American Freedom Defense Initiative et al v. Suburban Mobility Authority For Regional Transportation (SMART) et al

Filing 58

MOTION for Summary Judgment by All Plaintiffs. (Attachments: # 1 Index of Exhibits, # 2 Exhibit 1--Declaration of Robert Spencer, # 3 Exhibit 2--Declaration of Pamela Geller, # 4 Exhibit 3--Declaration of Robert J. Muise, # 5 Exhibit 4--SMART deposition excerpts, # 6 Exhibit 5--SMART deposition exhibits, # 7 Exhibit 6--Beth Gibbons deposition excerpts, # 8 Exhibit 7--Pamela Geller deposition excerpts, # 9 Exhibit 8--Pamela Geller deposition exhibits, # 10 Exhibit 9--Elizabeth Dryden deposition excerpts) (Muise, Robert)

EXHIBIT 7

Pamela Geller
5/9/2013
Page 1
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IN THE DISTRICT COURT OF THE UNITED STATES

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FOR THE EASTERN DISTRICT OF MICHIGAN

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SOUTHERN DIVISION

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AMERICAN FREEDOM DEFENSE

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INITIATIVE, PAMELA GELLER, and

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ROBERT SPENCER,

8
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Plaintiffs,
-vs-

CASE NO. 2:10-cv-12134

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HON. DENISE PAGE HOOD

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SUBURBAN MOBILITY AUTHORITY

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FOR REGIONAL TRANSPORTATION

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("SMART"); GARY L. HENDRICKSON,

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Individually and in his official capacity as

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Chief Executive of SMART; JOHN HERTEL,

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Individually and in his official capacity as

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General Manager of SMART; and BETH

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GIBBONS, Individually and in her official

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capacity as Marketing Program Manager

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of SMART,

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Defendants.

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_______________________________________ /

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PAGES 1 TO 197

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Pamela Geller
5/9/2013
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Page 12
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MR. HILDEBRANDT: Do you have a middle name?

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EXHIBITS (CONTINUED):
Exhibit
Page
DEPOSITION EXHIBIT UU
Blog post
(Exhibits attached to transcript)

THE WITNESS: No.

3

MR. HILDEBRANDT: Let the record reflect that

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this is the deposition of Pamela Geller taken pursuant

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to notice to be used for all purposes under the

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Federal Rules of Evidence, the Federal Rules of Civil

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186

Procedure, and the common law.

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Can we go off the record, please?

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(An off-the-record
discussion was held)

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MR. HILDEBRANDT: Let's go on the record

11
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then.

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EXAMINATION BY MR. HILDEBRANDT:

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Q. Ms. Geller, are you currently employed?

15

A. Yes.

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Q. Where are you employed?

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A. I am president of the American Freedom Defense

18
19
20

Initiative.
Q. American Freedom Defense Initiative is a defendant -or a plaintiff in this case; is that correct?

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A. Yes. I think so.

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Q. Are you qualified here today to speak on behalf of

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American Freedom Defense Initiative as well?

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MR. MUISE: Objection. This deposition was

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not noticed as a Rule 30(b)(6) deposition. So I will

Page 11

Page 13

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Troy, Michigan

1

state for the record the answer is her -- her

2

May 9, 2013

2

deposition that is going to be taken pursuant to the

3

About 9:58 a.m.

3

notice is the deposition of Pamela Geller. You didn't

4

notice this as a 30(b)(6) deposition.

4

THE REPORTER: My name is Anne Chilton, court

MR. HILDEBRANDT: Well, I'm not required to,

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reporter with Hanson/Renaissance Court Reporting

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located at 400 Renaissance Center, Suite 2160 in

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under the court rules, to notice it as a 30(b)(6)

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Detroit, Michigan.

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deposition, as you well know.

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Today is Thursday, May 9th, 2013. This is

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MR. MUISE: No. That's exactly not true.

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the time and place for the deposition of Pamela Geller

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MR. HILDEBRANDT: Well --

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being taken at the offices of Vandeveer Garzia located

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MR. MUISE: You have to designate specific

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at 1450 West Long Lake Road, Suite 100, Troy,

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categories that you are going to -- that you want to

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Michigan, 48098.

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-- that you want to ask of a corporate entity and then

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we designate who the witness is pursuant to what

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PAMELA GELLER,

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having first been duly sworn, was examined

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your...to what questions you designated, the subject

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and testified on her oath as follows:

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matter you designate. You've done neither of those.
MR. HILDEBRANDT: Rule 30 (b)(6) is a method

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THE WITNESS: I do.

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THE REPORTER: And present today is Attorney

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in which you can identify a witness, just like a

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Robert Muise on behalf of the plaintiffs from Ann

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question at a deposition is a method in which you can

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Arbor, Michigan, Attorney Christian Hildebrandt with

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identify an appropriate witness of an organization.

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Vandeveer Garzia, Attorney Avery Gordon with SMART,

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Rule 30(b)(6) specifically says that it does not

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Plaintiff Robert Spencer, and Mr. Hildebrandt's law

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preclude a deposition by any other procedure allowed

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clerk, Chelsea Pasquali.

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by the rules. And so if Ms. Geller here is the person

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who would normally be produced as the 30(b)(6)

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witness, she can certainly identify herself as that

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and this can proceed as a witness from both based upon

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MR. HILDEBRANDT: Can you state your full
name for me, please?
THE WITNESS: Pamela Geller.

4 (Pages 10 to 13)

Pamela Geller
5/9/2013
Page 14
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the rule you cite.

Page 16
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MR. MUISE: You have to identify the subject

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matter upon which you intend to inquire of the

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corporation. You have not done that.

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of speech, freedom of conscience, freedom of religion,
freedom from religion, and individual rights.
Q. Okay. Does it have a particular focus within that
broad category?
A. I just --

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MR. HILDEBRANDT: If I choose to name the

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corporation directly, then I have to identify that and

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you get the opportunity to identify the witness, I

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BY MR. HILDEBRANDT:

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agree, that is what 30(b)(6) is for, however, in this

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Q. Does it?

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deposition I get to ask her whether she would also be

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A. I just answered the question.

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the 30(b)(6) witness and ask her questions concerning

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the corporation as well.

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MR. MUISE: It has not been properly noticed.

MR. MUISE: Objection, vague.

Q. I didn't hear because Mr. Muise was speaking at the
same time. What did you say?

12

A. I just answered the question.
Q. Okay. My question was does it have a particular focus

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She's going to be answering pursuant to her personal

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knowledge as a plaintiff in this case, Pamela Geller.

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MR. HILDEBRANDT: Okay. So she's not

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allowed, you're saying, to answer questions for AFDI.

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within that broad description you gave.
MR. MUISE: Objection, asked and answered,
vague.

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BY MR. HILDEBRANDT:

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be answering questions in her personal capacity as a

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Q. What was the answer?

19

plaintiff, Pamela Geller.

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A. It's a human rights organization dedicated to freedom

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of speech, freedom of conscience, freedom of religion,

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MR. MUISE: At this deposition she's going to

MR. HILDEBRANDT: Can you answer my question

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about whether you're going to allow her to answer

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freedom from religion, and individual rights.

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questions about AFDI with a yes or no?

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Q. Okay. Do you focus on any particular religion

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MR. MUISE: She -- whatever personal

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primarily?

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knowledge she has about AFDI, she can answer those

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A. Maybe.

25

questions, but she's not testifying here on behalf of

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Q. What would that religion be?

Page 15

Page 17
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A. Islam.

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MR. HILDEBRANDT: Fair enough.

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Q. How long have you been associated with American

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MR. MUISE: She was not noticed as such.

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MR. HILDEBRANDT: Again, I don't believe she

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A. Since 2009.
Q. I understand that you've had a number of blogs prior

1

AFDI.

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needed to be, but we'll proceed as you wish, and if we

5

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need to bring her back, we'll bring her back.

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Freedom Defense Initiative?

to that time, is that correct, since prior to that
time?

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BY MR. HILDEBRANDT:

7

8

Q. Ms. Geller, you said you were the president of

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A. What's -- what do you mean about blog?

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Q. Do you know what a blog is?

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American Freedom Defense Initiative?

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A. Yes. Executive director.

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A. I know what a blog is.

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Q. Is there a difference between president and executive

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Q. Okay.

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A. Do you mean blogs? Do you mean posts?
Q. I mean blogs, actual blogs, not specific posts.

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director or are you both?

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A. It's a distinction without difference.

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Q. Okay. It's one -- it's one thing with two names

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essentially is what you're saying; correct?

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You've been operating, for instance, the
atlasshrugs.com blog for how long?

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A. (Witness nodded.)

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A. February 2005.

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Q. Is there a title for president and a separate title

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Q. Do you have any other blogs that you regularly post on

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for executive director?

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A. I don't know.

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Q. Okay. Fair enough.

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All right. What is American Freedom Defense

or manage?
A. I have other blogs. I don't post regularly, but
American Freedom Defense Initiative has a blog.

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Q. What is the internet address for that?

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A. AFDI.US.

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A. It's a 501 -- it's a non-profit.

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Q. And how long has that been operating?

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Q. And what is its purpose?

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A. I don't recall.

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A. It is a human rights organization dedicated to freedom

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Q. Okay. Was it pretty much since the inception of AFDI?

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Initiative?

5 (Pages 14 to 17)

Pamela Geller
5/9/2013
Page 166

Page 168
religious ad. It's not a political ad.

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Q. Is this a religious ad?

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A. Yes.

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Q. There's nothing political in this ad?

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because it was a political ad and we're allowed to,

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A. No. It was The New York Times that denied me the ad.

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would you agree that this was political enough to

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They're a private company.

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Q. If you presented this to SMART and SMART rejected it

reject?

refused it?
A. Yes. I sought to run it when they were running the

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A. I wouldn't submit this ad to SMART. I would submit --

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Q. You sought to put this in The New York Times and they

Q. Why?

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A. Because I would --

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Q. It's got a graphic of a burning Quran. And who is
that individual to the left?
A. That is -- it's not The Blind Sheik. I forget his
name. He's a notorious Jihadi.

Because they don't take political ads. I

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would submit a purely religious message, that's it.

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Catholic ad, the same exact ad.

Q. Okay. A purely religious message is all you would

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submit to SMART.
A. Yes.

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And that's me. Because they had a cartoon

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DEPOSITION EXHIBIT RR

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and so we just flipped the people. It was -- it was

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WAS MARKED BY THE REPORTER

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really -- it was snarky. It was snark.

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FOR IDENTIFICATION

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Q. What do you mean by snark?

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BY MR. HILDEBRANDT:

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A. I mean I took their ad and I took out -- they had the

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Q. Okay. Let's go to the next one, which is going to be

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Pope or they had some Catholic bishop and I flipped it

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RR. Shariah: Got Fatwa? Get help! Call a number.

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with these people to make a point because I didn't

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think they would run the ad.

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A. Yeah.

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Q. Is this a political message?

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A. This is a religious message. It is the exact copy of

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23

Q. But this is a fully religious message and not a
political message?

24

A. Yeah.

24

25

Q. Obama has compromised, but Islam --

25

www.defendingreligiousfreedom.us.

a pro-Sharia ad that ran in Kansas.
Q. Okay.

Page 167

Page 169

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A. Oh.

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Q. -- never budges?

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A. Yeah.

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4

Q. Eliminating and destroying Western civilization from

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within and sabotaging its miserable house?

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A. That's a direct quote.

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Q. I understand, but is it a political quote or is it a

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9
10
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religious quote?
A. It's a religious -- well, it's a quote from Muslim
Brotherhood groups.
Q. Ask your imam: Does he support Hamas? Hizb'Allah?

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A. And I sought to run this and it did run right opposite
it.
Q. Okay. This is not political, is that what you're
saying?
A. Well, it's definitely -- it has a political aspect to
it, but it's a religious ad. It's relig- -- it's
both. Yeah. It's both.
Q. Okay. All right. Fair enough.
DEPOSITION EXHIBIT SS

9

WAS MARKED BY THE REPORTER

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FOR IDENTIFICATION

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12

The destruction of Israel? Does he condemn the

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BY MR. HILDEBRANDT:

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killing of Christians in Egypt, Nigeria, Indonesia,

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Q. Let's go to SS, and we're talking about the ad that's

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etc.?

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A. Yeah.

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Fatwa on your head? Is your family or

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Q. Does he vocally denounce Islamic honor killings, FGM,

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community threatening you? Got questions? Get

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answers! Leaving Islam? RefugeFromIslam.com.

17
18

forced marriages, child marriage, polygamy.
FGM being female genital mutilation; correct?

at issue in our particular case.

Is this a political message?

18

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A. Correct.

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A. No.

20

Q. Those are not political issues?

20

Q. Is there any political aspect of this message?

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A. The reference to Obama, clearly that's -- that --

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A. No.
Q. Can you look at RR and tell me what the political

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Obama is a political figure, but the ad is not about

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Obama.

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Q. Okay.

24

25

A. The ad is about Islam, and so that's why it's a

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aspect of that message was that is not also present in
SS?
A. Repeat.

43 (Pages 166 to 169)

Pamela Geller
5/9/2013
Page 174
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Q. Okay. Let me ask you this. Was she even honor
killed?

Page 176
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Muslims, support networks, safe houses, Ali Sena,
Nonie Darwish.

3

A. Absolutely.

3

4

Q. According to her family?

4

5

A. The family that had a hand in honor killing her?

5

A. Not to my knowledge, but, again, that's not on this --

6

Q. Well, now, wait a second. What evidence do you have

Q. Are there any political postings on
RefugeFromIslam.com?

6

Q. When did you last look at it?

7

that there's an honor killing when the prosecutor of

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A. I don't recall.

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Macomb County has determined there's not, when the

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Q. Okay.

9

sheriff's department in Macomb County has determined

9

A. But, again, the ad is what it is, it speaks for

10

there's not, and the family has asked you to stop

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itself, and honestly, all of this, different messages,

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using Jessica Mokdad's name in your conferences that

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different objectives. You may try and tie it, but

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you set up in Dearborn in her honor?

12

you, in your heart, look at this ad and it is what it

13

A. Yes.

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is. Fatwa on your head? A religious edict. A

14

Q. What is it that you have that says she was honor

14

religious edict. We know about what these religious

15

killed?

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--

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A. Apart from the fact that that has nothing to do with

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Q. The application of Sharia law; correct?

17

this ad and this -- this has nothing to do with the

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A. Not by the government.

18

ad.

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Q. Not by the government.

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A. Not by the government.
Q. Is it an issue that has been politicized?

19

Q. Now, wait a second. You said the ad ran to save the

20

honor killed and you knew the honor killed was Jessica

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Mokdad who wasn't killed in Dearborn, but that's the

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one you gave me as an example and so what I'm trying

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A. Yeah. What does that mean?

to do is explore really that.

MR. MUISE: Objection, vague.

23

BY MR. HILDEBRANDT:

24

A. Yeah.

24

Q. Well, you've answered the question before. You must

25

Q. What do you have that says she was honor killed?

25

23

have known what it --

Page 175
A. Well, her best friends who said that she feared, that

Page 177
1

A. No. I've questioned your -- that word, politicized.

2

she feared being honor murdered, and one friend who

2

Q. And I said has the issue of Sharia law been used to

3

would not -- who stopped being friends with her

3

advance a campaign or to gain a political advantage or

4

because he feared for his own life. But, again, this

4

to -- in a speech in any political fashion that's

5

has nothing to do with that and you really can't go to

5

politicizing. You acknowledged that before and

6

the family when a girl has been honor murdered because

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7

it is a family affair. But, again, that's what this

7

8

ad was. It was for girls like Rifqa Bary, a girl -- a

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Muslim girl who ran away from home.

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1

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Q. R-i-f-q-a B-a-r-r-y[sic].
Go ahead. I'm sorry. I just need to make

11
12

sure she gets the names.

10
11
12

answered the question before.
A. No. I said -- you can politicize a cupcake is what I
said.
Q. Yes, you did, but is Sharia law politicized under that
definition?
A. This is a -- this is -- this is a call to girls who
need help.

13

A. Yeah. Muslim girls who want to lead a more Western

13

14

life, Western girls like Rifqa Bary who want to lead a

14

15

more Western life, but their family is devout and

15

Q. I might.

16

their lives are in danger. That was the point of this

16

A. Really?

17

ad.

17

Q. I don't know. Try to run the ad. But, nevertheless,

How -- I don't see anything political in this

18
19

ad.

18

If this was battered wives, would you be
sitting here grilling me for six hours about this?

Sharia law is a politicized issue, is it not?
MR. MUISE: Objection, vague.

19

20

Q. Is this ad --

20

BY MR. HILDEBRANDT:

21

A. And whatever other ads I've done is completely

21

Q. This is a religious freedom issue, is that what you

22

irrelevant. This is saying is your family or your

22

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community threatening you, got questions, get answers,

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24

and Refuge From Islam, even though -- you don't have

24

25

to go off the four corners, as you put it, is former

25

say?
A. This is a help for girls, young Muslim girls' issues,
and they need it.
Q. Is there any political component to

45 (Pages 174 to 177)

Pamela Geller
5/9/2013
Page 178
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2
3

RefugeFromIslam.com?

Page 180
1

A. No.

2

MR. MUISE: Objection, asked and answered.

3

A. I guess you could say it's freedom from their
religious parents ad.
Q. Is it a religious freedom ad as you previously

4

BY MR. HILDEBRANDT:

4

testified?

5

Q. Does it link to any political websites of yours?

5

A. No, it is not.

6

A. I have no idea.

6

Q. Okay. So -- so --

7

Q. Don't all your websites cross link to each other?

7

A. It is very narrow in what it says, and honestly, SMART

8

A. What do you mean? Links on the side?

8

9

Q. Yeah.

9

did not refuse my ad for political reasons. They
refused my ad because they said it was controversial.

10

A. I -- this is not -- it's not relevant to this ad.

10

Q. No.

11

Q. Yes, it is because it's referenced in this ad.

11

A. Yes.

12

A. It's not relevant to the ad, the message of the ad.

12

Q. Does this -A. She testified. Beth -- Beth -- Beth Gibbons was it?

13

Anyone who's in trouble would go and be able to get in

13

14

contact with help. That's what this ad is. It's ver-

14

I forget -- I may have it wrong. I think it's Beth

15

-- it's very specific. It's not ambiguous. Leaving

15

Gibbons testified it was because it was controversial.

16

Islam? Is there Fatwa on your head? Is your family

16

They saw a newspaper article in the Miami Herald and

17

threatening you? Do you need help?

17

they -- they thought it was controversial and that's

18

why they refused the ad. That's what happened. You

18

And the reason --

19

Q. It doesn't say do you need help, does it?

19

wanted to morph -- you want to change it now. That's

20

A. Got questions, get answers, that to me -- okay. But

20

something else. I understand that, but that's what

21
22

clearly it's offering help.

21

Q. Is it a religious message or a religious freedom

happened.

22

Q. Is this ad disparaging to Muslims?

23

A. No. Where are Muslims being disparaged in this ad?

24

A. It is a religious message.

24

Q. Is this ad insulting a subset of Muslims?

25

Q. Okay.

25

A. No. This ad is trying to save lives, period.

23

message or both?

Page 179
1
2

A. It's for girls that are being -- that are in trouble
because of their religion.

3

Q. The last time you testified on this in court --

4

A. Yes.

5

Q. -- you said this was a religious freedom message.

6

What did you mean by religious freedom at that time?

7

A. A girl that wants to escape a dangerous household.

8

Q. Is religious freedom a political issue?

9

A. This is not a political ad.

10

Q. Can you acknowledge that this can be more than one

11

category of ad?

12

A. No, and even --

13

Q. So this is not --

14
15

So what you're saying is that this is a
religious ad.

16

A. This is a religious ad.

17

Q. This is not a political ad.

18

A. This is not a political ad.

19

Q. This is not a religious freedom ad.

20

A. This is an ad for help.

21

Q. Okay. Is this a religious freedom ad?

22

A. This is an ad to help girls.

23

Q. I get that. Is this a religious freedom ad?

24

A. It's a religious ad.

25

Q. I understand. Is this a religious freedom ad?

Page 181
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Q. Is this ad likely to hold up to scorn or ridicule
Muslims?
A. No. This ad is designed to save lives, and save
lives -Q. Whatever it's designed for, is it likely to hold up to
scorn or ridicule Muslims?
A. No.
MR. MUISE: Objection, asked and answered.
BY MR. HILDEBRANDT:
Q. Is it likely -A. It's more likely to save a life. That's what it's
more likely to do.
Q. Is it likely to -I'm not asking what's more likely.
Is it likely to hold up to scorn or ridicule
Muslim fathers that are threatening their children?
A. No.
Q. Okay. Is it likely to hold up to scorn or ridicule
communities that are threatening Muslim girls?
A. No.
Q. Is it likely to hold up to scorn or ridicule a
religious law that issues fatwas for leaving Islam?
A. No.
Q. Okay. Fair enough.
DEPOSITION EXHIBIT TT

46 (Pages 178 to 181)

Pamela Geller
5/9/2013
Page 182

Page 184

1

WAS MARKED BY THE REPORTER

1

there in order to correct the rejection; right? You

2

FOR IDENTIFICATION

2

wouldn't have bothered if it was some other rejection;
correct?

3

BY MR. HILDEBRANDT:

3

4

Q. TT. What is this ad?

4

A. I went to -- I went to -- I resubmitted it.

5

A. This is a religious ad much like the one that ran --

5

Q. Okay. Without that.

6

the one you actually did run for the atheist group.

6

And what happened when you resubmitted it?

7

Q. Where did this ad run?

7

A. They accepted it.

8

A. It didn't run.

8

Q. Okay. So without the website

9

Q. Did this ad ever run anywhere?

9

10

A. No.

10

11

Q. What was this ad created for?

11

12

A. For SMART.

12

13

Q. Okay. Specifically to run on SMART buses?

13

14

A. Yes.

14

15

Q. Was there any other purpose in presenting this ad to

TheTruthAboutMuhammad.com you would have been able to
run this ad, Don't believe in Muhammad, You are not

15

16

that sounds, yes.
Q. As much as -I mean you asked for it and they approved it.

16

SMART, perhaps as a litigation trap?

A. I didn't understand the refusal. I still don't.
Q. You asked to -- you re-presented it to run it and they

17

A. No.

17

18

Q. Okay. Fair enough.

18

So you wanted people to get the message don't

19

alone; correct?
A. As ridiculous as that sounds, it's true. As silly as

accepted it. Have you run it?

19

A. No.

20

Q. Why have you not run it?

21

A. Correct.

21

A. I just don't have the money right now, but I'll get to

22

Q. And you submitted that to SMART; correct?

22

23

A. Yes.

23

Q. Okay. You do plan on running it?

24

Q. Did SMART accept this ad?

24

A. At some point.

25

A. No.

25

Q. Okay. What is TheTruthAboutMuhammad.com?

20

believe in Muhammad, you're not alone; correct?

it.

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Page 185
A. It's a site with...or it's a page with many of

1

Q. What did SMART do?

1

2

A. They refused it.

2

3

Q. Why did they refuse it ostensibly?

3

4

A. I don't recall. You would know. I honestly don't

4

Q. Does it refer to Muhammad as a pedophile prophet?

5

A. I -- I don't know. I have to look at the site. I

5

recall the actual reason. I did go back --

Spencer's writings discussing the truth about
Muhammad.

don't know.

6

Q. Did they tell you it was disparaging to Muslims?

6

7

A. I don't recall.

7

Q. Does it insult the Islamic faiths in any way?

8

Q. Did they tell you that it would hold up to scorn or

8

A. I don't know and it's not on the ad that was accepted.

9

ridicule a group of Muslims or subset of Muslims?

9

So why are we having this conversation?

10

A. I do not recall.

10

Q. Is it political in nature, TheTruthAboutMuhammad.com?

11

Q. Did they tell you that it was political in nature?

11

A. It's a religious ad.

12

A. I don't recall.

12

Q. Is the website political in nature?

13

Q. Did they tell you that the website that it referred to

13

A. No. Not to my knowledge. If there's a link there

14
15
16
17
18
19
20
21
22

was political in nature?

14

or -- I can't -- I don't know.

A. I don't recall why.

15

Q. Do you agree that even if it was a religious message,

Q. Did you offer to run this ad without the website

16

a particular ad could likely hold somebody up to scorn

17

or ridicule?

reference?
A. I went back to them and offered to run the ad without
the website.
Q. So they obviously rejected it because of the website
reference; correct?
MR. MUISE: Objection, calls for speculation.

18

MR. MUISE: Objection, calls for speculation.

19

BY MR. HILDEBRANDT:

20

Q. Do you believe that's a possibility, that an ad could

21
22

do both?
A. I can't answer that. You want me to answer what's in
people's minds. I can't do it.

23

A. Yeah. I don't know.

23

24

BY MR. HILDEBRANDT:

24

Q. Do you acknowledge that you could have a religious

25

Q. Well, you went back to them without the website on

25

message that was holding somebody up to scorn or

47 (Pages 182 to 185)