Michael Ahrens' Jan 6th Interview Transcript
Michael Ahrens' Jan 6th Interview Transcript
7 WASHINGTON, D.C.
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17 Washington, D.C.
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20 The interview in the above matter was held via Webex, commencing at 10:05 a.m.
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2 Appearances:
8 STAFF ASSOCIATE
9 INVESTIGATIVE COUNSEL
12 FINANCIAL INVESTIGATOR
13 CHIEF CLERK
14 FINANCIAL INVESTIGATOR
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20 TODD STEGGERDA
21 EMILY KELLY
22 MCGUIREWOODS
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3 conducted by the House Select Committee to Investigate the January 6th Attack on the
5 At this time, I'd ask the witness to please state your full name and spell your last
9 although members may choose to attend and ask questions. At this time, I will note that
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counsel;
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senior investigative counsel;
17 Washington, D.C., office of our law firm. I am joined off screen but in the room by Emily
18 Kelly, an associate at McGuireWoods, and there is no one else here other than the two of
21 transcribed interview. The ground rules for the interview are as follows.
23 reported transcription is the official record of the proceeding. The proceeding is also
25 Please wait until each question is completed before you begin to respond, and we
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1 will do our best to wait until your response is complete before we ask the next question.
2 The reporter cannot note nonverbal responses, such as shaking or nodding your
3 head, so it's important that you respond to each question with an audible, verbal
4 response.
7 And we remind you that it's unlawful to deliberately provide false information to
9 Logistically, any time if you want a break, whether for comfort or to speak with
13 Okay. Great.
14 EXAMINATION
15 BY
16 Q All right. Mr. Ahrens, can you provide us, please, with your date of birth?
17 A Sure.
19 A It's
20 Q And for the period of November 2020 through January '21, did you have
22 A I did.
25 @michael_ahrens.
5
14 A So they fell into four main buckets: national press; regional and local press;
15 the research team; and the war room, who handled media monitoring.
16 Q Now, when you say the research team, does that mean you oversaw the RNC
17 research team?
18 A Yes, it does.
21 focused on the 2020 candidates, researching them; and then also a rapid response team
22 that would keep their eyes and ears on the news and candidate speeches, whatnot.
1 A It grew along the way, but by the election we were somewhere between 85
2 and a hundred.
4 A They -- I mean, they had -- they had team leads. Those were the amount of
5 people in the -- on the team. I would say I had maybe five to seven who were senior
7 Q And where would you say that, in the reporting structure, you compared to
8 Michael Reed?
10 team together.
11 Q And what about Cassie Docksey? Then, I think, Smedile was her last name.
12 A Yeah. Cassie was in charge of that first bucket that I had mentioned, the
13 national press. She was deputy communications director for national press.
17 All right. We're going to start by talking about the TMAGAC fund raising
18 apparatus. And are you familiar with TMAGAC, the fundraising committee?
19 A I am.
21 understand generally how the approval process worked, so I'm not going to recap that
22 with you. But generally our understanding is copy writers at the RNC created copy for
23 TMAGAC, and then that went up to the approval process and included individuals from
25 Is that generally what your understanding of what the approval process was for
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2 A I wasn't quite sure where the copy originated, but that's my understanding
4 Q Were you on the approval -- let's call it a listserv or chain -- for these emails
5 and texts?
6 A I was.
7 Q So then any emails that were sent and approved for TMAGAC from the
8 election through January 6th, you would have been at least on the email. We'll talk
9 about whether you did anything with that. But you were on the emails that were sent
10 out.
12 Q And what did you understand to be the process that occurred when those
15 sign-off by the RNC, there was a communications sign-off, typically a research sign-off,
16 and typically a sign-off from legal. And I never had a specific conversation about these,
17 but I just assume that that would be the case for this as well.
18 Q Okay. Then let's move forward to -- well, let's talk about the pre-election
19 period.
20 Were you at any time actively involved in approving any copy that was sent out,
24 I'm trying to get a sense, Mr. Ahrens, of whether you approved copy that went out
3 BY
4 Q Well, we can talk about press, but I'm really thinking about specific, like,
5 emails and text messages, whether they were political or fund raising in nature, but emails
6 and texts.
7 A No.
8 Q Okay. And who did you understand, pre-election, to be involved from the
12 Q And can you give us some -- can you kind of flesh out for us your
13 involvement? Was this something that was really out of your wheelhouse pre-election,
14 or were you seeing -- overseeing this from a kind of macro level? Could you just flesh
16 A I never really recall having much of a role in it. It was something that they
17 handled and something that they inherited from their predecessors. In Mike's case, that
18 was himself as the research director the cycle before, and Cassie took over that
20 And it's possible that, if one of them was at a doctor's appointment or something,
21 they'd say, "Hey, could you look at something that I'm supposed to look at?" which may
22 have included an email or like that. But I don't recall ever being actively involved.
24 Michael Reed. Anyone else from the RNC that was approving emails prior to the
2 election, our press secretary, whose name is Mandi Merritt at the time, would have
3 stepped in. I think, in a situation like that, Mike may have just taken over as well.
4 I also could be conflating it with -- conflating this with approving press releases
5 and that sort of thing. There was just a lot of content to approve from across
6 departments.
7 Q And what about the Trump campaign side? Were you aware who was on
10 Q All right. I want to move forward in time to the lead-up towards the
11 election. We have received information that TMAGAC, coming into election day, had
12 prepared a specific kind of copy in some areas and had elected not to do prepared copies
13 on other subjects.
14 Leading up to election day, what role did you have, if any, in deciding or approving
17 Q So did you have any discussions with anyone about the pre-approval of copy
20 Q Did you have any discussions with anyone about preparing copy that would
21 focus on election fraud issues or election integrity issues that would be sent out
22 post-election?
24 Q Now, from the RNC legal side, who did you understand to be on the
25 approvals chain?
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1 A Justin Riemer, who is the lead counsel, was typically on those emails. I'm
4 chains?
5 A I mean, generally speaking, legal's role in approving content was to check for
6 accuracy. As it pertained to specific fund raising emails, I wasn't part of any conversation
7 about what they were looking for or what their standards were, that sort of thing.
8 Q And where did you get your understanding that it was legal's role to check
9 the accuracy?
11 up to -- I mean, really at the start of COVID, maybe March 2020, various lawsuits in
12 different States that the RNC was involved in. And so I got to work a little bit more
14 Q So from that experience you understood that the value they added was to
16 A Generally speaking, I viewed that as something that legal was looking for.
18 A I knew Jenna because she used to work on -- she used to be part of the
19 communications team. She was on the research team, I believe, before I was
20 communications director.
21 Q And she worked with Justin Riemer on the legal team, right?
23 Q And are you aware that she was involved in approving TMAGAC emails as
24 well?
1 Q All right. Now, Mr. Ahrens, we've looked through your production, and it
2 appears that you received, at least through your personal account, a lot of these TMAGAC
4 A Yes.
5 Q And I assume, as com ms director, part of your job was also to be aware of
6 the messaging that the RNC is sending out through all its various mediums. Is that fair?
9 Q Well, no, I'm not suggesting that you're reading each one. I mean, I know
10 that there are a lot of emails that go out. I'm trying to get a sense of whether you were
11 generally aware of the messaging that was in those fundraising emails as they went out
12 post-election?
13 A From a very broad sense. I mean, I really wasn't reading any of them.
14 knew what I was hearing from the President and from the campaign, I think, in other
16 Q And it would be fair to say that, post-election, the fundraising emails focused
17 on themes such as election fraud and things of that nature. Is that fair?
18 A Generally, I think that that was something that was maybe touched on, but I
20 Q Well, when you say it was maybe touched on, we've looked through a
21 variety of these emails, and we've spoken to a variety of your colleagues, and those
22 messages are central to the post-election messaging that's coming out of TMAGAC, not
24 Is that something you were aware of in real time, that that's what the TMAGAC
1 A I was aware that there -- that content like that was focusing on the election
2 results. But, like I said, I wasn't aware of and don't recall specific fraud allegations in
3 that content.
4 Q All right. Well, Mr. Ahrens, when we look through those emails, we see
5 from November 4th on messaging that, for example, Democrats are trying to steal the
6 election. And that is a theme that runs through certainly the 2 months post-election,
8 Did you have any discussions with any senior staff at RNC about the RNC's -- let
9 me rephrase that.
10 Did you have any discussions with senior staff about the content of these
11 messages going out from the RNC or TMAGAC about the RNC's views on fraud, the RN C's
13 A No, I did not. Not that I recall. Certainly not about the fund raising copy.
14 Q And what was your focus post -- from election day forward as com ms
15 director?
17 Most reporters reached out with questions to me. I also had to lay off about 60 to 70
18 members of my team, so I was spending a lot of time meeting with them individually and
19 helping them with new jobs and fixing up resumes, that sort of thing.
20 We were also gearing up for a big fight in Georgia over the Senate seats there.
21 took some vacation. That was -- that's mostly what I was doing after the election day.
25 Q I'm just trying to get a sense of what your role was post-election. We
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1 understand that, for example, Michael Reed was involved with the fundraising emails.
4 Trying to get a sense of how you fit into the RNC com ms role here post-election.
6 A So, like I said, I was the sort of first stop for most members of the media who
7 were -- who had questions about the results, and also took a role in social media. That
8 was historically something that I was a little bit more involved in.
9 Certainly, if there was a press release, that's something that I likely, but not in
11 Q Okay. Mr. Ahrens, I want to go to about a week after the election. The
14 We've reviewed a variety of the approval email chains that you stated that you
15 were on earlier. Is it fair to say that when people replied all with the approvals, like
16 Cassie or Michael Reed, you would have been receiving those as well? Is that fair?
17 A Yes.
22 Q Did you have discussions offline about the approval chains post-election?
24 Q Did you have any discussions with anyone about the substance or the tone
2 Q Did you have any discussions post-election with anyone about whether or
3 not the RNC would publicly assert that President Trump had won the election?
4 A I want to make sure I understand your question right. After the election,
5 did I have any conversations with the team about -- with the RNC team about the
7 Q Yeah, the RNC's position as to publicly stating that President Trump had, in
9 A I mean, I'm sure that that's something that we discussed. You know, it's a
10 little bit of a blur about with who or when. The situation was developing from election
11 day on. So, I mean, I'm certain that we would have discussed messaging around the
14 When you say you would have discussed messaging, give us a bit of a summary
15 about what the discussions were like and what conclusions you all arrived at regarding
17 A So, I mean, typically, Mike Reed and I were in communication with Richard
18 Walters on a pretty regular basis, also Chairwoman McDaniel, and we'd be speaking as
20 Justin Riemer regularly at different points, but not consistently throughout that period.
21 And we would just make decisions based on events as they occurred about
22 how -- what we should say, what the RNC's position -- how that position should be
24 Q Did there come a time where a decision was made that the RNC's position
25 would diverge from the Trump campaign's position as it pertained to the 2020 election?
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1 A I recall there being sort of a, I recall, a divergence occurring around the time
2 that -- maybe 2 weeks, week or 2 -- I'm not quite sure -- after the election, when folks like
3 Rudy Giuliani, Sidney Powell, Jenna Ellis got involved in the President's legal efforts.
4 I don't remember a specific conversation. It just became clear that that was not
5 necessarily aligned with our legal efforts and that messaging would -- was going to be
7 Q And can you expand on the lack of alignment? What do you mean by that?
9 expert -- so I couldn't walk through in detail differences between the litigation strategies.
10 I just knew that they were no longer working as closely as they maybe were prior to that
11 and that claims that Rudy and Sidney Powell had been making weren't necessarily
13 Q So is it fair to say that the RNC was not in agreement with the statements
14 that Rudy Giuliani and Sidney Powell were making on behalf of the campaign as it
16 A I would say that that's a fair characterization. Maybe they agreed with
18 Q And was there also a divergence between, as you saw it, what the RNC was
19 willing to say about the election and what President Trump was saying about the
20 election?
22 Q And that divergence, was it fair to say, was focused on President Trump was
23 making claims about massive fraud that was dispositive and that the RNC did not agree
24 with that?
1 Q So you noted about a week or -- let's go 2 weeks after the election, the
2 timing where you suggest there was a meeting or at least an agreement at the RNC to
4 A I would say it's similar to what I said about our legal team not necessarily
5 agreeing with everything that Rudy Giuliani and Sidney Powell had said, that I'm sure
6 there were statements that the President made that the RNC would agree with about the
7 election results and certain statements that he made that we wouldn't necessarily have
8 promoted.
9 Q And what kind of statements would you, RNC, not have promoted?
11 would -- yeah, I would just need to know when it was made and a little bit of context
12 around that.
13 You know, to give you an example, the President gave, as I'm sure you're well
14 aware, gave a speech on January 6th. I remember watching that. I don't remember
15 specific claims that were made in it to cite to you now, but I do recall coming away from
16 that thinking, okay, I'm not sure that some of these statements are things that the RNC
18 Q All right. So let's talk a little bit more specifics, though. For example, I
19 believe in November and December the President was making claims that thousands of
20 dead people had voted in a way that was dispositive, that kind of fraud.
21 Did you have discussions about those statements regarding dead people voting?
24 Q Did you have discussions within the RNC that the RNC would not -- well,
25 Mr. Ahrens, let me rephrase that, let me give you some background.
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1 We've looked at a variety of these approval email chains, and what we see in a
2 variety of examples -- which I'm happy to show you, but for the sake of time I'm not going
3 to pull them up just yet, but anything I'm referencing, to be frank, your lawyer has seen
5 But we see emails coming out from -- revisions coming from Justin Riemer and
6 Jenna Kirsch specifically that happened about November 11th through November 20th
7 where there are edits made that appear consistent with what you're saying, which is a
8 divergence between what President Trump is claiming, or the campaign, and the RNC.
9 So, for example, in one email Mr. Riemer removes a line that Joe Biden should not
10 wrongfully claim the office of the President. In another email, Mr. Riemer removes the
11 line that says that President Trump won the election by a lot and, instead, says a whole
12 different phrasing, that he got 71 million votes, as opposed to saying he won the election.
13 Jenna Kirsch makes edits of a similar ilk, meaning that they removed one line that
15 Are those kind of edits consistent with the divergence between the RNC and the
17 A You know, I definitely am -- I'm here to be helpful, but I never saw that email
18 or those revisions or -- and so it's a little difficult for me to give you a complete answer on
20 Q Would it be helpful for me to pull them up? These are the approval emails
21 that I know you didn't -- you said you weren't replying to them, but you were receiving
22 them. So I'm happy to pull them up if that would help provide some context. Would
23 that be helpful?
24 A Yes, because, I mean, I can almost guarantee you I never opened any of
1 Mr. Steggerda. Maybe another way that would be helpful to the committee is,
2 did you have any awareness in this period from November 11th to 20th that you can
3 remember where legal appears to have been softening the TMAGAC fundraising emails?
4 Mr. Ahrens. Only to the degree that legal typically softens language in any sort
6 cautious with language. But as it pertains to the fund raising emails, I would assume that
7 that would also be the case, but I don't ever recall reading any of their edits to fundraising
8 emails.
9 Mr. Steggerda. Hey,.would you -- I know if-- I don't know if you're going to
10 pull these up or not, but would you mind if we took a quick just 5-minute break? We're
14 [Recess.]
15 BY
16 Q So, Mr. Ahrens, we were talking about you had previously mentioned a
17 divergence between the RNC and the Trump campaign as it related to statements or
18 actions being taken by Rudy Giuliani and Sidney Powell that RNC legal was not fully
20 A Yes.
21 Q Now, I want to talk specifically about President Trump and whether or not
22 you had discussions about the RNC diverging because of statements and actions he was
23 taking as it pertained to claims regarding the election and claims regarding fraud that
25 Did you have discussions about that kind of divergence, or any awareness about
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2 A I'm sure that it occurred. I mean, there were -- the President -- the former
3 President would say something, and if it was controversial, oftentimes those folks that I
4 mentioned before, like the chairwoman, Mike Reed, Richard Walters, and I would usually
5 have a brief follow-up discussion about it. Not always, but it kind of depended on the
6 circumstance. And that happened as a regular course of the job before the election, and
8 Q Now, when you say "things that were controversial," is it fair to say that
9 President Trump sometimes made claims post-election about things that were false that
10 you and the chairwoman and Mr. Walters and Mr. Reed would then have to discuss about
12 A Usually what would happen is a reporter would ask -- would reach out and
13 ask for the RNC's view on a statement that the President made, particularly if it pertained
14 to us or something that we were involved in. That would spur a discussion internally
16 No specific event like that pops out in my mind, but I'm sure that there were cases
17 like that.
18 Q When you say "cases like that," cases about the President saying things that
20 A Yes.
21 Q And did you have discussions with the chairwoman about how the RNC
22 would deal with false statements from President Trump about the election?
23 A Well, like I said, it was usually more like a case-by-case basis. I don't think
24 there was a moment where we said, "Okay, this is the standard that we are going to
25 apply."
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1 Typically she would have conversations with the legal team, or I would have
2 conversations with the legal team, and some group of us would sort out how we were
4 Q So is it fair to say that, if the President said something that was, for lack of a
5 better term, more extreme, the RNC might make a statement that diverged? If there
8 agreed, we would --
9 Q Exactly. Are you basically saying you took the President's statements on a
10 case-by-case basis on whether or not the RNC would publicly diverge from them as it
12 A Yes. But sometimes -- I mean, the President spoke a lot. Sometimes the
13 President would say something and we would neither repeat it or diverge. It would just
14 usually depend on -- a lot of times it would depend on if we were asked about it, at least
15 as it pertained to communications.
16 Q Now, did you have any discussions from the com ms perspective as to the
17 specific claims that the election was stolen through dispositive fraud?
18 And I'm not talking about what we would call election integrity that's often
19 referenced or things of that nature, but, for example, things that are more of the ilk of
20 dead people were voting, or so-called illegal immigrants voted, things that would be
21 traditional election fraud that the President was making claims about.
22 Did the RNC have discussions post-election as to whether it would diverge from
24 A Not that I recall. I mean, not -- certainly not to the level of -- I mean, we
25 had discussions about generally where there was a news report about a dead person
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1 voting or a noncitizen voting as some localities were trying to do. But I don't remember
2 a discussion as it pertained to that amount of fraud that you've cited, from instances that
3 you've cited, was going to impact the outcome of the election and lead to Trump winning.
4 Q I'm sorry. Can you just rephrase that last part for me? I want to make
6 A I don't recall a specific conversation about there being so much fraud from
7 dead people voting or noncitizens voting that it would change the outcome of the
8 election, because I took your question to mean -- I took the context of your question to
10 Q Yes.
12 Q Did you have any discussions that the RNC as an institution or senior
13 leadership would not make claims that President Trump had legitimately won the
14 election?
15 A I'm sure that we did. Nothing's standing out. I'm sure we generally had,
16 like I said before, I'm sure we generally had conversations about messaging around the
17 election results, and I think that those evolved as the results evolved.
19 from the election. As I told you -- which, again, I'm happy to show you the emails, your
20 lawyer has seen them -- there seems to be a softening of language from the RNC legal
21 team about removing claims that President Trump had won the election.
22 Would it be fair to say that it was your understanding that the RNC senior
23 leadership was in agreement with that, that they would also not claim that
25 A I think that that's fair, although I would just say -- like, I haven't seen those
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1 emails, and so I don't know exactly what the softening is that you're referring to.
2 Q Well, even without those emails, just from your perspective, from your
3 vantage point as com ms director, was it the RNC's position that President Trump had not
4 won the election by the time you get to the end of November?
5 A Yeah, I -- yes, I don't recall us stating that unequivocally he had won the
6 election or that that was part of the messaging that was coming out of the RNC.
8 Q And was the reason for that messaging because at that point the RNC had
9 not seen -- there was not evidence of fraud to support that President Trump had won
11 A Well, I mean, we weren't saying that because there was -- yeah, there was
12 not evidence that we had seen that he won the election, that Biden had not won the
13 election.
14 Q And, Mr. Ahrens, we've reviewed messages that you exchanged with Cassie.
15 And if I could ask -- we could pull them up. This would be what's been marked as
17 Hold on. Let me make sure it's page 4. Give me one second. Okay. It's
19 But before we do, it's a November 23rd email, your lawyer has seen this, in
20 which -- do we have that? If we could have that pulled up, that would be great.
21 Maybe we don't have that ready. But -- okay. Here we go. I think that's up.
22 Okay.
24 A Yes.
25 Q Okay. So if we look at the top of page 5 here, these are, I believe, Gchat or
23
1 messages you're exchanging with Ms. Docksey. And you see at the top here, you
3 In the last two messages here you say -- you tell Cassie, "Send some standard
4 language about importance of vote/integrity to Sara and Richard, please, and see if they
7 And then, starting on the top of page 5, you say, "Should have something we can
8 recycle."
11 And then she says, "And there we have it. Ha. But can keep it tucked away in
13 And then you respond, "Yeah, I am done getting yelled at for, quote, 'RNC did not
14 respond and defend Trump,' end quote." And then you say, "So better to check."
15 Oh, sorry. That wasn't being scrolled. I was reading from my own document
18 Yeah.
19 Mr. Steggerda. Yeah, if you can just give him 30 seconds to read that feed.
22 So, if you look at the top there of page 5, Mr. Ahrens, do you see what I was
23 reading from? On the right column would be the message preview text.
24 Mr. Ahrens. What was -- and what was my -- what started the conversation?
1 would be helpful, at the bottom. So it's the November 23rd exchange. Just if you
6 Mr. Ahrens. I would be speculating. I think, based on the language I'm using,
7 that would have been a media inquiry that we received and that maybe there had been
9 BY
10 Q Okay. So with reference to the line where you say, "I am done getting
11 yelled at for, quote, 'RNC did not respond and defend Trump,"' what were you
12 referencing there?
14 speaking, the former President and his team were very sensitive to whether folks were
15 out defending him. And so you often had a -- there was often a pressure to go out and
16 defend a statement that he had made or an action that they had taken. And so that's
18 Q Okay. So here -- and is it fair to say, when you say, "I'm done getting yelled
20 A Well, I assumed what would happen is that someone from the President's
21 team or the White House -- the President himself, the White House, whatnot, would
22 express to the senior leadership at the RNC, "You guys should be out there doing more,
25 Q Were there any discussions you had about how much the RNC would, in fact,
25
1 defend President Trump or the Trump campaign or decisions that the RNC would not
3 A You know, I'm sure, like I had said before, they would come up in situations
4 where the President said something that maybe our team wasn't comfortable with and
7 A You know, I don't -- it did happen frequently. I'm not trying to be cagey or
8 anything. I just -- I don't know of a specific example that I could cite where I could walk
9 through the statement that was said, the conversation that we had afterwards, and then
11 Q Well, you said it seemed like you're suggesting or you said it happened
13 A I would need -- sitting here right now, I can't think of a specific example.
14 Q Is it fair to say that there were -- it happened numerous times that related to
16 A Yeah, it happened during this period. I don't know how -- it wasn't a daily
17 thing, but oftentimes he would go and give a speech or say something provocative, and
18 we would get a press inquiry about it. And oftentimes that would guide -- be the
20 Q And when you say "something provocative," it's fair to say a lot of times
22 A Yes.
23 Q And so, in these examples, the President would say something false about
24 the election, and then the RNC would have a discussion as to how to respond to that false
1 A Well, and like I said, usually -- if he said something that was false and it was
2 particularly outlandish, we would not have necessarily had a conversation about it. But
3 if a reporter had reached out and said what's the RNC's position on this statement, that
5 with whatever the President said, true or not true, we would, like, meet to talk about it.
7 A Typically it was some collection of Mike Reed, me, Justin Riemer, Richard
8 Walters. To a lesser extent, but sometimes Chairwoman McDaniel. And that was
9 usually maybe not all of us, maybe just a one-on-one conversation, but we were
12 attention -- well, let me rephrase that. On public statements the President made that
13 garnered a lot of public attention, those are likely the kind of things that you all would
14 have discussed if the statements he had made were false. Is that fair?
16 Q Yeah, that was confusing. Well, how about this? Let me give you an
17 example.
18 The President made a lot of claims publicly regarding the Georgia ballots, the
21 Q Exactly.
22 A Yes. Yes.
23 Q All right. And are you aware that thereafter officials from Georgia
24 explained what, in fact, happened and there was no fraud that occurred that night?
25 A Yeah. I remember the episode, and I remember there being some sort of
27
1 explanation given for why the video appeared the way that it did and that it -- and that
2 that explanation made clear that it wasn't actually evidence of fraud. I don't remember
4 Q And is that the kind of thing -- or was that one of the things that you would
5 have discussed, the President's statements about that issue with the leadership team you
6 just mentioned?
7 A Potentially. I don't know if anyone ever asked us about that. If there was
8 a situation like that where we weren't asked about it, we may not have had a discussion
9 about it.
10 Q So is it fair that there were times where the President might have made false
11 statements but the RNC would not have otherwise responded to them if the media didn't
14 Q And did you all ever make the decision to not respond or to combat the
16 A Well, if there was a statement that we disagreed with, if we had gone out
17 proactively and expressed that disagreement it would have just drawn even more
18 attention to the statement. That certainly would get more media coverage.
19 So, yes, there were sometimes cases where we maybe disagreed with what he
20 said, but it was often, like I had mentioned, that press engagement would spur us having
22 Q Did you have any discussions with RNC leadership that the President's
23 inflammatory language might lead to potential violence or something of the like in the
2 [11:10 a.m.]
3 BY
4 Q Did you have any discussions, more broadly, that the President's persistent
5 attacks on the election were in and of themselves problematic? Did you have those
8 McDaniel included, that I disagreed with some statements that he's making.
9 don't remember -- that he was making. I don't remember, you know, any specific
11 occurring.
12 Q All right. Mr. Ahrens, I want to circle back to our conversations regarding
13 Rudy Giuliani. We saw a message that you exchanged with -- with Ms. -- with Ms.
14 Docksey again in which you talked about the I think it was the November 19th press
17 A I do.
20 embarrassing.
22 A I mean, it ranged from the hair dye running down his face, the claim that a
23 dead Hugo Chavez had orchestrated international scheme to change voting machines.
24 There was a lot in there. It just didn't seem professional, and I thought it was pretty
25 embarrassing.
29
1 Q And did the other members of the RNC leadership team share your position?
2 A Generally, yes.
7 A Well, for the reasons that I gave. I thought it was, at least from a
8 communications perspective, a disaster. And I think a lot of people that were watching
10 Q Now I want to -- I know I'm kind of hopping around. But I'm just -- I want to
11 be cognizant of your time and move efficiently. We reviewed the documents you
12 produced, and thank you for those. In some of those documents, you exchanged
13 messages with Kevin Zambrano. Now Kevin Zambrano was the chief digital officer of the
14 RNC, correct?
15 A Yes.
17 assume -- have you reviewed the documents that your lawyer produced to the
18 committee?
19 A Yes, I have.
20 Q Okay. And do you recall a text message you sent to Mr. Zambrano the day
21 after the election that said: Tonight might be our last best time to raise money if the
23 A I do.
25 And Mr. Zambrano responds: Yeah, we're pushing far today. Pacing
30
2 What did you mean by "tonight might be our last best time to raise money"?
3 A So generally speaking, as was the case in this -- with this election, there's a
4 lot of media interest in the money raised between the two sides. And that starts before
5 the election with fundraising disclosures every quarter, and there's a lot of interest in
6 who raised more. Did Biden raise more? Did Trump raise more? Did the RNC raise
8 And I assuming that that's what I -- that that's what I was referring to, that there
9 was interest in, you know, how much was being raised in the 24 hours after the polls
10 closed. It's possible that Biden and the DNC had put out a figure -- I don't recall.
12 And so, that's something that I was needing to kind of keep my eye on about
13 what -- how the money was going on -- fundraising was going on on our side of things,
14 you know, and then we would have discussions about -- about, you know, whether to
16 Q All right. Now with regard to where the money was going, you included a
18 PAC, Save America. Do you recall the message I'm talking about?
19 A I remember there being a message about that. Who was -- do you have
22 Mr. Steggerda. - i s that the message that has the 99 versus 1 question in it?
24 Well, no.
25 BY
31
1 Q But it's this particular time, Mr. Ahrens, what I'm asking is it fair to say you
2 recall at some point, President Trump set up a leadership PAC after the election that
3 began -- that joined the joint -- joined the joint fundraising committee, the Joint
4 Fundraising Agreement?
5 A I remember him setting up Save America. I wasn't exactly sure how that -- I
6 don't -- I'm sure I knew at the time, because I would have been asked about it. But I
7 don't remember now exactly how that arrangement affected the other fundraising
8 entities.
9 Q Is it fair to say that you were aware, even through media inquiries, that the
10 funds that were coming out of TMAGAC towards President Trump were primarily going to
11 Save America?
12 A I think so, because -- I think so, because I think there's a limit about how
14 Q Now at this point -- sorry. Were you going to say something else?
15 A Oh, I was just going say but I'm not -- I'm not positive about how that -- how
17 Q When you say that there were limits, are you referencing because the
18 campaign was limited to spending only recount funds? That was your understanding?
19 You have an message here, which I'm happy to pull up, but you say something to the
20 effect of:
21 "On December 9th, the campaign legally ceased to exist. They can't raise money
22 into the campaign after the general and can't raise money into the recount fund after the
25 A Yeah, I think that -- that sounds right. I think that was a note that I had
32
2 Q And where did you get that note from? What was the source of the
3 information?
6 Q So, did you have -- is it fair you had discussions with the RNC leadership
7 about the role that Save America was playing in the joint fund raising agreement, the fact
8 that they were getting the money from the postelection period as opposed to the
10 A I -- you would think that I would have been, if we were receiving inquiries
11 about the fund raising apparatus. So it's possible that we would have a conversation
12 after that like the one that you're referencing where I took down some notes.
15 And some of those articles speak to the fact that the TMAGAC emails were putting
16 out messaging like raising money for the Election Defense Fund and otherwise raising
17 money to challenge the election, but the money was, in fact, going to the Save America
18 PAC.
21 part of December, and so, you know, when that was getting up and running. I'm not
22 sure I was following the stories super closely about it, but that sounds generally right.
23 Q And did you have discussions with RNC leadership about how to message
24 around the accusations that donors were being duped or otherwise misled with the
2 Q Did you ever have any discussions with RNC leadership regarding Save
5 about how the arrangement was set up and, you know, as we just mentioned, the split
6 with who, if someone gave a dollar, how that dollar was split up between the entities.
8 Q Did you have any discussions with RNC leadership that with two Senate seats
9 still up in the air, that so much money was going to a leadership PAC as opposed to the
11 A No, I don't.
12 Q Did you have any discussions about whether donors were being, or had a
13 message around the idea that donors were being misled by TMAGAC emails, claiming that
16 Q All right. I want to talk. You have some messages in which you are
17 exchanging again with Mr. Zambrano, and you speak about an inquiry from a reporter
18 that -- excuse me -- Vice President Pence might have wanted his logo removed from the
20 A I do.
22 communications -- excuse me, on that issue. And Mr. Zambrano tells you -- you say to
23 him: Is there precedent for you taking Pence out before? People are reading into this.
24 Mr. Zambrano responds: No. We were just trying new tactics. We're adding
3 call it when they -- when they create fund raising emails. They test different fonts and
4 logos and copy to see how it performs. That's what I interpreted it as.
5 Q And, here, that would be tests to see whether more money was raised,
7 A I would be guessing that that's -- that that's what but, yes, that's what I'd
9 Q Now then Mr. Zambrano then responds: But also he stopped approving us
13 Q Did you have any other conversations with Mr. Zambrano about Vice
14 President Pence stopping the RNC or TMAGAC from using his name to fund raise?
15 A It's possible, just because of the way that I started that text. Like it
16 sounded like maybe we had -- like I don't know if I called -- I got a call from the reporter.
17 I may have tried to call Kevin and then gotten 10 seconds of his time or something and
19 And then maybe he said can you text me, just because I seemed to jump in right
21 But it also could have just been some tweets on -- that were popping up on
23 I don't really remember, but I don't remember having a broader conversation with
24 Kevin outside of this exchange about the Pence role in the fundraising content.
25 Q So did you have any follow-up with this revelation that Vice President Pence
35
2 A With the reporter and the exchange that I provided but not with Kevin.
4 Q What was your takeaway from that? I mean, that, to me, seems like pretty
6 overturn it. And you've learned -- and is raising -- at that point, I think had already
7 raised $200 million off those claims, along with the RNC. And now the Vice President
9 Did you not discuss this with anyone else after hearing this from Mr. Zambrano?
11 exactly, but the text from Kevin about the name being used, I interpreted that to mean
12 that Pence didn't -- no longer wanted to be the sender of the email. And so, it would
13 either be, you know, when you would get the email for it to, say, from Mike Pence or
14 signed --
15 Mr. Steggerda. You mean the surrogate for the fund raising purposes?
16 Mr. Ahrens. Sure. So sometimes you could call it that, or the sender or the
18 And so, that's what I took his message to be, not that his name couldn't be used to
19 fundraise, because as I believe the reporter pointed out, his name was still being used in
20 the fundraising.
21 BY
23 26. It's the -- can you start on page 9 of the PDF, not 10, actually, page 9. It says "Sam
24 Stein" at the top. So here it's a December 2nd email. You write to Sam Stein.
1 A Yes.
2 Q And you say: To make sure I've heard you right, you said you had Pence
4 And then he responds: Wouldn't go that far. We have people saying Pence
6 And he says: We have folks saying it's not coincidental that his name hasn't been
8 And then you respond: So off the record, I could care less. Have no dog in this
9 at all, but the truth is people are reading into it too much. Our digital guy was like, we
10 were just testing a new end-of-month deadline logo and then our vendor messes up and
12 Would you be okay saying something like this, that RNC officials at the digital team
13 was merely testing a new logo around the end-of-month deadline, and that Trump-Pence
16 Now the digital guy you're referencing there, that's Kevin Zambrano, correct?
17 A Yes.
18 Q All right. Let's look at the message you sent with Kevin Zambrano, which
20 And then you say: Is there is precedent for you taking Pence out before?
22 Now you're emailing him -- you're texting him about your conversation with the
23 reporters, correct?
24 A You're asking if I'm texting him about the conversation with the reporter?
25 Q With the reporter, when you're saying people are reading into this, you're
37
1 talking about what the feedback you're getting from reporters. Is that right?
3 Q Okay. And then Mr. Zambrano responds: No. We were just trying new
6 A Yes.
7 Q Now Mr. Zambrano then adds. He says: But also he stopped approving us
9 Now so here, reading that, it appears he's saying, yes, on the logos, that was a
10 test. But, separately, Vice President Pence does not approve of using his name to
11 fund raise.
12 So on that second message, was it your understanding that Vice President Pence
14 A As the sender, as the surrogate for them, that's what I interpreted that to
15 be.
16 Q And are you aware of any other surrogates asking that the campaign stop
17 using -- the campaign or TMAGAC or the RNC stop using their name as a surrogate?
18 A I don't recall another case of that. It wasn't something that I really was
19 looped in on. As I've said before, a lot chimes I learn of these things because the media
21 Q So reading Mr. Stein's message, saying that we have people saying Pence
22 wants distance from it all, in addition to Mr. Zambrano saying that he understands that
23 Vice President Pence has stopped approving his name being used to fundraise, did you
24 have any further conversations with anyone about Vice President Pence's position when
25 it came to his either fundraising specifically, or more generally, where he stood with the
38
1 campaign?
5 Did you have any follow-up regarding Vice President Pence's removing of his
9 removal of approvals?
11 Q Did you ever talk to the chairwoman about learning that Vice President
14 Q Was this surprising to you? Was this -- was this a notable thing to you that
15 the Vice President no longer wanted to fundraise under his name with the campaign's
17 A I believe at the time, that he had sort of receded from public view of it or
18 was just not as out there, certainly standing alongside the President, making statements
19 about the election results that weren't in line with him. So I didn't think that it was that
20 notable.
22 there was a split between President Trump and Vice President Pence?
23 A If I recall correctly from that time, I believe that to have been the case.
24 Q Did you or anyone else within the leadership, are you aware of any
25 conversations between the RNC leadership team, in light of this understanding you have
39
1 in early December, did you have any follow-up conversations when President Trump's
2 public pressure campaign began with regard to Vice President Pence? Did this come
4 A No.
9 Q Did have you any conversations with RNC legal about the import of Vice
11 A No. And I would just -- I would just point out that, you know, that -- the
12 messages that you referred to, like, if you can see, I didn't even react to that to Kevin.
14 And I think it just speaks to the fact that I --1 didn't think of it as -- as that
15 significant, just given that surrogates sometimes, you know, have to approve certain
16 emails and whatnot, and that he had said that his name was going back on them.
17 So, you know, it wasn't a blanket, you know, "I can no longer be featured at all"
18 type of a situation.
19 Q Well, when you say the name that was going back, the only -- it's a name
20 going on the logo is the only thing that was happening. Correct?
21 A Well, yes, I mean, I think that's fairly significant if it's -- if it says Trump-Pence
23 Q But there's no assertion by Mr. Zambrano that Vice President Pence asked
24 for his name to be off the logo. The name came off the logo for testing reasons, and
25 then was being put back on. But separately, Vice President Pence had removed his
40
1 approval for his name to be used in fundraising. That's what happened, correct?
3 Q There's another message about 7 days later that you again exchanged with
4 Mr. Geldmacher where you talk about the -- you reference -- you provide a statement
5 where you say that you talk about a normal decoupling of shared lists and data to occur
8 A Yes, I do.
9 Q Now that's a decoupling of the RNC and the Trump campaign. Is that
10 correct?
11 A I believe it means -- and forgive me. This was complicated at the time.
13 But I think that it had to do with decoupling of -- of email lists for -- or lists for
14 fund raising. I believe there was a fundraising component and that -- the notes that you
15 saw, that you referenced before, that I took, I believe were -- pertain to that inquiry.
16 Q Was the -- now we have a statement here you provided to Mr. Geldmacher.
17 Did that -- did the timing of that decoupling, as you framed it, have any relation to
18 the divergence of messaging between the Trump campaign and the RNC that happened
19 postelection?
20 A That -- I don't -- I don't believe that that was the impetus for it. I remember
21 from talking to Richard Walters that it was a -- sort of a common thing that after
22 campaign was done, the presidential campaign was done, that there was, like, a winding
23 down of sorts of that relationship that had been close up to that point, but that if -- that
24 it -- I never got the sense that it was due to anything other than, like, a normal course of
25 action.
41
1 Q Now but at this time, though, President Trump is still saying -- is still
2 challenging the election. There are two Senate seats that President Trump is still
3 campaigning for.
4 Did that -- did you have any discussions with anyone as to how that played in, why
5 the decoupling would happen, when President Trump asserted things were not over yet,
6 he was actively challenging, the RNC was supporting litigation at least publicly, why
9 And just to be clear, like, I -- you know, behind the scenes, I mean, it's -- it's a -- it
10 was characterized to me as a standard course of business that any party committee and
11 presidential candidate on both sides would do. There's an intertwining of those efforts
12 and then -- and then they sort of, for legal reasons, have to separate.
16 between the RNC and the campaign, as you called it. Were there any further discussions
17 in December 2020 about that same theme, continuing that divergence, making it larger,
20 think, as time went along, the -- and the results developed that there was maybe a
21 continued divergence. But, I mean, really more of an inflexion point was a couple of
22 weeks into November that I had described with the legal, the new legal team that was
1 All right. I want to switch gears. Are you familiar with the concept of -- well, let
2 me ask you this. Are you aware that there was an effort to have Trump-Pence electors
3 cast votes in contested States regardless of the outcome? Some people would call it
4 alternative electors. Some would call it fake electors. Are you aware of that?
5 A I'm most aware of that from just media reporting after the fact.
6 Q Okay. So is it fair to say prior to January 6th, did you have any awareness
10 Q Okay. All right. I want to move forward to January 6th. Were you at the
12 A Did you -- I'm -- excuse me. Did you ask if I was there on the 5th?
16 Mr. Ahrens. No, you're right. I was down there. I think I went down on some
17 point on the 5th, because I remember I -- I was at work. I was at the office the day
20 started on the 5th or the 6th. And then maybe that's why he was actually stumbling on
21 that one.
22 Mr. Ahrens. Yeah, it actually might not have officially started until, like, the 7th
23 or something. We usually get there a little before. I don't remember what day it
24 started.
25 BY
43
1 Q So whichever day it was, the 6th happened. You're at the winter meeting
3 So we reviewed the statement. The RNC released a statement, saying the RNC
4 members condemned violence at the Capitol. And then you separately released or
5 tweeted, maybe not so-called a release. But you tweeted out a statement as well, I
6 believe. It might have been on January 7th, but either the 6th or the 7th in which you
7 said:
8 What happened today was domestic terrorism. Our soldiers have died, carrying
9 the American flag into battle for our freedom. To see that flag used in the name of
10 unfounded conspiracy theories is a disgrace to the Nation, and every decent American
14 Q Okay. Now in that tweet, you mentioned the flag being used in the name
17 A Some of them, yes. I mean, what I was -- what -- the visual that stood out
18 to me was a lot of the people who had gone to the Capitol were waving American flags
19 and they were alongside of these Q signs and QAnon Shaman that everyone's seen, that
20 we were seeing footage of. That was the kind of thing that I was referencing.
21 Q And when you say -- so when you say conspiracy theories, you're talking, for
22 example, QAnon. You're talking about elections, conspiracy regarding the election
24 A Yeah, I'm speaking about wild conspiracy theories like the one that I
25 referenced before about that Sidney Powell had said about Hugo Chavez changing the
44
1 voting machines. I mean, there was a lot that pertained to the election and with QAnon
2 and whatnot. And I thought that it was disgraceful that we were seeing that alongside
4 Q Now you were at the winter meeting with other RNC leadership, like the
6 A I was.
7 Q And when the RNC released the statement, its statement regarding the
8 attack, that -- was it fair to say that the RNC leadership team included Richard Walters
9 and the chairwoman provided thoughts and were involved in deciding how to message
11 A Not exactly. Just to set that up, I mean, I was in my hotel room by myself
12 for most of that day including when that statement went out and after.
14 So I didn't -- I don't believe I saw them until much later on. And so, you know, as we
15 were dealing with -- I'm sure you know there was a pipe bomb put outside of the RNC.
17 And then when it came time to put out statements, either from the chairwoman's
18 Twitter account, this statement that you're referencing, there was communication via
19 either email or messaging with predominantly Richard, I believe. I'm sure that there's a
20 chance that it was where Chairwoman McDaniel was as well, but we were in a separate
21 place.
22 Q Is it fair to say that the chairwoman and the rest of RNC leadership shared
24 A Eventually, yes, I think that they -- that they -- that they shared that they
25 were -- I believe away from any TVs and conducting these meetings for most of the attack
45
1 on the Capitol, and therefore, weren't seeing it in the same way that I was, because I
3 Q Did you have any discussions with anyone in RNC leadership about the role
4 President Trump played in the attack and what responsibility that he bore for the attack?
9 I know that I believed that he bore a lot of responsibility for what happened, and that that
10 was the sentiment that I expressed. A specific, you know, a specific conversation, I don't
11 remember. That's a bit of a blur at that -- at that late stage of the day.
12 BY
13 Q Did Ms. McDaniel express to you whether she thought President Trump bore
14 responsibility?
15 A I don't remember, you know, how she categor -- how she categorized that
16 day. I mean, I did -- I do recall her being disgusted with what had happened that day.
18 A Not that I -- not that I recall. I mean, I mainly recall an insistence that we
22 Q Of 2022, right?
24 months of this.
25 Q Did you have any discussions before you left about the RNC, in effect,
46
1 softening its position as it pertained to what happened at the Capitol into a more neutral
4 Q I want to turn to same January but move a few days. There was reporting
5 that went out around January 11th that indicated that Salesforce had taken action to stop
6 its -- its services from being used to insight political violence. To be specific, Salesforce
7 indicated that they were deeply troubled by the events. And it says:
8 The RNC has been a longstanding customer, predating the current administration.
9 And we have taken action to prevent its use of our services in any way that could lead to
10 violence.
12 Sa lesforce?
14 Q And what did you as com ms director do in response to that? Who did you
16 A I remember I spoke with Kevin Zambrano. I would have likely spoken with
17 Richard Walters about it. Potentially, Mike Reed would have been part of those
18 conversations. But I'm not -- I don't remember anything specifically about -- about that.
19 Q Well, here, you have Salesforce telling, you know, saying publicly that
20 they've stopped the RNC from using its services in any way that could lead to violence.
21 Did anyone brief you on what they were talking about, what action they had taken
22 against the RNC, any amount of detail so that you could be up to speed when speaking to
23 the press?
24 A My understanding, and, again, it's been -- it's been a while -- was that
25 we -- that the RNC was still able to use Salesforce. I don't know -- I actually don't recall
47
2 I -- my recollection of this was that this was more of a problem for the President
3 himself and his campaign wanting to be able to continue to fundraise than it was for us,
4 because we had had that longstanding relationship with Salesforce, and that we would
6 Q So the understanding that you just expressed, who did you get that from?
7 A Kevin Zambrano.
8 Q So Mr. Zambrano told you that this problem was more for a problem with
11 and that that's where he was -- that's what he was basing our conversation on, things that
13 Q And did you understand him to be the primary RNC contact for Salesforce?
16 else, in addition to that, were you aware of any complaints that Salesforce had received
19 specific issues that folks have. But I'm not surprised that certain people would take
20 issue.
21 Q And when you say you're not surprised by certain people taking issue, what
22 do you mean?
23 A Well, we just live in this age where, if you provide a service to folks on the
24 right, there are folks on the left that don't like that and want -- and want businesses to
1 Q How about -- let's stay specifically with the content of the emails. Are you
2 aware of any complaints as to the substance of the emails that were coming out of
5 A You're asking if I recall any of that messaging being in the fundraising emails?
6 Mr. Steggerda. No. He's asking you: Do you remember any complaints
8 Mr. Ahrens. Oh, no, I -- no, not -- I remember, after January 6th, there being
10 That's about the extent of -- I don't know if you would call that a complaint. I guess it
11 would depend on who was sharing it. That's about the extent of what I remember
13 BY
14 Q And with regard to the scrutiny you just mentioned, are you referencing
15 reporters after the 6th looking back at the TMAGAC emails and saying, you know, this
16 email, for example, is inflammatory, this email was violent in nature? Are you talking
17 about that?
18 A That kind of a thing. I mean, if IT HAD been in the press that there was an
19 issue with Salesforce, you know, it could have come up in that kind of reporting.
20 Q And when that reporting came out, did you otherwise do anything to
21 respond to that or speak with anyone in response to those increased scrutiny from the
24 You know, I personally disagreed with some of that copy that I seen at that point,
25 particularly in light of what happened on January 6th. But I don't remember speaking to
49
1 anybody about, you know, concerns with those message that had gone out, you know,
3 Q And is your -- when you say your disagreement, are you saying with the
4 benefit of seeing, you know, with the hindsight of seeing what happened on the 6th, that
5 some of that, the messaging that went out through TMAGAC was too violent or too
7 A You know, that -- that's very broad without looking at a particular example.
8 And I'm sure that I was looking at particular examples when I, you know, in the episode
10 I think that, yeah, if there were claims -- if there was a claim being made that was
11 not accurate, seeing what happened on the 6th, you know, you can look back and say,
13 Q So it's fair to say that, looking at some of the emails that went out, that
15 A I think with the rhetoric that coming from the President and his campaign
17 Q And fair to say that some of that rhetoric made it through the TMAGAC
18 emails. And those emails themselves were then -- were not helpful and went too far.
19 A I think that there, yeah, there were statements that were echoed from the
21 Q And when you say, "not helpful," you mean that they increased the change
23 A Well, when you look at it now and look what people were, you know, were
24 supporters were saying, yes, I don't think that it was -- it was helpful language.
25 Q And I don't want to beat a dead horse, but just so I want the record to be
50
1 clear. When you say what supporters are saying, what do you mean by that?
2 A Well, if you watch footage, as I'm sure you have, from January 6th, you had a
3 lot of people believing false things about the election results. And the President echoed
5 Q And it's more -- and the President, he led the way in saying those things,
6 right? He more than echoed them. He was leading the charge. Isn't that fair?
7 A I was referring to folks that were there, echoing things that the President
9 Q So, yeah, so fair to say that the emails took the President's false statement.
10 They blast them out to millions of people. And that led -- that assisted at least to some
11 degree in those people believing those false claims about the election.
12 A Yeah, I mean, the President was out, saying a lot of things. And I think
14 January 6th.
15 And, you know, without having looked at them really, there was -- I know there
16 was messaging from the President about the election in, you know, those fundraising
17 emails that were being sent out. So, you know, you could make a connection there.
18 Q On the complaints front, were you aware of any complaints about too many
19 emails going out on a single day or people unsubscribing and not getting, you know,
20 anything more technical, subscriptions, that email practices, people unsubscribed and
21 they didn't -- they were put back on, they were receiving too many emails a day? Any
24 Mr. Steggerda. Hey, llllwith respect to a break, would you all be willing to do
3 So let's take a quick break. We'll circle up, and we'll hop back on.
5 [Recess.]
7 All right. Mr. Ahrens, we're actually we're done with our
8 questions.
9 So I want to thank you for taking out the time. We appreciate the answers
10 you've provided.
11 We typically provide people, if they want anything else they want to tell us or
12 anything else they think we would have asked that we didn't that you think we should
17 If anything comes up, Mr. Ahrens, you remember something, you want to clarify
18 something, we didn't ask you something you thought we should know, don't hesitate to
19 reach out to your lawyer who can update us on anything that might come to mind after
22 Well, you both -- well, all three of you, I should say, have a
1 Bye, everyone.
1 Certificate of Deponent/Interviewee
4 I have read the foregoing _ _ pages, which contain the correct transcript of the
10 Witness Name
11
12
13
14 Date
15