Isner Deposition - Open Records Lawsuit

Reverend Tabitha Isner v.
Reverend Taabitha Isner

Jefferson S. Dunn January 29, 2018
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1 IN THE CIRCUIT COURT OF 1 S T I P U L A T I O N S
2 MONTGOMERY COUNTY, ALABAMA 2
3 3 IT IS STIPULATED AND AGREED,
4 4 by and between the parties through their
5 CASE NO.: CV-17-240-J-H 5 respective counsel, that the deposition of
6 6 REV. TABITHA ISNER may be taken before
7 REVEREND TABITHA ISNER, 7 Victoria M. Castillo, Commissioner, at
8 Plaintiff/Petitioner, 8 McGUIRE & ASSOCIATES, 31 Clayton Street,
9 vs. 9 Montgomery, Alabama, on the 29th day of
10 JEFFERSON S. DUNN, in his Personal Capacity 10 January, 2018.
11 as Commissioner of the Alabama Department 11 IT IS FURTHER STIPULATED AND
12 of Corrections, 12 AGREED that the signature to and the
13 Defendant/Respondent. 13 reading of the deposition by the witness is
14 14 waived, the deposition is said to have the
15 15 same force and effect as if full compliance
16 DEPOSITION OF 16 had been had with all laws and rules of
17 REV. TABITHA ISNER 17 Court relating to the taking of
18 January 29, 2018 18 depositions.
19 19 IT IS FURTHER STIPULATED AND
20 BEFORE: Victoria M. Castillo 20 AGREED that it shall not be necessary for
21 Certified Court Reporter and 21 any objections to be made by counsel to any
22 Notary Public 22 questions, except as to form or leading
23 ACCR# 17, Expires 9/30/2018 23 questions, and that counsel for the parties
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1 In accordance with Rule 5(d) 1 may make objections and assign grounds at
2 of The Alabama Rules of Civil Procedure, as 2 the time of trial, or at the time said
3 Amended, effective May 15, 1988, I, 3 deposition is offered in evidence, or prior
4 Victoria M. Castillo, am hereby delivering 4 thereto.
5 the original transcript of the oral 5 IT IS FURTHER STIPULATED AND
6 testimony taken on the 29th day of January, 6 AGREED that notice of filing of the
7 2018, along with exhibits. 7 deposition by the Commissioner is waived.
8 Please be advised that this 8
9 is the same and not retained by the Court 9
10 Reporter, nor filed with the Court. 10
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Min-U-Script® Baker Realtime Reporting Worldwide (1) Pages 1 - 4

www.BakerRealtime.com
Reverend Tabitha Isner v. Reverend Taabitha Isner
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1 I N D E X
1 following proceedings were had:
2
2 REV. TABITHA ISNER,
3 EXAMINATION BY: PAGE NUMBER:
3 being first duly sworn, was examined and
4 Mr. Harmon 8, 114
4 testified as follows:
5 Mr. McGuire 103, 118
5 COURT REPORTER: Usual
6
6 stipulations?
7 EXHIBITS: PAGE NUMBER:
7 MR. McGUIRE: Yes.
8 Defendant's Exhibit 1 54
8 MR. HARMON: Yes.
9 (Summons)
9 THE DEPONENT: Yes.
10 Defendant's Exhibit 2 82
10
11 (Isner for Congress tweets)
11
12 12
13 A P P E A R A N C E S 13
14 14
15 FOR THE PLAINTIFF: 15
16 Hon. J. Mitch McGuire 16
17 McGUIRE & ASSOCIATES 17
18 31 Clayton Street 18
19 Montgomery, Alabama 36104 19
20 (334)517-1000 20
21 MandAbusinesslaw.com 21
22 22
23 23
Page 6 Page 8
1 A P P E A R A N C E S (continued)
1 EXAMINATION BY MR. HARMON:
2
2 Q. Reverend Isner, would you please
3 FOR THE DEFENDANT:
3 state your name for the record?
4 Hon. Bart Harmon
4 A. Tabitha Kay Isner.
5 Hon. Joseph G. Stewart, Jr.
5 Q. What does the "K" stand for?
6 ALABAMA DEPARTMENT OF CORRECTIONS
6 A. K-A-Y.
7 301 South Ripley Street
7 Q. K-A-Y. So you spelled it and
8 Montgomery, Alabama 36104
8 you gave me the abbreviation, same one.
9 (334)353-3881
9 Thank you for being here today.
10 (334)353-3883
10 A. Uh-huh.
11 bart.harmon@doc.alabama.gov
11 Q. And I have some kind of ground
12 joseph.stewart@doc.alabama.gov 12 rules I talk about in every deposition, so
13 ********************* 13 bear with me, just so we're on the same
14 I, Victoria M. Castillo, a 14 page.
15 Court Reporter of Montgomery, Alabama, 15 Have you ever been deposed
16 acting as Commissioner, certify that on 16 before?
17 this date, as provided by the Alabama Rules 17 A. No.
18 of Civil Procedure and the foregoing 18 Q. Okay. Have you ever given
19 stipulation of counsel, there came before 19 testimony in court before?
20 me at McGUIRE & ASSOCIATES, 31 Clayton 20 A. No.
21 Street, Montgomery, Alabama, commencing at 21 Q. All right. You understand
22 1:15 p.m., REV. TABITHA ISNER, in the above 22 you're under oath?
23 cause, for oral examination, whereupon the 23 A. Yes.

Page 9 Page 11
1 Q. And you understand that this 1 A. No, I'm not.

2 court reporter is going to take down every 2 Q. Clear thinking? Your memory is
3 question I ask and every response that you 3 good?
4 make? 4 A. Yes.
5 A. Yes. 5 Q. That kind of thing. Okay. Fair
6 Q. All right. And your plan today 6 enough.
7 is to tell me the truth, the whole truth, 7 Now, again in a normal
8 nothing but the truth? 8 conversation, as we talk -- it's going to
9 A. Yes. 9 stretch on for, you know, a few hours --
10 Q. Of course. I mean, I'm -- just 10 it's normal that you're going to anticipate
11 the way I start out. Unless your attorney, 11 what I'm asking and answer. I'm probably
12 of course, instructs you not to. 12 going to stop you and say, Let me finish
13 Otherwise, you'll give truthful and 13 the question. And that's not an offensive
14 complete answers, right? Yes? 14 thing. It's just -- you know, even though
15 A. Yes. 15 you're guessing right, the record is best
16 Q. Okay. And I have to ask for 16 when I finish the question and then you
17 that response because it's different than a 17 answer. Whatever the answer is is fine.
18 normal conversation because I can see a 18 I'm just saying we've got to kind of take
19 head nod or a head shake. And all of us 19 turns. And in a normal conversation, often
20 here will know what you mean, but for 20 you don't -- Oh, yeah -- you're guessing
21 purposes of the record I may have to ask 21 what I'm trying to say, and you're probably
22 you to verbally say yes or no. And we try 22 right. So I might have to stop you a few
23 to avoid uh-huh and huh-uh because it's -- 23 times. That's okay. That's very normal.
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1 I get it, but it's hard for her to 1 Okay. Let's see. Let's just go
2 distinguish the two. You know, it's the 2 to the basic things and we'll get to the
3 same kind of sound. 3 case. I'm assuming you're a resident of
4 So I might ask you to clarify, 4 Montgomery?
5 but that's just for the record. Okay? 5 A. Yes, I am.
6 A. Yes, I understand that. 6 Q. What is your address?
7 Q. Okay. And if I ask a question 7 A.
8 and you don't understand or you need to be 8
9 clarified, just ask me. It won't be your 9 Q. And that's your home address?
10 fault. It will be my fault. But that will 10 A. That is my home address.
11 give me a chance to fix it maybe and make 11 Q. Do you have a business address
12 it clear. Is that okay? 12 as well, or a professional address?
13 A. Great. 13 A. I have a campaign address.
14 Q. And if you answer, I'm going to 14 Q. Is that a physical address or
15 assume you understood the question. 15 just a P.O. box?
16 A. Yes. 16 A. Yes, I have one of each.
17 Q. Okay. Just a few more 17 Q. Okay. What is your physical
18 preliminary things and we'll head on. 18 address?
19 You're feeling good today? Do you feel up 19 A. It is not -- I just want to
20 to doing this? 20 clarify it's not my address. It's an
21 A. Yes, I feel up to doing this. 21 organization that I'm a part of. Yes.
22 Q. You're not under the influence 22 Q. I got that. So, yes, the
23 of any medication at all? 23 congressional campaign office. Is that --

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1 A. Yes. 1 democratic party? Are you running for the

2 Q. What is that address? 2 democratic nomination?
3 A. So the physical address is 1460 3 A. I am running for the democratic
4 Ann Street. 4 nomination for Alabama 2nd congressional
5 Q. And are there staff that work 5 district.
6 there full time or... 6 Q. And the election is summer? I
7 A. I have staff that are full time. 7 don't even know when the election is.
8 They're not always there full time. 8 A. It's in November 2018. There's
9 Q. I got you. I got what you mean. 9 a primary first that both of us has to go
10 They work -- they work hard, but they might 10 through.
11 not be present at that building? 11 Q. Right. The election -- the
12 A. Yes. 12 election is in November and the primaries
13 Q. And who are those staff members? 13 are --
14 A. Can you tell me more about why 14 A. In June.
15 we're -- 15 Q. So maybe -- okay. Yes.
16 Q. Well, yes, this is -- 16 Okay. So does -- does the open
17 A. -- going down my campaign road? 17 records request and this lawsuit, in your
18 Q. This -- you know, I can't answer 18 mind, have anything to do with your
19 questions because it's your deposition. 19 congressional aspirations?
20 Mitch might want to depose me next week, 20 A. I don't understand that
21 but I guess -- 21 question.
22 A. So everything is on the table? 22 Q. Is there any connection?
23 Q. Everything is on the table. 23 A. I am the connection between
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1 A. Okay. 1 those two things.

2 Q. Unless Mitch might have -- at 2 Q. So you are the same person
3 some point tells you don't answer. But 3 running for congress and making the --
4 other than that, it's very wide ranging, 4 A. Yes.
5 very open. 5 Q. But I'm -- let me ask this. Are
6 So, anyway, who are your staff 6 you a death penalty opponent?
7 members? 7 A. Can you define what you -- how
8 A. My only full time staff member 8 you would define that?
9 is Megan Skipper. 9 Q. I think the common -- in the
10 Q. And you have part time as well? 10 common parlance, someone who opposes the
11 A. I have consultants. 11 death penalty.
12 Q. Okay. Let's see now. Let's -- 12 A. Personally?
13 I mean, we've kind of gone into that a 13 Q. Uh-huh.
14 little bit. I mean, you're obviously 14 A. My personal belief as a
15 running for congress? 15 Christian would -- would be to be concerned
16 A. Yes. 16 about any taking of life because all life
17 Q. That's District 2? 17 is sacred. I am a resident of the state of
18 A. Yes. 18 Alabama where the death penalty is the law
19 Q. And the current placeholder in 19 of the land, and I recognize and respect
20 that district would be Martha Roby? 20 the law of the land.
21 A. Yes. 21 Q. All right. Are you members --
22 Q. Who is a republican in party. 22 are you a member of any group that opposes
23 And are you affiliated with the 23 publicly the administration of the death

Page 17 Page 19
1 penalty? 1 remember at this point?

2 A. Not that I'm aware of. 2 A. Uh-huh.
3 Q. Have you given money to any 3 Q. Are there any more that you can
4 group that opposes the death penalty? 4 remember off the top of your head?
5 A. Not that I am aware of. 5 A. If I worked on it -- if you want
6 Q. When you say "not that you're 6 me -- you want me to take time, I can sit
7 aware of," you just don't remember? It 7 here and try and think of some more.
8 could be or... 8 Q. Well, yeah, I want -- if they
9 A. I'm not sure what every -- I 9 come to mind, sure. If you have some more.
10 give to a number of organizations. I'm not 10 We have several here. We're in no hurry.
11 a hundred percent confident on where all 11 So, yeah, if some more come to mind. But
12 those organizations stand on the death 12 I'm primarily interested in any group that
13 penalty. 13 takes a public stand in opposition to the
14 Q. And let's make -- what 14 death penalty.
15 organizations are we talking about? 15 A. Not that I'm aware of.
16 A. Every organization I give to? 16 Q. Okay. Now, I think obviously
17 Q. Well, yes, start with the top 17 we're going to get into some ideological
18 ones. 18 grounds, and I don't want you to feel like
19 A. Oh, boy. All right. Here we 19 I'm making a judgment against you or for
20 go. Let's see. I give money to, on a 20 you. It's just I'm just going down some
21 regular basis, Washington University in 21 roads you brought up.
22 St. Louis, the University of Chicago. I 22 So one of the things was the
23 give money to Planned Parenthood. I give 23 sacredness of life. That's a principle or
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1 money to First Christian Church. I give 1 a core value that you hold; is that
2 money to the Christian Church Disciples of 2 correct?
3 Christ. I give money to the Week of 3 MR. McGUIRE: I'm going to
4 Compassion. I give money to the American 4 object to form.
5 Heart Association. I give -- 5 Q. You can answer.
6 Q. What was the Compassion? I'm 6 A. Is sacredness of life --
7 sorry. 7 Q. Yeah.
8 A. The Week of Compassion. 8 A. -- something that I value? Yes,
9 Q. Week of Compassion. 9 I do value the sacredness of life.
10 Okay. What else? 10 Q. You know, and, now, some people
11 A. American Heart Society, American 11 might say, How is that value expressed in
12 Cancer Society, Multiple Sclerosis Society. 12 donating to Planned Parenthood? How would
13 If I go back further -- those I would say 13 you respond to those people that say --
14 are annual gifts. If I go back further, 14 A. Planned Parenthood does very
15 there may be others. I also give as 15 important work for the health care of women
16 friends and family members ask for gifts to 16 whose lives are very valuable and sacred.
17 something that's important to them. 17 Q. And so are you saying you would
18 Q. Okay. 18 not support their -- their abortion work?
19 A. Faith in Action Alabama is 19 It would be the non-abortion work or -- do
20 another one that I've given to recently. 20 you think an abortion is consistent with
21 Q. Do any of these groups -- now, I 21 sacredness of life?
22 didn't mean to cut you off. Is that the 22 A. You've got some time today, huh?
23 ones -- off the top of your head you 23 Q. Yeah, I'm very curious. Yes.

Page 21 Page 23
1 A. Do I have free reign to -- 1 adoption groups, any, for lack of a better

2 Q. Well, I mean, it can go a long 2 word, pro-life groups that offer the same
3 time, but, yeah, I mean, give me your best 3 kind of counseling or assistance?
4 shot. Yeah. 4 A. I'm -- I'm a foster care
5 A. I -- you know, I believe deeply 5 provider -- or I was a foster care
6 in the sacredness of life, and I think we 6 provider. I'm not currently licensed. And
7 are faced with challenges on a regular 7 an adoptive parent myself. So, yes,
8 basis where the life of a mother and the 8 involved with several groups like that. I
9 life of a child can be impacted. And I 9 don't know that I donate regularly to any
10 am -- my personal belief about abortion is 10 of those groups.
11 that it -- in cases where a mother's life 11 Q. All right. Thank you so much.
12 is in danger or a mother's health is in 12 I've -- I find that interesting.
13 danger, it is absolutely appropriate for 13 Have you attended conferences
14 that to be a decision made between a woman 14 seminars, speeches, where the death penalty
15 and her doctor and her -- her family. 15 is -- is opposed -- you know, speakers, the
16 Q. So that wouldn't include, like, 16 curriculum, the purpose of the seminar
17 elective abortions? That -- 17 speech --
18 A. Well, elective abortions do 18 A. Not that I can recall.
19 include situations where the woman's health 19 Q. All right. Now, that would
20 is in danger. 20 be talking about the Reverend Isner as a
21 Q. Uh-huh. But how about people 21 person. How about the Tabitha Isner as
22 for sex selection; you know, I don't want 22 running for congress? Have you made the
23 any more children; I -- I don't want a Down 23 opposition to the death penalty part of
Page 22 Page 24
1 syndrome child; all those choices? 1 your platform?

2 A. Should we go through each one? 2 A. I have not, no.
3 Q. Yeah, well, if you want to. 3 Q. Okay. Is there anything on your
4 A. I don't want to. 4 website, anything in your literature,
5 Q. Okay. Well, how about this? 5 anything in the speeches you have given for
6 Just answer the question the best that you 6 congress where you've publicly opposed the
7 can. 7 death penalty?
8 A. I think that's a decision that 8 A. Not that I'm aware of.
9 is very complicated. The stories that I 9 Q. All right. So what would you
10 know of women in those positions have been 10 say would be the, you know, top three
11 faced with some very difficult decisions. 11 reasons, if you've, you know, formulated
12 And I trust that good, thoughtful decisions 12 those -- I'm sure you have -- for running
13 will be made. So I -- I think it's very 13 for congress?
14 situation specific. And I think Planned 14 A. My reasons for running for
15 Parenthood, in my understanding, offers 15 congress?
16 women with excellent -- excellent health 16 Q. Yeah.
17 care and access to resources to help to 17 A. Yeah. I'm running for congress
18 make those decisions. 18 because I want to bring a better service to
19 Q. Well -- 19 the people of Alabama's 2nd congressional
20 A. And also help in preventing 20 district. I would like to serve them both,
21 unwanted pregnancies, which is the number 21 you know, listening to their real needs --
22 one way to prevent abortion. 22 which is something I think that not all
23 Q. All right. Do you support any 23 representatives do -- really be in the

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1 community and listening to people, 1 A. By a church.

2 brokering partnerships and alliances among 2 Q. I see. And is your husband also
3 people within the community to promote 3 a pastor?
4 economic development. And I think we need 4 A. Yes. He is also ordained, and
5 leaders with integrity and a hard work 5 he is professionally employed as a pastor.
6 ethic to do that kind of work for the 6 Q. And where is he employed?
7 people in this district. 7 A. First Christian Church.
8 Q. Okay. So better service by 8 Q. And that's here in Montgomery?
9 listening, by providing integrity to -- to 9 A. Here in Montgomery.
10 the constituents. 10 Q. How long has he held that
11 All right. In your mind, 11 employment?
12 whether it's a part of a platform, does 12 A. Two years approximately.
13 opposing the death penalty fit within, you 13 Q. And I don't know much about the
14 know, those values you just expressed? 14 Disciples of Christ hierarchy, but is he
15 A. It's not an important -- it's 15 the senior pastor or the primary pastor or
16 not something I have talked about in the 16 assistant --
17 campaign. I don't see it as a key 17 A. He is the senior pastor.
18 component of my campaign. No. 18 Q. And how long have you-all been
19 Q. All right. Let me go back to, 19 married?
20 you know, your address. Who else lives in 20 A. Almost nine years.
21 your home, your personal residence, with 21 Q. And did you-all both attend the
22 you? 22 same seminary?
23 A. I am married to Shane Isner. 23 A. We both attended the University
Page 26 Page 28
1 Q. Shane? 1 of Chicago Divinity School.

2 A. Shane, S-H-A-N-E. 2 Q. At the same time?
3 Q. Okay. 3 A. We overlapped, but, no, did not
4 A. And I have a son. His name is 4 graduate the same year.
5 Tymari, T-Y-M-A-R-I. Tymari Isner. 5 Q. Have you ever been employed
6 Q. And is he the foster child or 6 professionally as a pastor?
7 adopted child -- 7 A. I have -- I did internships
8 A. Yes. Yes. We adopted him. 8 at -- internships, fellowships, never as a
9 Q. How long has he been adopted? 9 full-time permanent employee.
10 A. He was adopted in May of 2017. 10 Q. Okay. Was that here in
11 Q. Now, professionally you are a 11 Montgomery, or where was that?
12 reverend? 12 A. Okay. I have served at Iglesia
13 A. Not professionally. 13 Del Pueblo. That's a Christian church,
14 Q. Okay. So tell me what that 14 Iglesia Del Pueblo Christian Church, in
15 prefix means when you attach it to your 15 Hammond, Indiana. And at Beargrass -- it's
16 name, to you. 16 all one word -- B-E-A-R-G-R-A-S-S --
17 A. Yes. I am ordained by the 17 Christian Church, Louisville, Kentucky.
18 Christian Church Disciples of Christ. 18 Q. All right. Those were
19 Q. And so if you -- if you say "not 19 internships you told me?
20 professionally," it means you're not 20 A. Yes.
21 employed at the time? 21 Q. Okay. Have you held any other
22 A. I'm not employed as a -- 22 positions or worked in any other
23 Q. By a church? 23 occupations since your graduation from

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1 seminary? 1 And if you were a seminary, you would also,

2 A. Yes. I have been -- 2 in most of cases, work towards a master of
3 Q. Where have you been employed? 3 divinity. So --
4 A. I have been employed at Child 4 Q. So it's the same degree?
5 Trends. 5 A. Same degree.
6 Q. And where is that? 6 Q. How long is that program?
7 A. Well, that's a D.C.-based 7 A. You -- typically three years.
8 organization, but I worked in the 8 Q. That's how long you took?
9 Minneapolis office. 9 A. I did a master of public policy
10 Q. What is Child Trends? 10 at the same time.
11 A. It's a national research 11 Q. I see.
12 organization. They conduct research on 12 A. So it took four years to
13 children at all ages and stages. 13 complete two degrees.
14 Q. Okay. So what was your title at 14 Q. And when did you graduate from
15 that? 15 the University of Chicago?
16 A. Research analyst. 16 A. 2009.
17 Q. Research analyst? 17 Q. Okay. Is there, like I said,
18 A. And then senior research 18 any other employment that you've had
19 analyst. 19 besides Child Trends since you graduated?
20 Q. How long did you work for Child 20 A. Yes. I then worked at the State
21 Trends? 21 of Minnesota Department of Human Services.
22 A. Three and a half years 22 Q. And what did you do there?
23 approximately. I'm throwing in 23 A. I was the child care strategic
Page 30 Page 32
1 "approximately." 1 planning specialist.

2 Q. Okay. Okay. After that, where 2 Q. How long were you there?
3 else have you been employed since you 3 A. I was there for four years.
4 graduated from seminary besides those -- 4 Q. All right. Any other employment
5 A. Divinity school. 5 you've had since divinity school?
6 Q. Divinity school. 6 A. Yes. I am currently employed at
7 You were employed there as well? 7 New World Now, LLC. Okay.
8 A. No. No -- 8 Q. Okay. And how long have you
9 Q. I'm sorry. 9 been employed by New World Now?
10 A. -- I'm saying I did not go to a 10 A. About two years.
11 seminary. I went to a divinity school. 11 Q. And what is your title?
12 Q. I'm not sure I know the 12 A. Business analyst.
13 difference. Tell me the difference. 13 Q. And what does New World Now do?
14 A. It has to do with how the board 14 A. It's a software company.
15 of directors -- who sits on the board of 15 Q. Do you work online, or is there
16 directors for the institution of higher ed. 16 a physical address here in Montgomery?
17 Q. So the curriculum is basically 17 A. No, I work from home online.
18 the same? It's just the setup of the 18 They're located in Milwaukee.
19 school? Is that -- 19 Q. All right. Any other employment
20 A. Curriculum varies widely from 20 that you can recall you've had since
21 school to school. But it does produce a 21 divinity school?
22 master of divinity, so I have a master of 22 A. I worked as an independent
23 divinity from the University of Chicago. 23 contractor, independent consultant.

Page 33 Page 35
1 Q. Okay. Do you still do that, or 1 Q. And what were your positions at

2 that's previously? 2 those places?
3 A. I have not lately. 3 A. At Washington University in
4 Q. And what kind of consulting did 4 St. Louis, I was the assistant coordinator
5 you do? 5 for community service and women's programs
6 A. I did strategic planning, 6 for one year, and then I worked for
7 program evaluation. There should probably 7 approximately one year at the International
8 be an "and" in there. Strategic planning 8 Institute as a development and
9 and program evaluation. 9 communications specialist, and then I
10 Q. And how long have you been 10 returned to the University as special
11 doing -- or did you do that consulting? 11 assistant for special programs, or
12 A. On and off for about five years. 12 something like that.
13 Q. All right. Any other employment 13 Q. All right. And so what you
14 that you've had since divinity school? 14 described in the last few minutes is pretty
15 A. No. 15 much your education and employment history.
16 Q. And if you recall something 16 Would that be fair?
17 later on, just say, I remember this. I'll 17 Please say yes.
18 plug it in. 18 A. Yes. Yes, that is the gist of
19 Did you go straight to divinity 19 it.
20 school from college, or did you take some 20 Q. Okay. Thank you. In any of the
21 years off in between? 21 times you've worked as a consultant or in
22 A. I took some years off in 22 these groups, have you ever been called
23 between. 23 upon to work as a death penalty opponent or
Page 34 Page 36
1 Q. Where did you go to college? 1 in coordination with others opposing the

2 A. I went to Washington University 2 death penalty?
3 in St. Louis. 3 A. No.
4 Q. And what was your degree there? 4 Q. All right. What kinds of social
5 A. I had a -- dual majors in -- 5 media would you be involved in -- is that
6 have to think about this -- it feels like a 6 the right word -- use?
7 long time ago -- in psychology, and the 7 A. Yes. I use Facebook. I use
8 second major was in philosophy, 8 Twitter. I have dabbled in Snapchat
9 neuroscience, and psychology. 9 unsuccessfully. I have -- I have -- I have
10 Q. All right. When did you 10 an account on Instagram, not that I really
11 graduate from there approximately? 11 know a lot about that one.
12 A. 2003. 12 Q. Have you ever used any of those
13 Q. When did you start divinity 13 platforms to oppose the death penalty?
14 school? 14 A. Not that I can recall, but I am
15 A. 2005. 15 a frequent user so it's hard to remember
16 Q. Okay. And so were you employed 16 every post ever in time.
17 in the interim two years? 17 Q. All right. Have you used any of
18 A. Yes. 18 those platforms to provide information
19 Q. Where were you employed? 19 about the death penalty?
20 A. I was employed at Washington 20 A. Yes.
21 University in St. Louis, and then at the 21 Q. All right. So, in general,
22 International Institute, then again at 22 describe how you've used it in that sense.
23 Washington University in St. Louis. 23 A. I tweet regularly, use Twitter,

Page 37 Page 39
1 to communicate about executions that I'm 1 does that concern, as expressed in these
2 aware of and to pray over those executions 2 accounts, go into all losses of human life?
3 and invite others to join me in prayer. 3 A. Yes, I pray about other kinds of
4 Q. So I asked this earlier, and I 4 losses as well.
5 might want you to clarify it or repeat what 5 Q. And would that be evident in
6 you said. You want to provide information 6 reviewing this social media you've just
7 about the death penalty and pray over 7 described?
8 aspects of the death penalty, but not 8 A. Huh, it -- can you clarify what
9 necessarily in opposition to it? Is that 9 you're asking?
10 fair to say or not? 10 Q. Yes. And would the social
11 A. I want to pray over the process. 11 media -- a review of the social media
12 It is the law of the land. It concerns me, 12 accounts you've just described, would that
13 and so I pray over it. 13 show a focus on the death penalty in terms
14 Q. All right. And is that why you 14 of losses of life, or would it show just as
15 recently filed this request for open 15 much concern over other examples of human
16 records that's the subject of this 16 life being lost or taken?
17 litigation? 17 A. I've never done an audit of my
18 A. I filed this because I have 18 own social media to evaluate the percent of
19 begun to spend more of my prayer life on 19 my tweets which cover various topics. I
20 the death penalty and found that the death 20 feel confident that my social media does
21 penalty protocol was not available for 21 not reflect everything about my life nor
22 Alabama, and I would like for it to be. 22 everything about what I care about. I give
23 Q. All right. Are there any other 23 to a lot of organizations, for example,
Page 38 Page 40
1 reasons that you filed this opens record 1 that are on that list, and I don't tweet
2 request in this case? 2 about all of them. I don't Facebook about
3 A. No. 3 all of them. I don't Instagram about all
4 Q. All right. You have used the 4 of them.
5 word "concerns" several times with respect 5 Q. Right.
6 to the death penalty. You have concerns. 6 A. So I wouldn't -- I have never
7 And please elaborate what those concerns 7 before felt obligated to have my social
8 are, and why it's concerning to you? 8 media reflect -- be a perfect reflection of
9 A. Any time a human life is taken 9 the things that I care about.
10 I'm concerned. And I think that people 10 Q. Right. I get what you're
11 should be paying attention, praying that 11 saying. But I'm just saying, given all
12 it's done with discernment, with care, with 12 that, you never audit it, and you never
13 love. It's no small matter to take a 13 felt a duty to make the amount of social
14 person's life, no matter what they've been 14 media output equal everything you think. I
15 convicted of doing. And I think the very 15 get that.
16 least we can do is be open about what's 16 A. Yes.
17 happening and prayerful. It's being done 17 Q. I'm just saying if one were to
18 in my name as a citizen of the state of 18 only look at your social media output -- if
19 Alabama; the least I can do is pray. 19 I can use that word -- would one see it's a
20 Q. All right. And this concern for 20 lot about the death penalty and death
21 human life, if I understand, you feel 21 penalty protocols?
22 called to focus particularly on the 22 A. No, one would not say that.
23 administration of the death penalty, or 23 Q. So what kind of other subjects

Page 41 Page 43
1 would your social media output cover? 1 A. Sort of, yes.

2 A. Early childhood education, home 2 Q. Okay. Is there -- I'm assuming
3 visiting, foster care, adoptive care, 3 the Disciples of Christ is a Christian
4 criminal justice reform, civil asset 4 denomination?
5 forfeiture, mass incarceration, racism, 5 A. The Christian Church Disciples
6 sexism, government transparency, health 6 of Christ.
7 care, education, infrastructure, cute stuff 7 Q. And I may not say that -- the
8 my kid has done, a variety. 8 Christian Church Disciples of Christ is a
9 Q. All right. Out of those 9 Christian denomination?
10 different subjects, would you say the most 10 A. Yes, the Christian Church is a
11 frequently posted about -- if that's the 11 Christian denomination.
12 right word -- subject would be the death 12 Q. Yes. And it is, to some extent,
13 penalty and protocols and praying over 13 based on the holy scriptures, the Bible, as
14 that? 14 we refer to it, correct?
15 A. I don't know. I suppose it 15 A. Yes, that is one of the things.
16 depends on how you analyze the data. It 16 Q. So what is the biblical basis
17 would certainly not amount to more than 25 17 for, you know, the need to -- I know there
18 percent of my tweets. 18 wasn't Twitter in the Bible, but praying
19 Q. All right. 19 this way publicly about a matter you have
20 A. I don't think it's that high, 20 concern about? Is there a passage or a
21 but that's a nice safe number. It's 21 foundation in scripture that you say this
22 definitely lower than that. 22 is what this is based upon?
23 Q. Okay. Now we're going to 23 A. My -- my tradition, the
Page 42 Page 44
1 necessarily have to get into issues of 1 Christian Church Disciples of Christ,

2 theology just so I can understand where 2 generally recognizes four sources of
3 you're coming from. If you could explain 3 inspiration and guidance. And scripture is
4 the connection between praying and 4 one of them, but I'm also -- we are also
5 tweeting. And I think Judge Hardwick 5 guided by other forms of --
6 talked a little bit about that, but I want 6 Q. What are those four items? Be a
7 to hear it from you. What is your 7 good place a start.
8 understanding of praying and using your 8 A. Let's see if I can do them off
9 Twitter account? 9 the top of my head. Scripture, tradition,
10 A. If done in an attitude of 10 revelation, and I want to say it's
11 prayer, Twitter can be prayer. 11 inspiration. I'm not --
12 Q. All right. And there's 12 Q. All right. Of those four -- and
13 certainly private prayer and public prayer. 13 it may come to -- this is not meant to be a
14 Would you agree with that? 14 theology test. And so if it comes to you,
15 A. There are many forms of prayer. 15 it's fine. You haven't missed points. I'm
16 Q. And if you just use those 16 just trying to understand.
17 general broad categories, you would call 17 Of those four, three or four,
18 that public prayer, right? 18 explain to me how that, you know, informs
19 A. Yes. 19 your need or calling to pray publicly on
20 Q. Others can read it and -- and, I 20 Twitter about this issue.
21 guess, participate, if you call reading and 21 A. My -- my tradition -- so I would
22 then commenting? I guess you -- you get 22 say this comes from tradition. And in the
23 comments back on a Twitter account? 23 Christian tradition, public prayer is well

Page 45 Page 47
1 recognized as part of our tradition as 1 shot. It talks about at this time of the
2 demonstrated by great leaders of the past. 2 day on the day of -- on the day of an
3 It's a very common expression of 3 execution, or leading up to an execution,
4 faithfulness. 4 now is the time when the inmate is meeting
5 Q. Give me some examples. I'm sure 5 with their family. Let us pray for that
6 you're right. I'm just -- help me out 6 meeting to include closure and give the
7 here. Flesh this out. 7 family what they need and that inmate what
8 A. Martin Luther, Martin Luther 8 they need and may all find peace in this
9 King; the mystics wrote in books; the -- 9 final familial reunion. I don't, in the
10 the fathers of our faith wrote books, which 10 case of Alabama, know when that happens or
11 I would argue is the precursor to Twitter. 11 how that happens. So I pray with much less
12 Q. Okay. 12 specificity when I pray about Alabama
13 A. I think there's lots of writing 13 executions.
14 about religion and what our concerns are. 14 Q. What have you done to learn
15 Large books of prayer, large books of 15 about Alabama's death penalty protocols,
16 praise, large books of reflections. 16 the specifics that you just described?
17 Q. All right. 17 A. I have Googled and read articles
18 A. Long standing tradition of 18 about Alabama's death penalty protocol.
19 writing publicly about your faith. 19 And when I was unable to get as much
20 Q. All right. And how long have 20 information as I was able to find for other
21 you had a Twitter account? 21 states, that's when I filed the request.
22 A. I don't know. 22 Q. Have you interviewed anyone
23 Q. Several years? I mean, not one 23 about the death penalty in Alabama
Page 46 Page 48
1 year? Give me a ballpark. I'm not going 1 procedures or protocols?

2 to hold you to it. 2 A. I have not, no.
3 A. Three to five years. 3 Q. Is there anything preventing you
4 Q. Three to five. Good enough. 4 from doing that?
5 A. Ballpark. 5 A. Time. I'm a busy woman.
6 Q. You would agree with me that 6 Q. Well, this lawsuit takes time?
7 over that time you have used your Twitter 7 A. I -- more than I expected.
8 account to pray over these issues? 8 Q. Right. And maybe money -- maybe
9 A. Yes. 9 Mitch is doing this free. It would take
10 Q. So there's nothing that's 10 time to review the protocols?
11 prevented you from using your Twitter 11 A. Well, I can do -- I can do that
12 account in the way you have described, to 12 at 2 a.m. when I can't sleep, but I can't
13 pray over matters of concern publicly, 13 interview people at 2 a.m., which is when I
14 specifically the death penalty protocol of 14 have free time.
15 Alabama? 15 Q. All right. If you were to get
16 A. I have not been able to pray 16 the protocols that you've requested from
17 with any specificity over the death penalty 17 Judge Hardwick in this case, would your
18 protocol in Alabama. In other states the 18 plan be to use them in a -- to use them in
19 death penalty protocol is publicly 19 a similar fashion as you have used the
20 available. And in those cases, my tweets 20 protocols of other states?
21 often include a specific reference to a 21 A. Yes.
22 specific part of that state's protocol 22 Q. Which could include screen
23 where I can say, On page 3 here's a screen 23 shotting parts of those protocols, share

Page 49 Page 51
1 them on your Twitter account, and then, as 1 I'm not very good at coming up with names
2 you said, praying over them, or with them, 2 like that off the top of my head.
3 with your Twitter followers? 3 Q. I understand. Have you read
4 A. Yes. 4 court opinions that describe Alabama's
5 Q. How big is your Twitter account 5 protocol or drugs they use?
6 roughly? 6 A. No, I have not.
7 A. 2,100 followers approximately. 7 Q. And why have you not, consistent
8 Q. All right. Have you had any 8 with this need for education and
9 pushback from other states that you've used 9 information that you want to share and --
10 screen shots or examples of protocols 10 and pray over?
11 from -- other states, any pushback from 11 A. Because it -- it seems to me
12 them? Any opposition? 12 that the appropriate course of action was
13 A. No. 13 simply to go to the source and ask for the
14 Q. Any controversy? 14 information.
15 A. No, I have not received any 15 Q. So even though the information
16 pushback from other states. 16 may be available from other sources, your
17 Q. Have you tried to get the 17 choice is to go to seek Alabama's protocols
18 protocols from any state and been denied 18 from them?
19 them, other than Alabama? 19 A. Based on my Googling -- I'm not
20 A. I don't have standing in any 20 a legal scholar. I Googled like a regular
21 state but Alabama. 21 person and was not able to find the
22 Q. Have you tried? 22 information that I was looking for, so I
23 A. No. 23 asked the State for that information.
Page 50 Page 52
1 Q. Okay. 1 Q. I don't know if you're aware,

2 A. No, I have not tried. 2 but 11th Circuit Court opinions are
3 Q. Do you know if some other 3 available on Google on the internet?
4 states, besides Alabama, are protective of 4 A. I was not aware.
5 their protocols and procedures concerning 5 Q. Okay. Well, they are. In the
6 the death penalty? 6 time you worked as a research analyst, were
7 A. My understanding is, of the 7 you -- were you not aware of how to find
8 states that regularly execute people, 8 legal documents in cases on the internet?
9 Alabama is the only one that does not 9 A. No. That's not the kind of
10 provide a public protocol. 10 research that I did.
11 Q. Do you know what Alabama uses in 11 Q. All right. Let's skip back to
12 terms of drugs administered in the death 12 your employment. Is there ever a time that
13 penalty process? 13 you have been fired or discharged from
14 A. Only what I have read in news 14 employment?
15 articles. 15 A. Not that I'm aware of, no.
16 Q. And what have you read? 16 Q. In each case you left because
17 A. It -- let's see if I can 17 you found a different job or wanted to
18 remember the names. They're difficult 18 move?
19 names. 19 A. Yes.
20 Q. They are. 20 Q. Was your own choice?
21 A. Midazolam is the one that I hear 21 A. Yes.
22 about the most frequently, I think, in news 22 Q. Okay. Has any person or group
23 articles in Alabama. Pentobarbital. But 23 or organization asked you to assist them in

Page 53 Page 55
1 getting information on Alabama's death 1 look through it and your attorney can. Not
2 penalty protocols? 2 a big deal, but that's what we're referring
3 A. No. 3 to.
4 Q. Are you cooperating with any 4 That's Exhibit 1. That's the
5 person or group in getting, other than your 5 summons and complaint in this case with
6 attorney, the Alabama death penalty 6 some exhibits attached to the complaint,
7 protocols? 7 including her open records request. That
8 A. No. 8 will be Defendant's 1.
9 Q. Other than your Twitter account, 9 Have you had a chance to look at
10 do you have plans to provide them, any 10 that page? I don't -- I didn't say you got
11 person or group, death penalty opponent, 11 to memorize all of that.
12 with the information you might get from the 12 My question, though, is you will
13 death penalty protocol request? 13 agree with me that your records request
14 A. I don't know what I would do. 14 contains a lot more than the actual
15 I -- I don't intend to -- I don't have a 15 protocol eleven other items listed on that
16 grand plan. 16 page, correct?
17 Q. So, but the plan you do have, 17 A. Correct.
18 just to sum up what you said earlier, was 18 Q. And my question to you, have you
19 posting on the Twitter account and 19 sought any of that information from other
20 praying -- 20 states?
21 A. Yes. 21 A. I'm only in residence in
22 Q. -- for certain aspects and 22 Alabama.
23 sharing that information and those prayers 23 Q. All right. Let me ask it again.
Page 54 Page 56
1 with your Twitter followers? 1 Have you -- I know what you're saying, but,
2 A. Yes. I think it's a safe 2 I mean, just say it in a way that responds
3 assumption that I would continue to tweet 3 to my question.
4 the way that I have been tweeting about the 4 Have you requested any of that
5 Alabama execution protocol. 5 other information, items 2 through 12, from
6 Q. All right. In your public 6 other states?
7 records request, the first item listed is 7 A. No, I have not.
8 the current execution protocol, correct? 8 Q. And do you know if that
9 You remember that? 9 information, 2 through 12, is available
10 A. I -- I am not an expert on that 10 without restriction in other states?
11 document, but -- 11 A. Say it again, please.
12 Q. But, anyway, there was also -- 12 Q. Okay. Let me set it up a little
13 A. Sounds right. 13 bit like this -- but I'll get there. Your
14 Q. There was 11 other items on that 14 Twitter account has contained screen shots
15 list, and -- and I can read the whole 15 of protocol in other states, correct?
16 thing, or I can show you a summary of it. 16 A. Yes, it has.
17 MR. HARMON: Do you want to 17 Q. That you've shared with your
18 mark this as Exhibit 1? 18 Twitter followers, and you've prayed over
19 (Defendant's Exhibit 1 was 19 those aspects of other states' protocol,
20 marked for identification.) 20 correct?
21 Q. This is attached to the 21 A. Yes.
22 complaint in this case, and you can 22 Q. And my question is have you --
23 certainly look through it and feel free to 23 are you aware if those other states provide

Page 57 Page 59
1 the information described in paragraphs 2 1 checks and reporting on the results of such
2 through 12 on your list of documents 2 consciousness checks, in some states those
3 requested? 3 are details included in a protocol and in
4 A. Some of this information is 4 some states they are not. I have tweeted
5 available from other states as part of, or 5 about both training and about consciousness
6 separate from, their protocol. 6 checks.
7 Q. And if you haven't requested it, 7 Q. All right.
8 how would you know that -- the answer to 8 A. As an example.
9 that question? 9 Q. All right. How about let's go
10 A. There are websites where you can 10 to number 2 and 3 in that same list? A lot
11 obtain that information. 11 about receipts, purchase orders, packing
12 Q. And you're familiar enough with 12 slips. Are those something that you've
13 those websites to say some of this 13 seen are available on these websites from
14 information is available on those websites? 14 other states?
15 A. Yes. Yes. 15 A. No, I don't believe I've seen
16 Q. Okay. Have you ever used any of 16 any receipts or purchase orders.
17 that information from other states, other 17 Q. How would you pray -- how would
18 than the protocol, in your Twitter account 18 you use that? How would you intend to use
19 and, you know, the Twitter prayers? 19 that on your Twitter account and your
20 A. I have tweeted about many 20 Twitter prayers -- receipts, order forms,
21 things. Can you say more specifically what 21 purchase orders, checks, packing slips, et
22 you're asking? 22 cetera, described in items 2 and 3?
23 Q. Sure. We have described your 23 A. Answering that would be
Page 58 Page 60
1 interest in getting knowledge about the 1 conjecture.

2 death penalty protocols and then praying 2 Q. Okay. Well, that's what you're
3 over those protocols and how you've done 3 here for. Do the best you can. I mean,
4 that in other states. And we've described 4 you -- you've requested --
5 earlier how you use screen shots from those 5 A. Would you like me to tell you --
6 protocols in your Twitter account. That's 6 is that, like, tell you a story about what
7 the foundation. That's already been 7 might happen?
8 established. Did I say it correctly? 8 Q. No. I would not say tell a
9 A. With all of that -- 9 story. I would say you have requested
10 Q. Yes. What I did say -- 10 these documents. And I'm asking when you
11 A. That was generally correct, yes. 11 requested them, I'm assuming you had an
12 Q. So my question is have you used 12 intent or a purpose, a plan to use them.
13 other information, other than the protocols 13 And now you might say, I didn't have a
14 from other states relating to the death 14 plan. Or you can say, Oh, I had a plan.
15 penalty, in your Twitter account? 15 Here it is. So that's what I'm getting at.
16 A. I do not recall specifically. I 16 Was there a plan to use the
17 do know that in some states, some of these 17 items described in 2 and 3? And, if so,
18 other details are included in the protocol 18 what was the plan?
19 and in some states they're not included in 19 A. I have no plan other than I like
20 the protocol. For example, number 12, 20 to get details when I can get them and see
21 about training for conducting executions by 21 what they inspire.
22 lethal injection and/or electrocution, 22 Q. All right. Same would be true
23 including the conducting of consciousness 23 for the other items? We won't go through

Page 61 Page 63
1 them one by one, unless you want to. Would 1 for murder victims as well. Absolutely.
2 the same be true in the other ones? Your 2 Q. All right. Have you ever taken
3 main request is number 1, the current 3 steps to -- harass may be pejorative --
4 execution protocol. But 2 through 12 not a 4 let's say it this way. Have you ever taken
5 specific plan, you just kind of want to, 5 steps to pressure a drug supplier or a drug
6 like you say, get them and see where it 6 manufacturer to stop providing drugs used
7 goes, what inspires? 7 in a death penalty protocol?
8 MR. McGUIRE: I'm going to 8 A. No.
9 object to form on that. You can probably 9 Q. Ever written letters like that?
10 ask each one, but I don't think it's fair 10 A. No.
11 to kind of lump them all together. 11 Q. Made public statements or used
12 MR. HARMON: Okay. That's 12 your Twitter account to try to expose drug
13 fair. 13 manufacturers or drug suppliers?
14 Q. How about 4? Do you have a 14 A. Not that I can recall.
15 specific plan on how you would use 15 Q. Okay. Let's look at number 5:
16 information on the inventories and logs for 16 Maintenance records for the equipment used.
17 lethal injection drugs described in number 17 And did you have a specific plan on how you
18 4? 18 would use that information in your -- if
19 A. Conjecture. I can imagine. 19 you were provided it?
20 Knowing when a drug was going to expire 20 A. I would need to see the
21 would change the way that I might pray 21 information to make a specific plan, but I
22 about it. Knowing who handles those drugs. 22 can imagine that I would also pray for
23 I myself wouldn't want to handle such 23 those who maintain that equipment, for
Page 62 Page 64
1 drugs, drugs that I knew were going to be 1 those who have to wipe down a bed after
2 used to kill a person. So I would pray for 2 it's been used to execute a person, for
3 those who are handling those drugs and for 3 those who have to clean and dispose of
4 their peace of mind and their understanding 4 equipment before or after an execution. I
5 and reflection on the work that they're a 5 would pray for those people as well.
6 part of. 6 Q. Okay. I like the way you just
7 Q. So it sounds like you have 7 said that. Why couldn't you pray for those
8 compassion for the person/people carrying 8 people and what they do just like you just
9 out the death penalty protocols? 9 said it? I mean, you said it beautifully.
10 A. I have deep, deep compassion for 10 I want to pray for those people and -- as
11 those people. 11 they wipe down the equipment and they
12 Q. And the same would be true for 12 maintain the equipment. I mean, what's --
13 the victims of the -- of the person that's 13 I guess why would you need more?
14 been given the death penalty? 14 A. I can pray for cancer, but
15 A. The inmate who is being 15 praying for my friend Melissa who died of
16 executed, I also have compassion for their 16 cancer is a more powerful prayer.
17 soul. 17 Q. Right, I get that. But you know
18 Q. Yeah, but the victims as well? 18 the people -- name of the person on death
19 The victims -- his victims? 19 row that's being executed, right?
20 A. The people who were -- who were 20 A. Yes.
21 murdered, you're assuming -- 21 Q. And there's lots of publicly
22 Q. Yes. 22 available information on that person,
23 A. Yes. Yes, I also pray for -- 23 correct?

Page 65 Page 67
1 A. Usually, yes. 1 you can get, right?

2 Q. And I'm assuming you have 2 A. Is that a question?
3 learned a lot about the death penalty 3 Q. Yes. You understand that there
4 process even without this information? 4 is a limit to the degree and specificity of
5 A. Some. 5 the information that you can -- you can
6 Q. And so I guess what I'm trying 6 get?
7 to understand is why -- why do you need 7 A. I agree that government often
8 more to pray for the person, pray for the 8 limits the amount of information that they
9 equipment? Why do you need names of the 9 make available.
10 people or names of the equipment or how 10 Q. All right. I guess what I'm
11 it's wiped down or how it's cleaned? I 11 trying to say is: Even if you -- do you
12 mean, if you can, I guess, answer that 12 need to know the name of the person
13 question. Why is that necessary for you to 13 administering the certain elements of the
14 pray with enough specificity? 14 protocol?
15 A. Asking a person to describe 15 A. I understand that it would be
16 their spiritual life in a deposition is 16 inappropriate to violate a person's privacy
17 difficult. 17 by giving me their name.
18 Q. I understand. 18 Q. So there are limits to the
19 A. I'm an intellectual type. I 19 specificity -- specificity of the
20 went to schools like the University of 20 information you want and can use? That
21 Chicago and Washington University in 21 would be one limit is the person's
22 St. Louis. 22 identity, name, address? You agree with
23 Q. I can tell. 23 that?
Page 66 Page 68
1 A. I know best how to engage with a 1 A. I -- I do respect

2 subject by studying it. I feel it most 2 confidentiality and the privacy.
3 deeply in my heart, want to know the 3 Q. So you can pray even with
4 details, the specifics. I like to know not 4 certain limits?
5 just a friend of mine has cancer but what 5 A. I can pray in all things at all
6 kind and what treatment she'll get. I like 6 times. How I like to pray is another
7 the details. For me, they make it real in 7 matter.
8 a way that the details -- that without the 8 Q. Okay.
9 details it's not the same. It's easier to 9 A. What I would prefer and what I'm
10 blow it off. It's easier to swipe it 10 requesting remains unchanged.
11 aside. The details for me make it real, 11 Q. So you would -- you would prefer
12 and I want my prayers to be based on me 12 to have the personal names and information,
13 having spent the time studying. I could 13 but you're going to respect their
14 pray for Jesus generally, but I study the 14 confidentiality?
15 scriptures, even though I have read them 15 A. Yes.
16 before, I study them again and again and 16 Q. Okay. But I guess what I'm
17 look back to see if there's something I 17 trying to say, there are going to be limits
18 didn't see before. Because the study is an 18 to the information you get. There's --
19 important part of my scriptural practice -- 19 there's limits to what you get from other
20 of my spiritual practice. 20 states. I mean, like I say, you -- there
21 Q. All right. That's interesting. 21 are websites, you said earlier, with a lot
22 But you agree there's a -- there's always 22 of information on the death penalty in
23 going to be a limit to the information that 23 other states, but you haven't included all

Page 69 Page 71
1 the information in your Twitter account or 1 potentially between intended use and use in
2 your Twitter? 2 this case. I'd be looking at side effects.
3 A. Can you clarify what the 3 I'd be looking to learn as much as I can
4 question is? 4 about -- about those drugs.
5 Q. Yes. You described earlier in 5 Q. Now, you've already mentioned
6 other states there's death penalty 6 you know the names of the drugs, you can do
7 protocols, you know, are available, and 7 a lot of information review, even without
8 there's also websites that give you a lot 8 these labels? You agree with that?
9 more information about the death penalty 9 A. I -- I have not attempted that
10 administration in those states. You told 10 kind of research, so...
11 me that earlier, correct? That's what you 11 Q. Why would you not have attempted
12 told me? 12 that research? That is available, right?
13 A. Yes. There are websites where 13 You have the name of the drug? And if we
14 you can get some information about the 14 were to Google -- put those names in
15 death penalty. 15 Google, we could find a lot of information,
16 Q. That's right. And you said you 16 which would mean, the way I understand you
17 had made no effort to get more details, 17 described your prayer life, then that's a
18 made more requests in those states, 18 lot of praying and delving into the details
19 correct? 19 that you could do, correct?
20 A. I did not make requests in other 20 A. Yes.
21 states. My understanding is that I 21 Q. But you have chosen not to? Is
22 wouldn't have standing. 22 that what you just told me? Did I misstate
23 Q. But you didn't make any 23 that?
Page 70 Page 72
1 attempts? 1 A. I have not invested my energy

2 A. No, sir. 2 into that research.
3 Q. Okay. But you were still able 3 Q. Okay. Number 7: Any DEA -- I
4 to pray for the -- with the information you 4 guess that's Drug Enforcement Agency -- DEA
5 had, you are able to pray and do -- 5 licenses authorizing DOC to possess, order,
6 A. I can pray blindfolded, sir. 6 and administer these drugs.
7 Q. I respect that. So the answer 7 How would -- was there a planned
8 is, yes, you were able to pray over those 8 use for number 7 when you made this
9 states even with limited information? 9 request?
10 A. Yes. 10 A. No, I do not have a planned use.
11 Q. Okay. All right. Let's go to 11 Q. Okay. Number 8: Prescriptions
12 number 6: Writings of any kind, included, 12 written for the purposes of ordering drugs
13 but not limited to, manufacturing labels, 13 and other substances used in the execution.
14 packaging, and inserts. 14 Any planned use for that?
15 Okay. What was your planned use 15 A. No, no planned use.
16 for that request, number 6? 16 Q. Okay. How about correspondence,
17 A. I do not have a planned use. I 17 internal or external, about attempts to
18 can conjecture if you'd like. 18 obtain drugs used for execution? Any
19 Q. Well, you can. Yes. Okay, you 19 planned use for that?
20 don't have a plan. What do you think you 20 A. No, no distant plan for that.
21 would use it for if you got it? 21 Q. How about the DEA 222 forms used
22 A. I would review how the drugs are 22 to, I guess, obtain and request drugs? Any
23 to be used. I would review the difference 23 planned use for number 10?

Page 73 Page 75
1 A. No, no plan. 1 Q. Okay. Let's go back to the need

2 Q. Okay. 11: Records of any 2 to pray with specificity, and I certainly
3 budget items specific to executions and any 3 get your personal motivation and your
4 reports concerning the dispensation of 4 desire, your interest in that. But let me
5 funds allocated to the execution process. 5 just go -- step back to, again, those
6 Any planned use for that information? 6 sources, and let's start with scripture,
7 A. No specific plans. Budgets are 7 because that's something I'm a little more
8 moral documents, so I would certainly be 8 familiar with. And then we can go to
9 very interested to see. 9 tradition and then can go to --
10 Q. All right. And number 12: All 10 A. Revelation.
11 information and records concerning training 11 Q. Are there passages in scripture
12 about lethal injection and/or 12 where you would say it is commanded that if
13 electrocution -- consciousness checks and 13 you pray -- you pray with specificity, and
14 reporting of consciousness checks. Any 14 not just in general? Can you think of any?
15 planned use for that? 15 A. My desire to pray this way is
16 A. I have tweeted about similar 16 based on my tradition.
17 details in other states' execution 17 Q. Yes. You told me that. I'm
18 protocols, so I would plan to tweet 18 going to tradition. Just saying there
19 similarly about these. 19 might not be any that come to mind. That's
20 Q. All right. Now, most all these 20 fine. I want each aspect about how you
21 in items 2 through 12 contain the date 21 told me you -- authority --
22 September 1st, 2014, to the present, or the 22 A. It's just -- it's an exhausting
23 date of the request. How did you choose 23 task to think about discussing scripture
Page 74 Page 76
1 that date? 1 with you, but let's do it.

2 A. I asked for the advice of my 2 Q. I'm not sure what that means,
3 lawyer. 3 but --
4 Q. And I don't want to ask that. 4 A. No. I have places to be today.
5 That's attorney/client privilege. But just 5 But we can discuss the Bible, which is an
6 personally that's not a date that -- 6 enormous document. Let's start. So the --
7 there's not a significant -- that date is 7 in the Bible, the prophet tradition is
8 of no significance to you personally? 8 documented in multiple books of the Bible,
9 A. No. I had talked to my lawyer. 9 where the prophets were people who spoke
10 Q. Okay. And -- all right. I mean 10 openly and publicly. They read scripture
11 it's not a date somebody was executed, or 11 in the squares.
12 it's not a date that you're trying to tie 12 Q. All right.
13 into another event? That's what I'm trying 13 A. They prayed in public settings.
14 to get to. 14 Q. I got -- I got the public part,
15 A. No. 15 just to cut you off. I got the public
16 Q. Okay. So it's roughly a 16 part. I got that. I'm talking about
17 three-year period of time. I know it's not 17 the -- is there a command or an example
18 exactly. It's a little less than that. 18 from scripture -- then we can go to
19 Two and a half years. We'll say that. 19 tradition next -- but is there a command in
20 Okay. 20 scripture that to pray you have to have a
21 MR. HARMON: Yes. I move to 21 certain level of specificity and without it
22 admit that first exhibit. 22 you're not accomplishing the prayer?
23 MR. McGUIRE: No objection. 23 A. I am not aware of a scriptural

Page 77 Page 79
1 text that uses the word specificity. 1 teaching of the Christian Church Disciples
2 Q. Well, I didn't -- doesn't 2 of Christ? Omniscient?
3 require that. But you just -- are there 3 A. We leave those sorts of things
4 any scriptures that you point to that you 4 to the individual reader of scripture to
5 feel like are the motivation, inspiration, 5 determine.
6 for you to have such a need for these 6 Q. But certainly the God described
7 details? 7 in those scriptures is an omniscient God?
8 A. It's not based on a particular 8 A. God is often described in
9 text. 9 scripture as omniscient.
10 Q. Okay. And you would agree 10 Q. Which means knows all things, if
11 there's a lots of examples of prophets, of 11 I got my Latin right?
12 men and women in the Bible, who are praying 12 A. Yes.
13 for people that are far away that they know 13 Q. And so if God hears our prayers,
14 very little about, and there's -- is there 14 all prayers, and God knows all things, God
15 any indication that those prayers were not 15 would -- God would know the details of
16 heard or answered in scripture that you 16 these protocols that you want to find out
17 know about? 17 about under that theory. You agree with
18 A. The Bible is an enormous book. 18 that?
19 There are examples of people praying 19 A. Yes, I think God knows how
20 without specificity and people praying with 20 people are killed.
21 specificity throughout the Bible. 21 Q. Okay. And would know every
22 Q. They're both -- 22 detail of these receipts and these
23 A. Every -- 23 protocols, these maintenance records, who's
Page 78 Page 80
1 Q. Every kind of prayer. Right. I 1 doing the maintenance? He -- you can call
2 agree. 2 him a God that knows all those things?
3 I'm just saying you can't point 3 A. I don't know what God knows and
4 me to any injunction, command, decree 4 doesn't know. I'm not going to speak for
5 where, Thou shall not and thou shall, where 5 God.
6 this is -- this kind of level of 6 Q. Huh. I respect that actually.
7 specificity is required? And then we'll go 7 All right. Let's go down to -- the next
8 to tradition next. 8 thing is the tradition. Is there a
9 A. My understanding is that God 9 particular decree, command, is there
10 hears all prayers. 10 anything credal in the Disciples of Christ
11 Q. Okay. 11 Christian Church that expresses this need
12 A. Period. 12 to have specific -- specificity in your
13 Q. So he hears the prayers, even 13 prayers? Do you know?
14 your general prayers? 14 A. We don't have a creed.
15 A. I -- my understanding is that 15 Q. Okay. There was something on
16 God hears all prayers. 16 the -- on the website I looked at. It was
17 Q. All right. And according to 17 very short. And I thought it called it a
18 biblical traditions, I guess God knows all 18 creed?
19 things? 19 A. No.
20 A. Yes. 20 Q. I can pull it up. But anything
21 Q. And I think that's the term 21 that you're familiar with in terms of
22 that -- you correct me if I'm wrong -- 22 church writings -- I don't know if you have
23 omniscient. God is omniscient. Is that a 23 catechisms -- traditions, anything that

Page 81 Page 83
1 would describe what you're talking about 1 Q. Do those appear to be printoffs

2 the need to pray in detail? 2 of portions of your Twitter account?
3 A. The church tradition, I think, 3 A. Yes.
4 is full of examples of people who paid very 4 Q. So you don't deny any of those
5 close attention to very specific events 5 were entries that you personally made at
6 happening in the world and prayed 6 some point?
7 specifically about those things. 7 A. Yes.
8 Q. I'm sure you're right on that. 8 Q. All right. And what is the
9 That's like the prophets we talked about. 9 title of this Twitter account? It's Isner
10 But there are examples -- I'm sure. But 10 for Congress?
11 what I'm asking you are there commands? 11 A. Yes. It's both my personal
12 Are there -- 12 account and my -- I converted my personal
13 A. That's not how a tradition 13 account to be a congressional account.
14 works. 14 Q. Some even though it says "for
15 Q. Okay. Well, are there 15 Congress," you're -- that does not indicate
16 traditions that compel you to conclude, I 16 to you that every tweet is part of your
17 need to pray with this level of 17 congressional campaign? Part of it is a
18 specificity? 18 personal viewpoint as well? Is that what
19 A. I try to follow the example of 19 you're saying?
20 the great leaders within my tradition, and 20 A. Yes. I mean it was my -- it was
21 many of them pray with great specificity in 21 my -- before I ran for congress, it was my
22 public. 22 personal account. So I don't know the
23 MR. HARMON: All right. 23 dates on all of --
Page 82 Page 84
1 Let's take a break. I think I need to use 1 Q. Sure.

2 the restroom as well. 2 A. I haven't checked closely, but
3 MR. McGUIRE: Sure. 3 some of these were done before I was
4 2:36 p.m. 4 running for congress. So they originally
5 (Short break.) 5 would have been tweeted under plain old me.
6 2:45 p.m. 6 Q. I don't see any of them -- at
7 Q. Next thing, I'm going to show 7 the top it says: Isner for Congress. So
8 you what I've marked or what we marked as 8 they all say that. I guess what I'm
9 Exhibit 2. And it looks to be printoffs 9 asking --
10 from some of your Twitter account. And if 10 A. It must have been printed
11 you will just a take a minute and thumb 11 recently. I mean in the last -- since
12 through that and just -- I'm not going to 12 October.
13 ask you a question about them all. But 13 Q. All right. So even if you print
14 just if -- if there's anything that you see 14 off prior tweets, if you change the name of
15 that, No, this is not mine or how it got 15 the account, it's going to all say --
16 here or whatever. I purport to you it came 16 A. Correct.
17 off your printoffs from your Twitter 17 Q. -- Isner for Congress?
18 account. 18 A. Some people change the name of
19 (Defendant's Exhibit 2 was 19 their account on a daily basis to reflect
20 marked for identification.) 20 current events.
21 Q. You've had a chance to look at 21 Q. I see. But when you print them,
22 Exhibit 2? 22 that's what's going to show the current
23 A. Yes. 23 account title?

Page 85 Page 87
1 A. As of the time you printed, yes. 1 death penalty.

2 Q. All right. And I do have -- you 2 Q. How many states practice the
3 might want to just thumb through with us, 3 death penalty in that sentence?
4 and I will refer to different pages. Now, 4 A. It's about 25, is my
5 on the second page there of Exhibit 2, you 5 understanding. I don't remember off the
6 asked the question: Does Alabama use -- 6 top of my head.
7 how do you say that -- midazolam in its 7 Q. So there are some states that
8 executions? We don't even know. 8 practice the death penalty that do not make
9 Well, earlier I thought you said 9 their protocols public, including Alabama?
10 that you did know that that is the drug 10 A. I don't know how many states
11 they use in their executions? 11 practice the -- the death penalty and don't
12 A. I don't know with certainty, no. 12 make it public. I do know that. It's not
13 Q. But you -- but you cite a 13 very many.
14 Reuters article. Is that what you link to? 14 Q. I said "some," I think. There
15 Is that what that means? 15 are some states who -- besides Alabama, who
16 A. It appears that way, yes. 16 practice the death penalty and do not make
17 Q. All right. Now, on the third 17 their protocols public?
18 page at the top you say in your tweet: Why 18 A. I don't feel confident answering
19 won't Alabama DOC release information about 19 that question.
20 how they carry out executions? It lists at 20 Q. Okay. The next page, 4, at the
21 least 15 states have made it public. Does 21 bottom tweet you say: The last two
22 that indicate that 35 states have not made 22 executions were botched.
23 it public? 23 Okay. Do you know how they were
Page 86 Page 88
1 A. It indicates that 15 other 1 botched, and what do you mean by botched?

2 states have made it public. 2 A. I read articles about inmates
3 Q. I understand that. Are you 3 being executed and there being quite a bit
4 aware if the other 35 states have not made 4 of difficulty in the execution. So the
5 it public? 5 word botched is not one that I came up with
6 A. Looks look I tweeted this in 6 on my own, but was used in various -- as I
7 April of 2017. So, as of April 2017, I 7 recall to the best of my memory, it was
8 knew of at least 15 other states that had 8 used in other articles. But it seems like
9 made it public. 9 the intention was that executions should
10 Q. Okay. Were you unaware of 10 include a consciousness check, and the --
11 whether the other 35 states made it public 11 that the inmate should be completely
12 or refused to make it public, or you just 12 unconscious and unable to feel pain at the
13 did not know? 13 time of the execution. And there was
14 A. As of April 27th, 2017 -- I do 14 reason to believe that the executed inmates
15 not recall what I knew as of April 27th, 15 were at least partially conscious or
16 2017. 16 feeling some pain, based on their behavior
17 Q. How about today? Do you -- is 17 at the time of the execution.
18 it your understanding that a majority of 18 Q. All right.
19 states do not make their execution 19 A. I'm not an expert on these
20 protocols public? 20 matters. Just providing commentary on
21 A. It's my understanding that a 21 articles.
22 majority of states don't have an execution 22 Q. All right. But you did say
23 protocol because they don't practice the 23 earlier that's part of your thing, you want

Page 89 Page 91
1 to get into the details, the specifics? 1 and compile different --

2 You want to find out every piece of 2 A. Yes.
3 information you can so you can pray over 3 Q. -- tweets?
4 the details of them, right? 4 A. Yes. Yes.
5 A. I want to have access to that 5 Q. What does -- on the next page,
6 information and be able to get as detailed 6 which is page 6 of this exhibit -- #FIAAL
7 as I want to get. 7 stand for?
8 Q. All right. Now, on the next 8 A. Uh-huh. Faith in Action
9 page, you describe an execution as a day of 9 Alabama. That's an organization that I'm a
10 vengeance? 10 part of.
11 A. Yes. 11 Q. And is death penalty opposition
12 Q. Is vengeance the only purpose or 12 part of their goals?
13 reason that the State may have for the 13 A. Not that I'm aware of. No.
14 death penalty in your understanding? 14 Q. Same thing about Disciples for
15 A. I don't know that I can a 15 Justice, is that a group you're part of, or
16 hundred percent answer that question. It 16 is that just a hashtag unrelated to a
17 seems to me like it's not a day of 17 group?
18 reconciliation. It's not a day of keeping 18 A. There is a group. I -- I think
19 the public safe. It's a day of vengeance. 19 there's a -- don't know how formal the
20 I will stand by that statement. Yes. 20 group is, but it's related to the Christian
21 Q. Okay. Now, some of these 21 Church Disciples of Christ.
22 hashtags that you use at the end of your 22 Q. So the disciples aspect refers
23 tweets and -- you know, forgive me of my 23 to --
Page 90 Page 92
1 age and state of ancient understanding, but 1 A. To my church.

2 a hashtag is just a common phrase that 2 Q. So the church --
3 emphasizes an important part of what you're 3 A. Uh-huh. And the Faith and in
4 saying? Is that how would you describe -- 4 Action, because I was talking about both
5 what is hashtag, how you used a hashtag? 5 faith and a social justice issue in the
6 A. This is a wide ranging 6 public sphere -- by using those hashtags, I
7 discussion we're having here today. 7 tagged two organizations that I know are
8 Q. Okay. That's fine. 8 interested in conversations about people of
9 A. If I were to describe what a 9 faith getting involved in the public
10 hashtag does to someone who's not familiar, 10 sphere.
11 I would say that a hashtag is a way to 11 Q. All right. Next page. The top
12 connect with other organizations and with 12 tweet you're talking about you link to
13 organizations, users. It's a way to link 13 information on the Ohio death penalty for
14 together larger conversations. So putting 14 protocols. Do you see that top tweet
15 something like #Alabama means that someone 15 there?
16 who looks for #Alabama is going to be 16 A. On page 7?
17 looking for Alabama-related news and would 17 Q. Page 7, yes, ma'am.
18 know that something about the tweet is 18 A. Yes. Okay.
19 related to Alabama. So it's kind of a form 19 Q. Okay. What steps, efforts, did
20 of categorization -- 20 you make to find out details about the Ohio
21 Q. And the way to -- 21 death penalty protocols and information?
22 A. -- how people find things. 22 A. I think I have answered that
23 Q. Is there a way to search those 23 question already.

Page 93 Page 95
1 Q. Well, answer it again. Thank 1 A. Yes.

2 you. 2 Q. That's on pages 7 and 8 and 9.
3 A. I did not make an effort to get 3 Although you were able to look at the
4 information from the state of Alabama -- or 4 protocol for Texas, you were not able to
5 state of Ohio, since I am a resident of the 5 get all the information, other information
6 state of Alabama. 6 you've requested on your Alabama open
7 Q. Yet you were able to pray? It's 7 records request; is that correct?
8 the first four words were, I will be 8 A. Correct.
9 praying, correct? 9 Q. Yet you're able to pray for them
10 A. Yes. 10 and ask others to join you to pray?
11 Q. And you were able to ask others 11 A. Yes.
12 to join you in prayer? 12 Q. Okay.
13 A. Yes. 13 MR. HARMON: I will just
14 Q. That's the next line. Same 14 move to admit those -- Exhibit 2.
15 question for the next tweet about Texas. 15 Any objections?
16 Same answer? You didn't make any efforts 16 MR. McGUIRE: No objection.
17 to request information about that, but you 17 Q. We're going through the reasons
18 were able to pray for Texas? 18 that you feel you're called to strive for
19 A. Texas has a public protocol. 19 specificity in these prayers. We talked
20 Q. Right. And you -- I guess you 20 about scripture. There's examples in
21 link it -- I don't know what that link is. 21 scripture, but no direct command that you
22 That's to another tweet. 22 can recall. There are traditions.
23 Who is Robin Konrad? I can't 23 There's -- and history of people you
Page 94 Page 96
1 read that last name. 1 respect in your faith background that have
2 A. I don't know. 2 spoken with specificity and prayed publicly
3 Q. Okay. Now, do you -- are there 3 with no direct command.
4 any tweets that refer to people being 4 How about revelation? Is there
5 executed in other countries? Is that a 5 anything in revelation, that aspect of your
6 concern of yours? 6 authority, that you feel has called you to
7 A. It is -- I'm concerned about all 7 seek more specificity in your prayers?
8 life. All life is sacred. Yes. 8 A. Yes. So revelation, as I'm
9 Q. I would think so. But do the 9 taught it -- as I have been taught it, is
10 tweets reflect that? Again, we've 10 when God speaks to you directly and reveals
11 already -- 11 things to you directly. And I have felt
12 A. No. No. 12 the holy spirit call to me to care more
13 Q. -- established your tweets don't 13 deeply about this issue. I have not always
14 reflect everything about you. 14 lived up to that call and done as much
15 A. Right. 15 as -- as I probably should to respond to
16 Q. I'm just asking the question. 16 the spirit. But, nonetheless, the spirit
17 No? 17 pushes me onward. And on my good days,
18 A. No. I have not tweeted about 18 I -- I listen --
19 executions outside the United States. 19 Q. All right.
20 Q. Okay. Okay. You have several 20 A. -- to that call.
21 tweets about the Texas inmate on death row. 21 Q. Now, those were the three things
22 I guess TaiChin Preyor? I'm not Spanish. 22 that we've got -- or maybe the four --
23 You see what I'm saying? 23 A. I should have looked for the

Page 97 Page 99
1 other. 1 Q. Have you ever made a records

2 Q. Okay. It's okay. But if it 2 request to any other state?
3 does come to you, let me know. Would you 3 A. No.
4 say that's the primary basis, those three 4 Q. Have you ever made any other
5 aspects that you described so far, that 5 records requests to Alabama besides this
6 kind of drives you to want this more 6 particular one we're here for today?
7 specific information so you can pray more 7 A. No.
8 specifically? 8 Q. Have you ever been registered as
9 A. In my spiritual life those are 9 a lobbyist?
10 all important things. I have not taken 10 A. No.
11 time to reflect deeply on exactly which 11 Q. Have you ever -- have you ever
12 aspect of that is most driving my behavior. 12 participated in activities designed to
13 Q. Is there anything other than 13 change the law of Alabama?
14 that that compels you, moves you, inspires 14 A. Yes.
15 you to want more information, more 15 Q. Okay. What have you done?
16 specifics, more detail, so you can pray 16 A. I'm involved with this group,
17 with a level of detail that you want to? 17 Faith in Action Alabama, and we work on a
18 A. I want -- I mean, my motivation 18 number of policy issues.
19 for praying is purely spiritual. 19 Q. What would be some of those
20 Q. Okay. And -- and so these -- 20 policies?
21 there's three aspects. That part of your 21 A. We work a lot on criminal
22 spiritual life. Those are compelling you, 22 justice reform, education, and immigration,
23 driving you to, inspiring you to want a 23 xenophobia issues.
Page 98 Page 100
1 greater level of detail, is what I'm trying 1 Q. And has the death penalty reform
2 to get at? 2 been part of those criminal justice reforms
3 A. I feel like I'm misunderstanding 3 you talked about?
4 the question. 4 A. No. Those have not been
5 Q. It's okay. You know, I -- God 5 identified as priority.
6 is -- your spiritual life in general is 6 Q. All right. So what part of
7 what is motivating you? 7 criminal justice reform would that group be
8 A. To want this information? 8 advocating?
9 Q. Right. 9 A. If I recall correctly, the
10 A. Yes. 10 current issues that group is working on is
11 Q. And, I guess, in my mind the 11 civil asset forfeiture, putting an end to
12 part of your spiritual life that is the 12 civil asset forfeiture -- and there are
13 driving force in that desire are examples 13 bills in the state legislature to consider
14 from scripture? Examples are tradition and 14 that -- the defelonization of marijuana --
15 revelation? Did I summarize that fairly 15 there's a third other one.
16 enough? 16 Q. Uh-huh.
17 A. That's fairly summarized. 17 A. And then we work on some issues
18 Q. Okay. Have you ever been sued 18 related to conversations with the police
19 before, a defendant in a lawsuit? 19 department about how they handle immigrants
20 A. No. 20 in cooperation with ICE. We work with
21 Q. Before this case have you ever 21 community groups to be a part of looking
22 been a plaintiff in a lawsuit? 22 for solutions for the Montgomery Public
23 A. No. 23 Schools turnaround process. But, sorry, I

Page 101 Page 103
1 think you asked specifically about criminal 1 have a few questions.

2 justice reform. 2 EXAMINATION BY MR. McGUIRE:
3 Q. That's okay. I'm learning a 3 Q. Reverend Isner, you know me,
4 lot. Thank you. 4 Mitch McGuire. I'm going to ask you a very
5 None of what you described seems 5 few questions just in response to some of
6 to be -- directly involves the Department 6 the questions that counsel for Department
7 of Corrections of Alabama and prison 7 of Corrections asked you a little earlier.
8 conditions, for instance? Any part of your 8 I want to talk to you first
9 advocacy or legislative work kind of 9 about, ultimately, Twitter. But let me
10 directly involve the Department of 10 start by asking you this. To your
11 Corrections or prison conditions? 11 knowledge, isn't it true that some people
12 A. I do not think so. They are 12 can just pray in the closet?
13 also working on cash bail, bail reform. 13 MR. HARMON: Object to the
14 Q. Yes. That would have an 14 form. Leading.
15 indirect -- I see it has an indirect 15 You may answer.
16 effect. But you're not involved in any of 16 A. Some people pray in private.
17 this -- the current litigation about prison 17 MR. McGUIRE: By the way,
18 conditions or violence in the prisons or 18 this is cross-examination.
19 mistreatment of inmates? That's just -- I 19 MR. HARMON: I don't agree
20 don't see any indication that you have been 20 with that. Anyway, object to the form.
21 involved in that kind of advocacy? 21 Go ahead.
22 A. No. No. 22 Q. And people can -- you did say
23 Q. Okay. Do you see yourself using 23 yes to the answer that some people can pray
Page 102 Page 104
1 the information you obtained, if 1 in the closet?

2 successful, in this request in this 2 A. Yes, some people pray in the
3 lawsuit? Do you see yourself using that to 3 closet.
4 try to change the law on the death penalty 4 MR. HARMON: Object to form.
5 in Alabama? 5 Q. Can some people pray in the
6 A. I don't think that will be my -- 6 public square, for example?
7 I don't have any plans to do that. 7 A. Yes, people can pray anywhere.
8 Q. And do you have any plans to 8 Q. And people can pray in a stadium
9 give this information to people who might 9 with 100,000 people, could they not?
10 use that or would use that to change the 10 A. Yes, people can and often do.
11 law in the death penalty in Alabama? 11 Q. And that's not a novel
12 A. I don't have any plans to do 12 concept --
13 that. 13 MR. HARMON: Form.
14 Q. Have you met with people to 14 A. No.
15 discuss the information being used in that 15 Q. -- to your knowledge, is it,
16 way? 16 Reverend Isner?
17 A. No. 17 A. No. That seems pretty common.
18 Q. All right. Look at my notes. 18 Q. You have heard of, for example,
19 MR. HARMON: I think that's 19 the PTL Club, have you not? Have you heard
20 all I have. Your attorney may have some 20 of that broadcast, Praise the Lord Club,
21 questions. 21 that comes on television?
22 Mitch, you have questions? 22 A. I don't really watch TV.
23 MR. McGUIRE: Yes. I just 23 Q. You've heard, have you not, of,

Page 105 Page 107
1 let's say, Pat Robertson? 1 A. Yes, I have made a request.

2 A. Oh, yes. 2 Q. And if I recall your question
3 Q. And you do recognize that Pat 3 correctly, you asked the State for that
4 Robertson, for example, has television 4 information -- I think if I'm correct --
5 broadcasts, correct? 5 you said because the State has it? Am I
6 A. Yes, he has broadcast. 6 correct to your knowledge?
7 Q. And his television broadcasts 7 A. I'm not sure I understand.
8 are to hundreds of thousands, if not 8 Q. The State is the source of the
9 millions of people; is that correct? 9 information; is that correct?
10 A. Yes. 10 A. Yes. The State seems like the
11 Q. And is -- 11 most knowledgeable source for the
12 A. To my understanding. 12 information. More knowledgeable than
13 Q. Is Pat Robertson, to your 13 Google or a news article or other Twitter
14 knowledge, known from time to time to have 14 users.
15 a political issue in which he speaks about 15 Q. Okay. Now, you're a citizen of
16 to his hundreds of thousands of people 16 Alabama, correct?
17 during his broadcast? 17 A. I am. I'm a resident, yes.
18 MR. HARMON: Form. 18 Q. And would you agree that Alabama
19 A. Yes. 19 citizens -- well, each of them, their
20 Q. And, in fact, have you ever 20 prayers are perhaps a little bit different?
21 known Pat Robertson, for example, to appear 21 A. All of us pray differently, I'm
22 on Fox News? 22 sure.
23 A. Yes. 23 Q. And correct me if I'm wrong, but
Page 106 Page 108
1 MR. HARMON: Form. 1 you aren't God, are you?

2 Q. And when Pat Robinson -- 2 A. I am not God.
3 Robertson has appeared on Fox News, for 3 Q. Okay. So would I be making a
4 example, he is there discussing political 4 correct statement if I said your request is
5 issues; isn't that true? 5 about your prayers, am I correct?
6 A. Yes. 6 A. Yes, it is about my prayers.
7 MR. HARMON: Object to the 7 Q. So by process of elimination,
8 form. 8 this case is not about what God knows. Am
9 A. I understand that. 9 I correct?
10 MR. HARMON: Let me -- I'm 10 A. Correct.
11 going to just ask can I just have a 11 Q. Okay.
12 standing objection to form? 12 A. Don't make any claims about what
13 MR. McGUIRE: Sure. 13 God knows.
14 MR. HARMON: And I don't 14 Q. I -- I do have a question I'm a
15 mean interrupting you-all. Go ahead. 15 it bit curious about. I heard a question
16 MR. McGUIRE: Thank you. 16 that said, Hey, well, since God knows
17 Q. Now, Reverend Isner, you've 17 everything, you can just pray to God. Do
18 asked the State for a number of records 18 you remember a question similar to that?
19 about their drug protocol and other 19 You can just pray to God, and he'll know
20 information relative to how the death 20 what you're praying for? I'm paraphrasing,
21 penalty is, for lack of a better term, 21 but you remember that question?
22 executed in the State of Alabama; is that 22 A. Yes.
23 correct? 23 Q. If we operate under the

Page 109 Page 111
1 assumption that God knows everything and 1 Q. Does he use that Twitter handle
2 therefore he will fix it, is there a need 2 to discuss whether people should be put to
3 to pray at all? 3 death or not?
4 A. The arc of a moral universe is 4 A. Yes, he has.
5 long, but it bends towards justice, is a 5 Q. Now, death by executions occur
6 favorite quote of mine. I used to think it 6 in other countries?
7 was God who pulled on that arc. I don't 7 A. Yes, they do.
8 think that it's God who makes justice on 8 Q. And death by executions occur in
9 Earth. I think it's courts and citizens 9 other states?
10 who make justice on Earth. 10 A. Yes.
11 Q. Thank you, Reverend Isner. Are 11 Q. You live in the United States,
12 you familiar with the Twitter handle 12 don't you?
13 @POTUS? 13 A. I do.
14 MR. HARMON: I'm sorry. At? 14 Q. And you live in the state of
15 MR. McGUIRE: @POTUS, 15 Alabama, don't you?
16 P-O-T-U-S. 16 A. I do.
17 MR. HARMON: The @ sign. I 17 Q. So you're asking the state of
18 got you. 18 Alabama, in the United States of America,
19 Q. Do you know whose Twitter handle 19 for the information as a citizen of the
20 that is? 20 state and of this country, are you not?
21 A. I do. 21 A. Yes, that's correct.
22 Q. Tell me -- 22 Q. Okay. Now, does anything about
23 A. The president of the United 23 your request for this information about
Page 110 Page 112
1 States. 1 Alabama's drug protocol and the other

2 Q. And to your knowledge, does our 2 information that you requested, does it
3 president of the United States use @POTUS 3 have anything to do with what's in any
4 to put forth his political and personal 4 Alabama official or their lawyers' mind as
5 views? 5 to what is appropriate -- what an
6 A. It's hard to tell them apart. 6 appropriate -- an appropriate request is?
7 It's unclear. 7 A. Can you ask that again?
8 Q. Have you heard of a Twitter 8 Q. Yes. Sorry. Does anything
9 handle called @realDonaldTrump? 9 about your request have anything to do with
10 A. Yes. 10 what's in an Alabama official or their
11 Q. Is that also a Twitter handle in 11 lawyers' mind as to what is appropriate?
12 which the president of the United States 12 A. I am not asking anyone about
13 uses? 13 their opinion on the death penalty. I'm
14 A. It is. 14 only asking for documents about how it is
15 Q. And to your knowledge does he 15 carried out in the state of Alabama.
16 use that Twitter handle frequently? 16 Q. To your knowledge, is it legal
17 A. Yes, it is. 17 for you to get public records? Is it legal
18 Q. Does he use that Twitter handle 18 for you to get records in the possession of
19 to discuss political issues? 19 the state of Alabama?
20 A. Yes, he does. 20 A. To my knowledge, it is legal for
21 Q. Does he use that Twitter handle 21 me to ask and receive those records.
22 to discuss religious freedom issues? 22 Q. And by the way, if you ask and
23 A. Yes, he does. 23 you received those records, is there

Page 113 Page 115
1 anything that prevents you from sharing 1 access to other things. PTL didn't strike
2 those records? 2 a memory with me.
3 A. As far as I know, there is no -- 3 Q. How about Pat Robertson --
4 nothing preventing me from sharing those 4 A. Absolutely familiar with Pat
5 records if I receive them. 5 Robertson.
6 Q. Now, if there is a law that 6 Q. Who is Pat Robertson?
7 prevented you from sharing those records, 7 A. He's an evangelical Christian
8 would you share those records? 8 leader who often speaks about faith and
9 A. I would not. 9 politics.
10 Q. Is there a court order that says 10 Q. Is he alive or dead?
11 you may not share -- you shall not share 11 A. He's alive, as last I check.
12 those records, would you share them? 12 Q. White or black?
13 A. I would not. 13 A. White.
14 Q. So if I understand, based on the 14 Q. What is his approximate age? Do
15 last few questions that I asked you, you 15 you know?
16 make no representation that you will 16 A. Old.
17 violate any law -- 17 MR. HARMON: Object to that.
18 A. I -- 18 A. I'm really bad at guessing ages,
19 Q. -- with these records? 19 so I'm just going to go with old
20 A. I do not intend to violate any 20 white-haired guy.
21 law. 21 Q. Could you describe what he looks
22 Q. And you don't -- do you intend 22 like?
23 to violate any court order? 23 A. Um, he's old and kind of skinny
Page 114 Page 116
1 A. I do not intend to violate any 1 and kind of white-haired and --

2 court order. 2 Q. All right.
3 Q. Now, outside the law and a court 3 A. I don't watch a lot of TV.
4 order, you are free to do with public 4 Q. I get that. Okay. Now, on this
5 records what you wish, are you not? 5 citizenship, I get you're a citizen of
6 A. That's my understanding of 6 Alabama. But the fact that you're not a
7 public records, yes. 7 citizen of Texas, Ohio, those other places
8 MR. McGUIRE: I don't have 8 did not stop you from trying to get
9 any other questions. 9 information on those other states and
10 MR. HARMON: I got a few 10 praying for them, right?
11 follow-up. 11 A. Correct.
12 MR. McGUIRE: Sure. 12 Q. Prayers know no boundaries,
13 EXAMINATION BY MR. HARMON: 13 correct?
14 Q. My friend Mitch asked you about 14 A. Correct.
15 Pat Robertson and the PTL Club. 15 Q. And compassion, I'm sure you
16 A. Yes. 16 will agree, knows no political boundaries,
17 Q. Do you remember that? 17 correct?
18 I thought your response was 18 A. Correct. Correct.
19 you're not really familiar with who that 19 Q. So you can pray for somebody in
20 is, what the club does, and you don't watch 20 Cuba or Russia or China who's facing
21 much TV? Is that -- 21 political execution just as well as you can
22 A. I don't watch a lot of -- I 22 right here in Alabama?
23 don't watch TV. I watch YouTube and have 23 A. Yes.

Page 117 Page 119
1 Q. All right. And I'm sure if you 1 A. Not to my knowledge.

2 looked at your basis of authority: 2 MR. HARMON: All right.
3 Scripture, traditions -- and I don't know 3 That's all I have.
4 what your revelation is -- but there are 4 3:26 p.m.
5 examples of people praying for other people 5 FURTHER DEPONENT SAITH NOT
6 all over the world, right? Lots of 6 ****************
7 examples in your tradition of that? 7
8 A. Yes, people pray for each other 8
9 all over the world. 9
10 Q. All right. No one -- as far as 10
11 I know, has anybody tried to stop you from 11
12 praying using your Twitter account as an 12
13 instrument of prayer? Anybody tried to 13
14 stop that? 14
15 A. No. 15
16 Q. Has anybody tried to stop you 16
17 from using your Twitter account to post or 17
18 give screen shots to other legally obtained 18
19 public documents from other states? 19
20 A. No, freedom of -- 20
21 Q. Right. 21
22 A. -- freedom of speech. 22
23 Q. And nobody has even tried to 23
Page 118 Page 120

1 STATE OF ALABAMA)
1 stop you from doing that?
2 COUNTY OF MONTGOMERY)
2 A. Not at all.
3
3 Q. All right. No one from Alabama
4 I hereby certify that the above
4 has tried to stop you from using your
5 proceedings were taken down by me and
5 account like that?
6 transcribed by me using computer-aided
6 A. No.
7 transcription and that the above is a true
7 Q. Okay. So Mr. -- my friend Mitch
8 and accurate transcript of said proceedings
8 talked about our esteemed president's use
9 of the Twitter account, right? So you -- 9 taken down by me and transcribed by me.
10 in this case you're aspiring to be like 10 I further certify that I am
11 Donald Trump; is that correct? 11 neither of kin nor of counsel to any of the
12 A. I wouldn't say that. 12 parties nor in anywise financially
13 Q. Okay. That wasn't a good 13 interested in the outcome of this case.
14 question. 14 I further certify that I am duly
15 MR. HARMON: Okay. Thank 15 licensed by the Alabama Board of Court
16 you for your time. I think we're done 16 Reporting as a Certified Court Reporter as
17 unless you have follow-up? 17 evidenced by the ACCR number following my
18 MR. McGUIRE: One follow-up 18 name found below.
19 question. 19
20 EXAMINATION BY MR. McGUIRE: 20
21 Q. To your knowledge, Reverend 21 ______________________________
22 Isner, does China, Russia, or Cuba have an 22 VICTORIA CASTILLO, ACCR #17, 9/30/18
23 open records act? 23 FREELANCE COURT REPORTER

80:6 90:17 article (2) 52:3;56:9;57:5,14;

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account (32) ago (1) apart (1) 70:1;72:17 28:15
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18:19;51:12;91:8; 19;87:9,15;90:19;91:9; 34:11;35:7;49:7 39:17;40:12 besides (5)
92:4;99:17 93:4,6;95:6;99:5,13, April (4) authority (3) 30:4;31:19;50:4;
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Min-U-Script® Baker Realtime Reporting Worldwide (1) #Alabama - better

23:1;24:18;25:8; 48:5 certain (4) citizen (5) compel (1)

106:21 53:22;67:13;68:4; 38:18;107:15; 81:16
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100:13 calling (1) challenges (1) 108:12 complete (2)
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66:10 19:3,6;20:5;21:2,9; checked (1) 65:11 104:12
board (2) 22:7;23:18;32:20; 84:2 clear (2) concern (6)
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77:18 46:23;48:11,11;50:17; Chicago (5) 81:5 concerned (3)
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76:8 61:9,19;63:14,22; child (9) closet (3) 38:8;50:5;73:4,11
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87:22;88:1,1,5 5,20;68:3,5;69:3,14; 29:4,10,20;31:19,23 closure (1) 37:12;38:5,6,7;45:14
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53:4 daily (1) degrees (1) 85:4;91:1;107:20 96:14;99:15;118:16
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100:20 danger (3) Del (2) 107:21 9:2;13:17;19:20;
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courts (1) 38:6,23;39:13;40:20, describe (8) 73:4 37:4;53:18;58:5;
109:9 20;41:12;46:14,17,19; 36:22;51:4;65:15; dispose (1) 68:21;69:5,11;85:9;
cover (2) 47:15,18,23;50:6,12; 81:1;89:9;90:4,9; 64:3 88:23;103:7
Min-U-Script® Baker Realtime Reporting Worldwide (3) consistent - earlier

Early (1) equal (1) 75:22 45:10 forgive (1)

41:2 40:14 Exhibit (10) fault (2) 89:23
Earth (2) equipment (7) 54:18,19;55:4;74:22; 10:10,10 form (11)
109:9,10 63:16,23;64:4,11,12; 82:9,19,22;85:5;91:6; favorite (1) 20:4;61:9;90:19;
easier (2) 65:9,10 95:14 109:6 103:14,20;104:4,13;
66:9,10 established (2) exhibits (1) feel (13) 105:18;106:1,8,12
economic (1) 58:8;94:13 55:6 10:19,21;19:18; formal (1)
25:4 esteemed (1) expected (1) 38:21;39:20;54:23; 91:19
ed (1) 118:8 48:7 66:2;77:5;87:18;88:12; forms (4)
30:16 et (1) expert (2) 95:18;96:6;98:3 42:15;44:5;59:20;
education (5) 59:21 54:10;88:19 feeling (2) 72:21
35:15;41:2,7;51:8; ethic (1) expire (1) 10:19;88:16 formulated (1)
99:22 25:6 61:20 feels (1) 24:11
effect (1) evaluate (1) explain (2) 34:6 forth (1)
101:16 39:18 42:3;44:18 fellowships (1) 110:4
effects (1) evaluation (2) expose (1) 28:8 foster (4)
71:2 33:7,9 63:12 felt (3) 23:4,5;26:6;41:3
effort (2) evangelical (1) expressed (3) 40:7,13;96:11 found (2)
69:17;93:3 115:7 20:11;25:14;39:1 few (8) 37:20;52:17
efforts (2) even (14) expresses (1) 10:17;11:9,22;35:14; foundation (2)
92:19;93:16 11:14;15:7;51:15; 80:11 103:1,5;113:15;114:10 43:21;58:7
elaborate (1) 65:4;66:15;67:11;68:3; expression (1) filed (4) four (9)
38:7 70:9;71:7;78:13;83:14; 45:3 37:15,18;38:1;47:21 31:12;32:3;44:2,6,
election (4) 84:13;85:8;117:23 extent (1) final (1) 12,17,17;93:8;96:22
15:6,7,11,12 event (1) 43:12 47:9 Fox (2)
elective (2) 74:13 external (1) find (10) 105:22;106:3
21:17,18 events (2) 72:17 23:12;47:8,20;51:21; free (5)
electrocution (2) 81:5;84:20 52:7;71:15;79:16;89:2; 21:1;48:9,14;54:23;
58:22;73:13 evident (1) F 90:22;92:20 114:4
elements (1) 39:5 fine (4) freedom (3)
67:13 exactly (2) Facebook (2) 11:17;44:15;75:20; 110:22;117:20,22
eleven (1) 74:18;97:11 36:7;40:2 90:8 frequent (1)
55:15 EXAMINATION (4) faced (2) finish (2) 36:15
elimination (1) 8:1;103:2;114:13; 21:7;22:11 11:12,16 frequently (3)
108:7 118:20 facing (1) fired (1) 41:11;50:22;110:16
else (3) examined (1) 116:20 52:13 friend (4)
18:10;25:20;30:3 7:3 fact (2) first (8) 64:15;66:5;114:14;
emphasizes (1) example (10) 105:20;116:6 7:3;15:9;18:1;27:7; 118:7
90:3 39:23;58:20;59:8; Fair (5) 54:7;74:22;93:8;103:8 friends (1)
employed (14) 76:17;81:19;104:6,18; 11:5;35:16;37:10; fit (1) 18:16
26:21,22;27:5,6; 105:4,21;106:4 61:10,13 25:13 full (5)
28:5;29:3,4;30:3,7; examples (12) fairly (2) five (3) 13:6,7,8;14:8;81:4
32:6,9;34:16,19,20 39:15;45:5;49:10; 98:15,17 33:12;46:3,4 full-time (1)
employee (1) 77:11,19;81:4,10; Faith (10) fix (2) 28:9
28:9 95:20;98:13,14;117:5, 18:19;45:10,19;91:8; 10:11;109:2 funds (1)
employment (8) 7 92:3,5,9;96:1;99:17; Flesh (1) 73:5
27:11;31:18;32:4,19; excellent (2) 115:8 45:7 further (3)
33:13;35:15;52:12,14 22:16,16 faithfulness (1) focus (2) 18:13,14;119:5
end (2) execute (2) 45:4 38:22;39:13
89:22;100:11 50:8;64:2 familial (1) follow (1) G
energy (1) executed (7) 47:9 81:19
72:1 62:16;64:19;74:11; familiar (7) followers (4) gave (1)
Enforcement (1) 88:3,14;94:5;106:22 57:12;75:8;80:21; 49:3,7;54:1;56:18 8:8
72:4 execution (17) 90:10;109:12;114:19; following (1) general (5)
engage (1) 47:3,3;54:5,8;61:4; 115:4 7:1 36:21;42:17;75:14;
66:1 64:4;72:13,18;73:5,17; family (4) follows (1) 78:14;98:6
enormous (2) 86:19,22;88:4,13,17; 18:16;21:15;47:5,7 7:4 generally (3)
76:6;77:18 89:9;116:21 far (4) follow-up (3) 44:2;58:11;66:14
enough (5) executions (13) 77:13;97:5;113:3; 114:11;118:17,18 gifts (2)
11:6;46:4;57:12; 37:1,2;47:13;58:21; 117:10 force (1) 18:14,16
65:14;98:16 73:3;85:8,11,20;87:22; fashion (1) 98:13 gist (1)
entries (1) 88:9;94:19;111:5,8 48:19 forfeiture (3) 35:18
83:5 exhausting (1) fathers (1) 41:5;100:11,12 given (6)
Min-U-Script® Baker Realtime Reporting Worldwide (4) Early - given

8:18;17:3;18:20; guy (1) Hey (1) 41:5 36:10;40:3

24:5;40:11;62:14 115:20 108:16 include (6) instance (1)
giving (1) hierarchy (1) 21:16,19;46:21;47:6; 101:8
67:17 H 27:14 48:22;88:10 Institute (2)
goals (1) high (1) included (5) 34:22;35:8
91:12 half (2) 41:20 58:18,19;59:3;68:23; institution (1)
God (27) 29:22;74:19 higher (1) 70:12 30:16
78:9,16,18,23;79:6,7, Hammond (1) 30:16 including (3) instructs (1)
8,13,14,14,15,19;80:2, 28:15 history (2) 55:7;58:23;87:9 9:12
3,5;96:10;98:5;108:1, handle (10) 35:15;95:23 independent (2) instrument (1)
2,8,13,16,17,19;109:1, 61:23;100:19; hold (2) 32:22,23 117:13
7,8 109:12,19;110:9,11,16, 20:1;46:2 Indiana (1) integrity (2)
goes (1) 18,21;111:1 holy (2) 28:15 25:5,9
61:7 handles (1) 43:13;96:12 indicate (2) intellectual (1)
good (8) 61:22 home (5) 83:15;85:22 65:19
10:19;11:3;22:12; handling (1) 12:9,10;25:21;32:17; indicates (1) intend (5)
44:7;46:4;51:1;96:17; 62:3 41:2 86:1 53:15;59:18;113:20,
118:13 happen (1) hours (1) indication (2) 22;114:1
Google (4) 60:7 11:9 77:15;101:20 intended (1)
52:3;71:14,15; happening (2) huh (3) indirect (2) 71:1
107:13 38:17;81:6 20:22;39:8;80:6 101:15,15 intent (1)
Googled (2) happens (2) huh-uh (1) individual (1) 60:12
47:17;51:20 47:10,11 9:23 79:4 intention (1)
Googling (1) harass (1) Human (5) influence (1) 88:9
51:19 63:3 31:21;38:9,21;39:2, 10:22 interest (2)
government (2) hard (5) 15 information (64) 58:1;75:4
41:6;67:7 10:1;13:10;25:5; hundred (2) 36:18;37:6;47:20; interested (3)
graduate (3) 36:15;110:6 17:11;89:16 51:9,14,15,22,23;53:1, 19:12;73:9;92:8
28:4;31:14;34:11 Hardwick (2) hundreds (2) 12,23;55:19;56:5,9; interesting (2)
graduated (2) 42:5;48:17 105:8,16 57:1,4,11,14,17;58:13; 23:12;66:21
30:4;31:19 HARMON (24) hurry (1) 61:16;63:18,21;64:22; interim (1)
graduation (1) 7:8;8:1;54:17;61:12; 19:10 65:4;66:23;67:5,8,20; 34:17
28:23 74:21;81:23;95:13; husband (1) 68:12,18,22;69:1,9,14; internal (1)
grand (1) 102:19;103:13,19; 27:2 70:4,9;71:7,15;73:6, 72:17
53:16 104:4,13;105:18; 11;85:19;89:3,6;92:13, International (2)
Great (4) 106:1,7,10,14;109:14, I 21;93:4,17;95:5,5; 34:22;35:7
10:13;45:2;81:20,21 17;114:10,13;115:17; 97:7,15;98:8;102:1,9, internet (2)
greater (1) 118:15;119:2 ICE (1) 15;106:20;107:4,9,12; 52:3,8
98:1 hashtag (6) 100:20 111:19,23;112:2;116:9 internships (3)
ground (1) 90:2,5,5,10,11;91:16 identification (2) informs (1) 28:7,8,19
8:11 hashtags (2) 54:20;82:20 44:18 interrupting (1)
grounds (1) 89:22;92:6 identified (1) infrastructure (1) 106:15
19:18 head (8) 100:5 41:7 interview (1)
group (13) 9:19,19;10:18;18:23; identity (1) injection (3) 48:13
16:22;17:4;19:12; 19:4;44:9;51:2;87:6 67:22 58:22;61:17;73:12 interviewed (1)
52:22;53:5,11;91:15, health (5) ideological (1) injunction (1) 47:22
17,18,20;99:16;100:7, 20:15;21:12,19; 19:17 78:4 into (8)
10 22:16;41:6 Iglesia (2) inmate (5) 14:13;19:17;39:2;
groups (7) hear (2) 28:12,14 47:4,7;62:15;88:11; 42:1;71:18;72:2;74:13;
18:21;23:1,2,8,10; 42:7;50:21 imagine (2) 94:21 89:1
35:22;100:21 heard (6) 61:19;63:22 inmates (3) inventories (1)
guess (15) 77:16;104:18,19,23; immigrants (1) 88:2,14;101:19 61:16
13:21;42:21,22; 108:15;110:8 100:19 inserts (1) invested (1)
64:13;65:6,12;67:10; hears (4) immigration (1) 70:14 72:1
68:16;72:4,22;78:18; 78:10,13,16;79:13 99:22 inspiration (3) invite (1)
84:8;93:20;94:22; Heart (3) impacted (1) 44:3,11;77:5 37:3
98:11 18:5,11;66:3 21:9 inspire (1) involve (1)
guessing (3) held (2) important (6) 60:21 101:10
11:15,20;115:18 27:10;28:21 18:17;20:15;25:15; inspires (2) involved (6)
guidance (1) help (3) 66:19;90:3;97:10 61:7;97:14 23:8;36:5;92:9;
44:3 22:17,20;45:6 inappropriate (1) inspiring (1) 99:16;101:16,21
guided (1) here's (1) 67:16 97:23 involves (1)
44:5 46:23 incarceration (1) Instagram (2) 101:6
Min-U-Script® Baker Realtime Reporting Worldwide (5) giving - involves

ISNER (15) kinds (2) 47:14;71:3 24:4 61:11

7:2;8:2,4;23:20,21; 36:4;39:3 learned (1) litigation (2) Luther (2)
25:23;26:5;83:9;84:7, King (1) 65:3 37:17;101:17 45:8,8
17;103:3;104:16; 45:9 learning (1) little (8)
106:17;109:11;118:22 knew (3) 101:3 14:14;42:6;56:12; M
issue (4) 62:1;86:8,15 least (5) 74:18;75:7;77:14;
44:20;92:5;96:13; Knowing (2) 38:16,19;85:21;86:8; 103:7;107:20 ma'am (1)
105:15 61:20,22 88:15 live (2) 92:17
issues (9) knowledge (11) leave (1) 111:11,14 main (1)
42:1;46:8;99:18,23; 58:1;103:11;104:15; 79:3 lived (1) 61:3
100:10,17;106:5; 105:14;107:6;110:2, left (1) 96:14 maintain (2)
110:19,22 15;112:16,20;118:21; 52:16 lives (2) 63:23;64:12
item (1) 119:1 legal (5) 20:16;25:20 Maintenance (3)
54:7 knowledgeable (2) 51:20;52:8;112:16, LLC (1) 63:16;79:23;80:1
items (9) 107:11,12 17,20 32:7 major (1)
44:6;54:14;55:15; known (2) legally (1) lobbyist (1) 34:8
56:5;59:22;60:17,23; 105:14,21 117:18 99:9 majority (2)
73:3,21 knows (11) legislative (1) located (1) 86:18,22
78:18;79:10,14,19; 101:9 32:18 majors (1)
J 80:2,3;108:8,13,16; legislature (1) logs (1) 34:5
109:1;116:16 100:13 61:16 makes (1)
Jesus (1) Konrad (1) less (2) long (14) 109:8
66:14 93:23 47:11;74:18 21:2;26:9;27:10,18; making (3)
job (1) lethal (3) 29:20;31:6,8;32:2,8; 16:3;19:19;108:3
52:17 L 58:22;61:17;73:12 33:10;34:7;45:18,20; manufacturer (1)
join (3) letters (1) 109:5 63:6
37:3;93:12;95:10 labels (2) 63:9 look (10) manufacturers (1)
Judge (2) 70:13;71:8 level (5) 40:18;54:23;55:1,9; 63:13
42:5;48:17 lack (2) 76:21;78:6;81:17; 63:15;66:17;82:21; manufacturing (1)
judgment (1) 23:1;106:21 97:17;98:1 86:6;95:3;102:18 70:13
19:19 land (3) licensed (1) looked (3) many (6)
June (1) 16:19,20;37:12 23:6 80:16;96:23;117:2 42:15;57:20;81:21;
15:14 Large (3) licenses (1) looking (5) 87:2,10,13
justice (10) 45:15,15,16 72:5 51:22;71:2,3;90:17; marijuana (1)
41:4;91:15;92:5; larger (1) life (26) 100:21 100:14
99:22;100:2,7;101:2; 90:14 16:16,16;19:23;20:6, looks (4) mark (1)
109:5,8,10 last (6) 9,21;21:6,8,9,11;37:19; 82:9;86:6;90:16; 54:18
35:14;84:11;87:21; 38:9,14,21;39:2,14,16, 115:21 marked (4)
K 94:1;113:15;115:11 21;65:16;71:17;94:8,8; Lord (1) 54:20;82:8,8,20
lately (1) 97:9,22;98:6,12 104:20 married (2)
Kay (1) 33:3 limit (3) losses (3) 25:23;27:19
8:4 later (1) 66:23;67:4,21 39:2,4,14 Martha (1)
K-A-Y (2) 33:17 limited (2) lost (1) 14:20
8:6,7 Latin (1) 70:9,13 39:16 Martin (2)
keeping (1) 79:11 limits (5) lot (15) 45:8,8
89:18 law (10) 67:8,18;68:4,17,19 36:11;39:23;40:20; mass (1)
Kentucky (1) 16:18,20;37:12; line (1) 55:14;59:10;65:3; 41:5
28:17 99:13;102:4,11;113:6, 93:14 68:21;69:8;71:7,15,18; master (4)
key (1) 17,21;114:3 link (5) 99:21;101:4;114:22; 30:22,22;31:2,9
25:17 lawsuit (5) 85:14;90:13;92:12; 116:3 matter (4)
kid (1) 15:17;48:6;98:19,22; 93:21,21 lots (4) 38:13,14;43:19;68:7
41:8 102:3 list (4) 45:13;64:21;77:11; matters (2)
kill (1) lawyer (2) 40:1;54:15;57:2; 117:6 46:13;88:20
62:2 74:3,9 59:10 Louis (6) may (12)
killed (1) lawyers' (2) listed (2) 17:22;34:3,21,23; 9:21;18:15;26:10;
79:20 112:4,11 54:7;55:15 35:4;65:22 43:7;44:13;47:8;51:16;
kind (23) leader (1) listen (1) Louisville (1) 63:3;89:13;102:20;
8:11;10:3;11:5,18; 115:8 96:18 28:17 103:15;113:11
14:13;23:3;25:6;33:4; leaders (3) listening (3) love (1) maybe (5)
40:23;52:9;61:5,11; 25:5;45:2;81:20 24:21;25:1,9 38:13 10:11;15:15;48:8,8;
66:6;70:12;71:10;78:1, leading (2) lists (1) lower (1) 96:22
6;90:19;97:6;101:9,21; 47:3;103:14 85:20 41:22 McGUIRE (17)
115:23;116:1 learn (2) literature (1) lump (1) 7:7;20:3;61:8;74:23;
Min-U-Script® Baker Realtime Reporting Worldwide (6) ISNER - McGUIRE

82:3;95:16;102:23; minute (1) 45:9 17:10;22:21;41:21; 18

103:2,4,17;106:13,16; 82:11 58:20;59:10;61:3,17; ones (3)
109:15;114:8,12; minutes (1) N 63:15;70:12,16;72:3,8, 17:18;18:23;61:2
118:18,20 35:14 11,23;73:10;99:18; online (2)
mean (22) missed (1) name (12) 106:18 32:15,17
9:10,20;13:9;14:13, 44:15 8:3;26:4,16;38:18; only (7)
14;18:22;21:2,3;45:23; misstate (1) 64:18;67:12,17,22; O 14:8;40:18;50:9,14;
56:2;60:3;64:9,12; 71:22 71:13;84:14,18;94:1 55:21;89:12;112:14
65:12;68:20;71:16; mistreatment (1) names (8) oath (1) onward (1)
74:10;83:20;84:11; 101:19 50:18,19;51:1;65:9, 8:22 96:17
88:1;97:18;106:15 misunderstanding (1) 10;68:12;71:6,14 object (7) open (7)
means (6) 98:3 national (1) 20:4;61:9;103:13,20; 14:5;15:16;37:15;
26:15,20;76:2;79:10; Mitch (7) 29:11 104:4;106:7;115:17 38:16;55:7;95:6;
85:15;90:15 13:20;14:2;48:9; necessarily (2) objection (3) 118:23
meant (1) 102:22;103:4;114:14; 37:9;42:1 74:23;95:16;106:12 openly (1)
44:13 118:7 necessary (1) objections (1) 76:10
media (10) money (8) 65:13 95:15 opens (1)
36:5;39:6,11,11,18, 17:3,20,23;18:1,2,3, need (19) obligated (1) 38:1
20;40:8,14,18;41:1 4;48:8 10:8;25:4;43:17; 40:7 operate (1)
medication (1) Montgomery (7) 44:19;47:7,8;51:8; obtain (3) 108:23
10:23 12:4,8;27:8,9;28:11; 63:20;64:13;65:7,9; 57:11;72:18,22 opinion (1)
meeting (2) 32:16;100:22 67:12;75:1;77:6;80:11; obtained (2) 112:13
47:4,6 moral (2) 81:2,17;82:1;109:2 102:1;117:18 opinions (2)
Megan (1) 73:8;109:4 needs (1) obviously (2) 51:4;52:2
14:9 more (27) 24:21 14:14;19:16 opponent (3)
Melissa (1) 10:17;13:14;19:3,7, neuroscience (1) occupations (1) 16:6;35:23;53:11
64:15 9,11;21:23;37:19; 34:9 28:23 oppose (1)
member (2) 41:17;48:7;55:14; New (3) occur (2) 36:13
14:8;16:22 57:21;64:13,16;65:8; 32:7,9,13 111:5,8 opposed (2)
members (4) 69:9,17,18;75:7;96:7, news (6) October (1) 23:15;24:6
13:13;14:7;16:21; 12;97:6,7,15,15,16; 50:14,22;90:17; 84:12 opposes (3)
18:16 107:12 105:22;106:3;107:13 off (13) 16:10,22;17:4
memorize (1) most (7) next (11) 18:22,23;19:4;33:12, opposing (2)
55:11 31:2;41:10;50:22; 13:20;76:19;78:8; 21,22;44:8;51:2;66:10; 25:13;36:1
memory (3) 66:2;73:20;97:12; 80:7;82:7;87:20;89:8; 76:15;82:17;84:14; opposition (5)
11:2;88:7;115:2 107:11 91:5;92:11;93:14,15 87:5 19:13;23:23;37:9;
men (1) mother (1) nice (1) offensive (1) 49:12;91:11
77:12 21:8 41:21 11:13 ordained (2)
mentioned (1) mother's (2) nine (1) offer (1) 26:17;27:4
71:5 21:11,12 27:20 23:2 order (6)
met (1) motivating (1) nobody (1) offers (1) 59:20;72:5;113:10,
102:14 98:7 117:23 22:15 23;114:2,4
Midazolam (2) motivation (3) nod (1) office (2) ordering (1)
50:21;85:7 75:3;77:5;97:18 9:19 12:23;29:9 72:12
might (14) move (3) nomination (2) official (2) orders (3)
10:4;11:22;13:10,20; 52:18;74:21;95:14 15:2,4 112:4,10 59:11,16,21
14:2;20:11;37:5;53:12; moves (1) non-abortion (1) often (6) organization (6)
60:7,13;61:21;75:19; 97:14 20:19 11:19;46:21;67:7; 12:21;17:16;29:8,12;
85:3;102:9 much (9) None (1) 79:8;104:10;115:8 52:23;91:9
millions (1) 23:11;27:13;35:15; 101:5 Ohio (4) organizations (7)
105:9 39:15;47:11,19;71:3; nonetheless (1) 92:13,20;93:5;116:7 17:10,12,15;39:23;
Milwaukee (1) 96:14;114:21 96:16 old (4) 90:12,13;92:7
32:18 Multiple (2) nor (1) 84:5;115:16,19,23 originally (1)
mind (9) 18:12;76:8 39:21 omniscient (5) 84:4
15:18;19:9,11;25:11; murder (1) normal (5) 78:23,23;79:2,7,9 others (6)
62:4;75:19;98:11; 63:1 9:18;11:7,10,19,23 one (28) 18:15;36:1;37:3;
112:4,11 murdered (1) notes (1) 8:8;12:16;18:20; 42:20;93:11;95:10
mine (3) 62:21 102:18 19:22;22:2,22;28:16; Otherwise (1)
66:5;82:15;109:6 must (1) novel (1) 35:6,7;36:11;40:17,19, 9:13
Minneapolis (1) 84:10 104:11 22;43:15;44:4;45:23; out (10)
29:9 myself (2) November (2) 50:9,21;61:1,1,10; 9:11;41:9;45:6,7;
Minnesota (1) 23:7;61:23 15:8,12 67:21;88:5;99:6; 62:9;79:16;85:20;89:2;
31:21 mystics (1) number (17) 100:15;117:10;118:3, 92:20;112:15
Min-U-Script® Baker Realtime Reporting Worldwide (7) mean - out

output (3) party (2) person/people (1) 99:20 praying (19)

40:14,18;41:1 14:22;15:1 62:8 policy (2) 38:11;41:13;42:4,8;
outside (2) passage (1) personal (10) 31:9;99:18 43:18;49:2;53:20;58:2;
94:19;114:3 43:20 16:14;21:10;25:21; political (6) 64:15;71:18;77:12,19,
over (18) passages (1) 68:12;75:3;83:11,12, 105:15;106:4;110:4, 20;93:9;97:19;108:20;
37:2,7,11,13;39:15; 75:11 18,22;110:4 19;116:16,21 116:10;117:5,12
41:13;46:7,8,13,17; past (1) Personally (4) politics (1) precursor (1)
49:2;51:10;56:18;58:3; 45:2 16:12;74:6,8;83:5 115:9 45:11
70:8;89:3;117:6,9 pastor (6) person's (3) portions (1) prefer (2)
overlapped (1) 27:3,5,15,15,17;28:6 38:14;67:16,21 83:2 68:9,11
28:3 Pat (9) philosophy (1) positions (3) prefix (1)
own (3) 105:1,3,13,21;106:2; 34:8 22:10;28:22;35:1 26:15
39:18;52:20;88:6 114:15;115:3,4,6 phrase (1) possess (1) pregnancies (1)
paying (1) 90:2 72:5 22:21
P 38:11 physical (4) possession (1) preliminary (1)
peace (2) 12:14,17;13:3;32:16 112:18 10:18
packaging (1) 47:8;62:4 piece (1) post (2) Prescriptions (1)
70:14 pejorative (1) 89:2 36:16;117:17 72:11
packing (2) 63:3 place (1) posted (1) present (2)
59:11,21 penalty (61) 44:7 41:11 13:11;73:22
page (13) 16:6,11,18;17:1,4, placeholder (1) posting (1) president (3)
8:14;46:23;55:10,16; 13;19:14;23:14,23; 14:19 53:19 109:23;110:3,12
85:5,18;87:20;89:9; 24:7;25:13;35:23;36:2, places (3) potentially (1) president's (1)
91:5,6;92:11,16,17 13,19;37:7,8,20,21; 35:2;76:4;116:7 71:1 118:8
pages (2) 38:6,23;39:13;40:20, plain (1) P-O-T-U-S (1) pressure (1)
85:4;95:2 21;41:13;46:14,17,19; 84:5 109:16 63:5
paid (1) 47:15,18,23;50:6,13; plaintiff (1) powerful (1) pretty (2)
81:4 53:2,6,11,13;58:2,15; 98:22 64:16 35:14;104:17
pain (2) 62:9,14;63:7;65:3; plan (18) practice (7) prevent (1)
88:12,16 68:22;69:6,9,15;87:1,3, 9:6;48:18;53:16,17; 66:19,20;86:23;87:2, 22:22
paragraphs (1) 8,11,16;89:14;91:11; 60:12,14,14,16,18,19; 8,11,16 prevented (2)
57:1 92:13,21;100:1;102:4, 61:5,15;63:17,21; praise (2) 46:11;113:7
paraphrasing (1) 11;106:21;112:13 70:20;72:20;73:1,18 45:16;104:20 preventing (3)
108:20 Pentobarbital (1) Planned (14) pray (62) 22:20;48:3;113:4
parent (1) 50:23 17:23;20:12,14; 37:2,7,11,13;38:19; prevents (1)
23:7 people (46) 22:14;70:15,17;72:7, 39:3;44:19;46:8,13,16; 113:1
Parenthood (4) 20:10,13;21:21; 10,14,15,19,23;73:6,15 47:5,11,12;51:10; previously (1)
17:23;20:12,14; 24:19;25:1,3,7;38:10; planning (3) 59:17;61:21;62:2,23; 33:2
22:15 48:13;50:8;62:11,20; 32:1;33:6,8 63:22;64:5,7,10,14; Preyor (1)
parlance (1) 64:5,8,10,18;65:10; plans (5) 65:8,8,14;66:14;68:3,5, 94:22
16:10 76:9;77:13,19,20; 53:10;73:7;102:7,8, 6;70:4,5,6,8;75:2,13, primaries (1)
part (24) 79:20;81:4;84:18; 12 13,15;76:20;81:2,17, 15:12
12:21;14:10;23:23; 90:22;92:8;94:4;95:23; platform (2) 21;89:3;93:7,18;95:9, primarily (1)
25:12;45:1;46:22;57:5; 102:9,14;103:11,16,22, 24:1;25:12 10;97:7,16;103:12,16, 19:12
62:6;66:19;76:14,16; 23;104:2,5,7,8,9,10; platforms (2) 23;104:2,5,7,8;107:21; primary (3)
83:16,17;88:23;90:3; 105:9,16;111:2;117:5, 36:13,18 108:17,19;109:3; 15:9;27:15;97:4
91:10,12,15;97:21; 5,8 please (4) 116:19;117:8 principle (1)
98:12;100:2,6,21; percent (4) 8:2;35:17;38:7; prayed (4) 19:23
101:8 17:11;39:18;41:18; 56:11 56:18;76:13;81:6; print (2)
partially (1) 89:16 plug (1) 96:2 84:13,21
88:15 perfect (1) 33:18 prayer (16) printed (2)
participate (1) 40:8 pm (3) 37:3,19;42:11,11,13, 84:10;85:1
42:21 perhaps (1) 82:4,6;119:4 13,15,18;44:23;45:15; printoffs (3)
participated (1) 107:20 PO (1) 64:16;71:17;76:22; 82:9,17;83:1
99:12 period (2) 12:15 78:1;93:12;117:13 prior (1)
particular (3) 74:17;78:12 point (5) prayerful (1) 84:14
77:8;80:9;99:6 permanent (1) 14:3;19:1;77:4;78:3; 38:17 priority (1)
particularly (1) 28:9 83:6 prayers (18) 100:5
38:22 person (14) points (1) 53:23;57:19;59:20; prison (3)
partnerships (1) 16:2;23:21;51:21; 44:15 66:12;77:15;78:10,13, 101:7,11,17
25:2 52:22;53:5,11;62:2,13; police (1) 14,16;79:13,14;80:13; prisons (1)
parts (1) 64:2,18,22;65:8,15; 100:18 95:19;96:7;107:20; 101:18
48:23 67:12 policies (1) 108:5,6;116:12 privacy (2)
Min-U-Script® Baker Realtime Reporting Worldwide (8) output - privacy

67:16;68:2 34:7,9 42:21 registered (1) resident (4)

private (2) PTL (3) real (3) 99:8 12:3;16:17;93:5;
42:13;103:16 104:19;114:15;115:1 24:21;66:7,11 regular (3) 107:17
privilege (1) public (33) really (5) 17:21;21:7;51:20 resources (1)
74:5 19:13;31:9;42:13,18; 24:23;36:10;104:22; regularly (3) 22:17
probably (5) 44:23;50:10;54:6; 114:19;115:18 23:9;36:23;50:8 respect (7)
11:11,21;33:7;61:9; 63:11;76:13,14,15; reason (2) reign (1) 16:19;38:5;68:1,13;
96:15 81:22;85:21,23;86:2,5, 88:14;89:13 21:1 70:7;80:6;96:1
procedures (2) 9,11,12,20;87:9,12,17; reasons (4) related (3) respond (2)
48:1;50:5 89:19;92:6,9;93:19; 24:11,14;38:1;95:17 90:19;91:20;100:18 20:13;96:15
proceedings (1) 100:22;104:6;112:17; recall (11) relating (1) responds (1)
7:1 114:4,7;117:19 23:18;32:20;33:16; 58:14 56:2
process (6) publicly (10) 36:14;58:16;63:14; relative (1) response (4)
37:11;50:13;65:4; 16:23;24:6;43:19; 86:15;88:7;95:22; 106:20 9:3,17;103:5;114:18
73:5;100:23;108:7 44:19;45:19;46:13,19; 100:9;107:2 release (1) restriction (1)
produce (1) 64:21;76:10;96:2 receipts (4) 85:19 56:10
30:21 Pueblo (2) 59:11,16,20;79:22 religion (1) restroom (1)
professional (1) 28:13,14 receive (2) 45:14 82:2
12:12 pull (1) 112:21;113:5 religious (1) results (1)
professionally (5) 80:20 received (2) 110:22 59:1
26:11,13,20;27:5; pulled (1) 49:15;112:23 remains (1) returned (1)
28:6 109:7 recently (3) 68:10 35:10
program (3) purchase (3) 18:20;37:15;84:11 remember (11) reunion (1)
31:6;33:7,9 59:11,16,21 recognize (2) 17:7;19:1,4;33:17; 47:9
programs (2) purely (1) 16:19;105:3 36:15;50:18;54:9;87:5; Reuters (1)
35:5,11 97:19 recognized (1) 108:18,21;114:17 85:14
pro-life (1) purport (1) 45:1 repeat (1) REV (1)
23:2 82:16 recognizes (1) 37:5 7:2
promote (1) purpose (3) 44:2 REPORTER (2) reveals (1)
25:3 23:16;60:12;89:12 reconciliation (1) 7:5;9:2 96:10
prophet (1) purposes (2) 89:18 reporting (2) revelation (7)
76:7 9:21;72:12 record (5) 59:1;73:14 44:10;75:10;96:4,5,
prophets (3) pushback (3) 8:3;9:21;10:5;11:15; reports (1) 8;98:15;117:4
76:9;77:11;81:9 49:9,11,16 38:1 73:4 Reverend (8)
protective (1) pushes (1) records (26) representation (1) 8:2;23:20;26:12;
50:4 96:17 15:17;37:16;54:7; 113:16 103:3;104:16;106:17;
protocol (27) put (3) 55:7,13;63:16;73:2,11; representatives (1) 109:11;118:21
37:21;46:14,18,19, 71:14;110:4;111:2 79:23;95:7;99:1,5; 24:23 review (5)
22;47:18;50:10;51:5; putting (2) 106:18;112:17,18,21, republican (1) 39:11;48:10;70:22,
53:13;54:5,8;55:15; 90:14;100:11 23;113:2,5,7,8,12,19; 14:22 23;71:7
56:15,19;57:6,18; 114:5,7;118:23 request (22) reviewing (1)
58:18,20;59:3;61:4; Q refer (3) 15:17;37:15;38:2; 39:6
63:7;67:14;86:23; 43:14;85:4;94:4 47:21;53:13;54:7;55:7, right (93)
93:19;95:4;106:19; quite (1) reference (1) 13;61:3;70:16;72:9,22; 8:21;9:6,14;11:15,
112:1 88:3 46:21 73:23;93:17;95:7;99:2; 22;15:11;16:21;17:19;
protocols (28) quote (1) referring (1) 102:2;107:1;108:4; 22:23;23:11,19;24:9;
40:21;41:13;47:15; 109:6 55:2 111:23;112:6,9 25:11,19;28:18;32:4,
48:1,10,16,20,23; refers (1) requested (9) 19;33:13;34:10;35:13;
49:10,18;50:5;51:17; R 91:22 48:16;56:4;57:3,7; 36:4,6,17,21;37:14,23;
53:2,7;58:2,3,6,13; reflect (6) 60:4,9,11;95:6;112:2 38:4,20;40:5,10;41:9,
62:9;69:7;73:18;79:16, racism (1) 39:21;40:8;84:19; requesting (1) 12,19;42:12,18;44:12;
23;86:20;87:9,17; 41:5 94:10,14;97:11 68:10 45:6,17,20;48:8,15;
92:14,21 ran (1) reflection (2) requests (3) 49:8;52:11;54:6,13;
provide (5) 83:21 40:8;62:5 69:18,20;99:5 55:23;59:7,9;60:22;
36:18;37:6;50:10; ranging (2) reflections (1) require (1) 63:2;64:17,19;66:21;
53:10;56:23 14:4;90:6 45:16 77:3 67:1,10;69:16;70:11;
provided (1) read (10) reform (6) required (1) 71:12;73:10,20;74:10;
63:19 42:20;47:17;50:14, 41:4;99:22;100:1,7; 78:7 76:12;78:1,17;79:11;
provider (2) 16;51:3;54:15;66:15; 101:2,13 research (10) 80:7;81:8,23;83:8;
23:5,6 76:10;88:2;94:1 reforms (1) 29:11,12,16,17,18; 84:13;85:2,17;88:18,
providing (3) reader (1) 100:2 52:6,10;71:10,12;72:2 22;89:4,8;92:11;93:20;
25:9;63:6;88:20 79:4 refused (1) residence (2) 94:15;96:19;98:9;
psychology (2) reading (1) 86:12 25:21;55:21 100:6;102:18;116:2,
Min-U-Script® Baker Realtime Reporting Worldwide (9) private - right

10,22;117:1,6,10,21; 66:19;76:23 25:23;26:1,2 18:11,12,12 8:7

118:3,9;119:2 scripture (16) S-H-A-N-E (1) software (1) spend (1)
Road (2) 43:21;44:3,9;75:6, 26:2 32:14 37:19
12:7;13:17 11,23;76:10,18,20; share (6) solutions (1) spent (1)
roads (1) 77:16;79:4,9;95:20,21; 48:23;51:9;113:8,11, 100:22 66:13
19:21 98:14;117:3 11,12 somebody (2) sphere (2)
Robertson (9) scriptures (4) shared (1) 74:11;116:19 92:6,10
105:1,4,13,21;106:3; 43:13;66:15;77:4; 56:17 someone (3) spirit (3)
114:15;115:3,5,6 79:7 sharing (4) 16:10;90:10,15 96:12,16,16
Robin (1) search (1) 53:23;113:1,4,7 son (1) spiritual (7)
93:23 90:23 short (2) 26:4 65:16;66:20;97:9,19,
Robinson (1) second (2) 80:17;82:5 sorry (5) 22;98:6,12
106:2 34:8;85:5 shot (2) 18:7;30:9;100:23; spoke (1)
Roby (1) seek (2) 21:4;47:1 109:14;112:8 76:9
14:20 51:17;96:7 shots (4) Sort (1) spoken (1)
roughly (2) seems (6) 49:10;56:14;58:5; 43:1 96:2
49:6;74:16 51:11;88:8;89:17; 117:18 sorts (1) square (1)
row (2) 101:5;104:17;107:10 shotting (1) 79:3 104:6
64:19;94:21 selection (1) 48:23 sought (1) squares (1)
rules (1) 21:22 show (5) 55:19 76:11
8:12 seminar (1) 39:13,14;54:16;82:7; soul (1) St (6)
running (9) 23:16 84:22 62:17 17:22;34:3,21,23;
14:15;15:1,3;16:3; seminars (1) side (1) sound (1) 35:4;65:22
23:22;24:12,14,17; 23:14 71:2 10:3 stadium (1)
84:4 seminary (5) sign (1) Sounds (2) 104:8
Russia (2) 27:22;29:1;30:4,11; 109:17 54:13;62:7 staff (5)
116:20;118:22 31:1 significance (1) source (3) 13:5,7,13;14:6,8
senior (3) 74:8 51:13;107:8,11 stages (1)
S 27:15,17;29:18 significant (1) sources (3) 29:13
sense (1) 74:7 44:2;51:16;75:6 stand (5)
sacred (3) 36:22 similar (3) Spanish (1) 8:5;17:12;19:13;
16:17;20:16;94:8 sentence (1) 48:19;73:16;108:18 94:22 89:20;91:7
sacredness (5) 87:3 similarly (1) speak (1) standing (4)
19:23;20:6,9,21;21:6 separate (1) 73:19 80:4 45:18;49:20;69:22;
safe (3) 57:6 simply (1) speakers (1) 106:12
41:21;54:2;89:19 September (1) 51:13 23:15 start (7)
SAITH (1) 73:22 sit (1) speaks (3) 9:11;17:17;34:13;
119:5 serve (1) 19:6 96:10;105:15;115:8 44:7;75:6;76:6;103:10
same (20) 24:20 sits (1) special (2) state (25)
8:8,13;10:3;16:2; served (1) 30:15 35:10,11 8:3;16:17;31:20;
23:2;27:22;28:2,4; 28:12 situation (1) specialist (2) 38:18;49:18,21;51:23;
30:18;31:4,5,10;59:10; service (3) 22:14 32:1;35:9 89:13;90:1;93:4,5,6;
60:22;61:2;62:12;66:9; 24:18;25:8;35:5 situations (1) specific (12) 99:2;100:13;106:18,
91:14;93:14,16 Services (1) 21:19 22:14;46:21,22;61:5, 22;107:3,5,8,10;
saying (12) 31:21 skinny (1) 15;63:17,21;73:3,7; 111:14,17,20;112:15,
11:18;20:17;30:10; set (1) 115:23 80:12;81:5;97:7 19
40:11,11,17;56:1; 56:12 skip (1) specifically (6) statement (2)
75:18;78:3;83:19;90:4; settings (1) 52:11 46:14;57:21;58:16; 89:20;108:4
94:23 76:13 Skipper (1) 81:7;97:8;101:1 statements (1)
scholar (1) setup (1) 14:9 specificity (19) 63:11
51:20 30:18 sleep (1) 46:17;47:12;65:14; states (50)
School (12) several (5) 48:12 67:4,19,19;75:2,13; 46:18;47:21;48:20;
28:1;30:5,6,11,19,21, 19:10;23:8;38:5; slips (2) 76:21;77:1,20,21;78:7; 49:9,11,16;50:4,8;
21;32:5,21;33:14,20; 45:23;94:20 59:12,21 80:12;81:18,21;95:19; 55:20;56:6,10,15,23;
34:14 sex (1) small (1) 96:2,7 57:5,17;58:4,14,17,19;
schools (2) 21:22 38:13 specifics (4) 59:2,4,14;68:20,23;
65:20;100:23 sexism (1) Snapchat (1) 47:16;66:4;89:1; 69:6,10,18,21;70:9;
Sclerosis (1) 41:6 36:8 97:16 85:21,22;86:2,4,8,11,
18:12 shake (1) social (11) speech (2) 19,22;87:2,7,10,15;
screen (6) 9:19 36:4;39:6,10,11,18, 23:17;117:22 94:19;110:1,3,12;
46:23;48:22;49:10; shall (3) 20;40:7,13,18;41:1; speeches (2) 111:9,11,18;116:9;
56:14;58:5;117:18 78:5,5;113:11 92:5 23:14;24:5 117:19
scriptural (2) Shane (3) Society (3) spelled (1) states' (2)
Min-U-Script® Baker Realtime Reporting Worldwide (10) Road - states'

56:19;73:17 20:18;22:23 79:17 78:18;80:23;81:16; two (9)

state's (1) suppose (1) therefore (1) 95:22;117:3 10:2;16:1;27:12;
46:22 41:15 109:2 training (3) 31:13;32:10;34:17;
step (1) sure (17) thinking (1) 58:21;59:5;73:11 74:19;87:21;92:7
75:5 17:9;19:9;24:12; 11:2 transparency (1) Tymari (2)
steps (3) 30:12;45:5;57:23;76:2; third (2) 41:6 26:5,5
63:3,5;92:19 81:8,10;82:3;84:1; 85:17;100:15 treatment (1) T-Y-M-A-R-I (1)
still (2) 106:13;107:7,22; Thou (2) 66:6 26:5
33:1;70:3 114:12;116:15;117:1 78:5,5 Trends (4) type (1)
stipulations (1) swipe (1) though (5) 29:5,10,21;31:19 65:19
7:6 66:10 11:14;51:15;55:12; tried (8) typically (1)
stop (9) sworn (1) 66:15;83:14 49:17,22;50:2; 31:7
11:12,22;63:6;116:8; 7:3 thought (3) 117:11,13,16,23;118:4
117:11,14,16;118:1,4 syndrome (1) 80:17;85:9;114:18 true (5) U
stories (1) 22:1 thoughtful (1) 60:22;61:2;62:12;
22:9 22:12 103:11;106:5 ultimately (1)
story (2) T thousands (2) Trump (1) 103:9
60:6,9 105:8,16 118:11 Um (1)
straight (1) TABITHA (3) three (9) trust (1) 115:23
33:19 7:2;8:4;23:21 24:10;29:22;31:7; 22:12 unable (2)
strategic (3) table (2) 44:17;46:3,4;96:21; truth (3) 47:19;88:12
31:23;33:6,8 13:22,23 97:4,21 9:7,7,8 unaware (1)
Street (1) tagged (1) three-year (1) truthful (1) 86:10
13:4 92:7 74:17 9:13 unchanged (1)
stretch (1) TaiChin (1) throughout (1) try (5) 68:10
11:9 94:22 77:21 9:22;19:7;63:12; unclear (1)
strike (1) talk (3) throwing (1) 81:19;102:4 110:7
115:1 8:12;11:8;103:8 29:23 trying (9) unconscious (1)
strive (1) talked (7) thumb (2) 11:21;44:16;65:6; 88:12
95:18 25:16;42:6;74:9; 82:11;85:3 67:11;68:17;74:12,13; under (5)
study (3) 81:9;95:19;100:3; tie (1) 98:1;116:8 8:22;10:22;79:17;
66:14,16,18 118:8 74:12 turnaround (1) 84:5;108:23
studying (2) talking (6) times (4) 100:23 understood (1)
66:2,13 17:15;23:20;76:16; 11:23;35:21;38:5; turns (1) 10:15
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subjects (2) 75:23 today (8) tweet (12) 109:4
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Min-U-Script® Baker Realtime Reporting Worldwide (11) state's - use

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Min-U-Script® Baker Realtime Reporting Worldwide (12) used - 9


Isner Deposition - Open Records Lawsuit

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Isner Deposition - Open Records Lawsuit

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Reverend Tabitha Isner v.

Reverend Taabitha Isner

Min-U-Script® Baker Realtime Reporting Worldwide (1) Pages 1 - 4

Min-U-Script® Baker Realtime Reporting Worldwide (2) Pages 5 - 8

1 Q. And you understand that this 1 A. No, I'm not.

Min-U-Script® Baker Realtime Reporting Worldwide (3) Pages 9 - 12

1 A. Yes. 1 democratic party? Are you running for the

1 A. Okay. 1 those two things.

Min-U-Script® Baker Realtime Reporting Worldwide (4) Pages 13 - 16

1 penalty? 1 remember at this point?

Min-U-Script® Baker Realtime Reporting Worldwide (5) Pages 17 - 20

1 A. Do I have free reign to -- 1 adoption groups, any, for lack of a better

1 syndrome child; all those choices? 1 your platform?

Min-U-Script® Baker Realtime Reporting Worldwide (6) Pages 21 - 24

1 community and listening to people, 1 A. By a church.

1 Q. Shane? 1 of Chicago Divinity School.

Min-U-Script® Baker Realtime Reporting Worldwide (7) Pages 25 - 28

1 seminary? 1 And if you were a seminary, you would also,

1 "approximately." 1 planning specialist.

Min-U-Script® Baker Realtime Reporting Worldwide (8) Pages 29 - 32

1 Q. Okay. Do you still do that, or 1 Q. And what were your positions at

1 Q. Where did you go to college? 1 in coordination with others opposing the

Min-U-Script® Baker Realtime Reporting Worldwide (9) Pages 33 - 36

Min-U-Script® Baker Realtime Reporting Worldwide (10) Pages 37 - 40

1 would your social media output cover? 1 A. Sort of, yes.

1 necessarily have to get into issues of 1 Christian Church Disciples of Christ,

Min-U-Script® Baker Realtime Reporting Worldwide (11) Pages 41 - 44

1 year? Give me a ballpark. I'm not going 1 procedures or protocols?

Min-U-Script® Baker Realtime Reporting Worldwide (12) Pages 45 - 48

1 Q. Okay. 1 Q. I don't know if you're aware,

Min-U-Script® Baker Realtime Reporting Worldwide (13) Pages 49 - 52

Min-U-Script® Baker Realtime Reporting Worldwide (14) Pages 53 - 56

1 interest in getting knowledge about the 1 conjecture.

Min-U-Script® Baker Realtime Reporting Worldwide (15) Pages 57 - 60

Min-U-Script® Baker Realtime Reporting Worldwide (16) Pages 61 - 64

1 A. Usually, yes. 1 you can get, right?

1 A. I know best how to engage with a 1 A. I -- I do respect

Min-U-Script® Baker Realtime Reporting Worldwide (17) Pages 65 - 68

1 attempts? 1 A. I have not invested my energy

Min-U-Script® Baker Realtime Reporting Worldwide (18) Pages 69 - 72

1 A. No, no plan. 1 Q. Okay. Let's go back to the need

1 that date? 1 with you, but let's do it.

Min-U-Script® Baker Realtime Reporting Worldwide (19) Pages 73 - 76

Min-U-Script® Baker Realtime Reporting Worldwide (20) Pages 77 - 80

1 would describe what you're talking about 1 Q. Do those appear to be printoffs

1 Let's take a break. I think I need to use 1 Q. Sure.

Min-U-Script® Baker Realtime Reporting Worldwide (21) Pages 81 - 84

1 A. As of the time you printed, yes. 1 death penalty.

1 A. It indicates that 15 other 1 botched, and what do you mean by botched?

Min-U-Script® Baker Realtime Reporting Worldwide (22) Pages 85 - 88

1 to get into the details, the specifics? 1 and compile different --

1 age and state of ancient understanding, but 1 A. To my church.

Min-U-Script® Baker Realtime Reporting Worldwide (23) Pages 89 - 92

1 Q. Well, answer it again. Thank 1 A. Yes.

Min-U-Script® Baker Realtime Reporting Worldwide (24) Pages 93 - 96

1 other. 1 Q. Have you ever made a records

Page 98 Page 100

Min-U-Script® Baker Realtime Reporting Worldwide (25) Pages 97 - 100

1 think you asked specifically about criminal 1 have a few questions.

Page 102 Page 104

1 the information you obtained, if 1 in the closet?

Min-U-Script® Baker Realtime Reporting Worldwide (26) Pages 101 - 104

1 let's say, Pat Robertson? 1 A. Yes, I have made a request.