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UNITED STATES DISTRICT COURT

WESTERN DISTRICT OF TEXAS

AUSTIN DIVISION

DR. JEROME CORSI and 

LARRY KLAYMAN,

Plaintiffs,

vs.

INFOWARS, LLC, FREE SPEECH 

SYSTEMS, LLC, ALEX E. JONES, 

DAVID JONES, OWEN SHROYER, and 

ROGER STONE

Defendants.

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CIVIL ACTION NO. 1:20-CV-00298-LY

PLAINTIFFS’ JOINT DESIGNATION OF WITNESSES, EXPERTS, AND EXHIBITS

Plaintiffs Larry Klayman and Jerome Corsi (“Plaintiffs”) hereby designate their potential 

witnesses, testifying experts, and proposed exhibits as follows:

I. POTENTIAL WITNESSES

1. Larry Klayman

2. Jerome Corsi

3. Roger Stone

4. Alex Jones

5. Owen Shroyer

6. David Jones

7. Thomas Fitton

8. Randy Credico

9. Victims of the Sandy Hook massacre who were defamed by Alex Jones and the 

Infowars Defendants

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10. Mark Randazza, Esq.

11. Robert Buschel, Esq.

12. Christopher Ruddy

13. John Cardillo

14. John Bachman

15. Mark Cernovich

16. Kelly Morales

17. Cassandra Fairbanks

18. Robert Mueller

19. Andrew Weismann

20. Aaron Zalinsky

21. Jeannie Rhee

22. Hon. Amy Berman Jackson

23. Tucker Carlson

24. Chuck Ross of The Daily Caller

25. Michael Caputo

26. Margaret Kuntsler

27. Dennis Montgomery

28. Sandy Cobas

29. Dianne Thorne

30. Joel Gilbert

31. Scott Reed

32. Bob Barr

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33. Alan Keyes

34. Hon. Royce Lamberth and Hon. Stanley Sporkin

35. Sheriff Joe Arpaio

36. Charles Strange

37. Joseph Farah

38. Witnesses attesting to Dr. Corsi’s affected health and good will and reputation

caused by Defendants

39. Persons who have heard and watched the defamatory statements, which will be 

uncovered as discovery progresses, notwithstanding Defendants’ obstructionist 

tactics.

40. Any witnesses identified by any party or third party in discovery

41. Any witnesses identified in the Amended Complaint

 42. All documents and witnesses put forth by Defendants in their disclosure today.

Plaintiffs reserve the right to supplement this list. Discovery is also underway which will 

uncover more information and documentary evidence.

II. TESTIFYING EXPERTS

Plaintiffs designate no testifying experts at this time, but reserve the right to supplement 

this designation upon discovery.

III. POTENTIAL EXHIBITS

1. The defamatory videos and documents identified and referenced in the Amended 

Complaint

2. Deposition transcript of Thomas Fitton

3. Infowars, LLC’s corporate documents

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4. Free Speech Systems, LLC’s corporate documents

5. Contract between Dr. Corsi and Infowars.

6. Roger Stone’s indictment, jury verdict, and judgment

7. Documents showing Infowars’ commercial sales of goods, services and other 

commercial activities

8. Articles regarding Pizzagate, including but not limited to: 

https://www.rollingstone.com/feature/anatomy-of-a-fake-news-scandal-125877/

9. Articles on Roger Stone admitting to spreading lies on Infowars and settling 

lawsuits, including but not limited to: https://theweek.com/speedreads/813286/roger-stonesettles-lawsuit-admits-spreading-lies-infowars

10. Articles evidencing that Roger Stone is still working with the Infowars 

Defendants, including but not limited to: https://www.infowars.com/posts/roger-stone-revealstrumps-path-to-victory/ and that Stone has a radio show.

11. Affidavits of Larry Klayman and Jerome Corsi and Kelly Morales.

12. Book jackets for books authored by Larry Klayman including Whores: Why and 

How I Came to Fight the Establishment and It Takes a Revolution: Forget the Scandal Industry!

13. Deposition transcript of Roger Stone taken by Mr. Klayman (CASE NO. 19-

011394)

14. New York Times Bestseller lists

15. Any documents identified by any party or third party in discovery.

16. Any documents identified in the Amended Complaint

Insert exhibits identified by the Defendants

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Plaintiffs reserve the right to supplement this list. And discovery is underway despite 

Defendants efforts to obstruct it. Motions to compel will be soon filed, as Plaintiffs have served 

discovery and Defendants have brazenly stonewalled Plaintiffs’ requests. In sum, Plaintiffs 

reserve the right to amend. 

Dated: December 1, 2020 Respectfully Submitted, 

/s/Sanjay Biswas 

SANJAY BISWAS, Esq.

#24061235—Texas

#24966--Louisiana

11720 Duxbury Dr.

Frisco, Texas 75035

Telephone: (972)-866-5879

Email:sanjaybiswas41@gmail.com

Fax: 1-800-506-6804

Counsel for Dr. Jerome Corsi

/s/Larry Klayman 

Larry Klayman

7050 W. Palmetto Park Rd

Boca Raton FL, 33433

Email:leklayman@gmail.com

Fax: 561-558-5336

Plaintiff Pro Se

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this 1st day of December 2020, a true copy of the 

foregoing was filed via ECF and served to all counsel of record though the Court’s ECF system.

/s/ Sanjay Biswas

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