Wow, I watch Fox and never saw those shows. When were they on?
MEMORANDUM OF LAW IN SUPPORT OF FOX DEFENDANTS’ MOTION TO
DISMISS PURSUANT TO THE FIRST AMENDMENT AND CPLR §§3211(a)(1), (a)(7),
and (g)
Paul D. Clement (pro hac vice forthcoming)
Erin E. Murphy (pro hac vice forthcoming)
K. Winn Allen, P.C. (pro hac vice forthcoming)
KIRKLAND & ELLIS LLP
1301 Pennsylvania Avenue, N.W.
Washington, DC 20004
Telephone: 202.289.5000
Email:
paul.clement@kirkland.com
Email:
erin.murphy@kirkland.com
Email:
winn.allen@kirkland.com
I've never heard of any of those people. What shows were they on? When were they on them?
96. On November 12, 2020, Mr. Giuliani appeared on Lou Dobbs Tonight to spread the
disinformation campaign to millions of people. (Lou Dobbs Tonight, November 12,2020 (Exhibit
1)).5
At the time of his appearance, Mr. Giuliani had presented no evidence that the 2020 U.S.
election had been rigged or stolen. He provided no such evidence to Mr. Dobbs and Mr. Dobbs
had seen no such evidence. But, Mr. Dobbs was in alignment with the false story that Mr. Giuliani
and Ms. Powell wanted to spread.
Mr. Dobbs: Let’s talk about, just for a moment, an update on Dominion and
how important do you believe the concerns that are being expressed of a
number of states about the ability of these machines not to be hacked?
Mr. Giuliani: Well, first of all, the machines can be hacked. There’s no
question about that. Their machines can be hacked, but it’s far worse than
that. Dominion, Dominion is a company that’s owned by another company
Smartmatic, through its intermediary company Indra. Smartmatic is a
company that was formed way back in 2004, 2003, 2004. You’re gonna be
astonished when I tell you how it was formed. It was formed really by three