IN THE UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRICT OF TEXAS

JEROME CORSI, et al

Plaintiff, 

 v.

INFOWARS LLC, et al

Defendants

 Civil Action No. 1:20-cv-298-LY

 REQUEST FOR HEARING

PLAINTIFF’S SECOND SUPPLEMENT TO MOTION FOR RECONSIDERATION AND 

REPLY TO THE INFOWARS DEFENDANTS’ RESPONSE TO THE REPORT AND 

RECOMMENDATION OF MAGISTRATE ANDREW W. AUSTIN AND MOTION FOR 

LEAVE FILE SECOND AMENDED COMPLAINT

Pursuant to Federal Rule of Procedure (“FRCP”) 15(a), Plaintiffs Larry Klayman and 

Jerome Corsi (“Plaintiffs”) move for leave to file the attached Second Amended Complaint. 

Exhibit A, which notwithstanding the actionable merits of Plaintiffs’ prior Amended Complaint, 

clearly and conclusively moots out the issues in the Magistrate’s Report and Recommendation, 

which was adopted, respectfully in error, by this honorable Court. 

I. LEGAL STANDARD

FRCP Rule 15(a) provides that leave to amend shall be freely given when justice 

requires. “Leave to amend a complaint should be freely given in the absence of undue delay, bad 

faith, undue prejudice to the opposing party, repeated failure to cure deficiencies, or futility.” 

Richardson v. United States, 193 F.3d 545, 548-49 (D.C. Cir. 1999). The U.S. Supreme Court 

has declared that “this mandate is to be heeded.” Foman v. Davis, 371 U.S. 178, 182 (1962); 

Davis v. Liberty Mut. Ins. Co., 871 F.2d 1134, 1136 (D.C. Cir. 1989). The U.S. Supreme Court 

explained that “if the underlying facts or circumstances relied upon by a plaintiff may be a 

proper source of relief, he ought to be afforded an opportunity to test his claim on the merits.” 

Foman, 371 at 182. A plaintiff may even amend a complaint during or after trial, if justice so 

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requires. “A party may move – at any time, even after judgment – to amend the pleadings to 

conform them to the evidence and to raise an unpleaded issue. But failure to amend does not 

affect the result of the trial of that issue.” Fed. R. Civ. P. 15(b)(2). Indeed, “cases should, as far 

as possible, be determined on their merits and not on technicalities . . .” Copeland Motor Co. v. 

General Motors Corp., 199 F.2d 566, 567-68 (5th Cir. 1952). 

II. ARGUMENT

The proposed Second Amended Complaint cures any perceived pleading deficiencies of

the Magistrate and attaches and incorporates the affidavits of Mr. Klayman and Dr. Corsi, as well 

as the affidavits of Ms. Morales and Defendant David Jones himself. These affidavits were 

already in the judicial court record, as they were previously attached to Plaintiffs’ opposition to 

Defendants motions to dismiss. While Plaintiffs respectfully maintain that these affidavits should 

have been considered by Magistrate Austin and this honorable Court in rendering rulings on 

Defendants’ dismissal motions, the fact that they are now attached and incorporated into the 

proposed Second Amended Complaint moots out any possible Fed R. Civ. P. 12(b)(6) issues 

with regard to the “four corners of the Amended Complaint.” 

 Indeed, in adopting Magistrate Austin’s Report and Recommendation, this honorable Court 

specifically found that “[t]he affidavits referenced in Corsi and Klayman's objections were

attached to Corsi and Klayman's opposition briefs and not included with the Amended 

Complaint. The Magistrate is correct to focus on the actual pleadings and the application of the 

Rule 12(b)(6) legal standard.” ECF No. 122 at 3. Nowhere in the Court’s Order does it make the 

finding that the sworn affidavits, if properly considered, would still not be adequate to survive a 

motion to dismiss. Thus, notwithstanding that Plaintiffs properly and in detail pled the actionable 

causes of action against all Defendants, they at a minimum should have been afforded leave to 

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amend their Amended Complaint to incorporate their affidavits, along with Ms. Kelly Morales’ 

sworn affidavit, and moot out any other concerns that the Court might have had. Importantly, 

Defendants offered no affidavits in response, effectively conceding the merits and truthfulness of 

the facts set forth therein.

Now, in the proposed Second Amended Complaint, which is sworn to and verified under 

oath by Plaintiffs Klayman and Corsi, any perceived pleading deficiencies have been cured even 

more – although the Amended Complaint was sufficient as well -- and the affidavits, which 

were already part of the record, are included and incorporated by reference. This means that 

there is no longer any possible contention that a motion to dismiss would be proper.

For instance, with regard to actual malice, the proposed Second Amended Complaint 

makes it abundantly clear that each and every Defendant was intricately familiar with each of the 

Plaintiffs, their work, successes and prominence, and had actual knowledge that the false and 

defamatory statements that they were making were, indeed, false. With regard to Dr. Corsi: 

Dr. Corsi personally knows Defendant Stone he personally knows Dr. Corsi’s 

numerous qualifications. Dr. Corsi has even ghostwritten books for Defendant 

Stone and they used to be friends and colleagues. Defendant Stone is thus 

intimately familiar with Dr. Corsi’s personal and professional history. 

In 2016, after the presidential election, Dr. Corsi worked very closely with Alex 

Jones and his father David Jones, as well as with the Infowars staff, including 

Owen Shroyer. Dr. Corsi made multiple trips to Austin, Texas, to appear live instudio on Infowars broadcasts. Dr. Corsi even accepted an assignment from Alex 

Jones to create for Infowars a news bureau in Washington, D.C.

At all material times, books written by Dr. Corsi were available for sale on the 

Infowars website, which shows that Defendants had actual knowledge that Dr. 

Corsi was not a perjurer, liar, fraud, and alcoholic. SAC ¶¶ 95 – 97.

With regard to Mr. Klayman:

Defendant Stone was a “political consultant” who claimed to help get presidents 

and other politicians elected. The firm made money by then lobbying the very 

men they put in office.

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Because Defendant Stone knew of Mr. Klayman’s successes and capabilities as a 

private lawyer, he told him that he had recommended Mr. Klayman for U.S. 

Attorney when George Bush was President in 1992.

Because he was aware of my prior successes at Judicial Watch and before, 

Defendant Stone wanted to work with Mr. Klayman as his U.S. Senate campaign 

manager. During this time, the spring, summer, and fall of 2003, and in 

preparation for Mr. Klayman’s U.S. Senate run, Defendant Stone researched and 

kept books and records of many of his accomplishments. He had several binders 

(2-3 feet) full of information about Mr. Klayman and the victories that he had 

obtained at Judicial Watch and elsewhere. Again, because Defendant Stone knew 

of Mr. Klayman’s successes and legal political acumen, Defendant Stone wanted 

to be on his team and help him run for the U.S. Senate. SAC ¶¶ 86, 87, 93.

The same is true with regard to Plaintiffs’ claims under the Lanham Act, where the 

Magistrate recommended dismissal because he found that the parties merely “may compete in 

the marketplace of ideas.” ECF No. 108 at 6. The proposed Second Amended Complaint firmly 

establishes “commercial speech” at issue by buttressing the allegations that Plaintiffs and

Defendants are direct competitors in the marketplace:

The Infowars Defendants, each and every one of them, in concert, do substantial 

business and promote and sell various goods in this judicial district and 

nationwide, including medicine, supplements, and “tchotchkes” with their 

branding. SAC ¶ 19

Defendant Stone also does business promotes and sells various goods in this 

judicial district and nationwide, including medicine, supplements, books, and 

“tchotchkes” with his own branding, and he also fundraises by direct mail and the 

internet in this district. SAC ¶ 20.

Plaintiffs Klayman and Corsi are direct competitors with the Defendants and also 

sell products, souvenirs, books, and tchotchkes with their own branding in their 

broadcasts, as they too are conservative talk show hosts, commentators and 

members of the media. SAC ¶ 21

Plaintiff Corsi, like the Defendants, also sells non-prescription pharmaceuticals 

and health products like supplements. SAC. ¶ 22.

Furthermore: 

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Both Plaintiffs derive financial benefit from appearing on radio and internet 

programs as a conservative political analysist and media personalities, as well as 

from their other endeavors as pled herein. 

The Infowars Defendants and Stone also derive financial benefit from appearing 

on radio and internet programs as conservative political analysts and media 

personalities. 

Both Plaintiffs are therefore a direct competitor of the Infowars Defendants and 

Stone, as they all derive income from appearing on radio and internet programs 

and through writings as political analysts, and as media pundits. 

By way of example, Stone, in a recent interview with Real Clear Politics, 

admitted that he intends to host a weekly syndicated radio show and a daily 

podcast in 2021. 

Mr. Klayman also hosts a weekly syndicated radio show and does daily podcasts. 

Dr. Corsi is an investigative journalist and New York Times bestselling author. 

Dr. Corsi, like Plaintiff Klayman, and the Infowars Defendants and Defendant 

Stone all sell books and other tangible goods on their respective websites that 

carry their personal branding for their fans and followers to purchase.

Defendants have directed, made, adopted, and or ratified numerous false or 

misleading statements of fact of and concerning Plaintiffs during their various 

subject programs and media postings and publications as pled herein, which all 

contain significant advertisement or promotions. 

These statements by the Defendants directly reference Plaintiffs’ products and 

services, and deliberately denigrate the quality of Plaintiffs’ products and services 

in order to drive sales, contributions, and money to their own products and 

services instead. SAC ¶¶ 100 – 108.

Furthermore, it is important to note that the original Amended Complaint was not filed to 

cure any perceived deficiencies, only to add Defendant Stone because Plaintiffs thought that this 

honorable Court might want to see him added as a party, and to prevent any claims by 

Defendants that he was a necessary party under Fed. R. Civ. P. 19. This would be the first 

amendment to cure any perceived deficiencies by the Magistrate.

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Lastly, in writing his Report and Recommendation, the Magistrate even referenced that 

amendment could be proper: “Given the lack of any allegations that David Jones personally 

engaged in defamatory conduct, or allegations supporting a basis to pierce the corporate veil or 

to hold David Jones liable on a theory of conspiracy, Plaintiffs’ defamation claims against David 

Jones should be dismissed without prejudice.” ECF No. 108 at 10.

Thus, given that “[l]eave to amend a complaint should be freely given in the absence of 

undue delay, bad faith, undue prejudice to the opposing party, repeated failure to cure 

deficiencies, or futility, ” Richardson 193 F.3d at 548-49, and Plaintiffs having shown good 

cause as to why amendment would not be futile, Plaintiffs respectfully request leave to file the 

attached Second Amended Complaint. This will conclusively moot out any issues now before 

this honorable Court and in the interests of fundamental fairness and justice, allow this case to 

proceed to discovery, which had been denied by the Magistrate. Discovery, like the previously 

submitted sworn affidavits, and this verified Second Amended Complaint, would have provided 

and provides further conclusive support for Plaintiffs’ otherwise well-pled and actionable 

allegations.

Dated: August 5, 2021 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 

Case 1:20-cv-00298-LY-DH Document 147 Filed 08/05/21 Page 6 of 107
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Larry Klayman, Esq.

7050 W. Palmetto Park Rd

Boca Raton FL, 33433

Email:leklayman@gmail.com

Tel: 561-558-5336

Plaintiff Pro Se

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on August 5, 2021 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

Case 1:20-cv-00298-LY-DH Document 147 Filed 08/05/21 Page 7 of 107
EXHIBIT A

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IN THE UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRICT OF TEXAS

DR. JEROME CORSI, Individually

Denville, NJ, 07834

And

LARRY KLAYMAN, Individually

7050 W. Palmetto Park Rd. #15-287

Boca Raton, FL, 33433

Plaintiffs

v.

INFOWARS, LLC

100 Congress Ave., 22nd Floor

Austin, TX 78701

And

FREE SPEECH SYSTEMS, LLC

100 Congress Ave., 22nd Floor

Austin, TX 78701

And

ALEX E. JONES, Individually

3019 Alvin Devane Blvd., Suite 300-350

Austin, TX 78741

And

DAVID JONES, Individually

3019 Alvin Devane Blvd., Suite 300-350

Austin, TX 78741

And

OWEN SHROYER, Individually

3019 Alvin Devane Blvd., Suite 300-350

Austin, TX 78741

And

 Case Number: 1:20-cv-298-LY

 VERIFIED SECOND

AMENDED COMPLAINT 

Case 1:20-cv-00298-LY-DH Document 147 Filed 08/05/21 Page 9 of 107
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ROGER STONE, Individually

447 Coral Way

Fort Lauderdale, FL 33301

Defendants.

INTRODUCTION

Plaintiffs DR. JEROME CORSI (“Plaintiff Corsi or Dr. Corsi”) and LARRY 

KLAYMAN (“Klayman”) hereby files this action against INFOWARS, LLC (“Defendant 

InfoWars”), FREE SPEECH SYSTEMS, LLC (“Defendant Free Speech Systems”), ALEX E. 

JONES (“Defendant Alex Jones”), DAVID JONES (“Defendant David Jones”), OWEN 

SHROYER (“Defendant Shroyer”) (collectively the “Infowars Defendants”), and ROGER 

STONE (“Defendant Stone”) for Defamation, Intentional Infliction of Emotional Distress, and 

Assault, and violation of the Lanham Act.

JURISDICTION AND VENUE

1. This Court has federal question jurisdiction over this case pursuant to 28 U.S.C § 

1331.

2. Venue is proper pursuant to 28 U.S.C. § 1391(b)(2), (3) in that a substantial part 

of the events or omissions giving rise to Plaintiffs’ claims arose in this district. The U.S. District 

Court in the Southern District of Florida transferred this action to this Court. Defendants actions 

were targeted to influence Special Counsel Robert Mueller’s Russian collusion investigation and 

prosecution of Defendant Stone, a colleague of the other Defendants, which and who are

centralized in this judicial district and the defamatory and other illegal acts occurred herein as 

well as throughout the United States and worldwide.

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THE PARTIES

3. Plaintiff Corsi is an author and political commentator who publishes works in this 

judicial district and nationwide. Plaintiff Corsi is a citizen of New Jersey.

4. Plaintiff Klayman is a public interest legal advocate, private practitioner and

litigator who represented Plaintiff Corsi with regard to Special Counsel Robert Mueller’s 

(“Mueller”) Russian collusion investigation. Plaintiff Klayman is also a media personality and 

author, columnist and syndicated radio talk show host. Plaintiff Klayman is a citizen of Florida. 

5. Defendant InfoWars is a Texas limited liability company with principal offices 

located in Austin, TX. 

6. Defendant Free Speech Systems is a Texas limited liability company with principal 

offices located in Austin, TX.

7. Defendant Alex Jones is a well-known extreme fabricator of false stories and 

conspiracies, who has been sued numerous times for alleged defamation. He is media personality

and in effect “shock jock” who creates frequently false and defamatory content for profit that is 

broadcasted on the radio and posted on the internet at www.infowars.com and elsewhere on the 

internet and other social media sites in this district, nationally and internationally. Defendant Alex 

Jones is a citizen of Texas.

8. Defendant David Jones is Defendant Alex Jones’s father and holds the official title 

of Director of Human Relations for Defendant Free Speech Systems. Defendant David Jones runs, 

operates, and manages Infowars and Free Speech Systems in conjunction with Alex Jones and he 

manages the business activities for Defendants Infowars and Free Speech Systems, as well as 

Defendant Alex Jones’ other companies. At all material times he worked in concert with the other 

Defendants and Roger Stone and furthered and ratified and furthered the illegal acts set forth in this 

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Complaint. Exhibit 1, an attached affidavit of Kelly Morales, which is incorporated substantively 

into this Second Amended Complaint, attests under oath to David Smith’s direct and substantial 

involvement in the acts and practices alleged to be illegal in this Second Amended Complaint. In 

another affidavit made by David Jones, he admits, “I have been involved with Alex Jones’ personal 

and business finances for many years....” Exhibit 1.

9. Defendant Shroyer is a newscaster for Defendant InfoWars. Defendant Shroyer is a 

citizen of Texas.

10. Defendant Stone is an individual and a citizen of Florida and a resident of Fort 

Lauderdale, Florida. Defendant Stone was indicted by Special Counsel Robert Mueller as part of the 

alleged “Russian Collusion’ investigation and subsequently convicted on seven felony counts of 

perjury, witness tampering and obstruction of justice. While his 40 month sentence to serve time 

federal prison was commuted by President Donald J. Trump on specious claims he would die in 

prison during Covid-19. He was later pardoned for his felony convictions for perjury, witness 

tampering and obstruction of justice stand. He is a self-proclaimed “Dirty Trickster” who admires 

and frequently extols the “virtues” of Mafia figures and other unsavory persons, who he professes to 

pattern himself after. See Exhibit 2 – Mueller Indictment. 

11. All of the Defendants, each and every one of them, as well as Stone, do substantial 

commercial and other business in this district, not only broadcasting daily into this district for profit, 

but also selling products and services for profit continuously in this district, nationally and 

internationally.

GENERAL ALLEGATIONS

12. Defendant InfoWars and Defendant Free Speech Systems are both owned, 

controlled, and operated by Defendant Alex Jones and David Jones. Defendant Free Speech 

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Systems owns www.infowars.com, where content created by Defendants Alex Jones, Shroyer 

and Stone were at all material times posted and broadcast into this district, nationally and 

internationally.

13. Defendant Alex Jones hosts The Alex Jones Show, which is broadcast on radio 

and internet social media networks throughout the United States of America and internationally, 

including this judicial district, and online. 

14. Defendant David Jones “runs Infowars with Alex Jones and directs, assists and 

helps him with his activities, including fixing media stores and endorsing and/or aiding his 

slanderous and/or fraudulent behaviors, all for profit. This is set forth in the Sworn Declaration 

of Kelly Morales, Alex Jones’ ex-wife. Exhibit 1. Ms. Morales’ affidavit is hereby incorporated 

substantively by reference. 

15. Ms. Morales swears under oath: 

I am the former wife of Defendant Alex Jones. I was married to Alex Jones for 12 

years and with him for 15 years and we have 3 children together. During our time 

together, I was involved in the activities of Alex, his father David and Infowars 

and am intimately knowledgeable about their activities and business structure.

Based on my personal knowledge and experience, David Jones runs Infowars with 

Alex Jones and helps him with his activities, including fixing media stories and 

endorsing and/or aiding his slanderous and/or fraudulent behaviors, all for profit.

Infowars, LLC is a sub-entity of Free Speech Systems, LLC (“FSS”), and David 

Jones is an employee of FSS, or he has been.

David Jones is additionally a managing member of multiple entities that are 

closely held businesses, constituting financial holding companies or financial 

distribution centered around Infowars/Alex Jones’ supplement line, which are 

quintessential to funding and running Infowars.

Alex Jones could not function without David Jones, and has conspired with him 

on the past to commit this breach of fiduciary duty and fraud on my business with 

Alex Jones. While David Jones did this, he slandered and/or defamed me to 

experts and assisted Alex Jones and his attorneys to do the same, so as to 

steal/hide my estate and his grandchildren’s inheritance.

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16. David Jones is additionally a managing member of multiple entities that are 

closely held businesses, constituting financial holding companies or financial distribution 

centered around Infowars/Alex Jones’ supplement line, which are quintessential to funding and 

running Infowars.

17. At all material times Defendant Shroyer hosted The War Room along with 

Defendant Stone and Alex Jones, which is broadcast on radio and internet social media networks 

in this district and throughout the United States of America and nationally, and internationally, 

and online.

18. Defendants’ reach and influence are enormous. On information and belief, 

Defendant Alex Jones and InfoWars has a radio audience of over two million people. Before it 

was banned from YouTube, Defendant Alex Jones’ and InfoWars’ channel had more than 2.4 

million subscribers.1

19. The Infowars Defendants, each and every one of them, in concert, do substantial 

business and promote and sell various goods in this judicial district and nationwide, including 

medicine, supplements, and “tchotchkes” with their branding. The money earned from these 

sales funded the conspiracy and concerted acts between amongst Defendants to defame, 

intimidate, coerce and threaten Plaintiffs by then attempting to improperly influence the Mueller 

Russian collusion investigation and subsequently try to coerce false testimony from Plaintiff 

Corsi at Stone’s criminal prosecution favorable to Defendant Stone once he had been indicted.

20. Defendant Stone also does business promotes and sells various goods in this 

1 Casey Newton, YouTube deletes Alex Jones’ channel for violating its community guidelines, 

The Verge, Aug. 6, 2018, available at: https://www.theverge.com/2018/8/6/17656708/youtubealex-jones-infowars-account-deleted-facebook-apple-spotify

Case 1:20-cv-00298-LY-DH Document 147 Filed 08/05/21 Page 14 of 107
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judicial district and nationwide, including medicine, supplements, books, and “tchotchkes” with 

his own branding, and he also fundraises by direct mail and the internet in this district. He claims 

to have raised millions of dollars with his fundraising, wherein he falsely claims to have been 

persecuted by a federal judge and the jury, despite not having presented one witness, including

himself, at his criminal trial, obviously because he was guilty as charged. In fact, he was 

convicted on seven felony counts in this own words, as the undersigned pro se counsel, Mr. 

Klayman, who sat in on the trial for his client Plaintiff Corsi, can attest. The money earned from 

these sales funds Defendant Stone’s legal defense fund and the conspiracy between Defendants 

and Stone to defame, intimidate, coerce and threaten Plaintiffs in order to first try to improperly 

influence the Mueller Russian collusion investigation and subsequently try to coerce false 

testimony from Plaintiff Corsi, Plaintiff Klayman’s client, favorable to Defendant Stone once he 

had been indicted.

21. Plaintiffs Klayman and Corsi are direct competitors with the Defendants and also 

sell products, souvenirs, books, and tchotchkes with their own branding in their broadcasts, as 

they too are conservative talk show hosts, commentators and members of the media. 

22. Plaintiff Corsi, like the Defendants, also sells non-prescription pharmaceuticals 

and health products like supplements.

23. The Defendants related to Infowars in particular have a long and sordid history of 

publishing and broadcasting defamatory material, including falsely, recklessly and baselessly 

accusing the families of the schoolchildren who lost their lives during the 2012 Sandy Hook 

Elementary School massacre of staging the massacre and faking the deaths of their children.2

2 Aaron Katersky, Families of Sandy Hook shooting victims win legal victory in lawsuit against 

InfoWars, Alex Jones, ABC News, Jan. 11, 2019, available at: 

https://abcnews.go.com/US/families-sandy-hook-shooting-victims-win-legalCase 1:20-cv-00298-LY-DH Document 147 Filed 08/05/21 Page 15 of 107
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24. The Sandy Hook families had to endure years of abuse and torture from 

Defendants before finally filing suit against numerous parties involved with InfoWars, including 

Defendant Alex Jones and Shroyer, for defamation. 

25. As just one example, a Florida woman was arrested for making death threats to a 

parent of a Sandy Hook victim.3 According to the U.S. Department of Justice, the motivation 

behind the threats was the lies propagated by these Defendants that the Sandy Hook massacre 

was a hoax.4

26. Furthermore, Defendant Alex Jones in concert with the other Defendants

propagated and promoted the “Pizzagate” conspiracy on his show, accusing a restaurant called 

Comet Ping Pong in the Washington D.C. area of operating a child sex ring in its non-existent 

basement that purportedly involved Hillary Clinton and John Podesta. This caused one of his 

listeners to shoot up the restaurant after being told by Defendant Jones to “self-investigate” the 

“Pizzagate” conspiracy theory.5

27. Defendants, acting in concert, propagated these outrageous lies with no regard for 

the grief of their victims in order to gain notoriety, fame, and profit. 

28. The Defendants, acting in concert, as part of their latest scheme for notoriety, 

fame, and profit, worked in concert with and on information and belief continue to work in 

concert with Defendant Stone, who was at all material times an integral host on Infowars, and 

victory/story?id=60314174

3 Daniella Silva, Conspiracy Theorist Arrested for Death Threats Against Sandy Hook Parent, 

NBC News, Dec. 7, 2016, available at: https://www.nbcnews.com/news/us-news/conspiracytheorist-arrested-death-threats-against-sandy-hook-parent-n693396

4 Id. 5 James Doubek, Conspiracy Theorist Alex Jones Apologizes For Promoting 'Pizzagate', NPR, 

Mar. 26, 2017, available at: https://www.npr.org/sections/thetwoway/2017/03/26/521545788/conspiracy-theorist-alex-jones-apologizes-for-promoting-pizzagate

Case 1:20-cv-00298-LY-DH Document 147 Filed 08/05/21 Page 16 of 107
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handsomely compensated by it, to defame, intimidate, and threaten Plaintiffs. 

29. Defendant Stone - who was indicted and later convicted on seven counts of 

perjury, witness tampering and obstruction of justice by Special Counsel Robert Mueller and 

then placed under a total gag order by the jurist, the Honorable Amy Berman Jackson, presiding 

over his prosecution for, in part, even threatening her by posting, among other coercive and 

threatening acts, an Instagram meme of a crosshairs, that is a gun, to her head, and subsequently 

convicted on all seven felony counts - has appeared numerous times on shows broadcasted by 

Defendant InfoWars, and hosted by Defendants Alex Jones and Shroyer, where Defendants at 

the direction of Stone and Stone himself have published malicious false, misleading, and 

defamatory statements concerning Plaintiffs.

30. Specifically, the seven count Mueller Indictment against Stone involved lying 

under oath to the federal government - that is, perjury - witness tampering and obstruction of 

justice by threatening to kill a material witness, Randy Credico (“Credico”) and his service dog,

if Credico did not lie or invoke the Fifth Amendment to government authorities concerning his 

involvement with Roger Stone. Credico is Person 2 in the Mueller Indictment of Stone. Id.

Person 1 in this Mueller Indictment is Dr. Corsi.

31. Even before Defendant Stone was indicted, he began a public relations campaign

in this district, nationally and internationally to maliciously defame, smear, intimidate and 

threaten Dr. Corsi and Plaintiff Klayman, Plaintiff Corsi’s lawyer and defense counsel.

32. As just one example, in an article from The New Yorker, Defendant Stone was 

quoted as saying about Plaintiff Corsi, “He’s certifiably insane, and he has told multiple provable 

lies.”6 This malicious defamatory statement, among others, was published in concert with 

6 Jeffrey Toobin, Roger Stone’s and Jerome Corsi’s Time in the Barrel, The New Yorker, Feb. 

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Defendants.

33. Defendant Stone knew that he was going to be indicted, and therefore began this 

public relations campaign to maliciously defame smear, intimidate and threaten Plaintiff Corsi

and Plaintiff Klayman, Corsi’s legal counsel, even before his actual indictment on January 25, 

2019, in order to try to influence public opinion and Special Counsel Robert Mueller – by trying 

to attribute guilt to Plaintiff Corsi and not him - as well as to try to raise money for his legal 

defense. 

34. This defamatory public relations campaign was calculated to coerce Plaintiff 

Corsi to testify falsely at Defendant Stone’s criminal trial before Judge Jackson. 

35. Defendant Stone likes to portray himself as Mafia, and indeed on information and 

belief has Mafia connections, frequently making reference to Mafia figures who he admires, as 

well as other unsavory types who have been alleged to have engaged in unethical and/or illegal 

behavior. For example, he frequently makes reference to his heroes being Hyman Roth in the 

‘Godfather,” who was the movie version of Meyer Lansky, and Roy Cohn, not to mention,

Richard Nixon, for his role in Watergate. In this regard, after Stone was indicted he held a press 

conference on the courthouse steps of the federal courthouse in Ft. Lauderdale, where he was 

booked, with his arms defiantly in the air in the “victory’ pose used by Nixon after he resigned in 

disgrace as a result of the Watergate scandal. At the time, Stone had been employed by a Nixon 

group called CREEP, or the Committee to Reelect the President. Defendant Stone even has a 

large tattoo of Richard Nixon affixed to his back. Thus, given his admiration for persons such as 

these, particularly Mafia figures, his actions as pled herein must be taken as threats, as well as 

being defamatory. And, Plaintiff Corsi is 72 years old and thus very vulnerable emotionally, 

18 & 25 Issue, available at: https://www.newyorker.com/magazine/2019/02/18/roger-stones-andjerome-corsis-time-in-the-barrel

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physically and financially to these threats. Stone’s intentional infliction of emotional distress and 

coercion and threats were intended to try even cause Plaintiff Corsi to have heart attacks and 

strokes, in order that Plaintiff Corsi would be unable to testify at Stone’s criminal trial. Tellingly, 

Stone threatened kill a material witness and his service dog, Credico, Person 2 in the Mueller 

Indictment, “Mafia style.” During his criminal trial, testimony was elicited by the government 

prosecutors in proving their witness and obstruction of justice felony charges, that Defendant 

Stone had told material witness Credico to do a Frank Pentangeli, a Mafia character in the film 

The Godfather, that is not testify to the truth. Stone also fashions himself and indeed has the 

reputation, at a minimum, as being the preeminent “dirty trickster,” of which he is proud. See

“Get Me Roger Stone” on Netflix.

36. By defaming Plaintiffs, Defendant Stone had hoped to not only intimidate 

Plaintiffs to severely harm and damage their reputations, but also to coerce and threaten Plaintiff

Corsi to testify falsely if subpoenaed to be called as a material witness in Stone’s criminal trial. 

He was also trying divert funds away from Dr. Corsi’s legal defense fund and Klayman’s legal 

practice who defended Dr. Corsi in the Mueller Russian Collusion investigation, while boosting 

his own legal defense fund.

37. Stone has also used and continues to employ surrogates and agents, either out in 

the open or secretly, to defame Plaintiffs, such as Defendants herein, and his “friend” Michael 

Caputo, Cassandra Fairbanks, reporter Chuck Ross of The Daily Caller, and Tom Fitton of 

Judicial Watch, to name just a few.

38. Tellingly, in a video published by The Daily Caller, Defendant Shroyer appearing 

with Stone, admits that he will serve as a surrogate, that is an agent for Stone if Stone receives a 

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gag order, which he did. 7 The other Defendants, like Shroyer, are also surrogates and agents of 

Stone, including but not limited to agent and Defendant David Jones, who controls and approves 

of and ratifies the conduct at all material times all of the Defendants.

39. Defendant Stone’s illegal and improper attempts to influence the Russian 

collusion investigation was even recognized by the presiding judge, the Honorable Amy Berman 

Jackson (“Judge Jackson”), who was forced to issue a complete “gag” order on Stone after Stone

attempted to incite violence against Judge Jackson by putting a picture of her face and gun 

crosshairs up on his Instagram account.8

40. In her minute order of February 21, 2019 imposing the total “gag” order on Stone, 

Judge Jackson directly cited and referenced his use of surrogates, such as all of the other 

Defendants herein :

Furthermore, the defendant may not comment publicly about the case indirectly 

by having statements made publicly on his behalf by surrogates, family members, 

spokespersons, representatives, or volunteers.

41. Defendants have, by working in concert with and as agents of Stone, therefore

engaged in illegal witness tampering, intimidation and threats in violation of 18 U.S.C. § 1512 

by virtue of the defamatory and threatening acts and practices as alleged herein. Not 

coincidentally, this was what largely Stone was indicted and convicted for by Special Counsel 

Robert Mueller, for which he was sentenced to 40 months of incarceration a federal penitentiary, 

before he was given clemency and then a pardon for political reasons.

DEFENDANTS’ DEFAMATORY CONDUCT

7 https://www.youtube.com/watch?v=SSDkh5RYtGo

8 Judge in Roger Stone case orders hearing after he appeared to threaten her on Instagram, 

Washington Post, Feb. 19, 2019, available at: 

https://www.washingtonpost.com/politics/2019/02/18/roger-stone-deletes-photo-judge-presidingover-his-case-says-he-didnt-mean-threaten-her/?utm_term=.2d3c5afa6326

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42. Defendant Stone has appeared numerous times on programs of the Defendants, 

The Alex Jones Show and The War Room (and has been a compensated Infowars host in his own 

right). These shows are hosted by Defendant Alex Jones and Shroyer and Stone where numerous 

false, misleading, malicious and defamatory statements of and concerning Plaintiffs were made, 

published, and or ratified by all of the Defendants, each and every one of them, as surrogates and 

agents of Defendant Stone.

43. At all material times Defendants Shroyer and Stone hosted The War Room

together as co-hosts, and therefore planned, coordinated, and worked together in concert to 

produce and create each episode of The War Room, including the episodes at issue which contain 

defamatory material about the Plaintiffs.

44. Defendants Shroyer and Stone also necessarily worked together in concert with 

Defendants Alex Jones and David Jones to plan, coordinate, and execute each and every episode 

of The War Room, with Alex Jones and David Jones being the individuals who manage and 

operate Infowars. 

45. As set forth in the affidavit of Ms. Morales, Exhibit 1, Defendant Alex Jones 

works together in concert with Defendant David Jones to plan, coordinate, and execute his 

defamatory attacks, including those made on Plaintiffs. 

46. Thus, each and every one of the Defendants get together to plan, coordinate, and 

execute each of the episodes of The War Room and The Alex Jones Show. Each Defendant knows 

of and ratifies the defamatory material that will be spewed on each and every episode, as they are 

planned as a group effort.

47. Plaintiffs have demanded retraction and correction of the defamatory videos and 

publications set forth below and generally in this Complaint, but Defendants have arrogantly 

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refused, thereby ratifying any and all defamatory statements contained therein, and compounding 

the damage alleged herein.

48. Defendants, at a minimum, acted recklessly with disregard for the truth, as they 

have known Plaintiff Corsi for a long time, and even worked with him and are also intimately 

familiar with Plaintiff Klayman, so they were well aware that the statements made by the coDefendant Stone, and their own false, misleading, malicious and defamatory statements were, 

indeed, false, as well as their acting as agents of, much less their ratification of the malicious 

false statements published by Defendant Stone on their networks and media sites.

49. In this regard, Plaintiffs have each prepared sworn affidavits, attached hereto as 

Exhibit 3 and Exhibit 4, which sets from their long history with the Defendants and how each of 

the Defendants acted with actual malice. These affidavits are incorporated herein to the Second 

Amended Complaint by reference, as well as what is set forth herein under oath by the Plaintiffs.

50. Mr. Klayman has worked closely with the Infowars Defendants and Stone in the 

past and therefore they are all aware of his legal victories and his capabilities as an attorney and 

his standing and expertise as a columnist, author and syndicated media personality and 

syndicated radio talk show host. Exhibit 3; Affidavit of Larry Klayman attached hereto and 

incorporated by reference. 

51. As the content containing the malicious false, misleading, and defamatory 

statements were published on the internet and elsewhere, it is proliferated like a “cancerous 

virus,” and is was and remains available for viewing from countless sources, thereby 

exponentially increasing the prejudicial and defamatory impact and severe damage inflicted on 

Plaintiffs. Judge Jackson, in issuing her two gag orders against Stone, herself recognized how 

postings calling for physical harm to her and other threatening postings on the internet proliferate 

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widely and once made cannot be taken back.

I. The October 26, 2018 Video

52. In a video from October 26, 2018, Defendant Alex Jones, acting in concert with 

the other Defendants and at their direction, particularly Defendant Stone, makes several false, 

misleading, malicious and defamatory statements about Plaintiff Corsi.9

53. At 0:45, Defendant Alex Jones maliciously and falsely published at the direction 

of Defendant Stone and the other Defendants that Plaintiff Corsi “seemed to be extremely 

mentally degraded to the point of what I would call dementia.” 

54. In the same video, Defendant Alex Jones, acting in concert with and at the 

direction of Defendant Stone and the other Defendants, maliciously fabricates a story where he 

purportedly saw Plaintiff Corsi at a steakhouse “on the ground at another table” and that his 

security staff “thought he was dead in the elevator.” 

55. Dr. Corsi was never “on the ground at another table,” and there was no one that 

“throught [Dr. Corsi] was dead in the elevator.” This is made up by Alex Jones.

56. At 5:08, Defendant Alex Jones, acting in concert with and at the direction of 

Defendant Stone and the other Defendants, after accusing Plaintiff Corsi of having suffered a 

stroke, publishes maliciously that “whatever comes out of his mouth ain’t the truth.”

57. Tellingly and not at all coincidentally, Stone appeared as a guest on the same 

video, as evidence of Defendants working in concert with and as agents of Stone. 

58. These malicious false, misleading, and defamatory statements were published by 

Defendants acting in concert and at the direction of Defendant Stone as Stone’s agents to 

discredit and coerce into false testimony from Plaintiff Corsi in order to preserve the reputation

9 https://www.youtube.com/watch?v=UuXPAn0nZo8

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of and assist their co-conspirator Stone before Mueller’s Russian collusion investigation and later 

prosecution, as Stone had been indicted and Plaintiff Corsi named a material witness. 

Importantly, Plaintiff Corsi was not indicted. Plaintiff Klayman was known by all of the 

Defendants to be Dr. Corsi’s legal counsel.

II. The January 18, 2019 Video

59. Before Defendant Stone was indicted, on or about January 18, 2019, he appeared 

on The War Room with Defendant Shroyer, where he made several malicious false, misleading, 

and defamatory statements in this district, nationally and internationally regarding Plaintiffs

(the “January 18 Video”).10 The same video was published on Stone’s YouTube channel, “Stone 

Cold Truth,” on January 18, 2019.11

60. These malicious false, misleading, and defamatory statements were at the 

direction of all of the Defendants and adopted and published by each and every one of the 

Defendants, rendering them joint tortfeasors and jointly and severally liable. 

61. At 2:09 in the January 18 Video, Stone and the other Defendants working in 

concert and at the direction of Defendant Stone as his agents maliciously and falsely published

that Plaintiff Corsi was “fired from World Net Daily.”

62. Dr. Corsi was never fired from World Net Daily.

63. At 2:27 in the January 18 Video, Stone and the other Defendants working in 

concert and at the direction of Defendant Stone as his agents maliciously falsely and 

misleadingly published that, “He (Corsi) was perfectly willing to lie, to perjure himself saying 

that a memo that he had wrote me was written on the 30th for the purposes of cover-up.... which 

is further proof that Jerry lied under oath.”

10 https://www.infowars.com/watch/?video=5c3fbf24fe49383dcf6996e4

11 https://www.youtube.com/watch?v=cJyfgdvtFx8

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64. At 2:55 in the January 18 Video, Stone and the other Defendants working in 

concert with at the direction of and as agents of Defendant Stone maliciously falsely and 

misleadingly published, “and then states that I knew about John Podesta’s emails being stolen in 

advance, the only proof of that is Jerry’s feeble alcohol affected memory – it’s a lie....”

65. Dr. Corsi is not an alcoholic, and has never had a single alcohol-related offense on 

his record.

66. At 3:35 in the January 18 Video, Stone and the other Defendants working in 

concert at the direction of and as agents of Defendant Stone maliciously falsely and misleadingly 

published that “Jerry was prepared to stab a principle Trump supporter in the back, he was 

perfectly prepared to bear false witness against me, even though I had done nothing in my entire 

life other than help him.”

67. At 4:20 in the January 18 Video, Stone and the other Defendants working in 

concert with and at the direction and as agents of Defendant Stone maliciously falsely and 

misleadingly published that “all I ever did was show Jerry Corsi friendship and support and try to 

help him and his family and what I get is Judas Iscariot, the willingness to testify against me and 

help the deep state bury me....and then he makes up this story about helping me formulate a 

cover story.” 

68. At 6:26 in the January 18 Video, Stone and the other Defendants working in 

concert with and as agents at the direction of Defendant Stone maliciously falsely published that 

“you can always tell when Jerry Corsi is lying because his lips are moving....”

69. At 1:25 in the January 18 Video, Stone and the other Defendants working in 

concert with and as agents at the direction of Defendant Stone maliciously falsely published that 

“He’s (Klayman) never actually won a courtroom victory in his life.”

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70. This is false, and Defendant Stone knows that this is false. Just a small sampling 

of Mr. Klayman’s numerous courtroom victories is set forth in Mr. Klayman’s affidavit. Exhibit

3. 

71. At 1:30 in the January 18 Video, Stone and the other Defendants working in 

concert and as agents at the direction of Defendant Stone maliciously falsely published, “He 

(Klayman) was ousted at Judicial Watch. Ask Tom Fitton [the current president of Judicial 

Watch] why he left. He was ‘ousted’ because of a ‘sexual harassment complaint.’”

72. In actuality and truth, Plaintiff Klayman left Judicial Watch voluntarily on his 

own accord in order to run for U.S. Senate in Florida in 2003-2004.

73. Indeed, at a deposition in another matter, Thomas Fitton was forced to admit 

“[n]o, because that's not true. You weren't ousted as a result of a sexual harassment complaint.” 

Exhibit 5. Thus, Defendant Stone’s assertion is patently false, and completely fabricated by 

Defendant Stone, evidencing actual malice. 

74. Defendant Stone cannot even credibly assert that he lacked actual malice and 

simply misunderstood Fitton. At his deposition, he was forced to admit that he never actually 

spoke to Fitton: 

Q. You've spoken to Tom Fitton, haven't you?

A. One time in my entire life. I saw him backstage at a conference in -- at Dural, 

maybe a couple months ago, and we -- we shook hands in passing. Beyond that, 

I've never spoken to the man. Exhibit 5.

75. This shows that Defendant Stone simply made this up, with obvious knowledge of 

its falsity, because he had absolutely no basis to make this false statement. 

76. At 1:37 in the January 18 Video, Stone acting in concert with the other 

Defendants maliciously working in concert with the other Defendants falsely published, “He’s 

(Klayman) incompetent, he’s a numbskull, he’s an idiot, he’s an egomaniac, and he could be the 

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single worst lawyer in America. With him as Jerry Corsi’s lawyer, Corsi may get the electric 

chair. So your idea that he’s a good guy is entirely wrong”

77. In actuality, Plaintiff Klayman has been a practicing attorney for over four 

decades and has won numerous cases on behalf of his clients and also against the government for 

constitutional and other violations. He is the founder of both Judicial Watch and Freedom 

Watch, a former candidate for the U.S. Senate in Florida, a former trial attorney and prosecutor 

of the Antitrust Division of the U.S. Department of Justice, where he was a member of the trial 

team that successfully broke up the AT&T monopoly and created competition in the 

telecommunications industry. Among many other legal victories, Plaintiff Klayman also won 

landmark decisions at the chairman and general counsel of Freedom Watch enjoining the illegal 

mass surveillance by the National Security Agency. Klayman v. Obama, 1:13-cv-851 (D.D.C).

Stone knew this when working in concert with the other Defendants he published acting in 

concert with the other Defendants the malicious false and misleading statements about Klayman

and thus willfully and maliciously defamed Plaintiff Klayman.

78. At 2:01 in the January 18 Video, Stone maliciously working in concert with the 

other Defendants falsely and misleadingly published that Plaintiff Klayman is a “piece of 

garbage.”

79. At 4:11 in the January 18 Video, Stone maliciously working in concert with the 

other Defendants falsely and misleadingly published, “For those people out there who 

think...that Larry Klayman’s IQ is higher than 70, you’re wrong...”

80. Defendants, all of them working in concert and as agents of Defendant Stone,

published these malicious false, misleading, and defamatory statements with actual malice and 

with full knowledge that they were false and misleading, and/or at a minimum, with a reckless 

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disregard for its truthfulness. These statements falsely and misleadingly state that Plaintiff Corsi 

was fired from World Net Daily, that he committed perjury (a federal offense), and that he is an 

untruthful person. They also create the false and misleading implication that Plaintiff Klayman is 

unqualified to be an attorney, public advocate and is a bad and loathsome person, unfit for his 

trades and professions. Plaintiff Klayman is also an author, columnist and nationally syndicated 

radio and internet talk show host on Radio America, his show titled “Special Prosecutor with 

Larry Klayman.” See www.radioamerica.com. The malicious false and misleading published 

statements as alleged herein also severely damaged Plaintiff Klayman personally and 

professionally in this regard, particularly since he and his show compete with Defendant 

InfoWars and and the other Defendants in media markets in this district, nationally and 

internationally. Plaintiff Corsi also competes with Defendant InfoWars and the other Defendants 

in media markets in this district, nationally and internationally.

III. Other Malicious Defamatory Publications

81. In another appearance on InfoWars which was posted to YouTube12 on January 

17, 2019, Defendant Stone working in concert with the other Defendants at 6:22 maliciously 

falsely and misleadingly published that “He [Corsi] was perfectly willing to bear false witness 

against me on multiple points that are complete fabrications.”

82. In another appearance on InfoWars, this time on The Alex Jones Show from 

January 21, 2019, Defendant Stone maliciously working in concert with the other Defendants 

falsely and misleadingly published that “the good doctor [Corsi] has told a number of lies. In 

fact, he’s starting to conflate his lies.... he was perfectly willing to lie about me.... but now lying 

about Alex Jones, lying about InfoWars, lying about Dr. (David) Jones, who’s one of the nicest, 

12 https://www.youtube.com/watch?v=GJd8YBDvm1Q

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gentlest, sweetest, most honest men I have ever met, it’s beyond the pale.... Jerry Corsi can no 

longer be believed.”13

83. In the same appearance, Stone maliciously working in concert with the other 

Defendants falsely and misleadingly published that, “I think you’ve [Corsi] been deep state from 

the beginning. Your whole birther thing is used as a club to destroy conservatives....I look 

forward to our confrontation. I will demolish you. You’re a fraudster, out of your alcoholic haze 

you have made up lies about David Jones and Alex Jones and Roger Stone and now I suspect 

they want you to lie about the President.” This is clearly a threat, as well as being maliciously 

defamatory. It is akin to the threats against Person 2 in the Mueller Indictment, Randy Credico,

who Defendant Stone, as set forth in the Mueller Indictment, based on Stone’s own words 

contained in his own documentary evidence, threatened to kill along with Credico’s service dog.

Later Stone threatened the judge presiding over his criminal prosecution, the Honorable Amy 

Berman Jackson.

84. In the same January 21, 2019 video, at 43:40, Defendant Alex Jones maliciously 

acting in concert with the other Defendants and as an agent at the direction of Defendant Stone 

falsely accuses Plaintiff Corsi of being a “spook, back and forth with different agencies,” falsely 

saying that Dr. Corsi had worked with different government agencies.

85. Defendant Alex Jones further maliciously acting in concert with the other 

Defendants and at the direction as an agent of Defendant Stone falsely accuses Plaintiff Corsi of 

sometimes “not being able to walk,” creating the false and defamatory implication that he is an 

alcoholic.

86. Defendants acting in concert as an agent at the direction of Stone published these 

13 https://www.youtube.com/watch?v=ANfe9d7YzL0 (Beginning at 38:00)

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false, misleading, and defamatory statements at the direction and agent of and in concert with 

Stone with actual malice and with full knowledge that they were false and misleading, and/or at a 

minimum, with a reckless disregard for their truthfulness. These statements falsely and 

misleadingly published that Plaintiff Corsi committed perjury (a federal offense), is an untruthful 

person, and is an alcoholic. They also contain threats, amplified by Defendants facial expressions 

and hostile demeanor against Plaintiff Corsi and his legal counsel Larry Klayman. 

87. The actual malice of the Defendants is evidenced by the fact that at all material 

times, books written by Dr. Corsi were available for sale on the Infowars website, which shows 

that Defendants had actual knowledge that Dr. Corsi was not a perjurer, liar, fraud, and alcoholic. 

Otherwise, if the Defendants thought that these false statements concerning Dr. Corsi were 

actually true, they obviously would not carry his books for sale on their website.

88. Defendants, acting at the direction and working in concert with Stone, obviously 

believed that in order to advance their interests and improper if not criminal motivations, they 

also had to destroy and severely harm the legal counsel of Plaintiff Corsi, who had been at all 

material times representing Plaintiff Corsi before Special Counsel Robert Mueller, congressional 

committees and generally and counseled Plaintiff Corsi when he was subpoenaed to testify 

truthfully in Stone’s criminal trial for perjury, witness tampering, threatening to kill a material 

witness and his service dog, as well as obstruction of justice. Corsi, despite all of this, was never 

called as a witness by Defendant Stone, since Stone and his legal counsel must have concluded 

that his truthful testimony would not have benefited Stone.

FACTS PERTAINING TO ACTUAL MALICE

89. Each and every Defendant is intricately familiar with both Mr. Klayman and Dr. 

Corsi, having worked closely with them in the past. Thus, each and every Defendant had actual 

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knowledge that the statements at issue in this action were false.

90. Mr. Klayman met Defendant Stone at the Old Ebbitt Grill in Washington, D.C. in 

1988 while he was a partner with Paul Manafort and others and Mr. Klayman was working as a 

lobbyist for the firm Black, Manafort, Stone, & Kelly. 

91. Defendant Stone was a “political consultant” who claimed to help get presidents 

and other politicians elected. The firm made money by then lobbying the very men they put in 

office.

92. Because Defendant Stone knew of Mr. Klayman’s successes and capabilities as a 

private lawyer, he told him that he had recommended Mr. Klayman for U.S. Attorney when 

George Bush was President in 1992.

93. In 1996, at a Republican Convention in San Diego, California, Defendant Stone 

was filmed at a “toga party” with his wife at a “swingers party.”

94. The media at the time went after Defendant Stone because of his alleged 

participation in the “sex party” and created a scandal. 

95. The media alleged at the time that Defendant Stone solicited sex half-naked, and 

that there was a picture of Defendant Stone in a compromising position to back up the story. 

96. Defendant Stone contacted Mr. Klayman and, because he knew Mr. Klayman’s

capabilities and acumen as a lawyer, retained him to get the media to cease what he claimed then 

was a smear campaign.

97. Mr. Klayman maintained sporadic contact with Defendant Stone until 2003 when 

he told Defendant Stone of his plans to voluntarily leave Judicial Watch and run for the U.S. 

Senate.

98. Because he was aware of my prior successes at Judicial Watch and before, 

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Defendant Stone wanted to work with Mr. Klayman as his U.S. Senate campaign manager. 

During this time, the spring, summer, and fall of 2003, and in preparation for Mr. Klayman’s 

U.S. Senate run, Defendant Stone researched and kept books and records of many of his 

accomplishments. He had several binders (2-3 feet) full of information about Mr. Klayman and 

the victories that he had obtained at Judicial Watch and elsewhere. Again, because Defendant 

Stone knew of Mr. Klayman’s successes and legal political acumen, Defendant Stone wanted to 

be on his team and help him run for the U.S. Senate.

99. Mr. Klayman also has a long history and working relationship with the Infowars 

Defendants, with Each of the Infowars Defendants, Alex Jones, David Jones, Owen Shroyer, 

Free Speech and Infowars, being intimately familiar with his background, qualifications and 

successes as a public interest and private attorney. For this reason, Mr. Klayman was previously 

invited to appear on Infowars on many occasions before the Infowars Defendants decided – at 

the direction of Defendant Stone – to defame Plaintiffs. 

100. Dr. Corsi personally knows Defendant Stone he personally knows Dr. Corsi’s 

numerous qualifications. Dr. Corsi has even ghostwritten books for Defendant Stone and they 

used to be friends and colleagues. Defendant Stone is thus intimately familiar with Dr. Corsi’s 

personal and professional history. 

101. In 2016, after the presidential election, Dr. Corsi worked very closely with Alex 

Jones and his father David Jones, as well as with the Infowars staff, including Owen Shroyer. Dr. 

Corsi made multiple trips to Austin, Texas, to appear live in-studio on Infowars broadcasts. Dr. 

Corsi even accepted an assignment from Alex Jones to create for Infowars a news bureau in 

Washington, D.C.

102. At all material times, books written by Dr. Corsi were available for sale on the 

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Infowars website, which shows that Defendants had actual knowledge that Dr. Corsi was not a 

perjurer, liar, fraud, and alcoholic. 

FACTS PERTAINING TO DEFENDANTS’ UNFAIR COMPETITION

103. In addition to being an investigative journalist/author and a public interest 

litigator/advocate, respectively, Plaintiffs Corsi and Plaintiff Klayman are both competitors to 

each and every one of the Defendants as conservative media personalities, broadcasters, authors 

and columnists and salesmen on social media and elsewhere. See Exhibits 3 and 4.

104. Mr. Klayman is the founder, Chairman and General Counsel of Freedom Watch, 

Inc., which has the mission of investigating and prosecuting government corruption and abuse 

through legal advocacy. He also is in private practice with The Klayman Law Group, P.A. He is 

unique as a public interest advocate. He is at all material times a columnist for World Net Daily 

and has had about 600+ columns published over the last 10 years. He has also been a columnist 

for Newsmax through a blog titled “Klayman’ Court” and in addition to his book “Whores: How 

and Why I Came to Fight the Establishment”, he also published three other books. He also has 

his own syndicated radio show and daily podcasts with Radio America called “Special 

Prosecutor with Larry Klayman.” See Exhibit 3.

105. Both Plaintiffs derive financial benefit from appearing on radio and internet 

programs as a conservative political analysist and media personalities, as well as from their other 

endeavors as pled herein. 

106. The Infowars Defendants and Stone also derive financial benefit from appearing 

on radio and internet programs as conservative political analysts and media personalities. See

Exhibit 3.

107. Both Plaintiffs are therefore a direct competitor of the Infowars Defendants and 

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Stone, as they all derive income from appearing on radio and internet programs and through 

writings as political analysts, and as media pundits. See Exhibit 3. 

108. By way of example, Stone, in a recent interview with Real Clear Politics, 

admitted that he intends to host a weekly syndicated radio show and a daily podcast in 2021. See

Exhibit 3.

109. Mr. Klayman also hosts a weekly syndicated radio show and does daily podcasts. 

See Exhibit 3.

110. Dr. Corsi is an investigative journalist and New York Times bestselling author. 

Exhibit 4. 

111. As also plead previously, Dr. Corsi, like Plaintiff Klayman, and the Infowars 

Defendants and Defendant Stone all sell books and other tangible goods on their respective 

websites that carry their personal branding for their fans and followers to purchase.

112. Defendants have directed, made, adopted, and or ratified numerous false or 

misleading statements of fact of and concerning Plaintiffs during their various subject programs

and media postings and publications as pled herein, which all contain significant advertisement 

or promotions.

113. These statements by the Defendants directly reference Plaintiffs’ products and 

services, and deliberately denigrate the quality of Plaintiffs’ products and services in order to 

drive sales, contributions, and money to their own products and services instead. 

114. These false and/or misleading facts materially prejudice the viewers and/or 

listeners as to the quality, nature, and contents of Plaintiffs’ services and goods for sale, which 

has caused significant competitive and commercial injury to Plaintiffs, as well as loss of good 

will and reputation.

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115. These false and/or misleading facts in effect refer specifically to Plaintiffs’ 

products and services by falsely advertising about Plaintiffs.

116. Plaintiffs, like Defendants, rely on viewer and listener financial and other support 

and sales and their reputations and good will in order to continue their work. Defendants’ false 

and/or misleading statements concerning Plaintiffs is meant to, and has, diverted financial and 

other support, referrals and sales away from Plaintiffs and to Defendants instead, and severely 

harmed Plaintiffs’ personal and professional reputations.

117. Thus, Defendants had a strong economic motivation to make these false and/or 

misleading statements concerning Plaintiffs’ goods and services.

FIRST CAUSE OF ACTION

Defamation

118. Plaintiffs re-alleges and incorporates by reference the allegations in the preceding 

paragraphs of the Complaint as if fully set forth herein.

119. Acting in concert Defendants and as an agent at the direction of Defendant Stone 

published the aforementioned malicious, false, misleading and defamatory statements of and 

concerning Plaintiffs in this judicial district, nationwide, and worldwide.

120. These false and misleading statements were published with actual malice, as 

Defendants knew that they were false and misleading, or at a minimum acted with a reckless 

disregard for the truth.

121. Plaintiffs have been severely harmed and damaged by these false and misleading 

statements because they subjected him to hatred, distrust, ridicule, contempt, and disgrace.

122. Plaintiffs have been damaged by these false and misleading statements because 

they severely injured Plaintiff Corsi and Plaintiff Klayman in their profession and businesses, as

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well as severely injured and damaged them personally and professionally, financially, 

emotionally, and in terms of their good will and reputations.

SECOND CAUSE OF ACTION

Defamation Per Se

123. Plaintiffs re-alleges and incorporates by reference the allegations in the preceding 

paragraphs of the Complaint as if fully set forth herein.

124. Acting in concert, Defendants as alleged herein, published the aforementioned

numerous false, misleading and defamatory statements to severely harm and damage Plaintiffs, 

which were republished elsewhere and widely in this district, nationally and internationally, and 

through surrogates, which and wo published the falsities that Plaintiffs have committed crimes, 

including perjury, and engaged in moral turpitude in the form of alcoholism, and committed 

sexual misconduct, as set forth in the preceding paragraphs. These malicious and false statements 

defamed Plaintiffs in their trades and professions.

125. These false, misleading and defamatory statements were published in this district 

and on the internet and elsewhere, domestically and internationally for the entire world to see 

and hear and in so doing Defendants published false and misleading facts, inter alia, that 

Plaintiffs’ conduct, characteristics or a condition are incompatible with the proper exercise of 

their lawful business, trades, professions or offices, as well as personally.

126. These false and misleading statements were published with actual malice, as 

Defendants knew that they were false and misleading, and/or at a minimum acted with a reckless 

disregard for the truth.

127. This statements are per se defamatory because they falsely and misleadingly 

published that Plaintiff Corsi committed perjury and Plaintiff Klayman had committed sexual 

misconduct which are federal offense and felony, as well as defamed Plaintiffs in their trades and 

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professions. Defamation per se gives rise to the presumption that severe harm and damage has 

arisen by virtue of the malicious false and misleading statements.

128. These malicious false, misleading, and defamatory statements are defamatory per 

se and these false and misleading statements severely harmed and damaged Plaintiff Corsi in this 

profession and business as a journalist, author and political commentator, whose credibility is the 

most important trait, as well as personally and Plaintiff Klayman in his professions as a public 

interest and private advocate and litigator and as an author, columnist and radio and internet 

radio talk show and syndicated host, as well as personally.

THIRD CAUSE OF ACTION

Defamation by Implication

129. Plaintiffs re-alleges and incorporates by reference the allegations in the preceding 

paragraphs of the Complaint as if fully set forth herein.

130. Acting in concert, Defendants published the aforementioned numerous false, 

misleading and defamatory statements about Plaintiffs, as set forth in the preceding paragraphs.

131. These false, misleading and defamatory statements were published on the internet 

and published and republished elsewhere in this district, domestically and internationally for the 

entire world to see and hear. 

132. These false and misleading statements were published with actual malice, as 

Defendants knew that they were false and misleading, and/or at a minimum acted with a reckless 

disregard for the truth.

133. These statements created the false and misleading implication that Plaintiff Corsi 

is dishonest, committed perjury and is an alcoholic, and that Plaintiff Klayman committed sexual 

misconduct and is incompetent, among other false and misleading statements as pled in the 

preceding paragraphs. These malicious false statements also defamed Plaintiffs in their trades 

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and professions.

134. Plaintiffs have been severely harmed and damaged by these false and misleading 

statements because they subject him to hatred, distrust, ridicule, contempt, and disgrace.

135. Plaintiffs has been damaged by these malicious false and misleading statements 

because the statements severely harmed and damaged Plaintiffs in their trades and professions as 

journalists, authors, columnists, pubic interest and private practitioner lawyers and syndicated 

radio talk show hosts, whose credibility is the most important trait, as well as personally.

FOURTH CAUSE OF ACTION

Intentional Infliction of Emotional Distress

136. Plaintiffs re-alleges and incorporates by reference the allegations in the preceding 

paragraphs of the Complaint as if fully set forth herein.

137. Acting in concert, Defendants engaged in extreme and outrageous conduct by 

threatening Plaintiffs, acting as agents in concert with Stone, who has made death threats to at 

least one witness involved in Special Counsel Mueller’s Russian collusion investigation, Person

2 Randy Credico, as well as incited violence against Judge Amy Berman Jackson by posting a 

meme on Instagram with a crosshairs and gun pointed at the jurist’s head, for which Stone was 

sanctioned with a total gag order and threat of incarceration if this type of violative conduct of 

the Court’s gag order occurred again, which it apparently has. 

138. Defendants knowingly and intentionally threatened Plaintiffs, in a manner similar 

to other death threats co-conspirator and Defendant Stone made to at least one material witness,

involved in Special Counsel Mueller’s Russian collusion investigation, such as Randy Credico, 

Person 2 in the Mueller Indictment, as well as Judge Amy Berman Jackson.

139. Defendants’ extreme and outrageous conduct directly caused Plaintiffs severe 

emotional distress and resulting severe harm and damage.

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FIFTH CAUSE OF ACTION

Assault

140. Plaintiffs re-alleges and incorporates by reference the allegations in the preceding 

paragraphs of the Complaint as if fully set forth herein.

141. Acting in concert, Defendants placed Plaintiffs in apprehension of an imminent 

harmful or offensive contact and physical harm and death, by coercing and threatening Plaintiffs, 

in a similar manner that co-conspirator Stone has used to make death threats to at least one 

material witness involved in Special Counsel Mueller’s Russian collusion investigation, such as 

Person 2 in the Mueller Indictment, Randy Credico and Judge Amy Berman Jackson.

142. The threats issued by Defendants are credible, as co-conspirator Stone portrays 

and sees himself as a “Mafia” figure, as set forth above.

143. Furthermore, as set forth above, acting in concert Defendants have a pattern and 

practice of calling their followers “to arms,” which has resulted in deadly violence against their 

victims.

144. Plaintiffs did not consent to Defendants’ conduct.

145. As a direct and proximate result of Defendants’ wrongful conduct, acting in 

concert and as an agent at the direction of Defendant Stone, Plaintiffs suffered conscious pain, 

suffering, severe emotional distress and the fear of imminent serious bodily injury or death, and 

other mental and physical injuries, and Plaintiffs were severely harmed and damaged thereby.

SIXTH CAUSE OF ACTION

Unfair Competition – Lanham Act 15 U.S.C. § 1125(a)

146. Plaintiffs re-alleges and incorporates by reference the allegations in the preceding 

paragraphs of the Complaint as if fully set forth herein.

147. Defendants have and are engaged in acts of unfair competition in violation of the 

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Lanham Act, 15 U.S.C. § 1125(a) and common law

148. Defendants have made false and/or misleading statements that have deceived 

and/or had the tendency to deceive a substantial segment of the receiving audience.

149. Defendants’ false and/or misleading statements misrepresent the nature, 

characteristics, and qualities of Plaintiff Klayman and Plaintiff Corsi’s goods or services.

150. Defendants false and/or misleading statements are material because that were 

highly likely to mislead and influence supporters’ decisions to provide financial support and 

sales to Defendants instead of Plaintiffs, in order to harm Plaintiffs and cut off their financial 

support such that Dr. Corsi could adequately defend himself in the Mueller Russian collusion 

investigation and also testify, as Defendants believed he would, against Stone in the ensuing 

criminal trial.

151. These false and misleading statements were made in interstate commerce, as they 

were widely broadcast on radio, on the internet, in social media, and elsewhere in this district, 

nationally and internationally.

152. Plaintiffs have suffered significant damages, which are ongoing, due to 

Defendants’ false and/or misleading statements. By law these damages are calculated based on 

Defendants’ gross sales and receipts, which are trebled, plus an award of attorneys fees and 

costs.

PRAYER FOR RELIEF

WHEREFORE, Plaintiffs pray for judgment against Defendants as follows:

a. Awarding Plaintiffs compensatory including actual, consequential, incidental and 

punitive damages for malicious tortious concerted conduct, jointly and severally 

in an amount to be determined at trial and in excess of $75, 000, 000 U.S. Dollars

Case 1:20-cv-00298-LY-DH Document 147 Filed 08/05/21 Page 40 of 107
33

for each Plaintiff.

b. Awarding Treble Damages Under the Lanham Act, 15 U.S.C. 1125(a).

b. Awarding Plaintiffs attorney fees and costs

c. Granting such other relief as the Court deems appropriate and necessary

including preliminary and permanent injunctive relief. 

 PLAINTIFFS DEMAND TRIAL BY JURY ON ALL CLAIMS SO TRIABLE.

Dated: August 5, 2021 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, Esq.

7050 W. Palmetto Park Rd

Boca Raton FL, 33433

Email:leklayman@gmail.com

Tel: 561-558-5336

Plaintiff Pro Se

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34

VERIFICATION

I, Larry Klayman declare as follows: 

1. I am a Plaintiff in the present case.

2. I verify under penalty of perjury under the laws of the United States of America 

that the factual statements in this Second Amended Complaint are true and correct to the best of 

my personal knowledge and belief.

Executed on August 5, 2021

__/s/ Larry Klayman_____________

Larry Klayman

Case 1:20-cv-00298-LY-DH Document 147 Filed 08/05/21 Page 42 of 107
35

VERIFICATION

I, Jerome Corsi declare as follows: 

1. I am a Plaintiff in the present case.

2. I verify under penalty of perjury under the laws of the United States of America 

that the factual statements in this Second Amended Complaint are true and correct to the best of 

my personal knowledge and belief.

Executed on August 5, 2021

___/s/ Dr. Jerome Corsi__________

Dr. Jerome Corsi

Case 1:20-cv-00298-LY-DH Document 147 Filed 08/05/21 Page 43 of 107
EXHIBIT 1

Case 1:20-cv-00298-LY-DH Document 147 Filed 08/05/21 Page 44 of 107
IN THE UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRICT OF TEXAS

DR. JEROME CORSI, ET AL

 

Plaintiffs

v.

INFOWARS, LLC, et al

Defendants.

 Case Number: 1:20-cv-298-LY

SWORN DECLARATION OF KELLY MORALES

1. I, Kelly Morales, hereby declare under penalty of perjury that the following is true and

correct and based on my personal knowledge and belief.

2. I am over the age of 18 and mentally and legally competent to make this affidavit,

sworn under oath.

3. I am the former wife of Defendant Alex Jones. I was married to Alex Jones for 12

years and with him for 15 years and we have 3 children together. During our time together, I was

involved in the activities of Alex, his father David and Infowars and am intimately

knowledgeable about their activities and business structure.

4. Based on my personal knowledge and experience, David Jones runs Infowars with

Alex Jones and helps him with his activities, including fixing media stories and endorsing and/or

aiding his slanderous and/or fraudulent behaviors, all for profit.

5. Infowars, LLC is a sub-entity of Free Speech Systems, LLC (“FSS”), and David Jones

is an employee of FSS, or he has been.

6. David Jones is additionally a managing member of multiple entities that are closely

held businesses, constituting financial holding companies or financial distribution centered

around Infowars/Alex Jones’ supplement line, which are quintessential to funding and running

Infowars.

 

 

 

 

 

I hereby swear under oath and penalty of perjury that the foregoing facts are true and

correct to the best of my knowledge and belief.

Executed on September 30, 2020

8. Alex Jones is quasi-illiterate, and cannot use technology or apps such as email with

any fluency, and he cannot function without assistance from those around him, including David

Jones.

7. Alex Jones could not function without David Jones, and has conspired with him on the

past to commit this breach of fiduciary duty and fraud on my business/estate with Alex Jones.

While David Jones did this, he slandered and/or defamed me to experts and assisted Alex Jones

and his attorneys to do the same, so as to steal/hide my estate and his grandchildren’s inheritance.

Case 1:20-cv-00298-LY-DH Document 147 Filed 08/05/21 Page 45 of 107 Case 1:20-cv-00298-LY-AWA Document 74 Filed 09/30/20 Page 37 of 39
________________________________

Kelly Morales

2

Case 1:20-cv-00298-LY-DH Document 147 Filed 08/05/21 Page 46 of 107 Case 1:20-cv-00298-LY-AWA Document 74 Filed 09/30/20 Page 38 of 39
UNITED STATES BANKRUPTCY COURT

WESTERN DISTRICT OF TEXAS

AUSTIN DIVISION

§

§

§ CASE NO. 20-10118-hem

§

§ Chapter 11

§

Affidavit of David Jones in Support of Alleged Debtor’s Motion to Dismiss

STATE OF TEXAS §

§

COUNTY OF TRAVIS §

BEFORE ME, the undersigned authority, on this day personally appeared David Jones,

who after being sworn did state upon his oath, as follows:

1. “My name is David Jones. .1 am over 18 years of age and otherwise competent and

capable ofmaking this Affidavit. I have personal knowledge oflhe facts set forth herein and they

are true and correct.

2. “I have been involved with Alex Jones' personal and business finances for many

years and have personal knowledge ofthe matters set forth herein, and they are true and correct.

3. "I have personally reviewed the Real Estate Lien Note from Alexander Jones to

Kel ly R. Jones dated March 19, 2015 (the "Note''), which is attached to the Involuntary Bankruptcy

Petition filed in the above referenced case and have reviewed the record of payments made by

Alexander Jones to Kelly R, Jones under the Note. I have personally calculated the remaining

balance ofthe Note. The balance oflhe Note is $596.267.16 as ofthe date hereof.

''Further Affiant sayeth not."’

SIGNED on this J ^ y of February. 2020. / \

Sworn to and subscribed before me. the undersigned authority, on day of

February. 2020.

/C

_____ {/

Notary Public for the State ofTexas

gyp

-583/-5475-5/P

$

PATRICK RILEY

c Notary Public, State of Texas

Comra- Empires 09-24-2022

Notary ID 131734177

In re:

Alexander E. .Jones,

Alleged Debtor.

20-10118-hcm Doc#8 Filed 02/13/20 Entered 02/13/20 13:17:45 Main Document Pg 97 of

 97

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EXHIBIT 2

Case 1:20-cv-00298-LY-DH Document 147 Filed 08/05/21 Page 48 of 107
IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

UNITED STATES OF AMERICA

v. 

ROGER JASON STONE, JR., 

Defendant.

*

* 

* 

* 

* 

* 

* 

* 

* 

*

*******

CRIMINAL NO.

Grand Jury Original

18 U.S.C. §§ 1001, 1505, 1512, 2 

INDICTMENT

The Grand Jury for the District of Columbia charges: 

Introduction 

1. By in or around May 2016, the Democratic National Committee (“DNC”) and the 

Democratic Congressional Campaign Committee (“DCCC”) became aware that their computer 

systems had been compromised by unauthorized intrusions and hired a security company 

(“Company 1”) to identify the extent of the intrusions. 

2. On or about June 14, 2016, the DNC—through Company 1—publicly announced that it

had been hacked by Russian government actors. 

3. From in or around July 2016 through in or around November 2016, an organization 

(“Organization 1”), which had previously posted documents stolen by others from U.S. persons, 

entities, and the U.S. government, released tens of thousands of documents stolen from the DNC

and the personal email account of the chairman of the U.S. presidential campaign of Hillary

Clinton (“Clinton Campaign”). 

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a. On or about July 22, 2016, Organization 1 released documents stolen from the 

DNC. 

b. Between on or about October 7, 2016 and on or about November 7, 2016, 

Organization 1 released approximately 33 tranches of documents that had been 

stolen from the personal email account of the Clinton Campaign chairman, totaling 

over 50,000 stolen documents. 

4. ROGER JASON STONE, JR. was a political consultant who worked for decades in U.S. 

politics and on U.S. political campaigns. STONE was an official on the U.S. presidential campaign 

of Donald J. Trump (“Trump Campaign”) until in or around August 2015, and maintained regular 

contact with and publicly supported the Trump Campaign through the 2016 election. 

5. During the summer of 2016, STONE spoke to senior Trump Campaign officials about 

Organization 1 and information it might have had that would be damaging to the Clinton 

Campaign. STONE was contacted by senior Trump Campaign officials to inquire about future 

releases by Organization 1. 

6. By in or around early August 2016, STONE was claiming both publicly and privately to

have communicated with Organization 1. By in or around mid-August 2016, Organization 1 made 

a public statement denying direct communication with STONE. Thereafter, STONE said that his 

communication with Organization 1 had occurred through a person STONE described as a “mutual 

friend,” “go-between,” and “intermediary.” STONE also continued to communicate with members

of the Trump Campaign about Organization 1 and its intended future releases. 

7. After the 2016 U.S. presidential election, the U.S. House of Representatives Permanent 

Select Committee on Intelligence (“HPSCI”), the U.S. Senate Select Committee on Intelligence 

(“SSCI”), and the Federal Bureau of Investigation (“FBI”) opened or announced their respective 

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3

investigations into Russian interference in the 2016 U.S. presidential election, which included 

investigating STONE’s claims of contact with Organization 1. 

8. In response, STONE took steps to obstruct these investigations. Among other steps to

obstruct the investigations, STONE: 

a. Made multiple false statements to HPSCI about his interactions regarding 

Organization 1, and falsely denied possessing records that contained evidence of 

these interactions; and 

b. Attempted to persuade a witness to provide false testimony to and withhold 

pertinent information from the investigations. 

Other Relevant Individuals 

9. Person 1 was a political commentator who worked with an online media publication during 

the 2016 U.S. presidential campaign. Person 1 spoke regularly with STONE throughout the 

campaign, including about the release of stolen documents by Organization 1. 

10. Person 2 was a radio host who had known STONE for more than a decade. In testimony 

before HPSCI on or about September 26, 2017, STONE described Person 2 (without naming him) 

as an “intermediary,” “go-between,” and “mutual friend” to the head of Organization 1. In a 

follow-up letter to HPSCI dated October 13, 2017, STONE identified Person 2 by name and 

claimed Person 2 was the “gentleman who confirmed for Mr. Stone” that the head of

Organization 1 had “‘[e]mails related to Hillary Clinton which are pending publication.’” 

Background 

STONE’s Communications About Organization 1 During the Campaign 

11. By in or around June and July 2016, STONE informed senior Trump Campaign officials

that he had information indicating Organization 1 had documents whose release would be

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4

damaging to the Clinton Campaign. The head of Organization 1 was located at all relevant times

at the Ecuadorian Embassy in London, United Kingdom. 

12. After the July 22, 2016 release of stolen DNC emails by Organization 1, a senior Trump 

Campaign official was directed to contact STONE about any additional releases and what other 

damaging information Organization 1 had regarding the Clinton Campaign. STONE thereafter 

told the Trump Campaign about potential future releases of damaging material by Organization 1. 

13. STONE also corresponded with associates about contacting Organization 1 in order to

obtain additional emails damaging to the Clinton Campaign. 

a. On or about July 25, 2016, STONE sent an email to Person 1 with the subject line, 

“Get to [the head of Organization 1].” The body of the message read, “Get to [the 

head of Organization 1] [a]t Ecuadorian Embassy in London and get the pending 

[Organization 1] emails . . . they deal with Foundation, allegedly.” On or about the 

same day, Person 1 forwarded STONE’s email to an associate who lived in the

United Kingdom and was a supporter of the Trump Campaign. 

b. On or about July 31, 2016, STONE emailed Person 1 with the subject line, “Call

me MON.” The body of the email read in part that Person 1’s associate in the 

United Kingdom “should see [the head of Organization 1].” 

c. On or about August 2, 2016, Person 1 emailed STONE. Person 1 wrote that he was

currently in Europe and planned to return in or around mid-August. Person 1 stated

in part, “Word is friend in embassy plans 2 more dumps. One shortly after I’m 

back. 2nd in Oct. Impact planned to be very damaging.” The phrase “friend in

embassy” referred to the head of Organization 1. Person 1 added in the same email, 

“Time to let more than [the Clinton Campaign chairman] to be exposed as in bed w 

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5

enemy if they are not ready to drop HRC. That appears to be the game hackers are

now about. Would not hurt to start suggesting HRC old, memory bad, has stroke – 

neither he nor she well. I expect that much of next dump focus, setting stage for

Foundation debacle.” 

14. Starting in early August 2016, after receiving the August 2, 2016 email from Person 1, 

STONE made repeated statements about information he claimed to have learned from the head of 

Organization 1. 

a. On or about August 8, 2016, STONE attended a public event at which he stated, “I 

actually have communicated with [the head of Organization 1]. I believe the next 

tranche of his documents pertain to the Clinton Foundation, but there’s no telling 

what the October surprise may be.” 

b. On or about August 12, 2016, STONE stated during an interview that he was “in

communication with [the head of Organization 1]” but was “not at liberty to discuss 

what I have.” 

c. On or about August 16, 2016, STONE stated during an interview that “it became 

known on this program that I have had some back-channel communication with

[Organization 1] and [the head of Organization 1].” In a second interview on or 

about the same day, STONE stated that he “communicated with [the head of 

Organization 1]” and that they had a “mutual acquaintance who is a fine 

gentleman.” 

d. On or about August 18, 2016, STONE stated during a television interview that he 

had communicated with the head of Organization 1 through an “intermediary, 

somebody who is a mutual friend.” 

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6

e. On or about August 23, 2016, Person 2 asked STONE during a radio interview, 

“You’ve been in touch indirectly with [the head of Organization 1]. . . . Can you 

give us any kind of insight? Is there an October surprise happening?” STONE

responded, “Well, first of all, I don’t want to intimate in any way that I control or 

have influence with [the head of Organization 1] because I do not. . . . We have a 

mutual friend, somebody we both trust and therefore I am a recipient of pretty good 

information.” 

15. Beginning on or about August 19, 2016, STONE exchanged written communications, 

including by text message and email, with Person 2 about Organization 1 and what the head of 

Organization 1 planned to do. 

a. On or about August 19, 2016, Person 2 sent a text message to STONE that read in

part, “I’m going to have [the head of Organization 1] on my show next Thursday.” 

On or about August 21, 2016, Person 2 sent another text message to STONE,

writing in part, “I have [the head of Organization 1] on Thursday so I’m completely 

tied up on that day.” 

b. On or about August 25, 2016, the head of Organization 1 was a guest on Person 2’s 

radio show for the first time. On or about August 26, 2016, Person 2 sent a text

message to STONE that stated, “[the head of Organization 1] talk[ed] about you 

last night.” STONE asked what the head of Organization 1 said, to which Person 2 

responded, “He didn’t say anything bad we were talking about how the Press is

trying to make it look like you and he are in cahoots.” 

c. On or about August 27, 2016, Person 2 sent text messages to STONE that said, “We

are working on a [head of Organization 1] radio show,” and that he (Person 2) was

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7

“in charge” of the project. In a text message sent later that day, Person 2 added, 

“[The head of Organization 1] has kryptonite on Hillary.” 

d. On or about September 18, 2016, STONE sent a text message to Person 2 that said, 

“I am e-mailing u a request to pass on to [the head of Organization 1].” Person 2 

responded “Ok,” and added in a later text message, “[j]ust remember do not name 

me as your connection to [the head of Organization 1] you had one before that you 

referred to.” 

i. On or about the same day, September 18, 2016, STONE emailed

Person 2 an article with allegations against then-candidate Clinton 

related to her service as Secretary of State. STONE stated, “Please

ask [the head of Organization 1] for any State or HRC e-mail from 

August 10 to August 30—particularly on August 20, 2011 that 

mention [the subject of the article] or confirm this narrative.” 

ii. On or about September 19, 2016, STONE texted Person 2 again, 

writing, “Pass my message . . . to [the head of Organization 1].” 

Person 2 responded, “I did.” On or about September 20, 2016, 

Person 2 forwarded the request to a friend who was an attorney with

the ability to contact the head of Organization 1. Person 2 blindcopied STONE on the forwarded email. 

e. On or about September 30, 2016, Person 2 sent STONE via text message a 

photograph of Person 2 standing outside the Ecuadorian Embassy in London where 

the head of Organization 1 was located. 

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8

f. On or about October 1, 2016, which was a Saturday, Person 2 sent STONE text

messages that stated, “big news Wednesday . . . now pretend u don’t know me . . . 

Hillary’s campaign will die this week.” In the days preceding these messages, the

press had reported that the head of Organization 1 planned to make a public 

announcement on or about Tuesday, October 4, 2016, which was reported to be the 

ten-year anniversary of the founding of Organization 1. 

g. On or about October 2, 2016, STONE emailed Person 2, with the subject line 

“WTF?,” a link to an article reporting that Organization 1 was canceling its “highly 

anticipated Tuesday announcement due to security concerns.” Person 2 responded 

to STONE, “head fake.” 

h. On or about the same day, October 2, 2016, STONE texted Person 2 and asked, 

“Did [the head of Organization 1] back off.” On or about October 3, 2016, Person 

2 initially responded, “I can’t tal[k] about it.” After further exchanges with

STONE, Person 2 said, “I think it[’]s on for tomorrow.” Person 2 added later that 

day, “Off the Record Hillary and her people are doing a full-court press they [sic] 

keep [the head of Organization 1] from making the next dump . . . That’s all I can

tell you on this line . . . Please leave my name out of it.” 

16. In or around October 2016, STONE made statements about Organization 1’s future 

releases, including statements similar to those that Person 2 made to him. For example: 

a. On or about October 3, 2016, STONE wrote to a supporter involved with the Trump 

Campaign, “Spoke to my friend in London last night. The payload is still coming.” 

b. Also on or about October 3, 2016, STONE received an email from a reporter who 

had connections to a high-ranking Trump Campaign official that asked, “[the head 

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9

of Organization 1] – what’s he got? Hope it’s good.” STONE responded in part, 

“It is. I’d tell [the high-ranking Trump Campaign official] but he doesn’t call me

back.” 

c. On or about October 4, 2016, the head of Organization 1 held a press conference 

but did not release any new materials pertaining to the Clinton Campaign. Shortly 

afterwards, STONE received an email from the high-ranking Trump Campaign 

official asking about the status of future releases by Organization 1. STONE

answered that the head of Organization 1 had a “[s]erious security concern” but that 

Organization 1 would release “a load every week going forward.” 

d. Later that day, on or about October 4, 2016, the supporter involved with the Trump 

Campaign asked STONE via text message if he had “hear[d] anymore from 

London.” STONE replied, “Yes - want to talk on a secure line - got Whatsapp?” 

STONE subsequently told the supporter that more material would be released and 

that it would be damaging to the Clinton Campaign. 

17. On or about October 7, 2016, Organization 1 released the first set of emails stolen from the 

Clinton Campaign chairman. Shortly after Organization 1’s release, an associate of the highranking Trump Campaign official sent a text message to STONE that read “well done.” In

subsequent conversations with senior Trump Campaign officials, STONE claimed credit for

having correctly predicted the October 7, 2016 release. 

The Investigations 

18. In or around 2017, government officials publicly disclosed investigations into Russian 

interference in the 2016 U.S. presidential election and possible links to individuals associated with

the campaigns. 

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a. On or about January 13, 2017, the chairman and vice chairman of SSCI announced 

the committee would conduct an inquiry that would investigate, among other 

things, any intelligence regarding links between Russia and individuals associated 

with political campaigns, as well as Russian cyber activity and other “active 

measures” directed against the United States in connection with the 2016 election. 

b. On or about January 25, 2017, the chairman and ranking member of HPSCI

announced that HPSCI had been conducting an inquiry similar to SSCI’s. 

c. On or about March 20, 2017, the then-director of the FBI testified at a HPSCI

hearing and publicly disclosed that the FBI was investigating Russian interference 

in the 2016 election and possible links and coordination between the Trump 

Campaign and the Russian government. 

d. By in or around August 2017, news reports stated that a federal grand jury had 

opened an investigation into matters relating to Russian government efforts to

interfere in the 2016 election, including possible links and coordination between 

the Trump Campaign and the Russian government. 

STONE’s False Testimony to HPSCI

19. In or around May 2017, HPSCI sent a letter requesting that STONE voluntarily appear 

before the committee and produce: 

Any documents, records, electronically stored information 

including e-mail, communication, recordings, data and tangible 

things (including, but not limited to, graphs, charts, photographs, 

images and other documents) regardless of form, other than those 

widely available (e.g., newspaper articles) that reasonably could 

lead to the discovery of any facts within the investigation’s publiclyannounced parameters.

On or about May 22, 2017, STONE caused a letter to be submitted to HPSCI stating that “Mr.

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11

Stone has no documents, records, or electronically stored information, regardless of form, other 

than those widely available that reasonably could lead to the discovery of any facts within the 

investigation’s publicly-announced parameters.” 

20. On or about September 26, 2017, STONE testified before HPSCI in Washington, D.C. as

part of the committee’s ongoing investigation. In his opening statement, STONE stated, “These 

hearings are largely based on a yet unproven allegation that the Russian state is responsible for the 

hacking of the DNC and [the Clinton Campaign chairman] and the transfer of that information to

[Organization 1].” STONE further stated that “[m]embers of this Committee” had made certain

“assertions against me which must be rebutted here today,” which included “[t]he charge that I 

knew in advance about, and predicted, the hacking of Clinton campaign chairman[’s] email, [and] 

that I had advanced knowledge of the source or actual content of the [Organization 1] disclosures 

regarding Hillary Clinton.” 

21. In the course of his HPSCI testimony, STONE made deliberately false and misleading 

statements to the committee concerning, among other things, his possession of documents 

pertinent to HPSCI’s investigation; the source for his early August 2016 statements about 

Organization 1; requests he made for information from the head of Organization 1; his 

communications with his identified intermediary; and his communications with the Trump 

Campaign about Organization 1. 

STONE’s False and Misleading Testimony About His Possession of Documents Pertinent to

HPSCI’s Investigation 

22. During his HPSCI testimony, STONE was asked, “So you have no emails to anyone 

concerning the allegations of hacked documents . . . or any discussions you have had with third 

parties about [the head of Organization 1]? You have no emails, no texts, no documents 

whatsoever, any kind of that nature?” STONE falsely and misleadingly answered, “That is correct. 

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12

Not to my knowledge.” 

23. In truth and in fact, STONE had sent and received numerous emails and text messages

during the 2016 campaign in which he discussed Organization 1, its head, and its possession of

hacked emails. At the time of his false testimony, STONE was still in possession of many of these 

emails and text messages, including: 

a. The email from STONE to Person 1 on or about July 25, 2016 that read in part, 

“Get to [the head of Organization 1] [a]t Ecuadorian Embassy in London and get

the pending [Organization 1] emails . . . they deal with Foundation, allegedly.”; 

b. The email from STONE to Person 1 on or about July 31, 2016 that said an associate 

of Person 1 “should see [the head of Organization 1].”; 

c. The email from Person 1 to STONE on or about August 2, 2016 that stated in part, 

“Word is friend in embassy plans 2 more dumps. One shortly after I’m back. 2nd 

in Oct. Impact planned to be very damaging.”; 

d. Dozens of text messages and emails, beginning on or about August 19, 2016 and 

continuing through the election, between STONE and Person 2 in which they 

discussed Organization 1 and the head of Organization 1; 

e. The email from STONE on or about October 3, 2016 to the supporter involved with

the Trump Campaign, which read in part, “Spoke to my friend in London last night. 

The payload is still coming.”; and 

f. The emails on or about October 4, 2016 between STONE and the high-ranking 

member of the Trump Campaign, including STONE’s statement that Organization 

1 would release “a load every week going forward.” 

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13

24. By falsely claiming that he had no emails or text messages in his possession that referred

to the head of Organization 1, STONE avoided providing a basis for HPSCI to subpoena records 

in his possession that could have shown that other aspects of his testimony were false and 

misleading. 

STONE’s False and Misleading Testimony About His Early August 2016 Statements 

25. During his HPSCI testimony on or about September 26, 2017, STONE was asked to

explain his statements in early August 2016 about being in contact with the head of Organization 1. 

STONE was specifically asked about his statement on or about August 8, 2016 that “I’ve actually 

communicated with [the head of Organization 1],” as well as his statement on or about August 12, 

2016 that he was “in communication with [the head of Organization 1]” but was “not at liberty to

discuss what I have.” 

26. STONE responded that his public references to having a means of contacting Organization 

1 referred exclusively to his contact with a journalist, who STONE described as a “go-between, as

an intermediary, as a mutual friend” of the head of Organization 1. STONE stated that he asked 

this individual, his intermediary, “to confirm what [the head of Organization 1] ha[d] tweeted, 

himself, on July 21st, that he ha[d] the Clinton emails and that he [would] publish them.” STONE

further stated that the intermediary “was someone I knew had interviewed [the head of 

Organization 1]. And I merely wanted confirmation of what he had tweeted on the 21st.” STONE

declined to tell HPSCI the name of this “intermediary” but provided a description in his testimony 

that was consistent with Person 2. 

27. On or about October 13, 2017, STONE caused a letter to be submitted to HPSCI that 

identified Person 2 by name as the “gentleman who confirmed for Mr. Stone” that the head of

Organization 1 had “‘[e]mails related to Hillary Clinton which are pending publication.’” 

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28. STONE’s explanation of his August 2016 statements about communicating with the head 

of Organization 1 was false and misleading. In truth and in fact, the first time Person 2 interviewed 

the head of Organization 1 was on or about August 25, 2016, after STONE made his August 8 and 

August 12, 2016 public statements. Similarly, at the time STONE made his August 2016 

statements, STONE had directed Person 1—not Person 2—to contact the head of Organization 1. 

And Person 1—not Person 2—had told STONE in advance of STONE’s August 8 and August 12, 

2016 public statements that “[w]ord is friend in embassy plans 2 more dumps,” including one in

October. At no time did STONE identify Person 1 to HPSCI as another individual STONE

contacted to serve as a “go-between,” “intermediary,” or other source of information from 

Organization 1. STONE also never disclosed his exchanges with Person 1 when answering 

HPSCI’s questioning about STONE’s August 8 and August 12, 2016 statements. 

STONE’s False and Misleading Testimony About Requests He Made for Information from the 

Head of Organization 1 

29. During his HPSCI testimony, STONE was asked, “[W]hat was the extent of the 

communication with [the intermediary]?” STONE replied, “I asked him to confirm . . . that the 

tweet of [the head of Organization 1] of the 21st was accurate, that they did in fact have . . . Hillary

Clinton emails and that they would release them.” STONE was then asked, “Did you ask [the 

intermediary] to communicate anything else to [the head of Organization 1]?” STONE falsely and 

misleadingly responded, “I did not.” STONE was then asked, “Did you ask [the intermediary] to

do anything on your own behalf?” STONE falsely and misleadingly responded, “I did not.” 

30. In truth and in fact, STONE directed both Person 1 and Person 2 to pass on requests to the 

head of Organization 1 for documents that STONE believed would be damaging to the Clinton 

Campaign. For example: 

a. As described above, on or about July 25, 2016, STONE sent Person 1 an email that 

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15

read, “Get to [the head of Organization 1] [a]t Ecuadorian Embassy in London and 

get the pending [Organization 1] emails . . . they deal with Foundation, allegedly.” 

b. On or about September 18, 2016, STONE sent a text message to Person 2 that said, 

“I am e-mailing u a request to pass on to [the head of Organization 1],” and then 

emailed Person 2 an article with allegations against then-candidate Clinton related

to her service as Secretary of State. STONE added, “Please ask [the head of 

Organization 1] for any State or HRC e-mail from August 10 to August 30—

particularly on August 20, 2011 that mention [the subject of the article] or confirm 

this narrative.” 

c. On or about September 19, 2016, STONE texted Person 2 again, writing “Pass my

message . . . to [the head of Organization 1].” Person 2 responded, “I did,” and the 

next day Person 2, on an email blind-copied to STONE, forwarded the request to

an attorney who had the ability to contact the head of Organization 1. 

STONE’s False and Misleading Testimony About Communications with His Identified 

Intermediary 

31. During his HPSCI testimony, STONE was asked repeatedly about his communications 

with the person he identified as his intermediary. STONE falsely and misleadingly stated that he

had never communicated with his intermediary in writing in any way. During one exchange, 

STONE falsely and misleadingly claimed only to have spoken with the intermediary 

telephonically: 

Q: [H]ow did you communicate with the intermediary? 

A: Over the phone. 

Q: And did you have any other means of communicating with

the intermediary? 

A: No. 

Q: No text messages, no – none of the list, right? 

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A: No. 

Later during his testimony, STONE again falsely denied ever communicating with his 

intermediary in writing: 

Q: So you never communicated with your intermediary in

writing in any way? 

A: No. 

Q: Never emailed him or texted him? 

A: He’s not an email guy. 

Q: So all your conversations with him were in person or over 

the phone. 

A: Correct. 

32. In truth and in fact, as described above, STONE and Person 2 (who STONE identified to

HPSCI as his intermediary) engaged in frequent written communication by email and text

message. STONE also engaged in frequent written communication by email and text message

with Person 1, who also provided STONE with information regarding Organization 1. 

33. Written communications between STONE and Person 1 and between STONE and Person 2 

continued through STONE’s HPSCI testimony. Indeed, on or about September 26, 2017—the day

that STONE testified before HPSCI and denied having ever sent or received emails or text

messages from Person 2—STONE and Person 2 exchanged over thirty text messages. 

34. Certain electronic messages between STONE and Person 1 and between STONE and 

Person 2 would have been material to HPSCI. For example: 

a. In or around July 2016, STONE emailed Person 1 to “get to” the head of 

Organization 1 and obtain the pending emails. 

b. In or around September 2016, STONE sent messages directing Person 2 to pass a 

request to the head of Organization 1. 

c. On or about January 6, 2017, Person 2 sent STONE an email that had the subject 

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17

line “Back channel bs.” In the email, Person 2 wrote, “Well I have put together 

timelines[] and you [] said you have a back-channel way back a month before I had

[the head of Organization 1] on my show . . . I have never had a conversation with

[the head of Organization 1] other than my radio show . . . I have pieced it all

together . . . so you may as well tell the truth that you had no back-channel or there’s 

the guy you were talking about early August.” 

STONE’s False and Misleading Testimony About Communications with the Trump Campaign 

35. During his HPSCI testimony, STONE was asked, “did you discuss your conversations with

the intermediary with anyone involved in the Trump campaign?” STONE falsely and misleadingly 

answered, “I did not.” In truth and in fact, and as described above, STONE spoke to multiple 

individuals involved in the Trump Campaign about what he claimed to have learned from his 

intermediary to Organization 1, including the following: 

a. On multiple occasions, STONE told senior Trump Campaign officials about 

materials possessed by Organization 1 and the timing of future releases. 

b. On or about October 3, 2016, STONE wrote to a supporter involved with the Trump 

Campaign, “Spoke to my friend in London last night. The payload is still coming.” 

c. On or about October 4, 2016, STONE told a high-ranking Trump Campaign official 

that the head of Organization 1 had a “[s]erious security concern” but would release

“a load every week going forward.” 

Attempts to Prevent Person 2 from Contradicting STONE’s False Statements to HPSCI

36. On or about October 19, 2017, STONE sent Person 2 an excerpt of his letter to HPSCI that 

identified Person 2 as his “intermediary” to Organization 1. STONE urged Person 2, if asked by

HPSCI, to falsely confirm what STONE had previously testified to, including that it was Person 2 

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18

who provided STONE with the basis for STONE’s early August 2016 statements about contact 

with Organization 1. Person 2 repeatedly told STONE that his testimony was false and told him 

to correct his testimony to HPSCI. STONE did not do so. STONE then engaged in a prolonged 

effort to prevent Person 2 from contradicting STONE’s false statements to HPSCI. 

37. In or around November 2017, Person 2 received a request from HPSCI to testify voluntarily 

before the committee. After being contacted by HPSCI, Person 2 spoke and texted repeatedly with

STONE. In these discussions, STONE sought to have Person 2 testify falsely either that Person 2 

was the identified intermediary or that Person 2 could not remember what he had told STONE. 

Alternatively, STONE sought to have Person 2 invoke his Fifth Amendment right against selfincrimination. For example: 

a. On or about November 19, 2017, in a text message to STONE, Person 2 said that 

his lawyer wanted to see him (Person 2). STONE responded, “‘Stonewall it. Plead

the fifth. Anything to save the plan’ . . . Richard Nixon.” On or about November 

20, 2017, Person 2 informed HPSCI that he declined HPSCI’s request for a 

voluntary interview. 

b. On or about November 21, 2017, Person 2 texted STONE, “I was told that the house 

committee lawyer told my lawyer that I will be getting a subpoena.” STONE

responded, “That was the point at which your lawyers should have told them you 

would assert your 5th Amendment rights if compelled to appear.” 

c. On or about November 28, 2017, Person 2 received a subpoena compelling his 

testimony before HPSCI. Person 2 informed STONE of the subpoena. 

d. On or about November 30, 2017, STONE asked Person 1 to write publicly about 

Person 2. Person 1 responded, “Are you sure you want to make something out of 

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19

this now? Why not wait to see what [Person 2] does. You may be defending 

yourself too much—raising new questions that will fuel new inquiries. This may

be a time to say less, not more.” STONE responded by telling Person 1 that 

Person 2 “will take the 5th—but let’s hold a day.” 

e. On multiple occasions, including on or about December 1, 2017, STONE told 

Person 2 that Person 2 should do a “Frank Pentangeli” before HPSCI in order to

avoid contradicting STONE’s testimony. Frank Pentangeli is a character in the film

The Godfather: Part II, which both STONE and Person 2 had discussed, who 

testifies before a congressional committee and in that testimony claims not to know 

critical information that he does in fact know. 

f. On or about December 1, 2017, STONE texted Person 2, “And if you turned over 

anything to the FBI you’re a fool.” Later that day, Person 2 texted STONE, “You 

need to amend your testimony before I testify on the 15th.” STONE responded, “If

you testify you’re a fool. Because of tromp I could never get away with a certain

[sic] my Fifth Amendment rights but you can. I guarantee you you are the one who 

gets indicted for perjury if you’re stupid enough to testify.” 

38. On or about December 12, 2017, Person 2 informed HPSCI that he intended to assert his 

Fifth Amendment privilege against self-incrimination if required to appear by subpoena. Person 2 

invoked his Fifth Amendment privilege in part to avoid providing evidence that would show 

STONE’s previous testimony to Congress was false. 

39. Following Person 2’s invocation of his Fifth Amendment privilege not to testify before 

HPSCI, STONE and Person 2 continued to have discussions about the various investigations into 

Russian interference in the 2016 election and what information Person 2 would provide to

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20

investigators. During these conversations, STONE repeatedly made statements intended to

prevent Person 2 from cooperating with the investigations. For example: 

a. On or about December 24, 2017, Person 2 texted STONE, “I met [the head of 

Organization 1] for f[i]rst time this yea[r] sept 7 . . . docs prove that. . . . You should 

be honest w fbi . . . there was no back channel . . . be honest.” STONE replied 

approximately two minutes later, “I’m not talking to the FBI and if your smart you 

won’t either.” 

b. On or about April 9, 2018, STONE wrote in an email to Person 2, “You are a rat. 

A stoolie. You backstab your friends-run your mouth my lawyers are dying Rip

you to shreds.” STONE also said he would “take that dog away from you,” 

referring to Person 2’s dog. On or about the same day, STONE wrote to Person 2, 

“I am so ready. Let’s get it on. Prepare to die [expletive].” 

c. On or about May 21, 2018, Person 2 wrote in an email to STONE, “You should 

have just been honest with the house Intel committee . . . you’ve opened yourself 

up to perjury charges like an idiot.” STONE responded, “You are so full of 

[expletive]. You got nothing. Keep running your mouth and I’ll file a bar 

complaint against your friend [the attorney who had the ability to contact the head 

of Organization 1].” 

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21

COUNT ONE

(Obstruction of Proceeding)

40. Paragraphs 1 through 39 of this Indictment are re-alleged and incorporated by reference as

if fully set forth herein. 

41. From in or around May 2017 through at least December 2017, within the District of 

Columbia and elsewhere, the defendant ROGER JASON STONE, JR., corruptly influenced, 

obstructed, impeded, and endeavored to influence, obstruct, and impede the due and proper 

exercise of the power of inquiry under which any inquiry and investigation is being had by either 

House, and any committee of either House and any joint committee of the Congress, to wit:

STONE testified falsely and misleadingly at a HPSCI hearing in or around September 2017; 

STONE failed to turn over and lied about the existence of responsive records to HPSCI’s requests 

about documents; STONE submitted and caused to be submitted a letter to HPSCI falsely and 

misleadingly describing communications with Person 2; and STONE attempted to have Person 2 

testify falsely before HPSCI or prevent him from testifying. 

All in violation of Title 18, United States Code, Sections 1505 and 2. 

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22

COUNTS TWO THROUGH SIX

(False Statements)

42. Paragraphs 1 through 39 of this Indictment are re-alleged and incorporated by reference as

if fully set forth herein. 

43. On or about September 26, 2017, within the District of Columbia and elsewhere, in a matter

within the jurisdiction of the legislative branch of the Government of the United States, the

defendant ROGER JASON STONE, JR., knowingly and willfully made and caused to be made

materially false, fictitious, and fraudulent statements and representations, to wit: 

Count False Statement

2 STONE testified falsely that he did not have

emails with third parties about the head of 

Organization 1, and that he did not have any

documents, emails, or text messages that refer

to the head of Organization 1. 

3 STONE testified falsely that his August 2016

references to being in contact with the head of

Organization 1 were references to

communications with a single “go-between,” 

“mutual friend,” and “intermediary,” who 

STONE identified as Person 2. 

4 STONE testified falsely that he did not ask the

person he referred to as his “go-between,” 

“mutual friend,” and “intermediary,” to

communicate anything to the head of 

Organization 1 and did not ask the 

intermediary to do anything on STONE’s

behalf. 

5 STONE testified falsely that he and the person

he referred to as his “go-between,” “mutual 

friend,” and “intermediary” did not 

communicate via text message or email about 

Organization 1. 

6 STONE testified falsely that he had never

discussed his conversations with the person he 

referred to as his “go-between,” “mutual

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23

Count False Statement

friend,” and “intermediary” with anyone

involved in the Trump Campaign. 

All in violation of Title 18, United States Code, Sections 1001(a)(2) and 2. 

COUNT SEVEN

(Witness Tampering)

44. Paragraphs 1 through 39 of this Indictment are re-alleged and incorporated by reference as

if fully set forth herein. 

45. Between in or around September 2017 and present, within the District of Columbia and 

elsewhere, the defendant ROGER JASON STONE, JR., knowingly and intentionally corruptly 

persuaded and attempted to corruptly persuade another person, to wit: Person 2, with intent to

influence, delay, and prevent the testimony of any person in an official proceeding. 

All in violation of Title 18, United States Code, Section 1512(b)(1). 

 ________________________ 

 Robert S. Mueller, III

 Special Counsel 

U.S. Department of Justice 

A TRUE BILL:

________________________ 

Foreperson 

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24

Date: January 24, 2019 

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EXHIBIT 3

Case 1:20-cv-00298-LY-DH Document 147 Filed 08/05/21 Page 73 of 107
1 

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. 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

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

SWORN AFFIDAVIT OF LARRY KLAYMAN

I, Larry Klayman, being over eighteen years of age and duly competent to testify, hereby 

swear and affirm as follows: 

A BRIEF HISTORY OF MY BACKGROUND

1. I have personal knowledge of the following facts and if called upon as a witness, 

could testify competently thereto. 

2. In 1973, I graduated from Duke University where I majored in political science and 

French literature. I excelled academically and graduated with honors. 

3. I then matriculated at Emory Law School where I excelled academically and 

graduated in 1977. While in law school, I worked as an intern at the U.S. International Trade 

Commission, the Georgia Attorney General and the U.S. Attorney for the Northern District of 

Georgia. 

4. I passed The Florida Bar the first time I took the exam. 

5. I passed all bar exams on my first attempt, including the District of Columbia Bar. 

Case 1:20-cv-00298-LY-DH Document 147 Filed 08/05/21 Page 74 of 107 Case 1:20-cv-00298-LY-AWA Document 73 Filed 09/30/20 Page 28 of 66
2 

6. I began my legal career in this circuit in Miami, Florida as an associate for 

Blackwell, Walker, Gray, Roberts, Flick & Hoehl (. Blackwell ́), which was then the largest and 

most prestigious law firm in Florida. I was admitted into The Florida Bar having been sworn in on 

December 7, 1977. I have practiced law in this circuit continuously and extensively throughout my 

forty-two-year career and have active cases pending in this circuit and elsewhere in Florida, 

LQFOXGLQJ GXULQJ WKH SHULRG WKDW I ZDV D WULDO DWWRUQH\ IRU WKH U.S. DHSDUWPHQW RI JXVWLFH¶V (3DOJ ́) 

Antitrust Division, from 1980 to 1982, where I was assigned litigation in this circuit. 

7. I FRQFHLYHG RI DQG IRXQGHG JXGLFLDO WDWFK, IQF. (3JXGLFLDO WDWFK ́) LQ 1994, D

SXEOLF LQWHUHVW JURXS WKDW¶V PLVVLRQ ZDV WR LQYHVWLJDWH DQG SURVHFXWH JRYHUQPHQW FRUUXSWLRQ DQG

abuse. I was the Chairman, General Counsel, and Corporate Treasurer of Judicial Watch until I 

voluntarily departed in 2003 to run as a candidate for the U.S. Senate in Florida in the Republican 

primary election. 

8. In 1998, during the time I ran Judicial Watch, I KLUHG TKRPDV J. FLWWRQ (3FLWWRQ ́) DV

my contract assistant. I later appointed him president of the organization I founded. 

9. In September of 2003, I voluntarily departed from Judicial Watch to run for the 

U.S. Senate in Florida. At the time I left Judicial Watch, I learned that Fitton had never graduated 

from college, which he had told me he had when I initially hired him. 

10. CRQWUDU\ WR DHIHQGDQW RRJHU SWRQH¶V (3DHIHQGDQW SWRQH ́) IDOVH DQG GHIDPDWRU\

publications, I have enjoyed many successes in my career as a lawyer, many of which have been 

brought to the attention of the public by complimentary newspapers, magazines, editorials and 

journals. 

11. For example, I practiced law at Blackwell with my supervising partners Paul Larkin 

and Layton Mank and participating in winning product liability cases as defense counsel for 

Blackwell including cases involving Raleigh bicycles, pharmaceutical drugs manufactured by 

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3 

Burroughs-Wellcome, and allegedly misdiagnosed cancer victims, and other personal injury and 

medical malpractice cases. Additionally, I handled lawsuits in admiralty.

12. I left Blackwell to join the DOJ as a trial lawyer, prosecutor and defense lawyer in 

late 1979. During my time at the DOJ, I had many victories in the courtroom as well as favorable 

settlements for the government, i.e., such as for the Consumer Affairs Section of the Antitrust 

Division over misbranded, adulterated food and drug products including fruit drinks and 

prophylactics for the Food & Drug Administration (3FDA ́) and successful seizures and criminal 

prosecutions of dangerous products on behalf of the Consumer Product Safety Commission 

(3CPSC ́) such as slant-sided refuse bins, IODPPDEOH FKLOGUHQ¶V sleepwear, and intraocular lens 

implants for cataract patients.

13. Importantly, I was also on the trial team that successfully broke up the AT&T 

monopoly ± creating competition in the telecommunications industry. I left the DOJ in late 1981. 

14. Then, working as an international trade lawyer for Busby, Rehm & Leonard and 

after a few years having founded my own firm The Law Offices of Larry E. Klayman, later named

Klayman & Associates, P.C., I won countervailing duty and antidumping duty cases concerning 

steel from South Africa, garden furniture from Italy, musical instrument pads from Italy, coffee 

filters from Brazil, key limes from Peru, fireworks from China and a host of other product imports.

I represented both importers and exporters. (While at Busby, Rehm & Leonard, I also took some 

months on hiatus and worked in the Competition Directorate (DG-4) of the Commission of the 

EuropeDQ CRPPXQLWLHV SHFWLRQ (3E.C. ́). 

15. Later, with my law firm, I won Section 337 unfair trade practice cases at the U.S. 

IQWHUQDWLRQDO TUDGH CRPPLVVLRQ (3USITC ́) concerning tennis rackets from Belgium, power tools

from Taiwan, luggage from Taiwan, mass spectrometers from France, jam from Belgium, and 

machine tools from Brazil. I won a landmark case concerning recloseable plastic bags, which 

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4 

broke the patents of Minigrip and Dow Corning, MLQLJULS¶V licensee. That case victory opened up 

competition for zip lock bags, a multi-trillion dollar industry. 

16. There was also an USITC patent case, pursuant to Section 337, which I litigated 

and won involving motorcycle helmets and another antidumping and countervailing duty cases

before the Commerce Department and USITC concerning fire protection products and scuba 

diving neoprene body suits.

17. I also won a Section 302 case involving paper from Brazil. 

18. All of the Section 337 cases were judge-tried and I won every one of them. 

19. I won a jury trial against Makita over power tools, another jury trial against a 

domestic manufacture of removable swimming pools for my client Remove Pool Fence Co., and 

yet another jury trial for my client, Maccaferri, on a contract dispute. These are only some of the 

jury trials I won during my early career. 

20. Because of my work during the time I ran Judicial Watch, a court ruled that 

President William Clinton committed a crime during the Filegate litigation. I also triggered the 

famous Chinagate scandal in a Freedom of Information Act, 5 U.S.C. § 552 et seq., which gave 

rise to Judicial Watch ultimately being awarded almost a million dollars. I filed cases which ended 

Bill and Hillary COLQWRQ¶V DWWHPSWHG LOOHJDO SXUFKDVH DW EHORZ PDUNHW UDWHV IRU WKHLU PRUWJDJH RI

their home at Chappaqua, New York and ended the illegal payment of legal fees to the Clintons by 

State Farm, which was a form of bribery. I also participated in the famous Gore v. Bush litigation 

in Tallahassee, Florida that settled the 2000 presidential elections by the U.S Supreme Court. I 

DOVR EURXJKW D FDVH XQGHU WKH FRUHLJQ AJHQWV RHJLVWUDWLRQ AFW (3FARA ́) RYHU WKH CKHQH\ EQHUJ\

Task Force that made its way to the U.S. Supreme Court. 

21. I brought a case for Jose Basulto of Brothers to the Rescue in a Florida court, which 

resulted in a $1.8 million judgment against the Republic of Cuba for shooting down Brothers to 

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5 

the Rescue planes, and I represented the Miami family of Elian Gonzales and other victims of 

Fidel Castro, such as journalists who were jailed by Castro for their political beliefs. In this regard, 

I not only filed criminal complaints for these victims against Fidel Castro in Belgium courts, but 

also lobbied and testified in both Italian and French in Italy and France, as I am fluent in both 

languages, before various European parliaments to increase economic sanctions on Cuba for abuse 

of human rights. I also lobbied the European Union in Brussels, Belgium for increased sanctions 

on Cuba. 

22. On December 16, 2013, Judge Richard J. Leon granted my request for a 

SUHOLPLQDU\ LQMXQFWLRQ LQ P\ FDVH DJDLQVW WKH NDWLRQDO SHFXULW\ AJHQF\ (3NSA ́) DQG WKH OEDPD

administration, when Judge Leon found for the first time in history that the collection of metadata 

telephony records by the NSA was likely unconstitutional. 

23. Because of that ruling, Congress enacted the USA Freedom Act, which sought to 

end illegal and unconstitutional mass surveillance by government intelligence agencies and the 

Federal Bureau of IQYHVWLJDWLRQ (3FBI ́). 

24. I obtained a jury verdict in the U.S. District Court for the Southern District of 

Florida against my former public interest group Judicial Watch, which was then run by Fitton, for 

maliciously defaming me in the amount of $181,000, which included punitive damages. 

25. My client Sheriff Joe Arpaio and I were the first to challenge former President 

OEDPD¶V XQFRQVWLWXWLRQDO H[HFXWLYH DPQHVW\ IRU over 5 million illegal aliens and were ultimately 

successful, along with 25 other attorneys general, in front of the U.S. Supreme Court. 

26. IW ZDV P\ HIIRUWV WKDW SUHYHQWHG DU. JHURPH CRUVL (3DU. CRUVL ́) from getting 

indicted, first because he told the truth and did not engage in witness tampering and threaten to kill 

a witness such as Randy Credico, as Defendant Stone did, and second because of my legal skill 

and acumen. Dr. Corsi is a material witness in the Russian Collusion investigation by Special 

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6 

CRXQVHO RREHUW MXHOOHU (3MXHOOHU ́) DQG LV OLVWHG DV a material witness as Person 1 in Defendant 

SWRQH¶V MXHOOHU LQGLFWPHQW. 

27. I have had many other successes in addition to the above-listed victories. 

28. I myself DXWKRUHG D ERRN WLWOHG 3WKRUHV: WK\ DQG HRZ I CDPe to Fight the 

EVWDEOLVKPHQW ́ SXEOLVKHG LQ 2009. IQ LW, I wrote about my unfortunate experience with Defendant 

Stone. See Exhibit A. I authored this book myself without a ghostwriter and I came runner-up at

an International Book Fair. It also still has a review on www.Barnesandnoble.com of 4.5 stars out 

of the maximum 5 stars. 

29. Upon its publication, JDFN CDVKLOO, WKH DXWKRU RI 3RRQ BURZQ¶V BRG\ ́ KDG WKLV WR

VD\ DERXW PH: 3TKDW Time PDJD]LQH KDV \HW WR QDPH LDUU\ KOD\PDQ μMDQ RI WKH <HDU¶ LV D IDLOXUH

of Time, QRW KOD\PDQ¶V. TKH ZRUN KH DQG JXGLFLDO WDWFK GLG RQ WKH BURZQ FDVH LV VWXQQLQJ. ́ See

Exhibit B. 

30. JRVHSK FDUDK, WKH IRXQGHU RI WRUOGNHWDDLO\.FRP, KDG WKLV WR VD\ DERXW PH: 3LDUU\

Klayman is my hero because he has integrity ± enough to prevent him from blind loyalty to party 

or ideolog\ . . . TKDW¶V EHFDXVH KH LV IHDUOHVV DQG UHOHQWOHVV LQ WKH SXUVXLW RI MXVWLFH . . . TKHUH ZHUH

other men like Larry early in American history. Their names were Washington, Jefferson, 

Madison and Henry. See Exhibit B. 

31. Louis Jacobson of the National Journal said this of me: 3 . . . WKURXJK KLV FKDOOHQJH

of secrecy rules, Larry Klayman has become a force in Washington. See Exhibit B. 

32. BLOO MR\HUV, RI 3NRZ ́ PBS, VDLG WKLV: 3. . . KLV LGHD RI IXQ LV WU\LQJ WR NLFN GRZQ D

door some public official has marked secret . . . Larry Klayman is himself a conservative, but 

WKHUH¶V QRWKLQJ SDUWLVDQ ERXW KLV LQGLJQDWLRQ. ́

33. Frank Rich, famed FROXPQLVW IRU 3TKH NHZ <RUN TLPHV ́ VDLG WKLV: 3LDUU\ . . . I 

appreciate your own maverick ± if we can still use that word! ± thinking DQG VWDQGV. ́

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7 

34. These are just a few of the accolades I have received over the years from 

conservatives and liberals alike, who appreciate and admire my work. See my biography attached 

as Exhibit C and incorporated herein by reference; see also E[KLELW D, 3LDUU\ KOD\PDQ, WKH OQH

MDQ THD PDUW\ ́ ZKLFK DWWULEXWHV WKH genesis of the Tea Party to me. 

35. I am now the founder, Chairman and General Counsel of Freedom Watch, Inc., 

which has the mission of investigating and prosecuting government corruption and abuse through 

legal advocacy. I also am in private practice with The Klayman Law Group, P.A. I am unique as a 

public interest advocate. I am a columnist for World Net Daily and have had about 500+ columns 

published over the last 10 years. I have also been a columnist for Newsmax through a blog titled 

3KOD\PDQ¶ CRXUW ́ and in addition to my book 3Whores: How and Why I Came to Fight the 

EVWDEOLVKPHQW ́, I also published two other books: 3Fatal Neglect ́ and 3Essays of a Mad Man. ́ I 

also have my own syndicatHG UDGLR VKRZ ZLWK RDGLR APHULFD FDOOHG 3SSHFLDO PURVHFXWRU ZLWK

LDUU\ KOD\PDQ. ́

MY EXPERIENCES WITH DEFENDANT ROGER STONE

36. I met Defendant Stone at the Old Ebbitt Grill in Washington, D.C. in 1988 while he 

was a partner with Paul Manafort and others and was working as a lobbyist for the firm Black, 

Manafort, Stone, & Kelly. 

37. Defendant Stone was a 3political consultant ́ who claimed to help get presidents 

and other politicians elected. The firm made money by then lobbying the very men they put in 

office. 

38. Defendant Stone backed Republican candidate Jack Kemp for President and he 

recommended that I be put on the executive finance committee, which also included Donald J. 

Trump. 

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8 

39. Because Defendant Stone knew of my successes and capabilities as a private 

lawyer, he told me that he had recommended me for U.S. Attorney when George Bush was 

President in 1992. 

40. In 1996, at a Republican Convention in San Diego, California, Defendant Stone 

ZDV ILOPHG DW D 3WRJD SDUW\ ́ ZLWK KLV ZLIH DW D 3VZLQJHUV SDUW\. ́

41. The media at the time went after Defendant Stone because of his alleged 

paUWLFLSDWLRQ LQ WKH 3VH[ SDUW\ ́ DQG FUHDWHG D VFDQGDO. 

42. The media alleged at the time that Defendant Stone solicited sex half-naked, and 

that there was a picture of Defendant Stone in a compromising position to back up the story. 

43. Defendant Stone contacted me and, because he knew my capabilities and acumen 

as a lawyer, retained me to represent him to get the media to cease what he claimed then was a

smear campaign. 

44. I successfully got the media to back off Defendant Stone through my skill as a 

lawyer and Defendant Stone was grateful.

45. I maintained in sporadic contact with Defendant Stone until 2003 when I told him 

of my plans to voluntarily leave Judicial Watch and run for the U.S. Senate. 

46. There were confirmed rumors that Senator Bob Graham would retire from the U.S 

Senate well before he announced his retirement in November 2003. Defendant Stone traveled in 

Republican and political circles and knew that the Senator would be retiring in early to mid 2003.

47. Thus, I was in contact with Defendant Stone in early to mid 2003, having been put 

in contact with him by Scott Reed, then Chief of Staff to Jack Kemp, who then was Secretary of 

Housing and Urban Development, and Defendant Stone was made aware by Scott Reed that I 

LQWHQGHG WR UXQ IRU WKH U.S. SHQDWH WR ILOO BRE GUDKDP¶V VHDW. 

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9 

48. As I was a newcomer to politics, it would have been virtually impossible for me to 

beat Bob Graham, the incumbent, given the privileges and name recognition an incumbent 

receives, unless he or she is enmeshed in a major scandal. Senator Bob Graham was never 

enmeshed in such scandal. 

49. Because he was aware of my prior successes at Judicial Watch and before, 

Defendant Stone wanted to work with me as my U.S. Senate campaign manager. During this time, 

the spring, summer, and fall of 2003, and in preparation for my U.S. Senate run, Defendant Stone 

researched and kept books and records of many of my accomplishments. He had several binders 

(2-3 feet) full of information about me and the victories that I had obtained at Judicial Watch and 

elsewhere. Again, because Defendant Stone knew of my successes and legal political acumen, 

Defendant Stone wanted to be on my team and help me run for the U.S. Senate. 

50. Defendant Stone thus knew of many cases I had won in courtrooms and other legal 

accomplishments and in fact had kept records of successes in a book of my accomplishments. 

51. Soon after I hired him and during the height of my U.S. Senate campaign, I 

discovered that Defendant Stone had a conflict of interest and was working with Al Sharpton, 

while simultaneously working with me. He had agreed to represent me exclusively and I 

considered Al Sharpton to be an unsavory character. He also was not competently running my 

campaign with a staff of his friends which he had hired at great expense to me. 

52. I let Defendant Stone go roughly after about one month of his working with me on 

my U.S. Senate campaign. Shortly after his being let go, Defendant Stone and his sidekick Mike 

Caputo, ZKRP KH KLUHG RQ P\ EHKDOI DV WKH FDPSDLJQ¶V SUHVV VHFUHWDU\, along with other staff 

Defendant Stone had hired, stole thousands of dollars of campaign cell phones and laptops, which 

I had purchased with my personal funds for the campaign. 

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10 

53. I have not spoken to Defendant Stone since I parted ways with him in 2003 given 

this experience. 

54. Defendant Stone is an individual and citizen of Florida. Special Counsel Robert 

MXHOOHU (3MXHOOHU ́) LQGLFWHG SWRQH DV SDUW RI WKH DOOHJHG 3RXVVLDQ CROOXVLRQ ́ LQYHVWLJDWLRQ ZLWK

seven different felony counts, including lying under oath, witness tampering and obstruction of 

justice by threatening to kill a material witness and his service dog.

55. The January 18, 2019 InfoWars video, published in this circuit, contained several 

false, misleading and defamatory statements concerning me. These false and defamatory 

statements include but are not limited to: 

A ̀ 1:25, DeIe. daQW SWRQe Va\V, 3He¶V (KOa\PaQ) QeYeU acWXaOO\ ZRQ a 

cRXUWURRP YLcWRU\ LQ KLV OLIe. ́ 

AW 1:30, DeIeQdaQW SWRQe Va\V, 3He (KOa\PaQ) ZaV RXVWed aW JXdLcLaO WaWcK. 

AVN TRP FLWWRQ ZK\ Ke OeIW. He ZaV μRXVWed¶ becaXVe RI a μVe[XaO KaUaVVPeQW 

cRPSOaLQW.¶ ́

AW 1:37, DeIeQdaQW SWRQe Va\V, 3He¶V (KOa\PaQ) LQcRPSeWeQW, Ke¶V a 

QXPbVNXOO, Ke¶V aQ LdLRW, Ke¶V aQ eJRPaQLac, aQd Ke cRXOd be WKe VLQJOe ZRUVW

OaZ\eU LQ APeULca. WLWK KLP aV JeUU\ CRUL¶V OaZ\eU, CRUVL Pa\ JeW WKe 

electric cKaLU. SR \RXU Ldea WKaW Ke¶V a JRRd JX\ LV eQWLUeO\ ZURQJ. ́ 

AW 2:01, DeIeQdaQW SWRQe SXbOLVKed WKaW POaLQWLII LV 3a SLece RI JaUbaJe. ́ 

AW 4:11, DeIeQdaQW SWRQe Va\V, 3FRU WKRVe SeRSOe RXW WKeUe ZKR WKLQN . . . WKaW

LaUU\ KOa\PaQ¶V IQ LV KLJKeU WKaQ 70, \RX¶Ue ZURQJ . . . ́

Am. Compl. at ¶¶ 55, 56, 59, 61, 62.

56. Defendant Stone acted with actual when he published the false, misleading and 

defamatory statements concerning me because he knew they were false or acted with a reckless 

disregard to their truth, as set forth herein. 

57. Defendant Stone not only acted with actual malice when he published the false, 

misleading and defamatory statements concerning me, but he also had motives to maliciously 

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11 

defame me. He published the false and misleading statements knowing that they were false or with 

a reckless disregard for their truth. Defendant Stone had reason to know that his statements were 

false. 

58. Defendant Stone is aware of many, many victories of mine as he was in charge of 

putting together the book of my accomplishments for fundraising purposes for my U.S. Senate 

campaign, among other reasons. 

59. Since the time I let Defendant Stone go as my campaign manager in late 2003, 

Defendant Stone has tried to trade off my clients like a 3scavenger. ́ I have warned my clients not 

to become involved with him as, in my opinion and through my experience, Defendant Stone is 

not an honorable, ethical or honest person. He has been widely and rightly called a self-styled 

3GLUW\ WULFNVWHU ́ In my opinion, this characterization is accurate based on my experience dealing 

with him. See 3GHW PH RRJHU SWRQH ́ RQ NHWIOL[, 

https://www.netflix.com/title/80114666. He tried to trade off my clients for his own profit and 

purposes. 

60. When the National Enquirer contacted me in 2018 to get a comment on a story it 

was writing about President Donald Trump and to get my legal opinion on the Mueller 

investigation, I told the reporter not to quote me in the same article as Defendant Stone, or any 

article in which he wrote, as Defendant Stone wrote for the National Enquirer at the time. The 

National Enquirer is located in South Florida and is apparently close with Defendant Stone, a 

South Florida citizen. I did not want to be quoted or associated at all with Defendant Stone 

because I consider him ± like others do ± to be a self-styled dirty trickster who was likely going to 

be indicted for alleged criminal behavior by Mueller and in fact was indicted by Mueller. 

61. In 2018, I also told Alex Jones and his show producers on InfoWars that I did not 

want to appear on any show which included Defendant Stone or had ties to Defendant Stone, 

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12 

either as a guest or as a host, because I strongly felt at the time that Mueller may indict Defendant 

Stone. Defendant Stone was at the time a host on InfoWars. 

62. I also warned Alex Jones not to release any information ± that was potentially 

under seal in the contempt case of Melendrez v. Arpaio, 07-cv-02513 (D. Ariz. 2007) ± which he 

may have improperly obtained from Defendant Stone or others concerning Dennis Montgomery, 

another whistleblower client of mine who contracted with the U.S. government so it could use his 

software capabilities for intelligence gathering. 

63. During the criminal trial of my client Cliven Bundy, again to try to scavenge off 

my clients, Defendant Stone flew to Las Vegas, Nevada where the Bundys lived and boasted that 

KH FRXOG JHW D SDUGRQ IRU COLYHQ BXQG\ DQG KLV VRQV. I WROG CDURO BXQG\, COLYHQ¶V ZLIH DQG WKH

VRQV¶ PRWKHU, to stay away from Defendant Stone and she did. 

64. I also warned my then client at the time, Dennis Montgomery, to stay away from 

Defendant Stone. 

65. Defendant Stone wanted to ± and did ± intimate and threaten my client Dr. Corsi 

since he is a material witness in the Mueller investigation as Defendant Stone obviously feared 

that he would testify agDLQVW KLP WR MXHOOHU. DHIHQGDQW SWRQH IHDUHG PH DV DU. CRUVL¶V ODZ\HU DV

he knew that I know what type of person he is and must have thought falsely that my 

representation of Dr. Corsi was my revenge for him having harmed me during my U.S. Senate 

campaign.

66. In sum, Defendant Stone tried to trade off my clients and I shut this down every 

time in order to protect my clients from Defendant Stone. He also knew that I wanted nothing to 

do with him and I predicted early on in the Russian collusion investigation that Mueller would 

most likely indict Defendant Stone because of ± in my experience with him ± his rank dishonesty 

and dirty tricks. 

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13 

67. This, in addition to other information that will be meted out in discovery, supplies 

the motive to maliciously defame me. That he attacks my acumen and ability as a lawyer and 

defamed me personally with false sexual harassment complaint claims is directly related to my 

having kept him away from my clients. 

68. This vindictive, malicious retaliation by Defendant Stone had a logical purpose. He 

tried to intimate and threaten Dr. Corsi and me in order for us not to collaborate with Mueller. We 

obviously did not collaborate with Mueller but Defendant Stone is both unstable and unhinged 

(See CDs containing videos of defamatory statements and publications) and apparently paranoid 

and he tried to prevent collaboration at all costs in order to save his own skin. His conduct toward 

us is similar to his conduct toward Material Witness 2 in the Mueller investigation, Randy 

Credico, who he allegedly threatened 3MDILRVR VW\OH ́ to kill. He even allegedly threatened to kill 

CUHGLFR¶V VHUYLFH GRJ, IRU ZKLFK KH ZDV LQ SDUW LQGLFWHG. 

DAMAGES 

69. As an attorney, I rely on my virtue and integrity, as my reputation and good will 

determines the amount of clients that come to me to earn a living for their legal matters in the 

public interest and privately.

70. Any damage done to my reputation harms my ability to practice law as a lawyer,

particularly in this circuit, which is my community. This also harms my work as an author, 

columnist and syndicated radio talk show host, all of which depend on reputation and good will. 

71. DHIHQGDQW SWRQH¶V VWDWHPHQWs in this instance have caused harm to my reputation, 

good will and well being in this circuit, the United States, and globally, as I am also an 

international lawyer as previously set forth in this affidavit. 

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14 

72. There was never any single instance of someone making a sexual harassment 

complaint against me during my almost ten years at Judicial Watch. DefenGDQW SWRQH¶V VWDWHPHQWV

to the contrary are false and defamatory and made with actual malice.

73. Defendant Stone acted with actual PDOLFH ZKHQ KH SXEOLVKHG WKDW I ZDV 3RXVWHG ́

because of a sexual harassment complaint because he knew that was false. Am. Compl. at ¶ 56. 

Defendant Stone knew or had reason to know that this was false, as he was my campaign manager 

when I left Judicial Watch. 

74. AV VHW IRUWK LQ P\ RSSRVLWLRQ WR DHIHQGDQWV¶ PRWLRQV WR GLVPLVV, ZKLFK DWWDFKHV WKH

testimony of Fitton of Judicial Watch, this also proves the falsity of this statement. Indeed, both 

Fitton and Defendant Stone have been forced to testify under oath that they never spoke about my 

EHLQJ 3RXVWHG. ́ Defendant Stone thus fabricated this falsity, according to FLWWRQ¶V sworn 

testimony. 

75. The damage done to me and my clients Dr. Corsi, Cliven Bundy, and the Gold Star 

parents of Extortion 17 whose sons died in combat in Afghanistan, because of Defendant Stone is 

continuing. As just one example, a person approached me in an elevator and told me that I was 

3RXVWHG ́ DW JXGLFLDO WDWFK. 

76. Defendant Stone acted with actual malice when he published all of the defamatory 

statements. He knew the statements were false or had a reckless disregard for their truth. He had 

reason to know his false and misleading statements were false. 

77. I was damaged financially, as well as to my reputation and good will, and 

emotionally, by the defamatory and other tortious acts of Defendant Stone.

78. Each of the Defendants, Alex Jones, David Jones, Owen Shroyer, Free Speech and 

Infowars, is intimately familiar with my background, qualifications and successes as a public 

interest and private attorney. For this reason, I was previously invited to appear on Infowars on 

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15 

many occasions before Defendants decided ± at the direction of Defendant Stone ± to defame my 

client, Dr. Corsi and me. 

Affiant Sayeth Not 

SWORN TO UNDER OATH THIS 30TH DAY OF SEPTEMBER OF 2020. 

_______________________

Larry Klayman

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EXHIBIT 4

Case 1:20-cv-00298-LY-DH Document 147 Filed 08/05/21 Page 89 of 107
1

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.

§

§

§

§

§

§

§

§

§

§

§

§

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

SWORN DECLARATION OF DR. JEROME CORSI

I, Dr. Jerome Corsi, being over eighteen years of age and duly competent to testify, 

hereby swear and affirm as follows:

1. I have personal knowledge of the following facts and if called upon as a witness, 

could testify competently thereto. 

2. I graduated magna cum laude with a B.A. in Political Science and Economics 

from Case Western Reserve University in 1968.

3. I received a Ph.D. in Political Science from Harvard University in 1972.

4. For over twenty-five (25) years, I worked in banking and finance, establishing 

investment programs for banks in the United States and worldwide to create financial planning 

services for their retail customers. 

5. From 1968 to 1981, I worked at various universities where I conducted research 

on federally funded grants. 

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2

6. In 1981, I published “Terrorism as a Desperate Game: Fear, Bargaining, and 

Communication in the Terrorist Event” in Journal of Conflict Resolution, a mathematical gametheoretical model for predicting the outcome of terrorist events. 

7. The content of my publication resulted in a top-secret clearance by the U.S. 

Department of State’s (“State Department”) Agency for International Development, where I 

joined a team of psychiatrists and psychologists to develop a hostage-survival training program 

for State Department’s officials overseas. 

8. Since 2004, I have published over twenty-five (25) books, seven (7) of which 

were New York Times Bestsellers, including two (2) #1 New York Times Best-sellers. 

9. In addition to being a New York Times Bestselling author, I am also an 

investigative journalist and political analyst. 

10. I currently hold active Life & Health insurance licenses, as well as Property & 

Casualty insurance licenses in New Jersey. 

11. For over twenty (20) years, I have been a licensed National Association of 

Security Dealers registered representative, currently holding FINRA-registered licenses as a 

Registered Principal, Financial Principal, Options Principal and Municipals Principal. 

12. I have been a frequent guest on radio and television shows, including but not 

limited to appearances on CNN, Fox News, Fox Business, MSNBC, and on Infowars, before 

having been defamed by Defendants.

13. I personally know Defendant Roger Stone (“Defendant Stone”) and he personally 

knows my qualifications and me. I have even ghostwritten books for Defendant Stone and we 

used to be friends and colleagues. Defendant Stone is thus intimately familiar with my personal 

and professional history. 

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3

14. In 2016, after the presidential election, I worked very closely with Alex Jones and 

his father David Jones, as well as with the Infowars staff, including Owen Shroyer. I made 

multiple trips to Austin, Texas, to appear live in-studio on Infowars broadcasts. I accepted an 

assignment from Alex Jones to create for Infowars a news bureau in Washington, D.C. From the 

beginning, I found Alex Jones to be erratic, subjects to emotional outbursts, even reacting that I 

was trying to “steal his company” when with his father’s assistance, I brought a multi-million 

dollar legitimate investment offer from highly credible sources to the table to discuss the 

proposal with Alex and his father.

15. Several times, concerned that I might quit over how badly Alex Jones was treating 

me, Dr. Jones met with me privately, often over breakfast. In those breakfasts, I counseled Dr. 

Jones over my concerns that Alex should seek professional psychological help. While in my 

work under various contracts with federal government agencies to consult over anti-terrorism 

tactics, I had the opportunity to work with very experienced psychiatrists and psychologists. Still, 

I am not medically trained, and I cautioned Dr. Jones that the problems I perceived with Alex’s 

behavior should be professionally evaluated by qualified medical professionals.

16. My efforts to create a news bureau in the nation’s capital failed because Alex 

Jones insisted that staff I wanted to hire must work for free as “interns.” Throughout my 12 

years at World Net Daily, I frequently had White House press credentials. In 2012, the Secret 

Service cleared me to work as “traveling press,” riding on the Romney campaign airplane for the 

last 3 weeks of the presidential campaign. At no time was I ever denied press credentials at the 

highest levels was alcohol ever raised as an issue in the many extensive background checks I 

underwent. In the early 1980s, I received Top Secret clearance from the federal government to 

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work on anti-terrorism contracts with the Agency for International Development at the State 

Department in Washington, D.C.

17. Throughout the time I spent with Infowars, Dr. Jones would typically pick me up 

at the Austin Airport to transport me to the downtown hotel where Dr. Jones had made my room 

reservations. At various times, we had breakfast together, often on trips when he was returning 

me to the airport to depart Austin.

18. I am today 74 years-old. I have no alcohol-related offenses on my record. Since 

the mid-1980s, I have held securities licenses, first with the NASD and now with FINRA, 

agencies that conduct licensing in the securities industry for the federal government. My 

securities records over that time, contain no customer complaints and no reports of behavior 

problems of any kind, including no alcohol-related problems. I also have held for decades 

property and casualty as well as life and health insurance licenses in New Jersey. I have created 

two broker/dealers in my financial services career.

19. On my website, CorsiNation.com — a website I founded and managed as CEO —

I conduct a daily hour-long podcast, live-streamed on multiple Internet channels 

simultaneously. I hold a Ph.D. from Harvard University’s Department of Political Science, 

dating back to 1972. I appear regularly on various news programs, including those broadcast by 

the major networks. I have conducted thousands of radio interviews going back to 2004, when I 

entered the third phase of my career, currently working full-time as an investigative journalist 

and political commentator.

20. Charges of alcoholism by the Defendants including broadcast charges made by 

Alex Jones and Defendant Roger Stone, have no basis in fact or substantiation in the extensive 

public record that exists of my life and professional career.

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21. Special Counsel Robert Mueller indicted Defendant Stone on seven counts of 

perjury, witness tampering and obstruction of justice.

22. The Honorable Amy Berman Jackson who presided over Defendant Stone’s 

prosecution, placed a gag order on him in part for threatening the judge herself by posing an 

Instagram meme of a crosshairs (gun) to her head. 

23. The seven-count indictment against Defendant Stone included lying under oath, 

witness tampering and obstruction of justice by threatening to kill a material witness, Randy 

Credico (“Credico”) and his service dog if Credico did not lie or invoke the Fifth Amendment to 

government authorities concerning his involvement with Defendant Stone. Credico is Person 2 in 

the indictment. I am Person 1. Defendant Stone was later convicted of all seven (7) felony counts.

24. Based on my personal knowledge of the interactions of Defendant Stone and the 

other Defendants, I assert that Defendant Stone, acting in concert with the other Defendants 

including Alex Jones, David Jones, Owen Shroyer, Free Speech and Infowars, began a calculated 

and premeditated public relations campaign against my lawyer, Mr. Larry Klayman (“Mr. 

Klayman”) and myself.

25. Defendant Stone knew of his imminent indictment and therefore began his 

malicious crusade against Mr. Klayman and myself in order to influence public opinion and 

Special Counsel Robert Mueller by trying to attribute guilt to me. 

26. It is apparent that the malicious crusade against me by Defendants, who acted in 

concert, was calculated to coerce me to testify falsely at Defendant Stone’s criminal trial. 

27. Defendant Stone, acting in concert with the other Defendants, also sought to 

divert funds away from my legal defense fund, while boosting his own. 

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28. Contrary to Defendant Stone’s false publication, I am not “certifiably insane and I 

have not “told multiple provable lies.” Compl. at ¶ 26. In publishing this false statement that 

Defendants knew to be false or published recklessly because they are intimately familiar with me,

as set forth above, Defendant Stone acted in concert with the other Defendants, including Alex 

Jones, David Jones, Owen Shroyer, Free Speech and Infowars.

29. Contrary to Defendant Stone’s false publication, I am not “mentally degraded to 

the point of [] dementia.” Compl. at ¶ 42. I do not have dementia and have never been diagnosed 

with any mental illness. In publishing this false statement that Defendants knew to be false or 

published recklessly because they are intimately familiar with me, as set forth above, Defendant 

Stone acted in concert with the other Defendants, including Alex Jones, David Jones, Owen 

Shroyer, Free Speech and Infowars. 

30. Importantly, I was under contract with Infowars until the relationship ended and 

Defendants would not have retained me if I was “mentally degraded to the point of [] dementia.” 

Compl. at ¶ 42. 

31. Contrary to Defendant Stone’s false publication, he never saw me at a steakhouse 

where I was “on the ground at another table” where security staff “thought that [I] was dead in 

the elevator.” Compl. at ¶ 43. In publishing this false statement that Defendants knew to be false

or published recklessly because they are intimately familiar with me, as set forth above, 

Defendant Stone acted in concert with the other Defendants, including Alex Jones, David Jones, 

Owen Shroyer, Free Speech and Infowars. 

32. Contrary to Defendant Stone’s false publication, I never suffered a stroke and it is 

a false statement of fact that “whatever comes out of [my] mouth ain’t the truth.” Compl. at ¶ 44. 

In publishing this false statement that Defendants knew to be false or published recklessly 

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because they are intimately familiar with me, as set forth above, Defendant Stone acted in 

concert with the other Defendants, including Alex Jones, David Jones, Owen Shroyer, Free 

Speech and Infowars. 

33. Contrary to Defendant Stone’s false publication, I was not “fired from World Net 

Daily.” Compl. at ¶ 49. In publishing this false statement that Defendants knew to be false or 

published recklessly because they are intimately familiar with me, as set forth above, Defendant 

Stone acted in concert with the other Defendants, including Alex Jones, David Jones, Owen 

Shroyer, Free Speech and Infowars.

34. Contrary to Defendant Stone’s false publication, I was not “perfectly willing to lie, 

to perjure [myself] saying that a memp that [I] had [written] [Defendant Stone] on the 30th for the 

purposes of cover-up . . . which is further proof that [I] lied under oath.” Compl. at ¶ 50. In 

publishing this false statement that Defendants knew to be false or published recklessly because 

they are intimately familiar with me, as set forth above, Defendant Stone acted in concert with 

the other Defendants, including Alex Jones, David Jones, Owen Shroyer, Free Speech and 

Infowars.

35. Contrary to Defendant Stone’s false publication, I do not have a “feeble alcohol 

affected memory.” Compl. at ¶ 51. In publishing this false statement that Defendants knew to be 

false or published recklessly because they are intimately familiar with me, as set forth above, 

Defendant Stone acted in concert with the other Defendants, including Alex Jones, David Jones, 

Owen Shroyer, Free Speech and Infowars.

36. Contrary to Defendant Stone’s publication, I was not “prepared to stab a principle 

Trump supported in the back” nor was I “perfectly prepared to bear false witness against 

[Defendant Stone].” Compl. at ¶ 52. In publishing this false statement that Defendants knew to 

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be false or published recklessly because they are intimately familiar with me, as set forth above, 

Defendant Stone acted in concert with the other Defendants, including Alex Jones, David Jones, 

Owen Shroyer, Free Speech and Infowars.

37. Contrary to Defendant Stone’s publication, it is a false statement of fact that “all 

[Defendant Stone] ever did was show [me] friendship and support and try to help [me] and [my] 

family and what [Defendant Stone] got was Judas Iscariot, the willingness to testify against 

[Defendant Stone] and help the deep state bury [Defendant Stone] . . . and then [I] make[] up this 

story about helping [Defendant Stone] formulate a cover story.” Compl. at ¶ 53. In publishing 

this false statement that Defendants knew to be false or published recklessly because they are 

intimately familiar with me, as set forth above, Defendant Stone acted in concert with the other 

Defendants, including Alex Jones, David Jones, Owen Shroyer, Free Speech and Infowars.

38. Contrary to Defendant Stone’s false publication, it is a false statement of fact that 

“you can always tell when [I] [am] lying because [my] lips are moving . . .” Compl. at ¶ 54. In 

publishing this false statement that Defendants knew to be false or published recklessly because 

they are intimately familiar with me, as set forth above, Defendant Stone acted in concert with 

the other Defendants, including Alex Jones, David Jones, Owen Shroyer, Free Speech and 

Infowars.

39. Contrary to Defendant Stone’s false publication, it is a false statement of fact that 

Mr. Klayman “never actually won a courtroom victory in his life.” Compl. at ¶ 55. In publishing 

this false statement that Defendants knew to be false or published recklessly because they are 

intimately familiar with me, as set forth above, Defendant Stone acted in concert with the other 

Defendants, including Alex Jones, David Jones, Owen Shroyer, Free Speech and Infowars.

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40. Contrary to Defendant Stone’s false publication, it is a false statement of fact that 

Mr. Klayman “was ousted at Judicial Watch. Ask Tom Fitton why he left .he was ‘ousted’ 

because of a sexual harassment complaint.” Compl. at ¶ 56. In publishing this false statement 

that Defendants knew to be false or published recklessly because they are intimately familiar Mr. 

Klayman and with me, as set forth above, Defendant Stone acted in concert with the other 

Defendants, including Alex Jones, David Jones, Owen Shroyer, Free Speech and Infowars.

41. Contrary to Defendant Stone’s false publication, it is a false statement of fact that 

Mr. Klayman is “incompetent, he’s a numbskull, he’s an idiot, he’s an egomaniac, and he could 

be the worst single lawyer in America. With him as [my] lawyer, [I] may get the electric chair. 

So [the] idea that he’s a good guy is entirely wrong.” Compl. at ¶ 59. In publishing this false 

statement that Defendants knew to be false or published recklessly because they are intimately 

familiar with Mr. Klayman and me, as set forth above, Defendant Stone acted in concert with the 

other Defendants, including Alex Jones, David Jones, Owen Shroyer, Free Speech and Infowars.

42. Contrary to Defendant Stone’s false publication, it is a false statement of fact that 

Mr. Klayman is “a piece of garbage.” Compl. at ¶ 61. In publishing this false statement that 

Defendants knew to be false or published recklessly because they are intimately familiar with Mr. 

Klayman and me, as set forth above, Defendant Stone acted in concert with the other Defendants, 

including Alex Jones, David Jones, Owen Shroyer, Free Speech and Infowars.

43. Contrary to Defendant Stone’s false publication, Mr. Klayman’s IQ is higher than 

70. Compl. at ¶ 62. In publishing this false statement that Defendants knew to be false or 

published recklessly because they are intimately familiar with me, as set forth above, Defendant 

Stone acted in concert with the other Defendants, including Alex Jones, David Jones, Owen 

Shroyer, Free Speech and Infowars.

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44. Contrary to Defendant Stone’s false publication, it is a false statement of fact that 

“[I] was perfectly willing to bear false witness against [Defendant Stone] on multiple points that 

are complete fabrications.” Compl. at ¶ 64. In publishing this false statement that Defendants 

knew to be false or published recklessly because they are intimately familiar with me, as set forth 

above, Defendant Stone acted in concert with the other Defendants, including Alex Jones, David 

Jones, Owen Shroyer, Free Speech and Infowars.

45. Contrary to Defendant Stone’s false publication, it is a false statement of fact that 

“[I] had told a number of lies. In fact, [I] [am] starting to conflate [my] lies . . . [I] was perfectly 

willing to lie about [Defendant Stone] . . . but now lying about Alex Jones, lying about Infowars, 

lying about Dr. [David] Jones . . . [I] can no longer be believed.” Compl. at ¶ 65. 

46. Defendant Stone falsely published: “I think you’ve [Corsi] been deep state from 

the beginning. Your whole birther thing is used as a club to destroy conservatives . . . I look 

forward to our confrontation. I will demolish you. You’re a fraudster, out of your alcoholic 

haze you have made up lies about David Jones and Alex Jones and Roger Stone and now I 

suspect they want you to lie about the President.” Compl. at ¶ 66 (emphasis added). Not only 

does Defendant Stone know this to be false but this malicious rant is also a threat. In publishing 

this false statement that Defendants knew to be false or published recklessly because they are 

intimately familiar with me,, as set forth above, Defendant Stone acted in concert with the other 

Defendants, including Alex Jones, David Jones, Owen Shroyer, Free Speech and Infowars.

47. Contrary to Defendant Stone’s false publication, I am not a “spook, back and 

forth with different agencies[.]” Compl. at ¶ 67. In publishing this false statement that 

Defendants knew to be false or published recklessly because they are intimately familiar with me, 

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EXHIBIT 5

Case 1:20-cv-00298-LY-DH Document 147 Filed 08/05/21 Page 101 of 107
Transcript of Thomas J. Fitton

Date: June 6, 2019

Case: Klayman -v- Fitton

Planet Depos

Phone: 888.433.3767

Email:: transcripts@planetdepos.com

www.planetdepos.com

WORLDWIDE COURT REPORTING | INTERPRETATION | TRIAL SERVICES

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 IN THE UNITED STATES DISTRICT COURT

 FOR THE SOUTHERN DISTRICT OF FLORIDA

LARRY KLAYMAN, *

 Plaintiff, *

 vs. * Civil Action

THOMAS FITTON, * No. 1:19-cv-20544

 Defendant. *

 Videotaped Deposition of THOMAS J. FITTON

 Washington, D.C.

 Thu rsday, June 6, 2019

 3:06 p.m.

Job No.: 247643

Pages 1 - 92

Reported by: Vicki L. Forman

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 A P P E A R A N C E S

ON BEHALF OF THE PLAINTIFF PRO SE:

 LARRY KLAYMAN, ESQUIRE

 Klayman Law Group, P.A.

 Suite 345

 2020 Pennsylvania Avenue, Northwest

 Washington, D.C. 20006

 (310) 595-8088

ON BEHALF OF THE DEFENDANT:

 RICHARD W. DRISCOLL, ESQUIRE

 Driscoll & Seltzer

 Suite 610

 300 North Washington Street

 Alexandria, Virgini a 22314

 (703) 822-5001

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 Videotaped Deposition of THOMAS J. FITTON,

held at the offices of:

 Planet Depos

 Suite 950

 1100 Connecticut Avenue, Northwest

 Washington, D.C. 20036

 (888) 433-3767

 Pursuant to agreement, before Vicki L.

Forman, Court Reporter and Notary Public in and

for the District of Columbia.

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ON BEHALF OF THE DEFENDANT:

 KATIE M. MERWIN, ESQUIRE

 Cole, Scott & Kissane, P.A.

 Suite 120

 222 Lakeview Avenue

 West Palm Beach, Florida 33401

 (561) 383-9206

 (Present via Telephone.)

ALSO PRESENT: Joannis Arsenis, Videographer

Transcript of Thomas J. Fitton 1 (1 to 4)

Conducted on June 6, 2019

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 MR. KLAYMAN: Certify it.

 Q So as President of Judicial Watch you

would have known for sure that this Complaint had

been filed, correct?

 MR. DRISCOLL: Objection to form.

 A Well, the press release indicates it was

filed and I recall we sued about the raid, yes.

 Q And you gave interviews about suing in the

raid, correct, in the media?

 A I don't remember.

 Q Turn to the last page, page five.

 The Complaint is signed by James F

Peterson, correct?

 A His name is on the last page of the

Complaint as a signatory.

 Q He is an attorney at Judicial Watch,

correct?

 A Yes.

 Q Now, Mr. Peterson had contact with Roger

Stone over the issue of the raid on his house, did

he not?

 A Not that I'm aware of.

 MR. DRISCOLL: Objection to form.

 Q You're saying you don't know one way or

the other?

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have been disclosed to me.

 Q But you don't know for sure that

Mr. Peterson didn't have contact with Roger Stone?

 MR. DRISCOLL: Objection to form.

 A I'm confident there was no such contact.

 Q You have told Mr. Peterson in the past,

have you not, that I was ousted from Judicial

Watch because of a sexual harassment complaint?

 MR. DRISCOLL: Objection to form.

Mr. Peterson is an in-house counsel and I'm going

to direct the witness not to answer. That's an

attorney-client privilege.

 MR. KLAYMAN: Certify it.

 Q So you don't know whether or not

Mr. Peterson repeating what you had told him then

republished that to Roger Stone?

 MR. DRISCOLL: The communications between

an in-house counsel and the President of the

corporation relating to legal advice and

assistance are privileged. He can't answer the

question about the contents of the communication

or derivative questions that would disclose the

content of the communication.

 MR. KLAYMAN: That's the crux of the

lawsuit. That does not apply in this context.

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 A I don't believe he has. I said I would

know if he had.

 Q How would you know if you couldn't even

identify the Complaint?

 A Another abusive harassing question.

 MR. DRISCOLL: It's a foundation question.

You can go ahead and answer it.

 How would you know if he had contacted

Roger Stone?

 MR. KLAYMAN: Or if Roger Stone contacted

him.

 A Is it privileged?

 MR. DRISCOLL: That's an interesting

question. The fact of the communication would not

be. The contents of it would be.

 A How I would know is my question of whether

it's privileged or not.

 MR. DRISCOLL: No, I'm going to allow you

to answer that one.

 A How I would know about what my attorneys

are doing or Judicial Watch's attorneys are doing?

 MR. DRISCOLL: Yeah, and you're not

disclosing a communication. You're just

describing a process.

 A Typically that type of communication would

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 MR. DRISCOLL: That doesn't waive the

privilege.

 Q Are you saying that you never told anyone

at Judicial Watch that I was ousted because of a

sexual harassment complaint?

 MR. DRISCOLL: Anyone other than the

attorneys?

 MR. KLAYMAN: Anyone.

 MR. DRISCOLL: No, I can't allow him to

answer that question.

 Q Are you saying that you never told anyone

that I was -- regardless -- let's take attorneys

out of it.

 Have you ever -- you have told other

people in addition to -- strike that.

 You have told other people excluding

attorneys that I was ousted from Judicial Watch

because of a sexual harassment complaint?

 A You have to ask the question again.

 MR. KLAYMAN: Read it back, please.

 A Please.

 MR. KLAYMAN: Let me rephrase it.

 Q I'm taking attorneys out of this question.

I'm saying you have told others who aren't

attorneys over the course of the last 16 years

Transcript of Thomas J. Fitton 11 (41 to 44)

Conducted on June 6, 2019

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since I left Judicial Watch that I was ousted

because of a sexual harassment complaint?

 A No, because that's not true. You weren't

ousted as a result of a sexual harassment

complaint.

 Q After I sued you in this particular case

has anyone -- have you or anyone at Judicial Watch

or your counsel tried to contact Roger Stone?

 MR. DRISCOLL: Objection to form. The

question invades the attorney-client privilege and

the attorney work product. I direct the witness

not to answer.

 MR. KLAYMAN: Certify it.

 Madam court reporter, have a page in the

front where you have all the certified questions

and where you can find them to make it easy for

the Magistrate Judge. Thank you.

 Q Now, I turn your attention back to your

affidavit which is --

 A Exhibit 3.

 Q Exhibit 3. Turn your attention to

paragraph seven where it says "I have no

recollection of ever having any communication with

Roger Stone," do you see that?

 A Uh-huh.

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Judicial Watch was motivated by an employee's

sexual harassment complaint," do you see that?

 A Yeah.

 Q Again, that statement does not say that

you never spoke with Roger Stone, just that you've

never published that particular issue, correct?

 A It says what it says.

 Q And then it states "Any statement by Roger

Stone regarding Klayman was made without my

knowledge or information and therefore I did not

intend and could not intend to harm Klayman or his

reputation," do you see that?

 A Yes.

 Q Now, you're not saying in that statement

that you didn't communicate with Roger Stone.

You're saying that you didn't know that he was

going to republish anything about me, correct?

 MR. DRISCOLL: Objection to form. The

document speaks for itself.

 A The document speaks for itself.

 Q If you don't want to explain it that's

fine.

 A You're mischaracterizing it.

 Q I do agree. It speaks for itself and

there's a lot of loopholes in it.

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 Q Now, it doesn't say you didn't have a

communication with Roger Stone. It just says that

you have no recollection of having one, correct?

 A That's correct.

 Q Do you remember during the Clinton years

that witnesses would always come in and say we

have no specific recollection and we would contest

that?

 MR. DRISCOLL: Just ask your question,

Larry.

 Q So you can't say categorically that you

haven't had communications with Roger Stone?

You're just saying you don't have a recollection

of ever having it, correct?

 A I think the statement speaks for itself.

 Q You could have said I have never

communicated with Roger Stone, correct, if that's

what you were trying to say, that you never had

any contact?

 A The statement speaks for itself.

 Q Then you state in the next sentence "I

have never published, uttered or implied to Roger

Stone that Klayman was the subject of a sexual

harassment complaint during his employment by

Judicial Watch or that his resignation from

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 MR. DRISCOLL: Why don't you just ask him

the question. Did he ever --

 MR. KLAYMAN: I will ask the questions

that I want to ask, Mr. --

 MR. DRISCOLL: All right.

 Q I want to turn to paragraph eight.

 Do you see the statements in the last

sentence of paragraph eight where it says "To

support his claim Judicial Watch submitted

evidence demonstrating that Klayman was forced to

resign due to inappropriate conduct" and you list

three examples of your alleged inappropriate

conduct, do you see that?

 A Yeah.

 Q Now, you have in the last 16 years told

many people, and I'm excluding any attorneys,

exactly what is written in this affidavit and

which you swore to under oath?

 MR. DRISCOLL: I'm going to object to the

question and direct the witness not to answer that

question to the extent it's related to the other

lawsuit that is currently pending in the U.S.

District Court for the District of Columbia, Case

Number 06-cv-670.

 MR. KLAYMAN: That's not a basis to tell

Transcript of Thomas J. Fitton 12 (45 to 48)

Conducted on June 6, 2019

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Roger Stone taken on 2/12/2020

Bailey & Associates c/o Empire Legal Reporting (954) 241-1010 Page: 1

 1 IN THE CIRCUIT COURT OF THE SEVENTEENTH CIRCUIT

 IN AND FOR BROWARD COUNTY AND THE FIFTEENTH JUDICIAL

 2 CIRCUIT FOR PALM BEACH COUNTY, FLORIDA, FLORIDA

 3

 4 LARRY KLAYMAN,

 CASE NO. 19-011394

 5 Plaintiff,

 6 -vs-

 7 ROGER STONE,

 8 Defendant.

 ____________________________________/

 9

 JEROME CORSI, et al

10

 Plaintiff

11

12 vs. CASE NO. 50-2019-CA-013711

13

 ROGER STONE, et al

14

 Defendant

15 ____________________________________/

16

 VIDEOTAPED DEPOSITION OF ROGER STONE

17

 VOLUME I OF II

18

 Wednesday, February 12, 2020

19 9:42 a.m. - 4:28 p.m.

20

 110 Southeast 6th Street, Suite 1700

21 Fort Lauderdale, Florida 33301

22

 Stenographically Reported By:

23 PATRICIA BAILEY-ENTIN, FPR

 Notary Public, State of Florida

24 BAILEY & ASSOCIATES REPORTING, INC.

 Fort Lauderdale Office

25 Phone - 954-358-9090

Case 1:20-cv-00298-LY-DH Document 147 Filed 08/05/21 Page 106 of 107 Case 1:20-cv-00298-LY-AWA Document 73 Filed 09/30/20 Page 58 of 66
Roger Stone taken on 2/12/2020

Bailey & Associates c/o Empire Legal Reporting (954) 241-1010 Page: 39

 1 But let's start with my sworn affidavit on top,

 2 and I'll ask that that be marked. It -- it entails --

 3 MR. KLAYMAN: And you can just mark it right in

 4 the book --

 5 THE REPORTER: Sure.

 6 MR. KLAYMAN: -- to make it easy.

 7 That's Exhibit 2 to the Stone deposition and it

 8 entails 59 pages.

 9 (Plaintiffs' No. 2, Affidavit of Larry Klayman,

10 was marked for Identification.)

11 BY MR. KLAYMAN:

12 Q. You are aware, Mr. Stone, that I'm the founder

13 of Judicial Watch?

14 A. I am.

15 Q. You've spoken to Tom Fitton, haven't you?

16 A. One time in my entire life. I saw him

17 backstage at a conference in -- at Dural, maybe a couple

18 months ago, and we -- we shook hands in passing. Beyond

19 that, I've never spoken to the man.

20 Q. You've spoken to others at Judicial Watch,

21 though, haven't you?

22 A. No, actually, I haven't. Not that I recall.

23 Q. You -- you may have, but you just don't recall?

24 A. I don't recall ever speaking to anyone at -- at

25 Judicial Watch. I couldn't name anybody else at

Case 1:20-cv-00298-LY-DH Document 147 Filed 08/05/21 Page 107 of 107 Case 1:20-cv-00298-LY-AWA Document 73 Filed 09/30/20 Page 59 of 66