Page:CTRL0000034607 - Deposition of Ali Alexander, (Dec. 9, 2021).pdf/96

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96

Q And I have to assume that it would be just the most logical search term for you to go to Mr. Steve Brown, who was getting your permits for you, that you should have found an email from January 4th, correct?

A No. Incorrect. What I wouldn't find, because the subject line doesn't say "Stop the Steal" or "January 6th" or "Lot 8 event." To my knowledge, that doesn't say this in this email. Again, I'm being asked questions about something that I don't recall reading and haven't read.

Q That's fine.

A But what I'm saying is those are terms that we would have used to come up with something like this. And so I didn't grab all Stephen Brown emails if they weren't—that they didn't fit into House Resolution 503.

Q So you didn't search Stephen Brown emails after January 1st and at January 6th, like between that date range? You didn't search for those Stephen Brown emails?

A I think we looked—we tried to look for—we produced thousands of records, we produced thousands of records, represented by hundreds of pages. There's five volumes of binders here on the table. And we've—I've literally worked on this full time.

And so we've been as responsive as we can. If you said, "This is a subject line that we want you to authenticate ahead of this meeting," I would have done that.

Q That's not my responsibility. But did you not search—I mean, the subject line literally says, "6th Draft Names."

A Yes. "6th" is not a term I would have looked for by itself.

 . Could we ask that perhaps maybe we have a conversation afterwards in terms of the thoroughness of the terms, given this line of conversation, that if the 6th wasn't included in the search emails that may be something that we need to discuss?