dustin stockton Jennifer bak

<div>never asked about ginni</div><div>
</div><div>===
6 SELECT COMMITTEE TO INVESTIGATE THE
7 JANUARY 6TH ATTACK ON THE U.S. CAPITOL,
8 U.S. HOUSE OF REPRESENTATIVES,
9 WASHINGTON, D.C.
13 DEPOSITION OF: DUSTIN STOCKTON nass atty joshua no firm

Tuesday, December 14, 2021

...6
1 identifies you as one of those anonymous sources, correct?
Yes, that is correct.2
Q So I'd like to talk a little bit about some of the information that's provided by
4 the sources in this article to get us started. The article provides information about
5 communications with Members of Congress. Did you communicate with Members of
6 Congress between Election Day, 2020, and January 6, 2021?
7 A Yes, I did.
Who did you communicate with?
Specifically, there were many members as a result of the three different
10 rallies that we did in D.C., November, December, and January, and then also, traveling
11 around the country. Those members in the House include Madison Cawthorn, Lauren
12 Boebert, Paul Gosar, Good from Virginia, [nick dyer staff]Marjorie Taylor Greene and her staff. Who
13 else spoke? There were many. Several freshmen. I would have to go back and
14 refresh my memory for an exhaustive list.
15 Q So in the article, it refers to communications regarding January 6th
16 specifically. Were you in communication with any of those members about
17 January 6th?
18 A I want to go back just briefly. We also did communicate with Marsha
19 Blackburn on the Senate side, and members of Rand Paul's staff, I believe members of
Ted Cruz's staff as well.
When you say, "we communicated with," who are you referring to?
Specifically, myself; Jennifer Lawrence, my fiance; and Amy and Kylie Kremer
23 from Women for America First.
24 Q Some of those communications, it sounds like, had to do with November and
25 December rallies. Could you describe sort of -- we can start in general terms and maybe
...
11
1 the States that we had identified as being especially susceptible towards manipulation
2 because of the close vote totals was definitely where our primary emphasis was.
3 Q So you've gone into some detail here on a call with Mr. Dyer from
4 Representative Green's staff. Do you remember other specific phone calls you had with
5 members during this time period?
6 A I remember speaking to Dr. Gosar and Tom Van Flein from his staff.
7 remember speaking with --1 mean, Kim Paxton. I believe Louie Gohmert was on that
8 call. I had spoken with -- I remember calls with Marsha Blackburn. She actually
9 provided a video for us before the December event, and was one of the primary people
10 that we were trying to persuade to become an objector.
11 Q Okay. Let's start with Senator Blackburn and move backward then from
12 that. When you say you were trying to persuade her, can you tell me specifically what
13 steps you were taking to try to persuade Senator Blackburn to object?
14 A So, one, we shared the energy and enthusiasm that we were witnessing as
15 we were touring. We also applied pressure in that -- actually, so there's a better
16 explanation that I remember more clearly with another Senator, which is Senator
17 Kennedy from Louisiana  [2nd tour hawley] matt seeley mad cawthore boebert
</div><div>bob good spokr...gohmert alex jones... mo brooks...not rand paul, cruz maybe
...18
1 guidance from. I would say, specifically, Congressman Gosar. I recollect Mo Brooks to
2 a lesser extent. And on the Senate side, I would add Senator Blackburn to that list.
3 Q Okay. You also, before I forget, mentioned the staff of Senator Paul and
4 the staff of Senator Cruz. How would you characterize those communications?
5 A Senator Paul's staff was frankly incredulous that we would even bring it up,
6 and we quickly checked Senator Paul off the potential -- like the list of people that could
7 be persuaded. Senator Cruz, Amy -- I was not there for that call, but I remember Amy
8 characterizing it as -- right, because I remember her specifically using the "We endorsed
9 him at 2 percent" line, and I believe that she had been successful at getting him on board.
10 Q Let's talk about the communications with Congressman Gosar's office, and
11 you mentioned having the relationship with his -- with Tom Van Flein. That's his -- at
12 least was at the time his chief of staff, correct?
I believe so, yes.
So can you describe sort of what your relationship has been like -- you
15 mentioned, I think earlier, you and your fiance, Ms. Lawrence, sort of having a closer
16 relationship with Representative Gosar. How did that relationship form?
17 A I believe the -- going back many years, I -- we had worked elections in
18 Arizona, being from Nevada. It's a neighboring State that's very competitive. We had
19 seen Dr. Gosar at many events that I was speaking at, or where we were endorsing
20 candidates.
21 I remember specifically, I asked Congressman Gosar and Congressman Gohmert at
22 one point to help my daughter with her fourth-grade video project, and they both gave
23 her interviews. And Congressman Gosar has been our best resource inside the Congress
24 for when we were doing a variety of activist campaigns.
25 Over the years, I used a program, that has since been taken offline, but called Rally
pardons we build wall, willard VP staff said trump wd pardon?]
...
31
1 direction; you were made aware of things and then you were trying to filter that
2 information up to Members?
3 A Amy primarily was, like, the centerpiece of those communications. And it
4 was definitely a mixture of both, which is -- I think that -- State-related, so the objectors
5 from each individual State were obviously interested in what the best stuff we had seen
6 as far as election fraud in that State.
7 There was also, right, like, with Matt Sealy or Senator Mastriano, when we would
8 listen to what they were saying or if there was something that was particularly
9 compelling, we would make sure to pass that along.
10 Q You mentioned Mr. Mastriano from Pennsylvania. Are there other State
11 elected officials other than -- you mentioned Attorney General Paxton earlier. Setting
12 those two examples aside, additional State elected representatives that you remember
13 having communications with like that?
14 A I know we -- there were a lot of them who came across our stages. Frankly,
15 the only ones -- I remember Attorney General Paxton. I remember Attorney General
 Landry, the Louisiana attorney general who was opposed to the legal strategy. And then
17 Senator Mastriano. Matt Maddock, Michigan, have a long-term -- he's a State
18 representative in Michigan -- we have a long-term relationship with him and his wife for
19 campaigns and activism we've done in Michigan over the years. Those are the on ones ...
eeded a place to park these buses -- or a bus. Anyway, we had a parking issue with the
2 bus. And Scott Johnston, who is a long-term volunteer and friend of Jen and l's who,
3 like, we kind of looped into this process, we needed to -- we wanted to park the bus at
4 the Trump Hotel in Las Vegas, and he called the hotel, and the hotel manager had told
5 him that the only way he'd let us do it is if a member of the Trump family personally
6 called him. And I remember Amy immediately getting on the phone with Lara Trump
7 and getting that done right away.
8 Q So the reason I ask about that is, to get back to the October 25th Rolling
9 Stone article that sort of provided the jumping-off point for us this morning, it describes I
10 think from you or Ms. Lawrence, you know, the statement that Mr. Meadows was 100
11 percent made aware of what was going on and that he's a regular figure in these really
12 tiny groups of national organizers.
13 And so what I understand you to say is, obviously, to the best of your recollection
14 right now, you don't remember having, other than the three conversations you've
15 mentioned --
16 A So -- and there's actually a ProPublica article that preceded that article that
17 we also go into detail on this on and provided the same chain of events to their
18 fact-checkers.
19 So, very specifically, we had an issue with the permits being changed temporarily
20 by Cindy Chafian that had, I see it as, kind of a butterfly effect point. When we go back,
21 I'm sure we're going to get into detail on that, because it's critical in all this...
nd we didn't -- I didn't like it, but I was asked to help kind of play Switzerland in
2 that, because I hadn't been engaging in any of the, like -- I hadn't really been engaging
3 much in the, like, fighting, because I was so busy putting all this stuff together. So I'd
4 been asked to, like, help facilitate that and help guide the pastors into the agreement and
5 the permitting process and politically what it looked like.
6 And part of that agreement was that all planning and promotion of anything but
7 the one rally on January 6th would stop. And we saw a tweet from Matt Couch, who's a
8 friend of mine, that was continuing to promote this event at the Capitol. And we sent
9 that around, like, one of the internal groups, and were upset by it.
10 And what we decided -- me and Amy put our heads together and decided that it
11 seemed like there was a stalemate between the two factions and the D.C. organizer
12 group. One side was, as we were being told, one side was Katrina Pierson and Kylie,
13 who were advocating for no involvement of the Ali-Alex Jones faction, and Caroline Wren,
14 who was kind of, like, advocating for their participation.</div><div>
15 And that showed us -- I was upset because part of the agreement was that they
16 would drop promotion of it. And I, frankly, didn't want to work with them in the first
17 place, right? But I had agreed to kind of do this January 5th thing and help out with it on
18 the understanding that, like, all right, this is going to stop the crap and we're going to
19 come together for this one last thing and drop all this infighting.
20 And so we put our heads together, and we decided that we would go over
21 everybody's head. And we specifically talked about reaching out to Mark Meadows and
other people with direct regular contact with President Trump, including Mercedes
Schlapp and Gina Loudon. I mean, it was kind of a -- we kind of decided, like,
we'll full- -- and the family -- let's full-court press this. Like, let's put an end to this
garbage....

36
1 I believe I went outside to do a rally, and, shortly after that conversation, Amy
2 sends a text to the full group that both the White House and the campaign are aware of
3 the Ali and Cindy situation and it's taken care of, or it's handled. I'd have to go back to
4 look at it. But I took it to mean that, like, their participation is done. Like, the
5 stalemate is over, it has been settled and in our favor.
6 Q That's very helpful. And there's obviously a lot of detail in the explanation
7 you just gave.

Absolutely.
So I'd like to pick back a couple of things, just to get clarification.
Sure.
One thing you said was having raised concerns to Representative Biggs about
12 Ali Alexander. What were the concerns that you had about Ali Alexander?
13 A So he had been making unhinged public statements. I mean, from our
14 perspective, he was kind of mentally ill and was exhibiting signs of a messiah complex,
15 like, you know, technically. Like, we were genuinely concerned.
16 He had also been leveling really serious attacks against the Kremers that were
17 misogynistic. And him and Roger Stone and Alex Jones had been attacking us because
18 we -- for being too soft, that we wanted -- that we were doing Tea Party rallies and that,
19 you know, this called for far more masculine and angry action.
20 And having traveled the country and having done this for a long time, we knew
21 how high tensions were, and we were concerned, like, between the Periscopes, which
22 made it very personal, I mean, calling the Kremers fat and, you know, Miss Piggys and
23 gluttons and -- right? -- really nasty attacks. Alex Jones was calling me Satanic Santa on
 his show.
25 We saw what they -- while we weren't engaging with them publicly, because w
...beef w flynn] ali took $ and funders thot they wd have a stage?/slot? 1AP security // hell's angels] glock to head if kid vax]...
43
1 permits or even setting up a separate stage on January 5th. Like, Pastor Gibson had
2 worked out with the Parks Department that we could even split Freedom Plaza if we had
3 to, because we really wrestled hard with that, whether we wanted to -- frankly, being at
4 same stage with those kind of people did not seem like good optics or something that we
5 wanted to do.
6 The argument that was made and relayed to us was that, if you don't, then on
7 January 6th all it's going to be is, like, them running around fighting everybody, causing
8 problems. So this is the way that we give them enough so that it's not -- that they don't
9 cause trouble on January 6th.

So who, if you know, kind of forced that appeasement compromise through?
I'm not sure who forced it through. I know that it -- where it was relayed to
12 me and where I was asked to kind of jump in and manage it was from Kylie Kremer and
13 Katrina Pierson.
Q Okay.
I think that's a good stopping point.
BY
17 Q Can I just ask -- quick followup question from earlier. I think you
18 mentioned someone named Nick Funes. Is that right?
Jason Funes.
Jason Funes, excuse me. Who is he?
So Jason Funes worked as -- doing advance work on the bus tour and some
22 of the D.C. rally stuff for us.
23 He was a -- he was a little unhinged, right, and had, like, a -- he would dive into
24 some of the, like, crazier conspiracy stuff and just kind of seemed all over the place. But
25 he had worked for the Department of Interior under Ryan Zinke. And I only met him the
night before the November rally, and he was wearing the Trump team jacket and was
2 introduced to me as a member of the campaign's advance team until just recently.
3 And so we used him for advance, although we -- I continued to take
4 responsibility -- more and more responsibility away from him the longer I worked with
5 him, because he seemed -- it seemed like he was -- suffered a little bit of mental illness
6 stuff.
7 Q And for Ali Alexander, was it your impression that he was working with
8 General Flynn with respect to any of these rallies or just taking Mr. Flynn's money?
9 A So this is a little -- it's kind of a challenging question, because I've learned a
10 lot, even in recent days, that has surprised me considerably.
11 My assumption was that everything Ali was saying was bullshit, frankly. Like, it
12 didn't surprise me that he was talking to some Members of Congress, but the idea that he
13 really was working with the -- just seemed laughable. Like, it was inconceivable to me
14 that that would -- that a guy like that would actually be working with the White House on
15 anything. Like, there's a great solemnity to the White House, and the people who work
16 there -- and they kind of have a responsibility to live up to that. And so, to me, the idea
17 that Ali was doing anything but blustering on that was inconceivable.
18 So, since, I think as things have come out post- that there has -- like, I've come to
19 find some things. I didn't think General Flynn -- the one place I had a concern is that
20 when I saw Gen- -- the encounters I had with General Flynn, he seemed to be surrounded
21 by, like, the same group of Oath Keepers, with Stewart Rhodes, that Ali was kind of
22 floating around with. But I kind of assumed that they were just doing that because they
 were cheap.
24 But it was not -- I did not think -- I thought that -- well, not because -- I remember
25 we had -- and I believe we talked to General Flynn about why he was planning to speak
...
54
1 they had witnessed, and that they were willing to sign sworn affidavits to. So that there
2 definitely was a -- an emphasis on the people making allegations, but not necessarily -- I
3 think kind of -- I've heard a similar line of questioning about this stuff in regards to
4 organizing efforts since to elect and install election officials in some of these positions.
5 And to that regard, I think all of that started post like all January 6th and January 20th.
6 Q So your -- from what you recall or what you were involved with, the
7 conversations with poll workers, it was just to the extent that they had submitted sworn
8 affidavit or had talked publicly about instances of fraud that they thought that they had
9 believed?

Correct.
And for the, like, the sworn affidavits, were those things -- affidavits you
12 obtained or they had already been prepared?
13 A Primarily, they'd been submitted to Sidney Powell or Lin Wood.
14 remember them specifically, like she submitted her -- I remember reading through her
15 submission and it was like hundreds of pages long with, right, lots of different things.
16 And I remember -- I remember it specifically, because we disagreed on some of the tactics
17 in that some of what was included there had come from people that we had kind of
18 deemed when we evaluated them to be less credible.
19 Q So did you say you disagreed on tactics with Sidney Powell, Lin Wood?
20 A Yeah, so when we saw what they were doing publicly and presenting
21 publicly, and I read through the hundreds of pages of what they had submitted to the
22 court, I remember thinking that it had -- it was a mistake to include some of the people
23 that they included, because we'd met them at the stop. I think in several instances we
24 hadn't even allowed them to speak on the stage because we found them that un-credible
[pete sessions is in" knew staff] gosar ed martin
...

63
1 is sacrosanct.
2 At this point in the process, it was the broad coalition that included Ali as kind of,
3 like, the leader of this other group of influencers. And my experiences with Ali in the
4 past led me to believe that I did not want him having access to data that I was collecting.
What experiences did you have previously that led you to that concern?
We've existed in the same space. He used to hold Blog Bash at CPAC every
year. He -- I would see his activist campaigns, I believe him and -- who is the crazy guy
 and the lawyer that we talked about --
Mr. Nass. Lin Wood and Sidney Powell.
The Witness. No, no, Burk -- Burkman. Jacob Wall.
Mr. Nass. Oh, Jacob Wall and Jack Burkman.
The Witness. Right.
Mr. Nass. They actually -- they were here with Ali. I know I'm not sworn, but
14 I'm just -- last week when he was here.
The Witness. Oh, my goodness.
Mr. Nass. I don't know if you're aware of it.
The Witness. I was not.
Mr. Nass. No. All right.
The Witness. I'm sorry. But I had concerns from the very beginning about
20 working with him just because I knew them not to be honest brokers in all cases.
21 Okay. So before we move to specifics for November planning, do
[lindell 250K for bus tour]
...69
1 Virginia -- PA border if any things got really sticky. What's that comment about?
2 A So both Jennifer and I worked for Gun Owners of America for a long time,
3 and it was frankly like braggadocios fluff about knowing a bunch of the patriot groups in
4 Virginia in case, you know -- especially with Cindy and Jason Funes, there was over the
5 top talk about like, Well, what if they come in and start shooting and stuff. So that was
6 kind of my overly braggadocios like, Oh, I know the people in Virginia we could call over if
7 things got sticky.
8 Q Right. And I'm just not familiar with some of the shorthand that you might
9 be using. When you say 3K guys with 2K AR-15s, is that -- what does that mean?
10 A Like the groups -- I mean, the numbers kind of pulled out of thin air, but like
11 Gun Owners of America is headquartered in Virginia. And, so, like I know a bunch of
12 guys with a bunch of guns that we could call if things -- right, if as you're worried about
13 like, you know, the Feds are going to start shooting at us.
So 3K means 3,000 and 2K means 2,000?
Correct.
Sorry, real quick. Did you say, was the concern that the Federal
18 government was going to shoot on you?
19 A Correct. Correct. I'm not saying that that was my concern, but I'm saying
20 with some of the other people who were involved, especially surrounding like the 1AP
21 guys, that their frankly paranoias around some of this stuff was often over the top.
22 BY
23 Q Well, I think that raises an interesting question that I'd be interested in
24 getting your perspective on is, the distinction between what you're getting when you
25 have a licensed professional security firm versus a more volunteer, takes on the loo
...
71
1 And so we literally started having to, like, fight our way through the crowd to try to get to
2 the stage, because I didn't have anybody there to manage it.
3 And on the way there, I ran into one of the lines of guys who like are hands on the
4 shoulders as they kind of moved around and got actually into a shoving match with this
5 group, because I was like trying to break through their line or whatever. And they
6 started pushing, like, right, we got into a verbal altercation, and it turned out to be like
7 Alex Jones' like group around there.
8 Eventually I was able to get through and get to the stage. And at that point, it
9 was my volunteers, and we had set it up -- the speaker lineup at the Supreme Court was
10 like our highest profile speakers, and the Freedom Plaza was, like, the junior varsity, if you
11 will, like the influencers and different people. But like our top draws we had scheduled
12 to be at the Supreme Court.
13 There were so many people there that they were struggling to get, just like we
14 were, to get through the crowd to get to the stage, because we hadn't preset up like a
15 path for people to get through. So by the time I got there and Jen got there, the only
 other high-profile person was Congressman Gohmert, who had managed to work his way
 through the crowd to get to the stage.
18 And that same group that I had had a confrontation with before as I was working
19 my way through the crowd actually physically stormed the stage, and Alex Jones was
20 trying to get to the microphone. And I remember them pushing us off the stage,
21 including Congressman Gohmert. And I'll never forget one of them like shoved Louie,
22 and he said, you realize I'm a Member of Congress, like you don't get to put your hands
23 on me, son.
24 And I made the immediate decision, and like a quick deal with Alex that I would
 allow him to give his speech if they would immediately leave the stage. And at that
...
74
1 Q So is it fair to say these folks who were there as part of either in support of
2 or providing some security for Alex Jones were Oath Keepers?
3 A Yes. Well, I can't speak to all of them, but I made the assumption that they
4 were, because where Stewart goes, usually he's got the same group of, like, national OathKeepers with him.

Q Right.
Do you have anything specific on that?
Q Was Alex Jones under the impression that he was going to speak on that day,
10 whether or not misguided?
11 A So I didn't find this out till later. So we have -- so that happens at the
12 November rally. In the December rally, the day before, Kylie arrives at the Willard, and
13 Alex confronts her, gets right up in her face, like, spittle, right, telling her -- calling her
14 Miss Piggy and that he is going to take over our stage the next day.
15 This time I was prepared for him, though. So Lyndon and the boys, like, we -- I
16 think we had 15, at least 15 to 20 professional security. We also had some stout
17 volunteers, like, kind of surrounding the immediate area. So, when Alex that time tried
18 to take the stage, we beat him back.
19 And the crowd was chanting, like, "We want Alex." And I remember Amy was
20 like, "Don't do it," but I went and I got the microphone, and I explained, "This guy has
21 done nothing but try to sabotage everything we've been doing. And so what kind of
22 man would I be if I allowed this man, who's done nothing but try to attack us and harm
23 us, to get up and use the stage that we paid for, the sound system that we paid for, the
24 security we provided, to speak? I'm not going to let it happen." And then I let Millie
25 Weaver, who had had a, like, big, public falling-out, like, get on the microphone and kind
of taunt him.
2 So that's -- so that confrontation led to him calling me Satanic Santa on his show
3 for a couple -- like, a week. It's on my resume now. I'm kinda proud of it.
4 But, before the January event, January 4th or 5th -- and I've got a picture of
5 this -- I was outside smoking, and I could tell that Alex was lingering and, like, watching
6 me, like, kind of -- like, being courteous to let me finish my phone call. And I didn't
7 really want to talk to him, so, like, I kept talking and talking and talking. And he wasn't
8 going anywhere
...
77
1 was: In your professional work at this time, was a $1,000 one-time contribution a
2 notable donation to the cause?
Yes.
And so --
A Well, I won't say it was overly notable, right? We were getting quite a few.
6 But it was that he did a thou -- I remember he did a thousand dollars and a recurring
7 hundred dollars, which is a significant commitment.
8 Q And when you said earlier raising -- correct me if I'm wrong. I think you
9 had said earlier that the fundraising for Women for America First during this time period
10 generated a few hundred thousand dollars?
Which time period are you referring to?
Well, let me actually just ask you: Between this
13 post-election-to-January-6th timeframe, how much, if you had to ballpark it, were they
14 raising?
15 A I believe, in grassroots contributions, I believe we brought in between
16 $700,000 and $800,000.
17 Q And that does not count the $250,000 donation --
18 A That is not including the Lindell donation or any other large donations the
19 Kremers may have got without my knowledge or, you know, have shared with me.
...ion beforehand, which felt like a very tense situation.
2 The -- I'm trying to think if there's anything else that stands out.
3 It felt real -- like, compared to November, it felt like we had done a really good job
4 at adapting, and we felt that we did a vastly superior job with security. And then also
5 that there were vastly less confrontations between the people who -- we see ourselves as
6 representing, like, the Tea Party grandmas, if you will. And, after the November rally, I
7 remember how upset we were to go home and watch -- there were a bunch of viral
8 videos of, like, Trump people walking back to their hotel and getting attacked, like, even
9 old ladies and stuff. And I remember we didn't -- the feeling in December was
10 that -- there were a bunch of Proud Boys and antifa people who had, like, clashed; like,
11 both sides were out looking for the same fight. So, like, for us, the crazies are the
12 crazies, but our job was to protect and secure, like, the patriotic Americans who were
13 answering our call to come out and have their voices heard. And December felt like we
14 did a really good job with that.

When you say "the crazies are the crazies," is that -- you're referring to --
1mean on both sides. So, like, the -- there are elements, right, within the
17 Proud Boys and some of these -- some of the militia groups that are, frankly -- they're like
18 soccer hooligans. They're looking to get into -- like, they get off on battling each other.
19 And you see it play out in, you know, these events all over the country where you
20 see the leftist crazies and the right-wing crazies fight each other with their shields and all
21 the other silliness.
22 Q But it was your sense that the security you had put in place for December at
23 least was sufficient to protect the Tea Party grandmas or the people who were coming...
[vip mad b/c no badges] p.m.]
2 The Witness. So she tells me that she raised $3 million. She's the one who
3 raised all the money and paid for everything at the Ellipse, and the Kremers paid
4 absolutely nothing, which was news to me because the Kremers had been pressuring me
5 to ramp up fundraising since like Christmas-ish, saying that like we were completely out
6 of money, and we weren't going to be able to continue unless, like, I pulled a rabbit out of
7 the hat. And I was able to go to another guy who's in my business, who was able to do a
8 rev share that was wildly successful in, like, cover stuff.
9 But it was portrayed to me that like we were spending a massive amount of
10 money on this January 6th event. And Caroline told me that she raised the $3 million,
11 and that she parked the money with the Republican Governors Association, TPUSA, and
12 Tea Party Express.
13 And I actually clarified with her, because, like, I assumed she meant Tea Party
14 Patriots, but she clarified that it was Tea Party Express, which seemed interesting because
15 both Amy and I have our political roots there.
16 And she tells me that she's not giving -- that she's not giving the VIP badges over
17 to the Kremers to fuck them over, that's her language, because Kylie Kremer is the worst
18 human being she's ever interacted with, ever, and that -- she also says that Kylie is so
19 stupid that she actually fought to make her organization the one on the, like, headlines,
20 which is just a liability nightmare, right.
21 She's like, I don't -- these people are having, like, blowups over something no one
22 else wants anyway. And she tells me that -- so she tells me about the money. She tells
23 me about the badges. She tells me about parking the money at the different
24 organizations. And she gives me a couple of badges for Jen and I.
25 And I immediately -- and I believe I included these, so it's one of these text threads...

ll of it, but I think she was present for almost all of it.
19 Q Did Caroline tell you anything about her contacts or ability to sort of have
20 persuasion with the White House?
21 A Well, I knew beforehand, I knew Caroline as, like, Kimberly Guilfoyle's, like,
22 fundraising girl. And so, I kind of -- she didn't say it because people who do high-dollar
23 fundraising like that really hoard their like contacts closely. But she was very specific
24 about how much she raised, where she sent it, and what it -- like that she -- that was the
25 money used to pay for everything at the Ellipse even
...
101
1 Q In your professional experience, is it common for fund raisers to, in your
2 words, park money at different organizations?
3 A There is. In the 501{c)4 world, there are these organizations that because
4 of the idiotic way our nonprofit laws are designed, my personal opinion, the (c)4 groups
5 are 51/49, so 51 percent have to be nonpolitical but 49 percent can be political, and you
6 don't have to report the donors in the (c)4 structure.
7 So if you have a big donor who is willing to write you a big political check, you
8 have to have a robust enough percentage, right, to still be 51/49, to stay within the legally
9 mandated, like, percentages of activity. I think I described that pretty well, actually.
10 So there is, on the shadier side of stuff, right, an understanding that there are
11 certain groups that if you have a big political donor who wants to remain anonymous,
12 that, like, they have the extra space to take that money in and spend it politically without
13 it exposing the donor.

16 Express.
17 Q
18 Association?

And you said those three organizations were --
RGA, Republican Governors Association; Turning Point USA; and Tea Party
Did she mention anything about the Republican Attorneys General
I actually may be wrong with the RGA. Maybe it was the -- I actually think
20 you're right, actually. I'm sorry. It was RAG -- the acronyms get mixed sometimes.
21 think it was the Republican Attorneys General. I think I got mixed up with Republican
22 Governors Association.
23 Q So the organizations that Caroline Wren told you she parked the $3 million
24 with was the Republican Attorneys General Association, Turning Point USA, and the Tea
25 Party Express?
...[burner phones]
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1 4th-January 5th that I described earlier and then what I've watched since, I believe, for as
2 ridiculous as he is sometimes, I think Alex Jones was kind of duped into his role of stuff.
3 I don't think that he -- and this is just me talking about -- like, having processed
4 post-everything and then during, I don't think Alex Jones intended causing the violence or
5 doing the violence. I think he was more being set up to be used as, like, a patsy.
6
7 Q
BY
But you I think said that you have heard Alex Jones say he was taken out of
8 the Ellipse by Secret Service --
9 A Yes.
10 Q -- but you witnessed Caroline Wren and Cindy Chafian come and gather him
11 to leave the Ellipse early.
12 A I do remember it being Cindy and Caroline who pulled him and Alex and, like,
13 a couple of people with them, like, out of the VIP.
14 BY
And what about Roger Stone?
Roger -- so I don't remember seeing Roger at all on January 6th.
17 remember seeing him on the 5th, but I don't remember seeing him at all on the 6th.
18 Q Did you have any involvement in what has been coined or has been
19 referenced in the press with the "war room" at the Willard?
20 A So there were several war rooms. So Women for America First, we had our
21 suite. Rudy Giuliani and John Eastman had a suite that I visited briefly a couple times.
22 The Chafian/1AP had a suite on a different floor. I think Flynn had a suite on a different
23 floor. So there were big suites in several places, and, at one point or another, I was in
24 probably all of them...
Well, so the raw and complete video, have you watched it?
No.
I mean, it's not something I think is appropriate or helpful for me to
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4 comment on, because it's not something I have firsthand knowledge of, but it should be a
5 centerpiece of any investigation.
6 Q Well, I guess I'm just trying to understand, in which direction is it skewing?
7 Is it skewing towards this makes the President's supporters look very bad in the face of
8 what's happening? Or does it support the notions of -- you know, there's been
9 suppositions of false flag operations.
10 I'm just asking you, in your opinion, when you say it's hard to square that footage,
11 I don't know what you mean.
12 A So what's clear is that there were paramilitary groups who were directing
13 the crowd and instigating a lot of the violence that day. In the videos I've watched, they
14 wear orange, right, there's identifiable markings.
15 From my time working undercover in some of these anarchist groups, like,
16 globally, I've been exposed to tactically how they use flags to direct and communicate in
 large crowds of these type. I can see those things in the footage that I've watched of
18 the Capitol since.
19 And my sincere hope is that -- I don't know if -- I honestly don't know if they're
20 foreign actors or -- but it's clear to me that there was a well-funded, well-paid group of
21 probably S0ish who were intent specifically on causing violence and chaos that day. And
22 they were aided and abetted by a bunch of assholes from the Proud Boys and some of
23 these other groups.
 But it's clear to me that there is -- that there was a paramilitary group that was
well-trained at moving a crowd. And it wouldn't take a lot of people to kind of -- to
steer that, especially in the absence of the kind of security procedures that we used at
every other event.
3 So, one of the hard things for me is that: We called all these people to D.C. and
4 to our rallies around the country. [stopped molotov cocktail]
bannon boris e navarro] pompeo trump lobby DC [signal app]

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