EXHIBIT A

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 1 of 319
In The Matter Of:

The Satanic Temple and Michelle Shortt v.

City of Scottsdale, Arizona, by it City Council

30(b)(6) of Adversarial Truth, LLC

September 26, 2019

By Michelle Shortt

Original File MS092619 30(b)(6) Adversarial Truth_LLC.txt

Min-U-Script® with Word Index

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 2 of 319
By Michelle Shortt

 UNITED STATES DISTRICT COURT

 DISTRICT OF ARIZONA

 The Satanic Temple and Michelle )

 Shortt, )

 )

 Plaintiffs, )

 )

 vs. ) No. CV18-00621-PHX-DGC

 )

 City of Scottsdale, Arizona, by )

 it City Council, consisting of )

 the Mayor and council members, )

 WJ Jim Layne, Suzanne Klapp, )

 Virginia Korte, Kathy )

 Littlefield, Guy Phillips, and )

 David Smith, )

 )

 Defendants. )

 )

 30(B)(6) DEPOSITION OF ADVERSARIAL TRUTH, LLC

 By: Michelle Shortt

 Phoenix, Arizona

 Thursday, September 26, 2019

 10:08 a.m.

 REPORTED BY:

 Kelly M. Olhausen, RPR

 Certified Reporter

 Certificate No. 50867

 PREPARED FOR:

 ASCII/COPY

 (Certified Copy)

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By Michelle Shortt

2

 1 I N D E X

 2 WITNESS PAGE

 3 MICHELLE SHORTT

 4 Examination by Mr. Claus 5

 5 Examination by Mr. de Haan 50

 6 Further examination by Mr. Claus 52

 7

 8

 9

 E X H I B I T S

10

 Deposition

11 Exhibits Description Marked

12 48 Color copy printout of Bloody Blog, 6

 dated 10/10/18

13 (7 pages)

14 49 Excerpt printout from The Satanic 35

 Temple website, dated 04/17/14

15 (1 page)

16 50 The Satanic Temple Affiliation 15

 Agreement, dated 08/10/16

17 (3 pages)

18 51 Color copy printout of Fundamental 35

 Tenets of The Satanic Temple

19 website, dated 03/26/13

 (1 page)

20

 52 Color copy printout of Tenets from 35

21 The Satanic Temple website, dated

 06/20/13

22 (1 page)

23 53 Color copy printout of Tenets from 35

 The Satanic Temple website, dated

24 07/22/13

 (1 page)

25

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By Michelle Shortt

3

 1

 E X H I B I T S

 2

 Deposition

 3 Exhibits Description Marked

 4 54 Color copy printout of Tenets from 35

 The Satanic Temple website, dated

 5 08/05/13

 (1 page)

 6

 55 Color copy printout of Tenets from 35

 7 The Satanic Temple website, dated

 09/04/13

 8 (1 page)

 9 56 Color copy printout of Tenets from 35

 The Satanic Temple website, dated

10 11/03/13

 (1 page)

11

 57 Color copy printout of Tenets from 35

12 The Satanic Temple website, dated

 12/12/13

13 (1 page)

14 58 Color copy printout of The Satanic 54

 Temple website news section, dated

15 04/21/15

 (3 pages)

16

17

18

19

20

21

22

23

24

25

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By Michelle Shortt

4

 1 30(B)(6) DEPOSITION OF ADVERSARIAL TRUTH,

 2 LLC, BY MICHELLE SHORT, was taken on Thursday,

 3 September 26, 2019, commencing at 10:08 a.m. at the law

 4 offices of Dickinson Wright, PLLC, 1850 North Central

 5 Avenue, Suite 1400, Phoenix, Arizona, before Kelly M.

 6 Olhausen, a Certified Reporter in the State of Arizona.

 7 COUNSEL APPEARING:

 8 DICKINSON WRIGHT, PLLC

 By: Mr. Scot L. Claus

 9 Mr. Vail C. Cloar

 Ms. Holly M. Zoe

10 1850 North Central Avenue

 Suite 1400

11 Phoenix, AZ 85004

 (Attorneys for Defendants)

12

13 DE HAAN LAW FIRM, PLLC

 By: Mr. Stuart P. de Haan

14 101 East Pennington

 Suite 201

15 Tucson, AZ 85701

 (Attorneys for Plaintiffs)

16

17

18

19

20

21

22

23

24

25

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By Michelle Shortt

5

 1 MICHELLE SHORTT,

 2 a witness herein, having been duly sworn by the Certified

 3 Court Reporter to speak the truth and nothing but the

 4 truth, testified as follows:

 5 EXAMINATION

 6 BY MR. CLAUS:

 7 Q. Ms. Shortt, good morning. My name is Scot Claus,

 8 Dickinson Wright law firm. I represent the City of

 9 Scottsdale.

10 I've handed you -- because we only have an

11 hour for each deponent, I'm going to go rather fast. And

12 I apologize for that. If I'm going too fast, please let

13 me know. And if I'm really going too fast, our court

14 reporter will let me know. But if you could turn to

15 Exhibit 8, please. All of the exhibits are tabbed, and

16 the tabs correspond with the Exhibit number.

17 Exhibit 8 is the notice of deposition -- the

18 first amended notice of deposition for Adversarial Truth,

19 LLC.

20 Do you see that?

21 A. Yes.

22 Q. The pages are numbered at the bottom of the

23 page --

24 A. Uh-huh.

25 Q. -- until you get to Exhibit A of Exhibit 8. So

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 1 if you could turn to page 3 of Exhibit 8, and now turn to

 2 the very next page. That is Exhibit A of Exhibit 8.

 3 And those were the topics for which you've

 4 been designated as the deponent with the knowledge of the

 5 topics identified in Exhibit A for Adversarial Truth, LLC;

 6 correct?

 7 A. Yes.

 8 Q. Do you agree that you are the person

 9 knowledgeable about the topics identified in Exhibit A to

10 Exhibit 8 to your deposition?

11 A. I am.

12 Q. And when was the first time you reviewed Exhibit

13 A to Exhibit 8?

14 A. Yesterday.

15 Q. Yesterday.

16 MR. CLAUS: There are some exhibits that

17 aren't in the book. This is 47. I have copies of this

18 one. We're not going to use one, but I'll just give it to

19 you before we go because I wasn't able to have Exhibit 47

20 electronically. I have it here.

21 So this is 48.

22 (Deposition Exhibit No. 48 marked for

23 identification.)

24 BY MR. CLAUS:

25 Q. I've handed you a document that is Exhibit 48 to

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 1 your deposition. Exhibit 48 appears to be a publication

 2 of an interview of you published on October 10 of 2018.

 3 Have you seen Exhibit 48 before?

 4 A. Yeah. I seem to remember this.

 5 Q. Were you interviewed for the Bloody Blog post?

 6 A. I was.

 7 Q. When you reviewed Exhibit 48 for the first time,

 8 did you notice anything false or misleading in it?

 9 A. I could not recall. But if -- do I have a moment

10 to read it again to see? I do not recall.

11 Q. Okay. So you don't recall seeing anything when

12 you reviewed it for the first time, any statements

13 attributed to you that you thought were false or

14 misleading at the time?

15 So I see you're reading the document now.

16 My question was --

17 A. Oh.

18 Q. -- you don't recall when you read it the first

19 time seeing anything that was attributed to you that was

20 false or misleading; is that correct?

21 A. No. No.

22 Q. That's not correct, or that is correct?

23 A. I don't remember anything that would have been

24 false or misleading.

25 Q. Okay. Is it accurate to say that you were the

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 1 chapter head of something called The Arizona Chapter of

 2 The Satanic Temple at the time you were interviewed for

 3 Exhibit 48?

 4 A. Yes.

 5 Q. And you were the chapter head of something called

 6 The Arizona Chapter of the Satanic Temple when Exhibit 48

 7 was published?

 8 A. Yes.

 9 Q. You are no longer the chapter head of the

10 Arizona --

11 A. Correct.

12 Q. -- Satanic Temple; correct?

13 A. (No audible response.)

14 Q. You have to answer audibly so the court

15 reporter --

16 A. Oh. Correct.

17 Q. Okay. Is it accurate to say that Adversarial

18 Truth, LLC, is the entity that was organized to operate

19 the Arizona chapter of The Satanic Temple?

20 A. That is correct.

21 Q. And do you know when Adversarial Truth, LLC, was

22 first organized?

23 A. We have a letter of incorporation from -- from

24 the formation, and it says the incorporated date was

25 January 24th, 2017. And -- but, however, we received the

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 1 Arizona Corporation Commission approval letter May 3rd,

 2 2017.

 3 Q. Okay. If you take a look at Exhibit 26, which is

 4 tab 26, Exhibit 26 is the articles of organization filed

 5 with the Arizona Corporation Commission for Adversarial

 6 Truth, LLC.

 7 Have you seen Exhibit 26 before?

 8 A. Yes.

 9 Q. And it reflects a filing date with the Arizona

10 Corporation Commission of April 14, 2017; is that correct?

11 A. Yeah.

12 Q. When you asked to give an invocation before a

13 City of Scottsdale council meeting on February 8th, 2016,

14 were you asking to give that invocation on behalf of the

15 members of Adversarial Truth, LLC?

16 A. Could you repeat the question, please?

17 Q. Sure.

18 When you asked to give an invocation before

19 the City of Scottsdale council meeting, were you asking to

20 give that invocation on behalf of the members of

21 Adversarial Truth, LLC?

22 A. I was requesting to give the invocation as a

23 spokesperson of The Satanic Temple. As the chapter head,

24 I had the authority to be able to have media presence,

25 speaking arrangements. So as -- I guess in regards to

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 1 members -- I mean, we do represent, you know, Arizona

 2 Satanists.

 3 So it's -- in that case, you know, not

 4 necessarily doing it for them. But, you know, they

 5 certainly feel represented when, you know, another

 6 Satanist within their community gets to speak and exercise

 7 their -- their rights in the public forum.

 8 Q. Is there any written document that vests a

 9 chapter head with the authority to act as a spokesperson

10 for The Satanic Temple?

11 A. A document? Yeah. I mean, I assume it would be

12 in this -- not that one -- in our packet when we first

13 sign on to The Satanic Temple. Let's see. It gives us

14 guidelines for behavior, online code of conduct. We did

15 have to sign a member agreement. But as to -- you know,

16 it's kind of, like, unsaid in a way. Like, you know,

17 there's three -- three different positions of leadership

18 within each chapter. You can have co-chapter heads.

19 Arizona did not have a co-chapter head. It was just me

20 acting as a single chapter head. And you can also have a

21 media liaison.

22 Both -- both the media liaison and myself

23 had authority to speak on behalf of the chapter in a

24 public setting. I can't say if there's an actual paper

25 that says that, but it's -- no one else other than the

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 1 chapter heads and the media liaison are allowed to speak

 2 to the media in any way.

 3 Q. You just testified that it was unspoken. In

 4 fact, it was spoken by The Satanic Temple in 2016 that

 5 membership in the organization does, quote, "not grant

 6 anyone the authority to act" --

 7 A. Oh, good.

 8 Q. -- "as a spokesperson for The Satanic Temple as

 9 an organization."

10 Were you aware of that?

11 A. Yeah. That's good. Okay. It's on the website,

12 then.

13 Q. Go to Exhibit 32, which is tab 32 --

14 A. Oh, good.

15 Q. -- under the heading "Membership." You've said

16 now "good," but I want to make sure you understand.

17 The Satanic Temple published information in

18 2016 which stood for the opposite proposition of what you

19 just testified to. I'm going to quote from the third

20 bullet point under "Membership."

21 "Membership does not grant anyone the

22 authority to act as a spokesperson for The Satanic Temple

23 as an organization."

24 A. But I wasn't just a member, though. I was --

25 Q. First, did I read that correctly?

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 1 A. You did.

 2 Q. Okay. Is there any document of which you are

 3 aware that confers authority on chapter heads of chapters

 4 to speak on behalf of The Satanic Temple?

 5 A. Would it be in this one (indicating)?

 6 Q. Answer the question, if you can, and then we can

 7 go off --

 8 A. I do not -- I don't think I do. No.

 9 Q. Okay.

10 A. That there isn't an actual document that says...

11 Q. You were just reading from a document.

12 A. I was reading from our affiliation agreement.

13 Q. And I noticed on the back of the agreement there

14 was a signature. Mr. de Haan has it right now.

15 A. Uh-huh. That was from 2018, and this one is from

16 2016.

17 Q. Okay. So when did you sign the affiliation

18 agreement? Is the affiliation agreement an agreement for

19 the Arizona chapter to become affiliated with The Satanic

20 Temple?

21 A. Yes. And we first signed it in 2016.

22 Q. On what day?

23 A. August 10th, 2016.

24 Q. So after you sought to give an invocation before

25 the City of Scottsdale --

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 1 A. Yes.

 2 Q. -- council meeting?

 3 A. Yes. At the time when we had requested to do the

 4 invocation for the City of Scottsdale, we had not formed

 5 our LLC or our corporation yet. We were just in the

 6 beginning of trying to establish our chapter.

 7 It was prior to the Scottsdale invocation

 8 that we received a lot of media attention for Phoenix. So

 9 due to that influx of interest, we had a lot of people

10 kind of coming to us, and a lot of changes were being

11 made. We didn't even have, like, a formalized structure

12 to, like, admit members or council members at the time.

13 We were working under the directive of the executive

14 ministry, which is Lucien Greaves and Malcolm Jarry, who

15 are the cofounders.

16 And -- yeah. Like, we -- we formed our

17 chapter around that same time, but we didn't actually

18 quite incorporate or do anything official until we signed

19 this.

20 Q. So you formed -- the Arizona chapter of The

21 Satanic Temple was formed when the affiliation agreement

22 you just referred to was executed in August of 2016; is

23 that right?

24 A. No, that's not right.

25 Q. So when was the Arizona chapter of The Satanic

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 1 Temple formed?

 2 A. In February.

 3 Q. Well, the Arizona chapter of The Satanic Temple

 4 had no members, you just testified to.

 5 Is there a document that demonstrates that

 6 the Arizona chapter of The Satanic Temple was formed in

 7 February of 2016?

 8 A. No.

 9 Q. So the only document that reflects an agreement

10 between The Satanic Temple and the Arizona chapter -- the

11 affiliation of the Arizona chapter of The Satanic Temple

12 was not executed until August of 2016; is that correct?

13 A. I do remember --

14 Q. Ma'am, just answer my question. I only have an

15 hour with you. So -- and I'm sorry to interrupt, but I do

16 want you to answer my questions.

17 So is it accurate to say that there was no

18 document that recognized the creation and affiliation of

19 the Arizona chapter of The Satanic Temple with The Satanic

20 Temple in existence until August 10, 2016?

21 A. No, that is not accurate. But I -- because I do

22 recall having to sign something earlier at a pizza place.

23 It was actually the Red -- the Red -- yeah. I do remember

24 signing something earlier than this day.

25 Q. And what day was that?

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 1 A. I don't remember. But it was earlier in that

 2 year because this -- August is a little late. Like -- and

 3 I remember having to sign our chapter paperwork that

 4 designated us as the official chapter of Arizona sometime

 5 earlier in the summer.

 6 MR. CLAUS: Since we're referring to that,

 7 can I take a break and make a copy of it so we can put it

 8 in the record?

 9 MR. DE HAAN: Sure.

10 MR. CLAUS: Just that document right there.

11 Why don't we go off the record. We'll be

12 right back.

13 (A short recess was taken from 10:22 a.m. to

14 10:25 a.m.)

15 (Deposition Exhibit No. 50 marked for

16 identification.)

17 BY MR. CLAUS:

18 Q. Ms. Shortt, I've just handed you the document

19 that we referred to previously -- the affiliation

20 agreement dated August 10, 2016, which is now marked as

21 Exhibit 50 to your deposition.

22 A. Uh-huh.

23 Q. Are you aware of any agreements between the

24 United Federation of Churches, LLC, d/b/a The Satanic

25 Temple and the affiliate The Satanic Temple Arizona that

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 1 predate Exhibit 50?

 2 A. Well, as a subchapter of The Satanic Temple --

 3 which there is a photo that has a date on it where we were

 4 signing on it. I was at a pizza parlor, and it was many

 5 months before that document, where we had signed as -- to

 6 become a chapter under the banner of The Satanic Temple.

 7 The Satanic Temple -- they are registered

 8 under the United Federation of Churches. And this

 9 document clearly stated that, you know, they were

10 registered under that. And as a chapter, we were also

11 kind of going to be umbrellaed under that -- under the

12 banner of The Satanic Temple.

13 Q. So let me ask you this: Are you -- have you

14 brought with you today -- or have you read an agreement

15 between the United Federation of Churches, LLC, and the

16 affiliate that is executed at a date earlier than

17 August 10, 2016?

18 A. I'm not sure if I understand the question.

19 Q. Okay.

20 A. I kind of want to say "no." I'm not aware.

21 MR. DE HAAN: You --

22 BY MR. CLAUS:

23 Q. Okay. So the question is --

24 MR. DE HAAN: There's an earlier.

25

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 1 THE WITNESS: Well, there is an earlier one.

 2 MR. CLAUS: No, no, no. We can't -- that's

 3 completely inappropriate, Stu. Your deposition isn't

 4 being taken. You have just inserted -- you've just

 5 coached the witness, and you've just acted as a percipient

 6 witness while you're acting as counsel. And that is

 7 inappropriate.

 8 BY MR. CLAUS:

 9 Q. You've just said that you didn't understand my

10 question and that you think you want to say "no."

11 So my question is is there an affiliation

12 agreement between the United Federation of Churches, LLC,

13 and an entity that is signed by you and/or Mr. de Haan

14 that was signed on a date earlier than August 10, 2016?

15 A. Yes. There is the earlier copy that I keep

16 mentioning.

17 Q. And an earlier copy that is called an

18 "affiliation agreement"?

19 A. Not necessarily. I think it was called the --

20 this (indicating). It was -- oh. Maybe it's not that.

21 It was a member agreement -- okay. I might be wrong. I

22 don't know. I don't want to say -- I don't know.

23 There -- I know that there is a backdated packet, but that

24 was all that --

25 Q. "A backdated packet" -- what does that mean?

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 1 A. The photo that I keep saying. It was basically

 2 this (indicating). It was the code of conduct, the member

 3 agreement -- everything that we are entrusted to do as

 4 chapter heads. And we first received that, like, at the

 5 beginning of 2016 when we first were becoming a chapter.

 6 Q. Well -- so maybe you're referring to an agreement

 7 that you signed when you became a member of The Satanic

 8 Temple? Could that be it?

 9 A. We became a chapter head of The Satanic Temple.

10 Q. Okay. Is there any document that exists with a

11 date earlier than 08/10/2016 reflecting that there is an

12 Arizona chapter of The Satanic Temple?

13 A. I think so. Yes. I don't have it.

14 Q. You don't have it.

15 A. I don't have it.

16 Q. Has it been disclosed in this litigation?

17 A. No.

18 Q. And you don't know when it's dated.

19 A. No. It's -- if I had the photo, which I wish I

20 really would have printed out the photo. No, I don't. It

21 was earlier dated, though.

22 Q. Take a look at Exhibit 40, which is tab 40.

23 You're familiar with the website maintained by the United

24 Federation of Churches, LLC, www.thesatanictemple.com?

25 A. Yes.

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 1 Q. This is an Internet archive of that website from

 2 February 1, 2016.

 3 Do you see at the top of the page, centered,

 4 "February 1, 2016"?

 5 A. March 2017?

 6 Q. No. The one in the black box right next to

 7 March.

 8 A. Oh, yes. February 1st.

 9 Q. February 1, 2016. And this is a section of the

10 website that lists chapters of The Satanic Temple. And

11 there is no Arizona chapter as of February 1, 2016.

12 Do you see that?

13 A. I do.

14 Q. Okay.

15 A. The website doesn't necessarily update as quickly

16 as we would like it to.

17 Q. Did you ever tell any representative of the City

18 of Scottsdale that you were seeking to give an invocation

19 on behalf of an entity called Adversarial Truth, LLC?

20 A. Did I ever tell a representative of Scottsdale?

21 Q. Correct.

22 A. Other than the e-mail that we submitted for the

23 request, no.

24 Q. Does the e-mail that you submitted for the

25 request contain the phrase "Adversarial Truth, LLC"?

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 1 A. It does not. We -- we went only as a satanic

 2 temple Arizona.

 3 Q. So that was my question.

 4 Did you ever tell the City of Scottsdale

 5 that you sought to give an invocation on behalf of an

 6 entity called Adversarial Truth, LLC?

 7 A. No.

 8 Q. How many members of Adversarial Truth, LLC, are

 9 there today?

10 A. Well, are we talking about just the corporation?

11 Because the corporation is only run by one member -- that

12 is me -- and a statutory agent, which is Stu de Haan.

13 Are you speaking in regards to the chapter?

14 How many members our chapter has?

15 Q. I asked you how many members of Adversarial

16 Truth, LLC, there are, and you answered the question. So

17 thank you.

18 A. Okay.

19 Q. Has an amendment -- if you'd turn back to

20 Exhibit 26.

21 Has an amendment to Exhibit 26 ever been

22 filed with the Arizona Corporation Commission?

23 A. No. We're actually in the process -- or,

24 actually, yes. I'm in the process of trying to change the

25 statutory agent from Stu de Haan to myself. And that was,

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 1 like, around the time of my resignation.

 2 However, the chapter now has a new chapter

 3 head. So our request to amend the corporation for the

 4 statutory agent, it was denied. It was probably due to a

 5 typo, they said.

 6 So as of now, that was the only amendment we

 7 tried to do to change the statutory agent. But other than

 8 that, there's been no amendments. I think I changed the

 9 address once or twice. So...

10 Q. Were you a member of The Satanic Temple as of

11 February 8th, 2016?

12 A. Yes.

13 Q. Had you -- how long had you been a member?

14 A. A little over a year.

15 Q. Did you -- did you first hear of The Satanic

16 Temple through the website or through some other means?

17 A. I first heard of The Satanic Temple through Brian

18 Warner. He was a prominent Satanist in the community at

19 the time. He was almost acting like a spokesperson with

20 Lucien Greaves. He was also the singer of a band called

21 Vital Remains. And they were touring, and I met him at a

22 show, and that's when he told me about The Satanic Temple.

23 And that's where my interest first began.

24 Q. On -- I want to focus on the date of

25 February 8th, 2016.

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 1 On that date, were you seeking to give an

 2 invocation before a City of Scottsdale council meeting on

 3 behalf of a religion?

 4 A. Yes.

 5 Q. What religion?

 6 A. Satanism.

 7 Q. Were you ordained to act as a minister for The

 8 Satanic Temple as of February 8th, 2016?

 9 A. No. We do not have an official ordainment

10 program. We are currently in the works of that. But I

11 was given the authority to speak on behalf of The Satanic

12 Temple in regards to the invocation in Arizona.

13 Q. Did The Satanic Temple have an ordination program

14 as of February 8th, 2016?

15 A. No.

16 Q. And you just testified that it does not today;

17 correct?

18 A. No. It's still in the works.

19 Q. Do you know how many members of The Satanic

20 Temple resided in Arizona as of February 8th, 2016?

21 A. No. We don't keep track of, you know, how many

22 members nationally we have. We kind of base our numbers

23 on our Facebook page.

24 In regards to Arizona at the time of

25 February 8th, 2016, I would say we had about, you know,

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 1 ten members in Tucson and about seven members scattered

 2 throughout the Phoenix metro area.

 3 Q. So I want you to remember you took an oath to

 4 testify under penalty of perjury based on your knowledge.

 5 So I'm not asking you to guess about anything. I want you

 6 to only testify about what you know.

 7 A. Okay.

 8 Q. How many members of The Satanic Temple that

 9 resided in Arizona did you personally know as of

10 February 8th, 2016?

11 A. Members of The Satanic -- okay.

12 Q. Do you want me to ask it again?

13 A. Well -- I mean, it's just -- there's different

14 degrees of membership. That's -- that's why.

15 Q. Okay. So I'm going to ask it again.

16 So focusing on February 8th, 2016, how many

17 members of The Satanic Temple did you personally know that

18 you also knew resided in the state of Arizona?

19 A. My number is still the same. I don't know why

20 that would be considered misleading. Like, the people

21 that we knew at the time -- you know, the ten people in

22 Tucson, they all came to us, and they were our friends and

23 then initially formed our council. Then, because of the

24 Phoenix media presence, we made friends with people in the

25 Phoenix metro area, which were about seven.

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 1 Q. Okay. So 7 -- you personally knew 17 people as

 2 of February 8th, 2016, who resided in Arizona?

 3 A. Yeah.

 4 Q. And do you know the identity of any of those 17

 5 people?

 6 A. I know them all. They were our friends. They

 7 were our --

 8 Q. Okay. Well, you've been asked in Topic 5 to be

 9 the person knowledgeable to testify about the identity and

10 domicile of the members of The Satanic Temple as of

11 February 8th, 2016. So that's why I'm asking you.

12 A. Okay.

13 Q. Can you give me the names of any of the members

14 of The Satanic Temple that you personally knew who resided

15 in the state of Arizona as of February 8th, 2016?

16 A. Yes. Would you like these names?

17 Q. Yes.

18 MR. DE HAAN: I'm going to object as to the

19 relevance of the names and domiciles of each member.

20 MR. CLAUS: Well, you can object to form.

21 That's what the rules allow you to do.

22 BY MR. CLAUS:

23 Q. So go ahead and give me those names.

24 A. We had Robert Armola, Jack Matirko.

25 Q. Okay.

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 1 A. Michael Fisher. We had Kat Stratford, Morgan

 2 Treiber.

 3 Q. Okay.

 4 A. Do you want all 17 that I can recall?

 5 Q. Sure.

 6 MR. DE HAAN: I just have a running

 7 objection to form for this question.

 8 THE WITNESS: Okay. Let's see. Cody --

 9 what's Cody's last name? James, Jeremy Zarzycki. That

10 one chick, Nicki, she's gone. I'm sorry. I'm trying to

11 remember everybody that was on our initial council.

12 Stu, me. Who else was in our -- I thought I

13 had a photo of that one time. Robert, Michael, Jack.

14 BY MR. CLAUS:

15 Q. So far you have Robert, Jack, Michael, Kat,

16 Morgan, Cody, James, Jeremy, Nicki, Stu, you.

17 A. I know there's more.

18 Q. Okay. Do you know how many members of The

19 Satanic Temple that you knew personally resided in the

20 city of Scottsdale as of February 8th, 2016?

21 A. Yes. Robert.

22 Q. Robert --

23 A. -- Armola.

24 Q. -- Armola. A-R-M-O-L-A?

25 A. Yes. And he had volunteered to give the

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26

 1 invocation, but because -- you know, after we did our

 2 research and found that there was no resident -- policy

 3 against residency and because I was the spokesperson for

 4 the chapter, we just continued with me being the one to

 5 give the invocation. But, however, Robert did live in

 6 Scottsdale, and he had volunteered if need be.

 7 Q. I'll just use their first names. You've given me

 8 11 names, including you and Mr. de Haan. I'll just use

 9 their first names and ask you just to tell me a "yes" or

10 "no."

11 Do you know when Robert became a member of

12 The Satanic Temple?

13 A. Around -- probably the beginning of that year for

14 the Phoenix invocation.

15 Q. That's not what I'm asking you. I'm asking you

16 can you testify under penalty of perjury --

17 A. Oh, no. I don't know exactly when. No.

18 Q. Okay. So all of my questions are asking you to

19 testify on personal knowledge under penalty of perjury.

20 So do you know when Robert became a member

21 of The Satanic Temple?

22 A. No.

23 Q. Do you know when Jack became a member of The

24 Satanic Temple?

25 A. No.

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 1 Q. Do you know when Michael became a member of The

 2 Satanic Temple?

 3 A. No. I do not know when anyone became...

 4 Q. Do you know when Kat became a member of The

 5 Satanic Temple?

 6 A. No.

 7 Q. Do you know when Morgan became a member of The

 8 Satanic Temple?

 9 A. No.

10 Q. Do you know when Cody became a member of The

11 Satanic Temple?

12 A. No.

13 Q. Do you know when James became a member of The

14 Satanic Temple?

15 A. No.

16 Q. Do you know when Jeremy became a member of The

17 Satanic Temple?

18 A. No.

19 Q. Do you know when Nicki became a member of The

20 Satanic Temple?

21 A. No.

22 Q. Do you know when Stu became a member of The

23 Satanic Temple?

24 A. No.

25 Q. Do you -- I asked you this -- if you could recall

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 1 the date. You said you couldn't.

 2 Do you recall the year in which you became a

 3 member of The Satanic Temple?

 4 A. 2015.

 5 Q. Can you testify under penalty of perjury with

 6 knowledge that any of the members that I named did not

 7 become members of The Satanic Temple in 2013?

 8 A. '13?

 9 Q. Yes.

10 A. Can you repeat the question?

11 Q. Sure.

12 MR. CLAUS: Can you read it?

13 THE COURT REPORTER: Sure.

14 (The requested portion of the record was

15 read back by the court reporter.)

16 THE WITNESS: Did any of these people did

17 not become members -- did any of these people not become

18 members of The Satanic Temple? I don't know when they

19 became members.

20 BY MR. CLAUS:

21 Q. Okay. And the -- I named 11 people. The six

22 members that I didn't name, because you didn't give me the

23 names, you're similarly unaware as to when they became

24 members of The Satanic Temple?

25 A. Correct. I mean, it's kind of a personal thing,

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 1 your religion and how you identify.

 2 Q. Can you look -- here. I'll just give you my

 3 copy, if we need to refer to the first amended complaint.

 4 It's not an exhibit to the deposition. But if we need to

 5 refer to it, it's fine.

 6 A. What am I looking at?

 7 Q. You're not looking at anything right now. I just

 8 wanted to give it to you in case we need to look at

 9 something in that. Thank you.

10 Is it accurate to say that you did not feel

11 comfortable calling Satanism a religion until 2018?

12 A. No. That's not true. I did an interview where I

13 recalled saying that I found it very interesting to find

14 myself to be a part of a religion because I did not used

15 to identify with anything religion. Like, it was kind of

16 like a bad word to me until The Satanic Temple came along

17 and changed my world view on what a religion could be,

18 what it could mean to people, and how it can also be for

19 people who don't believe in God.

20 Q. If you look at Exhibit 48, the pages aren't

21 numbered. But you see each of the questions are numbered.

22 So No. 1 has an answer and No. 2 has an

23 answer and No. 3 has an answer. I've going to have you go

24 to -- it's actually -- if you could just count in, it's

25 the fifth page under No. 4, the question "Have you always

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 1 been an atheist [sic]?"

 2 A. Uh-huh.

 3 Q. Do you see that?

 4 A. "Have you always been a Satanist?"

 5 Q. Sorry. Strike that. Yes. Correct. "Have you

 6 always been a Satanist?"

 7 Do you recall telling the interviewer that,

 8 "Until recently, I was not comfortable calling Satanism a

 9 religion due to the trauma I had endured due to the

10 Catholic church"?

11 A. Yes.

12 Q. Do you -- as former chapter head and as the

13 designee for United Federation of Churches, LLC, do you

14 agree that there's a difference between a religion and a

15 political zeal?

16 MR. DE HAAN: Objection. Form.

17 BY MR. CLAUS:

18 Q. You can answer.

19 A. Do I agree that there's a difference between

20 religion and political zeal? No. Not entirely.

21 Q. Do you believe as the designee that there's a

22 difference between religion and a sociopolitical counter

23 method?

24 A. Do I believe there's a difference between --

25 Q. -- religion and a sociopolitical counter method.

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 1 A. Yes.

 2 Q. Have you ever heard Satanism referred to as a

 3 sociopolitical counter method?

 4 A. I've heard people calling it that, yes. Not that

 5 I agree with it.

 6 Q. You are -- as the -- as being no longer the

 7 chapter head for the Arizona chapter of The Satanic

 8 Temple, do you have any leadership role at all in The

 9 Satanic Temple?

10 A. Yes. I am still considered a spokesperson.

11 Q. By whom?

12 A. By executive ministry by a national council.

13 Q. According to what?

14 A. According to my upcoming position in one of

15 their, like, online -- we're starting an online platform,

16 and they're going to give me a show to speak to the masses

17 in regards to topics of taboo and sexuality.

18 Q. Do you know Kevin Soleng?

19 A. Yes.

20 Q. Have you ever spoken with Kevin Soleng?

21 A. Yes.

22 Q. Have you ever had any written communication with

23 Kevin Soleng?

24 A. Kevin Soleng is Malcolm Jarry?

25 Q. You have to just testify based upon your

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 1 knowledge.

 2 A. I've spoken to Kevin Soleng as Malcolm Jarry in

 3 e-mails in correspondence with Satanic Temple matters.

 4 Q. Is it accurate to say that one does not need to

 5 be a practicing Satanist to become a member of the Arizona

 6 chapter of The Satanic Temple?

 7 A. Currently or back then?

 8 Q. Currently.

 9 A. Currently, the chapter is making changes to where

10 they're trying to focus more on the satanic aspect of our

11 religion as opposed to the activism aspect, especially

12 after the Hail Satan movie. We're attracting a lot of

13 people who are ignorant to our religion, and we are not

14 trying to make this an activist group. We are, first and

15 foremost, a religion.

16 Q. Between February 8, 2016, and July 6, 2016, it is

17 true, is it not, that one did not need to be a practicing

18 Satanist --

19 A. That is true.

20 Q. -- to be -- you've got to let me finish the

21 question.

22 A. Oh. Sorry.

23 Q. It's true that, between February 8th, 2016, and

24 July 6th, 2016, one did not need to be a practicing

25 Satanist to become a member of the Arizona chapter of The

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 1 Satanic Temple; correct?

 2 A. That is true.

 3 Q. Can you testify with knowledge under penalty of

 4 perjury regarding whether any of the persons whom you

 5 named were practicing Satanists as of February 8th, 2016?

 6 A. Yes.

 7 Q. And how do you know that?

 8 A. Because they tell us. They live the life. Like,

 9 usually when we have allies that are members, they are

10 very vocal about how they align. You know, "I may not be

11 a Satanist, but I'm a sure ally." Like, they're very

12 vocal. And Satanists are also very vocal when they

13 practice, you know. We have rituals. We have, you know,

14 practices as Satanists. So it's kind of obvious who is

15 and who isn't.

16 Q. Is the religious aspect of The Satanic Temple

17 more than the firmly held religious beliefs of its

18 members?

19 A. The religious aspect?

20 Q. Yes. The religious aspect of The Satanic Temple

21 more than the firmly held beliefs of its members.

22 A. Yes.

23 Q. I'm going to ask you about some of those beliefs.

24 Is one of those firmly held beliefs that a

25 supernatural God created an actual Satan to preside over

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 1 the universe as his proxy?

 2 A. No. We don't believe that.

 3 Q. Is a firmly held belief of The Satanic Temple

 4 that "Satan hears our prayers and responds"?

 5 A. No. We don't believe that.

 6 Q. Is a firmly held religious belief of The Satanic

 7 Temple that "Satan can exist in a corporeal realm"?

 8 A. No. We don't believe that.

 9 Q. Can you please turn to Exhibit 27? It's an

10 Internet archive of the www.thesatanictemple.com with a

11 banner heading "Religious beliefs of The Satanic Temple."

12 Do you see that?

13 A. Yes.

14 Q. Have you seen Exhibit 27 before?

15 A. Yes.

16 Q. When?

17 A. It goes around in our conspiracy -- in the

18 conspiracy chats online. They try to use this against us,

19 especially the Church of Satan, saying that, you know, we

20 don't know what Satanism is because "Look at this website

21 where they say they believed in atheistic Satanism."

22 And we've already explained a way why this

23 was and why it's no longer part of our website, why we

24 completely did away with it.

25 Q. But the religious beliefs of The Satanic Temple

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 1 espoused in Exhibit 27 were available to the public as an

 2 articulation of the religious beliefs of The Satanic

 3 Temple in 2013; correct?

 4 A. Well, if you were to look -- I don't know if

 5 you've seen the movie Hail Satan. But it explains how --

 6 Q. I just want you -- because I'm so limited on

 7 time, ma'am, I would otherwise love to have this

 8 conversation. But I just want to know if it's "yes" or

 9 "no" that the religious beliefs of The Satanic Temple

10 articulated in Exhibit 27 were available and espoused to

11 the public in 2013.

12 A. They were. But they are not our beliefs now.

13 Q. I'm going to go through these real quickly.

14 A. May I add that this website was also a

15 placeholder at the time.

16 Q. I've heard that story.

17 A. That's not a story.

18 MR. CLAUS: Let's go off the record real

19 quick while we mark these.

20 (A short recess was taken from 10:50 a.m. to

21 10:54 a.m.)

22 (Deposition Exhibit Nos. 49, 51 through 57

23 marked for identification.)

24 BY MR. CLAUS:

25 Q. Ma'am, you're still under oath. I've handed you

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 1 Exhibit 49. You said -- I told you before we broke that I

 2 had heard that story, and you commented that it's not a

 3 story. And you're right that it is not a story. It was

 4 actually under oath testimony given under penalty of

 5 perjury regarding the fact -- regarding the assertion that

 6 it was merely a placeholder.

 7 I'm showing you Exhibit 49, which is an

 8 Internet archive page from the www.thesatanictemple.com

 9 from April of 2014, one year and four months after the

10 religious views espoused and Exhibit 27 were articulated.

11 And, again, I'm going to read from, now, Exhibit 49.

12 "God is supernatural and thus outside of the

13 sphere of the physical. God's perfection means that He

14 cannot interact with the imperfect corporeal realm.

15 Because God cannot intervene in the material world, He

16 created Satan to preside over the universe as His proxy.

17 Satan has the compassion and wisdom of an angel. Although

18 Satan is subordinate to God, he is mankind's only conduit

19 to the dominion beyond the physical. In addition, only

20 Satan can hear our prayers, and only Satan can respond.

21 While God is beyond human comprehension, Satan desires to

22 be known and knowable. Only in this way can there be

23 justice and can life have meaning."

24 First, did I read that correctly?

25 A. Yes.

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 1 Q. Second, would you agree that, as of April 17th,

 2 2014, Doug Misicko, otherwise known as Lucien Greaves, was

 3 intimately involved with The Satanic Temple?

 4 A. Yes.

 5 Q. And as of April 17, 2014, the notion that "God is

 6 supernatural, that Satan presides over this universe as

 7 God's proxy, that Satan has the compassion and wisdom of

 8 an angel, that Satan hears our prayers and can respond,

 9 and that Satan desires to be known and knowable" -- those

10 were all articulated as of April 17, 2014; correct?

11 A. Yes.

12 Q. When you asked to give an invocation to the City

13 of Scottsdale, were you asking to give an invocation on

14 behalf of a religion that believed the views articulated

15 in Exhibits 27 and 49?

16 A. No.

17 Q. Can you tell me how many members of The Satanic

18 Temple who resided in Arizona as of February 8th, 2016,

19 joined The Satanic Temple based upon the religious beliefs

20 espoused on April 17, 2014, in Exhibit 49?

21 A. None.

22 Q. And you can testify under penalty of perjury of

23 that.

24 A. Yes. I'm pretty confident because at the time --

25 Q. I'm not asking you pretty confident. I'm asking

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 1 you can you testify with actual knowledge under penalty of

 2 perjury that none of the members of The Satanic Temple who

 3 resided in Arizona as of February 8th, 2016, joined The

 4 Satanic Temple based upon the religious beliefs espoused

 5 on April 17, 2014?

 6 A. Yes. I'm confident that they did not join

 7 because of this.

 8 Q. Though you don't know when they joined.

 9 A. Correct.

10 Q. And you don't know that they didn't join between

11 January 15, 2013, and April 17, 2014; correct?

12 A. Sorry?

13 Q. You don't know, such that you can testify under

14 penalty of perjury, that any members of The Satanic Temple

15 who resided in Arizona as of February 8, 2016, did not

16 join The Satanic Temple between January 2013 and

17 April 2017; correct?

18 A. I don't know.

19 Q. If a member of The Satanic Temple who resided in

20 Arizona as of February 8th, 2016, believed that "God was

21 supernatural, that Satan was created by God, that Satan is

22 God's proxy in this universe, that Satan can hear our

23 prayers and respond, and that Satan desires to be known

24 and knowable," then that member had a different religious

25 belief than you; is that correct?

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 1 A. Yes.

 2 Q. Are the religious beliefs of The Satanic Temple

 3 also moored in their beliefs in the tenets of The Satanic

 4 Temple?

 5 A. Yes.

 6 Q. The nine tenets or the seven tenets?

 7 A. The seven.

 8 Q. Not the nine?

 9 A. Not the nine.

10 Q. Take a look at Exhibit 28.

11 A. Wait. Did I answer the question right? Can

12 you -- sorry.

13 Q. You answer the questioned under oath. So I don't

14 know if you answered it correctly. I hope you did.

15 Exhibit 28 is an Internet archive of The

16 Satanic Temple. Page 2 has the religious beliefs of The

17 Satanic Temple. Page -- it's not paginated. But if you

18 count 1, 2, 3, 4, 5, 6 in -- one more. Just go one more.

19 One more. Sorry. I think you went too far. You're

20 looking for the page that says "Fundamental Tenets of The

21 Satanic Temple." Are you there?

22 A. Uh-huh. Yes.

23 Q. This is an Internet archive dated January 16,

24 2013, "Fundamental Tenets of The Satanic Temple." The

25 text says "There are nine fundamental tenets, with nine

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 1 being a significant satanic number. Each tenet is

 2 represented by one of the choir of nine angels sent from

 3 heaven to oversee earth."

 4 Just read those nine tenets to yourself, and

 5 let me know when you're done.

 6 A. Okay. I'm done.

 7 Q. You're familiar with the seven tenets of The

 8 Satanic Temple currently articulated?

 9 A. Yes.

10 Q. Are you able to see that, other than No. 9,

11 "Every tenet is a guiding principle" --

12 A. Uh-huh.

13 Q. And then there's a typo. But "Every tenet is a

14 guiding principle to designed to inspire nobility in

15 action and thought."

16 But other than tenet 9 expressed in

17 Exhibit 28, none of the seven tenets are the same as the

18 one through eight tenets articulated in Exhibit 28?

19 A. They're not exactly the same. But the premise of

20 each tenet is the same. It looks like some of them have

21 been combined.

22 Q. So if Mr. Misicko testified that, other than the

23 last tenet, none of the tenets are the same, you would

24 disagree with him, Mr. Misicko, who does business as

25 Lucien Greaves?

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 1 A. I mean -- can you repeat the question?

 2 Q. Sure. If Mr. Misicko testified under penalty of

 3 perjury that the seven tenets currently espoused by The

 4 Satanic Temple are different from the nine tenets

 5 contained in Exhibit 28, other than tenet nine, you would

 6 disagree with that?

 7 A. Yeah. I mean, I don't think -- why he would say

 8 that they're different when they're basically the same,

 9 except some of them have been combined and the words --

10 the wordage has been cleared up and the typos have been

11 removed.

12 Q. So, for instance, No. 5, "All life is precious in

13 the eyes of Satan" -- you think that that is a tenet that

14 is currently espoused by The Satanic Temple?

15 A. I think that it kind of -- the first one, "People

16 should be guided by compassion" --

17 Q. No, ma'am. You have to listen to my question and

18 answer my question.

19 Tenet 5 expressed in Exhibit 28 of The

20 Satanic Temple as of January 16, 2013 -- quote, "All life

21 is precious in the eyes of Satan," end quote -- is that

22 still a tenet of The Satanic Temple?

23 A. No.

24 Q. Okay.

25 A. It was removed.

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 1 Q. So we're going to go through these quickly.

 2 Was Exhibit 28, this January 16, nine

 3 tenets -- the nine fundamental tenets of The Satanic

 4 Temple, was that a placeholder too, according to you?

 5 A. Yes. According to me, everything pre- --

 6 Q. Okay.

 7 A. Anything on this website was a placeholder, and

 8 then a new website was created.

 9 Q. Except the website is www.thesatanictemple.com;

10 correct?

11 A. Yes.

12 Q. Okay. Handing you Exhibit 51, those same nine

13 tenets of The Satanic Temple were espoused as the tenets

14 of The Satanic Temple to members of the public as of

15 March 26, 2013.

16 Do you see that at the top?

17 A. Uh-huh.

18 Q. Is that "yes"?

19 A. Yes.

20 Q. Exhibit 52 -- those same tenets of The Satanic

21 Temple, those nine fundamental tenets were expressed to

22 members of the public as beliefs of The Satanic Temple as

23 of June 20, 2013; correct?

24 A. Yes.

25 Q. Exhibit 53 -- those same nine tenets of The

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 1 Satanic Temple were espoused and articulated to members of

 2 the public as the religious beliefs of The Satanic Temple

 3 as of July 22, 2013; correct?

 4 A. Yes.

 5 Q. 54 -- those nine tenets were espoused as the

 6 religious beliefs of The Satanic Temple as of August 5,

 7 2013; correct?

 8 A. Yes.

 9 Q. 55 -- those nine tenets were expressed as the

10 religious beliefs of The Satanic Temple as of September 4,

11 2013; correct?

12 A. Yes.

13 Q. 56 -- those nine tenets were expressed as the

14 religious beliefs of The Satanic Temple as of November 3,

15 2013; correct?

16 A. Correct.

17 Q. 57 -- those nine tenets were espoused as the

18 religious beliefs of The Satanic Temple as of December 12,

19 2013; correct?

20 A. Correct.

21 Q. Can you testify under penalty of perjury that any

22 of the members on whose behalf you sought to give an

23 invocation on February 8, 2016, did not become members of

24 The Satanic Temple prior to December 12, 2013?

25 A. Did any of the members of The Satanic Temple of

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 1 Arizona --

 2 MR. CLAUS: I'll have the court reporter

 3 read it back. Just listen carefully.

 4 (The requested portion of the record was

 5 read back by the court reporter.)

 6 THE WITNESS: I cannot.

 7 BY MR. CLAUS:

 8 Q. But if a member of The Satanic Temple believed,

 9 for instance, that "All life is precious in the eyes of

10 Satan," then they held a different religious belief than

11 you; correct?

12 A. Yes.

13 Q. And they held a different religious belief than

14 you as of February 8, 2016; correct?

15 A. Yes.

16 Q. And they held a different religious belief than

17 you as of July 6, 2016; correct?

18 A. Yes.

19 Q. And they held a different religious belief than

20 you as of February 24, 2018, when this lawsuit was filed;

21 correct?

22 A. Yes.

23 Q. Because the religious belief on which -- for

24 which you sought to give an invocation is not a theistic

25 religion; correct?

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 1 A. That is correct.

 2 Q. It does not believe in a deity; correct?

 3 A. Correct.

 4 Q. It does not have an official literary source for

 5 doctrine; correct?

 6 A. Correct.

 7 Q. It does not have an ordination program for

 8 pastors or ministers; correct?

 9 A. Correct.

10 MR. CLAUS: Why don't we take a break. I

11 think I'm done with this one.

12 Are you going to want to ask questions too?

13 MR. DE HAAN: Not on this one. No. Well --

14 MR. CLAUS: Well, you don't have to decide

15 now.

16 MR. DE HAAN: Yeah. Give me a couple

17 minutes.

18 (A short recess was taken from 11:09 a.m. to

19 11:16 a.m.)

20 BY MR. CLAUS:

21 Q. Ms. Shortt, you're still under oath. You

22 testified close to the beginning of the deposition

23 regarding the record keeping of members, and I think you

24 were referring to the national level lack of record

25 keeping. And I want to know, does the Arizona chapter --

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 1 and I'll ask you about what occurs now, if you know, and

 2 what occurred in 2016.

 3 So, now, does the -- does Adversarial Truth,

 4 LLC, maintain records of members of the Arizona chapter of

 5 The Satanic Temple?

 6 A. Yes. We have 55 official members.

 7 Q. As of February 8, 2016, did -- as of February 8,

 8 2016, Adversarial Truth, LLC, didn't exist; correct?

 9 A. Correct.

10 Q. So as of February 8, 2016, did anyone maintain

11 records or a database of the number of members of The

12 Satanic Temple Arizona chapter?

13 A. Any -- I had a list of names of people who were

14 participatory, if that's considered a record. It was just

15 mostly a handful of us working at the time.

16 Q. When is the first time that the Arizona chapter

17 of The Satanic Temple accepted members?

18 A. When we had our first meeting in January of 2016.

19 Q. How many members joined then?

20 A. I think there was, like, six or seven people in

21 that meeting that joined.

22 Q. Where was that?

23 A. I wasn't in attendance.

24 Q. Oh. So you don't know where the meeting was?

25 A. It was at a local bar in Tucson.

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 1 Q. And it's true, is it not, that membership in The

 2 Satanic Temple does not necessarily confer upon someone's

 3 membership in The Satanic Temple Arizona chapter? True?

 4 A. If they're members of the Arizona chapter, they

 5 should be members of The Satanic Temple.

 6 Q. That wasn't my question.

 7 If someone lives in Arizona but is a member

 8 of The Satanic -- if someone lives in Arizona and is a

 9 member of The Satanic Temple, that does not necessarily

10 confer upon them membership in the Arizona chapter of The

11 Satanic Temple.

12 A. Correct.

13 Q. Okay. And was that correct as of February 8,

14 2016?

15 A. That that was still the case. Yes.

16 Q. And was that still the case as of July 8, 2016?

17 A. Yes.

18 Q. So does it -- to be a member of the Arizona

19 chapter of The Satanic Temple, one needs to complete an

20 application?

21 A. That is correct. They need to complete an

22 initial vetting process prior to receiving an application.

23 Once they've met a few of our community members, we then

24 extend the application for them to fill out. After

25 review, if they get accepted, they are to sign a member

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 49 of 319
By Michelle Shortt

48

 1 agreement with a code of conduct and, in addition, another

 2 agreement that the Arizona chapter made delineating what

 3 is expected of them as members.

 4 Q. When did the Arizona chapter begin having written

 5 member agreements with its members?

 6 A. Oh, I'd say -- so we started in February.

 7 Written -- it wasn't until later that year. It was -- I

 8 would say around August. Like, I think when -- that

 9 August document you saw, that's kind of when everybody

10 was -- when we tried to get everybody on board to make

11 sure we had an agreement.

12 Q. And does United Federation -- strike that.

13 Does Adversarial Truth, LLC, currently

14 maintain a copy of those member agreements?

15 A. Yes.

16 Q. Did you review copies of those member agreements

17 to make yourself knowledgeable to testify today?

18 A. No. The member agreements are the same for

19 everybody. It's what you see here. They all have to sign

20 that.

21 Q. The vetting process to which you referred, when

22 did that vetting process get implemented?

23 A. Immediately. I mean, we have always been fearful

24 for our safety. So anybody that comes across us is vetted

25 in whatever capacity we can -- online, in person. We just

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 50 of 319
By Michelle Shortt

49

 1 want to know who's approaching us.

 2 Q. How long does that vetting process take place?

 3 A. I mean, it really depends. I mean, it depends on

 4 numbers of interactions, how participatory the person is,

 5 any kind of inflammatory comments that we may have

 6 noticed.

 7 I mean, it -- usually, we try to do it as

 8 quickly as possible, but we -- it could be anywhere from,

 9 you know, a day to a few months. It just really depends

10 on the impression the person gives us.

11 Q. Between February 8th, 2016, and July 6, 2016, do

12 you know who was responsible for that vetting process?

13 A. All of us. All of us in the council. We formed

14 a council for The Satanic Temple Arizona, and we all gave

15 our input as to potential members that we would come

16 across.

17 Q. Who were members of that council on February 8,

18 2016?

19 A. It was --

20 MR. DE HAAN: Object to the form.

21 BY MR. CLAUS:

22 Q. Go ahead.

23 A. It was me, Stu, Kat, Morgan, Jeremy, James, Cody.

24 Is that it? Gosh. I feel like I'm forgetting somebody.

25 I can't remember anybody else. I'm sorry.

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 51 of 319
By Michelle Shortt

50

 1 Q. Do you agree with Mr. Misicko that neither The

 2 Satanic Temple, Inc., nor the United Federation of

 3 Churches, LLC, play any role of -- in deciding who may

 4 become a member of the Arizona chapter of The Satanic

 5 Temple?

 6 A. That is correct. We are autonomous in that

 7 sense.

 8 MR. CLAUS: Okay. That's all I have for

 9 this deposition.

10 Did you --

11 MR. DE HAAN: I just have a couple brief

12 questions.

13 THE WITNESS: Okay.

14 EXAMINATION

15 BY MR. DE HAAN:

16 Q. A lot of talk -- I'll refer you to the exhibits.

17 Do you have these?

18 A. Yeah.

19 Q. Okay. So 51 through 57 -- can you tell me what

20 those are that we referred to earlier?

21 MR. CLAUS: Form.

22 THE WITNESS: Well, these exhibits that were

23 presented to me are what I consider a placeholder for The

24 Satanic Temple's original website. The Satanic Temple was

25 originally created as a film project. It was not meant to

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 52 of 319
By Michelle Shortt

51

 1 be a real religion. It was not meant to be a real

 2 organization. It wasn't until they started gaining media

 3 attention and people started coming to The Satanic Temple

 4 for their activism that they started to consider the

 5 implications, and they decided to make it an official

 6 organization with -- you know, I now see seven tenets as

 7 opposed to nine tenets.

 8 BY MR. DE HAAN:

 9 Q. Okay. Has -- in your role as the chapter head of

10 The Satanic Temple of Arizona, has any member ever

11 approached you adhering to the nine tenets?

12 A. No.

13 MR. CLAUS: Form.

14 BY MR. DE HAAN:

15 Q. You still can answer.

16 A. No, they have not.

17 Q. Has anyone mentioned any other set of tenets,

18 other than what's known as the seven tenets, to you?

19 MR. CLAUS: Form.

20 THE WITNESS: They have not. The seven

21 tenets are what we consider to be our sincerely held

22 religious beliefs.

23 BY MR. DE HAAN:

24 Q. Okay. Okay.

25 MR. DE HAAN: That's all I have.

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 53 of 319
By Michelle Shortt

52

 1 MR. CLAUS: Okay. Let me just take a quick

 2 break.

 3 (A short recess was taken from 11:25 a.m. to

 4 11:32 a.m.)

 5 FURTHER EXAMINATION

 6 BY MR. CLAUS:

 7 Q. You just testified, ma'am, under

 8 cross-examination that you considered Exhibits 51

 9 through 57 placeholders because The Satanic Temple had not

10 yet engaged in its religious activities; is that correct?

11 A. Yes. To my knowledge.

12 Q. You would agree that, when The Satanic Temple

13 performed a ceremony at the gravesite of the member of the

14 Westboro Baptist Church, that was part of its religious

15 activity; correct?

16 MR. DE HAAN: Objection. This has nothing

17 to do with standing --

18 MR. CLAUS: It has to do with directly your

19 cross-examination question.

20 BY MR. CLAUS:

21 Q. Correct?

22 A. I consider the pink mass to be when The Satanic

23 Temple kind of made their debut as an official religion.

24 Q. When Mr. Misicko, under the name Lucien Greaves,

25 advocated for The Satanic Temple being allowed to give

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 54 of 319
By Michelle Shortt

53

 1 invocations under the First Amendment, that was -- The

 2 Satanic Temple was involved in its religious views;

 3 correct?

 4 A. Yes.

 5 Q. And when -- when The Satanic Temple adopted a

 6 highway in New York, that was part of its members coming

 7 together as a religious community; correct?

 8 A. Yes.

 9 Q. And when Lucien Greaves gave lectures at Harvard

10 on Satanism from the Old Testament to The Satanic Temple,

11 that was part of its religious activities; correct?

12 A. I mean, I don't know if it's part of the

13 religious activities. I think that's just -- it's not --

14 there's nothing about giving speeches to be part of our

15 religious practice.

16 Q. Well, when -- you said that -- you testified that

17 Exhibits 51 through 57 were place- -- merely placeholders

18 because The Satanic Temple was not active in the community

19 fulfilling its current mission.

20 And I want to ask you if Mr. Greaves giving

21 talks at Harvard regarding Satanism from the Old Testament

22 to The Satanic Temple was part of The Satanic Temple's

23 mission.

24 A. Part of our mission? No, it's not part of our

25 mission to give lectures at Harvard. No.

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 55 of 319
By Michelle Shortt

54

 1 Q. Okay. I'll hand you what's been marked or what

 2 will be marked as Exhibit 58.

 3 A. Activism --

 4 THE COURT REPORTER: Wait. My hands are not

 5 on the record.

 6 (Deposition Exhibit No. 58 marked for

 7 identification.)

 8 BY MR. CLAUS:

 9 Q. Say that again. Activism what, ma'am?

10 A. Activism is one of the many ways we just, you

11 know, show our sincerely held religious beliefs.

12 Q. I see. Okay.

13 And so take a look at Exhibit 49. That's

14 one of the previous ones. Are you there?

15 A. Uh-huh.

16 Q. That is an Internet archive from April 17, 2014,

17 that espouses the religious beliefs of The Satanic Temple.

18 Do you see that?

19 A. Yes.

20 Q. And -- and Exhibit 57 --

21 A. I have 58.

22 Q. You have 57 as well.

23 A. Yes.

24 Q. -- articulating the religious beliefs in the nine

25 tenets as of December 12, 2013; correct?

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 56 of 319
By Michelle Shortt

55

 1 A. Uh-huh.

 2 Q. And -- is that "yes"?

 3 A. Yes.

 4 Q. And it's your testimony that Exhibits 57 and 49

 5 were merely placeholders, ma'am?

 6 A. I think so. Yeah.

 7 Q. Under penalty of perjury, that's your testimony?

 8 A. Yes. That's what I believe.

 9 Q. Okay. Well, if you take a look at Exhibit 58,

10 you see this is from an Internet archive Web page from

11 April 21, 2014, from the website thesatanictemple.com;

12 correct?

13 A. Yes.

14 Q. And the first entry under "News" -- not the first

15 entry. The first entry is on the last page. But the

16 first entry on page 1 says it was "Posted March 6th,

17 2014," by Lucien and filed under News."

18 Do you see that?

19 A. Yes. Exhibit 58.

20 Q. Exhibit 58. The first entry under the heading

21 "News" says "The Satanic Temple and the First Amendment.

22 Posted March 6th, 2014, by Lucien and filed under News."

23 Do you see that?

24 A. Yes. Yes.

25 Q. Titled "The Satanic Temple and the First

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 57 of 319
By Michelle Shortt

56

 1 Amendment"; correct?

 2 A. Yes.

 3 Q. Published at the same time The Satanic Temple was

 4 advocating its religious beliefs that "God is

 5 supernatural; that Satan is God's proxy in this universe;

 6 that Satan is subordinate to God, can hear our prayers and

 7 can respond; and that he desires to be known and

 8 knowable"; correct?

 9 A. Yes.

10 Q. And Exhibit 58 also reflects activity by The

11 Satanic Temple performing a ceremony at the Westboro

12 Baptist Church family gravesite posted on July 17, 2013,

13 by Lucien and filed under "News"; correct?

14 A. Yes.

15 Q. That was part of the activism of The Satanic

16 Temple to which you referred previously; correct?

17 A. Yes.

18 Q. And that news article was published on the

19 website of The Satanic Temple as having taken place on

20 July 17, 2013, posted by Lucien at the time when both the

21 religious beliefs of The Satanic Temple espoused in

22 Exhibit 49 and the nine tenets espoused in Exhibit 47 --

23 57 were articulated by The Satanic Temple; correct?

24 A. Yes.

25 Q. And, in fact, The Satanic Temple -- if you look

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 58 of 319
By Michelle Shortt

57

 1 at the story that was posted by Lucien on July 17, 2013,

 2 under "News," the one, two, three -- third paragraph that

 3 starts with the words "The Satanic Temple supports freedom

 4 and the pursuit of happiness for all people" -- do you see

 5 that?

 6 A. Uh-huh.

 7 Q. "The Satanic Temple supports freedom and the

 8 pursuit of the happiness for all people. Thus, they

 9 support same-sex couples' legal equality. The Satanic

10 Temple claims that the mass was conducted as an

11 affirmation of those values and claims that the action is

12 meant to convey a message of love in the face of hate."

13 Did I read that correctly?

14 A. Yes.

15 Q. Lucien Greaves was the spokesperson for The

16 Satanic Temple as of July 17, 2013; correct?

17 A. Yes.

18 Q. We know that from this paragraph that precedes

19 that paragraph that states "Satanic Temple spokesperson

20 Lucien Greaves officiated the ceremony"; true?

21 A. Yes.

22 Q. Does The Satanic Temple currently hold mass?

23 A. They have weekly services at the headquarters. I

24 don't know if it's described as mass, but they do have

25 services.

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 59 of 319
By Michelle Shortt

58

 1 Q. And if you look at -- we're still on Exhibit 58.

 2 During all of these times when you say that the nine

 3 tenets and the religious beliefs of The Satanic Temple

 4 were espoused to the public as mere placeholders, we have,

 5 for instance, another entry that -- on page 1 of 58, "Hail

 6 Satan in Austin, Texas."

 7 Do you see that?

 8 A. Uh-huh.

 9 Q. Posted on July -- was that a "yes"?

10 A. Yes.

11 Q. Posted on July 6, 2013, by Lucien; true?

12 A. Yes.

13 Q. And then the next entry, "The Satanic Temple

14 crowdsources effort to Adopt-a-Highway in New York City,"

15 posted on June 10, 2013, by Lucien; true?

16 A. True.

17 Q. In fact, that was done according to the post on

18 Exhibit 58 in further efforts to increase public

19 understanding and acceptance of Satanism; correct?

20 A. Yes.

21 Q. And if the public desired to further understand

22 and accept Satanism as of June 10, 2013, they would see

23 articulated a religious belief that God and Satan were

24 both actual supernatural beings; correct?

25 A. Yes.

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 60 of 319
By Michelle Shortt

59

 1 Q. And that there were nine tenets, not seven

 2 tenets; correct?

 3 A. Yes.

 4 Q. So can you actually testify on knowledge under

 5 penalty of perjury that Exhibits 49 -- or 51 through 57

 6 were actually mere placeholders on the website maintained

 7 and operated for the public by The Satanic Temple?

 8 A. The reason I continue to say "yes" is because

 9 Lucien Greaves says that it is a placeholder. He said so

10 publicly on Twitter. I took it for face value. So that's

11 why I continue to say "yes." It's not through any other

12 information that I've received. It's directly from Lucien

13 that I continue to say "yes."

14 Q. And you see, though, that, in Exhibit 58,

15 Mr. Greaves, whose name is Doug Misicko, was actually

16 actively involved in promoting The Satanic Temple and

17 being a spokesperson long before The Satanic Temple

18 stopped articulating the religious belief that God and

19 Satan are actually supernatural beings and before they

20 stopped promoting nine instead of seven tenets; correct?

21 A. Correct.

22 Q. Does the Arizona chapter of The Satanic Temple

23 hold mass or services?

24 A. No.

25 Q. Did the Arizona chapter of The Satanic Temple

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 61 of 319
By Michelle Shortt

60

 1 hold mass or services in February 8th -- strike that -- as

 2 of February 8, 2016?

 3 A. No.

 4 Q. Did the Arizona chapter of The Satanic Temple

 5 hold mass or services as of July 6, 2016?

 6 A. No.

 7 Q. Okay.

 8 MR. CLAUS: I think that's all I have.

 9 Do you want to read and sign?

10 MR. DE HAAN: Sure.

11 MR. CLAUS: Okay.

12

13 (The deposition concluded at 11:44 a.m.)

14

15

16

17

18

19

20

21

 MICHELLE SHORTT

22

23

24

25

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 62 of 319
By Michelle Shortt

61

 1 STATE OF ARIZONA )

 ) ss.

 2 COUNTY OF MARICOPA )

 3 BE IT KNOWN that the foregoing proceedings were

 taken before me; that the witness before testifying was

 4 duly sworn by me to testify to the whole truth; that the

 foregoing pages are a full, true, and accurate record of

 5 the proceedings, all done to the best of my skill and

 ability; that the proceedings were taken down by me in

 6 shorthand and thereafter reduced to print under my

 direction.

 7

 I CERTIFY that I am in no way related to any of

 8 the parties hereto, nor am I in any way interested in the

 outcome hereof.

 9

10 [X] Review and signature was requested; any

 changes made by the witness will be attached to the

11 original transcript.

 [ ] Review and signature was waived/not

12 requested.

 [ ] Review and signature not required.

13

 I CERTIFY that I have complied with the ethical

14 obligations set forth in ACJA 7-206(F)(3) and ACJA 7-206

 J(1)(g)(1) and (2).

15 Dated at Phoenix, Arizona, this 30th day of

 September, 2019.

16

17

18 _____________________________ ______

 KELLY M. OLHAUSEN, RPR

19 Certified Reporter

 Arizona CR No. 50867

20

 * * * * *

21

 I CERTIFY that GRIFFIN & ASSOCIATES, LLC, has

22 complied with the ethical obligations set forth in ACJA

 7-206 (J)(1)(g)(1) through (6).

23

 _____________________________________

24 GRIFFIN & ASSOCIATES, LLC

 Registered Reporting Firm

25 Arizona RRF No. R1005

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 63 of 319
The Satanic Temple and Michelle Shortt v.

City of Scottsdale, Arizona, by it City Council

By Michelle Shortt 30(b)(6) of Adversarial Truth, LLC

September 26, 2019

[

[sic] (1)

 30:1

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able (3)

 6:19;9:24;40:10

accept (1)

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acceptance (1)

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accepted (2)

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According (5)

 31:13,14;42:4,5;

 58:17

accurate (6)

 7:25;8:17;14:17,

 21;29:10;32:4

across (2)

 48:24;49:16

act (4)

 10:9;11:6,22;22:7

acted (1)

 17:5

acting (3)

 10:20;17:6;21:19

action (2)

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active (1)

 53:18

actively (1)

 59:16

activism (6)

 32:11;51:4;54:3,9,

 10;56:15

activist (1)

 32:14

activities (3)

 52:10;53:11,13

activity (2)

 52:15;56:10

actual (5)

 10:24;12:10;33:25;

 38:1;58:24

actually (10)

 13:17;14:23;20:23,

 24;29:24;36:4;59:4,

 6,15,19

add (1)

 35:14

addition (2)

 36:19;48:1

address (1)

 21:9

adhering (1)

 51:11

admit (1)

 13:12

Adopt-a-Highway (1)

 58:14

adopted (1)

 53:5

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 9:5,15,21;19:19,25;

 20:6,8,15;46:3,8;

 48:13

advocated (1)

 52:25

advocating (1)

 56:4

affiliate (2)

 15:25;16:16

affiliated (1)

 12:19

affiliation (9)

 12:12,17,18;13:21;

 14:11,18;15:19;

 17:11,18

affirmation (1)

 57:11

again (5)

 7:10;23:12,15;

 36:11;54:9

against (2)

 26:3;34:18

agent (4)

 20:12,25;21:4,7

agree (7)

 6:8;30:14,19;31:5;

 37:1;50:1;52:12

agreement (18)

 10:15;12:12,13,18,

 18,18;13:21;14:9;

 15:20;16:14;17:12,

 18,21;18:3,6;48:1,2,

 11

agreements (5)

 15:23;48:5,14,16,

 18

ahead (2)

 24:23;49:22

align (1)

 33:10

allies (1)

 33:9

allow (1)

 24:21

allowed (2)

 11:1;52:25

ally (1)

 33:11

almost (1)

 21:19

along (1)

 29:16

Although (1)

 36:17

always (4)

 29:25;30:4,6;48:23

amend (1)

 21:3

amended (2)

 5:18;29:3

amendment (6)

 20:19,21;21:6;

 53:1;55:21;56:1

amendments (1)

 21:8

and/or (1)

 17:13

angel (2)

 36:17;37:8

angels (1)

 40:2

answered (2)

 20:16;39:14

apologize (1)

 5:12

appears (1)

 7:1

application (3)

 47:20,22,24

approached (1)

 51:11

approaching (1)

 49:1

approval (1)

 9:1

April (11)

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 10,20;38:5,11,17;

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archive (7)

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area (2)

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Arizona (55)

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 10:1,19;12:19;13:20,

 25;14:3,6,10,11,19;

 15:4,25;18:12;19:11;

 20:2,22;22:12,20,24;

 23:9,18;24:2,15;

 31:7;32:5,25;37:18;

 38:3,15,20;44:1;

 45:25;46:4,12,16;

 47:3,4,7,8,10,18;

 48:2,4;49:14;50:4;

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Armola (3)

 24:24;25:23,24

A-R-M-O-L-A (1)

 25:24

around (5)

 13:17;21:1;26:13;

 34:17;48:8

arrangements (1)

 9:25

article (1)

 56:18

articles (1)

 9:4

articulated (9)

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 14;40:8,18;43:1;

 56:23;58:23

articulating (2)

 54:24;59:18

articulation (1)

 35:2

aspect (5)

 32:10,11;33:16,19,

 20

assertion (1)

 36:5

assume (1)

 10:11

atheist (1)

 30:1

atheistic (1)

 34:21

attendance (1)

 46:23

attention (2)

 13:8;51:3

attracting (1)

 32:12

attributed (2)

 7:13,19

audible (1)

 8:13

audibly (1)

 8:14

August (11)

 12:23;13:22;14:12,

 20;15:2,20;16:17;

 17:14;43:6;48:8,9

Austin (1)

 58:6

authority (7)

 9:24;10:9,23;11:6,

 22;12:3;22:11

autonomous (1)

 50:6

available (2)

 35:1,10

aware (4)

 11:10;12:3;15:23;

 16:20

away (1)

 34:24

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back (7)

 12:13;15:12;20:19;

 28:15;32:7;44:3,5

backdated (2)

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bad (1)

 29:16

band (1)

 21:20

banner (3)

 16:6,12;34:11

Baptist (2)

 52:14;56:12

bar (1)

 46:25

base (1)

 22:22

based (4)

 23:4;31:25;37:19;

 38:4

basically (2)

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became (17)

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 23;27:1,3,4,7,10,13,

 16,19,22;28:2,19,23

become (9)

 12:19;16:6;28:7,

 17,17;32:5,25;43:23;

 50:4

becoming (1)

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began (1)

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begin (1)

 48:4

beginning (4)

 13:6;18:5;26:13;

 45:22

behalf (10)

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behavior (1)

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beings (2)

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belief (10)

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beliefs (27)

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 34:11,25;35:2,9,12;

 37:19;38:4;39:2,3,

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 36:19,21

black (1)

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Blog (1)

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Bloody (1)

 7:5

board (1)

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book (1)

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Both (4)

 10:22,22;56:20;

 58:24

bottom (1)

Min-U-Script® Griffin Group International

602.264.2230

(1) [sic] - bottom

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 64 of 319
The Satanic Temple and Michelle Shortt v.

City of Scottsdale, Arizona, by it City Council

By Michelle Shortt 30(b)(6) of Adversarial Truth, LLC

September 26, 2019

 5:22

box (1)

 19:6

break (3)

 15:7;45:10;52:2

Brian (1)

 21:17

brief (1)

 50:11

broke (1)

 36:1

brought (1)

 16:14

bullet (1)

 11:20

business (1)

 40:24

C

called (7)

 8:1,5;17:17,19;

 19:19;20:6;21:20

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 29:11;30:8;31:4

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 25:4;26:16;28:5,10,

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 33:3;34:7,9;36:20,20,

 22,23;37:8,17,22;

 38:1,13,22;39:11;

 41:1;43:21;48:25;

 50:19;51:15;56:6,7;

 59:4

capacity (1)

 48:25

carefully (1)

 44:3

case (4)

 10:3;29:8;47:15,16

Catholic (1)

 30:10

centered (1)

 19:3

ceremony (3)

 52:13;56:11;57:20

certainly (1)

 10:5

Certified (1)

 5:2

change (2)

 20:24;21:7

changed (2)

 21:8;29:17

changes (2)

 13:10;32:9

chapter (57)

 8:1,1,5,6,9,19;9:23;

 10:9,18,20,23;11:1;

 12:3,19;13:6,17,20,

 25;14:3,6,10,11,19;

 15:3,4;16:6,10;18:4,

 5,9,12;19:11;20:13,

 14;21:2,2;26:4;

 30:12;31:7,7;32:6,9,

 25;45:25;46:4,12,16;

 47:3,4,10,19;48:2,4;

 50:4;51:9;59:22,25

chapters (2)

 12:3;19:10

chats (1)

 34:18

chick (1)

 25:10

choir (1)

 40:2

church (4)

 30:10;34:19;52:14;

 56:12

Churches (7)

 15:24;16:8,15;

 17:12;18:24;30:13;

 50:3

City (11)

 5:8;9:13,19;12:25;

 13:4;19:17;20:4;

 22:2;25:20;37:12;

 58:14

claims (2)

 57:10,11

CLAUS (33)

 5:6,7;6:16,24;15:6,

 10,17;16:22;17:2,8;

 24:20,22;25:14;

 28:12,20;30:17;

 35:18,24;44:2,7;

 45:10,14,20;49:21;

 50:8,21;51:13,19;

 52:1,6,18,20;54:8

cleared (1)

 41:10

clearly (1)

 16:9

close (1)

 45:22

coached (1)

 17:5

co-chapter (2)

 10:18,19

code (3)

 10:14;18:2;48:1

Cody (4)

 25:8,16;27:10;

 49:23

Cody's (1)

 25:9

cofounders (1)

 13:15

combined (2)

 40:21;41:9

comfortable (2)

 29:11;30:8

coming (3)

 13:10;51:3;53:6

commented (1)

 36:2

comments (1)

 49:5

Commission (4)

 9:1,5,10;20:22

communication (1)

 31:22

community (5)

 10:6;21:18;47:23;

 53:7,18

compassion (3)

 36:17;37:7;41:16

complaint (1)

 29:3

complete (2)

 47:19,21

completely (2)

 17:3;34:24

comprehension (1)

 36:21

conduct (3)

 10:14;18:2;48:1

conducted (1)

 57:10

conduit (1)

 36:18

confer (2)

 47:2,10

confers (1)

 12:3

confident (3)

 37:24,25;38:6

consider (4)

 50:23;51:4,21;

 52:22

considered (4)

 23:20;31:10;46:14;

 52:8

conspiracy (2)

 34:17,18

contain (1)

 19:25

contained (1)

 41:5

continue (3)

 59:8,11,13

continued (1)

 26:4

conversation (1)

 35:8

convey (1)

 57:12

copies (2)

 6:17;48:16

copy (5)

 15:7;17:15,17;

 29:3;48:14

Corporation (8)

 9:1,5,10;13:5;

 20:10,11,22;21:3

corporeal (2)

 34:7;36:14

correctly (4)

 11:25;36:24;39:14;

 57:13

correspond (1)

 5:16

correspondence (1)

 32:3

council (11)

 9:13,19;13:2,12;

 22:2;23:23;25:11;

 31:12;49:13,14,17

counsel (1)

 17:6

count (2)

 29:24;39:18

counter (3)

 30:22,25;31:3

couple (2)

 45:16;50:11

couples' (1)

 57:9

Court (8)

 5:3,13;8:14;28:13,

 15;44:2,5;54:4

created (5)

 33:25;36:16;38:21;

 42:8;50:25

creation (1)

 14:18

cross-examination (2)

 52:8,19

crowdsources (1)

 58:14

current (1)

 53:19

currently (9)

 22:10;32:7,8,9;

 40:8;41:3,14;48:13;

 57:22

D

d/b/a (1)

 15:24

database (1)

 46:11

date (9)

 8:24;9:9;16:3,16;

 17:14;18:11;21:24;

 22:1;28:1

dated (4)

 15:20;18:18,21;

 39:23

day (4)

 12:22;14:24,25;

 49:9

de (21)

 12:14;15:9;16:21,

 24;17:13;20:12,25;

 24:18;25:6;26:8;

 30:16;45:13,16;

 49:20;50:11,15;51:8,

 14,23,25;52:16

debut (1)

 52:23

December (3)

 43:18,24;54:25

decide (1)

 45:14

decided (1)

 51:5

deciding (1)

 50:3

degrees (1)

 23:14

deity (1)

 45:2

delineating (1)

 48:2

demonstrates (1)

 14:5

denied (1)

 21:4

depends (3)

 49:3,3,9

deponent (2)

 5:11;6:4

deposition (13)

 5:17,18;6:10,22;

 7:1;15:15,21;17:3;

 29:4;35:22;45:22;

 50:9;54:6

described (1)

 57:24

designated (2)

 6:4;15:4

designed (1)

 40:14

designee (2)

 30:13,21

desired (1)

 58:21

desires (4)

 36:21;37:9;38:23;

 56:7

Dickinson (1)

 5:8

difference (4)

 30:14,19,22,24

different (9)

 10:17;23:13;38:24;

 41:4,8;44:10,13,16,

 19

directive (1)

 13:13

directly (2)

 52:18;59:12

disagree (2)

 40:24;41:6

disclosed (1)

 18:16

doctrine (1)

 45:5

document (16)

Min-U-Script® Griffin Group International

602.264.2230

(2) box - document

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 65 of 319
The Satanic Temple and Michelle Shortt v.

City of Scottsdale, Arizona, by it City Council

By Michelle Shortt 30(b)(6) of Adversarial Truth, LLC

September 26, 2019

 6:25;7:15;10:8,11;

 12:2,10,11;14:5,9,18;

 15:10,18;16:5,9;

 18:10;48:9

domicile (1)

 24:10

domiciles (1)

 24:19

dominion (1)

 36:19

done (4)

 40:5,6;45:11;58:17

Doug (2)

 37:2;59:15

due (4)

 13:9;21:4;30:9,9

duly (1)

 5:2

During (1)

 58:2

E

earlier (13)

 14:22,24;15:1,5;

 16:16,24;17:1,14,15,

 17;18:11,21;50:20

earth (1)

 40:3

effort (1)

 58:14

efforts (1)

 58:18

eight (1)

 40:18

electronically (1)

 6:20

else (3)

 10:25;25:12;49:25

e-mail (2)

 19:22,24

e-mails (1)

 32:3

end (1)

 41:21

endured (1)

 30:9

engaged (1)

 52:10

entirely (1)

 30:20

entity (4)

 8:18;17:13;19:19;

 20:6

entrusted (1)

 18:3

entry (7)

 55:14,15,15,16,20;

 58:5,13

equality (1)

 57:9

especially (2)

 32:11;34:19

espoused (14)

 35:1,10;36:10;

 37:20;38:4;41:3,14;

 42:13;43:1,5,17;

 56:21,22;58:4

espouses (1)

 54:17

establish (1)

 13:6

even (1)

 13:11

everybody (4)

 25:11;48:9,10,19

exactly (2)

 26:17;40:19

EXAMINATION (3)

 5:5;50:14;52:5

except (2)

 41:9;42:9

executed (3)

 13:22;14:12;16:16

executive (2)

 13:13;31:12

exercise (1)

 10:6

Exhibit (66)

 5:15,16,17,25,25;

 6:1,2,2,5,9,10,12,13,

 19,22,25;7:1,3,7;8:3,

 6;9:3,4,7;11:13;

 15:15,21;16:1;18:22;

 20:20,21;29:4,20;

 34:9,14;35:1,10,22;

 36:1,7,10,11;37:20;

 39:10,15;40:17,18;

 41:5,19;42:2,12,20,

 25;54:2,6,13,20;55:9,

 19,20;56:10,22,22;

 58:1,18;59:14

exhibits (9)

 5:15;6:16;37:15;

 50:16,22;52:8;53:17;

 55:4;59:5

exist (2)

 34:7;46:8

existence (1)

 14:20

exists (1)

 18:10

expected (1)

 48:3

explained (1)

 34:22

explains (1)

 35:5

expressed (5)

 40:16;41:19;42:21;

 43:9,13

extend (1)

 47:24

eyes (3)

 41:13,21;44:9

F

face (2)

 57:12;59:10

Facebook (1)

 22:23

fact (4)

 11:4;36:5;56:25;

 58:17

false (4)

 7:8,13,20,24

familiar (2)

 18:23;40:7

family (1)

 56:12

far (2)

 25:15;39:19

fast (3)

 5:11,12,13

fearful (1)

 48:23

February (37)

 9:13;14:2,7;19:2,4,

 8,9,11;21:11,25;22:8,

 14,20,25;23:10,16;

 24:2,11,15;25:20;

 32:16,23;33:5;37:18;

 38:3,15,20;43:23;

 44:14,20;46:7,7,10;

 47:13;48:6;49:11,17

Federation (8)

 15:24;16:8,15;

 17:12;18:24;30:13;

 48:12;50:2

feel (3)

 10:5;29:10;49:24

few (2)

 47:23;49:9

fifth (1)

 29:25

filed (6)

 9:4;20:22;44:20;

 55:17,22;56:13

filing (1)

 9:9

fill (1)

 47:24

film (1)

 50:25

find (1)

 29:13

fine (1)

 29:5

finish (1)

 32:20

firm (1)

 5:8

firmly (5)

 33:17,21,24;34:3,6

first (30)

 5:18;6:12;7:7,12,

 18;8:22;10:12;11:25;

 12:21;18:4,5;21:15,

 17,23;26:7,9;29:3;

 32:14;36:24;41:15;

 46:16,18;53:1;55:14,

 14,15,16,20,21,25

Fisher (1)

 25:1

focus (2)

 21:24;32:10

focusing (1)

 23:16

follows (1)

 5:4

foremost (1)

 32:15

forgetting (1)

 49:24

form (7)

 24:20;25:7;30:16;

 49:20;50:21;51:13,

 19

formalized (1)

 13:11

formation (1)

 8:24

formed (8)

 13:4,16,20,21;14:1,

 6;23:23;49:13

former (1)

 30:12

forum (1)

 10:7

found (2)

 26:2;29:13

four (1)

 36:9

freedom (2)

 57:3,7

friends (3)

 23:22,24;24:6

fulfilling (1)

 53:19

Fundamental (5)

 39:20,24,25;42:3,

 21

FURTHER (3)

 52:5;58:18,21

G

gaining (1)

 51:2

gave (2)

 49:14;53:9

gets (1)

 10:6

given (3)

 22:11;26:7;36:4

gives (2)

 10:13;49:10

giving (2)

 53:14,20

God (13)

 29:19;33:25;36:12,

 15,18,21;37:5;38:20,

 21;56:4,6;58:23;

 59:18

God's (4)

 36:13;37:7;38:22;

 56:5

goes (1)

 34:17

good (5)

 5:7;11:7,11,14,16

Gosh (1)

 49:24

grant (2)

 11:5,21

gravesite (2)

 52:13;56:12

Greaves (11)

 13:14;21:20;37:2;

 40:25;52:24;53:9,20;

 57:15,20;59:9,15

group (1)

 32:14

guess (2)

 9:25;23:5

guided (1)

 41:16

guidelines (1)

 10:14

guiding (2)

 40:11,14

H

Haan (21)

 12:14;15:9;16:21,

 24;17:13;20:12,25;

 24:18;25:6;26:8;

 30:16;45:13,16;

 49:20;50:11,15;51:8,

 14,23,25;52:16

Hail (3)

 32:12;35:5;58:5

hand (1)

 54:1

handed (4)

 5:10;6:25;15:18;

 35:25

handful (1)

 46:15

Handing (1)

 42:12

hands (1)

 54:4

happiness (2)

 57:4,8

Harvard (3)

 53:9,21,25

hate (1)

 57:12

head (12)

 8:1,5,9;9:23;10:9,

 19,20;18:9;21:3;

Min-U-Script® Griffin Group International

602.264.2230

(3) domicile - head

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 66 of 319
The Satanic Temple and Michelle Shortt v.

City of Scottsdale, Arizona, by it City Council

By Michelle Shortt 30(b)(6) of Adversarial Truth, LLC

September 26, 2019

 30:12;31:7;51:9

heading (3)

 11:15;34:11;55:20

headquarters (1)

 57:23

heads (4)

 10:18;11:1;12:3;

 18:4

hear (4)

 21:15;36:20;38:22;

 56:6

heard (5)

 21:17;31:2,4;

 35:16;36:2

hears (2)

 34:4;37:8

heaven (1)

 40:3

held (11)

 33:17,21,24;34:3,

 6;44:10,13,16,19;

 51:21;54:11

herein (1)

 5:2

highway (1)

 53:6

hold (2)

 57:22;59:23

hope (1)

 39:14

hour (2)

 5:11;14:15

human (1)

 36:21

I

identification (4)

 6:23;15:16;35:23;

 54:7

identified (2)

 6:5,9

identify (2)

 29:1,15

identity (2)

 24:4,9

ignorant (1)

 32:13

Immediately (1)

 48:23

imperfect (1)

 36:14

implemented (1)

 48:22

implications (1)

 51:5

impression (1)

 49:10

inappropriate (2)

 17:3,7

Inc (1)

 50:2

including (1)

 26:8

incorporate (1)

 13:18

incorporated (1)

 8:24

incorporation (1)

 8:23

increase (1)

 58:18

indicating (3)

 12:5;17:20;18:2

inflammatory (1)

 49:5

influx (1)

 13:9

information (2)

 11:17;59:12

initial (2)

 25:11;47:22

initially (1)

 23:23

input (1)

 49:15

inserted (1)

 17:4

inspire (1)

 40:14

instance (3)

 41:12;44:9;58:5

instead (1)

 59:20

interact (1)

 36:14

interactions (1)

 49:4

interest (2)

 13:9;21:23

interesting (1)

 29:13

Internet (7)

 19:1;34:10;36:8;

 39:15,23;54:16;

 55:10

interrupt (1)

 14:15

intervene (1)

 36:15

interview (2)

 7:2;29:12

interviewed (2)

 7:5;8:2

interviewer (1)

 30:7

intimately (1)

 37:3

invocation (19)

 9:12,14,18,20,22;

 12:24;13:4,7;19:18;

 20:5;22:2,12;26:1,5,

 14;37:12,13;43:23;

 44:24

invocations (1)

 53:1

involved (3)

 37:3;53:2;59:16

J

Jack (4)

 24:24;25:13,15;

 26:23

James (4)

 25:9,16;27:13;

 49:23

January (7)

 8:25;38:11,16;

 39:23;41:20;42:2;

 46:18

Jarry (3)

 13:14;31:24;32:2

Jeremy (4)

 25:9,16;27:16;

 49:23

join (3)

 38:6,10,16

joined (5)

 37:19;38:3,8;

 46:19,21

July (12)

 32:16,24;43:3;

 44:17;47:16;49:11;

 56:12,20;57:1,16;

 58:9,11

June (3)

 42:23;58:15,22

justice (1)

 36:23

K

Kat (4)

 25:1,15;27:4;49:23

keep (3)

 17:15;18:1;22:21

keeping (2)

 45:23,25

Kevin (5)

 31:18,20,23,24;

 32:2

kind (12)

 10:16;13:10;16:11,

 20;22:22;28:25;

 29:15;33:14;41:15;

 48:9;49:5;52:23

knew (5)

 23:18,21;24:1,14;

 25:19

knowable (4)

 36:22;37:9;38:24;

 56:8

knowledge (9)

 6:4;23:4;26:19;

 28:6;32:1;33:3;38:1;

 52:11;59:4

knowledgeable (3)

 6:9;24:9;48:17

known (6)

 36:22;37:2,9;

 38:23;51:18;56:7

L

lack (1)

 45:24

last (3)

 25:9;40:23;55:15

late (1)

 15:2

later (1)

 48:7

law (1)

 5:8

lawsuit (1)

 44:20

leadership (2)

 10:17;31:8

lectures (2)

 53:9,25

legal (1)

 57:9

letter (2)

 8:23;9:1

level (1)

 45:24

liaison (3)

 10:21,22;11:1

life (5)

 33:8;36:23;41:12,

 20;44:9

limited (1)

 35:6

list (1)

 46:13

listen (2)

 41:17;44:3

lists (1)

 19:10

literary (1)

 45:4

litigation (1)

 18:16

little (2)

 15:2;21:14

live (2)

 26:5;33:8

lives (2)

 47:7,8

LLC (22)

 5:19;6:5;8:18,21;

 9:6,15,21;13:5;

 15:24;16:15;17:12;

 18:24;19:19,25;20:6,

 8,16;30:13;46:4,8;

 48:13;50:3

local (1)

 46:25

long (3)

 21:13;49:2;59:17

longer (3)

 8:9;31:6;34:23

look (12)

 9:3;18:22;29:2,8,

 20;34:20;35:4;39:10;

 54:13;55:9;56:25;

 58:1

looking (3)

 29:6,7;39:20

looks (1)

 40:20

lot (5)

 13:8,9,10;32:12;

 50:16

love (2)

 35:7;57:12

Lucien (17)

 13:14;21:20;37:2;

 40:25;52:24;53:9;

 55:17,22;56:13,20;

 57:1,15,20;58:11,15;

 59:9,12

M

Ma'am (7)

 14:14;35:7,25;

 41:17;52:7;54:9;55:5

maintain (3)

 46:4,10;48:14

maintained (2)

 18:23;59:6

making (1)

 32:9

Malcolm (3)

 13:14;31:24;32:2

mankind's (1)

 36:18

many (12)

 16:4;20:8,14,15;

 22:19,21;23:8,16;

 25:18;37:17;46:19;

 54:10

March (5)

 19:5,7;42:15;

 55:16,22

mark (1)

 35:19

marked (7)

 6:22;15:15,20;

 35:23;54:1,2,6

mass (5)

 52:22;57:10,22,24;

 59:23

masses (1)

 31:16

material (1)

 36:15

Matirko (1)

 24:24

matters (1)

 32:3

May (5)

 9:1;33:10;35:14;

Min-U-Script® Griffin Group International

602.264.2230

(4) heading - May

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 67 of 319
The Satanic Temple and Michelle Shortt v.

City of Scottsdale, Arizona, by it City Council

By Michelle Shortt 30(b)(6) of Adversarial Truth, LLC

September 26, 2019

 49:5;50:3

Maybe (2)

 17:20;18:6

mean (13)

 10:1,11;17:25;

 23:13;28:25;29:18;

 41:1,7;48:23;49:3,3,

 7;53:12

meaning (1)

 36:23

means (2)

 21:16;36:13

meant (3)

 50:25;51:1;57:12

media (8)

 9:24;10:21,22;

 11:1,2;13:8;23:24;

 51:2

meeting (7)

 9:13,19;13:2;22:2;

 46:18,21,24

member (37)

 10:15;11:24;17:21;

 18:2,7;20:11;21:10,

 13;24:19;26:11,20,

 23;27:1,4,7,10,13,16,

 19,22;28:3;32:5,25;

 38:19,24;44:8;47:7,9,

 18,25;48:5,14,16,18;

 50:4;51:10;52:13

members (52)

 9:15,20;10:1;

 13:12,12;14:4;20:8,

 14,15;22:19,22;23:1,

 1,8,11,17;24:10,13;

 25:18;28:6,7,17,18,

 19,22,24;33:9,18,21;

 37:17;38:2,14;42:14,

 22;43:1,22,23,25;

 45:23;46:4,6,11,17,

 19;47:4,5,23;48:3,5;

 49:15,17;53:6

membership (8)

 11:5,15,20,21;

 23:14;47:1,3,10

mentioned (1)

 51:17

mentioning (1)

 17:16

mere (2)

 58:4;59:6

merely (3)

 36:6;53:17;55:5

message (1)

 57:12

met (2)

 21:21;47:23

method (3)

 30:23,25;31:3

metro (2)

 23:2,25

Michael (4)

 25:1,13,15;27:1

MICHELLE (1)

 5:1

might (1)

 17:21

minister (1)

 22:7

ministers (1)

 45:8

ministry (2)

 13:14;31:12

minutes (1)

 45:17

Misicko (7)

 37:2;40:22,24;

 41:2;50:1;52:24;

 59:15

misleading (5)

 7:8,14,20,24;23:20

mission (4)

 53:19,23,24,25

moment (1)

 7:9

months (3)

 16:5;36:9;49:9

moored (1)

 39:3

more (7)

 25:17;32:10;33:17,

 21;39:18,18,19

Morgan (4)

 25:1,16;27:7;49:23

morning (1)

 5:7

mostly (1)

 46:15

movie (2)

 32:12;35:5

myself (3)

 10:22;20:25;29:14

N

name (5)

 5:7;25:9;28:22;

 52:24;59:15

named (3)

 28:6,21;33:5

names (9)

 24:13,16,19,23;

 26:7,8,9;28:23;46:13

national (2)

 31:12;45:24

nationally (1)

 22:22

necessarily (5)

 10:4;17:19;19:15;

 47:2,9

need (8)

 26:6;29:3,4,8;32:4,

 17,24;47:21

needs (1)

 47:19

neither (1)

 50:1

new (4)

 21:2;42:8;53:6;

 58:14

News (7)

 55:14,17,21,22;

 56:13,18;57:2

next (3)

 6:2;19:6;58:13

Nicki (3)

 25:10,16;27:19

nine (25)

 39:6,8,9,25,25;

 40:2,4;41:4,5;42:2,3,

 12,21,25;43:5,9,13,

 17;51:7,11;54:24;

 56:22;58:2;59:1,20

nobility (1)

 40:14

None (4)

 37:21;38:2;40:17,

 23

nor (1)

 50:2

Nos (1)

 35:22

notice (3)

 5:17,18;7:8

noticed (2)

 12:13;49:6

notion (1)

 37:5

November (1)

 43:14

number (4)

 5:16;23:19;40:1;

 46:11

numbered (3)

 5:22;29:21,21

numbers (2)

 22:22;49:4

O

oath (5)

 23:3;35:25;36:4;

 39:13;45:21

object (3)

 24:18,20;49:20

objection (3)

 25:7;30:16;52:16

obvious (1)

 33:14

occurred (1)

 46:2

occurs (1)

 46:1

October (1)

 7:2

off (3)

 12:7;15:11;35:18

official (7)

 13:18;15:4;22:9;

 45:4;46:6;51:5;52:23

officiated (1)

 57:20

Old (2)

 53:10,21

once (2)

 21:9;47:23

one (30)

 6:18,18;10:12,25;

 12:5,15;17:1;19:6;

 20:11;25:10,13;26:4;

 31:14;32:4,17,24;

 33:24;36:9;39:18,18,

 19;40:2,18;41:15;

 45:11,13;47:19;

 54:10,14;57:2

ones (1)

 54:14

online (5)

 10:14;31:15,15;

 34:18;48:25

only (11)

 5:10;14:9,14;20:1,

 11;21:6;23:6;36:18,

 19,20,22

operate (1)

 8:18

operated (1)

 59:7

opposed (2)

 32:11;51:7

opposite (1)

 11:18

ordained (1)

 22:7

ordainment (1)

 22:9

ordination (2)

 22:13;45:7

organization (6)

 9:4;11:5,9,23;51:2,

 6

organized (2)

 8:18,22

original (1)

 50:24

originally (1)

 50:25

otherwise (2)

 35:7;37:2

out (2)

 18:20;47:24

outside (1)

 36:12

over (4)

 21:14;33:25;36:16;

 37:6

oversee (1)

 40:3

P

packet (3)

 10:12;17:23,25

page (14)

 5:23;6:1,2;19:3;

 22:23;29:25;36:8;

 39:16,17,20;55:10,

 15,16;58:5

pages (2)

 5:22;29:20

paginated (1)

 39:17

paper (1)

 10:24

paperwork (1)

 15:3

paragraph (3)

 57:2,18,19

parlor (1)

 16:4

part (11)

 29:14;34:23;52:14;

 53:6,11,12,14,22,24,

 24;56:15

participatory (2)

 46:14;49:4

pastors (1)

 45:8

penalty (13)

 23:4;26:16,19;

 28:5;33:3;36:4;

 37:22;38:1,14;41:2;

 43:21;55:7;59:5

people (19)

 13:9;23:20,21,24;

 24:1,5;28:16,17,21;

 29:18,19;31:4;32:13;

 41:15;46:13,20;51:3;

 57:4,8

percipient (1)

 17:5

perfection (1)

 36:13

performed (1)

 52:13

performing (1)

 56:11

perjury (13)

 23:4;26:16,19;

 28:5;33:4;36:5;

 37:22;38:2,14;41:3;

 43:21;55:7;59:5

person (5)

 6:8;24:9;48:25;

 49:4,10

personal (2)

 26:19;28:25

personally (5)

 23:9,17;24:1,14;

 25:19

persons (1)

 33:4

Phoenix (5)

 13:8;23:2,24,25;

 26:14

Min-U-Script® Griffin Group International

602.264.2230

(5) Maybe - Phoenix

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 68 of 319
The Satanic Temple and Michelle Shortt v.

City of Scottsdale, Arizona, by it City Council

By Michelle Shortt 30(b)(6) of Adversarial Truth, LLC

September 26, 2019

photo (5)

 16:3;18:1,19,20;

 25:13

phrase (1)

 19:25

physical (2)

 36:13,19

pink (1)

 52:22

pizza (2)

 14:22;16:4

place (3)

 14:22;49:2;56:19

place- (1)

 53:17

placeholder (6)

 35:15;36:6;42:4,7;

 50:23;59:9

placeholders (5)

 52:9;53:17;55:5;

 58:4;59:6

platform (1)

 31:15

play (1)

 50:3

please (4)

 5:12,15;9:16;34:9

point (1)

 11:20

policy (1)

 26:2

political (2)

 30:15,20

portion (2)

 28:14;44:4

position (1)

 31:14

positions (1)

 10:17

possible (1)

 49:8

post (2)

 7:5;58:17

Posted (8)

 55:16,22;56:12,20;

 57:1;58:9,11,15

potential (1)

 49:15

practice (2)

 33:13;53:15

practices (1)

 33:14

practicing (4)

 32:5,17,24;33:5

prayers (5)

 34:4;36:20;37:8;

 38:23;56:6

pre- (1)

 42:5

precedes (1)

 57:18

precious (3)

 41:12,21;44:9

predate (1)

 16:1

premise (1)

 40:19

presence (2)

 9:24;23:24

presented (1)

 50:23

preside (2)

 33:25;36:16

presides (1)

 37:6

pretty (2)

 37:24,25

previous (1)

 54:14

previously (2)

 15:19;56:16

principle (2)

 40:11,14

printed (1)

 18:20

prior (3)

 13:7;43:24;47:22

probably (2)

 21:4;26:13

process (7)

 20:23,24;47:22;

 48:21,22;49:2,12

program (3)

 22:10,13;45:7

project (1)

 50:25

prominent (1)

 21:18

promoting (2)

 59:16,20

proposition (1)

 11:18

proxy (5)

 34:1;36:16;37:7;

 38:22;56:5

public (11)

 10:7,24;35:1,11;

 42:14,22;43:2;58:4,

 18,21;59:7

publication (1)

 7:1

publicly (1)

 59:10

published (5)

 7:2;8:7;11:17;56:3,

 18

pursuit (2)

 57:4,8

put (1)

 15:7

Q

quick (2)

 35:19;52:1

quickly (4)

 19:15;35:13;42:1;

 49:8

quite (1)

 13:18

quote (4)

 11:5,19;41:20,21

R

rather (1)

 5:11

read (12)

 7:10,18;11:25;

 16:14;28:12,15;

 36:11,24;40:4;44:3,

 5;57:13

reading (3)

 7:15;12:11,12

real (4)

 35:13,18;51:1,1

really (4)

 5:13;18:20;49:3,9

realm (2)

 34:7;36:14

reason (1)

 59:8

recall (9)

 7:9,10,11,18;

 14:22;25:4;27:25;

 28:2;30:7

recalled (1)

 29:13

received (4)

 8:25;13:8;18:4;

 59:12

receiving (1)

 47:22

recently (1)

 30:8

recess (4)

 15:13;35:20;45:18;

 52:3

recognized (1)

 14:18

record (9)

 15:8,11;28:14;

 35:18;44:4;45:23,24;

 46:14;54:5

records (2)

 46:4,11

Red (2)

 14:23,23

refer (3)

 29:3,5;50:16

referred (6)

 13:22;15:19;31:2;

 48:21;50:20;56:16

referring (3)

 15:6;18:6;45:24

reflecting (1)

 18:11

reflects (3)

 9:9;14:9;56:10

regarding (5)

 33:4;36:5,5;45:23;

 53:21

regards (5)

 9:25;20:13;22:12,

 24;31:17

registered (2)

 16:7,10

relevance (1)

 24:19

religion (19)

 22:3,5;29:1,11,14,

 15,17;30:9,14,20,22,

 25;32:11,13,15;

 37:14;44:25;51:1;

 52:23

religious (41)

 33:16,17,19,20;

 34:6,11,25;35:2,9;

 36:10;37:19;38:4,24;

 39:2,16;43:2,6,10,14,

 18;44:10,13,16,19,

 23;51:22;52:10,14;

 53:2,7,11,13,15;

 54:11,17,24;56:4,21;

 58:3,23;59:18

Remains (1)

 21:21

remember (9)

 7:4,23;14:13,23;

 15:1,3;23:3;25:11;

 49:25

removed (2)

 41:11,25

repeat (3)

 9:16;28:10;41:1

Reporter (8)

 5:3,14;8:15;28:13,

 15;44:2,5;54:4

represent (2)

 5:8;10:1

representative (2)

 19:17,20

represented (2)

 10:5;40:2

request (3)

 19:23,25;21:3

requested (3)

 13:3;28:14;44:4

requesting (1)

 9:22

research (1)

 26:2

resided (10)

 22:20;23:9,18;

 24:2,14;25:19;37:18;

 38:3,15,19

residency (1)

 26:3

resident (1)

 26:2

resignation (1)

 21:1

respond (4)

 36:20;37:8;38:23;

 56:7

responds (1)

 34:4

response (1)

 8:13

responsible (1)

 49:12

review (2)

 47:25;48:16

reviewed (3)

 6:12;7:7,12

right (9)

 12:14;13:23,24;

 15:10,12;19:6;29:7;

 36:3;39:11

rights (1)

 10:7

rituals (1)

 33:13

Robert (8)

 24:24;25:13,15,21,

 22;26:5,11,20

role (3)

 31:8;50:3;51:9

rules (1)

 24:21

run (1)

 20:11

running (1)

 25:6

S

safety (1)

 48:24

same (12)

 13:17;23:19;40:17,

 19,20,23;41:8;42:12,

 20,25;48:18;56:3

same-sex (1)

 57:9

Satan (28)

 32:12;33:25;34:4,

 7,19;35:5;36:16,17,

 18,20,20,21;37:6,7,8,

 9;38:21,21,22,23;

 41:13,21;44:10;56:5,

 6;58:6,23;59:19

Satanic (160)

 8:2,6,12,19;9:23;

 10:10,13;11:4,8,17,

 22;12:4,19;13:21,25;

 14:3,6,10,11,19,19;

 15:24,25;16:2,6,7,12;

 18:7,9,12;19:10;

 20:1;21:10,15,17,22;

 22:8,11,13,19;23:8,

 11,17;24:10,14;

 25:19;26:12,21,24;

 27:2,5,8,11,14,17,20,

 23;28:3,7,18,24;

Min-U-Script® Griffin Group International

602.264.2230

(6) photo - Satanic

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 69 of 319
The Satanic Temple and Michelle Shortt v.

City of Scottsdale, Arizona, by it City Council

By Michelle Shortt 30(b)(6) of Adversarial Truth, LLC

September 26, 2019

 29:16;31:7,9;32:3,6,

 10;33:1,16,20;34:3,6,

 11,25;35:2,9;37:3,17,

 19;38:2,4,14,16,19;

 39:2,3,16,17,21,24;

 40:1,8;41:4,14,20,22;

 42:3,13,14,20,22;

 43:1,2,6,10,14,18,24,

 25;44:8;46:5,12,17;

 47:2,3,5,8,9,11,19;

 49:14;50:2,4,24,24;

 51:3,10;52:9,12,22,

 25;53:2,5,10,18,22,

 22;54:17;55:21,25;

 56:3,11,15,19,21,23,

 25;57:3,7,9,16,19,22;

 58:3,13;59:7,16,17,

 22,25

Satanism (10)

 22:6;29:11;30:8;

 31:2;34:20,21;53:10,

 21;58:19,22

Satanist (8)

 10:6;21:18;30:4,6;

 32:5,18,25;33:11

Satanists (4)

 10:2;33:5,12,14

saw (1)

 48:9

saying (3)

 18:1;29:13;34:19

scattered (1)

 23:1

Scot (1)

 5:7

Scottsdale (13)

 5:9;9:13,19;12:25;

 13:4,7;19:18,20;

 20:4;22:2;25:20;

 26:6;37:13

Second (1)

 37:1

section (1)

 19:9

seeing (2)

 7:11,19

seeking (2)

 19:18;22:1

seem (1)

 7:4

sense (1)

 50:7

sent (1)

 40:2

September (1)

 43:10

services (3)

 57:23,25;59:23

set (1)

 51:17

setting (1)

 10:24

seven (13)

 23:1,25;39:6,7;

 40:7,17;41:3;46:20;

 51:6,18,20;59:1,20

sexuality (1)

 31:17

short (4)

 15:13;35:20;45:18;

 52:3

SHORTT (4)

 5:1,7;15:18;45:21

show (3)

 21:22;31:16;54:11

showing (1)

 36:7

sign (7)

 10:13,15;12:17;

 14:22;15:3;47:25;

 48:19

signature (1)

 12:14

signed (6)

 12:21;13:18;16:5;

 17:13,14;18:7

significant (1)

 40:1

signing (2)

 14:24;16:4

similarly (1)

 28:23

sincerely (2)

 51:21;54:11

singer (1)

 21:20

single (1)

 10:20

six (2)

 28:21;46:20

sociopolitical (3)

 30:22,25;31:3

Soleng (5)

 31:18,20,23,24;

 32:2

somebody (1)

 49:24

someone (2)

 47:7,8

someone's (1)

 47:2

sometime (1)

 15:4

sorry (8)

 14:15;25:10;30:5;

 32:22;38:12;39:12,

 19;49:25

sought (4)

 12:24;20:5;43:22;

 44:24

source (1)

 45:4

speak (7)

 5:3;10:6,23;11:1;

 12:4;22:11;31:16

speaking (2)

 9:25;20:13

speeches (1)

 53:14

sphere (1)

 36:13

spoken (3)

 11:4;31:20;32:2

spokesperson (10)

 9:23;10:9;11:8,22;

 21:19;26:3;31:10;

 57:15,19;59:17

standing (1)

 52:17

started (4)

 48:6;51:2,3,4

starting (1)

 31:15

starts (1)

 57:3

state (2)

 23:18;24:15

stated (1)

 16:9

statements (1)

 7:12

states (1)

 57:19

statutory (4)

 20:12,25;21:4,7

still (10)

 22:18;23:19;31:10;

 35:25;41:22;45:21;

 47:15,16;51:15;58:1

stood (1)

 11:18

stopped (2)

 59:18,20

story (6)

 35:16,17;36:2,3,3;

 57:1

Stratford (1)

 25:1

Strike (2)

 30:5;48:12

structure (1)

 13:11

Stu (7)

 17:3;20:12,25;

 25:12,16;27:22;

 49:23

subchapter (1)

 16:2

submitted (2)

 19:22,24

subordinate (2)

 36:18;56:6

summer (1)

 15:5

supernatural (7)

 33:25;36:12;37:6;

 38:21;56:5;58:24;

 59:19

support (1)

 57:9

supports (2)

 57:3,7

Sure (10)

 9:17;11:16;15:9;

 16:18;25:5;28:11,13;

 33:11;41:2;48:11

sworn (1)

 5:2

T

tab (3)

 9:4;11:13;18:22

tabbed (1)

 5:15

taboo (1)

 31:17

tabs (1)

 5:16

talk (1)

 50:16

talking (1)

 20:10

talks (1)

 53:21

telling (1)

 30:7

Temple (154)

 8:2,6,12,19;9:23;

 10:10,13;11:4,8,17,

 22;12:4,20;13:21;

 14:1,3,6,10,11,19,20;

 15:25,25;16:2,6,7,12;

 18:8,9,12;19:10;

 20:2;21:10,16,17,22;

 22:8,12,13,20;23:8,

 17;24:10,14;25:19;

 26:12,21,24;27:2,5,8,

 11,14,17,20,23;28:3,

 7,18,24;29:16;31:8,9;

 32:3,6;33:1,16,20;

 34:3,7,11,25;35:3,9;

 37:3,18,19;38:2,4,14,

 16,19;39:2,4,16,17,

 21,24;40:8;41:4,14,

 20,22;42:4,13,14,21,

 22;43:1,2,6,10,14,18,

 24,25;44:8;46:5,12,

 17;47:2,3,5,9,11,19;

 49:14;50:2,5,24;51:3,

 10;52:9,12,23,25;

 53:2,5,10,18,22;

 54:17;55:21,25;56:3,

 11,16,19,21,23,25;

 57:3,7,10,16,19,22;

 58:3,13;59:7,16,17,

 22,25

Temple's (2)

 50:24;53:22

ten (2)

 23:1,21

tenet (10)

 40:1,11,13,16,20,

 23;41:5,13,19,22

tenets (36)

 39:3,6,6,20,24,25;

 40:4,7,17,18,23;41:3,

 4;42:3,3,13,13,20,21,

 25;43:5,9,13,17;51:6,

 7,11,17,18,21;54:25;

 56:22;58:3;59:1,2,20

Testament (2)

 53:10,21

testified (10)

 5:4;11:3,19;14:4;

 22:16;40:22;41:2;

 45:22;52:7;53:16

testify (14)

 23:4,6;24:9;26:16,

 19;28:5;31:25;33:3;

 37:22;38:1,13;43:21;

 48:17;59:4

testimony (3)

 36:4;55:4,7

Texas (1)

 58:6

theistic (1)

 44:24

thesatanictemplecom (1)

 55:11

third (2)

 11:19;57:2

though (4)

 11:24;18:21;38:8;

 59:14

thought (3)

 7:13;25:12;40:15

three (3)

 10:17,17;57:2

throughout (1)

 23:2

thus (2)

 36:12;57:8

times (1)

 58:2

Titled (1)

 55:25

today (4)

 16:14;20:9;22:16;

 48:17

together (1)

 53:7

told (2)

 21:22;36:1

took (2)

 23:3;59:10

top (2)

 19:3;42:16

Topic (1)

 24:8

topics (4)

 6:3,5,9;31:17

touring (1)

 21:21

track (1)

Min-U-Script® Griffin Group International

602.264.2230

(7) Satanism - track

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 70 of 319
The Satanic Temple and Michelle Shortt v.

City of Scottsdale, Arizona, by it City Council

By Michelle Shortt 30(b)(6) of Adversarial Truth, LLC

September 26, 2019

 22:21

trauma (1)

 30:9

Treiber (1)

 25:2

tried (2)

 21:7;48:10

true (11)

 29:12;32:17,19,23;

 33:2;47:1,3;57:20;

 58:11,15,16

truth (17)

 5:3,4,18;6:5;8:18,

 21;9:6,15,21;19:19,

 25;20:6,8,16;46:3,8;

 48:13

try (2)

 34:18;49:7

trying (5)

 13:6;20:24;25:10;

 32:10,14

Tucson (3)

 23:1,22;46:25

turn (5)

 5:14;6:1,1;20:19;

 34:9

twice (1)

 21:9

Twitter (1)

 59:10

two (1)

 57:2

typo (2)

 21:5;40:13

typos (1)

 41:10

U

umbrellaed (1)

 16:11

unaware (1)

 28:23

under (35)

 11:15,20;13:13;

 16:6,8,10,11,11;23:4;

 26:16,19;28:5;29:25;

 33:3;35:25;36:4,4;

 37:22;38:1,13;39:13;

 41:2;43:21;45:21;

 52:7,24;53:1;55:7,14,

 17,20,22;56:13;57:2;

 59:4

United (8)

 15:24;16:8,15;

 17:12;18:23;30:13;

 48:12;50:2

universe (5)

 34:1;36:16;37:6;

 38:22;56:5

unsaid (1)

 10:16

unspoken (1)

 11:3

up (1)

 41:10

upcoming (1)

 31:14

update (1)

 19:15

upon (5)

 31:25;37:19;38:4;

 47:2,10

use (4)

 6:18;26:7,8;34:18

used (1)

 29:14

usually (2)

 33:9;49:7

V

value (1)

 59:10

values (1)

 57:11

vests (1)

 10:8

vetted (1)

 48:24

vetting (5)

 47:22;48:21,22;

 49:2,12

view (1)

 29:17

views (3)

 36:10;37:14;53:2

Vital (1)

 21:21

vocal (3)

 33:10,12,12

volunteered (2)

 25:25;26:6

W

Wait (2)

 39:11;54:4

Warner (1)

 21:18

way (4)

 10:16;11:2;34:22;

 36:22

ways (1)

 54:10

Web (1)

 55:10

website (16)

 11:11;18:23;19:1,

 10,15;21:16;34:20,

 23;35:14;42:7,8,9;

 50:24;55:11;56:19;

 59:6

weekly (1)

 57:23

Westboro (2)

 52:14;56:11

what's (3)

 25:9;51:18;54:1

who's (1)

 49:1

whose (2)

 43:22;59:15

wisdom (2)

 36:17;37:7

wish (1)

 18:19

within (2)

 10:6,18

witness (10)

 5:2;17:1,5,6;25:8;

 28:16;44:6;50:13,22;

 51:20

word (1)

 29:16

wordage (1)

 41:10

words (2)

 41:9;57:3

working (2)

 13:13;46:15

works (2)

 22:10,18

world (2)

 29:17;36:15

Wright (1)

 5:8

written (4)

 10:8;31:22;48:4,7

wrong (1)

 17:21

wwwthesatanictemplecom (4)

 18:24;34:10;36:8;

 42:9

Y

year (6)

 15:2;21:14;26:13;

 28:2;36:9;48:7

Yesterday (2)

 6:14,15

York (2)

 53:6;58:14

Z

Zarzycki (1)

 25:9

zeal (2)

 30:15,20

0

08/10/2016 (1)

 18:11

1

1 (8)

 19:2,4,9,11;29:22;

 39:18;55:16;58:5

10 (7)

 7:2;14:20;15:20;

 16:17;17:14;58:15,

 22

10:22 (1)

 15:13

10:25 (1)

 15:14

10:50 (1)

 35:20

10:54 (1)

 35:21

10th (1)

 12:23

11 (2)

 26:8;28:21

11:09 (1)

 45:18

11:16 (1)

 45:19

11:25 (1)

 52:3

11:32 (1)

 52:4

12 (3)

 43:18,24;54:25

13 (1)

 28:8

14 (1)

 9:10

15 (1)

 38:11

16 (3)

 39:23;41:20;42:2

17 (13)

 24:1,4;25:4;37:5,

 10,20;38:5,11;54:16;

 56:12,20;57:1,16

17th (1)

 37:1

1st (1)

 19:8

2

2 (3)

 29:22;39:16,18

20 (1)

 42:23

2013 (23)

 28:7;35:3,11;

 38:11,16;39:24;

 41:20;42:15,23;43:3,

 7,11,15,19,24;54:25;

 56:12,20;57:1,16;

 58:11,15,22

2014 (11)

 36:9;37:2,5,10,20;

 38:5,11;54:16;55:11,

 17,22

2015 (1)

 28:4

2016 (52)

 9:13;11:4,18;

 12:16,21,23;13:22;

 14:7,12,20;15:20;

 16:17;17:14;18:5;

 19:2,4,9,11;21:11,25;

 22:8,14,20,25;23:10,

 16;24:2,11,15;25:20;

 32:16,16,23,24;33:5;

 37:18;38:3,15,20;

 43:23;44:14,17;46:2,

 7,8,10,18;47:14,16;

 49:11,11,18

2017 (5)

 8:25;9:2,10;19:5;

 38:17

2018 (4)

 7:2;12:15;29:11;

 44:20

21 (1)

 55:11

22 (1)

 43:3

24 (1)

 44:20

24th (1)

 8:25

26 (7)

 9:3,4,4,7;20:20,21;

 42:15

27 (6)

 34:9,14;35:1,10;

 36:10;37:15

28 (7)

 39:10,15;40:17,18;

 41:5,19;42:2

3

3 (4)

 6:1;29:23;39:18;

 43:14

32 (2)

 11:13,13

3rd (1)

 9:1

4

4 (3)

 29:25;39:18;43:10

40 (2)

 18:22,22

47 (3)

 6:17,19;56:22

48 (9)

 6:21,22,25;7:1,3,7;

 8:3,6;29:20

49 (10)

 35:22;36:1,7,11;

 37:15,20;54:13;55:4;

Min-U-Script® Griffin Group International

602.264.2230

(8) trauma - 49

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 71 of 319
The Satanic Temple and Michelle Shortt v.

City of Scottsdale, Arizona, by it City Council

By Michelle Shortt 30(b)(6) of Adversarial Truth, LLC

September 26, 2019

 56:22;59:5

5

5 (5)

 24:8;39:18;41:12,

 19;43:6

50 (3)

 15:15,21;16:1

51 (6)

 35:22;42:12;50:19;

 52:8;53:17;59:5

52 (1)

 42:20

53 (1)

 42:25

54 (1)

 43:5

55 (2)

 43:9;46:6

56 (1)

 43:13

57 (10)

 35:22;43:17;50:19;

 52:9;53:17;54:20,22;

 55:4;56:23;59:5

58 (11)

 54:2,6,21;55:9,19,

 20;56:10;58:1,5,18;

 59:14

6

6 (5)

 32:16;39:18;44:17;

 49:11;58:11

6th (3)

 32:24;55:16,22

7

7 (1)

 24:1

8

8 (17)

 5:15,17,25;6:1,2,

 10,13;32:16;38:15;

 43:23;44:14;46:7,7,

 10;47:13,16;49:17

8th (19)

 9:13;21:11,25;

 22:8,14,20,25;23:10,

 16;24:2,11,15;25:20;

 32:23;33:5;37:18;

 38:3,20;49:11

9

9 (2)

 40:10,16

Min-U-Script® Griffin Group International

602.264.2230

(9) 5 - 9

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 72 of 319
EXHIBIT B

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 73 of 319
 Atkinson-Baker, Inc.

 www.depo.com

 September 24, 2019 

 30(b)(6): Douglas Misicko

1

1 UNITED STATES DISTRICT COURT

2 DISTRICT OF ARIZONA

3 Case No. CV 18-00621-PHX-DGC

4 --------------------------------x 

5 THE SATANIC TEMPLE and MICHELLE : 

6 SHORTT, : 

7 Plaintiffs, : 

8 vs. : 

9 CITY OF SCOTTSDALE, ARIZONA, by : 

10 its City Council, consisting of : Volume I

11 the Mayor and council members, : Pages 1 to 59

12 (Caption continued on following page)

13

14 RULE 30(b)(6) TELEPHONIC DEPOSITION OF THE 

15 SATANIC TEMPLE INC. BY AND THROUGH DOUGLAS 

16 ALEXANDER MISICKO

17 conducted at Spaces Newbury 

18 359 Newbury Street, Boston, Massachusetts 

19 on Tuesday, September 24, 2019 

20 commencing 9:50 AM and ending 11:09 AM 

21 reported by

22 Lawrence A. Brown, CSR, RPR and Notary Public

23 ATKINSON-BAKER, INC.

24 (800) 288-3376 - www.depo.com

25 ABI File Number AD08F98

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 74 of 319
 Atkinson-Baker, Inc.

 www.depo.com

 September 24, 2019 

 30(b)(6): Douglas Misicko

2

1 (Caption continued from preceding page)

2 WJ Jim Layne, Suzanne Klapp, : 

3 Virginia Korte, Kathy : 

4 Littlefield, Guy Phillips, and : 

5 David Smith, : 

6 Defendants. : 

7 --------------------------------x 

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 75 of 319
 Atkinson-Baker, Inc.

 www.depo.com

 September 24, 2019 

 30(b)(6): Douglas Misicko

3

1 APPEARANCES OF COUNSEL

2

3 KEZHAYA LAW PLC

4 by Attorney Matthew A. Kezhaya (via telephone)

5 1202 Northeast McClain Road

6 Bentonville, Arkansas 72712

7 479.431.6112 - matt@kezhaya.law

8 for the Plaintiffs

9

10 DICKINSON WRIGHT PLLC

11 by Attorney Scot L. Claus

12 1850 North Central Avenue, Suite 1400

13 Phoenix, Arizona 85004-4568

14 602.285.5000 - sclaus@dickinsonwright.com

15 for the Defendants

16

17

18

19

20

21

22

23

24

25

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 76 of 319
 Atkinson-Baker, Inc.

 www.depo.com

 September 24, 2019 

 30(b)(6): Douglas Misicko

4

1 I N D E X

2

3 EXAMINATION OF DOUGLAS ALEXANDER MISICKO

4 DIRECT CROSS REDIRECT RECROSS

5 by Mr. Claus 6

6 by Mr. Tezhaya 56

7

8 E X H I B I T S

9

10 NUMBER DESCRIPTION FIRST MENTION

11

12 6 Notice of 30(b)(6) deposition 6

13 18 Articles of organization for The Satanic 

14 Temple 8

15 19 Articles of amendment for The Satanic 

16 Temple 8

17 20 Annual report filed May 24, 2019 16

18 21 Annual report filed May 24, 2019 20

19 22 Certificate of change of address of 

20 resident agent 21

21 23 Print-out of search of United States 

22 Patent & Trademark Office Trademark 

23 Electronic Search System 26

24 24 Trademark registration, October 30, 2018 28

25 25 Trademark registration, October 30, 2018 29

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 77 of 319
 Atkinson-Baker, Inc.

 www.depo.com

 September 24, 2019 

 30(b)(6): Douglas Misicko

5

1 E X H I B I T S

2

3 NUMBER DESCRIPTION FIRST MENTION

4

5 31 Web site membership page 41

6 32 Web site membership page 42

7 34 Archive Web site of The Satanic Temple 38

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24 Original exhibits attached to transcript original 

25 Binder of unused exhibits returned to Mr. Claus

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 78 of 319
 Atkinson-Baker, Inc.

 www.depo.com

 September 24, 2019 

 30(b)(6): Douglas Misicko

6

1 P R O C E E D I N G S

2

3 (Witness sworn.)

4 

5 DOUGLAS ALEXANDER MISICKO,

6 a witness called by Counsel for the Defendant, 

7 having identified himself by means of his United 

8 States of America Passport Card and having been 

9 duly sworn by the Notary Public, was questioned 

10 and testified as follows:

11

12 DIRECT EXAMINATION BY MR. CLAUS: 

13 Q Mr. Misicko, my name is Scot Claus at 

14 Dickinson Wright Law Firm. I represent the City 

15 of Scottsdale. Good morning. 

16 A Good morning. 

17 Q If you could turn, please, to Exhibit 6, 

18 tab 6. As we explained off the record, each of 

19 the deposition exhibits corresponds with a tab. 

20 We won't get through all of the exhibits today. 

21 We'll mark them for identification so then we can 

22 use them in subsequent depositions. 

23 Tab 6, Exhibit 6, is the notice of 

24 30(b)(6) deposition of The Satanic Temple Inc. 

25 Do you see that? 

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 79 of 319
 Atkinson-Baker, Inc.

 www.depo.com

 September 24, 2019 

 30(b)(6): Douglas Misicko

7

1 A This 30(b)(6) --

2 Q All right. 

3 A -- yeah. I see that, yes. 

4 Q Okay. Now turn, please, to Exhibit A to 

5 Exhibit 6. It's the fourth page in. 

6 (Pause.)

7 Q Exhibit A is the list of topics for which 

8 you have been designated as the designee of The 

9 Satanic Temple Inc. Have you reviewed Exhibit A 

10 to Exhibit 6 before? 

11 A Exhibit A to Exhibit 6? 

12 Q Correct. Those two sheets you're looking 

13 at right now. Have you seen those before? 

14 A Yes. 

15 Q When was the first time you saw those? 

16 A Yesterday. 

17 Q Okay. Do you agree that you're the 

18 representative of The Satanic Temple Inc. most 

19 knowledgeable to talk about the topics on Exhibit 

20 A to Exhibit 6? 

21 A I do. 

22 Q Do you know when The Satanic Temple Inc. 

23 was first organized as a corporate entity? 

24 A Month, I'm not sure. 2017. 

25 Q If you could turn to tab 18, which is 

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 80 of 319
 Atkinson-Baker, Inc.

 www.depo.com

 September 24, 2019 

 30(b)(6): Douglas Misicko

8

1 Exhibit 18. 

2 (Pause.)

3 A Okay. 

4 Q Now, Exhibit 18 constitutes the articles 

5 of organization for an entity called The Satanic 

6 Temple. Do you see that? 

7 A Yes. 

8 Q When The Satanic Temple was organized as a 

9 corporate entity on November 14, 2007, it did not 

10 include "Inc." in its name. Is that correct? 

11 A In Article I it says "The exact name of 

12 the corporation is The Satanic Temple."

13 Q Could you -- Is it accurate -- 

14 If you'd turn to Exhibit 19. 

15 A Yes. 

16 Q -- that in May -- on May 24, 2019 articles 

17 of amendment were filed for The Satanic Temple 

18 changing the exact name of the corporation to The 

19 Satanic Temple Inc.? 

20 A Correct. "The Satanic Temple Inc.," 

21 Article I, is what this page says. 

22 Q And reading the text, do you see in the 

23 middle there are words after -- the bold words 

24 that say "do hereby certify that these Articles 

25 of Amendment"? Do you see that language? 

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 81 of 319
 Atkinson-Baker, Inc.

 www.depo.com

 September 24, 2019 

 30(b)(6): Douglas Misicko

9

1 There's a check under Article I -- or an X next 

2 to Article I. See that? 

3 A "Do hereby certify" --

4 Q Yeah. 

5 A -- "that these Articles of Amendment" -- 

6 Q And the -- 

7 A -- "affecting articles numbered."

8 Okay. Yeah. I see -- 

9 Q And then there's a text box below that. 

10 Do you see that? 

11 A Oh, for "the Articles of Organization" --

12 Q Yes. 

13 A -- "were duly adopted." Okay. 

14 Q Yeah. Read that to yourself, and let me 

15 know when you're done, just that text box. 

16 (Pause.)

17 A Okay. 

18 Q You are identified as the president of The 

19 Satanic Temple Inc. in Exhibit 19? 

20 A Correct. 

21 Q And you are identified as the clerk of The 

22 Satanic Temple Inc. in Exhibit 19. True? 

23 A Correct. Yeah. 

24 Q And reading the actual text of that text 

25 box, it looks like you held a -- the -- the 

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 82 of 319
 Atkinson-Baker, Inc.

 www.depo.com

 September 24, 2019 

 30(b)(6): Douglas Misicko

10

1 president and the clerk held a meeting on May 23, 

2 2019 and that by a vote of one decided to amend 

3 the articles of incorporation. Is that right? 

4 A Correct. 

5 Q And if you'd turn to Exhibit 2 -- or -- 

6 I'm sorry. Strike that. 

7 If you'd turn to page 2 of Exhibit 19. 

8 A Is it this one we're on? 

9 Q Same -- Same tab -- 

10 A All right. 

11 Q -- page 2. 

12 That you, as the clerk, signed Exhibit 19 

13 under penalties of perjury. Is that correct? 

14 A Correct. 

15 Q Also as the president, slash, vice 

16 president. True? 

17 A Yeah. 

18 Q And you stated under penalty of perjury 

19 when you filed Exhibit 19 with the Commonwealth 

20 of Massachusetts that at least two thirds of the 

21 members, slash, directors -- I'm reading from 

22 that text box again on page 1 -- legally 

23 qualified to vote in the meetings of the 

24 corporation made the decision to amend the 

25 articles of organization. True? 

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 83 of 319
 Atkinson-Baker, Inc.

 www.depo.com

 September 24, 2019 

 30(b)(6): Douglas Misicko

11

1 A Yes. Correct. 

2 Q And so mathematically you would agree with 

3 me that only one member could comprise at least 

4 two thirds of the legally qualified members. 

5 True? 

6 A Well, now, this was a discussion between 

7 me and Malcolm Jarry. We're the only two. So I 

8 mean we both knew we were doing it and both 

9 approved it with the lawyer we were working with. 

10 So that would be 100 percent really. 

11 Q Okay. Well, the -- the document that you 

12 filed, Exhibit 19, with the Commonwealth of 

13 Massachusetts under penalty of perjury states 

14 that there was a vote of one. Correct? 

15 A Yeah. I would just say that's incorrect. 

16 I mean Malcolm was not unaware of this -- of -- 

17 that this process was taking place. We were both 

18 in agreement so that was -- I'm not sure why it's 

19 filed that way. 

20 Q Okay. So there were -- as of May 24, 2019 

21 there were two members or directors qualified to 

22 vote in meetings of the corporation? 

23 A Correct. Yeah. 

24 Q Were -- Have there ever been more than two 

25 directors of the corporation identified in 

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 84 of 319
 Atkinson-Baker, Inc.

 www.depo.com

 September 24, 2019 

 30(b)(6): Douglas Misicko

12

1 Exhibit 19 qualified to vote on corporate 

2 matters? 

3 A There have not. 

4 Q As the legally -- As one of the legally 

5 qualified members of The Satanic Temple Inc., 

6 have you ever asked to give an invocation before 

7 a City of Scottsdale Council meeting? 

8 A As -- As president or director of --

9 Q Satanic Temple. 

10 A -- Satanic Temple? 

11 Q Mm-hmm. 

12 A I have not. 

13 Q But do you know, as the Rule 30(b)(6) 

14 designee of The Satanic Temple Inc. today, if the 

15 person you identify as Malcolm Jarry has ever 

16 requested to give an invocation before the City 

17 of Scottsdale Council meeting? 

18 A To my knowledge, he has not. 

19 Q Turning back to Exhibit 18, which is tab 

20 18 --

21 A Okay. 

22 Q -- the entity reflected in Exhibit 18, 

23 which changed its name to The Satanic Temple Inc. 

24 in 2019, did not exist as an entity until 

25 November 14, 2017. Is that right? 

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 85 of 319
 Atkinson-Baker, Inc.

 www.depo.com

 September 24, 2019 

 30(b)(6): Douglas Misicko

13

1 A I actually don't know how you phrase that 

2 in -- in legal terminology. I mean The Satanic 

3 Temple as an organization existed and as a DBA 

4 LLC existed, but The Satanic Temple Inc., you 

5 know, didn't exist on paper until -- until this 

6 paperwork of 2017. 

7 Q Right. And so the -- the corporation The 

8 Satanic Temple Inc. did not become organized 

9 under the laws of the state of Massachusetts 

10 until November 2017. Correct? 

11 A Right. The Satanic Temple Inc.

12 Q Had The Satanic Temple Inc. ever been 

13 incorporated in a state other than Massachusetts? 

14 A No. 

15 Q Had The Satanic Temple Inc. ever been 

16 incorporated in a jurisdiction outside of the 

17 United States? 

18 A No. 

19 Q You mentioned an LLC, and we'll -- we'll 

20 talk about the -- the relationship between -- The 

21 LLC you referred to is the United Federation of 

22 Churches LLC? 

23 A Yeah. Right. 

24 Q Has The Satanic Temple Inc. ever owned a 

25 membership interest in the United Federation of 

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 86 of 319
 Atkinson-Baker, Inc.

 www.depo.com

 September 24, 2019 

 30(b)(6): Douglas Misicko

14

1 Churches LLC? 

2 A A membership interest? 

3 Q Yes. 

4 A I'm not -- I'm not sure how that would 

5 work. I mean this is kind of set up through 

6 lawyers so -- and we asked them what the best 

7 process is, and I'm not necessarily aware of the 

8 terminology or the -- the -- I mean that said, 

9 I'm still the best person to answer to this, but 

10 I -- I didn't necessarily do the -- you know, do 

11 the template set-up and that kind of thing so 

12 I -- 

13 Q Sure. 

14 A So you -- I -- I might need that qualified 

15 a little bit. 

16 Q Well, I can -- you are the designee to 

17 answer questions and be knowledgeable about the 

18 relationship, if any, between and/or amongst the 

19 United Federation of Churches LLC, The Satanic 

20 Temple Inc., Adversarial Truth LLC and Michelle 

21 Shortt. 

22 A Right. 

23 Q I'm reading from number 11 of Exhibit A to 

24 Exhibit 6. 

25 Is that correct? 

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 87 of 319
 Atkinson-Baker, Inc.

 www.depo.com

 September 24, 2019 

 30(b)(6): Douglas Misicko

15

1 A Yeah. Yeah. 

2 Q Okay. So one of the questions that I have 

3 about the relationship, if any exists, is whether 

4 The Satanic Temple Inc. owns a membership 

5 interest in the United Federation of Churches -- 

6 the United Federation of Churches LLC now. 

7 A I -- I don't -- I don't know what that 

8 means. 

9 Q Okay. Do you know that a limited 

10 liability company has members? 

11 A Yes. 

12 Q Do you know if The Satanic Temple Inc. is 

13 a member of the United Federation of Churches 

14 LLC? 

15 A I know I'm a -- I'm a member, and -- and 

16 Malcolm Jarry is the managing member. I know 

17 that's the terminology for that. 

18 Q Okay. So then using, I suppose, the -- 

19 using elimination, then, if Malcolm Jarry is a 

20 member and you are a member, do you know if there 

21 are any other members of the United Federation of 

22 Churches of LL -- United Federation of Churches 

23 LLC now? 

24 A No. 

25 Q Okay. So if you are a member, Malcolm 

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 88 of 319
 Atkinson-Baker, Inc.

 www.depo.com

 September 24, 2019 

 30(b)(6): Douglas Misicko

16

1 Jarry is a member and there are no other members, 

2 then one can deduce that The Satanic Temple Inc. 

3 is not a member of the United Federation of 

4 Churches LLC. Correct? 

5 A Yeah. As a discrete entity it's not 

6 listed as a -- as a member on the documentation. 

7 Q Has the United Federation of Churches LLC 

8 ever been managed by anyone other than -- Strike 

9 that. 

10 Has the United Federation of Churches LLC 

11 ever been managed by The Satanic Temple Inc.? 

12 A Managed by Satanic Temple Inc. I don't 

13 think that that's the arrangement laid out --

14 Q Okay. 

15 A -- but -- 

16 Q Did The Satanic Temple Inc., after it was 

17 formed in 2017, fail to file annual reports on a 

18 yearly basis? 

19 A The Satanic Temple Inc.? 

20 Q Yes. 

21 A No, not that I'm -- not that I'm aware of. 

22 Q If you'd turn to tab 20. Tab 20, Exhibit 

23 20, is a filing with the Commonwealth of 

24 Massachusetts Secretary of the Commonwealth that 

25 has a filing date of May 24, 2019 at 1:24 PM, if 

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1 you look up at the top, the very top of the page, 

2 very top centered. 

3 A Oh, here (indicating)? 

4 Q Yeah. 

5 A Okay. Yeah. Gotcha. 

6 Q But it is an annual report that states it 

7 is a -- it is a filing for November 1 of 2017. 

8 Do you see that? 

9 A Yes. 

10 Q Do you know why the -- And -- And we know 

11 that as of November 1, 2017 The Satanic Temple 

12 Inc. didn't exist yet as a corporate entity. 

13 Correct? 

14 A When did it say it existed? 

15 Q If you could turn back to Exhibit 18. 

16 November 14, 2017. 

17 A I'm sorry. Which exhibit? 

18 Q 18. 

19 A 18. Okay. 

20 (Pause.)

21 A So November 14 -- Okay. Yeah. 

22 Q Do you know why the annual report -- 

23 MR. KEZHAYA: I'm going to object on this 

24 question. 

25 MR. CLAUS: You can object to form. 

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1 That's all you can say. 

2 MR. KEZHAYA: Actually under Rule 30 I can 

3 object to not just form question but also -- 

4 (The reporter requested audible speech.)

5 MR. KEZHAYA: In addition to objection to 

6 form, you can also object to questions outside 

7 the scope of discovery as expressly ordered by 

8 the court. If you look at document 55, the court 

9 orders limited discovery on the issue of subject 

10 matter jurisdiction -- 

11 MR. CLAUS: This has to do with -- 

12 MR. KEZHAYA: -- shall be completed by 

13 9/27. 

14 MR. CLAUS: Okay. You made your record. 

15 MR. KEZHAYA: So it's outside the issue of 

16 standing. 

17 MR. CLAUS: Okay. So -- 

18 (The reporter requested single voices.) 

19 MR. KEZHAYA: So as I was saying, in 

20 addition to objecting on the basis of limiting it 

21 to the issues that the judge has already ordered, 

22 you can also instruct the deponent not to answer. 

23 So I'm not objecting on the issue of form. I'm 

24 objecting that the judge has already decided this 

25 issue. This is outside the issue of standing. 

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1 MR. CLAUS: It is not outside the issue of 

2 subject matter jurisdiction, and it is a -- it is 

3 a foundational question to ask further questions. 

4 If you're really going to ask the -- the -- 

5 you're really going to instruct the witness not 

6 to answer, then you really don't understand the 

7 Federal Rules of Civil Procedure as they're 

8 enforced in Arizona and -- 

9 MR. KEZHAYA: Help me understand. Help me 

10 understand how this relates to standing. 

11 MR. CLAUS: It relates to standing because 

12 it doesn't -- the question about whether -- 

13 asking him why the report was filed, if the 

14 annual reports are not filed, the corporation 

15 becomes delinquent. If the corporation becomes 

16 delinquent, the corporate charter can be revoked. 

17 If the corporate charter is revoked, the 

18 corporation doesn't have the power to do 

19 anything. So these are all foundational 

20 questions to ask him if the corporate charter has 

21 ever been revoked and when. 

22 MR. KEZHAYA: Okay. 

23 MR. CLAUS: So -- 

24 MR. KEZHAYA: I'll withdraw the -- 

25 MR. CLAUS: Thank you. 

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1 Q So do you know why Exhibit 20 was filed in 

2 May 2019 reflecting an annual report for a filing 

3 of November 1, 2017? 

4 A No, I do not know. 

5 Q Exhibit 20 identifies you as the 

6 president, treasurer, clerk and director. 

7 Correct? 

8 A Correct. 

9 Q Does not identify anyone named Malcolm 

10 Jarry as an officer or director of the 

11 corporation? 

12 A I'm sorry. Which -- Which exhibit? 

13 Q Exhibit 20. 

14 A 20. 

15 (Pause.)

16 A Correct. 

17 Q Has Malcolm Jarry ever been a director or 

18 officer of The Satanic Temple Inc.? 

19 A Yes. It was my understanding that he was 

20 actually supposed to be listed as treasurer and 

21 director, and I'm president and clerk. That's -- 

22 I -- I don't know why this paperwork says 

23 otherwise, but that was the understanding I had 

24 with him. 

25 Q If you'd turn to Exhibit 21, please, 

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1 Exhibit 21 also has a filing date of May 24, 

2 2019. Do you see that at the top? 

3 A Yes. 

4 Q Exhibit 21 is an annual report that has a 

5 filing for November 1, 2018 identified in Exhibit 

6 21. Do you see that? 

7 A Yes. 

8 Q And again you are identified as the only 

9 officer and director of the corporation. Do you 

10 see that? 

11 A Yes. 

12 Q Exhibit 22. Exhibit 22 is a certificate 

13 of change of address of the resident agent where 

14 you as the resident agent identify a new address 

15 for the resident agent. Do you see that? 

16 A Yes. 

17 Q Has there ever been a resident agent of 

18 The Satanic Temple Inc. other than you? 

19 A I don't believe so. It would have -- only 

20 would -- The only other person would have been 

21 Malcolm. 

22 Q Has the corporate charter for the 

23 corporation identified in Exhibits 18 through 22, 

24 The Satanic Temple Inc., ever been suspended? 

25 A Has not. 

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1 Q Has the corporate charter for The Satanic 

2 Temple Inc. ever been revoked? 

3 A It has not. 

4 Q If you could go back to Exhibit 18, 

5 please. 

6 (Pause.)

7 Q Do you see how there are centered 

8 headings, "Article I," "Article II," Article 

9 Roman numeral III -- 

10 A Yes. 

11 Q -- article Roman -- 

12 I want you to please read the text under 

13 Article Roman numeral III to yourself and just 

14 let me know when you're done. 

15 (Pause.)

16 A Okay. 

17 Q Does The Satanic Temple Inc. have by-laws? 

18 A Yes. 

19 Q Have you reviewed the by-laws of The 

20 Satanic Temple Inc. to prepare for this 

21 deposition? 

22 A Briefly, yes. 

23 Q Do the by-laws authorize anyone other than 

24 the officers and directors of The Satanic Temple 

25 Inc. to act as its agent in corporate matters? 

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1 A It -- It -- The by-laws authorize us to 

2 authorize other people to perform duties on our 

3 behalf. 

4 Q All right. And when you say "us," are you 

5 referring to yourself and Malcolm Jarry? 

6 A Correct. 

7 Q Is Malcolm Jarry a fake name too? 

8 A It's a pseudonym. 

9 Q For Steven Soling? 

10 A Cevin. 

11 Q For Cevin Soling? 

12 A Yeah, with a C. 

13 Q Oh. I didn't know that was Cevin. Okay. 

14 A Yeah, that wasn't artistic license. His 

15 parents actually gave that -- 

16 Q Yeah, my mom couldn't spell either. I got 

17 one T in my name. 

18 Do you know if The Satanic Temple Inc. 

19 owns any shares in any other corporation? 

20 A To my knowledge, absolutely not. 

21 Q Okay. Has Michelle Shortt ever been an 

22 officer of The Satanic Temple Inc.? 

23 A An officer. I mean you'll have to help me 

24 out on the terminology because there's those -- 

25 you know, on -- on the papers obviously she's not 

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1 listed as anything, but inside -- I mean if you 

2 want to call those informal relationships -- we 

3 authorize and designate people for all manner of 

4 tasks. 

5 Q No. I want to know if Michelle Shortt has 

6 ever held a position as an officer of the 

7 corporation The Satanic Temple Inc.

8 A No. 

9 Q Has Michelle Shortt ever held a position 

10 as a director of The Satanic Temple Inc.? 

11 A No. 

12 Q Do you know if The Satanic Temple Inc. has 

13 ever filed articles of merger with the 

14 Commonwealth of Massachusetts? 

15 A Like merging with another corporation? 

16 Q Or another entity. 

17 A No, not that I -- not that I know of. 

18 Q Has -- 

19 A No, I don't -- I don't think there's ever 

20 been a merger with like United Federation of 

21 Churches -- 

22 (The reporter requested audible speech.)

23 Q Has The Satanic Temple Inc. ever filed 

24 articles of consolidation with another entity? 

25 A No. 

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1 Q Is it true that The Satanic Temple Inc. 

2 has never registered as a foreign corporation 

3 authorized to transact business in the State of 

4 Arizona? 

5 A As a foreign corporation authorized to 

6 transact in the State of Arizona. To my 

7 knowledge, I -- I didn't know that that's a -- 

8 that that's a thing, honestly. I -- I thought 

9 that when we incorporated where we are, we are 

10 authorized to operate anywhere within the US. 

11 That could be incorrect, though. 

12 Q Has The Satanic Temple Inc. ever filed a 

13 document with the Arizona Corporation Commission? 

14 A Not that I -- Not that I'm aware of, no. 

15 Q Has The Satanic Temple Inc. ever filed a 

16 document with the Arizona Secretary of State? 

17 A Not to my knowledge, no. 

18 Q Have any copyrights been assigned to The 

19 Satanic Temple Inc.? 

20 A Copyrights, yes. 

21 Q What copyrights? 

22 A We copyright our logo, our name, and I 

23 don't know what other proprietary stuff that 

24 comes from our licensing agreements with the 

25 various chapters. 

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1 Q Has The Satanic Temple Inc. been granted 

2 an assignment as -- or -- Strike that -- been 

3 granted a license as a licensee of any federally 

4 registered trademarks? 

5 A A licensee of federally registered 

6 trademarks. I believe so. I kind of lose the -- 

7 the distinction sometimes between copyright and 

8 trademark. I know we're in the middle of 

9 trademarking my own pseudonym, Lucien Greaves, 

10 because there's imposter accounts that show 

11 up trying to pull illuminati scams from Nigeria 

12 in my name, get people to give them money for 

13 membership or whatever. And I don't know -- 

14 That's the one trademark effort I know is in 

15 process for sure. As for other trademark, I'm 

16 not -- I'm not certain. 

17 Q If you'd turn to tab 23, please. 

18 A 23. Okay. 

19 Q Tab 23, Exhibit 23, is a print-out of a 

20 search of the United States Patent & Trademark 

21 Office Trademark Electronic Search System, and it 

22 reflects an application for the word mark "The 

23 Satanic Temple." Do you see under the owner who 

24 the applicant is? 

25 A "Owner/applicant United Federation of 

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1 Churches LLC DBA The Satanic Temple Inc. Limited 

2 Liability Company."

3 Q Yeah. So the applicant for the trademark 

4 in Exhibit 23 appears to be the United Federation 

5 of Churches LLC. And this application was filed, 

6 if you look at the filing date, it was, either 

7 coincidentally or not, filed on May 24, 2019, the 

8 same date as all those annual reports that we 

9 looked at previously. Do you see that under 

10 "Filing Date"? 

11 A Sorry. Oh, okay. Yeah, I see that. 

12 Q And the attorney of record is Brendan 

13 Durrigan? 

14 A Correct. Yeah. Brendan. 

15 Q And the application that is reflected in 

16 Exhibit 23 for The Satanic Temple reflects a date 

17 of first use in commerce of -- if you look under 

18 "Goods and Services" here (indicating) --

19 A Yes. 

20 Q -- of January 1, 2013. That's 20130101. 

21 Do you see that? 

22 A Yeah. Yes. 

23 Q That date, January 1, 2013, predated the 

24 existence of The Satanic Temple Inc. as a 

25 corporate entity. Correct? 

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1 A Correct. 

2 Q Okay. If you'd turn to Exhibit 24. 

3 A Wait. We're on -- Oh, no. That's the 

4 next one. 

5 Q Tab 24, Exhibit 24. 

6 A Yeah. 

7 Q Exhibit 24 is for the word and design mark 

8 "TST" plus design, and this is actually a 

9 registered trademark with a registration date of 

10 October 30, 2018, if you look at the last line. 

11 A I see it. 

12 Q You see that? 

13 A Yeah. 

14 Q And if you turn to the next page of 

15 Exhibit 24 --

16 A Yes. 

17 Q -- at the very top line is the owner 

18 identified the registrant as the United 

19 Federation of Churches Limited Liability Company. 

20 Do you see that? 

21 A Yes. 

22 Q So one of my questions is has The Satanic 

23 Temple Inc. as a corporate entity ever received a 

24 license to use the trademark reflected in Exhibit 

25 24? 

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1 A Well, I don't -- I don't know if formally 

2 on paper we did that. I mean I am -- I am the 

3 best person to answer these questions. 

4 However -- I mean I'm the best representative of 

5 this company to answer these questions, but this 

6 is Brendan's work, you know, and -- and how this 

7 was done by him wasn't necessarily something I 

8 kept close watch over. So it's kind of -- kind 

9 of new to me as we go through it. 

10 Q Okay. Turn to Exhibit 25, which is tab 

11 25. 

12 A Oh, Exhibit -- Gotcha. 

13 Q Exhibit 25 is another trademark 

14 registration with a date of registration of 

15 February 10, 2015. Do you see that (indicating) 

16 under "Registration Date"? 

17 A Yes. 

18 Q And it is for the word mark "The Satanic 

19 Temple." Do you see that? 

20 A Correct. 

21 Q And if you look -- Do you see the -- the 

22 heading (indicating) "Goods and Services"? 

23 A Goods and services. 

24 Q Right there (indicating). 

25 A Oh, yeah. Yeah. Sorry. 

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1 Q "Goods and Services." The goods and 

2 services designed to be covered by this mark are, 

3 quote, religious services, namely information and 

4 news relating to religious and philosophical 

5 beliefs by providing information, providing a Web 

6 site featuring information about religion, 

7 charitable outreach services, namely providing 

8 counseling services in the field of religion, 

9 counseling in the field of religion and spiritual 

10 services. 

11 Did I read that correctly? 

12 A Correct. 

13 Q With an alleged date of first use of 

14 January 1, 2013. Do you see that? 

15 A I see that, yes. 

16 Q And again if you look at the owner 

17 identified in Exhibit 25 of that trademark for 

18 those goods and services, the owner is identified 

19 as United Federation of Churches LLC DBA The 

20 Satanic Temple. Do you see that? 

21 A I see that, yes. 

22 Q With the 519 Somerville Avenue address, 

23 number 288. Correct? 

24 A Oh, correct. Yes. 

25 Q Has the trademark identified in Exhibit 25 

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1 ever been licensed for use to The Satanic Temple 

2 Inc.? 

3 A That I do not know. 

4 Q Have the trademarks identified in Exhibits 

5 24 and 25 ever been assigned to The Satanic 

6 Temple Inc.? 

7 A Not that I'm aware of. 

8 (Pause.)

9 Q Does The Satanic Temple Inc. currently own 

10 or operate any top level domain names for the use 

11 it -- for Web sites? 

12 A What do you mean by "top level"? 

13 Q Top level domain level is a -- is a domain 

14 name with an I can [phonetic] suffix like .com, 

15 .biz, .net. 

16 I'll ask it a different way --

17 A Okay. 

18 Q -- to make it easier for you. 

19 A Sure. Sure. 

20 Q Does The Satanic Temple Inc., the 

21 corporation, own the Web site -- Strike that. 

22 Does The Satanic Temple Inc., the 

23 corporation, own the domain name 

24 www.thesatanictemple.com? 

25 A To be honest, I don't know who registered 

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1 thesatanictemple.com. I just know we have that 

2 back-end access and for all intents and purposes 

3 own it and use it to conduct business. 

4 Q That domain name was registered prior to 

5 the existence of The Satanic Temple Inc. as a 

6 corporate entity. Correct? 

7 A That is correct. Yeah. 

8 Q And the Web site that is utilized through 

9 that domain name address has existed prior to the 

10 incorporation of The Satanic Temple Inc. 

11 Correct? 

12 A It -- It in fact preceded my own 

13 involvement with it. 

14 Q Is there any written agreement through 

15 which the owner of thesatanic -- 

16 www.satanictemple.com [sic] has conferred use of 

17 that domain name on The Satanic Temple Inc.? 

18 A I have no written documentation, but I'm 

19 certain we could procure an affidavit. 

20 Q Is there any corporate relationship 

21 between The Satanic Temple Inc. and the United 

22 Federation of Churches LLC? 

23 A Any -- I'm sorry. 

24 Q It's all right. 

25 A Say -- Say again. 

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1 Q Is there any corporate relationship 

2 between the United Federation of Churches LLC and 

3 The Satanic Temple Inc.? 

4 A That's difficult for me to -- to answer 

5 because I -- you know, I -- I don't know if 

6 there's that kind of paperwork connection, but 

7 the -- the fact of the matter is is we -- we put 

8 these structures in place after the fact to -- to 

9 formalize and support something that was already 

10 in operation. Right? So I don't know if it was 

11 the best procedurally, but for all intents and 

12 purposes our activities are the same, were the 

13 same, whether they were -- whether they were DBA 

14 United Federation of Churches or The Satanic 

15 Temple Inc. The Satanic Temple Inc. was somewhat 

16 necessitated by our recognition by the IRS as 

17 a -- as a tax-exempt religious organization. 

18 Q The United Federation of Churches LLC is 

19 not a tax-exempt religious organization. Is that 

20 correct? 

21 MR. KEZHAYA: I object. 

22 MR. CLAUS: All right. I can ask him in 

23 the next deposition. That's fine. 

24 MR. KEZHAYA: Okay. 

25 Q Do you know if The Satanic Temple Inc. has 

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1 any written agreements with the United Federation 

2 of Churches LLC? 

3 A Not that I -- Not that I know of. I don't 

4 think there's formal paperwork --

5 Q Okay. 

6 A -- elucidating that. 

7 Q Let -- Let me ask it a different way. 

8 Do you know if there is any corporate 

9 relationship between the United Federation of 

10 Churches LLC and The Satanic Temple Inc.? 

11 A I'm not trying to play dumb here, but 

12 you're going to have to explain to me what 

13 "corporate relationship" means in this -- 

14 Q Well, I don't, and I probably can't. 

15 So -- So it's not -- I'm not asking you to play 

16 dumb. I'm really asking you if you have 

17 knowledge. And if you don't, then -- then -- 

18 then that's the answer. 

19 Do you have knowledge of any corporate 

20 relationship between The Satanic Temple Inc. and 

21 any other entity? 

22 A Well, from my perspective they're 

23 completely inter-related because they're part of 

24 the -- part of the paperwork process that 

25 formalized one continuous entity. Right? 

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1 And it -- And it consists of the same people. As 

2 far as documentation that might say, you know, we 

3 have an agreement between one and the other, I 

4 can't name such documentation. 

5 Q Has The Satanic Temple Inc. ever attempted 

6 to gain recognition by the Internal Revenue 

7 Service of the United States for tax-exempt 

8 treatment? 

9 A The Satanic Temple Inc., my understanding 

10 is, is the formal -- is just the formal corporate 

11 paperwork for the tax-exempt religious entity 

12 known as The Satanic Temple. 

13 Q And my question is has The Satanic Temple 

14 Inc. ever sought to extend that tax-exempt status 

15 to the United Federation of Churches LLC? 

16 A No. No, not to my knowledge. 

17 Q Is the -- Does The Satanic Temple Inc. 

18 have any relationship with an entity called 

19 Adversarial Truth LLC? 

20 A Well, there again the relationship, if 

21 you're asking for -- for paperwork 

22 documentation -- 

23 Q That's what I'm asking for. 

24 A Okay. That I -- I do -- I'm not aware of 

25 which documents would formalize that. 

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1 (Pause.)

2 Q So let's go back to Exhibit 18. 

3 A Okay. 

4 Q Exhibit 18 states that the corporation The 

5 Satanic Temple is organized as a tax-exempt 

6 organization for religious purposes. Do you see 

7 that? 

8 A Yes. 

9 Q What is the religion promoted by the 

10 corporation identified in Exhibit 18? 

11 A Satanism. 

12 Q So accurately characterized, Satanism is 

13 the religion, not The Satanic Temple. Correct? 

14 A Satanism is the religion of The Satanic 

15 Temple. 

16 Q Got it. 

17 I made you a copy of the first amended 

18 complaint. It's not going to be an exhibit. 

19 A Okay. 

20 Q At least it shouldn't be, but it's -- I 

21 made you a copy. 

22 (Document handed to the witness.)

23 MR. CLAUS: So he's taking a look at the 

24 first amended complaint, Matt. 

25 MR. KEZHAYA: Yeah. Hold on one second. 

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1 I got to pull that up and -- 

2 MR. CLAUS: Sure. No problem. 

3 MR. KEZHAYA: That's document 57. Right? 

4 MR. CLAUS: Correct. 

5 MR. KEZHAYA: Yeah. Okay. 

6 Q If you look at paragraph 1 -- It's on page 

7 2 -- 

8 A Okay. 

9 Q -- of the first amended complaint. 

10 A "Explanatory Note"? 

11 Q Yes. 

12 A Okay. 

13 Q Paragraph 1 states that "Principally this 

14 amendment adds the various juristic bodies which 

15 at various times have given an organizational 

16 structure to the voluntary association of 

17 self-identified Satanists practicing under the 

18 moniker 'The Satanic Temple.'" 

19 Did I read that correctly? 

20 A Correct. 

21 Q Is it accurate to say that one does not 

22 need to be a practicing Satanist to become a 

23 member of The Satanic Temple? 

24 A Well, one -- Yeah, I mean I guess that 

25 depends on whether one considers somebody who 

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1 adheres to our tenets a practicing Satanist. So 

2 I -- I would. So then I mean in that regard we 

3 do require that people read and agree with the 

4 tenets before they sign up as a member. 

5 Q Let's use the date range of February 8, 

6 2016 to July 6 of 2016. Between those dates 

7 wasn't it the -- the mission statement of The 

8 Satanic Temple that it, quote, facilitates 

9 the communication and mobilization of politically 

10 aware Satanists, comma, secularists, comma, and 

11 advocates for individual liberty? 

12 A Correct. 

13 Q Let's just take a look, for instance, at 

14 Exhibit 34. 

15 A Okay. 

16 MR. KEZHAYA: Can we pause one second as I 

17 look for that? 

18 MR. CLAUS: Sure. 

19 MR. KEZHAYA: I think I may have gotten 

20 only up to thirty -- Okay. 

21 All right. I'm on it. 

22 MR. CLAUS: Thank you. 

23 Q Are you familiar with something called the 

24 Internet Wayback Machine? 

25 A Yes. 

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1 Q This is an archive Web site from September 

2 7 of 2015 of The Satanic Temple, and that -- that 

3 preceded the existence of The Satanic Temple Inc. 

4 as a corporate entity. Correct? 

5 A Correct. 

6 Q Do you see how it says "Our mission, The 

7 Satanic Temple (TST) facilitates the 

8 communication and mobilization of politically 

9 aware Satanists, secularists and advocates for 

10 individual liberty"? 

11 (Mr. Claus indicated.)

12 A Oh. 

13 MR. KEZHAYA: Did you say 34? 

14 MR. CLAUS: 34. 

15 THE WITNESS: It's on the side bar. 

16 MR. KEZHAYA: Okay. 

17 THE WITNESS: Top. 

18 A Yeah. Correct. Sorry. 

19 Q Correct. 

20 A secularist is different than a Satanist. 

21 Correct? 

22 A Well, a secularist isn't necessarily a 

23 Satanist. 

24 Q Correct. 

25 And one who advocates for individual 

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1 liberty does not necessarily have to be a 

2 Satanist. Correct? 

3 A Correct. 

4 Q So the mission of The Satanic Temple 

5 expressed on the Web site, at least as of 

6 September 7, 2015, was to facilitate 

7 communication and mobilization of Satanists, 

8 comma, secularists, comma, and advocates for 

9 individual liberty. Correct? 

10 A Right. And I would -- I would add anybody 

11 else. Our position is that everybody should have 

12 an equal voice. 

13 Q So one who is a secularist may be served 

14 by the mission of The Satanic Temple. Correct? 

15 A Correct. So long as their secularism is 

16 predicated on the concept of pluralism. 

17 Q And one who advocates for individual 

18 liberty may be served by the mission of The 

19 Satanic Temple. Correct? 

20 A Correct. 

21 Q And membership currently to The Satanic 

22 Temple is open to anyone who is dedicated to 

23 participating in or identifying with the 

24 activities of The Satanic Temple. Correct? 

25 A Correct. 

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1 Q Not merely to those who practice Satanism. 

2 Correct? 

3 A Correct. We don't -- You know, we don't 

4 expect of everybody that they'll openly identify 

5 in that way because it's a -- it can be dangerous 

6 depending on their situation. 

7 Q And that was true -- If you'd turn to 

8 Exhibit 31, which is tab 31. 

9 A I'm going to set this aside (indicating). 

10 Q Okay. 

11 That was true as of February 1, 2016. 

12 True? 

13 A This is what -- You're saying the mission 

14 statement -- 

15 Q Both the mission statement and the fact 

16 that membership is open to anyone who is 

17 dedicated to participating in or identifying with 

18 the activities of The Satanic Temple. 

19 A And you're asking me to confirm that this 

20 is from -- 

21 Q February --

22 A -- February -- 

23 Q -- 1, 2016. 

24 A That's what this designates on this image 

25 from Wayback Machine at the top of the -- 

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1 Q Exhibit 31. 

2 A Okay. And it seems accurate to me. 

3 Q Okay. 

4 A Is that -- 

5 Q Sure. I just want to make sure that -- 

6 that we are clear that as of -- as of February 1, 

7 2016 membership to The Satanic Temple was opening 

8 [sic] to those who dedic -- who were dedicated to 

9 participating in or identifying with the 

10 activities of The Satanic Temple. 

11 A Sure. I -- I mean yes. Sorry. 

12 Q And if you turn to Exhibit 32 -- That's an 

13 archive from July 13, 2016 -- 

14 A I see that. 

15 Q -- the same statement is true, that 

16 membership is open to anyone who is dedicated to 

17 participating in or identifying with the 

18 activities of The Satanic Temple. Correct? 

19 A Right. I mean with the caveat of member 

20 registration that they acknowledge and follow the 

21 tenets of The Satanic Temple. 

22 Q And both in February 2016 and in July 2016 

23 putative members, potential members, were told 

24 that membership in The Satanic Temple does not 

25 grant anyone the authority to act as a 

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1 spokesperson for The Satanic Temple as an 

2 organization. Correct? 

3 A Correct. But it didn't preclude anybody 

4 from that. Membership alone does not give one 

5 the rights to speak on our behalf or act in some 

6 type of licensing arrangement. 

7 Q Currently -- And I'm talking about today, 

8 September 24, 2019 -- does the Satanic Temple 

9 Inc. as a corporate body exercise any oversight 

10 or control over who may be a member of something 

11 called the Arizona Chapter of The Satanic Temple? 

12 A No. That's within the purview of the 

13 Arizona chapter itself. 

14 Q Are you familiar with the National -- 

15 something called the National Council of The 

16 Satanic Temple? 

17 A Yes. They recently changed their name to 

18 International Council. 

19 Q Was the body that was called the National 

20 Council of The Satanic Temple formed by The 

21 Satanic Temple Inc., the corporate body? 

22 A The National Council was formed before 

23 paperwork was filed for Satanic Temple Inc.

24 Q When did the National Council of The 

25 Satanic Temple first exist? 

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1 A That's -- That's difficult. I'm not -- 

2 I'm really bad at this, and that's not something 

3 I looked over before this. So I would say 

4 probably 2015. 

5 MR. CLAUS: Can we take a quick break, 

6 Matt? I think I may be done. 

7 MR. KEZHAYA: Okay. 

8 MR. CLAUS: I just need to use the rest 

9 room. 

10 MR. KEZHAYA: I paused -- I paused the 

11 time -- Oh, do you need to use the rest room? 

12 MR. CLAUS: Yeah. 

13 MR. KEZHAYA: Okay. I'll probably take it 

14 as well. 

15 MR. CLAUS: Thank you. 

16 (Discussion off the record.)

17 (Recess taken.)

18 MR. CLAUS: You're still under oath, 

19 Mr. Misicko. 

20 (Witness gestured.)

21 Q Has The Satanic Temple Inc. ever held a 

22 meeting of the officers and directors -- Strike 

23 that. 

24 Has The Satanic Temple Inc. ever held a 

25 meeting of the directors where a corporate 

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1 resolution was agreed to that authorized anyone 

2 other than you and Mr. Jarry to act as an agent 

3 for The Satanic Temple Inc.? 

4 A Well, I would say yes. And I don't know 

5 if that meets the standard of the kind of formal 

6 corporate relationship you might be looking for 

7 in documentation, but we have meetings all the 

8 time in which we delegate the function of 

9 different agents we work with in the 

10 parameters -- 

11 Q Mm-hmm. 

12 A -- in which they're allowed to speak on 

13 our behalf or act on our behalf, whether they be 

14 public relations representatives, contractors 

15 within a limited scope, National Council in its 

16 function within the organization and the limits 

17 and rights of the various chapters that we -- we 

18 manage. 

19 Q You just said "the various chapters that 

20 we manage." What entity manages the chapters of 

21 The Satanic Temple? 

22 A Well, again I don't think there's a -- I 

23 don't think there's corporate paperwork that 

24 speaks to the chapters. So when I think of The 

25 Satanic Temple, I think of it as this continuous 

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1 entity that exists regardless of whether -- you 

2 know, whether it's under the banner of -- the DBA 

3 for United Federation of Churches. That's -- 

4 That's formal paperwork from where I'm standing. 

5 So the operative functions are -- are kind 

6 of this continuous entity so I think of The 

7 Satanic Temple as this kind of rubric designation 

8 for, you know, these different corporate entities 

9 that popped up as a matter of -- of just the -- 

10 the nature of the formalization process of this 

11 organization itself. 

12 Q Let me ask it a different way that refers 

13 back to an answer that you just gave. 

14 You just used the plural pronoun "we" 

15 manage the chapters --

16 A Yes. 

17 Q -- that spring up. I think you used "pop 

18 up." "We manage the chapters that pop up" is 

19 what you said in answer to a previous question. 

20 And I guess I'm looking for the -- the 

21 variable -- the -- the -- That plural pronoun 

22 "we," I'm trying to find what constitutes that 

23 plural pronoun "we." Is "we" an entity, or is 

24 "we" Mr. Misicko and Mr. Jarry? 

25 A We are The Satanic Temple, and we just 

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1 work with various people who we assign different 

2 functions. I mean I know Mr. Jarry and I have 

3 ultimate veto, and that's understood within the 

4 National Council and things like that. But we do 

5 assign different people status as media liaisons, 

6 chapter heads. And this all -- You know, in my 

7 mind this is all done as The Satanic Temple. 

8 It's not something that's formally designated as 

9 part of the LLC versus The Satanic Temple Inc. 

10 It's just The Satanic Temple. 

11 Q Which is autonomous from the chapters? 

12 A The chapters are -- are subsets of The 

13 Satanic Temple which we try to allow for a 

14 maximum of autonomy while also making certain 

15 that they work within certain parameters so as 

16 not to -- so as not to send the wrong message, 

17 that we're defamed or our brand is otherwise 

18 stained by their -- by their activities. 

19 Q And that brand is the trademark that's 

20 owned by the United Federation of Churches LLC? 

21 A Correct. Right. 

22 Q And so currently -- I'm trying to figure 

23 out currently does The Satanic Temple Inc. as a 

24 corporate body play any role in managing the 

25 chapters of The Satanic Temple as an 

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1 organization? 

2 A Well, I mean obviously it's Malcolm and I 

3 who are like the -- the top heads of management. 

4 Right? And we're also -- we're also owners of 

5 the Satanic Temple Inc., but -- I mean I -- I 

6 hope that's sufficient. I'm not sure. 

7 Q Let me ask it this way: Have you ever 

8 seen an agenda of a meeting of the board of 

9 directors of The Satanic Temple Inc. where a 

10 corporate resolution was an agenda item? 

11 A You mean like specific -- there's a 

12 specific template for paperwork designating these 

13 meeting notes as part of The Satanic Temple Inc. 

14 or -- 

15 Q I'm asking you the question that I'm 

16 asking you and just want to know if the answer is 

17 "Yes, I have," "No, I haven't" or "I don't 

18 understand." 

19 Have you ever seen a document called 

20 "Agenda for the Board of Directors of The Satanic 

21 Temple Inc."? Let's just start there. We'll 

22 start broad. Have you ever seen an agenda for a 

23 meeting of the board of directors of The Satanic 

24 Temple Inc.? 

25 A I have not seen a document with that exact 

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1 wording --

2 Q Okay. 

3 A -- prefacing it. 

4 Q Have you ever seen minutes of a meeting of 

5 the board of directors of The Satanic Temple 

6 Inc.? 

7 A I -- I -- I -- We wouldn't have meeting 

8 minutes that would say, you know, "Formal Agenda 

9 of The Satanic Temple Inc." It would say "The 

10 Satanic Temple" on them, and I'm not sure, you 

11 know, which -- which entity one would insist that 

12 that needs to fit under. 

13 Q I'm going to ask my question again. 

14 Have you ever seen a document that is 

15 called "Minutes of a Meeting of the Board of 

16 Directors of The Satanic Temple, Inc."? 

17 A I -- 

18 MR. KEZHAYA: Objection. Asked and 

19 answered. 

20 Go ahead and answer. 

21 A I cannot say that I've seen a document 

22 with that as the header. 

23 Q Okay. Do you know if the board of 

24 directors of The Satanic Temple Inc. has ever 

25 agendized a meeting at which the topic of a 

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1 corporate resolution to authorize agency of 

2 another has been discussed, moved for and voted 

3 upon by the board of directors? 

4 A Formally designated as a meeting of the 

5 Satanic Temple Inc.? 

6 Q Correct. 

7 A I know of no such meeting. 

8 Q Since its formation in November -- on 

9 November 14, 2017, has Michelle Shortt made any 

10 written request to The Satanic Temple Inc. to act 

11 as its agent? 

12 A Since its incorporation in 2017 --

13 Q Correct. 

14 A -- a formal request to act on behalf of 

15 The Satanic Temple Inc.

16 Q Correct. 

17 A Not to my knowledge has she -- had she 

18 written any -- any such dispatch. 

19 Q Has Michelle Shortt ever been employed as 

20 a statutory employee of The Satanic Temple Inc.? 

21 A She has not. 

22 Q Has Michelle Shortt ever been hired as an 

23 independent contractor of The Satanic Temple 

24 Inc.? 

25 A That's possible, but not to my knowledge. 

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1 Q Is there any written agreement, to your 

2 knowledge, between Michelle Shortt and the 

3 corporation called The Satanic Temple Inc.? 

4 A No. 

5 (Pause.)

6 Q Do you know if the Satanic Temple Inc., as 

7 a corporate entity, has had any communication at 

8 all with any representative of the City of 

9 Scottsdale? 

10 A Not to my knowledge, no. 

11 (Pause.)

12 Q Do you today -- We're talking September 

13 24, 2019 -- as the designee of The Satanic Temple 

14 Inc., know how many members of The Satanic Temple 

15 reside in the State of Arizona? 

16 A Well, I can give you a minimum number. 

17 And the reason it's a minimum number is because 

18 we allow people to sign up by E mail address on 

19 line and we don't ask for address. However, we 

20 have a way to isolate by shipping address who's 

21 ordered membership cards, slash, certificate 

22 packages in a certain -- by mailing address. 

23 Right? 

24 Q Okay. 

25 A So to the -- at this day -- Oh, shit. I'm 

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1 sorry. I only have the -- between February and 

2 April of 2016. 

3 Q Okay. Well, I'll ask you that --

4 A Okay. 

5 Q -- in the next deposition since --

6 A Okay. I'm sorry. 

7 Q Since you didn't -- Since Satanic Temple 

8 didn't exist as of July 2016, I'll ask you that 

9 question in the next deposition. 

10 A Oh, okay. 

11 Q So it's good to have it. 

12 But today do you know how many members of 

13 The Satanic Temple Inc. reside in the State of 

14 Arizona? 

15 A I -- 

16 Q I'm sorry. Strike that. I just said 

17 Satanic Temple Inc. Strike that question. 

18 Today, as the designee of the Satanic 

19 Temple Inc., do you know how many members of The 

20 Satanic Temple reside in the State of Arizona? 

21 A I don't know, but I can give you a minimum 

22 number --

23 Q Okay. 

24 A -- if I check my -- my phone here. A 

25 minimum number of -- 

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1 (Pause.)

2 A -- 450. 

3 Q Do you know today how many of those 

4 members of The Satanic Temple reside in the City 

5 of Scottsdale? 

6 A A minimum number of 27. 

7 Q Do you know, of the 450 members of The 

8 Satanic Temple, Inc. -- or -- Strike that. 

9 Do you know, of the members in Arizona 

10 today, those 450, how many are secularists? 

11 A I assume they're all secularists. 

12 Q But I'm not asking you for your 

13 assumption. Let me ask it a different way. 

14 Do you know, of those 450 today, how many 

15 adhere to the religion of Satanism rather than 

16 being either a secularist who -- whose mission is 

17 served by the Satanic Temple or one who advocates 

18 for individual liberty whose mission is served by 

19 The Satanic Temple? 

20 A I don't see there necessarily being a 

21 distinction with -- with the members. I would 

22 think that, you know, if they agree with our 

23 tenets and they sign up with us, I would see that 

24 they're advancing the cause of Satanism. But as 

25 for their reasons for doing that, I can't -- I 

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1 can't speak to their subjective experience. 

2 Q Well, you just said "advancing the cause 

3 of Satanism," but according to the exhibits that 

4 we looked at, for instance Exhibit 34, the 

5 mission of the Satanic Temple is to facilitate 

6 communication, mobilization of politically aware 

7 Satanists, comma, secularists, comma, and 

8 advocates for individual liberty. Correct? 

9 A Well, correct, but I --

10 Q And -- 

11 A -- I think those are taken together rather 

12 than as -- They're not necessarily separate and 

13 discrete. I mean it has to be taken with the 

14 membership standards that ask that they adhere to 

15 the seven tenets. 

16 Q Well, the membership is open to 

17 individuals who are dedicated to or 

18 participating -- or participating in or 

19 identifying with not Satanism but the activities 

20 of The Satanic Temple. Correct? 

21 A Correct. But the activities include the 

22 practice of Satanism. 

23 Q Or may include secularism or advocating 

24 for individual liberty. Correct? 

25 A Also included. 

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1 Q Do you know -- 

2 MR. KEZHAYA: I'm going to interject. We 

3 just hit that one-hour mark. 

4 MR. CLAUS: Okay. Let me just ask this 

5 question. 

6 Q Do you know if The Satanic Temple Inc. 

7 currently imposes any membership requirements on 

8 members of the Arizona chapter? 

9 A No. That's in the jurisdiction of the 

10 Arizona chapter. 

11 Q Okay. 

12 MR. CLAUS: I don't know if you have any 

13 questions, Matt. 

14 MR. KEZHAYA: I do, but I don't know how 

15 to resolve my questions against the -- the 

16 court's one-hour limit. Are you willing to 

17 afford -- I don't know if by stipulation we could 

18 just agree to two limited topics. 

19 MR. CLAUS: I mean but -- I mean the 

20 stipulation would be conditioned upon my -- my 

21 being able to ask him questions about whatever 

22 you ask him. 

23 MR. KEZHAYA: I'm -- I'm okay with that. 

24 One -- I'll -- I'll tell you what the two topics 

25 are. The first one's going to be -- Pretty well 

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1 already covered -- just fleshing out a little bit 

2 more the number of Satanists and -- TST 

3 Satanists, I should say, the number of TST 

4 Satanists specifically in Scottsdale; and, two, 

5 the -- the contours around, well, what happened 

6 that Michelle Shortt said that she was going to 

7 give an invocation -- 

8 (The reporter requested audible speech.)

9 (Discussion off the record.)

10 MR. CLAUS: Let's go off the record. 

11 MR. KEZHAYA: All right. 

12 (Discussion off the record.)

13 

14 CROSS EXAMINATION BY MR. KEZHAYA: 

15 Q Doug, how do you know this minimum number 

16 of Satanists in -- in Scottsdale? 

17 MR. CLAUS: Form. 

18 Go ahead. 

19 A This -- This minimum number is determined 

20 by the mailing addresses that people gave when 

21 they ordered a membership card, slash, 

22 certificate membership package. I say it's a 

23 minimum number because one doesn't need to 

24 purchase a card and certificate package to be a 

25 member, but the only way in which we get people's 

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1 addresses is if we're actually mailing something 

2 to them. So while we may have many members 

3 within Arizona or within Scottsdale or within any 

4 given space that we just don't know the 

5 geographic location of, we can base a minimum 

6 number on those -- on those mail orders. 

7 Q Is it required -- In order to be a member 

8 of TST, is it required to order a membership 

9 card? 

10 A No, it is not required to order a 

11 membership card to be a member of The Satanic 

12 Temple. 

13 (Pause.)

14 MR. KEZHAYA: Pass the witness. 

15 MR. CLAUS: I don't have any follow-up. 

16 MR. KEZHAYA: Okay. 

17 MR. CLAUS: So read and sign? 

18 MR. KEZHAYA: Yeah, read and sign. I'm 

19 going to use the rest room real quick, and then 

20 I'll be ready for -- for -- for round two here. 

21 Do we want to take a five-minute break? 

22 MR. CLAUS: Yeah. That sounds great. 

23 (The proceedings adjourned at 11:09 AM.)

24

25

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1

2 STATE OF ___________________)

3 ) ss.

4 COUNTY OF __________________)

5

6

7

8 I, DOUGLAS ALEXANDER MISICKO, a witness called to 

9 testify in the matter of SATANIC TEMPLE ET AL. 

10 vs. CITY OF SCOTTSDALE ET AL., do hereby certify 

11 under penalty of perjury that I have read the 

12 foregoing transcript and have made any 

13 corrections, additions or deletions that I was 

14 desirous of making; and that the foregoing is a 

15 true and accurate record of my testimony therein. 

16

17

18 Signed by me on the _____ day of _______________ 

19

20 20 _____ at _________________, _________________.

21 (City) (State)

22

23

24 _________________________________

25 DOUGLAS ALEXANDER MISICKO 

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1 COMMONWEALTH OF MASSACHUSETTS

2 COUNTY OF SUFFOLK

3

4 I, Lawrence A. Brown, Certified Shorthand 

5 Reporter Number 1430F96, Registered Professional 

6 Reporter and Notary Public in and for the 

7 Commonwealth of Massachusetts, do hereby certify 

8 that the foregoing transcript of the proceedings 

9 therein described is a complete and accurate 

10 record of same to my best knowledge and belief 

11 and that the deponent requested review of the 

12 transcript. 

13

14 I further certify that I am not related to 

15 or employed by any party in or counsel to this 

16 matter and that I am not financially interested 

17 in its outcome. 

18

19 In witness whereof, I hereunto set my hand 

20 on the 26th day of September 2019. 

21

22

23 ____________________________________

24 Lawrence A. Brown, Notary Public

25 My commission expires July 2, 2021

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A

ABI 1:25

able 55:21

absolutely 23:20

access 32:2

accounts 26:10

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acknowledge 42:20

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authorize 22:23 23:1,2

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B

B 4:8 5:1

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bar 39:15

base 57:5

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behalf 23:3 43:5 45:13

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Bentonville 3:6

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box 9:9,15,25 10:22

brand 47:17,19

break 44:5 57:21

Brendan 27:12,14

Brendan's 29:6

Briefly 22:22

broad 48:22

Brown 1:22 59:4,24

business 25:3 32:3

by-laws 22:17,19,23

23:1

C

C 6:1 23:12

call 24:2

called 6:6 8:5 35:18

38:23 43:11,15,19

48:19 49:15 51:3 58:8

Caption 1:12 2:1

card 6:8 56:21,24 57:9

57:11

cards 51:21

Case 1:3

cause 53:24 54:2

caveat 42:19

centered 17:2 22:7

Central 3:12

certain 26:16 32:19

47:14,15 51:22

certificate 4:19 21:12

51:21 56:22,24

Certified 59:4

certify 8:24 9:3 58:10

59:7,14

Cevin 23:10,11,13

change 4:19 21:13

changed 12:23 43:17

changing 8:18

chapter 43:11,13 47:6

55:8,10

chapters 25:25 45:17,19

45:20,24 46:15,18

47:11,12,25

characterized 36:12

charitable 30:7

charter 19:16,17,20

21:22 22:1

check 9:1 52:24

Churches 13:22 14:1,19

15:5,6,13,22,22 16:4,7

16:10 24:21 27:1,5

28:19 30:19 32:22

33:2,14,18 34:2,10

35:15 46:3 47:20

City 1:9,10 6:14 12:7,16

51:8 53:4 58:10,21

Civil 19:7

Claus 3:11 4:5 5:25 6:12

6:13 17:25 18:11,14

18:17 19:1,11,23,25

33:22 36:23 37:2,4

38:18,22 39:11,14

44:5,8,12,15,18 55:4

55:12,19 56:10,17

57:15,17,22

clear 42:6

clerk 9:21 10:1,12 20:6

20:21

close 29:8

coincidentally 27:7

com 31:14

comes 25:24

comma 38:10,10 40:8,8

54:7,7

commencing 1:20

commerce 27:17

commission 25:13

59:25

Commonwealth 10:19

11:12 16:23,24 24:14

59:1,7

communication 38:9

39:8 40:7 51:7 54:6

company 15:10 27:2

28:19 29:5

complaint 36:18,24 37:9

complete 59:9

completed 18:12

completely 34:23

comprise 11:3

concept 40:16

conditioned 55:20

conduct 32:3

conducted 1:17

conferred 32:16

confirm 41:19

connection 33:6

considers 37:25

consisting 1:10

consists 35:1

consolidation 24:24

constitutes 8:4 46:22

continued 1:12 2:1

continuous 34:25 45:25

46:6

contours 56:5

contractor 50:23

contractors 45:14

control 43:10

copy 36:17,21

copyright 25:22 26:7

copyrights 25:18,20,21

corporate 7:23 8:9 12:1

17:12 19:16,17,20

21:22 22:1,25 27:25

28:23 32:6,20 33:1

34:8,13,19 35:10 39:4

43:9,21 44:25 45:6,23

46:8 47:24 48:10 50:1

51:7

corporation 8:12,18

10:24 11:22,25 13:7

19:14,15,18 20:11

21:9,23 23:19 24:7,15

25:2,5,13 31:21,23

36:4,10 51:3

correct 7:12 8:10,20

9:20,23 10:4,13,14

11:1,14,23 13:10

14:25 16:4 17:13 20:7

20:8,16 23:6 27:14,25

28:1 29:20 30:12,23

30:24 32:6,7,11 33:20

36:13 37:4,20 38:12

39:4,5,18,19,21,24

40:2,3,9,14,15,19,20

40:24,25 41:2,3 42:18

43:2,3 47:21 50:6,13

50:16 54:8,9,20,21,24

corrections 58:13

correctly 30:11 37:19

corresponds 6:19

council 1:10,11 12:7,17

43:15,18,20,22,24

45:15 47:4

counsel 3:1 6:6 59:15

counseling 30:8,9

COUNTY 58:4 59:2

court 1:1 18:8,8

court's 55:16

covered 30:2 56:1

CROSS 4:4 56:14

CSR 1:22

currently 31:9 40:21

43:7 47:22,23 55:7

CV 1:3

D

D 4:1 6:1

dangerous 41:5

date 16:25 21:1 27:6,8

27:10,16,23 28:9

29:14,16 30:13 38:5

dates 38:6

David 2:5

day 51:25 58:18 59:20

DBA 13:3 27:1 30:19

33:13 46:2

decided 10:2 18:24

decision 10:24

dedic 42:8

dedicated 40:22 41:17

42:8,16 54:17

deduce 16:2

defamed 47:17

Defendant 6:6

Defendants 2:6 3:15

delegate 45:8

deletions 58:13

delinquent 19:15,16

depending 41:6

depends 37:25

deponent 18:22 59:11

deposition 1:14 4:12

6:19,24 22:21 33:23

52:5,9

depositions 6:22

described 59:9

DESCRIPTION 4:10 5:3

design 28:7,8

designate 24:3

designated 7:8 47:8

50:4

designates 41:24

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 September 24, 2019 

 30(b)(6): Douglas Misicko

designating 48:12

designation 46:7

designed 30:2

designee 7:8 12:14

14:16 51:13 52:18

desirous 58:14

determined 56:19

Dickinson 3:10 6:14

different 31:16 34:7

39:20 45:9 46:8,12

47:1,5 53:13

difficult 33:4 44:1

DIRECT 4:4 6:12

director 12:8 20:6,10,17

20:21 21:9 24:10

directors 10:21 11:21,25

22:24 44:22,25 48:9

48:20,23 49:5,16,24

50:3

discovery 18:7,9

discrete 16:5 54:13

discussed 50:2

discussion 11:6 44:16

56:9,12

dispatch 50:18

distinction 26:7 53:21

DISTRICT 1:1,2

document 11:11 18:8

25:13,16 36:22 37:3

48:19,25 49:14,21

documentation 16:6

32:18 35:2,4,22 45:7

documents 35:25

doing 11:8 53:25

domain 31:10,13,13,23

32:4,9,17

Doug 56:15

DOUGLAS 1:15 4:3 6:5

58:8,25

duly 6:9 9:13

dumb 34:11,16

Durrigan 27:13

duties 23:2

E

E 4:1,8 5:1 6:1,1 51:18

easier 31:18

effort 26:14

either 23:16 27:6 53:16

Electronic 4:23 26:21

elimination 15:19

elucidating 34:6

employed 50:19 59:15

employee 50:20

enforced 19:8

entities 46:8

entity 7:23 8:5,9 12:22

12:24 16:5 17:12

24:16,24 27:25 28:23

32:6 34:21,25 35:11

35:18 39:4 45:20 46:1

46:6,23 49:11 51:7

equal 40:12

ET 58:9,10

everybody 40:11 41:4

exact 8:11,18 48:25

EXAMINATION 4:3 6:12

56:14

exercise 43:9

exhibit 6:17,23 7:4,5,7,9

7:10,11,11,19,20 8:1,4

8:14 9:19,22 10:5,7,12

10:19 11:12 12:1,19

12:22 14:23,24 16:22

17:15,17 20:1,5,12,13

20:25 21:1,4,5,12,12

22:4 26:19 27:4,16

28:2,5,7,15,24 29:10

29:12,13 30:17,25

36:2,4,10,18 38:14

41:8 42:1,12 54:4

exhibits 5:24,25 6:19,20

21:23 31:4 54:3

exist 12:24 13:5 17:12

43:25 52:8

existed 13:3,4 17:14

32:9

existence 27:24 32:5

39:3

exists 15:3 46:1

expect 41:4

experience 54:1

expires 59:25

explain 34:12

explained 6:18

Explanatory 37:10

expressed 40:5

expressly 18:7

extend 35:14

F

facilitate 40:6 54:5

facilitates 38:8 39:7

fact 32:12 33:7,8 41:15

fail 16:17

fake 23:7

familiar 38:23 43:14

far 35:2

featuring 30:6

February 29:15 38:5

41:11,21,22 42:6,22

52:1

Federal 19:7

federally 26:3,5

Federation 13:21,25

14:19 15:5,6,13,21,22

16:3,7,10 24:20 26:25

27:4 28:19 30:19

32:22 33:2,14,18 34:1

34:9 35:15 46:3 47:20

field 30:8,9

figure 47:22

file 1:25 16:17

filed 4:17,18 8:17 10:19

11:12,19 19:13,14

20:1 24:13,23 25:12

25:15 27:5,7 43:23

filing 16:23,25 17:7 20:2

21:1,5 27:6,10

financially 59:16

find 46:22

fine 33:23

Firm 6:14

first 4:10 5:3 7:15,23

27:17 30:13 36:17,24

37:9 43:25 55:25

fit 49:12

five-minute 57:21

fleshing 56:1

follow 42:20

follow-up 57:15

following 1:12

follows 6:10

foregoing 58:12,14 59:8

foreign 25:2,5

form 17:25 18:3,6,23

56:17

formal 34:4 35:10,10

45:5 46:4 49:8 50:14

formalization 46:10

formalize 33:9 35:25

formalized 34:25

formally 29:1 47:8 50:4

formation 50:8

formed 16:17 43:20,22

foundational 19:3,19

fourth 7:5

function 45:8,16

functions 46:5 47:2

further 19:3 59:14

G

G 6:1

gain 35:6

geographic 57:5

gestured 44:20

give 12:6,16 26:12 43:4

51:16 52:21 56:7

given 37:15 57:4

go 22:4 29:9 36:2 49:20

56:10,18

going 17:23 19:4,5 34:12

36:18 41:9 49:13 55:2

55:25 56:6 57:19

good 6:15,16 52:11

goods 27:18 29:22,23

30:1,1,18

Gotcha 17:5 29:12

gotten 38:19

grant 42:25

granted 26:1,3

great 57:22

Greaves 26:9

guess 37:24 46:20

Guy 2:4

H

H 4:8 5:1

hand 59:19

handed 36:22

happened 56:5

header 49:22

heading 29:22

headings 22:8

heads 47:6 48:3

held 9:25 10:1 24:6,9

44:21,24

help 19:9,9 23:23

hereunto 59:19

hired 50:22

hit 55:3

Hold 36:25

honest 31:25

honestly 25:8

hope 48:6

I

identification 6:21

identified 6:7 9:18,21

11:25 21:5,8,23 28:18

30:17,18,25 31:4

36:10

identifies 20:5

identify 12:15 20:9 21:14

41:4

identifying 40:23 41:17

42:9,17 54:19

II 22:8

III 22:9,13

illuminati 26:11

image 41:24

imposes 55:7

imposter 26:10

include 8:10 54:21,23

included 54:25

incorporated 13:13,16

25:9

incorporation 10:3

32:10 50:12

incorrect 11:15 25:11

independent 50:23

indicated 39:11

indicating 17:3 27:18

29:15,22,24 41:9

individual 38:11 39:10

39:25 40:9,17 53:18

54:8,24

individuals 54:17

informal 24:2

information 30:3,5,6

inside 24:1

insist 49:11

instance 38:13 54:4

instruct 18:22 19:5

intents 32:2 33:11

inter-related 34:23

interest 13:25 14:2 15:5

interested 59:16

interject 55:2

Internal 35:6

International 43:18

Internet 38:24

invocation 12:6,16 56:7

involvement 32:13

IRS 33:16

isolate 51:20

issue 18:9,15,23,25,25

19:1

issues 18:21

item 48:10

J

January 27:20,23 30:14

Jarry 11:7 12:15 15:16

15:19 16:1 20:10,17

23:5,7 45:2 46:24 47:2

Jim 2:2

judge 18:21,24

July 38:6 42:13,22 52:8

59:25

jurisdiction 13:16 18:10

19:2 55:9

juristic 37:14

K

Kathy 2:3

kept 29:8

Kezhaya 3:3,4 17:23

18:2,5,12,15,19 19:9

19:22,24 33:21,24

36:25 37:3,5 38:16,19

39:13,16 44:7,10,13

49:18 55:2,14,23

56:11,14 57:14,16,18

kind 14:5,11 26:6 29:8,8

33:6 45:5 46:5,7

Klapp 2:2

knew 11:8

know 7:22 9:15 12:13

13:1,5 14:10 15:7,9,12

15:15,16,20 17:10,10

17:22 20:1,4,22 22:14

23:13,18,25 24:5,12

24:17 25:7,23 26:8,13

26:14 29:1,6 31:3,25

32:1 33:5,5,10,25 34:3

34:8 35:2 41:3 45:4

46:2,8 47:2,6 48:16

49:8,11,23 50:7 51:6

51:14 52:12,19,21

53:3,7,9,14,22 55:1,6

55:12,14,17 56:15

57:4

knowledge 12:18 23:20

25:7,17 34:17,19

35:16 50:17,25 51:2

51:10 59:10

knowledgeable 7:19

14:17

known 35:12

Korte 2:3

L

L 3:11

laid 16:13

language 8:25

Law 3:3 6:14

Lawrence 1:22 59:4,24

laws 13:9

lawyer 11:9

lawyers 14:6

Layne 2:2

legal 13:2

legally 10:22 11:4 12:4,4

let's 36:2 38:5,13 48:21

56:10

level 31:10,12,13,13

liability 15:10 27:2 28:19

liaisons 47:5

liberty 38:11 39:10 40:1

40:9,18 53:18 54:8,24

license 23:14 26:3 28:24

licensed 31:1

licensee 26:3,5

licensing 25:24 43:6

limit 55:16

limited 15:9 18:9 27:1

28:19 45:15 55:18

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 134 of 319
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 www.depo.com

 September 24, 2019 

 30(b)(6): Douglas Misicko

limiting 18:20

limits 45:16

line 28:10,17 51:19

list 7:7

listed 16:6 20:20 24:1

little 14:15 56:1

Littlefield 2:4

LLC 13:4,19,21,22 14:1

14:19,20 15:6,14,23

16:4,7,10 27:1,5 30:19

32:22 33:2,18 34:2,10

35:15,19 47:9,20

location 57:5

logo 25:22

long 40:15

look 17:1 18:8 27:6,17

28:10 29:21 30:16

36:23 37:6 38:13,17

looked 27:9 44:3 54:4

looking 7:12 45:6 46:20

looks 9:25

lose 26:6

Lucien 26:9

M

Machine 38:24 41:25

mail 51:18 57:6

mailing 51:22 56:20 57:1

making 47:14 58:14

Malcolm 11:7,16 12:15

15:16,19,25 20:9,17

21:21 23:5,7 48:2

manage 45:18,20 46:15

46:18

managed 16:8,11,12

management 48:3

manages 45:20

managing 15:16 47:24

manner 24:3

mark 6:21 26:22 28:7

29:18 30:2 55:3

Massachusetts 1:18

10:20 11:13 13:9,13

16:24 24:14 59:1,7

mathematically 11:2

Matt 36:24 44:6 55:13

matt@kezhaya.law 3:7

matter 18:10 19:2 33:7

46:9 58:9 59:16

matters 12:2 22:25

Matthew 3:4

maximum 47:14

Mayor 1:11

McClain 3:5

mean 11:8,16 13:2 14:5

14:8 23:23 24:1 29:2,4

31:12 37:24 38:2

42:11,19 47:2 48:2,5

48:11 54:13 55:19,19

means 6:7 15:8 34:13

media 47:5

meeting 10:1 12:7,17

44:22,25 48:8,13,23

49:4,7,15,25 50:4,7

meetings 10:23 11:22

45:7

meets 45:5

member 11:3 15:13,15

15:16,20,20,25 16:1,3

16:6 37:23 38:4 42:19

43:10 56:25 57:7,11

members 1:11 10:21

11:4,21 12:5 15:10,21

16:1 42:23,23 51:14

52:12,19 53:4,7,9,21

55:8 57:2

membership 5:5,6 13:25

14:2 15:4 26:13 40:21

41:16 42:7,16,24 43:4

51:21 54:14,16 55:7

56:21,22 57:8,11

MENTION 4:10 5:3

mentioned 13:19

merely 41:1

merger 24:13,20

merging 24:15

message 47:16

Michelle 1:5 14:20 23:21

24:5,9 50:9,19,22 51:2

56:6

middle 8:23 26:8

mind 47:7

minimum 51:16,17

52:21,25 53:6 56:15

56:19,23 57:5

minutes 49:4,8,15

Misicko 1:16 4:3 6:5,13

44:19 46:24 58:8,25

mission 38:7 39:6 40:4

40:14,18 41:13,15

53:16,18 54:5

Mm-hmm 12:11 45:11

mobilization 38:9 39:8

40:7 54:6

mom 23:16

money 26:12

moniker 37:18

Month 7:24

morning 6:15,16

moved 50:2

N

N 4:1 6:1

name 6:13 8:10,11,18

12:23 23:7,17 25:22

26:12 31:14,23 32:4,9

32:17 35:4 43:17

named 20:9

names 31:10

National 43:14,15,19,22

43:24 45:15 47:4

nature 46:10

necessarily 14:7,10 29:7

39:22 40:1 53:20

54:12

necessitated 33:16

need 14:14 37:22 44:8

44:11 56:23

needs 49:12

net 31:15

never 25:2

new 21:14 29:9

Newbury 1:17,18

news 30:4

Nigeria 26:11

North 3:12

Northeast 3:5

Notary 1:22 6:9 59:6,24

Note 37:10

notes 48:13

notice 4:12 6:23

November 8:9 12:25

13:10 17:7,11,16,21

20:3 21:5 50:8,9

number 1:25 4:10 5:3

14:23 30:23 51:16,17

52:22,25 53:6 56:2,3

56:15,19,23 57:6 59:5

numbered 9:7

numeral 22:9,13

O

O 6:1

oath 44:18

object 17:23,25 18:3,6

33:21

objecting 18:20,23,24

objection 18:5 49:18

obviously 23:25 48:2

October 4:24,25 28:10

Office 4:22 26:21

officer 20:10,18 21:9

23:22,23 24:6

officers 22:24 44:22

Oh 9:11 17:3 23:13

27:11 28:3 29:12,25

30:24 39:12 44:11

51:25 52:10

okay 7:4,17 8:3 9:8,13

9:17 11:11,20 12:21

15:2,9,18,25 16:14

17:5,19,21 18:14,17

19:22 22:16 23:13,21

26:18 27:11 28:2

29:10 31:17 33:24

34:5 35:24 36:3,19

37:5,8,12 38:15,20

39:16 41:10 42:2,3

44:7,13 49:2,23 51:24

52:3,4,6,10,23 55:4,11

55:23 57:16

one's 55:25

one-hour 55:3,16

open 40:22 41:16 42:16

54:16

opening 42:7

openly 41:4

operate 25:10 31:10

operation 33:10

operative 46:5

order 57:7,8,10

ordered 18:7,21 51:21

56:21

orders 18:9 57:6

organization 4:13 8:5

9:11 10:25 13:3 33:17

33:19 36:6 43:2 45:16

46:11 48:1

organizational 37:15

organized 7:23 8:8 13:8

36:5

original 5:24,24

outcome 59:17

outreach 30:7

outside 13:16 18:6,15,25

19:1

oversight 43:9

owned 13:24 47:20

owner 26:23 28:17 30:16

30:18 32:15

Owner/applicant 26:25

owners 48:4

owns 15:4 23:19

P

P 6:1

package 56:22,24

packages 51:22

page 1:12 2:1 5:5,6 7:5

8:21 10:7,11,22 17:1

28:14 37:6

Pages 1:11

paper 13:5 29:2

papers 23:25

paperwork 13:6 20:22

33:6 34:4,24 35:11,21

43:23 45:23 46:4

48:12

paragraph 37:6,13

parameters 45:10 47:15

parents 23:15

part 34:23,24 47:9 48:13

participating 40:23

41:17 42:9,17 54:18

54:18

party 59:15

Pass 57:14

Passport 6:8

Patent 4:22 26:20

pause 7:6 8:2 9:16 17:20

20:15 22:6,15 31:8

36:1 38:16 51:5,11

53:1 57:13

paused 44:10,10

penalties 10:13

penalty 10:18 11:13

58:11

people 23:2 24:3 26:12

35:1 38:3 47:1,5 51:18

56:20

people's 56:25

percent 11:10

perform 23:2

perjury 10:13,18 11:13

58:11

person 12:15 14:9 21:20

29:3

perspective 34:22

Phillips 2:4

philosophical 30:4

Phoenix 3:13

phone 52:24

phonetic 31:14

phrase 13:1

place 11:17 33:8

Plaintiffs 1:7 3:8

play 34:11,15 47:24

PLC 3:3

please 6:17 7:4 20:25

22:5,12 26:17

PLLC 3:10

plural 46:14,21,23

pluralism 40:16

plus 28:8

PM 16:25

politically 38:9 39:8 54:6

pop 46:17,18

popped 46:9

position 24:6,9 40:11

possible 50:25

potential 42:23

power 19:18

practice 41:1 54:22

practicing 37:17,22 38:1

preceded 32:12 39:3

preceding 2:1

preclude 43:3

predated 27:23

predicated 40:16

prefacing 49:3

prepare 22:20

president 9:18 10:1,15

10:16 12:8 20:6,21

Pretty 55:25

previous 46:19

previously 27:9

Principally 37:13

print-out 4:21 26:19

prior 32:4,9

probably 34:14 44:4,13

problem 37:2

procedurally 33:11

Procedure 19:7

proceedings 57:23 59:8

process 11:17 14:7

26:15 34:24 46:10

procure 32:19

Professional 59:5

promoted 36:9

pronoun 46:14,21,23

proprietary 25:23

providing 30:5,5,7

pseudonym 23:8 26:9

public 1:22 6:9 45:14

59:6,24

pull 26:11 37:1

purchase 56:24

purposes 32:2 33:12

36:6

purview 43:12

put 33:7

putative 42:23

Q

qualified 10:23 11:4,21

12:1,5 14:14

question 17:24 18:3

19:3,12 35:13 46:19

48:15 49:13 52:9,17

55:5

questioned 6:9

questions 14:17 15:2

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29:3,5 55:13,15,21

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quote 30:3 38:8

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 30(b)(6): Douglas Misicko

range 38:5

read 9:14 22:12 30:11

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reading 8:22 9:24 10:21

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registration 4:24,25 28:9

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round 57:20

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Rule 1:14 12:13 18:2

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30:20 31:1,5,9,20,22

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33:15,25 34:10,20

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taken 44:17 54:11,13

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33:15,25 34:10,20

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46:7,25 47:7,9,10,13

47:23,25 48:5,9,13,21

48:24 49:5,9,10,16,24

50:5,10,15,20,23 51:3

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testimony 58:15

text 8:22 9:9,15,24,24

10:22 22:12

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32:1

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things 47:4

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45:24,25 46:6,17

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thirds 10:20 11:4

thirty 38:20

thought 25:8

time 7:15 44:11 45:8

times 37:15

today 6:20 12:14 43:7

51:12 52:12,18 53:3

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 136 of 319
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 September 24, 2019 

 30(b)(6): Douglas Misicko

53:10,14

told 42:23

top 17:1,1,2 21:2 28:17

31:10,12,13 39:17

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we'll 6:21 13:19,19 48:21

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words 8:23,23

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yeah 7:3 9:4,8,14,23

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1 1:11 10:22 17:7,11

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2019 1:19 4:17,18 8:16

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29 4:25

3

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Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 137 of 319
EXHIBIT C

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 138 of 319
 Atkinson-Baker, Inc.

 www.depo.com

 September 24, 2019 

 30(b)(6): Douglas Misicko

1

1 UNITED STATES DISTRICT COURT

2 DISTRICT OF ARIZONA

3 Case No. CV 18-00621-PHX-DGC

4 --------------------------------x 

5 THE SATANIC TEMPLE and MICHELLE : 

6 SHORTT, : 

7 Plaintiffs, : 

8 vs. : 

9 CITY OF SCOTTSDALE, ARIZONA, by : 

10 its City Council, consisting of : Volume I

11 the Mayor and council members, : Pages 1 to 83

12 (Caption continued on following page)

13

14 RULE 30(b)(6) TELEPHONIC DEPOSITION OF UNITED 

15 FEDERATION OF CHURCHES LLC BY AND THROUGH

16 DOUGLAS ALEXANDER MISICKO

17 conducted at Spaces Newbury 

18 359 Newbury Street, Boston, Massachusetts 

19 on Tuesday, September 24, 2019 

20 commencing 11:20 AM and ending 1:01 PM 

21 reported by

22 Lawrence A. Brown, CSR, RPR and Notary Public

23 ATKINSON-BAKER, INC.

24 (800) 288-3376 - www.depo.com

25 ABI File Number AD08F98

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 139 of 319
 Atkinson-Baker, Inc.

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 September 24, 2019 

 30(b)(6): Douglas Misicko

2

1 (Caption continued from preceding page)

2 WJ Jim Layne, Suzanne Klapp, : 

3 Virginia Korte, Kathy : 

4 Littlefield, Guy Phillips, and : 

5 David Smith, : 

6 Defendants. : 

7 --------------------------------x 

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 140 of 319
 Atkinson-Baker, Inc.

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 September 24, 2019 

 30(b)(6): Douglas Misicko

3

1 APPEARANCES OF COUNSEL

2

3 KEZHAYA LAW PLC

4 by Attorney Matthew A. Kezhaya (via telephone)

5 1202 Northeast McClain Road

6 Bentonville, Arkansas 72712

7 479.431.6112 - matt@kezhaya.law

8 for the Plaintiffs

9

10 DICKINSON WRIGHT PLLC

11 by Attorney Scot L. Claus

12 1850 North Central Avenue, Suite 1400

13 Phoenix, Arizona 85004-4568

14 602.285.5000 - sclaus@dickinsonwright.com

15 for the Defendants

16

17

18

19

20

21

22

23

24

25

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 141 of 319
 Atkinson-Baker, Inc.

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 September 24, 2019 

 30(b)(6): Douglas Misicko

4

1 I N D E X

2

3 EXAMINATION OF DOUGLAS ALEXANDER MISICKO

4 DIRECT CROSS REDIRECT RECROSS

5 by Mr. Claus 6

6 by Mr. Tezhaya 59

7 by Mr. Claus 68

8 by Mr. Kezhaya 79

9 by Mr. Claus 80

10

11 E X H I B I T S

12

13 NUMBER DESCRIPTION FIRST MENTION

14

15 7 Notice of 30(b)(6) deposition 6

16 10 Certificate of organization 16

17 11 Annual report filed September 12, 2006 18

18 12 Annual report filed September 12, 2006 19

19 13 Annual report filed April 3, 2017 22

20 14 Restated certificate of organization 23

21 15 Certificate of amendment 27

22 16 2019 annual report 28

23 23 Print-out of search of United States 

24 Patent & Trademark Office Trademark 

25 Electronic Search System 29 

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 142 of 319
 Atkinson-Baker, Inc.

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 September 24, 2019 

 30(b)(6): Douglas Misicko

5

1 E X H I B I T S

2

3 NUMBER DESCRIPTION FIRST MENTION

4

5 24 Trademark registration, October 30, 2018 30 

6 25 Trademark registration, October 30, 2018 31 

7 27 Archived Web page from The Satanic Temple 43

8 28 Archived Web page from The Satanic Temple 45

9 37 Archived Web site from February 24, 2015 

10 identifying The Satanic Temple chapters 41

11 40 Archive Web page of The Satanic Temple

12 from February 1, 2016 42

13 42 Web site of The Satanic Temple Arizona 56

14 47 Screenshot of Web page archive from 

15 January 15, 2013 of The Satanic Temple 70

16

17

18

19

20

21

22

23

24 Original exhibits attached to transcript original 

25 Binder of unused exhibits returned to Mr. Claus

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 143 of 319
 Atkinson-Baker, Inc.

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 September 24, 2019 

 30(b)(6): Douglas Misicko

6

1 P R O C E E D I N G S

2

3 (Witness sworn.) 

4 MR. CLAUS: Thank you. 

5 

6 DOUGLAS ALEXANDER MISICKO,

7 a witness called by Counsel for the City 

8 Defendants, having identified himself by means of 

9 his United States of America Passport Card and 

10 having been duly sworn by the Notary Public, was 

11 questioned and testified as follows:

12

13 DIRECT EXAMINATION BY MR. CLAUS: 

14 Q You're going to need your book back -- 

15 A Sure. It's -- It's right here. 

16 Q Great. 

17 Take a look at Exhibit 7. 

18 A Okay. 

19 Q Exhibit 7 is the notice of 30(b)(6) 

20 deposition of the United Federation of Churches 

21 LLC. Do you see that? 

22 A Yes. 

23 Q And please take a look at Exhibit A to 

24 Exhibit 7, which is the list of topics for which 

25 you've been designated as the deponent. Exhibit 

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 144 of 319
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 September 24, 2019 

 30(b)(6): Douglas Misicko

7

1 A to Exhibit 7. 

2 A Okay. Yes. 

3 Q Do you agree that you're the person most 

4 knowledgeable about the topics listed in Exhibit 

5 A of Exhibit 7? 

6 A The most knowledgeable representative of 

7 the company in question. 

8 Q Of the United federation of Churches LLC? 

9 A Correct. Yeah. 

10 Q The United Federation of Churches LLC 

11 still exists as a limited liability company 

12 today. Correct? 

13 A Correct. 

14 Q Let me ask you the question that we 

15 alluded to in the previous deposition. How -- 

16 Oh, do you have your -- 

17 A Yes. 

18 Q -- the complaint there? 

19 A Yeah. 

20 Q The first amended complaint, if you go to 

21 paragraph 10, which is on page 3 -- 

22 A I see it. 

23 Q Just -- Just read paragraph 10 to yourself 

24 and let me know when you're done. 

25 (Pause.)

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 145 of 319
 Atkinson-Baker, Inc.

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 September 24, 2019 

 30(b)(6): Douglas Misicko

8

1 A Okay. 

2 Q Focusing on the last sentence of paragraph 

3 10, is it a true statement that at the times 

4 relevant to the litigation that is framed by the 

5 first amended complaint that The Satanic Temple 

6 was given structure through the United Federation 

7 of Churches LLC? 

8 A The -- The time framed by the first 

9 amended complaint. I'm not sure I know what 

10 frame of time is -- is in question here. You 

11 mean when the -- when this was filed? 

12 Q No. I'm -- So it says -- I'll just read 

13 that last sentence starting on line 3 of page 3, 

14 paragraph 10 of the first amended complaint. 

15 A Okay. 

16 Q "At the times relevant to this litigation 

17 TST," which is defined as The Satanic Temple, 

18 "was given structure through United Federation of 

19 Churches LLC (DBA The Satanic Temple), a 

20 Massachusetts LLC."

21 First did I read that correctly? 

22 A Correct. 

23 Q Is that a true statement, the sentence 

24 that I just read? 

25 A "The Satanic Temple Inc. has been formally 

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1 recognized as a tax-exempt religious 

2 organization" -- 

3 Q No. No. 

4 A "At the times relevant to this litigation, 

5 TST was given structure through United 

6 Federations [sic] of Churches LLC (DBA The 

7 Satanic Temple), a Massachusetts LLC."

8 Q Yeah. And my question is is that a true 

9 statement? 

10 A To the best of my knowledge, that is a 

11 true statement. 

12 Q Okay. Do you know how many members of The 

13 Satanic Temple resided in Scottsdale, Arizona as 

14 of February 8, 2016? 

15 A As of February 8, 2016. I have a 

16 different time frame. I don't have a -- I don't 

17 have a number at a specific date. I have a time 

18 frame of between February and April 2016. 

19 Q Okay. So is the answer to my question 

20 that you do not know how many members of The 

21 Satanic Temple resided in Scottsdale as of 

22 February 8, 2016? 

23 A Correct. I can give you again a minimum 

24 number from a time frame, but I -- I -- I don't 

25 have an exact number given our lack of geographic 

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1 tracking. 

2 Q Well, go to Exhibit 7 again. 

3 A Okay. And -- 

4 Q You're still there. 

5 A Oh, yeah. 

6 Q Exhibit 7. 

7 A Sure. 

8 Q Exhibit A to Exhibit 7. Topic 5 asked for 

9 the designee of the deponent to be knowledgeable 

10 about, quote, the identity and domicile of the 

11 members of the deponent identified in the notice 

12 from February 8, 2016 through July 6, 2016. Do 

13 you see that? 

14 A Yes. 

15 Q Also number 7 asked for a deponent 

16 knowledgeable about the membership operations for 

17 the deponent identified in the notice including 

18 the member on-boarding process, leadership 

19 election, membership fees and uses thereof. Do 

20 you see that? 

21 A Yes. 

22 Q So using topic number 5 in Exhibit A to 

23 Exhibit 7, do you know the identity and domicile 

24 of the members of The Satanic Temple as of 

25 February 8, 2016? 

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1 A No. I know a minimum number of members, 

2 but some of them I've never known their domicile. 

3 Q Okay. Do you know the -- Okay. Do you 

4 know the minimum members as of February 8, 2016? 

5 A February 8 -- Again I have -- I have April 

6 2016. I know the minimum number as of April 

7 2016. 

8 Q Did you do anything to become 

9 knowledgeable about the topics identified in 

10 topic number 5 of Exhibit A to Exhibit 7 to 

11 testify today? 

12 A Yes. 

13 Q Did you do anything to become 

14 knowledgeable about the identity and domicile of 

15 the members of the deponent as of February 8th, 

16 2016? 

17 A As of February 8th, no. I -- I went with 

18 the time frame of February to April 2016. I 

19 thought that's what you were working on. 

20 Q Okay. 

21 (Pause.)

22 MR. CLAUS: Let's go off the record for a 

23 second. 

24 (Pause.)

25 MR. CLAUS: Okay. Let's go back on. 

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1 Q If you look, Sir, at again Exhibit A to 

2 Exhibit 7 --

3 A Okay. 

4 Q -- topic -- topic number 3 provides a -- 

5 an exact and discrete date range of February 8, 

6 2016 to July 6, 2016. Correct? 

7 A Correct. 

8 Q And if you turn the page to number 13, 

9 topic number 13 of Exhibit A to Exhibit 7 

10 provides a discrete and exact date range 

11 from February 8, 2016 to July 6, 2016. Correct? 

12 Number -- You're still on Exhibit 7 -- 

13 A Oh, okay. 

14 Q -- the next page of Exhibit A to Exhibit 

15 7. So turn the page -- 

16 A Correct. Yeah. Yeah. 

17 Q Just turn the page. Topic number 13 

18 identifies an exact and discrete date range of 

19 February 8, 2016 to July 6, 2016. Correct? 

20 A Correct. 

21 Q Okay. So as of February 8, 2016, that 

22 date in the -- in the universe, do you know if 

23 any members of The Satanic Temple resided in 

24 Scottsdale, Arizona as of February 8, 2016? 

25 A I know -- I don't know why my search ended 

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1 up being February to April 2016, but I have a 

2 number -- a minimum number for that time frame. 

3 Q That's not the time -- I'm not asking you 

4 about the time frame. I'm asking you as of 

5 February 8, 2016 do you know if any members of 

6 The Satanic Temple, under penalty of perjury, 

7 resided in the State of Arizona? 

8 A As of February 8th. 

9 Q Correct. 

10 A Okay. No, I can't -- I cannot give you -- 

11 I just can't -- I just don't have a number for an 

12 exact date. I can only do -- 

13 Q Okay. 

14 A We can only do it in time frames. 

15 Q Do you know, under penalty of perjury, if 

16 any members of The Satanic Temple resided in the 

17 City of Scottsdale, Arizona as of February 8, 

18 2016? 

19 A I -- I could not tell you that with 

20 100-percent certainty. 

21 Q Okay. 

22 (Pause.)

23 Q Do you know when the United Federation of 

24 Churches LLC -- Well, let me ask this again, 

25 then: 

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1 Do you know and are you able to testify 

2 under penalty of perjury if any members of The 

3 Satanic Temple resided in the State of Arizona as 

4 of the discrete date July 6, 2016? 

5 A Do I -- Do I know if there were any 

6 members of The Satanic Temple by the date of July 

7 6th --

8 Q Let me ask it again. 

9 A -- 2016 -- 

10 Q Let me ask it again. 

11 A Okay. 

12 Q Do you know, under penalty of perjury, if 

13 any members of The Satanic Temple resided in the 

14 State of Arizona as of the date July 6, 2016? 

15 A Yes. I have a minimum number of 

16 membership in Arizona by that date of 17. 

17 Q And do you know how -- if any members of 

18 The Satanic Temple resided in the City of 

19 Scottsdale, Arizona as of July 6, 2016? 

20 A A minimum number of five. 

21 Q Who? 

22 A That I do not know. 

23 MR. KEZHAYA: Ah --

24 Q Do you know the identity of the members of 

25 The Satanic Temple that resided in the State 

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1 of -- the 17 members that you testified resided 

2 in the State of Arizona as of July 6, 2016? 

3 A Know them. How do you -- Can you --

4 Q Do you know -- 

5 A -- clarify -- 

6 Q Do you know their identity? For instance, 

7 do you know their names? 

8 A Again people often use pseudonyms with us, 

9 and we don't ask that they not. So we would have 

10 the names they gave us and their mailing address. 

11 So that would be sufficient for us for 

12 identification. 

13 Q And the number of members that you 

14 identified as of July 6, 2016 who resided in the 

15 City of Scottsdale, are you using their mailing 

16 address to divine that knowledge? 

17 A I'm sorry. The -- The knowledge of 

18 their -- 

19 Q The knowledge of their -- their residence. 

20 A Correct. Their mailing address is, we 

21 assume, their residence. 

22 Q Got it. 

23 Do you know when the United Federation of 

24 Churches LLC was first organized as an entity? 

25 A 2014. 

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1 Q If you'd turn to Exhibit 10 --

2 A Yes. 

3 Q -- Exhibit 10 is the certificate of 

4 organization for the United Federation of 

5 Churches LLC. Correct? 

6 A Correct. 

7 Q And it identifies -- Exhibit 10 identifies 

8 you as the resident agent of that LLC. Correct? 

9 A Correct. 

10 Q And identifies you as the manager of that 

11 LLC. Correct? 

12 A I -- I don't see the wording "manager."

13 Q Number 6. 

14 A Number 6. Okay. 

15 Q The name and business address -- 

16 A Oh, of each manager. Okay. I gotcha. 

17 Yes. 

18 Q So the articles -- the certificate, 

19 rather, of organization for the United Federation 

20 of Churches LLC identified you as the only 

21 manager when that entity was organized. Correct? 

22 A Correct. 

23 Q Do you recognize the signature on page 2 

24 of Exhibit 10? 

25 A Yes. 

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1 Q Is that your signature? 

2 A It is. 

3 Q Is it accurate to say that Michelle Shortt 

4 has never been identified as a manager of the 

5 United Federation of Churches LLC in any filing 

6 with the Commonwealth of Massachusetts? 

7 A That is accurate. 

8 Q Exhibit 10 identifies the general 

9 character of the business of the United 

10 Federation of Churches LLC. True? 

11 A I'm sorry. What do you mean by "general 

12 character"? 

13 Q Number 3. There is an enumerated line 3 

14 on the first page of Exhibit 10 that has pretyped 

15 "The general character of the business, colon," 

16 and then words are entered by the organizer after 

17 that colon. Do you see that? 

18 A Correct. Yes. 

19 Q And the words entered are "educational 

20 activities and all other lawful purposes"? 

21 A Correct. 

22 Q Exhibit 10 -- Do you see anything in 

23 Exhibit 10 that specifically articulates a 

24 religious purpose to the United Federation of 

25 Churches LLC? 

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1 A I do not. 

2 Q Exhibit 11. Exhibit 11 is a limited 

3 liab -- liability company annual report. Do you 

4 see that? 

5 A I do. 

6 Q Filed on September 12, 2016. Do you see 

7 that? 

8 A Yes. 

9 Q Identifies a different manager of the LLC 

10 as Cevin Soling. Correct? 

11 A Correct. 

12 Q If you turn to the second page of Exhibit 

13 11, do you see the handwritten signature at the 

14 bottom of the page? 

15 A Oh, yes. 

16 Q Do you recognize that signature? 

17 A I don't. 

18 Q Do you recognize that signature to not be 

19 yours? 

20 A I do. 

21 Q Okay. Turn back to page 1 of Exhibit 11. 

22 The annual report is for the year 2015 and still 

23 identifies the general character of the business 

24 as "educational activities and all other lawful 

25 purposes." Correct? 

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1 A Correct. 

2 Q Do you see anything in Exhibit 11 that 

3 specifically articulates a religious purpose to 

4 the limited liability company? 

5 A I do not. 

6 Q Exhibit 12, please. 

7 A Okay. 

8 Q This is a filing of an annual report for 

9 the limited liability company filed the same 

10 date, September 12, 2016. Do you see that? 

11 A Yes. 

12 Q I'm going to ask you the same question 

13 that I asked about The Satanic Temple. Do you 

14 know if the United Federation of Churches LLC was 

15 ever suspended by the Commonwealth of 

16 Massachusetts for failure to file an annual 

17 report on a timely manner? 

18 A No. 

19 Q Do you know if the charter for the United 

20 Federation of Churches LLC was ever revoked by 

21 the secretary of the commonwealth? 

22 A It has not been. 

23 Q Okay. So back to Exhibit 12, Exhibit 12 

24 identifies you as the resident agent of the LLC. 

25 Correct? 

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1 A Correct. 

2 Q Has Michelle Shortt ever been identified 

3 as a resident agent of the United Federation of 

4 Churches LLC? 

5 A She has not. 

6 Q Has anyone other than you ever been 

7 identified as an agent of the limited liability 

8 company identified in Exhibit 12? 

9 A Would not Cevin Soling be considered 

10 identified as an agent from line 6 where it says 

11 "name and business address of each manager"? 

12 Q Mr. Soling is identified as the manager. 

13 I'm asking you under line 5 -- Do you know that a 

14 limited liability company under Massachusetts law 

15 must identify a, quote, resident agent, end 

16 quote? 

17 A My awareness of this is only through this 

18 very paperwork. 

19 Q Okay. Do you know if anyone other than 

20 you has been identified as a resident agent of 

21 the limited liability company identified in 

22 Exhibit 12? And if you don't know, that's fine. 

23 Just tell me. 

24 A Well, I can say with almost certainty that 

25 nobody else has --

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1 Q Okay. 

2 A -- but I will -- I'll offer the caveat 

3 that it would not -- it would also not surprise 

4 me if there were other paperwork in which Cevin 

5 might be listed as a -- as a resident agent --

6 Q Okay. 

7 A -- as well. 

8 Q And the annual report identified in 

9 Exhibit 12 is for the year 2016. True? 

10 A That's correct. 

11 Q And the general character of the business 

12 identified in line 3 of Exhibit 12 is the same as 

13 in the certificate of organization and the prior 

14 annual report, "educational activities and all 

15 other lawful purposes." Correct? 

16 A Correct. 

17 Q Do you see anything in Exhibit 12 that 

18 articulates a religious purpose to the United 

19 Federation of Churches LLC? 

20 A I do not. 

21 Q And let's look at that handwritten 

22 signature on page 2. 

23 A Yes. 

24 Q Do you recognize that signature to not be 

25 your signature? 

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1 A Correct. I recognize that signature to 

2 not be my own. 

3 Q Great. Turn to Exhibit 13, please. 

4 A Okay. 

5 Q Exhibit 13 is the annual report for the 

6 United Federation of Churches LLC filed on April 

7 3, 2017. Do you see that? 

8 A Yes. 

9 Q Identifies you as the resident agent? 

10 A Correct. 

11 Q And identifies Mr. Soling as the manager. 

12 Correct? 

13 A Correct. 

14 Q Identifies the general character of the 

15 business in the same manner as the previous 

16 filings, "educational activities and all other 

17 lawful purposes." Correct? 

18 A Correct. 

19 Q Do you see anything in Exhibit 13 that 

20 identifies a religious purpose to the United 

21 Federation of Churches LLC? 

22 A I do not. 

23 Q And again, if you go to the second page, 

24 there is a handwritten signature. Do you 

25 recognize that signature? 

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1 A I -- I do not. 

2 Q Do you recognize that signature to not be 

3 yours? 

4 A I recognize that signature to not be my 

5 own. 

6 Q Great. 

7 (Pause.)

8 Q If you'd turn to Exhibit 14 -- We've 

9 entered the age of digital filings -- Exhibit 14 

10 is a restated certificate of organization. Do 

11 you see how -- 

12 (Mr. Claus indicated.)

13 A I see that, yes. 

14 Q Filed May 21, 2018? 

15 A It says two thousand -- Oh, okay. This -- 

16 Okay. The date at the top says -- Oh, this is 

17 for the original filing of the original 

18 organization. It says February 4, 2014. 

19 Q Right. And if we --

20 A Okay. 

21 Q -- look back at Exhibit 10, we see that 

22 that is the date of the original filing, February 

23 4, 2014. 

24 A Okay. And this is an annual filing in 

25 2018? 

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1 Q No. Exhibit 14 is a restated certificate 

2 of organization. Do you see that? 

3 A "Restated Certificate of Organization," 

4 yes. Okay. I understand that. 

5 Q Filed in May of 2018. Correct? 

6 A Correct. 

7 Q And -- Excuse me -- it provides -- if you 

8 go to page 2 of Exhibit 14, there's a box that 

9 has the number 10 -- 

10 Do you see box 10? 

11 A Correct. Yes. 

12 Q -- that describes the amendments to be 

13 affected by the restated certificate. Just read 

14 it to yourself and let me know when you're done. 

15 (Pause.)

16 A Okay. 

17 Q I'm going to ask you do you know if 

18 Massachusetts law -- Do you see how it says that 

19 it's signed under penalties of perjury this 21st 

20 day of May 2018? 

21 A Correct. I see that. 

22 Q Do you know if Mr. Soling has legally 

23 changed his name to Malcolm Jarry? 

24 A I do not know -- 

25 MR. KEZHAYA: Object as outside the scope 

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1 of the 30(b)(6) deposition notice. 

2 Q So do you know? 

3 A Well, should I -- I -- 

4 Q Yeah, you -- 

5 MR. KEZHAYA: Oh. Yeah, go ahead and 

6 answer. 

7 THE WITNESS: Okay. 

8 A I -- I have no knowledge of him changing 

9 his name. 

10 Q Do you know if Massachusetts law -- Strike 

11 that. 

12 Do you know how the execution and filing 

13 of organizational documents with the secretary of 

14 the commonwealth using a false name signed under 

15 penalty of perjury impacts the ability of that 

16 organization to continue to do business? 

17 MR. KEZHAYA: Same objection. 

18 Go ahead and answer. 

19 THE WITNESS: Okay. 

20 A No, I do -- I -- I have no knowledge of 

21 that. 

22 Q Okay. If you turn to page 1 of Exhibit 

23 14 -- So still the same exhibit, but now we're 

24 just turning back to page 1 -- the general 

25 character of the business is now described as 

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1 "The purpose of the company is to conduct any and 

2 all lawful business that can be performed by a 

3 limited liability company formed under GL.c. 156C 

4 including but not limited to educational 

5 activities, concluding the sale of any 

6 merchandise and literature and any and all 

7 activities incidental thereto." 

8 Did I read that correctly? 

9 A Correct. 

10 Q Still does not articulate a religious 

11 purpose to the United Federation of Churches LLC. 

12 Correct? 

13 A Correct. 

14 Q Do you know if making a false statement in 

15 a filing with the Commonwealth of Massachusetts 

16 impacts the ability of an organization to 

17 continue to do business? 

18 A I -- 

19 MR. KEZHAYA: Same objection. 

20 Go ahead and answer. 

21 A I -- I -- I do not -- I do not know the -- 

22 the letter of the law on this. 

23 Q Okay. Turn to tab 15, please. 

24 Tab 15 is a certificate of amendment for 

25 the United Federation of Churches LLC. Do you 

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1 see that? 

2 A Yes. 

3 Q And identifies you in box 5 as the 

4 resident agent still. Correct? 

5 A Correct. 

6 Q In box 6 it identifies two managers. 

7 Correct? 

8 A Correct. 

9 Q But those two managers are in fact the 

10 same person. Correct? 

11 A Correct. 

12 Q Have you ever notified -- As a 

13 representative of and the resident agent for the 

14 United Federation of Churches LLC, have you ever 

15 notified the secretary of the commonwealth that 

16 any misleading statements were ever made in an 

17 organizational filing on behalf of the United 

18 Federation of Churches LLC? 

19 A I have not. 

20 Q And in fact if you look at box 10 on the 

21 second page of Exhibit 15, the purpose of the 

22 amendment is specifically articulated to add a 

23 manager, slash, officer. Do you see that? 

24 A Yes. 

25 Q But Mr. Soling was always, since the 

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1 filing of the first annual report, a manager of 

2 the United Federation of Churches LLC. True? 

3 A I'm sorry. Can you say that again. 

4 MR. CLAUS: Can you read it back, please. 

5 (Record read.)

6 A I'm sorry. Yes. Correct. 

7 Q Tab 16. Tab 16, Exhibit 16, is an annual 

8 report of United Federation of Churches LLC. Do 

9 you see that? 

10 A Yes. 

11 Q And now changes the general character of 

12 the business and states that it engages in 

13 campaigns and provides services that promote 

14 reason and empathy and religious pluralism and 

15 sell merchandise to support these efforts. True? 

16 A Correct. 

17 Q Has the United Federation of Churches LLC 

18 ever sought tax-exempt status from the IRS? 

19 A To my knowledge, that was never -- never 

20 the route we pursued that with. 

21 Q We can see, based upon Exhibit 16, that 

22 because it was filed in February of 2019 that the 

23 United Federation of Churches LLC has existed 

24 concurrently as a separate legal entity from The 

25 Satanic Temple Inc. True? 

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1 A As a separate legal entity. Correct. 

2 Q And Exhibit 16 represents the first time 

3 that the United Federation of Churches LLC is 

4 described as having been organized to engage in 

5 any type of religious activity. True? 

6 A This is the first filing in which it 

7 explicitly states any religious function. 

8 Q Is it true to say that the United 

9 Federation of Churches LLC has never sought to 

10 register as a foreign limited liability company 

11 in the State of Arizona? 

12 A I believe it is accurate to say that. 

13 Q Has the United Federation of Churches LLC 

14 ever filed anything with the Arizona Corporation 

15 Commission? 

16 A To my knowledge, no. 

17 Q Has the United Federation of Churches LLC 

18 ever made a filing with the Arizona Secretary of 

19 State? 

20 A To my knowledge, no. 

21 (Pause.)

22 Q Let me ask you about these trademark 

23 applications again as the designee of the United 

24 Federation of Churches LLC. Go to Exhibit 23, 

25 please. 

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1 A 23. Okay. 

2 Q Exhibit 23 is a trademark application -- 

3 application filed on May 24, 2019 for the 

4 trademark "The Satanic Temple." Do you see that? 

5 A Yes. 

6 Q That identifies the applicant as the 

7 United Federation of Churches LLC. Do you see 

8 that? 

9 A Applicant -- Yes, I see that. 

10 Q So do you know -- And -- And you may not 

11 know this -- that when an application is filed 

12 with the United States Patent & Trademark Office 

13 that a representation is made under penalty of 

14 perjury regarding who uses a mark in commerce and 

15 who uses a mark in interstate commerce? 

16 MR. KEZHAYA: Object as outside of the 

17 30(b)(6) notice. 

18 Go ahead and answer. 

19 A No, I'm not aware of the relevant legal 

20 background on that. 

21 Q Okay. If you'd turn to just Exhibits 24 

22 and 25, these are trademark registrations for the 

23 trademark "TST" and design and the word mark 

24 "Satanic Temple" that reflects ownership of that 

25 registration by the United Federation of Churches 

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1 LLC. Correct? You have to go to the next page 

2 for Exhibit 24. 

3 A Yes, I see that on there. 

4 Q And Exhibit 25, at the bottom of the first 

5 page, reflects the owner as the United Federation 

6 of Churches LLC. 

7 A Correct. 

8 Q Has the United Federation of Churches LLC 

9 ever assigned the trademark reflected in Exhibits 

10 24 and 25 to any person or entity? 

11 A Assigned the trademark to any person or 

12 entity. Again, you know, I operate under -- 

13 under just this operational understanding that 

14 I'm acting as The Satanic Temple. So when we do 

15 these kind of licensing agreements with chapters 

16 and other such entities, you know, I'm not 

17 thinking it in terms of distinguishing it from 

18 United Federation of Churches or -- or The 

19 Satanic Temple Inc. 

20 Q Well, you just used the -- the -- the 

21 first person pronoun "I." I just want to make 

22 sure I understand. You, Douglas Misicko, are not 

23 the owner of any of the trademarks reflected in 

24 Exhibits 23, 24 or 25. Correct? 

25 A Correct. But as -- as a authoritative 

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1 voice for the United Federation of Churches, I 

2 don't -- 

3 Q Well, but you're not a manager of the 

4 United Federation of Churches LLC. Correct? 

5 A Right. I'm a -- I'm a member. Isn't -- 

6 Isn't that the language we're -- 

7 Q Well, if we look back at Exhibit 11 --

8 A Okay. 

9 Q -- Exhibit 11 identifies the manager on 

10 line 6 as Cevin Soling. Correct? 

11 A Correct. 

12 Q And -- And -- And the commonwealth 

13 required you to identify the name and business 

14 address of each manager of the limited liability 

15 company. Correct? 

16 A Correct. You're right. 

17 Q And Cevin Soling is list -- identified as 

18 the only manager. Correct? 

19 A Correct. 

20 Q And if you turn to the next page, number 

21 7, you are identified as someone who is not a 

22 manager but given limited authority to, quote, 

23 execute documents filed with the corporation 

24 division. Correct? 

25 A Correct. 

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1 Q Okay. And if we turn to Exhibit 12 -- So 

2 that's for the year 2015 you were not the 

3 manager. For the year 2016, in Exhibit 12, you 

4 were not the manager. Correct? 

5 A Correct. 

6 Q In the year 2017 you were not the manager. 

7 Correct? 

8 A On --

9 Q Exhibit 13. 

10 A -- 13? 

11 Correct. Here again I'm the resident 

12 agent. 

13 Q Right. In Exhibit 15 you are not 

14 identified as a manager. Correct? 

15 A Correct. I'm listed as resident agent. 

16 Q In Exhibit 16 for the year 2019 you were 

17 not identified as a manager. Correct? 

18 A Correct. I am listed as resident agent. 

19 Q Okay. So let's turn back to Exhibit 25. 

20 A 25. Okay. 

21 Q A document with a registration date of 

22 February 10, 2015. Correct? 

23 A I'm sorry. Let me -- Let me see. 

24 Q "Registration Date." 

25 (Mr. Claus indicated.) 

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1 A Oh, okay. Okay. 

2 Q February 10, 2015. Correct? 

3 A I see that, yes. 

4 Q For the trademark "The Satanic Temple." 

5 Correct? 

6 A Correct. 

7 Q We know, having now looked at the 

8 organizational filings with the commonwealth, 

9 that as of February 10, 2015 you were not a 

10 manager of the United Federation of Churches LLC. 

11 Correct? 

12 A Correct. 

13 Q So do you see there is a tab that says 

14 "Assign Status" on Exhibit 25? 

15 A I see that. 

16 Q Do you know if a document has been filed 

17 with the United States Patent & Trademark Office 

18 that assigns the trademark reflected in Exhibit 

19 25 to any individual or entity other than the 

20 United Federation of Churches LLC? 

21 A I do not know that that has ever taken 

22 place. 

23 Q Okay. Do you know if the United 

24 Federation of Churches LLC has entered into a 

25 licensing agreement with The Satanic Temple Inc. 

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1 whereby The Satanic Temple Inc. is permitted to 

2 lawfully use the trademark, quote, The Satanic 

3 Temple, end quote? 

4 A Again let me say I know of no legal 

5 documentation that would -- that would confer 

6 that right. 

7 Q We looked at paragraph 10 of the first 

8 amended complaint which alleged that The Satanic 

9 Temple was given organizational structure by the 

10 United Federation of Churches LLC. Do you 

11 remember that? 

12 A Yes. 

13 Q You've watched -- I'm assuming you've 

14 watched the documentary Hail Satan. 

15 A Yeah. I've seen that a few times. 

16 Q I think it's very well done. 

17 In the number of times that you've seen 

18 the documentary Hail Satan were you able to 

19 identify any false or misleading statements made 

20 by Michelle Shortt or Stu de Haan in that 

21 documentary? 

22 A No, I cannot think of any false or 

23 misleading statements by either of them in the 

24 documentary. 

25 Q Okay. Prior to February 8, 2016 did 

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1 Michelle Shortt ever ask Cevin Soling, as the 

2 manager of the United Federation of Churches LLC, 

3 for permission to speak on behalf of that legal 

4 entity? 

5 A Not that I'm aware of. 

6 Q Prior to February 8, 2016 did Michelle 

7 Shortt ever ask any -- ever ask the manager of 

8 the United Federation of Churches LLC for 

9 permission to speak on behalf of something called 

10 the Arizona Chapter of The Satanic Temple? 

11 A So you're asking if she had this 

12 conversation with Cevin Soling? 

13 Q On -- Prior to February 8, 2016. I'll 

14 just ask it again. 

15 A Okay. 

16 Q Do you know if -- prior to February 8, 

17 2016 or on February 8, 2016, if Michelle Shortt 

18 ever sought permission from the manager of the 

19 United Federation of Churches LLC for permission 

20 to speak on behalf of an organization that called 

21 itself the Arizona Chapter of The Satanic Temple? 

22 A I do not know of any such discussion. 

23 Q Did Mr. Soling, as the only manager of the 

24 Satanic -- Strike that -- as the only -- I'll ask 

25 it all over again. 

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1 Did Mr. Soling, as the only manager of the 

2 United Federation of Churches LLC from 2015 to 

3 2019, ever confer authority on Michelle Shortt to 

4 act as an authorized representative of the United 

5 Federation of Churches LLC? 

6 A Now, if you're asking for a direct 

7 discussion between Michelle and Cevin, I would 

8 know of no such thing. But I do know that as 

9 agents conferred with the authority to give such 

10 permission as -- given our organizational 

11 structure of The Satanic Temple, the National 

12 Council and myself, she was -- she was -- I know 

13 she was explicitly given that permission by 

14 myself. 

15 Q Does the United Federation of Churches LLC 

16 have an operating agreement? 

17 A Yes. 

18 Q When did that operating agreement get 

19 entered into? 

20 A The United Federation of Churches LLC? 

21 Q Mm-hmm. 

22 A I -- I'm not -- I'm not certain, no. 

23 Q Okay. Do you know if the operating 

24 agreement of the United Federation of Churches 

25 LLC existed prior to February 8, 2016? 

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1 A It is my understanding that it did. 

2 Q Have you reviewed the operating agreement 

3 of the United Federation of Churches LLC to 

4 prepare for your deposition today? 

5 A Yes. And I believe it was from 2014. 

6 Q Does the operating agreement of United 

7 Federation of Churches LLC confer agency 

8 authority on anyone other than the manager of 

9 that entity? 

10 A Not that I'm aware of. 

11 Q Okay. So I'm going to ask it -- I'm going 

12 to ask my question again. 

13 Do you know -- It's not communications. 

14 Do you know if the manager of the United 

15 Federation of Churches LLC ever conferred 

16 authority on Michelle Shortt to act as an 

17 authorized representative of the United 

18 Federation of Churches LLC? 

19 A Well, I would say indirectly. And maybe 

20 that doesn't meet your criteria, but I'm 

21 explicitly given the permission to confer 

22 agents with permission to use that type of 

23 licensing. 

24 Q But not by the operating agreement. 

25 Correct? 

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1 A Not -- Not by the operating agreement. 

2 Q Okay. 

3 A Just by --

4 Q So did -- Let me just ask you this: Have 

5 you ever seen a written communication -- or -- 

6 Strike that. 

7 Have you ever seen a written document 

8 where Mr. Soling, as the only manager of the 

9 United Federation of Churches LLC, conferred 

10 authority on Michelle Shortt to act as an 

11 authorized representative of the United 

12 Federation of Churches LLC? 

13 A I know of no such documentation. 

14 Q Have you -- Has Mr. Soling ever told you 

15 that he, as the only manager of the United 

16 Federation of Churches LLC, ever conferred 

17 authority on Michelle Shortt to act as an 

18 authorized representative of the United 

19 Federation of Churches LLC? 

20 A Well, he was made aware of my 

21 conversations with Michelle Shortt and approved 

22 of her being authorized to speak on behalf of The 

23 Satanic Temple at the invocation. 

24 Q Is Michelle Shortt a member of the 

25 organization that calls itself The Satanic 

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1 Temple? 

2 A Yes, it's my understanding that she is. 

3 Q When did she become a member? 

4 A I -- I'm not certain. 

5 (Pause.)

6 Q Do you know -- Do you know if Michelle 

7 Shortt was a member of The Satanic Temple as of 

8 February 8, 2016? 

9 A It is my understanding that she was. 

10 Q From where did you obtain that 

11 understanding? 

12 A From Michelle Shortt herself. 

13 Q Have you seen any documents or any records 

14 in preparation for your deposition today 

15 demonstrating that Michelle Shortt was in fact a 

16 member of The Satanic Temple as of February 8, 

17 2016? 

18 A Not in preparation of my deposition, but I 

19 know she has a certificate of membership. 

20 Q And when was the certificate of membership 

21 sought? 

22 A That I do not know. 

23 Q You don't know the date? 

24 A I do not know the date. 

25 Q When was the certificate of membership 

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1 granted? 

2 A I do not know a date for that either. 

3 Q Hmm. Is there currently an Arizona 

4 chapter of The Satanic Temple? 

5 A There is. 

6 Q That chapter did not exist as of February 

7 1, 2016. Is that correct? 

8 A I -- I -- I don't know. I do not know 

9 their founding date. 

10 Q You know that the chapters of The Satanic 

11 Temple are identified on the Web site 

12 www.thesatanictemple.com? 

13 A Correct. 

14 Q If you'd turn to Exhibit 37, please. 

15 MR. KEZHAYA: Hold on one second so I can 

16 navigate to that. I only got up to 34. 

17 MR. CLAUS: Sure. 

18 MR. KEZHAYA: You said 37? 

19 MR. CLAUS: Yes. 

20 MR. KEZHAYA: Okay. I'm here. 

21 Q Exhibit 37 is an archived Web site from 

22 February 24, 2015 that identifies chapters of The 

23 Satanic Temple. Do you see that? 

24 A Correct. 

25 Q Eight chapters are identified? 

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1 A Correct. 

2 Q None of those eight are Arizona. Correct? 

3 A Correct. However, there can sometimes be 

4 a real time lag between when a chapter is formed 

5 and when it's posted on the Web site. It's not 

6 often immediate. So it doesn't give me a clear 

7 indication of their founding date. But I do 

8 remember that requesting an invocation in Phoenix 

9 and Scottsdale were two kind of foundational 

10 activities for the Arizona chapter when they 

11 were -- when they were collecting -- when they 

12 were nascent in -- in building their community. 

13 Q If you'd turn to Exhibit 40, which is tab 

14 40. 

15 MR. KEZHAYA: Just a moment here. 

16 MR. CLAUS: Sure. 

17 MR. KEZHAYA: I believe I'm at it. Okay. 

18 Q This is an Internet archive from February 

19 1, 2016? 

20 A Okay. 

21 Q Correct? 

22 A February -- Yes. Sorry. 

23 Q And the Arizona chapter is still not 

24 identified as a chapter on the Web site of The 

25 Satanic Temple as of February 1, 2016? 

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1 A I -- I see that. Correct. It -- It might 

2 just be that they didn't have a Web site yet, 

3 though. 

4 Q The religious aspect of The Satanic Temple 

5 is moored in the firmly held beliefs of its 

6 members. Is that right? 

7 A Correct. 

8 Q Is one of those firmly held beliefs that a 

9 supernatural god created an actual Satan to 

10 preside over the universe as his proxy? 

11 A It is not. It's -- Not in literal 

12 terminology any -- in any case. That could be 

13 taken metaphorically but not -- not in the 

14 supernatural sense. 

15 Q Is a firmly held belief of The Satanic 

16 Temple that Satan hears our prayers and responds? 

17 A It is not. 

18 Q Is a firmly held belief of The Satanic 

19 Temple that Satan can exist in a corporeal realm? 

20 A It is not. 

21 Q But all of those firmly held beliefs were 

22 the beliefs of The Satanic Temple at one point. 

23 Correct? 

24 A Incorrect. 

25 Q Go to Exhibit 27, please. 

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1 A Okay. 

2 Q Exhibit 27 is an archived Web page from 

3 The Satanic Temple, www.thesatanictemple.com, 

4 dated January 15, 2013. Do you see that? 

5 A I see that. 

6 Q With a heading, quote, Religious Beliefs 

7 of The Satanic Temple, end quote. Do you see 

8 that? 

9 A I see that. 

10 Q I'm going to read the text, and you just 

11 tell me if I read it correctly because it's 

12 rather small. 

13 A Right. 

14 Q "The Satanic Temple believes that God is 

15 supernatural and thus outside of the sphere of 

16 the physical. God's perfection means that he 

17 cannot interact with the imperfect corporeal 

18 realm. Because God cannot intervene in the 

19 material world, he created Satan to preside over 

20 the universe as his proxy. Satan has the 

21 compassion and wisdom of an angel. Although 

22 Satan is subordinate to God, he is mankind's only 

23 conduit to the dominion beyond the physical. In 

24 addition, only Satan can hear our prayers and 

25 only Satan can respond. While God is beyond 

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1 human comprehension, Satan desires to be known 

2 and knowable. Only in this way can there be 

3 justice and can life have meaning. Hail Satan, 

4 exclamation point."

5 Did I read that correctly? 

6 A Yes. 

7 Q Do you know -- Strike that. 

8 Also one of the firmly held religious 

9 beliefs of The Satanic Temple now is moored in 

10 the seven tenets. Is that correct? 

11 A Correct. 

12 Q But there have not always been seven 

13 tenets. Correct? 

14 A Correct. 

15 Q In fact if you look at Exhibit 28 -- 

16 A Why is mine missing? 

17 Q Oh. Shoot. I'll give you mine. 

18 MR. CLAUS: Do you have Exhibit 28, Matt? 

19 MR. KEZHAYA: I believe so. I have a 

20 document after a number as Exhibit 28. 

21 MR. CLAUS: Yeah. 

22 MR. KEZHAYA: It has what looks like a 

23 tarot card, the devil -- 

24 MR. CLAUS: That's it. 

25 MR. KEZHAYA: Okay. 

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1 Q So handing you Exhibit 28, I inserted the 

2 page numbers. We'll just make this the official 

3 Exhibit 28. We'll pop it in your binder. 

4 A Okay. 

5 Q Go to -- Go to page 6 since --

6 A 6? 

7 Q Right. 

8 A Okay. So -- 

9 MR. KEZHAYA: Page 6? 

10 MR. CLAUS: Page 6 of Exhibit 28. 

11 MR. KEZHAYA: Okay. Let's see, here. 

12 One, two -- For benefit of the record, does it 

13 have a mission statement? 

14 THE WITNESS: Fundamental tenets. 

15 MR. CLAUS: Fundamental tenets. 

16 MR. KEZHAYA: Oh. Is that before or after 

17 mission statement? Looks like after. No, that 

18 says "Why Satan?" 

19 MR. CLAUS: "Why Satan?"

20 MR. KEZHAYA: I may not have -- 

21 MR. CLAUS: The next -- The next page. 

22 MR. KEZHAYA: Okay. Does it go with 

23 "There are nine fundamental tenets"? 

24 MR. CLAUS: Yeah. 

25 MR. KEZHAYA: Yeah. Okay. I'm on it. 

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1 Q And the archive date of that Web site 

2 is -- 

3 A January -- 

4 Q -- January 16, 2013. Is that correct? 

5 A Oh. Sorry. Yes. 

6 Q Okay. So currently there are seven 

7 fundamental tenets --

8 A Correct. 

9 Q -- for The Satanic Temple? 

10 A Yes. 

11 Q And I'm going to just read them. 

12 "1. One should strive to act with 

13 compassion and empathy toward all creatures in 

14 accordance with reason."

15 That's number 1? 

16 A Correct. 

17 Q Do you see that tenet articulated in the 

18 nine fundamental tenets that were articulated in 

19 January 2013? 

20 A No. 

21 Q "2. The struggle for justice is an 

22 ongoing and necessary pursuit that should prevail 

23 over laws and institutions."

24 That's one of the seven tenets. Correct? 

25 A Correct. 

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1 Q Do you see that tenet articulated among 

2 the nine tenets that were articulated in Exhibit 

3 28? 

4 A No. 

5 Q "3. One's body is inviolable, subject to 

6 one's own will alone."

7 That's one of the seven tenets? 

8 A Correct. 

9 Q Do you see that tenet articulated among 

10 the nine tenets as of January 2013? 

11 A I do not. 

12 Q "4. The freedoms of others should be 

13 respected, including the freedom to offend. To 

14 willing -- To willfully and unjustly encroach 

15 upon the freedoms of another is to forgo one's 

16 own."

17 That's one of the seven tenets. Correct? 

18 A Correct. 

19 Q Do you see that tenet articulated among 

20 the nine in Exhibit 28? 

21 A I do not. 

22 Q Number 5. "Beliefs should conform to 

23 one's best scientific understanding of the world. 

24 One should take care never to distort scientific 

25 facts to fit one's beliefs."

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1 That's one of the seven tenets? 

2 A Correct. 

3 Q Do you see that tenet articulated among 

4 the nine in Exhibit 28? 

5 A I do not. 

6 Q "6. People are fallible. If one makes a 

7 mistake, one should do one's best to rectify it 

8 and resolve any harm that might have been 

9 caused."

10 That's one of the seven tenets? 

11 A Correct. 

12 Q Is that tenet articulated among the nine 

13 in Exhibit 28? 

14 A Somewhat under different wording of number 

15 3 here, but --

16 Q Okay. 

17 A -- but no, not in this exact form. 

18 Q And then the last of the seven tenets is 

19 "Every tenet is a guiding principle designed to 

20 inspire nobility in action and thought. The 

21 spirit of compassion, wisdom and justice should 

22 always prevail over the written or spoken word."

23 I think that tenet is actually tenet 9 on 

24 Exhibit 28. Correct? 

25 A Not verbatim but very close. 

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1 Q Okay. Do you know if, as of February 8, 

2 2016, Michelle Shortt -- Go back to Exhibit 27. 

3 Do you know if, as of February 8, 2016, 

4 Michelle Shortt adhered to the, quote, religious 

5 beliefs that The Satanic Temple, end quote, 

6 articulated in Exhibit 27? 

7 A Oh, no. As far as I know, nobody with The 

8 Satanic Temple now has any connection to this Web 

9 site, including myself. I -- This Web site 

10 predates me and was rather a placeholder site for 

11 www.thesatanictemple.com. So later on I came on 

12 board and was more the philosophical author of 

13 the actual beliefs of what became The Satanic 

14 Temple. And so this was all -- I'm not even sure 

15 who -- who wrote a lot of this material and if 

16 it -- and if it came from somebody who was just 

17 setting up a boilerplate Web site, a -- you know, 

18 a, quote, unquote, Satanic site for -- for these 

19 purposes or whatever. But it didn't -- I mean as 

20 far as our concept of our history goes, it didn't 

21 really start until I came in. We -- We cohered 

22 the seven tenets, and it wasn't a -- a film 

23 project for a couple other individuals. 

24 Q Well, hold on. The -- The logo identified 

25 on Exhibit 27, for instance, the -- the logo --

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1 A Yes. 

2 Q -- at the top of the page is the logo for 

3 which the United Federation of Churches LLC has a 

4 trademark registration. Correct? 

5 A That's incorrect. That's a separate logo. 

6 Q I see. 

7 The -- The trademark identified in Exhibit 

8 25 for the word mark "The Satanic Temple" 

9 identifies the date of first use of January 1, 

10 2013. Correct? 

11 A I'm sorry. Which -- 

12 Q Sure. Exhibit 25 --

13 A 25. 

14 Q -- identifies a date of first use --

15 A Right. Right. 

16 Q -- as January 1, 2013. Correct? 

17 A Correct. 

18 Q And Exhibit 27 was a publicly accessible 

19 Web site using the trademark of The Satanic 

20 Temple as of January 13, 2013. Correct? 

21 A Correct. 

22 Q After the date of first use of The Satanic 

23 Temple as applied for by The Satanic -- by the 

24 United Federation of Churches LLC. Correct? 

25 A Correct. I believe the question was when 

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1 was that name first used, and we still have the 

2 Web site so it seemed accurate. I don't see that 

3 that's actually -- 

4 Q Well, these are all predicate questions. 

5 A Okay. 

6 Q Let me ask you this: Has Michelle Shortt 

7 ever told you expressly that she does not adhere 

8 to the religious beliefs that The Satanic Temple 

9 articulated in Exhibit 27? 

10 A No. I'm -- No. As far as I know, she's 

11 never even seen this. So I have no idea. 

12 Q Okay. 

13 A She -- She -- Her -- Her only requirement 

14 is to agree with the seven tenets as a -- as a 

15 member of The Satanic Temple. 

16 Q Do you know if any member -- Do you 

17 know -- Strike that. 

18 Do any members of The Satanic Temple who 

19 resided in Arizona as of February 8, 2016 -- 

20 Strike that. 

21 Did any members of The Satanic Temple who 

22 resided in Arizona as of February 8, 2016 adhere 

23 to the religious beliefs of The Satanic Temple 

24 articulated in Exhibit 27? 

25 A I -- I cannot speak to their -- to their 

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1 subjective state. 

2 Q Okay. Did any members of The Satanic 

3 Temple who resided in Arizona as of February 8, 

4 2016 adhere to the nine tenets expressed in 

5 Exhibit 28 as opposed to the seven tenets that 

6 are currently expressed by The Satanic Temple? 

7 A I assume not because my recollection is at 

8 that time we weren't taking membership, but I 

9 could be wrong. 

10 Q Can I see Exhibit 28 again? 

11 A Sure. 

12 (Document handed to Mr. Claus.)

13 MR. CLAUS: Let's go off the record for 

14 just a second, Matt. 

15 MR. KEZHAYA: All right. 

16 (Pause.)

17 (Discussion off the record.)

18 (Recess taken.)

19 (Discussion off the record.)

20 MR. CLAUS: Okay. Back on the record. 

21 Q Exhibit 37 is a -- Don't pack up yet. 

22 A Okay. Well, I -- 

23 Q I don't want you to be distracted. 

24 A Just take this out. 

25 Q Exhibit 37 is an archive Web site from 

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1 February 24, 2015. Do you see that? 

2 A Correct. I see that. 

3 Q And do you see under -- it says "Join us 

4 for an official membership card." Do you see 

5 that? 

6 A Here (indicating). 

7 Q Yes. 

8 A Correct. Yeah. 

9 Q Okay. Do you know when membership in The 

10 Satanic Temple began? 

11 A I do not. 

12 Q Okay. Back to my question, then. 

13 Has any member of the Arizona chapter of 

14 The Satanic Temple ever told you that they do not 

15 adhere to the religious beliefs articulated in 

16 Exhibit 27 or the nine tenets articulated in 

17 Exhibit 28? 

18 A Michelle Shortt has told me she is a 

19 super -- is not a supernaturalist, and Michelle 

20 Shortt is explicitly aware of the seven tenets 

21 and that those form the basis of the beliefs of 

22 The Satanic Temple. 

23 Q Okay. Other than Michelle Shortt, has any 

24 member of The Satanic Temple who resides in 

25 Arizona told you explicitly that they do not 

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1 adhere to the religious beliefs articulated in 

2 Exhibit 27 or the nine tenets articulated in 

3 Exhibit 28? 

4 A I have had interpersonal communication 

5 with more than I can enumerate off the top of my 

6 head from Arizona, but I don't recall any one of 

7 them specifically citing that material and saying 

8 that they don't believe it. 

9 Q Okay. Does the United Federation of 

10 Churches LLC play any role in governing or 

11 determining who may be a member of the Arizona 

12 chapter of The Satanic Temple? 

13 A No. The Arizona chapter is autonomous in 

14 that regard. 

15 Q Has the United Federation of Churches LLC 

16 ever played a role in governing or determining 

17 who may be a member of the Arizona chapter of The 

18 Satanic Temple? 

19 A No. They're given, by our authority with 

20 our agreement with them, the autonomy to 

21 determine membership. We only convene and 

22 adjudicate on leadership themselves, chapter 

23 head, cochapter head and media liaison positions. 

24 Q As a designee of the United Federation of 

25 Churches LLC, do you know if one must be a 

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1 Satanist to become a member of the Arizona 

2 chapter of The Satanic Temple? 

3 A One must be -- must self-identify as a 

4 Satanist to be chapter head or cochapter head or 

5 media liaison within The Satanic Temple. So to 

6 have an active leadership role or to act as a 

7 media liaison, we do require that one 

8 self-identify as a Satanist. 

9 Q But to be a member of the chapter, one 

10 needn't be a Satanist. Correct? 

11 A Depending on the chapter. The chapter may 

12 accept people who consider themselves allies but 

13 aren't willing to openly identify as a Satanist. 

14 Q Exhibit 42. This will be my last. 

15 A Okay. 

16 MR. KEZHAYA: Give me just a second so I 

17 can navigate to it. 

18 MR. CLAUS: Sure. 

19 MR. KEZHAYA: Okay. You said 42? 

20 MR. CLAUS: Yes. 

21 Q And they're paginated up at the top. 

22 A I see. 

23 MR. KEZHAYA: I'm with you. 

24 Q It's the Web site of The Satanic Temple 

25 Arizona. Does the United Federation of Churches 

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1 LLC currently have -- play any role in 

2 editorializing or -- or an editorial role in the 

3 content of the Web site run by The Satanic Temple 

4 of Arizona? 

5 A Only insofar as if we determine material 

6 placed as content on the Web site to be 

7 objectionable or outside the purview of what our 

8 actual beliefs and function are or otherwise 

9 stands to misrepresent the organization. We can 

10 ask for it to be taken down. We do not 

11 necessarily provide the content, though they're 

12 free to use some of the content we've put 

13 together as kind of a -- kind of a cut and paste 

14 option. 

15 Q Okay. Last question. Page 6 of Exhibit 

16 42. 

17 A Okay. Hang on. I see it. 

18 Q Still part of the FAQ. Do you see the 

19 centered bold type "I am not a Satanist, but I 

20 support what you do. Can I still become an 

21 official chapter member?" Do you see that 

22 question? 

23 A Yes. 

24 Q And the answer is "Maybe." Do you see 

25 that? 

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1 A Correct. 

2 Q That answer is not one of the things over 

3 which the United Federation of Churches LLC 

4 decided to exercise editorial control and remove. 

5 Correct? 

6 A Correct. 

7 Q Does reading page 6 of Exhibit 42 refresh 

8 your recollection that a nonSatanist may become a 

9 member of the Arizona chapter of The Satanic 

10 Temple? 

11 A Yes, with the caveat that leadership must 

12 be self-identified Satanists. Leadership, media 

13 liaisons, they -- they absolutely do have to 

14 self-identify with us. But to be a member, you 

15 know, to actively engage in the community, we 

16 find it -- you know, we find it acceptable if 

17 they accept people who are allies who don't want 

18 to self-identify as Satanists. 

19 MR. CLAUS: Okay. That's all I have, 

20 Matt. 

21 MR. KEZHAYA: All right. Cross 

22 examination on the same -- Well, let's just 

23 present for the record on the -- on the 

24 stipulation that -- 

25 MR. CLAUS: Hold on a second. 

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1 MR. KEZHAYA: -- whatever I get into you 

2 get to recross? 

3 MR. CLAUS: Yes, that's correct. 

4 MR. KEZHAYA: Okay. All right. Do we 

5 want to take a brief break, or do we want to just 

6 get back into it? 

7 MR. CLAUS: We can get back into it. 

8 MR. KEZHAYA: All right. 

9 

10 CROSS EXAMINATION BY MR. KEZHAYA: 

11 Q Doug, is it an obligation of members to 

12 keep their addresses updated with any -- any form 

13 of centralized authority? 

14 A It -- It is not. We do not ask people for 

15 their address, nor do we ask them to update their 

16 addresses. 

17 Q Okay. In the regular course of business 

18 do y'all maintain addresses --

19 A We do not --

20 Q -- again as a -- 

21 (The reporter requested single voices.)

22 Q Do you -- Do you maintain a database of 

23 members? 

24 A We have a -- a database of members based 

25 upon the E mail addresses entered for the people 

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1 who want to sign up as members and receive the 

2 regular newsletter. 

3 Q Okay. Is it -- Is it a requirement to be 

4 a TST member that you sign up for the newsletter? 

5 A Well, the newsletter comes when people 

6 sign up as TST members, and that -- that's the 

7 way people get the newsletter. 

8 Q Okay. Are there TST members who consider 

9 themselves TST members but just don't get the 

10 newsletter because they haven't signed up? 

11 MR. CLAUS: Form. 

12 Q Go ahead and answer. 

13 A It's my understanding that people 

14 considers [sic] themselves members or otherwise 

15 aligned with The Satanic Temple as something that 

16 expresses the beliefs of their religious 

17 identity, and they don't necessarily sign up for 

18 the newsletter or otherwise put themselves into 

19 any database because, my understanding of this, 

20 for the most part people who do that, people who 

21 stay removed but still consider themselves allied 

22 on some level -- These are the types of people 

23 I've talked to after lectures and things like 

24 that -- they do so because they have a certain 

25 distinct fear of -- of being -- of being 

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1 recognized as -- as a Satanist. 

2 Q Is there a social stigma to being 

3 recognized as a Satanist? 

4 MR. CLAUS: Form. 

5 A There -- There generally is a social 

6 stigma to being recognized as a Satanist. 

7 Q I want to turn your attention to the 

8 annual reports of the United Federation of 

9 Churches. The -- The business purposes includes 

10 a catch-all of "all other lawful purposes." Do 

11 you remember that? 

12 A Correct. 

13 Q Is religious activity a lawful purpose? 

14 MR. CLAUS: Form. 

15 A Yes. I mean to us that was just a very 

16 general and vague blanket statement that could 

17 encompass all of the activities we were engaged 

18 in and that we were doing without putting too 

19 fine a point on it to make it too narrow. 

20 Q Okay. In any of the papers filed with the 

21 secretary of the commonwealth did TST, by -- by 

22 way of United Federation of Churches, ever 

23 intentionally mislead the secretary? 

24 A No, not -- not -- not to my understanding. 

25 Q In the course of TST's operations do you 

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1 have voting authority on -- on decisions for the 

2 United Federation of Churches? 

3 MR. CLAUS: Form. 

4 A Yes. 

5 Q Is Cevin aware that you from time to time 

6 exercise that voting authority? 

7 MR. CLAUS: Form. 

8 A Yeah, Cevin is aware that I exercise that 

9 authority on a daily basis. 

10 Q Has he ever threatened you with a breach 

11 of contract or otherwise taken issue with your 

12 use of your authority? 

13 A No. It's our explicit understanding that 

14 I exercise that authority. In fact it's our 

15 understanding with each other that we exercise 

16 equal authority in that regard. 

17 Q Was Cevin aware that Michelle desired to 

18 give this legislative invocation to the City of 

19 Scottsdale? 

20 MR. CLAUS: Form. 

21 A Correct. Cevin was aware that Michelle 

22 sought to give the invocation in -- in 

23 Scottsdale. 

24 Q But he was aware -- 

25 A And he was aware that I -- 

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1 (The reporter requested single voices.)

2 Q Go ahead and just give me the exact same 

3 answer. That answers my next question as well. 

4 MR. CLAUS: Form. 

5 A I'm sorry. Do you want to restate the 

6 question? 

7 Q Let's -- Let's just take it in two parts. 

8 Was Cevin aware that Michelle desired to 

9 give a legislative invocation for the City of 

10 Scottsdale? 

11 MR. CLAUS: Form. 

12 A Yes. Through me, as I was the one in 

13 dialogue with Michelle Shortt at the time, Cevin 

14 was made explicitly aware that Michelle sought to 

15 give an invocation in Scottsdale. 

16 Q Did he object? 

17 MR. CLAUS: Form. 

18 A Cevin did not object. In fact he -- he 

19 endorsed -- he endorsed this. 

20 Q Okay. When did this endorsement happen? 

21 A I can't give you an exact date. I can 

22 only tell you the circumstances, but he -- he -- 

23 he gave his consent in -- in dialogue with me, 

24 and I would dialogue with him after I would 

25 converse with Michelle Shortt. 

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1 Q When were those conversations happening 

2 between you and Michelle? 

3 A Prior to her applying for the Scottsdale 

4 invocation. 

5 Q Were your -- Were your dialogues with 

6 Cevin, I guess, at the same time? 

7 MR. CLAUS: Form. 

8 A It -- It -- I'm sorry. At the same time 

9 as -- as what? 

10 Q So relative to your conversations with 

11 Michelle, how much time would pass before you 

12 would talk with Cevin about your conversations 

13 with Michelle? 

14 MR. CLAUS: Form. 

15 A Typically these dialogues -- And again of 

16 course I don't have exact record on this, but to 

17 my recollection it would be within the day that I 

18 would speak with Michelle, probably later in the 

19 evening, I would apprise Cevin of the -- the 

20 situation surrounding Michelle's request. 

21 Q How often do you and Cevin co-ordinate on 

22 TST's activities? 

23 A I would say very often. Certainly not 

24 less than once a week and usually far more often 

25 than that. It's usually on a daily basis. 

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1 Q Okay. What -- What happened with these 

2 nine tenets that they became seven tenets? 

3 A Well, the -- that -- that whole Web site 

4 predated me, and I'm not sure who put it up. My 

5 understanding is that that was kind of a 

6 placeholder site and somebody we had just working 

7 as a web person put some of the content on there. 

8 I'm not sure how long some of the old material 

9 remained before we got a new Web site together, 

10 but the -- the actual philosophical foundations 

11 of The Satanic Temple weren't put in place 

12 until -- until my entry into The Satanic Temple, 

13 which kind of made it an entirely new 

14 organization even though it had continuity with 

15 the URL and -- and in some of the -- some of the 

16 other paperwork. 

17 Q Do you remember about when you -- you 

18 entered into The Satanic Temple? 

19 A Sometime in 2013. 

20 Q Was it the early part of 2013 or the 

21 late -- late part? 

22 A I'm sorry. I don't recall. And the 

23 reason I don't recall was because it wasn't an 

24 immediate full entry. I was aware that Cevin 

25 wanted to work on a film project related to this 

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1 idea of The Satanic Temple, and he was consulting 

2 me because I am a Satanist. And it wasn't until 

3 later activities were being done and I was 

4 consulting on them that I kind of -- I kind of 

5 overtook the whole thing in certain ways, as it 

6 were. 

7 Q Okay. As -- As of February two 

8 thousand -- I guess '16, February 8, 2016, were 

9 the nine tenets as described earlier a part of 

10 The Satanic Temple? 

11 MR. CLAUS: Form. 

12 A I'm sorry. As of -- As of what -- what 

13 date? 

14 Q February 8, 2016. This is when Michelle 

15 first asked for the invocation, I believe. 

16 A Oh. Correct. By -- By 2016 that old Web 

17 site material had no relevance to The Satanic 

18 Temple as it was at that time. 

19 Q Okay. And in the deposition of The 

20 Satanic Temple Inc. you had a number as of April 

21 2016 of people in Scottsdale. Do you -- Do you 

22 have that number still? 

23 A Yes. As of -- Let me see. As of April 

24 2016 -- and again noting that this is a minimum 

25 known number based upon mailing addresses -- we 

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1 would have had a minimum of five members in 

2 Scottsdale. 

3 Q Okay. Do you have the number as of today 

4 or at least as of more recently than that? 

5 A Yes. Let me check that. I had it looked 

6 up yesterday. 

7 (Pause.)

8 A Okay. We have a minimum number now, based 

9 upon the criteria I already -- I already 

10 outlined, of 27 members in Scottsdale. 

11 Q Okay. And is that -- is that as of 

12 yesterday? Where did this number come from? 

13 A This just came from a search of -- of 

14 addresses up 'til now that we've -- we've sent 

15 membership cards and certificates to. 

16 Q Tell me a little bit more about this 

17 search. Are you searching a -- a range or as of 

18 a date? 

19 A You know, I'm not actually certain. I 

20 asked the person who does the shipping on these 

21 things to do the search, and she just came back 

22 with a -- with a number of 27. 

23 Q Okay. All right. 

24 (Pause.)

25 Q How did Scottsdale come to be chosen as a 

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1 city where these -- these -- where TST wanted to 

2 give a legislative invocation for? 

3 MR. CLAUS: Well -- 

4 THE WITNESS: Sorry. 

5 MR. CLAUS: I mean I'm fine with you 

6 asking all of these questions, Matt, but -- 

7 Go ahead. Go ahead. Answer. 

8 A That was -- It was Michelle and/or Stu 

9 that approached us with the idea of giving the 

10 invocation in Scottsdale, and I -- I don't know 

11 the -- the thinking on their part that preceded 

12 that request. 

13 Q Okay. 

14 MR. KEZHAYA: All right. Well, that -- 

15 that answers all of my questions. Do you have 

16 recross? 

17 MR. CLAUS: I sure do. 

18 

19 REDIRECT EXAMINATION BY MR. CLAUS: 

20 Q You testified previously that -- and just 

21 now that you think that the Web page archive 

22 shown in Exhibit 27 -- if you go to Exhibit 27 -- 

23 was, I think, to use your words, a placeholder --

24 A Yeah. 

25 Q -- and that the nine tenets identified in 

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1 Exhibit 28 was a placeholder? 

2 A Sure. 

3 Q But you don't know -- you -- you don't 

4 know that. That is your assumption? 

5 A Well, how do you -- how do you mean? As 

6 opposed to what? 

7 Q Has anyone told you that the nine tenets 

8 articulated in Exhibit 28 were simply a 

9 placeholder? 

10 A Yes. 

11 Q Who? 

12 A Cevin Soling. 

13 Q Okay. When did Cevin Soling tell you 

14 that? 

15 A I -- I don't know. He's maintained that 

16 from the beginning when I started kind of 

17 revising, you know, the whole perception of The 

18 Satanic Temple --

19 Q So did Cevin -- 

20 A -- and I wanted to -- 

21 Q I'm sorry. 

22 A -- I -- I wanted the Web site to reflect 

23 what -- the beliefs I was willing to advocate 

24 for. So this -- this Web site was described as 

25 more of a placeholder for a previous project he 

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1 was working on. 

2 Q Did Cevin Soling draft the nine tenets 

3 identified in Exhibit 28? 

4 A Not that I know of. 

5 Q You testified that as of January 15 in 

6 response to one of my questions, January 15, 

7 2013, you didn't believe that The Satanic Temple 

8 was accepting members. Correct? 

9 A I -- I do not believe so. 

10 Q I'm showing you a Web -- It is not an 

11 exhibit. We'll make it an exhibit. It will be 

12 Exhibit 47 -- a Web page archive from January 15, 

13 2013 from The Satanic Temple -- 

14 www.thesatanictemple.com, backslash, join. Do 

15 you see that? 

16 A I see that, yes. 

17 Q That invites members to join The Satanic 

18 Temple. Correct? 

19 A That's correct. 

20 MR. KEZHAYA: Object. Wait. You're 

21 looking at an Exhibit 47. Mine ends at 46. 

22 MR. CLAUS: Right. I just said that it's 

23 not marked yet. We will mark it as Exhibit 47. 

24 It is the Internet archive from January 15, 2013 

25 for www.thesatanictemple.com, backslash, join. 

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1 Q And that Web -- So as of January 15, 2013 

2 members were invited to join The Satanic Temple. 

3 Correct? 

4 A That's -- That's what it appears from 

5 here. I'm not -- This is -- I mean I have to say 

6 this is before -- this is before my time. Right? 

7 This is -- 

8 Q But you are the designee with knowledge. 

9 A But this -- this predates the formation 

10 of -- of the company and -- and to my -- as far 

11 as I'm concerned, it predates The Satanic Temple 

12 as -- as I have a part in it now. 

13 Q Okay. Do you see --

14 (Telephone interruption.)

15 (Discussion off the record.)

16 MR. CLAUS: So now back on the record. 

17 Q Do you see how members were invited to 

18 join The Satanic Temple and pay a $25 fee for a 

19 certificate on parchment? 

20 A That's what I see now. But as I explained 

21 before Matt got cut off -- or after Matt got cut 

22 off, this predated me. I'm not -- You know, to 

23 me this -- this predates the -- the form -- 

24 formalization of The Satanic Temple and what it 

25 is today. 

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1 Q Do you know if there's been a time -- 

2 Since you've been associated with The Satanic 

3 Temple and as the designee for the United 

4 Federation of Churches LLC, do you know if there 

5 has been a time when a member did not have to pay 

6 $25 to receive a certificate? 

7 A If there -- To receive a certificate? 

8 Q Correct. 

9 A So membership doesn't cost anything. 

10 Q That wasn't my question. 

11 Do you know of a time when a member did 

12 not have to pay $25 to receive a certificate? 

13 A No. To my knowledge, for somebody to 

14 receive the card with certificate, they need to 

15 pay for that. 

16 Q $25? 

17 A Correct. 

18 Q It's always been $25. Correct? 

19 A I believe it's always been $25. 

20 Q You said Mr. Soling did not object. Was 

21 Mr. Soling provided by Michelle Shortt any draft 

22 of an invocation Michelle Shortt sought to give? 

23 A Mr. Soling was aware that the invocation 

24 Michelle Shortt sought to give was the same 

25 invocation that I had penned in the Los Angeles 

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1 Times. 

2 Q Let me ask you this, back to what will be 

3 Exhibit 47: Do you know -- Do you know -- And -- 

4 And I mean know such that you could testify under 

5 penalty of perjury -- that any of the members of 

6 The Satanic Temple who resided in Arizona as of 

7 February 8, 2016 did not use the membership form 

8 reflected in Exhibit 47? 

9 A I -- I could not do that, no. 

10 Q Okay. Do you know, such that you can 

11 testify under penalty of perjury, that any 

12 members of The Satanic Temple who resided in 

13 Scottsdale did not use the form reflected in the 

14 Internet archive of January 15, 2013 which is 

15 Exhibit 47? 

16 A Well, we know as a matter of fact that 

17 we've had members join that are members in 

18 Scottsdale well after this Web site in this form 

19 was active. 

20 Q That wasn't my question. 

21 As of February 8, 2016 do you know if any 

22 of the five members who resided in Scottsdale did 

23 not use the form reflected in Exhibit 47? 

24 A Yes. 

25 Q How many? 

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1 A Let me see. We know that between -- 

2 between February and April of 2016 we had five 

3 members sign up from Scottsdale. So they would 

4 have been in -- they would have been on the -- on 

5 the current Web site, not this -- 

6 Q Well, hold on a second. 

7 So between February and April of 2016 five 

8 members who resided in Scottsdale signed up. Is 

9 that what you testified to? 

10 A Correct. Yeah. 

11 Q So I'm asking you as of February 8, that 

12 date --

13 A Uh-huh. 

14 Q -- as of February 8, 2016, do you know if 

15 any members of The Satanic Temple resided in the 

16 City of Scottsdale? 

17 A As of February 8th if any members resided 

18 in Scottsdale. 

19 Q Correct. 

20 A I -- I cannot say that with certainty. 

21 Q Okay. As of February 8, 2016, that date, 

22 did any members of The Satanic Temple who resided 

23 in Scottsdale utilize the form reflected in 

24 Exhibit 47? Do you know? 

25 A I do not know, and I do not know if we 

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1 kept record of any of the people who signed up on 

2 this form at all so --

3 Q Okay. 

4 A -- it's just -- I just don't know. 

5 Q And as of February 8, 2016 do you know, 

6 such that you can testify under penalty of 

7 perjury, that any members of The Satanic Temple 

8 who resided in Arizona did not adhere to the nine 

9 tenets reflected in Exhibit 28? 

10 (Pause.)

11 A Not at the moment, not at the immediate 

12 moment, but we could do a search for everybody 

13 who signed up post this Web site up and to that 

14 date. 

15 Q But you haven't done that to prepare for 

16 your deposition today. 

17 A I -- I do not have that. 

18 Q Okay. You were asked if The Satanic -- 

19 You were asked if United Federation of Churches 

20 LLC maintains a database of addresses, and you 

21 were asked about the TST member newsletter. Does 

22 the United Federation of Churches LLC publish the 

23 TST member newsletter? 

24 A I do not know that the newsletter has been 

25 given explicit corporate entity ownership. 

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1 Q Do you know if engaging in religious 

2 activities is a law -- was a lawful activity 

3 under chapter 156 of the Massachusetts General 

4 Laws as of February 8, 2016? 

5 A As opposed to illegal? 

6 Q Well, do you know if engaging in a 

7 religious activity by a limited liability company 

8 was a lawfully permitted activity of a limited 

9 liability company under Massachusetts General Law 

10 156C as of February 8, 2016? 

11 A I'm sorry. That's a question I never 

12 thought to ask because I never thought there 

13 could be any -- any question that that would be 

14 lawful. 

15 Q Okay. So does the answer, then -- You 

16 don't know? 

17 A Correct. 

18 Q You were asked about whether you had 

19 breached a contract -- or been threatened with a 

20 breach of contract lawsuit. Are there any 

21 written contracts between the United Federation 

22 of Churches LLC and you whereby you are conferred 

23 the authority to act as a manager or agent of 

24 that entity? 

25 A Well, we just looked at -- I'm -- I'm 

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1 defined as resident agent, I think we saw in the 

2 documentation. 

3 Q I'm asking you about contracts. Are there 

4 any written agreements supported by consideration 

5 where you are authorized to act as anything other 

6 than a resident agent of the United Federation of 

7 Churches LLC? 

8 A Not that I can recall. 

9 Q Do you know for a fact that Mr. Soling -- 

10 Such that you could testify under penalty of 

11 perjury, do you know for a fact that you informed 

12 Mr. Soling of Michelle Shortt's desire to give an 

13 invocation before a City of Scottsdale Council 

14 meeting prior to February 8, 2016? 

15 A Was -- Now, to clarify, was February 8th, 

16 2016 supposed to be the date that the invocation 

17 would be delivered? 

18 Q That's just the date I'm using for my 

19 question. 

20 So do you know if prior to February 8, 

21 2016 -- Such that you could testify under penalty 

22 of perjury, do you know that prior to that date 

23 you informed Mr. Soling of Michelle Shortt's 

24 desire to give an invocation before a City of 

25 Scottsdale Council meeting? 

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1 A Given my deficiency on recollecting dates, 

2 all I can say is that Mr. Soling was informed, as 

3 I was being informed, through me that this was in 

4 process, that Michelle wanted to give the 

5 invocation in Scottsdale. 

6 Q When in time did you inform Mr. Soling 

7 that Michelle Shortt was going to request the 

8 ability from the City of Scottsdale to give an 

9 invocation prior to a City of Scottsdale Council 

10 meeting? 

11 A I can give you proximity within events 

12 that happened between Michelle and I by which I 

13 would say that I would speak to Mr. Soling within 

14 the day of having spoken to Michelle about 

15 requesting to give an invocation in Scottsdale. 

16 Q But you cannot give me a date? 

17 A Correct. Yeah, I can -- I cannot. 

18 Q Then you said "Michelle and Stu approached 

19 us." Is it accurate to say that the United 

20 Federation of Churches LLC never made a decision 

21 as an organization to ask Michelle Shortt to 

22 speak on its behalf in the State of Arizona? 

23 A It would be accurate to say we gave 

24 permission to Michelle to speak on behalf of our 

25 beliefs in Scottsdale. 

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1 Q That wasn't my question. 

2 My question is is it accurate to say that 

3 the United Federation of Churches LLC never asked 

4 Michelle Shortt to act as its spokesperson in the 

5 State of Arizona? 

6 A I -- I'm having a little trouble 

7 understanding the distinction because the 

8 request -- the idea originated from Arizona. So 

9 if the question is did we reach out to Arizona 

10 and request that they represent us in Scottsdale, 

11 the answer is no. It was the other way round. 

12 Q Great.

13 MR. CLAUS: That's all I have. 

14 MR. KEZHAYA: Okay. I have -- I have one 

15 final question. 

16 

17 RECROSS EXAMINATION BY MR. KEZHAYA: 

18 Q Doug, are you -- Actually I have -- I have 

19 one final topic that may be multiple questions. 

20 Doug, United Federation of Churches has an 

21 operating agreement. Right? 

22 A Yes. 

23 Q Are you a party to that operating 

24 agreement? 

25 A How do you mean "party"? 

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1 Q Like did you sign the operating agreement? 

2 A Yes, it's my understanding that I did. 

3 Q Did you sign it as a member? 

4 A For the LLC. I'm -- I'm a member. 

5 Q Yes. 

6 A Yes. 

7 Q Okay. And so to -- to clarify, you signed 

8 the operating agreement for United Federation of 

9 Churches LLC as a member of that LLC. Right? 

10 A Correct. 

11 Q Okay. 

12 MR. KEZHAYA: That's all I got. 

13 

14 FURTHER REDIRECT EXAMINATION BY MR. CLAUS: 

15 Q And you're sure of that under penalty of 

16 perjury? 

17 A Yes. Yes. 

18 Q And do you know when that happened? 

19 A No. I'm -- I'm not good at that. 

20 Q Okay. 

21 MR. CLAUS: Do you want to read and sign? 

22 MR. KEZHAYA: Yeah. Same -- Same thing, 

23 Doug. We read and sign. We get it back to the 

24 court reporter inside of 30 days. 

25 THE WITNESS: I'm sorry. 

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1 MR. KEZHAYA: Okay. 

2 THE WITNESS: We do the transcripts once 

3 it's available. Right? Okay. 

4 MR. KEZHAYA: Yeah. So we're going to -- 

5 We're off the record. Right? 

6 MR. CLAUS: Yes, let's go off the record. 

7 (Discussion off the record.)

8 (The proceedings adjourned at 1:01 PM.)

9 (Exhibits Numbers 7, 10, 11, 12, 13, 14, 

10 15, 16, 27, 28, 37, 42 and 47 marked for 

11 identification.)

12

13

14

15

16

17

18

19

20

21

22

23

24

25

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1

2 STATE OF ___________________)

3 ) ss.

4 COUNTY OF __________________)

5

6

7

8 I, DOUGLAS ALEXANDER MISICKO, a witness called to 

9 testify in the matter of SATANIC TEMPLE ET AL. 

10 vs. CITY OF SCOTTSDALE ET AL., do hereby certify 

11 under penalty of perjury that I have read the 

12 foregoing transcript and have made any 

13 corrections, additions or deletions that I was 

14 desirous of making; and that the foregoing is a 

15 true and accurate record of my testimony therein. 

16

17

18 Signed by me on the _____ day of _______________ 

19

20 20 _____ at _________________, _________________.

21 (City) (State)

22

23

24 _________________________________

25 DOUGLAS ALEXANDER MISICKO

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1 COMMONWEALTH OF MASSACHUSETTS

2 COUNTY OF SUFFOLK

3

4 I, Lawrence A. Brown, Certified Shorthand 

5 Reporter Number 1430F96, Registered Professional 

6 Reporter and Notary Public in and for the 

7 Commonwealth of Massachusetts, do hereby certify 

8 that the foregoing transcript of the proceedings 

9 therein described is a complete and accurate 

10 record of same to my best knowledge and belief 

11 and that the deponent requested review of the 

12 transcript. 

13

14 I further certify that I am not related to 

15 or employed by any party in or counsel to this 

16 matter and that I am not financially interested 

17 in its outcome. 

18

19 In witness whereof, I hereunto set my hand 

20 on the 26th day of September 2019. 

21

22

23 ____________________________________

24 Lawrence A. Brown, Notary Public

25 My commission expires July 2, 2021

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documentary 35:14,18

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everybody 75:12

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expires 83:25

explained 71:20

explicit 62:13 75:25

explicitly 29:7 37:13

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expressed 53:4,6

expresses 60:16

expressly 52:7

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failure 19:16

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false 25:14 26:14 35:19

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February 5:9,12 9:14,15

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Federations 9:6

fee 71:18

fees 10:19

file 1:25 19:16

filed 4:17,18,19 8:11

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filings 22:16 23:9 34:8

film 50:22 65:25

final 79:15,19

financially 83:16

find 58:16,16

fine 20:22 61:19 68:5

firmly 43:5,8,15,18,21

45:8

first 4:13 5:3 7:20 8:5,8

8:14,21 15:24 17:14

28:1 29:2,6 31:4,21

35:7 51:9,14,22 52:1

66:15

fit 48:25

five 14:20 67:1 73:22

74:2,7

Focusing 8:2

following 1:12

follows 6:11

foregoing 82:12,14 83:8

foreign 29:10

forgo 48:15

form 49:17 54:21 59:12

60:11 61:4,14 62:3,7

62:20 63:4,11,17 64:7

64:14 66:11 71:23

73:7,13,18,23 74:23

75:2

formalization 71:24

formally 8:25

formation 71:9

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foundational 42:9

foundations 65:10

founding 41:9 42:7

frame 8:10 9:16,18,24

11:18 13:2,4

framed 8:4,8

frames 13:14

free 57:12

freedom 48:13

freedoms 48:12,15

full 65:24

function 29:7 57:8

fundamental 46:14,15

46:23 47:7,18

further 80:14 83:14

G

G 6:1

general 17:8,11,15 18:23

21:11 22:14 25:24

28:11 61:16 76:3,9

generally 61:5

geographic 9:25

give 9:23 13:10 37:9

42:6 45:17 56:16

62:18,22 63:2,9,15,21

68:2 72:22,24 77:12

77:24 78:4,8,11,15,16

given 8:6,18 9:5,25

32:22 35:9 37:10,13

38:21 55:19 75:25

78:1

giving 68:9

GL.c 26:3

go 7:20 10:2 11:22,25

22:23 24:8 25:5,18

26:20 29:24 30:18

31:1 43:25 46:5,5,22

50:2 53:13 60:12 63:2

68:7,7,22 81:6

god 43:9 44:14,18,22,25

God's 44:16

goes 50:20

going 6:14 19:12 24:17

38:11,11 44:10 47:11

78:7 81:4

good 80:19

gotcha 16:16

governing 55:10,16

granted 41:1

Great 6:16 22:3 23:6

79:12

guess 64:6 66:8

guiding 49:19

Guy 2:4

H

H 4:11 5:1

Haan 35:20

Hail 35:14,18 45:3

hand 83:19

handed 53:12

handing 46:1

handwritten 18:13 21:21

22:24

Hang 57:17

happen 63:20

happened 65:1 78:12

80:18

happening 64:1

harm 49:8

head 55:6,23,23 56:4,4

heading 44:6

hear 44:24

hears 43:16

held 43:5,8,15,18,21

45:8

hereunto 83:19

history 50:20

Hmm 41:3

hold 41:15 50:24 58:25

74:6

human 45:1

I

idea 52:11 66:1 68:9

79:8

identification 15:12

81:11

identified 6:8 10:11,17

11:9 15:14 16:20 17:4

20:2,7,8,10,12,20,21

21:8,12 32:17,21

33:14,17 41:11,25

42:24 50:24 51:7

68:25 70:3

identifies 12:18 16:7,7

16:10 17:8 18:9,23

19:24 22:9,11,14,20

27:3,6 30:6 32:9 41:22

51:9,14

identify 20:15 32:13

35:19 56:13

identifying 5:10

identity 10:10,23 11:14

14:24 15:6 60:17

illegal 76:5

immediate 42:6 65:24

75:11

impacts 25:15 26:16

imperfect 44:17

incidental 26:7

includes 61:9

including 10:17 26:4

48:13 50:9

incorrect 43:24 51:5

indicated 23:12 33:25

indicating 54:6

indication 42:7

indirectly 38:19

individual 34:19

individuals 50:23

inform 78:6

informed 77:11,23 78:2

78:3

inserted 46:1

inside 80:24

insofar 57:5

inspire 49:20

instance 15:6 50:25

institutions 47:23

intentionally 61:23

interact 44:17

interested 83:16

Internet 42:18 70:24

73:14

interpersonal 55:4

interruption 71:14

interstate 30:15

intervene 44:18

inviolable 48:5

invited 71:2,17

invites 70:17

invocation 39:23 42:8

62:18,22 63:9,15 64:4

66:15 68:2,10 72:22

72:23,25 77:13,16,24

78:5,9,15

IRS 28:18

issue 62:11

J

January 5:15 44:4 47:3,4

47:19 48:10 51:9,16

51:20 70:5,6,12,24

71:1 73:14

Jarry 24:23

Jim 2:2

join 54:3 70:14,17,25

71:2,18 73:17

July 10:12 12:6,11,19

14:4,6,14,19 15:2,14

83:25

justice 45:3 47:21 49:21

K

Kathy 2:3

keep 59:12

kept 75:1

Kezhaya 3:3,4 4:8 14:23

24:25 25:5,17 26:19

30:16 41:15,18,20

42:15,17 45:19,22,25

46:9,11,16,20,22,25

53:15 56:16,19,23

58:21 59:1,4,8,10

68:14 70:20 79:14,17

80:12,22 81:1,4

kind 31:15 42:9 57:13,13

65:5,13 66:4,4 69:16

Klapp 2:2

know 7:24 8:9 9:12,20

10:23 11:1,3,4,6 12:22

12:25,25 13:5,15,23

14:1,5,12,17,22,24

15:3,4,6,7,23 19:14,19

20:13,19,22 24:14,17

24:22,24 25:2,10,12

26:14,21 30:10,11

31:12,16 34:7,16,21

34:23 35:4 36:16,22

37:8,8,12,23 38:13,14

39:13 40:6,6,19,22,23

40:24 41:2,8,8,10 45:7

50:1,3,7,17 52:10,16

52:17 54:9 55:25

58:15,16 67:19 68:10

69:3,4,15,17 70:4

71:22 72:1,4,11 73:3,3

73:4,10,16,21 74:1,14

74:24,25,25 75:4,5,24

76:1,6,16 77:9,11,20

77:22 80:18

knowable 45:2

knowledge 9:10 15:16

15:17,19 25:8,20

28:19 29:16,20 71:8

72:13 83:10

knowledgeable 7:4,6

10:9,16 11:9,14

known 11:2 45:1 66:25

Korte 2:3

L

L 3:11

lack 9:25

lag 42:4

language 32:6

late 65:21,21

law 3:3 20:14 24:18

25:10 26:22 76:2,9

lawful 17:20 18:24 21:15

22:17 26:2 61:10,13

76:2,14

lawfully 35:2 76:8

Lawrence 1:22 83:4,24

laws 47:23 76:4

lawsuit 76:20

Layne 2:2

leadership 10:18 55:22

56:6 58:11,12

lectures 60:23

legal 28:24 29:1 30:19

35:4 36:3

legally 24:22

legislative 62:18 63:9

68:2

let's 11:22,25 21:21

33:19 46:11 53:13

58:22 63:7,7 81:6

letter 26:22

level 60:22

liab 18:3

liability 7:11 18:3 19:4,9

20:7,14,21 26:3 29:10

32:14 76:7,9

liaison 55:23 56:5,7

liaisons 58:13

licensing 31:15 34:25

38:23

life 45:3

limited 7:11 18:2 19:4,9

20:7,14,21 26:3,4

29:10 32:14,22 76:7,8

line 8:13 17:13 20:10,13

21:12 32:10

list 6:24 32:17

listed 7:4 21:5 33:15,18

literal 43:11

literature 26:6

litigation 8:4,16 9:4

little 67:16 79:6

Littlefield 2:4

LLC 1:15 6:21 7:8,10 8:7

8:19,20 9:6,7 13:24

15:24 16:5,8,11,20

17:5,10,25 18:9 19:14

19:20,24 20:4 21:19

22:6,21 26:11,25

27:14,18 28:2,8,17,23

29:3,9,13,17,24 30:7

31:1,6,8 32:4 34:10,20

34:24 35:10 36:2,8,19

37:2,5,15,20,25 38:3,7

38:15,18 39:9,12,16

39:19 51:3,24 55:10

55:15,25 57:1 58:3

72:4 75:20,22 76:22

77:7 78:20 79:3 80:4,9

80:9

logo 50:24,25 51:2,5

long 65:8

look 6:17,23 12:1 21:21

23:21 27:20 32:7

45:15

looked 34:7 35:7 67:5

76:25

looking 70:21

looks 45:22 46:17

Los 72:25

lot 50:15

M

mail 59:25

mailing 15:10,15,20

66:25

maintain 59:18,22

maintained 69:15

maintains 75:20

making 26:14 82:14

Malcolm 24:23

manager 16:10,12,16,21

17:4 18:9 20:11,12

22:11 27:23 28:1 32:3

32:9,14,18,22 33:3,4,6

33:14,17 34:10 36:2,7

36:18,23 37:1 38:8,14

39:8,15 76:23

managers 27:6,9

mankind's 44:22

manner 19:17 22:15

mark 30:14,15,23 51:8

70:23

marked 70:23 81:10

Massachusetts 1:18

8:20 9:7 17:6 19:16

20:14 24:18 25:10

26:15 76:3,9 83:1,7

material 44:19 50:15

55:7 57:5 65:8 66:17

Matt 45:18 53:14 58:20

68:6 71:21,21

matt@kezhaya.law 3:7

matter 73:16 82:9 83:16

Matthew 3:4

Mayor 1:11

McClain 3:5

mean 8:11 17:11 50:19

61:15 68:5 69:5 71:5

73:4 79:25

meaning 45:3

means 6:8 44:16

media 55:23 56:5,7

58:12

meet 38:20

meeting 77:14,25 78:10

member 10:18 32:5

39:24 40:3,7,16 52:15

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 224 of 319
Page 4

 Atkinson-Baker, Inc.

 www.depo.com

 September 24, 2019 

 30(b)(6): Douglas Misicko

52:16 54:13,24 55:11

55:17 56:1,9 57:21

58:9,14 60:4 72:5,11

75:21,23 80:3,4,9

members 1:11 9:12,20

10:11,24 11:1,4,15

12:23 13:5,16 14:2,6

14:13,17,24 15:1,13

43:6 52:18,21 53:2

59:11,23,24 60:1,6,8,9

60:14 67:1,10 70:8,17

71:2,17 73:5,12,17,17

73:22 74:3,8,15,17,22

75:7

membership 10:16,19

14:16 40:19,20,25

53:8 54:4,9 55:21

67:15 72:9 73:7

MENTION 4:13 5:3

merchandise 26:6 28:15

metaphorically 43:13

Michelle 1:5 17:3 20:2

35:20 36:1,6,17 37:3,7

38:16 39:10,17,21,24

40:6,12,15 50:2,4 52:6

54:18,19,23 62:17,21

63:8,13,14,25 64:2,11

64:13,18 66:14 68:8

72:21,22,24 77:12,23

78:4,7,12,14,18,21,24

79:4

Michelle's 64:20

mine 45:16,17 70:21

minimum 9:23 11:1,4,6

13:2 14:15,20 66:24

67:1,8

Misicko 1:16 4:3 6:6

31:22 82:8,25

mislead 61:23

misleading 27:16 35:19

35:23

misrepresent 57:9

missing 45:16

mission 46:13,17

mistake 49:7

Mm-hmm 37:21

moment 42:15 75:11,12

moored 43:5 45:9

multiple 79:19

N

N 4:1 6:1

name 16:15 20:11 24:23

25:9,14 32:13 52:1

names 15:7,10

narrow 61:19

nascent 42:12

National 37:11

navigate 41:16 56:17

necessarily 57:11 60:17

necessary 47:22

need 6:14 72:14

needn't 56:10

never 11:2 17:4 28:19,19

29:9 48:24 52:11

76:11,12 78:20 79:3

new 65:9,13

Newbury 1:17,18

newsletter 60:2,4,5,7,10

60:18 75:21,23,24

nine 46:23 47:18 48:2,10

48:20 49:4,12 53:4

54:16 55:2 65:2 66:9

68:25 69:7 70:2 75:8

nobility 49:20

nonSatanist 58:8

North 3:12

Northeast 3:5

Notary 1:22 6:10 83:6,24

notice 4:15 6:19 10:11

10:17 25:1 30:17

notified 27:12,15

noting 66:24

number 1:25 4:13 5:3

9:17,24,25 10:15,22

11:1,6,10 12:4,8,9,12

12:17 13:2,2,11 14:15

14:20 15:13 16:13,14

17:13 24:9 32:20

35:17 45:20 47:15

48:22 49:14 66:20,22

66:25 67:3,8,12,22

83:5

numbers 46:2 81:9

O

O 6:1

object 24:25 30:16 63:16

63:18 70:20 72:20

objection 25:17 26:19

objectionable 57:7

obligation 59:11

obtain 40:10

October 5:5,6

offend 48:13

offer 21:2

Office 4:24 30:12 34:17

officer 27:23

official 46:2 54:4 57:21

Oh 7:16 10:5 12:13

16:16 18:15 23:15,16

25:5 34:1 45:17 46:16

47:5 50:7 66:16

okay 6:18 7:2 8:1,15

9:12,19 10:3 11:3,3,20

11:25 12:3,13,21

13:10,13,21 14:11

16:14,16 18:21 19:7

19:23 20:19 21:1,6

22:4 23:15,16,20,24

24:4,16 25:7,19,22

26:23 30:1,21 32:8

33:1,19,20 34:1,1,23

35:25 36:15 37:23

38:11 39:2 41:20

42:17,20 44:1 45:25

46:4,8,11,22,25 47:6

49:16 50:1 52:5,12

53:2,20,22 54:9,12,23

55:9 56:15,19 57:15

57:17 58:19 59:4,17

60:3,8 61:20 63:20

65:1 66:7,19 67:3,8,11

67:23 68:13 69:13

71:13 73:10 74:21

75:3,18 76:15 79:14

80:7,11,20 81:1,3

old 65:8 66:16

on-boarding 10:18

once 64:24 81:2

one's 48:5,6,15,23,25

49:7

ongoing 47:22

openly 56:13

operate 31:12

operating 37:16,18,23

38:2,6,24 39:1 79:21

79:23 80:1,8

operational 31:13

operations 10:16 61:25

opposed 53:5 69:6 76:5

option 57:14

organization 4:16,20 9:2

16:4,19 21:13 23:10

23:18 24:2,3 25:16

26:16 36:20 39:25

57:9 65:14 78:21

organizational 25:13

27:17 34:8 35:9 37:10

organized 15:24 16:21

29:4

organizer 17:16

original 5:24,24 23:17

23:17,22

originated 79:8

outcome 83:17

outlined 67:10

outside 24:25 30:16

44:15 57:7

overtook 66:5

owner 31:5,23

ownership 30:24 75:25

P

P 6:1

pack 53:21

page 1:12 2:1 5:7,8,11

5:14 7:21 8:13 12:8,14

12:15,17 16:23 17:14

18:12,14,21 21:22

22:23 24:8 25:22,24

27:21 31:1,5 32:20

44:2 46:2,5,9,10,21

51:2 57:15 58:7 68:21

70:12

Pages 1:11

paginated 56:21

papers 61:20

paperwork 20:18 21:4

65:16

paragraph 7:21,23 8:2

8:14 35:7

parchment 71:19

part 57:18 60:20 65:20

65:21 66:9 68:11

71:12

parts 63:7

party 79:23,25 83:15

pass 64:11

Passport 6:9

paste 57:13

Patent 4:24 30:12 34:17

Pause 7:25 11:21,24

13:22 23:7 24:15

29:21 40:5 53:16 67:7

67:24 75:10

pay 71:18 72:5,12,15

penalties 24:19

penalty 13:6,15 14:2,12

25:15 30:13 73:5,11

75:6 77:10,21 80:15

82:11

penned 72:25

people 15:8 49:6 56:12

58:17 59:14,25 60:5,7

60:13,20,20,22 66:21

75:1

perception 69:17

perfection 44:16

performed 26:2

perjury 13:6,15 14:2,12

24:19 25:15 30:14

73:5,11 75:7 77:11,22

80:16 82:11

permission 36:3,9,18,19

37:10,13 38:21,22

78:24

permitted 35:1 76:8

person 7:3 27:10 31:10

31:11,21 65:7 67:20

Phillips 2:4

philosophical 50:12

65:10

Phoenix 3:13 42:8

physical 44:16,23

place 34:22 65:11

placed 57:6

placeholder 50:10 65:6

68:23 69:1,9,25

Plaintiffs 1:7 3:8

play 55:10 57:1

played 55:16

PLC 3:3

please 6:23 19:6 22:3

26:23 28:4 29:25

41:14 43:25

PLLC 3:10

pluralism 28:14

PM 1:20 81:8

point 43:22 45:4 61:19

pop 46:3

positions 55:23

post 75:13

posted 42:5

prayers 43:16 44:24

preceded 68:11

preceding 2:1

predated 65:4 71:22

predates 50:10 71:9,11

71:23

predicate 52:4

preparation 40:14,18

prepare 38:4 75:15

present 58:23

preside 43:10 44:19

pretyped 17:14

prevail 47:22 49:22

previous 7:15 22:15

69:25

previously 68:20

principle 49:19

Print-out 4:23

prior 21:13 35:25 36:6

36:13,16 37:25 64:3

77:14,20,22 78:9

probably 64:18

proceedings 81:8 83:8

process 10:18 78:4

Professional 83:5

project 50:23 65:25

69:25

promote 28:13

pronoun 31:21

provide 57:11

provided 72:21

provides 12:4,10 24:7

28:13

proximity 78:11

proxy 43:10 44:20

pseudonyms 15:8

Public 1:22 6:10 83:6,24

publicly 51:18

publish 75:22

purpose 17:24 19:3

21:18 22:20 26:1,11

27:21 61:13

purposes 17:20 18:25

21:15 22:17 50:19

61:9,10

pursued 28:20

pursuit 47:22

purview 57:7

put 57:12 60:18 65:4,7

65:11

putting 61:18

Q

question 7:7,14 8:10 9:8

9:19 19:12 38:12

51:25 54:12 57:15,22

63:3,6 72:10 73:20

76:11,13 77:19 79:1,2

79:9,15

questioned 6:11

questions 52:4 68:6,15

70:6 79:19

quote 10:10 20:15,16

32:22 35:2,3 44:6,7

50:4,5,18

R

R 6:1

range 12:5,10,18 67:17

reach 79:9

read 7:23 8:12,21,24

24:13 26:8 28:4,5

44:10,11 45:5 47:11

80:21,23 82:11

reading 58:7

real 42:4

really 50:21

realm 43:19 44:18

reason 28:14 47:14

65:23

recall 55:6 65:22,23 77:8

receive 60:1 72:6,7,12

72:14

Recess 53:18

recognize 16:23 18:16

18:18 21:24 22:1,25

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 225 of 319
Page 5

 Atkinson-Baker, Inc.

 www.depo.com

 September 24, 2019 

 30(b)(6): Douglas Misicko

23:2,4

recognized 9:1 61:1,3,6

recollecting 78:1

recollection 53:7 58:8

64:17

record 11:22 28:5 46:12

53:13,17,19,20 58:23

64:16 71:15,16 75:1

81:5,6,7 82:15 83:10

records 40:13

recross 4:4 59:2 68:16

79:17

rectify 49:7

REDIRECT 4:4 68:19

80:14

reflect 69:22

reflected 31:9,23 34:18

73:8,13,23 74:23 75:9

reflects 30:24 31:5

refresh 58:7

regard 55:14 62:16

regarding 30:14

register 29:10

Registered 83:5

registration 5:5,6 30:25

33:21,24 51:4

registrations 30:22

regular 59:17 60:2

related 65:25 83:14

relative 64:10

relevance 66:17

relevant 8:4,16 9:4 30:19

religious 9:1 17:24 19:3

21:18 22:20 26:10

28:14 29:5,7 43:4 44:6

45:8 50:4 52:8,23

54:15 55:1 60:16

61:13 76:1,7

remained 65:9

remember 35:11 42:8

61:11 65:17

remove 58:4

removed 60:21

report 4:17,18,19,22

18:3,22 19:8,17 21:8

21:14 22:5 28:1,8

reported 1:21

reporter 59:21 63:1

80:24 83:5,6

reports 61:8

represent 79:10

representation 30:13

representative 7:6 27:13

37:4 38:17 39:11,18

represents 29:2

request 64:20 68:12

78:7 79:8,10

requested 59:21 63:1

83:11

requesting 42:8 78:15

require 56:7

required 32:13

requirement 52:13 60:3

resided 9:13,21 12:23

13:7,16 14:3,13,18,25

15:1,14 52:19,22 53:3

73:6,12,22 74:8,15,17

74:22 75:8

residence 15:19,21

resident 16:8 19:24 20:3

20:15,20 21:5 22:9

27:4,13 33:11,15,18

77:1,6

resides 54:24

resolve 49:8

respected 48:13

respond 44:25

responds 43:16

response 70:6

restate 63:5

restated 4:20 23:10 24:1

24:3,13

returned 5:25

review 83:11

reviewed 38:2

revising 69:17

revoked 19:20

right 6:15 23:19 32:5,16

33:13 35:6 43:6 44:13

46:7 51:15,15 53:15

58:21 59:4,8 67:23

68:14 70:22 71:6

79:21 80:9 81:3,5

Road 3:5

role 55:10,16 56:6 57:1,2

round 79:11

route 28:20

RPR 1:22

RULE 1:14

run 57:3

S

S 4:11 5:1 6:1

sale 26:5

Satan 35:14,18 43:9,16

43:19 44:19,20,22,24

44:25 45:1,3 46:18,19

Satanic 1:5 5:7,8,10,11

5:13,15 8:5,17,19,25

9:7,13,21 10:24 12:23

13:6,16 14:3,6,13,18

14:25 19:13 28:25

30:4,24 31:14,19 34:4

34:25 35:1,2,8 36:10

36:21,24 37:11 39:23

39:25 40:7,16 41:4,10

41:23 42:25 43:4,15

43:18,22 44:3,7,14

45:9 47:9 50:5,8,13,18

51:8,19,22,23 52:8,15

52:18,21,23 53:2,6

54:10,14,22,24 55:12

55:18 56:2,5,24 57:3

58:9 60:15 65:11,12

65:18 66:1,10,17,20

69:18 70:7,13,17 71:2

71:11,18,24 72:2 73:6

73:12 74:15,22 75:7

75:18 82:9

Satanist 56:1,4,8,10,13

57:19 61:1,3,6 66:2

Satanists 58:12,18

saw 77:1

saying 55:7

says 8:12 20:10 23:15,16

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Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 228 of 319
EXHIBIT D

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 229 of 319
1 

UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF NEW YORK 

UNITED FEDERATION OF CHURCHES LLC 

d/b/a THE SATANIC TEMPLE, 

 Plaintiff, 

 -againstNETFLIX, INC. and 

WARNER BROS. ENTERTAINMENT INC., 

 Defendants. 

Index No. 1:18-cv-10372 

COMPLAINT AND JURY 

DEMAND 

 Plaintiff, United Federation of Churches LLC d/b/a The Satanic Temple (“Plaintiff” or 

“TST”), by its attorneys, D’Agostino, Levine, Landesman & Lederman, LLP, for its complaint 

(the “Complaint”) against defendant, Netflix, Inc. (“Netflix”), and defendant, Warner Bros. 

Entertainment Inc. (“Warner Bros.”), alleges as follows: 

NATURE OF THE ACTION 

1. This is an action for copyright infringement, false designation of original, false 

description; and forbidden dilution under trademark dilution under 15 USC § 1125, and Injury to 

Business reputation dilution under New York General Business Law § 360-l, all arising out of 

Warner Bros.’s production and Netflix’s distribution of the original Netflix television series known 

as the Chilling Adventures of Sabrina (the “Sabrina Series”), and advertisements thereof, which 

prominently feature, benefit from and defame TST’s unique original expression (the “TST 

Baphomet with Children”) of the historic Baphomet, an androgynous goat-headed deity. Copies 

of images of the TST Baphomet with Children in its original plater cast form and current bronze 

casted form are annexed as Exhibits A-1 through A-4 and Exhibit B. 

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 230 of 319 Case 1:18-cv-10372-LAP Document 1 Filed 11/08/18 Page 1 of 18
2 

2. This case presents, among other things, a textbook example of the hornbook 

explanation of copyright protection that copyright law protects unique expressions, but not the 

ideas themselves. What makes this case particularly striking and significant is that it arises in the 

context of Defendants who are highly sophisticated media production and distribution companies 

which blatantly misappropriated Plaintiff’s unique expression of an idea even though they have a 

long history of vigorously protecting their own intellectual property. For example, one of the 

leading Second Circuit Court of Appeals dealing with copyright protection is Warner Bros, Inc. v. 

Gay Toys, Inc., 724. F.2d 327 (1983)(involving among other things, Warner Bros.’s objections to 

“General Lee” symbols on toy cars and the Dukes of Hazard movie). Copies of side by side images 

of the TST Baphomet with Children and a Netflix scene featuring its copy thereof are annexed as 

Exhibit C. Copies of screenshots of promotions for the Sabrina Series from YouTube and its 

Instagram account are annexed as Exhibits D-1 and D-2. Exhibit D-1 is a screenshot from the 

official trailer of the Sabrina Series entitled “Chilling Adventures of Sabrina | Featurette: Inside 

the World of Sabrina Spellman [HD] | Netflix. See 

https://www.youtube.com/watch?v=DLMULlJA0Us. 

3. As explained more fully below, Baphomet is a historical deity which has a complex 

history, having been associated with accusations of devil worship against the Knight Templar. 

Baphomet historically involved a goat’s head (sometimes known as the “Sabbatic Goat”) on a 

female body associated with Lilith, a figure from Jewish mysticism sometimes considered a 

goddess of the night. The classic visual representation of idea of Baphomet is an image created in 

or about 1856 by an occult historian Eliphas Levi (the “1856 Baphomet”), which is notable for its 

use of a seated figure, with exposed large voluptuous female breasts, androgynous arms, a seeming 

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3 

male lower body and a Sabbatic Goat’s head. Id. A copy of the historic Levi drawing of Baphomet 

is annexed as Exhibit E. 

4. TST’s original expression of Baphomet, i.e., the TST Baphomet with Children, 

consists of several modifications from the historic expressions of the deity. Those original 

modifications are: (1) the placement of human children on either side, forming a triangle where 

(a) the children are male and female, respectively; (b) the children are a young male of African 

descent and young girl of Anglo-Saxon descent, respectively; (c) the human children are wearing 

particular clothes, with the girl wearing knee length sleeveless dress with a prominent high waisted 

sash, and the boy wearing a sports coat, (d) the girl has straight shoulder length hair with exposed 

ears and the boy has close cropped hair establishing African ancestry, and (2) use of an exposed 

male chest, instead of exposed large voluptuous female breasts. Importantly, these original 

expressions are misappropriated through use of an obvious copy which is featured prominently 

throughout the Sabrina Series and the central focal point of the school in the Sabrina Series which 

represents evil antagonists. 

5. The Sabrina Series depicts the evil antagonists in conformity to the “Satanic Panic” 

conspiracy theories from the 1980s. See, generally, Wikipedia “Satanic ritual abuse” (available at 

https://en.wikipedia.org/wiki/Satanic_ritual_abuse) (last visited November 7, 2018). 

6. The Sabrina Series’ evil antagonists stand in stark contrast to TST’s tenets and 

beliefs. See “Tenets,” at ¶21, below. By misappropriating TST Baphomet with Children (which 

is a registered copyright and famous mark of TST) to publish this false and defamatory depiction 

of TST, Defendants have engaged in three classes of wrong: copyright infringement (Claim 1), 

trademark violation (Claim 2), and injury to business reputation (Claim 3). 

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JURISDICTION AND VENUE 

7. This action arises under the Copyright Act of 1976 (the “Copyright Act”), 17 U.S.C. 

§§ 101 et seq., and concerns rights in an original work of authorship over which this Court has 

original and exclusive subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331 and 1338(a), as 

well as the Lanham Act, 11 U.S.C. § 1125, and also pendent and ancillary claims for Injury to 

Business Reputation under New York’s General Business Law § 360-l. 

8. The Court has personal jurisdiction under New York’s CPLR § 311 over Netflix 

because it is a foreign corporation registered to do business in the state of New York, and also 

because it maintains offices at 245 West 17th Street, New York, NY. 

9. The Court has personal jurisdiction under New York’s CPLR § 311 over Warner 

Bros. because it is a foreign corporation registered to do business in the state of New York, and 

also because it maintains offices at 1325 Avenue of the Americas, New York, NY. 

10. Venue is proper in this district pursuant to 28 U.S.C. § 1400(a). 

11. Prior to commencing this lawsuit, TST complied with all legal prerequisites. TST 

registered the TST Baphomet with Children with the United States Copyright Office and been 

granted registrations VA 2-116-092 and VA 0002124601. 

THE PARTIES 

12. Plaintiff TST is a Massachusetts limited liability company, with its principal place 

of business located at 64 Bridge Street, Salem, Massachusetts 01970. 

13. Upon information and belief, Warner Bros. is, among other things, a production 

company of motion pictures and television series. 

14. Warner Bros. is the producer of the Sabrina Series. 

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15. Upon information and belief, Netflix is, among other things, an internet distributor 

of television series. 

16. Netflix is the internet distributor of the Sabrina Series. 

FACTUAL ALLEGATIONS 

A. Historic Background of Baphomet 

17. As indicated above, Baphomet is a goat-headed, angel-winged, hermaphroditic 

(having both male and female features) deity of antiquity. Baphomet represents a conciliation of 

opposites. Baphomet is neither human nor beast, neither male nor female, neither angelic nor 

demonic. Simultaneously, Baphomet is all of these. Baphomet historically was believed to have 

a Sabbatic Goat’s head placed on the body of Lilith, a figure from Jewish mysticism sometimes 

considered the goddess of the night. Baphomet was first rendered to modern form (See Exhibit E) 

by Eliphas Levi, an occult historian, in 1856. See Dogme et Rituel de la Haute Magie (“Dogma 

and Rituals of High Magic.”) The Knights Templar were falsely accused of worshipping 

Baphomet and that subsequently became incorporated into various occult and mystical tradition. 

See, generally, Wikipedia “Baphomet” (available at https://en.wikipedia.org/wiki/Baphomet) (last 

visited November 7, 2018). The 1856 Baphomet is notable for its use of exposed large voluptuous 

female breasts, androgynous arms, and a seeming male lower body. 

B. The Satanic Temple 

18. TST is an organization founded and designed to encourage benevolence and 

empathy among people rejecting tyrannical authority, advocating practical and common-sense 

justice, and undertaking noble pursuits guided by individual will. Foundational to TST’s belief 

structure is protection of an individual’s right to make informed choices of their own free will. 

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19. TST does not promote evil and instead holds to the basic principle that undue 

suffering is bad, and that which reduces suffering is good. 

20. Satan, for TST, is a literary figure symbolic of the eternal rebel in opposition, rather 

than the personalization of evil. To TST, “Satan” is the literary Satan, meant to be a rebel against 

God’s authority, rather than an evil being, best exemplified by Milton and the Romantic Satanists, 

from Blake to Shelley to Antole France. 

21. TST believes in the pursuit of knowledge and freedom of will, based upon the 

following seven (7) tenets. 

(a) One should strive to act with compassion and empathy towards all creatures in 

accordance with reason. 

(b) The struggle for justice is an ongoing and necessary pursuit that should prevail over 

laws and institutions. 

(c) One’s body is inviolable, subject to one’s own will alone. 

(d) The freedoms of others should be respected including the freedom to offend. To 

willfully and unjustly encroach upon the freedoms of another is to forgo one’s own. 

(e) Beliefs should conform to one’s best scientific understanding of the world. 

(f) People are fallible. If one makes a mistake, one should do one’s best to rectify it 

and resolve any harm that might have been caused. 

(g) Every tenet is a guiding principal designed to inspire nobility in action and thought. 

The spirit of compassion, wisdom and justice should always prevail over the written 

or spoken word. 

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22. TST is politically aware and has, among other things, opposed The Westboro 

Baptist Church, advocated on behalf of children in public schools to abolish corporal punishment, 

and has applied for equal representation where religious monuments are place on public property. 

23. In connection with its mission, TST believes that the First Amendment of the 

Constitution of the United States mandates that the United States Government treat all religions 

equally. 

24. TST’s Baphomet with Children was designed so that after a statue of the Ten 

Commandments was donated to Oklahoma City by State Representative Mike Reitze, TST could 

donate its own unique expression of Baphomet. 

C. The Creation of the TST Baphomet with Children 

25. In or around 2013/2014, TST’s members and managers designed and

commissioned, at substantial cost and with great effort and attention to detail, the TST Baphomet 

with Children. 

26. Members and managers of TST initially created a sketch (the “Initial Sketch”), 

showing a figure somewhat similar to the 1856 Baphomet, but which was configured in a triangular 

arrangement, with a young girl of apparent Anglo-Saxon descent on the left facing Baphomet and 

a young boy of apparent African descent on the right facing Baphomet. The idea was to have the 

children looking reverentially at Baphomet. A copy of the initial sketch is attached as Exhibit F. 

27. The TST Baphomet with Children was designed to be an answer to religious display 

on public property and as an assertion of pluralism and equal status in an environment of religious 

freedom, all key tenets of TST. See also ¶ 21(b), (d). 

28. Each element of the TST Baphomet with Children was carefully and specifically 

developed from the initial sketch with an artist, commissioned on a work-for-hire basis. Among 

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other things, numerous child models were considered to find a specific expression of bi-racial 

childlike innocence by children of different races, looking up in reverence at Baphomet. An 

affirmative decision was made to put the young boy of African descent into a sports jacket instead 

of the tee-shirt in the initial sketch and to put the young girl in a sleeveless knee length dress with 

a high waist sash, rather than the dress with covered shoulders and leggings in the original sketch 

Additionally, Baphomet’s arms, which were originally angled down similar to the 1856 Baphomet, 

were raised to be a straight and rigid right angles, with prominent muscular biceps. In the 1856 

Baphomet, Baphomet’s eyes are intense and seem to imply evil; in TST Baphomet with Children, 

Baphomet’s eyes are softened to imply wisdom. 

29. TST spent countless number of hours and approximately $100,000 to develop the 

actual statue which is the now-famous TST Baphomet with Children. 

D. Extensive publicity which has made the TST Baphomet with Children a famous 

symbol of TST 

30. The public release of the TST Baphomet with Children has been subject to 

extensive world-wide publicity and media coverage which has made it a famous symbol of TST. 

31. Publicity surrounding the release of the initial drawing, the original plaster cast and 

the final bronze version, include articles in Time Magazine and The New York Time, as well as 

pieces on CBS, Fox News, the Colbert Show and Lisa Ling’s This is Life on CNN, among others, 

as follows: 

 January 6, 2014 

CBS News and Time Magazine display initial sketch 

https://www.cbsnews.com/news/group-unveils-plans-for-satan-statue-at-okla-capitol/ 

http://nation.time.com/2014/01/07/satanists-unveil-statue-for-oklahoma-capitol/

 May 1, 2014 

TST releases the first images of the plaster Baphomet still under construction in a piece for 

Vice Magazine 

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https://www.vice.com/en_us/article/xd5gjd/heres-the-first-look-at-the-new-satanicmonument-being-built-for-oklahomas-statehouse

 May 6, 2014 

Colbert Report 

http://www.cc.com/video-clips/zekn1k/the-colbert-report-satanic-monument-for-theoklahoma-state-house 

https://www.huffingtonpost.com/2014/05/07/stephen-colbert-war-on-religionamerica_n_5282574.html

 July 10, 2015 

NY Times publishes image of plaster Baphomet (not the first to do so, but a major outlet) 

https://www.nytimes.com/2015/07/11/us/a-mischievious-thorn-in-the-side-ofconservative-christianity.html?login=email&auth=login-email

 July 2015 

Fox News Video on Detroit unveiling of bronze statue 

https://www.dailymotion.com/video/x30r201

 Sept 6, 2015 

RT displays plaster Baphomet 

https://www.rt.com/usa/314775-arkansas-capitol-satanic-temple/

 November 30, 2015 

Lisa Ling, This is Life on CNN (during prime time on Sundays) 

https://www.cnn.com/videos/tv/2015/11/30/satanic-temple-lisa-ling-orig.cnn

 November 13, 2015 

Raw Story - Plaster Baphomet 

https://www.rawstory.com/2015/11/christians-unwittingly-allowed-satanists-to-ambushmissouris-anti-abortion-laws-heres-how/

 August 17, 2016 

Arkansas Times - Plaster Baphomet 

https://www.arktimes.com/arkansas/the-devil-is-in-the-details-at-the-arkansas-statecapitol/Content?oid=4538981

 November 2, 2016 

Boston College student paper - Bronze Baphomet 

http://bcheights.com/2016/11/02/reassessing-world-satanic-temple/ 

 January 25, 2017 

Arkansas Times - Plaster Baphomet 

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https://www.arktimes.com/ArkansasBlog/archives/2017/01/25/site-plan-approved-forsatanic-temple-monument-public-comment-legislative-approval-hurdles-yet-to-becleared

 May 2017 

Heavy - Plaster Baphomet 

Heavyhttps://heavy.com/news/2017/05/satanic-temple-monument-statue-salem-tenentsbaphomet-abortion/

 June 28, 2017 

Haute Macabre - Bronze Baphomet 

http://hautemacabre.com/2017/06/never-let-your-activism-be-artless-an-interview-withlucien-greaves-of-the-satanic-temple/

32. A YouTube video shows the TST Baphomet with Children as a unique work of art. 

(See https://www.youtube.com/watch?v=NrnW6-pjQa0). 

33. In 2015, coinciding with announcement of TST’s intention to donate the TST 

Baphomet with Children to Oklahoma to be placed alongside the Ten Commandments, the 

Oklahoma Supreme Court overturned the statutory framework which permitted the Oklahoma Ten 

Commandments monument. See Prescott v. Okla. Capitol Pres. Comm'n, 2015 OK 54, 373 P.3d 

1032. 

34. Following that, TST Baphomet with Children was repurposed to be paired with a 

then-proposed Ten Commandments monument in Arkansas. Litigation in Arkansas is ongoing. 

See Cave v. Martin, (4:18-cv-00342) (E.D. Ark.). 

35. TST’s website, at all relevant times, explained that TST’s Baphomet with Children 

was a unique expression, noting that TST Baphomet with Children has a “male chest” and picturing 

Baphomet with two children, a small boy and small girl, looking up at the Sabbatical Goat head of 

the statute. TST’s website further explains that the TST Baphomet with Children is on display in 

an art gallery and is being offered to other states where a religious statute appears on publiclyowned land. TST’s website explains the relationship of the TST Baphomet with Children to the 

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First Amendment mission of TST to ensure that government treats all religions equally. A copy 

of the Baphomet page of TST’s website is attached as Exhibit G.

36. Partly due to the extensive broadcasted depictions of TST Baphomet with Children, 

both bronze-cast and plaster-cast, as well as the efforts of TST to publicize its mission in 

connection with the TST Baphomet with Children, this statue has become a famous mark which 

is inextricably linked with TST. 

E. The Sabrina Series 

37. The Sabrina Series is a fictional television series based upon issues of magic and 

mischief colliding as a half-human, half-witch teenager named Sabrina navigates between two 

worlds: mortal teen life and her family legacy, the Church of the Night. 

38. This series was produced by Warner Bros. and distributed by Netflix. The Sabrina 

Series was released to the public on October 26, 2018. 

39. Shortly prior to airing, featurettes and advertisements were circulated on public 

media, such as YouTube and Instagram. Upon information and belief, these advertisements 

included the misappropriated TST Baphomet with Children, such as the image on Exhibits D-1 

and D-2. 

40. Defendants misappropriated the TST Baphomet Children in ways implying that the 

monument stands for evil. Among other morally repugnant actions, the Sabrina Series’ evil 

antagonists engage in cannibalism and forced-worship of a patriarchal deity. 

41. The TST Baphomet with Children appears in at least 4 of the 10 episodes of the 

Sabrina Series, and numerous scenes. 

42. Defendants feature the TST Baphomet with Children as a central figure for the 

antagonists. In Episode 2 of the Sabrina Series, TST Baphomet with Children is unveiled as a 

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foreboding figure and the focal point of the Witches Academy. In the final scene of the series at 

the end of Episode 10, the main character walks in front of TST Baphomet with Children, rendering 

it a key element of the season finale. 

43. Comparison of the parties’ statues, as show in Exhibit C, demonstrates that the 

unique elements of TST’s expression of the idea of Baphomet, and particularly the use of a male 

chest rather than voluptuous large female breasts, and the configuration with a small boy and small 

girl looking at the Sabbatic Goat head of the statue, were unquestionably copied by Defendants. 

The similarities are no coincidence. Also, compare Exhibit A-1 with Exhibit D-1. 

44. By notice dated October 26, 2018, Defendants were notified of copyright violations 

inherent in Netflix’s use of the TST Baphomet with Children. Defendants have not responded. 

45. Defendants brazenly ignored TST’s demands, thereby forcing TST to file suit to 

protect its intellectual property rights. 

46. Defendants’ unauthorized reproduction and distribution of the Sabrina Series and 

advertising thereof has harmed and, if not permanently enjoined, will continue to harm the 

commercial value of TST’s copyrighted work and the rights of ownership and control which TST 

enjoys in the TST Baphomet with Children. 

47. TST seeks, among other things, a permanent injunction barring Defendants from 

reproducing and distributing the Sabrina Series utilizing images of the TST Baphomet with 

Children, and TST submits that absent the relief requested herein, Defendants will continue to 

willfully infringe TST’s copyright, trademark and common law rights. 

F. Defendants’ cavalier disregard to TST’s property rights 

48. TST’s objection to the Sabrina Series’ blatant misappropriation of the TST 

Baphomet with Children was, among other places, reported in VICE, a news media organization, 

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on October 29, 2018. See https://broadly.vice.com/en_us/article/zm9pe3/satanic-temple-claimsnetflixs-sabrina-illegally-copied-baphomet-statue (Last visited November 7, 2018). There, Lisa 

Soper (the production designer for the Sabrina Series) spoke about the statue and falsely stated, “I 

think that's kind of a coincidence.” Going further, “When you look at Baphomet, there's really 

only a couple of statues of him—which, they have their statue, and we’ve got our statue in the 

show.” “If you look at Goya paintings, if you look at a lot of the tarot cards, or the Alistair Crawley 

iterations of him—because there’s hundreds and hundreds of iterations of him, he’s always seen 

with his people around him and it’s more of like a father figure kind of thing. So depicting his 

children with him, that kind of stuff, and those kinds of elements are all kind of the same.” Soper 

further said: “But it’s no different from, in my opinion anyhow... from any other of the mass 

amounts of iterations of him that have been around.” 

49. The above is demonstrably false. Upon information and belief, Baphomet has never 

been depicted with two children gazing reverentially at the Sabbatic Goat head. Likewise, upon 

information and belief, Baphomet, prior to TST’s Baphomet with Children depictions generally 

include large exposed large voluptuous female breasts, not a male chest. The female breasts are a 

central feature of the traditional depiction of Baphomet, the hermaphroditic deity. 

50. Ms. Soper’s statement is a bold lie. That lie was designed to further damage TST 

and promote the Sabrina Series at the expense of TST and its business reputation. 

FIRST CLAIM FOR RELIEF 

(Copyright Infringement) 

51. Plaintiff repeats and realleges each and every allegation contained in paragraphs 1 

through 50 above as if fully set forth herein. 

52. The TST Baphomet with Children is an original work of authorship and is 

copyrightable under the laws of the United States. 

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53. TST is the holder of US Copyright registrations VA 2-116-0092 and VA 

002124601 for the TST Baphomet with Children. 

54. The TST Baphomet with Children is the, “most politically charged sculpture of our 

time.” See Exhibit G. See also https://salemartgallery.com/baphomet/. This puts the public, 

specifically Defendants, on reasonable notice of intellectual property issues and that the TST 

Baphomet with Children is a unique work of art that should not be misappropriated as a symbol of 

evil. 

55. Plaintiff has not assigned, licensed, or otherwise transferred any of its exclusive 

rights to Defendants or made them available for public use. 

56. Defendants are unlawfully reproducing, distributing, and selling copies of the 

Sabrina Series, including advertisements thereof which include unauthorized use of the TST 

Baphomet with Children, without authorization. This violates Plaintiff’s exclusive intellectual 

property rights. 

57. Defendants are aware that they do not have permission to reproduce, distribute, or 

sell copies of television series featuring of the TST Baphomet with Children. 

58. By failing or refusing to take down the misappropriated imagery, Defendants are 

willfully infringing upon Plaintiff’s copyright. 

59. Based upon the foregoing, Plaintiff is entitled to a judgment against Defendants in 

an amount to be determined at trial, but believed to be no less than $50,000,000.00, together with 

injunctive relief. 

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SECOND CLAIM FOR RELIEF

(False designation of original, false description; 

and forbidden dilution under trademark dilution under 15 USC 1125) 

60. Plaintiff repeats and realleges each and every allegation contained in paragraphs 1 

through 59 above as if fully set forth herein 

61. The TST Baphomet with Children is a symbol of TST. 

62. The TST Baphomet with Children is a famous mark, within the meaning of 15 USC 

§ 1125 (c). 

63. Defendants have used the TST Baphomet with Children in ways that falsely 

designate its origin and are misleading and false to the extent that the Sabrina Series indicates, 

impliedly and expressly, that the TST Baphomet with Children is a symbol of evil, associated with 

forced-devil worship, cannibalism, and murder. 

64. Among other things, TST designed and commissioned the TST Baphomet with 

Children to be a central part of its efforts to promote First Amendment values of separation of 

church and state and equal protection. Defendants’ prominent use of this symbol as the central 

focal point of the school associated with evil, cannibalism and murder blurs and tarnishes the TST 

Baphomet with Children as a mark of TST. 

65. Defendants have used the TST Baphomet with Children in ways that causes caution 

by blurring or diluting by tarnishment as a symbol of TST. 

66. Defendants’ use of the TST Baphomet with Children has injured and continues to 

injure Plaintiff. 

67. Based upon the foregoing, Plaintiff is entitled to a judgment against Defendants in 

an amount to be determined at trial, but believed to be no less than $50,000,000.00, together with 

injunctive relief. 

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THIRD CLAIM FOR RELIEF

(Injury to Business reputation dilution under New York General Business Law § 360-l) 

68. Plaintiff repeats and realleges each and every allegation contained in paragraphs 1 

through 67 above as if fully set forth herein. 

69. Defendants have used images of the TST Baphomet with Children in a way that 

injures the business reputation of TST and dilutes the distinctive quality of the TST Baphomet 

with Children as a mark of TST in violation of New York’s General Business Law Section 360-l. 

70. Among other things, TST designed and commissioned the TST Baphomet with 

Children to be a central part of its efforts to promote First Amendment values of separation of 

church and state. Defendants’ prominent use of it as the central focal point of the school associated 

with evil, cannibalism and possibly murder is injurious to TST’s business. 

71. Defendants’ use of the TST Baphomet with Children has injured and continues to 

injure Plaintiff. 

72. Based upon the foregoing, Plaintiff is entitled to a judgment against Defendants in 

an amount to be determined at trial, but believed to be no less than $50,000,000.00, together with 

injunctive relief. 

 

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DEMAND FOR RELIEF 

WHEREFORE, Plaintiff demands the following relief: 

(a) An order declaring that Defendants are liable for infringement of TST’s 

copyright in and to the TST Baphomet with Children; 

(b) An order declaring that Defendants have willfully infringed Plaintiff’s 

copyright in and to the TST Baphomet with Children; 

(c) An order pursuant to 17 U.S.C. § 504, awarding Plaintiff monetary damages 

for copyright infringement, in an amount to be established at trial but believed to exceed 

$50,000,000.00 consisting of: (i) actual damages, in an amount to be determined at trial, along 

with disgorgement of all of Netflix’s profits attributable to sales of the Sabina Series; or, (ii) in the 

alternative, statutory damages, in an amount to be determined at trial, arising from Defendants’ 

willful copyright infringement; 

(d) An order enjoining Defendants from any future reproduction or distribution 

of the Sabrina Series with the TST Baphomet with Children and requiring Defendants to digitally 

remove the TST Baphomet with Children from all future distributions of the Sabrina Series and to 

cease and desist all marketing of the Sabrina Series which uses the images of the TST Baphomet 

with Children and to deliver the TST Baphomet with Children to the Plaintiff; 

(e) An order pursuant to 17 U.S.C. § 505, awarding Plaintiff the recovery of 

attorneys’ fees, interest and costs; 

(f) An order declaring that Defendants are liable for false designation of 

original, false description and forbidden dilution under trademark dilution under 15 USC § 1125; 

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(g) An order pursuant to 15 U.S.C. 1125, awarding Plaintiff monetary damages 

in an amount to be established at trial but believed to exceed $50,000,000.00 and an injunction for 

false designation of original, false description and forbidden dilution under trademark dilution; 

(h) An order pursuant to New York General Business Law § 360-l declaring 

that Defendants are liable for injury to business reputation and dilution of a mark; 

(i) An order pursuant to New York General Business Law § 360-l, awarding 

Plaintiff monetary damages in an amount to be established at trial but believed to exceed 

$50,000,000.00 and an injunction for liable for injury to business reputation and dilution of a mark; 

(j) Reimbursement of attorneys’ fees, costs and disbursements.

(k) Such other and further relief as the Court deems just and proper. 

DEMAND FOR JURY TRIAL 

Pursuant to Rule 38 of the Federal Rules of Civil Procedure, the Plaintiff demands trial by 

jury in this action of all issues so triable. 

Dated: November 8, 2018 

D’Agostino, Levine, Landesman & 

Lederman, LLP 

By: ________/s/__________________ 

Bruce H. Lederman, Esq. 

Attorneys for the Plaintiff 

345 Seventh Ave., 23rd Floor 

New York, New York 10001 

Tel: (212) 564-9800 

Fax: (212) 564-9802 

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EXHIBIT E

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EXHIBIT F

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EXHIBIT G

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EXHIBIT H

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EXHIBIT I

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EXHIBIT J

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In The Matter Of:

The Satanic Temple and Michelle Shortt v.

City of Scottsdale, Arizona, by it City Council

30(b)(6) Deposition of The Satanic Temple

September 26, 2019

By Michelle Shortt

Original File MS092619 30(b)(6) Satanic Temple.txt

Min-U-Script® with Word Index

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 269 of 319
By Michelle Shortt

 UNITED STATES DISTRICT COURT

 DISTRICT OF ARIZONA

 The Satanic Temple and Michelle )

 Shortt, )

 )

 Plaintiffs, )

 )

 vs. ) No. CV18-00621-PHX-DGC

 )

 City of Scottsdale, Arizona, by )

 it City Council, consisting of )

 the Mayor and council members, )

 WJ Jim Layne, Suzanne Klapp, )

 Virginia Korte, Kathy )

 Littlefield, Guy Phillips, and )

 David Smith, )

 )

 Defendants. )

 )

 30(B)(6) DEPOSITION OF THE SATANIC TEMPLE

 By: Michelle Shortt

 Phoenix, Arizona

 Thursday, September 26, 2019

 11:52 a.m.

 REPORTED BY:

 Kelly M. Olhausen, RPR

 Certified Reporter

 Certificate No. 50867

 PREPARED FOR:

 ASCII/COPY

 (Certified Copy)

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 270 of 319
By Michelle Shortt

2

 1 I N D E X

 2 WITNESS PAGE

 3 MICHELLE SHORTT

 4 Examination by Mr. Claus 5

 5

 6

 7

 E X H I B I T S

 8

 Deposition

 9 Exhibits Description Marked

10

 (None marked.)

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 271 of 319
By Michelle Shortt

3

 1 30(B)(6) DEPOSITION OF THE SATANIC TEMPLE BY

 2 MICHELLE SHORTT was taken on Thursday, September 26, 2019,

 3 commencing at 11:52 a.m. at the law offices of Dickinson

 4 Wright, PLLC, 1850 North Central Avenue, Suite 1400,

 5 Phoenix, Arizona, before Kelly M. Olhausen, a Certified

 6 Reporter in the State of Arizona.

 7 COUNSEL APPEARING:

 8 DICKINSON WRIGHT, PLLC.

 By: Mr. Scot L. Claus

 9 Mr. Vail C. Cloar

 Ms. Holly M. Zoe

10 1850 North Central Avenue

 Suite 1400

11 Phoenix, AZ 85004

 (Attorneys for Defendants)

12

13 DE HAAN LAW FIRM, PLLC

 By: Mr. Stuart P. de Haan

14 101 East Pennington

 Suite 201

15 Tucson, AZ 85701

 (Attorneys for Plaintiffs)

16

17

18

19

20

21

22

23

24

25

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 272 of 319
By Michelle Shortt

4

 1 MICHELLE SHORTT,

 2 a witness herein, having been duly sworn by the Certified

 3 Court Reporter to speak the truth and nothing but the

 4 truth, testified as follows:

 5 EXAMINATION

 6 BY MR. CLAUS:

 7 Q. Ms. Shortt, I'm still Scot Claus. I still

 8 represent the City of Scottsdale.

 9 Could you please take a look at Exhibit 9?

10 Tab 9. I just realized you tucked the first amended

11 complaint into the pocket. We're going to be talking

12 about that. So maybe untuck it.

13 A. (Witness complies.)

14 Q. There you go. So Exhibit 9 to your deposition is

15 the "First Amended Notice of 30(b)(6) Deposition of The

16 Satanic Temple, a voluntary group of persons without an

17 Arizona charter, formed by mutual consent for the purpose

18 of promoting a common enterprise or prosecuting a common

19 objective."

20 Do you see that?

21 A. Yes.

22 Q. Exhibit A to Exhibit 9 lists the topics for which

23 you are designated.

24 Did you review Exhibit A to Exhibit 9 prior

25 to appearing to testify today?

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 273 of 319
By Michelle Shortt

5

 1 A. Yes.

 2 Q. And when did you first see Exhibit A to

 3 Exhibit 9?

 4 A. Yesterday.

 5 Q. I'm going to ask you to identify all -- and we're

 6 going to go through written consent, and we'll go through

 7 verbal consent.

 8 Has any individual given you written consent

 9 to file a lawsuit on their behalf?

10 A. No.

11 Q. Has any individual given you verbal consent to

12 file a lawsuit on their behalf?

13 A. Yes.

14 Q. Who?

15 A. Lucien Greaves.

16 Q. Anyone else?

17 A. I assume --

18 Q. I don't want you to assume. I want you to be

19 able to testify --

20 A. Just Lucien Greaves.

21 Q. Just Lucien Greaves, whose real name is Douglas

22 Misicko?

23 A. Yes.

24 Q. The heading and the text of the first amended

25 complaint refers to "A voluntary group of persons without

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 274 of 319
By Michelle Shortt

6

 1 an Arizona charter formed by mutual consent for the

 2 purpose of promoting a common enterprise or prosecuting a

 3 common objective."

 4 Has any person to whom the complaint

 5 refers -- and I'm referring to paragraph 11, the first

 6 amended complaint -- paragraph 11 of the first amended

 7 complaint, document 57 -- refers -- states that "At the

 8 times relevant" -- "At the relevant times of this

 9 litigation" -- I'm reading from line 8 -- line 8 of

10 paragraph 11, page 3. Just tell me when you're there.

11 A. I'm there.

12 Q. Okay. "At the relevant times of this litigation,

13 the Arizona chapter was simply a voluntary group of

14 persons without an Arizona charter formed by mutual

15 consent for the purpose of promoting a common enterprise

16 or prosecuting a common objective."

17 First, did I read that correctly?

18 A. Yes.

19 Q. Did any member of that voluntary group of persons

20 give you written authorization to file a lawsuit on their

21 behalf?

22 A. No.

23 Q. Did any member of that voluntary group of persons

24 give you verbal consent -- express verbal consent to file

25 a lawsuit on their behalf?

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 275 of 319
By Michelle Shortt

7

 1 A. I'm sorry. Am I speaking on behalf Adversarial

 2 Truth or The Satanic Temple, Inc.? Is that the thing that

 3 I was doing?

 4 Q. You've been designated as the deponent with

 5 knowledge as of the topics identified in Exhibit 9; is

 6 that correct?

 7 A. Yes.

 8 Q. So that's the deposition that I'm taking. So --

 9 A. There was no verbal consent from any of the

10 members.

11 Q. Okay. What is the common enterprise or common

12 objective --

13 A. Wait. I'm sorry. Like -- I'm sorry. The verbal

14 consent was, like, we're just discussing like, "Yes. We

15 should proceed with this."

16 Is that kind of what you're discussing?

17 Q. So I'll ask it again.

18 Has any of -- has any member of the

19 voluntary group of persons referred to in paragraph 11 of

20 the first amended complaint expressly authorized you to

21 file a lawsuit on her or his behalf?

22 A. Oh. No.

23 Q. What is the common enterprise or common objective

24 sought to be promoted through the first amended complaint?

25 A. It would be to uphold -- the common objective

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 276 of 319
By Michelle Shortt

8

 1 would be to uphold pluralism in lieu of secularism, where

 2 we feel that we should live in a pluralistic society and

 3 have everybody represented in the public forum.

 4 Q. And what was the common enterprise or common

 5 objective sought to be promoted or prosecuted when that

 6 voluntary group of persons formed?

 7 A. What the was the common goal?

 8 Q. I'll ask it again.

 9 What was the common enterprise or common

10 objective sought to be promoted or prosecuted when that

11 voluntary group of persons formed?

12 A. Pluralism.

13 Q. And that's it?

14 A. Yes.

15 Q. Did the -- when did that voluntary group of

16 persons without an Arizona chapter -- strike that.

17 When did that voluntary group of persons

18 without an Arizona charter form by mutual consent? When

19 in time?

20 A. When in time? That first meeting I was

21 mentioning was in January of 2016.

22 Q. That you did not attend?

23 A. I did not attend.

24 Q. Do you know who attended that meeting?

25 A. My co-chapter head -- or media liaison.

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 277 of 319
By Michelle Shortt

9

 1 Q. Who's that?

 2 A. Stu de Haan.

 3 Q. Did anyone else attend?

 4 A. Yes. It was Kat, Cody, James, Jeremy.

 5 Q. Anyone else?

 6 A. I don't think Morgan was there that night. I

 7 think that was it for the first meeting.

 8 Q. Was there ever another meeting -- and how did

 9 those members express their mutual consent to promote a

10 common enterprise or prosecute a common objective?

11 A. We would meet on a weekly basis.

12 Q. No, ma'am. Let me -- I'm asking you about the

13 January 2016 meeting, which is when you said is the first

14 time that voluntary group of persons formed by mutual

15 consent.

16 My question is how did that group of

17 persons -- Stu de Haan, Kat, Cody, James, and Jeremy --

18 express their mutual consent to promote a common

19 enterprise or prosecute a common objective?

20 A. Oh. By agreeing to form the council of what

21 would become the Arizona chapter.

22 Q. Did -- strike that.

23 Did a subsequent meeting of that voluntary

24 group of persons occur?

25 A. Yes.

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 278 of 319
By Michelle Shortt

10

 1 Q. When was the next meeting of that voluntary group

 2 of persons?

 3 A. It was probably the week after or the week -- or

 4 two weeks after that. We were -- at that moment, we were

 5 meeting close to a weekly basis.

 6 Q. Did you attend that meeting?

 7 A. Yes. I think I did.

 8 Q. Where was that meeting?

 9 A. Probably at Stu's house. Stu's house.

10 Q. You are --

11 A. Sorry.

12 Q. And I understand -- no, no. It's fine. You

13 don't have to apologize. I do -- and I know it's

14 nerve-racking, but I do want to make sure I get your best

15 testimony. But I also want you to be careful. I don't

16 want you to say something that you think might be true but

17 then turns out not to be. So that's the only reason I'm

18 saying -- so you said, "Probably Stu's house."

19 Do you know for a fact that it was Mr. de

20 Haan's house?

21 A. Yes. We don't -- we did not meet anywhere else

22 other than Stu's house at the time. Yes.

23 Q. And where did Mr. de Haan live? You don't have

24 to give me address or anything. But where did Mr. de Haan

25 live at the time? What city?

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 279 of 319
By Michelle Shortt

11

 1 A. Tucson.

 2 Q. Do you know who attended that meeting?

 3 A. It was the same people plus Morgan.

 4 Q. And was there a meeting after that?

 5 A. Yes.

 6 Q. And did -- when did the meeting of that voluntary

 7 group of persons stop being at Mr. de Haan's house?

 8 A. Probably -- we stopped meeting there in 2018.

 9 Q. Is it true that the Arizona chapter of The

10 Satanic Temple does not currently have a physical

11 location?

12 A. Yes, that's true.

13 Q. And has that always been true?

14 A. Uh-huh.

15 Q. "Yes"?

16 A. Yes. Yes.

17 Q. When is the first time persons other than Stu de

18 Haan, Kat, Cody, James, Jeremy, Morgan, and Michelle met?

19 In other words, when is the first time that

20 more than Stu, Kat, Cody, James, Jeremy Morgan, and

21 Michelle met as a voluntary group of persons formed by

22 mutual consent?

23 A. It was the day of our -- I don't remember the

24 exact day. It was the day of our supposed Phoenix

25 invocation, which did not happen. In lieu of that, we

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 280 of 319
By Michelle Shortt

12

 1 decided to have a meet-up in the area -- and we attended a

 2 concert -- and another person met us there.

 3 Q. Who?

 4 A. Mitch. What was his last name? Mitch -- I don't

 5 remember his last name.

 6 Q. What was the concert?

 7 A. At The Gates.

 8 Q. Is that the name of the band?

 9 A. Yeah.

10 Q. The -- when is the next -- when is the first time

11 that Robert Almora [sic] --

12 A. Armola.

13 Q. Armola. I'm so sorry.

14 When is the first time that Robert Armola

15 attended a meeting of the voluntary group of persons

16 identified in the first amended complaint?

17 A. Oh, that was our first event in Tucson. Oh, I

18 don't remember the exact day. I can't remember the exact

19 day.

20 Q. What was the name of the event?

21 A. It was a meet-and-greet. It was just AZ's first

22 meet-and-greet at God's Bar, or the -- it's called the

23 Meat Rack in Tucson, Arizona.

24 Q. You said TST AZ's first meet-and-greet?

25 A. Yes.

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 281 of 319
By Michelle Shortt

13

 1 Q. So did TST Arizona have a website at that time?

 2 A. No.

 3 Q. Did it have a Facebook page?

 4 A. Yes.

 5 Q. Had TST Arizona officially formed as a chapter at

 6 the time of that first meet-and-greet?

 7 A. Yes.

 8 Q. Did the voluntary group of persons without an

 9 Arizona charter -- I'm going to ask it this way. And if

10 you can't answer it, I understand, because of the way I'm

11 wording it. And then I'll ask it in a way I think you can

12 answer it.

13 It's a weird way to start out a question,

14 but did the voluntary group of persons without an Arizona

15 charter referred to in paragraph 11 of the first amended

16 complaint previously have an Arizona charter?

17 That's exactly the look I was expecting.

18 Can you not answer it that way? Let me ask it a better

19 way.

20 A. Okay.

21 Q. Do you know if there had ever been a limited

22 liability company or corporate entity formed that had an

23 Arizona chapter -- strike that. I keep saying "chapter."

24 So strike all of that.

25 Do you know if there had ever been a limited

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 282 of 319
By Michelle Shortt

14

 1 liability company or corporation formed that had an

 2 Arizona charter that had been either suspended or revoked

 3 as of January 2016?

 4 A. No.

 5 Q. "No," you don't know? Or, "No," you know of no

 6 such corporation?

 7 A. I know -- no, I know of no such corporation.

 8 Q. Have any members of the voluntary group of

 9 persons without an Arizona charter referred to in

10 paragraph 11 of the first amended complaint expressly

11 authorized you to appear as the designee to give testimony

12 pursuant to the notice that is contained in Exhibit 9?

13 A. Could you repeat that?

14 (The requested portion of the record was

15 read back by the court reporter.)

16 THE WITNESS: This is Exhibit 9?

17 BY MR. CLAUS:

18 Q. No. That's the first amended complaint.

19 Exhibit 9 is the notice of deposition.

20 A. Oh, okay. Did I -- did I receive explicit notice

21 to appear?

22 Q. No. Let me ask it again.

23 So if I could have you put the first amended

24 complaint to the side. Now pull up the first page of

25 Exhibit 9, just so you have that in your head. Exhibit 9

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 283 of 319
By Michelle Shortt

15

 1 is the first amended notice of Rule 30(b)(6) deposition of

 2 The Satanic Temple, a voluntary group of persons without

 3 an Arizona charter, formed by mutual consent for the

 4 purpose of promoting a common enterprise or prosecuting a

 5 common objective.

 6 Do you see that?

 7 A. Yes.

 8 Q. And my question is did any of that voluntary

 9 group of persons -- did anyone expressly authorize you to

10 appear today to give testimony on behalf of that voluntary

11 group of persons?

12 A. Yes. I was -- I was given --

13 Q. Who?

14 A. Oh. The council decided I should be the one to

15 do the invocation.

16 Q. No, ma'am. That's not my question.

17 A. Oh. Isn't --

18 Q. Nope. So put that -- my suggestion would be to

19 not even touch that. That way, it's out of your -- it's

20 out of your physical grip and out of your mind.

21 I'm asking you about the notice of

22 deposition that brings you here today.

23 A. Oh.

24 Q. So did any member of the voluntary group of

25 persons say to you, "I authorize you, Ms. Michelle Shortt,

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 284 of 319
By Michelle Shortt

16

 1 to give testimony today on my behalf as the designee of

 2 the voluntary group of persons"?

 3 A. Oh, no.

 4 Q. How were you selected to be the deponent with

 5 knowledge to give testimony for the deposition that is

 6 contained in the notice that is Exhibit 9?

 7 A. Isn't it because I'm the plaintiff?

 8 Q. I can't answer the question. That's why I asked

 9 it.

10 A. Because I'm the plaintiff? Period? I don't

11 know. Like -- I mean, I thought the person doing the

12 suing has to do the deposing. I didn't think anyone else

13 could.

14 MR. DE HAAN: Can we take a five-minute

15 break?

16 MR. CLAUS: Yeah. Sure.

17 (A short recess was taken from 12:09 p.m. to

18 12:13 p.m.)

19 BY MR. CLAUS:

20 Q. You're still under oath, ma'am.

21 Did the voluntary group of persons referred

22 to in the first amended complaint pay membership dues to

23 become members of the Arizona chapter of The Satanic

24 Temple?

25 A. No.

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 285 of 319
By Michelle Shortt

17

 1 Q. Have there ever been membership dues?

 2 A. No.

 3 Q. Did you ever inform a representative of the City

 4 of Scottsdale that you were seeking to give an invocation

 5 on behalf of a voluntary group of persons formed by mutual

 6 consent to promote a common objective or prosecute a --

 7 strike that.

 8 Did you ever tell a representative of the

 9 City of Scottsdale that you sought to give an invocation

10 on behalf of a voluntary group of persons formed by mutual

11 consent for the purpose of either promoting a common

12 enterprise or prosecuting a common objective?

13 A. Yes.

14 Q. You used those words?

15 A. No, I did not use those words. It was the e-mail

16 that we used to submit wanting to give an invocation.

17 Q. And the e-mail said that you sought to give an

18 invocation on behalf of whom?

19 A. The Satanic Temple Arizona.

20 Q. Which had not yet entered into an affiliation

21 agreement with The Satanic Temple at the time that e-mail

22 was sent; correct?

23 A. Correct.

24 Q. Strike that. Had not yet entered into an

25 affiliation agreement with the United Federation of

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 286 of 319
By Michelle Shortt

18

 1 Churches, LLC, d/b/a The Satanic Temple; correct?

 2 A. Correct.

 3 Q. Did you identify in your e-mail to the City of

 4 Scottsdale the religion on who -- for which you sought to

 5 give an invocation?

 6 A. No. Strike that.

 7 I did not send that e-mail. That was one of

 8 our council members, Jeremy, who sent the e-mail directly

 9 to the City of Scottsdale.

10 Q. Did Jeremy, in Jeremy's e-mail, indicate that the

11 religion -- indicate the religion for which The Satanic

12 Temple Arizona sought to give an invocation?

13 A. I did not see the e-mail.

14 Q. Have you ever seen the e-mail?

15 A. I think I -- I think I saw it once and that was

16 it. And I do not recall the specific wording. But I know

17 he did mention The Satanic Temple Arizona in the e-mail

18 that we were representatives of. Whether or not he

19 specified we are of the religion of Satanism, I do not

20 know.

21 Q. Did members of the voluntary group of persons

22 referred to in paragraph 11 of the first amended complaint

23 elect members of the council to which you previously

24 referred in your testimony?

25 A. Did we elect members of our council?

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 287 of 319
By Michelle Shortt

19

 1 Q. Uh-huh.

 2 A. No. The members of the council were elected by

 3 Stu and myself.

 4 Q. And how did you and Stu get vested with the

 5 authority as members of this voluntary group of persons to

 6 elect members of a council?

 7 A. We were authorized by executive ministry, which

 8 comprises of Lucien Greaves, Malcolm Jarry, to begin

 9 forming the chapter, which -- of Arizona. And, therefore,

10 we were given the authority to form a council.

11 Q. Is there anything in writing that -- so the

12 authority you were given to elect the council was not

13 given to you by the voluntary group of persons referred to

14 in paragraph 11. It was given to you by Mr. Misicko and

15 Mr. Soleng?

16 A. Yes.

17 Q. The -- were you friends with any of the

18 individuals you mentioned -- Kat, James, Cody, Jeremy,

19 Morgan, or Mitch -- prior to January 2016?

20 A. No.

21 Q. You became friends after?

22 A. Uh-huh.

23 Q. "Yes"?

24 A. Yes. Sorry.

25 Q. Are all of those individuals still members of The

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 288 of 319
By Michelle Shortt

20

 1 Satanic Temple Arizona chapter?

 2 A. Not official members of the chapter, no. They

 3 may still be national members, but they have no active

 4 role within the chapter.

 5 Q. When did you become chapter head of the Arizona

 6 chapter? When in time?

 7 A. I would say February 2016. February or March,

 8 around there, because the Phoenix invocation thing

 9 happened. And then really, like, immediately after that,

10 they're like, "All right. You did great. Have a

11 chapter."

12 Q. Is there anything that precludes -- strike

13 that -- prevents any of those voluntary group of persons

14 from being involved in this litigation?

15 A. Huh?

16 Q. Is there anything of which you are aware that

17 prevents any member of the voluntary group of persons

18 formed by mutual consent for the purpose of promoting a

19 common enterprise or prosecuting a common objective -- is

20 there anything that prevents any of those members from

21 becoming actively part of this litigation?

22 A. I brought in as -- no. I don't -- no?

23 Q. In paragraph 14 of the first amended complaint --

24 so that document I asked you to not look at before, I'm

25 asking you to look at now. Paragraph 14 of the first

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 289 of 319
By Michelle Shortt

21

 1 amended complaint says "TST has members throughout

 2 Arizona. Some of these members reside in Scottsdale,

 3 Arizona."

 4 Let me ask you this: There came a time when

 5 the Arizona chapter of The Satanic Temple did have an

 6 Arizona charter; correct?

 7 A. There was a time where we did have an Arizona

 8 charter.

 9 Q. There became a time when Adversarial Truth, LLC,

10 was formed to operate The Satanic Temple Arizona chapter;

11 correct?

12 A. Yeah.

13 Q. And it was prior to that that this voluntary

14 group of persons without an Arizona charter formed by

15 mutual consent for the purpose of promoting a common

16 enterprise or a prosecuting a common objective; correct?

17 A. Yes.

18 Q. So do you know if The Satanic Temple had members

19 who resided in Scottsdale, Arizona, prior to the formation

20 of Adversarial Truth, LLC?

21 A. No. I do not know.

22 Q. Did you ever have a -- and I mean you, Michelle

23 Shortt. Did Michelle Shortt -- I'll ask it that way.

24 Did Michelle Shortt ever have a written

25 communication with Kelly Kuester?

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 290 of 319
By Michelle Shortt

22

 1 A. No. I don't -- do I know a Kelly Kuester?

 2 Q. Kuester is spelled K-U-E-S-T-E-R.

 3 A. No.

 4 Q. Did Michelle Shortt ever have have a written

 5 communication with any member of the city council of the

 6 City of Scottsdale?

 7 A. No.

 8 Q. Did Michelle Shortt ever have any written

 9 communication with the mayor of the City of Scottsdale?

10 A. No.

11 Q. Did Michelle Shortt ever have any written

12 communication with the city manager for the City of

13 Scottsdale?

14 A. Is that who takes the e-mails for invocations?

15 Q. No.

16 A. Okay. Then no.

17 Q. And you said that you did not send -- Michelle

18 Shortt did not send the e-mail.

19 A. No.

20 Q. Correct?

21 A. That is correct.

22 Q. All right. So I asked you about written

23 communication. Now I'm going to ask you the same types of

24 questions with verbal communications.

25 Did you ever have verbal communication of

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 291 of 319
By Michelle Shortt

23

 1 any kind -- Telephone? Anything like that? -- with Kelly

 2 Kuester?

 3 A. No.

 4 Q. Did you ever have telephonic communication with

 5 any representative of the City of Scottsdale?

 6 A. No.

 7 Q. Did you ever have a telephonic communication with

 8 any member of the city council or the mayor of Scottsdale?

 9 A. No.

10 Q. So now I've asked you about written communication

11 and verbal communication. I can't think of any other kind

12 of communication, but I'm just going to ask you.

13 Did you ever have communication of any kind

14 with any representative of the City of Scottsdale prior to

15 July 6, 2016?

16 A. No.

17 Q. So then I'm going to ask you to go to

18 paragraph 26 of the first amended complaint. Read

19 paragraph 26 to yourself, and let me know when you're

20 done.

21 A. I'm done.

22 Q. Based upon your under-oath testimony just now,

23 the allegation in paragraph 26 of the first amended

24 complaint simply is not accurate; true?

25 A. That is true. I do not recall calling anyone to

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 292 of 319
By Michelle Shortt

24

 1 request invocations. That was Jeremy's job specifically.

 2 Q. Did any member -- strike that. No. Don't strike

 3 that. Keep it.

 4 Did any member of the voluntary group of

 5 persons referred to in paragraph 11 of the first amended

 6 complaint inform the City of Scottsdale that that

 7 voluntary group of persons sought to give an invocation

 8 before a city council meeting to promote the common

 9 enterprise or prosecute the common objective of pluralism?

10 A. No. No. I mean, the one member, Jeremy, in his

11 e-mail -- I don't think he was that detailed. He was just

12 like, "Please put us on the list for an invocation."

13 There was not much dialogue after that.

14 Q. Following that e-mail -- I know that we've talked

15 about the e-mail. And you haven't seen the e-mail?

16 A. I saw it once awhile back, and it was, like,

17 super straightforward. Like, "We would like an

18 invocation." And that was it.

19 Q. Got it.

20 Since that e-mail -- so I'm talking about

21 after that e-mail, and I'll talk about it before. Let's

22 talk about before that e-mail.

23 Before that e-mail, do you know if any

24 member of the voluntary group of persons referred to in

25 paragraph 11 of the first amended complaint told a

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 293 of 319
By Michelle Shortt

25

 1 representative of the City of Scottsdale that that

 2 voluntary group of persons wished to give an invocation to

 3 promote pluralism?

 4 A. No.

 5 Q. After the e-mail that you referred to that Jeremy

 6 sent, do you know if any members of the voluntary group of

 7 persons formed by mutual consent told a representative of

 8 the City of Scottsdale that that voluntary group of

 9 persons wished to give an invocation before a City of

10 Scottsdale meeting to promote or prosecute pluralism?

11 A. No.

12 Q. Did you review the first amended complaint --

13 this document -- before it was filed?

14 A. They told me to skim it and look at it. Yes.

15 Q. And did you skim it and look at it?

16 A. Yes.

17 MR. CLAUS: I think I'm done. Let me just

18 take a quick break.

19 Oh. Did you want to say something?

20 THE WITNESS: No.

21 MR. CLAUS: Let's just take a quick break,

22 and then I think I'm done.

23 (A short recess was taken from 12:29 p.m. to

24 12:33 p.m.)

25

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 294 of 319
By Michelle Shortt

26

 1 BY MR. CLAUS:

 2 Q. Ms. Shortt, you're still under oath here. You

 3 recognize that.

 4 You're familiar with LaVeyan Satanism?

 5 A. Yes.

 6 Q. Do you know if any members of the voluntary group

 7 of persons referred to in paragraph 11 adhered to the

 8 beliefs of LaVeyan Satanism as of February 8, 2016?

 9 A. Yes.

10 Q. They did?

11 A. Well, as of February 8th? Well -- I mean,

12 religion -- the way you're trying to frame the question,

13 it's like either one or the other, which is not really the

14 case with any religion, I think, you know. Like, there's

15 some things about LaVeyan Satanism that, you know, are --

16 that resonate with some people and other things that

17 don't.

18 Q. Well -- sorry.

19 A. So to label oneself as a LaVeyan Satanist would,

20 you know, mean that one is a member of their church and,

21 you know, probably plays a membership fee or something, or

22 subscribes to their philosophy. But -- I mean, members of

23 TST, many of us came from a LaVeyan background, including

24 myself, you know. It wasn't until TST that I realized

25 that there was more to Satanism than just LaVeyan's

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 295 of 319
By Michelle Shortt

27

 1 interpretation.

 2 So to just say like, "Oh. Like, it's either

 3 one or the other," that's the wrong frame of the question,

 4 in my opinion. I'm sorry it's not a yes-or-no answer.

 5 Q. Well -- but that is my question, to which you

 6 answered "yes." So let me just ask it again.

 7 Do you have knowledge that members of the

 8 voluntary group of persons referred to in paragraph 11

 9 adhere to the beliefs espoused by Anton LaVey?

10 A. Yes, there are some. But not all.

11 Q. As of February 8th, 2016; correct?

12 A. Yes.

13 Q. And Anton LaVey's -- LaVeyan Satanism promotes a

14 belief in a literal satanic being; correct?

15 A. No, that is incorrect.

16 Q. Does LaVeyan Satanism promote magick? Spelled

17 M-A-G-I-C-K.

18 A. They do.

19 Q. Does LaVeyan Satanism articulate a belief and did

20 it articulate a belief in 2016 that magick, spelled C-K,

21 was a practice that could invoke supernatural or other

22 worldly powers?

23 A. Yes. They do say that.

24 Q. To effect change in the world; correct?

25 A. Yes.

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 296 of 319
By Michelle Shortt

28

 1 Q. And that is not a belief espoused by The Satanic

 2 Temple; correct?

 3 A. That is correct.

 4 Q. And that is not a belief espoused or adhered to

 5 by The Satanic Temple Arizona chapter; correct?

 6 A. That is correct.

 7 Q. And that was not a belief espoused by The Satanic

 8 Temple as of February 8th, 2016; correct?

 9 A. Correct.

10 Q. As a matter of fact, the belief in magic that

11 could -- by which one could utilize supernatural powers to

12 intercede in the corporeal realm is antithetical to the

13 beliefs promoted by The Satanic Temple as of February 8th,

14 2016; correct?

15 A. Yes.

16 Q. How did -- prior to the recognition -- strike

17 that.

18 Prior to the organization of the Arizona

19 chapter through the execution of the affiliation agreement

20 that is Exhibit 50, how did members of the Arizona chapter

21 of The Satanic Temple become members?

22 A. Prior to the formation of the Arizona chapter,

23 how did they become members of The Satanic Temple?

24 Q. Let me ask it that way.

25 Prior to the execution of the affiliation

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 297 of 319
By Michelle Shortt

29

 1 agreement that is Exhibit 50, through which The Satanic

 2 Temple Arizona chapter was officially created, was there a

 3 way through which a voluntary group of persons could

 4 become members of The Satanic Temple Arizona chapter?

 5 A. Yes.

 6 Q. How?

 7 A. It was through vetting. And at the time, we had

 8 a very simple application process. It was two questions:

 9 "What brought you to The Satanic Temple?" and "How much

10 time do you have in your schedule to help us with things?"

11 Q. Could you take a look at Exhibit 50 again? It

12 may be tucked in.

13 Have you ever seen a version of Exhibit 50

14 that was countersigned by a representative of the United

15 Federation of Churches, LLC?

16 A. No.

17 Q. Do you know if there has ever been an agreement

18 signed by the United -- by an authorized representative of

19 the United Federation of Churches, LLC, that confers

20 affiliation on The Satanic Temple Arizona chapter?

21 A. No.

22 Q. Do you know -- among Stu, Kat, Cody, James,

23 Jeremy, Morgan, Michelle, Mitch, and Robert -- who

24 adhered -- who among those believed in LaVeyan Satanism as

25 of February 8th, 2016?

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 298 of 319
By Michelle Shortt

30

 1 A. I did.

 2 Q. You did?

 3 A. Yeah. I came from a LaVeyan background.

 4 Q. Did anyone else?

 5 A. No. That I -- oh. Michael. Michael.

 6 Q. Did you ever stop adhering to LaVeyan Satanism?

 7 A. I take some things from it. But would I call

 8 myself a LaVeyan Satanist? No.

 9 Q. When would you have said, "I stopped calling

10 myself a LaVeyan Satanist"?

11 A. When I joined TST.

12 Q. And when was that?

13 A. That was in 2015 -- the summer of 2015 when I met

14 Brian.

15 Q. Is Brian a member of the TST?

16 A. No.

17 Q. Has he ever been?

18 A. He was. And then he -- he quit many years ago.

19 Q. You mentioned the documentary Hail Satan. I take

20 it you've seen the documentary?

21 A. I'm in it.

22 Q. I know. I know. But have you seen the

23 documentary Hail Satan?

24 A. Yeah.

25 Q. Were there any -- were there any statements in

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 299 of 319
By Michelle Shortt

31

 1 Hail Satan made by you or Mr. de Haan that, to your

 2 knowledge, were false or misleading?

 3 A. No.

 4 MR. CLAUS: That's all I've got.

 5 MR. DE HAAN: Nothing from me.

 6 MR. CLAUS: Read and sign?

 7 MR. DE HAAN: Read and sign.

 8

 9 (The deposition concluded at 12:41 p.m.)

10

11

12

13

14

15

 MICHELLE SHORTT

16

17

18

19

20

21

22

23

24

25

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 300 of 319
By Michelle Shortt

32

 1 STATE OF ARIZONA )

 ) ss.

 2 COUNTY OF MARICOPA )

 3 BE IT KNOWN that the foregoing proceedings were

 taken before me; that the witness before testifying was

 4 duly sworn by me to testify to the whole truth; that the

 foregoing pages are a full, true, and accurate record of

 5 the proceedings, all done to the best of my skill and

 ability; that the proceedings were taken down by me in

 6 shorthand and thereafter reduced to print under my

 direction.

 7

 I CERTIFY that I am in no way related to any of

 8 the parties hereto, nor am I in any way interested in the

 outcome hereof.

 9

10 [X] Review and signature was requested; any

 changes made by the witness will be attached to the

11 original transcript.

 [ ] Review and signature was waived/not

12 requested.

 [ ] Review and signature not required.

13

 I CERTIFY that I have complied with the ethical

14 obligations set forth in ACJA 7-206(F)(3) and ACJA 7-206

 J(1)(g)(1) and (2).

15 Dated at Phoenix, Arizona, this 30th day of

 September, 2019.

16

17

18 _____________________________ ______

 KELLY M. OLHAUSEN, RPR

19 Certified Reporter

 Arizona CR No. 50867

20

 * * * * *

21

 I CERTIFY that GRIFFIN & ASSOCIATES, LLC, has

22 complied with the ethical obligations set forth in ACJA

 7-206 (J)(1)(g)(1) through (6).

23

 _____________________________________

24 GRIFFIN & ASSOCIATES, LLC

 Registered Reporting Firm

25 Arizona RRF No. R1005

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 301 of 319
The Satanic Temple and Michelle Shortt v.

City of Scottsdale, Arizona, by it City Council

By Michelle Shortt 30(b)(6) Deposition of The Satanic Temple

September 26, 2019

[

[sic] (1)

 12:11

A

able (1)

 5:19

accurate (1)

 23:24

active (1)

 20:3

actively (1)

 20:21

address (1)

 10:24

adhere (1)

 27:9

adhered (3)

 26:7;28:4;29:24

adhering (1)

 30:6

Adversarial (3)

 7:1;21:9,20

affiliation (5)

 17:20,25;28:19,25;

 29:20

again (5)

 7:17;8:8;14:22;

 27:6;29:11

ago (1)

 30:18

agreeing (1)

 9:20

agreement (5)

 17:21,25;28:19;

 29:1,17

allegation (1)

 23:23

Almora (1)

 12:11

always (1)

 11:13

amended (22)

 4:10,15;5:24;6:6,6;

 7:20,24;12:16;13:15;

 14:10,18,23;15:1;

 16:22;18:22;20:23;

 21:1;23:18,23;24:5,

 25;25:12

among (2)

 29:22,24

answered (1)

 27:6

antithetical (1)

 28:12

Anton (2)

 27:9,13

apologize (1)

 10:13

appear (3)

 14:11,21;15:10

appearing (1)

 4:25

application (1)

 29:8

area (1)

 12:1

Arizona (40)

 4:17;6:1,13,14;

 8:16,18;9:21;11:9;

 12:23;13:1,5,9,14,16,

 23;14:2,9;15:3;

 16:23;17:19;18:12,

 17;19:9;20:1,5;21:2,

 3,5,6,7,10,14,19;28:5,

 18,20,22;29:2,4,20

Armola (3)

 12:12,13,14

around (1)

 20:8

articulate (2)

 27:19,20

assume (2)

 5:17,18

attend (4)

 8:22,23;9:3;10:6

attended (4)

 8:24;11:2;12:1,15

authority (3)

 19:5,10,12

authorization (1)

 6:20

authorize (2)

 15:9,25

authorized (4)

 7:20;14:11;19:7;

 29:18

aware (1)

 20:16

awhile (1)

 24:16

AZ's (2)

 12:21,24

B

back (2)

 14:15;24:16

background (2)

 26:23;30:3

band (1)

 12:8

Bar (1)

 12:22

Based (1)

 23:22

basis (2)

 9:11;10:5

became (2)

 19:21;21:9

become (6)

 9:21;16:23;20:5;

 28:21,23;29:4

becoming (1)

 20:21

begin (1)

 19:8

behalf (11)

 5:9,12;6:21,25;7:1,

 21;15:10;16:1;17:5,

 10,18

belief (7)

 27:14,19,20;28:1,4,

 7,10

beliefs (3)

 26:8;27:9;28:13

best (1)

 10:14

better (1)

 13:18

break (3)

 16:15;25:18,21

Brian (2)

 30:14,15

brings (1)

 15:22

brought (2)

 20:22;29:9

C

call (1)

 30:7

called (1)

 12:22

calling (2)

 23:25;30:9

came (3)

 21:4;26:23;30:3

can (3)

 13:11,18;16:14

careful (1)

 10:15

case (1)

 26:14

Certified (1)

 4:2

change (1)

 27:24

chapter (24)

 6:13;8:16;9:21;

 11:9;13:5,23,23;

 16:23;19:9;20:1,2,4,

 5,6,11;21:5,10;28:5,

 19,20,22;29:2,4,20

charter (13)

 4:17;6:1,14;8:18;

 13:9,15,16;14:2,9;

 15:3;21:6,8,14

church (1)

 26:20

Churches (3)

 18:1;29:15,19

City (19)

 4:8;10:25;17:3,9;

 18:3,9;22:5,6,9,12,

 12;23:5,8,14;24:6,8;

 25:1,8,9

C-K (1)

 27:20

CLAUS (8)

 4:6,7;14:17;16:16,

 19;25:17,21;26:1

close (1)

 10:5

co-chapter (1)

 8:25

Cody (6)

 9:4,17;11:18,20;

 19:18;29:22

common (31)

 4:18,18;6:2,3,15,

 16;7:11,11,23,23,25;

 8:4,4,7,9,9;9:10,10,

 18,19;15:4,5;17:6,11,

 12;20:19,19;21:15,

 16;24:8,9

communication (12)

 21:25;22:5,9,12,23,

 25;23:4,7,10,11,12,

 13

communications (1)

 22:24

company (2)

 13:22;14:1

complaint (21)

 4:11;5:25;6:4,6,7;

 7:20,24;12:16;13:16;

 14:10,18,24;16:22;

 18:22;20:23;21:1;

 23:18,24;24:6,25;

 25:12

complies (1)

 4:13

comprises (1)

 19:8

concert (2)

 12:2,6

confers (1)

 29:19

consent (22)

 4:17;5:6,7,8,11;

 6:1,15,24,24;7:9,14;

 8:18;9:9,15,18;

 11:22;15:3;17:6,11;

 20:18;21:15;25:7

contained (2)

 14:12;16:6

corporate (1)

 13:22

corporation (3)

 14:1,6,7

corporeal (1)

 28:12

correctly (1)

 6:17

council (12)

 9:20;15:14;18:8,

 23,25;19:2,6,10,12;

 22:5;23:8;24:8

countersigned (1)

 29:14

Court (2)

 4:3;14:15

created (1)

 29:2

currently (1)

 11:10

D

d/b/a (1)

 18:1

day (5)

 11:23,24,24;12:18,

 19

de (8)

 9:2,17;10:19,23,

 24;11:7,17;16:14

decided (2)

 12:1;15:14

deponent (2)

 7:4;16:4

deposing (1)

 16:12

deposition (7)

 4:14,15;7:8;14:19;

 15:1,22;16:5

designated (2)

 4:23;7:4

designee (2)

 14:11;16:1

detailed (1)

 24:11

dialogue (1)

 24:13

directly (1)

 18:8

discussing (2)

 7:14,16

document (3)

 6:7;20:24;25:13

documentary (3)

 30:19,20,23

done (4)

 23:20,21;25:17,22

Douglas (1)

 5:21

dues (2)

 16:22;17:1

duly (1)

 4:2

E

effect (1)

 27:24

either (4)

 14:2;17:11;26:13;

 27:2

elect (4)

 18:23,25;19:6,12

Min-U-Script® Griffin Group International

602.264.2230

(1) [sic] - elect

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 302 of 319
The Satanic Temple and Michelle Shortt v.

City of Scottsdale, Arizona, by it City Council

By Michelle Shortt 30(b)(6) Deposition of The Satanic Temple

September 26, 2019

elected (1)

 19:2

else (6)

 5:16;9:3,5;10:21;

 16:12;30:4

e-mail (20)

 17:15,17,21;18:3,7,

 8,10,13,14,17;22:18;

 24:11,14,15,15,20,21,

 22,23;25:5

e-mails (1)

 22:14

entered (2)

 17:20,24

enterprise (14)

 4:18;6:2,15;7:11,

 23;8:4,9;9:10,19;

 15:4;17:12;20:19;

 21:16;24:9

entity (1)

 13:22

espoused (4)

 27:9;28:1,4,7

even (1)

 15:19

event (2)

 12:17,20

everybody (1)

 8:3

exact (3)

 11:24;12:18,18

exactly (1)

 13:17

EXAMINATION (1)

 4:5

execution (2)

 28:19,25

executive (1)

 19:7

Exhibit (19)

 4:9,14,22,22,24,24;

 5:2,3;7:5;14:12,16,

 19,25,25;16:6;28:20;

 29:1,11,13

expecting (1)

 13:17

explicit (1)

 14:20

express (3)

 6:24;9:9,18

expressly (3)

 7:20;14:10;15:9

F

Facebook (1)

 13:3

fact (2)

 10:19;28:10

familiar (1)

 26:4

February (8)

 20:7,7;26:8,11;

 27:11;28:8,13;29:25

Federation (3)

 17:25;29:15,19

fee (1)

 26:21

feel (1)

 8:2

file (5)

 5:9,12;6:20,24;

 7:21

filed (1)

 25:13

fine (1)

 10:12

first (36)

 4:10,15;5:2,24;6:5,

 6,17;7:20,24;8:20;

 9:7,13;11:17,19;

 12:10,14,16,17,21,

 24;13:6,15;14:10,18,

 23,24;15:1;16:22;

 18:22;20:23,25;

 23:18,23;24:5,25;

 25:12

five-minute (1)

 16:14

Following (1)

 24:14

follows (1)

 4:4

form (3)

 8:18;9:20;19:10

formation (2)

 21:19;28:22

formed (17)

 4:17;6:1,14;8:6,11;

 9:14;11:21;13:5,22;

 14:1;15:3;17:5,10;

 20:18;21:10,14;25:7

forming (1)

 19:9

forum (1)

 8:3

frame (2)

 26:12;27:3

friends (2)

 19:17,21

G

Gates (1)

 12:7

given (7)

 5:8,11;15:12;

 19:10,12,13,14

goal (1)

 8:7

God's (1)

 12:22

great (1)

 20:10

Greaves (4)

 5:15,20,21;19:8

grip (1)

 15:20

group (43)

 4:16;5:25;6:13,19,

 23;7:19;8:6,11,15,17;

 9:14,16,24;10:1;11:7,

 21;12:15;13:8,14;

 14:8;15:2,9,11,24;

 16:2,21;17:5,10;

 18:21;19:5,13;20:13,

 17;21:14;24:4,7,24;

 25:2,6,8;26:6;27:8;

 29:3

H

Haan (6)

 9:2,17;10:23,24;

 11:18;16:14

Haan's (2)

 10:20;11:7

Hail (2)

 30:19,23

happen (1)

 11:25

happened (1)

 20:9

head (3)

 8:25;14:25;20:5

heading (1)

 5:24

help (1)

 29:10

herein (1)

 4:2

house (6)

 10:9,9,18,20,22;

 11:7

Huh (1)

 20:15

I

identified (2)

 7:5;12:16

identify (2)

 5:5;18:3

immediately (1)

 20:9

Inc (1)

 7:2

including (1)

 26:23

incorrect (1)

 27:15

indicate (2)

 18:10,11

individual (2)

 5:8,11

individuals (2)

 19:18,25

inform (2)

 17:3;24:6

intercede (1)

 28:12

interpretation (1)

 27:1

into (3)

 4:11;17:20,24

invocation (14)

 11:25;15:15;17:4,

 9,16,18;18:5,12;20:8;

 24:7,12,18;25:2,9

invocations (2)

 22:14;24:1

invoke (1)

 27:21

involved (1)

 20:14

J

James (6)

 9:4,17;11:18,20;

 19:18;29:22

January (4)

 8:21;9:13;14:3;

 19:19

Jarry (1)

 19:8

Jeremy (10)

 9:4,17;11:18,20;

 18:8,10;19:18;24:10;

 25:5;29:23

Jeremy's (2)

 18:10;24:1

job (1)

 24:1

joined (1)

 30:11

July (1)

 23:15

K

Kat (6)

 9:4,17;11:18,20;

 19:18;29:22

keep (2)

 13:23;24:3

Kelly (3)

 21:25;22:1;23:1

kind (4)

 7:16;23:1,11,13

knowledge (3)

 7:5;16:5;27:7

Kuester (4)

 21:25;22:1,2;23:2

K-U-E-S-T-E-R (1)

 22:2

L

label (1)

 26:19

last (2)

 12:4,5

LaVey (1)

 27:9

LaVeyan (13)

 26:4,8,15,19,23;

 27:13,16,19;29:24;

 30:3,6,8,10

LaVeyan's (1)

 26:25

LaVey's (1)

 27:13

lawsuit (5)

 5:9,12;6:20,25;

 7:21

liability (2)

 13:22;14:1

liaison (1)

 8:25

lieu (2)

 8:1;11:25

limited (2)

 13:21,25

line (2)

 6:9,9

list (1)

 24:12

lists (1)

 4:22

literal (1)

 27:14

litigation (4)

 6:9,12;20:14,21

live (3)

 8:2;10:23,25

LLC (5)

 18:1;21:9,20;

 29:15,19

location (1)

 11:11

look (7)

 4:9;13:17;20:24,

 25;25:14,15;29:11

Lucien (4)

 5:15,20,21;19:8

M

ma'am (3)

 9:12;15:16;16:20

magic (1)

 28:10

magick (2)

 27:16,20

M-A-G-I-C-K (1)

 27:17

Malcolm (1)

 19:8

manager (1)

 22:12

many (2)

 26:23;30:18

March (1)

 20:7

Min-U-Script® Griffin Group International

602.264.2230

(2) elected - March

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 303 of 319
The Satanic Temple and Michelle Shortt v.

City of Scottsdale, Arizona, by it City Council

By Michelle Shortt 30(b)(6) Deposition of The Satanic Temple

September 26, 2019

matter (1)

 28:10

may (2)

 20:3;29:12

maybe (1)

 4:12

mayor (2)

 22:9;23:8

mean (6)

 16:11;21:22;24:10;

 26:11,20,22

Meat (1)

 12:23

media (1)

 8:25

meet (2)

 9:11;10:21

meet-and-greet (4)

 12:21,22,24;13:6

meeting (17)

 8:20,24;9:7,8,13,

 23;10:1,5,6,8;11:2,4,

 6,8;12:15;24:8;25:10

meet-up (1)

 12:1

member (13)

 6:19,23;7:18;

 15:24;20:17;22:5;

 23:8;24:2,4,10,24;

 26:20;30:15

members (26)

 7:10;9:9;14:8;

 16:23;18:8,21,23,25;

 19:2,5,6,25;20:2,3,

 20;21:1,2,18;25:6;

 26:6,22;27:7;28:20,

 21,23;29:4

membership (3)

 16:22;17:1;26:21

mention (1)

 18:17

mentioned (2)

 19:18;30:19

mentioning (1)

 8:21

met (4)

 11:18,21;12:2;

 30:13

Michael (2)

 30:5,5

MICHELLE (12)

 4:1;11:18,21;

 15:25;21:22,23,24;

 22:4,8,11,17;29:23

might (1)

 10:16

mind (1)

 15:20

ministry (1)

 19:7

Misicko (2)

 5:22;19:14

Mitch (4)

 12:4,4;19:19;29:23

moment (1)

 10:4

more (2)

 11:20;26:25

Morgan (6)

 9:6;11:3,18,20;

 19:19;29:23

much (2)

 24:13;29:9

mutual (14)

 4:17;6:1,14;8:18;

 9:9,14,18;11:22;

 15:3;17:5,10;20:18;

 21:15;25:7

myself (4)

 19:3;26:24;30:8,10

N

name (5)

 5:21;12:4,5,8,20

national (1)

 20:3

nerve-racking (1)

 10:14

next (2)

 10:1;12:10

night (1)

 9:6

Nope (1)

 15:18

Notice (7)

 4:15;14:12,19,20;

 15:1,21;16:6

O

oath (2)

 16:20;26:2

objective (16)

 4:19;6:3,16;7:12,

 23,25;8:5,10;9:10,19;

 15:5;17:6,12;20:19;

 21:16;24:9

occur (1)

 9:24

official (1)

 20:2

officially (2)

 13:5;29:2

once (2)

 18:15;24:16

one (7)

 15:14;18:7;24:10;

 26:13,20;27:3;28:11

oneself (1)

 26:19

only (1)

 10:17

operate (1)

 21:10

opinion (1)

 27:4

organization (1)

 28:18

out (5)

 10:17;13:13;15:19,

 20,20

P

page (3)

 6:10;13:3;14:24

paragraph (17)

 6:5,6,10;7:19;

 13:15;14:10;18:22;

 19:14;20:23,25;

 23:18,19,23;24:5,25;

 26:7;27:8

part (1)

 20:21

pay (1)

 16:22

people (2)

 11:3;26:16

Period (1)

 16:10

person (3)

 6:4;12:2;16:11

persons (44)

 4:16;5:25;6:14,19,

 23;7:19;8:6,11,16,17;

 9:14,17,24;10:2;11:7,

 17,21;12:15;13:8,14;

 14:9;15:2,9,11,25;

 16:2,21;17:5,10;

 18:21;19:5,13;20:13,

 17;21:14;24:5,7,24;

 25:2,7,9;26:7;27:8;

 29:3

philosophy (1)

 26:22

Phoenix (2)

 11:24;20:8

physical (2)

 11:10;15:20

plaintiff (2)

 16:7,10

plays (1)

 26:21

please (2)

 4:9;24:12

pluralism (5)

 8:1,12;24:9;25:3,

 10

pluralistic (1)

 8:2

plus (1)

 11:3

pm (4)

 16:17,18;25:23,24

pocket (1)

 4:11

portion (1)

 14:14

powers (2)

 27:22;28:11

practice (1)

 27:21

precludes (1)

 20:12

prevents (3)

 20:13,17,20

previously (2)

 13:16;18:23

prior (9)

 4:24;19:19;21:13,

 19;23:14;28:16,18,

 22,25

probably (5)

 10:3,9,18;11:8;

 26:21

proceed (1)

 7:15

process (1)

 29:8

promote (7)

 9:9,18;17:6;24:8;

 25:3,10;27:16

promoted (4)

 7:24;8:5,10;28:13

promotes (1)

 27:13

promoting (7)

 4:18;6:2,15;15:4;

 17:11;20:18;21:15

prosecute (5)

 9:10,19;17:6;24:9;

 25:10

prosecuted (2)

 8:5,10

prosecuting (7)

 4:18;6:2,16;15:4;

 17:12;20:19;21:16

public (1)

 8:3

pull (1)

 14:24

purpose (7)

 4:17;6:2,15;15:4;

 17:11;20:18;21:15

pursuant (1)

 14:12

put (3)

 14:23;15:18;24:12

Q

quick (2)

 25:18,21

quit (1)

 30:18

R

Rack (1)

 12:23

read (3)

 6:17;14:15;23:18

reading (1)

 6:9

real (1)

 5:21

realized (2)

 4:10;26:24

really (2)

 20:9;26:13

realm (1)

 28:12

reason (1)

 10:17

recall (2)

 18:16;23:25

receive (1)

 14:20

recess (2)

 16:17;25:23

recognition (1)

 28:16

recognize (1)

 26:3

record (1)

 14:14

referred (12)

 7:19;13:15;14:9;

 16:21;18:22,24;

 19:13;24:5,24;25:5;

 26:7;27:8

referring (1)

 6:5

refers (3)

 5:25;6:5,7

relevant (3)

 6:8,8,12

religion (6)

 18:4,11,11,19;

 26:12,14

remember (4)

 11:23;12:5,18,18

repeat (1)

 14:13

Reporter (2)

 4:3;14:15

represent (1)

 4:8

representative (8)

 17:3,8;23:5,14;

 25:1,7;29:14,18

representatives (1)

 18:18

represented (1)

 8:3

request (1)

 24:1

requested (1)

 14:14

reside (1)

 21:2

resided (1)

 21:19

resonate (1)

Min-U-Script® Griffin Group International

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(3) matter - resonate

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 304 of 319
The Satanic Temple and Michelle Shortt v.

City of Scottsdale, Arizona, by it City Council

By Michelle Shortt 30(b)(6) Deposition of The Satanic Temple

September 26, 2019

 26:16

review (2)

 4:24;25:12

revoked (1)

 14:2

right (2)

 20:10;22:22

Robert (3)

 12:11,14;29:23

role (1)

 20:4

Rule (1)

 15:1

S

same (2)

 11:3;22:23

Satan (2)

 30:19,23

Satanic (25)

 4:16;7:2;11:10;

 15:2;16:23;17:19,21;

 18:1,11,17;20:1;21:5,

 10,18;27:14;28:1,5,7,

 13,21,23;29:1,4,9,20

Satanism (10)

 18:19;26:4,8,15,

 25;27:13,16,19;

 29:24;30:6

Satanist (3)

 26:19;30:8,10

saw (2)

 18:15;24:16

saying (2)

 10:18;13:23

schedule (1)

 29:10

Scot (1)

 4:7

Scottsdale (17)

 4:8;17:4,9;18:4,9;

 21:2,19;22:6,9,13;

 23:5,8,14;24:6;25:1,

 8,10

secularism (1)

 8:1

seeking (1)

 17:4

selected (1)

 16:4

send (3)

 18:7;22:17,18

sent (3)

 17:22;18:8;25:6

short (2)

 16:17;25:23

SHORTT (11)

 4:1,7;15:25;21:23,

 23,24;22:4,8,11,18;

 26:2

side (1)

 14:24

signed (1)

 29:18

simple (1)

 29:8

simply (2)

 6:13;23:24

skim (2)

 25:14,15

society (1)

 8:2

Soleng (1)

 19:15

sorry (8)

 7:1,13,13;10:11;

 12:13;19:24;26:18;

 27:4

sought (8)

 7:24;8:5,10;17:9,

 17;18:4,12;24:7

speak (1)

 4:3

speaking (1)

 7:1

specific (1)

 18:16

specifically (1)

 24:1

specified (1)

 18:19

spelled (3)

 22:2;27:16,20

start (1)

 13:13

statements (1)

 30:25

states (1)

 6:7

still (6)

 4:7,7;16:20;19:25;

 20:3;26:2

stop (2)

 11:7;30:6

stopped (2)

 11:8;30:9

straightforward (1)

 24:17

strike (11)

 8:16;9:22;13:23,

 24;17:7,24;18:6;

 20:12;24:2,2;28:16

Stu (7)

 9:2,17;11:17,20;

 19:3,4;29:22

Stu's (4)

 10:9,9,18,22

submit (1)

 17:16

subscribes (1)

 26:22

subsequent (1)

 9:23

suggestion (1)

 15:18

suing (1)

 16:12

summer (1)

 30:13

super (1)

 24:17

supernatural (2)

 27:21;28:11

supposed (1)

 11:24

sure (2)

 10:14;16:16

suspended (1)

 14:2

sworn (1)

 4:2

T

Tab (1)

 4:10

talk (2)

 24:21,22

talked (1)

 24:14

talking (2)

 4:11;24:20

Telephone (1)

 23:1

telephonic (2)

 23:4,7

Temple (24)

 4:16;7:2;11:10;

 15:2;16:24;17:19,21;

 18:1,12,17;20:1;21:5,

 10,18;28:2,5,8,13,21,

 23;29:2,4,9,20

testified (1)

 4:4

testify (2)

 4:25;5:19

testimony (7)

 10:15;14:11;15:10;

 16:1,5;18:24;23:22

therefore (1)

 19:9

thought (1)

 16:11

throughout (1)

 21:1

times (3)

 6:8,8,12

today (4)

 4:25;15:10,22;16:1

told (3)

 24:25;25:7,14

topics (2)

 4:22;7:5

touch (1)

 15:19

true (6)

 10:16;11:9,12,13;

 23:24,25

truth (5)

 4:3,4;7:2;21:9,20

trying (1)

 26:12

TST (8)

 12:24;13:1,5;21:1;

 26:23,24;30:11,15

tucked (2)

 4:10;29:12

Tucson (3)

 11:1;12:17,23

turns (1)

 10:17

two (2)

 10:4;29:8

types (1)

 22:23

U

under (2)

 16:20;26:2

under-oath (1)

 23:22

United (4)

 17:25;29:14,18,19

untuck (1)

 4:12

up (1)

 14:24

uphold (2)

 7:25;8:1

upon (1)

 23:22

use (1)

 17:15

used (2)

 17:14,16

utilize (1)

 28:11

V

verbal (9)

 5:7,11;6:24,24;7:9,

 13;22:24,25;23:11

version (1)

 29:13

vested (1)

 19:4

vetting (1)

 29:7

voluntary (42)

 4:16;5:25;6:13,19,

 23;7:19;8:6,11,15,17;

 9:14,23;10:1;11:6,

 21;12:15;13:8,14;

 14:8;15:2,8,10,24;

 16:2,21;17:5,10;

 18:21;19:5,13;20:13,

 17;21:13;24:4,7,24;

 25:2,6,8;26:6;27:8;

 29:3

W

Wait (1)

 7:13

way (11)

 13:9,10,11,13,18,

 19;15:19;21:23;

 26:12;28:24;29:3

website (1)

 13:1

week (2)

 10:3,3

weekly (2)

 9:11;10:5

weeks (1)

 10:4

weird (1)

 13:13

Who's (1)

 9:1

whose (1)

 5:21

wished (2)

 25:2,9

within (1)

 20:4

without (10)

 4:16;5:25;6:14;

 8:16,18;13:8,14;

 14:9;15:2;21:14

witness (4)

 4:2,13;14:16;25:20

wording (2)

 13:11;18:16

words (3)

 11:19;17:14,15

world (1)

 27:24

worldly (1)

 27:22

writing (1)

 19:11

written (9)

 5:6,8;6:20;21:24;

 22:4,8,11,22;23:10

wrong (1)

 27:3

Y

years (1)

 30:18

yes-or-no (1)

 27:4

Yesterday (1)

 5:4

1

11 (12)

 6:5,6,10;7:19;

 13:15;14:10;18:22;

Min-U-Script® Griffin Group International

602.264.2230

(4) review - 11

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 305 of 319
The Satanic Temple and Michelle Shortt v.

City of Scottsdale, Arizona, by it City Council

By Michelle Shortt 30(b)(6) Deposition of The Satanic Temple

September 26, 2019

 19:14;24:5,25;26:7;

 27:8

12:09 (1)

 16:17

12:13 (1)

 16:18

12:29 (1)

 25:23

12:33 (1)

 25:24

14 (2)

 20:23,25

2

2015 (2)

 30:13,13

2016 (12)

 8:21;9:13;14:3;

 19:19;20:7;23:15;

 26:8;27:11,20;28:8,

 14;29:25

2018 (1)

 11:8

26 (3)

 23:18,19,23

3

3 (1)

 6:10

30b6 (2)

 4:15;15:1

5

50 (4)

 28:20;29:1,11,13

57 (1)

 6:7

6

6 (1)

 23:15

8

8 (3)

 6:9,9;26:8

8th (5)

 26:11;27:11;28:8,

 13;29:25

9

9 (13)

 4:9,10,14,22,24;

 5:3;7:5;14:12,16,19,

 25,25;16:6

Min-U-Script® Griffin Group International

602.264.2230

(5) 12:09 - 9

Case 2:18-cv-00621-DGC Document 63-1 Filed 10/04/19 Page 306 of 319
EXHIBIT K

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EXHIBIT L

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EXHIBIT M

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