizona and Georgia and some other States. And what was being communicated to me

16 was that what were the legal legislative rules for this process. Again, this actually -- this

17 actually proves that I'm participating in the legislative process, and that I don't desire

18 violence and -- but this happened prior.

19 Q Okay.

20 A You know, that type of text message would have happened prior to any of

21 this conflict stuff. And Occupy D.C., just for the record, is a reference to a popular

22 far-left, anarcho-left movement in which people set up tents in D.C. and Lafayette Park

23 and they did it in New York and stuff like that. It was legally permissible.

24 Q So when you get there on the ground, do you recall, you and Mr. Alex Jones

25 directing individuals to the other side the Capitol, to the east side the Capitol?
 54

1 A What I recall was seeing, seeing it and being shocked, saying we need to

2 deescalate this -- this is in the text messages, and it's verbally on video -- and then

3 climbing on a wet stack of metal chairs in which I could have fallen and injured myself,

4 but it was more important to get the outskirts of the crowd. These people were not on

5 the plaza, and they weren't on the building. These people were in a legally permissible

6 area where there was not an event happening.

7 And we started chanting. We started yelling. We tried all types of tools that

8 speakers use to get attention to say there's no event here. There's no event on the

9 inauguration side. And so, these people were either new to Washington, D.C., new to

10 the event, or had no idea about the Lot 8 event.

11 And my worst fears about The Ellipse event had happened. It's, like, people look

12 at the scaffolding and they think there's going to be an event here. So I was, like, Okay.

13 This is a simple mistake. Why don't we try to remedy it? Meanwhile

14 there's -- there's -- there's tear gas in the air.

15 And I'm, like, okay. We are officially exiting this. We've got as many people as

16 we can get with a megaphone. We need to move them away from the inauguration

17 side. Don't defile the inauguration side. Don't be a part of scaffolding that could fall

18 and hurt people. I was very concerned the scaffolding was going to fall and collapse on

19 people.

20 Q On exhibit 26, can you go to page 256, please? And this is going to be

21 around 2:34 at the time. There's an STS Patriots group. I'm assuming STS Patriots

22 stands for Stop the Steal Patriots.

23 A Yes, sir.

24 Q And you say in one of these group chats, "Please let me know if anyone gets

25 arrested. Civil War is," and then there's, like, a blank after that.
 55

1 A What time is this at?

2 Q 2:56 or 2:34, I mean, 2:34, page 256.

3 A Oh I'm reading here "please also have check-in times with each other. So

4 this is me telling people to make sure that they're safe. I can't possibly text everybody

5 everyone. Everyone needs to make sure that everyone's safe.

6 There was, in addition to the conflict that happened at the Capitol, which was

7 inappropriate, there were, at night, there were activists in this group called Antifa that

8 used totalitarian force to back up their ideas. And they would beat up. You know, this

9 is in all the D.C. police reports. So at our events at night, we frequently told people stay

10 inside because you're in danger. So I'm saying have check-in times with each other, and

11 then and let me know if anyone gets arrested. There should have been a period there.

12 And civil war is like near.

13 I'm very concerned that our Nation is irreparably divided. And you can see this

14 not just, like, in what I'm talking about, because I'm not advocating a civil war. I haven't

15 even advocated what's called a national divorce. You can find that in Newsweek on the

16 left. You can find people talking about it on the right. Twitter CEO Jack Dorsey has

17 tweeted an article about this. This is something a lot of intellectuals talk about, and I'm

18 very concerned.

19 When you watch what you watched at the Capitol happen, you know, I can

20 understand why Democrats say you guys are causing a Civil War. And I understand why

21 Republicans are saying you guys are causing a Civil War. All I'm concerned about is that

22 that threatens to break apart the Nation that I love and that I've worked -- I'm fighting for

23 elections, which inherently means I'm opposed to war.

24 Q Right above that, right above that text where you say civil war -- and we now

25 understand you say is near --you say --

 56

1 A I think. I think. I think.

2 Q You think. Right.

3 A Yeah.

4 Q You think. Thank you for clarifying.

5 A I think there would have been an emoji or something that --

6 Q Right.

7 A -- meant near or whatever.

8 Q Thank you for clarifying.

9 You say, "And do not text message each other. Start a Signal group." So did

10 you use Signal with the STS Patriots?

11 A I don't know that we ever started one. This was me just giving advice to

12 people, and Signal is a popular app used by politicos and government officials and

13 members of Congress that are, you know, present here, I assume. So it's kind of a

14 standard app. And I just did not think that it was good for people to willy-nilly be texting

15 each other with all of the campaign to frame people and violate our privacy rights.

16 Q I don't recall in your production. Please correct me if I'm wrong. Did we

17 get any Signal chats you from?

18 A I provided one with Charlie Kirk. They auto-disappeared. That's like a

19 data retention policy. So I don't -- in response to the committee's investigation on the

20 Capitol attack, and then as you guys widened it, in my opinion, to cover legally

21 permissible events that I wanted to cooperate with this committee about like January

22 5th, I don't recall having any in my possession from Signal. Most of what I did was

23 verbal. Some of what I did is in text message.

24 And you can -- well, you can't. But if you were to ask Google, you know, for my

25 email activity prior to Stop the Steal, it would be 10 times more, because I was just that
 57

1 busy. So I didn't really have time for, you know.

2 Q So staying in exhibit 26, can you now go to page 238? And on the bottom

3 half of the page, it appears that you're texting Ms. Kimberly Fletcher.

4 A Yeah.

5 Q So at 2:38, or as it's here 1438. Sorry. I am just translating the 24-hour

6 clock there. It looks like you say, "POTUS is not ignorant of what his words will do.

7 Wish it didn't happen, but understand the people and I won't denounce them." So

8 reading this text, is it fair to say that President Trump's words were influential to his

9 supporters?

10 A The short answer is no, because we have a wise Supreme Court that came

11 out with a case called Brandenburg v. Ohio which helped us, you know -- and I say "us" as

12 in human civilization -- establish jurisprudence about, you know, what is a tool of rhetoric,

13 and then what is incitement. And the Supreme Court, you know, tried to help guide us

14 on that philosophical journey.

15 What I will tell you about this text is, this text was sent when I didn't know some

16 of the worst that had happened. So I'm specifically referencing, you know, aggressive

17 stuff that was, you know, not good, not good at all. Trespassing stuff, not good at all.

18 Being on the scaffolding, stupid, stupid and reckless.

19 But I will tell you that, you know, no one has the authority outside of a judge or a

20 jury to determine the answer to your question. I certainly don't. But because this text

21 can be used against what -- what did I mean, is I was hurt. I was hurt. I was frustrated.

22 And, you know, at one point, what I want to point out is, if you scroll up on those text

23 messages, you know, it's almost like what happened? Ali, this is a madhouse.

24 And I'm getting this flurry of text message that spontaneous come in because of

25 the jammers that were put up. And I'm thinking, like, like, I can't possibly be responsible
 58

1 for tens of thousands of folks. Why are you texting me? I'm busy trying to remove

2 bystanders from becoming protesters or protesters becoming agitators. That's how I'm

3 thinking. I'm trying to triage people in my brain of who can I save, because nobody

4 needs to be hit with tear gas. Nobody needs to be hit at all.

5 And So I was very frustrated, very mad. And I'm of the opinion that the

6 President's words without the context of where to go was not helpful. And I've said as

7 much, and I don't care who that pisses off. But, you know, as someone who's done

8 professional events, that's, you know, the agreement should have been honored and we

9 should have had the speeches talking about Lot 8.

10 Q What people were you not going to denounce in this text?

11 A Excuse me?

12 Q What people were you not going to denounce?

13 A Okay. I'm really excited to take an opportunity to clarify what I meant,

14 because there is a viral video that -- where it shows me on top of 101 Constitution

15 Avenue. And I do a video, and I said I don't denounce this. I don't disavow this.

16 People want me to disavow this. And this is kind of a tool of rhetoric and debate that I

17 got from my late friend, Andrew Breitbart. Apologize for what, you know, he said.

18 Apologize for what? And that was to say that you don't owe your enemies an apology.

19 And then my Christian doctrine is, like, but you owe them something when you've done

20 something wrong.

21 So, first off, I'd like to say I've done nothing wrong. And I did nothing wrong.

22 So asking me to disavow the actions of other adults would be silly. People who didn't

23 attend Lot 8, would be silly. People who disrupted my event from taking place, me to

24 denounce them, that would seem silly.

25 And then what -- the video's cut off but it's gone viral, millions of views, and
 59

1 people who think that I was saying I support the violence. The video says that I don't.

2 It says, obviously, I denounce the people inside and the agitators. And I still have that

3 position. I've said that we should prosecute the violent actors. I've said it in my

4 opening. I've said it always, but people want to conflate it.

5 And so what I'm saying here in this text message, I won't denounce them, I'm

6 talking about the people on the ground. I'm not talking about the people in the

7 building. I'm not talking about people who punch cops. I'm not talking about any

8 unjustified violence. There's no evidence. There's no evidence that I've supported

9 violence. There's no text message where I'm celebrating injured people. There's not a

10 single text message that has that.

11 M r . - I'd just like to note for the record that Ms. Cheney and

12 Ms. Lofgren and Mr. Schiff have left the deposition, and the only remaining members are

13 Mr. Kinzinger and Mr. Aguilar.

14 BY
15 Q I believe in the afternoon of January 6th you tweeted, and I quote,

16 "Democrats and media ended the republic and that people responded. Welcome to," in

17 quotes, "duh." What did you mean? Please explain this tweet for us.

18 A What exhibit is this?

19 Q It's exhibit 17 actually. Go to exhibit 17, and I'll actually narrow my

20 question here.

21 A Thank you.

22 Q When you say that people responded, what are they responding to?

23 A Well, again, I have to say this for the record for anything that's presented to

24 me that either I didn't authenticate, or was -- does not look like it was pulled from Twitter

25 itself. So this, again, assuming that this is true and out of great respect for the
 60

1 committee, Democrats and media ended the republic. So this is my truly held belief

2 that -- and it was 47 percent of America at the time believed that there were election

3 irregularities. Right now 80-something percent, 80-plus-something percent of

4 Republicans still believe that. And we're not going to stop believe that because there's

5 evidence for some.

6 And I said, you know, people responded. And that's unfortunate. This is not a

7 value-based judgment. This is not one. This is me making some analysis, and it's not

8 good. It's not healthy for you. It's not healthy for me. It's not healthy for either of

9 our parties. And I think that this is a failing of Democrat Party that compromised our

10 election itself, and I think this is a failing of the media which is supposed to speak truth to

11 power, and fight for transparency in elections.

12 I want to state this: Stop the Steal was not a Trump movement, and that's why I

13 really resent this whole March for Trump stuff and Trump 45 stuff and all of that. That's

14 silly to me. Okay? We support fair elections and transparent counting. We believe

15 that there are election irregularities, and we believe those irregularities favor Joe Biden,

16 who's the current President of the United States.

17 So that's our stance, and that better describes and adds context to this tweet.

18 Mr. Kamenar. Excuse me. I didn't mean to interrupt. Is there a date and time

19 of this exhibit?

20 Mr. Not on the exhibit, no.

21 Mr. Kamenar. Is there any reason why? We're talking about chronology and so

22 forth. I just thought it might help the witness if he had a date and time.

23 Mr. - It's not in the exhibit, and he provided the analysis that we

24 needed for this tweet.

25 Mr. Kamenar. Okay.

 61

1 Mr. Alexander. Okay. Can I -- I'd like to clarify on the record then. I thought

2 you just reported that this was a January 6th tweet.

3 BY

4 Q It is.

5 A And I'm glad that -- I'm glad that I clarified at the beginning of my tweet,

6 assuming that this is true, okay. But if this was in response to something else, because

7 we're having all kinds of small victories or small defeats at the States, then that's

8 whatever. But, you know, if I was writing this tweet today, that's, you know, what it

9 would mean.

10 Q And with this tweet, when you're saying, "duh," are you saying that, you

11 know, the response you just described is the natural and obvious result to those alleged

12 election irregularities that you described?

13 A No, not necessarily.

14 Q So you talked about how you went to I believe you said 101 Constitution

15 Avenue. Is that where you went after you left the Capitol complex grounds?

16 A That's where I believe I went. I've since gathered the address from trying

17 to get evidence gathered for y'all. So I'm trying to best represent where I was.

18 Q Who did you leave with?

19 A I left with Mr. Jones and his security and camera staff, and if there were

20 other people with us. Michael Coudrey was with me. If there's other people, I don't

21 recall.

22 Q And when you say you were talking about the video of you making the

23 speech about you don't disavow this, you don't denounce this, who recorded that video

24 of you?

25 A I don't know.
 62

1 Q You don't recall?

2 A No. I mean, it could -- you know, it could have been Michael. It wouldn't

3 have been Alex, you know. It could have been staff. It could have been security.

4 was friendly -- those guys were protecting me. So I was friendly with everybody. And,

5 obviously, I didn't film it myself.

6 I'll be honest. Before I had to gather this evidence, my recollection was actually

7 that I shot my own video. And so that's how, you know, in reviewing this evidence,

8 weird it is. And to be de platformed and not have access to any of that stuff makes

9 me -- you know, I'm acting in good faith. I'm cooperating and acting in good faith.

10 Q So going back to exhibit 26 -- and I'd like to direct you to page to page 236.

11 Sorry. Let's go back to the east side of the Capitol. Sorry. When you got to

12 the east side the Capitol, did you give another speech? Or did you and Alex Jones give

13 another speech?

14 A The east side of the Capitol.

15 BY

16 Q How about do you just remember, Mr. Alexander, when you were on the

17 pallet, talking next to the stairs? You all left and went to another area on the Capitol.

18 Do you remember that? And can you just walk us through that movement?

19 A I'm actually more confused.

20 Q Remember with the -- you were talking about statement that, you know,

21 when you climbed up whatever you called it, at risk to your own personal safety?

22 A Yeah. There were chairs.

23 Q Right. Sorry. And then you left from there and went somewhere else.

24 Do you remember where you went?

25 A Yes.
 63

1 Q Okay. Where did you go?

2 A I believe, again --

3 Q Without -- just the way, what you remember, yeah.

4 A Well in consultation with my attorneys and, again, remember I was stupid.

5 I missed -- I was confusing -- I was confusing, I believe, south with east and north with

6 west. And this is reflected in these text message, including a text message that I ended

7 up sending to all kinds of supporters.

8 So we were walking, I believe, on the south side. We ran into an officer who

9 was, you know, politely but very annoyed, directing people to the east side. And we

10 asked him several times how can we help. What can we do? And he didn't want to

11 engage in that conversation. He's, like, just go to the east side. Just go to the east

12 side.

13 So we, of course, are walking towards the direction of Lot 8. When you're

14 walking -- when you're walking, you know, again from The Ellipse to Freedom Plaza, to

15 the west, past the north -- I hope I didn't just previously just say south -- past the north.

16 Q We get it. That's fine.

17 A And then what's directly in front of you, you think it's Lot 8, but it's actually, I

18 believe, Lot 9. But if somebody showed me a map, we cube more accurate about it.

19 What we see then is about six or seven officers, I believe, on the steps closest to us. So

20 this is hard northeast of the Capitol building. We walk up to them, engage them.

21 And, again, we're -- we're escalating our deescalation efforts, myself and Alex

22 Jones and Owen Shroyer and thinking, well, we'll be recognized by part of this crowd.

23 These aren't all our supporter, but a lot of them are. And we engage with those officers.

24 Eventually they tell us, you know, okay. Try to get those people down if you can. We

25 don't think you can. That's my best recollection of that.

 64

1 We go up the steps of, like, I guess the south or, no, the northwest side.

2 And -- and we're doing chants that is common to Alex Jones' audience to get people's

3 attention because there's music blaring. And, again, I'm in the state of, you know, I've

4 worked this -- I'm working through it, you know, with a therapist and stuff like that. But

5 I'm in a state of, like, shock. Like, like, why are there vehicles on the Capitol Plaza?

6 The cops told us there wouldn't be any vehicles. Why are there vehicles? Why is there

7 loud music playing? Who the hell has a speaker that loud? Because on the Capitol,

8 you're only allowed wound-up speaker, and this speaker's loud and it's playing, like,

9 heavy metal music. It seems like something out of, like, Abu Ghraib.

10 I mean, it's just -- it was just a, frankly, bizarre situation. And there's all these

11 people who some of them think that that's where the rally is, and then other people who

12 are just bystanders. And then some idiots, some real idiots, you know, some bad,

13 nefarious people, I guess, you know, they're up at the front. But I don't see them.

14 never physically saw these people.

15 And then, so, we spend, I don't know, 5 to 15 minutes -- I don't think it's 15 -- but

16 5 to 15 minutes getting people's attention so we can shove them down. This

17 loudspeaker and these vehicles are interrupting our ability to take command of the crowd

18 where we cannot take command of crowd and physically grabbing people and shoving

19 them down the stairs. Okay. That's how desperate I was to deescalate this situation,

20 me, Alex Jones and Owen Shroyer, all deescalating.

21 And -- and, so, then we -- so then we exit. And we start talking to people on,

22 like, Lots 10, 11, 9, and 8 and trying -- what happened before we got here? Were you

23 here? And what we come -- came to learn is that most of those people had never

24 attended The Ellipse rally and heard Trump's speech. Most of those people, you know,

25 certainly weren't at Lot 8.

 65

1 All the people at Lot 8 were peaceful. Lot 8 never erupted into violence. Lot 8

2 maybe had, like, 10 people on it. But those people, you know, had gotten my tweets.

3 So maybe I affected 10 people, and that was kind of defeating. And ultimately I

4 was, like, I don't want people to think I'm condoning this. And I don't want people to be

5 attracted here and then accidentally get swept up in all of this. Mob psychology's a real

6 thing.
 66

2 [12:16 p.m.]

3 The Witness. And so, then I said, let's go. Me and Alex Jones make the

4 decision, the executive decision that we are leaving the entire premises, we've

5 abandoned our event. The police we wish would have given a dispersement order.

6 We wish would have had barricades, we wish we this protection. None of our security is

7 there. It was a failure of epic proportions. And I found myself, you know, just trying to

8 deescalate and then trying to exit, because that's what I've been taught.

9 BY

10 Q Right. And as you were moving from where the chairs were around to

11 where you ended up on the stairs, you were with Mr. Jones during that time, walking with

12 him?

13 A I believe so.

14 Q Right. And Mr. Shroyer was with you as well?

15 A I believe so. We were all in the same security bubble because we were

16 really scared about ourselves getting hurt. It's like you don't know who is punching who

17 or why they are punching people.

18 Q Right.

19 A Honest to God, at this moment, I'm not thinking it's the stop the

20 certification, that is contrary to our purposes. We are winning our political purpose.

21 Even if we lose, we are winning our political purpose. And we were going to primary

22 bad Republicans, including two --

23 Q I'm just asking --

24 A Well, I really want to answer this.

25 Q The answer is who you are with and as you are walking?
 67

1 A Can I answer the question?

2 Q I'm not trying to be combative. I am just trying to figure out some moves,

3 and that's it. You can get in more as we speak, we are just trying to move this along.

4 A Yeah.

5 Q And so, and Shroyer, for the record, is S-h-r-o-y-e-r. And so as you're

6 moving along with Mr. Jones and Mr. Shroyer along the side of the Capitol where you end

7 up, there are times when you come in contact with Capitol police officers or Mr. Jones

8 does. Is that right?

9 A We collectively did.

10 Q Right. Okay.

11 And did you hear Mr. Jones tell the police officers that President Trump was

12 coming?

13 A I don't recall that, but that totally could have happened.

14 Q Do you recall when you were on top of the chairs when Mr. Jones had a

15 megaphone, or a bullhorn, whatever you call it, do you remember that?

16 A Do I remember being there? Yes. I've described that event.

17 Q I understand you did. Do you remember if he had a megaphone and was

18 speaking to the crowd at that time? Mr. Jones?

19 A Yes.

20 Q And you were right next to him at the time?

21 A Yes.

22 Q Do you remember him telling the crowd that President Trump was coming?

23 A I didn't -- I did not recall that contemporaneously. It was a traumatic event,

24 like I've said. And I apologize if you I are doing a little back and forth. I'm trying to be

25 as detailed and free giving as I can.

 68

1 And so, what I have seen since then is a video that I believe to be true, and which

2 he says, Hey, guys, you can't be here. Go to Lot 8, that's where Trump said he's going.

3 Q Right.

4 A And so, that was a tool of rhetoric by speaker. At that point I have to

5 believe that Alex -- but Alex can be naive and innocent and he could have believed that.

6 Q That's fine. We saw a text message earlier you saw where Caroline Wren

7 told you --

8 A What time was it at?

9 Q 12:59, POTUS not walking. Do you remember that?

10 A Yeah. And that's what -- my true belief is that the President was not

11 coming.

12 Q Right. So at that time you knew it wasn't true, as far as you knew that the

13 President -- when Mr. Jones said that the President was coming, you knew at that time he

14 wasn't coming. Is that right?

15 A It would have seemed logistically improbable.

16 Q I'm asking what you understood at the time that he wasn't coming.

17 A Yes. My understanding was that it was logistically improbable to the nth

18 degree. And again, I already told this committee that in my professional opinion, there

19 was no way for Trump to ever come.

20 Q I heard you. I heard you.

21 And so, did you ask Mr. Jones at the time why are you saying that President Trump

22 is coming?

23 A No. I'm observ -- I have tear gas in my eyes. I'm not thinking about

24 correcting him. And again, we're engaged in tools of rhetoric to get people out of the

25 conflict zone. And so, if Mr. Jones said that there are aliens on the other side, I would
 69

1 support that, because that would get people away from tear gas, away from conflict.

2 Q Right. Because what attracted people is the fact that President Trump was

3 there in your mind, right? That they would go to where he said President Trump was?

4 A If Trump was coming to Lot 8, a lot of people would come to Lot 8.

5 Q Right. Because as we talked earlier we talked about President Trump's

6 words, we are not talking about Brandenburg in the Supreme Court. The people who

7 were there were Trump supporters, right?

8 A There are a lot of people and a lot of evidence to suggest that the reason

9 that we saw no counter protesters is that they were in the crowd, too.

10 Q There. The majority of the people you saw there were Trump supporters

11 from everything that you saw?

12 A They purport themselves to be Trump supporters. I sometimes do not feel

13 safe, which is why I said me, and Owen Shroyer, and Alex Jones are all in the security

14 bubble. And we are stuck together. There is no exiting the security bubble. We are

15 in the security bubble and we are at the mercy of whatever those gentlemen tell us to do.

16 Q Right, okay. And so, at any point did you ever talk to Mr. Jones where he is

17 getting the information that President Trump --

18 A No.

19 Q You never asked him?

20 A No. That would be improbable. I have tear gas in my eyes. I'm suffering

21 from a traumatic event. My event is being barred from happening. And I'm just

22 thinking about how do I save human lives, you know.

23 Q And part of that would be it sounds like at least Mr. Jones was saying that

24 President Trump was coming.

25 Mr. Kamenar. Counsel, I think he's asked and answered your question. You've
 70

1 asked it several times.

2 Mr. Okay. Fair enough.

B-
3 Mr. Kamenar. And he said he hasn't talked to Jones to explain --

5 Q How about after the fact? Did you ever have a conversation with Mr. Jones

6 why he said at the time at the Capitol Grounds that President Trump was coming?

7 A I don't recall that Alex Jones and I have had a conversation about a play by

8 play of the traumatic event, no.

9 Q Okay, so no. Okay.

10 BY
11 Q Let's go back to Exhibit 26, page 236. You're on that page already.

12 Mr. Kamenar. What's the page?

13

14 The Witness. I was on the page, I'm sorry.

15 BY
16 Q That's okay.

17 And it looks like you're testing a Jordan Harrison, do you see that part of the page?

18 A Yes.

19 Q And there are messages to say make the wild protest. I am assuming the

20 [Link] page, a blank page. First, who is Jordan Harrison?

21 A Jordan Harrison is a web vendor that I frequently use for computer-related

22 stuff. I had no computer access.

23 Q And who was in control of the [Link] website?

24 A It was a Stop the Steal website.

25 Q And why are you telling Jordan Harrison to make the web page blank at the
 71

1 time on January 6th?

2 A Because I believe he has access to it.

3 Q No. Why are you telling him, Mr. Harrison, who has access to

4 [Link], to make it blank?

5 A Because my event had been prevented from happening because there was a

6 Capitol riot. There was no -- there was not going to be an event. And I did not want to

7 be subject to the defamation, and libel, and slander that I have since been subject to

8 confusing my efforts to deescalate with people who did deplorable things, horrible things.

9 Q I failed to mention that Mr. Raskin has joined the deposition.

10 Staying in the same exhibit, Exhibit 26, I'm going to page had 170.

11 I just have one quick question. Mr. Alexander, do you know who

12 Mr. Harrison works for or does he own his own web vending company?

13 Mr. Alexander. I think he owns his own company.

14 Mr. Kamenar. What's the next exhibit?

15

16

17
Mr.-

Q
B- Exhibit 26, page 170.

And this is a message from Ms. Wren -- so kind of on the same lines of what

18 you said to Mr. Harrison about making the web page blank, Ms. Wren writes you and said

19 can we take down the coalition partners page on the website? This is on January 7th.

20 So is she -- which website is she referring to?

21 A I'm sorry, what's the time stamp?

22 Q Looks like January 7, at 11:35 a.m. She says quote, unquote, "Vo, crazy day

23 yesterday. Can we take down the coalition partners page on the website, please."

24 And it looks like you replied "yes." And then it looks like she replies "thanks." Is she

25 referring to [Link]?
 72

1 A No. I'm just trying to read the prior text messages to figure it out because I

2 did not know because it could be the website you just mentioned, because we were

3 running two different websites. So it could have been that website, but it doesn't say

4 here in the prior text messages but it could have been that one.

5 Q What websites did you have control of on January 6th?

6 A I'm aware -- right now, I'm aware of Stop the Steal U.S. so three, Stop the

7 [Link], [Link], and then the [Link], I believe.

8 Q So when she says can he take it down the coalition partners page, is it your

9 testimony here it is either the [Link] or [Link]?

10 A Excuse me?

11 Q When she says take down -- can we take down the coalition partners pages

12 on the website, please, it could have been [Link] or [Link]?

13 A It could have been.

14 Q You don't remember which one it was?

15 A Whatever one had a coalition partners page.

16 Mr. - Should we take a break? It is 12:30. It is up to you all.

17 Mr- I am just going to open the floor up to the members to ask

18 follow-up questions. Any questions from the members? That's a negative. And any

19 follow-on questions for counsel?

20 Let's go on recess then, I believe this is the lunch recess.

21 Mr. How long will that be 30 minutes?

22 Mr. - Yes. Just come back at 1 o'clock p.m.

23 [Recess.]
 73

2 [1:10 p.m.]

3 BY

4 Q Mr. Alexander, I just want to go back before we move on to the next topic.

5 And before we start, I would like to announce that no members are on. And that Mr.

6 - l e f t the deposition as well.

7 Mr. Kamenar. No members?

8 Mr. No members. That's correct.

9 B~

10 Q Can you go to Exhibit 26, page 238 again. The text messages with Ms.

11 Kimberly Fletcher?

12 A I'm sorry. What page is that?

13 Q It's going to be 238.

14 A 238?

15 Q That's correct. So on the bottom half of the page where you say, "POTUS is

16 not ignorant of what words would do." Just very clearly explain to us what do you mean

17 by what his words would do?

18 Mr. Kamenar. That has been asked and answered.

19 M r . - What do you mean by--what would his word do?

20 Mr. Kamenar. I mean, if you want to speculate.

21 BY

22 Q You're saying it. I am just asking what you mean by your words.

23 A Yeah, I've already been asked this question and given the record an answer

24 and I don't want to give a contrary answer.

25 Q So when you -- Mr. Alexander, I'm going to ask you the question again.
 74

1 A Well, this is the fourth time you've asked me, but I already have an answer

2 on the record an hour ago. And I would feel very uncomfortable exposing myself to that

3 legal liability. I am under oath. I acknowledge that I'm under oath. And I had to

4 recontextualize it here 11 months later for y'all in my first answer. So the fourth one

5 wouldn't --

6 Q So he was not ignorant that his words would lead to the rioters attacking the

7 Capitol?

8 A _ , you know, a fifth time. I would really just like to stick with my first

9 answer, if you're okay with that.

10 Q And as the rioters are attacking the Capitol, you're not going to denounce

11 them? Is that what you're saying to Ms. Fletcher?

12 A On that separate text message you've already asked me that, too. And I

13 actually remember said that I denounced all the people who performed vandalism, all of

14 the people who performed violence. I didn't denounce the people who were on the

15 grass and peacefully assembled. And a lot of people wanted to lump them in together.

16 And I just don't believe that that is equal treatment under the law. I am a little civil

17 libertarian on some of those issues. I believe that each individual should, you know,

18 have their fair day in court. And to denounce everybody and lump them in with people

19 who committed violent acts is not fair.

20 Q So show me where you're saying I denounce the people that are going in and

21 vandalizing -- why would it make sense to denounce people who are not breaching the

22 Capitol?

23 A That happens in politics all the time --

24 Q I'm trying --

25 A 1am really glad, and I appreciate the stenographer letting me finish my

 75

1 answer. But, you know, if I can go without interruptions, , because I didn't even

2 get a sentence in. This is the third time you and I are talking about this denouncement,

3 and I've described it here 11 months later. And I have a video of me that you guys have

4 denouncing violent people. And I told you, you know, you work in government, I work

5 in politics. A lot of people think they are the same, but they are not. And there is a

6 game in media and politics that -- a denouncing game where people try to associate you

7 with people that you're not associated with. And that's not fair. It happened to Barack

8 Obama, it's happened to Donald Trump, and I was afraid of it happening to me. And

9 guess what? It has happened to me. I am not associated with the Capitol attackers.

10 Q So at this moment while the rioters are attacking the Capitol, you're thinking

11 about the media?

12 A No. Because as I said in a previous answer, I was on the ground, I didn't get

13 to watch CNN like you. I didn't get to watch tweets or Twitter or anything like that.

14 And from what I saw was chaos. What I saw was tear gas. I didn't watch anyone

15 punch anyone. I was afraid that it was going to escalate. And so, what I was worried

16 about is that blame would be laid at the feet of Republicans who believe in election

17 integrity and not Capitol attackers. Whether they are Democrats or Republicans, they

18 should have their day in court, a fair day in court. But lumping everybody together,

19 whether it is me or two other Americans, it is not right, and not fair, and it doesn't speak

20 good of our system.

21 Q So going back to your security, while were you planning the wild protest

22 event at the Capitol on January 6th, did you have any security concerns?

23 A I'm a public figure and I walk around -- even coming to this hearing, I had

24 great security concerns. And us trying to get here on time, we actually approached four

25 times, and it was hard for us to get through the perimeter because y'all had a security
 76

1 concern. So I have general security concerns wherever I go.

2 Q So what were your security concerns while were you planning the wild

3 protest event at the Capitol?

4 A I wouldn't -- I think general event security issues, principally is that antifa

5 and some other fringe left-wing Socialists, Communist, Marxists, and other kind of gangs

6 get away with violence unprosecuted here. I've seen my face on a target map. I've

7 been called a nigger. I have been called everything by the left wing. And to this day,

8 you can go to Twitter right now and find death threats about me.

9 And so when I tried to get security, I got paid security to take on the liability of

10 confronting anyone if they confront me, self-defense only, but volunteer veterans or

11 police officers, first responders are mostly there to keep a perimeter around equipment.

12 Q Did you conduct a threat analysis while you're preparing the security for the

13 wild protest?

14 A Me personally?

15 Q Yeah. As you're planning to for the event, did your Stop the Steal or

16 anyone engaged with planning this event, did you conduct a threat analysis?

17 A I trust other people to do stuff like that. I myself am not qualified to do a

18 threat analysis. I've heard of this term, and I've, you know, it has probably been said to

19 me in passing or something like that. But, you know, an intelligent assessment would

20 require the time to be able do it. And I lack the time to collect anything of what was

21 happening on the ground or interface with the police directly myself. I hire people, or

22 have people delegated to that who have that expertise.

23 Q Did you hire someone to conduct a threat analysis for your event?

24 A I don't recall either way.

25 BY
 77

1 Q Real quick, sitting here today, can you remember anyone on behalf of or

2 associated with the Stop the Steal or One Nation Under God event conducting any kind of

3 threat analysis for that rally?

4 A What I recall is trusting the U.S. Capitol Police to communicate to us what

5 we needed to do, what they would do, and any, any concerns. And the permitting

6 process is an open process until the day of. And so I hired people to interface with the

7 U.S. Capitol Police and all other government agencies. And they communicated with

8 them on a regular basis. And sometimes, in our previous events, I don't recall January

9 6th receiving them, but sometimes if police want to pass something through us, we would

10 get that. But I -- I don't really recall today anything. But the process is super

11 elaborate, and security is not my primary expertise.

12 Q Outside of the interaction with the Capitol Police, do you know of anyone at

13 Stop the Steal or One Nation Under God who conducted a threat analysis for that event?

14 A I am the only officer, you know, at Stop the Steal, I'm a one-man shop, and I

15 have volunteers that do work with me and stuff like that. But, and that Stop the Steal

16 the organization, not Stop the Steal the hashtag, not Stop the Steal when someone is

17 chanting "stop the steal," not "stop the steal" that originated in 2016 with Roger Stone.

18 My Stop the Steal is a protest movement. It has 500 peaceful rallies in 50 States

19 under its belt, and January 6th was not one of ours. So this seems like a specific term,

20 and if you guys reference something, I can tell you if I recognize something or not, but it is

21 not triggering anything.

22 Q If you don't know the term, then you can say I'm not aware of any threat

23 analysis being conducted on that day on behalf of Stop the Steal.

24 A Today I do not. You know, I do not recall -- I do not recall -- I do not recall,

25 you know, like, paying $50,000 for a threat analysis or anything like that. That's what it
 78

1 sounds like to me, like this fancy --

2 Q I'm not trying to make it complicated because if you don't know the term,

3 that would suggest that you were not aware of a threat analysis. I'm literally just asking,

4 are you aware of any threat analysis being conducted for Stop the Steal?

5 A Today, right now, I am not aware.

6 Q That's it. And I'm not trying to trick you. I think you get what I'm asking,

7 so I appreciate the answer.

8 BY

9 Q Can you got to Exhibit 14, please, Mr. Alexander? This is a text message

10 exchange between you and Mr. Stephen Brown. Who is Mr. Brown?

11 A Mr. Brown is a -- I think he's like a preferred vendor with the National Park

12 Service or something like that. He has some special designation with -- there's like three

13 or four different groups that run permits around D.C., depending on what type of land it

14 is. And I met him during the December 12th event, I think it was, the Jericho march.

15 And he was -- I joined in on that event. I endorsed that event. And it was a Christian

16 event. And he, I thought, did an excellent job of, like, the staging and some of that.

17 And there was a lot of pressure. And so he was the guy that I knew who I could hire to

18 do permitting and tell me, you know, point me in the right direction, and just handle all of

19 that stuff. So we hired him for Lot 8.

20 Q So Stop the Steal hired Mr. Brown to help organize?

21 A I hired him.

22 Q You hired him?

23 A Yes.

24 Q Thank you. Okay.

25 So just to orient the room, this is text messages from Mr. Brown's standpoint, so it
 79

1 is to Mr. Alexander, that's why you see to Ali Alexandra, spelled wrong at the top.

2 Mr. Kamenar. What -- okay.

3 Mr. McBride. These are from Brown to Ali.

4 Mr. Kamenar. Where is Brown's name?

5 Mr. McBride. It is not here, just --

6 M r . - When you text from your phone, it doesn't say your name on it.

7 So it would not say his name on here. It just says to Mr. Ali Alexandra on here, but he

8 means Ali Alexander.

9 Mr. Kamenar. And this is from Brown's phone?

10 M r . - Correct.

11 Mr. Kamenar. Okay. And the reason you know that is --

12 Mr. We know that.

13 Mr. Kamenar. Don't try to find the name. Sorry. Go ahead.

14 BY
15 Q So in the middle of this page it looks like a message from Mr. Brown to you.

16 Mr. Alexander, it says, "Do you still want Stewart to provide you with two protection

17 detail officers?" Who is Stewart in this text?

18 A If this text message exchange is accurate and -- then I would say -- then I

19 would have to speculate that Stewart, is Stewart Rhodes from that veterans group.

20 Q Is he -- the veterans group, is that the Oath Keepers?

21 A Uh-huh.

22 Q And how do you know Mr. Rhodes?

23 A Well, this text message that you just pointed out is showing that I am not

24 talking to Mr. Rhodes about this, that Stephen's handling it for me, which sounds like me.

25 And I met -- I met -- let me see, I actually have -- I think I have some details. I think I met
 80

1 Stewart Rhodes in Atlanta. We had an Atlanta protest and Stewart Rhodes showed up.

2 Someone introduced us. And he said, Hey, wherever you guys go across the country, we

3 can provide veterans that are clean. And they actually, you know, were, like, we

4 don't -- we don't protect White nationalists, we don't do this, we don't do this. We are

5 just like here to help patriots like you. And, so, like I mentioned earlier, I believe I had

6 two Oath Keepers with me or my party at the Ellipse event. And so, this text message

7 seems to line up with that.

8 Q So when you were talking about the Oath Keepers, the veterans group is a

9 term we use, it sounds like they were pretty professional to work with in your

10 experiences in Atlanta, and then moving on through January 6th?

11 A In -- let's see. I worked with them in Atlanta. I don't know if we worked

12 with them in December or not at the Jericho march. But again, was an even I partnered

13 on. I didn't really run the whole thing. And so, maybe that's why Stephen is handling

14 the exchange because he worked with them more. That's what I was told about Oath

15 Keepers is they are a veterans group. And, you know, I've seen con -- I've seen other

16 media reporting characterizing them as other things or whatever, but January 6th, like I

17 said, I used two of them. I don't know if I just answered your question or not.

18 Q No. Did you consider them professional from your experiences with them

19 in Atlanta?

20 A In Atlanta they were professional. And I barely had any-- I didn't have any

21 direct interaction really, so they were on the perimeter.

22 Q You trusted them to provide your security, though, for January 6th?

23 A No.

24 Q You did not trust the Oath Keepers to provide security for you on January

25 6th?
 81

1 A What I have described to this committee is that I usually have several layers

2 of security. And the highest, the highest form of security I like to pay because they

3 usually come bonded and other stuff like that. I do know on the 6th, let me volunteer

4 this information is that I think I talked to either Stephen or somebody that the Oath

5 Keepers were -- because you can't have a rope line on the Capitol Grounds, so there is no

6 way to protect the stage or limit people, so the Oath Keepers were going to be the

7 limiting force for Lot 8. But you know, when I showed up there, they are not there.

8 Q Do you recall Mr. Morelock providing part of that voluntary security for you

9 on January 6th?

10 A If that is one of two gentlemen, I would have to see a picture.

11 Q Okay.

12 A Of his face.

13 Q It is M-o-r-e-1-o-c-k.

14 Can you go to Exhibit 18 for us, please?

15 A Yes, sir.

16 Q This appears to be a Signal chat entitled Jan 5/6, D.C., OK, which I believe

17 stands for Oath Keepers security. The rest of it is cut off. Do you recall being a

18 member of this Signal chat?

19 A Can I have a minute to read it?

20 Q Please.

21 A Could you define member?

22 Q Okay. Let's actually just make it easier, on the middle of this page, it says

23 Ali Alexandra. Is that you?

24 A Well, I'm Ali Alexander. This seems like what you're saying is that this is a

25 screen shot on Stephen Brown's phone based off what we just tackled and it says, I'm a
 82

1 participant in this chat. I'm not a member of an organization, I'm not a member of --

2 Q All right. That's fair. So you were a participant of the Signal chat?

3 A I don't recall this, but I am not reading anything that is sticking out that, you

4 know, that looks foreign.

5 Q Do you recall why this Signal group chat was created?

6 A Probably to handle security.

7 Q Right.

8 A Volunteers.

9 Q The Oath Keepers volunteered security for you?

10 A Yeah, yeah. Well, not for me. If Stephen Brown is not -- was not hired to

11 handle my January 5 events or me going around as a public figure to other events. And

12 so, this chat would have been specifically only about Lot 8, which means that if they

13 weren't my security they are again the Lot 8's, again, kind of perimeter buffers.

14 Q Okay. Go to Exhibit 22 for me, please.

15 A Yes, sir.

16 Q And this is where I got the name Jeff Morelock from.

17 A Okay.

18 Q There is a text message between you and Mr. Stephen Brown. And it looks

19 like he says, "room needed for Ali PSD guys at the JW in the name of Jeff Morelock and

20 Tom Burgess." And you respond back with a thumbs up emoji. Do you recall these

21 two individuals providing volunteer security for you on Jan 6th?

22 A The first thing I would like to point out is there is a discrepancy in the

23 evidence with Stephen Brown. And that's that the three or two other pieces of evidence

24 that you've shown me with him, my name an Ali Alexandra. On this one it says Ali

25 Akbar. And so, that's my birth name, which I don't think I've ever told Stephen, and
 83

1 your iPhone doesn't save it that way.

2 So I have told this committee already there are two gentlemen who I didn't know

3 the names of that were Oath Keeper volunteers. They were at the bottom of the stack

4 of my security detail. And when I say my security detail, it could apply to me as a person

5 or whatever group I was with, I do not recall this exchange. And the red flag to me here

6 is that there are two different names Ali Akbar and Ali Alexandra cannot occupy the same

7 space on an iPhone.

8 BY-

9 Q Mr. Alexander, on Exhibit 22, do you see the little picture next to the Ali

10 Akbar character. Is that your face or is it your position that that's not your face?

11 A That is a picture of me. That's a publicly available picture of me from

12 Georgia in the 2000s.

13 Q So sitting here you have no memory of this and it is your position that it is

14 not you on that text chain?

15 A My position is what I stated.

16 Q No, no. I'm asking you, yes or no, is it your position that it is not you on the

17 text chain in Exhibit 22?

18 A My position is that I do not recall this text exchange, that there were two

19 Oath Keepers given to me at the bottom of my security stack. If these are the two

20 gentlemen, then I will have to take someone else's word for it. I don't remember. I'm

21 getting their names. I meet a lot of people, I met tens of thousands of people on the 5th

22 and 6th, me personally. And I would just like to finish. But the discrepancy of

23 evidence, like this wouldn't be admitted to court. You have my name is Ali Akbar here.

24 Q I totally understand.

25 A I just want to finish. No, I would like to finish.

 84

1 Q I don't want to interrupt you. This is important, because this isn't court.

2 And I respect that there is a lot of prep and I really do respect that --

3 A No, it's not prep, this is me.

4 Q I get that, but it is important that this is not court. And I don't want you to

5 waste a lot of time, and, frankly, lawyers' fees, on objecting to things that aren't relevant

6 to our situation. I just need to know are you saying here today that you don't believe

7 that's you having that conversation, is it your position that's not me. That's a yes or no.

8 A My position is that I do not recall this text exchange.

9 ~ Thank you.

10 BY

11 Q Before I go on, who is Mr. Nathan Martin?

12 A Nathan Martin is a friend of mine that I've known, I think, for a decade and

13 he's not really a big Trump fan. And when Stop the Steal was growing faster than I could

14 by myself kind of coordinate, he volunteered to help coordinate some of that stuff, or I

15 recruited him to help coordinate some of that stuff, because he's really good at logistics.

16 And he runs, like, a travel agency so we were able to book stuff through him.

17 Q So he helps you, like, book travel for various events?

18 A Yeah.

19 Q Did he book your travel -- actually, did he book other people in Stop the

20 Stea l's travel as well, in addition to you?

21 A Like I said, Stop the Steal is me. But if I asked him to book someone else,

22 he would book it.

23 Q Okay. So can you go to Exhibit 21 then.

24 And go to the third page of Exhibit 21. So you've already said you stayed at the

25 JW Marriott on January 6th. The first name on the third page appears to say Akbar/Ali.
 85

1 This would be you staying at the JW Marriott, right? And it is double-sided?

2 A Okay.

3 Q I'm sorry.

4 A Yes.

5 Q Okay. And we mentioned in the text message from Stephen Brown earlier

6 about personal security. There is that Tom Burgess name under the Stop the Steal room

7 block. So did he stay in your -- you're not going to deny that he stayed in your room

8 block, right?

9 A According to these records, that seems to be what it suggests.

10 Q Okay. And if you go to two pages ahead, there is going to be a Jeff

11 Morelock, correct?

12 A Two pages? I'm sorry.

13 Q In the same exhibit, there is an individual in the Stop the Steal room block

14 named Jeff Morelock --

15 A This paperwork says that he was staying in the same room with this Tom

16 Burgess.

17 Q Okay. So let's he go back to Exhibit 14 -- not 14, sorry. I misspoke. Let's

18 go back to Exhibit 22, the one you were just saying you cannot confirm whether that is

19 you. The room block listings we just looked at is consistent with Stephen Brown saying

20 "room needed for Ali PSD guys at the JW in the name of Jeff Morelock and Tom Burgess,"

21 correct?

22 A That's what you've shown me, yes.

23 Q So let's go back to Exhibit 18 in the Signal chat. Do you know who OK Gator

24 1 is?

25 A No. That's someone who works with Stewart Rhodes. At first I thought
 86

1 OK meant Oklahoma, but I like your description better, Oath Keepers.

2 Q And you so you didn't know the name Kelly Meggs?

3 A Who?

4 Q Kelly Meggs. You didn't know that name?

5 A Kelly Meggs?

6 Q Yes.

7 A That name is not ringing a bell at all and I don't see it on this sheet.

8 Q Okay. What about, did you know Mr. Don Seikerman, he's on this chat on

9 the bottom.

10 A No, I don't. I'm not familiar with that name right now, and I don't

11 remember ever being familiar with that name.

12 Q Do you still have these Signal chats?

13 A I don't believe so.

14 Q Okay. Let's go to Exhibit 12, so it appears on January 4th that Mr. Stephen

15 Brown forwarded you a list and he says, "This is the list of PSD we have working with us

16 and their names/nicknames from Signal.

17 Mr. Kamenar. Sorry. What exhibit is this?

18 ~ Thisis12.

19

20 Q Is your email address?

21 A That is my email address.

22 Q And Nathan Martin, would refer probably I am

23 assuming to the Nathan Martin you just discussed who does did your logistics for Stop the

24 Steal?

25 A Yeah, he did some of the logistics. I believe that is his email address.
 87

1 Q And do you recall receiving this email?

2 A I do not recall receiving this email. And I can tell you why I don't recall it.

3 Q Why don't recall it?

4 A January 4th, 2021 at 5:55 p.m. I was in Georgia, helping out in the runoff.

5 I don't know that I ever saw this email. I was working on run off, helping out with

6 events on the 5th and the 6th, doing Georgia logistics, and trying to get my butt D.C. the

7 next morning by 6 a.m. So I don't recall ever seeing this email. And, you know, I see

8 here it says "Gator Kelly Meggs." When you said it the first time I thought Kelly was a

9 woman. And this suggests that it's a guy.

10 BY
11 Q Can I ask you something? Does that mean that you would have allowed

12 Stephen Brown and Nathan Martin to coordinate this with you on your behalf while were

13 you busy in Georgia?

14 A It could, because as I've testified to this committee, this is like such a

15 volunteer organic effort. We are not getting our marching orders from Trump or the

16 RNC. And so there's a lot of labor of love which requires a lot of delegation. And I

17 trust Steve Brown, Stephen Brown and Nathan Martin to be professionals and to do the

18 right thing. And they are both Christian and I'm a Christian. And I don't -- I don't mess

19 around with details like this when I don't have to. And sometimes, I'll fly into a

20 conversation and then I'm out, but that's why they have group conversations, so that

21 other people can take it -- take it from me.

22 Q I just wanted to clarify because I think earlier you said you were the one

23 person for Stop the Steal, so for them to do this, you believe they had your authority to

24 act on your behalf to make these arrangements without your knowledge -- without you

25 seeing this, they could make these arrangements.

 88

1 A I'm the only person with Stop the Steal, LLC. I didn't give anybody else a

2 directorship or officership, or -- and no one else was really given political making powers.

3 So logistics stuff I rely on people I pay, or volunteers who have that in their talent stack.

4 BY

5 Q So just humor me, there appears to be what 20 or so names in the list that

6 Mr. Brown forwards to you on January 4th. Is that right? And you can take time to

7 look it over.

8 A That's what this email kind of shows. And it's an email that I don't recall

9 seeing. I probably -- this is probably in my inbox as unread. And I don't -- I don't recall

10 seeing this, but I also don't see anything wrong with it, so.

11 Q Why would I need that many security folks for January 6th?

12 A Well, I think I've testified on the record already that I needed two at least

13 with my party. And then we just needed bodies for the perimeter of Lot 8 so that it

14 didn't get out of control, because you're not allowed rope lines. So this is about you

15 don't have equipment, what do you have? You have human bodies.

16 Q So these folks were supposed to, like, kind of protect the perimeter of Lot 8

17 on January 6th?

18 A That's what I've tasked Stephen Brown with, and that's why they are

19 coordinating together.

20 Q And these are the Oath Keepers that you talked to Mr. Rhodes about from

21 November of 2020 when you met him in Atlanta --

22 A I'm sorry. I missed it because of the cough.

23 Q These individuals, these are all Oath Keepers, and I'm presuming this is

24 coming from your relationship Mr. Rhodes from November of 2020?

25 A Oh, no. No, that would be the wrong presumption. I don't have anything
 89

1 to do with the Oath Keepers. They are a veterans group that has volunteered services

2 for other speakers associated with me and me. And so, I can't confirm this list the

3 people for you, because I'm not a part of their organization. And the only reason I

4 would think that we would need these names is because, you know -- and look, some of

5 them are missing names. So it is kind of weird to me, it's like that's not my -- that's -- I

6 needed people to watch my stage. If they were Oath Keepers, or if they were Moms for

7 America or whatever, we needed people as a perimeter, because we didn't have a rope

8 line. And you have a lot of speakers, and we have a video camera.

9 I even talked about how it's unlikely that we're going have a large crowd, they will

10 be doing other stuff or other permits. And we have a video where we do a tight shot of

11 everyone and we'll release those videos, so what these people are is about video

12 equipment, staging. And we can call that security -- I don't even know what PSD means.

13 So if somebody wants to inform me on what that means, that will help contextualize this,

14 too.
 90

2 [1:40 p.m.]

3 BY

4 Q So if I were to ask Mr. Martin why he reached out to Oath Keepers, it's your

5 testimony here today that he would say you didn't direct him to do so?

6 A What I just answered was that me and Stewart Rhodes did not come up with

7 this list together, and I can't vet it. And I didn't talk to -- you know, I don't recall talking

8 to Stew a rt a bout th is stuff.

9 Q I'm not focusing so much on the list. I'm focusing on why Mr. Martin sent

10 you this list. Did you direct him to go get Oath Keepers for your security?

11 A This email doesn't say that.

12 Q I'm not asking about the email. I'm asking, if I were to ask Mr. Martin did

13 you direct him to go to Oath Keepers for security, would he say no?

14 A You'd have to ask him what he recalls. I can't --

15 Q I'm asking what your testimony is today.

16 A I don't have testimony on what he'll say.

17 Q Did you direct Mr. Martin to go get Oath Keepers for security?

18 A You said that Nathan Martin sent this email.

19 Q Yes or no, yes or no, did you direct Mr. Martin to go get --

20 A I don't -- I don't recall.

21 Q You do not recall. Okay.

22 A Yeah, I've testified to that.

23 Q Thank you.

24 So let's look at this list. Are you aware that Kelly Meggs, Connie Meggs, Caleb

25 Berry, Kenneth Harrelson, David Moerschel, Jeremy Brown, Graydon Young, Jason Dolan,
 91

1 Joe Hackett, Ben Parker, Sandra Parker, Jessica Watkins, and Donovan Crowl have all

2 been charged by the Department of Justice for crimes committed at the Capitol on

3 January 6th? Were you aware of that?

4 A I'm not aware of that.

5 Q So that's 13 folks on this list that was sent to you by Mr. Martin. So you're

6 saying here today that you did not hear the Oath Keepers throughout the day on January

7 6th discussing any plans for the Capitol on January 6th?

8 A I had very little interaction with the Oath Keepers on all of January 6th

9 because, as the two were with me, I believe, the two came with me to the Ellipse, they

10 weren't sitting with me. I was in the front row for all of the speeches.

11 And they didn't -- I don't believe that they went with me when Alex Jones and I

12 were walking with his security, which was why I was in his security bubble.

13 And I don't recognize any of the Oath Keepers in pictures that I've seen in

14 preparing for my testimony in shots of us. And when I got to the Capitol, not only did I

15 not see them there, they weren't at Lot 8.

16 Q Right. So I guess that didn't answer the question. So you don't recall

17 hearing Oath Keepers talking about their plans for the Capitol --

18 A I didn't have an opportunity to hear any Oath Keepers talking about anything

19 that, you know, that would have lasted more than from, based off my recollection, from

20 the hotel to the Ellipse.

21 Q So you're providing the color without, kind of like what said earlier,

22 you're providing the color without answering the question.

23 A No, I'm answering the question.

24 Q Is it yes or no? Do you recall --

25 A 1do not recall.

 92

1 ~ Thankyou.

2 Do you have any follow-up,_

3 BY-:

4 Q Actually, I just -- I'm a little -- I'm confused. Because when I'm looking at

5 this email, if I understood -- and is far more familiar with this, so forgive

6 me -- but Stephen Brown -- or Steve Brown, excuse me -- was a media agency event

7 planner that Stop the Steal hired, correct?

8 A I hired him.

9 Q You hired him. Okay.

10 And Nathan Martin was somebody that worked for you, correct?

11 A He worked with me, half volunteer. And then when I could compensate

12 him for his travel services or that company, then I --

13 Mr.- He worked at your direction?

14 M r . - Mostly.

15 Mr.- Okay.

16 BY

17 Q And so I'm looking at an email from Steve Brown, somebody that you hired,

18 to you and Nathan Martin, saying: "This is the list of personal security detail" -- and if

19 you don't know what PSD is, that's usually what it means --

20 A Oh, okay.

21 Q -- "we have working with us and their names/nicknames from Signal." And

22 you are completely unaware of this, despite that it's from the person that you hired,

23 addressed to the person that you direct.

24 And I'm just trying to figure out, is it your position that, despite the fact that this is

25 who you hired and this is who you direct, you had no idea that any of this was happening
 93

1 and you never read this email?

2 A What is "any of this"?

3 Q The email, like the arrangement of the personal security detail, you had no

4 idea that Nathan was getting Oath Keepers, you had no idea that he sent this to you?

5 I'm confused, because these are two individuals that you either hired or directed,

6 and I just want to make sure that what you're saying is, "I've never seen this email. I had

7 no idea that they were doing this."

8 A There's like three or four questions stacked in there. So let me in a

9 narrative form try to summarize what I believe I've told this committee.

10 I do not recall seeing this email until today. I still believe that I probably have

11 possession of this email and did not know that I did. And it's probably marked unread,

12 and I gave the context of the date and the time and what I would have been doing.

13 The second thing I'd like to observe is I trust Stephen Brown and Nathan Martin

14 mostly at my direction. You know, I don't know if we want to play around with language

15 or whatever. I'm so unfamiliar with this email I didn't know what PSD means until you

16 told me. And I appreciate that,

17 What I will say is I'm unfamiliar with this list. This is my best recollection first

18 time seeing this list. So when read out the list faster than I could put dots near

19 the name of who was arrested, that's how new this information is for me.

20 And the question I have is, are the two that guarded me that were not with me

21 until -- were no longer with me after 10 a.m., did they get arrested?

22 Q And what I want to make sure is that you're not getting wrapped up.

23 Because what we're not trying to do is trick you. We have an email from people to

24 people. We're not trying to trick you about what the email says or doesn't say.

25 What we're trying to get from you sitting here today is, do you remember the
 94

1 facts and circumstances surrounding the three of you via this email arranging the Oath

2 Keepers to serve as the personal security detail? And if you want to answer it in

3 narrative form, that's fine. I'm really not trying to trick you.

4 Mr. Kamenar. I think he already answered that he doesn't recall this email. So

5 I don't know what more --

6 But I'm not asking him if he recalls the email.

7 The Witness. Why were you referencing it?

8 Well, because sometimes that triggers people's recollection --

9 The Witness. It doesn't.

10 . -- because it was the --

11 The Witness. Not to me.

12 And that's fine.

13 Sitting here today -- forget the email -- do you remember any conversations with

14 Nathan, any conversations with Stephen, about hiring the Oath Keepers to be a personal

15 security detail on January 5th or January 6th?

16 The Witness. I either made the decision or authorized the decision for Oath

17 Keepers, for two to be with me and my party, and then a gaggle.

18 And I do not remember. I mean, this is a big list. Okay? I don't know who

19 came up with this amount of people. It could have been me. It could have been

20 Stephen. It could have been Nathan. It could have been Stewart. It could have been

21 the man on the Moon. Okay?

22 But let me say this. Their job, we can call them security or PSD, I've never called

23 anyone PSD. You won't find that --

24 BY

25 Q Can I stop you right there?

 95

1 A They are perimeter people. They are there just because we can't have a

2 rope line on the Capitol stage. We wanted to cooperate with the U.S. Capitol Police.

3 Q You keep saying you never used PSD. Turn to exhibit 22 for me and go to

4 the second page, please, because on that you literally text, "Means I have 2 PSD guys."

5 The second page on the back. You literally say it. Vet you're sitting here, testifying

6 here today saying you've never used the term PSD.

7 A I don't recall.

8 Q So help me understand that.

9 A Yeah,_ I'll help you understand that.

10 In all of the evidence that we've reviewed today, I don't recall using PSD. This is

11 on the back of a page that we all reviewed together in which, you know, you're saying

12 that Stephen used PSD first and I responded back with his language.

13 Q That's fair.

14 A I'm sorry.

15 Q I want to go back to the email in exhibit 12 that was just talking to

16 you about. You said it's probably in your inbox unread.

17 Which brings me to the point of, how did you search for responsive documents?

18 I'm assuming you searched , right?

19 A I consulted with my attorneys on providing responsive documents.

20 Q And I'm assuming you searched for emails of Nathan Martin since he was

21 working at your direction on January 4th, right?

22 A I worked with my attorneys on providing responsive documents. And we

23 even in a correspondence tried to provide some of the terms that we looked for and

24 asked the committee to specify any particular people that they were drilling down on so

25 that we could do a more expansive search.

 96

1 Q And I have to assume that it would be just the most logical search term for

2 you to go to Mr. Steve Brown, who was getting your permits for you, that you should

3 have found an email from January 4th, correct?

4 A No. Incorrect. What I wouldn't find, because the subject line doesn't say

5 "Stop the Steal" or "January 6th" or "Lot 8 event." To my knowledge, that doesn't say

6 this in this email. Again, I'm being asked questions about something that I don't recall

7 reading and haven't read.

8 Q That's fine.

9 A But what I'm saying is those are terms that we would have used to come up

10 with something like this. And so I didn't grab all Stephen Brown emails if they

11 weren't -- that they didn't fit into House Resolution 503.

12 Q So you didn't search Stephen Brown emails after January 1st and at

13 January 6th, like between that date range? You didn't search for those Stephen Brown

14 emails?

15 A I think we looked -- we tried to look for -- we produced thousands of records,

16 represented by hundreds of pages. There's five volumes of binders here on the table.

17 And we've -- I've literally worked on this full time.

18 And so we've been as responsive as we can. If you said, "This is a subject line

19 that we want you to authenticate ahead of this meeting," I would have done that.

20 Q That's not my responsibility. But did you not search -- I mean, the subject

21 line literally says, "6th Draft Names."

22 A Yes. "6th" is not a term I would have looked for by itself.

23 - Could we ask that perhaps maybe we have a conversation afterwards

24 in terms of the thoroughness of the terms, given this line of conversation, that if the 6th

25 wasn't included in the search emails that may be something that we need to discuss?
 97

1 Mr. Kamenar. Yes, be glad to.

2 ~ Okay.

3 Mr. Kamenar. Also, I believe when we provided documents, Mr. Baron Coleman

4 also said this is what we've found. It's not exhaustive. It's not everything. We'd be

5 glad to go back and recheck to see what may be missing or what was overlooked by a

6 consultant --

7 Yeah.

8 Mr. Kamenar. -- that was hired to look through these search terms.

9 - That's fair. And it might help actually maybe we could give you a list

10 of key words?

11 No.

12 - No, no, no, I know. But to the extent that there's any confusion.

13 Because I think we would have thought the 6th would have been an obvious term.

14 Mr. McBride. Well, we believe that the 6th is an obvious term. And if we

15 looked for it and if we don't have it, we'd be more than happy to take a second look for

16 you.

17 Mr. Thank you.

18 So you said you met -- did you have any follow-up, by the way, ? Sorry

19 about that.

20 BY-

21 Q I just -- one thing, because I think it's really important to understand

22 something.

23 Our job is to find the facts, and sometimes that's just to take the answer from you.

24 Okay?

25 When the report by this committee comes out, it will be so and so said this, so and
 98

1 so said this, so and so said this, right? And what I want to make sure is that we're not

2 putting words in your mouth, that we're not mischaracterizing you. And sometimes it's

3 hard because there's a lot of color added to the answers. So when we try to drill down,

4 it's because we don't want there to be confusion in terms of what your position is.

5 And what I want to make sure, because I'm looking at the exhibit in 12, and I'm

6 looking at the exhibit in 22, and what I see in 22 is a text conversation. And I'm sorry,

7 my eyes are terrible, but it looks like it's between Stephen Brown and somebody named

8 Ali Akbar, who has your picture on it, who's talking about rooms at the JW Marriott that

9 you've admitted that you stayed at --

10 A Uh-huh.

11 Q -- with individuals who are in your room block with a personal security detail,

12 a term that you used, presuming that this is you in this text, with the layers that you've

13 described, with an individual that you hired.

14 And your position is that that's not me on the text and I don't remember this

15 email and I didn't tell Stephen Brown to send this.

16 I'm just -- that's where I'm -- that's what I'm taking away. And I want to make

17 sure that I understand that that's what you're saying. And if I'm wrong, I want you to

18 correct me.

19 A I'd like to refer you to my previous answer.

20 Q But here's the thing. If your previous answer wasn't clear, I have the right

21 to ask you to clarify, which is not "asked and answered," it's a clarification. So if what I

22 just said is wrong, I'd like you to correct me.

23 Mr. Kamenar. Well, excuse me. What you said, asked what was wrong, you

24 had three or four, five things in there. So if you could go --

25 Sure.
 99

1 Mr. Kamenar. -- one by one.

2 After everything that Mr. Childress asked you about the JW receipts,

3 about your personal security detail, I'd like you to answer, sitting right here, that you

4 believe that this is not you in exhibit 22.

5 The Witness. I'm not saying what I believe or don't believe. I'm saying I do not

6 recall this exchange. This exchange lines up with all these other facts.

7 Mr. Kamenar. All right. That's it.

8 BYMR.

9 Q Going back to when you said you met Mr. Rhodes in November of 2020,

10 where did you -- like what was going on where you met him? Was it an event,

11 preplanning an event? What was going on? How did you meet him?

12 A We were in -- I was protesting in Atlanta. And, yeah, someone wanted to

13 introduce me to Stewart Rhodes. And he volunteered to, you know, hey, wherever

14 you're going across the country, if you'll give me a call or have your people give me a call,

15 you know, we'll try to provide you with a veteran.

16 Q What event were you throwing in November when you met him? Or what

17 was -- actually, let me backtrack.

18 Do you not recall the date, the rally or the event you were planning in November

19 around -- what event was it then?

20 A I don't, I don't recall. It was either mid-November, late November, or the

21 first days of December.

22 Q Okay. Was it a rally at the State Capitol in Georgia?

23 A Yes.

24 Q Okay. And what were you protesting at the State Capitol in Georgia in

25 November?
 100

1 A We were lobbying the governor to call for a special session.

2 Q Okay. Does November 18th sound about right, because that was the day

3 that Georgia was supposed to complete the audit and recount? Does that sound about

4 right, November 18th?

5 A That date range sounds around there.

6 Q Did you official -- was this your rally in Atlanta at the Capitol? Was it a Stop

7 the Steal rally?

8 A It was a Stop the Steal rally.

9 Q Did Women for America First have a role in this event?

10 A No. However, at one point in Georgia, and I don't know if it was in this

11 series of events or later that --

12 The Witness. Is that a reporter?

13 I think it's maintenance looking to see if someone's in here.

14 - Sorry about that.

15 ~ Sorry about that. We apologize.

16 Can you please continue with what you were saying?

17 The Witness. I think I was saying -- I'm sorry.

18 No, I'm sorry.

19 We apologize for the record, ma'am.

20 BY
21 Q Just to clarify, we were talking about whether the event on November 18th

22 at the Capitol was with Women for America First.

23 A Definitely not.

24 Q Okay. When you were having this event, were you coordinating with the

25 Trump campaign at this time?

 101

1 A No, I don't believe so. I think going into Georgia after D.C. was a "me"

2 decision.

3 Q What about did you coordinate this even with the White House at all?

4 A How I'm interpreting your question of coordinating is seeking someone

5 else's permission to do something like that as a collaborative effort, and the answer is I

6 made the decision that we would protest Georgia. I formerly lived there, I know the

7 governor, and I wanted a special session.

8 Q I guess let me go back a little bit. That's a great way to get to this.

9 Who have you talked to that works in the White House in December or January?

10 Who do you know in the White House?

11 Mr. Kamenar. Is that a question who does he know or who does he talk to?

12 BY
13 Q Actually, who have you talked to in the White House in December or

14 January?

15 A That's pertinent to the Capitol attack?

16 Q Just in general.

17 A I would really like to stick to the pertinency of the Capitol attack and January

18 6th and not go through my personal life or social dealings.

19 Q So the reason why I'm asking is because throughout the text messages that

20 you produced to us there's the term "White House is telling me" or "White House this."

21 I'm trying to figure out who in the White House is telling you anything.

22 A I described early in the -- in this testimony -- and then I'm happy to go

23 through each one of those text messages one by one and see if I recall something or try to

24 recontextualize it contemporaneously.

25 But in politics, someone can either indirectly tell you something or you'll indirectly
 102

1 hear chatter or they'll tweet about something and put out a press release and someone

2 won't be in the know and you're telling them that they're in the know.

3 What I can say is that I'm just going to volunteer this information, even though,

4 again, I don't think it has anything to do with the Capitol attack.

5 I spoke with White House adviser Peter Navarro on January 5th at our rally, and to

6 my recollection that's my first time ever talking to him.

7 Q Okay.

8 A And, you know, he was at the rally. So I think we spoke for 2 minutes, and I

9 introduced him.

10 You know, I know a lot of people in politics. Some people, like, you know, take

11 leave from the administration or they're in the administration but not the White House.

12 But what I will say is that the people -- you know, I didn't need to talk about the Ellipse

13 and Lot 8.

14 The person that I talked to was Caroline Wren, and to make a duplicative effort to

15 me would seem a waste of resources or my time. I talk to hundreds of people probably

16 a day. I mean, I was like the busiest person in America. I know some people don't like

17 that, but a lot of other people love it.

18 And another gentleman I talked to at the White House was -- and we did talk

19 about election integrity, but I don't recall talking about the 6th -- Garrett Ziegler, who

20 worked for Mr. Navarro. And I know we talked about election integrity. I don't recall

21 talking to him about the 6th or the 5th. And I don't see how he would be in any

22 authority to kind of do anything like that.

23 Q Okay. Okay. When you were doing this rally at the Capitol, did you

24 coordinate it with any Members of Congress?

25 A "We," like this proverbial --

 103

1 Q Yeah, we as in Stop the Steal, which you are the single leader of.

2 A Yeah, yeah. Recruited and attempted to recruit several Members to speak

3 when the Lot 8 event was going to happen and --

4 Q I'm talking about the November rally.

5 A November rally?

6 Q Yeah, the November rally.

7 A Can you establish a nexus between that and the Capitol attack?

8 Q Well, I know you've probably read this, right? But our House Resolution

9 memo allows us to also investigate the influencing factors that fomented the attack on

10 the Capitol on January 6th.

11 And so you've already talked about how Oath Keepers provided you security on

12 November 6th. When asked how you first met Mr. Stewart Rhodes, you said you met

13 him at a rally in November. So, of course, I'm just trying to explore this rally in

14 November that led to you talking to Mr. Rhodes for the January 6th event.

15 A It's not clear to me the nexus between Members of Congress and my First

16 Amendment right to seek redress from them and the Capitol attack or the resolution.

17 And the resolution's pretty wide.

18 Q Are you refusing to answer the question? Are you refusing to answer the

19 question?

20 A I'm not refusing. I'm asking for you guys to establish --

21 Mr. Alexander, we've explained House Resolution 503. And if you

22 need to step out and talk with your lawyers to understand the context of how to make an

23 objection, prior rallies at capitols is absolutely within the purview of investigating a

24 subsequent Capitol attack on January 6th.

25 If we need to step out for you to have that conversation, we will. Our position is
 104

1 it's relevant. If yours is that it's not relevant --

2 The Witness. That helps.

3 . -- you can just object.

4 The Witness. That helps. I didn't have -- I didn't have a Capitol rally in

5 November.

6 You just said November 18th you had a rally -- you had a rally --

7 The Witness. In Washington, D.C., at Freedom Plaza, not the Capitol.

8 Not in Atlanta?

9 Post-election rallies at State capitols are within the purview of our

10 investigation.

11 Mr. Kamenar. Okay. I think we need some clarification. What rally? What

12 date?

13 November 18th rally in Atlanta at the State Capitol that he just

14 said Stop the Steal through.

15 The Witness. You guys have gone back and forth between two different events

16 right now.

17 And you know what? Defer to , like, because he's

18 saying November --

19 The Witness. I'm just very confused.

20 What I was saying is pre-January 6th rallies were relevant to the

21 January 6th rally. is asking you about November 18th, 2020, in Atlanta.

22 Is that correct?

23 - That's exactly right.

24 On November 18th --

25 The Witness. Did I talk to any Members of Congress about Atlanta November
 105

1 18th?

2 BY

3 Q About coordinating that rally with Members of Congress.

4 A At the Atlanta State Capitol, I don't believe so.

5 Q Thank you.

6 A That helped. That helped. I really heard, like, two or three difference

7 questions.

8 Q Thank you. No, that's fine. I'm sorry if we were unclear.

9 - And we will try not to do that. Apologies. That was unintentional.

10 BY

11 Q It's reported that at this event on November 18th that you said, "Who's

12 going to be ready to storm the capitol with us in a couple minutes?" Do you recall

13 making that statement?

14 A I don't recall making that statement.

15 Q Do you recall going in the State Capitol on November 18th in Georgia?

16 A I recall being invited into the State Capitol and coordinating with police and

17 making sure that we weren't too loud as not to interrupt the work.

18 Q Who invited you in?

19 A Representative Vernon Jones, who was a Democrat at the time.

20 Q Yeah. Did any other rally attendees go in with you?

21 A A bunch.

22 Q And what happened when you went inside?

23 A We worked with security to make sure that everyone went in peacefully.

24 There was a gentleman there who wanted to stage a sit-in. And I said, "No, under no

25 circumstances are we going to participate in Antifa tactics," I think I said, or something

 106

1 like that.

2 It was a viral video, because I then got attacked by White supremacists because I

3 called him a hillbilly. And, you know, I probably should have been more artful in my

4 language. But I got attacked for weeks by White nationalists and White supremacists for

5 calling him a hillbilly.

6 But, anyway, I think we had a photo op. We talked to the media. I think the

7 whole -- well, I don't know how long the security process lasted. But being on the

8 capitol steps with the cooperation of Georgia State Police and Representative Vernon

9 Jones, I think that, I mean, it lasted like 10 or 15 minutes. And then we single-filed out.

10 Q Did you also in this time period -- I want to say it's November 21st -- did you

11 go to the governor's mansion in Georgia?

12 A I know that I went outside the governor's mansion across the street, and we

13 held a protest there. I don't know what the date was.

14 Q Okay.

15 A It's usually at night.

16 Q And did you talk to Mr. -- is this when you talked to Mr. Stewart Rhodes

17 about for the first time around this time?

18 A Yes. I think we spoke for the first time -- man, actually I don't know if it

19 was this or a subsequent trip to Atlanta. Atlanta, you know, we were frequently in

20 Atlanta.

21 Q Can you go to page 1 of exhibit 26 from your production? It looks like you

22 say to Mr. Stewart Rhodes in this chat -- and the date, to be clear for the record, is

23 November 21st, 2020 -- "It's Ali Alexander. Can we meet after the governor mansion

24 op?"

25 He says, "You bet, brother. Getting my men fed, and then we'll all be there at
 107

1 the mansion. What's your ETA?"

2 I'm trying to understand, what was the purpose of having the Oath Keepers go to

3 the governor's mansion with you?

4 A So I said, "Can we meet up after the governor's mansion?" I didn't invite

5 them to the governor's mansion. He then later says in this that he's going to show up.

6 We had said earlier that day at the State Capitol, we said let's go protest at night

7 at the governor's -- outside the governor's mansion, peacefully and legally. And so

8 everyone who heard my voice would have heard that. That means I don't think I had

9 met Stewart Rhodes even at this point.

10 Q Okay. So if I were to ask Mr. Steward Rhodes if you invited him to the

11 governor's mansion on November 21st, it's your testimony here today that he would say

12 no?

13 A My testimony is I made a universal public call for people to come to the

14 mansion. I did not make specific calls that I recall.

15 Q Okay. So I want to think big picture here for a second. And you've

16 mentioned that you -- Stop the Steal, I say you, but I mean Stop the Steal had thrown

17 rallies at State capitols after the election, leading up to January 6th. Was there a certain

18 reason why you were having rallies at State capitols?

19 A Yes. That's where the lawmakers meet. And we sought to seek a redress

20 from our government, consistent with Black Lives Matter or Second Amendment

21 supporters or whatever.

22 This happened a lot in the lockdown era. So this is just a ritual. You know, it's

23 probably been, you know, 60, 70 years Americans have been meeting at State capitols

24 and doing Capitol rotunda type protests.

25 And, you know, we only, fortunately, thank God, participated in peaceful and
 108

1 legal, you know, redresses of our government. And we wanted State legislatures,

2 particularly, to call for special sessions. So that's why we were looking for action from

3 the people's houses.

4 Q Got it. And so you said, speaking, like, lockdown. I'm assuming that's

5 COVID lockdown.

6 A Yes, sir.

7 Q Is one of those State capitol protests you're talking about like the one on

8 August 25th where protesters pushed their way past police forces in the Idaho

9 statehouse? Are you familiar with that?

10 A I'm not at all familiar. This is first time I'm hearing of that.

11 Q And you aren't familiar with the December 21st protest in the Oregon State

12 Capitol during a special session where protesters went inside the capitol?

13 A I'm very familiar with that one because I publicly denounced it. I publicly

14 denounced it on Twitter. It was widely reported. This committee should, you know,

15 be aware of that. I think we've even provided documentation to this sort or a statement

16 to this sort. And if not, we can provide a list of that.

17 But I was totally opposed to what happened in Oregon. I remember watching

18 that on Twitter. Came out very early. And I said that those people are not strategic.

19 They're not thinking about the safety of people. And it was just -- it was inappropriate.

20 It wasn't a Stop the Steal event. So --

21 Q Okay.

22 A It wasn't a Stop the Steal event. I want to go on the record with that.

23 Q And I'm going to defer t o - a f t e r I ask just the first question. But

24 for, like, this November rally at the State Capitol, how did you raise the funds to throw

25 this rally? How does Stop the Steal do it?

 109

1 A I gave general tweets where I was, like, you know, hey, if we needed money

2 to, like, mainly flights and hotels and food, water, security, if we were paying for them,

3 signs, rally signs.

4 But there was no staging. You know, we just worked with the police. So we

5 didn't even need a permit there. Our permitting activities were really focused for

6 Washington, D.C., because we took things seriously up here.

7 BY

8 Q Sorry. Let me clarify and ask it at a more granular level.

9 What was the actual mechanism that you used to fundraise? So, like, I think you

10 said you did tweets. There was like a link to a donation page? Like, what was the

11 actual fundraising mechanism?

12 A Oh, yes, it was usually tweets to -- the fundraising platform we were using

13 was Donorbox.

14 Q Okay. Was that all you were using at the time in November, or were you

15 using any cryptocurrency then?

16 A Okay. So Stop the Steal starts on November 4th. And at that point I'm

17 basically alone. There's no Stop the Steal organization. There's me. And I said, "Hey,

18 if you guys want to send me personal donations, I will redistribute this and I'll buy

19 people's flights."

20 And then when we formed Stop the Steal and we provided that type of

21 documentation and finally got to move over to Donorbox, that made me feel easier,

22 because then we were doing something with some organizations, some rhythm. And

23 that's consistent with, you know, whatever.

24 So, however, I collected personal donations for that. I think it was a week. It

25 could have been two.

 110

1 Q Actually maybe we could do this a different way because I really -- I don't

2 want to confuse this. It would help me.

3 Could you do it in a chronological order? Because it sounds like you were doing

4 it. When you started Stop the Steal, it changed. Like, could you tell me at

5 this -- before I was fund raising "X" way and then Stop the Steal happened. Because I got

6 what you were saying, but there was a lot in there.

7 A Okay.

8 Q And it would be easier if you could just timewise how were you fundraising

9 before and then at what -- like, how did it change, at what point? That would be easier

10 for me to keep track of.

11 A At brunch on November 4th, I decided that I was going to help an election

12 integrity movement and that I would borrow from my 2018 protest in Florida, in Broward

13 County.

14 And so when I was like a one-man team soliciting allies, I encouraged my existing

15 customers, clients, and donors to donate for me to do this type of stuff. And then I

16 offered activists to pay for their flights and I said we'll figure it out as we go.

17 I don't know how many weeks it lasted that we kind of had to do that, and I wasn't

18 able to phase myself out. I was on a phone call with Scott Presler and Alexander

19 Bruesewitz where I said, "I could help you guys set this up for 2 weeks, and then I'm going

20 to hand it over to you guys. I don't want anything to do with this, you know, whatever."

21 And I couldn't get out. So what we had to do instead was form an LLC so that we

22 could get a Donorbox and fund raise that way through, until we got deplatformed shortly

23 after the 7th.

24 Q And so help me understand. Prior to Donorbox, when you were saying that

25 it was you or that you were trying, what was the fundraising mechanism before
 111

1 Donorbox?

2 A I had links of it was, like, PayPal or other sites, and that was all, my personal

3 site. And I know there's a screenshot of that in here that is my personal site.

4 Q Okay. All right. So prior to it was the personal stuff. And then as soon

5 as you get Stop the Steal set up, the LLC is able to establish Donorbox. You use

6 Donorbox until you're deplatformed. And then after deplatforming, what are you using

7 after deplatforming?

8 A Well, that's after the 6th. I mean, that has nothing to do with the Capitol

9 attack. But we, you know, we went -- we got a credit card processing company to bill,

10 like, the back-end stuff. I mean, I'm a techie, but this is, like, above my pay grade.

11 Q And just so you know, because I don't want you to think we're asking

12 irrelevant questions, the fact that you may have been de platformed because of your

13 participation in January 6th is actually relevant because how payment processors

14 responded to these events is part of the narrative.

15 That's not necessarily about you. You just got deplatformed. So that's -- it's

16 just a factual -- it's not a comment. It's not a, you know, judgment. It's just the fact

17 that you got deplatformed, possibly because of your role in January 6th, maybe not.

18 I'm just curious, after you were de platformed, were you able to raise money?

19 A Yeah. And I did make the comment to make commentary about

20 deplatforming. I made the comment to say that donations raised after the 6th couldn't

21 have possibly contributed to the Capitol attack.

22 Q Yeah. No, but --

23 Mr. Kamenar. Just answer the question.

24 BY

25 Q Yeah, it would just be helpful if you could answer the question. Were you
 112

1 able to raise money after you were deplatformed?

2 A Yes.

3 Q And, if so, how?

4 A Yes. Like I said, the technical details are above my pay grade. We saw the

5 credit card processor, and they built something custom. And that's on the

6 stopthestealdot -- that was on the stopthesteal or is on the [Link] website.

7 Q Okay. Great. So Stop the Steal through the website, you use a credit card

8 processor. And you're able to directly take donations through that credit card processor

9 through your website. That's perfect. I totally understand that. Appreciate it.

10

11 Q Mr. Alexander, when did you start planning the January 6th events?

12 Approximately when?

13 A I probably actually should have nailed down that date. The date I keep

14 using is I think December 16th.

15 Q Okay.

16 A But I do know I made a public tweet about it.

17 Q Yep. Yep.

18 A And at first people are just going to go to State capitols.

19 Q Okay. So around December 16th, December 17th, it's fair to say you

20 started thinking about the 6th as the next event in D.C.?

21 A I know I made the announcement prior to President Trump.

22 Q Okay. And President Trump made his announcement on Twitter on

23 December 19th. Does that sound about right?

24 A That sounds right.

25 Q That was like the same day you were having -- or I don't know if you were
 113

1 having or participating in the Stop the Coup rally in Arizona?

2 A I --

3 Q Do you recall a Stop the Coup event in Arizona?

4 A We -- well, we had a -- there's a local --

5 Q Uh-huh.

6 A -- Arizona activist who wanted to rebrand the local "Stop the Steal" Stop the

7 Coup. As far as I'm concerned, I was there, Stop the Steal. There were some signs that

8 said Stop the Coup as well.

9 And it's kind of clever. It's kind of clever branding. But I just didn't think it was

10 as catchy.

11 ~ I'm sorry. Before you go on, are you going past the security

12 questions? Because there was one I wanted to cover real quick.

13 You can just ask it.

14 Are you familiar with the First Amendment Praetorian group?

15 Are you getting there?

16 - I'm getting there.

17 I'm so sorry.

18 See, this was my fault. I need to trust , and that is my fault.

19 BY

20 Q While you were planning this Stop the Steal event in Arizona, I believe in

21 your production we saw text messages with Mr. Ed Martin.

22 Who is Ed Martin?

23 A Ed Martin is the -- I think he's a former, like, State house member, State

24 senator. I think he ran for Congress or RNC chair. I forget. But he runs a group called

25 the Eagle Forum.

 114

1 Q Okay. And was he involved with helping you plan January 6th events?

2 A Yeah, he was involved with, you know, a lot of things.

3 Q Can you just -- was he involved with helping you book January 6th?

4 A Well, he was kind of like a mentor. I could bounce ideas off him. He's

5 been in politics longer than me and he knows some Members that I don't know and -- like

6 Senator Josh Hawley. And I don't have a personal relationship with him.

7 So, yeah, he was a guy I got to -- a sound board and then sometimes, you know,

8 we prayed together every morning. And he runs a, you know, he runs the Eagle Forum,

9 Phyllis Schlafly's old group.

10 Q I want to direct you back to exhibit 26 and page 85. The reason why I'm

11 asking about Mr. Ed Martin, on this page -- and I'll just start reading it as you're flipping

12 there. It's page 85. It's before the December 19th rally, on about December 16th.

13 Mr. Martin asks for Congressman Brooks' cell phone.

14 Do you know -- how do you know Congressman Brooks?

15 A What time is this? Oh, here it is. I got it.

16 Mr. Kamenar. Where is it?

17 The Witness. 1451.

18 I know a lot of people in Alabama. I was there in 2010. I think Brooks was

19 elected in 2010. And so I just have a huge grassroots network in Alabama and

20 so--yeah.

21 So did you ever personally talk to Congressman Brooks yourself?

22 The Witness. I think I was sending texts to his office number. And I definitely

23 spoke to his staff. And, you know, we were talking about a Dear -- what in politics you

24 guys know, but what's called a Dear Colleague Letter. Yeah.

25 Okay.
 115

1 I'm actually not in politics. What is a Dear Colleague Letter?

2 The Witness. A Dear Colleague Letter is when a Member of Congress is lobbying

3 for legislation or a legislative fix or action by the executive or judicial branch, and they

4 write to their colleagues. And they say, "Dear Colleague, I want you to support this.

5 These are the good reasons why."

6 And it was widely reported that Representative Brooks started a Dear Colleague

7 Letter around election integrity. And when we caught wind of that, I knew that, like, we

8 need to talk to him team, because we can be helpful in lobbying Members of Congress

9 because a lot of Americans want to participate in the legislative process.

10 Thank you.

11 BY

12 Q Did you work with Congressman Brooks' staff or Congressman Brooks

13 himself in planning January 6th?

14 A In planning January 6th?

15 Q Uh-huh.

16 A The word "planning" to me as an event planner, you know, means like

17 logistics or fund raising and stuff like that.

18 Q I'll rephrase it then. In the leadup to January 6th, did you speak to

19 Congressman Brooks' staff or Congressman Brooks himself?

20 A I believe I spoke to him. I don't think we talked about -- well, we had to

21 obviously ask his staff if he was available to speak. And we talked, you know, we talked

22 about election integrity. Yeah.

23 Q But when you say "we," was it you?

24 A It was me. They had, I think, two staffers on their end on a call.

25 Q Who were the staffers?

 116

1 A I do not recall. If there's a text message that refreshes it, that would be

2 better.

3 Q So it was a phone call. It wasn't a text message, you talked to the staffers?

4 A The staffers, I believe -- I believe it was a phone call. I know that we had a

5 phone call. If I exchanged text messages with the staff, I don't readily recall that.

6 But we definitely had a conference call, me, Ed, at least two of their staff

7 members. And they were telling us about their efforts. And we were like, oh, we can

8 probably be helpful in tweeting this, or, oh, we can be helpful in giving out phone

9 numbers, you know, to Members of Congress' offices so that people know that they need

10 to call their Member of Congress.

11 Q When was this call approximately?

12 A I don't recall. It would have been around when he announced the Dear

13 Colleague Letter is my guess.

14 Q So was this end of December?

15 A It could have been middle of December. It could have been

16 early -- actually -- actually, you know, I don't know when the Dear Colleague Letter came

17 out. It's kind of a blur. It's 12 months ago.

18 Q Okay. But you spoke to, it sounds like, Congressman Brooks after the 2020

19 election, general election?

20 A Speaking to? I don't know that we "spoke" spoke. I know that I sent him

21 messages that were getting -- that I thought were getting delivered that weren't getting

22 delivered. And then I believe I got a message to him. And he sent me some boilerplate

23 stuff or something, or a staff member.

24 But I do know that the substantive part of my relationship -- not relationship -- my

25 interaction with the Brooks office was the call where they got to describe their actions to
 117

1 me and Ed and we got to say, hey, we can tweet about this.

2 Q And when you said, "He sent me some stuff," was this over email?

3 A No, I don't think so, no.

4 Q So how would you send somebody something if it's not over email or mail?

5 Just help me understand, what was sent to you, how was it sent to you?

6 A I mean, it was probably a text message because it wasn't resolving. And it

7 wasn't about January 6th. It was about election integrity. And, you know, and again,

8 to my best recollection, they are telling us what they are doing.

9 And they were doing it independent of me. They were doing it independent of

10 the White House. They were doing what they thought was right.

11 There were several different Members of Congress on different tracks. I thought

12 that was silly. What I wanted to know, I wanted to be a clearinghouse for some of this

13 information and concentrate the effort in a productive, legislative, legal, peaceful way.

14 Q How did you know they were doing it independent of the White House?

15 A Because on the call they were in over their heads. They were, you know,

16 saying -- I asked -- I think I asked, "How many Members?" Again, like, this makes me

17 feel icky because, like, my First Amendment or whatever.

18 But they -- they -- I asked them, I think, you know, how many Members you guys

19 have or something? We're trying to probe the political viability of the issue. And it

20 was a ridiculous answer or something like that. And I was like, "Are you guys working

21 with White House Legislative Affairs? Are you working with anybody who's, like, helping

22 y'all with whip counting?" It was something about whip counting.

23 And whip counting is, you know, counting the expected votes for a piece of

24 legislation.

25 No, no, I watched "House of Cards." I know that one. But I

 118

1 appreciate it.

2 BY

3 Q What was the issue again? What was the issue that you all were

4 discussing?

5 A I know it was something -- it was election integrity. And it was a Dear

6 Colleague Letter. So it will be referenced there. But I don't recall what -- everyone had

7 their own bright idea, and everyone wanted to be a star. Jody Hice wanted to be a star.

8 Ted Cruz wanted to be a star. Mo Brooks wanted to be a star. And then there were

9 team players like, you know, Paul Gosar, who was, like, "Okay, I'll sign onto anything

10 election integrity-wise."

11 Q I don't recall seeing any text messages in your production with anyone from

12 Congressman Brooks' staff. You just said it was probably over text message.

13 A I'll have to get with counsel and see what -- see if there's something

14 responsive there.

15 Q Again, were you searching for various Congressmen's names when looking

16 for responsive documents responsive to the subpoena?

17 A I consulted counsel when trying to find responsive documents and then

18 hired a consultant ultimately when it was in over my head, as you guys know. I had to

19 submit -- well, I've submitted three or four different times.

20 But there was such a dramatic difference between our first production and our

21 second production, because the first production was me trying to understand the House

22 resolution and me trying to provide documents responsive to that.

23 Mr. Kamenar. As we said earlier, this is not a definitive, exhaustive list. We'll

24 be glad to go back and re-check. So I appreciate your pointing these out, and we'll go

25 back to the consultant or whatever to see.

 119

1 ~ Understood. Thank you, Mr. Kamenar.

2 BY
3 Q I'm just pointing out various information that would be responsive to the

4 subpoena that should be searched for in your documents, Mr. Alexander.

5 So at this rally in Arizona, you mentioned marching thousands of patriots going to

6 D.C. for certification on January 6th. What was your plan for January 6th as of that

7 protest on December 19th?

8 A I do not recall. I don't have a copy of that speech. All speeches are

9 impromptu. I think you told me the date is December 21st?

10 Q No. Actually I never mentioned December 21st, but that's a great segue.

11 December 21st, do you recall a meeting between congressional Members and

12 President Trump in the Oval Office?

13 A I wasn't in the Oval Office. So I wouldn't recall.

14 Q Did you call in to the meeting between President Trump and congressional

15 Members on December 21st?

16 A I do not recall calling in to the Oval Office.

17 Q Were you aware of a meeting between President Trump and congressional

18 Members on December 21st?

19 A I do not -- that's an interesting question. I don't recall a specific meeting

20 with Members of Congress and the President. I do know that the President hosts

21 Members of Congress within his own party regularly.

22 Q So it's your testimony here today you did not know about a meeting

23 between President Trump and congressional Members on December 21st of 2020?

24 A I do not readily recall any specific meeting between Members of Congress

25 and the President in the Oval Office. Did not call in to a conference call, to my
 120

1 knowledge.

2 And there were times when, you know, a Member of Congress, like

3 Representative Gosar, if he would talk, you know, to the President or met with the

4 President, might relay some good news back to me.

5 Q Got it.

6 A But I don't know when that was.

7 Q How would that good news get relayed back to you?

8 A I was in Arizona a lot in person.

9 Q I asked, how would it be relayed to you? Was it in person? Was it via

10 text? Was it a phone call? Was it email?

11 A I don't recall, but it would usually probably be me in person in Arizona -- I

12 spent some time there -- or if I would talk to his chief of staff on the phone.

13 Q Got it. Going -- can you flip to exhibit 30, please?

14 I'm just curious. What is your tweet, "Hoping this call changed the world?"

15 What is "this call"?

16 A No idea. I don't have access to Twitter. If I saw some tweets before or

17 after it, I might be able to assign some context.

18 Q So your testimony here today is, looking at this tweet of you saying, "Hoping

19 this call changed the world," with the screenshot of a phone number of

20 , which appears to be a conference line, it's your testimony here

21 today that you do not know what this refers to?

22 A I probably held well over 200 conference calls or participated in them. So I

23 would definitely not know what this one was. But if I tweeted about it, it was a big deal.

24 BY
25 Q__I guess that's where I'm a little confused. I don't -- and I don't profess to
 121

1 remember all of your tweets. But I don't think you tweeted every time that you had a

2 call. And usually when somebody tweets, "Hoping this call changed the world" -- and

3 don't get me wrong. I'm not saying that you didn't think you were changing the world

4 every day. But this seems like a big one, "Hoping this call changed the world." And

5 you screenshotted the number of the call.

6 Take a minute and think. Can you remember what this call was?

7 A This call happened almost 12 months ago, and I honestly do not recall.

8 agree with you on it must have been significant for me to tweet it out. I am prone to

9 hyperbole, exaggeration, and victory laps.

10 Q Okay.

11 A And colorful language.

12 Q We appreciate that.

13 A And I think you should hunt down this number and then you guys tell me

14 who I was on the phone with. That would be great.

15 Actually so, Mr. Kamenar, I'm cognizant of the time. We've been

16 going for about an hour, a little over an hour and a half. Do you want to take a recess

17 now?

18 Mr. Kamenar. Yeah. Let's take a recess.

19 Let's take a recess, and then we'll come back. How about let's

20 just do 5 minutes so we can try to get this over.

21 Mr. Kamenar. We want to get this over as soon as possible.

22 So let's just do like 5 minutes.

23 [Recess.]

24 All right. We're going to go back on the record at 2:33 p.m.

25
 122

1 Q So I want to go back.

2 Mr. Alexander, earlier I believe you said words to the effect of Mr. Gosa r's office

3 or Mr. Gosar was the only Congressman that you had been in contact with. Then we

4 heard information just now that you had been in contact with Congressman Brooks' staff.

5 We heard Congressman Biggs.

6 So I'm going to ask you, what Congressmen in the December-January timeframe

7 were you in contact with?

8 A Here's an answer about Biggs, Representative Biggs. I recall speaking to

9 Representative Biggs in December. We were both speaking at a Christian event, and I

10 introduced myself. We were backstage.

11 He thanked me for my peaceful protest work. I can't recall what all we said

12 except that he had mentioned that he had talked to a group of Republican Senators and

13 that he was optimistic about something. He mentioned Senator Rick Scott by name.

14 I remember being happy about that because my Stop the Steal efforts originated

15 in 2018 to save his Senate seat.

16 So that's Representative Biggs.

17 I provided information about Representative Gosar, you know, Brooks' staff

18 mostly. And I think, you know, there were some of these events where me and a

19 Member of Congress spoke. Mike Kelly was at the November rally. Briefly got

20 introduced to him by Rose Tennent. I don't think that we had a substantive

21 conversation.

22 I asked at one point Ed Martin to reach out to Senator Hawley. His wife was

23 pregnant. He was supportive of some efforts but I think couldn't participate in

24 something that we wanted him to participate in.

25 Q So I want to direct you to exhibit 26 again and text messages that you
 123

1 produced and to page 86. And this goes back to the conversations that we were -- that

2 you were describing with Congressman Brooks' staff, I believe. But I'll allow you to add

3 color.

4 So on December 16th, 2020, after Mr. Ed Martin asked for Congressman Brooks'

5 number, it looks like there -- it looks like outgoing. So this is like you say to him, "Mo

6 Brooks number works." And it looks like Mr. Ed Martin says, "Great." And then it

7 looks like you said back, "He sent me this."

8 Who from Congressman Brooks' staff sent you this?

9 A I'm unsure, but I'm really happy that we provided this document.

10 Q We are, too, yeah.

11 I'm sorry. Are you saying that that was a document attached to the

12 text, or you're saying that you're glad you provided the text that has that language in it?

13 Like when you say, "I'm glad we provided this document," you mean the text or --

14 The Witness. The text message.

15 - Okay.

16 BY
17 Q Why? What is this text message? "He sent me this." Who is "he"?

18 A It either would have been Congressman Brooks or his staff.

19 Q How come we don't see anywhere on December 16th, 2020, in your texts or

20 emails of anyone from Congressman Brooks' staff sending you this message?

21 A Well, I can say that, like, for example, right now, sitting here, I couldn't tell

22 you the first or the last names of Representative Brooks' staffers that I was on the

23 conference call with and had a substantive conversation with. And so if that evaded our

24 search, then that evaded it. But that we put -- that it is, the substance is here, you

25 know, we're happy to provide the actual record when we find it.
 124

1 Q So your testimony here today is that you can't recall anyone on

2 Congressman Brooks' staff that you spoke to in December of 2020?

3 A I provided --

4 Q It's a yes or no.

5 A Yeah, I don't recall.

6 Q Okay. And you didn't speak to Congressman Brooks himself in December

7 of 2020?

8 A Excuse me?

9 Q Did you speak to Congressman Brooks himself in December of 2020? Like

10 you speaking directly to Congressman Brooks. Did you speak to him in December of

11 2020?

12 A I don't believe I verbally spoke to Congressman Brooks. And so if I got a

13 text from this number, that's either him or his chief of staff or secretary.

14 Q Do you recall -- let's put verbally aside. Do you recall in a written form

15 talking to Congressman Brooks in December of 2020?

16 A I'm saying that this message was either from him or his staff.

17 Q And I guess I'm trying to figure out where this message comes from, because

18 we don't see it in your production.

19 A The substance is there. And if we can find a responsive document that I

20 still have possession of -- I don't have possession of everything from December and

21 everything from January of last year. I don't have possession of all those things.

22 Q I'm just trying to figure out who the "he" is in this.

23 A I believe it's -- I believe that it's Congressman Mo Brooks or -- they're doing it

24 again. It's weird.

25 Sorry. Just for the record, someone was up against the glass.
 125

1 Q It's the court reporter.

2 It's a fair concern though. If you see something, please don't

3 hesitate. And we will jump up and check. I appreciate it.

4 The Witness. So the "he" is either Congressman Brooks or his staff. Sometimes

5 in politics it is the Member. Sometimes it's someone representing the Member, and

6 then someone represents that as a third party as the Member. I hope that's not

7 confusing.

8 So help me out then. Show me anywhere in your production

9 where you are speaking to Congressman Brooks.

10 The Witness. We provided, I think, you know, over a thousand text message. If

11 it's not in here and it exists and it's in my possession, I'm instructing my counsel to go

12 over it and look for it with our consultants and provide it?

13 B

14 Q Maybe I could ask a clarifying question. A second ago you said the

15 reach-out may be the Congressperson or it could be their staff.

16 How often is it the Congressperson that reaches out directly to you?

17 A I wouldn't know.

18 Q No, no, I mean just generally, like, how often do Congresspeople call you,

19 text, or email you directly?

20 A That's a rare thing. Most stuff is delegated to staff, even if it's in the

21 Member's name, is what I'm trying to, I think, explain, and I'm not doing a good job of it.

22 Q This is my lack of political knowledge. But I've gotten the impression from

23 some of the folks I work with that it's actually a big deal when a Congressperson calls you,

24 emails you, or texts you in person, like, themselves.

25 Do you agree with that? Like is that your perception of it or in your experience?
 126

1 Because, I mean, I know you're very politically active. Is it not a big deal when

2 Congresspeople contact you directly?

3 It seems it would stick out in your mind.

4 The Witness. Well, I mean --

5 All I'm trying to get at is for some people, because of how politically

6 involved they are, they talk to Congresspeople all the time and have them on speed dial.

7 That is not my world. So if a Congressperson contacts me, it's pretty memorable.

8 I'm trying to gauge, where are you on that spectrum? Are you somebody who

9 talks to Congresspeople directly all the time, or is it more a rarity when you directly talk

10 to the Congressperson?

11 A It's really a mixed bag, depending on the year, whether it's an election year,

12 and then what I'm doing. Because I was leading Stop the Steal, I was one of the more

13 popular conservative figures in the country for 60-something days.

14 And, you know, what you pointed out is a real observation. And I want to

15 acknowledge it. It's not one that I agree with, but it's not one that I dismiss. And I

16 don't know how else to put this except for put it this way.

17 I've been very critical of both the Democrat and the Republican establishments.

18 In some cases I've called the Republican establishment the "Blue Blood, Bowl Cut Boys."

19 And so what's interesting is a lot of these guys go to Ivy League schools, or they'll

20 come and intern on the Hill. They'll do five internships, and I didn't have to do that.

21 Now, what's interesting is it's an inverse relationship. When I talk to a Member

22 of Congress, oftentimes I'm not impressed. I'm just speaking truthfully. That's why

23 I've never gone in and worked in government. Some of them are not impressive people.

24 But there are a lot of people who have a wealth status far above mine who are enamored

25 by it. And it's interesting.

 127

1 So I would say it is special when I talk to a Member of Congress. But it is not

2 unique and it's not -- and while I was leading Stop the Steal, you know, I was just very

3 popular. It's like, you know, I was leading a cause that Members wanted to be

4 associated with.

5 So are you saying that, during that 60-day period when you were

6 leading "stop the steal," that you so frequently talked directly to Congress people that

7 you can't remember those occasions that you talked to them.

8 The Witness. I'm not saying that. A lot of my work was at the State legislature

9 level and with bureaucrats that are either unelected or elected; it was really at the State

10 level. And there have been periods in my life, like during the birth of the Tea Party

11 movement or other things that I've done, where it's like, oh, I could talk to a dozen

12 Members in a week. And that's impressive for some people. And that's -- you know, I

13 work my ass off, so I've earned it.

14 Mr. Kamenar. I think the witness has basically described his interaction with the

15 various Congressmen when you went down the list, did you talk to this one? He said, in

16 Arizona, he had a personal --

17

18 Q I think that's -- Mr. Kamenar, let me go off that.

19 Can you go to exhibit 3 for us? This is it looks like the [Link] website

20 and it looks like an advertisement for "stop the coup," the rally you are talking about in

21 Arizona, December 19th, and on it their speakers, including you, Congressman Andy

22 Biggs, Congressman Paul Gosar. Who communicated with them to be speakers on

23 December 19th?

24 A Adele (ph) is the local organizer there. And so it probably would have been

25 a mixture of, like, one of these faces I don't even recognize or know who is.
 128

1 Q Who is Adele (ph)?

2 A Adele (ph) is a Phoenix-based entrepreneur who shared our concerns about

3 election integrity and was organizing there. And I was introduced to him by

4 Congressman Gosa r's chief of staff and told he was doing good work on the ground

5 preceding my physical arrival.

6 Q How did the individual on Mr. Gosa r's staff -- or actually who was the

7 individual on Mr. Gosa r's staff who introduced you to it looks like Mr. Adele (ph) Belgate

8 (ph)?

9 A I just stated that it was Congressman's chief of staff.

10 Q So Mr. Van Flein?

11 A Yes.

12 Q I didn't see that in your production. Was it in person, or was it a text

13 message?

14 A On a phone call.

15 Q On a phone call?

16 A Yeah.

17 Q And what was the nature of this phone call? Why was Mr. Van Fie in

18 introducing you to Mr. Belgate (ph)?

19 A Because we were -- they were going to host a hearing, I believe, I don't know

20 if this is this date or another one, but my first physical trip out to Arizona -- again, I don't

21 know if that's December 19th or not -- was to be in support of a legislative hearing of,

22 like, Republican caucus members. And I needed people on the ground to coordinate

23 with, you know, because like, okay, I've got to get picked up from the airport. I need to

24 get signs. I need to encourage bodies there. I need to know, like, what's the situation

25 on the ground.
 129

1 Q So, at this rally, do you recall saying that you'd been on the phone with State

2 legislatures and people from the White House? Do you remember making that claim

3 during this speech on December 19?

4 A I don't remember any of the contents of my speeches from December.

5 Q Would it be unusual for you to say that you were on the phone with State

6 legislatures and people from the White House?

7 A No, that would not be unusual.

8 Q So, on December 19th, what people from the White House were you in

9 contact with?

10 A I don't know who I was referencing. Mary -- maybe it was Garrett Ziegler.

11 Q I don't see Garrett Ziegler in any of your productions. Was it a phone call --

12 A We --

13 Q I was going to say was it a phone call, was it a text message, or was it an

14 email?

15 A I believe having the phone call with him. I don't remember receiving any

16 emails from him.

17 Q Okay.

18 A I don't remember receiving any text messages from him. And we did have I

19 think one -- one, you know, physical interaction in D.C. and, you know, small talk.

20 Q How did you have Mr. Garrett Ziegler's phone number?

21 A I don't know who passed it along to me.

22 Q Okay.

23 Can you go back to exhibit 26 at page 81? These are text messages. So we're

24 going to move a day past December 19th. We're going to go to December 20th of 2020.

25 And this is a text message to Mr. Alex Jones.

 130

1 Mr. Kamenar. What's the exhibit?

2 Exhibit 26, the text messages. And that's going to be page 81.

3 Mr. Kamenar. Here we go. You find it?

4 The Witness. Yeah.

6 Q So you found it? In your text message, you say, "POTUS is deciding in the

7 next 24 to 48 hours if he wants to go all the way." What does "go all the way" mean?

8 A No idea. I'm talking with Alex Jones, who is prone to hyperbole, and it

9 looks like I was, you know, buttering him up.

10 Q I mean, just, it might be hyperbole, but what is "go all the way" in context

11 to?

12 A I have no idea.

13 Q So it's your testimony here today that, on December 20th, when you're

14 telling Mr. Alex Jones that POTUS was going to decide within the next 24 hours to go all

15 the way, you have no idea what the context of that statement was?

16 A It is my testimony that, sitting here today, 11 and a half months later, that I

17 don't know what this text means. And I don't even know who would have told me.

18 And, in context, me talking to Alex Jones, it seems kind of humorous. And I see later

19 that Alex sends me again a hyperbolic title to one of the videos he made that he wants

20 me to promote. It is just the nature of our relationship.

21 Q Did you have any contacts with anyone from the White House on December

22 20th to base this text on?

23 A I'm not sure.

24

25 Q Could we go back for one second. A second ago, you said it is the nature of
 131

1 your relationship. I don't want to mischaracterize, but it sounds like you said, "The

2 nature of our relationship is to send hyperbolic things to each other, and then we retweet

3 them out, and we promote each other's hyperbolic things"? There is nothing illegal

4 about that or wrong --

5 A I think so.

6 Q -- with that. I just don't want to mischaracterize what he's saying.

7 A Yeah, yeah, yeah. He's -- he loves comedy, he's extreme. He's funny.

8 He's self-deprecating, and he uses clickbaity things. And, you know, sometimes I'll

9 venture into that territory. Most times I don't, but, clearly, you know, we have some

10 evidence in production that, you know, shows that I sometimes engage in hyperbole and

11 exaggeration and, you know.

12 That's very helpful color. Thank you.

13 BY

14 Q Going back to this, or we're going past December 20th to December 21st.

15 We've asked you if you recalled a meeting with Congressional Members and President

16 Trump. You said that you do not recall that meeting, correct?

17 A Correct.

18 Q Do you recall receiving a debrief about that meeting?

19 A I don't recall one. I don't -- today, right now, I do not recall receiving one.

20 I have -- I have volunteered in my testimony that, you know, there was some times, like,

21 for example, when Paul Gosar had a conversation with the President or the White House

22 and then, you know, it would be some big news or something like that.

23 Q Okay. But, for this specific situation, you don't recall this debrief from

24 Mr. Gosar?

25 A No, that's a very specific date, and I don't even know that he was there.
 132

1 Q Not date, I'm talking about the meeting.

2 A Yeah.

3 Q Do you recall Mr. Gosar debriefing you about a meeting with the President

4 on December 21st?

5 A No, I don't recall that.

6 Q Okay. You made a comment you don't even know if he was there. Can

7 you flip to exhibit 33 for us, please? So this is a December 21st tweet. And I apologize;

8 the date is not on here. But Mr. Gosar says: Great meeting today with real Donald

9 Trump and Mark Meadows and Rudy Giuliani, my homies Andy Biggs, Rep. Mo Brooks,

10 Matt Gaetz, and others, President is resolute. We will not accept disenfranchisement of

11 80 million who cast a vote for POTUS. This sedition will be stopped.

12 You don't recall getting a debrief about this meeting that Mr. Gosar tweeted

13 about?

14 A There is no date on this.

15 Mr. Kamenar. He said December 23rd.

16 Mr. 20 -- 21st.

17 Mr. Kamenar. 21st?

18 Mr. Yes, that's when the date is.

19 Mr. Kamenar. Oh, I'm sorry, I thought you said 23rd.

20 BYMR

21 Q Okay.

22 A I definitely don't recall this.

23 Q You don't recall this?

24 A I definitely do not recall this.

25 Q Okay. Okay. So we move past December -- I am just moving

 133

1 chronologically now for your planning for January 6th, just to give you an idea. Right?

2 So you have the idea around the 16th or 17th. You spoke about it at your rally on

3 December 19th. I just went through the texts with Mr. Alex Jones on the 20th. You do

4 not recall the congressional meeting on the 21st.

5 So now we're going to move to the One Nation Under God permit. You told us

6 that Mr. Stephen Brown -- you hired him to help you do it seems like planning for the

7 January 6th. Did you tell him to file for a permit for January 6th in Washington, D.C.?

8 A Yeah, I have no idea how to do that by myself.

9 Q That's fair. No, that's fair.

10 So why did you -- did you direct him to file the permit or apply -- do the permit

11 application under One Nation Under God?

12 A I know we had consultation about it. And I believe that -- we had a

13 consultation about it, and I don't know how we decided on the name. But, like I said,

14 One Nation Under God was a coalition effort of "stop the steal," which is itself a coalition,

15 and then other Christian and Jewish groups.

16 Q If I were to ask Mr. Brown whose decision it was to file the permit under One

17 Nation Under God, it's your testimony here today that you all discussed this together and

18 made the decision together?

19 A That's why I hire consultants, yeah. They consult me, and then I make a

20 decision on what I'm comfortable with based off of expertise that I don't have.

21 Q So, look, I'm saying so is it your testimony here today that, if I were to ask

22 Mr. Stephen Brown whether he consulted you on filing this application under One Nation

23 Under God, his answer would be yes, right? That's your testimony?

24 A I believe so.

25 Q Okay. So the date on the application was December 21st, 2020. Why did
 134

1 you file for the application on December 21st, which happens to be the same day as the

2 congressional meeting with the President?

3 A We -- the horrible thing about all of this was that I announced that we are,

4 instead of doing State capitals, we're going to go to Washington, D.C., and that our voices

5 will be peacefully heard outside. That's on video. And, when the President announces

6 it -- I believe the 19th is when his tweet was -- was a Friday late afternoon, and all of the

7 permitting offices were closed. So that was stupid on my end because I either hadn't

8 talked to Stephen Brown or we hadn't decided on where we wanted to -- where we

9 wanted to do it because I was so busy in the States.

10 And so the 21st would have been the first available date in which my consultant

11 would have had the information or the wherewithal at the time to have filed this. This

12 is, you know, my understanding of it all.

13 Q Why did you file under One Nation Under God and not under "stop the

14 steal"?

15 A Because, as I've said before is -- I even said this at the event where I

16 appeared with Representative Andy Biggs, is that "stop the steal" could not just be

17 political; it needs to be a Christian ministry as well. And that some groups didn't

18 consider themselves political; they just wanted to pray over Democrats and Republicans,

19 but they wanted to participate. They thought it was historic. And so we called it One

20 Nation Under God because we also thought, well, you know, we don't want to over

21 advertise this. And there's other events happening right by us that we want people to

22 feel comfortable going to. If you see a big fat "stop the steal" logo, then we would be

23 taking away from other people's events. I wanted to share the love.

24 Q What did you mean by "over advertise this"?

25 A Just logistically, if the President of the United States is saying come to D.C.,
 135

1 then all of those people could not attend my event. I wanted them to be able to attend

2 other events as well. We didn't "stop the steal."

3 Q Who is in control One Nation Under God?

4 A One Nation Under God is a pseudonym. And, as I understand it, based off

5 what my consultant told me, is that on permits the event name and organization name

6 are synonymous with each other.

7 Q So there's no one who's in control of One Nation Under God that could give

8 Mr. Brown permission to file this permit under that name?

9 A It's a -- it's more of an event name. Like, for example, I believe that I

10 participated in an anti-CCP, pro-Uyghur event, and, like, on their application, it will say

11 the event name under organization -- from my understanding when you're dealing with

12 these agencies, you know, these consultants tell you it doesn't have to be a (c)(4) or

13 (c)(3). It doesn't have to have a board of directors; it just can be an event name.

14 Q I'm not following.

15 Can you go to exhibit 36 for me, please? This is going to be the actual

16 application you submitted. And I know everything is double sided, but go to, like, the

17 fourth physical page of exhibit 36. And box 1 says, "organization and/or spokesperson."

18 You just said it could be the event name. Where in box 1 does it say it can be the event

19 name?

20 A Well, as I just testified, that's what my consultant told me that that's a norm

21 within it. And I didn't fill out this application; my consultant did.

22 Q So, if I were to go ask Mr. Stephen Brown whether it was his decision to put

23 One Nation Under God as the organization and/or spokesperson, your testimony is that

24 was his decision?

25 A My testimony is that we came up -- after talking with one another, we came

 136

1 up with that.

2 Q So you had some input in putting One Nation Under God as the organization

3 and/or spokeperson?

4 A Yes.

5 Q Why? If it wasn't an organization or a spokesperson?

6 A I just told you what the norms are for these applications that I have not

7 seen.

8 Q Where did you get these norms from?

9 A The highly credentialed expert, Stephen Brown.

10 Q So, if were to ask Mr. Stephen Brown whether he told you the norm is that

11 you could put One Nation Under God in box 1, your testimony is he would say yes?

12 A Yes. I'm not even aware that there was a box 1. I didn't see a copy of

13 these applications before they're submitted.

14 Q Were you trying to keep the term "stop the steal" off the application?

15 A I'm -- I wasn't opposed to having a "stop the steal" branded event until I

16 thought we got a crappy lot. There are other patriots who have done great work that

17 deserve some of the audience. I can't fit everybody. And that was my main

18 consideration, to my best recollection, of why we chose to do something, in addition to

19 the Christian and the Jewish groups that did not want -- you know, it is the last electorial

20 day for us.

21 Q So, if you go to exhibit 32, and I would direct you to the second page, the

22 second physical page. These are text messages between you and Mr. Stephen Brown.

23 The --

24 A You said 32?

25 Q Yep, exhibit 32.

 137

1 A The second page?

2 Q The second physical page.

3 A I don't have a second page.

4 Q On exhibit -- sorry. I must have misspoke. 34, I read the wrong tab, so I

5 apologize. It looks like you text Mr. Brown, "I will have the team make separate One

6 Nation Under God graphics in case the cops ask you for a copy of promo so you can deny

7 Wild Protest being totally affiliated or whatever." It looks like you're trying to hide

8 Wild Protest and your involvement with this application. Why?

9 A I don't think we're trying to hide it. Again, we're trying to disperse the

10 crowd. And he had called me and said he needed to submit a graphic advertisement,

11 but also that he advised that we not -- you know, that we not -- not like over publicize

12 One Nation Under God. And so, I said, okay. I'll have it done, because either he was

13 going to have to have the graphic work done and charge me or I can get volunteers to do

14 it.

15 Q Help me understand how, on the day of January 6th, it's your testimony here

16 today that you were trying to direct everyone to Lot 8. "I want to get everyone off the

17 grounds. Need to go to Lot 8." But now you're testifying, "I wanted everyone

18 dispersed." Help me understand that difference --

19 A -- great question. So, as I'm walking -- as I'm walking and I am standing on

20 those chairs, I'm still under this stupid belief that my event can take place, that all of this

21 can be just deescalated and chilled out. By the time I ever make it to the northeast side,

22 we're just trying to get people away from the building. And so whatever you have to say

23 to get people away from the building, including "there's an alien, there's free burgers

24 over there," you have got to get people away from the building. They were

25 ignorantly -- a lot of people, what I observed personally, were ignorantly

 138

1 participating -- for whatever reason, they were ignorantly participating in being in areas

2 that they had no business in.

3 Q So, in the lead up to January 6th, you were trying to minimize "stop the

4 steal's" involvement to have people dispersed. Correct?

5 A I wanted to share -- I definitely wanted, you know, as full a crowd as we

6 could have. And, as I understood it -- again, my consultant is telling me sometimes you

7 can have more people, and sometimes the cops will give you a warning, but they won't

8 just tell you to disperse without a warning. And that is what I'm aware the norms are,

9 and I just thumbs-up that.

10 Q But, on January 6th, you're not telling people to disperse onto various lots.

11 You're telling them to go to your event on Lot 8. That's correct? Right?

12 A I'd refer you to my answer before my last answer, which is that it happens in

13 two different sections. When I first see the conflict, and what I'm trying to do is get

14 everyone over to Lot 8 because I ignorantly believe that, even though this is a little

15 collapse of civil authority, we'll still be able to have our event. When I run into the U.S.

16 Capitol Police officer or I don't know if he was the U.S. Capitol Police or the D.C. Metro,

17 but I talked to a gentleman on the north side. He also says, "Go that way, go that way,

18 go to the east and north." So he's also -- the cop is reiterating what we've just

19 reiterated, that makes me feel good. When I crossed the corner on to the east side and

20 I am expecting a peaceful people in my stage and instead what I see is people on the

21 plaza, people on the grounds, people on the Capitol, then I realize, oh, it wasn't just the

22 west side that had essentially collapsed, but the east side had collapsed. I wasn't aware

23 of that. Then it was, like, tell people to go to Lot 8 because it is the farthest point away

24 from the physical building.

25 Q Did you ever file any other permits, and let's just cabin it between November
 139

1 of 2020 and January of 2021, under the name One Nation Under God?

2 A I'm unaware.

3 Q So why do it now?

4 A I think I've described why we did it.

5 Q So to disperse the crowd is why you did it for January 6th?

6 A We had political and spiritual considerations, that's first. And the second is

7 I did want to share the love there. There were other organizers. There was an

8 anti-CCP group, there was a Defend Medical Liberty group. And these people needed

9 people and bodies, and we possibly could not fit all of them. And we had lost a third or

10 a quarter of our schedule when we moved the event at the behest of the Ellipse rally.

11 Q So it's your testimony here today that you weren't trying to mask the

12 involvement of "stop the steal" when you filed this permit?

13 A Not in any meaningful way. And I --

14 Q It doesn't have to be in a meaningful way, just in any way. Were you trying

15 to mask "stop the steal's" involvement when you filed this permit on December 21st?

16 A I don't recall that. What I recall doing is following the advice of my

17 consultant. And I do note there was an exchange between the officer and my

18 consultant in which we disclosed that "stop the steal" and Ali Alexander involved in One

19 Nation God, so I would not call that hidden.

20 Q Okay. So going back to this --

21 BY-:

22 Q Wait.

23 Mr. Alexander, I need to you look at exhibit 34. And I need you to look at the

24 second page because there are ramifications to some of your answers today. And I

25 need you to read your text, "I will have the team make separate One Nation Under God
 140

1 graphics in case the cops ask you for a copy of promo so you can being deny WildProtest

2 being totally affiliated or whatever." And we're going to ask you again, was it your

3 intent to put the permit under One Nation Under God to mask WildProtest being

4 affiliated with "stop the steal"?

5 A My intent was what I have stated, which was there is a political and spiritual

6 consideration. There was a consideration --

7 Q I'll make it even easier, because maybe there's some confusion. Did you

8 put the permit under One Nation Under God so that, if the cops ask for a copy, the person

9 receiving this text -- let me just make sure, Nathan -- could deny that Wild Protest was

10 affiliated with "stop the steal"?

11 A That was --

12 Mr. The group chat with Mr. Nathan Martin, Mr. Stephen Brown, and

13 yourself.

14 Mr. McBride. What page is this on?

15 Mr. It's on the second page of the exhibit --

16 Ms. The second page in the middle.

17 Mr. McBride. Sorry. The second physical page?

18 M s . - Yes. I'm sorry. The second physical page.

19 BY-:

20 Q There is like a tweet, and then it says, "I will have the team make separate

21 One Nation under God graphics in case the cops ask you for a copy of promo so you can

22 deny WildProtest being totally affiliated or whatever."

23 So I will make this as clear and simple as possible, did you put the permit under

24 One Nation Under God so that, if the cops asked for a copy of the promo, they could deny

25 that Wild Protest was affiliated with "stop the steal"?

 141

1 A The text message does not deny a relationship between Wild Protest and

2 "stop the steal." WildProtest had outdated information on it that was no longer true

3 and we could not update in time because of the, you know, the moving the events. My

4 intention was to do the right thing with the expert advice of my consultant. I do not

5 have an expertise in permitting or the process. I am only informed of that process

6 through my consultant. And I could only approve recommendations that I was given.

7 And the last consideration that I'd ask you to make is that -- is that there are a lot

8 of isolated things and, you know, that could look damning. But it is my understanding

9 from what my consultant told me and then what I've later read in congressional

10 testimony, that even if it was -- if we said, "Oh, this is "stop the steal."' and we wanted to

11 keep out the Christian groups and the Jewish groups, or we wanted all the people, that

12 they couldn't deny it, they couldn't deny the permit. So I wasn't scared of getting

13 denied a permit, if that's the question.

14 Q My question was about this text. But you actually raise a really good point

15 that it doesn't actually say affiliated with whom. It doesn't say affiliated with "stop the

16 steal." But the next two texts say: The application's under the name One Nation

17 Under God. I also included Nathan's name on it. I kept yours off so you're below

18 anybody's radar.

19 Was there concern that the affiliation with you would be a problem and so you

20 didn't put you on the permit for that reason?

21 A Not that I'm aware of.

22

23 Q So, if I ask Mr. Stephen Brown whether you directed him to put Mr. Nathan

24 Martin's name on the application instead of yours, your testimony is that you did not

25 direct him to do that?

 142

1 A This message says that he directed --

2 Q 1asked you, if I were to ask Mr. Stephen Brown whether you directed him to

3 put Mr. Nathan Martin on the application to keep your yours off of it, he would say no?

4 A I don't recall.

5 Q You do not recall giving Mr. Nathan or Mr. Stephen Brown any directions

6 about putting Nathan Martin's name on the application instead of you?

7 A I don't recall. I'm reading this text message and --

8 Q I'm not talking about the text message. Is it your testimony that you do not

9 recall giving Mr. Stephen Brown any directions to put Mr. Nathan Martin's name on the

10 application instead of yours?

11 A I do not specifically recall giving direction. I got consultation with my

12 expert consultant on this matter, and he sends me a text about it. And I acknowledge it

13 right here.

14 Ms. So it's your testimony that your consultant told you to put the permit

15 under One Name Under God?

16 Mr. McBride. I think that's an unfair characterization of what he said. I also

17 feel like we've answered this question several times, several different ways.

18 Ms. I will be candid with you.

19 Mr. McBride. Sure.

20 Ms. I am really concerned. This one spoke for itself. We thought we

21 were just clarifying what they were trying to mask. I really didn't think we were going to

22 be debating the masking. So I want to be really careful that we are not

23 mischaracterizing, because this one I thought was a softball of it says what it says. It's

24 pretty clear they are masking. We just wanted to get what is it that you're trying -- what

25 are you afraid of the affiliation will be if the cops ask. Maybe that's the best way to ask
 143

1 it.

2 BY

3 Q What was the concern -- who were you afraid the cops would think that it

4 was affiliated with?

5 A That's a good question, because I can't imagine what the concern would be.

6 Q I think you can; your "stop the steal," you change it to One Nation Under

7 God.

8 A We did not change it. That did not happen. That's factually incorrect.

9 Q Your organization was called "stop the steal." At the time that the permit

10 was obtained, One Nation Under God I don't believe previously existed, and then it

11 suddenly exists for the permit.

12 A That's the event name, which is synonymous, and this is what I am telling

13 you. My consultant says -- and my own observation and experience tells me that this is

14 true. So my consultant is not lying to me. If someone throws an anti-CCP, pro-Uyghur

15 event, then in line one what they put is yadda, yadda, yadda. Now, I don't it even know

16 what the applications look like the permit applications look like, and it is a working

17 process until the day of. So it's not a permit. It's an application, and there are all kinds

18 of amendments or whatever. I'm not really concerned about that. There are some

19 things that you can't do, and then there are other things that are political considerations.

20 And I'm not worried about that because to me what I have heard from my consultant

21 based off his conversations was they were aware, based off of Trump's tweet, that

22 hundreds of thousands of people were going to be on the Capitol. My consultant told

23 me that based off a conversation that he had with the U.S. Capitol Police.

24 So I'm not worried that we're disguising anything. And that we are following the

25 rules. We never changed the name. We have an event to accommodate people.

 144

1 And that is a one time, one shot -- we weren't going to continue One Nation Under God

2 after that.

3 BY MR.

4 Q So, t o - point, the application has 50 people as the number of

5 attendees. There is a text message on page 1 of the same exhibit 34 that we've been

6 talking about where you say, "What's your say 500 people." So whose decision was it to

7 put 50 people as the number of attendees on this permit?

8 A It was based off consultation. I don't know that I ever, you know -- I was

9 told that -- I was told that these lots are allotted 50 people. If more people show up and

10 it is not a problem, there is no disbursement order. If more people show up, there is

11 either a warning or for those people to disperse and that the event itself could continue.

12 Q Was it you or Mr. Stephen Brown's decision to put 50 people on the

13 application for the number of attendees?

14 A Oh, I think that was the U.S. Capitol Police.

15 Q So it was the U.S. Capitol Police's idea to put 50 people on --

16 A 1 didn't talk directly to them. But my understanding is that the advice that

17 they give to anyone who is applying to the permit is that if you say for -- this is what I

18 heard, okay? This is total hearsay. But it's like if you say, "Oh, I'm going have 200

19 people," then they say, "well, you can't apply for 200 people. You can apply for 50

20 people." So we made sure that we had under 50 speakers so that we could comply.

21 And I made sure that we had a camera man so that if we had no crowd and everybody is

22 at everybody's else's event, we would still have our speakers, our camera, and we would

23 get our moment.

24 Q So, I mean, kind of what said, I thought this would be kind of a

25 layup here. Go back to page 4 of exhibit 35. Estimated number of participants, it says
 145

1 50. Date of application --

2 Sorry, exhibit 35. I will give you a second to get there.

3 The Witness. 35 or 34?

4 Mr. 34. No, no, 36, 36. Sorry. 36, page 4, it is your application

5 that was filed on December 21st, 2020.

6 Ms. - I'm sorry, hard copy 4 not --

7 Mr. - Hard copy 4.

8 Ms. - I'm with you.

9 BYMR.-:

10 Q It says: Estimated number of participants, 50. You're saying that's the

11 Capitol Police's idea to put that down?

12 A That's the guidance that the U.S. Capitol Police gave everyone that they

13 talked to is what my consultant and other people told me, and I was informed of it.

14 Q Is it advice, or is it that you only can hold an event with 50 or less people?

15 A That's not true. And that's not been my experience at all.

16 Q So, again, when you put 50 down on this application, it is not the U.S. Capitol

17 Police filing this application. It is a fake entity called One Nation Under God, instead of

18 "stop the steal." Why did you make the decision to put 50 on this application?

19 A I didn't make that -- I didn't -- I didn't fill out this application. I don't have

20 the expertise to fill out this application. I don't have originating information that would

21 enable me to fill out this information. And One Nation Under God is not a fictitious

22 entity, as I've described here before. It is an event name. And that is a norm that

23 honors our First Amendment in the application process for decades.

24 Q You just said one One Nation Under God is not an entity; it is a name of an

25 event. So it's not an entity. And I want to ask you so we're clear on the record, is it
 146

1 your testimony here today that you did not direct Mr. Stephen Brown to put 50 on this

2 application for number of participants?

3 A I could not have independently, to my knowledge, directed him to fill out

4 something in accordance with rules and conversations I wasn't having.

5 Q All right. So, if we ask Mr. Stephen Brown, "Did Mr. Ali Alexander tell you

6 to put 50 on the application for the number of participants," your testimony here today is

7 that you did not?

8 [Discussion off the record.]

9 The Witness. Yeah. Based off my recollection, I provided with -- with how I

10 understand in hindsight that number was come up with. I have no recollection of that

11 number, you know, previously except for to say that me and the consultant had

12 conversations or the consultant had conversations with other people, and I hadn't seen

13 this application until months after January 6th.

14 - I'm sorry. That first part was word salad for me. I think we got to

15 go back. Can we reread question, and then just ask him to answer it?

16 And I apologize that may have just been --

17 The Witness. No, it's my fault.

18 It did not just register with me. I'm so sorry. I hate to ask you to

19 do that.

20 [The reporter read back the record as requested.]

21 The Witness. I apologize for making the answer more complicated than it

22 needed to be. The short answer is I do not recall.

23 Ms.

24

25 Q Do you recall discussing the number of attendees with Mr. Stephen Brown?
 147

1 A I vaguely recall broad conversations about attendees and ways we could

2 remain compliant.

3 Q Ways you can remain compliant by keeping the number of attendees under

4 50, because that's what the Capitol Police policy was at that time?

5 A I don't recall.

6 Mr. Can we have a brief recess, please? And come back in 10

7 minutes, please?

8 Mr. McBride. Sure.

9 [Recess.]
 148

2 BYMR.

3 Q We will go back on the record at 3:29 p.m.

4 Going back to exhibit 34, Mr. Alexander. The second physical page. I just want

5 to make sure we're clear. You say, quote/unquote, "One Nation Under God graphics in

6 case the cops ask for a copy of promo so you can deny WildProtest being totally affiliated

7 or whatever." In this text, "you can deny" refers to Mr. Stephen Brown, correct?

8 A I'm sorry. I didn't hear the last part of your question.

9 Q "You can deny," the "you" in "you can deny" refers to Mr. Stephen Brown?

10 Correct?

11 A I believe so.

12 Q So that Mr. Stephen Brown can deny Wild Protest being affiliated with the

13 One Nation Under God event? Is that what this is saying?

14 A I don't know that that's what this is saying.

15 Q What other plausible explanation could this be saying?

16 A It could be about him and his persons.

17 Q Is Mr. Stephen Brown affiliated with WildProtest or "stop the steal"?

18 A He's more so affiliated with me. And I think that that's why, when you said,

19 did "stop the steal" hire him, I said I hired him.

20 Q Let's use our common sense in the ways of the world. You hired

21 Mr. Stephen Brown to file this application. Correct?

22 A Yes.

23 Q And he's the one communicating with the Capitol Police about this

24 application. Right?

25 A Yes.
 149

1 Q So he's the one fielding questions from the U.S. Capitol Police about the

2 application. Isn't he?

3 A Yes.

4 Q So it would be common sense for him to be able to deny Wild Protest's

5 affiliation because he is the one speaking to the U.S. Capitol Police. Isn't he?

6 A I don't know. I think -- I think it's like a leap and a jump. And I don't

7 know. And I don't recall these conversations.

8 Q Do you recall ever texting Mr. Stephen Brown for him to put, in quotes, 50

9 people on the application?

10 A No, I do not recall that.

11 Q And, since Mr. Stephen Brown is talking to the U.S. Capitol Police, if we just

12 flow down to the next message so that he can deny to the Capitol Police WildProtest's

13 affiliation, he can also deny your affiliation by putting Nathan Martin's name on there.

14 Does that make sense?

15 A No. I don't want my name as any point of contact for any vendor, logistics,

16 anything like that, because people calling me would slow me down. I was concerned

17 about political remedies, legal remedies, and legislative remedies. So it was a question

18 of who handles what things and who -- I handle the political things. I had consultants to

19 handle other things. And I couldn't afford to be the point of contact for the JW Marriott

20 or travel arrangements or anything like that.

21 Q So, for this, you are saying that because if he would have put your name on

22 there, you would have been the point of contact for the Capitol Police? Is that what

23 you're saying?

24 A Yes. I would have had to be able to field questions. I didn't have time to

25 field questions from anyone. And I don't have the expertise to field those questions
 150

1 about the permit.

2 Q Was it Mr. Nathan Martin's expertise to field questions about the Capitol

3 permit?

4 A It's not his expertise, but he had the time.

5 Q So is your testimony here today that you put him, Mr. Nathan Martin, on the

6 application so he could field questions from the Capitol Police about the permit?

7 A No. That is not my testimony, and that is not what this piece of evidence

8 says.

9 Q I mean, you just said, "I didn't want to put myself on there because I didn't

10 have time to field questions. It is not my expertise," but you put Mr. Nathan Martin on

11 the application to field questions. What is Mr. Nathan Martin fielding questions for?

12 A I said as a general rule for all "stop the steal" activities.

13 Q I am talking about this permit.

14 A I know.

15 Q Why did you put Mr. Nathan Martin on this application?

16 A I didn't put him on the application.

17 Q Why did you instruct Mr. Stephen Brown to put Mr. Nathan Martin on this

18 application?

19 A I don't know that I instructed him to do that.

20 Q So it is your testimony here today that you did not instruct Mr. Stephen

21 Brown to put Nathan Martin on the application?

22 A I don't have any recollection of that. And I haven't been presented with

23 any evidence that says that I directed that.

24 Q It is a yes or no. Do you recall telling Mr. Nathan Martin -- Mr. Stephen

25 Brown to put Nathan Martin on the application?

 151

1 A I don't recall.

2 Q And, even though Mr. Stephen Brown says on here, "I also included Nathan's

3 name on it, I kept yours off so you are below anybody's radar," it is your testimony here

4 today that you did not direct him to do that?

5 A That is my testimony, that I am not aware that -- his message to me is my

6 message to him.

7 ~ Do you have any follow u p , _ ?

8 I guess I just want to clarify something. It is not a crime to put a

9 different name on a permit. It's not a crime to necessarily keep your name off of a

10 permit. What is a crime is to sit here in front of us and lie about what happened, about

11 the facts of what happened. So, when we're looking at a text that says from you, "I will

12 have the team make separate One Nation Under God graphics in case the cops ask you

13 for a copy of promo so you can deny WildProtest being totally affiliated whatever," and I

14 ask you, did you put the permit under One Nation Under God so that you could deny

15 Wild Protest being affiliated, and your answer is "no" or "I don't recall," which we

16 cannot -- maybe put that one aside. Is your answer -- I just want a yes or no to that

17 question. Did you put the permit under One Nation Under God -- and I'm literally just

18 going to read this -- so that you could deny Wild Protest being affiliated with the event?

19 Mr. McBride. Ms. •, I'm sorry. I don't understand the question.

20 Ms. We have asked lots of questions around this.

21 Mr. McBride. Sure.

22 Ms. - And I'm literally just asking him.

23 Mr. McBride. Did he send the message?

24 Ms. • No, no. I think he admitted that he sent the message. I asked him,

25 did he put the permit under -- did they, I will say "they," put the permit under One Nation
 152

1 Under God so that they could deny WildProtest was affiliated? That seems like a very

2 straightforward --

3 Mr. Kamenar. But he's also testified why he called it One Nation Under God

4 because of the religious coalition aspect. Okay? So that's already --

5 Ms. That's fine --

6 M r . - He said, to clarify, Mr. Alexander said he put One Nation Under

7 God because he wanted to put the name of the event instead of the name of an

8 organization.

9 Mr. Kamenar. Right. And he also testified that that is common practice with

10 respect to filling out permit applications, which he did not fill out, but which his

11 consultant filled out.

12 BY

13 Q So I just want to confirm that. It's your testimony here today that putting

14 the event One Nation Under God the event name instead of the organization name was

15 told to you by Mr. Stephen Brown? Is that your testimony here today? Or was

16 consulted or advised or told or informed by Mr. Stephen Brown to put One Nation Under

17 God, the name of the event, instead of the name of the organization on the application?

18 A That's my recollection.

19 BYMS

20 Q And now I will go back to my question, because what is common is maybe

21 changing names on permits. But what's not common is telling somebody, in the event

22 that you get asked by cops, you can deny an affiliation. So what I am asking you is, did

23 you put the One Nation Under God permit -- excuse me, did you put the permit under

24 One Nation Under God so -- I'm quoting from your text -- in case the cops ask, you can

25 deny WildProtest being affiliated? I'm literally just asking if you were telling the truth
 153

1 when you put this text -- those are your words, aren't they?

2 A I don't recall this text. And so I don't know --

3 Q I'm not asking if you recall. Are you sitting here today saying that is not

4 your text? Because your text says what it says.

5 A The text says what it says. So what I'm telling you, you guys asked me to

6 give my complete answer based off of recollection, and I do not know that this text

7 represents a complete answer so that if I positively affirmed that, that that would be the

8 complete reason why the series of events happened with the permit. So that's why I'm

9 saying I do not recall. And I'm trying to be forthright. I am trying to -- maybe I add too

10 much stuff.

11 Q There's a lot of reasons why you might think it would be good for somebody

12 to be able to deny Wild Protest being affiliated. There could be a lot of reasons for that.

13 I honestly don't -- there's a myriad number of reasons. The why is separate from the

14 question that I'm asking.

15 A Okay.

16 Q Which is, in this text, you say, "I'm having them make separate graphics,"

17 and the permit ends up under One Nation Under God. Everything is under One Nation

18 Under God, not your name, and not "stop the steal." And you say, "In case the cops ask

19 you, you can deny WildProtest being affiliated." And all I'm asking you is, was it your

20 intent to do that so this individual could deny an affiliation with WildProtest, whatever

21 the reason is for it?

22 A I don't -- I don't know.

23 Mr. Kamenar. Did we establish what WildProtest, that's in caps, is that the name

24 of a particular --

25 Mr. - [Link], and please correct this, Mr. Alexander, refers to

 154

1 your WildProtest website and an event you were planning on January 6th?

2 Mr. Kamenar. Okay. I just wanted to make sure that was the name on the

3 website.

4 Mr. It is affiliated with "stop the steal."

5 BYMR.-:

6 Q Mr. Alexander, do you recall having a planning call with Congressional

7 Members on January 3rd?

8 A Do I recall having a --

9 Q A phone call of some sort with Ms. Wren and Congressional Members on

10 January 3rd?

11 A If that was the -- if that was the planning call with all of the speakers, then I

12 recall that that call took place. A call with just Members and Ms. Wren, I do not recall

13 that happening.

14 Q So there was a call that happened on January 3rd with all the speakers, and

15 that included Congressional Members?

16 A Did it?

17 Q I'm asking you, did it include -- you just said, was it a call that included all the

18 speakers -- was there a call on January 3rd that included congressional speakers and Ms.

19 Wren and yourself?

20 A I don't -- I don't --1 don't recall.

21 Q You don't recall having this call?

22 A I don't --- no, I recall the call taking place. I don't recall who was all in

23 attendance.

24 Q So you don't recall there being any Congressional Members in attendance on

25 this call?
 155

1 A I don't recall who was on the call, but myself and Caroline Wren who spoke.

2 Q Okay. Can you go to page 164 of exhibit 26? That's your text messages.

3 A You said page 164?

4 Q Yes. Ms. Wren says to you, "Who are the Members of Congress that were

5 on who can help lead the coalition to organize buses of their colleagues?" To clarify,

6 this is on January 3rd. And you respond, "Gosar, Lance Goodman, Lauren B, Marjorie,

7 and maybe Congressman Kelley at a minimum were on." It appears Mr. Wren loved it.

8 So I'll ask you again, do you recall Members of Congress being on a call with you

9 and Ms. Wren on January 3rd?

10 A I don't recall. And I think this text message, it's asking about -- it's not

11 asking about their presence on the call.

12 Q So go then to page 163, the page right before it. The bottom with Ms.

13 Wren. Actually, we can start in the middle. The time of it is January 3rd around 5 p.m.

14 You are all are talking about an 8 p.m. call.

15 A Uh-huh.

16 Q Do you see that? It's on January 3rd?

17 A Uh-huh.

18 Mr. Is that a yes?

19 The Witness. Yes.

20 BY
21 Q Okay.

22 And then it looks like Ms. Wren says, "Great." And this is around 6:30. She

23 says: Great, everyone will be muted, but unmute yourself early. I'll credit you with

24 blah, blah, blah. Say don't bug her and say she's here to thank everyone for unity blah,

25 blah, blah. That's what you say.

 156

1 A Yeah.

2 Q And then, at 6:28, Ms. Wren says: Ha, ha, ha, okay, perfect.

3 So now we're going to go to page 164.

4 At around 7:33, it appears this is after the call of some sort. I don't know if the

5 time is accurate. I don't know what the time here is. It looks like she says, "Who are

6 the Members of Congress that were on," referring or assuming the call, "who could help

7 lead the coalition," and that's when you respond, "Gosar, Lance Goodman, Lauren B,

8 Marjorie, and maybe Congressman Kelley."

9 A So I don't know that the call is over at this time. I do know that Caroline

10 Wren exited the call after her portion and she was at the front of that call. And I

11 frequently type and am on the phone. I multitask.

12 Q So, as you sent the message "Gosar, Lance, Goodman," that's at 7:34. And

13 it looks likes, either 7:34, 7:35, Ms. Wren says, "Great call. Thanks." So, within a

14 minute of you saying it. So it looks like the call was over at this point.

15 A Her portion is most certainly over. I can't testify here today that I know

16 that the call was over.

17 Q So let's not talk about whether her portion -- do you recall Congressmen

18 being on this call?

19 A No, I don't.

20 Q So is your testimony here today that, on January 3rd in a call, it appears with

21 Ms. Caroline Wren, that you were not on a call with Members of Congress --

22 Mr. Kamenar. He didn't say that.

23 BY
24 Q Okay. Were you on a call with Members of Congress on January 3rd with

25 Caroline Wren?
 157

1 A We invited Members of Congress and/or their staffs. I don't know who was

2 in attendance, because I don't believe that there was a roll call. So I don't recall because

3 I don't believe I can recall.

4 Q How did you know to send her the names of those Congressional Members?

5 A Those were Members or their offices that we had definitely invited.

6 Mr. Do you have questions?

7 BYMR.-

8 Q Mr. Alexander, I apologize; I was gone. I think your opening statement says

9 you prepared for 120 hours to testify today. Is that right?

10 A Yes.

11 Q Okay. And so, as part of that, I imagine your effort was to try to recall the

12 events around January 6th and the days leading up to it.

13 A I mean, that gets into, you know, what I talked about with my attorneys.

14 Q I didn't ask about your attorneys. It is just about the fact that you were

15 trying to recall the events and the day of January 6th and the days leading up.

16 A We've done a lot of documenting. And I've tried to do some recalling, but

17 it was, you know, it's a lot of little details that people expect me to remember that I can't

18 possibly remember 12 months later.

19 Q And is it part of your normal course to talk with speakers before an event, I

20 imagine?

21 A Yes.

22 Q So it would be in the usual course that you would at least a day or two

23 before the event set up a call to talk about expectations for the event with the speakers?

24 A Either them or their point person.

25 Q Fair enough. But the point is they need to know what the event is going to
 158

1 be about, logistics and that sort of thing. Is that right?

2 A Or their point person will transport them and tell them 5 minutes before

3 they take a mike.

4 Q So, given that you had invited people to speak on January 6th at Lot 8, you

5 would at least acknowledge that it would have been part of your practice to set up a call

6 with the invited speakers or their point people?

7 A Yes.

8 Q So this text message at least looks like that's what that call was, whether you

9 remember or not, that's what it looks like?

10 A And I'm saying that that's what it was.

11 Q It was.

12 A Okay.

13 Q And so, when you say you don't recall who was on the call, you at least

14 acknowledge that the call took place?

15 A A call most certainly took place.

16 Q And so why did you ask Ms. Wren to be on the call?

17 A She was there as the Trump campaign representative, as much as I

18 understand it, and had details that I did not have about VIP this or that.

19 Q Details about what event that you did not have, because your event was Lot

20 8. Right?

21 A The Ellipse event and the Lot 8 event, so it is the day's events.

22 Q Were the Kramers on this call?

23 A Don't believe so. I didn't invite them.

24 Q Okay. So we talked about the invited speakers, and I apologize if you

25 covered it, but were these people invited for the Ellipse, Lot 8, or both?
 159

1 A Some -- some couldn't possibly be Lot 8 because if I'm talking or someone

2 else is talking to a com ms director or a chief of staff or a Member, then they couldn't

3 possibly. So it's a combination of either/or.

4 Q By that point on January --

5 Mr. This is the 3rd.

6 Mr.

8 Q So, on January 3rd, you already knew no Members were going to be

9 appearing at your event on Lot 8?

10 A Yeah, I believe so.

11 Q Okay. And that's because of the timing of the event being that it was going

12 to be during the certification vote?

13 A Yes.

14 Q Okay. So, if it -- as of January 3rd, you believed you were still organizing

15 the speakers for the Ellipse rally?

16 A I was -- yeah. I was still -- I was still participating in all of that organizing,

17 and all of these text messages established that.

18 Q And so is it that you don't remember the particular Members of Congress

19 that are on or their staff?

20 A I don't recall nearly anyone else who was on this call other than me, and

21 Caroline Wren, because it was a large call. I believe that I invited all the speakers.

22 There were a lot of speakers so I wouldn't be able to do a roll call with you on who

23 attended and who didn't or who sent a surrogate or who didn't.

24 Q Of the people in the text message at least, the Members who are there, who

25 are the ones who you had a connect with directly to either them or their staff? And you
 160

1 can look at a text, whether you remember them or not, but go through the names. So

2 start with Paul Gosar. I think you talked about that -- him. Is that right?

3 A Yes.

4 Q So that would have been through his chief of staff Tom Van Flein?

5 A Yes.

6 Q Any other names you can remember?

7 A No.

8 Q Okay?

9 A I did mention earlier in my testimony that I met a staffer or two in Arizona.

10 Q You don't recall the name?

11 A Right.

12 Q And I don't see -- I mean, you've been through your texts. You don't see

13 any texts with anyone that appears to be --

14 A No, no. Definitely not.

15 Q Lance Goodman, do you know?

16 A I don't know him personally. I don't know that we've ever spoken

17 personally.

18 Q Who within your orbit would have -- you would expect would have reached

19 out?

20 A He has a consultant.

21 Q What's the consultant's name?

22 A Alexander Brushwitz (ph).

23 Q And so if Representative Goodman was contacted, you would have expected

24 it to be through Mr. Brushwitz (ph)?

25 A Yeah, or it might have been another party like Brushwitz (ph) to his comms
 161

1 director or something like that. That's my expectation.

2 Q Do you know how to spell Brushwitz (ph)?

3 Mr. We can follow up.

4 Ms. - Common spelling.

5 BYMR.-

6 Q All right. So then Lauren B within the text message, I read that as

7 Representative Boebert. Do you as well?

8 A I think so. And I don't remember if that was a contact with Alexander or

9 with someone else.

10 Q But not yours?

11 A No. I don't think I've ever exchanged two words with her.

12 Q You say Marjorie is the next name. Is that right?

13 A Yes.

14 Q Who is that?

15 A Congresswoman Greene.

16 Q Do you have any direct contact with her?

17 A I don't believe so. I know that we've, you know -- I think we've, you know,

18 once at the Trump Hotels exchanged pleasantries or an introduction.

19 Q Enough that you were on a first name basis with her?

20 A No. I just think that she's awesome.

21 Q That's fair. But you refer to her in the first name as just shorthand?

22 A Yeah.

23 Q Did you have any contact with any staffer of hers or campaign?

24 A Alexander was her consultant.

25 Q Understood. And then Congressman Kelly. Did you have any direct
 162

1 contact with Congressman Kelly?

2 A I'm not sure. Rose Tennent was his contact.

3 Q I think you covered that.

4 I think that's --

6 Q Do you remember who arranged this call on January 3rd?

7 A I believe that I was the person who initiated this call.

8 BYMR

9 Q Were any representations made by Ms. Wren about the expectation for the

10 events from the White House or campaign perspective that you remember?

11 A I really -- I -- I don't recall.

 163

2 [3:51 p.m.]

3 BYMR.-:

4 Q What did you, at the time, understand to be the expectations for the

5 speakers and what they would speak about at the event?

6 A A lot of details were in flux. So what we wanted to do was communicate,

7 not set things in stone but to communicate because there were a lot of moving parts.

8 remember Wren talking about where the VIP entrance would be, and I don't know if she

9 talked about the locale or the process or -- or what.

10 BY

11 Q Okay. So moving to January 4th, right. So it's January 3rd, and now it's

12 January 4th. Do you recall speakers being changed, or being notified that speakers were

13 changed from your original list for the January 6th Ellipse rally?

14 A I don't recall.

15 Q You don't recall being told by Ms. Wren on the evening of January 4th or the

16 morning of January 5th that there was a new group of speakers that would be speaking

17 on January 6th? I'm not referring to the text messages. I'm just asking if you

18 remember.

19 A I don't remember. I don't remember at all. I remember every day there

20 being significant changes in logistics and/or speakers for either event.

21 Q Who was communicating these significance changes to you around January

22 4th or 5th?

23 A Caroline Wren.

24 Q And what was her -- and what was her reaction, or her mood as she was

25 communicating these changes to you?

 164

1 A I don't know what her mood was.

2 Q Was she telling you someone that was making these decisions about the

3 changes? Who was she saying was making these changes?

4 A I can't recall.

5 Q You can't recall if it was the White House making these changes?

6 A Yeah, I can't -- I -- there were changes every day. And I can't recall a

7 specific change.

8 Q I guess I'm just trying to understand. If there's changes being made to a

9 program that you're helping Ms. Wren with, it makes common sense that you'd want to

10 know why the changes were being made. So what was your understanding at this point

11 of why these changes were being made?

12 A That's an easy mistake to make. But it's not -- the Trump campaign is a

13 bigger fish than me. So it actually would not be common sense for me to give a rebuttal

14 or ask for a reason why if I wasn't already provided one.

15 Q So you thought it was the Trump campaign making these changes?

16 A She was there as a representative of Trump World, and I was there to keep

17 them happy and be a team player.

18 Q You weren't aware if Ms. Katrina Pierson was making changes to the speaker

19 list?

20 A I -- I don't know if I had direct knowledge or not. I had suspected that

21 because of Ms. Pierson's previous relationship with Women for America First and her

22 advocacy for them and things that had happened in prior events that got disrupted, that

23 there was interference going on in Trump World and that Katrina Pierson was likely a

24 source of that or a part of that.

25 Q So when you say interference going on in the Trump world, are you referring
 165

1 to the Trump campaign like you say with Ms. Wren? Is that what Trump world is?

2 A Trump world, it's -- it's -- you know, I don't know.

3 Q So Trump world, your testimony here today, can include the Trump

4 campaign and the actual White House? Is that fair to say?

5 A Yeah, I think I'm using it in the same way that the press uses it. So it could

6 be RNC. It could be the Trump White House, it could be the Trump campaign. And it

7 could be joint fund raising committees that they have any influence over.

8 Q So your understanding: Why would Ms. Katrina Pierson or Women for

9 America First be running interference on your speakers around this time?

10 A They don't like several of us. In November, we had a call with Ms. Katrina

11 Pierson, me, and Kylie Kremer before our D.C. rally, I think November 14th, in which she

12 had tried to -- would seem like misrepresent a position in the White House. That stuck

13 out to me because I knew she wasn't employed at the White House.

14 Q What was she trying to misrepresent to you about the position of the White

15 House?

16 A That -- that they didn't want the term "Stop the Steal" to be used. Instead,

17 they wanted -- there was another coalition going on and they wanted -- they wanted the

18 rest of us to kind of fall in line behind that.

19 Q So I saw text messages of that with Ms. Kylie Kremer where she was telling

20 you to stop using the term "Stop the Steal." Why was it your understanding that this

21 was not the representation of the White House?

22 A Because Katrina does not work at the White House. And then when I

23 immediately confronted her that one of the President's children had recently just

24 tweeted that, and that a either -- yeah, I think an RNC official had just tweeted that, that

25 that couldn't possibly be true, that if I was kind of the last to find out, then these other
 166

1 people, in a closer orbit of the President would surely be in the know. And shortly after

2 that call, another official tweeted it.

3 So it was strange. It was obviously untrue. When I confronted her, then she

4 said, "Oh, well, I just walked out after meeting with chairman -- Chairwoman Ronna

5 McDaniel."

6 And I don't like Ms. McDaniel. So I wouldn't follow that advice, even if the

7 President told me what to do.

8 Q But in this text message, it appeared like you were alluding that you knew

9 from directly from the White House that they liked the message Stop the Steal. So who

10 in the White House was telling you that they liked the term "Stop the Steal," or were you

11 just relying on a tweet?

12 A I don't -- I don't recall.

13 Q You don't recall anyone from the White House calling you about Stop the

14 Steal in November?

15 A No. I -- what I recall is that there's RNC officials and people with the last

16 name Trump tweeting #shopthesteal, and that the President's longtime advisor, Roger

17 Stone, had come up with the term to kind of save an RNC delegate fight. So I just knew

18 it could not be true. And I've got a good read on the President usually. And, you

19 know, sometimes I'm wrong. But I've done a lot of commentary and analysis on his

20 behavior sometimes, and that's why a lot of people followed me on Twitter.

21 Q So what is your view today on December 9th of 2021 of why certain speakers

22 that you were advocating for didn't end up speaking at The Ellipse on January 6th?

23 A Considering all the press reporting that I've read?

24 Q Just tell us what your view is. Why did your speakers not speak on

25 January 6th?
 167

1 A I'm unsure, and I'm still investigating that, because it's something that

2 greatly concerns me.

3 BY

4 Q Did Ms. Pierson call you directly at some point and tell you that you wouldn't

5 be speaking at the event?

6 A No.

7 Q Did she ever contact you directly to tell you that your associates wouldn't be

8 speaking at the event?

9 A Certainly not.

10 Q All right. So your expectation, I think as you covered early, just so we

11 know, the morning you walked in on January 6th was that at The Ellipse was that you

12 would be speaking.

13 A Yes, and that's why I wore suits. It was only one of four times I wore a suit

14 during the whole 60-plus day thing. It's why I showed up early. It's why I worked my

15 ass off.

16 BY MR

17 Q Do you recall recording a video where you said you were the person who

18 came up with January 6th, the January 6th idea with Congressman Gosar, Congressman

19 Brooks, and Congressman Andy Biggs? Do you recall saying that?

20 A I do recall saying that.

21 Q So when did you come up with this idea of Congressman Gosar,

22 Congressman Brooks, and Congressman Biggs?

23 A I think that was a synthesis based off of interactions that I've given this

24 committee that includes the Brooks staff call about the Dear Colleague Letter, Andy Biggs

25 and me talking in December, and, you know, generally me having a good relationship with
 168

1 Dr. Paul Gosar, and him being very supportive of an effort that involved peacefully

2 protesting outside.

3 Q So just to continue part of that statement, you say we four schemed it up.

4 And just to make sure we're clear here: You all, the four of you never sat down or got

5 on the phone call and schemed up January 6th, correct?

6 A I can definitively say that the four of us did not get on a conference call

7 together.

8 Q Okay.

9 A Or any type of messaging service and scheme it up like that.

10 Mr.~ Just so I -- what was the January 6th scheme? When you say that,

11 what do you mean?

12 The Witness. I meant that instead of -- the general tenor was that December

13 was the last time people were going to travel to D.C., and that people were then going to

14 protest on January 6th at their State capitals, and that seemed like a wasted opportunity.

15 So when I ran the idea by Congressman Gosar and he's, like, you know, Yeah, that would

16 be a good idea, then I felt that it was a really good idea. And we wanted to primary bad

17 Republicans was our chief cause.

18 Mr. - You said it sounds like --you said that sounds like a good idea.

19 When did you speak to Congressman Gosar?

20 The Witness. Probably when I was in Arizona. We both spoke at that rally

21 on -- on -- that you pointed out in Arizona. So I don't know if it was before then or if it

22 was -- or if it was on that day.

23

24 The Witness. No, I don't -- I don't know if it was in person or on the phone.

25 BYMR.
 169

1 Q Okay. So you're saying you talked to Dr. Gosar and said to the effect of we

2 should have people come to D.C. to protest on January 6th.

3 A Yes, we definitely spoke about that.

4 Q Okay. And he said that was good idea?

5 A Yes.

6 Q Was anyone else, do you recall, a part of that conversation you had with

7 Mr. Gosar?

8 A I don't recall.

9 Q Did you ever have a conversation with Mr. Van Flein along the same lines

10 about January 6th?

11 A Yes.

12 Q And he agreed it was a good idea for people to come to D.C. to protest that

13 day?

14 A I don't -- I don't recall what he specifically said at all.

15 Q Did you understand him to be in agreement though?

16 A That's my understanding of it.

17 Q Sure. And when you talked to Mr. Gosar about this -- or Dr. Gosar,

18 apologies -- what was the plan that you talked about in terms of how the protest would

19 play out, where it would be, and what would be done?

20 A That it would be somewhere -- I think initially, it was, like, just anywhere in

21 D.C. and that -- and it could have been that we had talked about the Capitol Grounds, but

22 I'm not sure.

23 And what we talked about was that there were some soft Republicans that were

24 leaning towards voting the same way that the House Freedom Caucus was voting, the

25 majority of them, and that having that many people who are your door knockers and
 170

1 phone bankers and small donors, that some of those Republicans would come to our side,

2 that we'd probably still lose, you know, short of a miracle.

3 But we'd lose, but we'd lose doing the right thing. We'd lose doing the legislative

4 remedy and that -- and that 2022 would be kind of like a Tea Party year where we primary

5 bad Republicans.

6 And I've said as much in those same speeches where I characterize coming up with

7 the idea of January 6th.

8 Q And did Mr. Gosar help you in anyway, or Dr. Gosar, with planning for your

9 event in January -- on January 6th?

10 A I don't know.

11 Q You don't know whether he provided you any help?

12 A It seems overly broad. And I don't want to, like, misstate, you know.

13 Q What did he do regarding January 6th that you're aware of?

14 A He was supportive of it. He tweeted in favor of it and --

15 Mr. You're basing your statement he was supportive off of it based

16 upon tweets, right?

17 The Witness. No.

18 Mr. - So what other support did he provide to you then?

19 The Witness. No, I -- I -- you said -- you're asking two -- you're mixing up two

20 different things in your questions. I can attest to his support because I'm a primary

21 source to him telling me he supported it. And then I'm saying what he -- and then, you

22 know, counsel asked what did he do to potentially help? That's different, you know.

23 And I said, well, I do recall that he tweeted about it. If he did anything else, I don't

24 recall.

25 BY
 171

1 Q Would he have worked with anyone else in your orbit, other than you, to

2 provide help?

3 A That would probably be a question for him because I don't recall and

4 because, like, for example, The Ellipse was a coalition event. If he was talking to

5 someone else additional, then I don't have any recollection of hearing that third-hand.

6 Q How about Mr. Van Flein? Did he do anything, to your knowledge, in

7 connection with the events of January 6th to help organize, or otherwise put that

8 together?

9 A He made sure that his boss was going to be there on time.

10 Q All right. And then when it comes to Mr. Brooks --

11 Mr. Brooks.

12 Mr -- I know if we can just hone in. So you think that was when that

13 you talked to him, or it was about the Dear Colleague Letter?

14 The Witness. I remember talking to his staff around the time of the Dear

15 Colleague Letter. And then, you know, in an exchange with the committee, I provided a

16 copy of something that was either sent by Mo Brooks or his staff, or secretary. And the

17 text of that is in here, and we've said that I'm going to work with my counsel to provide a

18 timestamp or something for that?

19 Mr. Not a timestamp. The actual communication of when you

20 received that.

21 The Witness. Okay.

22 Mr So when Mr. Brooks says he's never met you or never met or spoke

23 with you, is that true?

24 The Witness. I think that we met in 2010, you know, at the Tea Party years.

25 think it was likely.

 172

1 Mr So if he had met you, to your memory, it would have been 11 years

2 before January 6th -- excuse me -- yeah, 11 years before January 6th.

3 The Witness. Yeah, we haven't shared a room together in my knowledge, and

4 been in physical proximity, you know, since then in The Ellipse?

5 Mr Or talked, right? Does that include talking? You and --

6 The Witness. No, this was -- the message that I sent to Ed Martin was,

7 again -- and I don't know if it was sent by him or someone, a representative of his, and

8 who had the authority to talk, you know, because of the conversation I had with his staff.

9 And that, to my knowledge, is our only interactions.

10

11 Q And then Mr. Biggs, again, can you put a finer point on that just so I

12 understand? When would that conversation about January 6th have taken place the

13 first time?

14 A So we didn't -- I don't know that we talked about January 6th specifically.

15 In fact, I don't think that we talked about the date, you know. I don't think so. And I

16 don't think you were here. But I talked about we had the Jericho march which is a

17 Judea-Christian event that Stop the Steal did in which, again, kind of like, you know, it

18 wasn't a Stop the Steal event. It was a Jericho march event that Stop the Steal was a

19 part of, and that's how these events work.

20 And the day after that, there was another opportunity to speak. And I found

21 myself backstage with Congressman Biggs. And he had said that he had talked to U.S.

22 Senators and conveyed, that he conveyed his optimism about whatever. And he

23 mentioned Rick Scott. So I remember optimism and Rick Scott.

24 Q But that's the extent of whatever involvement, to your knowledge, he had

25 with January 6th when you were speaking about it?

 173

1 A Yes. And this Arizona event, he was supposed to appear at it. And then I

2 think he was stuck in D.C. or something like that. And I got a hold of a video, and I

3 played it on my phone on the microphone.

4 Q But that -- but that's it in terms of when you say that you schemed together.

5 That's as far as it goes.

6 A Yeah, because, again, when I'm publicly taking credit for it, what I'm trying to

7 do is contrast the disinformation campaign from, you know, people who consider

8 themselves, myself -- myself their rival for no reason.

9 And I'm synthesizing that Paul Gosar and I are thinking about the mechanics of it.

10 Andy Biggs is saying that there's juice with some soft Senators. And Mo Brooks is doing

11 this Dear Colleague Letter. The synthesis of that is that we are seeking a peaceful

12 legislative remedy that would occur on January 6th, that could legally allow the vote for

13 the certification of the electoral college, or the protest thereof, to occur at a later date, or

14 later that date or lose, and our objections are in the record.

15 Q Right. And so, you could understand, though, how someone could

16 interpret your statement that you schemed up January 6th with Representative Biggs,

17 Representative Brooks, and Representative Gosar as suggesting that you had a

18 conversation together with the three of them, and the four of you together came up with

19 the idea?

20 A I can absolutely understand that. And the first time that I -- it was

21 almost -- it was the first political, you know, nightmare scenario that I was dealing with

22 post 6th. So it's very fresh in my memory, because what happened is initially, you know,

23 very liberal Democrats took a video of mine right as I was being deplatformed, chopped

24 it, and then misreported the date, because I'm talking. You can watch the video. I'm

25 almost also talking in a past tense, and it's before January 6th.
 174

1 And so to them, they think I'm confessing to admitting that me and three

2 Members of Congress secretly got in a backroom to plot violence. And so I can

3 understand that that much disinformation coming allowed a lot of people to put a lot of

4 eyeballs on something that is exactly what I've just characterized.

5 Q Okay. So put aside the violence that happens, the words you use to say

6 that you schemed it up with the three of them would convey, to a reasonable person

7 listening, I would think, that you, together, the four of you, worked out the details, not

8 the violence, right? I mean, you schemed up with them.

9 A I wouldn't say so in politics. I'd say it was a -- it's a synthesis. It's the

10 same reason why we adopt -- in our, you know, congressional body, we allow cosponsors

11 and co-authors. There's a credit-sharing thing that goes on in politics.

12 Q Sure. And cosponsors get the decision to say they sign off on that and they

13 say I'll cosponsor that.

14 A And that's -- and that's in politics for government. But in politics

15 electioneering, there's a lot of things that that go on like, Oh, I'm going to do the repeal

16 pledge or I'm going to do this type of repeal pledge or this is the Drill Here, Drill Now

17 pledge.

18 And a lot of people like to -- because I'm not an elected Member of Congress,

19 when I'm saying, Hey, if -- it would be easier for me to say we four schemed this up than

20 me saying, Well, I went to this Congressman and he said this. I went to the second one,

21 and he said this. I went to the third one. He said this. And then I came up with this

22 brilliant idea, and you all need to praise me.

23 It's easier to say I want credit alongside these other three guys than, you know,

24 this idea took form over thought, prayer, and individualized conversations with different

25 aspects.
 175

1 Q Okay.

2 A And that's the truth.

3 Mr.~ Thank you.

4 Ms. •, did you have any follow-up to that?

5 Ms. • No.

7 Q Leading up to January 6th, I want to talk about, like, the crowd-building

8 promotion of this. How did you build awareness and excitement for the event on

9 January 6th?

10 A I don't think we had to, because the President's tweet. I don't think that

11 there's anything that I could have done to top that, or contribute to that. There's no

12 person who said, I saw an Ali tweet. I saw the Trump tweet. I'm not going. I saw the

13 Ali tweet. I am going.

14 Q So did you use your social media at all to promote the events on

15 January 6th?

16 A Yes.

17 Q Which social media platforms did you use to promote the events on

18 January 6th?

19 A Primarily Twitter.

20 Q Primarily Twitter?

21 A Yes.

22 Q And approximately how many followers at this time did have you on

23 Twitter?

24 A I'm not sure. I don't have access to my account anymore.

25 Q You don't -- can you give us a ballpark -- recall how many you had around
 176

1 January 6th?

2 A No. I mean, it's definitely more than 100,000.

3 Q And what were you tweeting on Twitter to your followers about

4 January 6th?

5 A I probably put out a couple of hundred, or several hundred tweets. So I

6 wouldn't know.

7 Q Did you use Parler at all to advertise for January 6th?

8 A I don't recall using Parler. And if I did, it would have been a copy and paste

9 of some post on Twitter. I certainly didn't have time to put all my tweets on Parler.

10 And I didn't trust anyone with my -- well, I think there was one person with my password.

11 But, you know, I -- so, I certainly didn't have time. So if anything, it's there's some

12 copying and pasting going on but nothing unique or exclusive to Parler. Parler doesn't

13 have any direct messaging feature, I don't believe. So it really was kind of lame.

14 Q Did you utilize influencers on the social media to get the word out on

15 January 6th?

16 A Influencers made up what Stop the Steal Coalition was.

17 Q Okay. So who are these influencers that you -- that made up the Stop the

18 Steal Coalition?

19 A Scott Presler, one S. Brandon Straka, myself, Michael Coudrey,

20 C.J. Pearson, Alexander Bruesewitz, Rose Tennent, you know, we all had -- well, not all of

21 us that I mentioned. Maybe I shouldn't have mentioned some of this, but we had large

22 accounts and we would retweet each other.

23 Q What do you mean by large accounts? What does that mean?

24 A You know, if you have, like, more than -- more than 50,000 followers, you

25 have a large account, I think.

 177

1 Q Were you all advertising or publicizing the January 5th event in Freedom

2 Plaza and the January 6th events together?

3 A Not always. And I do know there was a graphic that mentioned the 5th and

4 two events on the 6th.

5 Q So there were times where you were advertising the events on the 5th and

6 the 6th together?

7 A Yes.

8 Q Were you asked by Women for America First to promote the event at The

9 Ellipse?

10 A No. I think I ceased contact with them in November. And -- and though

11 the permit was in their name, it wasn't solely their event.

12 Q So whose event was The Ellipse then?

13 A It's difficult to say. The permit is under their name. It's, you know, under

14 the influence of the Trump campaign, to my understanding. We were supposed to be a

15 part of it. Either we weren't a part of it and we were led to believe we were, or the

16 morning of we show up and we're disbarred. And so that's why I tried to be accurate in

17 this migrating timeline of people who either exercised decision-making power, or exerted

18 it that they shouldn't have had but had.

19 Q And you used -- I believe you maintained or created websites to also

20 advertise for the events on January 5th and 6th?

21 A I believe so.

22 Q Such as [Link]? Did you advertise for the events on January 5th

23 and 6th on [Link]?

24 A I'm not sure, but normally what we would do with a large event is put a

25 graphic at the top of [Link].

 178

1 Q What about was [Link] a website that you controlled?

2 A Not at all.

3 Q Okay. Was [Link] a website you controlled?

4 A Yes, I got that name based off of the President's tweet.

5 Q So what did you advertise on [Link]?

6 A Initially that was going to be our sole event, you know, for a morning event

7 that would go until whenever the voting was done. And we advertised the speakers, the

8 location. And we may -- I think we may have even done the website prior to getting the

9 permit. That's how fast things were moving. And, so, it was kind of like a precursor

10 that kind of fell apart.

11 Q Do you recall creating a website [Link] to advertise for the events

12 on January 5th and 6th?

13 A I don't recall. I don't recall making a unique site. I vaguely recall getting

14 that URL. I probably pointed it to [Link] or another property.

15 Q Okay. And then what about March to Save America? Was that a website

16 that you maintained control of?

17 A Yes, that was a website that I maintained. And, you know, I got the name

18 from Caroline Wren who said, you know, this was the branding that they were going for.

19 And then, you know, it kind of migrated. It kind of was called several things, you know.

20 But, and you guys can see based off of this and even the MOU agreement that I gave you

21 guys about the event of the 5th, you can see, I was talking with my counsel earlier today.

22 And we observed that --

23 Mr. We don't want to hear that.

24 Mr. Kamenar. Yeah, attorney-client privilege.

25 The Witness. Yeah, I want to say this.

 179

1 But just to say how things were moving is that that contract is either signed on 1-2

2 or 1-3. So that's how in flux a lot of these things are.

3 And like -- and I think part of the reason I'm here testifying today instead of taking

4 the stance that several other, you know, I think well-meaning people are is because I

5 want y'all to understand the timeline, because none of these other press pieces have

6 them correct. And it just seems like a stupid shame.

7 BY
8 Q Why is Ms. Wren going to you to make the website

9 [Link]?

10 A No, I got the -- we got the name from her of what we were going to call The

11 Ellipse. And we made the website, and because we were trying to figure out who makes

12 the website. I'm a guy of action. I'm, like, let's just make a website. Whether we

13 control it, whether we hand it over, whether we delete it, I need the website done.

14 Q And the March to Save America website included directions to start at The

15 Ellipse and then march to the Capitol grounds on January 6th?

16 A I don't recall any of the contents of that website. I know that we went, like,

17 for a different color scheme. But that's the extent to [Link], what I

18 recall of it.

19 Q Why didn't you just fold in everything that you wanted to advertise in the

20 [Link] website?

21 A I didn't own [Link].

22 Q Who owned [Link]?

23 A It's my understanding that that's Women for America First and their

24 consultant, Scott Graves.

25 Q And if you all were working together on this, how come you-all didn't make a
 180

1 website together?

2 A Through working through Caroline Wren, because we weren't talking to

3 them and they weren't talking to us.

4 BY

5 Q Wren told to you make [Link]. Did she give you money

6 to create that?

7 A She didn't tell me to make the website. She gave me the name, because I

8 know they were making a decision outside of my -- I know I gave, at some point, some

9 suggestions of what we should call The Ellipse event.

10 Q Oh, I'm sorry. A minute ago you said, "I said we should just create a

11 website," and you said, "Caroline Wren gave me the name March to Save America. Got

12 it."

13 A And I don't mean the domain name. I mean the literal phrase.

14 Q Got it. Did you buy the [Link] domain?

15 A Yes, I believe so.

16 Q Okay. How did you do it? Who paid for that?

17 A Me.

18 Q How?

19 A I don't know if I owned it as my persons, or if I owned it as Stop the Steal,

20 but Stop the Steal is just me. So that's what that was.

21 Q And for, I think you said Stop the Steal U.S., Wild Protest, Fight for Trump,

22 and March to Save America, did I get all your websites right?

23 A I believe so.

24 Q Okay. Because I excluded Trump March after you said that wasn't you.

25 Were all of those post-creation Stop the Steal -- remember our conversation earlier when
 181

1 you said, "Oh, after Stop the Steal, I was using Donorbox"? Were you using Donorbox

2 for the fund raiding on all of those sites?

3 A I believe so.

4 Q Okay.

5 A Around the dates we're talking about?

6 Q Well, I hadn't -- from what I remember you saying, you had said after you

7 created Stop the Steal, I want to say two thousand -- when was that, November --

8 A I originally created Stop the Steal in 2018.

9 Q That's what I had in my notes. I thought you had said, after you created

10 that, you were using Donorbox.

11 A Okay. That is not what I mean at all.

12 Q Oh, okay. So, let's actually clarify that, because that's really important.

13 When we were talking about the time earlier, I thought you had said, I was using personal

14 stuff, PayPal, et cetera, to my person; and then when Stop the Steal was created, I moved

15 to Donorbox.

16 A Uh-huh.

17 Q I thought you had said Stop the Steal was created in November 2018. So I

18 thought that's when you were using Donorbox. But let's clarify. When did you stop

19 collecting the money personally?

20 A The collection of the funds personally was from my personal activism.

21 When Stop the Steal 2020 became a more organized effort that I knew was going to

22 involve other people, accountability, you know, all that other crap, that was -- we got off

23 my person as soon as we could. And so, that requires first doing an LLC, then setting up

24 something or applying for something. I think you have to get a Stripe account, connect

25 it to your Donorbox account. So there's several moving technical parts, some of which
 182

1 I'm aware of and others which, you know, I may not be aware of.

2 And then as soon as we could, you know, because it's a volunteer effort, we make

3 [Link]' button, donate button, not go to my personal site where people can

4 support me or any of my friends, but instead support a broader thing where, you know,

5 each person's running their own State.

6 Q Okay. I think I understand now.

7 So prior to Stop the Steal 2020 creation was when you were using the personal

8 stuff. I think you said PayPal and --

9 A For part of November.

10 Q For part of November 2020?

11 A Yes.

12 Q Okay.

13 A Stop the Steal, Stop the Steal as a hashtag, Stop the Steal as an Ali Alexander

14 effort that harkened back to the themes of 2018, that was personal. That was personal.

15 When Stop the Steal got an LLC -- and I believe and we've submitted that paperwork -- we

16 began the process of moving that all over so that an organization could have that.

17 Q And I thought you said earlier all your tweets, et cetera, like, when you

18 would fundraise prior to November 2020, that was also all personal, either PayPal or

19 some kind of direct transfer to you.

A Prior to November 2020?

21 Q Righ

A Like October 2020 and prior?

23 Q I mean just prior to 2020. You were doing fundraising, I'm assuming,

24 prior --

25 A For what?
 183

1 Q Well, for your activism, with your tweets, I mean -- oh, here. Let me ask it

2 a different way. When did you start fund raising?

3 A When I have one-off projects, I fundraise it. I'm sorry. I fundraised, and it

4 really depends on what that project is. I've had a variety of clients. And then if I'm

5 doing a project under my own name, then I'll say, I'll ask people to contribute to me.

6 So I did a documentary in 2019, a 20-minute documentary. And I raised money

7 for that. I don't know if that was through the entity that published the documentary or

8 through my persons.

9 Q Okay. So --

10 A But there was no -- and I've seen this in this binder. I'll just leave it there.

11 Q No. I think I understand what you're saying. For these websites that I'm

12 assuming Stop the Steal U.S., Wild Protest, Fight for Trump, March to Save America, what

13 was the fundraising mechanism for those?

14 A Those websites came after November 4th. So --

15 Q Right. Donorbox?

16 A The websites themselves, like even those domains, if I own [Link]

17 from 2018, then it was probably dormant. And those other sites are all in particular,

18 like, January 6th focused. So I couldn't have owned them before December 16th.

19 Q No, I know. I'm saying after you created them, what was the fund raising

20 mechanism when you set --

21 A Donorbox.

22 Q Donorbox. Yeah, okay. That's what I thought. Okay.

23 And did that ever change?

24 A Through January 6th?

25 Q These websites, if I was understanding you, you used Donorbox for

 184

1 fundraising. At any point did the fund raising mechanism for these websites change

2 from Donorbox to anything else?

3 A I don't believe so outside of our conversation when I said, when we got

4 deplatformed and we moved to an independent credit card processor for [Link]

5 Q And I don't think I asked you, but do you remember when that was, the

6 deplatforming?

7 A Different websites deplatformed us on different days.

8 Q Ballpark? Like a month?

9 A Well, January 6th is the fallout. So I would just say from January 6th to a

10 week or two later.

11 Q Oh, it that was -- okay. I thought -- it was quick. Okay.

12 A I was eviscerated.

13 Mr. Kamenar. Excuse me. Could we be able to take a 5-minute break?

14 Mr. We'll go on recess now for 5 minutes. We'll come back at 4:30.

15 [Recess.]

16 M r - Back on. The time is 4:31 p.m.

17 BY

18 Q So. Mr. Alexander, you said before you weren't working with the Kremers

19 to plan January 6th at any point. That's correct, right? You were planning your own

20 event at -- you were planning your own event for January 6th Stop the Steal, correct?

21 A Yeah, I wasn't directly working with them. I was working with Caroline.

22 Q Okay. So then we see Caroline. When did Caroline come into the picture

23 for planning January 6th?

24 A I'm not sure. I think the text messages reflect when she first reached out to

25 me, and then we had a subsequent phone call. And she talked about a unifying effort,
 185

1 and she was very nervous because she had had poor interactions with other people. We

2 had a positive interaction. I'm a political professional. I'm not going to say no to, you

3 know, somebody from Trump world. And I folded my event in.

4 Q And so what people was she bringing in that she told you she was going to

5 bring in for the January 6th event?

6 A The Kremers -- she -- I do remember explicitly saying that, you know, like,

7 they want to bring in anybody who had been supportive and they needed help identifying

8 some of those people. And then some of the people she had already spoken to, to the

9 best of my recollection, were obviously the Kremers, Cindy Chafian. And, you know,

10 then she tossed around some other names as prospects, you know, likes Alex Jones and

11 Roger Stone, stuff like that.

12 Q Was the plan when she brought you in -- and I'll -- I'm just going to say

13 coalition partners. Is that okay to say?

14 A Yes.

15 Q Coalition partners?

16 A That's fair.

17 Q When she brought in the coalition partners, was the plan to have one big

18 event? Or was it to have multiple events on January 5th and 6th?

19 A When we initially talked about it, she needed my expertise on that. And

20 my advice was to do multiple events and --you know, when the decision came down, it

21 was, like, let's do multiple events on multiple days.

22 Q Why did you want to have -- why was it your advice to give -- to have

23 multiple events?

24 A Because as I understand it, again, based off of higher-income consultants

25 and other people who know D.C. better than me and all this other stuff is that it seems
 186

1 logistically improbable to have an event near the Capitol with the President of the United

2 States. Secret Service would freak out at something like that.

3 And so if we were to have an event -- and I should say in that first conversation

4 there was the possibility of the President's participation. And that's why -- I think that's

5 what kept everybody in line was, you know, if he can participate, then we better do

6 whatever anybody who's a representative of Trump world says. And --

7 BY
8 Q Let me just stop.

9 A Yeah.

10 Q Just she was -- Ms. Wren was saying that? She was saying there was the

11 possibility of the President speaking?

12 A That Trump could participate.

13 Q Okay. And what did she explain about that and why he was interested in

14 doing that? Do you remember?

15 A I can't recall. I just remember that being the significant, exciting detail.

16 Q In that first call she's telling you that.

17 A I think it was our first call.

18 Q Yeah. Had she ever called you before?

19 A No. I think I loosely heard her name because I, again, spent some time in

20 Alabama politics years ago. And -- and then I know I looked her up real quick.

21 Q Just simply, do you know how she got your number?

22 A I don't recall.

23 Q Had she talked to Mr. Stone before she talked to you? Do you know?

24 A I don't recall.

25 Q Do you know whether she had talked to Mr. Jones, Alex Jones?
 187

1 A Before me?

2 Q Yes.

3 A I don't know what the order was at all.

4 Q So it was a call out of the blue.

5 A I think it was a text message and then a call.

6 Q Okay. But you knew who she was when you got the message.

7 A When we talked on the phone.

8 Q Did you have her in your contacts?

9 A No.

10 Q No. So this is Caroline Wren, and then it sets up.

11 A Yes.

12 BYMR.

13 Q Were you expecting a text from Ms. Caroline Wren at this time?

14 A When I received one out of the blue?

15 Q Uh-huh.

16 A I don't believe so.

17 Q So no one had given you a heads-up that a random person in Trump world

18 might reach out to you --

19 A It's possible.

20 Q -- about January 6th?

21 A It's possible, but I don't recall anybody giving me the heads-up on that. But

22 it's possible that I would have heard rumblings. But I don't -- I don't -- specifically

23 Caroline Wren, no, I don't recall that.

24 Q Do you recall the President tweeting you, and then Arthur Schwartz getting

25 Dan or someone else the POTUS access to un-retweet you? Do you recall that?
 188

1 A I recall the President's account retweeting me, and I recall that tweet

2 disappearing.

3 Q Who is Arthur Schwartz?

4 A Arthur Schwartz is a Jewish Republican individual. I think he does PR, or I'm

5 not sure how you would characterize his services. And he did a lot of work with Don, Jr.,

6 Donald Trump, Jr.

7 Q And in that, "Dan" would refer I assume to Mr. Dan Scavino in the text? So

8 the text, to be clear, is in exhibit 26 at page 102 is where you say this.

9 A In 102?

10 Q Yes. I'm just want to make sure that when it says Arthur Schwartz got Dan,

11 we're talking about Dan Scavino.

12 A Oh, this sounds like -- I'm sorry. 102?

13 Q Yes.

14 A This sounds like it's me speculating on who the possible -- because, you

15 know, it's been widely reported that Trump has access to his Twitter account and Dan has

16 access to his Twitter account. So I relied on public reporting for that. And I -- and I

17 actually I've seen Dan use Trump's account for it. So I --1 was trying to figure out who

18 lobbied and who did it, or if that was the same person. And I know that Arthur Schwartz

19 hated my guts.

20 Q Do you recall on December 30th, 2020, going to a meeting at the White

21 House with Mr. Ed Martin?

22 A When?

23 Q At the end of December, December 30th, 2020, going to a meeting with Ed

24 Martin, Mr. Ed Martin, at the White House?

25 A No, I don't believe I was there.

 189

1 Q Okay.

2 A I don't believe I went to the White House at all during Stop the Steal.

3 went out of my way to not.

4 Q When planning for January 6th with Ms. Wren, when you were talking to

5 her, was the coalition partners responsible for fund raising on their own?

6 A No. Not for -- no -- let me clarify. Not for The Ellipse events.

7 Q So how did the fundraising work for The Ellipse event?

8 A I have no idea.

9 Q How did the fund raising for the Wild Protest event?

10 A That was all on me.

11 Q How did you raise funds for the Wild Protest?

12 A Me and other influencers would tweet out the Donorbox link.

13 Q Approximately how much money did you raise for the Wild Protest event?

14 A I don't recall. I have seen an image floating around on the internet, and

15 what I can't figure out is if that figure is for everything that we raised for the website on

16 Stop the Steal, or during a period or for just that cause, because I don't have access to be

17 able to parse that data.

18 Q Did you receive funds for any of your -- did Stop the Steal receive funds from

19 any other entities in planning events on January 5th and 6th?

20 A I'll think about that, so that I can try to drum up something if there is

21 something.

22 BYMR-
23 Q Why did you go out of your way to stay away from the White House during

24 the Stop the Steal effort?

25 A I was doing something very unconventional, and I didn't want to play White
 190

1 House politics. And I thought it would be a weird or bad look if I disagreed -- there are

2 several times when I publicly disagreed with the White House. And when you do that, I

3 think you want to distance and you want your independence. You don't want someone

4 to be able to call you and tell what you to do, and conversely you also don't want to be

5 somebody's whipping boy.

6 And so I -- they weren't paying me. So whenever I'm talking to a State legislator

7 or someone, and saying this is the political fallout, I don't want anyone to think President

8 Trump told this kid to come up and threaten me. I didn't want that to be perceived.

9 So I made sure I didn't go to the White House Christmas party, you know, or anything like

10 that.

11 Q Were you invited to the White House Christmas party?

12 A No. But what happens is the White House throws several White House

13 Christmas parties, and it's the last one. So if I wanted an invite, I could have got one.

14 Q You referred to Dan Scavino as Dan, by his first name. Do you know him?

15 A We know of each other, you know. We've had positive interactions

16 publicly and privately, and then publicly, I've disagreed with some of his techniques.

17 Q When what are the private interactions you've had with him?

18 A It's documented I went to the White House and I believe it's 2019 for a social

19 media summit, and I was in a room with a lot of people. And Dan was there, and I

20 walked in late. And he said, Hey, Ali. And it was very positive. And there was a

21 gentleman who had been blocked, I guess accidentally, by the President's account. And

22 Dan unblocked him.

23 Q Okay. But did you ever have any other interaction with Dan Scavino other

24 than the social media influencer event in 2019?

25 A I think the other ones just, you know, remain public, you know.
 191

1 Q What does that mean?

2 A I forgot. He -- Trump or the White House or Dan did something that ticked

3 a lot of people off in my community. And, again, this isn't, I don't think, pertinent to

4 January 6th at all. But this was years ago. And he -- so we started a campaign to block

5 Dan, to try to get at his ego.

6 Q Okay.

7 A And I know that probably ticked him off.

8 Q So the last time you've actually spoken to Dan Scavino was in 2019.

9 A I believe so.

10 Q Did you have his number in your phone?

11 A No, I don't have his number that I recall.

12 Q All right. And Arthur Schwartz, is that someone you know?

13 A I've had a few more interactions with Arthur Schwartz.

14 Q Did you communicate with him at all about January 6th?

15 A No, I don't believe so.

16 Q So when you say you went out of your way to stay away from the White

17 House, did you have anyone in the White House who could have invited you in to come

18 by at that time?

19 A Anyone of any influence can get a ticket at the -- for a White House

20 Christmas party.

21 Q Okay.

22 A So that's what I mean by that.

23 Q But no one in particular that you had a connection with in the White House.

24 A No, I mean, no. It would be like the broader -- no.

25 Q Was it your perception that President Trump knew who you were?
 192

1 A President Trump, when we, the few times that we've seen each other, you

2 know, on campaign rallies and I'll be in a VIP backstage thing or something, you know, we

3 exchange pleasantries, because we had our first positive interaction back in 2014.

4 Q All right. So is that a yes? It's your impression he knows who you are?

5 A Yeah, I'm sorry. Yes.

6 Q And, in fact, I think you've told many people publicly that he referred to you

7 once or at once as you look like Sammy Davis, Jr.?

8 A Frequently.

9 Q Okay. All right.

10 Ms Frequently he has said that, or frequently you've been told that?

11 The Witness. Whenever we see each other, he makes --

12 Ms. - He -- okay.

13 The Witness. -- the comment to say "Sammy?"

14 Ms.

15

16 Q When's the last time you saw him and interacted with him in that way in

17 person?

18 A I can't recall. I can't recall the date. I think it was a rally in Minneapolis.

19 Q Preelection?

20 A Yeah, certainly.

21 Q But in the 2020 election?

22 A I don't know if it was in 2020.

23 Q You don't know. Okay.

24 A Yeah.

25 Q But for the 2020 election cycle?

 193

1 A No, I don't know that it was. I mean, it's clearly after he was in the White

2 House. But it could have been 2017 or 2018 or 2019.

3 Q All right.

4 A It wasn't in 2017. I can say that. So 2018, 2019, or 2020.

5 Q And did Ms. Wren in that first phone call -- she's saying the President's going

6 to speak on the 6th. Did she say who she was working with from Trump world on the

7 event?

8 A No, she -- I just for clarification, she didn't say that Trump was --

9 Q Possibility.

10 A Yeah, possibility.

11 Q Yes.

12 A And, no, I -- you know, again, you know, I saw her and introduced her on

13 that conference call that we all talked about earlier as like the -- with Caroline Wren with

14 the Trump campaign.

15 Q Did she -- okay. Did she ever relay to you at any point between that first

16 call and January 6th who, if anyone, she was working with within Trump world on

17 this -- on the events on the 5th and 6th?

18 A She mentioned passing, you know, she mentioned passing conversations like

19 with Kimberly Guilfoyle and, you know, Oh, I'm talking to Charlie Kirk, and stuff like that.

20 And, you know, she would give me these periodic updates.

21 Q Did she ever convey to you that she had spoken to President Trump about

22 the events?

23 A I'm not sure, but that is my impression.

24 Q Did she ever convey to you that she talked to Don, Jr., the President's son,

25 about the events?

 194

1 A I'm not sure, but I assumed so.

2 BY

3 Q Going back to receiving funds, did Stop the Steal organize buses in various

4 cities to come to D.C. from January 5th and 6th?

5 A We participated in organizing buses.

6 Q And who paid for those buses?

7 A I think it was my understanding that it was ran through Turning Point USA.

8 That was my understanding. And they needed more bodies, and Stop the Stea l's just a

9 very popular brand. And, so, if Stop the Steal said, Hey, you know, there's a bus

10 available, it's easier than one of these groups that look more established.

11 Q Who --

12 Mr. Oh, I'm sorry. You can g o , - .

13 Ms- No,no.

14 BY

15 Q Who put you in contact with Turning Point USA to organize the buses?

16 A Caroline Wren.

17 Q And who did she put you in contact with at Turning Point USA?

18 A Well, she just mentioned -- I know Charlie and I know Tyler. And so, you

19 know, she had mentioned this stuff needs to run through Tyler, and I believe I partnered

20 Nathan with Tyler and said I have no time for this. I'm focused on the Georgia run-off.

21 You guys do this. And where I could, I helped. And where I could, I amplified appeared

22 tweeted and tweeted out bus routes and stuff like that.

23 Q And Tyler, what's Tyler's last name?

24 A I think Bower.

25 Q Bower.
 195

1 And so it seems like it was Mr. Martin largely running this bus operation for Stop

2 the Steal for January 6th?

3 A I would say that we acted as an endorser and an amplifier. And it was hard

4 to call it, you know, Stop the Steal's bus effort. But we definitely wanted to natively

5 market it that way to our audience so that they would feel comfortable participating.

6 Q Did Stop the Steal pay for the bus fees up front, or did Turning Point USA pay

7 for them?

8 A I don't think we paid for the bus fees up front. I think -- and I don't know.

9 We may have even got one independent bus, but I'm not sure that that ever went

10 through or didn't go through. So I would -- I would not know that.

11 Q So you're not aware of Mr. Martin maybe being reimbursed by Turning Point

12 USA for buses that he may have paid expenses for?

13 A Yeah, I'm not sure how that all logistically finally finalized.

14 Mr. - Do you have follow-up,_?

15 BY-:

16 Q No. I just -- it sounds like you're saying that to the extent that buses were

17 paid for with the exception of one possible one that you may have had for Stop the Steal,

18 your involvement in the buses was basically to advertise Turning Point's offering of the

19 bus.

20 A Yes. And that included -- we made our own landing page on Stop the Steal.

21 And we tried to rally, sometimes very unsuccessfully, tried to rally interest in some cities

22 that didn't materialize. But if there was a city that materialized, that would get handed

23 over to Turning Point USA, I believe.

24 Q And I guess you kind of just said it. But in terms of the mechanics of, if you

25 were signing people up in interest for the buses, was it like a list that you then passed on
 196

1 to Turning Point for them to organize the bus? Like what was the -- I mean, let me

2 rephrase. What was kind of the mechanism for getting people to sign up and then

3 getting them on a bus?

4 A I don't think I know the answer past tweeting the link.

5 Q Okay.

6 A And then there being an error in a form and me trying to involve myself in it,

7 getting frustrated, and saying this is stupid. I don't want to be involved and saying you

8 guys fix it. So there's, like, a web form problem. I don't know if the list got exported

9 and sent to them, or if we emailed them and said go to this location at this time. I don't

10 know where it ended.

11 Q When you say you tweet or you emailed somebody "you guys fix it," are you

12 talking about Nathan and Turning Point?

13 A Nathan and the web team.

14 Q Okay. The Stop the Steal people.

15 A Volunteers.

16 Q Okay.

17 BY
18 Q You said earlier that when you started planning your event on January 6th,

19 you were not working with the Kremers. Did you do an event with the Kremers in

20 Women for America First in November in Washington, D.C.?

21 A Yes.

22 Q Can you -- so were you all cosponsors? What was the relationship like in

23 doing the event on November -- it is a November 14th event. Is that correct?

24 A I believe so.

25 Q It's a March for Trump at Freedom Plaza?

 197

1 A Well, it wasn't supposed to be -- it's not -- it's tough, man. I don't think it's

2 called that.

3 Q Okay.

4 A Okay. My understanding is that it's called the Stop the Steal rally.

5 Q Okay.

6 A Now what happened is -- and my text messages reflect this -- is they lobbied

7 me to say let's take Stop the Steal to Washington, D.C. I was very skeptical that we

8 could pull off something like that. We have no funding, no nothing, no nothing. And

9 I'm telling people to go to D.C. in it was either a week's notice or two weeks' notice.

10 Maybe it was two weeks' notice.

11 And Amy said, Ali, we've been through the permit process. Have you?

12 And I said, Never.

13 And they said, Okay. Well, we'll handle it for you. It will be you event. You

14 can pick the run of show and all of that."

15 What happened is that they, I think, I think amended an existing permit that they

16 had for January. I guess they were going to, like, protest -- participate in the

17 inauguration that they had preelection day. And they amended it for whatever. There

18 was -- I don't know what was going on and the event slowly got hijacked to the point

19 where their logo is sitting in front of it.

20 And we were basically blackmailed or threatened that if we got up on stage and

21 plugged the broader coalition, which had a retweet agreement and an agreement that we

22 not put our own independent logos on things, that we would be kicked off an event that

23 was ours. And so, the crowd's understanding was that it was a Stop the Steal event.

24 It's advertised, and its permit probably says Trump March or something silly.

25 Q So the speakers that spoke at that event were Stop the Steal speakers?
 198

1 A Not all of them. I got some of my guys in, and a majority of it was theirs.

2 And then at the Supreme Court they had an event. So they marched over to the

3 Supreme Court and then did a -- an event. And I think, you know, maybe one of those

4 people is affiliated with Stop the Steal and the rest were them.

5 Q So when you say they did an event, did Women for America First have an

6 event at the Supreme Court --

7 A Yes.

8 Q -- or did Stop -- okay. So Stop The Steal did not have the event at the

9 Supreme Court?

10 A No, not at all.

11 Q Did you all coordinate the November 14th event with anyone from the

12 Trump campaign?

13 A I don't believe so at all. It was very grassroots.

14 Q And did you all coordinate the event with -- I think you've been using the

15 term together but I want to make sure -- with the White House? Did anyone from the

16 White House coordinate the November 14th event with you?

17 A I don't believe so.

18 Q Do you recall President Trump running by in his vehicle, in his motorcade,

19 passing the November 14th event?

20 A I heard about that after the event.

21 Q So you weren't aware that was going to happen before?

22 A Not at all.

23 Q And you said that you didn't have any money or the two weeks' notice.

24 How did you all raise money for the event on November 14th?

25 A Tweeting.
 199

1 Q And how did the money actually come in though? How it was donated to

2 you?

3 A Through Donorbox.

4 Q Okay. Through the [Link]?

5 A Yeah, I believe so, unless that aligns with my, you know, personal website.

6 But I think we were trying to get away from that as soon as possible, yeah, so.

7 Q Did you and Women for America First have an agreement that they would

8 raise certain funds and you would raise certain funds?

9 A No. Because they, after I let them -- after I had authorized them to get a

10 permit on behalf of Stop the Steal, they started ghosting us, claimed that someone had

11 died in the family, proceeded to get into fights. And then it was a big question of, well,

12 how is everything getting paid for if you're not asking me to raise the money or transfer

13 money. And that was a weird, bizarre thing.

14 So what I should clarify and say is Stop the Steal funds for November 14th were

15 mainly used for travel expenses. We didn't pay for the staging. We didn't pay for any

16 of that other stuff, Porta Potties. And, you know, so we didn't have an agreement.

17 There was just -- it was a --yeah.

18 BY-:

19 Q Real quick. I wanted to go back because it sounds like you said if it wasn't

20 my personal website. Did you -- you had a personal website for fund raising, or maybe I

21 misunderstood.

22 A That we've talked about before. So [Link]. The first part is Stop

23 the Steal where it's basically, I'm a one-man show, recruiting people into it. And my

24 existing customers and my existing donors are mainly donating to me, but then some

25 people who see my tweets, and some of my friends are recommending that people
 200

1 donate to me so I can pay for their flights. That's that first part of November, and I don't

2 know what the cutoff date is.

3 Q Oh, okay. So it's [Link] prior to Stop the Steal. And

4 you're -- when you were talking about prior to Stop the Steal is my personal fundraising,

5 it's through that web page, [Link]?

6 A Yes.

7 Q And did you have a PayPal link on there?

8 A Yeah, there's a PayPal -- I think there's a PayPal's and a couple other links.

9 But PayPal's the one -- I think I know that there was a link to PayPal.

10 Q Okay. And other than PayPal, do you remember any of the other links on

11 there or --

12 A No.

13 Q -- what type of payment it was?

14 A I -- I wouldn't be certain. I just know that there was -- there was -- this site

15 was mainly a content locker for my customers. There are people who can't afford my

16 consulting services but want my analysis. So I do a monthly call with them.

17 And so some people like to pay over the top. So that's why all that information

18 had already been listed for, you know, a year or 2 years. And so when everyone's, like,

19 Ali needs to start Stop the Steal, my donors and my customers are, like, start Stop the

20 Steal. We'll give you money to buy flights and stuff for people. I'm, like, okay.

21 So, like, I'm the first donor to Stop the Steal. My customers are the second

22 donors to Stop the Steal. My friends who want to participate, their audiences are the

23 nexus for donating to Stop the Steal. And that's when I said, okay. Well if my friends

24 are recommending their readers to me that don't follow me, this even we need to

25 formalize this entity.

 201

1 Q Okay. So this is -- so [Link] is when you were referring to the

2 personal stuff prior to Stop the Steal in November 2020. Then you create the entity.

3 At that point you start the Donorbox. Everything fund raised in November under Stop

4 the Steal is through Donorbox. Do I have that right?

5 A Not -- so my effort to Stop the Steal pre-formalization is November 4th like

6 at 1:00 p.m. Immediately start pointing people to my personal site. It isn't until

7 November 7th or 10th that we formalize Stop the Steal.

8 Q Oh, okay. You create Stop the Steal, and for that brief period of time from

9 the 4th to the 7th you're still putting people to [Link] for fundraising because

10 you don't have yet have the LLC.

11 A Right.

12 Q Then on the 7th, you get the LLC. You set up Donorbox, Stripe, et cetera,

13 and going forward --

14 A The 7th or the 10th or something like that?

 202

2 [4:54 p.m.]

3 The Witness. 7th or the 10th, or something like that. Okay.

4 Ms. That's probably fine.

5 At that point, you set up the Donorbox, Stripe, et cetera, and now it's going

6 through that for the Stop the Steal, LLC?

7 The Witness. Yes. And I don't know how many days that process takes,

8 because sometimes, like, Stripe can take 3 days to confirm you.

9 Ms. I understand those aren't exact dates. That's helpful.

10

11 Q At this rally in November, the November the 14th rally, did you engage with

12 the First Amendment Praetorians for security?

13 A The November rally? Yes.

14 Q Who are the First Amendment Praetorians?

15 A They -- I'm trying to think who recommended them to me. I don't know if

16 it was Tracy Beanz, B-e-a-n-z, or -- and Tracy with a y -- or if it was someone else.

17 And someone said, "Do we have security?" So speakers started asking about

18 security. I'm thinking, again, how can we raise this money? You know, I was like,

19 we're buying people's flights. We're buying hotels. I don't want to stay at the Willard.

20 Everyone's staying at the Willard. This is, okay, you guys are going to have to, like, you

21 know, sleep two to a room.

22 And so then we started worrying about security. And so I think it was -- it was

23 either Tracy who recommended them, or someone said that Tracy had used them in the

24 past.

25 Anyway, I was like, okay. And I don't know who set up a call or how I reached
 203

1 out, but they just said it was their vision to protect the First Amendment. A lot of them

2 are ex-Special Forces or a pay grade above, like, the regular dudes. And so then they

3 were involved.

4 Q Who is Tracy? Ms. Tracy Beanz, who is that?

5 A She's a blogger, journalist.

6 Q Okay. So it sounds like the First Amendment Praetorians provided event

7 security for the November 14th event?

8 A For the Stop the Steal Coalition, not Women for America First, who had

9 basically taken the position that they were going to occupy my permit.

10 Q So did you coordinate with Mr. Robert Patrick Lewis for the security?

11 A I actually think what happened is I tasked Nathan with coordinating with Rob

12 and a gentleman who went by the name Yoda, and --

13 Q Okay. And what services or expertise did you think that the First

14 Amendment Praetorians were offering?

15 A Just a general detail protection. Like, I think a lot of security in political

16 circles is just moving you through a large crowd. So it's you with supporters, but to be

17 prepared, if somebody comes and assaults you, to exit you from that situation.

18 Q So why did you use the Oath Keepers in January, but use the First

19 Amendment Praetorians in November?

20 A I stopped using 1AP, is what they're short for, in -- shortly, I think -- I think

21 Atlanta might have been our last efforts with them.

22 Q And that's around the time Mr. Rhodes reached out to you, correct, with

23 those messages you went over earlier?

24 A Yeah. Coincidentally, I actually put that together, but yeah.

25 Q And why did you stop using 1AP?

 204

1 A I think that they became -- it was weird. I think that there was some

2 logistical conflict or whatever, because the agreement with them was, if you tweet out

3 their link, you don't have to pay them. And so we tweeted out their link, but then I

4 heard through the grapevine that they weren't happy with me. And I'm like, "Tell me

5 what you want me to tweet and I'll tweet it."

6 And so some conflict happened somewhere down the chain of command between

7 my folks and their folks. When I reached out to try to figure out what it was, I got

8 stonewalled, and that was just very abnormal to me.

9 And so then, like, for example, I went to Lansing, Michigan, because the

10 Republican electors were meeting, and we wanted to support them, or something like

11 that. And the 1AP people wouldn't show up for me.

12 So then I either called or had someone else call Stewart Rhodes and said, "Do you

13 have a guy up there?" And then there was a veteran who met us at the Lansing site.

14 Q And so it sounds like you didn't pay the First Amendment Praetorians for the

15 November 14th event?

16 A Yeah. I don't know if we made a donation or not. It's very possible that

17 we made a donation on top of tweeting out their links, but the agreement was tweet out

18 their link and crowd fundraise for them.

19 Q Do you recall working with any congressional Members for the

20 November 14th event?

21 A No, I don't recall that.

22 Q Do you recall a conversation where you told Ms. Amy Kremer that

23 Congressman Mike Kelly is taken care of, they don't want to be annoyed with multiple

24 points of contact? And I'm assuming that's because you were the point of contact?

25 A The point of contact was Rose Tennett --

 205

1 Q Gotcha. Okay.

2 A -- who was part of Stop the Steal Coalition, and she was not a fan of the

3 Kremers.

4 Q Okay.

5 Mr. Anything else?

6 BY

7 Q Did you go up to the Supreme Court after the event at Freedom Plaza?

8 A I did walk, or march, whatever, over from Freedom Plaza to the Supreme

9 Court after the series of Stop the Steal speeches were done.

10 Q And you talked about earlier this morning what the security posture around

11 the Capitol looked like on that day, in November. Do you remember just generally --

12 A In November?

13 Q Yeah. In November --

14 A For the Capitol?

15 Q Yeah. As you walked past. Because you contrasted the 6th, if you

16 remember earlier, about where the barricades were further out, I think, compared to the

17 times in November --

18 A Oh, no. I'm sorry. I was talking about the city's barricades.

19 Q Oh.

20 A Not the Capitol barricades.

21 Q Not the Capitol particularly?

22 A Yeah.

23 Q Okay. All right.

24 Any reason particular reason that you know of that people organized at the

25 Supreme Court that day versus anywhere else?

 206

1 A It's a popular place to organize. The second fact is that you don't -- there is

2 no permitting process for it.

3 And it's something that they had done before. And so the Kremers had done

4 something, you know, for Justice Barrett, and their last, you know, little rah-rah was at

5 the Supreme Court. So I think that they wanted to kind of relive some of that.

6 A lot of people love that shot. I've never -- I had never previously, you know,

7 attended any Washington, D.C., protests at the Supreme Court to my knowledge.

8 Q And is the upshot of November that that's it for you working with the

9 Kremers?

10 A Yes.

11 Q All right.

12 BY-:

13 Q Real quick on that.

14 It sounds like you said there was some problem with the First Amendment

15 Praetorians where -- but did you ever figure out or have conversations like, "What

16 happened there?"

17 A No. And still to this day I'm wondering why two -- who -- where did the

18 relationship sour, because they treated me like a son, you know.

19 And they were extremely professional. They were extremely on point. And I

20 was trying to figure out how they were just giving all these services, I don't want to say

21 for free, because we were very popular people tweeting out their link, so we raised them

22 a lot of money. But that was a huge leap of faith.

23 Q How did you know that you raised them a lot of money? Did you have

24 conversations with them about --

25 A It was on a public fundraising page.

 207

1 Q Do you remember which page?

2 A Not at all?

3 Q Was it GiveSendGo?

4 A I don't think GiveSendGo existed then.

5 Q RallyPay?

6 A I'm really not sure.

7 Q Okay. I thought maybe it like --

8 A Yeah.

9 Q If it --

10 A I'm sorry.

11 Q If it was a remembering thing.

12 And you said you might have made a donation to the First Amendment

13 Praetorians. Would you have done that, or would Nathan have done that?

14 A I don't recall.

15 Q Would Nathan have done that without your approval?

16 A With my money?

17 Q Yeah. Did he have the ability --

18 A No.

19 Q -- to just make donations without you --

20 A I'm sure he had the ability, but he wouldn't, you know.

21 Q Do you remember making donations to First Amendment Praetorians?

22 A I don't. I do remember, in my process of trying to make things right or

23 trying to be supportive or whatever, that that is something I have frequently done with

24 causes I believe in in the past.

25 Q If you had done that, would you have personally done that, or would Stop
 208

1 the Steal or [Link] have donated the money?

2 A My guess is that I personally would have done that. That's my guess, and

3 that, to me, makes sense.

4 Q And, sorry, just to tie a bow on that, you went to working with the Oath

5 Keepers because you never got -- you never heard back from First Amendment

6 Praetorians?

7 A We didn't go to -- we worked with Oath Keepers -- I shouldn't say we worked

8 with them.

9 Stewart Rhodes provided me a Michigan contact, and -- but, like, in Chicago, I

10 hired my own security. When I went back to Atlanta, I don't know who we used. In

11 Arizona I used, I think, nobody, or we -- or we -- we hired someone out.

12 So I didn't -- Oath Keepers wasn't following me around. And they made a

13 promise that they could provide people everywhere, but, really, that just kind of fell

14 short. And I only have secondhand knowledge of that, because, again, those are other

15 details.

16 It's like, if Ali is going somewhere, somebody around me would say, "Go find him

17 security," and we stopped using 1AP. Oath Keepers sometimes was unresponsive or

18 couldn't provide somebody in their veterans group, and so we hire security.

19 BYMR.-:

20 Q Did you ever use the Proud Boys?

21 A Me, I don't think so. I don't believe so at all.

22 Q Did you ever -- do you know of Mr. Enrique Tarrio?

23 A Yes, I do.

24 Q Did you ever use him to come speak at an event?

25 A I had never invited him to an event, I believe, and -- but he -- you know, we
 209

1 saw each other in Atlanta. We saw each other in D.C.

2 You know, a lot of people run into each other. I do know Atlanta, for example,

3 one of the days -- one of the smaller days -- I gave him a shout-out. He was standing -- I

4 saw him standing on the sidelines, and I could tell he wanted a shout-out. If I didn't give

5 him a shout-out, then, you know, there might be, "Oh, Ali is being a megalomaniac" or

6 something, and I didn't want that. So I gave him a shout-out, and -- yeah.

7 Q Okay. So you never -- it's your testimony that you never, like, reached out

8 to the Proud Boys for them to provide event or personal security for you?

9 A Yeah, that's my testimony. There was one night in either November or

10 December where I was walking, and the Proud Boys asked if I wanted an escort. And I

11 think that they escorted me three blocks.

12 Q Okay.

13 Ms. - How do you find these security teams? Like, you said you go to a

14 city, you're looking for them. I think you mentioned you found someone in Chicago.

15 How do you find them?

16 The Witness. Just google security firms, and a lot of police officers don't make

17 enough money at their day job, so they will moonlight as security officers or bouncers.

18 And the good thing about professional security is they don't ask you your politics.

19 You don't know if they agree with you or not. And so I know that I've had several, you

20 know, security members where I don't know their political beliefs, and I don't know that

21 they agree with me.

22 Ms. - Is that how you found First Amendment Praetorians?

23 The Witness. No. I've described how I best recollect finding 1AP.

24 Ms. Oh, okay. I apologize. That's just my bad memory if that was on

25 the record.
 210

1 BYMR.

2 Q So I believe you said the upshot of the November 14th event was you were

3 no longer working with Women for America First. Is that correct?

4 A That's correct.

5 Q So on the December 12th rally -- I believe this was the Jericho March, right?

6 A Yes.

7 Q Who were you -- who did this event? Who did Stop the Steal do this event

8 with?

9 A We joined in on an existing event at The National Mall. The Women for

10 America First was still doing something elsewhere, and we did -- and that was with the

11 Jericho March, which is a Christian-based group.

12 Q Okay. And who was in charge of the Jericho March Christian-based group

13 that you coordinated with?

14 A A gentleman named Rob -- and I can't remember his last name -- and a lovely

15 woman named Arina. And I think her last name starts with a G. It might be Arina --

16 Q Is it Grossu?

17 A That sounds -- I think she's Italian or something.

18 Q Okay. And for the December 12th rally, the Jericho March, did you help

19 pick speakers for that March?

20 A Yes.

21 Q Okay. Did you have more creative control over the speaker list for that

22 march?

23 A Yes.

24 Q Did you coordinate the speakers through, like, the Trump campaign at all?

25 A No.
 211

1 Q And did you talk to the White House about any of the speakers for the

2 Jericho March?

3 A I don't believe so.

4 Q Did you coordinate with Members of Congress to be speakers for the Jericho

5 March?

6 A I think we would have definitely reached out. And in talking with you right

7 now, I can't recall anyone who was on stage that was a Member -- that was an elected

8 Member. And I --

9 Q I'm sorry. Who do you think you reached out to?

10 A Oh, I definitely would have reached out to Congressman Gosar. You know,

11 I've tweeted that he's my spirit animal -- or he was the movement's spirit animal. But I

12 think he was out of town, so I don't think he -- so I don't recall any Members -- elected

13 Members. And it was broadcasted nationally, so I don't think it would be hard to figure

14 out who the speakers were. But I don't remember any Members of Congress speaking.

15 Q And did you, for this march -- it was on The National Mall. Did you all

16 march to the Capitol or Supreme Court on this first march?

17 A I don't believe so. The term Jericho March is a Biblical term, and it deals

18 with the whole religious thing that -- event that happened that was a literal march.

19 So I understand that early, early in the morning, they had marched around the

20 Supreme Court, I believe, and that was way too early for my participation. But the event

21 didn't break up and then walk somewhere or march somewhere or anything like that.

22 Q So you only participated in events on The National Mall on December 12th?

23 A I believe so. I don't know what I was doing at night, but --

24 Q But you weren't at the Supreme Court or the Capitol the night of

25 December --
 212

1 A I don't believe so. I might have walked over to Supreme Court, but I don't

2 think I participated in an event.

3 Q So there was an event at the Supreme Court on December 12th?

4 A My guess is that there could have been one, you know, because there's all

5 kinds of groups, you know.

6 Q But not one that Stop the Steal had organized?

7 A No.

8 Q Okay.

9 A Not to -- no.

10 Q How did you and the Jericho March, how did you all fund raise for the

11 December 12th event?

12 A That was weird. Again, it was like Stop the Steal needed to fundraise

13 money for travel for our people, hotels for our people, expenses for our people.

14 And then we also helped Jericho March fund raise. And they had a link on their

15 page, you know, I think [Link] or whatever. And so we helped them

16 fundraise by making -- because they -- again, Stop the Steal is a popular brand, and not a

17 lot of people knew who Jericho March was.

18 Q When you say "our people," do you mean the speakers that you coordinated

19 to have speak on December 12th?

20 A I mean the influencers that associate themselves with the Stop the Steal

21 movement.

22 Q The ones that you kind of listed out earlier chosen --

23 A Yes.

24 Q Okay.

25 Ms Real quick. That was December 12th, after you had created Stop the
 213

1 Steal. So to the extent that you were fundraising for that, would it have gone through

2 the Donorbox link?

3 The Witness. Yes, it should have?

4 Ms. Okay.

5 The Witness. I can't see why it wouldn't.

6 BY

7 Q Were you aware -- or you remember President Trump flying over the

8 protests on December 12th in his helicopter.

9 A I do.

10 Q Did you have any advance notice that that was going to happen?

11 A I think it's weird. It's like I'm trying to figure out how I would have heard

12 that, or if someone heard it and then told me, because then I started telling everybody.

13 And so, yeah, I definitely was spreading the word around and backstage prior to

14 the -- to Marine One actually flying over.

15 Q So you were aware before Marine One --

16 A Yes.

17 Q -- flew over that it was going to happen?

18 A Yes.

19 Q Do you recall around what time you became aware that President Trump

20 was going to fly over in Marine One? Was it morning? Early afternoon? Do you

21 know when?

22 A I think shortly right before it happened.

23 Q And you don't recall who told you?

24 A I don't. I don't know if I heard in person or text or whatever. But I was -- I

25 remember being super excited. I remember General Mike Flynn was speaking on our
 214

1 stage. And so I think I found out contemporaneously during his long speech.

2 Q Okay.

3 BYMR.

4 Q Were you a witness personally to any of the what I'll call the drama between

5 the Kremers and Alex Jones around December, just yes or no?

6 A I don't believe so.

7 Q Do you know anything about that?

8 A I think I've read a report recently on it.

9 Q But you weren't personally witness to any of it?

10 A I don't believe so.

11 Q Okay.

12 M s . . Do you -- oh, sorry.

13 Mr.- Yeah.

14 When did you -- are you still on December?

15 Ms- Uh-huh.

16 M r . - Okay. Yeah. Go ahead. That was all I had.

17 M s . - Oh, actually, I think mine was funding related to January, so --

18 Mr.- Yeah. I was just going to -- just to square it off -- you tell me if

19 you've covered this already.

20 BYMR.-

21 Q Did we -- we saw I think a tweet around December 16th where you said Stop

22 the Steal is coming back to D.C.

23 Does that timing sound about right, before the President said the "wild" protest?

24 A Yes.

25 Q Okay. And the Kremers, also that same day, said they were coming back to
 215

1 D.C. on January 6th. Do you remember that they --

2 A No, I don't. I thought theirs was also December 19th.

3 Q No.

4 A It's news to me.

5 Q So when the President released or did the wild protest, did you have any

6 foreknowledge he was going to do that?

7 A No.

8 Q Okay. And, afterwards, did you ever hear from someone whether -- when

9 he tweeted on the 19th for the wild protest -- whether he was referring to Stop the Steal

10 or the Kremers or anyone in particular?

11 A I assumed just until this moment that it could only be Stop the Steal,

12 because I was -- literally everyone was going to capitals, and I had had a conversation -- a

13 direct conversation with, you know, Paul Gosar. And so I just figured the President had

14 to be tweeting about, you know, our presence or us.

15 Q And that's the coalition broadly, or you in particular and the people you

16 were with?

17 A The Stop the Steal Coalition and the influencers that I mentioned that, you

18 know, we deployed to these various States.

19 Q Okay. And then, you know, understand how Ms. Wren comes onto the

20 scene. She texted you, and you had that conversation. And just in brief, it sounds like

21 it was just a continuing conversation trying to work out how the coalition will work

22 together for all of these events on the 5th and 6th. Is that fair?

23 A That sounds fair.

24 Q All right. And in terms of the working dynamic, again, just so I know, you

25 weren't communicating with the Kremers. You were going through Caroline Wren.
 216

1 A Yes.

2 Q And that's a reflection of what had happened back in November at that first

3 event?

4 A Yes.

5 Q And the plan -- we talked about right when we started the deposition about

6 how you walked, marched, whatever you want to call it, from the Ellipse to the Capitol,

7 and that when it actually happened you were with Alex Jones and Owen Shroyer. Am I

8 right?

9 A [Nonverbal response.]

10 Q When did you come to know that you were going to make that movement,

11 walk with them, those two particular men? Was it just the morning of January 6th, or

12 had that always been the plan, that the three of you together would walk up there?

13 A There was no plan for Owen to walk with us.

14 Q Okay.

15 A I don't know when there was a plan. I wouldn't even call it a plan. The

16 idea that Roger Stone, myself, and Alex Jones would go at the end of Trump's speech and

17 position ourselves at the front of the overflow crowd and figuring out how logistically that

18 worked so we didn't have to go out the same exit as everybody was something that

19 Caroline Wren first proposed to me -- don't know when -- and I thought, okay, cool idea.

20 Q But before the morning of the 6th?

21 A Certainly we talked about the idea, yeah.

22 Q Okay. And did you ever talk with Mr. Jones about this before the morning

23 of the 6th, this plan to march or walk, whatever you call it?

24 A I'm not sure.

25 Q Is it possible you did and you just don't remember?

 217

1 A It's possible.

2 Q Is Mr. Jones someone you would speak to on the phone, only in person, or

3 what was the nature of the relationship?

4 A Yeah, I would speak on the phone. I appeared on his show a few times.

5 could call a security guard if I couldn't get ahold of his head of security. I could call if I

6 didn't get ahold of Alex.

7 Q Is that Tim Enlow?

8 A I know his name is Tim.

9 Q Okay. And for the record, E-n-1-o-w.

10 And so what do you remember before January 6th about Mr. Jones telling you, if

11 you do remember anything, about walking from the Ellipse to the Capitol? Do you

12 remember him saying anything about that event?

13 A No.

14 Q All right. So you've never heard it from his lips to you that he spoke with

15 someone in the White House or Trump about him walking from the Ellipse to the Capitol?

16 A I don't recall anything like that.

17 Q Okay. Now, are you aware that he said publicly that that happened, that

18 he had -- that he was told by Trump to walk from the Capitol -- from the Ellipse to the

19 Capitol?

20 A I'm not aware of that. Alex is prone to exaggeration and/or could have

21 been referencing Caroline Wren.

22 Q Understood. When it comes to Mr. Stone, do you know -- he has said

23 publicly that he was told, whether by Trump or the White House, that he was going to

24 lead or be a part of leading the walk from the Ellipse to the Capitol. Are you aware that

25 he said that publicly?

 218

1 A I believe so.

2 Q All right. Did he ever talk to you about that before January 6th, what his

3 thoughts or what his beliefs were about what was going to happen in terms of that

4 march?

5 A Not to the best of my recollection.

6 Q So whether anybody -- whether Trump or the White House told him that he

7 was going to be part of that march?

8 A Again, I think this was an idea, as best that I understood it, that originated

9 with Caroline, pinged off me, I said okay, and then was given to Alex and Roger, if it was

10 given to them at all. I could have given -- I could have talked to them about it.

11 Q That's why we're asking.

12 A Okay. Yeah, I don't know.

13 Q We're trying to understand.

14 A Yeah. And I don't know what the play by play of all of that was.

15 Q Was it your understanding that Mr. Jones, from what you observed, that on

16 the morning of January 6th thought that he was going to be speaking that day?

17 A Yes.
 219

2 BYMS.

3 Q Really quickly, do you know a woman named Cindy Chafian?

4 A Yes.

5 Q And did you have any conversations with her about the events on

6 January 5th or 6th?

7 A Yeah. She was the main organizer for the 5th.

8 Q When you say, like, main organizer, what do you mean? Like, how would

9 you describe her role? What does she do?

10 A You know, she -- she took care of all the vendors. And I, again, provided

11 the committee with documentation showing an agreement between Stop the Steal; her

12 group, 80 Percent Coalition; and a pastoral group called, I think, called Peaceably

13 Assemble, and we divided the stage times up, but essentially, Cindy was the head honcho.

14 You know, the permit was under her name. And -- and then I believe the Trump

15 campaign was represented for all of our blocks by Katrina Pierson and some other people

16 that -- again, better documented in what I've provided you all.

17 Q What's your understanding of who paid for or funded January 5th?

18 A Well, I know we had to pay our own bill, so the Stop the Steal portion of -- of

19 our -- of our -- of our thing, we paid for. And, you know, Cindy made reference to a

20 donor, a client. Maybe she said client and not donor. I'm not -- I'm not really sure,

21 but -- but -- and then Alex had teamed up with her to make sure that Alex would have

22 speaking time.

23 This is separate from any conversations about -- brokering a deal about the Ellipse,

24 because I've read press reports that people were given the 5th as a consolation prize.

25 And that's just ridiculous -- ridiculous according to my understanding of the events.

 220

1 Q So just to make sure. Did you produce records regarding your payments

2 related to January 5th and what Stop the Steal --

3 A I believe so.

4 Q -- paid for? Okay. I'm just asking, because I haven't seen it.

5 And it's your understanding that Cindy had a donor or a client, but do you know

6 who that was?

7 A I -- I -- I don't know definitively who it is. I have seen press reports recently

8 of who it may be, but I did not know at the time, and I did not ask.

9 Q Okay. And it's your understanding that Alex Jones also paid for events on

10 the 5th?

11 A Yes. And -- yeah. That -- that was what he said, actually, is what I should

12 say. That was what he said.

13 Q Okay. And do you know a woman named Julie Fancelli?

14 A I don't know her.

15 Q You don't know her. Were you -- was her name mentioned to you by

16 anyone?

17 A If -- I don't believe so. I don't believe so, but, if it was, it would have been

18 in passing. I know that I, you know, didn't probe, haven't done a call to my knowledge

19 with her. I haven't done a call with someone where I -- where she may have secretly

20 been on the phone call that I'm aware of. I've stayed away from all of that.

21 We did small-dollar fundraising on Twitter using DonorBox, and I paid for my crap,

22 and everyone else had to pay for theirs.

23 Ms- Okay.

24 M r . - We can take a break.

25 M r . - Yeah, we can take a break.

 221

1 [Recess.]

2 Mr- So it's 5:25, and we're back on the record.

3 BYMS. •

4 Q If we can turn really quickly to Exhibit 26, and if we could turn to page 113.

5 I think it's the big text string. There is a text in the middle of the page to Ed Martin, and

6 it looks like -- I believe this is Mr. Alexander. You say, can you check to see if we had a

7 $6,000 wire tomorrow to the C3. What is the C3?

8 A His group, the Eagle Forum, was acting as a sponsor for collecting Stop the

9 Steal funds that could be appropriated for that use, and so, all of that money, you know,

10 was kept at Eagle Forum.

11 Q So that's the Eagle Forum's 501{c)(3)? That's what you're referencing?

12 A Yeah, I believe so.

13 Q Okay.

14 A I -- they have a -- they have, like, an umbrella of organizations there, but,

15 yeah, I believe so.

16 Q Okay. No. That makes sense.

17 Earlier, when we were talking about the deplatforming, I want to be clear there,

18 what I'm talking about isn't Twitter or social media. I'm talking about when we were

19 talking about, like, the payment processors. I think you said donations couldn't be

20 processed.

21 Did they tell you why you were being de platformed?

22 A I -- January 6 was a traumatic event. And then, as I was being obliterated

23 on line, I didn't read most of the emails that were coming in. I've watched these type of

24 campaigns go on before, and, you know, they're partisan, so some organizations will send

25 you an email, and then others won't. And some will make it up in their terms of service,
 222

1 and then some will create a new policy and then implement it.

2 Q But you believe there may have been emails from the platforms to you

3 explaining the why of why you were de platformed?

4 A Some of them.

5 Q Okay.

6 A Like, I know, for example, I believe that YouTube did. You know, what

7 you'll do is you'll get -- I went from zero strikes to three strikes in an hour, and it was a

8 retroactive way of punishing me and having plausible deniability.

9 Q Were you fundraising on YouTube, or was that just --

10 A No.

11 Q -- content?

12 A No. I lost it because I'm -- I'm me.

13 Q No. I'm sorry. What I mean is if you were de platformed from content,

14 from posting -- I'm asking about, like, the fundraising deplatform. So were you

15 fundraising on YouTube, or that was just you couldn't post videos?

16 A Yeah, I believe I couldn't post videos --

17 Q Okay.

18 A -- or something like that.

19 Q Did you ever have any conversations verbally -- I -- not emails, with any of

20 the payment processors as to why you were de platformed?

21 A I don't remember.

22 Q Okay. Do you remember using the fundraising site GiveSendGo after

23 January 6th?

24 A Yes.

25 Q And why did you start fundraising with them?

 223

1 A It was a Christian -- it was a Christian site. DonorBox had cut us off, but

2 Stripe had not, and so my -- your Stripe -- you know what Stripe is? Yeah. Okay. So I

3 had to move it somewhere.

4 Q And did you ever have any issues with GiveSendGo in terms of them

5 deplatforming you?

6 A I lost access to my Stripe account, so I couldn't process donations, and

7 they've -- they've either come up with a secondary process that I haven't used, or they

8 haven't figured that out.

9 Q Okay. So, when you lost your Stripe account, you couldn't raise funds, but

10 you could still stay on there and get, like, the prayers and, like, the --

11 A Yep.

12 Q -- the nonfund things?

13 Okay. So do you still have that, the GiveSendGo?

14 A Yes. I believe so.

15 Q And it's related to Stop the Steal specifically?

16 A No. It was related to my personal safety.

17 Q Were you using -- so was there a time period where you were on

18 GiveSendGo using Stripe before Stripe got cut off?

19 A I would have had to use Stripe to process the donation.

20 Q During that time, were the funds from Stripe going to you personally, or just

21 Stop the Steal?

22 A I think I -- I think I lost two Stripe accounts, one for Stop the Steal, and one

23 for myself.

24 Q Okay. At some point -- and I'm not sure when -- let me check -- you started

25 putting -- let me pull it up. I don't want to get it wrong.

 224

1 There was a ways to donate, and I actually don't -- this may have been as

2 of -- sometime right after January 6th. I think you said that the payment processors had

3 cut you off from receiving money, and you would only be able to accept cryptocurrency?

4 Do you know how you started doing that?

5 A No, I don't recall.

6 Q There was a -- I think a ways to donate link that included Bitcoin, Litecoin,

7 Ether, Money Button, PayPal, Cash App, and an Amazon Wish List.

8 A So that sounds like the donate page to my personal site, [Link],

9 you know, that's a few years old.

10 Q It's a few years old?

11 A Yeah, I believe so. My personal site? That's, again, where my content

12 locker was, where, if my existing customers and people who liked my content wanted to

13 give me extra money or whatever, they had different ways to donate.

14 Q You've been taking cryptocurrency for years?

15 A Yeah.

16 Q Not everyone's that knowledgeable about cryptocurrency. Sorry. That

17 was just a moment of marvel.

18 Did you -- would you have been the person to process these -- the -- your personal

19 donations to the [Link] website, or did anybody else process the funds that

20 were donated?

21 A I don't know. I'm actually really horrible with -- with all of that stuff. My

22 intention was to just provide optionality for people. Most of the time, they don't use it.

23 Q Did you ever collect any funds raised from the cryptocurrency?

24 A Related to Stop the Steal?

25 Q Uh-huh.
 225

1 A I don't -- I don't believe so.

2 Q Did you ever end up using any exchanges at all for -- related to

3 cryptocurrency?

4 A Related to Stop the Steal? I do not believe so.

5 Q So that would have been just like personal financial activity to the extent

6 that you used it?

7 A Yeah, I believe so.

8 Q Was that coin-based?

9 A I -- I --yeah, I have a -- I still have a coin-based account.

10 Q Do you have any idea how much money Stop the Steal has raised since it was

11 created in November 2020?

12 A I unfortunately don't. And, in trying to come up with this information, we

13 didn't even discover that our bank account at SunTrust was shut down. So I found that

14 out a few weeks -- well, 4 or 5 weeks ago. And I was told that it was shut down

15 October 24th, I believe so.

16 And so, you know, it survived the FBI investigation and didn't survive this

17 committee's investigation.

18 Q Do you have any -- do you have any cold storage wallets, paper wallets, or

19 public addresses that contain funds related to Stop the Steal?

20 A I don't know. I know that I, like, have, like, really outdated, like, ledger USB

21 things, and -- and I've never used it. I may have had like a friend set it up for me. But,

22 you know, I can't -- I can't recall past that. I buy a lot of little gadgets, you know.

23 think I bought this thing called Everykey once that John McAfee came up with, and

24 it's -- you know, they just sit and collect dust.

25 Q When you say these "sit and collect dust," so you're not using them?
 226

1 A Certainly not actively. And, if I would have used it, then I wouldn't have

2 recalled using it. It's -- seems like a risky endeavor, like -- and I'm scared to screw it up.

3 And so, you know, sometimes -- you know, it's like something I want to sit down and take

4 6 hours to make sure I bulletproof now, but -- but yeah.

5 Q Well, I guess let me ask: To the extent that any of the funds were raised

6 when you were using these links for crypto, where did that go, or who was administering

7 that for you?

8 A I administer my personal crypto. I don't know that Stop the Steal, or

9 January 6th, or anything like that raised crypto. I know that -- again, after I'm

10 deplatformed and you read that message that, you know, I guess is from me, that's not

11 Stop the Steal-related. I'm not raising money for election integrity or politics, I was

12 raising money for my safety, relocation, et cetera, et cetera.

13 Q So, after the events on January 6th, are you raising money for Stop the Steal,

14 LLC?

15 A After January 6th? I believe that we tried to or attempted to, but we've

16 run into problems with SMS sending or email sending, and I'm not sure. I don't want to

17 speak out churn. We could have gone through multiple credit card processors. I'm

18 not sure. And so, you know, it -- it's all kind of like a blurry line. Yeah, it's all kind

19 of -- it's all kind of blurry.

20 Q When you were deplatformed from the payment processors, what made you

21 turn to cryptocurrency?

22 A Well, I -- like I said, personally, I, you know, have been a big fan of crypto

23 for -- for years, and -- and so, you know, if you can't -- if you can't process in, you know,

24 cash or credit card or whatever, then all you have is, you know, crypto.

25 And there are a lot of people around the country who were concerned about my
 227

1 safety. I was concerned about my safety, and I obviously wasn't working, and so, you

2 know -- you know, people say, Oh, you know, do you have this? Do you have that?

3 And a lot of times the people who say that don't do anything for you. They're like, you

4 better have a -- like I hate Ethereum, and everybody was like, you better have a, you

5 know, Ether Wallet, and I'm just like, you know, what am I going to do with it?

6 Q Did you ever have any crypto other than Bitcoin, Litecoin, or Ether?

7 A I'm not sure.

8 Q Did you ever own any Manero, Zcash or Dash?

9 A Related to Stop the Steal, no. I don't believe so. Not at all.

10 Q Personally?

11 A Personally? I may have, but most of that list would have to be a no.

12 Q I think earlier you said that Stop the Steal was at SunTrust, and they shut you

13 down in October. Was that the only bank that you ever used for Stop the Steal funds?

14 A I'm not sure.

15 Q Is that the primary one that you're familiar with?

16 A That is the primary one I'm familiar with.

17 Q Okay. Who was responsible for tracking the accounting for Stop the Steal,

18 LLC?

19 M s - Did you already ask -- I'm sorry.

20 M r . - No.

21 The Witness. Unfortunately, like, no, we were moving too fast, so it's something

22 that falls under -- under my purview, and -- but oftentimes, like, if Stop the Steal couldn't

23 do something, then I would say, Okay, well, I'll loan the money, or I'll pay for this,

24 and -- and, you know, like small things, like, you know, posters or an Uber ride or

25 something like that.

 228

1 And so -- because we didn't have like multiple cards floating around. It was more

2 like, you know, like just get flights, get hotels, get signs, keep moving, you know, faster

3 than we could.

4 BY

5 Q And I apologize. I have not seen your production, but did you produce the

6 Stop the Steal, LLC accounting expenditures?

7 A I don't have access to a SunTrust -- the SunTrust online banking or anything

8 like that. I don't have access to any -- I never got mailed a statement -- a monthly

9 statement or anything like that. So -- so I provided 100 percent of everything I have

10 with SunTrust, which is -- which was the piece of paper that I had, and yeah.

11 Q Am I -- you didn't have access to the SunTrust bank account for Stop the

12 Steal, LLC, or you don't have it now?

13 A Before the -- when I tried logging in --

14 Q Right, because it's shut down now?

15 A Yeah, to comply with this --

16 Q But you had access before October, right? You were on the account?

17 A Yeah. I -- I was on -- yeah.

18 Q Was there anyone else who had access to that account?

19 A I initially authorized my friend, Daniel Bostic, to open it up, and -- and so he

20 opened it up, and there -- you know, there is not a SunTrust in Texas, so that's why I

21 didn't have immediate access. I didn't have an online login, and why I was in the dark.

22 BYMR.

23 Q And, Mr. Alexander, just following up on a comment you made -- and

24 apologies if you talked about this, but I don't think so. Have you had interactions with

25 the FBI or DOJ over January 6th?

 229

1 A The only interactions that I've had with the FBI in relation to January 6 has

2 been handled through counsel.

3 Q So -- okay. But I'm just asking the question -- not privileged. Just have

4 you sat down and been interviewed by the FBI?

5 The Witness. Can I consult with my counsel?

6 Mr. Sure. You can step out. That's fine.

7 [Discussion off the record.]

8 The Witness. No, I've -- I have not been interviewed by the FBI in connection to

9 the January 6 Capitol attack that I had nothing to do with.

10 BY MR.

11 Q How about by the Department of Justice?

12 A No.

13 Q No. Have you provided any information about January 6th to law

14 enforcement? I'm just trying to, broadly speaking.

15 A Yeah. Have I -- I don't recall if I authorized or what I -- what I authorized

16 counsel to, you know, give or not give the FBI, but I myself have never --

17 Q And the reason I'm asking is you brought it up. Is it your understanding

18 that the FBI requested certain things from you, or did they execute a search warrant?

19 A My understanding is that several of my vendors and associates have been

20 harassed or targeted by the FBI, and I was also placed on a -- not the no-fly list, but the

21 SSSS list, so the secondary selective screening, something. It's mandatory selective

22 screening.

23 And I'm trying to think what else. And then I'm aware of -- you know, because of

24 reporting of threat tags that have been assigned to people like me and the FBl's, you

25 know, internal database, so yeah. That's -- that's what I referenced.

 230

1 Q So whatever your counsel has done with law enforcement has been in the

2 context of these -- it sounds like restrictions placed on you, or tags on you. Is that what

3 we're talking about?

4 A No. I mean, additionally, you know, my counsel had -- the counsel who is

5 not here --

6 Q Yeah.

7 A -- had, you know, a conversation with the FBI.

8 Q Okay. Is it your understanding that you're a target of, or that they're

9 threatening criminal charges against you for anything?

10 Mr. Kamenar. I'm going to have to object to that, because that calls for

11 speculation and --

12 Mr. Just what's been told. Not speculation. Whether they -- and it's

13 common practice, or can be for DOJ to say whether someone is a target, to convey it to

14 someone. That's all I'm asking.

15 Mr. Kamenar. Well, again, I think he's talking about conversations with his

16 counsel who is not here, but, you know, target's a specific term --

17 Mr. It is.

18 Mr. Kamenar. -- I suppose, so I don't know whether he can speak --

19 M r . - Just his perception. He can't speak for DOJ.

20 Mr. Kamenar. Perception?

21 Mr. Just what he understands has been conveyed from --

22 The Witness. I'd really not -- I'd like not to speculate on it.

23

24 Q So you don't have a perception about it?

25 A My perception is that I have been, how I've characterized in my opening

 231

1 statement, targeted in the Ali term. But what you guys are talking about is why I defer

2 to counsel and let counsel talk to the FBI, because that's above my pay grade.

3 Q All right. Okay. I think we're clear. Just the point is, to your knowledge,

4 you haven't been told that you're being charged by the government or they're looking to

5 charge you?

6 A Correct.

7 Q Okay. That's all.

8 Ms. • I found it.

9 BY-:

10 Q I think you posted that one of your donation methods was

11

12 A Uh-huh.

13 Q Did you create that?

14 A Yes.

15 Q Okay. And then --

16 A And that's a personal non-Stop the Steal, non- election integrity, non-Jan

17 texting, but something I wanted to answer.

18 Q So what do you take donations for for that? When you say GiveSendGo has

19 disabled my ability to take donations for the time being, you're hoping to get it restored,

20 Bitcoin, Money Button, I'm out of options, Christ is king, what are those donations for?

21 A For religious purposes, spiritual purposes. Sometimes media purposes, like

22 I said, when I, like, made a documentary on a Member of Congress, and -- and then, you

23 know, people just like love me as a public figure. This goes back 10 years -- 10-plus

24 years. People, you know, all across the country just, you know, like me and want, you

25 know, Hey, go buy a steak, go buy a burger, or something like that.

 232

1 It's not -- it predates Stop the Steal. It's not related to Stop the Steal. Money

2 Button was not created after Stop the Steal. And they ultimately shut down my account

3 because of pressure on Twitter.

4 Q Are you familiar with Bit Burner?

5 A Bit Burner?

6 Q Uh-huh.

7 A Nope.

8 Q And you've never used it?

9 A I don't believe so.

10 Q Okay.

11 A I play with a lot of products and stuff, and, you know, test a lot of things, but

12 I -- you know, it's not ringing a bell.

13 Ms.~ Those are my questions.

14 BYMR.

15 Q You just mentioned your opening statement. So your opening statement

16 this morning, you claimed that you demand nonviolence at your events, didn't you,

17 correct? Is that correct?

18 A I do.

19 Q And, during that opening statement, you also claimed that you demand

20 nonviolence among your membership and leadership. Is that correct?

21 A That is correct.

22 Q And you also -- I think the third thing you claimed was that you demand

23 nonviolence among your associates. Is that correct as well?

24 A I -- yes.

25 Q So do you recall, in the lead-up to January 6th, in a Periscope video where

 233

1 you said, We've got to punch the left -- and I quote -- "We've got to punch the left in the

2 nose. You must fight. They will kill us."

3 How does this statement -- explain how this statement does not encourage

4 violence?

5 A I don't recall making that statement on Periscope, and I don't have my

6 Periscope account to authenticate this. It actually sounds like a play on words from

7 Representative Maxine Waters, or Speaker Nancy Pelosi, that I'm playing with.

8 Q And, on December 19th -- you talked about the rally in Arizona earlier today.

9 You said to that crowd, We don't throw bricks. Not yet. Oh, yes, not yet.

10 So, again, is it still your testimony here today that you don't advocate for

11 nonviolence?

12 A That is the -- the literal interpretation of that is advocating for nonviolence

13 right there.

14 Q Okay. And, at this same rally, you said, We will not go quietly. We will

15 shut this country down if we have to.

16 A Yes.

17 Q So saying we will shut this country down if we have to is not advocating for

18 violence?

19 A That's definitely not violence. That's talking about economic activity,

20 parting away from the system. This is a phrase that I actually borrowed from

21 like -- there is groups out there on the left, like, by any means necessary or stuff like that,

22 and so it's just a tool of rhetoric, and it's talking about economic activity.

23 Q Uh-huh. And, on the morning of January 6th -- we talked about this

24 earlier -- you tweeted 1776, right? So, for you, the election had been stolen, so it was

25 time for the people to respond. And, in 1776, being the year that our country declared
 234

1 independence, it was a call to arms.

2 So, leading up to January 6, you're promoting the imagery to the Revolutionary

3 War rather than to a peaceful movement, such as the civil rights movement.

4 So, Mr. Alexander, I want to go back to the text that we talked about earlier from

5 Ms. Wren. It was at 12:59 on January 6, where she said, I think you should leave.

6 This will come down on you hard.

7 She didn't say us. She didn't say the movement. She didn't say Stop the Steal

8 or Women for America First. She said you. After receiving that text, show me where

9 you responded back asking why this attack on the Capitol would come back on you hard.

10 Where did you ask her that question?

11 A That's a very subjective interpretation that I don't agree with.

12 Q So you didn't push back on her assertion?

13 A She was a friend who was concerned about me in a direct text to me.

14 Q And, in fact, after she sent you that text, you left the Capitol complex, didn't

15 you, afterwards?

16 A I made the decision when I left the Capitol complex.

17 Q And you made the [Link] web page blank, didn't you?

18 A We wanted to take down anything that could confuse the association

19 between our peaceful demonstration and the peaceful Lot 8 with anything that was going

20 on inside of the Capitol.

21 Q And you removed the coalition partners from the [Link]

22 website, didn't you?

23 A I believe so, for the same reason that we didn't want to be confused with the

24 violent actors.

25 Q And so that brings us back to the point, right? Why didn't you push back
 235

1 on Ms. Wren's assertion that this would come down on you hard?

2 A I was escaping tear gas.

3 Q It's because you knew she was right, right? You knew that --

4 A No.

5 Q -- some portion of this attack on the Capitol would come back to you,

6 because, for the previous 3 months and leading up to January 6, you had advocated for a

7 revolutionary war? You had tweeted 1776, and that message came to fruition on

8 January 6th, didn't it?

9 A No.

10

11

12

13 Mr. Do you have anything else?

14 M r - Fine. Good.

15 Mr Do you have anything e l s e - ?

16 Ms.-No.

17 Mr Mr. Alexander, thank you for coming in today pursuant to the

18 subpoena for this deposition.

19 With that, we will go into a recess at -- the time being 5:49 p.m. eastern time.

20 The Witness. Thank you.

21 M r . - Thank you.

22 [Whereupon, at 5:50 p.m., the deposition was completed.]

 236

1 Certificate of Deponent/Interviewee

4 I have read the foregoing _ _ pages, which contain the correct transcript of the

5 answers made by me to the questions therein recorded.

10 Witness Name

11

12

13

14 Date

15