Deposition of Ali Alexander, (Dec. 9, 2021)/2:33pm

Q So I want to go back.

Mr. Alexander, earlier I believe you said words to the effect of Mr. Gosar's office or Mr. Gosar was the only Congressman that you had been in contact with. Then we heard information just now that you had been in contact with Congressman Brooks' staff. We heard Congressman Biggs.

So I'm going to ask you, what Congressmen in the December-January timeframe were you in contact with?

A Here's an answer about Biggs, Representative Biggs. I recall speaking to Representative Biggs in December. We were both speaking at a Christian event, and I introduced myself. We were backstage.

He thanked me for my peaceful protest work. I can't recall what all we said except that he had mentioned that he had talked to a group of Republican Senators and that he was optimistic about something. He mentioned Senator Rick Scott by name.

I remember being happy about that because my Stop the Steal efforts originated in 2018 to save his Senate seat.

So that's Representative Biggs.

I provided information about Representative Gosar, you know, Brooks' staff mostly. And I think, you know, there were some of these events where me and a Member of Congress spoke. Mike Kelly was at the November rally. Briefly got introduced to him by Rose Tennent. I don't think that we had a substantive conversation.

I asked at one point Ed Martin to reach out to Senator Hawley. His wife was pregnant. He was supportive of some efforts but I think couldn't participate in something that we wanted him to participate in.

Q So I want to direct you to exhibit 26 again and text messages that you produced and to page 86. And this goes back to the conversations that we were that you were describing with Congressman Brooks' staff, I believe. But I'll allow you to add color.

So on December 16th, 2020, after Mr. Ed Martin asked for Congressman Brooks' number, it looks like there—it looks like outgoing. So this is like you say to him, "Mo Brooks number works." And it looks like Mr. Ed Martin says, "Great." And then it looks like you said back, "He sent me this."

Who from Congressman Brooks' staff sent you this?

A I'm unsure, but I'm really happy that we provided this document.

Q We are, too, yeah.

 . I'm sorry. Are you saying that that was a document attached to the text, or you're saying that you're glad you provided the text that has that language in it? Like when you say, "I'm glad we provided this document," you mean the text or—

The Witness. The text message.

  .Okay.

Q Why? What is this text message? "He sent me this." Who is "he"?

A It either would have been Congressman Brooks or his staff.

Q How come we don't see anywhere on December 16th, 2020, in your texts or emails of anyone from Congressman Brooks' staff sending you this message?

A Well, I can say that, like, for example, right now, sitting here, I couldn't tell you the first or the last names of Representative Brooks' staffers that I was on the conference call with and had a substantive conversation with. And so if that evaded our search, then that evaded it. But that we put—that it is, the substance is here, you know, we're happy to provide the actual record when we find it.

Q So your testimony here today is that you can't recall anyone on Congressman Brooks' staff that you spoke to in December of 2020?

A I provided—

Q It's a yes or no.

A Yeah, I don't recall.

Q Okay. And you didn't speak to Congressman Brooks himself in December of 2020?

A Excuse me?

Q Did you speak to Congressman Brooks himself in December of 2020? Like you speaking directly to Congressman Brooks. Did you speak to him in December of 2020?

A I don't believe I verbally spoke to Congressman Brooks. And so if I got a text from this number, that's either him or his chief of staff or secretary.

Q Do you recall—let's put verbally aside. Do you recall in a written form talking to Congressman Brooks in December of 2020?

A I'm saying that this message was either from him or his staff.

Q And I guess I'm trying to figure out where this message comes from, because we don't see it in your production.

A The substance is there. And if we can find a responsive document that I still have possession of—I don't have possession of everything from December and everything from January of last year. I don't have possession of all those things.

Q I'm just trying to figure out who the "he" is in this.

A I believe it's—I believe that it's Congressman Mo Brooks or—they're doing it again. It's weird.

Sorry. Just for the record, someone was up against the glass.

Q It's the court reporter.

 . It's a fair concern though. If you see something, please don't hesitate. And we will jump up and check. I appreciate it.

The Witness. So the "he" is either Congressman Brooks or his staff. Sometimes in politics it is the Member. Sometimes it's someone representing the Member, and then someone represents that as a third party as the Member. I hope that's not confusing.

 . So help me out then. Show me anywhere in your production where you are speaking to Congressman Brooks.

The Witness. We provided, I think, you know, over a thousand text message. If it's not in here and it exists and it's in my possession, I'm instructing my counsel to go over it and look for it with our consultants and provide it?

BY  :

Q Maybe I could ask a clarifying question. A second ago you said the reach-out may be the Congressperson or it could be their staff.

How often is it the Congressperson that reaches out directly to you?

A I wouldn't know.

Q No, no, I mean just generally, like, how often do Congresspeople call you, text, or email you directly?

A That's a rare thing. Most stuff is delegated to staff, even if it's in the Member's name, is what I'm trying to, I think, explain, and I'm not doing a good job of it.

Q This is my lack of political knowledge. But I've gotten the impression from some of the folks I work with that it's actually a big deal when a Congressperson calls you, emails you, or texts you in person, like, themselves.

Do you agree with that? Like is that your perception of it or in your experience? Because, I mean, I know you're very politically active. Is it not a big deal when Congresspeople contact you directly?

 . It seems it would stick out in your mind.

The Witness. Well, I mean—

 . All I'm trying to get at is for some people, because of how politically involved they are, they talk to Congresspeople all the time and have them on speed dial. That is not my world. So if a Congressperson contacts me, it's pretty memorable.

I'm trying to gauge, where are you on that spectrum? Are you somebody who talks to Congresspeople directly all the time, or is it more a rarity when you directly talk to the Congressperson?

A It's really a mixed bag, depending on the year, whether it's an election year, and then what I'm doing. Because I was leading Stop the Steal, I was one of the more popular conservative figures in the country for 60-something days.

And, you know, what you pointed out is a real observation. And I want to acknowledge it. It's not one that I agree with, but it's not one that I dismiss. And I don't know how else to put this except for put it this way.

I've been very critical of both the Democrat and the Republican establishments. In some cases I've called the Republican establishment the "Blue Blood, Bowl Cut Boys."

And so what's interesting is a lot of these guys go to Ivy League schools, or they'll come and intern on the Hill. They'll do five internships, and I didn't have to do that.

Now, what's interesting is it's an inverse relationship. When I talk to a Member of Congress, oftentimes I'm not impressed. I'm just speaking truthfully. That's why I've never gone in and worked in government. Some of them are not impressive people. But there are a lot of people who have a wealth status far above mine who are enamored by it. And it's interesting.

So I would say it is special when I talk to a Member of Congress. But it is not unique and it's not—and while I was leading Stop the Steal, you know, I was just very popular. It's like, you know, I was leading a cause that Members wanted to be associated with.

 . So are you saying that, during that 60-day period when you were leading "stop the steal," that you so frequently talked directly to Congress people that you can't remember those occasions that you talked to them.

The Witness. I'm not saying that. A lot of my work was at the State legislature level and with bureaucrats that are either unelected or elected; it was really at the State level. And there have been periods in my life, like during the birth of the Tea Party movement or other things that I've done, where it's like, oh, I could talk to a dozen Members in a week. And that's impressive for some people. And that's—you know, I work my ass off, so I've earned it.

Mr. Kamenar. I think the witness has basically described his interaction with the various Congressmen when you went down the list, did you talk to this one? He said, in Arizona, he had a personal—

BY  :

Q I think that's—Mr. Kamenar, let me go off that.

Can you go to exhibit 3 for us? This is it looks like the stopthesteal.us website and it looks like an advertisement for "stop the coup," the rally you are talking about in Arizona, December 19th, and on it their speakers, including you, Congressman Andy Biggs, Congressman Paul Gosar. Who communicated with them to be speakers on December 19th?

A Adele (ph) is the local organizer there. And so it probably would have been a mixture of, like, one of these faces I don't even recognize or know who is.

Q Who is Adele (ph)?

A Adele (ph) is a Phoenix-based entrepreneur who shared our concerns about election integrity and was organizing there. And I was introduced to him by Congressman Gosar's chief of staff and told he was doing good work on the ground preceding my physical arrival.

Q How did the individual on Mr. Gosar's staff—or actually who was the individual on Mr. Gosar's staff who introduced you to it looks like Mr. Adele (ph) Belgate (ph)?

A I just stated that it was Congressman's chief of staff.

Q So Mr. Van Flein?

A Yes.

Q I didn't see that in your production. Was it in person, or was it a text message?

A On a phone call.

Q On a phone call?

A Yeah.

Q And what was the nature of this phone call? Why was Mr. Van Flein introducing you to Mr. Belgate (ph)?

A Because we were—they were going to host a hearing, I believe, I don't know if this is this date or another one, but my first physical trip out to Arizona—again, I don't know if that's December 19th or not—was to be in support of a legislative hearing of, like, Republican caucus members. And I needed people on the ground to coordinate with, you know, because like, okay, I've got to get picked up from the airport. I need to get signs. I need to encourage bodies there. I need to know, like, what's the situation on the ground.

Q So, at this rally, do you recall saying that you'd been on the phone with State legislatures and people from the White House? Do you remember making that claim during this speech on December 19?

A I don't remember any of the contents of my speeches from December.

Q Would it be unusual for you to say that you were on the phone with State legislatures and people from the White House?

A No, that would not be unusual.

Q So, on December 19th, what people from the White House were you in contact with?

A I don't know who I was referencing. Mary—maybe it was Garrett Ziegler.

Q I don't see Garrett Ziegler in any of your productions. Was it a phone call—

A We—

Q I was going to say was it a phone call, was it a text message, or was it an email?

A I believe having the phone call with him. I don't remember receiving any emails from him.

Q Okay.

A I don't remember receiving any text messages from him. And we did have I think one—one, you know, physical interaction in D.C. and, you know, small talk.

Q How did you have Mr. Garrett Ziegler's phone number?

A I don't know who passed it along to me.

Q Okay.

Can you go back to exhibit 26 at page 81? These are text messages. So we're going to move a day past December 19th. We're going to go to December 20th of 2020. And this is a text message to Mr. Alex Jones.

Mr. Kamenar. What's the exhibit?

 . Exhibit 26, the text messages. And that's going to be page 81.

Mr. Kamenar. Here we go. You find it?

The Witness. Yeah.

BY  :

Q So you found it? In your text message, you say, "POTUS is deciding in the next 24 to 48 hours if he wants to go all the way." What does "go all the way" mean?

A No idea. I'm talking with Alex Jones, who is prone to hyperbole, and it looks like I was, you know, buttering him up.

Q I mean, just, it might be hyperbole, but what is "go all the way" in context to?

A I have no idea.

Q So it's your testimony here today that, on December 20th, when you're telling Mr. Alex Jones that POTUS was going to decide within the next 24 hours to go all the way, you have no idea what the context of that statement was?

A It is my testimony that, sitting here today, 11 and a half months later, that I don't know what this text means. And I don't even know who would have told me. And, in context, me talking to Alex Jones, it seems kind of humorous. And I see later that Alex sends me again a hyperbolic title to one of the videos he made that he wants me to promote. It is just the nature of our relationship.

Q Did you have any contacts with anyone from the White House on December 20th to base this text on?

A I'm not sure.

BY  :

Q Could we go back for one second. A second ago, you said it is the nature of your relationship. I don't want to mischaracterize, but it sounds like you said, "The nature of our relationship is to send hyperbolic things to each other, and then we retweet them out, and we promote each other's hyperbolic things"? There is nothing illegal about that or wrong—

A I think so.

Q —with that. I just don't want to mischaracterize what he's saying.

A Yeah, yeah, yeah. He's—he loves comedy, he's extreme. He's funny. He's self-deprecating, and he uses clickbaity things. And, you know, sometimes I'll venture into that territory. Most times I don't, but, clearly, you know, we have some evidence in production that, you know, shows that I sometimes engage in hyperbole and exaggeration and, you know.

 . That's very helpful color. Thank you.

BY  :

Q Going back to this, or we're going past December 20th to December 21st. We've asked you if you recalled a meeting with Congressional Members and President Trump. You said that you do not recall that meeting, correct?

A Correct.

Q Do you recall receiving a debrief about that meeting?

A I don't recall one. I don't—today, right now, I do not recall receiving one. I have—I have volunteered in my testimony that, you know, there was some times, like, for example, when Paul Gosar had a conversation with the President or the White House and then, you know, it would be some big news or something like that.

Q Okay. But, for this specific situation, you don't recall this debrief from Mr. Gosar?

A No, that's a very specific date, and I don't even know that he was there.

Q Not date, I'm talking about the meeting.

A Yeah.

Q Do you recall Mr. Gosar debriefing you about a meeting with the President on December 21st?

A No, I don't recall that.

Q Okay. You made a comment you don't even know if he was there. Can you flip to exhibit 33 for us, please? So this is a December 21st tweet. And I apologize; the date is not on here. But Mr. Gosar says: Great meeting today with real Donald Trump and Mark Meadows and Rudy Giuliani, my homies Andy Biggs, Rep. Mo Brooks, Matt Gaetz, and others, President is resolute. We will not accept disenfranchisement of 80 million who cast a vote for POTUS. This sedition will be stopped.

You don't recall getting a debrief about this meeting that Mr. Gosar tweeted about?

A There is no date on this.

Mr. Kamenar. He said December 23rd.

Mr.   20—21st.

Mr. Kamenar. 21st?

Mr.   Yes, that's when the date is.

Mr. Kamenar. Oh, I'm sorry, I thought you said 23rd.

BY MR.  

Q Okay.

A I definitely don't recall this.

Q You don't recall this?

A I definitely do not recall this.

Q Okay. Okay. So we move past December—I am just moving chronologically now for your planning for January 6th, just to give you an idea. Right? So you have the idea around the 16th or 17th. You spoke about it at your rally on December 19th. I just went through the texts with Mr. Alex Jones on the 20th. You do not recall the congressional meeting on the 21st.

So now we're going to move to the One Nation Under God permit. You told us that Mr. Stephen Brown—you hired him to help you do it seems like planning for the January 6th. Did you tell him to file for a permit for January 6th in Washington, D.C.?

A Yeah, I have no idea how to do that by myself.

Q That's fair. No, that's fair.

So why did you—did you direct him to file the permit or apply—do the permit application under One Nation Under God?

A I know we had consultation about it. And I believe that—we had a consultation about it, and I don't know how we decided on the name. But, like I said, One Nation Under God was a coalition effort of "stop the steal," which is itself a coalition, and then other Christian and Jewish groups.

Q If I were to ask Mr. Brown whose decision it was to file the permit under One Nation Under God, it's your testimony here today that you all discussed this together and made the decision together?

A That's why I hire consultants, yeah. They consult me, and then I make a decision on what I'm comfortable with based off of expertise that I don't have.

Q So, look, I'm saying so is it your testimony here today that, if I were to ask Mr. Stephen Brown whether he consulted you on filing this application under One Nation Under God, his answer would be yes, right? That's your testimony?

A I believe so.

Q Okay. So the date on the application was December 21st, 2020. Why did you file for the application on December 21st, which happens to be the same day as the congressional meeting with the President?

A We—the horrible thing about all of this was that I announced that we are, instead of doing State capitals, we're going to go to Washington, D.C., and that our voices will be peacefully heard outside. That's on video. And, when the President announces it—I believe the 19th is when his tweet was—was a Friday late afternoon, and all of the permitting offices were closed. So that was stupid on my end because I either hadn't talked to Stephen Brown or we hadn't decided on where we wanted to—where we wanted to do it because I was so busy in the States.

And so the 21st would have been the first available date in which my consultant would have had the information or the wherewithal at the time to have filed this. This is, you know, my understanding of it all.

Q Why did you file under One Nation Under God and not under "stop the steal"?

A Because, as I've said before is—I even said this at the event where I appeared with Representative Andy Biggs, is that "stop the steal" could not just be political; it needs to be a Christian ministry as well. And that some groups didn't consider themselves political; they just wanted to pray over Democrats and Republicans, but they wanted to participate. They thought it was historic. And so we called it One Nation Under God because we also thought, well, you know, we don't want to over advertise this. And there's other events happening right by us that we want people to feel comfortable going to. If you see a big fat "stop the steal" logo, then we would be taking away from other people's events. I wanted to share the love.

Q What did you mean by "over advertise this"?

A Just logistically, if the President of the United States is saying come to D.C., then all of those people could not attend my event. I wanted them to be able to attend other events as well. We didn't "stop the steal."

Q Who is in control One Nation Under God?

A One Nation Under God is a pseudonym. And, as I understand it, based off what my consultant told me, is that on permits the event name and organization name are synonymous with each other.

Q So there's no one who's in control of One Nation Under God that could give Mr. Brown permission to file this permit under that name?

A It's a—it's more of an event name. Like, for example, I believe that I participated in an anti-CCP, pro-Uyghur event, and, like, on their application, it will say the event name under organization—from my understanding when you're dealing with these agencies, you know, these consultants tell you it doesn't have to be a (c)(4) or (c)(3). It doesn't have to have a board of directors; it just can be an event name.

Q I'm not following.

Can you go to exhibit 36 for me, please? This is going to be the actual application you submitted. And I know everything is double sided, but go to, like, the fourth physical page of exhibit 36. And box 1 says, "organization and/or spokesperson." You just said it could be the event name. Where in box 1 does it say it can be the event name?

A Well, as I just testified, that's what my consultant told me that that's a norm within it. And I didn't fill out this application; my consultant did.

Q So, if I were to go ask Mr. Stephen Brown whether it was his decision to put One Nation Under God as the organization and/or spokesperson, your testimony is that was his decision?

A My testimony is that we came up—after talking with one another, we came up with that.

Q So you had some input in putting One Nation Under God as the organization and/or spokeperson?

A Yes.

Q Why? If it wasn't an organization or a spokesperson?

A I just told you what the norms are for these applications that I have not seen.

Q Where did you get these norms from?

A The highly credentialed expert, Stephen Brown.

Q So, if were to ask Mr. Stephen Brown whether he told you the norm is that you could put One Nation Under God in box 1, your testimony is he would say yes?

A Yes. I'm not even aware that there was a box 1. I didn't see a copy of these applications before they're submitted.

Q Were you trying to keep the term "stop the steal" off the application?

A I'm—I wasn't opposed to having a "stop the steal" branded event until I thought we got a crappy lot. There are other patriots who have done great work that deserve some of the audience. I can't fit everybody. And that was my main consideration, to my best recollection, of why we chose to do something, in addition to the Christian and the Jewish groups that did not want—you know, it is the last electorial day for us.

Q So, if you go to exhibit 32, and I would direct you to the second page, the second physical page. These are text messages between you and Mr. Stephen Brown. The—

A You said 32?

Q Yep, exhibit 32.

A The second page?

Q The second physical page.

A I don't have a second page.

Q On exhibit—sorry. I must have misspoke. 34, I read the wrong tab, so I apologize. It looks like you text Mr. Brown, "I will have the team make separate One Nation Under God graphics in case the cops ask you for a copy of promo so you can deny Wild Protest being totally affiliated or whatever." It looks like you're trying to hide Wild Protest and your involvement with this application. Why?

A I don't think we're trying to hide it. Again, we're trying to disperse the crowd. And he had called me and said he needed to submit a graphic advertisement, but also that he advised that we not you know, that we not—not like over publicize One Nation Under God. And so, I said, okay. I'll have it done, because either he was going to have to have the graphic work done and charge me or I can get volunteers to do it.

Q Help me understand how, on the day of January 6th, it's your testimony here today that you were trying to direct everyone to Lot 8. "I want to get everyone off the grounds. Need to go to Lot 8." But now you're testifying, "I wanted everyone dispersed." Help me understand that difference—

A —great question. So, as I'm walking—as I'm walking and I am standing on those chairs, I'm still under this stupid belief that my event can take place, that all of this can be just deescalated and chilled out. By the time I ever make it to the northeast side, we're just trying to get people away from the building. And so whatever you have to say to get people away from the building, including "there's an alien, there's free burgers over there," you have got to get people away from the building. They were ignorantly a lot of people, what I observed personally, were ignorantly participating—for whatever reason, they were ignorantly participating in being in areas that they had no business in.

Q So, in the lead up to January 6th, you were trying to minimize "stop the steal's" involvement to have people dispersed. Correct?

A I wanted to share—I definitely wanted, you know, as full a crowd as we could have. And, as I understood it—again, my consultant is telling me sometimes you can have more people, and sometimes the cops will give you a warning, but they won't just tell you to disperse without a warning. And that is what I'm aware the norms are, and I just thumbs-up that.

Q But, on January 6th, you're not telling people to disperse onto various lots. You're telling them to go to your event on Lot 8. That's correct? Right?

A I'd refer you to my answer before my last answer, which is that it happens in two different sections. When I first see the conflict, and what I'm trying to do is get everyone over to Lot 8 because I ignorantly believe that, even though this is a little collapse of civil authority, we'll still be able to have our event. When I run into the U.S. Capitol Police officer or I don't know if he was the U.S. Capitol Police or the D.C. Metro, but I talked to a gentleman on the north side. He also says, "Go that way, go that way, go to the east and north." So he's also—the cop is reiterating what we've just reiterated, that makes me feel good. When I crossed the corner on to the east side and I am expecting a peaceful people in my stage and instead what I see is people on the plaza, people on the grounds, people on the Capitol, then I realize, oh, it wasn't just the west side that had essentially collapsed, but the east side had collapsed. I wasn't aware of that. Then it was, like, tell people to go to Lot 8 because it is the farthest point away from the physical building.

Q Did you ever file any other permits, and let's just cabin it between November of 2020 and January of 2021, under the name One Nation Under God?

A I'm unaware.

Q So why do it now?

A I think I've described why we did it.

Q So to disperse the crowd is why you did it for January 6th?

A We had political and spiritual considerations, that's first. And the second is I did want to share the love there. There were other organizers. There was an anti-CCP group, there was a Defend Medical Liberty group. And these people needed people and bodies, and we possibly could not fit all of them. And we had lost a third or a quarter of our schedule when we moved the event at the behest of the Ellipse rally.

Q So it's your testimony here today that you weren't trying to mask the involvement of "stop the steal" when you filed this permit?

A Not in any meaningful way. And I—

Q It doesn't have to be in a meaningful way, just in any way. Were you trying to mask "stop the steal's" involvement when you filed this permit on December 21st?

A I don't recall that. What I recall doing is following the advice of my consultant. And I do note there was an exchange between the officer and my consultant in which we disclosed that "stop the steal" and Ali Alexander involved in One Nation God, so I would not call that hidden.

Q Okay. So going back to this—

BY  :

Q Wait.

Mr. Alexander, I need to you look at exhibit 34. And I need you to look at the second page because there are ramifications to some of your answers today. And I need you to read your text, "I will have the team make separate One Nation Under God graphics in case the cops ask you for a copy of promo so you can being deny Wild Protest being totally affiliated or whatever." And we're going to ask you again, was it your intent to put the permit under One Nation Under God to mask WildProtest being affiliated with "stop the steal"?

A My intent was what I have stated, which was there is a political and spiritual consideration. There was a consideration—

Q I'll make it even easier, because maybe there's some confusion. Did you put the permit under One Nation Under God so that, if the cops ask for a copy, the person receiving this text—let me just make sure, Nathan—could deny that Wild Protest was affiliated with "stop the steal"?

A That was—

Mr.   The group chat with Mr. Nathan Martin, Mr. Stephen Brown, and yourself.

Mr. McBride. What page is this on?

Mr.   It's on the second page of the exhibit—

Ms.   The second page in the middle.

Mr. McBride. Sorry. The second physical page?

Ms.   Yes. I'm sorry. The second physical page.

BY  :

Q There is like a tweet, and then it says, "I will have the team make separate One Nation under God graphics in case the cops ask you for a copy of promo so you can deny WildProtest being totally affiliated or whatever."

So I will make this as clear and simple as possible, did you put the permit under One Nation Under God so that, if the cops asked for a copy of the promo, they could deny that Wild Protest was affiliated with "stop the steal"?

A The text message does not deny a relationship between Wild Protest and "stop the steal." Wild Protest had outdated information on it that was no longer true and we could not update in time because of the, you know, the moving the events. My intention was to do the right thing with the expert advice of my consultant. I do not have an expertise in permitting or the process. I am only informed of that process through my consultant. And I could only approve recommendations that I was given.

And the last consideration that I'd ask you to make is that—is that there are a lot of isolated things and, you know, that could look damning. But it is my understanding 9 from what my consultant told me and then what I've later read in congressional testimony, that even if it was—if we said, "Oh, this is "stop the steal." and we wanted to keep out the Christian groups and the Jewish groups, or we wanted all the people, that they couldn't deny it, they couldn't deny the permit. So I wasn't scared of getting denied a permit, if that's the question.

Q My question was about this text. But you actually raise a really good point that it doesn't actually say affiliated with whom. It doesn't say affiliated with "stop the steal." But the next two texts say: The application's under the name One Nation Under God. I also included Nathan's name on it. I kept yours off so you're below anybody's radar.

Was there concern that the affiliation with you would be a problem and so you didn't put you on the permit for that reason?

A Not that I'm aware of.

BY  :

Q So, if I ask Mr. Stephen Brown whether you directed him to put Mr. Nathan Martin's name on the application instead of yours, your testimony is that you did not direct him to do that?

A This message says that he directed—

Q I asked you, if I were to ask Mr. Stephen Brown whether you directed him to put Mr. Nathan Martin on the application to keep your yours off of it, he would say no?

A I don't recall.

Q You do not recall giving Mr. Nathan or Mr. Stephen Brown any directions about putting Nathan Martin's name on the application instead of you?

A I don't recall. I'm reading this text message and—

Q I'm not talking about the text message. Is it your testimony that you do not recall giving Mr. Stephen Brown any directions to put Mr. Nathan Martin's name on the application instead of yours?

A I do not specifically recall giving direction. I got consultation with my expert consultant on this matter, and he sends me a text about it. And I acknowledge it right here.

Ms.   So it's your testimony that your consultant told you to put the permit under One Name Under God?

Mr. McBride. I think that's an unfair characterization of what he said. I also feel like we've answered this question several times, several different ways.

Ms.   I will be candid with you.

Mr. McBride. Sure.

Ms.   I am really concerned. This one spoke for itself. We thought we were just clarifying what they were trying to mask. I really didn't think we were going to be debating the masking. So I want to be really careful that we are not mischaracterizing, because this one I thought was a softball of it says what it says. It's pretty clear they are masking. We just wanted to get what is it that you're trying—what are you afraid of the affiliation will be if the cops ask. Maybe that's the best way to ask it.

BY  :

Q What was the concern—who were you afraid the cops would think that it was affiliated with?

A That's a good question, because I can't imagine what the concern would be.

Q I think you can; your "stop the steal," you change it to One Nation Under God.

A We did not change it. That did not happen. That's factually incorrect.

Q Your organization was called "stop the steal." At the time that the permit was obtained, One Nation Under God I don't believe previously existed, and then it suddenly exists for the permit.

A That's the event name, which is synonymous, and this is what I am telling you. My consultant says—and my own observation and experience tells me that this is true. So my consultant is not lying to me. If someone throws an anti-CCP, pro-Uyghur event, then in line one what they put is yadda, yadda, yadda. Now, I don't it even know what the applications look like the permit applications look like, and it is a working process until the day of. So it's not a permit. It's an application, and there are all kinds of amendments or whatever. I'm not really concerned about that. There are some things that you can't do, and then there are other things that are political considerations. And I'm not worried about that because to me what I have heard from my consultant based off his conversations was they were aware, based off of Trump's tweet, that hundreds of thousands of people were going to be on the Capitol. My consultant told me that based off a conversation that he had with the U.S. Capitol Police.

So I'm not worried that we're disguising anything. And that we are following the rules. We never changed the name. We have an event to accommodate people.

And that is a one time, one shot—we weren't going to continue One Nation Under God after that.

BY MR.  :

Q So, to   point, the application has 50 people as the number of attendees. There is a text message on page 1 of the same exhibit 34 that we've been talking about where you say, "What's your say 500 people." So whose decision was it to put 50 people as the number of attendees on this permit?

A It was based off consultation. I don't know that I ever, you know—I was told that—I was told that these lots are allotted 50 people. If more people show up and it is not a problem, there is no disbursement order. If more people show up, there is either a warning or for those people to disperse and that the event itself could continue.

Q Was it you or Mr. Stephen Brown's decision to put 50 people on the application for the number of attendees?

A Oh, I think that was the U.S. Capitol Police.

Q So it was the U.S. Capitol Police's idea to put 50 people on—

A I didn't talk directly to them. But my understanding is that the advice that they give to anyone who is applying to the permit is that if you say for—this is what I heard, okay? This is total hearsay. But it's like if you say, "Oh, I'm going have 200 people," then they say, "well, you can't apply for 200 people. You can apply for 50 people." So we made sure that we had under 50 speakers so that we could comply. And I made sure that we had a camera man so that if we had no crowd and everybody is at everybody's else's event, we would still have our speakers, our camera, and we would get our moment.

Q So, I mean, kind of what   said, I thought this would be kind of a layup here. Go back to page 4 of exhibit 35. Estimated number of participants, it says 50. Date of application—

Sorry, exhibit 35. I will give you a second to get there.

The Witness. 35 or 34?

Mr.  . 34. No, no, 36, 36. Sorry. 36, page 4, it is your application that was filed on December 21st, 2020.

Ms.   I'm sorry, hard copy 4 not—

Mr.   Hard copy 4.

Ms.   I'm with you.

BY MR.  :

Q It says: Estimated number of participants, 50. You're saying that's the Capitol Police's idea to put that down?

A That's the guidance that the U.S. Capitol Police gave everyone that they talked to is what my consultant and other people told me, and I was informed of it.

Q Is it advice, or is it that you only can hold an event with 50 or less people?

A That's not true. And that's not been my experience at all.

Q So, again, when you put 50 down on this application, it is not the U.S. Capitol Police filing this application. It is a fake entity called One Nation Under God, instead of "stop the steal." Why did you make the decision to put 50 on this application?

A I didn't make that—I didn't—I didn't fill out this application. I don't have the expertise to fill out this application. I don't have originating information that would enable me to fill out this information. And One Nation Under God is not a fictitious entity, as I've described here before. It is an event name. And that is a norm that honors our First Amendment in the application process for decades.

Q You just said one One Nation Under God is not an entity; it is a name of an event. So it's not an entity. And I want to ask you so we're clear on the record, is it your testimony here today that you did not direct Mr. Stephen Brown to put 50 on this application for number of participants?

A I could not have independently, to my knowledge, directed him to fill out something in accordance with rules and conversations I wasn't having.

Q All right. So, if we ask Mr. Stephen Brown, "Did Mr. Ali Alexander tell you to put 50 on the application for the number of participants," your testimony here today is that you did not?

[Discussion off the record.]

The Witness. Yeah. Based off my recollection, I provided with—with how I understand in hindsight that number was come up with. I have no recollection of that number, you know, previously except for to say that me and the consultant had conversations or the consultant had conversations with other people, and I hadn't seen this application until months after January 6th.

 . I'm sorry. That first part was word salad for me. I think we got to go back. Can we reread   question, and then just ask him to answer it? And I apologize that may have just been—

The Witness. No, it's my fault.

 . It did not just register with me. I'm so sorry. I hate to ask you to do that.

[The reporter read back the record as requested.]

The Witness. I apologize for making the answer more complicated than it needed to be. The short answer is I do not recall.

Ms.   Okay.

BY  :

Q Do you recall discussing the number of attendees with Mr. Stephen Brown?

A I vaguely recall broad conversations about attendees and ways we could remain compliant.

Q Ways you can remain compliant by keeping the number of attendees under 50, because that's what the Capitol Police policy was at that time?

A I don't recall.

Mr.   Can we have a brief recess, please? And come back in 10 minutes, please?

Mr. McBride. Sure.

[Recess.]