Democrat politicians set to rob the public to pay reperations to slaves.

A few years ago, in our first encounter here, JoeB and I were going at it for several days as he was insisting Dark people are dumb and need help not falling for Whitey tricking them into being our slaves.
The man is a racist through and through, but like most of my and my wife's family they're too emotionally disturbed and mentally ill to realize it.

Yes, Joe is clearly just exploiting blacks for government handouts. Particularly he wants free healthcare and free retirement. In fairness, he doesn't just hate blacks, he hates everyone. It's pretty funny how he claims to want to help black people when he doesn't care about anyone but himself.

He also insists he doesn't have a bad attitude in real life. That's even funnier than his nonsense about race

Yes, all subsidies ballooned under covid. What are you arguing exactly?
That was before covid. Tariffs

Some yes, some no. What's your point?
Handouts

Again, never thought Trump was a conservative. So OK, you're telling me something I already knew and no one is disputing. I've never heard anyone say Trump is a conservative
Trump is not an political ideologue, he is more of a pragmatic centrist. That's one of the huge reasons why he is by far the greatest president in our lifetimes.
81 million Americans disagree with you

Actually it's in the 70s of millions since you said people. You mean 81 million ballots disagree with him with all the fraudulent ones the Democrats included when they stole the election
But the fact
that Fox programs pressed guests for evidence and attempted to investigate the allegations as the
story unfolded just reinforcesations because it was confident they were true; it
was covering them because it was confident they
the conclusion that a reasonable viewer would readily have

understood that Fox was not covering those allegwere newsworthy—as

Wow, I watch Fox and never saw those shows. When were they on?
MEMORANDUM OF LAW IN SUPPORT OF FOX DEFENDANTS’ MOTION TO
DISMISS PURSUANT TO THE FIRST AMENDMENT AND CPLR §§3211(a)(1), (a)(7),
and (g)
Paul D. Clement (pro hac vice forthcoming)
Erin E. Murphy (pro hac vice forthcoming)
K. Winn Allen, P.C. (pro hac vice forthcoming)
KIRKLAND & ELLIS LLP
1301 Pennsylvania Avenue, N.W.
Washington, DC 20004
Telephone: 202.289.5000
Email: [email protected]
Email: [email protected]
Email: [email protected]

I've never heard of any of those people. What shows were they on? When were they on them?
Those are fox's lawyers

So let's try this again. You said it was on fox shows. Which shows? I never saw that
121. On November 21, Ms. Pirro returned as a voice for the disinformation campaign on
Justice with Judge Jeanine. (Justice with Judge Jeanine, November 21, 2020 (Exhibit 28)). Her
apparent objective was to lend credibility to the statements that had previously been made by Mr.
Giuliani and Ms. Powell, specifically about the “affidavits” that they had been using to prop up the
fake narrative about Smartmatic. Ms. Pirro said:
Ms. Pirro: The President’s lawyers [are] alleging a company called
Dominion, which they say started in Venezuela with Cuban money and with
the assistance of Smartmatic software, [has] a backdoor [that] is capable of
flipping votes. And the President’s lawyers [are] alleging that American votes
in a presidential election are actually counted in a foreign country. These are
 
A few years ago, in our first encounter here, JoeB and I were going at it for several days as he was insisting Dark people are dumb and need help not falling for Whitey tricking them into being our slaves.
The man is a racist through and through, but like most of my and my wife's family they're too emotionally disturbed and mentally ill to realize it.

Yes, Joe is clearly just exploiting blacks for government handouts. Particularly he wants free healthcare and free retirement. In fairness, he doesn't just hate blacks, he hates everyone. It's pretty funny how he claims to want to help black people when he doesn't care about anyone but himself.

He also insists he doesn't have a bad attitude in real life. That's even funnier than his nonsense about race

Yes, all subsidies ballooned under covid. What are you arguing exactly?
That was before covid. Tariffs

Some yes, some no. What's your point?
Handouts

Again, never thought Trump was a conservative. So OK, you're telling me something I already knew and no one is disputing. I've never heard anyone say Trump is a conservative
Trump is not an political ideologue, he is more of a pragmatic centrist. That's one of the huge reasons why he is by far the greatest president in our lifetimes.
81 million Americans disagree with you

Actually it's in the 70s of millions since you said people. You mean 81 million ballots disagree with him with all the fraudulent ones the Democrats included when they stole the election
But the fact
that Fox programs pressed guests for evidence and attempted to investigate the allegations as the
story unfolded just reinforcesations because it was confident they were true; it
was covering them because it was confident they
the conclusion that a reasonable viewer would readily have

understood that Fox was not covering those allegwere newsworthy—as

Wow, I watch Fox and never saw those shows. When were they on?
MEMORANDUM OF LAW IN SUPPORT OF FOX DEFENDANTS’ MOTION TO
DISMISS PURSUANT TO THE FIRST AMENDMENT AND CPLR §§3211(a)(1), (a)(7),
and (g)
Paul D. Clement (pro hac vice forthcoming)
Erin E. Murphy (pro hac vice forthcoming)
K. Winn Allen, P.C. (pro hac vice forthcoming)
KIRKLAND & ELLIS LLP
1301 Pennsylvania Avenue, N.W.
Washington, DC 20004
Telephone: 202.289.5000
Email: [email protected]
Email: [email protected]
Email: [email protected]

I've never heard of any of those people. What shows were they on? When were they on them?
Jeanine Pirro: “Now the President's lawyers offered evidence by way of
affidavits, which I told you last Saturday as a judge, from a legal
perspective, are sworn statements of individuals signed under penalty of
perjury. Meaning they know they face the penalty of prosecution and five
years if they lie. These sworn statements are factual allegations, are part of
virtually every lawsuit. It's how you start a case. The President's lawyers
have indicated that they have 250 such affidavits under oath. People ready
to testify, people ready to face the hate that the left has inflicted upon all of
us from day one.” (Justice with Judge Jeanine, November 21, 2020 (Exhibit
28)).
 
A few years ago, in our first encounter here, JoeB and I were going at it for several days as he was insisting Dark people are dumb and need help not falling for Whitey tricking them into being our slaves.
The man is a racist through and through, but like most of my and my wife's family they're too emotionally disturbed and mentally ill to realize it.

Yes, Joe is clearly just exploiting blacks for government handouts. Particularly he wants free healthcare and free retirement. In fairness, he doesn't just hate blacks, he hates everyone. It's pretty funny how he claims to want to help black people when he doesn't care about anyone but himself.

He also insists he doesn't have a bad attitude in real life. That's even funnier than his nonsense about race

Yes, all subsidies ballooned under covid. What are you arguing exactly?
That was before covid. Tariffs

Some yes, some no. What's your point?
Handouts

Again, never thought Trump was a conservative. So OK, you're telling me something I already knew and no one is disputing. I've never heard anyone say Trump is a conservative
Trump is not an political ideologue, he is more of a pragmatic centrist. That's one of the huge reasons why he is by far the greatest president in our lifetimes.
81 million Americans disagree with you

Actually it's in the 70s of millions since you said people. You mean 81 million ballots disagree with him with all the fraudulent ones the Democrats included when they stole the election
But the fact
that Fox programs pressed guests for evidence and attempted to investigate the allegations as the
story unfolded just reinforcesations because it was confident they were true; it
was covering them because it was confident they
the conclusion that a reasonable viewer would readily have

understood that Fox was not covering those allegwere newsworthy—as

Wow, I watch Fox and never saw those shows. When were they on?
MEMORANDUM OF LAW IN SUPPORT OF FOX DEFENDANTS’ MOTION TO
DISMISS PURSUANT TO THE FIRST AMENDMENT AND CPLR §§3211(a)(1), (a)(7),
and (g)
Paul D. Clement (pro hac vice forthcoming)
Erin E. Murphy (pro hac vice forthcoming)
K. Winn Allen, P.C. (pro hac vice forthcoming)
KIRKLAND & ELLIS LLP
1301 Pennsylvania Avenue, N.W.
Washington, DC 20004
Telephone: 202.289.5000
Email: [email protected]
Email: [email protected]
Email: [email protected]

I've never heard of any of those people. What shows were they on? When were they on them?
Those are fox's lawyers

So let's try this again. You said it was on fox shows. Which shows? I never saw that
Rudy Giuliani: “They did it in big cities where they have corrupt machines
that will protect them. Meaning in Pennsylvania, Philadelphia, in
Pittsburgh, [and] in Detroit. They didn't have to do it in Chicago, in New
York or Boston. They could have, they have corrupt machines there. They
did it absolutely in Phoenix, Arizona. They did it absolutely in
Milwaukee, Wisconsin.” (Sunday Morning Futures with Maria Bartiromo,
November 15, 2020 (Exhibit 5)).
 
A few years ago, in our first encounter here, JoeB and I were going at it for several days as he was insisting Dark people are dumb and need help not falling for Whitey tricking them into being our slaves.
The man is a racist through and through, but like most of my and my wife's family they're too emotionally disturbed and mentally ill to realize it.

Yes, Joe is clearly just exploiting blacks for government handouts. Particularly he wants free healthcare and free retirement. In fairness, he doesn't just hate blacks, he hates everyone. It's pretty funny how he claims to want to help black people when he doesn't care about anyone but himself.

He also insists he doesn't have a bad attitude in real life. That's even funnier than his nonsense about race

Yes, all subsidies ballooned under covid. What are you arguing exactly?
That was before covid. Tariffs

Some yes, some no. What's your point?
Handouts

Again, never thought Trump was a conservative. So OK, you're telling me something I already knew and no one is disputing. I've never heard anyone say Trump is a conservative
Trump is not an political ideologue, he is more of a pragmatic centrist. That's one of the huge reasons why he is by far the greatest president in our lifetimes.
81 million Americans disagree with you

Actually it's in the 70s of millions since you said people. You mean 81 million ballots disagree with him with all the fraudulent ones the Democrats included when they stole the election
But the fact
that Fox programs pressed guests for evidence and attempted to investigate the allegations as the
story unfolded just reinforcesations because it was confident they were true; it
was covering them because it was confident they
the conclusion that a reasonable viewer would readily have

understood that Fox was not covering those allegwere newsworthy—as

Wow, I watch Fox and never saw those shows. When were they on?
MEMORANDUM OF LAW IN SUPPORT OF FOX DEFENDANTS’ MOTION TO
DISMISS PURSUANT TO THE FIRST AMENDMENT AND CPLR §§3211(a)(1), (a)(7),
and (g)
Paul D. Clement (pro hac vice forthcoming)
Erin E. Murphy (pro hac vice forthcoming)
K. Winn Allen, P.C. (pro hac vice forthcoming)
KIRKLAND & ELLIS LLP
1301 Pennsylvania Avenue, N.W.
Washington, DC 20004
Telephone: 202.289.5000
Email: [email protected]
Email: [email protected]
Email: [email protected]

I've never heard of any of those people. What shows were they on? When were they on them?
Those are fox's lawyers

So let's try this again. You said it was on fox shows. Which shows? I never saw that
Sidney Powell: “First of all, I never say anything I can't prove. Secondly,
the evidence is coming in so fast, I can't even process it all. Millions of
Americans have written, I would say by now, definitely hundreds of
thousands have stepped forward with their different experiences of voter
fraud. But this is a massive election fraud. And I’m very concerned it
involved not only Dominion and its Smartmatic software but that the
software essentially was used by other election machines also. It’s the
software that was the problem. Even their own manual explains how votes
can be wiped away. They can put, it's like drag-and-drop Trump votes to
a separate folder and then delete that folder. It’s absolutely brazen how
people bought this system and why they bought this system. In fact, every
state that bought Dominion, for sure, should have a criminal investigation
or at least a serious investigation of the … officers in the States who bought
the software. We've even got evidence from kickbacks, essentially.”
(Sunday Morning Futures with Maria Bartiromo, November 15, 2020
(Exhibit
 
A few years ago, in our first encounter here, JoeB and I were going at it for several days as he was insisting Dark people are dumb and need help not falling for Whitey tricking them into being our slaves.
The man is a racist through and through, but like most of my and my wife's family they're too emotionally disturbed and mentally ill to realize it.

Yes, Joe is clearly just exploiting blacks for government handouts. Particularly he wants free healthcare and free retirement. In fairness, he doesn't just hate blacks, he hates everyone. It's pretty funny how he claims to want to help black people when he doesn't care about anyone but himself.

He also insists he doesn't have a bad attitude in real life. That's even funnier than his nonsense about race

Yes, all subsidies ballooned under covid. What are you arguing exactly?
That was before covid. Tariffs

Some yes, some no. What's your point?
Handouts

Again, never thought Trump was a conservative. So OK, you're telling me something I already knew and no one is disputing. I've never heard anyone say Trump is a conservative
Trump is not an political ideologue, he is more of a pragmatic centrist. That's one of the huge reasons why he is by far the greatest president in our lifetimes.
81 million Americans disagree with you

Actually it's in the 70s of millions since you said people. You mean 81 million ballots disagree with him with all the fraudulent ones the Democrats included when they stole the election
But the fact
that Fox programs pressed guests for evidence and attempted to investigate the allegations as the
story unfolded just reinforcesations because it was confident they were true; it
was covering them because it was confident they
the conclusion that a reasonable viewer would readily have

understood that Fox was not covering those allegwere newsworthy—as

Wow, I watch Fox and never saw those shows. When were they on?
MEMORANDUM OF LAW IN SUPPORT OF FOX DEFENDANTS’ MOTION TO
DISMISS PURSUANT TO THE FIRST AMENDMENT AND CPLR §§3211(a)(1), (a)(7),
and (g)
Paul D. Clement (pro hac vice forthcoming)
Erin E. Murphy (pro hac vice forthcoming)
K. Winn Allen, P.C. (pro hac vice forthcoming)
KIRKLAND & ELLIS LLP
1301 Pennsylvania Avenue, N.W.
Washington, DC 20004
Telephone: 202.289.5000
Email: [email protected]
Email: [email protected]
Email: [email protected]

I've never heard of any of those people. What shows were they on? When were they on them?
Maria Bartiromo: “Yeah, I mean, you heard what Rudy Giuliani said earlier
in the program, he and Sidney Powell are investigating the Smartmatic
software and the Dominion voting machines because they do believe, and
they say they have evidence, that there were back doors and the votes were
manipulated to turn Trump votes into Biden votes.” (Sunday Morning
Futures with Maria Bartiromo, November 15, 2020 (Second Video)
(Exhibit 6)).
l. Lou Dobbs: “Your reaction to what the Trump legal team and others are
discovering about Dominion, Smartmatic and many of the other voting
companies, which almost seems like probable cause for a complete and
thorough investigation.” (Lou Dobbs Tonight, November 16, 2020 (Exhibit
14)).
 

Wow, I watch Fox and never saw those shows. When were they on?
MEMORANDUM OF LAW IN SUPPORT OF FOX DEFENDANTS’ MOTION TO
DISMISS PURSUANT TO THE FIRST AMENDMENT AND CPLR §§3211(a)(1), (a)(7),
and (g)
Paul D. Clement (pro hac vice forthcoming)
Erin E. Murphy (pro hac vice forthcoming)
K. Winn Allen, P.C. (pro hac vice forthcoming)
KIRKLAND & ELLIS LLP
1301 Pennsylvania Avenue, N.W.
Washington, DC 20004
Telephone: 202.289.5000
Email: [email protected]
Email: [email protected]
Email: [email protected]

I've never heard of any of those people. What shows were they on? When were they on them?
96. On November 12, 2020, Mr. Giuliani appeared on Lou Dobbs Tonight to spread the
disinformation campaign to millions of people. (Lou Dobbs Tonight, November 12,2020 (Exhibit
1)).5
At the time of his appearance, Mr. Giuliani had presented no evidence that the 2020 U.S.
election had been rigged or stolen. He provided no such evidence to Mr. Dobbs and Mr. Dobbs
had seen no such evidence. But, Mr. Dobbs was in alignment with the false story that Mr. Giuliani
and Ms. Powell wanted to spread.
Mr. Dobbs: Let’s talk about, just for a moment, an update on Dominion and
how important do you believe the concerns that are being expressed of a
number of states about the ability of these machines not to be hacked?
Mr. Giuliani: Well, first of all, the machines can be hacked. There’s no
question about that. Their machines can be hacked, but it’s far worse than
that. Dominion, Dominion is a company that’s owned by another company
Smartmatic, through its intermediary company Indra. Smartmatic is a
company that was formed way back in 2004, 2003, 2004. You’re gonna be
astonished when I tell you how it was formed. It was formed really by three

What does this have to do with anything I ever said? I never said that anyone hacked voting machines. I have no idea. Democrats just printed more ballots and delivered them in the middle of the night. It wasn't necessary for them to be so devious as to hack the machine. Maybe they did, maybe not. I have no idea and it changes nothing
 
A few years ago, in our first encounter here, JoeB and I were going at it for several days as he was insisting Dark people are dumb and need help not falling for Whitey tricking them into being our slaves.
The man is a racist through and through, but like most of my and my wife's family they're too emotionally disturbed and mentally ill to realize it.

Yes, Joe is clearly just exploiting blacks for government handouts. Particularly he wants free healthcare and free retirement. In fairness, he doesn't just hate blacks, he hates everyone. It's pretty funny how he claims to want to help black people when he doesn't care about anyone but himself.

He also insists he doesn't have a bad attitude in real life. That's even funnier than his nonsense about race

Yes, all subsidies ballooned under covid. What are you arguing exactly?
That was before covid. Tariffs

Some yes, some no. What's your point?
Handouts

Again, never thought Trump was a conservative. So OK, you're telling me something I already knew and no one is disputing. I've never heard anyone say Trump is a conservative
Trump is not an political ideologue, he is more of a pragmatic centrist. That's one of the huge reasons why he is by far the greatest president in our lifetimes.
81 million Americans disagree with you

Actually it's in the 70s of millions since you said people. You mean 81 million ballots disagree with him with all the fraudulent ones the Democrats included when they stole the election
But the fact
that Fox programs pressed guests for evidence and attempted to investigate the allegations as the
story unfolded just reinforcesations because it was confident they were true; it
was covering them because it was confident they
the conclusion that a reasonable viewer would readily have

understood that Fox was not covering those allegwere newsworthy—as

Wow, I watch Fox and never saw those shows. When were they on?
MEMORANDUM OF LAW IN SUPPORT OF FOX DEFENDANTS’ MOTION TO
DISMISS PURSUANT TO THE FIRST AMENDMENT AND CPLR §§3211(a)(1), (a)(7),
and (g)
Paul D. Clement (pro hac vice forthcoming)
Erin E. Murphy (pro hac vice forthcoming)
K. Winn Allen, P.C. (pro hac vice forthcoming)
KIRKLAND & ELLIS LLP
1301 Pennsylvania Avenue, N.W.
Washington, DC 20004
Telephone: 202.289.5000
Email: [email protected]
Email: [email protected]
Email: [email protected]

I've never heard of any of those people. What shows were they on? When were they on them?
Those are fox's lawyers

So let's try this again. You said it was on fox shows. Which shows? I never saw that
Fox's lawyers are lying?

Non-sequitur
Question

Answer
 
A few years ago, in our first encounter here, JoeB and I were going at it for several days as he was insisting Dark people are dumb and need help not falling for Whitey tricking them into being our slaves.
The man is a racist through and through, but like most of my and my wife's family they're too emotionally disturbed and mentally ill to realize it.

Yes, Joe is clearly just exploiting blacks for government handouts. Particularly he wants free healthcare and free retirement. In fairness, he doesn't just hate blacks, he hates everyone. It's pretty funny how he claims to want to help black people when he doesn't care about anyone but himself.

He also insists he doesn't have a bad attitude in real life. That's even funnier than his nonsense about race

Yes, all subsidies ballooned under covid. What are you arguing exactly?
That was before covid. Tariffs

Some yes, some no. What's your point?
Handouts

Again, never thought Trump was a conservative. So OK, you're telling me something I already knew and no one is disputing. I've never heard anyone say Trump is a conservative
Trump is not an political ideologue, he is more of a pragmatic centrist. That's one of the huge reasons why he is by far the greatest president in our lifetimes.
81 million Americans disagree with you

Actually it's in the 70s of millions since you said people. You mean 81 million ballots disagree with him with all the fraudulent ones the Democrats included when they stole the election
But the fact
that Fox programs pressed guests for evidence and attempted to investigate the allegations as the
story unfolded just reinforcesations because it was confident they were true; it
was covering them because it was confident they
the conclusion that a reasonable viewer would readily have

understood that Fox was not covering those allegwere newsworthy—as

Wow, I watch Fox and never saw those shows. When were they on?
MEMORANDUM OF LAW IN SUPPORT OF FOX DEFENDANTS’ MOTION TO
DISMISS PURSUANT TO THE FIRST AMENDMENT AND CPLR §§3211(a)(1), (a)(7),
and (g)
Paul D. Clement (pro hac vice forthcoming)
Erin E. Murphy (pro hac vice forthcoming)
K. Winn Allen, P.C. (pro hac vice forthcoming)
KIRKLAND & ELLIS LLP
1301 Pennsylvania Avenue, N.W.
Washington, DC 20004
Telephone: 202.289.5000
Email: [email protected]
Email: [email protected]
Email: [email protected]

I've never heard of any of those people. What shows were they on? When were they on them?
Those are fox's lawyers

So let's try this again. You said it was on fox shows. Which shows? I never saw that
251. One of Fox News’s most prominent anchors likewise acknowledged that Ms.
Powell had not provided any evidence to support any of her claims about Smartmatic. On
November 19, Tucker Carlson wrote an article titled: “Tucker Carlson: Time for Sidney Powell to
show us her evidence.” (11/19/20 Tucker Carlson Article (Exhibit 136)). He wrote the following:
For more than a week, Powell has been all over conservative media with the
following story: This election was stolen by a collection of international
leftists who manipulated vote tabulating software in order to flip millions of
votes from Donald Trump to Joe Biden. The other day on television, Powell
said of Trump that when the fraud is finally uncovered, “I think we’ll find he
had at least 80 million votes.” In other words, rigged software stole about
seven million votes in this election.
On Sunday night, “Tucker Carlson Tonight” texted her after watching one of
her segments. What Powell was describing would amount to the single
greatest crime in American history. Millions of votes stolen in a day,
democracy destroyed, the end of our centuries-old system of self-
government. Not a small thing.

OK, thanks for clarifying that. I'm good now
 
A few years ago, in our first encounter here, JoeB and I were going at it for several days as he was insisting Dark people are dumb and need help not falling for Whitey tricking them into being our slaves.
The man is a racist through and through, but like most of my and my wife's family they're too emotionally disturbed and mentally ill to realize it.

Yes, Joe is clearly just exploiting blacks for government handouts. Particularly he wants free healthcare and free retirement. In fairness, he doesn't just hate blacks, he hates everyone. It's pretty funny how he claims to want to help black people when he doesn't care about anyone but himself.

He also insists he doesn't have a bad attitude in real life. That's even funnier than his nonsense about race

Yes, all subsidies ballooned under covid. What are you arguing exactly?
That was before covid. Tariffs

Some yes, some no. What's your point?
Handouts

Again, never thought Trump was a conservative. So OK, you're telling me something I already knew and no one is disputing. I've never heard anyone say Trump is a conservative
Trump is not an political ideologue, he is more of a pragmatic centrist. That's one of the huge reasons why he is by far the greatest president in our lifetimes.
81 million Americans disagree with you

Actually it's in the 70s of millions since you said people. You mean 81 million ballots disagree with him with all the fraudulent ones the Democrats included when they stole the election
But the fact
that Fox programs pressed guests for evidence and attempted to investigate the allegations as the
story unfolded just reinforcesations because it was confident they were true; it
was covering them because it was confident they
the conclusion that a reasonable viewer would readily have

understood that Fox was not covering those allegwere newsworthy—as

Wow, I watch Fox and never saw those shows. When were they on?
MEMORANDUM OF LAW IN SUPPORT OF FOX DEFENDANTS’ MOTION TO
DISMISS PURSUANT TO THE FIRST AMENDMENT AND CPLR §§3211(a)(1), (a)(7),
and (g)
Paul D. Clement (pro hac vice forthcoming)
Erin E. Murphy (pro hac vice forthcoming)
K. Winn Allen, P.C. (pro hac vice forthcoming)
KIRKLAND & ELLIS LLP
1301 Pennsylvania Avenue, N.W.
Washington, DC 20004
Telephone: 202.289.5000
Email: [email protected]
Email: [email protected]
Email: [email protected]

I've never heard of any of those people. What shows were they on? When were they on them?
Those are fox's lawyers

So let's try this again. You said it was on fox shows. Which shows? I never saw that
110. On November 16, Mr. Dobbs continued his part in spreading the disinformation
campaign on Lou Dobbs Tonight. (Lou Dobbs Tonight, November 16, 2020 (Exhibit 15)). At the
time of the broadcast, Mr. Dobbs had seen no evidence that Smartmatic’s election technology and
software were used to rig or steal the election. Smartmatic had only been used in Los Angeles
County, making it impossible for Smartmatic to have influenced the outcome of the election.
Nonetheless, he started his show by stating: “Dominion has connections to U.K based Smartmatic,
a voting technology company established in 2000 that had ties to Venezuela’s Hugo Chávez.” And
then he made sure everyone understood that Smartmatic had stolen the election.
Mr. Dobbs: This is a nation that has just been wronged mightily. Only an
idiot would try to claim that there were no irregularities, that there were no
anomalies, that there were insufficient evidence and documents suggesting

Cool beans
 
A few years ago, in our first encounter here, JoeB and I were going at it for several days as he was insisting Dark people are dumb and need help not falling for Whitey tricking them into being our slaves.
The man is a racist through and through, but like most of my and my wife's family they're too emotionally disturbed and mentally ill to realize it.

Yes, Joe is clearly just exploiting blacks for government handouts. Particularly he wants free healthcare and free retirement. In fairness, he doesn't just hate blacks, he hates everyone. It's pretty funny how he claims to want to help black people when he doesn't care about anyone but himself.

He also insists he doesn't have a bad attitude in real life. That's even funnier than his nonsense about race

Yes, all subsidies ballooned under covid. What are you arguing exactly?
That was before covid. Tariffs

Some yes, some no. What's your point?
Handouts

Again, never thought Trump was a conservative. So OK, you're telling me something I already knew and no one is disputing. I've never heard anyone say Trump is a conservative
Trump is not an political ideologue, he is more of a pragmatic centrist. That's one of the huge reasons why he is by far the greatest president in our lifetimes.
81 million Americans disagree with you

Actually it's in the 70s of millions since you said people. You mean 81 million ballots disagree with him with all the fraudulent ones the Democrats included when they stole the election
But the fact
that Fox programs pressed guests for evidence and attempted to investigate the allegations as the
story unfolded just reinforcesations because it was confident they were true; it
was covering them because it was confident they
the conclusion that a reasonable viewer would readily have

understood that Fox was not covering those allegwere newsworthy—as

Wow, I watch Fox and never saw those shows. When were they on?
MEMORANDUM OF LAW IN SUPPORT OF FOX DEFENDANTS’ MOTION TO
DISMISS PURSUANT TO THE FIRST AMENDMENT AND CPLR §§3211(a)(1), (a)(7),
and (g)
Paul D. Clement (pro hac vice forthcoming)
Erin E. Murphy (pro hac vice forthcoming)
K. Winn Allen, P.C. (pro hac vice forthcoming)
KIRKLAND & ELLIS LLP
1301 Pennsylvania Avenue, N.W.
Washington, DC 20004
Telephone: 202.289.5000
Email: [email protected]
Email: [email protected]
Email: [email protected]

I've never heard of any of those people. What shows were they on? When were they on them?
Those are fox's lawyers

So let's try this again. You said it was on fox shows. Which shows? I never saw that
121. On November 21, Ms. Pirro returned as a voice for the disinformation campaign on
Justice with Judge Jeanine. (Justice with Judge Jeanine, November 21, 2020 (Exhibit 28)). Her
apparent objective was to lend credibility to the statements that had previously been made by Mr.
Giuliani and Ms. Powell, specifically about the “affidavits” that they had been using to prop up the
fake narrative about Smartmatic. Ms. Pirro said:
Ms. Pirro: The President’s lawyers [are] alleging a company called
Dominion, which they say started in Venezuela with Cuban money and with
the assistance of Smartmatic software, [has] a backdoor [that] is capable of
flipping votes. And the President’s lawyers [are] alleging that American votes
in a presidential election are actually counted in a foreign country. These are

Nardo!
 

Wow, I watch Fox and never saw those shows. When were they on?
MEMORANDUM OF LAW IN SUPPORT OF FOX DEFENDANTS’ MOTION TO
DISMISS PURSUANT TO THE FIRST AMENDMENT AND CPLR §§3211(a)(1), (a)(7),
and (g)
Paul D. Clement (pro hac vice forthcoming)
Erin E. Murphy (pro hac vice forthcoming)
K. Winn Allen, P.C. (pro hac vice forthcoming)
KIRKLAND & ELLIS LLP
1301 Pennsylvania Avenue, N.W.
Washington, DC 20004
Telephone: 202.289.5000
Email: [email protected]
Email: [email protected]
Email: [email protected]

I've never heard of any of those people. What shows were they on? When were they on them?
96. On November 12, 2020, Mr. Giuliani appeared on Lou Dobbs Tonight to spread the
disinformation campaign to millions of people. (Lou Dobbs Tonight, November 12,2020 (Exhibit
1)).5
At the time of his appearance, Mr. Giuliani had presented no evidence that the 2020 U.S.
election had been rigged or stolen. He provided no such evidence to Mr. Dobbs and Mr. Dobbs
had seen no such evidence. But, Mr. Dobbs was in alignment with the false story that Mr. Giuliani
and Ms. Powell wanted to spread.
Mr. Dobbs: Let’s talk about, just for a moment, an update on Dominion and
how important do you believe the concerns that are being expressed of a
number of states about the ability of these machines not to be hacked?
Mr. Giuliani: Well, first of all, the machines can be hacked. There’s no
question about that. Their machines can be hacked, but it’s far worse than
that. Dominion, Dominion is a company that’s owned by another company
Smartmatic, through its intermediary company Indra. Smartmatic is a
company that was formed way back in 2004, 2003, 2004. You’re gonna be
astonished when I tell you how it was formed. It was formed really by three

What does this have to do with anything I ever said? I never said that anyone hacked voting machines. I have no idea. Democrats just printed more ballots and delivered them in the middle of the night. It wasn't necessary for them to be so devious as to hack the machine. Maybe they did, maybe not. I have no idea and it changes nothing
262. For example, on November 12, Mr. Dobbs gave an update on Dominion and
Smartmatic on Lou Dobbs Tonight, asking Mr. Giuliani how important the concerns were being
expressed by a number of states about the ability of their machines to be hacked. Mr. Giuliani told
Mr. Dobbs that the machines can be hacked and specifically named Smartmatic and its software.
In discussing this hacking, Mr. Giuliani stated: “What the heck was Georgia doing in hiring this
company?” However, there was publicly available information from the state of Georgia at the
time that showed that Dominion and Smartmatic were two separate companies and that
 

Wow, I watch Fox and never saw those shows. When were they on?
MEMORANDUM OF LAW IN SUPPORT OF FOX DEFENDANTS’ MOTION TO
DISMISS PURSUANT TO THE FIRST AMENDMENT AND CPLR §§3211(a)(1), (a)(7),
and (g)
Paul D. Clement (pro hac vice forthcoming)
Erin E. Murphy (pro hac vice forthcoming)
K. Winn Allen, P.C. (pro hac vice forthcoming)
KIRKLAND & ELLIS LLP
1301 Pennsylvania Avenue, N.W.
Washington, DC 20004
Telephone: 202.289.5000
Email: [email protected]
Email: [email protected]
Email: [email protected]

I've never heard of any of those people. What shows were they on? When were they on them?
96. On November 12, 2020, Mr. Giuliani appeared on Lou Dobbs Tonight to spread the
disinformation campaign to millions of people. (Lou Dobbs Tonight, November 12,2020 (Exhibit
1)).5
At the time of his appearance, Mr. Giuliani had presented no evidence that the 2020 U.S.
election had been rigged or stolen. He provided no such evidence to Mr. Dobbs and Mr. Dobbs
had seen no such evidence. But, Mr. Dobbs was in alignment with the false story that Mr. Giuliani
and Ms. Powell wanted to spread.
Mr. Dobbs: Let’s talk about, just for a moment, an update on Dominion and
how important do you believe the concerns that are being expressed of a
number of states about the ability of these machines not to be hacked?
Mr. Giuliani: Well, first of all, the machines can be hacked. There’s no
question about that. Their machines can be hacked, but it’s far worse than
that. Dominion, Dominion is a company that’s owned by another company
Smartmatic, through its intermediary company Indra. Smartmatic is a
company that was formed way back in 2004, 2003, 2004. You’re gonna be
astonished when I tell you how it was formed. It was formed really by three

What does this have to do with anything I ever said? I never said that anyone hacked voting machines. I have no idea. Democrats just printed more ballots and delivered them in the middle of the night. It wasn't necessary for them to be so devious as to hack the machine. Maybe they did, maybe not. I have no idea and it changes nothing
"I've never heard of any of those people. What shows were they on? When were they on them?"
 
A few years ago, in our first encounter here, JoeB and I were going at it for several days as he was insisting Dark people are dumb and need help not falling for Whitey tricking them into being our slaves.
The man is a racist through and through, but like most of my and my wife's family they're too emotionally disturbed and mentally ill to realize it.

Yes, Joe is clearly just exploiting blacks for government handouts. Particularly he wants free healthcare and free retirement. In fairness, he doesn't just hate blacks, he hates everyone. It's pretty funny how he claims to want to help black people when he doesn't care about anyone but himself.

He also insists he doesn't have a bad attitude in real life. That's even funnier than his nonsense about race

Yes, all subsidies ballooned under covid. What are you arguing exactly?
That was before covid. Tariffs

Some yes, some no. What's your point?
Handouts

Again, never thought Trump was a conservative. So OK, you're telling me something I already knew and no one is disputing. I've never heard anyone say Trump is a conservative
Trump is not an political ideologue, he is more of a pragmatic centrist. That's one of the huge reasons why he is by far the greatest president in our lifetimes.
81 million Americans disagree with you

Actually it's in the 70s of millions since you said people. You mean 81 million ballots disagree with him with all the fraudulent ones the Democrats included when they stole the election
But the fact
that Fox programs pressed guests for evidence and attempted to investigate the allegations as the
story unfolded just reinforcesations because it was confident they were true; it
was covering them because it was confident they
the conclusion that a reasonable viewer would readily have

understood that Fox was not covering those allegwere newsworthy—as

Wow, I watch Fox and never saw those shows. When were they on?
MEMORANDUM OF LAW IN SUPPORT OF FOX DEFENDANTS’ MOTION TO
DISMISS PURSUANT TO THE FIRST AMENDMENT AND CPLR §§3211(a)(1), (a)(7),
and (g)
Paul D. Clement (pro hac vice forthcoming)
Erin E. Murphy (pro hac vice forthcoming)
K. Winn Allen, P.C. (pro hac vice forthcoming)
KIRKLAND & ELLIS LLP
1301 Pennsylvania Avenue, N.W.
Washington, DC 20004
Telephone: 202.289.5000
Email: [email protected]
Email: [email protected]
Email: [email protected]

I've never heard of any of those people. What shows were they on? When were they on them?
Those are fox's lawyers

So let's try this again. You said it was on fox shows. Which shows? I never saw that
Fox's lawyers are lying?

Non-sequitur
Question

Answer
You didnt
 

Wow, I watch Fox and never saw those shows. When were they on?
MEMORANDUM OF LAW IN SUPPORT OF FOX DEFENDANTS’ MOTION TO
DISMISS PURSUANT TO THE FIRST AMENDMENT AND CPLR §§3211(a)(1), (a)(7),
and (g)
Paul D. Clement (pro hac vice forthcoming)
Erin E. Murphy (pro hac vice forthcoming)
K. Winn Allen, P.C. (pro hac vice forthcoming)
KIRKLAND & ELLIS LLP
1301 Pennsylvania Avenue, N.W.
Washington, DC 20004
Telephone: 202.289.5000
Email: [email protected]
Email: [email protected]
Email: [email protected]

I've never heard of any of those people. What shows were they on? When were they on them?
96. On November 12, 2020, Mr. Giuliani appeared on Lou Dobbs Tonight to spread the
disinformation campaign to millions of people. (Lou Dobbs Tonight, November 12,2020 (Exhibit
1)).5
At the time of his appearance, Mr. Giuliani had presented no evidence that the 2020 U.S.
election had been rigged or stolen. He provided no such evidence to Mr. Dobbs and Mr. Dobbs
had seen no such evidence. But, Mr. Dobbs was in alignment with the false story that Mr. Giuliani
and Ms. Powell wanted to spread.
Mr. Dobbs: Let’s talk about, just for a moment, an update on Dominion and
how important do you believe the concerns that are being expressed of a
number of states about the ability of these machines not to be hacked?
Mr. Giuliani: Well, first of all, the machines can be hacked. There’s no
question about that. Their machines can be hacked, but it’s far worse than
that. Dominion, Dominion is a company that’s owned by another company
Smartmatic, through its intermediary company Indra. Smartmatic is a
company that was formed way back in 2004, 2003, 2004. You’re gonna be
astonished when I tell you how it was formed. It was formed really by three

What does this have to do with anything I ever said? I never said that anyone hacked voting machines. I have no idea. Democrats just printed more ballots and delivered them in the middle of the night. It wasn't necessary for them to be so devious as to hack the machine. Maybe they did, maybe not. I have no idea and it changes nothing
"Wow, I watch Fox and never saw those shows. When were they on?"
 

Wow, I watch Fox and never saw those shows. When were they on?
MEMORANDUM OF LAW IN SUPPORT OF FOX DEFENDANTS’ MOTION TO
DISMISS PURSUANT TO THE FIRST AMENDMENT AND CPLR §§3211(a)(1), (a)(7),
and (g)
Paul D. Clement (pro hac vice forthcoming)
Erin E. Murphy (pro hac vice forthcoming)
K. Winn Allen, P.C. (pro hac vice forthcoming)
KIRKLAND & ELLIS LLP
1301 Pennsylvania Avenue, N.W.
Washington, DC 20004
Telephone: 202.289.5000
Email: [email protected]
Email: [email protected]
Email: [email protected]

I've never heard of any of those people. What shows were they on? When were they on them?
96. On November 12, 2020, Mr. Giuliani appeared on Lou Dobbs Tonight to spread the
disinformation campaign to millions of people. (Lou Dobbs Tonight, November 12,2020 (Exhibit
1)).5
At the time of his appearance, Mr. Giuliani had presented no evidence that the 2020 U.S.
election had been rigged or stolen. He provided no such evidence to Mr. Dobbs and Mr. Dobbs
had seen no such evidence. But, Mr. Dobbs was in alignment with the false story that Mr. Giuliani
and Ms. Powell wanted to spread.
Mr. Dobbs: Let’s talk about, just for a moment, an update on Dominion and
how important do you believe the concerns that are being expressed of a
number of states about the ability of these machines not to be hacked?
Mr. Giuliani: Well, first of all, the machines can be hacked. There’s no
question about that. Their machines can be hacked, but it’s far worse than
that. Dominion, Dominion is a company that’s owned by another company
Smartmatic, through its intermediary company Indra. Smartmatic is a
company that was formed way back in 2004, 2003, 2004. You’re gonna be
astonished when I tell you how it was formed. It was formed really by three

What does this have to do with anything I ever said? I never said that anyone hacked voting machines. I have no idea. Democrats just printed more ballots and delivered them in the middle of the night. It wasn't necessary for them to be so devious as to hack the machine. Maybe they did, maybe not. I have no idea and it changes nothing
Link?
 

I've never heard of any of those people. What shows were they on? When were they on them?
Those are fox's lawyers

So let's try this again. You said it was on fox shows. Which shows? I never saw that
Fox's lawyers are lying?

Non-sequitur
Question

Answer
You didnt

It's in black and white
 

Wow, I watch Fox and never saw those shows. When were they on?
MEMORANDUM OF LAW IN SUPPORT OF FOX DEFENDANTS’ MOTION TO
DISMISS PURSUANT TO THE FIRST AMENDMENT AND CPLR §§3211(a)(1), (a)(7),
and (g)
Paul D. Clement (pro hac vice forthcoming)
Erin E. Murphy (pro hac vice forthcoming)
K. Winn Allen, P.C. (pro hac vice forthcoming)
KIRKLAND & ELLIS LLP
1301 Pennsylvania Avenue, N.W.
Washington, DC 20004
Telephone: 202.289.5000
Email: [email protected]
Email: [email protected]
Email: [email protected]

I've never heard of any of those people. What shows were they on? When were they on them?
96. On November 12, 2020, Mr. Giuliani appeared on Lou Dobbs Tonight to spread the
disinformation campaign to millions of people. (Lou Dobbs Tonight, November 12,2020 (Exhibit
1)).5
At the time of his appearance, Mr. Giuliani had presented no evidence that the 2020 U.S.
election had been rigged or stolen. He provided no such evidence to Mr. Dobbs and Mr. Dobbs
had seen no such evidence. But, Mr. Dobbs was in alignment with the false story that Mr. Giuliani
and Ms. Powell wanted to spread.
Mr. Dobbs: Let’s talk about, just for a moment, an update on Dominion and
how important do you believe the concerns that are being expressed of a
number of states about the ability of these machines not to be hacked?
Mr. Giuliani: Well, first of all, the machines can be hacked. There’s no
question about that. Their machines can be hacked, but it’s far worse than
that. Dominion, Dominion is a company that’s owned by another company
Smartmatic, through its intermediary company Indra. Smartmatic is a
company that was formed way back in 2004, 2003, 2004. You’re gonna be
astonished when I tell you how it was formed. It was formed really by three

What does this have to do with anything I ever said? I never said that anyone hacked voting machines. I have no idea. Democrats just printed more ballots and delivered them in the middle of the night. It wasn't necessary for them to be so devious as to hack the machine. Maybe they did, maybe not. I have no idea and it changes nothing
 

I've never heard of any of those people. What shows were they on? When were they on them?
Those are fox's lawyers

So let's try this again. You said it was on fox shows. Which shows? I never saw that
Fox's lawyers are lying?

Non-sequitur
Question

Answer
You didnt

It's in black and white
So no link
 

Wow, I watch Fox and never saw those shows. When were they on?
MEMORANDUM OF LAW IN SUPPORT OF FOX DEFENDANTS’ MOTION TO
DISMISS PURSUANT TO THE FIRST AMENDMENT AND CPLR §§3211(a)(1), (a)(7),
and (g)
Paul D. Clement (pro hac vice forthcoming)
Erin E. Murphy (pro hac vice forthcoming)
K. Winn Allen, P.C. (pro hac vice forthcoming)
KIRKLAND & ELLIS LLP
1301 Pennsylvania Avenue, N.W.
Washington, DC 20004
Telephone: 202.289.5000
Email: [email protected]
Email: [email protected]
Email: [email protected]

I've never heard of any of those people. What shows were they on? When were they on them?
96. On November 12, 2020, Mr. Giuliani appeared on Lou Dobbs Tonight to spread the
disinformation campaign to millions of people. (Lou Dobbs Tonight, November 12,2020 (Exhibit
1)).5
At the time of his appearance, Mr. Giuliani had presented no evidence that the 2020 U.S.
election had been rigged or stolen. He provided no such evidence to Mr. Dobbs and Mr. Dobbs
had seen no such evidence. But, Mr. Dobbs was in alignment with the false story that Mr. Giuliani
and Ms. Powell wanted to spread.
Mr. Dobbs: Let’s talk about, just for a moment, an update on Dominion and
how important do you believe the concerns that are being expressed of a
number of states about the ability of these machines not to be hacked?
Mr. Giuliani: Well, first of all, the machines can be hacked. There’s no
question about that. Their machines can be hacked, but it’s far worse than
that. Dominion, Dominion is a company that’s owned by another company
Smartmatic, through its intermediary company Indra. Smartmatic is a
company that was formed way back in 2004, 2003, 2004. You’re gonna be
astonished when I tell you how it was formed. It was formed really by three

What does this have to do with anything I ever said? I never said that anyone hacked voting machines. I have no idea. Democrats just printed more ballots and delivered them in the middle of the night. It wasn't necessary for them to be so devious as to hack the machine. Maybe they did, maybe not. I have no idea and it changes nothing
Link?

1624394674372.png
 

Wow, I watch Fox and never saw those shows. When were they on?
MEMORANDUM OF LAW IN SUPPORT OF FOX DEFENDANTS’ MOTION TO
DISMISS PURSUANT TO THE FIRST AMENDMENT AND CPLR §§3211(a)(1), (a)(7),
and (g)
Paul D. Clement (pro hac vice forthcoming)
Erin E. Murphy (pro hac vice forthcoming)
K. Winn Allen, P.C. (pro hac vice forthcoming)
KIRKLAND & ELLIS LLP
1301 Pennsylvania Avenue, N.W.
Washington, DC 20004
Telephone: 202.289.5000
Email: [email protected]
Email: [email protected]
Email: [email protected]

I've never heard of any of those people. What shows were they on? When were they on them?
96. On November 12, 2020, Mr. Giuliani appeared on Lou Dobbs Tonight to spread the
disinformation campaign to millions of people. (Lou Dobbs Tonight, November 12,2020 (Exhibit
1)).5
At the time of his appearance, Mr. Giuliani had presented no evidence that the 2020 U.S.
election had been rigged or stolen. He provided no such evidence to Mr. Dobbs and Mr. Dobbs
had seen no such evidence. But, Mr. Dobbs was in alignment with the false story that Mr. Giuliani
and Ms. Powell wanted to spread.
Mr. Dobbs: Let’s talk about, just for a moment, an update on Dominion and
how important do you believe the concerns that are being expressed of a
number of states about the ability of these machines not to be hacked?
Mr. Giuliani: Well, first of all, the machines can be hacked. There’s no
question about that. Their machines can be hacked, but it’s far worse than
that. Dominion, Dominion is a company that’s owned by another company
Smartmatic, through its intermediary company Indra. Smartmatic is a
company that was formed way back in 2004, 2003, 2004. You’re gonna be
astonished when I tell you how it was formed. It was formed really by three

What does this have to do with anything I ever said? I never said that anyone hacked voting machines. I have no idea. Democrats just printed more ballots and delivered them in the middle of the night. It wasn't necessary for them to be so devious as to hack the machine. Maybe they did, maybe not. I have no idea and it changes nothing
Link?

View attachment 504450
It depends on the definition of link?
 

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