Defendants have filed, under seal, a motion in limine (Dkt. No. 128] to preclude Plaintiffs from introducing their proposed Exhibit 121. A copy of Plaintiffs’ Exhibit 121 was filed by Defendants under seal. Dkt. No. 115-1.
Exhibit 121 is an email from Project Veritas founder and president James O’Keefe to a recipient with a Project Veritas email address (whose name is redacted), suggesting that Project Veritas should approach its donors and “ask for their input” as to when Project Veritas should post certain of its videos, stories, evidently including the one that is the subject of this lawsuit (“on the subject of Creamer”). O’Keefe goes on to state that, “by giving them [donors] the option of getting their input you will succeed in your development role.”
The sole purpose for which Plaintiffs would introduce this document is to show that Project Veritas is not a legitimate news organization. Real news organizations — whether Fox News, the New York Times or any other recognized media outlet — do not go to their donors, or advertisers, and ask for their “input” on when stories should be run.