Chuck may be feeling the heat during his deposition tomorrow. The National Abortion Federation filed a motion against David Daleiden on Friday, which names Chuck by name. I’ll post the full document later, but I have posted the document (see below for link), but here’s an excerpt.

A week and a half after forcing through this clearly overbroad production, Daleiden’s “great friend,” Charles C. Johnson, began publishing it on the Internet. (Foran Decl. Exs. 5, 7.) Johnson initially claimed that he obtained the recordings from a “congressional staffer.” (Foran Decl. Exs. 6, 8.) He would later tell the Washington Post, however, that he received it from someone with the username “patriotgeist,” and that this individual did not identify themselves as being from Congress. (Foran Decl. Ex. 9.) Rather, they told Johnson that “he” was someone who felt “morally interested in having this material come out.” (Id.) At the very same time, Johnson was in frequent contact with Daleiden himself, [REDACTED].

Whether or not Johnson’s incredible cover story is to believed (NAF will depose him next week), one of two things must be true: either (1) a Congressional staffer, out of the tens of millions of potential candidates, happened to select Daleiden’s “great friend” Johnson to leak materials covered by this Court’s TRO; or (2) Daleiden forced the overbroad disclosure to Congress and then used it as a smoke screen in order to pass the same materials to Johnson, an individual notorious for publishing on the Internet intimate, private details of people’s lives (including, to take one of many abhorrent examples, the names and pictures of rape victims). (Foran Decl. Ex. 10.)

The material Johnson posted included things like a 36-minute clip from a [REDACTED]
, and an hour-and-a-half panel discussion on [REDACTED] (Foran Decl. ¶¶ 17-18, Ex. 11.) Such videos have nothing to do with material sought by the congressional subpoena. Yet the videos, now publicly disclosed, identify multiple physicians by name and show their faces. (Id.) Moreover, as explained more fully in NAF’s Motion for Preliminary Injunction which is incorporated by reference, Johnson’s disclosure of the overbroad materials [REDACTED] notwithstanding this Court’s clear and unambiguous order has led directly to further instances of harassment and intimidation against NAF’s members. (See NAF Mtn. for Prelim. Inj. at 13 (collecting instances of online harassment and death threats as a result of Johnson’s disclosures).)

NAF is asking that Daleiden be held in contempt of court for failing to produce all the documents and videos demanded of him.

Scribd Document