Case: 2:17-cv-00720-EAS-EPD Doc #: 46 Filed: 11/16/18 Page: 1 of 15 PAGEID #: 830

IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO EASTERN DIVISION

DEAN OBEIDALLAH, CASE NO. 2:17-CV-00720-EAS-EPD

Plaintiff, Chief Judge Edmund A. Sargus

v. Magistrate Judge Elizabeth Preston Deavers

ANDREW B. ANGLIN, DBA Daily Stormer,

and

MOONBASE HOLDINGS, LLC, DBA Andrew Anglin,

and

JOHN DOES NUMBERS 1–10, Individuals who also assisted in the publication or representation of false statements regarding Mr. Obeidallah,

Defendants.

PLAINTIFF’S MOTION FOR ADDITIONAL DISCOVERY IN AID OF DEFAULT JUDGMENT

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PLAINTIFF’S MOTION FOR ADDITIONAL DISCOVERY IN AID OF DEFAULT JUDGMENT

In accordance with the Court’s October 2, 2018 Order, ECF No. 41, and as described in the

concurrently filed Status Report, Plaintiff Dean Obeidallah respectfully moves the Court for limited

discovery in aid of establishing a sum-certain of default judgment damages against Defendants Andrew

B. Anglin and Moonbase Holdings, LLC in the above-captioned action. Attached hereto is a

memorandum in support which establishes good cause for Mr. Obeidallah’s request for leave to take

the requested limited discovery. Also attached, as Exhibit 1, is a proposed order for the Court’s

consideration.

Respectfully submitted,

/s/ Subodh Chandra (trial counsel)

DATED: 11/16/2018 Juvaria Khan (N.Y. Bar No. 5027461) MUSLIM ADVOCATES Subodh Chandra (OH Bar No. 0069233) P.O. Box 66408 Donald Screen (OH Bar No. 0044070) Washington, D.C. 20035 THE CHANDRA LAW FIRM LLC Phone: 202.897.1894 1265 W. 6th St., Suite 400 [email protected] Cleveland, OH 44113-1326 [email protected] Phone: 216.578.1700 Fx: 216.578.1800 [email protected] Admitted pro hac vice [email protected]

Johnathan Smith (D.C. Bar No. 1029373)

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TABLE OF CONTENTS

CONTENTS

Clause Page

I. FACTUAL BACKGROUND ...... 1

II. STANDARD OF REVIEW ...... 7

III. GOOD CAUSE EXISTS FOR DISCOVERY IN AID OF DEFAULT JUDGMENT AGAINST DEFENDANTS ANDREW B. ANGLIN AND MOONBASE ...... 8

IV. REQUEST FOR RELIEF...... 12

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Memorandum In Support of Plaintiff’s Motion for Additional Discovery In Aid of Default Judgment

Plaintiff Dean Obeidallah respectfully moves this Court pursuant to Rule 26(d)(1) of the

Federal Rules of Civil Procedure for leave to take limited discovery in aid of establishing a sum-certain

of default judgment damages against Defendants Andrew B. Anglin (“Defendant Anglin”) and

Moonbase Holdings, LLC (“Moonbase”) (collectively, “Defendants”). The proposed requests for

production are attached hereto as Exhibit 2.

This Court has previously acknowledged Mr. Obeidallah’s good cause for limited third-party

discovery in order to determine “(1) the need for immediate entry of default judgment against

Defendant Moonbase; (2) how liability should be apportioned among the Defendants; and (3) the

extent of Plaintiff’s damages attributable to Defendant Moonbase.” ECF No. 39, at 9. As a result of

that previously authorized discovery, Mr. Obeidallah has now identified certain financial institutions

and accounts used by Defendants Anglin and Moonbase to funnel contributions from the Daily

Stormer’s readership and pay for the Daily Stormer’s operations. The financial details of these accounts

are relevant to the second and third points discussed above, but also to the calculation of appropriate

compensatory and punitive damages for Defendants’ wrongful actions. Therefore, Plaintiff Dean

Obeidallah respectfully seeks leave to take additional, limited, third-party discovery from these

financial institutions in aid of establishing a sum-certain of default judgment damages.

Concurrently with this Memorandum, Mr. Obeidallah is submitting: (1) a Status Report

regarding his efforts to file a Motion for Default Judgment, in which he seeks leave to supplement

that Motion on or before Friday, February 15, 2019; and (2) a Motion for Default Judgment

establishing liability for Defendants Andrew B. Anglin and Moonbase Holdings.

I. FACTUAL BACKGROUND

On August 20, 2018, the Court granted Mr. Obeidallah permission to seek limited third-party

discovery from Zappitelli CPAs Inc. (“Zappitelli Inc.”) and Mr. Greg Anglin. Counsel for

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Mr. Obeidallah then served limited document and discovery subpoenas on Zappitelli Inc. and Greg

Anglin.

With regard to Zappitelli Inc., Plaintiff’s counsel had numerous conversations with John and

Karen Zappitelli, both of whom are officers and employees of Zappitelli Inc., following service of the

document and 30(b)(6) deposition subpoenas. In response to the document subpoena, Mr. Zappitelli

produced, on behalf of Zappitelli Inc., a single document—a confirmation from the Internal Revenue

Service that an Employer Identification Number had been established for Defendant Moonbase. See

Ex. 4-B, Moonbase EIN Ltr. Alternatively, in lieu of the 30(b)(6) deposition, Mr. and Mrs. Zappitelli

provided sworn declarations regarding the nature and extent of their association with the Defendants

and Greg Anglin. Those declarations are attached hereto as Exhibits 3 and 4. Mr. and Mrs. Zappitelli

testified that: (1) in late 2016 or early 2016, Greg Anglin requested that Zappitelli Inc. assist him with

establishing Defendant Moonbase, which involved establishing an EIN and providing Greg Anglin

with form paperwork from the Ohio Secretary of State, see Ex. 3, J. Zappitelli Decl. ¶ 4; Ex. 4, K.

Zappitelli Decl. ¶ 3; and (2) in or around January 2018, conferring with Greg Anglin regarding a draft

Agent Address Change for Defendant Moonbase, see Ex. 3, J. Zappitelli Decl. ¶ 6; Ex. 4, K. Zappitelli

Decl. ¶ 3. Other than those two instances, Mr. and Mrs. Zappitelli testified that neither they nor

Zappitelli Inc. has performed any services for the Defendants. Additionally, Mr. and Mrs. Zappitelli

testified that neither they nor Zappitelli Inc. “has had, or currently has, any communication,

association, or relationship with . . . [Defendant] Anglin or The Daily Stormer.” Ex. 3, J. Zappitelli Decl.

¶ 8; Ex. 4, K. Zappitelli Decl. ¶ 6. As a result, Mr. and Mrs. Zappitelli were unable to provide Plaintiff

with any information regarding the Defendants’ financial condition or their culpability for publication

of the Defamatory Article.

As for Greg Anglin, Mr. Obeidallah effected in-person service of the document and deposition

subpoenas on September 25, 2018. As explained in greater detail in the Status Report filed in

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conjunction with this Motion, Greg Anglin willfully disregarded his obligations under those subpoenas

for numerous weeks. In response to the document subpoena, Greg Anglin, by and through his

counsel, merely provided Mr. Obeidallah’s counsel with printed copies of previously filed exhibits on

October 31, 2018. In doing so, he denied Mr. Obeidallah the opportunity to review those documents

as they are kept in the ordinary course, and Mr. Obeidallah has no way of knowing whether he would

have received additional probative information if Greg Anglin had complied with the subpoena.

Mr. Obeidallah’s counsel also took Greg Anglin’s deposition testimony on October 31, 2018

in accordance with the Court’s August 20, 2018 Order.1 During that deposition, Mr. Anglin described

how readers of the Daily Stormer have directed hundreds of thousands of dollars in financial

contributions to ”Andrew Anglin.”2 See, e.g., Ex. 5, G. Anglin Tr. 26:10-22 [hereinafter, “G. Anglin

Tr.] (estimating average monthly contributions of $1,500 until 2017, “and then there as a spike in the

deposits”), 27:14-28:4 (estimating total contributions from Daily Stormer readership of $100,000 to

$125,000). Those funds were first directed to Greg Anglin’s office suite—6827 N High Street, Suite

121, Worthington, Ohio 43085 (“Suite 121”). Id. at 9:5-7 (Greg Anglin acknowledging Suite 121 as

office space), 59:25-60:12 (contributions directed to “Andrew Anglin” and Daily Stormer at Suite 121).

In addition to receiving his personal mail at Suite 121, Greg Anglin authorized Defendants Anglin and

1 The recent factual background of this case prior to Greg Anglin’s deposition is set forth in Section I(B) of Mr. Obeidallah’s concurrently filed Status Report, as well as in his previously filed Motion for Limited Discovery in Aid of Default Judgment, ECF No. 31. In the interest of preserving the resources of the Court, it has not been recounted here. 2 As previously explained, it is unclear whether “Andrew Anglin” refers to Defendant Anglin or Moonbase, as Moonbase registered “Andrew Anglin” as a trade name with the Ohio Secretary of State. This is likely just another effort by Greg Anglin and the Defendants to conceal their activities and obfuscate any attempt to hold them liable. In any event, Greg Anglin acknowledged having filed the “Andrew Anglin” trade name registration on Defendant Moonbase’s behalf, and the Daily Stormer has stated that Moonbase is involved with receipt of credit card contributions from the Daily Stormer’s readership, see, e.g., G. Anglin Tr. 67:2-68:9; Pl.’s Mot. for Limited Discovery 8, ECF No. 31 (quoting Daily Stormer article explaining credit card donations would appear as “Moonbase Holdings” on credit card bills).

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Moonbase to direct their mail to that address. See, e.g., id. at 14:9-11 (Greg Anglin’s personal mail),

23:9-13 (Greg Anglin authorizing Defendant Anglin “to have his personal mail directed to . . . my

office”); 67:2-68:7 (Greg Anglin acknowledging he applied for “Andrew Anglin” trade name on

Moonbase’s behalf); A. Anglin Trade Name Reg. 3, ECF No. 23-10 (Greg Anglin designating

Moonbase’s “[b]usiness address” as his office, Suite 121). In 2017, shortly after protestors announced

their intention to picket outside Suite 121,3 Greg Anglin established a PO Box—Post Office Box 208,

Worthington, Ohio 43085 (“PO Box 208”)—on Moonbase’s behalf, to which the Daily Stormer

redirected its readers’ contributions. G. Anglin Tr. 107:14-108:7 (Greg Anglin registered for PO Box

208), 116:3-13 (Greg Anglin acknowledging Daily Stormer redirected readers to send contributions to

PO Box 208); PO Box 208 Reg. 2, ECF No. 23-12 (Greg Anglin registering PO Box 208 on behalf of

“[b]usiness/[o]rganization” named “Andrew Anglin,” which is Moonbase’s trade name).

From 2013 to December 2017, Greg Anglin collected contributions that Daily Stormer readers

directed to “Andrew Anglin” at Suite 121 and PO Box 208. G. Anglin Tr. 26:2-9 (five years), 28:22-

29:6 (last deposit in December 2017). Once received, Greg Anglin would take one of numerous

actions. Most often, Greg Anglin would deposit the funds, approximately once a month, into an

account at a bank (“Bank 14“) in the name of “Andrew Anglin.” Id. at 24:16-25:2 (deposits to account

at Bank 1 in the name of “Andrew Anglin”), 25:8-11 (approximately once per month). If the

contributions were foreign currency, Greg Anglin would deposit that currency into his personal

3 Protests were announced online as early as January 5, 2017, with the protest scheduled for January 14, 2017 outside Suite 121. See, e.g., Ex. 6, Ida Vox, Rally Against the Anglins of Daily Stormer in Ohio (Jan. 5, 2017). Days after the protest was announced, on January 12, 2017, Greg Anglin established PO Box 208 on behalf of Defendant Moonbase. See PO Box 208 Reg., ECF No. 23-12. 4 Due to the controversial nature of the Daily Stormer, Mr. Obeidallah is not naming the financial institutions that have likely received donations from Defendants Andrew B. Anglin and Moonbase Holdings, LLC in this document. Mr. Obeidallah is happy to provide this information to the Court at its request.

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accounts at another bank (“Bank 2”)5, and then wrote a check to Defendant Anglin, which he then

deposited at Bank 1. Id. at 31:2-14. Beginning in 2017, Greg Anglin also deposited contributions

from the Daily Stormer’s readership in U.S. currency into his personal account at Bank 2, and then

wrote checks to the account of “Andrew Anglin” at Bank 1. Id. at 31:15-32:13.

Greg Anglin would also use the contributions directed to “Andrew Anglin” as

“reimbursement” for services that he would perform on behalf of the Defendants, including those

relating to the Daily Stormer. See, e.g., id. at 49:7-51:25 (Greg Anglin “reimbursed” for paying fee to

register Moonbase with Ohio Secretary of State by keeping cash from Daily Stormer contributions),

54:11-55:3 (Greg Anglin “reimbursed” for paying fee to register “Andrew Anglin” as trade name for

Moonbase).6 Greg Anglin would often pay fees associated with those services from his personal bank

account at Bank 2 or his personal credit card before seeking such “reimbursement.” See e,g., id. at

52:12-52:25 (check from Bank 2 to pay fee associated with filing Moonbase’s Articles of Organization),

53:23-55:6 (potential check from Bank 2 to pay for Moonbase’s registration of trade name “Andrew

Anglin”), 80:20-81:22 (Greg Anglin’s personal credit card to register domain www.dailystormer.com).

Finally, Greg Anglin used a large sum of the Daily Stormer’s contributions for his own benefit—

having “borrowed” approximately $60,038 for a “real estate rehab”—which Greg Anglin allegedly

paid back by writing a check from his personal account at another bank (“Bank 3”) and depositing it

into the account for “Andrew Anglin” at Bank 1. Id. at 120:8-121:6 (Greg Anglin “borrowed”

$60,038), 123:4-23 (check from Bank 3 to Bank 1).

5 Mr. Greg Anglin’s checking account at Bank 2 has since been closed for unknown reasons, and he later began banking at Bank 3. Id. at 53:1-9. 6 Greg Anglin testified that there was no conversation or agreement reflecting this arrangement with Defendants Anglin or Moonbase. Instead, Greg Anglin claimed this was just an “implicit understanding” regarding how he would perform services for the Defendants. G. Anglin Tr. 51:8-16.

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Greg Anglin testified that he does not “keep any accounting or ledger of the amounts” that

are sent to “Andrew Anglin” by the Daily Stormer’s readers, id. at 52:2-4, nor did he produce any

materials to Mr. Obeidallah in response to the document subpoena in this regard. Also, though

testifying that he does not “really use email much” and that “[i]t’s not really my thing,” Greg Anglin

stated that it is his practice to delete emails from both his inbox and sent folders. Id. at 12:23-13:3

(email usage), 69:11-14 (deletions).

In addition to contributions from the Daily Stormer’s readers, Greg Anglin testified that he

received “legal documents” directed to Defendants Anglin and Moonbase at Suite 121 and PO Box

208. This is unsurprising since Greg Anglin filed paperwork with the Ohio Secretary of State

representing that Defendant Anglin was Moonbase’s registered agent for service, and service could be

affected at Suite 121 or, later, at PO Box 208. See, e.g., Moonbase’s Agent Address Change 4, ECF

No. 31-27 (designating Moonbase’s “[n]ew [a]ddress of [a]gent” as PO Box 208). Despite his role in

designating Suite 121 and PO Box 208 as appropriate addresses for legal process on Defendant

Moonbase, Greg Anglin testified that he throws all such communications in the trash. G. Anglin

Tr. 58:17-23. Alternatively, he places all legal documents directed to Defendants Anglin “in a big

plastic tub,” where they sit, and he makes no effort to forward them to anyone. Id. at 58:5-16.

In addition to the Daily Stormer contributions, Greg Anglin testified that he maintains two

envelopes for Defendant Anglin—one with foreign currency, and one with United States currency—

in a security box in Greg Anglin’s name at Bank 3. Id. at 121:21-122:15. Greg Anglin was uncertain

how much of Defendant Anglin’s money remains in those envelopes, but he estimated $2,000. Id. at

122:11-15.

Greg Anglin testified that he was not aware of any bank accounts that Defendant Moonbase

uses, whether it has any financial obligations, whether it owns any property, or whether it still exists

as a business entity. G. Anglin Tr. 20:2-15, 61:4-9. He also does not know whether Moonbase files

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tax returns. Id. at 57:19-21. He has allegedly never known the financial condition of Moonbase, and

does not know whether it is on the cusp of insolvency. Id. at 106:25-107:13. He also testified that, as

far as he is aware, Moonbase does not maintain any financial records. Id. at 32:14-19. Similarly, he

testified that he does not know why readers of the Daily Stormer were sending the contributions that

he deposited, nor does he allegedly know what Defendants Anglin or Moonbase do with that money.

Id. at 147:7-149:5.

II. STANDARD OF REVIEW

Courts enjoy “broad discretion” to order discovery. Arista Records, LLC v. Does 1-15, No. 2:07-

cv-450, 2007 WL 5254326, at *3 (S.D. Ohio Nov. 5, 2007). While the Federal Rules of Civil Procedure

anticipate that discovery will typically not begin “before the parties have conferred as required as

required by Rule 26(f),” they allow for discovery prior to the Rule 26(f) conference “by court order.”

Fed. R. Civ. P. 26(d); see also Arista Records, 2007 WL 5254326, at *2. This provision requires that the

party requesting expedited discovery show “good cause,” which “may be found where the need for

expedited discovery, in consideration of the administration of justice, outweighs the prejudice to the

responding party.” Arista Records, 2007 WL 5254326, at *2 (internal quotations and citations omitted).

Courts have regularly found good cause to authorize such discovery when, inter alia, a defendant

defaults and the plaintiff needs discovery in order to establish liability and/or damages in pursuit of

default judgment. See, e.g., Twitch Interactive, Inc. v. Johnston, No. 5:16-cv-03404-BLF, 2017 WL 1133520,

at *4 (N.D. Cal. Mar. 27, 2017) (authorizing discovery in aid of forthcoming motion for default

judgment from payment processors, financial institutions, and co-defendant); Antoine v. Boutte,

No. 3:15-cv-00561-JWD-EWD, 2016 WL 6138252, at *4 (M.D. La. Oct. 20, 2016) (same from third-

party distributors regarding quantum of damages); Adobe Sys. Inc. v. Bunhey, No. 5:13-cv-01365-VAP-

OPX, 2013 WL 12140304, at *2 (C.D. Cal. Oct. 29, 2013) (same from third-party distributors

regarding defaulting defendant’s purchase, sale, and/or distribution of counterfeit products); Texas

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Guaranteed Student Loan Corp. v. Dhindsa, No. 1:10-cv-00335-LJO-SKO, 2010 WL 2353520, at *3 (E.D.

Cal. June 9, 2010) (same from defaulting defendant regarding quantum of damages); Sheridan v. Oak

Street Mortg., LLC, 244 F.R.D. 520, 522 (E.D. Wis. 2007) (same regarding class certification and

quantum of damages).

III. GOOD CAUSE EXISTS FOR DISCOVERY IN AID OF DEFAULT JUDGMENT AGAINST DEFENDANTS ANDREW B. ANGLIN AND MOONBASE

The Court should grant Mr. Obeidallah leave to take limited discovery in aid of establishing a

sum-certain of default judgment damages, because doing so is necessary for the purposes of

quantifying the amount of compensatory and punitive damages attributable to Defendants Anglin and

Moonbase.

In both his Complaint and his concurrently filed Motion for Default Judgment, Mr. Obeidallah

seeks punitive damages for the false and defamatory actions and statements made by Defendants

Anglin and Moonbase. See, e.g., Compl. ¶ 74, ECF No. 1; id. at 37 (prayer for relief). As the Supreme

Court of Ohio has noted, the purposes of punitive damages are “(1) to punish the wrongdoer, and (2)

to deter others from similar conduct.” Wagner v. McDaniels, 459 N.E.2d 561, 564 (Ohio 1984).

Whether a damages award succeeds in punishing a wrongdoer or deterring others depends on the

scale of the damages award relative to the net worth of the defendant, and in particular, to the amount

of profit that that wrongful action generated for the wrongdoer. See id. (stating “evidence of a

defendant’s net worth may be considered by the fact-finder in determining appropriate punitive

damages”).

In this case, Defendants Anglin and Moonbase likely received hundreds of thousands of

dollars in “contributions” from readers of the Daily Stormer who were encouraged by their wrongful

actions. G. Anglin Tr. at 27:22-28:4. These donations “spike[d]” upward in 2017, when the

defamatory article that harmed Mr. Obeidallah was posted. Id. at 26:14-22. And Defendant Anglin

has specifically used his wrongful actions against Mr. Obeidallah as the basis to request additional

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contributions from the Daily Stormer readers, posting: “Presumably, even if Dean [Obeidallah]

disappears, the Association of Moslems will still sue me. So send me some money, lmao.“ 7

See Ex. 8, Daily Stormer, Steven Crowder Allegedly Hunting Manchester Bombing Mastermind Dean Obeidallah

in Isis-Occupied Syria (Aug. 29, 2017) (emphasis added). The twin goals of punishment and deterrence

will not be achieved if Defendants Anglin and Moonbase are permitted to profit from their extreme

and tortious conduct, and a fulsome accounting of their profits is necessary to avoid such an outcome.

Therefore, the requested discovery from Banks 1, 2, and 3 regarding the amount of money received

by Defendants Anglin and Moonbase, and the timing of those payments, are relevant to

Mr. Obeidallah’s crafting of a reasonable and appropriate damages request in this case.

In addition to punitive damages, information about the Defendants’ financial conditions is

relevant to the preliminary calculation of damages for many of Mr. Obeidallah’s claims. See, e.g., State,

ex rel. Brown v. Dayton Malleable, Inc., 438 N.E.2d 120, 128 (Ohio 1982) (stating, in dicta, that “evidence

of the wealth of the defendant is admissible . . . in cases where wealth is necessarily involved in

determining damages, such as in actions for defamation or injury to reputation”); Sayavich v. Creatore,

2009-Ohio-5270, ¶ 80, 2009 WL 3165555, at *8 (Oh. App. Ct. Sep. 29, 2009) (assessing defamation

claim and “conclude[ing] that evidence of a defendant’s net worth is only relevant as to punitive

damages”); Gosden v. Louis, 687 N.E.2d 481, 499 (Oh. App. Ct. 1996) (“Information about defendants’

financial status is admissible in defamation cases to help the jury determine proper awards of

compensatory and punitive damages. Without this information, a jury is less able to determine the

likely influence a defendant may have had in the community. More importantly, a jury cannot

determine what would constitute an effective punitive damage award unless they have an

understanding of the defendant’s financial status.”).

7 The acronym “lmao” is a crass slang abbreviation that indicates laughter. Oxford Living Dictionaries, LMAO, https://en.oxforddictionaries.com/definition/lmao (November 16, 2018).

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With respect Mr. Obeidallah’s claim for common-law misappropriation of name and likeness,

Courts have specifically noted that “the monetary benefit that [defendant] received as a result of a

wrongful use of [plaintiff]’s name is an appropriate (although not exclusive) measure of damages.” See

James v. Bob Ross Buick, Inc., 855 N.E.2d 119, 124 (Ohio Ct. App. 2006). In similar actions for invasion

of privacy of public figures, expert witnesses opining on appropriate damages have cited the financial

conditions of the defendants, including the “value” of a defendant’s website. See Ex. 7, Hulk Hogan

Sex Tape Earned Gawker Up to $15M, Jury Told, Law360,

https://www.law360.com/articles/770586/hulk-hogan-sex-tape-earned-gawker-up-to-15m-jury-told

(last visited November 15, 2018); Ex. 9, Hulk Hogan Awarded $115 Million in Privacy Suit Against

Gawker, New York Times, https://www.nytimes.com/2016/03/19/business/media/gawker-hulk-

hogan-verdict.html (last visited November 15, 2018) (Noting that punitive damages calculation “raises

the prospect that [defendant] will have to submit to a detailed examination of its finances in court so

the jury can assess the scale of the damages”). Mr. Obeidallah has engaged an expert witness to

provide similar analysis here, but cannot do so without the limited, additional discovery sought.

Mr. Obeidallah was hopeful that information regarding the financial status of Defendants

Anglin and Moonbase, which is relevant to demonstrating the compensatory and punitive damages to

which he is entitled, could obtained through the subpoenas directed to Greg Anglin and Zappitelli Inc.

However, Greg Anglin did not produce any documents other than those already filed by

Mr. Obeidallah in this case (in fact, he merely provided Mr. Obeidallah’s counsel with print outs of

previously filed exhibits), and neither Greg Anglin nor Zappitelli Inc. was able to provide information

regarding the financial condition of the Defendants. Greg Anglin also professed ignorance as to the

finances of Defendants Anglin and Moonbase, and confirmed that, although he funneled

contributions from the Daily Stormer’s readership on behalf of Defendants Anglin and/or Moonbase

for five years, he did not keep any logs or records regarding the amounts involved in those

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transactions. See, e.g., G. Anglin Tr. 32:14-19, 51:2-4, 57:19-21, 61:4-9, 106:25-107:13, 147:7-149:5.

Alternatively, Zappitelli Inc. confirmed that it did not perform financial services for Defendants, and

as a result did not have records relating to their financial conditions. Ex. 3, J. Zappitelli Decl. ¶¶ 4, 6-

7. Therefore, this information can only be obtained from the financial institutions that Greg Anglin

used to funnel contributions from Daily Stormer’s readership.

Specifically, in order to answer the outstanding questions regarding Defendants’ financial

condition, which are necessary in support of his Motion for Default Judgment, Mr. Obeidallah

respectfully seeks leave to issue narrowly-tailored subpoenas duces tecum to the financial institutions

identified above in Part I as Banks 1, 2, and 3. The proposed requests for production, the substance

of which would be incorporated in those subpoenas, are attached hereto as Exhibit 2. As explained

above, good cause exists for such discovery because Greg Anglin used accounts at Banks 1, 2, and 3

to funnel contributions from the Daily Stormer’s readership on behalf of Defendants Anglin and

Moonbase, and because he professed uncertainty regarding the volume of those transactions. See, e.g.,

G. Anglin Tr. 24:16-25:5, 32:8-13, 113:2-17. This information cannot be obtained from any other

sources because: (1) Defendants Anglin and Moonbase are in default, and thus unlikely to respond to

discovery requests8; and (2) Greg Anglin, who processed donations on behalf of both Defendants,

testified that he was not aware of any other source of financial records that would reflect this

information.

8 As previously explained, Defendants Anglin has regularly acknowledged and mocked the pendency of this federal action. See, e.g., Mem. In Supp. of Pl.’s Mot. for Limited Discovery 6, ECF No. 31. This was again confirmed through Greg Anglin’s testimony. According to Greg Anglin, he received a call from Defendant Anglin (from a U.S. number) days before he was deposed, and during that call Defendant Anglin made statements suggesting he was already aware of the subpoena’s scope. G. Anglin Tr. 35:5-10, 36:10-22.

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IV. REQUEST FOR RELIEF

For these reasons, Mr. Obeidallah respectfully moves this Court pursuant to Rule 26(d)(1) of

the Federal Rules of Civil Procedure for leave to take limited discovery in aid of establishing a sum-

certain of default judgment damages. The requests for production, which Mr. Obeidallah proposes

directing to Banks 1, 2, and 3, are attached as Exhibit 2.

Respectfully submitted,

DATED: 11/16/2018 /s/ Subodh Chandra (trial counsel)

Subodh Chandra (OH Bar No. 0069233) Donald Screen (OH Bar No. 0044070) Attorneys for Plaintiff Dean Obeidallah THE CHANDRA LAW FIRM LLC 1265 W. 6th St., Suite 400 Cleveland, OH 44113-1326 Phone: 216.578.1700 Fx: 216.578.1800 [email protected] [email protected]

Johnathan Smith (D.C. Bar No. 1029373) Juvaria Khan (N.Y. Bar No. 5027461) MUSLIM ADVOCATES P.O. Box 66408 Washington, D.C. 20035 Phone: 202.897.1894 [email protected] [email protected] Admitted pro hac vice

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EXHIBIT 1 Case: 2:17-cv-00720-EAS-EPD Doc #: 46-2 Filed: 11/16/18 Page: 2 of 2 PAGEID #: 849

IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO EASTERN DIVISION

DEAN OBEIDALLAH, CASE NO. 2:17-CV-00720-EAS-EPD

Plaintiff, Chief Judge Edmund A. Sargus

v. Magistrate Judge Elizabeth Preston Deavers

ANDREW B. ANGLIN, DBA Daily Stormer,

and

MOONBASE HOLDINGS, LLC, DBA Andrew Anglin,

and

JOHN DOES NUMBERS 1–10, Individuals who also assisted in the publication or representation of false statements regarding Mr. Obeidallah,

Defendants.

[PROPOSED] ORDER GRANTING PLAINTIFF’S MOTION FOR ADDITIONAL DISCOVERY IN AID OF DEFAULT JUDGMENT

This matter is before the Court on Plaintiff’s Motion for Additional Discovery in Aid of

Default Judgment. For good cause shown, Plaintiff’s motion is GRANTED.

It is ORDERED that Plaintiff Dean Obeidallah may serve the limited, immediate discovery

as set forth in Exhibit 2 of the Motion for Additional Discovery in Aid of Default Judgment.

IT IS SO ORDERED.

Date: ______United States Magistrate Judge Case: 2:17-cv-00720-EAS-EPD Doc #: 46-3 Filed: 11/16/18 Page: 1 of 4 PAGEID #: 850

EXHIBIT 2 Case: 2:17-cv-00720-EAS-EPD Doc #: 46-3 Filed: 11/16/18 Page: 2 of 4 PAGEID #: 851

IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO EASTERN DIVISION

DEAN OBEIDALLAH, CASE NO. 2:17-CV-00720-EAS-EPD

Plaintiff, Chief Judge Edmund A. Sargus

v. Magistrate Judge Elizabeth Preston Deavers

ANDREW B. ANGLIN, DBA Daily Stormer,

and

MOONBASE HOLDINGS, LLC, DBA Andrew Anglin,

and

JOHN DOES NUMBERS 1–10, Individuals who also assisted in the publication or representation of false statements regarding Mr. Obeidallah,

Defendants.

PLAINTIFF’S PROPOSED REQUESTS FOR PRODUCTION OF DOCUMENT AND THINGS

Plaintiff Dean Obeidallah submits the following document requests (which will accompany

subpoenas duces tecum) in support of his Motion for Additional Discovery in Aid of Default

Judgment. For sake of brevity, Mr. Obeidallah has foregone providing the Court with definitions,

instructions, and other portions of the proposed subpoenas which are ancillary to assessing whether

the requests are appropriately tailored to the relief requested and minimize the burden on the requested

party. Mr. Obeidallah is happy to submit complete copies of the subpoenas duces tecum upon the

Court’s request.

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I. BANK 11

A. Documents to Be Produced

1. Documents sufficient to show the transactional information during the Relevant Period2, including dollar value, date, deposit slips, and images, of any checks deposited into or withdrawn from any account associated with: (a) Andrew B. Anglin; or (b) Moonbase Holdings, LLC.

2. Documents sufficient to show the transactional information during the Relevant Period, including dollar value, date, and deposit slips, of any cash deposited into or withdrawn from any account associated with: (a) Andrew B. Anglin; or (b) Moonbase Holdings, LLC.

3. Documents sufficient to show the history of account balances and transactions during the Relevant Period, including amounts that have been deposited or withdrawn, and merchant names and transaction descriptions, for any account associated with: (a) Andrew B. Anglin; or (b) Moonbase Holdings, LLC.

II. BANK 2

A. Documents to Be Produced

1. Documents sufficient to show the transactional information during the Relevant Period, including dollar value, date, recipient, and images, of any checks withdrawn from or deposited into any account associated with Gregory Mark Anglin where the transaction involved one or more of the following parties: (a) Andrew B. Anglin; (b) Moonbase Holdings, LLC; (c) the Daily Stormer; (d) GoDaddy; (e) Zappitelli CPA Inc.; (f) the U.S. Postal Service; or (g) the Ohio Secretary of State.

2. Documents sufficient to show the transactional information during the Relevant Period, including dollar value, date, and any associated deposit slips or receipts, of any cash withdrawn from or deposited into any account associated with Gregory Mark Anglin.

3. Documents sufficient to show the transactional information during the Relevant Period, including dollar value, date, merchant name, and description, of any credit or debit account associated with Gregory Mark Anglin where the transaction involved one or more of the following parties: (a) Andrew B.

1 Due to the controversial nature of the Daily Stormer, Mr. Obeidallah is not naming the financial institutions that have likely received donations from Defendants Andrew B. Anglin and Moonbase Holdings, LLC in this document. Mr. Obeidallah is happy to provide this information to the Court at its request. 2 Mr. Obeidallah proposes defining “Relevant Period,” as used in each request, as March 1, 2013 to present.

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Anglin; (b) Moonbase Holdings, LLC; (c) the Daily Stormer; (d) GoDaddy; (e) Zappitelli CPA Inc.; (f) the U.S. Postal Service; or (g) the Ohio Secretary of State.

III. BANK 3

A. Documents to Be Produced

1. Documents sufficient to show the transactional information during the Relevant Period, including dollar value, date, recipient, and images, of any checks withdrawn from or deposited into any account associated with Gregory Mark Anglin where the transaction involved one or more of the following parties: (a) Andrew B. Anglin; (b) Moonbase Holdings, LLC; (c) the Daily Stormer; (d) GoDaddy; (e) Zappitelli CPA Inc.; (f) the U.S. Postal Service; or (g) the Ohio Secretary of State.

2. Documents sufficient to show the transactional information during the Relevant Period, including dollar value, date, and any associated deposit slips or receipts, of any cash withdrawn from or deposited into any account associated with Gregory Mark Anglin.

3. Documents sufficient to show the transactional information during the Relevant Period, including dollar value, date, merchant name, and description, of any credit or debit account associated with Gregory Mark Anglin where the transaction involved one or more of the following parties: (a) Andrew B. Anglin; (b) Moonbase Holdings, LLC; (c) the Daily Stormer; (d) GoDaddy; (e) Zappitelli CPA Inc.; (f) the U.S. Postal Service; or (g) the Ohio Secretary of State.

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EXHIBIT 3

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EXHIBIT A

DOC ID ----> 201625400014 Case: 2:17-cv-00720-EAS-EPD Doc #: 46-4 Filed: 11/16/18 Page: 7 of 21 PAGEID #: 860 DOC ID ----> 201625400014 Case: 2:17-cv-00720-EAS-EPD Doc #: 46-4 Filed: 11/16/18 Page: 8 of 21 PAGEID #: 861 DOC ID ----> 201625400014 Case: 2:17-cv-00720-EAS-EPD Doc #: 46-4 Filed: 11/16/18 Page: 9 of 21 PAGEID #: 862 DOC ID ----> 201625400014 Case: 2:17-cv-00720-EAS-EPD Doc #: 46-4 Filed: 11/16/18 Page: 10 of 21 PAGEID #: 863 Case: 2:17-cv-00720-EAS-EPD Doc #: 46-4 Filed: 11/16/18 Page: 11 of 21 PAGEID #: 864

EXHIBIT B

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EXHIBIT C

DOC ID ----> 201700502616 Case: 2:17-cv-00720-EAS-EPD Doc #: 46-4 Filed: 11/16/18 Page: 14 of 21 PAGEID #: 867 DOC ID ----> 201700502616 Case: 2:17-cv-00720-EAS-EPD Doc #: 46-4 Filed: 11/16/18 Page: 15 of 21 PAGEID #: 868 DOC ID ----> 201700502616 Case: 2:17-cv-00720-EAS-EPD Doc #: 46-4 Filed: 11/16/18 Page: 16 of 21 PAGEID #: 869 Case: 2:17-cv-00720-EAS-EPD Doc #: 46-4 Filed: 11/16/18 Page: 17 of 21 PAGEID #: 870

EXHIBIT D

DOC ID ----> 201801700160 Case: 2:17-cv-00720-EAS-EPD Doc #: 46-4 Filed: 11/16/18 Page: 18 of 21 PAGEID #: 871 DOC ID ----> 201801700160 Case: 2:17-cv-00720-EAS-EPD Doc #: 46-4 Filed: 11/16/18 Page: 19 of 21 PAGEID #: 872 DOC ID ----> 201801700160 Case: 2:17-cv-00720-EAS-EPD Doc #: 46-4 Filed: 11/16/18 Page: 20 of 21 PAGEID #: 873 DOC ID ----> 201801700160 Case: 2:17-cv-00720-EAS-EPD Doc #: 46-4 Filed: 11/16/18 Page: 21 of 21 PAGEID #: 874 Case: 2:17-cv-00720-EAS-EPD Doc #: 46-5 Filed: 11/16/18 Page: 1 of 16 PAGEID #: 875

EXHIBIT 4

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EXHIBIT A

DOC ID ----> 201625400014 Case: 2:17-cv-00720-EAS-EPD Doc #: 46-5 Filed: 11/16/18 Page: 6 of 16 PAGEID #: 880 DOC ID ----> 201625400014 Case: 2:17-cv-00720-EAS-EPD Doc #: 46-5 Filed: 11/16/18 Page: 7 of 16 PAGEID #: 881 DOC ID ----> 201625400014 Case: 2:17-cv-00720-EAS-EPD Doc #: 46-5 Filed: 11/16/18 Page: 8 of 16 PAGEID #: 882 DOC ID ----> 201625400014 Case: 2:17-cv-00720-EAS-EPD Doc #: 46-5 Filed: 11/16/18 Page: 9 of 16 PAGEID #: 883 Case: 2:17-cv-00720-EAS-EPD Doc #: 46-5 Filed: 11/16/18 Page: 10 of 16 PAGEID #: 884

EXHIBIT B

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EXHIBIT C

DOC ID ----> 201801700160 Case: 2:17-cv-00720-EAS-EPD Doc #: 46-5 Filed: 11/16/18 Page: 13 of 16 PAGEID #: 887 DOC ID ----> 201801700160 Case: 2:17-cv-00720-EAS-EPD Doc #: 46-5 Filed: 11/16/18 Page: 14 of 16 PAGEID #: 888 DOC ID ----> 201801700160 Case: 2:17-cv-00720-EAS-EPD Doc #: 46-5 Filed: 11/16/18 Page: 15 of 16 PAGEID #: 889 DOC ID ----> 201801700160 Case: 2:17-cv-00720-EAS-EPD Doc #: 46-5 Filed: 11/16/18 Page: 16 of 16 PAGEID #: 890 Case: 2:17-cv-00720-EAS-EPD Doc #: 46-6 Filed: 11/16/18 Page: 1 of 76 PAGEID #: 891

EXHIBIT 5

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Page 9 1 GREGORY ANGLIN

2 asked -- he told me he had a subpoena. I said, can 09:00:49

3 you meet at my office in an hour, and he said yes, 09:00:52

4 and we did. 09:00:55

5 Q. What is your office address? 09:00:56

6 A. It's 6827 North High Street, Suite 121, 09:01:02

7 Worthington, Ohio. 09:01:06

8 Q. Do you share that office space with 09:01:08

9 anybody? 09:01:09

10 A. My particular office Suite? 09:01:13

11 Q. Yes, sir, Suite 121. 09:01:15

12 A. There are some other counselors there, 09:01:17

13 yes. 09:01:19

14 Q. What business is resident at Suite 121? 09:01:19

15 A. Well, there is an office psychiatric, 09:01:25

16 which is a counselor that is there. There is Hope 09:01:29

17 Recovery, which is another counselor that's there, 09:01:36

18 and myself and some gentlemen that do some sort of 09:01:39

19 business consulting. 09:01:45

20 Q. And do you know those gentlemen's business 09:01:47

21 name or personal name? 09:01:49

22 A. Robert is the only thing I remember of his 09:01:51

23 name, yes. 09:01:53

24 Q. Do you have any understanding as to what 09:01:54

25 type of business consulting occurs? 09:01:56

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Page 12 1 GREGORY ANGLIN

2 not asking for any conversations between you and me. 09:04:13

3 THE WITNESS: Right. 09:04:17

4 A. I'm sorry, could you ask the question one 09:04:23

5 more time? 09:04:25

6 Q. I would like to understand what efforts 09:04:25

7 you undertook to identify whether or not you 09:04:27

8 possessed documents responsive to the five requests 09:04:30

9 detailed in Exhibit 1. 09:04:33

10 A. Well, I carefully read them, and it was my 09:04:34

11 understanding I did not have any copies of anything 09:04:40

12 that had been requested. 09:04:42

13 Q. Do you maintain files related to your 09:04:46

14 businesses at the Suite 121 address we spoke about 09:04:49

15 earlier? 09:04:54

16 A. No, I do not. 09:04:54

17 Q. Where do you maintain documents related to 09:04:55

18 your businesses? 09:04:58

19 A. At my personal residence. 09:04:58

20 Q. Do you use email for your business? 09:05:03

21 A. Well, I'm retired, so I don't really do 09:05:06

22 much business. 09:05:10

23 Q. Have you ever used email related to your 09:05:12

24 businesses in the last five years? 09:05:15

25 A. I mean, I'm sure I've sent some emails. I 09:05:23

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Page 13 1 GREGORY ANGLIN

2 don't really use email much. It's not really my 09:05:26

3 thing. 09:05:30

4 Q. Understood. Do you have an email address? 09:05:30

5 A. Yes, I do. 09:05:32

6 Q. What is that? 09:05:33

7 A. It's G R E G O R Y M A R K A N G L I 09:05:33

8 N@yahoo. 09:05:39

9 Q. And did you review the emails sent or 09:05:42

10 received from that address in connection with the 09:05:46

11 subpoena? 09:05:49

12 A. I'm not sure I understand what you're 09:05:52

13 asking. I'm sorry. 09:05:54

14 Q. As part of the efforts to respond to the 09:05:55

15 subpoena, did you log into your email account and 09:05:57

16 determine whether or not there's any emails, 09:06:00

17 correspondence, documents, responsive to the subpoena 09:06:02

18 in your email inbox? 09:06:05

19 A. Oh, yes, I did check my email. 09:06:07

20 Q. When did you do that? 09:06:09

21 A. After I received the subpoena. 09:06:10

22 Q. And that analysis revealed that there were 09:06:14

23 no documents responsive? 09:06:17

24 A. None at all, no. 09:06:18

25 Q. Did you talk to any person you worked with 09:06:23

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Page 14 1 GREGORY ANGLIN

2 in your business to look for responsive documents? 09:06:27

3 A. When you say my business, I'm not sure 09:06:34

4 what you're asking. 09:06:36

5 Q. I believe you said earlier that you work 09:06:38

6 in the counseling business? 09:06:40

7 A. I'm sorry, I retired about five years ago, 09:06:42

8 so I don't do any counseling. 09:06:46

9 Q. Do you still maintain an office address? 09:06:48

10 A. I get my mail sent to the office, my 09:06:51

11 personal mail. 09:06:53

12 Q. Do you have office space at Suite 121? 09:06:54

13 A. No, I do not. 09:06:57

14 Q. Do you ever visit that location? 09:06:58

15 A. To pick up my mail, yes. 09:07:00

16 Q. For any other reason? 09:07:01

17 A. No, I don't think so. 09:07:08

18 Q. Do you pay monthly rental? 09:07:10

19 A. Yes, I do. 09:07:13

20 Q. And what do you understand that payment to 09:07:15

21 represent? Why are you paying rent? 09:07:18

22 A. Well, because I'm still on a lease for 09:07:21

23 another 18 months. 09:07:23

24 Q. Do you have any possessions at that 09:07:27

25 location? 09:07:29

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Page 20 1 GREGORY ANGLIN

2 Q. Do you know of any bank accounts Moonbase 09:13:04

3 Holdings uses? 09:13:07

4 A. No, I do not. 09:13:08

5 Q. Do you know if Moonbase -- I'll just call 09:13:12

6 it Moonbase, but you'll know that I'm referring to 09:13:15

7 the entity Moonbase Holdings, LLC, is that fair? 09:13:19

8 A. Yes, sir. 09:13:23

9 Q. Do you know if Moonbase has any financial 09:13:23

10 obligations? Has it taken out any loans? Has it 09:13:25

11 bought any property? 09:13:28

12 A. I don't know. 09:13:29

13 Q. Do you know if Moonbase is still in 09:13:32

14 existence today? 09:13:36

15 A. I do not know. 09:13:38

16 Q. Have you ever spoken to your son about 09:13:39

17 Moonbase after that initial conversation where he 09:13:41

18 told you he was going to set it up? 09:13:44

19 A. I don't recall ever talking to him about 09:13:53

20 it, no. 09:13:54

21 Q. You talked to him initially when he told 09:13:58

22 you he was going to create it, correct? 09:14:00

23 A. He told me he was going to create it, yes. 09:14:04

24 Q. And it's your testimony that after that 09:14:07

25 date and time, you never spoke to him about it again? 09:14:09

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Page 22 1 GREGORY ANGLIN

2 A. Okay. Thank you. When I asked him to -- 09:15:45

3 he wanted to set up a post office box, and he -- I'm 09:15:59

4 trying to remember the details of it. He wanted to 09:16:10

5 establish a post office box, and he set it up under 09:16:15

6 Andrew Anglin. And I think there was some connection 09:16:22

7 between those, but I'm really not sure. 09:16:26

8 Q. And what involvement, if any, did you have 09:16:28

9 in the setting up of a post office box? 09:16:30

10 A. I filled out the application for the 09:16:34

11 postal service for his post office box. 09:16:35

12 Q. Why did you do that? 09:16:39

13 A. Because being out of the country at the 09:16:40

14 time, he was unable to set up a post office box, and 09:16:43

15 I told him I would do it for him. 09:16:48

16 Q. And did you have any understanding 09:16:50

17 regarding the purpose of setting up a post office 09:16:52

18 box? 09:16:54

19 A. For him to send his personal mail. 09:16:58

20 Q. Other than that understanding, did you 09:17:08

21 have any other awareness as to why he needed a post 09:17:09

22 office box? 09:17:13

23 A. I don't believe I did. 09:17:19

24 Q. Okay. Had you assisted him, prior to the 09:17:20

25 creation of the post office box, had you ever 09:17:23

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Page 23 1 GREGORY ANGLIN

2 assisted him with securing mail? 09:17:26

3 A. Yes, I had, at -- well, when he began 09:17:29

4 traveling in his 20's, he started using my office 09:17:35

5 address as his mailing address. 09:17:41

6 Q. And is this the address we discussed 09:17:43

7 earlier, Suite 121, 6827? 09:17:46

8 A. That's correct. 09:17:49

9 Q. And did you give him permission to do 09:17:50

10 that? 09:17:52

11 A. I gave him permission to have his personal 09:17:54

12 mail directed to my post office box -- to my office, 09:17:57

13 yes. 09:18:01

14 Q. And how would he retrieve it from the 09:18:02

15 office? 09:18:04

16 A. Well, there wasn't a lot of mail, but when 09:18:08

17 he came in town, I guess he would get it. But there 09:18:11

18 really wasn't much. 09:18:15

19 Q. When you would pick up your mail at Suite 09:18:17

20 121, did you also pick up his mail? 09:18:20

21 A. Yes. 09:18:24

22 Q. Okay. And what did you do with it? 09:18:24

23 A. With his personal mail? 09:18:26

24 Q. Yes, sir. 09:18:27

25 A. I'm trying to remember. We're talking 09:18:48

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Page 24 1 GREGORY ANGLIN

2 about his personal mail -- what mail are we talking 09:18:51

3 about exactly? His personal mail? 09:18:54

4 Q. Other than personal mail directed to 09:18:57

5 Mr. Andrew Anglin what other type of mail was sent to 09:18:59

6 that address? 09:19:03

7 A. Are we talking about the office address or 09:19:07

8 the post office box address, I'm sorry? 09:19:09

9 Q. Right now, sir, we're talking about Suite 09:19:11

10 121, 6827 North High Street. 09:19:13

11 A. Okay. He received legal documents to that 09:19:17

12 address. He received contributions sent to him. I 09:19:20

13 don't know if they were contributions; probably the 09:19:30

14 wrong word. Readers of the Daily Stormer would send 09:19:32

15 money to that address. 09:19:35

16 Q. And I believe you testified earlier that 09:19:38

17 you would pick up this mail. And my follow-up 09:19:40

18 question was: What would you do with it after you 09:19:45

19 picked it up? 09:19:47

20 A. If there were -- I would deposit it into 09:19:49

21 his bank account. 09:19:52

22 Q. Okay. And what bank is that? 09:19:56

23 A. 09:19:57

24 Q. And what is the name of the account 09:20:01

25 holder? 09:20:02

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Page 25 1 GREGORY ANGLIN

2 A. Andrew Anglin. 09:20:04

3 Q. And do you have the account number? 09:20:06

4 A. I have it somewhere. I don't know it. 09:20:10

5 I'm sure I could retrieve it. 09:20:14

6 MR. QURESHI: We would make a request for 09:20:16

7 that information, please. 09:20:17

8 And what was the frequency with which you 09:20:21

9 would make deposits on behalf of Mr. Andrew Anglin? 09:20:23

10 A. It varied quite a lot. Perhaps once a 09:20:33

11 month. 09:20:39

12 Q. The address at the where you 09:20:43

13 would make the deposits, do you recall that? 09:20:45

14 A. I don't. It was normally -- well, there 09:20:48

15 were a couple branches that are near my home. 09:20:50

16 So one of them would have been at Graceland Shopping 09:20:53

17 Center. One of them would have been on 09:20:56

18 Dublin-Granville Road. 09:21:00

19 Q. The deposits you would make are in an 09:21:05

20 account held in Mr. Andrew Anglin's name, is that 09:21:08

21 correct? 09:21:11

22 A. That's correct. 09:21:12

23 Q. Was there any business account associated 09:21:12

24 with the funds that you would receive? 09:21:14

25 A. No. 09:21:17

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Page 26 1 GREGORY ANGLIN

2 Q. And I understand that you said it would -- 09:21:20

3 the amounts would vary, the frequency would vary, 09:21:23

4 approximately once a month, is that correct? 09:21:26

5 A. Yes. Maybe not quite that often. 09:21:29

6 Q. And going back in time how far? 09:21:32

7 A. Probably five years. 09:21:39

8 Q. Roughly 2013, five years from today? 09:21:42

9 A. Roughly, yes. 09:21:49

10 Q. And what was the order of magnitude of the 09:21:50

11 deposits you would make on behalf of 09:21:53

12 Mr. Andrew Anglin? 09:21:55

13 A. I'm not sure I know what that means. 09:21:56

14 Q. I'm just looking for the amounts, sir. 09:21:58

15 You said you would make deposits once a month, 09:22:00

16 roughly. I'm trying to understand how big the 09:22:02

17 deposits were. 09:22:06

18 A. Up until 2000 -- we're going way out of 09:22:10

19 the -- maybe $1,500 a month on average up until mid 09:22:16

20 2017, and then there was a spike in the deposits. 09:22:36

21 Q. A spike increase? 09:22:41

22 A. Increase. 09:22:42

23 Q. To what magnitude? 09:22:43

24 A. You know, I'm just not comfortable 09:22:47

25 guessing on that. I mean, significantly more than a 09:22:49

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2 thousand dollars or $1,500 a month. 09:22:52

3 Q. Was it more than 10,000? 09:22:55

4 A. Yes. 09:22:56

5 Q. More than 25,000? 09:22:57

6 A. You mean average a month? I'm sorry. Oh, 09:23:00

7 no, not average a month. 09:23:02

8 Q. What about an aggregate? 09:23:04

9 A. Again, I'm not sure what you're asking. 09:23:07

10 Q. I'm just trying to get a sense of the 09:23:09

11 total amount of funds that were deposited into the 09:23:11

12 account at 09:23:15

13 A. Over what period? 09:23:16

14 Q. Since it started, from 2013 through the 09:23:18

15 present. I believe you said for some time it was 09:23:20

16 about 1500 to a thousand dollars a month, but there 09:23:22

17 was a spike. So I think I'm focused now on the 09:23:25

18 spike. How much did it spike to? 09:23:28

19 A. If I had to guess an amount totally 09:23:35

20 deposited, it's a guess. We're allowed to do that, 09:23:38

21 is that right? 09:23:42

22 Q. I'm entitled to your best testimony. If 09:23:43

23 you're telling me your best testimony is a guess, I 09:23:46

24 would like to know what that guess is. 09:23:48

25 A. My guess would be the total deposits were 09:23:50

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2 between -- let me just think for a moment. My guess 09:23:53

3 would be between, over the five-year period, between 09:24:03

4 100,000 and 125,000 would be my guess total deposits. 09:24:07

5 Q. Bank statements for this particular 09:24:14

6 account, were they also sent to the Suite 121 09:24:16

7 address? 09:24:18

8 A. No, they were not. 09:24:20

9 Q. Do you know where they were sent? 09:24:21

10 A. No, I do not. 09:24:23

11 Q. Did you have any signatory authority over 09:24:24

12 that account? 09:24:26

13 A. No, I did not. 09:24:26

14 Q. Other than depositing funds into the 09:24:28

15 account, did you do anything else with respect to the 09:24:31

16 account, sir? 09:24:33

17 A. No, I did not. 09:24:33

18 Q. Did you ever make any withdrawals? 09:24:36

19 A. No, I did not. 09:24:38

20 Q. Are you still engaging in this activity? 09:24:41

21 A. No, I'm not. 09:24:43

22 Q. When did it cease? 09:24:45

23 A. I think my last deposit was sometime last 09:24:51

24 year. 09:24:54

25 Q. Are you able to approximate when last 09:24:55

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2 year? When you say last year, it's 2017? 09:24:57

3 A. That's correct. 09:25:00

4 Q. Are you able to approximate when in 2017? 09:25:01

5 A. My best guess would be my last deposit was 09:25:05

6 December of 2017. 09:25:07

7 Q. And I would like to focus in a little bit 09:25:11

8 of the particulars of the deposits. 09:25:13

9 I'm sorry, just let me 09:25:16

10 interrupt. You're talking still now about deposits 09:25:17

11 made into Andrew Anglin's personal account? This has 09:25:20

12 nothing to do with Moonbase. 09:25:24

13 MR. QURESHI: Well, I'm trying to 09:25:25

14 understand the relationship between Mr. Anglin and 09:25:26

15 Mr. Moonbase (sic). I believe he said Mr. Anglin set 09:25:29

16 up Moonbase. 09:25:32

17 Right. But I think to the 09:25:33

18 extent you're going further than the scope of the 09:25:33

19 court's order, I would just ask you to use caution 09:25:37

20 there. 09:25:40

21 MR. QURESHI: I appreciate that. Thank 09:25:41

22 you. 09:25:42

23 Q. I would like to understand a little bit 09:25:43

24 about the nature of the funds that you deposited on 09:25:44

25 behalf of Mr. Andrew Anglin. Was it cash or was it 09:25:48

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2 checks that were received at Suite 121? 09:25:52

3 A. There was both. 09:25:57

4 Q. Would you say it was evenly split or was 09:25:59

5 there more checks or more cash? 09:26:01

6 A. I didn't really pay attention to that. I 09:26:11

7 couldn't really say. 09:26:13

8 Q. Did you notice any frequency in the people 09:26:15

9 who were sending checks? Were there certain names 09:26:19

10 that seemed more regular than others? 09:26:21

11 A. I don't know that I really paid attention 09:26:28

12 to who was writing the checks. I'm sure that there 09:26:29

13 were people that sent them regularly and people that 09:26:34

14 did not, but I didn't really pay attention to that. 09:26:36

15 Q. So you're unable to identify any name that 09:26:39

16 might have appeared on any check that you deposited 09:26:41

17 over a five-year period? 09:26:44

18 A. I deposited checks into his account 09:27:05

19 written from me. 09:27:08

20 Q. Other than yourself, anybody else whose 09:27:11

21 name you might recall that appeared on a check? 09:27:14

22 A. I don't recall any other names. 09:27:17

23 Q. Do you know if the checks were coming from 09:27:22

24 United States or were they coming from overseas? 09:27:24

25 A. Both. 09:27:29

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2 Q. Did you ever deposit any foreign currency? 09:27:31

3 A. I deposited foreign currency in to my 09:27:40

4 personal account and then wrote a check for whatever 09:27:44

5 amount that was into my son's personal account. 09:27:48

6 Q. Okay. Do you recall what foreign currency 09:27:53

7 you deposited into your own account and subsequently 09:27:56

8 wrote a check to your son's account? 09:27:59

9 A. The primary foreign courtesy would have 09:28:02

10 been pounds, but there were multiple foreign 09:28:03

11 currencies. 09:28:07

12 Q. This is, again, over the five-year period, 09:28:08

13 2013 to roughly December of 2017? 09:28:10

14 A. That's correct. 09:28:13

15 Q. Were there occasions when you wrote checks 09:28:18

16 to Mr. Andrew Anglin's account other than those 09:28:20

17 instances in which foreign currency was received? 09:28:25

18 A. There were sometimes that I did it with 09:28:31

19 United States currency as well. 09:28:33

20 Q. You would deposit the money received at 09:28:36

21 Suite 121 into your personal account, and then write 09:28:38

22 a check to Mr. Andrew Anglin for deposit in his 09:28:41

23 account? 09:28:45

24 A. That's correct. 09:28:45

25 Q. Okay. Why did you do that? 09:28:45

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2 A. Because changed their bank policy to 09:28:48

3 where you could not deposit cash into their account 09:28:53

4 unless you were the account holder. 09:28:56

5 Q. When did that change occur? 09:28:58

6 A. Maybe at the beginning of 2017. I don't 09:29:10

7 recall exactly. 09:29:12

8 Q. And the deposits that you made in to your 09:29:14

9 own account, are those also at or is it some 09:29:16

10 other banking institution? 09:29:19

11 A. That was a different banking institution. 09:29:24

12 Q. What institution was it? 09:29:26

13 A. 09:29:27

14 Q. Let's turn back to Moonbase, sir. Does 09:29:42

15 Moonbase maintain any financial records of which you 09:29:45

16 are aware? 09:29:47

17 A. Not of which I'm aware. 09:29:49

18 Q. Does it have any assets? 09:29:51

19 A. Not that I am aware of. 09:29:54

20 Q. You mentioned at some point that the name 09:29:57

21 Andrew Anglin was registered as a trade name; do you 09:30:00

22 recall that? 09:30:03

23 A. Yes, I do. 09:30:03

24 Q. What entity registered it? 09:30:06

25 A. I think Moonbase did, but I'm not certain 09:30:10

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2 Q. Have you had any discussions with 09:31:21

3 Mr. Andrew Anglin about the Daily Stormer? 09:31:23

4 A. Yes. 09:31:28

5 Q. Okay. And what do you recall about those 09:31:29

6 discussions? 09:31:32

7 A. Can you clarify your question a little 09:31:38

8 bit? What kind of discussions are you asking about? 09:31:40

9 Q. I'm trying to understand if you've spoken 09:31:42

10 to your son about this website and his role in it, 09:31:44

11 his involvement in it. What has he told you about 09:31:47

12 it? That is what I'm trying to get at. 09:31:50

13 A. Well, he writes on the website about 09:31:56

14 issues and things that I guess are important to him. 09:32:00

15 Q. And who funds the website? Where does the 09:32:04

16 money for the website come? 09:32:09

17 A. I don't really know how he structures 09:32:12

18 that. 09:32:15

19 Q. Have you ever spoken to him about that? 09:32:15

20 A. I know that he gets bitcoin, but I don't 09:32:22

21 know anything about how that works. He has mentioned 09:32:26

22 bitcoin before, though. 09:32:30

23 Q. And when did he mention bitcoin? 09:32:31

24 A. I don't know. Whenever bitcoin became a 09:32:34

25 thing. 09:32:36

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2 Q. But was it this year, 2018? 09:32:37

3 A. No, maybe a year ago. A year, year and a 09:32:41

4 half ago. 09:32:45

5 Q. When is the last time you spoke with him? 09:32:46

6 A. Just a few days ago. 09:32:49

7 Q. And what do you recall about that 09:32:51

8 conversation? 09:32:54

9 A. Just catching up, dad stuff, told him I 09:32:56

10 was mad about having to come in today. 09:32:59

11 Q. Was it a phone call? Was it an in-person 09:33:01

12 meeting? 09:33:03

13 A. Phone call. 09:33:04

14 Q. And where was he calling from? 09:33:04

15 A. I don't know. 09:33:06

16 Q. Did you receive a call on your cell phone? 09:33:08

17 Did you receive a call on your home phone? Where 09:33:10

18 were you when you received the call? 09:33:13

19 A. It was my cell phone. 09:33:15

20 Q. Does your cell phone tell you the incoming 09:33:16

21 number? 09:33:19

22 A. Yes. 09:33:19

23 Q. And what was the incoming number? 09:33:19

24 A. I don't recall. 09:33:21

25 Q. Was it an international number? 09:33:22

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2 A. No -- I'm sorry, what is the question 09:42:59

3 again? 09:43:02

4 Q. Have you ever spoken to Miss Karen 09:43:02

5 Zappitelli about these Articles of Organization for a 09:43:05

6 Domestic Limited Liability Company that's reflected 09:43:07

7 in Exhibit 2? 09:43:10

8 A. I'm not sure what the Articles of 09:43:11

9 Organization are. Is that on this document? 09:43:13

10 Q. Yes, sir. If you turn to Page 2 of 09:43:17

11 Exhibit 2, you'll see that the title is Articles of 09:43:19

12 Organization for a Domestic Limited Liability 09:43:24

13 Company; do you see that, sir? 09:43:27

14 A. Yes. 09:43:29

15 Q. Have you ever spoken to Miss Zappitelli 09:43:29

16 about this document? 09:43:31

17 A. I don't recall. 09:43:32

18 Q. If you turn to Page 3, you'll notice the 09:43:32

19 signature at the bottom? 09:43:38

20 A. Yes. 09:43:38

21 Q. Do you remember recognize that signature? 09:43:39

22 A. No, I do not. 09:43:40

23 Q. Do you know if that is your son's 09:43:41

24 signature, sir? 09:43:42

25 A. I do not know. 09:43:43

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2 Q. Okay. Did you ever sign this document on 09:43:44

3 behalf of your son? 09:43:46

4 A. No, I did not. 09:43:49

5 Q. Did he ever ask you to do that? 09:43:51

6 A. No, he did not. 09:43:54

7 Q. Do you see the address under the General 09:43:56

8 Appointment of Agent section on Page 2? 09:44:02

9 A. Yes. 09:44:05

10 Q. And what is that address? 09:44:05

11 A. 6827 North High Street, Suite 121. 09:44:07

12 Q. That, in fact, is your business address? 09:44:11

13 A. That's correct. 09:44:13

14 Q. And it was your business address in 09:44:13

15 September of 2016? 09:44:15

16 A. That is correct. 09:44:17

17 Q. Did you give permission for Mr. Andrew 09:44:17

18 Anglin to use this business address as the 09:44:20

19 Appointment of Agent Address for Moonbase Holdings, 09:44:23

20 LLC? 09:44:25

21 A. I don't believe I did. I can't say with 09:44:38

22 absolute certainty, but I don't believe I did. 09:44:40

23 Q. Did he ever tell you he was going to do 09:44:43

24 this? 09:44:45

25 A. He did tell me he was going to do it. 09:44:45

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2 Q. Do you have any understanding of a filing 09:47:59

3 fee associated with the submission of Articles of 09:48:01

4 Organization for a Domestic Limited Liability 09:48:04

5 Company? 09:48:07

6 A. I'm sorry, could you say that again? 09:48:11

7 Q. Do you know whether you have to submit a 09:48:13

8 fee in order to register a company in Ohio? 09:48:14

9 A. Yes, you do. 09:48:16

10 Q. Do you know how Mr. Andrew Anglin 09:48:18

11 submitted the fee for Moonbase Holdings in September 09:48:20

12 of 2016? 09:48:22

13 A. It was probably paid by Karen Zappitelli. 09:48:31

14 I don't know for sure. 09:48:35

15 Q. That was going to be my follow-up 09:48:36

16 question. What makes you say that? 09:48:38

17 A. Because I paid to reimburse them for this. 09:48:41

18 And my recollection was that that was a part of the 09:48:48

19 reimbursement to them. 09:48:51

20 Q. Okay. What's your understanding of the 09:48:52

21 reimbursement that they sought from you? 09:48:54

22 A. What's my understanding of it? 09:48:59

23 Q. Yes, sir. 09:49:00

24 A. I don't know what that means. 09:49:01

25 Q. Did they call you one day and say, hey, 09:49:03

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2 write us a check for $99? How did the process play 09:49:05

3 out? 09:49:09

4 A. I think she sent a bill, and then I paid 09:49:21

5 it. 09:49:25

6 Q. Where did she send the bill to? 09:49:26

7 A. That would have been my office address. 09:49:29

8 Q. The 6827 North High Street, Suite 121? 09:49:32

9 A. That's correct. 09:49:37

10 Q. And do you have a copy of the invoice? 09:49:37

11 A. No, I do not. 09:49:41

12 Q. Who was the invoice directed to? 09:49:42

13 A. I don't recall. 09:49:45

14 Q. Was it directed to you? 09:49:46

15 A. I don't recall. 09:49:49

16 Q. Okay. Did you ask any questions before 09:49:50

17 paying the invoice? 09:49:53

18 A. I don't believe so. 09:50:00

19 Q. Can you help me understand the process 09:50:01

20 between receipt of invoice and payment of the 09:50:03

21 reimbursement to Miss Zappitelli? 09:50:07

22 A. Well, I knew that they were setting up an 09:50:10

23 LLC for my son, and they sent an invoice. I paid the 09:50:15

24 invoice, and then was reimbursed by my son. 09:50:21

25 Q. And why did you pay the invoice? 09:50:25

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2 A. Because my son was out of the country. 09:50:28

3 Q. Did he ask you to pay it? 09:50:30

4 A. Yes, he did. 09:50:32

5 Q. And was it in a phone call or an email? 09:50:33

6 How did he communicate that information to you? 09:50:36

7 A. I don't recall. 09:50:42

8 Q. And what understanding did you have about 09:50:45

9 getting reimbursement from your son after you paid 09:50:48

10 this amount? 09:50:51

11 A. Well, I mean, I don't pay any expenses for 09:50:54

12 his adventures here. So he reimburses me for that. 09:50:57

13 Q. What is that understanding based on? Have 09:51:03

14 you talked to him about it or is that just an 09:51:05

15 implicit understanding? 09:51:08

16 A. It's an implicit understanding. 09:51:09

17 Q. How long after you paid the invoice to the 09:51:11

18 Zappitellis for the creation of Moonbase did you 09:51:14

19 receive reimbursement from your son? 09:51:17

20 A. I don't recall. 09:51:20

21 Q. Did he send you a check? 09:51:21

22 A. No. 09:51:23

23 Q. How did you get reimbursed? 09:51:24

24 A. I used cash from money that had been sent 09:51:25

25 to him. 09:51:29

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2 Q. Okay. Do you keep any accounting or 09:51:30

3 ledger of the amounts that are sent to him? 09:51:35

4 A. No, I don't. 09:51:39

5 Q. So you just deducted $99 from a 09:51:41

6 contribution, and the remainder you deposited in the 09:51:44

7 account; is that how it worked? 09:51:48

8 A. Yes. 09:51:58

9 Q. Did this occur in September of 2016? 09:52:00

10 A. It looks like it did from the date. I 09:52:03

11 don't have any recollection of that. 09:52:05

12 Q. The amount that you paid for the creation 09:52:07

13 of Moonbase Holdings, the $99, did you write a check 09:52:10

14 to the Zappitellis? 09:52:14

15 A. My recollection -- and I'm not sure this 09:52:24

16 is exactly right -- but my recollection was that 09:52:26

17 their fee was about $500 total. So I would have 09:52:30

18 written a check to Zappitellis and then being 09:52:35

19 reimbursed by my son. 09:52:37

20 Q. The total amount was $500? 09:52:40

21 A. That is my recollection. 09:52:42

22 Q. The check that you wrote to the 09:52:43

23 Zappitellis, was that from your account at 09:52:44

24 ? 09:52:48

25 A. Probably, yes. 09:52:52

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2 Q. Do you have access to that account? 09:52:54

3 A. No, I do not. 09:52:55

4 Q. Why not? 09:52:57

5 A. It's been closed down. 09:52:58

6 Q. When was it closed down? 09:53:00

7 A. Sometime late last year. 09:53:06

8 Q. And why was it closed late last year? 09:53:07

9 A. I don't know. The bank just closed it. 09:53:11

10 Q. And where do you bank currently? 09:53:15

11 A. 09:53:17

12 Q. -- 09:53:22

13 A. Frank Cathy -- or Frank Cat. Don't want 09:53:24

14 to mess you up there. 09:53:32

15 Q. You don't have a copy of a canceled check 09:53:36

16 from ? 09:53:38

17 A. Do I have a copy of a canceled check, no, 09:53:44

18 I do not. 09:53:46

19 Q. Did you get bank statements from 09:53:47

20 ? 09:53:49

21 A. I think the only statements I got were 09:53:54

22 online. That's the best of my recollection. 09:53:56

23 Q. Other than the $500 you paid to the 09:54:06

24 Zappitellis for the creation of Moonbase, have you 09:54:09

25 paid for any other expenses associated with Moonbase 09:54:11

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2 Holdings, LLC? 09:54:14

3 Objection, just in terms of it 09:54:16

4 was clearly a reimbursement situation. He didn't 09:54:19

5 actually pay for his son. 09:54:22

6 MR. QURESHI: Okay. 09:54:25

7 Just want to make it clear. 09:54:26

8 MR. QURESHI: Yeah, I think the record is 09:54:27

9 clear on that, that he subsequently was reimbursed 09:54:28

10 from his son's contributions. 09:54:31

11 A. So the question is: Were there any other 09:54:33

12 Moonbase expenses that I paid and then was reimbursed 09:54:35

13 for? 09:54:39

14 Q. Yes, sir. 09:54:40

15 A. Is that the question? 09:54:40

16 Q. Yes, sir. 09:54:41

17 A. I believe there was an expense associated 09:54:46

18 with registering the trade name Andrew Anglin. 09:54:48

19 Q. Do you recall the amount of that expense? 09:54:53

20 A. No, I do not. 09:54:55

21 Q. Can you describe the mechanics of how that 09:54:57

22 worked? 09:55:00

23 A. There was some fee involved, and I paid 09:55:03

24 it. I don't recall whether I paid -- used his cash 09:55:10

25 to pay the fee, or whether I wrote a check and then 09:55:13

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2 was reimbursed by Andrew. I don't recall which it 09:55:17

3 was. 09:55:19

4 Q. And if you had written a check, this was 09:55:20

5 during a time when was your bank? 09:55:23

6 A. That is correct. 09:55:26

7 Q. And I'm sorry if I am repeating a 09:55:28

8 question. Do you recall the amount that you paid? 09:55:30

9 A. No, I do not. 09:55:36

10 Q. Have you spoken to either Karen or John 09:55:41

11 Zappitelli recently? 09:55:44

12 A. Not recently. Sometime maybe five or six 09:55:50

13 months ago. 09:55:55

14 Q. What did you talk to them about five to 09:55:56

15 six months ago? 09:55:58

16 A. A friend of mine had some old coins he 09:55:59

17 wanted to sell, and I asked John if he had any ideas 09:56:02

18 about how to do that. 09:56:04

19 Q. Do you recall speaking with them about the 09:56:07

20 creation of Moonbase Holdings, LLC at any point in 09:56:09

21 time? 09:56:12

22 A. Not after the initial conversation that I 09:56:13

23 had with Karen. 09:56:16

24 Q. Do you know whether your son, in fact, did 09:56:17

25 speak to either Karen or John Zappitelli about the 09:56:20

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2 A. Okay. 09:58:23

3 Q. Sir, have you seen Exhibit 3 before? 09:58:24

4 A. I don't recall ever having seen this, no. 09:58:26

5 Q. Okay. I'll represent to you it's a letter 09:58:28

6 from the Internal Revenue Service to Moonbase 09:58:31

7 Holdings, LLC, and it's directed to an address that 09:58:33

8 we've talked about earlier today, 6827 North High 09:58:37

9 Street, Suite 121, correct? 09:58:40

10 A. Right. 09:58:43

11 Q. Do you recall ever receiving this document 09:58:44

12 at that address? 09:58:46

13 A. No, I do not recall. 09:58:49

14 Q. Have you had any discussions with 09:58:52

15 Mr. Andrew Anglin about the procurement of an 09:58:53

16 employer identification number for Moonbase Holdings, 09:58:56

17 LLC? 09:58:57

18 A. No, I have not. 09:58:59

19 Q. Do you know whether Moonbase Holdings 09:59:01

20 files tax returns? 09:59:03

21 A. I don't know. 09:59:05

22 Q. Did you provide him any advice or guidance 09:59:06

23 on obtaining an employer I.D. number? 09:59:08

24 A. No, I did not. 09:59:12

25 Q. You mentioned earlier in the day about 09:59:27

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2 receiving legal documents at the 6827 North High 09:59:29

3 Street address, Suite 121; do you recall that? 09:59:32

4 A. Yes, I do. 09:59:36

5 Q. And these are legal documents directed to 09:59:37

6 Mr. Andrew Anglin, is that correct? 09:59:39

7 A. When you say legal documents, I'm talking 09:59:41

8 about documents that come from attorneys, that have 09:59:43

9 an attorney return address. 09:59:46

10 Q. Okay. What is your practice with those 09:59:48

11 documents, what do you do with them? 09:59:49

12 A. I put them in a big plastic tub. 09:59:51

13 Q. And what happens to them afterwards? 09:59:54

14 A. They sit in the tub. 09:59:56

15 Q. You don't forward them on to anybody? 09:59:58

16 A. No, I do not. 10:00:00

17 Q. And what about letters from the Internal 10:00:01

18 Revenue Service that were directed to that address, 10:00:03

19 what did you do with those? 10:00:06

20 A. Any mailings that are directed to Moonbase 10:00:07

21 or Daily Stormer I don't open. 10:00:13

22 Q. What do you do with it? 10:00:16

23 A. Throw them away. 10:00:18

24 Q. Did you put it in the tub or you throw it 10:00:18

25 away? 10:00:21

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2 A. I put the attorney stuff in the tub. 10:00:21

3 Anything else I throw away. 10:00:23

4 Q. What is your practice to treat 10:00:25

5 correspondence from the Internal Revenue Service 10:00:27

6 directed to Moonbase? 10:00:29

7 A. That would be throw away. 10:00:30

8 Q. Do you ever have conversations with your 10:00:35

9 son about the fact that he has received 10:00:37

10 correspondence from the Internal Revenue Service that 10:00:40

11 you subsequently have thrown away; have you ever told 10:00:42

12 him that? 10:00:45

13 A. What I have told him is that I will not 10:00:46

14 open any correspondence addressed to Daily Stormer or 10:00:48

15 to Moonbase Holdings. 10:00:52

16 Q. And do you go on to tell him that you will 10:00:53

17 throw it away if it's from the Internal Revenue 10:00:55

18 Service? 10:00:58

19 A. I didn't specify the Internal Revenue 10:00:59

20 Service. What I said was: I will not open any mail 10:01:01

21 sent to Daily Stormer or Moonbase. 10:01:06

22 Q. And what did he say to you in response? 10:01:09

23 A. He said I can get anything I want online, 10:01:11

24 don't worry about it. 10:01:16

25 Q. Okay. And when contributions were 10:01:17

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2 directed to the 6827 North High Street, Suite 121 10:01:19

3 address, were they directed to Mr. Andrew Anglin or 10:01:24

4 were they directed to the Daily Stormer or to 10:01:27

5 Moonbase? 10:01:31

6 A. They were directed to Andrew Anglin. 10:01:31

7 There was -- almost all were directed to 10:01:34

8 Andrew Anglin. 10:01:38

9 Q. The instances when they were not directed 10:01:40

10 to Andrew Anglin, who were they directed to? 10:01:42

11 A. I only recall one directed to the Daily 10:01:46

12 Stormer of the whole five years. 10:01:48

13 Q. And what did you do with that particular 10:01:50

14 correspondence? 10:01:53

15 A. Threw it away unopened. 10:01:54

16 Q. Okay. And how did you know it was a 10:01:55

17 financial contribution? 10:01:57

18 A. I don't know that it was for sure. It 10:01:58

19 wasn't from an attorney. It could have been a note 10:02:00

20 of encouragement. I don't know. No, I take that 10:02:03

21 back. There was another one that I remember that was 10:02:11

22 a ten dollar check that was made out to Daily 10:02:14

23 Stormer, and I remember throwing that away. 10:02:17

24 Q. And who was the envelope addressed to? 10:02:20

25 A. The envelope was addressed to Daily 10:02:26

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2 Stormer. I opened it in error. I saw a ten dollar 10:02:29

3 check, and I threw it away. 10:02:34

4 Q. Are you aware of any bank accounts held by 10:02:36

5 Daily Stormer? 10:02:39

6 A. No, I'm not. 10:02:40

7 Q. Are you aware of any bank accounts held by 10:02:42

8 Moonbase Holdings, LLC? 10:02:45

9 A. No, I'm not. 10:02:47

10 Q. When your son told you he was going to 10:02:48

11 create an entity called Moonbase, did you ask him 10:02:50

12 why? 10:02:54

13 Objection. We've talked about 10:02:54

14 this, I think, at some length. 10:02:55

15 MR. QURESHI: Yeah. I think it ties to 10:02:57

16 the specific line of questioning. I'm not going to 10:02:59

17 dwell on it. 10:03:02

18 A. No, I did not. 10:03:03

19 Q. What familiarity do you have with the 10:03:14

20 concept of trade names? What's a trade name? 10:03:16

21 A. I think it's a name you register so that 10:03:22

22 other people can't use it. I think that is what it 10:03:24

23 is. 10:03:26

24 Q. And how did you come about this 10:03:27

25 understanding? 10:03:28

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2 (Plaintiff's Exhibit 4 was marked for 10:09:33

3 identification.) 10:09:33

4 Q. Mr. Anglin, I'm handing you a document 10:09:35

5 that's marked Exhibit 4. 10:09:37

6 A. Okay. 10:09:40

7 Q. Please take a moment to review it. 10:09:41

8 A. Okay. 10:10:00

9 Q. Have you seen this document before, 10:10:00

10 Mr. Anglin? 10:10:02

11 A. Yes, I have. 10:10:02

12 Q. What is it? 10:10:03

13 A. It is the trade name registration for the 10:10:04

14 name Andrew Anglin. 10:10:09

15 Q. And what role, if any, did you play in 10:10:11

16 this trade name registration for the name Andrew 10:10:13

17 Anglin? 10:10:15

18 A. I applied for the name. 10:10:16

19 Q. On whose behalf? 10:10:19

20 A. Andrew asked me to do it for him. 10:10:22

21 Q. If you turn to the second page of the 10:10:24

22 document, sir. 10:10:26

23 A. Yes. 10:10:27

24 Q. You'll see under name of the registrant 10:10:28

25 Moonbase Holdings, LLC? 10:10:31

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2 A. Um-hum. 10:10:34

3 Q. Did I read that correctly? 10:10:34

4 A. Yes. 10:10:36

5 Q. Is it your understanding you were applying 10:10:36

6 for the trade name on behalf of Moonbase Holdings? 10:10:38

7 A. That's correct. 10:10:41

8 Q. And you knew that? 10:10:41

9 A. Yes. 10:10:42

10 Q. What other conversations do you recall 10:10:54

11 with Mr. Andrew Anglin about the registration of his 10:10:55

12 name as a trade name? 10:10:59

13 A. I don't recall anything else. 10:11:17

14 Q. Okay. Can you describe to me in as much 10:11:20

15 detail as you recall the request he made of you? 10:11:23

16 A. Well, again, I'm a little bit fuzzy on 10:11:28

17 this one. I think -- I just don't want to guess. I 10:11:32

18 don't know. 10:11:38

19 Q. Do you recall a telephone call in which 10:11:39

20 you had a conversation with him? 10:11:42

21 A. I don't recall the phone conversation. I 10:11:52

22 know that he asked me to register his name as a trade 10:11:53

23 name, but I don't recall the conversation. 10:11:57

24 Q. Okay. My question was a little more 10:11:58

25 basic. It is: Was it a phone conversation? Was it 10:12:01

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2 a email? Was it a in-person meeting? Do you know 10:12:05

3 how the discussion arose? 10:12:08

4 A. Well, I know it wasn't in person, because 10:12:10

5 he was out of the country. I don't remember whether 10:12:12

6 it was email or phone. 10:12:16

7 Q. Okay. And in the survey of email that you 10:12:19

8 undertook to look for responsive documents did you 10:12:22

9 identify any email related to this topic? 10:12:26

10 A. No, I did not. 10:12:29

11 Q. Is it your practice to delete emails? 10:12:32

12 A. Yes, it is. 10:12:34

13 Q. Both in your inbox and your sent box? 10:12:35

14 A. That's correct. 10:12:38

15 Q. Did you work with the Zappitellis in 10:12:43

16 connection with this trade name registration in 10:12:45

17 Exhibit 4? 10:12:50

18 A. I don't think so. 10:12:57

19 Q. Had you ever done a trade name 10:12:58

20 registration before? 10:13:00

21 A. I may have for Morningstar Counseling, I 10:13:20

22 don't recall. 10:13:23

23 Q. And when you may have performed a trade 10:13:23

24 name registration for Morningstar, did you do it on 10:13:26

25 your own or did you work with an accountant or the 10:13:29

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2 Zappitellis or consultant? 10:13:33

3 A. I don't have any recollection of that. 10:13:37

4 Once again, we're going back 15 years, 20 years, 10:13:38

5 something like that. 10:13:41

6 Q. Exhibit 4, though, is dated January of 10:13:42

7 2017, is it not? 10:13:44

8 A. I understand that. I was talking about 10:13:45

9 Morningstar. 10:13:47

10 Q. And in connection with Exhibit 4, did you 10:13:48

11 undertake any research to figure out how to do a 10:13:51

12 trade name registration? 10:13:54

13 A. I don't remember -- I don't know how I 10:14:10

14 knew to go to the secretary of state. I don't recall 10:14:13

15 that. 10:14:15

16 Q. Okay. How much time did it take to 10:14:15

17 undertake the trade name registration, sir? 10:14:18

18 A. Again, I just don't recall enough of the 10:14:21

19 details of this. It doesn't look like it would take 10:14:23

20 a lot of time, but I don't recall. 10:14:26

21 Q. Who paid for the registration fee? 10:14:29

22 A. Andrew paid for it. 10:14:32

23 Q. And how did that work? 10:14:34

24 A. He would have -- if I paid cash, then it 10:14:36

25 would have been Andrew's cash. If I wrote a check, 10:14:39

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2 then Andrew would have reimbursed me. 10:14:42

3 Q. What makes you say that he would have 10:14:45

4 reimbursed you? 10:14:47

5 A. Because he always did. 10:14:48

6 Q. If you look at the second page of 10:14:49

7 Exhibit 4. You'll notice in the right-hand corner it 10:14:51

8 says Date Electronically Filed, January 5, 2017, is 10:14:53

9 that correct? 10:14:59

10 A. Yes. 10:15:00

11 Q. Does that refresh your recollection that 10:15:01

12 this document was electronically filed? 10:15:02

13 A. I just don't remember it. I don't 10:15:08

14 remember how it happened. 10:15:15

15 Q. And if it was electronically filed, sir, 10:15:17

16 do you have a recollection as to whether you 10:15:19

17 submitted credit card information, you provided 10:15:22

18 checking account information in order to pay the $39 10:15:26

19 filing fee? 10:15:29

20 A. I just don't remember. I don't remember 10:15:30

21 much about this at all. I don't remember how it was 10:15:32

22 paid. I just don't remember the document very well. 10:15:36

23 Q. Okay. If you look at the first box in the 10:15:42

24 left-hand corner on Page 2 of Exhibit 4; do you see 10:15:49

25 that box, sir? 10:15:59

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2 that's when he began everything. But, yeah I don't 10:43:58

3 remember. I just don't remember. 10:44:01

4 Q. Subsequent to the trade name registration, 10:44:03

5 after it was completed did you ever talk to him about 10:44:05

6 the trade name registration? 10:44:09

7 A. No, I didn't. 10:44:13

8 Q. Have you ever spoken to anyone else other 10:44:15

9 than your lawyer about the trade name registration of 10:44:16

10 Andrew Anglin on behalf of Moonbase Holdings, LLC? 10:44:20

11 A. No, I have not. 10:44:26

12 (Plaintiff's Exhibit 5 was marked for 10:44:30

13 identification.) 10:44:30

14 Q. Mr. Anglin, I'm handing you a document 10:44:31

15 that has been marked as Exhibit 5. Please take a 10:44:33

16 moment to review that, sir. 10:44:36

17 A. Okay. 10:44:46

18 Q. Have you seen this document before? 10:44:48

19 A. No, I have not. 10:44:49

20 Q. I'll represent to you, it is a printout 10:44:52

21 from the Whois Tool for a website entitled 10:44:54

22 DailyStormer.com. And if you look at the creation 10:44:57

23 date for the website, it's listed as March 20th, 10:45:02

24 2013; do you see that? 10:45:07

25 A. Yes, I do. 10:45:08

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2 Q. And if you continue to read down that 10:45:10

3 column, you'll see there's an entry for registrant 10:45:13

4 name? 10:45:16

5 A. Yes. 10:45:16

6 Q. And is that your name listed, sir? 10:45:17

7 A. That is my name listed, yes. 10:45:19

8 Q. Did you have any involvement in the 10:45:22

9 registration of the website Daily Stormer.com on or 10:45:23

10 about March 20, 2013? 10:45:27

11 A. Yes, I did. 10:45:31

12 Q. What was that involvement? 10:45:32

13 A. This one I actually remember. I was 10:45:34

14 sitting in my living room of my condo with my son, 10:45:36

15 and he told me that he was going to start another 10:45:40

16 website. And I said, okay. And he asked if he could 10:45:45

17 use my credit card to register the name. And I asked 10:45:51

18 how much it was, and it wasn't very much money, so I 10:45:58

19 said fine. 10:46:02

20 Q. Was it your understanding at the time that 10:46:02

21 he didn't have his own credit card? 10:46:04

22 A. That's correct. 10:46:06

23 Q. And what bank issued the credit card that 10:46:06

24 was used to register this website? 10:46:09

25 A. Probably although, it 10:46:11

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2 could have been American Express. I don't know. 10:46:16

3 Q. What else do you recall about that 10:46:20

4 conversation? 10:46:22

5 A. Just that I had no idea I was going to be 10:46:26

6 the registrant of a website that he was going to run. 10:46:28

7 Q. Do you recall whether he entered the 10:46:33

8 information related to the creation of the website or 10:46:38

9 is that something you did? 10:46:41

10 A. He would have entered everything, and then 10:46:42

11 asked me for my credit card. 10:46:44

12 Q. Do you have any understanding as to why he 10:46:46

13 listed you as the registrant? 10:46:48

14 A. I have no idea. 10:46:49

15 Q. Did you ever ask him about that? 10:46:51

16 A. Yeah. 10:46:52

17 Q. And what was that conversation like? 10:46:53

18 A. Well, the conversation was -- let me think 10:46:54

19 for just a minute. When I realized I was the 10:47:00

20 registrant, we had a very direct conversation where I 10:47:07

21 told him I was very disappointed in him that he 10:47:13

22 allowed that to happen, and that I wanted it removed 10:47:16

23 immediately. 10:47:19

24 Q. And, sir, when did that occur? 10:47:20

25 A. I didn't even find out about it until 10:47:22

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2 sure that the record is clear here. The domain name 11:00:51

3 was registered in March of 2013, correct? 11:00:54

4 A. Yes, that's correct. 11:00:57

5 Q. On the internet? 11:00:58

6 A. That's correct. 11:01:00

7 Q. And it listed you -- the registration 11:01:01

8 listed you as the registrant, the administrator, and 11:01:04

9 the technical contact, correct? 11:01:09

10 A. That's correct. 11:01:10

11 Q. And that's all reflected on Exhibit 5? 11:01:11

12 A. That's correct. 11:01:14

13 Q. And at some point after the registration 11:01:15

14 of the domain name reflected on Exhibit 5, you 11:01:18

15 expressed disappointment to your son about that fact, 11:01:22

16 correct? 11:01:25

17 A. That's correct. 11:01:26

18 Q. And my question was: Exhibit 6 is a trade 11:01:27

19 name registration for Daily Stormer. Did you submit 11:01:30

20 the trade name registration, Exhibit 6, before or 11:01:35

21 after you had expressed disappointment to your son 11:01:38

22 about the internet domain registration? 11:01:42

23 A. I don't recall. 11:01:45

24 Q. When you submitted the trade name 11:01:53

25 registration for Daily Stormer what did you 11:01:54

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2 understand you were doing? 11:01:57

3 A. Honestly, I didn't understand anything. 11:02:06

4 What he said was: Can you register this name? He 11:02:08

5 may have said so someone else doesn't use it, I don't 11:02:13

6 remember. 11:02:16

7 Q. Okay. 11:02:17

8 A. I just remember him asking me to do that. 11:02:18

9 Q. At this point in time in December of 2016, 11:02:21

10 had you ever visited the website DailylyStormer.com? 11:02:24

11 A. Yes, I had. 11:02:29

12 Q. Okay. Did you know the content on the 11:02:30

13 website? 11:02:31

14 A. Yes, sir, I did. 11:02:32

15 Q. Had you formed an opinion about whether 11:02:33

16 you agree or disagree with the content? 11:02:35

17 A. Yes, I had. 11:02:37

18 Q. And with that opinion in mind, you agreed 11:02:38

19 to do what your son asked? 11:02:40

20 A. I have a difficult time as a dad sometimes 11:02:51

21 knowing what to support and what not to support. I 11:02:54

22 don't take responsibility for somebody else's 11:02:58

23 actions. He asked me to record this form, and I did. 11:03:01

24 Q. Okay. The filing fee associated with the 11:03:08

25 trade name registration in Exhibit 6, who paid that? 11:03:15

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2 A. Andrew Anglin paid it. 11:03:21

3 Q. How did Andrew Anglin pay it? 11:03:23

4 A. I don't recall. 11:03:26

5 Q. Do you recall going to the clerk's office, 11:03:26

6 sir? 11:03:29

7 A. I think I can remember going to a clerk's 11:03:29

8 office on Broad Street or something downtown, and I 11:03:31

9 think it was related to this, but I'm just not 11:03:35

10 positive. And I don't recall whether I paid cash or 11:03:38

11 credit card, I just don't remember. 11:03:40

12 Q. And the visit that you do recall where you 11:03:42

13 went to the clerk's office, the cash or credit card 11:03:44

14 you used, was it yours? 11:03:48

15 A. It would not have been my son's. I never 11:03:51

16 used one of his. Is that your question? 11:03:53

17 Q. Yes, sir. 11:03:56

18 A. No. It would have been mine, yes. 11:03:56

19 Q. To go back to my earlier question: In 11:03:59

20 connection with the trade name registration of Daily 11:04:02

21 Stormer, who paid the filing fee? 11:04:04

22 A. This is the trade name document here, 11:04:09

23 right? 11:04:12

24 Q. Correct. Exhibit 6 is the trade name 11:04:12

25 registration. 11:04:14

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2 A. No, I do not. 11:18:14

3 Q. Have you ever asked him that question? 11:18:17

4 A. I've never talked to him about Moonbase. 11:18:18

5 Q. In registering the trade name Daily 11:18:21

6 Stormer on behalf of Moonbase, you didn't have a 11:18:29

7 conversation with him? 11:18:34

8 A. Well, I suppose he would have said 11:18:42

9 register it under Moonbase, but that's -- I don't 11:18:45

10 know about the conversation, but I followed whatever 11:18:51

11 his directions were. 11:18:53

12 Q. And registering the name of Andrew Anglin 11:18:55

13 on behalf of Moonbase, that was also a conversation 11:18:59

14 about Moonbase, correct? 11:19:02

15 A. It was a request to register something on 11:19:09

16 behalf of Moonbase. 11:19:11

17 Q. So you would agree that that was a 11:19:13

18 conversation about Moonbase, sir? 11:19:15

19 A. Well, I wouldn't say that we had a 11:19:16

20 conversation about Moonbase, no. I would say exactly 11:19:18

21 that, that he said, can you register this trade name 11:19:23

22 under Moonbase. So if you want to define it as a 11:19:27

23 conversation or not, I wouldn't, but you certainly 11:19:31

24 may, if you like. 11:19:33

25 Q. Okay. Other than those instances, do you 11:19:34

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2 recall any other instance in which Mr. Andrew Anglin 11:19:38

3 asked you to do something on behalf of Moonbase? 11:19:42

4 A. No, I don't recall anything else. 11:19:45

5 Q. Have you ever understood Mr. Andrew Anglin 11:20:05

6 to describe the financial condition of Moonbase? 11:20:10

7 A. No. 11:20:16

8 Q. Has he ever told you that it's on the cusp 11:20:17

9 of insolvency? 11:20:19

10 A. No. 11:20:21

11 Q. Has he ever said anything else about its 11:20:23

12 financial condition? 11:20:26

13 A. No, he has not. 11:20:26

14 (Plaintiff's Exhibit 8 was marked for 11:20:38

15 identification.) 11:20:38

16 Q. Mr. Anglin, I'm handing you a document 11:20:42

17 that's marked as Exhibit 8. Please take a moment to 11:20:45

18 review it. 11:20:50

19 A. Okay. 11:20:55

20 Q. Have you seen this document before, sir? 11:20:56

21 A. Yes, I filled it out. 11:20:58

22 Q. Okay. And what is it? 11:20:59

23 A. It's an application for a post office box. 11:21:01

24 Q. And why did you fill out an application 11:21:04

25 for a post office box? 11:21:07

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2 A. On the heels of my conversation that 11:21:11

3 Andrew needed to remove -- not use my office address 11:21:13

4 any more, he advised me that he could not set up a 11:21:18

5 post office box unless he was in the country, and he 11:21:22

6 was out of the country and asked if I would help him 11:21:25

7 accomplish that. 11:21:29

8 Q. Did you have an understanding as to where 11:21:30

9 he was? 11:21:32

10 A. No, I did not. 11:21:32

11 Q. You never asked him? 11:21:33

12 A. No. 11:21:34

13 Q. And the conversation you had with him, was 11:21:42

14 that over the phone? 11:21:45

15 A. I believe so, yes. 11:21:48

16 Q. And he told you, I'm out of the country, 11:21:49

17 correct? 11:21:52

18 A. That is correct. Well, he didn't tell me 11:21:52

19 I'm out of the country. I knew he was out of the 11:21:54

20 country. 11:21:57

21 Q. And how did you know that he was out of 11:21:57

22 the country? 11:22:00

23 A. Because he hadn't been back in the country 11:22:00

24 for five years probably. 11:22:02

25 Q. And how did you know that? 11:22:03

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2 A. Because he would have come and seen me if 11:22:04

3 he was in the country. 11:22:06

4 Q. Okay. And did you know where he was? 11:22:07

5 A. No. I know that at some point he spent 11:22:09

6 time in Thailand over that five-year period, but, no, 11:22:14

7 I did not know where he was. 11:22:20

8 Q. And you didn't believe it was important to 11:22:21

9 ask him? 11:22:23

10 A. No, I did not. 11:22:24

11 Q. Why not? 11:22:29

12 Objection. Go ahead. 11:22:33

13 A. He's a private person, and I'm a talkative 11:22:38

14 guy. And so he prefers and I prefer to not know 11:22:46

15 where he is. 11:22:51

16 Q. Sir, if you look at the document marked as 11:22:54

17 Exhibit 8, I believe you testified earlier that you 11:22:58

18 filled out this form? 11:23:01

19 A. Do you mind if I come back to a question 11:23:02

20 real quick? I want to make sure I said the right 11:23:04

21 thing. 11:23:06

22 Q. Okay. 11:23:06

23 A. He could have actually been in Russia. I 11:23:07

24 said Thailand, but I don't know. 11:23:10

25 Q. What makes you think that he may have been 11:23:12

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2 in Russia? 11:23:14

3 A. I know he had told me he had been in 11:23:16

4 Russia at one time, and I know that he had been in 11:23:18

5 Thailand at one time. 11:23:20

6 Q. And on the one time that he told you he 11:23:22

7 was in Russia, why did he tell you his location then, 11:23:24

8 but not on other occasions? 11:23:27

9 A. That was several years ago, and I think it 11:23:34

10 was -- I don't know why. 11:23:36

11 Q. I believe you testified that he was a 11:23:42

12 private person? 11:23:43

13 A. He is. 11:23:44

14 Q. And you were a talkative person? 11:23:45

15 A. That is what I said. 11:23:47

16 Q. Notwithstanding that, he shared with you 11:23:48

17 his location? 11:23:50

18 A. A number of years ago he did, yes. 11:23:52

19 Q. But more recently he has not? 11:23:54

20 A. That's correct. 11:23:56

21 Q. And you haven't asked him? 11:23:56

22 A. That's correct. 11:23:58

23 Q. If we turn to Exhibit 8, sir, the document 11:24:00

24 that I believe you testified you completed. 11:24:03

25 A. Yes. 11:24:06

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2 Q. Do you recall when you filled this out? 11:24:08

3 A. No, I do not. This looks like it's dated 11:24:09

4 there, though. 11:24:12

5 Q. And what is the date that you understand? 11:24:13

6 A. Well, let me find it here. 11:24:15

7 Q. There is a date stamp in the right-hand 11:24:18

8 corner. 11:24:20

9 A. Yes, that says December 15, 2017. 11:24:21

10 Q. Sir, in the right-hand corner the date 11:24:32

11 that I make out is January 12, 2017. 11:24:34

12 A. Oh, I'm sorry. 11:24:37

13 Q. Where it's a post office stamp. 11:24:40

14 It's hard to read. 11:24:43

15 A. I can read January 12. I can't quite read 11:24:46

16 the year. But if you guys say 2017, I'll go with 11:24:48

17 that. 11:24:51

18 Q. The December date you're referencing, 11:24:51

19 where do you see that? 11:24:53

20 A. That was at the top of my form there. 11:24:55

21 Q. Oh, okay. That's the date on which it was 11:24:57

22 faxed? 11:25:00

23 A. Okay. Sorry. 11:25:01

24 Q. The date in the right-hand corner I see is 11:25:02

25 January 12, 2017. 11:25:04

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2 A. Okay. 11:25:05

3 Q. Is that consistent with your recollection? 11:25:06

4 A. I don't recall when. It certainly -- I 11:25:08

5 have no reason to believe that is wrong. 11:25:11

6 Q. Okay. And I believe you testified that 11:25:13

7 Mr. Andrew Anglin was out of the country and therefor 11:25:15

8 he requested that you set up a post office box for 11:25:19

9 him? 11:25:21

10 A. That's correct. 11:25:22

11 Q. And did you provide identification to the 11:25:23

12 post office in connection with this process? 11:25:26

13 A. Yes, I did. 11:25:30

14 Q. Did you also pay a sum? 11:25:31

15 A. I did, yes. 11:25:32

16 Q. How much did you pay? 11:25:33

17 A. I don't recall. Maybe $125, something 11:25:35

18 around that range. 11:25:38

19 Q. And where did that money come from? 11:25:39

20 A. Andrew paid that. 11:25:40

21 Q. And can you describe for us the process by 11:25:42

22 which that occurred? 11:25:44

23 A. Again, I don't recall whether it was paid 11:25:45

24 directly with his cash or whether I paid it and then 11:25:47

25 he reimbursed me. 11:25:50

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2 Q. And if it was the first option, paid 11:25:51

3 directly with his cash, how would you have access to 11:25:53

4 his cash? 11:25:56

5 A. It would be cash that was mailed to Andrew 11:25:57

6 Anglin that I would still have possession of. 11:26:00

7 Q. And if it was the second option, whether 11:26:06

8 you paid it and then he later reimbursed you, how 11:26:08

9 would you have paid for it? 11:26:11

10 A. I could have written a check. I could 11:26:14

11 have used a credit card. 11:26:16

12 Q. And at this point in time, did you have a 11:26:19

13 checking account at January of 2017? 11:26:21

14 A. No, I did not. 11:26:29

15 Q. Okay. Did you bank at at that 11:26:30

16 point in time? 11:26:34

17 A. Yes, I did. 11:26:35

18 Q. Your checking account was with ? 11:26:35

19 A. My checking account was. I probably used 11:26:38

20 a credit card. I don't use checks very often. 11:26:40

21 Q. What credit card might you have used? 11:26:43

22 A. or possibly American Express. 11:26:46

23 Q. Okay. You testified earlier that 11:26:51

24 closed at some point in time? 11:26:55

25 A. My checking account, not my credit card. 11:26:58

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2 Q. The bank, itself, stayed open? 11:27:01

3 A. I'm sorry? 11:27:03

4 Q. The institution, itself, 11:27:05

5 is in existence? 11:27:08

6 A. Oh, institution, they closed my 11:27:10

7 accounts. 11:27:12

8 Q. Why did they close your accounts? 11:27:13

9 A. They never said. 11:27:15

10 Q. Did they ever send you any correspondence? 11:27:16

11 A. They just sent me a correspondence that 11:27:19

12 said we're closing your accounts, no explanation. 11:27:21

13 Q. And did they -- did you have money in the 11:27:25

14 accounts at the time they closed? 11:27:28

15 A. Yes, they mailed me checks. 11:27:30

16 Q. Did you ever ask them for an explanation? 11:27:33

17 A. Yes, I did. 11:27:36

18 Q. Okay. And I fail to understand. What did 11:27:38

19 I ask that was funny? 11:27:42

20 A. Yeah, I asked them for an explanation. I 11:27:43

21 thought it was kind of strange, and they didn't offer 11:27:46

22 one. 11:27:50

23 Q. Did you ask them in person or in writing? 11:27:51

24 A. Over the phone. 11:27:54

25 Q. Okay. Do you have any understanding that 11:27:56

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2 the closing of the accounts was related in any way to 11:27:58

3 your association with Moonbase? 11:28:01

4 A. I don't have any reason to believe that, 11:28:04

5 no. 11:28:05

6 Q. Any reason to believe that it was because 11:28:06

7 of your association with Daily Stormer? 11:28:08

8 A. No, I don't have any reason to believe 11:28:10

9 that either. 11:28:12

10 Q. Did you ever raise this issue with anyone 11:28:19

11 other than ? 11:28:21

12 A. No. 11:28:26

13 Q. Turning back to Exhibit 8, sir. Might you 11:28:28

14 describe what you understood to be the reason 11:28:33

15 Mr. Andrew Anglin wanted his own P.O. box? 11:28:38

16 A. Because I was no longer going to allow 11:28:43

17 mail to be sent to -- he had already ended sending 11:28:46

18 mail to my office. 11:28:52

19 Q. And did you understand that mail would 11:28:53

20 continue to be sent to the P.O. box instead of the 11:28:57

21 6827 North High Street address that we talked about 11:29:02

22 earlier? 11:29:05

23 A. I wasn't surprised when it was, but we 11:29:07

24 didn't really talk about where he was going to send 11:29:10

25 it. So I wasn't surprised, but we didn't talk about 11:29:14

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2 it. 11:29:17

3 Q. And did you have an understanding as to 11:29:18

4 where people would know to send mail for Mr. Andrew 11:29:22

5 Anglin, like, where would they get that information? 11:29:26

6 A. Well, I think it was on his website, but I 11:29:29

7 don't know that for sure. 11:29:32

8 Q. What website are you referring to? 11:29:34

9 A. That would be DailyStormer.com. 11:29:36

10 Q. So it's your understanding that at some 11:29:38

11 point the address on the website changed from 6827 11:29:40

12 North High Street, Suite 121, to a P.O. box? 11:29:43

13 A. That is correct. 11:29:50

14 Q. And whose responsibility was it to 11:29:54

15 retrieve mail from the P.O. box? 11:29:58

16 A. I retrieved the mail from the P.O. box. 11:30:01

17 Q. And how regularly did you retrieve mail 11:30:04

18 from the P.O. box? 11:30:06

19 A. It was sporadic. Somewhere between once a 11:30:08

20 week and once a month. 11:30:14

21 Q. And what type of mail would you retrieve? 11:30:15

22 A. I received money from readers of the Daily 11:30:19

23 Stormer. I received correspondence from attorneys, 11:30:31

24 and I don't recall anything else. 11:30:38

25 Q. Okay. Let's take them in reverse order. 11:30:44

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2 A. Okay. 11:30:47

3 Q. The correspondence you received from 11:30:47

4 attorneys based on your earlier testimony, I 11:30:49

5 understand that went into the tub? 11:30:52

6 A. That's correct, yes, sir. 11:30:54

7 Q. And I would like to understand what 11:30:55

8 happened to the money that was received at the P.O. 11:30:58

9 box? 11:31:01

10 A. What happened to the money that was 11:31:02

11 received at the P.O. box? 11:31:03

12 Q. Yes, sir. 11:31:04

13 A. It was -- let me think for a minute. The 11:31:06

14 money received at the P.O. box, I think that this is 11:31:15

15 the time period at which would not -- 11:31:23

16 would not accept cash deposits. So if there was 11:31:33

17 cash, I would deposit it into my account, and then 11:31:36

18 write a check to Andrew for the same amount. And 11:31:40

19 then checks, I would deposit into the account. 11:31:44

20 Q. Okay. I'll break that down to make sure I 11:31:47

21 understand it. The cash deposits that would come in 11:31:50

22 to the P.O. box, you would deposit them into your 11:31:53

23 account? 11:31:56

24 A. At some point I did. There may have still 11:31:59

25 been a time when I was taking them directly to 11:32:01

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2 and they were accepting cash. But changed 11:32:04

3 their banking policy to no longer accept cash. So at 11:32:07

4 some point, I would deposit the money in to my 11:32:10

5 account, write a check for the exact same amount, and 11:32:12

6 deposit it into Andrew's account. 11:32:15

7 Q. Okay. And which account would you deposit 11:32:18

8 the cash into, at what bank? 11:32:21

9 A. That would have been I 11:32:31

10 believe. 11:32:34

11 Q. And the checks that you would write to 11:32:35

12 Mr. Andrew Anglin were written from what bank? 11:32:37

13 A. From 11:32:41

14 Q. And when closed your 11:32:46

15 account how did your practice change, if at all? 11:32:48

16 A. I think by then -- I don't recall with 11:32:56

17 certainty, but I think by then he had stopped -- let 11:33:01

18 me think. It's so hard. Could you ask the question 11:33:05

19 again? I'm sorry. 11:33:15

20 Q. Certainly. When closed 11:33:16

21 your accounts how did your practice of depositing 11:33:19

22 cash change? 11:33:22

23 A. I don't believe I deposited -- I didn't 11:33:29

24 deposit any cash beyond that date. 11:33:37

25 Q. Okay. You would not have deposited cash 11:33:40

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2 into the account at 11:33:43

3 A. I don't believe I ever did. 11:33:51

4 Q. What gives you certainty about that? 11:33:54

5 A. I don't have certainty about it. But I 11:33:58

6 just think that we were winding up that whole cash 11:34:00

7 thing. 11:34:05

8 Q. Sir, I don't understand what you mean by 11:34:13

9 winding up -- we were winding up that whole cash 11:34:15

10 thing. Who is the we? 11:34:18

11 A. We would be me. I just need to think for 11:34:21

12 just a minute. I'm sorry. 11:34:25

13 Q. Please. 11:34:26

14 A. Starting in March -- I just want to make 11:34:56

15 sure I understand the question completely. I'm 11:35:04

16 sorry, I think I'm getting a little bit tired here. 11:35:06

17 But go ahead. 11:35:08

18 Q. Certainly. I have no problem repeating 11:35:10

19 it, sir. 11:35:12

20 A. Okay. Thank you. I don't want to be 11:35:12

21 annoying to you. 11:35:14

22 Q. You're not annoying. 11:35:15

23 A. Okay. 11:35:16

24 Q. You deposited cash received to the P.O. 11:35:16

25 Box into and then wrote a 11:35:18

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2 corresponding check to Mr. Andrew Anglin for that 11:35:22

3 amount, correct? 11:35:26

4 A. That's correct. 11:35:26

5 Q. At some point in time, 11:35:27

6 closed your accounts, correct? 11:35:30

7 A. That's correct. 11:35:32

8 Q. And so I would like to understand what you 11:35:33

9 did with the cash that came into the P.O. Box after 11:35:35

10 closed your account. 11:35:38

11 A. I think I just let it sit until about 11:35:44

12 April of this year, 2018, when I was doing a real 11:35:51

13 estate rehab, and I borrowed some money from my son. 11:35:59

14 And so he had some cash that had accumulated. I 11:36:02

15 borrowed that money, and then I paid it back later in 11:36:06

16 the year. 11:36:08

17 Q. Okay. And what was the amount that you 11:36:09

18 borrowed in April of this year for the real estate 11:36:11

19 rehab? 11:36:13

20 A. I misspoke. Thank you. It was actually 11:36:14

21 last year, it was 2017. 11:36:17

22 Q. Okay. 11:36:20

23 A. I borrowed -- I know the exact amount -- I 11:36:21

24 borrowed $60,038 from him early -- during the summer, 11:36:25

25 probably, of 2017. And then I deposited -- when I 11:36:31

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2 paid him back at the end of 2017, I wrote him a 11:36:37

3 check. And I don't recall making any -- doing 11:36:40

4 anything with cash other than perhaps there was a few 11:36:43

5 hundred dollars that trickled in that were still in 11:36:46

6 an envelope of his. 11:36:49

7 Q. Okay. Let's sort of go over all those 11:36:51

8 pieces of information separately. 11:36:53

9 A. Okay. 11:36:55

10 Q. The $60,000 loan you received, that was in 11:36:55

11 the form of cash that had accumulated and was left 11:37:01

12 undeposited? 11:37:04

13 A. I took it over time while I was doing 11:37:05

14 this. I underestimated how much money it would cost 11:37:07

15 to do this rehab. So I called Andrew and I said, can 11:37:15

16 I borrow some of this money for a few months, some of 11:37:19

17 your money. And he said sure. So I borrowed it, 11:37:22

18 like 5,000 here, 5,000 there. I never knew for sure 11:37:24

19 how much more I was going to need, but I would borrow 11:37:31

20 it from him, yes. 11:37:33

21 Q. How are you certain about the aggregate 11:37:35

22 amount? I believe you said $60,038. 11:37:37

23 A. Yes, I was real careful. Andrew had an 11:37:40

24 envelope with foreign currency. Andrew had an 11:37:46

25 envelope with United States currency, and I had an 11:37:50

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2 envelope. And when I took money in a loan from 11:37:54

3 Andrew, I would write it down on my envelope, the 11:37:57

4 date and the amount of money that I took. 11:38:00

5 Q. And these envelopes you're referencing in 11:38:02

6 your answers, where were they physically located? 11:38:04

7 A. They were located at a security box at 11:38:11

8 11:38:22

9 Q. In whose name is the security box in? 11:38:22

10 A. In mine. 11:38:24

11 Q. Okay. And what is in the security box 11:38:26

12 today that relates to Mr. Andrew Anglin? 11:38:30

13 A. Some currency, I would guess -- I don't 11:38:35

14 know the exact amount. Most of it is foreign. About 11:38:40

15 $2,000 would be my guess. I don't know. 11:38:43

16 Q. Of foreign currency? 11:38:46

17 A. That's correct. 11:38:49

18 Q. What's in the security box that relates to 11:38:49

19 Daily Stormer? 11:38:51

20 A. Nothing. 11:38:53

21 Q. What's in the security box that relates to 11:38:53

22 Moonbase? 11:38:55

23 A. Nothing. 11:38:56

24 Q. Other than the $2,000 in foreign currency 11:38:57

25 is there anything else in the security box? 11:39:01

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2 A. Some different personal possessions of 11:39:03

3 mine. 11:39:05

4 Q. When you paid back Mr. Andrew Anglin the 11:39:12

5 sum of $60,038, was it a lump sum payment you made or 11:39:14

6 did you pay it incrementally? 11:39:21

7 A. A lump sum payment. 11:39:23

8 Q. How did you make that payment? 11:39:24

9 A. I wrote a check from and deposited 11:39:26

10 it in his account. 11:39:30

11 Q. His account at ? 11:39:31

12 A. That's correct. 11:39:32

13 Q. And when did that occur? 11:39:33

14 A. December of last year, 2017. 11:39:36

15 Q. What is the last date in which you 11:39:38

16 deposited money into the account for Mr. Andrew 11:39:41

17 Anglin? 11:39:44

18 A. I believe that was the last deposit. 11:39:46

19 Q. The 60,038? 11:39:48

20 A. Yes. Thank you. 11:39:52

21 Q. And the check that you wrote him was from 11:39:54

22 your account at 11:39:55

23 A. That's correct. 11:39:57

24 Q. If we go back to Exhibit 8, sir, in the 11:40:00

25 upper right-hand corner it says Box Number 208. Is 11:40:03

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2 that consistent with your recollection as to where 11:40:09

3 you received mail for Mr. Andrew Anglin? 11:40:10

4 A. Yes, it is. 11:40:13

5 Q. And did you have any assistance in filling 11:40:14

6 out this form? 11:40:17

7 A. I mean, it's possible that I asked a 11:40:22

8 question of the woman at the post office. I don't 11:40:24

9 recall. 11:40:27

10 Q. Other than asking the person at the post 11:40:28

11 office, do you recall asking for anyone else's 11:40:30

12 assistance in completing the form? 11:40:34

13 A. No, I did not. 11:40:37

14 Q. Did you get the form at the post office or 11:40:38

15 was it mailed to you? 11:40:40

16 A. I don't recall. 11:40:41

17 Q. Do you recall visiting the post office to 11:40:42

18 submit it? 11:40:45

19 A. I don't recall if I visited the post 11:40:51

20 office or -- my guess would be I dropped it off at 11:40:53

21 the post office, but I don't recall that act. 11:40:58

22 Q. If you look at item number one, it says: 11:41:00

23 This service is for (required selection), and the box 11:41:01

24 that is checked is business/organization use. Is 11:41:08

25 that correct? 11:41:12

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Page 125 1 GREGORY ANGLIN

2 A. That is correct. 11:41:12

3 Q. You checked that box? 11:41:13

4 A. Yes, I did. 11:41:14

5 Q. What business or organization were you 11:41:15

6 checking that box for? 11:41:17

7 A. I think the business organization is 11:41:20

8 Andrew Anglin. 11:41:22

9 Q. And is that an individual's name or is 11:41:24

10 that a business name? 11:41:27

11 A. I guess it's both. It's my son's name, 11:41:28

12 yeah. 11:41:31

13 Q. And then if you turn back to Exhibit 4, 11:41:32

14 sir, the trade name registration? 11:41:34

15 A. Right. 11:41:38

16 Q. On January 10th, 2017, you registered the 11:41:38

17 trade name Andrew Anglin on behalf of Moonbase 11:41:43

18 Holdings, LLC, is that correct? 11:41:46

19 A. Yeah, that's correct. 11:41:49

20 Q. And two days later on Exhibit 8 you open a 11:41:50

21 P.O. box on behalf of the trade name Andrew Anglin, 11:41:55

22 is that correct? 11:41:59

23 A. Yes, I think that was his plan, yes. 11:42:00

24 Q. And the plan that you're referencing is to 11:42:02

25 create a trade name for Moonbase Holdings called 11:42:08

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Page 126 1 GREGORY ANGLIN

2 Andrew Anglin, correct? 11:42:11

3 A. I don't know if it was for Moonbase 11:42:13

4 Holdings or how any of that works. This is just how 11:42:14

5 he asked me to set it up. 11:42:19

6 Q. If you look at the middle of Exhibit 4, 11:42:21

7 sir, you'll see it references Moonbase Holdings, LLC. 11:42:23

8 A. Um-hum. 11:42:27

9 Q. If you turn to the first page of Exhibit 4 11:42:28

10 under the column that says Name of Registrant it says 11:42:30

11 Moonbase Holdings, LLC, correct? 11:42:33

12 A. That's correct. 11:42:36

13 Q. And you knew that at the time you 11:42:36

14 submitted this form on January 10, 2017, right? 11:42:38

15 A. Yeah, yeah. 11:42:42

16 Q. If you turn back to Exhibit 8, the name of 11:42:43

17 the person who was applying for the P.O. Box on 11:42:49

18 behalf of trade name Andrew Anglin is yourself, 11:42:52

19 Gregory Anglin, correct? 11:42:57

20 A. Yes, that's correct. 11:42:59

21 Q. And the address listed is your office 11:42:59

22 address, is that correct? 11:43:02

23 A. That's correct. 11:43:02

24 Q. And the phone number listed is your phone 11:43:02

25 number, correct? 11:43:04

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Page 127 1 GREGORY ANGLIN

2 A. That's correct. 11:43:05

3 Q. And the email address listed is your email 11:43:05

4 address, right? 11:43:08

5 A. That is correct. 11:43:09

6 Q. And under Photo I.D., you've checked Valid 11:43:10

7 Driver's License, is that right? 11:43:15

8 A. That's correct. 11:43:17

9 Q. And the Photo I.D. number there, is that a 11:43:17

10 reflection of your Driver's I.D. number? 11:43:21

11 A. I would presume it is. 11:43:23

12 Q. Okay. And then there's a reference to 11:43:25

13 home or vehicle insurance policy. Is that your home 11:43:27

14 or vehicle insurance policy? 11:43:30

15 A. Yes, it would be. 11:43:31

16 Q. Okay. And other than yourself, who else 11:43:32

17 was authorized to receive mail at the P.O. box? 11:43:35

18 A. Well, I think the next page says just me. 11:43:38

19 Q. Was Mr. Andrew Anglin, your son, the 11:43:42

20 individual, was he authorized to receive mail at the 11:43:45

21 P.O. box? 11:43:49

22 A. No, he was not. 11:43:49

23 Q. He was not allowed to pick it up? 11:43:50

24 A. You have to register that in person, and 11:43:53

25 he was never in the United States. 11:43:57

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Page 130 1 GREGORY ANGLIN

2 deposit box of which you're aware? 11:46:10

3 A. I'm only aware of one. 11:46:13

4 Q. And when did you open that safety deposit 11:46:15

5 box? 11:46:17

6 A. When I opened the account at that bank, so 11:46:24

7 I think that was sometime late in 2017. 11:46:28

8 Q. Okay. Did you previously have a safety 11:46:32

9 deposit box at 11:46:35

10 A. Yes, I did. 11:46:38

11 Q. Do you still have that? 11:46:39

12 A. No, I do not. 11:46:40

13 Q. When your accounts at were 11:46:41

14 closed was the safety deposit box closed as well? 11:46:42

15 A. I closed it. They didn't ask me to close 11:46:47

16 it. 11:46:49

17 Q. You referenced earlier, sir, an envelope 11:46:50

18 on which you tracked the amount of money that you 11:46:53

19 were borrowing from your son. Does that envelope 11:46:56

20 still exist? 11:47:01

21 A. No. 11:47:01

22 Q. What happened to it? 11:47:02

23 A. That would have been thrown away when I 11:47:03

24 paid the 60,038 back. 11:47:06

25 Q. Did you pay back exactly $60,038 or did 11:47:08

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Page 131 1 GREGORY ANGLIN

2 you pay any interest? 11:47:12

3 A. I did not pay interest, no. 11:47:14

4 Q. Have you borrowed any other sums from your 11:47:22

5 son? 11:47:24

6 A. No. 11:47:24

7 Q. On Item 2 for Exhibit 8, when you listed 11:47:33

8 Andrew Anglin, did you intend to denote your son, the 11:47:36

9 individual, or did you intend to denote the trade 11:47:43

10 name that was registered by Moonbase Holdings on 11:47:47

11 January 10th, 2017? 11:47:50

12 A. I didn't really have any intent either 11:47:53

13 way. I filled out the form the way that Andrew 11:47:55

14 Anglin asked me to. 11:47:58

15 Q. Okay. You checked the box 11:47:59

16 business/organization use -- 11:48:00

17 A. That's correct. 11:48:02

18 Q. -- rather than residential. 11:48:02

19 Did he tell you to do that? 11:48:04

20 A. He told me that I have to do that 11:48:06

21 because -- yes, he told me to do that. 11:48:08

22 Q. And did he have a copy of the form? 11:48:12

23 A. Apparently. 11:48:14

24 Q. Who sent it to him? 11:48:15

25 A. I didn't send it to him. I don't know. 11:48:17

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Page 132 1 GREGORY ANGLIN

2 Q. Were you talking to him on the phone while 11:48:19

3 you were filling out the form? 11:48:21

4 A. I don't remember. 11:48:29

5 Q. Do you still receive mail at 208? 11:48:42

6 A. Mail still goes to P.O. Box 208. I don't 11:48:48

7 collect it any longer. 11:48:51

8 Q. Who collects it? 11:48:53

9 A. Nobody to my knowledge. 11:48:54

10 Q. And when did you stop collecting mail at 11:48:55

11 P.O. Box 208? 11:48:57

12 A. I'm bad at time frames. Maybe a couple 11:49:03

13 months ago. 11:49:05

14 Q. Why did you make that decision? 11:49:05

15 A. I just didn't want to do it any more. 11:49:07

16 Q. Do you know if the P.O. Box still contains 11:49:11

17 cash contributions? 11:49:15

18 A. There had not been cash contributions for 11:49:17

19 quite a long time, so I would be surprised. 11:49:19

20 Q. But you don't know, because you haven't 11:49:24

21 visited the P.O. box? 11:49:26

22 A. That's correct. 11:49:28

23 (Plaintiff's Exhibit 9 was marked for 11:49:28

24 identification.) 11:49:28

25 Q. Okay. Mr. Anglin, I'm handing you a 11:49:32

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Page 137 1 GREGORY ANGLIN

2 information. 12:08:04

3 A. Yes, sir. 12:08:04

4 Q. Sir, you talked about the loan that was 12:08:05

5 made to you from funds sent to Andrew Anglin the 12:08:09

6 $60,038? 12:08:13

7 A. Um-hum. 12:08:15

8 Q. And you referenced a real estate rehab 12:08:15

9 project, is that correct? 12:08:19

10 A. That's correct. 12:08:20

11 Q. Was that rehab project related in any way 12:08:20

12 related to Mr. Andrew Anglin? 12:08:23

13 A. No, it was not. 12:08:24

14 Q. Related in any way to Moonbase Holdings? 12:08:26

15 A. No, it was not. 12:08:28

16 Q. Was it related to Daily Stormer? 12:08:29

17 A. No, it was not. 12:08:31

18 Q. Was it associated with your personal 12:08:32

19 business affairs? 12:08:34

20 A. Yes, sir, it was. 12:08:35

21 Q. And was that real estate rehab associated 12:08:36

22 with property here in Columbus, Ohio? 12:08:39

23 A. Yes, it was. 12:08:41

24 Q. Is that project complete? 12:08:44

25 A. Yes, sir, it is, finally. 12:08:46

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Page 144 1 GREGORY ANGLIN

2 121, Worthington, Ohio? 12:16:17

3 A. Yes, I see that. 12:16:19

4 Q. And on top of that it says, "And snail 12:16:20

5 mail for cash (any currency), checks, money orders, 12:16:22

6 and so on." Is that what it says? 12:16:29

7 A. That is what it says. 12:16:32

8 Q. And underneath it lists the address 12:16:33

9 associated with your consulting business, correct? 12:16:35

10 A. That's correct. 12:16:39

11 Q. We talked about cash, and we talked about 12:16:41

12 foreign currency. We didn't talk about money orders. 12:16:43

13 Did you ever receive money orders at that address? 12:16:47

14 A. Yes, I did. 12:16:49

15 Q. And how did you treat those? 12:16:50

16 A. Well, just like a check. 12:16:53

17 Q. You would deposit them into the 12:16:56

18 account? 12:16:59

19 A. That's correct. 12:16:59

20 Q. Or on occasion you would deposit them into 12:17:00

21 your account and then send a check to 12:17:02

22 Mr. Anglin for the corresponding amount? 12:17:06

23 A. Well, only with cash. 12:17:08

24 Q. You would only do that with cash? 12:17:09

25 A. That's correct. 12:17:13

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Page 147 1 GREGORY ANGLIN

2 Daily Stormer website? 12:20:10

3 A. No, I don't. 12:20:13

4 Q. Do you know if people who write for the 12:20:15

5 Daily Stormer get paid? 12:20:17

6 A. No, I don't know. 12:20:19

7 Q. Do you have any understanding as to what 12:20:24

8 happens to the money that is contributed to the Daily 12:20:25

9 Stormer? 12:20:27

10 A. No, I don't. 12:20:31

11 Q. Did you ever ask Andrew Anglin that 12:20:32

12 question? 12:20:35

13 A. No, I did not. 12:20:35

14 Q. You were depositing money in to his 12:20:38

15 account, correct? 12:20:41

16 A. I deposited money in to his account, yes, 12:20:44

17 sir. 12:20:46

18 Q. And you collected money from the P.O. box? 12:20:47

19 A. That's correct. 12:20:49

20 Q. You collected money from the 6827 North 12:20:49

21 High Street address? 12:20:52

22 A. That's correct. 12:20:53

23 Q. And you never asked him what's this money 12:20:54

24 for? 12:20:55

25 A. No, I never had a conversation with him 12:20:58

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Page 148 1 GREGORY ANGLIN

2 except before I borrowed the money, I asked him -- I 12:21:00

3 just confirmed again, I said, this is your money. He 12:21:11

4 said this is my money. 12:21:14

5 Q. And did you have an understanding 12:21:15

6 independent of any conversation you might have had 12:21:18

7 with him as to what the purpose of these 12:21:21

8 contributions that were coming into these addresses 12:21:24

9 was? 12:21:27

10 A. What the -- the purpose meaning why they 12:21:31

11 sent them or what they were supposed to do -- what he 12:21:34

12 was supposed to do with the money? 12:21:36

13 Q. We can talk about both. Let's talk about 12:21:38

14 the first concept first. Why do you understand 12:21:40

15 people were sending money? 12:21:42

16 A. I think it was primarily readers of the 12:21:44

17 site that were sending him money. 12:21:47

18 Q. The Daily Stormer website? 12:21:50

19 A. That is correct, readers of the Daily 12:21:52

20 Stormers website were sending Andrew money. 12:21:54

21 Q. And what about the second question, what 12:21:58

22 was going to be done with the money; what did you 12:21:59

23 understand to happen? 12:22:01

24 A. You know, I don't know what he does with 12:22:02

25 his money. 12:22:03

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Page 149 1 GREGORY ANGLIN

2 Q. And did you have any belief or opinion as 12:22:04

3 to what was going to occur with the funds that were 12:22:07

4 sent to the addresses we've talked about today? 12:22:10

5 A. No, I did not. 12:22:13

6 Q. Sir, are you paying your own legal fees in 12:22:21

7 connection with this deposition? 12:22:26

8 A. Yes, I am. 12:22:27

9 Q. Do you intend to seek reimbursement from 12:22:28

10 your son? 12:22:30

11 A. No, I do not. 12:22:30

12 MR. QURESHI: I have no further questions. 12:22:35

13 Thank you. 12:22:37

14 MR. QURESHI: Thank you for your time, 12:22:38

15 Mr. Anglin. 12:22:40

16 THE VIDEOGRAPHER: It's 12:21, we're off 12:25:44

17 the record. 12:25:44

18 (Signature Not Waived.) 12:25:44

19 - - - 12:25:44

20 (DEPOSITION CONCLUDED AT 12:21 P.M.) 12:25:44

21

22

23

24

25

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Page 151 1 GREGORY ANGLIN

2 CERTIFICATE 12:25:44

3 State of Ohio : 12:25:44

SS: 12:25:44

4 County of Franklin:

5 I, Jackie Olexa White, Notary Public in

6 and for the State of Ohio, duly commissioned and

7 qualified, certify that the within named GREGORY

8 ANGLIN was by me duly sworn to testify to the whole

9 truth in the cause aforesaid; that the testimony was

10 taken down by me in stenotypy in the presence of said

11 witness, afterwards transcribed upon a computer; that

12 the foregoing is a true and correct transcript of the

13 testimony given by said witness taken at the time and

14 place in the foregoing caption specified.

15 I certify that I am not a relative,

16 employee, or attorney of any of the parties hereto,

17 or of any attorney or counsel employed by the

18 parties, or financially interested in the action.

19 IN WITNESS WHEREOF, I have set my hand and

20 affixed my seal of office at Columbus, Ohio, on this

21 13th day of November, 2018.

22

______

23 JACKIE OLEXA WHITE, Notary Public

in and for the State of Ohio

24 and RPR-CM.

25 My Commission expires January 21, 2019.

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EXHIBIT 6

11/16/2018 Case: 2:17-cv-00720-EAS-EPDRally Doc Against #: the 46-7 Anglins Filed: of Daily 11/16/18 Stormer in Ohio Page: – Idavox 2 of 5 PAGEID #: 968

NOVEMBER 16, 2018

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HOME EVENTS Rally Against the Anglins of Daily Stormer in Ohio ALERTS, EVENTS & ANNOUNCEMENTS

Rally Against the Anglins of N O V 11:00 am Proud Boy- 17 Affiliated III%er Grou... Daily Stormer in Ohio Sat @ independence Visitor (https: Center //idavo (https://idavox.com/inde January 5, 2017 Idavox 2 x.com/ index. x.php/event/proud-boy- php/ca affiliated-iiier-group-to- lendar rally-in-philly/? /action ~oned instance_id=140) ay/exa ct_dat e~17- 11- 2018/)

(https://idavox.com/index.php/calendar/)

FOLLOW ON TWITTER

https://idavox.com/index.php/event/rally-against-the-anglins-of-daily-stormer-in-ohio/ 1/4 11/16/2018 Case: 2:17-cv-00720-EAS-EPDRally Doc Against #: the 46-7 Anglins Filed: of Daily 11/16/18 Stormer in Ohio Page: – Idavox 3 of 5 PAGEID #: 969

WHEN: (https://idavox.com/index.php/calendar/) Tweets by @IdavoxOPP January 14, 2017 @ 1:00

pm – 4:00 pm Idavox WHERE: @IdavoxOPP 6827 N High St Daryle Lamont Jenkins on the Black Kids in Outer Space podcast! Worthington, OH 43085 facebook.com/BlackKidsinOut… USA

CONTACT: 4h Colubus Anti-Racist Action Idavox (614)407-5887 @IdavoxOPP Email idavox.com/index.php/2018… (mailto:[email protected])

EVENT (HTTPS://IDAVOX.C

Andrew Anglin (https://idav Columbus (https://idavox.co

Daily Stormer (https://idavo Embed View on Twitter Greg Anglin (https://idavox Hate (https://idavox.com/in Ohio (https://idavox.com/in FOLLOW ON FACEBOOK racism (https://idavox.com/

We must state for the record: We are not sure if the Daily Stormer’s Andrew Anglin is actually going to pull of his armed anti- Jewish rally in Whitesh, Montana on Martin Luther King, Jr. Day. This is a guy who does not make public appearances, only talks trash from behind his computer and has not even led the application for a permit to rally in Whitesh on that or any day in the near future (we called the city clerk and they conrmed to us that the application had not been received). But screw HIS timetable. Anti-Racist Action isn’t going by that. See, Anglin keeps wanting to be an asshole screwing with people with his Nazi BS from afar, but he is in the Columbus, Ohio area and Columbus is not only the home of one of the strongest chapters of ARA, but it’s also where we called home for a year and a half. To that end antifa is making other plans – zeroing in on his disreputable father Greg

https://idavox.com/index.php/event/rally-against-the-anglins-of-daily-stormer-in-ohio/ 2/4 11/16/2018 Case: 2:17-cv-00720-EAS-EPDRally Doc Against #: the 46-7 Anglins Filed: of Daily 11/16/18 Stormer in Ohio Page: – Idavox 4 of 5 PAGEID #: 970

who seems to be a kind of silent partner of his son’s and just so happens to own an oce building just outside town! So Andrew now has a choice: Go out and posture thousands of miles away from where people back home are calling him and his Daddy out, or stay home and deal with the mess he is making of his life that is now being dealt with in more oine scenarios.

PREVIOUS NEXT ALERT! Neo ALERT! Neo-Fascist Confederate ‘Memorial ‘Atlanta Forum’ to Take Service’ in Lexington, Place Jan. 28 VA

2 COMMENTS

adolf the great

JANUARY 9, 2017 AT 11:31 PM

good luck with that antifa faggots

To all: The two negative comments you see here are posted because we just want to say how comical these net Nazis can be. Bravado doesn’t work when you don’t show up, and the 50 that turned out (and by the way eectively got the Anglin Family kicked out of that oce building in the process – more on that later) were not opposed in any way. So Adolf, thanks for the good luck wishes! We most certainly had that!–Idavox

REPLY

kerrang

JANUARY 11, 2017 AT 8:09 AM

so, lefties, are you scared of us? :)))) 14/88 WPWW

REPLY

https://idavox.com/index.php/event/rally-against-the-anglins-of-daily-stormer-in-ohio/ 3/4 11/16/2018 Case: 2:17-cv-00720-EAS-EPDRally Doc Against #: the 46-7 Anglins Filed: of Daily 11/16/18 Stormer in Ohio Page: – Idavox 5 of 5 PAGEID #: 971

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https://idavox.com/index.php/event/rally-against-the-anglins-of-daily-stormer-in-ohio/ 4/4 Case: 2:17-cv-00720-EAS-EPD Doc #: 46-8 Filed: 11/16/18 Page: 1 of 4 PAGEID #: 972 Case: 2:17-cv-00720-EAS-EPD Doc #: 46-8 Filed: 11/16/18 Page: 2 of 4 PAGEID #: 973 Case: 2:17-cv-00720-EAS-EPD Doc #: 46-8 Filed: 11/16/18 Page: 3 of 4 PAGEID #: 974 Case: 2:17-cv-00720-EAS-EPD Doc #: 46-8 Filed: 11/16/18 Page: 4 of 4 PAGEID #: 975 Case: 2:17-cv-00720-EAS-EPD Doc #: 46-9 Filed: 11/16/18 Page: 1 of 8 PAGEID #: 976

EXHIBIT 8 Steven Crowder Allegedly Hunting Manchester Bombing Mastermi... https://dailystormer.al/steven-crowder-allegedly-hunting-mancheste... Case: 2:17-cv-00720-EAS-EPD Doc #: 46-9 Filed: 11/16/18 Page: 2 of 8 PAGEID #: 977

Steven Crowder Allegedly Hunting Manchester Bombing Mastermind Dean Obeidallah in ISIS-Occupied Syria!

Andrew Anglin Daily Stormer

August 29, 2017

Dean “Dean of ISIS” Obediallaih, mastermind of the Manchester bombing

I am being sued by a greasy Islamic terrorist who is now claiming that real tweets that he posted were

faked by me, as he tries to wiggle his way out of guilt for masterminding the Manchester bombing.

Dean Obedelliah openly admitted to carrying out the attack on Twitter, and all I did was post screen shots.

His lawsuit – or perhaps I should say “lolsuit” – is pure fabrication, designed to cover-up his key role in the bombing.

You can read the fake news take on this at Cleveland.com.

Here’s an example:

1 of 7 8/30/17, 1:09 PM Steven Crowder Allegedly Hunting Manchester Bombing Mastermi... https://dailystormer.al/steven-crowder-allegedly-hunting-mancheste... Case: 2:17-cv-00720-EAS-EPD Doc #: 46-9 Filed: 11/16/18 Page: 3 of 8 PAGEID #: 978

See.

They are claiming I edited the Tweets. In fact, he edited the tweets. And before you’re like “ANGLIN TWITTER DOESN’T LET YOU EDIT TWEETS” – get this: he’s got what’s called a “Master’s Account,” which is a

special type of Twitter account that allows users to edit tweets.

That’s the reality we’re living in here, folks: I can’t even keep a website up, and this ADMITTED TERRORIST

who is PLANNING MORE ATTACKS from a base in RAQQA is still on TWITTER with a MASTER’S ACCOUNT.

And I’M THE ONE getting sued, while he lives it up in ISIS-controlled Syria with 14 Yazidi child sex slaves he calls his “girlies.”

Luckily for the forces of good in the universe, the heroic white hero Steve Crowder has taken up the cause

and vowed to hunt down Obedelliah AKA “The Dean of Comedy” and make him woe the day.

2 of 7 8/30/17, 1:09 PM Steven Crowder Allegedly Hunting Manchester Bombing Mastermi... https://dailystormer.al/steven-crowder-allegedly-hunting-mancheste... Case: 2:17-cv-00720-EAS-EPD Doc #: 46-9 Filed: 11/16/18 Page: 4 of 8 PAGEID #: 979

Dean Obelidiallh

Steven Crowder

US President Donald Trump has gone around the established and legal legal system and personally given a

warrant directly to the vigilante mass-murderer Crowder to bring Obelidelia to justice.

According to a series of Tweets during a back and forth with Obidiallah, Crowder, leader of a massive

3 of 7 8/30/17, 1:09 PM Steven Crowder Allegedly Hunting Manchester Bombing Mastermi... https://dailystormer.al/steven-crowder-allegedly-hunting-mancheste... Case: 2:17-cv-00720-EAS-EPD Doc #: 46-9 Filed: 11/16/18 Page: 5 of 8 PAGEID #: 980

secret army of Neo-Nazi terrorists, has traveled to Syria to track down the notorious bomber and frivolous

lawsuit filer…

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I cannot confirm that Crowder actually trained Seal Team Six. However, he has run the most infamous

international Neo-Nazi terrorist organization on the planet – The Blood Order of Aryan Skinheads – for nigh a decade, and is, according to the SPLC, “personally responsible for the brutal torture, murder and

dismemberment of hundreds of Jews, blacks, Muslims and Mexicans.” He is also responsible, again

according to the SPLC, for more than three dozen synagogue bombings dating back to 2002 when he released a grainy video declaring “the beginning of the real and final Holocaust.”

He has only been arrested once, in 2011, when he is said to have “slipped out of handcuffs, bent the bars of the jail cell and squeezed through.” He killed nine cops during his escape. He made 12 children

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fatherless, and one motherless. He has referred to cops as “blue ZOG niggers.”

Allegedly, Twitter won’t ban him due to repeated threats that if they do “all of their offices will explode

simultaneously.”

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Currently, it is unknown what has happened with Crowder (The Dean of Genocide) or the Dean of Comedy. What we do know is that these were the last Tweets by either of them.

Presumably, even if Dean disappears, the Association of Moslems will still sue me. So send some money,

lmao. I’m also getting sued by the Jews (although that is I think totally covered already). These Semitic rats

just crawl up into the country my ancestors built and start drinking the blood from my veins and demanding cash. I might even be getting sued over Charlottesville somehow. I’m also kicked off of the

internet by Jews, and that shit is not cheap.

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EXHIBIT 9 11/15/2018Case: 2:17-cv-00720-EAS-EPDHulk Hogan Awarded Doc $115 #: Million 46-10 in Privacy Filed: Suit 11/16/18 Against Gawker Page: - The 2New of Y ork6 TPAGEIDimes #: 985

Hulk Hogan Awarded $115 Million in Privacy Suit Against Gawker

By Nick Madigan and Ravi Somaiya

March 18, 2016

The retired wrestler Hulk Hogan was awarded $115 million in damages on Friday by a Florida jury in an invasion of privacy case against Gawker.com over its publication of a sex tape — an astounding figure that tops the $100 million he had asked for, that will probably grow before the trial concludes, and that could send a cautionary signal to online publishers despite the likelihood of an appeal by Gawker.

The wrestler, known in court by his legal name, Terry G. Bollea, sobbed as the verdict was announced in late afternoon, according to people in the courtroom. The jury had considered the case for about six hours.

Mr. Bollea’s team said the verdict represented “a statement as to the public’s disgust with the invasion of privacy disguised as journalism,” adding: “The verdict says, ʻNo more.’ ”

The damages awarded to Mr. Bollea on Friday were compensatory: $55 million for economic harm and $60 million for emotional distress. Punitive damages will be established separately, which raises the prospect that Gawker will have to submit to a detailed examination of its finances in court so the jury can assess the scale of the damages.

Gawker’s founder, Nick Denton, said in his own statement that the jury did not hear all the facts. “We feel very positive about the appeal that we have already begun preparing, as we expect to win this case ultimately,” he said.

The meaning of the verdict will not be clear for some time. But the perception that a Manhattan media company, noted for its wry tone and its insistence that nearly any topic is fair game, was brought low by a celebrity fighting for privacy is most likely to resonate widely across the industry.

At issue in the case, in Pinellas County Circuit Court, was a grainy black-and-white tape made in the mid-2000s, which showed Mr. Bollea having sex with the wife of a friend of his at the time, Todd Clem, a radio shock jock who had legally changed his name to Bubba the Love Sponge Clem.

Gawker posted a brief excerpt in a 2012 post by Albert J. Daulerio, the site’s former editor in chief, that mused on the appeal of celebrity sex tapes.

https://www.nytimes.com/2016/03/19/business/media/gawker-hulk-hogan-verdict.html?login=email&auth=login-email 1/5 11/15/2018Case: 2:17-cv-00720-EAS-EPDHulk Hogan Awarded Doc $115 #: Million 46-10 in Privacy Filed: Suit 11/16/18 Against Gawker Page: - The 3New of Y ork6 TPAGEIDimes #: 986 The case represented a peculiar clash of worlds, and it was a surreal spectacle. Mr. Bollea explained his relationship with Mr. Clem, and the ways in which Mr. Clem had encouraged him to sleep with his wife. He also drew a distinction between himself and Hulk Hogan, who he suggested were separate personas.

Mr. Daulerio, who was named in the suit along with Mr. Denton, decided to joke about child pornography in his deposition, which shocked the court. And the jurors had to try and make sense of it all.

Mr. Bollea’s lawyers said that the publication of the video was a gratuitous invasion of privacy, and had no news value. One of them, Kenneth G. Turkel, took particular aim at the contention that Gawker’s posting of the video was an act of journalism and was therefore protected under the First Amendment. He described the publication as “morbid and sensational prying.”

He maintained that had the site’s editors been operating under the rules of professional journalism, they would have contacted Mr. Bollea to ask his permission to publish the video, or at least to warn him that they were going to do so. In any case, Mr. Turkel said, it served only as fodder for readers’ clicks and a source for advertising revenue, Mr. Turkel said.

Gawker had argued that its posting of a brief excerpt of the tape was protected by the Constitution, and that Mr. Bollea had given up his right to privacy by talking often in public about his sex life. “He has chosen to seek the spotlight,” a lawyer for Gawker, Michael Sullivan, said. “He has consistently chosen to put his private life out there.”

In his closing statement for the defense, Mr. Sullivan insisted that uncovering the sometimes less- than-laudatory activities of public figures “is what journalists do, and at the end of the day it’s what we want journalists to do.”

After accounts of the video and images from it surfaced online — but several months before Mr. Daulerio’s 2012 post — Mr. Bollea addressed it in an appearance on a television show run by the website TMZ and in other interviews. “The public discussion was already going on,” Mr. Sullivan said.

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Hulk Hogan with Seema Ghatnekar, a lawyer. He claimed he was emotionally damaged by Gawker’s publication of the video.

The verdict is a blow for Gawker, which has rebranded itself as a politics site since it published the tape and has sought to clean up its image in the wake of a series of scandals.

The company is technically required to post a bond, which is capped at $50 million, before appealing. But it will almost certainly appeal that bond.

The potential effect on the business, which employs about 250 people across seven websites, was not immediately clear. The company recently took significant outside investment for the first time, specifically to prepare for the case, and has been confident it can meet any financial demands the case places on it. https://www.nytimes.com/2016/03/19/business/media/gawker-hulk-hogan-verdict.html?login=email&auth=login-email 3/5 11/15/2018Case: 2:17-cv-00720-EAS-EPDHulk Hogan Awarded Doc $115 #: Million 46-10 in Privacy Filed: Suit 11/16/18 Against Gawker Page: - The 5New of Y ork6 TPAGEIDimes #: 988 In the statement on Friday, Gawker said its team was “disappointed the jury was unable to see key evidence and hear testimony from the most important witness.”

That was an apparent reference to Mr. Clem. According to documents unsealed on Friday, the radio host initially told federal investigators that Mr. Bollea was aware that his tryst with Mrs. Clem was being recorded. But he later changed that account after Mr. Bollea sued him, saying the former wrestler did not know a camera was present.

Apparently fearing that if he testified in the trial he could be subject to prosecution for giving differing accounts of the events, Mr. Clem invoked his right to not incriminate himself and was not called as a witness.

The plaintiff’s legal team issued its own statement, saying that during the three and a half years since the lawsuit was filed, Mr. Clem had testified only once under oath and had “confirmed that Terry Bollea had no knowledge of being filmed or anything to do with it.”

Samantha Barbas, a law professor at the University at Buffalo whose research focuses on the intersection of the First Amendment, media and privacy, said the verdict “could have a profound impact on privacy rights and also free press rights” in the United States.

“For a jury to say that a celebrity has a right to privacy that outweighs the public’s ʻright to know,’ and that a celebrity sex tape is not newsworthy, represents a real shift in American free press law,” Professor Barbas said.

A version of this article appears in print on March 19, 2016, on Page A1 of the New York edition with the headline: Hefty Damages to Hulk Hogan in Gawker Suit

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