Defendants have filed, beneath seal, a movement in limine (Dkt. No. 128] to preclude Plaintiffs from introducing their proposed Exhibit 121. A replica of Plaintiffs’ Exhibit 121 was filed by Defendants beneath seal. Dkt. No. 115-1.
Exhibit 121 is an electronic mail from Challenge Veritas founder and president James O’Keefe to a recipient with a Challenge Veritas electronic mail tackle (whose identify is redacted), suggesting that Challenge Veritas ought to strategy its donors and “ask for his or her enter” as to when Challenge Veritas ought to put up sure of its movies, tales, evidently together with the one that’s the topic of this lawsuit (“with regards to Creamer”). O’Keefe goes on to state that, “by giving them [donors] the choice of getting their enter you’ll achieve your improvement function.”
The only real objective for which Plaintiffs would introduce this doc is to indicate that Challenge Veritas will not be a reputable information group. Actual information organizations — whether or not Fox Information, the New York Instances or every other acknowledged media outlet — don’t go to their donors, or advertisers, and ask for his or her “enter” on when tales must be run.