# Deposition of Ali Alexander, (Dec. 9, 2021)/3:29pm

    BY MR.
Q We will go back on the record at 3:29 p.m.
Going back to exhibit 34, Mr. Alexander. The second physical page. I just want to make sure we're clear. You say, quote/unquote, "One Nation Under God graphics in case the cops ask for a copy of promo so you can deny Wild Protest being totally affiliated or whatever." In this text, "you can deny" refers to Mr. Stephen Brown, correct?
A I'm sorry. I didn't hear the last part of your question.
Q "You can deny," the "you" in "you can deny" refers to Mr. Stephen Brown? Correct?
A I believe so.
Q So that Mr. Stephen Brown can deny Wild Protest being affiliated with the One Nation Under God event? Is that what this is saying?
A I don't know that that's what this is saying.
Q What other plausible explanation could this be saying?
A It could be about him and his persons.
Q Is Mr. Stephen Brown affiliated with Wild Protest or "stop the steal"?
A He's more so affiliated with me. And I think that that's why, when you said, did "stop the steal" hire him, I said I hired him.
Q Let's use our common sense in the ways of the world. You hired Mr. Stephen Brown to file this application. Correct?
A Yes.
Q And he's the one communicating with the Capitol Police about this application. Right?
A Yes.
​Q So he's the one fielding questions from the U.S. Capitol Police about the application. Isn't he?
A Yes.
Q So it would be common sense for him to be able to deny WildProtest's affiliation because he is the one speaking to the U.S. Capitol Police. Isn't he?
A I don't know. I think—I think it's like a leap and a jump. And I don't know. And I don't recall these conversations.
Q Do you recall ever texting Mr. Stephen Brown for him to put, in quotes, 50 people on the application?
A No, I do not recall that.
Q And, since Mr. Stephen Brown is talking to the U.S. Capitol Police, if we just flow down to the next message so that he can deny to the Capitol Police Wild Protest's affiliation, he can also deny your affiliation by putting Nathan Martin's name on there. Does that make sense?
A No. I don't want my name as any point of contact for any vendor, logistics, anything like that, because people calling me would slow me down. I was concerned about political remedies, legal remedies, and legislative remedies. So it was a question of who handles what things and who—I handle the political things. I had consultants to handle other things. And I couldn't afford to be the point of contact for the JW Marriott or travel arrangements or anything like that.
Q So, for this, you are saying that because if he would have put your name on there, you would have been the point of contact for the Capitol Police? Is that what you're saying?
A Yes. I would have had to be able to field questions. I didn't have time to field questions from anyone. And I don't have the expertise to field those questions ​about the permit.
Q Was it Mr. Nathan Martin's expertise to field questions about the Capitol permit?
A It's not his expertise, but he had the time.
Q So is your testimony here today that you put him, Mr. Nathan Martin, on the application so he could field questions from the Capitol Police about the permit?
A No. That is not my testimony, and that is not what this piece of evidence says.
Q I mean, you just said, "I didn't want to put myself on there because I didn't have time to field questions. It is not my expertise," but you put Mr. Nathan Martin on the application to field questions. What is Mr. Nathan Martin fielding questions for?
A I said as a general rule for all "stop the steal" activities.
Q I am talking about this permit.
A I know.
Q Why did you put Mr. Nathan Martin on this application?
A I didn't put him on the application.
Q Why did you instruct Mr. Stephen Brown to put Mr. Nathan Martin on this application?
A I don't know that I instructed him to do that.
Q So it is your testimony here today that you did not instruct Mr. Stephen Brown to put Nathan Martin on the application?
A I don't have any recollection of that. And I haven't been presented with any evidence that says that I directed that.
Q It is a yes or no. Do you recall telling Mr. Nathan Martin—Mr. Stephen Brown to put Nathan Martin on the application?
​A I don't recall.
Q And, even though Mr. Stephen Brown says on here, "I also included Nathan's name on it, I kept yours off so you are below anybody's radar," it is your testimony here today that you did not direct him to do that?
A That is my testimony, that I am not aware that—his message to me is my message to him.
. Do you have any follow up, ?
. I guess I just want to clarify something. It is not a crime to put a different name on a permit. It's not a crime to necessarily keep your name off of a permit. What is a crime is to sit here in front of us and lie about what happened, about the facts of what happened. So, when we're looking at a text that says from you, "I will have the team make separate One Nation Under God graphics in case the cops ask you for a copy of promo so you can deny WildProtest being totally affiliated whatever," and I ask you, did you put the permit under One Nation Under God so that you could deny Wild Protest being affiliated, and your answer is "no" or "I don't recall," which we cannot—maybe put that one aside. Is your answer—I just want a yes or no to that question. Did you put the permit under One Nation Under God—and I'm literally just going to read this—so that you could deny Wild Protest being affiliated with the event?
Mr. McBride. Ms. , I'm sorry. I don't understand the question.
Ms. We have asked lots of questions around this.
Mr. McBride. Sure.
Ms. And I'm literally just asking him.
Mr. McBride. Did he send the message?
Ms. No, no. I think he admitted that he sent the message. I asked him, did he put the permit under—did they, I will say "they," put the permit under One Nation ​Under God so that they could deny WildProtest was affiliated? That seems like a very straightforward—
Mr. Kamenar. But he's also testified why he called it One Nation Under God because of the religious coalition aspect. Okay? So that's already—
Ms. That's fine—
He said, to clarify, Mr. Alexander said he put One Nation Under God because he wanted to put the name of the event instead of the name of an organization.
Mr. Kamenar. Right. And he also testified that that is common practice with respect to filling out permit applications, which he did not fill out, but which his consultant filled out.
    BY :
Q So I just want to confirm that. It's your testimony here today that putting the event One Nation Under God the event name instead of the organization name was told to you by Mr. Stephen Brown? Is that your testimony here today? Or was consulted or advised or told or informed by Mr. Stephen Brown to put One Nation Under God, the name of the event, instead of the name of the organization on the application?
A That's my recollection.
    BY MS. :
Q And now I will go back to my question, because what is common is maybe changing names on permits. But what's not common is telling somebody, in the event that you get asked by cops, you can deny an affiliation. So what I am asking you is, did you put the One Nation Under God permit—excuse me, did you put the permit under One Nation Under God so—I'm quoting from your text—in case the cops ask, you can deny WildProtest being affiliated? I'm literally just asking if you were telling the truth ​when you put this text—those are your words, aren't they?
A I don't recall this text. And so I don't know—
Q I'm not asking if you recall. Are you sitting here today saying that is not your text? Because your text says what it says.
A The text says what it says. So what I'm telling you, you guys asked me to give my complete answer based off of recollection, and I do not know that this text represents a complete answer so that if I positively affirmed that, that that would be the complete reason why the series of events happened with the permit. So that's why I'm saying I do not recall. And I'm trying to be forthright. I am trying to—maybe I add too much stuff.
Q There's a lot of reasons why you might think it would be good for somebody to be able to deny Wild Protest being affiliated. There could be a lot of reasons for that. I honestly don't—there's a myriad number of reasons. The why is separate from the question that I'm asking.
A Okay.
Q Which is, in this text, you say, "I'm having them make separate graphics," and the permit ends up under One Nation Under God. Everything is under One Nation Under God, not your name, and not "stop the steal." And you say, "In case the cops ask you, you can deny WildProtest being affiliated." And all I'm asking you is, was it your intent to do that so this individual could deny an affiliation with WildProtest, whatever the reason is for it?
A I don't—I don't know.
Mr. Kamenar. Did we establish what Wild Protest, that's in caps, is that the name of a particular—
Mr. Wildprotest.com, and please correct this, Mr. Alexander, refers to ​your Wild Protest website and an event you were planning on January 6th?
Mr. Kamenar. Okay. I just wanted to make sure that was the name on the website.
Mr. It is affiliated with "stop the steal."
    BY MR. :
Q Mr. Alexander, do you recall having a planning call with Congressional Members on January 3rd?
A Do I recall having a—
Q A phone call of some sort with Ms. Wren and Congressional Members on January 3rd?
A If that was the—if that was the planning call with all of the speakers, then I recall that that call took place. A call with just Members and Ms. Wren, I do not recall that happening.
Q So there was a call that happened on January 3rd with all the speakers, and that included Congressional Members?
A Did it?
Q I'm asking you, did it include—you just said, was it a call that included all the speakers—was there a call on January 3rd that included congressional speakers and Ms. Wren and yourself?
A I don't—I don't—I don't recall.
Q You don't recall having this call?
A I don't—no, I recall the call taking place. I don't recall who was all in attendance.
Q So you don't recall there being any Congressional Members in attendance on this call?
​A I don't recall who was on the call, but myself and Caroline Wren who spoke.
Q Okay. Can you go to page 164 of exhibit 26? That's your text messages.
A You said page 164?
Q Yes. Ms. Wren says to you, "Who are the Members of Congress that were on who can help lead the coalition to organize buses of their colleagues?" To clarify, this is on January 3rd. And you respond, "Gosar, Lance Goodman, Lauren B, Marjorie, and maybe Congressman Kelley at a minimum were on." It appears Mr. Wren loved it.
So I'll ask you again, do you recall Members of Congress being on a call with you and Ms. Wren on January 3rd?
A I don't recall. And I think this text message, it's asking about—it's not asking about their presence on the call.
Q So go then to page 163, the page right before it. The bottom with Ms. Wren. Actually, we can start in the middle. The time of it is January 3rd around 5 p.m. You are all are talking about an 8 p.m. call.
A Uh-huh.
Q Do you see that? It's on January 3rd?
A Uh-huh.
Mr. Is that a yes?
The Witness. Yes.
    BY :
Q Okay.
And then it looks like Ms. Wren says, "Great." And this is around 6:30. She says: Great, everyone will be muted, but unmute yourself early. I'll credit you with blah, blah, blah. Say don't bug her and say she's here to thank everyone for unity blah, blah, blah. That's what you say.
​A Yeah.
Q And then, at 6:28, Ms. Wren says: Ha, ha, ha, okay, perfect.
So now we're going to go to page 164.
At around 7:33, it appears this is after the call of some sort. I don't know if the time is accurate. I don't know what the time here is. It looks like she says, "Who are the Members of Congress that were on," referring or assuming the call, "who could help lead the coalition," and that's when you respond, "Gosar, Lance Goodman, Lauren B, Marjorie, and maybe Congressman Kelley."
A So I don't know that the call is over at this time. I do know that Caroline Wren exited the call after her portion and she was at the front of that call. And I frequently type and am on the phone. I multitask.
Q So, as you sent the message "Gosar, Lance, Goodman," that's at 7:34. And it looks likes, either 7:34, 7:35, Ms. Wren says, "Great call. Thanks." So, within a minute of you saying it. So it looks like the call was over at this point.
A Her portion is most certainly over. I can't testify here today that I know that the call was over.
Q So let's not talk about whether her portion—do you recall Congressmen being on this call?
A No, I don't.
Q So is your testimony here today that, on January 3rd in a call, it appears with Ms. Caroline Wren, that you were not on a call with Members of Congress—
Mr. Kamenar. He didn't say that.
    BY :
Q Okay. Were you on a call with Members of Congress on January 3rd with Caroline Wren?
​A We invited Members of Congress and/or their staffs. I don't know who was in attendance, because I don't believe that there was a roll call. So I don't recall because I don't believe I can recall.
Q How did you know to send her the names of those Congressional Members?
A Those were Members or their offices that we had definitely invited.
Mr. Do you have questions?
    BY MR
Q Mr. Alexander, I apologize; I was gone. I think your opening statement says you prepared for 120 hours to testify today. Is that right?
A Yes.
Q Okay. And so, as part of that, I imagine your effort was to try to recall the events around January 6th and the days leading up to it.
A I mean, that gets into, you know, what I talked about with my attorneys.
Q I didn't ask about your attorneys. It is just about the fact that you were trying to recall the events and the day of January 6th and the days leading up.
A We've done a lot of documenting. And I've tried to do some recalling, but it was, you know, it's a lot of little details that people expect me to remember that I can't possibly remember 12 months later.
Q And is it part of your normal course to talk with speakers before an event, I imagine?
A Yes.
Q So it would be in the usual course that you would at least a day or two before the event set up a call to talk about expectations for the event with the speakers?
A Either them or their point person.
Q Fair enough. But the point is they need to know what the event is going to ​be about, logistics and that sort of thing. Is that right?
A Or their point person will transport them and tell them 5 minutes before they take a mike.
Q So, given that you had invited people to speak on January 6th at Lot 8, you would at least acknowledge that it would have been part of your practice to set up a call with the invited speakers or their point people?
A Yes.
Q So this text message at least looks like that's what that call was, whether you remember or not, that's what it looks like?
A And I'm saying that that's what it was.
Q It was.
A Okay.
Q And so, when you say you don't recall who was on the call, you at least acknowledge that the call took place?
A A call most certainly took place.
Q And so why did you ask Ms. Wren to be on the call?
A She was there as the Trump campaign representative, as much as I understand it, and had details that I did not have about VIP this or that.
Q Details about what event that you did not have, because your event was Lot 8. Right?
A The Ellipse event and the Lot 8 event, so it is the day's events.
Q Were the Kramers on this call?
A Don't believe so. I didn't invite them.
Q Okay. So we talked about the invited speakers, and I apologize if you covered it, but were these people invited for the Ellipse, Lot 8, or both?
​A Some—some couldn't possibly be Lot 8 because if I'm talking or someone else is talking to a comms director or a chief of staff or a Member, then they couldn't possibly. So it's a combination of either/or.
Q By that point on January—
Mr. This is the 3rd.
Mr. 3rd.
    BY :
Q So, on January 3rd, you already knew no Members were going to be appearing at your event on Lot 8?
A Yeah, I believe so.
Q Okay. And that's because of the timing of the event being that it was going
A Yes.
to be during the certification vote?
Q Okay. So, if it—as of January 3rd, you believed you were still organizing the speakers for the Ellipse rally?
A I was—yeah. I was still—I was still participating in all of that organizing, and all of these text messages established that.
Q And so is it that you don't remember the particular Members of Congress that are on or their staff?
A I don't recall nearly anyone else who was on this call other than me, and Caroline Wren, because it was a large call. I believe that I invited all the speakers. There were a lot of speakers so I wouldn't be able to do a roll call with you on who attended and who didn't or who sent a surrogate or who didn't.
Q Of the people in the text message at least, the Members who are there, who are the ones who you had a connect with directly to either them or their staff? And you ​can look at a text, whether you remember them or not, but go through the names. So start with Paul Gosar. I think you talked about that—him. Is that right?
A Yes.
Q So that would have been through his chief of staff Tom Van Flein?
A Yes.
Q Any other names you can remember?
A No.
Q Okay?
A I did mention earlier in my testimony that I met a staffer or two in Arizona.
Q You don't recall the name?
A Right.
Q And I don't see—I mean, you've been through your texts. You don't see any texts with anyone that appears to be—
A No, no. Definitely not.
Q Lance Goodman, do you know?
A I don't know him personally. I don't know that we've ever spoken personally.
Q Who within your orbit would have—you would expect would have reached out?
A He has a consultant.
Q What's the consultant's name?
A Alexander Brushwitz (ph).
Q And so if Representative Goodman was contacted, you would have expected it to be through Mr. Brushwitz (ph)?
A Yeah, or it might have been another party like Brushwitz (ph) to his comms ​director or something like that. That's my expectation.
Q Do you know how to spell Brushwitz (ph)?
Mr. We can follow up.
Ms. Common spelling.
    BY MR. :
Q All right. So then Lauren B within the text message, I read that as Representative Boebert. Do you as well?
A I think so. And I don't remember if that was a contact with Alexander or with someone else.
Q But not yours?
A No. I don't think I've ever exchanged two words with her.
Q You say Marjorie is the next name. Is that right?
A Yes.
Q Who is that?
A Congresswoman Greene.
Q Do you have any direct contact with her?
A I don't believe so. I know that we've, you know—I think we've, you know, once at the Trump Hotels exchanged pleasantries or an introduction.
Q Enough that you were on a first name basis with her?
A No. I just think that she's awesome.
Q That's fair. But you refer to her in the first name as just shorthand?
A Yeah.
Q Did you have any contact with any staffer of hers or campaign?
A Alexander was her consultant.
Q Understood. And then Congressman Kelly. Did you have any direct ​contact with Congressman Kelly?
A I'm not sure. Rose Tennent was his contact.
Q I think you covered that.
I think that's—
    BY MR.
Q Do you remember who arranged this call on January 3rd?
A I believe that I was the person who initiated this call.
    BY MR. :
Q Were any representations made by Ms. Wren about the expectation for the events from the White House or campaign perspective that you remember?
A I really—I—I don't recall.