ALT The BBC submits this Notice to raise newly available information regarding the “matters of national importance” that Plaintiff claimed kept him from his scheduled deposition. As the BBC now knows, on October 16, Plaintiff attended and addressed a campaign rally in Dalton, Georgia, alongside Plaintiff’s favored candidates in Georgia’s upcoming U.S. Senate and gubernatorial elections. Plaintiff subsequently traveled to his resort club and residence at Mar-a-Lago for a Republican National Committee fundraising event.

ALT No one forced Plaintiff to file this lawsuit and to dispute that his speech on January 6 incited the violence that followed at the Capitol. But as long as he chooses to maintain the case, he cannot commit the fundamental injustice of preventing the BBC from obtaining the evidence it needs to robustly defend itself on every element of his claim, including Plaintiff’s burden to prove falsity.