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Isner Deposition - Open Records Lawsuit
Isner Deposition - Open Records Lawsuit
Isner Deposition - Open Records Lawsuit
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1 In accordance with Rule 5(d) 1 may make objections and assign grounds at
2 of The Alabama Rules of Civil Procedure, as 2 the time of trial, or at the time said
3 Amended, effective May 15, 1988, I, 3 deposition is offered in evidence, or prior
4 Victoria M. Castillo, am hereby delivering 4 thereto.
5 the original transcript of the oral 5 IT IS FURTHER STIPULATED AND
6 testimony taken on the 29th day of January, 6 AGREED that notice of filing of the
7 2018, along with exhibits. 7 deposition by the Commissioner is waived.
8 Please be advised that this 8
9 is the same and not retained by the Court 9
10 Reporter, nor filed with the Court. 10
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1 A P P E A R A N C E S (continued)
1 EXAMINATION BY MR. HARMON:
2
2 Q. Reverend Isner, would you please
3 FOR THE DEFENDANT:
3 state your name for the record?
4 Hon. Bart Harmon
4 A. Tabitha Kay Isner.
5 Hon. Joseph G. Stewart, Jr.
5 Q. What does the "K" stand for?
6 ALABAMA DEPARTMENT OF CORRECTIONS
6 A. K-A-Y.
7 301 South Ripley Street
7 Q. K-A-Y. So you spelled it and
8 Montgomery, Alabama 36104
8 you gave me the abbreviation, same one.
9 (334)353-3881
9 Thank you for being here today.
10 (334)353-3883
10 A. Uh-huh.
11 bart.harmon@doc.alabama.gov
11 Q. And I have some kind of ground
12 joseph.stewart@doc.alabama.gov 12 rules I talk about in every deposition, so
13 ********************* 13 bear with me, just so we're on the same
14 I, Victoria M. Castillo, a 14 page.
15 Court Reporter of Montgomery, Alabama, 15 Have you ever been deposed
16 acting as Commissioner, certify that on 16 before?
17 this date, as provided by the Alabama Rules 17 A. No.
18 of Civil Procedure and the foregoing 18 Q. Okay. Have you ever given
19 stipulation of counsel, there came before 19 testimony in court before?
20 me at McGUIRE & ASSOCIATES, 31 Clayton 20 A. No.
21 Street, Montgomery, Alabama, commencing at 21 Q. All right. You understand
22 1:15 p.m., REV. TABITHA ISNER, in the above 22 you're under oath?
23 cause, for oral examination, whereupon the 23 A. Yes.
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1 I get it, but it's hard for her to 1 Okay. Let's see. Let's just go
2 distinguish the two. You know, it's the 2 to the basic things and we'll get to the
3 same kind of sound. 3 case. I'm assuming you're a resident of
4 So I might ask you to clarify, 4 Montgomery?
5 but that's just for the record. Okay? 5 A. Yes, I am.
6 A. Yes, I understand that. 6 Q. What is your address?
7 Q. Okay. And if I ask a question 7 A.
8 and you don't understand or you need to be 8
9 clarified, just ask me. It won't be your 9 Q. And that's your home address?
10 fault. It will be my fault. But that will 10 A. That is my home address.
11 give me a chance to fix it maybe and make 11 Q. Do you have a business address
12 it clear. Is that okay? 12 as well, or a professional address?
13 A. Great. 13 A. I have a campaign address.
14 Q. And if you answer, I'm going to 14 Q. Is that a physical address or
15 assume you understood the question. 15 just a P.O. box?
16 A. Yes. 16 A. Yes, I have one of each.
17 Q. Okay. Just a few more 17 Q. Okay. What is your physical
18 preliminary things and we'll head on. 18 address?
19 You're feeling good today? Do you feel up 19 A. It is not -- I just want to
20 to doing this? 20 clarify it's not my address. It's an
21 A. Yes, I feel up to doing this. 21 organization that I'm a part of. Yes.
22 Q. You're not under the influence 22 Q. I got that. So, yes, the
23 of any medication at all? 23 congressional campaign office. Is that --
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1 money to First Christian Church. I give 1 a core value that you hold; is that
2 money to the Christian Church Disciples of 2 correct?
3 Christ. I give money to the Week of 3 MR. McGUIRE: I'm going to
4 Compassion. I give money to the American 4 object to form.
5 Heart Association. I give -- 5 Q. You can answer.
6 Q. What was the Compassion? I'm 6 A. Is sacredness of life --
7 sorry. 7 Q. Yeah.
8 A. The Week of Compassion. 8 A. -- something that I value? Yes,
9 Q. Week of Compassion. 9 I do value the sacredness of life.
10 Okay. What else? 10 Q. You know, and, now, some people
11 A. American Heart Society, American 11 might say, How is that value expressed in
12 Cancer Society, Multiple Sclerosis Society. 12 donating to Planned Parenthood? How would
13 If I go back further -- those I would say 13 you respond to those people that say --
14 are annual gifts. If I go back further, 14 A. Planned Parenthood does very
15 there may be others. I also give as 15 important work for the health care of women
16 friends and family members ask for gifts to 16 whose lives are very valuable and sacred.
17 something that's important to them. 17 Q. And so are you saying you would
18 Q. Okay. 18 not support their -- their abortion work?
19 A. Faith in Action Alabama is 19 It would be the non-abortion work or -- do
20 another one that I've given to recently. 20 you think an abortion is consistent with
21 Q. Do any of these groups -- now, I 21 sacredness of life?
22 didn't mean to cut you off. Is that the 22 A. You've got some time today, huh?
23 ones -- off the top of your head you 23 Q. Yeah, I'm very curious. Yes.
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1 to communicate about executions that I'm 1 does that concern, as expressed in these
2 aware of and to pray over those executions 2 accounts, go into all losses of human life?
3 and invite others to join me in prayer. 3 A. Yes, I pray about other kinds of
4 Q. So I asked this earlier, and I 4 losses as well.
5 might want you to clarify it or repeat what 5 Q. And would that be evident in
6 you said. You want to provide information 6 reviewing this social media you've just
7 about the death penalty and pray over 7 described?
8 aspects of the death penalty, but not 8 A. Huh, it -- can you clarify what
9 necessarily in opposition to it? Is that 9 you're asking?
10 fair to say or not? 10 Q. Yes. And would the social
11 A. I want to pray over the process. 11 media -- a review of the social media
12 It is the law of the land. It concerns me, 12 accounts you've just described, would that
13 and so I pray over it. 13 show a focus on the death penalty in terms
14 Q. All right. And is that why you 14 of losses of life, or would it show just as
15 recently filed this request for open 15 much concern over other examples of human
16 records that's the subject of this 16 life being lost or taken?
17 litigation? 17 A. I've never done an audit of my
18 A. I filed this because I have 18 own social media to evaluate the percent of
19 begun to spend more of my prayer life on 19 my tweets which cover various topics. I
20 the death penalty and found that the death 20 feel confident that my social media does
21 penalty protocol was not available for 21 not reflect everything about my life nor
22 Alabama, and I would like for it to be. 22 everything about what I care about. I give
23 Q. All right. Are there any other 23 to a lot of organizations, for example,
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1 reasons that you filed this opens record 1 that are on that list, and I don't tweet
2 request in this case? 2 about all of them. I don't Facebook about
3 A. No. 3 all of them. I don't Instagram about all
4 Q. All right. You have used the 4 of them.
5 word "concerns" several times with respect 5 Q. Right.
6 to the death penalty. You have concerns. 6 A. So I wouldn't -- I have never
7 And please elaborate what those concerns 7 before felt obligated to have my social
8 are, and why it's concerning to you? 8 media reflect -- be a perfect reflection of
9 A. Any time a human life is taken 9 the things that I care about.
10 I'm concerned. And I think that people 10 Q. Right. I get what you're
11 should be paying attention, praying that 11 saying. But I'm just saying, given all
12 it's done with discernment, with care, with 12 that, you never audit it, and you never
13 love. It's no small matter to take a 13 felt a duty to make the amount of social
14 person's life, no matter what they've been 14 media output equal everything you think. I
15 convicted of doing. And I think the very 15 get that.
16 least we can do is be open about what's 16 A. Yes.
17 happening and prayerful. It's being done 17 Q. I'm just saying if one were to
18 in my name as a citizen of the state of 18 only look at your social media output -- if
19 Alabama; the least I can do is pray. 19 I can use that word -- would one see it's a
20 Q. All right. And this concern for 20 lot about the death penalty and death
21 human life, if I understand, you feel 21 penalty protocols?
22 called to focus particularly on the 22 A. No, one would not say that.
23 administration of the death penalty, or 23 Q. So what kind of other subjects
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1 recognized as part of our tradition as 1 shot. It talks about at this time of the
2 demonstrated by great leaders of the past. 2 day on the day of -- on the day of an
3 It's a very common expression of 3 execution, or leading up to an execution,
4 faithfulness. 4 now is the time when the inmate is meeting
5 Q. Give me some examples. I'm sure 5 with their family. Let us pray for that
6 you're right. I'm just -- help me out 6 meeting to include closure and give the
7 here. Flesh this out. 7 family what they need and that inmate what
8 A. Martin Luther, Martin Luther 8 they need and may all find peace in this
9 King; the mystics wrote in books; the -- 9 final familial reunion. I don't, in the
10 the fathers of our faith wrote books, which 10 case of Alabama, know when that happens or
11 I would argue is the precursor to Twitter. 11 how that happens. So I pray with much less
12 Q. Okay. 12 specificity when I pray about Alabama
13 A. I think there's lots of writing 13 executions.
14 about religion and what our concerns are. 14 Q. What have you done to learn
15 Large books of prayer, large books of 15 about Alabama's death penalty protocols,
16 praise, large books of reflections. 16 the specifics that you just described?
17 Q. All right. 17 A. I have Googled and read articles
18 A. Long standing tradition of 18 about Alabama's death penalty protocol.
19 writing publicly about your faith. 19 And when I was unable to get as much
20 Q. All right. And how long have 20 information as I was able to find for other
21 you had a Twitter account? 21 states, that's when I filed the request.
22 A. I don't know. 22 Q. Have you interviewed anyone
23 Q. Several years? I mean, not one 23 about the death penalty in Alabama
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1 them on your Twitter account, and then, as 1 I'm not very good at coming up with names
2 you said, praying over them, or with them, 2 like that off the top of my head.
3 with your Twitter followers? 3 Q. I understand. Have you read
4 A. Yes. 4 court opinions that describe Alabama's
5 Q. How big is your Twitter account 5 protocol or drugs they use?
6 roughly? 6 A. No, I have not.
7 A. 2,100 followers approximately. 7 Q. And why have you not, consistent
8 Q. All right. Have you had any 8 with this need for education and
9 pushback from other states that you've used 9 information that you want to share and --
10 screen shots or examples of protocols 10 and pray over?
11 from -- other states, any pushback from 11 A. Because it -- it seems to me
12 them? Any opposition? 12 that the appropriate course of action was
13 A. No. 13 simply to go to the source and ask for the
14 Q. Any controversy? 14 information.
15 A. No, I have not received any 15 Q. So even though the information
16 pushback from other states. 16 may be available from other sources, your
17 Q. Have you tried to get the 17 choice is to go to seek Alabama's protocols
18 protocols from any state and been denied 18 from them?
19 them, other than Alabama? 19 A. Based on my Googling -- I'm not
20 A. I don't have standing in any 20 a legal scholar. I Googled like a regular
21 state but Alabama. 21 person and was not able to find the
22 Q. Have you tried? 22 information that I was looking for, so I
23 A. No. 23 asked the State for that information.
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1 getting information on Alabama's death 1 look through it and your attorney can. Not
2 penalty protocols? 2 a big deal, but that's what we're referring
3 A. No. 3 to.
4 Q. Are you cooperating with any 4 That's Exhibit 1. That's the
5 person or group in getting, other than your 5 summons and complaint in this case with
6 attorney, the Alabama death penalty 6 some exhibits attached to the complaint,
7 protocols? 7 including her open records request. That
8 A. No. 8 will be Defendant's 1.
9 Q. Other than your Twitter account, 9 Have you had a chance to look at
10 do you have plans to provide them, any 10 that page? I don't -- I didn't say you got
11 person or group, death penalty opponent, 11 to memorize all of that.
12 with the information you might get from the 12 My question, though, is you will
13 death penalty protocol request? 13 agree with me that your records request
14 A. I don't know what I would do. 14 contains a lot more than the actual
15 I -- I don't intend to -- I don't have a 15 protocol eleven other items listed on that
16 grand plan. 16 page, correct?
17 Q. So, but the plan you do have, 17 A. Correct.
18 just to sum up what you said earlier, was 18 Q. And my question to you, have you
19 posting on the Twitter account and 19 sought any of that information from other
20 praying -- 20 states?
21 A. Yes. 21 A. I'm only in residence in
22 Q. -- for certain aspects and 22 Alabama.
23 sharing that information and those prayers 23 Q. All right. Let me ask it again.
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1 with your Twitter followers? 1 Have you -- I know what you're saying, but,
2 A. Yes. I think it's a safe 2 I mean, just say it in a way that responds
3 assumption that I would continue to tweet 3 to my question.
4 the way that I have been tweeting about the 4 Have you requested any of that
5 Alabama execution protocol. 5 other information, items 2 through 12, from
6 Q. All right. In your public 6 other states?
7 records request, the first item listed is 7 A. No, I have not.
8 the current execution protocol, correct? 8 Q. And do you know if that
9 You remember that? 9 information, 2 through 12, is available
10 A. I -- I am not an expert on that 10 without restriction in other states?
11 document, but -- 11 A. Say it again, please.
12 Q. But, anyway, there was also -- 12 Q. Okay. Let me set it up a little
13 A. Sounds right. 13 bit like this -- but I'll get there. Your
14 Q. There was 11 other items on that 14 Twitter account has contained screen shots
15 list, and -- and I can read the whole 15 of protocol in other states, correct?
16 thing, or I can show you a summary of it. 16 A. Yes, it has.
17 MR. HARMON: Do you want to 17 Q. That you've shared with your
18 mark this as Exhibit 1? 18 Twitter followers, and you've prayed over
19 (Defendant's Exhibit 1 was 19 those aspects of other states' protocol,
20 marked for identification.) 20 correct?
21 Q. This is attached to the 21 A. Yes.
22 complaint in this case, and you can 22 Q. And my question is have you --
23 certainly look through it and feel free to 23 are you aware if those other states provide
1 the information described in paragraphs 2 1 checks and reporting on the results of such
2 through 12 on your list of documents 2 consciousness checks, in some states those
3 requested? 3 are details included in a protocol and in
4 A. Some of this information is 4 some states they are not. I have tweeted
5 available from other states as part of, or 5 about both training and about consciousness
6 separate from, their protocol. 6 checks.
7 Q. And if you haven't requested it, 7 Q. All right.
8 how would you know that -- the answer to 8 A. As an example.
9 that question? 9 Q. All right. How about let's go
10 A. There are websites where you can 10 to number 2 and 3 in that same list? A lot
11 obtain that information. 11 about receipts, purchase orders, packing
12 Q. And you're familiar enough with 12 slips. Are those something that you've
13 those websites to say some of this 13 seen are available on these websites from
14 information is available on those websites? 14 other states?
15 A. Yes. Yes. 15 A. No, I don't believe I've seen
16 Q. Okay. Have you ever used any of 16 any receipts or purchase orders.
17 that information from other states, other 17 Q. How would you pray -- how would
18 than the protocol, in your Twitter account 18 you use that? How would you intend to use
19 and, you know, the Twitter prayers? 19 that on your Twitter account and your
20 A. I have tweeted about many 20 Twitter prayers -- receipts, order forms,
21 things. Can you say more specifically what 21 purchase orders, checks, packing slips, et
22 you're asking? 22 cetera, described in items 2 and 3?
23 Q. Sure. We have described your 23 A. Answering that would be
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1 them one by one, unless you want to. Would 1 for murder victims as well. Absolutely.
2 the same be true in the other ones? Your 2 Q. All right. Have you ever taken
3 main request is number 1, the current 3 steps to -- harass may be pejorative --
4 execution protocol. But 2 through 12 not a 4 let's say it this way. Have you ever taken
5 specific plan, you just kind of want to, 5 steps to pressure a drug supplier or a drug
6 like you say, get them and see where it 6 manufacturer to stop providing drugs used
7 goes, what inspires? 7 in a death penalty protocol?
8 MR. McGUIRE: I'm going to 8 A. No.
9 object to form on that. You can probably 9 Q. Ever written letters like that?
10 ask each one, but I don't think it's fair 10 A. No.
11 to kind of lump them all together. 11 Q. Made public statements or used
12 MR. HARMON: Okay. That's 12 your Twitter account to try to expose drug
13 fair. 13 manufacturers or drug suppliers?
14 Q. How about 4? Do you have a 14 A. Not that I can recall.
15 specific plan on how you would use 15 Q. Okay. Let's look at number 5:
16 information on the inventories and logs for 16 Maintenance records for the equipment used.
17 lethal injection drugs described in number 17 And did you have a specific plan on how you
18 4? 18 would use that information in your -- if
19 A. Conjecture. I can imagine. 19 you were provided it?
20 Knowing when a drug was going to expire 20 A. I would need to see the
21 would change the way that I might pray 21 information to make a specific plan, but I
22 about it. Knowing who handles those drugs. 22 can imagine that I would also pray for
23 I myself wouldn't want to handle such 23 those who maintain that equipment, for
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1 drugs, drugs that I knew were going to be 1 those who have to wipe down a bed after
2 used to kill a person. So I would pray for 2 it's been used to execute a person, for
3 those who are handling those drugs and for 3 those who have to clean and dispose of
4 their peace of mind and their understanding 4 equipment before or after an execution. I
5 and reflection on the work that they're a 5 would pray for those people as well.
6 part of. 6 Q. Okay. I like the way you just
7 Q. So it sounds like you have 7 said that. Why couldn't you pray for those
8 compassion for the person/people carrying 8 people and what they do just like you just
9 out the death penalty protocols? 9 said it? I mean, you said it beautifully.
10 A. I have deep, deep compassion for 10 I want to pray for those people and -- as
11 those people. 11 they wipe down the equipment and they
12 Q. And the same would be true for 12 maintain the equipment. I mean, what's --
13 the victims of the -- of the person that's 13 I guess why would you need more?
14 been given the death penalty? 14 A. I can pray for cancer, but
15 A. The inmate who is being 15 praying for my friend Melissa who died of
16 executed, I also have compassion for their 16 cancer is a more powerful prayer.
17 soul. 17 Q. Right, I get that. But you know
18 Q. Yeah, but the victims as well? 18 the people -- name of the person on death
19 The victims -- his victims? 19 row that's being executed, right?
20 A. The people who were -- who were 20 A. Yes.
21 murdered, you're assuming -- 21 Q. And there's lots of publicly
22 Q. Yes. 22 available information on that person,
23 A. Yes. Yes, I also pray for -- 23 correct?
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1 the information in your Twitter account or 1 potentially between intended use and use in
2 your Twitter? 2 this case. I'd be looking at side effects.
3 A. Can you clarify what the 3 I'd be looking to learn as much as I can
4 question is? 4 about -- about those drugs.
5 Q. Yes. You described earlier in 5 Q. Now, you've already mentioned
6 other states there's death penalty 6 you know the names of the drugs, you can do
7 protocols, you know, are available, and 7 a lot of information review, even without
8 there's also websites that give you a lot 8 these labels? You agree with that?
9 more information about the death penalty 9 A. I -- I have not attempted that
10 administration in those states. You told 10 kind of research, so...
11 me that earlier, correct? That's what you 11 Q. Why would you not have attempted
12 told me? 12 that research? That is available, right?
13 A. Yes. There are websites where 13 You have the name of the drug? And if we
14 you can get some information about the 14 were to Google -- put those names in
15 death penalty. 15 Google, we could find a lot of information,
16 Q. That's right. And you said you 16 which would mean, the way I understand you
17 had made no effort to get more details, 17 described your prayer life, then that's a
18 made more requests in those states, 18 lot of praying and delving into the details
19 correct? 19 that you could do, correct?
20 A. I did not make requests in other 20 A. Yes.
21 states. My understanding is that I 21 Q. But you have chosen not to? Is
22 wouldn't have standing. 22 that what you just told me? Did I misstate
23 Q. But you didn't make any 23 that?
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1 text that uses the word specificity. 1 teaching of the Christian Church Disciples
2 Q. Well, I didn't -- doesn't 2 of Christ? Omniscient?
3 require that. But you just -- are there 3 A. We leave those sorts of things
4 any scriptures that you point to that you 4 to the individual reader of scripture to
5 feel like are the motivation, inspiration, 5 determine.
6 for you to have such a need for these 6 Q. But certainly the God described
7 details? 7 in those scriptures is an omniscient God?
8 A. It's not based on a particular 8 A. God is often described in
9 text. 9 scripture as omniscient.
10 Q. Okay. And you would agree 10 Q. Which means knows all things, if
11 there's a lots of examples of prophets, of 11 I got my Latin right?
12 men and women in the Bible, who are praying 12 A. Yes.
13 for people that are far away that they know 13 Q. And so if God hears our prayers,
14 very little about, and there's -- is there 14 all prayers, and God knows all things, God
15 any indication that those prayers were not 15 would -- God would know the details of
16 heard or answered in scripture that you 16 these protocols that you want to find out
17 know about? 17 about under that theory. You agree with
18 A. The Bible is an enormous book. 18 that?
19 There are examples of people praying 19 A. Yes, I think God knows how
20 without specificity and people praying with 20 people are killed.
21 specificity throughout the Bible. 21 Q. Okay. And would know every
22 Q. They're both -- 22 detail of these receipts and these
23 A. Every -- 23 protocols, these maintenance records, who's
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1 Q. Every kind of prayer. Right. I 1 doing the maintenance? He -- you can call
2 agree. 2 him a God that knows all those things?
3 I'm just saying you can't point 3 A. I don't know what God knows and
4 me to any injunction, command, decree 4 doesn't know. I'm not going to speak for
5 where, Thou shall not and thou shall, where 5 God.
6 this is -- this kind of level of 6 Q. Huh. I respect that actually.
7 specificity is required? And then we'll go 7 All right. Let's go down to -- the next
8 to tradition next. 8 thing is the tradition. Is there a
9 A. My understanding is that God 9 particular decree, command, is there
10 hears all prayers. 10 anything credal in the Disciples of Christ
11 Q. Okay. 11 Christian Church that expresses this need
12 A. Period. 12 to have specific -- specificity in your
13 Q. So he hears the prayers, even 13 prayers? Do you know?
14 your general prayers? 14 A. We don't have a creed.
15 A. I -- my understanding is that 15 Q. Okay. There was something on
16 God hears all prayers. 16 the -- on the website I looked at. It was
17 Q. All right. And according to 17 very short. And I thought it called it a
18 biblical traditions, I guess God knows all 18 creed?
19 things? 19 A. No.
20 A. Yes. 20 Q. I can pull it up. But anything
21 Q. And I think that's the term 21 that you're familiar with in terms of
22 that -- you correct me if I'm wrong -- 22 church writings -- I don't know if you have
23 omniscient. God is omniscient. Is that a 23 catechisms -- traditions, anything that
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1 read that last name. 1 respect in your faith background that have
2 A. I don't know. 2 spoken with specificity and prayed publicly
3 Q. Okay. Now, do you -- are there 3 with no direct command.
4 any tweets that refer to people being 4 How about revelation? Is there
5 executed in other countries? Is that a 5 anything in revelation, that aspect of your
6 concern of yours? 6 authority, that you feel has called you to
7 A. It is -- I'm concerned about all 7 seek more specificity in your prayers?
8 life. All life is sacred. Yes. 8 A. Yes. So revelation, as I'm
9 Q. I would think so. But do the 9 taught it -- as I have been taught it, is
10 tweets reflect that? Again, we've 10 when God speaks to you directly and reveals
11 already -- 11 things to you directly. And I have felt
12 A. No. No. 12 the holy spirit call to me to care more
13 Q. -- established your tweets don't 13 deeply about this issue. I have not always
14 reflect everything about you. 14 lived up to that call and done as much
15 A. Right. 15 as -- as I probably should to respond to
16 Q. I'm just asking the question. 16 the spirit. But, nonetheless, the spirit
17 No? 17 pushes me onward. And on my good days,
18 A. No. I have not tweeted about 18 I -- I listen --
19 executions outside the United States. 19 Q. All right.
20 Q. Okay. Okay. You have several 20 A. -- to that call.
21 tweets about the Texas inmate on death row. 21 Q. Now, those were the three things
22 I guess TaiChin Preyor? I'm not Spanish. 22 that we've got -- or maybe the four --
23 You see what I'm saying? 23 A. I should have looked for the
1 greater level of detail, is what I'm trying 1 Q. And has the death penalty reform
2 to get at? 2 been part of those criminal justice reforms
3 A. I feel like I'm misunderstanding 3 you talked about?
4 the question. 4 A. No. Those have not been
5 Q. It's okay. You know, I -- God 5 identified as priority.
6 is -- your spiritual life in general is 6 Q. All right. So what part of
7 what is motivating you? 7 criminal justice reform would that group be
8 A. To want this information? 8 advocating?
9 Q. Right. 9 A. If I recall correctly, the
10 A. Yes. 10 current issues that group is working on is
11 Q. And, I guess, in my mind the 11 civil asset forfeiture, putting an end to
12 part of your spiritual life that is the 12 civil asset forfeiture -- and there are
13 driving force in that desire are examples 13 bills in the state legislature to consider
14 from scripture? Examples are tradition and 14 that -- the defelonization of marijuana --
15 revelation? Did I summarize that fairly 15 there's a third other one.
16 enough? 16 Q. Uh-huh.
17 A. That's fairly summarized. 17 A. And then we work on some issues
18 Q. Okay. Have you ever been sued 18 related to conversations with the police
19 before, a defendant in a lawsuit? 19 department about how they handle immigrants
20 A. No. 20 in cooperation with ICE. We work with
21 Q. Before this case have you ever 21 community groups to be a part of looking
22 been a plaintiff in a lawsuit? 22 for solutions for the Montgomery Public
23 A. No. 23 Schools turnaround process. But, sorry, I
1 assumption that God knows everything and 1 Q. Does he use that Twitter handle
2 therefore he will fix it, is there a need 2 to discuss whether people should be put to
3 to pray at all? 3 death or not?
4 A. The arc of a moral universe is 4 A. Yes, he has.
5 long, but it bends towards justice, is a 5 Q. Now, death by executions occur
6 favorite quote of mine. I used to think it 6 in other countries?
7 was God who pulled on that arc. I don't 7 A. Yes, they do.
8 think that it's God who makes justice on 8 Q. And death by executions occur in
9 Earth. I think it's courts and citizens 9 other states?
10 who make justice on Earth. 10 A. Yes.
11 Q. Thank you, Reverend Isner. Are 11 Q. You live in the United States,
12 you familiar with the Twitter handle 12 don't you?
13 @POTUS? 13 A. I do.
14 MR. HARMON: I'm sorry. At? 14 Q. And you live in the state of
15 MR. McGUIRE: @POTUS, 15 Alabama, don't you?
16 P-O-T-U-S. 16 A. I do.
17 MR. HARMON: The @ sign. I 17 Q. So you're asking the state of
18 got you. 18 Alabama, in the United States of America,
19 Q. Do you know whose Twitter handle 19 for the information as a citizen of the
20 that is? 20 state and of this country, are you not?
21 A. I do. 21 A. Yes, that's correct.
22 Q. Tell me -- 22 Q. Okay. Now, does anything about
23 A. The president of the United 23 your request for this information about
1 anything that prevents you from sharing 1 access to other things. PTL didn't strike
2 those records? 2 a memory with me.
3 A. As far as I know, there is no -- 3 Q. How about Pat Robertson --
4 nothing preventing me from sharing those 4 A. Absolutely familiar with Pat
5 records if I receive them. 5 Robertson.
6 Q. Now, if there is a law that 6 Q. Who is Pat Robertson?
7 prevented you from sharing those records, 7 A. He's an evangelical Christian
8 would you share those records? 8 leader who often speaks about faith and
9 A. I would not. 9 politics.
10 Q. Is there a court order that says 10 Q. Is he alive or dead?
11 you may not share -- you shall not share 11 A. He's alive, as last I check.
12 those records, would you share them? 12 Q. White or black?
13 A. I would not. 13 A. White.
14 Q. So if I understand, based on the 14 Q. What is his approximate age? Do
15 last few questions that I asked you, you 15 you know?
16 make no representation that you will 16 A. Old.
17 violate any law -- 17 MR. HARMON: Object to that.
18 A. I -- 18 A. I'm really bad at guessing ages,
19 Q. -- with these records? 19 so I'm just going to go with old
20 A. I do not intend to violate any 20 white-haired guy.
21 law. 21 Q. Could you describe what he looks
22 Q. And you don't -- do you intend 22 like?
23 to violate any court order? 23 A. Um, he's old and kind of skinny
11 Donald Trump; is that correct? 11 neither of kin nor of counsel to any of the
16 you for your time. I think we're done 16 Reporting as a Certified Court Reporter as
19 question. 19
20 EXAMINATION BY MR. McGUIRE: 20
21 Q. To your knowledge, Reverend 21 ______________________________
22 Isner, does China, Russia, or Cuba have an 22 VICTORIA CASTILLO, ACCR #17, 9/30/18
23 open records act? 23 FREELANCE COURT REPORTER