1 Miller031023

Nick Land/Secondary Sources/Texts/Miller & Power v Turner-20241125T094514Z-001/Miller & Power v Turner/1 Miller031023.pdf

1 Miller031023Nick Land / text
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Day 1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Miller & Power v Turner (Tuesday, 03 October 2023) (10.29 a.m.) MRS JUSTICE COLLINS RICE: Good morning, everyone. MR WALKER: May it please my Lady, introductions first. I appear with my junior, Ms Grossman, for the claimants, Mr Miller and Ms Power in this matter. The defendant, Mr Turner, is represented by Ms Evans of King's Counsel and Mr Scherbel-Ball. There are some issues of housekeeping, I think. The differences as to law may be apparent from the skeleton arguments that you will see from our opening and you will note that we propose that they can be dealt with at a later date, subject to how the court wants to deal with that. MRS JUSTICE COLLINS RICE: Mmhmm. MR WALKER: I understand there is an application to amend trial bundles by the defendant. Should you wish to hear more at that stage, I am sure my learned friend will assist. Other than that, it is for the parties to open the cases. And just to remind the court, 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MRS JUSTICE COLLINS RICE: Yes. MR WALKER: The issues for determination are in the list of issues. That is at volume 1, tab 35. My Lady, I do not intend to simply regurgitate the matters that are set out within the claimants' skeleton argument, which has already been served on the court and I hope that this skeleton argument sets out the law satisfactorily. If, as I have said, there are any legal issues that arise the court will know from the suggestion in our skeleton argument, that we will deal with them at a later date. And it will be Ms Grossman who will be responding on behalf of the claimants for any such issues that arise. Turning to the matters in issue, my Lady, Albert Einstein, is quoted as saying, "If you cannot explain something simply, you just do not understand it well enough", and, my Lady, I will be deliberately brief in opening as this case is, I submit, simple. Brevity is, I submit, an uncommon theme in this litigation which has been characterised by verbosity, pomposity and unnecessary complexity. And I do not intend to address at this stage every Page 1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 3 October 2023 Page 3 I know the court will have it well in mind, we have a transcriber who may need a break. MRS JUSTICE COLLINS RICE: Yes, I understand. MR WALKER: I do not know what my Lady was intending in terms of timings? MRS JUSTICE COLLINS RICE: Well, I think my clerk and the transcriber have spoken. I am obviously a bit reluctant to interrupt cross-examination. That is the issue, but perhaps we will see how we go. If time runs on, we will have to interrupt it, but, yes, that is the plan. MR WALKER: My Lady, this trial concerns a claim in libel and a counterclaim in harassment. MRS JUSTICE COLLINS RICE: Yes. MR WALKER: And the nature of the case is outlined in the agreed case summary and mutual chronology and that is at volume 1, tab 36 and tab 37 -MRS JUSTICE COLLINS RICE: Yes. MR WALKER: -- which contain the sequence of social media posts sued upon by the claimant and by the defendant. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 issue which is before the court or every fact that will be raised. This is a case about a series of tweets on Twitter and a webpage sued on in libel and a series of social media posts sued on in a counterclaim in harassment. The claim concerns a Twitter spat and it is brought in respect of a series of social media posts published by the defendant, as follows: volume 1, tab 1, allegations that Mr Miller made death threats and that is at chase level one, in other words, guilt as your Ladyship will recall from the trial of preliminary issues judgment. It is that Mr Miller made death threats and was under police investigation for them. That is volume 1, tab 1, page 1, both the tweets on that page and turning over to page 2. Moving on, allegations of harassment by Mr Miller that led to death threats. The reference is page 3 and of harassment and antisemitic propaganda. That is on the same page, 3. Allegations that Mr Miller made death threats and was under police investigation for them, page 4. On the same page, the Page 2 Page 4 1 (Pages 1 to 4) Epiq Europe Ltd (+44)207 4041400 www.epiqglobal.com casemanagers@epiqglobal.com Lower Ground, 20 Furnival Street London, EC4A 1JS
1 Miller031023Nick Land / text
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Day 1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Miller & Power v Turner allegation that he published a blog towards Hitlerian Disability Politics, which called for the killing of disabled people. Page 5, allegations of harassment and violent threats and complicity in those matters by the second claimant. Page 6, again, allegations of harassment and violent threats. Page 7, antisemitic harassment, and complicity in it. Violent harassment and complicity in it. Page 8, again, harassment, now both violent and antisemitic. Page 8 again, Ms Power is antisemitic in appearing at a conference. Page 9, antisemitic campaign. Not specified as harassment, but in the trial of preliminary issues, found as a campaign. Page 10, a content warning which, we say, speaks for itself. My Lady, put shortly, the claimants' case is that there were no death threats. That, we submit, can be judged on the face of the tweets themselves and that the defendant complains as being death threats. The most useful material for the court in determining that issue, we submit, will be the tweets themselves, which can be most easily 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 8, page 155. This tweet is sent after Mr Turner posts a tweet describing an art gallery as an Alt-Nazi gallery or Nazi space. Its central message is, we submit, "Don't bother engaging with Luke Turner." It is a personal comment and at this point we must remember that this is Twitter. It is not a platform where debate is always courteous or sophisticated. This personal comment was not even made by the first claimant. Secondly, page 161. This is the first claimant commenting on that very slanging match that the defendant was engaged in, against a young female artist named Deanna Havas. Page 166, this is not a threat. It is an overblown way of saying to the defendant, "You are effectively a keyboard warrior who can dish it out from behind a computer screen but, you cannot take it." Page 169, this is a re-tweet where the Nike logo has been deliberately cropped out by Mr Turner. It is a comment on capitalism and the vacuousness of advertising. It does not mention Mr Turner. It does not tag him. It does not reply to him, and we say, that is a Page 5 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 3 October 2023 Page 7 found in annex 2 to the defence and counterclaim. That is volume 1, tab 8, pages 160, 162 and 210. The statement given by the defendant to a police officer in which he complains of the conduct, that is volume 2, tab 48, page 1529. The crime report information systems log known as a CRIS report, which can be found at volume 1, tab 39. The claimants are plainly, we submit, not antisemites and the material attributed to them cannot found that accusation. Lastly, there was no harassment. This was effectively a slanging match that the defendant participated in willingly and knowingly. That brings me to the counterclaim, my Lady. This also concerns publications on Twitter, with some publications on Facebook, YouTube and, in the case of the second claimant, her appearance at a round table. And we could look at some of that material. I do not suggest turning it up. Firstly, the claimant liked a tweet from an account called, ParallaxOptics, volume 1, tab 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 thing. Page 178, this is the second claimant saying that Luke Turner should be arrested on charges of gross contemptibleness. It is a silly comment. It might not be something someone wants to read about themselves, but that is the height of it. Page 190. Again, this does not tag Mr Turner, doesn't reply to him. By the time the comment is made the defendant has repeatedly made accusations on Twitter about the first claimant, Deanna Havas, Daniel Keller, an art festival, an art publisher as well as others. It is a comment on his own activity in the public space. Seven. Mr Turner further claims that the second claimant harassed him by appearing at round table and not condemning another participant. We say that speaks for itself. My Lady, a principal difference between the parties' respective cases is, we submit, that the claimants case succeeds upon the documentary evidence itself that they rely upon. In contrast, we submit that the defendant's case is at least, in part dependent on either his accuracy and/or his honesty. In the libel case, the issues of liability the Page 6 Page 8 2 (Pages 5 to 8) Epiq Europe Ltd (+44)207 4041400 www.epiqglobal.com casemanagers@epiqglobal.com Lower Ground, 20 Furnival Street London, EC4A 1JS
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Day 1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Miller & Power v Turner court has to determine are serious harm and the defences. We say that as far as the claimants are concerned, their case succeeds on the material presented and on the reasonable inferences and inherent probabilities arising from that relevant material. As far as the defendant is concerned, his subjective view does not affect the issues of serious harm. Nor even in terms of the defences, the issues of truth and honest opinion and whether the publications concerned on, matters of public interest or an occasion of qualified privilege. It is part, but only part, of whether he had a reasonable belief in the public interest. And it features in the rebuttal to the occasion of qualified privilege, if found. The defendant's subjective view will need to be critically assessed. The primary purpose is to distinguish between that subjective view and what may be objectively ascertained. It is the latter, we suggest, not the former which is important. On the harassment counterclaim, so far as establishing liability goes, this is an objective 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 their exercise of freedom of speech, but that is only one part. I began, my Lady, by describing this case as being characterised by unnecessary complexity. Regrettably, much of that has arisen through how the defendant puts his defence, not just in the pleadings provided, but in his 145-page witness statement. The defendant relies extensively on evidence he contends is illustrative of fascism. My Lady, this case is not about fascism. Fascism is simply not an allegation sued upon, nor is it an allegation that is defended. It is, we submit, the manner by which the defendant seeks to complicate the issues in this case in order to extrapolate meaning or thought process where no reasonable meaning exists. The defendant contends that the statement on a matter of public interest was the presence and exposure of far right and antisemitic ideologies and the harassment of the antifascists who try to expose them. We submit this is, as is his way, an overcomplication by the defendant and is a mechanism designed to obfuscate, to divert from the real issues, Page 9 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 3 October 2023 Page 11 test in terms of the threshold issues for the defendant to prove: one, whether there was a course of conduct. Two: whether the conduct crossed over from what was regrettably, perhaps, discourteous to what was oppressive and of sufficient gravity as to meet a threshold of criminal liability. Alarming distress is guidance as to one element of the tort. It is not sufficient. Again, we say so far as the claimants are concerned, their defence succeeds on their statements, on the documentary evidence and on the reasonable inferences and inherent probabilities arising from the relevant material. So far as the defendant is concerned, any subjective experience he had of alarm or distress, we submit, is of limited importance. This does not prove that the threshold of oppressive criminal conduct was met. Again, that subjective view will need to be critically assessed to distinguish between that view and what may be objectively ascertained. So far as the defence goes, the court will of course be interested in the claimants' motivations in 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 which are in short, were death threats made; were exchanges antisemitic; was the defendant subject to harassment or did he willingly partake and elongate the unattractive argument in the metaphorical playground that Twitter can represent. As to reasonable belief, the defendant's reading, we submit, this is the mark. Case law emphasises that reasonable checks and enquiries must be made. On the defendant's own case there are mistakes and there is tardiness. For example, the defendant attributes an article entitled "Towards a Hitlerian Disability Politics", which was said to have encouraged the killing of disabled people as having been written by Mr Miller. The defendant, on reflection, concedes this is incorrect and is unable to provide the source material in any event. That is but one example. The defendant also relies on contentions about the occult, about the significance and meaning of cartoon frogs, about wolf imagery, even about a book by Chuck Palahniuk - apologies to Mr Palahniuk, if I have mispronounced his name Page 10 Page 12 3 (Pages 9 to 12) Epiq Europe Ltd (+44)207 4041400 www.epiqglobal.com casemanagers@epiqglobal.com Lower Ground, 20 Furnival Street London, EC4A 1JS
1 Miller031023Nick Land / text
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Day 1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Miller & Power v Turner - purely because Mr Miller sent a link to Ms Power about the alleged political beliefs and philosophy of individuals who are not in this case and feature only peripherally: Nick Land, Jack Stokoe, Justin Murphy. Similarly, the defendant has gone into much detail about his alleged experiences around his art project and the consequences of that art. We submit the court should not entertain a diversion of the issues onto matters that are not sued upon. My Lady, we submit that the matters in this case are clear, and the documentary evidence provided supports the case for the claimants such that, the court should find for them and against the defendant. Thank you. MRS JUSTICE COLLINS RICE: That is a very helpful overview, thank you. Did I understand you correctly to say, you will not be leading any evidence on the question of serious harm, you are relying on a wholly inferential case? Is that correct? MR WALKER: No, there will be crossexamination on serious harm and examination on serious harm. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 249 and they go through to 435. The others are just some transcripts of videos, otherwise, there is not a transcription of them, which we intend to go to at some point in the crossexaminations. If I show you visually it is about that much. So, it is not very much. MRS JUSTICE COLLINS RICE: Yes, well, I am, of course, at this stage in the trial, not particularly clear about their relevance and the use you are going to make of them. So, I suggest we get on with it, but of course, if we get to points where there are issues which arise about the fairness or otherwise of what you want to take me to, well, then I will listen to that as well. MS EVANS: Yes, of course. My Lady, thank you. I too will be brief in my opening remarks. I know that you have read obviously, the skeleton arguments and I am sure many of the other documents, obviously, particularly the statements of case and the witness statements. So, I do not intend to rehearse here what has already been said in the skeleton arguments. And you will of course, also get, no doubt, full closing Page 13 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 3 October 2023 Page 15 MRS JUSTICE COLLINS RICE: Thank you for clarifying that. I only ask because, as you will know, the courts have been quite preoccupied with the test to be met on serious harm and how inferential cases have to be put forward -MR WALKER: Yes. MRS JUSTICE COLLINS RICE: -including in Mr Justice Nicklin's judgment in Amersi this summer. So, I shall be paying close attention to that part of your case. MR WALKER: We are very grateful for that observation. Thank you, my Lady. MS EVANS: Good morning, my Lady. MRS JUSTICE COLLINS RICE: Good morning. MS EVANS: Can I just deal with the housekeeping matter that my learned friend mentioned. His description of the issue was a bit dramatic. It is just that there are a couple more documents at the back that we would like to insert. I think that they have been if not put into your Lady's bundle at volume 9, they are available. One is an update of correspondence. They start at tab 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 submissions, which in some ways are much more important of course because that is when we apply what has come out at trial to the law, or the other way round. So, I am not going to say anything about the law now. We very much also have in mind the serious harm threshold and that is something we will deal with in the closing. My Lady, what I will say now, briefly, is really therefore, for the benefit of the nonlawyers in court so, that they can understand what this case is about. My client, Luke Turner is as you know an artist and he is Jewish. In early 2017 after the election of President Trump, Mr Turner and his fellow artists who formed a trio called, LaBeouf, Rönkkö & Turner, created a durational art installation called, "He Will Not Divide US". It was intended to send a fightback message against polarisation and division in society and was a reaction to the election of President Trump. After the work was installed at a museum in New York in January 2017, the artwork which consisted of a fixed camera on the wall that filmed Page 14 Page 16 4 (Pages 13 to 16) Epiq Europe Ltd (+44)207 4041400 www.epiqglobal.com casemanagers@epiqglobal.com Lower Ground, 20 Furnival Street London, EC4A 1JS
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Day 1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Miller & Power v Turner members of the public, saying, "He Will Not Divide US", the artwork began to be the subject of attacks, both physically and via the online and media world, as is unfortunately a truism of the world that we live in. And those attacks were by proponents of what had become known in the United States at that point, as alt-right sympathisers. One can call them extremists, from the right-wing of politics. Neo-Nazis they are sometimes described as and other like terms. The attacks included appalling racist and antisemitic abuse. And such was the ferocity of them that the artwork itself had to be altered and it then had to be moved from museum to museum, each time being attacked, looking for an alt-right free space. Eventually it ended up in Europe. On the way it was subject to arson and the members of the trio and especially Mr Turner were relentlessly attacked by these alt-right types and much of the abuse continued to be antisemitic. Most of the attacks on Mr Turner were online, particularly on Twitter and other 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 continued for well over a year. In fact, Mr Turner regards it as ongoing. One reason for this is that these libel claims which the claimants brought in late 2020, or 2019 - it has been going on for so long, I cannot quite remember, but 2019 - that the libel claims were to Mr Turner a continuation of the online harassment that they had targeted at him. The libel claims accuse him of falsely defaming them, principally for stating publicly on his Twitter feed on 16 occasions that they had been involved in a harassment campaign and in four of those tweets it is described as being of an antisemitic nature. The tweets also said, well, many of them, that the police had been investigating the campaign and that it had included death threats and threats of violence by Mr Miller. Mr Turner will show in this trial that those allegations were true or the subject of honest opinion or the subject of other public interest offences, section 4 and the reply to attack, your Ladyship having already ruled that antisemitism and the other epithets which are sued on are statements of opinion. Mr Page 17 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 3 October 2023 Page 19 social media, but they also extended to an attempt on his life in Finland, and in the Spring and Summer of 2017, masked individuals turning up outside his flat in London, on occasions, posting swastikas though his letter box and putting disturbing instructions consisting of video online, showing how to enter his flat from the outside. Mr Turner was understandably terrified by these attacks and the police, who he called, were unable, ultimately to stop them, but ever since that period, Mr Turner has been the subject of vile abuse, especially of an antisemitic nature and especially online, but not only. One of the worst forms of it, emanating this time from persons based in this country, has been a campaign of harassment, perpetrated by the claimants, Daniel Miller and Nina Power which Mr Turner believes is antisemitic and which an honest person, we will say, would also, so believe, based on the facts which this court will hear about. That campaign began in July of 2018 and 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Turner is counterclaiming against Mr Miller and Ms Power for the harassment that he has suffered at their hands and the acute distress and anguish that they have put him through and he will, accordingly, partly be a defendant and partly a claimant in these proceedings at this trial. And so, my Lady, unless there is anything that you would wish me to address, those are my opening remarks, MRS JUSTICE COLLINS RICE: It was very helpful. Thank you very much. I can see there are some people standing at the back. Perhaps room can be found for them to sit down. MS EVANS: One person who is standing needs to stand because he cannot sit. MRS JUSTICE COLLINS RICE: I understand. MR WALKER: My Lady, I am sorry to ask, but a matter has arisen which I need to take some instructions on, and I would just ask at this stage whether I could have a 10-minute break just to speak to my lay client. MRS JUSTICE COLLINS RICE: Well, if Page 18 Page 20 5 (Pages 17 to 20) Epiq Europe Ltd (+44)207 4041400 www.epiqglobal.com casemanagers@epiqglobal.com Lower Ground, 20 Furnival Street London, EC4A 1JS
1 Miller031023Nick Land / text
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Day 1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Miller & Power v Turner that is necessary, 10 minutes. MR WALKER: Thank you. (10.56) (A short adjournment) (11.06) MR WALKER: I am extremely grateful for the time and I hope it will assist the court ultimately. I call Daniel Miller. DANIEL MILLER, sworn Examination-in-chief by MR WALKER Q. Mr Miller, you can see an array of folders over there, which are the bundle volumes. It is slightly artificial that I am asking the questions but your answers are to be directed to her Ladyship. Can I ask you first of all - it should be the top bundle, number one, tab 29. I am not asking you to read it but that is your witness statement, and at the back, page 42 there is a statement of truth. Do you remember signing that? A. Yes. Q. Can I ask you now to go to tab 14, page 290? Do you have it? A. Yes. Q. It is item 6 on the left-hand corner. I will 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 and I apologise. Q. You have heard, Mr Miller, my Lady speak about serious harm. MS EVANS: I am sorry, I do not think we have had an application for the witness to give evidence-in-chief on this issue. The witness statement on serious harm such as it is is his witness statement. We do object if this is an attempt, particularly without a form of new witness statement, to lead new evidence on this. MRS JUSTICE COLLINS RICE: Well, perhaps we can look at the evidence that he has already given on it. MR WALKER: I am so sorry, my Lady? MRS JUSTICE COLLINS RICE: I said perhaps we can start with the evidence he has already given on this. MR WALKER: Yes. May I turn my back, please? MRS JUSTICE COLLINS RICE: Yes. MR WALKER: (After a pause) I am so sorry. I am trying to find the reference, my Lady and as the court will be aware, there are quite a number of documents that I am trying Page 21 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 3 October 2023 Page 23 just read an aspect to you. "Item 6 is a reply by unknown third-party, DC Groyper". Can you read that? A. Yes. Q. Can I ask you to go to tab 13, so just go back from 290 to 287? A. Yes. Q. 287 and you can see that is your signature. Yes? A. Yes. Q. That aspect of item 6 which I read to you at 290, is that correct? A. No, it's not correct. Q. Is it true? A. It's not true. Q. Why did you sign something which you knew not to be true? A. (no reply) Q. There is no rush, Mr Miller. A. I was dealing with the material very quickly and I was flustered by it. I also understood that it was not unknown - it was in fact Nina's account. I didn't want to drag the issue into it, which I didn't think was relevant. I regret that decision that I made 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 to deal with, with assistance. I am sorry for the pause. (To the witness) Paragraph 109 of your witness statement, Mr Miller, which is tab 29. MRS JUSTICE COLLINS RICE: Did you say 109? MR WALKER: 109, yes. (To the witness) You refer to the publication, Mr Miller, of a webpage, and it is the second sentence: "The tweet included a link to his defamatory webpage, which had been updated in the meantime to include my responses to his 14 February claim." MR WALKER: My Lady, I intend to ask questions. If there is an objection to that, then I stand corrected, but if it is of assistance to the court and I can ask the questions, that is my application to do so. MRS JUSTICE COLLINS RICE: Well, what is the question? MR WALKER: The question is, "How did the publication of that defamatory website affect you?" THE WITNESS: For a long time this website was ... Page 22 Page 24 6 (Pages 21 to 24) Epiq Europe Ltd (+44)207 4041400 www.epiqglobal.com casemanagers@epiqglobal.com Lower Ground, 20 Furnival Street London, EC4A 1JS
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Day 1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Miller & Power v Turner MR WALKER: Can I just ask you to pause A. I am sorry. Q. Because out of courtesy to my learned friend MS EVANS: I am not going to object but I am assuming it is going to be one question. MRS JUSTICE COLLINS RICE: Well, let us hear the answer to this question. MR WALKER: To the witness) Can you help us? The defamatory page that you refer to, can you explain to us how this affected you? A. For a long time this webpage was the first hit that would appear when anybody searched for my name. The defendant was concerned to circulate it as widely as possible. The webpage presents me in the worst possible light. It takes statements made by me out of context. It manipulates evidence and would present me in a certain way. It presents a very ugly picture of who I am and what I believe. This fact alone was extremely distressing to me. it was used also by others in order to warn people from 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Cross-examination by MS EVANS Q. Mr Miller, could you please take up bundle 1? I think you have probably still got it open. Could you please turn to tab 5, which is your particulars of claim as it currently stands. It is called the "Reamended Particulars of Claim". Could you please go to page 75? Now, page 75 shows parts of what was your previous claim in harassment that you withdrew. That is why it is struck through. The paragraph I want to look at is 14.2.1, but we have put the original version in so you can see it better and that is the next tab at page 80M. Do you have that? A. Page 80? Q. 80M, paragraph 14.2.1. What I want to ask you about is the first sentence which says this MRS JUSTICE COLLINS RICE: I am sorry but I do not have that reference. MS EVANS: I am sorry. MRS JUSTICE COLLINS RICE: And the witness may not but we can read through the scored out MS EVANS: You can read through it. It has Page 25 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 3 October 2023 Page 27 sharing my work as proof that I was somehow a person that could not be given any kind of fair reading whatsoever. It was extremely disturbing. It was like having a wanted poster put up with my name on it. The webpage is intended to present me as a racist, as a fascist, as an antisemite. I completely reject all of these positions. To have a webpage which is claiming that I believe things that are directly the opposite of what I actually believe in, in fact have repeatedly and exclusively clarified that I reject was deranging, actually as well. The webpage was circulated amongst so-called antifascist activists who believe that it is appropriate to use physical violence against people they call fascists. I myself was targeted for physical violence including by people who are in contact with the defendant. The webpage has somehow therefore stood as a kind of malediction against me and it has been a horrible experience. Q. Thank you, Mr Miller. I do not have any other questions to ask of you, but I defer to my learned friend. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 not changed. MRS JUSTICE COLLINS RICE: So, it's 14.2.1? MS EVANS: 14.2.1. MRS JUSTICE COLLINS RICE: But I think I only have the crossed out version. Perhaps the witness has as well. MS EVANS: We will supply you with the proper one. MRS JUSTICE COLLINS RICE: Thank you. MS EVANS: (To the witness) The sentence I want to ask you about is the first one that says: "The Defendant, having posted the First Claimant's old Twitter post amongst very clear antisemitic posts published by "Parallax Optics", a Twitter account which is known for espousing and disseminating abhorrent antisemitic views" - do you see that? A. Yes. Q. Now, if you turn - I think you can do this but my Lady cannot do this, but we will try it. At the back of the new tab, 5A at page 80X - Page 26 Page 28 7 (Pages 25 to 28) Epiq Europe Ltd (+44)207 4041400 www.epiqglobal.com casemanagers@epiqglobal.com Lower Ground, 20 Furnival Street London, EC4A 1JS
1 Miller031023Nick Land / text
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Day 1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Miller & Power v Turner A. I am sorry. I am not sure what you are referring to. Q. Do you have tab 5A? A. I don't have tab 5A. I have only tab 5. Q. Okay. Can I pass this clean page up so you can see it? If that can be passed to the witness, and that can be passed to the witness - all I am asking you to look at here is the statement of truth which was signed on that original plea by you. So, if you go to 80S - I hope you have that? A. Okay. Q. And that is your signature on that page, is it? A. Yes. Q. With a statement of truth? A. (no reply) Q. Can we now look at some examples of the abhorrent - the antisemitic messages by Parallax Optics? You will need to go to bundle 3. A. I am sorry, where? Q. Bundle 3, tab 51, page 1778. A. I am sorry, can you repeat that, please? Q. Tab 51. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. Do you see that? A. Yes. Q. Do you agree that is antisemitic, what ParallaxOpticssaid there? A. Yes. Q. It suggests Jewish people are not human. A. Yes. Q. It's abhorrent. A. I agree. Q. And what about the image below with the crocodile coming out of an egg? Do you recognise that as an antisemitic trait or symbol? A. It's a very obnoxious statement. I think that it is obviously an antisemitic statement. Q. Thank you. Could you go on to page 1815, the same tab? Do you have that, on the left-hand side? A. Yes. Q. 29 August 2018. A. Mm hmm. Q. Another tweet by Parallax Optics. It just says: "Does the Holocaust even real". Do you see that? A. Mm hmm. Page 29 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 3 October 2023 Page 31 A. Mm hmm. Q. Page 1778 in the bottom right. Do you see that? A. I see 1778. Q. Yes, the bottom right number. A. I see 1788. Yes. Q. And at the top you will see it gives a date for this Twitter thread, 24 July 2018. A. Mm hmm. Q. And there is a conversation here which starts with someone called Nathan Cofness. A. Mm hmm. Q. It says, "Under certain conditions people will identify with and favor their group, including their ethnic group. That doesn't mean people tend to act in their ethnic interests, Dutton claims. (There's a section based of the paper on why I say this." Then he says: "See the examples of Jewish behaviour that clearly undermine Jewish ethnic interests." And the apparent ParallaxOpticsreplies: "And the classification of Jews as "people" is also obviously highly questionable." A. Mm. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. Do you agree that is an antisemitic message? A. Yes. Q. What does it mean? A. It questions whether the Holocaust is real, is how I understand it. Q. And would you say that that was abhorrent? A. I totally agree that ParallaxOpticshas made many obnoxious and abhorrent statements. Q. Do you agree that that is an abhorrently antisemitic statement? A. I find it personally very irritating. Q. Do you agree it is abhorrently antisemitic? A. I agree that it is antisemitic, yes. Q. We have your answer, thank you. Can you go forward to 1970? It is the right-hand facing page. This is 1 December 2018 and you will see that again there is a short conversation by an account called Outsideness -A. Mm hmm. Q. - who says that somebody says that Page 30 Page 32 8 (Pages 29 to 32) Epiq Europe Ltd (+44)207 4041400 www.epiqglobal.com casemanagers@epiqglobal.com Lower Ground, 20 Furnival Street London, EC4A 1JS
1 Miller031023Nick Land / text
P. 9
Day 1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Miller & Power v Turner Israelis are from Mars and American Jews are from Venus, and then we have ParallaxOpticsreplying, "# Jews" and then again some sort of reptile coming out of an egg, which you have already agreed is antisemitic. A. Yes. Q. Can you go on please in the same tab to 2186? A. Mm hmm. Q. It should say 21 April 2019 at the top, and this time the conversation has to be read in reverse, so it begins with someone called Joe Marney tweeting, "And some people call animals "vermin". There's only one species on this planet that that word can really apply to", and ParallaxOpticsreplies, "Jews?" A. Mm. Q. Is that abhorrently semitic on the part of Parallax Optics? A. It is abhorrently antisemitic, yes. Q. Antisemitic. Could you go to page 3393? You will probably find that bundle is very full, so it may be that we have to - sorry, it is tab 52, this one, not 51. 3393. This one 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 is not a supporter of Labour as far as I know. Q. Thank you. A. So, I don't think that he was in fact himself making any real claim about Labour's defeat actually. Q. Would you please go to page 2571 of the same tab? This is dated 24 January 2021 at the top. Now, I make clear that this is obviously A. I am sorry. Q. Sorry, do you have it? 2571? A. Yes. Q. Now, this is outside the period of time that this case is largely concerned with but it is illustrative of the same point that I have been making and suggest, so you read from the top with this one. It takes a bit of unpacking. Somebody called Ben says: "The Jews have resorted to the crypto tactic of defining Jewish representation in terms of religion but Unz hilariously turns this around to prove the original numbers correct." They are talking about positive action, by the look of it, and numbers of students in American universities. "The same chap, Cofness, says, Page 33 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 3 October 2023 Page 35 should be 13 December 2019 at the top. A. Mm hmm. Q. Another tweet by Parallax Optics. He poses the rhetorical question, perhaps: "There's only one thing that can explain Labour's defeat" - this is obviously after the last general election - and he answers it himself, "The Jews." A. Mm. Q. Do you agree that that is abhorrently antisemitic? A. I think this statement refers to claims being made by some of the supporters of Jeremy Corbyn that there was a kind of Jewish conspiracy against him. Q. Do you agree it is antisemitic in the way that ParallaxOpticsposes the question and answers it? A. I think the hypothesis that this is the reason for Labour's defeat is obviously an antisemitic hypothesis. I think ParallaxOpticsis referring to that hypothesis. That's an hypothesis that he didn't invent, but existed within the context of Labour Party internal politics. I think that he himself 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 "This whole debate is silly. Anyone who has been to an ivy league university knows that many of Hillel's stats are wrong except Unz himself who has an agenda" and then Torin McCabe says, "And like IQ data in Africa, the solution is better data" and ParallaxOpticssays, "The solution is bigger oven." That is a reference to concentration camp ovens, is it not? A. I think so, yes. Q. Is that appallingly or abhorrently antisemitic? A. Without question. Q. You can shut that file for now. I want to ask you some questions about your own interactions with this apparent Parallax Optics. By 2017 you were following ParallaxOpticson Twitter, were you not? A. Yes, although I also muted him, actually for long periods of time. Q. The account that you used at that point was called - you had the handle dcxtv. Correct? A. That's true. Q. And your identity would not have been Page 34 Page 36 9 (Pages 33 to 36) Epiq Europe Ltd (+44)207 4041400 www.epiqglobal.com casemanagers@epiqglobal.com Lower Ground, 20 Furnival Street London, EC4A 1JS
1 Miller031023Nick Land / text
P. 10
Day 1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Miller & Power v Turner known to people just from that handle if they did not already know who you were. Correct? A. My identity was widely known by many people. I never attempted to conceal it. I Q. If people did not know who you were already, they would not know from that handle, dcxtv who you were. A. I regularly posted links to articles I had written. I think that people would have been able very easily tell this is my account. I also used the same handle for my Median[?] account, which did have my name next to it, so it may not have been immediately obvious but it was not concealed. Q. And ParallaxOpticswas following you as well. A. Yes. Q. And the identity of the operator of that account was not immediately apparent to someone who did not know? A. No, he wanted to remain anonymous because he wanted to continue to make these obnoxious statements anonymously. Q. Now, we have not had any disclosure 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. Just so that my Lady can see what is happening here, all we have of the tweets from Parallax Optics, because all of yours have been deleted and you can see that from the reference in between as the conversation flows - correct? A. Yes. Q. Now, it starts with an Evening Standard article. That is the top left and if you turn actually to the page before, 3212, this is a chronology of this thread which assists in seeing the sequence but it also helpfully at the top gives you the full URL for that Standard article so you can see its headline. So, the headline of the article that ParallaxOpticshave tweeted was, "Jihadi suspected of fighting in Syria could jump the queue for council houses and get help finding jobs". Do you see that? A. Mm hmm. Q. Now, if you go back to the next page and look at it with the visuals, as it were, you will see how the conversation goes between the two of you, except of course you cannot because you cannot see your contribution Page 37 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 3 October 2023 Page 39 from you in this action of any communications between you and the operator of Parallax Optics. That is correct, is it not? A. That is correct. Q. And all your tweets with him you deleted, did you not? A. I regularly deleted my tweets in general. Q. Can we just have a look at a surviving example of one of your interactions with him, which has been disclosed from my side, I think. If you go to bundle 4, tab 118 A. Mm hmm. Q. If you go to page 3214 - it is 3213 and 3214. A. Mm hmm. Q. This is a reconstructed thread by my client so you can see the flow of it. I do not think there is any dispute that this is the correct flow, but if there is your counsel can take you through that later. This is the conversation between you and ParallaxOpticsand I think 2 November 2017, correct? A. Yes. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 directly, but my Lady can read the page on the left to herself. I want to focus on the page on the right. That starts with - this all seems to flow from the content of the article that you are discussing and there is a reference at the top from ParallaxOpticsto "Jobs for the Boys" then he says, "Smashed window economics 101". You reply, so you say something there. Do you agree? A. Yes. Q. He then replies, "Racists?" Do you see that? A. Mm hmm. Q. You then reply. That is deleted. Do you have any recollection of what you said? I do not expect you to. A. I mean I presume that I was arguing with him about things that he was saying. I mean, this is normally what Twitter interactions are. Q. And after your deleted and therefore unknown response, he says, "Is it possible to distinguish between the two?" Do you see that? A. Mm hmm. Q. So, I suggest that that indicates that you Page 38 Page 40 10 (Pages 37 to 40) Epiq Europe Ltd (+44)207 4041400 www.epiqglobal.com casemanagers@epiqglobal.com Lower Ground, 20 Furnival Street London, EC4A 1JS
1 Miller031023Nick Land / text
P. 11
Day 1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Miller & Power v Turner must have referred to two types of things. A. Mm hmm. Q. Possibly groups of people. Correct? This is just a hypothesis because we do not know. A. I think that ParallaxOpticsstatement, "Racists?" probably refers to, I suppose, anybody objecting to this policy because it is true that the term "Racist" is used in order to shut down critical discussion. Q. So, after your reply, which leads him to say that, is it possible to distinguish between the two? A. Mm-hmm. Q. Before you reply again, he says, "I mean Jews are different, they have horns?" A. Mm-hmm. Q. Then you reply again. So it is apparent, isn't it, from his, "Jews are different, they have horns", that you have mentioned Jews, possibly as one of the two groups that you mentioned or you said something that led him to infer -A. I really don't see -Q. -- something about Jews? A. I really don't know why that would have 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 exercise. Q. Well, I think that's for me to decide. Thank you. "They will take me away" I suggest to you is Parallax Optics' way of saying that you have just said something to him which is quite sensitive and which most people would be offended by, correct? A. I think his statement responds probably to me objecting to his previous statement. Q. Then the next thing he says is, "Problematic" in inverted commas, problematic in parentheses. Do you see that? A. Yes. Q. You know what the parentheses echo symbol stands for? A. Yes. Q. Would you like to tell the Court? A. It stands for, it was somehow a trope that was used in order to identify Jewish people online. Q. Just going back to the, "they have horns", saying that Jews have horns is another way of saying that they are not human, isn't it? A. Well, the most famous example I can think of with the horns is Michelangelo's Page 41 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 3 October 2023 Page 43 been the case. I understand his statement here actually is a provocation of me, he knew I was Jewish and he's -Q. Well, okay, so the next one is another reply -MR WALKER: I wonder whether he could finish the question, given the courtesy that he has been extended, to give an answer? A. ParallaxOpticsregularly made statements designed to be provocative, so the question is obviously, what do you do or how do you respond to such statements? If one becomes upset about it in a certain way, one loses that particular game. MS EVANS: Well, if you look at the next exchange, I suggest that you are the one who said something provocative next. Because there is your blank deleted reply and then he says, "Don't say that, they will take me away." A. I don't know. Q. Do you know what you might have said that led him to say that? A. I really don't know, but I'm not sure what you think we can gain really from this 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 statue of Moses where he has horns. There is actually a passage in the Bible where it describes Moses, it is maybe a corruption of Hebrew, for some reason Moses has horns, I don't know why that is. Obviously the notion that Jews have horns is ridiculous, I think it is difficult to take seriously on that basis. It is annoying but ... Q. Thank you. You can put that file away for now. Can we go back to file 1 and again look at your original particulars of claim. So I think you will find that in 5A and my Lady, I am afraid, will have to make do with the struck through in tab 5. It is paragraph 17.3. A. I'm sorry -Q. Sorry, I haven't given you a page number. So you need to go to tab 5A -A. Uh-huh. Q. -- which is the new one that you were handed and it should be - sorry, I think I am in the wrong document. Just one sec ... yes, sorry, I am in the wrong tab. It is actually not in your particulars of claim, it is in your reply which is at tab 9. It is page 241 which is a left-hand page and it is paragraph 17.3. Page 42 Page 44 11 (Pages 41 to 44) Epiq Europe Ltd (+44)207 4041400 www.epiqglobal.com casemanagers@epiqglobal.com Lower Ground, 20 Furnival Street London, EC4A 1JS
1 Miller031023Nick Land / text
P. 12
Day 1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Miller & Power v Turner You will remember this is the document you signed a statement of truth on. A. Uh-huh. Q. In 17.3 you made your point that you have just made about Michelangelo in the first sentence. Then you said this, "The first claimants did not, in any event, reply to this tweet, like it or retweet it or in any way encourage the continuation of the discussion which had not previously engaged any alleged anti-Semitic tropes." Now, that is about the thread that we have just been looking at. A. Uh-huh. Q. Do you see that? A. Yes. Q. But do you accept now that that is not true what that paragraph says about that thread? A. I agree that it is true, looking at this thread, that ParallaxOpticsdoes make statements about Jews, I don't make any statements about Jews. I found his statements annoying, I understood that they were calculated to annoy me. This paragraph 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 been deleted which you presume said this, but I really don't think it would have done. Q. Can you recall when you deleted those tweets that you have exchanged with Parallax Optics? A. I think shortly after the conversation took place. Q. On every single occasion? A. I, as I said, regularly deleted my tweets. I understood Twitter also as a medium for engaging in occasional interactions with people, I don't think that they have to be preserved in any way like, that any other conversation needed to be. I also found that exchange personally quite irritating because of Parallax Optics' responses to me. I find that irritating myself as a Jewish person. I think his statements were intended to irritate me. You want to hold me responsible for his provocations of me, okay. But ... Q. Could we please turn to tab 7 of the same bundle? This is annex 1 to the Defence. I want to ask you now about some of the images in this annex which are relied on by my client, and to be clear I am not suggesting Page 45 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 3 October 2023 Page 47 refers to anti-Semitic tropes, if you want to say that he is circulating anti-Semitic tropes, I will concede that. Q. "Jews have horns"? A. Is that a trope? I don't know, to be honest. Q. It doesn't really matter whether we describe it as a trope, it is, I suggest to you it is indicating that Jews are not human? A. Em ... well, I mean obviously I disagree with that. Q. Thank you. I suggest that that paragraph, 17.3, was untrue and the reason it has not been re-instigated into the document after those amendments is because you realised that the sequence in that thread did show that you had encouraged the continuation of the discussion after an anti-Semitic reference? A. I certainly didn't encourage any anti-Semitic discussion or engaged in any anti-Semitic content. Q. I suggest that it was you who had apparently introduced Jews into the conversation? A. You state this based on a tweet which has 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 that you are responsible for these images but I want to ask for your view about them. They were sent to the Defendant and his artistic partner, Mr LaBeouf, at various times after the "he will not divide us" artwork went up. But they were not, as far as I know, sent by Parallax Optics. So, if you could turn to page 136. Now, this is an image of concentration camp victims, evidently, and on one of them has been superimposed Mr Turner's face, do you see that? A. Uh-huh. Q. You see that, you agree that that's a representation of Mr Turner? A. Yes. Q. It is abhorrently anti-Semitic, would you say? A. It is abhorrent and disturbing on every level. Q. Including anti-Semitic? A. Yes, absolutely. Q. It is a threatening message to send someone, isn't it, if they are Jewish? A. It is a disgusting message. Q. The next page, you will see again Mr Page 46 Page 48 12 (Pages 45 to 48) Epiq Europe Ltd (+44)207 4041400 www.epiqglobal.com casemanagers@epiqglobal.com Lower Ground, 20 Furnival Street London, EC4A 1JS
1 Miller031023Nick Land / text
P. 13
Day 1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Miller & Power v Turner Turner's face superimposed on to a lampshade and also two bottles of soap. Now that, I think, is supposed to be a reference to the fate of concentration camp victims, do you understand that? The washing of the soap and being used for a lamp, discarded people, the cleansing of them as they arrive in concentration camp? A. I'm sorry, what is your question? Q. Do you understand it in that way? A. The first time I have seen this image is through the disclosures provided by the Defendant. Again, I think this image is very disturbing. In terms of its precise semantic content I am willing to accept this interpretation. I am, myself, disturbed by this image, I don't know why the Defendant has preserved this disturbing image, I don't know what purpose it serves for him. Q. Well, he has given evidence about that and will do. Could you turn over to the next page, 138? Do you agree that this is again Mr Turner in the first row of photographs? A. Yes. Q. It is a distorted depiction of him, isn't it, 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 forehead? A. Yes, I see that. Q. Do you agree that that is abhorrently anti-Semitic, given that he is Jewish? A. Yes, I do. I don't dispute, by the way, in general that your client has received anti-Semitic abuse from people on the internet. I condemn all of this as a Jewish person myself, I myself would never send in any of this material. Q. I made clear that I wasn't suggesting that you sent it. A. Okay. Q. The next page is page 140. Again, do you agree this is a distorted facial image of Mr Turner, with a hooked nose and Stars of David for eyes? A. Yes, I do agree, yes. Q. There is a picture of Hitler and there is a gun to his head. Do you agree that this is anti-Semitic? A. Yes, I do agree, yes. Q. Do you agree it also sends a threatening message? A. Yes, I do agree. Page 49 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 3 October 2023 Page 51 with a skull cap and an enlarged nose, agreed? A. Yes. Q. That is a Jewish stereotype, is it not? A. Yes, it is, yes. Q. It is juxtaposed, isn't it, in the row below with Nazi symbols? Swastikas, Iron Crosses, Eagles. Do you see that? A. Yes, but I don't know whether these images that were produced on the same date or what their original source is. Q. I'm asking you about the juxtaposition? A. Well, the juxtaposition seems to have been potentially created by your client, as far as I know, since the juxtaposition appears here, yes, in this way. But, again, I don't know what the source of this is. Q. Do you agree that the stereotype of Mr Turner as a Jew is anti-Semitic? A. Absolutely. Q. On the next page, 139, you will see here a picture of Mr Turner with horns? "Jews have horns." Do you see that? A. Okay, yes. Q. You see the Star of David on his 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. On the next page, 141, we see what is known as Pepe the Frog in green, which is, I think you will agree, a green anamorphic frog with a humanoid body might be one description of it, which was appropriated by alt-right groups online in the United States. Do you agree with that? A. Do I agree with what statement specifically? Q. Do you agree that it was appropriated, Pepe the Frog as an image, by alt-right groups? A. Pepe the Frog seems to have been used by a wide variety of groups and individuals. Q. Including, the alt-right, do you agree? A. I do agree conditionally with that, yes. Q. Do you notice that this Pepe the Frog is wearing President Trump, "Make America Great Again" cap? A. Yes, and he is drinking a glass of wine. Q. On his shoulder the hat says is, is written, "HWNDU" which is the artwork? A. Uh-huh. Q. The person that he is sexually assaulting and killing is Mr LaBeouf, who is one of the Page 50 Page 52 13 (Pages 49 to 52) Epiq Europe Ltd (+44)207 4041400 www.epiqglobal.com casemanagers@epiqglobal.com Lower Ground, 20 Furnival Street London, EC4A 1JS
1 Miller031023Nick Land / text
P. 14
Day 1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Miller & Power v Turner trio of the artwork. Do you recognise that? A. Yes. Q. Would you say, who is also Jewish, I should add. Would you say that this image is horrifically anti-Semitic? A. Em... I don't think this image is obviously anti-Semitic to me, it is obviously a horrible image. I don't see any reference to Jewishness in this image from my first glance at it. Q. Could you look at page 143? A. Uh-huh. Q. This is Pepe the Frog, again with a Swastika on his chest, again assaulting Mr LaBeouf, you will see he has the artwork's name on his back. Do you agree that that is anti-Semitic? A. I think the addition of the Nazi Swastika tattoo does then give it an anti-Semitic meaning, yes. Q. Do you agree it is threatening to have sent, to send that to somebody? A. Yes, I do. I do agree, yes. Q. I'm just asking you about two more. The next page, 144. This is from one of these 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Parallax Optics, would you accept that? A. Ah ... Q. As an approximate figure? A. I'm sorry, between which dates? Q. Between the 25th of October 2017 and the 6th of September 2018? A. No, it depends on how you are defining interaction. I really don't recall the number of interactions we had online. Q. Does that number sound wildly off to you, though? A. It sounds higher than I remembered. Q. Just some examples, I can take these quickly. 1741. You will see that 1737 and 1738 is all exchanges or interactions between you and ParallaxOpticsand you can tell that because you see that in each of them it says that, this was a reply to Dcxtv, among others sometimes, or you were tagged in so you would have got them or it was part of an exchange you were having. I am not interested in the content of these ones. But 1742, because these go on for pages? A. Uh-huh. Q. You read these from the bottom up Page 53 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 3 October 2023 Page 55 Groyper accounts which we will see are also associated with the alt-right. This is clearly a Nazi salute, is it? A. Yes. I think so. Q. On the next page, 145, you will see that Pepe the Frog here has a stereotypical image of a Jewish person, I suggest, in his sights, in other words the sights of his gun? A. Uh-huh. Q. Do you see that? A. Uh-huh. Q. Are both these images anti-Semitic? A. I would say so, yes. Q. You can shut that file, please. Can you take up file 3 again, please, tab 51. A. Uh-huh. Q. I want to now ask you a little bit about some of your engagement with ParallaxOpticsin 2017 and 2018, such as has survived. 1737. Again, we are dependent on screenshotted images from the ParallaxOpticsaccount, because yours were all deleted. If I tell you that between 25th of October 2017 and 6th of September 2018 there were 113 interactions between you and 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 because they are the result of searches on the ParallaxOpticsaccount. So the most recent is at the top. You will see, I just want to pick out a couple of them. 1742, the third from the bottom, ParallaxOpticsis engaging with you and other people. He refers to, he says, "All N/acc persuasions welcome?" A. Uh-huh. Q. What is N/acc persuasions? A. This refers to Nick Land's theory of accelerationism which bifurcated into different variants. Q. Thank you. In fact you will see on 1744 there is a reference to Nick Land. 1744 by the top hole (inaudible). There is a Parallax Optics' tweet at 24th of April 2018 talking about accelerative dynamics and refers to Land's "Nrx analysis of contemporary political economy." Nrx is neo-reaction, isn't it? A. That's correct. Q. On the same page, you will see, third from the bottom, again replying to you and one other person, ParallaxOpticssays, "That is old school/Acc. Nowadays it is all about Page 54 Page 56 14 (Pages 53 to 56) Epiq Europe Ltd (+44)207 4041400 www.epiqglobal.com casemanagers@epiqglobal.com Lower Ground, 20 Furnival Street London, EC4A 1JS
1 Miller031023Nick Land / text
P. 15
Day 1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Miller & Power v Turner taking hormones and cutting your dick off?" A. Uh-huh. Q. What do you think that is a reference to, since you were in that thread? A. I think this was a reference to so-called U/acc or unconditional accelerationism which had a very strong transgender component to it in terms of its interests and its emphasis. Q. If we then go to 1749. Do you have that on the left-hand side, in the middle there is a tweet which we will come on to shortly when we deal, start to go through the tweets which my client complains about as harassing. Do you see that one? A. Uh-huh. Q. "Luke Turner is a 50 Stalins!!!"? A. Uh-huh. Q. References to Nrx and so forth. But you will see at the bottom there, we see a reference to gorsedd6. ParallaxOpticsreplying to gorsedd6 and some others. Gorsedd6 was Nina Power, correct? A. That's true, yes. Q. In about February 2019, I will just ask 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 February 2019, I want to ask you about this page. This is a list of the accounts that you were following on 14th of February 2019. You will see at the top, it has your new handle? A. Uh-huh. Q. It is true, isn't it, that when you start a new account on Twitter you have to re-follow or anyway decide who you want to follow? A. That's true, yes. Q. On this list from, third from the bottom is Parallax Optics? A. Yes. Q. I just want to ask you now some questions about the person behind Parallax Optics? A. Uh-huh. MRS JUSTICE COLLINS RICE: Can I just check that the -MS EVANS: Oh yes, I'm sorry, about the transcriber. MRS JUSTICE COLLINS RICE: -- that the transcriber is, whether a break would help now? It would. Is that a convenient point for Page 57 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 3 October 2023 Page 59 you this while we are on Parallax Optics, you changed your handle on Twitter, didn't you, and you started a new one, which was called Real Dcxtv? A. I was banned from Twitter, I believe by your client, in October 2018. After that point I wasn't on Twitter -Q. We will come on to the sequence -A. No, but you have said that I have changed my Twitter handle, in fact I actually created a new account in order to respond to the claims that were being made by your client, including -Q. We will come to that. A. -- including the claim that I had written an article called Totalitarian Disability Politics in which I called for the euthanasia of disabled people. This was an absolutely abhorrent claim and I felt the need to create a new account to respond to it. Q. Can you take up bundle 2, tab 40. It is page 955. I am still asking you about your interactions with Parallax Optics, you see -A. Uh-huh. Q. -- so, although this has gone forward to 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 you? MS EVANS: Yes, that's a convenient point. MRS JUSTICE COLLINS RICE: Five minutes then. (12.01) (A short adjournment) (12.10) MS EVANS: Mr Miller, I was just coming on to ask you about your relationship with the operator of ParallaxOptics. His name is Jack - I do not know if you pronounce it Stokoe or Stockoe - Jack Stokoe. How would you pronounce it? A. I think Stokoe. Q. That is him, though, is it not? A. Yes. Q. I want to ask you first some questions about what your lawyers pleaded about you and Mr Stokoe on your instructions, but before I do that I need to point out that you have elected in this case to give no evidence at all about ParallaxOptics or Mr Stokoe in your witness statement. Do you understand? A. Yes. Q. So, that means the court has no case from Page 58 Page 60 15 (Pages 57 to 60) Epiq Europe Ltd (+44)207 4041400 www.epiqglobal.com casemanagers@epiqglobal.com Lower Ground, 20 Furnival Street London, EC4A 1JS
1 Miller031023Nick Land / text
P. 16
Day 1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Miller & Power v Turner you in answer to the defendant's case about your association with ParallaxOptics and Mr Stokoe or the nature of it. Do you understand that? A. Yes, I understand that. Q. But, nonetheless, I need to put my clients' case on this to you and I will do that against what your pleaded case says, although that is not your evidence. Do you understand? A. I think so. Q. I will take you to some of your pleaded case. The first question is: you accept, do you not, that you and Mr Stokoe both attended the LD50 Gallery counter-protest in Hackney on, I think it was the 25th of February 2017? A. That was where I met him. Q. You attended it together, did you not? A. No, that's not true. Q. Could you turn up bundle 2, tab 40, page 849, the first page, and do you see that photograph? A. Yes. Q. That is you with Mr Stokoe ... 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Yes, there was a protest organised against the Gallery. Q. And you went along and Mr Stokoe went along to protest against the protest? A. I went to protest against the anti-fascist activists. I don't know why Mr Stokoe went. He wasn't involved in protesting himself, he merely was observing. Q. The Gallery, LD50, was controversial, was it not, because it had put on exhibitions and staged events which had Far-Right or Alt-Right extremist themes, correct? A. No, I don't think that is correct. I think that the Gallery had produced a number of exhibitions from various perspectives. Most of them were concerned with the internet; it was an internet art gallery. In 2016 it produced a conference and an exhibition which was specifically focused on investigating the so-called, "Alt-Right" - this was a term that we began hearing in 2016. We didn't know what it was, nobody knew what it was. The first time that I heard it was when Hillary Clinton said that the people voting for Donald Trump were the Alt-Right. Page 61 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 3 October 2023 Page 63 A. Yes. Q. ... at the LD50 counter-protest, is it not? A. I think it's subsequent to the counterprotest. Q. Is it on the same day, nearby or in the vicinity of it? A. Mr Stokoe approached me after a counter-protest against the anti-fascist activists and he was the only person there. He wasn't screaming at me or threatening to assault me. I had just held up a sign that said, "I believe in the right to openly discuss ideas" and so I thought I had some commitment to that principle, and so I was willing to talk to him. That was the first time that I met him. Q. And is that his girlfriend standing there next to him in that photograph, Natalie Lambert? A. Yes. Q. So, just to be clear as to why you were at that counter-protest: there was a protest going on called Stop LD50, was there not? A. Er ... Q. Just Yes or No for now. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 So, I think that LD50 were investigating what that term meant and they organised an exhibition for that purpose and they also organised a conference for that purpose. Subsequent to the election of Trump - it's a complicated story - but a group of Londonbased Far-Left activists (associates of your client) organised a demonstration against LD50 because they held that the exhibition and the conference at LD50 had produced, it meant that the Gallery must be shut down immediately - and this was the claim that they made: they claimed that LD50 was in fact not an art gallery but was rather a NeoNazi organising space. They circulated these claims. I looked at these claims and I saw that there was no evidence to support those accusations. Those accusations were hyperbolic and wild. It seemed to me that actually what LD50 was doing was investigating sincerely, as an art gallery should, contemporary themes and contemporary questions and important contemporary questions because it's important to understand what these Page 62 Page 64 16 (Pages 61 to 64) Epiq Europe Ltd (+44)207 4041400 www.epiqglobal.com casemanagers@epiqglobal.com Lower Ground, 20 Furnival Street London, EC4A 1JS
1 Miller031023Nick Land / text
P. 17
Day 1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Miller & Power v Turner phenomena are. We must understand them. And so, on that basis I went to the protest that the activists had organised against the Gallery. The activists were there, many of them were masked, they had, in the days before the protest, been involved in vandalizing the Gallery; they threw rocks through the windows of the Gallery. The gallarus was forced to seek police protection because she was very frightened by the activities of these activists. These activists, to be clear, believe that it is legitimate, and in fact even almost obligatory, to apply physical violence to anyone they identify as a Fascist. LD50 was identified as a Fascist gallery and therefore as a target for violence. I thought that this was unsupportable, so I went to the Gallery to protest against these activists and in support of freedom of artistic expression and also in support of the discussion of ideas. I was not myself sympathetic to any of the ideas being discussed in the Gallery, and this is why I actually understood it as a free speech case. Everybody supports the free speech that they agree with. I also support 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Wing ideas ...'" - but you did not say that just now, when I first asked you, you said that it was not an Alt-Right or Far-Right space? A. No, I think that it was a space that was investigating these ideas. I think there is a distinction between an investigation and the promotion of ideas. Q. Can you go back a few tabs to 89, please? This is an article in The Guardian a few days earlier, actually, the 22nd of February, about the Gallery itself, and the bit that I want to focus on is at the bottom of 3082. It is talking about this Neo-Reaction conference that you mentioned the previous summer which was hosted by LD50, which included somebody called Brett Stevens, "A white Supremacist", as The Guardian describes him, " ... whose writing was an inspiration to Oslo Far-Right terrorist, Anders Breivik, who murdered 77 people in 2011." And if you go on to the top of the next page, it quotes from Stevens and it says, "After Breivik's attack, Stevens wrote, 'I am honoured to be so mentioned by someone who is clearly far braver than I. No comment on his methods. Page 65 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 3 October 2023 Page 67 the free speech that I don't agree with, and I certainly support the right of art galleries to investigate contemporary themes in a neutral way. The activists themselves conceded that the Gallery had not taken any kind of position on the exhibition or the conference that it had produced. Nonetheless, it still called to immediately shut down the Gallery. No response was possible from the gallarus. It was an extremely violent and disturbing episode and I felt that it was my obligation and duty to protest against it. Q. Yes, thank you, Mr Miller. Could you take up bundle 4, if it is not already open, and go to tab 91? It is page 3087. Now, this is an edition of the Hackney Citizen newspaper of that day and it has an article about the protest, and you will see that on the right hand page by the first hole punch it says, "Speaking to the Citizen, the counterprotestor, who have his name as D.C. Miller ..." - I assume that is you? A. Yes. Q. " ... explains his stance ... He said, 'LD50 hosted people speaking who hold very Right- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 But he chose to act where many of us write, think and breathe.'" But Stevens was one of the speakers at the conference, was he not? A. Brett Stevens sent a video to the conference. Q. Okay, a video, but he participated in it? A. He participated in it in the context of sending this - it was really an art work, it was a kind of nihilistic monologue in which he describes the decline of Western civilization as he sees it. Q. I will take that as a Yes. If you go back to tab 79 ... A. I would like to point out, with respect to this description of him, however, Anders Breivik was not mentioned in his contribution to LD50 in any shape or form, and I myself actually asked the gallarus, Miss Lucia Diego, subsequently if she had been aware of Mr Stevens' comments on Breivik. She said that she hadn't been when she invited him to the conference. He has a very popular blog, he's written, I think, something like 10,000 blog posts over the last several years in which he explains his thoughts. I Page 66 Page 68 17 (Pages 65 to 68) Epiq Europe Ltd (+44)207 4041400 www.epiqglobal.com casemanagers@epiqglobal.com Lower Ground, 20 Furnival Street London, EC4A 1JS
1 Miller031023Nick Land / text
P. 18
Day 1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Miller & Power v Turner don't think Mr Stevens is a particularly interesting thinker, but I think that the description of him, or rather the identification of him with the most deranged and abhorrent thing that he has ever said does somewhat prejudice the understanding of why he was appearing at this conference. Q. Do you have tab 79 open? A. Yes. Q. This is a catalogue or an online promotion of one of the exhibitions that LD50 put on, which you have defended as being in the interests of free speech. This exhibition was called, "My Twisted World, the Story of Elliott Rodger" and ... A. The - I'm sorry. Q. Just wait for the question. A. I'm sorry. Q. Elliott Rodger was a serial killer from California, was he not? A. He was a spree killer, to be specific. Q. Yes, he only killed six, did he not? A. No, I'm saying that he, in apparently some act of psychosis, embarked upon a murder spree in which six people were killed, 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 2016? A. Yes. Q. What I wanted to also just ask you about Elliott Rodger, who killed six and injured 14 in his spree in 2014, was that he had a manifesto, did he not, so-called? A. He wrote some kind of document, which I have not read, in which he explained, as I understand it, his unhappiness with life and his hatred of women and ... Q. Yes, he called it his, "War on Women" and the manifesto was called, "My Twisted World." It also contained, you may remember, plenty of racist remarks about the inferiority of black people? A. Well, I haven't read his manifesto, so I don't know. Q. So, you were at LD50 and Mr Stokoe was at LD50 to defend a gallery that puts on exhibitions like that? A. Well, I don't know what you mean, "Like that". Elliott Rodger has a peculiar status amongst people on the internet. He's not exactly considered to be an admirable figure, he's actually considered to be basically a Page 69 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 3 October 2023 Page 71 yes. Q. This exhibition - I should also just ask you, actually ... A. I'm sorry, but to clarify this point, the exhibition was not called, "My Twisted World." The exhibition was named after a 4chan thread which predicted the election of Trump. I don't know what this title refers to, actually. Q. Thank you for that. 4chan, of course, being one of the Alt-Right ... A. 4chan is an anonymous message board which is used by many different users of different political persuasions, as I understand it. I've never used it personally. Q. So, "My Twisted World, the Story of Elliott Rodger" is attached to the installation or whatever it is on page 3001. If you go forward in these pages to 3008, you will see another art work in this exhibition called, "Elliott Rodger Memorial", which seems to have involved a video of him, and on the next page, 3009, at the top, a photograph or a still of a video with the caption, "Elliott Rodger, Awakening." You see that, from 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 ridiculous figure and a weird person. He was incel - I think probably maybe even before that term was invented. He ended his life with this horrible act of murderous violence. He is somebody that people who similarly feel unhappy and insane in their own lives identify with, but, I mean, almost as an expression of their alienation. So, he is somehow relevant to understanding subcultures. I think it is a phenomenon worth discussing. Q. After the counter-protest in February 2017, at some point in 2017 you became friends with Mr Stokoe, did you not? A. Mr Stokoe, as I said, I was - he was the first person that I'd ever met, actually, who was somehow prepared to articulate RightWing positions and Neo-Reactionary positions. I wasn't particularly familiar with these positions and I did want to understand what they were. I think that he is in a sense an authentic representative of a certain kind of internet thought movement. So, we became acquaintances and I agree that our relationships were cordial. He also was the Page 70 Page 72 18 (Pages 69 to 72) Epiq Europe Ltd (+44)207 4041400 www.epiqglobal.com casemanagers@epiqglobal.com Lower Ground, 20 Furnival Street London, EC4A 1JS
1 Miller031023Nick Land / text
P. 19
Day 1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Miller & Power v Turner student of my friend, John Cousins, who is an art academic. I met him in Haiti. So, we had a connection on this level. In person, he was much more civilized than his behaviour on Twitter would suggest. You know, I thought that he was a complex figure in some ways, not completely stupid. He was driven to write these transgressive messages on Twitter. I find that very irritating. His actual central preoccupation was basically a kind of misogynistic diatribe against women, which just, was very repetitive, and ... Q. And against Jews? A. Well, I would say that his predominant theme was really women. He made scattered remarks about Jews which were also annoying, but his Twitter persona was like ... Q. Sorry, you said they were annoying, but you have accepted that they were abhorrently anti-semitic? A. I agree with both of these statements, but I think that his main mood was irritation, to be honest, you know, and he was making these statements precisely to irritate. I wouldn't say that, based on my personal 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Well, you say "rekindled" ... Q. ... I want to establish that it was in mid July? A. I'm sorry? Q. I want to establish that it was in mid July that you and Miss Power got reacquainted? A. Yes, I encountered her by chance and, you know, in fact, we hadn't parted on the best of terms, but I found that we had, you know, we had a lot to discuss, actually, and ... Q. And in - sorry. A. Well, I mean, our friend, Mark Fisher, who had introduced us, had committed suicide in the meantime, and this was actually the first point of commonality that we had, and I hadn't seen Nina at that point for, I think, almost 10 years, and, yes, as I said, we had a lot to discuss. Q. So, by late July you and Miss Power were socializing with Mr Stokoe, were you not, and his girlfriend? A. I introduced Nina to Mr Stokoe at a certain point, actually, specifically because of his views on women, which I thought would Page 73 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 3 October 2023 Page 75 conversations with him, that these were views that he was actually really attached to. They were views that he was - they were statements that he was making in order to provoke people, in order to provoke attention, and this was something that for some reason he felt compelled to do. I would say that his statements on Twitter are almost like the statements that people might write on a men's room wall, this would be the equivalent. You know, one encounters these statements and people do write abhorrent things in that context, but I think there's a limit to how seriously you can take them as well. Q. You were friends with him in July 2018, were you not? A. I mean, we were associates of a kind. I was in conversation with him. Q. And I think it was in the middle of July 2018 that you rekindled your friendship with Miss Power? A. Yes, I ran into Nina by chance. Q. You do not need to give us the details, unless you want to, but ... 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 be useful for her because she was writing a book about men and about the Manosphere, and again I think that he is an authentic representative of a certain set of views. Q. Could you take up bundle 5 please and turn to tab 131? A. I'm sorry, which tab? Q. 131, and you want page 3694. Now, these are transcribed WhatsApp messages between you and Miss Power. It is the only form of communication that the pair of you have disclosed in this case. It only covers a very brief period of time of relevance to the case, and I want to ask you about 3694, at the top. 29th of July, at lunchtime, and you are talking about the evening before with Miss Power, and I think, "D" is you and the number below is her. You talk about somebody called John, then you go down just below the first hole punch and Miss Power says, "It was great to be able to talk to Jack, etc. in a clear way that I can actually remember. He's such an interesting guy." That is Jack Stokoe, is it not? A. Yes, I think so. Page 74 Page 76 19 (Pages 73 to 76) Epiq Europe Ltd (+44)207 4041400 www.epiqglobal.com casemanagers@epiqglobal.com Lower Ground, 20 Furnival Street London, EC4A 1JS
1 Miller031023Nick Land / text
P. 20
Day 1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Miller & Power v Turner Q. And you say, "He's very funny and smart." And then she says, Miss Power says, "I mean, he says things I can't really countenance thinking, but that makes it even more interesting to engage with ..." and so forth, and there is a reference a few lines down by you to Natalie, his girlfriend, who was, presumably, there as well. Now, we will come back to the significance of this because this is the evening of the 28th, which is when you were together, and you will remember, because it was right at the start of your bombarding the defendant with Tweets. I will come back to that to give you a chance to deal with it, do not worry, but just whilst this page is open, so that my Lady can see the chronological relevance, also at this point, in the summer, and through to the autumn, you and Mr Stokoe were working on a book or a proposal for some sort of a book together, were you not? A. Well, that's not quite accurate. Actually, I encouraged Mr Stokoe to compile material referring to Neo-Reaction. We weren't writing a book. He was drawing material 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 ridiculous. We also thought he was in some ways, you know, quite a comical figure, actually. I mean, he was this, you know ... Q. If you look at the first hole punch, there is a line which is you doing your WhatsApp message, and it says, "Heathcliff and I are wrangling nrx material into some kind of a book format." A. That's correct. Q. And we have established that, "nrx" is shorthand for Neo-Reaction. That is a philosophy which certain Far-Right or extremist idealogues have developed, such as Nick Land, is it not? A. No, I don't agree with that description of Far-Right idealogues. Neo-Reaction is a form of thinking that comes, actually, out of Libertarianism. It was developed initially by a man called Curtis Yarvin, writing on his blog, the blog is called Unqualified Reservations. Mr Yarvin is himself halfJewish, he attempts to develop a kind of political philosophy and analysis of contemporary political economy. It's drawn a lot from James Burnham's work, actually. Page 77 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 3 October 2023 Page 79 that he was familiar with into the form of a book because it was clear that what NeoReaction was was not well understood and I felt that there would be a value in actually clarifying what it really was and meant, and Mr Stokoe did know a lot about it. Q. Can we just look at page 3872 in the same tab, in these WhatsApp messages? This is 7th of October 2018 and if you look at the very top of the page, it is the left hand page, you are, I think, just arranging to meet Miss Power, and you say, at 14.32, "It's a date!" and then you say, "Heathcliff has just arrived." Heathcliff is Stokoe, is he not? A. Yes. Q. And Miss Power says, "Say hi to the Viking." The Viking, is that a nickname for Mr Stokoe? A. I mean, it wasn't a nickname, it was just a sort of name that she came up with, I think, at that moment. Heathcliff was a name that we had for him because he, for whatever reason, initially introduced himself to me, actually also at LD50, under the name Sebastian, so we thought this was quite 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 His ideal polity is really Singapore. I don't know if you ... Q. Do not worry about that for now because we ... A. Well, you are describing it as a Far-Right ideology, and I think that it's important to be ... Q. I am not doubting that Curtis Yarvin was one of its originators, if you like, but ... A. He was the originator, I think. Q. But Nick Land was also important, was he not? A. Nick Land, at a certain moment, engages with Yarvin's work and I would say his position is a little bit different to Yarvin's. Q. Nick Land was associated with NeoReaction, was he not? A. Well, I think he is associated with it, but I think the nature of his association is complex. I mean, we're dealing with a kind of political philosophy. Q. Can we look at - sorry, we have to get another bundle out - bundle 4 and go to tab 70? Do you have that? A. Yes. Page 78 Page 80 20 (Pages 77 to 80) Epiq Europe Ltd (+44)207 4041400 www.epiqglobal.com casemanagers@epiqglobal.com Lower Ground, 20 Furnival Street London, EC4A 1JS
1 Miller031023Nick Land / text
P. 21
Day 1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Miller & Power v Turner Q. 2979 is the page. Now, Outsideness is the Twitter account of Nick Land, is it not, someone you followed? A. Mm hmm. Q. And this says, "Antisemitism is most likely a Jewish conspiracy. Nobody else could make a political theory that Baroque sound plausible to people". A. Mm. Q. That was from 2015, so that is a view expressed by another account that you follow, correct, which is, would you agree, antisemitic? A. I think it's quite a complex statement which Nick Land is making here. Q. Is it antisemitic? A. I think it's an ironic statement about first of all he says that antisemitism is a Baroque theory. Q. Could you just answer the question? Is it antisemitic? A. I don't think it's a simple question. I think this is a statement which has different levels of meaning to it. It is also relevant, by the way, that Nick Land is himself married to 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 poor dim Jews who get disproportionately shoah'd". The reference to "shoah'd", that is a reference to the holocaust, is it not? A. Yes. Q. Is this an antisemitic series of statements by Mr Land? A. I find it difficult again to interpret precisely what Nick Land is saying here. He is a very ironic writer. He is a very ironic writer. He is referring to elements in discourse using complex rhetorical techniques. I don't think he is saying these things in terms of his actual positions per se. he is referring to something. I don't really know what he is saying, to be honest. Q. Would you just please look back two more page in this bundle, tab 76, page 2991? Again, nothing has been disclosed by you in relation to your interactions online with Mr Land, so all we have are tweets by him and on these two pages it actually starts, I think, at the bottom of 2992. Again in the format we have seen before, these are all tweets where he has replied to you. Do you see the dcx Miller and npcdctv. These are 2016, Page 81 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 3 October 2023 Page 83 a Jewish woman and has Jewish children. The statement itself is - I mean it almost turns on itself in a certain way because he is saying, (a) antisemitism is Baroque. He is then claiming that that itself is a Jewish conspiracy, which is a very strange notion and I don't know what you are really left with at the end of the statement to be honest. I don't think it's simple to say this is an antisemitic statement. I've never heard such a statement before, to be honest. I don't think this is the typical view of most people who would describe themselves as antisemites. Q. Would you go forward, please, to tab 74? This is more tweeting by Nick Land. This is in 2016. He says: "Fact. White subnormals are (ideologically) the niggers of the earth. Also fact: they're white subnormals (Jewy machinations notwithstanding)." Then he says, "Of course they get a bum rap. The only people who will articulate that above the level of inchoate howl will be power-crazed hucksters." Then he says, "Going out on a limb here. I'm going to guess that it's the 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 2017. Now, to be clear, I am not suggesting that these are, per se, antisemitic message. I am referring to it to see if you agree that there were quite a number of exchanges between you during this period. A. There were a number but I wouldn't say that it was a large number. Q. Quite a number. I cannot put a number on it. A. Okay. Q. Could we now have a look at one of Mr Land's writings? This is in bundle 7, which I do not think we have ventured into yet. It is tab 349. Do you have that? A. Mm hmm. Q. Now, this is a blog post or it is his blog and it is an article and it is by Nick Land called "Hyper-Racism" from 2014. It may be easier and quickest if you read it very quickly, and my Lady as well to yourself and I just want to ask you two questions about it, particularly focusing on page 5481. A. Mm hm. Yes, i am prepared to answer questions on this topic. Q. Now, the first three paragraphs - I am Page 82 Page 84 21 (Pages 81 to 84) Epiq Europe Ltd (+44)207 4041400 www.epiqglobal.com casemanagers@epiqglobal.com Lower Ground, 20 Furnival Street London, EC4A 1JS
1 Miller031023Nick Land / text
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Day 1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Miller & Power v Turner going to summarise how I interpret those and ask you if you agree. They seem to show that he does not like what he calls the antiracist position taken by mainstream liberal democracies, in other words that all races are equal and none are superior. Do you see? He says, "This amounts to a programme for global genetic pooling", in paragraph 3, and he describes such a race equal society as a homogenous intermixture. Is that a fair summary? A. I don't know, to be honest. His first statement suggests that he is - well, it rejects in a way what he describes as ordinary racism. He says he doesn't find that interesting. He concedes that there is - that races do exist and there are differences between them and he says that the politically incorrect position is more realistic than the politically correct position on this matter. That's what I understand from the first paragraph. Q. And A. And Q. Sorry, go on. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. Well, he might do but racial identitarianism, which is the phrase that he likes, envisages what he calls a conservation of comparative genetic isolation. A. I am sorry, I am not sure where this is. Q. Paragraph (g). This is an argument for treating races differently, is it not? A. I am not sure that he is advocating this as a position. I think he is describing a position which exists. Q. If you turn over to 5482, in the middle paragraph by the first hole punch, he says this: "The genetically self-filtering elite is not merely different - and becoming ever more different - it is explicitly superior according to the established criteria that allocates social status." A. Mm hmm. Q. These are just extreme racist ideas, are they not? A. Well, he is talking about the existing elite and its patterns of assorted mating. He is not necessarily identifying himself with the elite. It is the case that people in, for example, the upper class, tend to marry and have children Page 85 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 3 October 2023 Page 87 A. In the second paragraph he again reiterates his critique of what he calls ordinary racism and he says that in the future, the genetic diversity of humanity is going to increase, actually, because of technological advances. And then he goes on to explain what he means by that. This is what he calls "hyper racism". This is a phenomenon that is developing. It develops as a consequence of, for example, gene editing technology. It already exists in terms of assorted mating. Nick Land is a Darwinist. He does believe in the Darwinistic view of biology and he thinks that that extends to human beings as well. Q. And to race? A. A race is a population group so, you know, it is true that human beings are biological in some form. Darwin does not have a conception of inferior or superior according to any kind of moral conception. Q. Well, we are talking about Mr Land here not Mr Darwin. A. Well, Nick Land's positions are derived from Darwin and Nick Land would define himself as a Darwinist, I think. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 with other people in the upper class. Nick Land thinks that that has a biological dimension to it. He says, "superior according to social status. This is his conception of superiority. I think what Nick Land is describing here is a reality that does exist. I don't think that he is advocating for it as extremist position, I think it is the case that this is something which is happening in our world, right now. Q. Can we go back to the WhatsApp messages at this point, I don't know, you probably haven't got that open. Bundle 5, 131. It is page 3872, the page that we were on before? A. I'm sorry, what is the tab? Q. Tab 131. Q. And the page? Q. Page 3872. A. Yes. Q. So, just after the bit we looked at, where you mention the book that you are working on, on Neoreaction and Mr Stokoe. In between the two hole punches, Ms Power says to you, "I think at some point we need to Page 86 Page 88 22 (Pages 85 to 88) Epiq Europe Ltd (+44)207 4041400 www.epiqglobal.com casemanagers@epiqglobal.com Lower Ground, 20 Furnival Street London, EC4A 1JS
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Day 1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Miller & Power v Turner read Mein Kampf properly." A. Uh-huh. Q. She says "Seriously!". You say, "I keep a copy in my study of course." Now, I don't think anyone in this room needs to be told what Mein Kampf is, but just in case, let's call it for short, Hitler's manifesto which described the process by which he became anti-Semitic and outlined his future plans for Germany, including the extermination of the Jews ultimately. Do you agree with that? A. Yes, I do. I haven't actually read Mein Kampf properly, it is obviously a very important historical document, precisely to understand how this terrible thing happened. This is why I have a copy of it. Q. Can we just look at your reply in bundle 1? A. Mm-hmm. Q. Which is tab 9, sorry to jump about. A. Tab 9? Q. Tab 9, page 260. A. I'm sorry, I'm a little bit confused. Q. Bundle 1, sorry, not the same bundle. A. Tab 9, page? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. I have written criticisms of Hitler, I call him a criminal psychopath. Q. Where are the copies of the writings? A. In my writings for IM 1776 I often criticise Fascist and Nazi positions. I can't tell you precisely where they are in our bundles from the top of my head. The article I wrote Must We Burn Back contains criticisms of Hitler in which I respond to people who I think are taking an irritatingly, somehow blasé, attitude towards, you know, the reality of what the Nazis were. I have other dialogues that I have done with people who do identify with the Right, unlike myself, I have never done so. Q. You haven't disclosed any of this in this action? A. We have disclosed numerous articles that I have written, in which I do deliver these criticisms, my criticisms are available. Again, I don't know where they are in the bundles, but I refer to the disclosure of the articles that I have written. Q. I am going to just ask you to look at one more reference before the luncheon Page 89 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 3 October 2023 Page 91 Q. Page 260. A. Mm-hmm. Q. At the paragraph at the bottom, 18.9.K, you are responding to the defence which has at this point referred to that reference to Mein Kampf, do you see? A. Uh-huh. Q. You say, both of you say that you "... considered reading Mein Kampf important in understanding the ways in which pathology becomes entangled with political ideology." Then it says, "The First Claimant has written criticisms of Hitler along similar lines?" A. Yes. Q. Now, I have got two questions -A. Uh-huh. Q. First, you have said you have just now, you haven't read Mein Kampf? A. I have read some of it. Q. You said you hadn't read it? A. Well, in this case I misspoke, but I have read some of it but I haven't read all of it. Q. The second question, where are copies in your disclosure of your written criticisms of Hitler along similar lines, if at all? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 adjournment. That is back in bundle 4, please. MR WALKER: Must we Burn Back is in the bundle at 315, I am told. A. Uh-huh. MS EVANS: Bundle 4, tab 106. A. I'm sorry, can you tell me the tab again, please? Q. Yes, 106. Page 3161. A. Yes. Q. This is another Twitter account that you were following? A. Uh-huh. Q. Correct? A. Uh-huh. Q. Depopulator 100%? A. Uh-huh. Q. I am just interested in its description of itself there, 100% European DNA, hashtag Neanderthal. There is a theme emerging here, isn't there, from these accounts that you follow? A. I followed a number of different accounts, you have obviously selected the ones precisely in order to attempt to create Page 90 Page 92 23 (Pages 89 to 92) Epiq Europe Ltd (+44)207 4041400 www.epiqglobal.com casemanagers@epiqglobal.com Lower Ground, 20 Furnival Street London, EC4A 1JS
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Day 1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Miller & Power v Turner the appearance of a theme. I would say this account is an account which is again representative of a certain kind of online Right position. I was interested in understanding what the online Right was and what it believes in and I think this is again a representative of that, at least to some degree. I think that if you read his description, it is a little bit strange what he could mean by this, Esoteric Thielo-Bannonist Neanderthal, I don't know what that means. You know, 100% European DNA Neanderthal, what does that mean? I don't really know, to be honest. Q. Well, my Lady, I think if that's a convenient moment because I can move on to something slightly different. MRS JUSTICE COLLINS RICE: Thank you. We will break now and return at 2.00. I have to remind you that you are, you remain on oath over the adjournment and you must not discuss your evidence with anyone. Talk about something else over your lunch. A. I understand. (12.57) 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 example, the first paragraph looks a bit paler, that is red; then it is black, then it is red and so forth. Now, luckily, we do not need to get involved in the content. I want to ask about it for a particular reason. So, this document which has been the subject of some inter partes' correspondence recently, you have admitted through your solicitors, consists of text which comes from you and comes from Ms Power, correct? A. And also, others. Q. In the letter, which I think we should look at from your solicitors, which is bundle 1, tab 38, page 759 -MRS JUSTICE COLLINS RICE: Now, I very much fear that I do not have this. MS EVANS: It sounds like your bundle has not been updated. I know you do not want more documentation, but -MRS JUSTICE COLLINS RICE: I want the right amount of documentation. MS EVANS: We will get a copy and hand it up now. MRS JUSTICE COLLINS RICE: Thank you. Page 93 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 3 October 2023 Page 95 (The short adjournment) (14.01) MRS JUSTICE COLLINS RICE: Yes? MS EVANS: My Lady, can I just hand up that missing tab, 5A, to you with the original particulars of claim? MRS JUSTICE COLLINS RICE: Thank you. MS EVANS: (To the witness) Mr Miller, I want to ask you about one last point arising in relation to ParallaxOptics and Mr Stokoe. If you could take bundle 6 this time, please, it is tab 206 and it is page 4563. Now, this is an article, or a blog post called, "CULTS II" -A. Mm-hmm. Q. -- which you will be familiar with. It was posted on the ParallaxOptics website, which is Mr Stokoe's website, is it not, from February 20, 2019. Now, unfortunately this is a black and white copy, but I think you can see from the contrasting darker and paler text - and I am saying for my Lady's benefit that this is a dialogue reproduced here. There are red bits and black bits, representing two different people. So, you will see for 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MS EVANS: What is the last number that you have on that tab? MRS JUSTICE COLLINS RICE: Well so, I have the material at tab 39, which starts at 765, but before that I have skeleton arguments... MS EVANS: So, you do not have anything in tab 38? MRS JUSTICE COLLINS RICE: No. MS EVANS: We will get you a full ... MRS JUSTICE COLLINS RICE: Thank you. THE WITNESS: I am sorry, which page am I searching for? Q. You should be looking in bundle 1, tab 38, page 759. A. Right. MS EVANS: We will get that tab sorted for you. We will just wait for Mr Miller to find it. A. Yes. Q. It is right towards the end of that tab. So, this is a letter from your solicitors on 10 August 2023, Patron Law and it is a reply to Mr Turner's solicitors who had asked about Page 94 Page 96 24 (Pages 93 to 96) Epiq Europe Ltd (+44)207 4041400 www.epiqglobal.com casemanagers@epiqglobal.com Lower Ground, 20 Furnival Street London, EC4A 1JS
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Day 1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Miller & Power v Turner this article and had put to your solicitors the theory that this article was an exchange of dialogue between you and Ms Power, okay -A. Mm-hmm. Q. -- following the red and the black pen. And the response was this, "We have now taken instructions. We are instructed that the document was not prepared by our clients. However, some of the black text belongs to Mr Miller and another, while some of the red text belongs to Ms Power and another. We do not know the identities of these third parties, nor can we identify which specific text was from our clients. The resulting text is therefore a composite authored by the blog author himself and not by our clients". Now, I have to confess, I do not understand what that letter is saying. A. Mm-hmm. Q. And perhaps you can help us, but how could your words have been used in an article on the ParallaxOptics blog without you knowing it? A. I think this formulation is not quite precise. Also, I agree with you. The 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 reasonable and more provocative dimension. There was a period of time where I wasn't really in contact with him, following the suspension of my Twitter account. I came back on Twitter. I had this text, I thought I might as well send it to him. Q. Will you just help me with this, going back to the solicitor's letter, 759. The last sentence says, "The resulting text is therefore a composite authored by the blog author himself". Who was the blog author? A. I think this statement is not accurate. I composed the text, actually, myself, so, I do admit that I -Q. So, you are at least one of the blog authors? A. Yes. Q. Was Mr Stokoe involved in editing it? A. I don't believe he was, no. And I also don't recall him participating in the dialogue. Q. But the reason I am asking you about your involvement in this article and about your various interactions with ParallaxOptics and Mr Stokoe, between 2017 and 2019 in a bit of detail, is because you have gone out of Page 97 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 3 October 2023 Page 99 dialogue was actually prepared on a programme called Rise Up. It is a software programme on the internet. Different people can collaborate on in order to create a single text. It features myself, also Ms Power, also some others, discussing the phenomenon of cults. When I created a new account to respond to your client's allegations that I had written a Hitlerian Disability Politics article, I had this text and I sent it to ParallaxOptics and he published it. Q. This text here that we see? A. Yes. Q. And were you aware that on the day that this was published that Ms Power retweeted a link to it? A. Yes, I think I was aware, yes. Q. So, you did not mind that your text was being published on the ParallaxOptics site? A. I think that ParallaxOptics's blog was a significantly more civilised piece of work than his Twitter account. In general, in terms of my interactions with him, I did want to encourage him in his more reasonable and thoughtful dimension as opposed to his less 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 your way in this action to try to distance yourself from the ParallaxOptics Twitter account and your friendship with Mr Stokoe. I suggest, to make it look like you had limited interaction with him and his antisemitic views, correct? A. Well, I think you have gone out of your way to bring us together I would say I have described our relationship accurately. As I said, I met Mr Stokoe in February 2017. He had definite right-wing positions. I had never encountered them before. I was interested in learning what they were in this context. We began a dialogue. He was also, as I said, the student of my friend, John Cousins, who is an academic who works in arts education. I met him in Haiti, so we got another connection through this. Your inferences appear to be that myself and Mr Stokoe shared similar views and this was never the case. I was interested in understanding what his views were. Around September 2018 it was fairly clear that our dialogue had run its course. I was becoming increasingly just actually bored by our Page 98 Page 100 25 (Pages 97 to 100) Epiq Europe Ltd (+44)207 4041400 www.epiqglobal.com casemanagers@epiqglobal.com Lower Ground, 20 Furnival Street London, EC4A 1JS
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Day 1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Miller & Power v Turner discussions because I think he was committed to these positions and he wasn't going to proceed beyond them. Also, I was speaking to Nina now and, to be honest, I found that conversation much more interesting. I don't share the views that Mr Stokoe has. I never shared his views. I agree that he has made extremely annoying and even abhorrent statements from his anonymous Twitter account. I was also profoundly annoyed by them. The fact that he would not stop making them is actually also what led to the end of our acquaintance but I would also note, and this is not irrelevant, I think, that at the time I knew Mr Stokoe both of his parents were dying and subsequently did die within a short period of time at the same time. I did take that into consideration, actually, also in terms of my interactions with him and that was a factor in my thinking. Q. We have seen one instance of your distancing yourself and that was the deletion of the abhorrent antisemitism admission. A. I am sorry, I don't agree that that is an 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 in order to be provocative. He did not make those to me personally in the context of the real world. I would ask what I as a Jewish man am supposed to do when I encounter an antisemitic statement. Should I condemn the speaker instantly and sever all contact with them? It seemed to me that it was more reasonable to attempt to encourage the better angels of Mr Stokoe's nature. I think that I was not ultimately able to do that to a particular profound extent but that was nonetheless my motivation. Your inferences are that I am improperly attempting to distance myself from him and I would say that that is not true. I was always very distant from him in terms of our different beliefs and our different views. Q. Can we just look at your pleading on this point because to be fair to you, it is only fair to let you see it. It is your amended reply at tab 9 in bundle 1, page 244, paragraph 11.3, which is the long paragraph that starts on page 243. I am sorry, I will wait for you to find it. So you see what this is, it is you see at the start of 11.3 it says, "As to paragraph Page 101 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 3 October 2023 Page 103 instance of what you claim that it is. As I pointed out, I regularly deleted my tweets. I simply deleted my tweets because I wished to delete my tweets. Q. No, sorry, we are at cross-purposes. I am not talking about you deleting your tweets. I am talking about you deleting the paragraph in your pleading that had admitted that ParallaxOptics' account was abhorrently antisemitic. A. I believe that we deleted this paragraph because we abandoned our claim of harassment. Q. That is correct but the defendant maintains his allegation about you consorting with an antisemitic attack and you did not reinstate it. All I am putting to you is that that is one instance of you trying to distance yourself from him because of the implication of it for you in this case, which is the natural reason that you were willingly consorting with somebody who was antisemitic. A. I don't actually think that it is precise to say that he was antisemitic. He made antisemitic statements upon occasion, I think, 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 14.10.1". That is a paragraph in the defence which, in fairness to you, you should look at, so go back to tab 6 and it is page 92. Tab 6 of the same bundle, page 92. A. I do not have a page 92 under tab 6. Oh, I am sorry, one moment. Q. So, it is a left-hand page. A. Okay. Q. So, it's the long 14.10.1 - do you see that? A. Yes. Q. In that paragraph, which is a particular of Mr Turner's defence of truth and honest opinion, it mentions the fact that ParallaxOptics was operated by Mr Stokoe and that he was until that time a friend of yours. It says that you shared similar far right ideological views with him and it says various other things, and if you look, you will see it refers to a part 18 response of yours. That is in response to a request for further information, which I will come on to. So, if you go back to tab 9 - I am sorry, it is a bit of jumping about there - page 244, you will see from the whole sentence it starts to Page 102 Page 104 26 (Pages 101 to 104) Epiq Europe Ltd (+44)207 4041400 www.epiqglobal.com casemanagers@epiqglobal.com Lower Ground, 20 Furnival Street London, EC4A 1JS
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Day 1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Miller & Power v Turner deal with the allegation of him being a friend. It denies it. Says that you interacted with the account occasionally, initially in response to its views about art and later to challenge its reductive political position and racist and misogynistic statements. It then says this: "The First Claimant and the second Claimant were willing to talk to Mr Stokoe but there were many points of disagreement between them and they were not friends." Now, we have seen, have we not, that you socialised with him, so it is a slight misrepresentation is it not to say there that you were willing to talk to him? Correct? A. No, I don't think so. Q. If you drop down, it says, "The First Claimant's attempt to work with Mr Stokoe on more intellectual material was a last attempt to steer him away from his reductive views." What was the more intellectual material? A. This is the new reactionary material that I was encouraging him to compile into a book. Q. And then just for completeness, the part 18 response that I mentioned is on at tab 13, 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 similar unsympathetic views about his ideas and we state that exclusively. I say, "I want to somehow get you out of your selfdefeating position but it's very difficult". I state that. That was my view. This is early October. Okay, an error there; I remembered it as September. This happened five years ago. Q. And then we also have the Cults II publication which we have just looked at on his website, which was February 2019. A. Mm. Q. And then you started to refollow him in February 2019 on Twitter, did you not, when you opened your new account? We looked at that this morning. A. Well, either he started to follow me or I started to follow him. I don't know what happened first. Q. So, not only does it show that that answer in your part 18 was not correct about when you stopped interacting with him but it does beg the question as to why you have not disclosed any of your communications with him over the whole relevant period: tweets, Page 105 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 3 October 2023 Page 107 page 284, paragraph 683. It talks about you meeting him on approximately four occasions at which you expressed disapprobation from his Twitter accounts and it says that you concluded that his purpose online was transgressing taboos and that therefore further discussion was pointless. A. Mm hmm. Q. And it was your case there that after September 2018 you had no more contact with him. A. I had much more limited contact with him. As I said, both of his parents were dying and so I had no particular desire to create a breach and add to his issues in that regard. Q. But we have seen, have we not, from the WhatsApp messages that on 7 October you were meeting him to discuss the ongoing book? A. I say September here. In fact, it was October. My memory was faulty in that regard, but it was around this time. You can see from the WhatsApp exchange that I had with the second claimant that we share 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 WhatsApps, emails, anything electronic, any drafts of the book. You must have communicated with each other, correct? A. Well, we communicated mainly on Twitter. I lost all those messages when my account was suspended. The book that we were compiling we were compiling on his computer, so he has those files. Those files consisted of material that has already been published on the internet. LD50 around this time actually published their own book compiling new reactionary material, so in a way that rendered this project moot. Q. When you arranged to meet with him, how would you arrange it? A. I think that I would message him on Twitter. I don't really remember, to be honest. Q. Not WhatsApp? A. I never had his WhatsApp. Q. And not email? A. No, not really, no. Q. You see, in your solicitor's letter about your disclosure this last summer - I do not think we need to turn it up but it is bundle 1, Page 106 Page 108 27 (Pages 105 to 108) Epiq Europe Ltd (+44)207 4041400 www.epiqglobal.com casemanagers@epiqglobal.com Lower Ground, 20 Furnival Street London, EC4A 1JS
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Day 1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Miller & Power v Turner tab 38, page 730 - my solicitors had asked your solicitors why you in this time have not disclosed any documents related to a list of named people, ParallaxOptics, Jack Stokoe was one; Nick Land, Justin Murphy and a variety of people, and the only answer that came back was, literally, "Our client" - about ParallaxOptics and indeed about all of them but, "Our clients have nothing further to disclose" and in answer to my solicitor's request for an explanation as to how it was that there was nothing to disclose, given that we live in the electronic era, there was no explanation. I suggest that it is inconceivable that you did not communicate electronically with Mr Stokoe and a range of the other people whose names feature in the pleadings in this case, and that you ought to disclose them and you deliberately have not. A. Well, as I said, I communicated with Mr Stokoe through Twitter whose messages were lost when my account was suspended. I never communicated with Mr Stokoe with respect to your client and I did not have extensive interactions with him in terms of 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 took place, we did stop communicating electronically to a large degree. Q. To a large degree? A. Well, we would still sometimes coordinate in terms of, for example, we practised yoga regularly but we never coordinated with respect to anything to do with your client and we ceased to have long exchanges as well because first of all we saw a lawyer at the end of October 2018 and he advised us with respect to this forthcoming libel action against your client, not to discuss things electronically, precisely because that would create a record that would be disclosed in the event of a trial. I was also tired, actually, of electronic messaging in general at this point. I think that it is a highly deranging phenomenon. I was understanding also the extent to which I myself was deranged to some extent by my participating in this medium, so we tried to restrict ourselves to speaking in person. I think around this time or maybe later, Nina actually attempted to arrange a meeting for people to take - to meet in newer space and Page 109 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 3 October 2023 Page 111 exchanging ideas online except for the lines that are already presented in the Twitter record that you have disclosed. I appreciate your desire to make Mr Stokoe a central feature of this case. From my perspective he is not. He made one reply to your client ever. Your client subsequently reported him to the police as I understand it from the disclosure that you have also provided. Your interest in connecting me to Mr Stokoe is I would say even stronger than my interest in dissociating myself from him. I had interactions with him. We had conversations. We never shared views. I do not know what else I can tell you about this. Q. Also, completely missing in the case is any documentation apart from the WhatsApp messages at tab 131 between you and Ms Power showing communication between you and Ms Power. Did you never communicate electronically with her other than on WhatsApp between 29th or 28 July 2018 and 25 October 2018? A. Subsequent to the period in which our WhatsApp messages that we have disclosed 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 have conversations in this hall, because ultimately the electronic medium is a very bad medium for discussing ideas. Q. I am going to put to you what my client's case is in relation to ParallaxOptics and Mr Stokoe before I move on to the next topic. You employed a close association with Stokoe between 2017 and 2019. Correct? A. No, I don't think that's correct. Q. You both shared views and ideas which any honest person would describe as extreme or far right and antisemitic. A. No, I completely reject that. Q. You knew that it would be damaging for your libel claim in this action against Mr Turner for the nature of your relationship with Mr Stokoe and your shared interests to be revealed, did you not? A. No. Q. You knew this because you knew that it would look like you were also antisemitic at the time you were interacting with Mr Stokoe of ParallaxOptics. A. I do not understand how it is that you able to so repeatedly characterise a Jewish Page 110 Page 112 28 (Pages 109 to 112) Epiq Europe Ltd (+44)207 4041400 www.epiqglobal.com casemanagers@epiqglobal.com Lower Ground, 20 Furnival Street London, EC4A 1JS
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Day 1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Miller & Power v Turner person as antisemitic when you don't have one single piece of evidence suggesting that except for the fact that I spoke to at different times people who did have these views, which I have admitted. Q. Antisemitic is indeed what Mr Turner concluded in 2018 after you started targeting him, which I will be coming on to shortly. Before that, could you please go back to the WhatsApps at bundle 5, tab 131? A. I am sorry, bundle 5? Q. Bundle 5, 131. And it is page 3724. A. Yes. Q. Now, these are your WhatsApp messages with Ms Power on 5 August 2018 at nearly 11.30 at night. Right at the top you say to her, "Did you ever read Kevin McDonald Culture of Critique? He's probably got the most sophisticated antisemitic theory". Now your solicitors have admitted in correspondence on your behalf that Kevin McDonald, who is an American, was or is antisemitic. A. Well, of course. I say that myself. He has an antisemitic theory. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 he not? A. I really have very little knowledge of Kevin McDonald. I know that he is popular amongst antisemites precisely because of his sophisticated antisemitic theory, which Cofness refutes, as I say. Q. You seem to be quite keen on recommending books you have not read. A. I don't recommend his book. I merely ask whether Nina has read it. Q. I suggest that usually, if somebody says that something is sophisticated, it is because it is something you admire. A. No, I think that's not the case. Chemical weapon is sophisticated. It is not something you would admire. It's a description of his theory. It doesn't make it admirable. Q. Since people in this court seem to find this quite funny, can we have a look at 18.9(a) of your reply, please, at tab 9? A. I am sorry, which bundle? Q. Bundle 1, tab 9, 258. Now, this is your reply to the defence where the defence has referred to this reference by you to Mr McDonald's sophisticated antisemitic theory, Page 113 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 3 October 2023 Page 115 Q. What did you mean by the most sophisticated antisemitic theory? A. I never read Kevin McDonald. I've read only Cofness's critique of him so my presentation of his theory is necessarily incomplete. As I understand it, Mr McDonald presents a theory of what he calls "evolutionary group selection" in which he claims that Jews become involved in various intellectual and political movements in order to advance Jewish group interests. He identifies, I believe, psychoanalysis and some form of anthropology and I think probably also Marxism as examples of this. Cofness critique's this theory and refutes it as I go on to say. I think that Kevin McDonald's theory is probably the most sophisticated antisemitic theory. He does have a theory. Most antisemites do not actually have any kind of theory; they simply are antagonistic towards Jews. This is what I meant by that statement. Q. Mr McDonald, or Professor McDonald gave evidence though, did he not, in the David Irvine libel trial in support of David Irvine and he was or is a holocaust denier, is 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 and your explanation in 18.9(a) is, to be charitable, rather difficult to follow. You say that most theories of antisemitism are simplistic and crude. You are contrasting his there. His was more developed and considered than is usual. But how can you say that if you haven't read it? A. I have read Cofness's description of it. Cofness provides in the context of his critique as is normal scholarly procedure, a description of the position that he is critiquing. Q. But is antisemitism per se not simplistic and crude? A. Antisemitism is an extremely complex phenomenon. As I say, it does span the whole history of western civilisation. Ultimately, you can trace it back to St Paul and to the evolution of Christianity which separates itself from Judaism at its inception. I, myself, have conducted research on this point when I was working for the Jewish Renaissance Movement in Poland. I interviewed a number of Jewish academics and we discussed these topics. Antisemitism Page 114 Page 116 29 (Pages 113 to 116) Epiq Europe Ltd (+44)207 4041400 www.epiqglobal.com casemanagers@epiqglobal.com Lower Ground, 20 Furnival Street London, EC4A 1JS
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Day 1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Miller & Power v Turner is incredibly not simply crude. It is something which is in the DNA of western thought and it should be understood, and it should be understood critically. I do believe that. Q. What exactly do you mean by, "It's in the DNA of western thought"? A. Well, as I say, Christianity is created through a separation of the new Christian message from the Jewish site from which it emerges. So, if you went to look at antisemitism you also have to look at the history of Christianity and how antisemitism develops through history is an extremely complex phenomenon because subsequent to the climb of Christianity, antisemitism begins to take on new forms. It becomes, for example, much more biological and this is a phenomenon that happens in the 19th century. Q. Forgive me, I have understood antisemitism in effect to be a theory that Jews are inferior to non-Jews, specifically Christians. Does that not rob Jewish people of their individuality to even talk about them 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 He is in those echo parenthesis again, is he not? A. Yes, he is Jewish, like myself. Q. You also say a bit further down - well, only two lines down: "Many things that one could say about this topic ultimately but of course it is not so easy to discuss." I suggest what you mean by that is that you know that talking about antisemitic ideas is not something that is regarded as acceptable in our society. A. I am saying what I mean, which is that antisemitism is a very complex phenomenon. If we want to talk about antisemitism, I think we should talk about antisemitism. We should try and talk about it in a sophisticated way. As I said previously, WhatsApp conversations are probably not the medium for doing that. I am not sure whether you are attempting to say that antisemitism is not a complex phenomenon. Q. I am not debating with you. it is not a symposium on it. A. Okay. Q. What I am going to put to you is that you Page 117 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 3 October 2023 Page 119 in that way? A. Forgive me but I don't think that this is what antisemitism actually is. Antisemitism is a much more complex phenomenon. Q. Antisemitism is not a theory that Jewish people are inferior? A. No, it's not the theory. It is the theory, for example, of - a Jewish world conspiracy is one of the most prominent antisemitic views. This is not a question of inferiority or superiority. If you look back to how antisemitism features in the mediaeval period, it has nothing to do with superiority or inferiority. It has to do with certain kinds of metaphysical and cultural divisions that are existing within this society in terms of the revelation of Christianity. This is a 200year-old highly complex history of psychological economic, social, cultural, religious dimensions. It's a very complex phenomenon. Q. Could you just look at page 3724 again, which is where Mc Donald is referred to? A. Mm hmm. Q. You have mentioned Nathan Cofness. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 have been caught out here. These WhatsApp messages which were disclosed very late in the action with no explanation again as to why they weren't disclosed when they should have been, have caught you out because they reveal that you are engaging with and endorsing antisemitic ideas and proponents of them. A. They reveal no such thing. I endorse in this discussion only Cofness's critique of Kevin McDonald's books. I don't endorse any antisemitic ideas. I oppose antisemitic ideas, but I want to understand what antisemitism is. I have spent quite a lot of time thinking about this topic. Q. I am sure you have. Can we have a look at page 3725? A. Well, if I may finish, I did research the topic of antisemitism when I was working for the Jewish Renaissance Movement in Poland, which was an art project which was created by an Israeli artist named Ial Bahtina[?]. As a Jewish person myself, I do wish to understand what antisemitism is and how it manifests itself. I also want to distinguish Page 118 Page 120 30 (Pages 117 to 120) Epiq Europe Ltd (+44)207 4041400 www.epiqglobal.com casemanagers@epiqglobal.com Lower Ground, 20 Furnival Street London, EC4A 1JS
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Day 1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Miller & Power v Turner what antisemitism is from what some people claim that it is and actually if possible I would like people to not be antisemitic and I understand the best way of moving them away from this position is not simply to start saying, "You're antisemitic" but to understand how it is that these positions are formed. These positions are formed as a consequence of a very complex triangulation of ideas, which are very deep in the society that we live in. Q. Can we go on to page 3725, which is the next page? Right by the first hole punch this is 5 August, the same day, about 15 minutes later. You say, "Only Land is really worthy." That is Nick Land, is it not? A. Mm hmm. Q. You see, what is surprising about finding that in there is that in the original reply at 17.2, which you will find in tab 9, page 241 it is crossed out but you can read it - do you have that? A. I am sorry, which page? Q. 241. A. Hmm. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. Could we please go forward to 3746 in the WhatsApp messages, if you still have that open at tab 131? A. Mm hmm. Q. So, just below the second hole punch, on 16 August at 1434 you say to Ms Power, "Good blog post here, quite comprehensive" and then you include a link. Now, that blog post, which I am going to ask you to look at is in bundle 9, tab 423. This is a blog post A. I am sorry, bundle 9? Q. I am sorry, it is bundle 9, tab 423. A. Okay. Q. Do you have that? A. Yes. Q. I am sorry, obviously the uploading has completely failed. MRS JUSTICE COLLINS RICE: I think I am probably missing the whole of 422 to 428. MS EVANS: The only ones I need at the moment are 423 and 4, so I will give you those. MRS JUSTICE COLLINS RICE: Thank you. Page 121 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 3 October 2023 Page 123 Q. This is paragraph 17.2. You say: "The first Claimant interacted with ParallaxOptics to challenge its reductive positions on a variety of issues, its endorsement of Nick Land, its misogyny and racism". But what we have just seen when you say, "Only Land is really worthy" is an expelling[?] of Land. It is not a challenge. A. I don't think - or rather, what I meant in this context is that only Land is even worthy of critique. "Critique" is the appropriate mode to discuss a philosopher. Anyone who is simply endorsing the views of any thinker is, in my opinion, not reading him properly. I do believe Land is worthy of critique. I think Land is an extremely influential philosopher. I appreciate that to an audience who is not familiar with his work you are compelled to attempt to present him as a raving audiologue but this is simply not the case. He has been extremely influential across the political spectrum for many years and it is worthy to criticise him and to critique him and to take him seriously as a thinker. I do believe that. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MS EVANS: Now, this one at 423 is an article or a blog post by a writer called Nicholas Wade, and it is called "Widening circle of empathy, the final frontier" and I am afraid I have to just take you through a little bit of this to ask you about your recommendation of it as being "good blog post here, quite comprehensive". So, starting on page 4261, he introduces it by setting it in a town in Hungary, making the point that that town, which is 1000 years old, has just applied for the coveted European Capital of Culture but they were turned down and the bottom paragraph quotes from an apparent explanation as to why they were turned down: "There were too many happy white people and crosses and not enough migrants." According to the EU experts. So, he takes this theme and develops it, perhaps in a fairly predictable way. If you turn the page to 4262, he then cites another example of the modern European Union or Europe by saying that the French football team are full of black players, at the top, and then he says in the middle: "Steven Pinker has written at Page 122 Page 124 31 (Pages 121 to 124) Epiq Europe Ltd (+44)207 4041400 www.epiqglobal.com casemanagers@epiqglobal.com Lower Ground, 20 Furnival Street London, EC4A 1JS
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Day 1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Miller & Power v Turner length about the widening circle of empathy. We at TWCS believe that it has four phases and that certain Western countries have now entered the fourth and terminal phase, the desire for self-replacement." He says, "On what do we base this claim and if true where does it come from? How do we know when it's approaching? Is there anything we can do to stop it?" And then he lists the three stages, the three with the fourth to come. "Our research" - this is the bottom of 4262 has led us to believe that out-group altruism goes through four phases: the clan", which is enmity towards all outside one's clan; the ethny, trust for all in one's own ethnic group; multiculturalism, which is trust for alien ethnic groups, "[most Western countries are here]" and 4, "Ethno-suicide, a wish for selfreplacement by alien ethnic groups." And then he goes through and develops each of these phases or stages and when you get to 4265 he seems very happy with one, as it were, the existing clan, two he can live with. Three, "Multiculturalism where we trust alien groups. Current example, Anglo- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 terminal phase we call on them to replace them." And then he divides that into some other subheadings below. Below that. at the bottom: "We are encouraged to replace ourselves with immigrants". That is the first complaint. Page 273: "We are encouraged to out marry." He says: "One interesting aspect of plain old multiculturalism was the quite forceful propagandising required to make people accept it. Not that we would use the word as a pejorative. Antismoking propaganda in the US in the 70s on for example has been hugely successful in stopping this harmful habit. Nonetheless, the images used and diversity campaigns have greatly evolved. In the past they were often of, say a multi-racial group of friends or a black family interacting with a white family. The new diversity images are altogether different. We now have advertisers, TV shows, etc. spurring on Euro-descended people to marry outside their group." And so it goes on. At 4277, the next feature, apparently, is the fourth phase. We are told to feel contempt Page 125 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 3 October 2023 Page 127 Scandinavians, Germanics." He says, "The third phase of the widening circle of empathy where much of the West has arrived today, is that of extending trust to alien out-groups, the more alien the better. When did this change come about?" and he goes on to talk about changes in immigration policy and then he sets out his study in relation to different countries. And at 4267 he is at the UK. He says, "In the UK, non-white immigration", because that is what he is talking about, "was very low until the 1990s" and then he says at the second hole punch, looking at the stats, "Who are all these foreign born? Non-whites lead the charge". Then if you turn to 4269 we have the Final Frontier of self-replacement, phase 4. He says at the bottom: "Multiculturalism we have just seen is a welcoming of alien ethnic groups". Turn the page: "But where is the line between multiculturalism and selfreplacement? It seems there is a slow evolution. First we welcome in alien groups. Then we start to offer them perks that we do not offer our own groups. Lastly, in the 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 for our own ethnic group. And then the fourth on page 4280, we are erasing ourselves, apparently, from our own history. And the last reference on 4286, this question, "Where will it end? We have seen some compelling evidence that multiculturalism in the West is metastasising into a kind of ethnic self death wish. Have we seen this before and where did it end" and so forth. Now, you say that is a good blog post, quite comprehensive but that was an unashamed expression in that blog post of the great replacement theory, white supremacism, whatever you want to call it, was it not? A. Well, I think we should be precise about what we are going to call it. I would say also your previous comment that the writer complains about the French football team having too many blacks is not actually a statement that I read on this, I read here. He quotes from the Anti Defamation League, actually, celebrating the diversity of the French national team. I said that the blog post was good because comprehensive. I think it's a comprehensive - Page 126 Page 128 32 (Pages 125 to 128) Epiq Europe Ltd (+44)207 4041400 www.epiqglobal.com casemanagers@epiqglobal.com Lower Ground, 20 Furnival Street London, EC4A 1JS
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Day 1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Miller & Power v Turner Q. Sorry, because what? I did not hear. A. Because comprehensive. It's a comprehensive statement of the HPD position. It's not clear that Q. HPD is human biological diversity, right? A. That's correct. Myself and Nina were discussing the ideas of the right in general. This is what we are doing in the context of our chat here and this is an idea which they do believe in, and I think this is an idea which we should discuss and I don't know exactly what to say about this blog post myself. I think the question is whether the facts that it presents, are they true or not. Q. So, you read this one, did you? A. I did read this, yes. Q. Human biological diversity is a theory promoted by Nick Land, is it not? A. Yes, he endorses this theory. Q. It is a euphemism for eugenics, I suggest to you ... A. No, that's not correct. It doesn't have a, it doesn't have any kind of a project attached to it, it is an attempt to describe the diversity, the biological diversity of the human world. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 tab, please, in the WhatsApp messages. 29th of August 2018, 11:41 in the morning. Now you are recommending something else to Ms Power. You just, you say, "Very long piece on Holocaust historiography here" with a link. I'd like to just look at that document as well. It is in the next tab in bundle 9 at 424. In your -- I don't think you need to turn this up. In your reply what you say about this document is that your defence of your reference to it is that you say you didn't endorse it, or his views, but you were just expressing your view that he would be cancelled for expressing them. Just so you know what you said about it? A. Uh-huh. Q. Now, I don't need to spend as long on this one but what he is doing in this article, Mr Unz, is he is looking back at old articles that posited to varying degrees that the Holocaust did not happen and that Holocaust was a hoax and a fake. I think everybody is familiar with that line of, inverted commas, "thinking". He spends a lot of the article criticising the overwhelming power, as he Page 129 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 3 October 2023 Page 131 Human beings are diverse, human beings are organised into different population groups, depending on where they come from. People from the Andaman Islands have extremely good lung capacities, for example. This blog, post claims that there is particular psychological characteristics associated with Western Europe to do with the alt group, marriage in particular, and it suggests that current immigration policies are an expression of that. Now, personally I am not particularly interested in biology and I am not well placed to respond to these claims on their merits, but I do think that it is a comprehensive statement of this position. I would also add that it doesn't seem to me to state it in a violent or extremist manner, it is mainly composed out of quotations, it is named after a concept from Stephen Pinker, who of course is a very well regarded scientist at, I believe, Harvard, it quotes and cites quite a lot of evidence. So if we want to reject this, then we can, but I think we nonetheless have to consider it carefully. Q. Could you turn to page 3786 of the same 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 sees it, of the narrative that the Holocaust did indeed happen and that six million Jews were killed, okay? I just want to look at his conclusions, bearing in mind you are recommending this. A. I deny recommending it, but okay. Q. 6332, the penultimate page. In the middle of that page he says, as he is coming to the end of this article. "My growing realization 15-odd years ago that substantial numbers of knowledgeable people appeared to be secret adherents of Holocaust Denial certainly reshaped my own unquestioning assumptions on that subject. The occasional newspaper account of a Holocaust Denier being discovered and then flayed and destroyed by the media easily explained why the public positions on that subject remained so unanimous." Then he says, if you drop down to just above that subheading, "For these reasons, I had grown quite suspicious and held a very open mind on Holocaust matters as I eventually began reading books on both sides of the issue." Under the heading, "The Future of Holocaust Denial, Page 130 Page 132 33 (Pages 129 to 132) Epiq Europe Ltd (+44)207 4041400 www.epiqglobal.com casemanagers@epiqglobal.com Lower Ground, 20 Furnival Street London, EC4A 1JS
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Day 1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Miller & Power v Turner the bottom paragraph. He says, "I have invested only a few weeks of reading and research in studying this large and complex ..." the term that you used "large and complex subject, and my knowledge is obviously dwarfed by that of the considerable number of individuals who have devoted many years ..." to it. Drop down to the next paragraph, "Any conclusions I have drawn are obviously preliminary ones, and the weight others should attach to these must absolutely reflect my strictly amateur status. However, as an outsider exploring this contentious topic I think it far more likely than not that the standard Holocaust narrative is at least substantially false, and quite possibly, almost entirely so. Despite this situation, the powerful media focus in support of the Holocaust over the last few decades has elevated it to a central position in Western culture." And so forth. That conclusion that he draws is abhorrently anti-Semitic, is it not? A. There are many things you could say about his conclusion. From my point of view 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Well, in fact he can't be cancelled because he runs his own website and it seems like nobody can actually cancel him but the statement that I make is in reference to the awareness that obviously anybody who does deny the Holocaust clearly places themselves beyond the bounds of what is considered acceptable opinion in contemporary society, that's I think clear. Q. I am just going to read to you what you do say, in fairness. You say at 18.9, and your reply at page 259, tab 9. You say, "The First Claimant did not endorse the views of Unz but was expressing the belief that Unz would be 'cancelled' (that is, subjected to widespread condemnation potentially impacting upon his platforms for expressing his views and his livelihood) for expressing those views." Now, the implication of that, as I read it, is that you don't think it would be a good thing if his views were cancelled; correct? A. I don't have an opinion on it, to be honest. I think that whether good or not, I don't know, I don't agree with his views. I Page 133 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 3 October 2023 Page 135 what somehow interested me about this article is it actually never occurred to me that the Holocaust itself had a history and Unz's article describes the history of Holocaust denial. I think that the Holocaust obviously did happen, I think the narrative is probably actually basically true, it an historical event, so as with all historical events people argue about them. But it is also true that the Holocaust has this status in our culture where to deny it is illegal in many countries. So, it is unusual from the point of view of historical events in that regard. Now, there are many historical events that you can actually deny, people used to be able to deny the divinity of Christ was a heretical crime and Holocaust denial has a similar status today. Unz is a Holocaust denier, that is without doubt. Q. In your pleading, I can take you to it if you want, I just told you what it said, it said that the point you were making, the point you are making about him is that your warning he is likely to be cancelled for holding those views; yes? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 don't know whether it is healthy for the Holocaust to have this kind of forbidden status in our culture or not. This is a view I share with Noam Chomsky, by the way, and multiple other actually often Jewish academics. In Israel the discussion is a little bit different to how it is outside of Israel. It is an extremely emotive and contentious topic, that is very clear. It is an horrific topic, frankly. I don't personally understand exactly why people are motivated to deny the Holocaust or why that is an important thing for some people to do, some people become extremely obsessed with this topic, I am not one of them. I don't like reading about historical atrocities of which the Holocaust is obviously the supreme example. Q. Could we please go to bundle 3. You can keep bundle 5 open, but go to bundle 3, tab 51. MRS JUSTICE COLLINS RICE: Forgive me, I was just making some notes. Can you repeat the reference, please? MS EVANS: I'm sorry. It is bundle 3. MRS JUSTICE COLLINS RICE: Yes. Page 134 Page 136 34 (Pages 133 to 136) Epiq Europe Ltd (+44)207 4041400 www.epiqglobal.com casemanagers@epiqglobal.com Lower Ground, 20 Furnival Street London, EC4A 1JS
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Day 1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Miller & Power v Turner MS EVANS: Tab 51. MRS JUSTICE COLLINS RICE: Yes. MS EVANS: Page 1815. MRS JUSTICE COLLINS RICE: Thank you. MS EVANS: Now, this is a tweet from ParallaxOpticsthat we looked at this morning, dated 29th of August 2018. You will see that he is enclosing a link there to this same article by Unz, American Pravda; do you see that? A. Yes. Q. On page 1815. If you go back, please, to bundle 5, tab 131 where we were just looking at your communications with Ms Power. A. Uh-huh. Q. Page 3786, where you recommend that blog is also the 29th of August, 2018. So, I suggest, and maybe I am wrong about this, but it is a bit of a coincidences that you were recommending the Unz blog by Mr Stokoe, Parallax Optics, on that day, weren't you? A. I think this is when Unz published his blog. It may be that I found this link through Parallax Optics' tweet. I sent it to Nina 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 once would deny religious realities. Q. Well, that tweet there from Parallax Optics, the Holocaust one, was one of the ones which I think you admitted this morning was abhorrently anti-Semitic. Can we just turn, please, to the last reference in the WhatsApp messages for now? 3760 is the page, so it is back to bundle 5, tab 131. A. I'm sorry, can you tell me the page again? Q. 3760. A. Uh-huh. Q. Now, below the second hole punch, on 3760, this is 18th of August 2018 at 2143. Ms Power says to you, "I wonder if the social disapproval for 'racism' is a psyop to stop people realising that there *are* alien and fairy races?" You say, "Good take." A. Uh-huh. Q. Then, if you drop down a few lines, Ms Power says, "Also, that black and white were alien races and very different." Then you say at the top of the next page, "Yes, you should not reveal this to most Page 137 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 3 October 2023 Page 139 because I was interested to know what she would say about it. As I said, you know, we are or were discussing the ideas of the online Right, of which ParallaxOpticsis an example. You say that I recommended the article, I don't think I recommended the article, I merely noted its existence. Parallax Optics' statement, "Does the Holocaust even real?" I think is an accurate summary of the question of the blog post. I think the way in which the statement is sort of formulated, nongrammatically, is not completely irrelevant because there is also a question here about what we mean when we refer to the Holocaust. I think that it is indisputable that Hitler murdered millions of Jewish people. The term "Holocaust" obviously as you may know, it means burnt sacrifice, actually this is its literal etymology, it has a religious meaning. So when people are discussing this term, they are also discussing it in this kind of a register and this is one of the reasons why it is so complex to discuss and I think also one of the reasons why people are motivated to deny the Holocaust, as they 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 people. That's definitely true - they can't handle it." If you go to the middle of that page, still carrying on the discussion, you then say at 21:47, "Personally I don't see any reason why this point of view is less plausible ...", in other words, having alien black and white races, "... then many socially acceptable theories which are, in fact, demonstrably false." The answer from Ms Power is, "You make a good point! Absolutely true." Now, what you and she were discussing there is your theory that black and white races are alien to each other, wasn't it? A. It wasn't a theory, it was in my opinion a preposterous statement that I was responding to in a highly tongue in cheek manner by suggesting that it was a very interesting idea. I think that, you know, we both thought that it was a ridiculous idea and this is basically we were exchanging on at this point. Q. What we see on 3761, which I read out in the middle, is another example of you recognising that there are certain subjects that don't get spoken about because they are Page 138 Page 140 35 (Pages 137 to 140) Epiq Europe Ltd (+44)207 4041400 www.epiqglobal.com casemanagers@epiqglobal.com Lower Ground, 20 Furnival Street London, EC4A 1JS
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Day 1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Miller & Power v Turner regarded as being over the line, and racism is one of them, that's what you mean about "I don't see any reason why this one is less plausible than many socially acceptable theories." You have just said at the top, "You should not reveal this to most people?" A. Well, that was a joke because what I was implying there was, in a way, that this actually ridiculous statement was somehow plausible in compelling theory. This is why, this is -Q. Just look at the bottom line of the page, 3761. You say, "... I think the most important single insight is the recognition that one can't speak like this with everyone, indeed that such spaces as these must be carved-out of a hostile world and then defended and protected ... therefore the history of occultism." So, again, it is a recognition, isn't it, that you are both discussing something that is regarded as socially unacceptable, racism, because you are discussing it in a way which indicates a particular view about the difference between black and white races; correct? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Athens because he was challenging people's opinions and he was trying to have open discussions with them. This is the nature of human communication, it is possible to misunderstand things, it is very difficult to discuss things, it is very difficult to critically discuss things, you do need spaces in which people can critically discuss ideas and can critically discuss ideas also that some people find reprehensible, abhorrent, highly problematic, insane, we should discuss all of those things and we need spaces to do these things. With Nina, my friend, we have such a space because she understands what I believe and she knows that I don't believe the things that you are imputing to me and I also trust her mind and we discuss these subjects critically; we don't endorse them. The notion that human races are actually alien races and fairy races is obviously not a serious statement, we also tell each other jokes and sometimes we laugh, this is how we amuse ourselves. MS EVANS: My Lady, I don't know if that's a convenient moment, if the transcriber Page 141 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 3 October 2023 Page 143 A. Our discussion is more complex than this. Racism is actually frequently discussed in our society, it is arguably discussed endlessly in our society. I think in an actually highly problematic way, I think in a way which encourages division between races which is extremely counterproductive. I think it is certainly true that our society, especially today, and to a greater extent than before is structured by taboos, it is structured by lines that one cannot cross, topics that one is not supposed to discuss because of the ease in which people who are motivated to do so can take discussions out of context, can read malicious intentions into them, can claim that one is endorsing something when one is actually simply discussing something. This is a phenomenon of contemporary society, it is a phenomenon that has been massively accelerated by the internet. Now, this is also a phenomenon actually that goes back, again historically a very long way, Socrates, you may recall, was himself executed for questioning the taboos of Athenian society, they said he was corrupting the youth of 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 would like a break because I am going to move on now to deal with the harassment part of the case. MRS JUSTICE COLLINS RICE: Let's take five minutes. (15.09) (A short adjournment) (15.18) MS EVANS: As I said, my Lady, I am going to move on to the topic of the tweets, largely tweets and media material which my client claims to be harassment of him. Mr Miller, this period starts, as you know, in late July 2018. I am going to begin asking you about that early period and then move through more or less chronologically. The early period being the period when you first start sending tweets to Mr Turner, okay? A. When I responded to his defeat about LD-50 -Q. We will come to that. But before I start, I must make clear again that based on the witness statement that you served you have not given any evidence to explain why you sent most of the specific or individual tweets Page 142 Page 144 36 (Pages 141 to 144) Epiq Europe Ltd (+44)207 4041400 www.epiqglobal.com casemanagers@epiqglobal.com Lower Ground, 20 Furnival Street London, EC4A 1JS
1 Miller031023Nick Land / text
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Day 1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Miller & Power v Turner that the Defendant complains about, for the entire period covered; you understand? A. Not really, no. I believe I actually have explained why I responded to the Defendant and what my motives were. Q. You have explained, yes, you have explained in what I would describe as a general way, you haven't addressed specific tweets other than a handful here or there but that's something that is a matter for you but it means that I will have to ask you questions off the documents which is a fairly forensic process because these are Twitter threads. So, I am going to have to go through it and I hope keep it as unpainful as possible for everybody concerned, including me. So, where we need to start is in bundle 2, tab 41, page 1025. A. I don't know which -Q. It is bundle 2, tab 41, page 1025. At the top it should say, "26-27 July 2018: Replies to @MatthausAnsatz by Defendant." Do you have that? A. Uh-huh, yes. Q. I just want to use this to explain to you 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 tweet I made reference to LD-50 as an example of Fascist tendencies within the art world and referred to the gallery as, "an explicitly alt-right (AKA alt-Nazi) gallery." So, that is the tweet that he sends which then prompts many responses. You see one here from dark mutualist, essentially the same person he has been talking to before, cyborg_nomade, who says "Lol, seriously? Shut down LD-50 was a moral panic beyond anything I could imagine plausible at the time." And so forth. You enter the fray at this point, correct? A. I think so, yes. Q. I don't expect you to remember the exact sequencing but what we see below this is a whole series of deleted tweets, those tweets were the tweets that you targeted at the Defendant in response to his LD-50 tweet, correct? A. No, I don't believe that's the correct description. Q. Those tweets came from you, can we establish that? A. I don't believe that -- yes, they came, Page 145 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 3 October 2023 Page 147 and to my Lady how this began because it is tweets you need to understand in sequence. These pages are ones where you read them from the top down because they are screenshots of the threads. In the middle there is a photograph of some people dancing and that is part of a tweet from Mr Turner, July 27th. He is attaching a link there to an article that he wrote on meta modernism, see? That then resulted in he and one other person in particular, but probably others, class warmonger, engaging in a Twitter discussion. Fine. If you turn over the page you will see it goes on for a few pages, to 1028, still July 27th, we don't need to worry about the content. Page 1029, what is missing, which is critical now in this chronology, still 27th of July, is that my client, Mr Turner, at this point, at the start of the top of page 1029 sends his tweet about the LD-50 Gallery and that tweet no longer exists because he deleted it after the pile-on that he experienced. But he describes it in his witness statement at paragraph 97 and I will tell you what it said. He said, "In my 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 some of them at least did. I don't know if all of them did. I don't agree that my responses were me targeting the Defendant, I was responding to his claim, which incidentally he previously denied in his pleadings, that he had said that LD-50 was Nazi space, and it was not a Nazi space and I felt compelled to respond to his claim that it was because that is an extremely hyperbolic claim with -Q. Sorry -A. -- with extremely damaging consequences for anybody who is, who is labelled in this way. Q. Well, we will look at hyperbole in a moment. But, just going back to Mr Turner's witness statement because obviously your tweets were deleted by him so we don't know what is said exactly but his recollection as recorded in paragraph 98 of his statement. He says, "I immediately began to be the subject of several tweets (referred to online as a 'pile-on') from people who appeared to be supporters of LD50. A dozen or so of these tweets (which were subsequently deleted by Mr Miller before I could preserve Page 146 Page 148 37 (Pages 145 to 148) Epiq Europe Ltd (+44)207 4041400 www.epiqglobal.com casemanagers@epiqglobal.com Lower Ground, 20 Furnival Street London, EC4A 1JS
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Day 1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Miller & Power v Turner them) came from (the handle) @dcxtv, an anonymous account." He explains that he didn't know who you were or that that was your account at that point. Now, his recollection, going back to his paragraph 98, is that the gist of those messages from you, as far as he can remember, was broadly consistent with your later attacks, which we do have reference there, and we will come to. He describes them as abusive and offensive insults which claimed that I was a deranged subhuman and a normal fascist, or words to that effect. Do you accept that that was the tenor of the tweets -A. No, that is a completely false statement. My initial responses to the Defendant were polite. I asked him whether he had ever visited the gallery before, I sent him the article that I had written about the gallery, this contained also the same handle of my Twitter account and my name. I was not impolite to him, I did not insult him, my initial responses to him were in no way abusive. I asked him whether he had ever attended the gallery. He admitted that he 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 fact because he wanted to say that my reaction to him was in response to him nearly claiming, this is in the Defendant's solicitor's pleadings, nearly claiming that LD-50 was an alt-right space, that's not what he said, he said it was a Nazi space. Q. Do you agree that his message about LD-50 didn't say anything about you? A. Yes, I do agree. Q. If you look at the bottom of page 1029, you see Mr Turner's reaction to all your tweets. It says, ""My god, you finally triggered me." That is at 2.34 pm. Could you please take up bundle 5 again, tab 131, which is the WhatsApp messages. Page 3691? A. What is the tab? Q. 131. A. Yes, and what is the page? Q. 3691, the first page. A. Yes. Q. Now, at the top you will see it is 27th of July 2018, which is the same date as these tweets and it is 13:50 and Ms Power says to you, "Luke Turner currently Page 149 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 3 October 2023 Page 151 hadn't and I said that I think that therefore he should withdraw his allegation because it is an extremely serious allegation. It was obvious that the Defendant had no basis for making this claim, as he himself admitted. He said he looked at the website and this was enough for him to form his opinion. Q. Do you -A. Now, the website of the gallery actually contained no indication that it was a Neo-Nazi gallery. At the time the website contained only a list of its previous exhibitions. So I knew that the Defendant's statement was extremely, well, in my opinion it was ill-founded and it was hyperbolic and it was, itself, libelous and I thought that it was very disappointing when he conceded that he hadn't visited the gallery, that he was nonetheless still unwilling to withdraw his accusation that it was a Nazi gallery. The Defendant subsequently denied ever claiming that LD-50 was a Nazi gallery. I think that he didn't understand that actually I had, for whatever reason, a copy of the tweet in which he did, he attempted to conceal that 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 discussing LD-50 stupidly on that twitter btw." You say, "Thanks for the heads up." So, is that what made you get involved, that tip off? A. Yes, well I think I wouldn't have seen it otherwise. Q. Then, by the first hole punch, at 14:41, which is seven minutes after Mr Turner tweeted, "My god, you finally triggered me" Ms Power said to you, "Loving your exchange with LT." Do you see that? A. Uh-huh. Q. So, she was aware at that point, when they have been deleted, but she was aware that you had sent all these tweets to Mr Turner, correct? A. She was aware that I had sent a series of totally cool tweets to Mr Turner, in which I had said that because he didn't actually know anything about the topic he should refrain from accusing things or people of being Nazis because that's a very serious allegation. Q. Did you know, at this point, anything about Mr Turner? Page 150 Page 152 38 (Pages 149 to 152) Epiq Europe Ltd (+44)207 4041400 www.epiqglobal.com casemanagers@epiqglobal.com Lower Ground, 20 Furnival Street London, EC4A 1JS
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Day 1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Miller & Power v Turner A. No. Q. Did you know about his, He Will Not Divide Us artwork? A. I knew about the He Will Not Divide Us project, I knew about it because of its association with Shia LaBoeuf, I didn't know anything about Mr Turner. Q. You didn't Google him before you started sending messages? A. No. Q. Can you please go to, I am afraid it is jumping about a bit. Bundle 1, tab 8, 155, which is in annex 2, I think, to the defence. A. Yes. Q. Now this is a tweet, I think we very briefly looked at this morning, from ParallaxOpticswho joins the Twitter argument that has been going on, 27th of July. I don't think the timings here are necessarily always reliable because of the international settings but this is after the bombardment by you that we have just been looking at? A. I don't agree that this is a bombardment by me, this was me responding to claims 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. If you turn to 156, please, the next page? A. Uh-huh. Q. Now, this is a Twitter report of your, some of your deleted tweets after Mr Turner had reported you to Twitter -A. Mm-hmm. Q. -- for your hateful conduct, and you have been suspended, you were then suspended for 24 hours? A. Mm-hmm. Q. This is the only record that survives of some of the tweets that you sent in those first couple of days, as I understand it. Certainly as far on the -- well, it is in fact not the only record, but one of the few. We have three there where you say, "Another deleted tweet by pathologically dishonest careerist retard shitbag @Luke_Turner." You say, "@Luke_Turner, I gave you an exit, and you choose not to take it. Why did you delete your tweets, cocksucker? Dumb-as-fuck dishonest propaganda hack cocksucker @Luke_Turner deleted these tweets - how about an apology and admission you were wrong?" Now, you say in your witness Page 153 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 3 October 2023 Page 155 being made by the Defendant, which were extremely serious, that LD-50 was a Nazi gallery. Q. You will see that it says on this page, it is a reply to you, replying to dcxtv and tagging in Luke turner himself. Luke_Turner is a, '50 Stalins!!!' Variety, 'radical' artists ... " And so forth. "Engagement beyond ad hominem - he is probably a homosexual - is a misguided waste of time." Below that, in the likes, there is a like from you; correct? A. Yes. Q. Why did you like it? A. Because I agree that actually engagement with him was probably a waste of time. Q. Did you think that the language that ParallaxOpticshad used was offensive? A. I mean I thought it was just, whatever, like he's probably, I don't care about this, it's not interesting to me. I mean, I don't know -- he makes a number of statements here, he draws attention to the fact that Mr Turner is a far-left extremist actually and I think the main point of this tweet was, it is worthless to engage with him. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 statement that you were annoyed that he had deleted his tweet, correct? A. I was annoyed because what subsequently happened here was the Defendant deleted his initial tweet, and he also deleted his admission that he had never visited the gallery. He issued a new tweet, in which he said that he had been attacked, for no reason, out of the blue by LD-50 supporting accelerationists and this was a misrepresentation of what had happened, which the Defendant actually persisted with for quite a long period of time. It also stated in his report that he eventually made to the police. Now, the Defendant reported these tweets. I recognise these tweets are intemperate and insulting. I was angry myself. The reason why I was angry is because I was myself triggered actually because ever since I had protested against the anti-fascist activists I had been targeted by them, I had been threatened by them. An Israeli book shop in which I was supposed to speak had been targeted and closed down, an anti-fascist activist named Justin Katko, who Page 154 Page 156 39 (Pages 153 to 156) Epiq Europe Ltd (+44)207 4041400 www.epiqglobal.com casemanagers@epiqglobal.com Lower Ground, 20 Furnival Street London, EC4A 1JS
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Day 1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Miller & Power v Turner threatened to cut out my tongue to prevent me from speaking so I was very familiar with the, let's say, anti-fascist position on these matters which Mr Turner, it seemed to me, was rehearsing and this was why I became so angry so quickly. I thought that what he was doing was extremely disingenuous and I certainly regret my statements. I think the fact that that he did report them already gives you an indication that my previous tweets were not of this nature, had they been he would have reported those tweets. I think he would have reported them immediately. The Defendant has no compunction about issuing reports. He has been doing that for a long period of time and has continued do it throughout the duration of these proceedings. Q. If you, please, go to bundle 2 now, tab 40. It is page 862. This is a tweet, 28th of July 9.43 by you replying to Mr Turner, Mr Turner having said to you, "The only person you're hammering ...", this is about your previous tweets "... is yourself. Your abusive homophobic and ableist tweets have been reported." You say, "He just can't tell 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Well, because I had been somehow suspended and it was like I was sort of rising from the dead in a way. But I think that this statement, or rather this image, you know, also was somehow a recognition of the, somehow unconscious or coordinated activity that was now proceeding basically also on my behalf because I had been triggered by the Defendant too. Q. Can we go to the next tab, 41. 1033. Again, just to give some of the chronology here. 1033 is still 28th of July and it is Mr Turner saying, "So, weirdly in the past 24 hours I started getting targeted by a bunch of LD-50 Gallery - supporting far-right accelerationists on here. (Charming)." Did you see that at the time, do you remember? A. I do remember seeing that and I remember thinking that this was a complete misrepresentation of what had actually happened. He says, weirdly I started getting targeted. He had made a statement about LD-50 and people had responded to it. He claimed LD-50 was a Nazi gallery. This is a statement that people responded to. He is not Page 157 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 3 October 2023 Page 159 the truth." What did that mean? A. I don't think my tweets to him were homophobic and ableist, to be frank, because as far as I understood the Defendant is not gay. I appreciate that I am using the term cocksucker, which if I did direct it to a gay person could be construed as anti -- I'm sorry, as homophobic. But I wasn't responding to the Defendant because I thought he was gay and I don't know that the word, "retard" is actually ableist either. My tweets were insulting but they were not politically motivated in having an ideological component in the way that he said that they did, I thought that was also a dishonest statement. Q. At this point you changed your profile picture, didn't you, to the one that you see, it is actually on the previous page, bizarrely, under the, "Violating Our Rules", sorry, the page we looked at before, 156. So you change it to the picture, an image of a zombie, is that right? A. Yes. Q. What was the reason for that? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 worriedly getting targeted, people are responding to his statements. Q. There is no reference to you in his tweet, is there? A. No, he is referring to everybody who is responding to him. Q. I don't think I need to take it up, turn it up. But you will know from this morning that on this date, 27th of July -- 28th of July, you and Ms Power had gone out for an evening with Mr Stokoe and his girlfriend, remember? A. I don't really remember but ... Q. On the 20 -- there is a record of you on the 29th in the morning discussing the fact that you had been on the evening before. When you went out with them on the evening of the 28th of July, Mr Stokoe and his girlfriend, did you discuss the Defendant? A. No, I don't think so. Q. And so what we are going to see after this is a whole sequence of Tweets which show that, despite having been suspended by Twitter for hateful conduct, what you did was double down by accelerating your Page 158 Page 160 40 (Pages 157 to 160) Epiq Europe Ltd (+44)207 4041400 www.epiqglobal.com casemanagers@epiqglobal.com Lower Ground, 20 Furnival Street London, EC4A 1JS
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Day 1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Miller & Power v Turner targeting of Mr Turner, correct? A. This is not correct. In fact, what happened when I was suspended was another person joined this thread, this is Deanna Havas, and it was the defendant who escalated it and he began to target her. This is what happened next. Q. Can we go to 1035 of the same tab, please? You will see that this is the 30th of July, you will see at the top there are three Tweets there which are deleted ones from you and then you will see an engagement between Mr Turner and somebody else who had been taking up your position, by the look of it, and then at the bottom Mr Turner says, "DCXTV [which is obviously a reference to your account] is posting this in response to their account getting temporarily suspended due to a series of wholly unprovoked abusive, bigoted attacks on me. You may want to think how retweeting/replying strongly implies enthusiasm for them calling me a 'fascist'. Not a good look." Now, that was the defendant's response at that point to your previous targeting of him, correct? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 coward. Luke Turner simply does not know when to quit." That was within 10 minutes of his message. What was it with the aggressive language? A. Well, first of all, his statement is untrue because he's claiming that he has been targeted with unprovoked abuse. This is not true. The defendant provoked this exchange. The defendant is claiming LD50 is a Nazi gallery. I defended the Gallery on the basis that it wasn't a Nazi gallery. As a consequence of defending it, I was really very viciously abused for an extremely long period of time by people who actually subsequently became very close associates of the defendant, specifically an individual named Andrew Osborne. I understood that what the defendant was doing corresponded to the behaviour of those activists. So, as I said, I was triggered by this. I think I was actually, looking back, somewhat traumatized by my experiences at the hands of these activists. It's very traumatizing to be called a Nazi by a mob of people screaming at you and threatening to beat you up. This is Page 161 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 3 October 2023 Page 163 A. No, I don't agree I was targeting the defendant. I was responding to the defendant's claim, which was baseless, that LD50 was a Nazi gallery. Now, the defendant says here I was temporarily suspended due to a series of wholly unprovoked abusive, bigoted attacks on me. My responses to his claim were not unprovoked. It's a very provocative statement to claim that someone is a Nazi, especially if you're an anti-fascist activist, because the claim carries with it an implicit threat of violence. The claim is that Nazis can and should be physically attacked. This is the position of the defendant and his associates, so ... Q. Correct me if I am wrong, but out of interest, you are not suing in this action any more, are you, on the allegation that came later of you being a Neo-Nazi? A. No, we're not suing on this basis. Q. Could you go over to 1036? 30th of July, still, this is your reply to Mr Turner's, I would suggest, moderate explanation, and you say, "Pathological liar and spineless 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 what happened in February 2017, this is what happened to me. Q. But you are not suing on that allegation. A. I'm explaining why my statements were intemperate, because I had seen this behaviour before. It was the same kind of provocative issuing of highly inflammatory claims and anybody objecting to it then becomes the subsequent target, and this is the implicit threat that the defendant makes to Eli Schiff. He says, "Not a good look." It's not a good look to defend me, basically. And the defendant, actually, has quite consistently then actually himself targeted anybody defending my position, and the second claimant is the best example of that. Q. But, you see, what I do not understand is, the way that Twitter works is that you could not possibly know all the targeting that he was receiving, so why did you put yourself in a position to judge whether he was lying about it? How did you know? A. Well, he is lying about people targeting him unprovoked, with respect to this particular exchange. He has stated at the Page 162 Page 164 41 (Pages 161 to 164) Epiq Europe Ltd (+44)207 4041400 www.epiqglobal.com casemanagers@epiqglobal.com Lower Ground, 20 Furnival Street London, EC4A 1JS
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Day 1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Miller & Power v Turner beginning of the exchange that LD50 is a Nazi gallery. This is the provocation I am responding to. He says here, "DCXTV is posting this in response to unprovoked attacks." My responses to his claim were not unprovoked. That is an untrue statement and that didn't make me angry. Q. But you believe in free speech, Mr Miller, do you not? A. Yes, but I don't believe that you can tell lies about people. Q. Again for the chronology, after Mr Turner's response there at the bottom, he did not engage directly with you or with Deanna Havas until early September, correct? A. That is not correct. Q. Well, your counsel will be able to correct that if I am wrong. A. Subsequently, what happened, I believe on July 29th, is Deanna Havas responded to the defendant and she said something along the lines of, "What happened to HWNDU?", which was his project, "He Will Not Divide Us", he said, "It's still going strong and resisting the kind of bigoted, unprovoked 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. And you followed her on Twitter and she followed you on Twitter. A. Yes. Q. This exchange here I would just like to take you through. So, it starts - again, this is a different thread now. It is the one from you saying to Luke Turner, "A pathological liar and spineless cowards." Now, your friend, Deanna Havas, pops up and says, "Laugh out loud. Whatever happened to HNDU ..." and Mr Turner, in what I would suggest is a very measured way, just says, "Hi Deanna. It's still going strong and resisting the normalization of the kind of bigoted behaviour dcxtv has been targeting me with on here." What is wrong with that? A. I have not been targeted with bigoted behaviour. I'm responding to his claim that LD50 is a Nazi gallery. I am responding intemperately. I do reject, rather, I do regret the language that I used, but there was no way in which my language was bigoted. It was merely angry. Q. And then someone else joins in called BasedBrooklyn - that was another account Page 165 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 3 October 2023 Page 167 abusive attacks ..." that I'm targeting him with. Somebody posted a picture of a cartoon frog. Deanna Havas Liked that image and as a result the defendant began to target Deanna Havas and in fact, actually, destroyed Deanna Havas' life and her career, because he was so incensed by her Liking this image and by being laughed at, and this is really also what then subsequently ... Q. On to page 1039, and we will see a bit of that. To be fair to you, the defence that you have provided in your witness statement for what you did is almost exclusively about, apparently, defending Miss Havas. A. That's correct. Q. So, let's see the sorts of things that she was saying. A. Which page is this? Q. 1039 of the same tab. She is, I think, an American artist, is she? She may be based in Britain. A. She's an American artist, she is halfJewish, her father was Jewish, she's the child of two refugees from Communism, she supported Trump, she is a funny girl. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 you followed, was it not? A. I don't remember, to be honest, but maybe I subsequently began to follow him. Q. And BasedBrooklyn deploys this Pepe the Frog depiction of a group running away with a He Will Not Divide us flag - you see that? A. Yes. Q. Which you keep insisting on calling a cartoon frog, but I think you have already accepted that, at least in some quarters, Pepe the Frog is regarded as an Alt-Right symbol, correct? A. In some quarters, that's true, yes. Q. And then you see the Tweet below is Mr Turner, again, totally temperate language, back to Deanna Havas, "Curious why you liked this", because she Liked that Pepe the Frog tweet. Mr Turner says, "Curious why you liked this. Perhaps you're unaware of the reality of the Neo-Nazi Traditionalist Worker Party being responsible for this?" She says, "Because it was funny" and he says, "But this is a depiction of an antiSemitic campaign and actual crimes Page 166 Page 168 42 (Pages 165 to 168) Epiq Europe Ltd (+44)207 4041400 www.epiqglobal.com casemanagers@epiqglobal.com Lower Ground, 20 Furnival Street London, EC4A 1JS
1 Miller031023Nick Land / text
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Day 1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Miller & Power v Turner committed against us by members of a violent, self-described Neo-Nazi group, the TWP. Is this genuinely funny to you?" And she says, "Chill out, bro. It was just a meme." Now, did you see this thread? A. Yes. Q. Did you not then go and look up Mr Turner and look into what he was saying? A. I looked at ... Q. About what had happened? A. I think I probably did click on his link. It was really quite confusing, to be honest. It consists of an assemblage of images and chat logs that he somehow acquired, I don't know how, in order to say something about these particular people, but the assertion that the image is the depiction of an anti-Semitic campaign by members of a Neo-Nazi group, again does not seem to be true. The image, as I understand it, refers to this response to his project, specifically this phase of the project that began after the initial phase was ended by the museum, because it was provoking violent reactions, in which internet users managed to track down this flag using a 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 form, but the response to the project itself was not motivated by these things, it was motivated by some kind of relationship that he established with the internet, and the internet reacted to him. Now, the defendant has produced a number of statements about what happened in terms of his project, in terms of He Will Not Divide Us, these statements do not seem to be borne out by third party or objective accounts of what had happened, and I think that what happens next in this exchange is really illustrative of the extremely vindictive nature of the defendant with respect to Deanna Havas because it was clear from what she says here that she meant no harm by what she was saying. You know, I think that she was also going on the mainstream media accounts of what happened with respect to this project. She doesn't want any trouble from the defendant, but what the defendant does next is, he produces this page about Deanna Havas which is designed to smear her, despite the fact that she is herself from a Jewish background, as an anti-Semitic Nazi, Page 169 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 3 October 2023 Page 171 complex series of techniques, including triangulating the jet trails of airplanes and so forth - this featured dozens of people, it was not the work of the Neo-Nazi Traditionalist Worker Party. The Traditionalist Worker Party ... Q. I am sorry, can I stop you? So, you did look it up, then, did you, you did look at what had happened? A. I did subsequently look at what had happened, and what I understood was that his description of it was not accurate or honest. Q. And you were to be the judge of that, were you? A. I have an opinion on this matter and I was looking at mainstream media accounts. The Traditionalist Worker Party are never mentioned in response as far as I know, except by the defendant, in response to his project. His project was in a certain way extremely successful as a public art project, it produced a very significant reaction from the internet. The response to the project, as I understand it, may have involved people who are Nazis or crazy or anti-Semitic in some 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 specifically in order to destroy her career, and that's what he does a day later. Q. We will come to that in a minute because it needs to be put much more accurately than you have done. If you could turn over to 1040, please? This is a continuation of the thread we have just been looking at between Mr Turner and Havas, which you were aware of and no doubt followed, and it is basically Mr Turner carrying on explaining what happened and Miss Havas basically being, I think, even putting it neutrally, quite abusive back, saying, "Don't tell me what to rethink, but do have a nice day ..." He says, "Not good enough." He says, "You're complicit in anti-Semitic violence ... whether you're Jewish or not." She says, "Do spare me the 'woke' lingo and do me a favour ..." and so forth. She, of course, also refers to it as a cartoon, a phrase that you both seem to think is appropriate. And then at the bottom, Mr Turner says, "It's a bit harder when you have to have security because you have violent Neo-Nazi groups posing credible threats to your safety on a daily basis across several Page 170 Page 172 43 (Pages 169 to 172) Epiq Europe Ltd (+44)207 4041400 www.epiqglobal.com casemanagers@epiqglobal.com Lower Ground, 20 Furnival Street London, EC4A 1JS
1 Miller031023Nick Land / text
P. 44
Day 1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Miller & Power v Turner countries. But, yeah: no, not good enough." Now, did you still think that you were the one in a position to know if he was telling the truth about his experience? A. I think that, based on my experience of what he had said, with respect to LD50, about it being the Nazi gallery, a claim that he had made with very little basis, and furthermore his claims that I had attacked him unprovoked and, furthermore, his claims that my comments to him were bigoted comments, I had a serious basis for doubting the credibility of the defendant by this point. Now, you say that Deanna Havas' comments were clearly abusive. I think she says, "Don't tell me what to think. Have a nice day." I don't think that's a clearly abusive statement. I think that's a statement which says, "Okay, I don't want to get involved in this, I didn't mean any harm by it, please leave me alone" and this is in fact what Deanna Havas will then continue to say for the subsequent days. The defendant threatens Deanna Havas. He says her response is not good enough, he says that her 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 We haven't really seen evidence of a murder plot in Finland, so ... Q. Can we just move on because we are going to be here for all week if we ... A. Well, fair enough, but ... Q. ... examine every thread at this length. A. Well, as you say, we should be forensic. Q. I will show you plenty of examples of Miss Havas being intemperate. Can you go to tab 40 please, page 866? MRS JUSTICE COLLINS RICE: If we are about to leave this thread, I would find it quite helpful to have a rather clearer reproduction of this picture on page 1039. MS EVANS: 1039? MRS JUSTICE COLLINS RICE: Yes, because it is quite hard to make out. MS EVANS: Yes, I am sure we can do that. You mean the one with Pepe the Frog? MRS JUSTICE COLLINS RICE: That is the one I mean. MS EVANS: Yes, I think these have been reproduced so many times ... MRS JUSTICE COLLINS RICE: Hard to see. Page 173 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 3 October 2023 Page 175 Liking these cartoon frogs - and, I'm sorry, but they are cartoon frogs, that is in the end what they are - makes her complicit in antiSemitic violence. Now, this is an extraordinary statement. She has Liked an image, basically, unthinkingly, which, as far as I understand, is referring to a very big response to the He Will Not Divide Us project, which is not reported as being antiSemitic in any mainstream account, which is not reported as being the work of Neo-Nazi Traditionalist Worker Group in any mainstream account. She just did that, she just wants to go about her day. This is not enough for the defendant. He begins to threaten her, he says he has to have security because he has credible threats to his safety and these statements, also we have asked for corroborating evidence and they have not been provided, by the way, in the context of our long preparation for this trial. I don't know what credible threats to the defendant's safety he has actually received. He has referred to, and you also referred to in your opening statement, a murder plot in Finland. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MS EVANS: Are there any others at the moment? If you can just let us know if there are any others? MRS JUSTICE COLLINS RICE: I will do. Thank you. MS EVANS: We will do that overnight. MRS JUSTICE COLLINS RICE: Thank you. MS EVANS: Moving on, I am afraid, through this riveting bundle of Tags and Tweets, tab 40, page 866. Same day, 30th July. Mr Miller, I do not want to stop you from saying what you want to, but I am going to try and speed up, otherwise we will not meet our timetable, and that requires you to keep your answers shorter, too, if that is all right. A. I will endeavour to do so. Q. Here, we start with this BasedBrooklyn account again, and it says, "Luke Turner is a Nazi shit." Do you see that? A. Um hum. Q. You then join in below and you say that, "Luke Turner is, specifically, a Normie Fascist. An institutionally-supported Page 174 Page 176 44 (Pages 173 to 176) Epiq Europe Ltd (+44)207 4041400 www.epiqglobal.com casemanagers@epiqglobal.com Lower Ground, 20 Furnival Street London, EC4A 1JS
1 Miller031023Nick Land / text
P. 45
Day 1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Miller & Power v Turner propagandist, his limited intelligence and narrow ethical horizon is circumscribed by a conformist-narcissistic ideology that prevents him from participating in any truth ..." and so forth, and it has been Liked, you see below, by your friend, Miss Havas, and you have tagged Mr Turner, so ... A. No, I simply respond to the thread. Q. Yes, that means he gets it, does it not? A. But I'm responding to the thread, I'm not specifically tagging him. Q. Yes, but, again, this is offensive, completely gratuitous language, is it not? A. Well, to be honest, I'm also trying to move away from the Nazi statement which I think is in fact also unfair. I don't want to start calling people Nazis, not even the defendant, so I'm saying this about him instead. Is this language insulting? Yes, it is insulting. I don't deny I insulted the defendant. He is at this point accusing Deanna Havas of being complicit in antiSemitic crimes against him because she Liked this image. Q. In an endeavour to speed this up, let me 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 are wrong to think that you can justify these Tweets by some all-knowing position at the time about the truth. A. I'm not claiming to possess such a position. Q. Fine. A. I am saying that the defendant's exchange with me had to me already revealed that he was not credible in the statements he was making because he had mischaracterised our initial exchange. I thought that his statements with respect to Deanna Havas were clearly hyperbolic and unbelievably exaggerated, because he is accusing her of being complicit in activists crimes against him, based on Liking a Tweet that had no activists content. There's nothing in the image that she Liked that makes any reference to Jewishness or otherwise. Q. Let's move on and see some other examples, then. If you can go to tab 41, 1041? Still on the 30th of July. There is Miss Havas at the top, saying, "Some OLDER WHITE CIS HET male from CENTRAL SAINT MARTINS just called Page 177 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 3 October 2023 Page 179 break this down, so that you understand and so I do not have to keep putting it to you for every Tweet, okay? Your complaint is that you think that Mr Turner was lying. My response to that on behalf of Mr Turner is that you were not in a position to judge that. Your other complaint is that he was expressing an opinion ultimately, at the start of this, about LD50, which was false/bad, whatever ultimately you want to call it, but it was an opinion, something that you, I think, you agree, value as part of the freedom of speech. Correct? A. Um. Q. And that includes a description of NeoNazi or Alt-Nazi. Now, I am also going to have to keep putting to you at every Tweet that every time you fight back and explain why you have said it, I will be saying to you, "But, what about this ..." - so, can we take it as a given that every time you defend one like that - and, incidentally, as I said at the beginning, you have not done this in your witness statement in respect of the Tweets, save for a few - I am putting to you that you 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 me PRIVILEGED." That was a response to Mr Turner, who was a student at Saint Martins. He then says, "No, I said it was your privilege for evidently never having had your life put in direct danger by anti-Semites ..." and so forth. So, he is making the same point, which is that it is his experience and story that he has experienced anti-Semitic abuse, and that is why he is explaining to her that that is why he takes the position he does. A. You say he's explaining. I think he is claiming; he is claiming that his life has been put in direct danger. I don't see any evidence that his life has been ... Q. That is his experience. A. That's a claim that he is making. He also claims in this Tweet that she is laughing at depictions of anti-Semitic abuse. I don't agree that the image that she Liked is ... Q. Could you go to tab 40? A. I'm sorry, may I finish? MR WALKER: I am so sorry but this has happened repeatedly, so I rise to my feet reluctantly, but where my learned friend has gone to the trouble of asking a question, I Page 178 Page 180 45 (Pages 177 to 180) Epiq Europe Ltd (+44)207 4041400 www.epiqglobal.com casemanagers@epiqglobal.com Lower Ground, 20 Furnival Street London, EC4A 1JS
1 Miller031023Nick Land / text
P. 46
Day 1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Miller & Power v Turner wonder whether we could hear the answer? If they are long, that is fine, but he has been repeatedly cut off today. MRS JUSTICE COLLINS RICE: Well, I am paying extremely close attention to this witness and I am looking forward to reading the transcript of his evidence also. I might have intervened myself before now but we do have to make progress. MR WALKER: I understand that but it has got to the point where I feel as though I have to express my concern. MS EVANS: I think we were on - yes, could we go to tab 40, 868? I will certainly try not to cut you off. It is only fair to give you time to read it. Now, this is Miss Havas at the top. She is responding, is she not, to a message from Oscillating? And it seems clear from this exchange that she believes that this was operated by Mr Turner, correct? A. It's a hypothesis that we discuss. Q. Because of your response below as well? A. It seemed to be an account which was almost exclusively interested in the defendant's art projects and, indeed, 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. Could we go to the next page please, 867? This is a different thread, it starts with you and the one we have already seen about Mr Turner being a Normie Fascist and so forth, and then we see the account, Depopulator, one which we have looked at, and the Onehundredpercenteuropean joins in as one of your followers and then at the bottom ... A. Well, he was one of Deanna Havas' followers, actually. Q. One of her's as well. If you look at the bottom, at what you then say: "A low pressure area, a sucking emptiness. He will be portentously anonymous, faceless, colourless. He will - probably - be born with smooth disks of skin instead of eyes. He always knows where it is going like a virus knows. He doesn't need eyes." What did that - first of all, that was you directing that at Mr Turner, was it not? A. Well, not precisely, no. This is actually a quote from William Burrows, from his novel Naked Lunch, he describes ... Q. But why was it in this thread? Page 181 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 3 October 2023 Page 183 replicated his language with respect to that in a significant way, and it was accusing her of being an anti-Semite following his claims. Q. She just says, "Go fuck yourself", but not just that, she puts in a Swastika, a Star of David, the Hammer and Sickle and all the rest of it. A. Yes, it's a series of symbols. Q. And that was directed at somebody that it would appear that she, and I think we agree, you, purported to - it is not very pleasant, though, is it? A. Well, our exchange with respect to this point actually occurs subsequent to her statement, so I don't know who she thought that was at this time. It's not very pleasant to be called an anti-Semite. To be frank, I would prefer somebody told me to go fuck myself than somebody called me an antiSemite. I think anti-Semite is a much more vicious charge than simply saying, "Fuck you" to somebody, and I think Deanna Havas didn't appreciate being called an anti-Semite, not least because she is herself at least partially Jewish. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. It was a response to this thread, it was describing the figure of the Sender as characterised by William Burrows. The Senders are one of four political parties of Interzone, they are characterised by a kind of endless broadcast, not unlike the defendant, but I'm not specifically accusing him of anything in this context. He's not named and I'm mentioning William Burrows' views of this topic that we're discussing. MR WALKER: The difficulty with the interjection is that the witness was just in the middle of an answer which quoted a piece of art called Naked Lunch, then he was cut across. I am seeking to assist the court and I assume the answers that he gives the court are going to be of assistance, and I wonder whether he could be asked again, "What do you mean by - what was the reference to Naked Lunch?" before he was cut across? MRS JUSTICE COLLINS RICE: I am interested in the direction of questioning, which is seeking to probe the extent to which this is directed at the defendant. There must be a concise way of answering that question. Page 182 Page 184 46 (Pages 181 to 184) Epiq Europe Ltd (+44)207 4041400 www.epiqglobal.com casemanagers@epiqglobal.com Lower Ground, 20 Furnival Street London, EC4A 1JS
1 Miller031023Nick Land / text
P. 47
Day 1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Miller & Power v Turner MR WALKER: In my submission, part of the problem is, although it was changed in the last question, some of these questions are open and they invite a descriptive answer. There was - my ears perked up because I am familiar with the piece of work. When it was cut across, this is a stressful situation, in my submission, for the witness and he has been cut across and that has happened all day. MRS JUSTICE COLLINS RICE: Well, let us just pause and collect ourselves and ask the open question again and I will listen attentively to the answer, but may I encourage you to keep it as concise and directed to the question as possible? MR WALKER: Thank you. MS EVANS: I will ask the question again that, as my Lady says, matters most, because I think you did answer it but you veered off a bit: was this targeted at Mr Turner? It may be Mr Turner among others, but was it targeted including to Mr Turner? A. No, I don't think so. It attempted to describe a kind of type. It doesn't refer specifically to him. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 from the Naked Lunch is, nevertheless, of a theme, is it not, in respect of the reference to, " ... dead jude eyes ..." and, "smooth disks of skin ..." and so forth, with what I suggest is a form of anti-Semitic description which I have just shown you on the 8chan message? A. Well, there's a critical difference between these comments, which is that, whereas the comment on 8chan specifically makes antiSemitic statements, my comment does not. My comment refers to a mode of being which has no ethnic characteristics at all. It in fact is some sort of non-human phenomena concerning the politics of communication. Q. Can we go on to - actually, staying in bundle 5, at 141, page 3913? This is within the archive that Mr Turner created of the various Tweets and messages from Miss Havas to him which you mentioned. Do you recognise it? A. Um hum. Q. And I just wanted to highlight and ask for your reaction to some of the images in it which Mr Turner has included because he regarded them as being anti-Semitic, Neo- Page 185 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 3 October 2023 Page 187 Q. Could we look at a reference, I am sorry, in a different bundle, bundle 5, tab 124, page 3654? I think it is just a single page. Now, this is from a Tweet, I think, but, anyway, it is on the 8chan platform, which I suggest is popular with Alt-Right groups. It is the 17th of December 2017. The reason I am showing it to you is because of the similarity in the language, I would suggest. So, you will see they targeted this, whoever sent this and I am not saying it is you, at Mr Turner: "You will never ever be white, Luke. Never. Look in the mirror at your dead jude eyes. Notice the parlor of your sunken cheeks and hollow eye sockets. I laugh at your rat heeb face from across the planet." If we go back in the other bundle, I am afraid, to your message that we were just looking at ... MRS JUSTICE COLLINS RICE: Sorry, the reference again, please? MS EVANS: Sorry, it is bundle 2, tab 40 and it is 867. MRS JUSTICE COLLINS RICE: Thank you. MS EVANS: The choice of your quote there 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Nazi and so forth. You will see on 3913 there is an image of somebody using a paint brush to create what must be a Hitler moustache. Below that, you see there is the image of, I do not know if it is a magazine cover, but anyway it is a mocked up image of Hitler doing a Hitler salute, which you will notice has been Liked by Miss Havas. And then if you go over the page there is Pepe the Frog again, if you go on to 3916, there is the, "Go fuck yourself" with a Swastika which has been included, and then a couple below that, a reference to, "You're a socialist from Goldsmiths. Laugh out loud. Kill yourself." And then there is a reference to her issuing, "A Fatwa against all socialists from Goldsmiths or Central Saint Martins ..." Central Saint Martins already having been marked by her as where Mr Turner had been. You see that? A. Yes. Q. And then on the next page, 3917, he includes a Tweet from her which has included an image of Mr Turner's face, and at the bottom of that thread the quote, "He Page 186 Page 188 47 (Pages 185 to 188) Epiq Europe Ltd (+44)207 4041400 www.epiqglobal.com casemanagers@epiqglobal.com Lower Ground, 20 Furnival Street London, EC4A 1JS
1 Miller031023Nick Land / text
P. 48
Day 1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Miller & Power v Turner has dead beady eyes. So scary." So, again, I suggest the motif of the dark, sinister eyes, which we suggest is used in an anti-Semitic way on various Alt-Right message boards. Do you remember seeing some of these images when Miss Havas was producing them? A. No. I need a more specific question to respond to, I think. I mean, some of these statements that you mention ... Q. Well, you were following her, were you not? A. I'm not sure I was following her at this point in January 2017, for example. But even if you follow someone, you don't necessarily see all their Tweets. I think that the meaning of these images is also to some extent ambiguous. Many of them are responses to the archive that the defendant had created by this point of Deanna Havas. Obviously, this was very upsetting to her. Okay, so she issues a Fatwa against him. Clearly, Deanna Havas has no authority to issue Fatwas. I think she is trying to respond to actually what is really quite a disturbing 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 meaning of this page. Q. If you look at 3918, and this is from 2019 ... A. I'm sorry, 39? Q. The next one, 3918, you will see that she begins at the top, after the, "Dead beady eyes, so scary", she says, "LT has Google alerts for my name and calls up every gallery I exhibit with ..." and so forth. And then somebody replies, which is Liked by her, and the person replies, "It's literally a psychosis and it's unsustainable. He's either going to end up killing himself or getting killed and pray I don't get cancelled for this but we're better off when that happens" and she Likes it. That is really very unpleasant on her behalf, is it not, to think that that message is acceptable? A. What the defendant is doing to her is extremely unpleasant. He is trying and in fact succeeding in destroying her life. He is accusing her of being a Nazi and an antiSemite based on messages that he's taken out of context, for the reason that she liked a picture of a cartoon frog that the defendant Page 189 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 3 October 2023 Page 191 thing that has happened, based on the fact that she Liked this image of these cartoon frogs. Now, there's a web page with her name on it filled with what the defendant describes in his correspondence, with, I believe, Bewley, as dirt that he was looking for to put on this page in order to destroy her career in the art world. That was the intention of this page and these are her responses to this. With respect to her Swastika, I do believe that it's useful to point out that this is clearly a Hindu Swastika. I presume that she was aware of that when she selected it. With respect to her Hitler moustache, I don't know what she means by that, but I think that's not a clear endorsement of Hitlerism, I think it's a kind of - again, Deanna Havas is a very ironic person. The defendant himself acknowledges that her Tweets were ironic, again I think in his statements to Bewley. So, these are ironic statements for the most part taken out of context in order to create an impression which is as damaging as possible in order to destroy Deanna Havas. That's the 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 found unacceptable. So, I agree that Deanna Havas' reaction to this is not pleasant but I think it is understandable. She has been put under considerable pressure by the defendant and, you know, I encourage anyone to ask themselves what - you know, how they would react if the defendant did this to them? They created a Wanted poster on the internet, begins to circulate it, claiming that you're guilty of holding these reprehensible beliefs this is what the defendant did to Deanna Havas because she liked a picture of cartoon frogs. Q. My Lady, I do not know if that is a convenient time? I am about to move into a different section of the chronology, but I can keep going. MRS JUSTICE COLLINS RICE: How are we doing for time altogether? We are due to continue with Mr Miller until lunchtime tomorrow. MS EVANS: I will definitely finish with him by lunchtime and in time for reexamination. MRS JUSTICE COLLINS RICE: Very Page 190 Page 192 48 (Pages 189 to 192) Epiq Europe Ltd (+44)207 4041400 www.epiqglobal.com casemanagers@epiqglobal.com Lower Ground, 20 Furnival Street London, EC4A 1JS
1 Miller031023Nick Land / text
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Day 1 Miller & Power v Turner 1 good. On that basis we will rise and resume 2 at 10.30 tomorrow. I am afraid it is a 3 difficult thing to be under oath overnight but 4 I do not think we have a choice here. If you 5 are in any doubt, your lawyers will explain to 6 you that you must not discuss your evidence. 7 The reason for that is that it is your evidence 8 I want, not the product of your discussing it 9 with anybody else. 10 A. I understand. 11 Q. Thank you very much. I will see you in 12 the morning. 13 (The witness stood down) 14 (16.21) 15 (The hearing adjourned until 10.30 a.m. on 16 the Wednesday, 04 October 2023) 3 October 2023 17 Page 193 49 (Page 193) Epiq Europe Ltd (+44)207 4041400 www.epiqglobal.com casemanagers@epiqglobal.com Lower Ground, 20 Furnival Street London, EC4A 1JS
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Day 1 Miller & Power v Turner 3 October 2023 Page 194 A a.m 1:2 193:15 abandoned 102:12 abhorrent 28:19 29:19 31:8 32:8 32:10 48:18 58:19 69:4 74:12 101:9,24 143:10 abhorrently 32:12 32:15 33:19,21 34:10 36:11 48:16 51:3 73:19 102:9 133:22 139:5 able 37:11 76:21 103:10 112:25 134:15 165:17 ableist 157:24 158:3,11 absolutely 48:21 50:20 58:18 133:12 140:11 abuse 17:13,22 18:14 51:7 163:7 180:9,18 abused 163:13 abusive 149:10,24 157:24 161:20 162:7 166:1 172:12 173:15,17 academic 73:2 100:16 academics 116:24 136:6 accelerated 142:20 accelerating 160:25 accelerationism 56:11 57:6 accelerationists 156:10 159:16 accelerative 56:17 accept 45:17 49:15 55:1 61:13 127:10 149:13 acceptable 119:10 135:8 140:8 141:4 191:18 accepted 73:19 Epiq Europe Ltd (+44)207 4041400 168:11 account 6:25 22:23 28:17 32:22 36:21 37:11,13,20 58:11,20 59:8 81:2,11 92:11 93:2,2 98:7,22 99:4 100:3 101:10 102:9 105:3 107:15 108:6 109:22 132:15 149:2,4 149:21 161:17,18 167:25 174:10,13 176:20 181:23 183:5 accounts 54:1 59:2 92:21,24 106:4 170:16 171:10,18 accuracy 8:24 accurate 77:22 99:12 138:9 170:12 accurately 100:9 172:4 accusation 6:12 150:20 accusations 8:9 64:18,18 accuse 19:9 accusing 152:21 177:21 179:14 182:2 184:7 191:22 acknowledges 190:20 acquaintance 101:13 acquaintances 72:24 acquired 169:14 act 30:16 68:1 69:24 72:4 action 35:23 38:1 91:17 100:1 111:12 112:15 120:3 162:18 activist 156:25 162:11 activists 26:15 62:9 63:6 64:7 65:3,4,11,11,18 66:4 156:21 163:19,23 179:15 179:17 activities 65:11 activity 8:13 159:7 actual 73:9 83:13 168:25 acute 20:3 ad 154:8 add 53:4 106:15 130:16 addition 53:18 address 3:25 20:9 addressed 145:8 adherents 132:12 adjourned 193:15 adjournment 21:4 60:6 92:1 93:21 94:1 144:7 admirable 71:24 115:17 admire 115:13,16 admission 101:24 155:24 156:6 admit 99:14 admitted 95:8 102:8 113:5,20 139:4 149:25 150:5 advance 114:11 advances 86:6 advertisers 127:20 advertising 7:23 advised 111:11 advocating 87:8 88:7 affect 9:9 24:23 afraid 44:13 124:5 153:11 176:9 186:17 193:2 Africa 36:5 agenda 36:4 aggressive 163:4 ago 107:8 132:10 agree 31:3,9 32:1 32:9,12,15,17 34:10,16 40:9 45:20 48:13 49:22 50:18 51:3 51:15,18,20,22 51:23,25 52:3,7,8 52:10,15,16 53:16,21,23 65:25 66:1 72:24 73:21 79:15 81:12 84:3 85:2 89:11 97:25 101:7,25 135:25 148:2 151:7,9 153:24 154:14 162:1 178:12 180:19 182:10 192:1 agreed 2:19 33:5 50:2 Ah 55:2 airplanes 170:2 AKA 147:4 alarm 10:17 Alarming 10:8 Albert 3:17 alerts 191:8 alien 125:16,19,25 126:4,5,19,23 139:17,23 140:6 140:14 143:20 alienation 72:8 all-knowing 179:2 allegation 5:1 11:12,13 102:15 105:1 150:2,3 152:23 162:19 164:3 allegations 4:10,19 4:23 5:4,6 19:20 98:8 alleged 13:2,7 45:11 allocates 87:17 alt 130:8 Alt-Nazi 7:3 147:4 178:16 alt-right 17:8,17 17:21 52:6,11,15 www.epiqglobal.com casemanagers@epiqglobal.com 54:2 63:12,20,25 67:3 70:11 147:4 151:5 168:12 186:6 189:4 altered 17:15 altogether 127:19 192:19 altruism 125:12 amateur 133:12 ambiguous 189:18 amend 1:21 amended 27:7 103:20 amendments 46:15 America 52:18 American 33:1 35:24 113:22 137:10 166:20,22 Amersi 14:10 amount 95:21 amounts 85:7 amuse 143:23 analysis 56:18 79:23 anamorphic 52:3 and/or 8:24 Andaman 130:4 Anders 67:19 68:15 Andrew 163:17 angels 103:9 Anglo- 125:25 angry 156:17,18 157:6 165:7 167:23 anguish 20:4 animals 33:15 annex 6:1 47:22,24 153:13 annoy 45:25 annoyed 101:11 156:1,3 annoying 44:8 45:24 73:17,18 101:8 anonymous 37:22 70:12 101:10 149:2 183:15 Lower Ground, 20 Furnival Street London, EC4A 1JS
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Day 1 Miller & Power v Turner 3 October 2023 Page 195 anonymously 37:24 answer 25:9 32:18 42:8 61:1 81:20 84:23 107:20 109:6,10 140:9 181:1 184:13 185:4,13,19 answering 184:25 answers 21:14 34:7,18 176:16 184:16 antagonistic 114:20 anthropology 114:13 anti 128:21 158:7 anti- 11:21 168:24 174:3,9 177:22 182:19 187:9 191:22 anti-fascist 62:8 63:5 156:21,25 157:3 162:11 anti-Semite 182:3 182:17,20,23 anti-Semites 180:5 anti-semitic 45:11 46:1,2,18,20,21 48:16,20 50:19 51:4,7,21 53:5,7 53:17,19 54:12 73:20 89:9 133:23 139:5 169:17 170:25 171:25 172:16 180:8,18 187:5 187:25 189:3 antifascist 26:15 antiracist 85:4 antisemite 26:7 antisemites 6:11 82:14 114:19 115:4 antisemitic 4:21 5:8,11,12,13 11:20 12:2 17:13 17:23 18:15,21 19:14 28:16,19 Epiq Europe Ltd (+44)207 4041400 29:19 31:3,12,15 32:1,13,16,17 33:6,21,22 34:11 34:16,21 36:12 81:13,16,21 82:10 83:5 84:2 100:6 102:10,16 102:22,24,25 103:5 112:12,21 113:1,6,19,23,25 114:2,17 115:5 115:25 118:9 119:9 120:7,12 120:12 121:3,6 antisemitism 19:24 81:5,18 82:4 101:24 116:3,13,15,25 117:12,13,16,22 118:3,3,5,12 119:13,14,15,20 120:14,19,24 121:1 Antismoking 127:11 anybody 25:15 41:7 135:5 148:12 164:8,14 193:9 anyway 59:9 186:4 188:6 apart 110:17 apologies 12:24 apologise 23:1 apology 155:24 appalling 17:12 appallingly 36:11 apparent 1:12 30:21 36:16 37:20 41:17 124:14 apparently 46:23 69:23 127:24 128:3 166:14 appear 1:6 25:15 100:19 182:10 appearance 6:21 93:1 appeared 132:11 148:22 appearing 5:12 8:15 69:7 appears 50:15 application 1:21 23:5 24:18 applied 124:12 apply 16:3 33:16 65:13 appreciate 110:3 122:17 158:5 182:23 approached 62:7 approaching 125:8 appropriate 26:16 122:11 172:21 appropriated 52:5 52:10 approximate 55:3 approximately 106:2 April 33:11 56:16 archive 187:17 189:19 area 183:14 arguably 142:3 argue 134:8 arguing 40:17 argument 3:6,8,12 12:5 87:6 153:18 arguments 1:13 15:19,24 96:6 arisen 11:6 20:21 arising 9:6 10:14 94:10 arrange 108:15 111:24 arranged 108:14 arranging 78:11 array 21:11 arrested 8:2 arrive 49:8 arrived 78:14 126:3 arson 17:19 art 7:2 8:11,11 13:8,9 16:17 63:17 64:14,21 66:2 68:8 70:20 73:2 105:4 120:21 147:2 170:21 181:25 184:14 190:8 article 12:13 39:9 39:14,15 40:4 58:16 66:17 67:9 84:17 91:7 94:14 97:1,2,22 98:9 99:22 124:2 131:18,24 132:9 134:2,4 137:10 138:5,6 146:9 149:19 articles 37:9 91:18 91:23 131:19 articulate 72:17 82:22 artificial 21:13 artist 7:14 16:13 120:22 166:20,22 artistic 48:4 65:19 artists 16:16 154:7 arts 100:17 artwork 16:24 17:2,14 48:5 52:22 53:1 153:3 artwork's 53:15 ascertained 9:21 10:23 asked 67:2 68:18 96:25 109:1 149:17,24 174:18 184:18 asking 21:13,17 29:8 50:12 53:24 58:22 99:21 144:14 180:25 aspect 22:1,11 127:8 assault 62:11 assaulting 52:24 53:14 assemblage 169:13 assertion 169:16 assessed 9:19 10:22 assist 1:24 21:7 www.epiqglobal.com casemanagers@epiqglobal.com 184:15 assistance 24:1,17 184:17 assists 39:11 associated 54:2 80:16,18 130:7 associates 64:7 74:18 162:16 163:15 association 61:2 80:19 112:7 153:6 assorted 86:11 87:22 assume 66:22 184:16 assuming 25:7 assumptions 132:14 Athenian 142:24 Athens 143:1 atrocities 136:16 attach 133:11 attached 70:17 74:2 129:23 attaching 146:8 attack 19:22 67:22 102:16 attacked 17:17,21 156:8 162:14 173:9 attacks 17:3,6,12 17:24 18:11 149:8 161:20 162:7 165:5 166:1 attempt 18:2 23:9 92:25 103:8 105:17,19 122:19 129:24 attempted 37:5 111:24 150:25 185:23 attempting 103:13 119:20 attempts 79:22 attended 61:15,19 149:25 attention 14:11 Lower Ground, 20 Furnival Street London, EC4A 1JS
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Day 1 Miller & Power v Turner 3 October 2023 Page 196 74:6 154:22 181:5 attentively 185:13 attitude 91:11 attributed 6:11 attributes 12:13 audience 122:17 audiologue 122:20 August 31:20 96:24 113:15 121:14 123:6 131:2 137:8,18 139:14 authentic 72:22 76:3 author 97:16 99:10,11 authored 97:15 99:10 authority 189:23 authors 99:16 autumn 77:18 available 14:24 91:20 Awakening 70:25 aware 23:24 68:20 98:14,17 152:13 152:14,17 172:8 190:13 awareness 135:5 B back 14:21 20:14 21:18 22:6 23:19 28:24 39:21 43:21 44:10 53:16 67:8 68:12 77:9,14 83:16 88:11 91:8 92:1 92:3 99:5,8 104:3,23 109:7 113:9 116:18 118:11 131:19 137:13 139:8 142:21 148:15 149:5 163:21 168:17 172:13 178:18 186:16 background 171:25 Epiq Europe Ltd (+44)207 4041400 bad 112:3 Bahtina 120:22 banned 58:5 Baroque 81:7,19 82:4 base 125:6 based 18:17,23 30:18 46:25 64:7 73:25 144:22 166:20 173:5 179:16 190:1 191:23 BasedBrooklyn 167:25 168:4 176:19 baseless 162:3 basically 71:25 73:10 134:7 140:20 159:7 164:12 172:9,11 174:6 basis 44:8 65:2 150:4 162:21 163:10 172:25 173:8,12 193:1 beady 189:1 191:6 bearing 132:4 beat 163:25 becoming 87:14 100:24 beg 107:23 began 11:3 17:2 18:25 63:21 100:14 132:23 146:1 148:20 161:6 166:4 168:3 169:22 beginning 165:1 178:23 begins 33:13 117:16 174:15 191:6 192:9 behalf 3:14 113:21 159:8 178:5 191:17 behaviour 30:20 73:4 163:19 164:6 167:15,18 beings 86:14,17 130:1,1 belief 9:15 12:7 135:14 beliefs 13:2 103:17 192:10 believe 18:23 25:23 26:10,11 26:15 58:5 62:12 65:12 86:12 99:19 102:11 114:12 117:4 122:15,25 125:2 125:12 129:10 130:21 143:15,15 145:3 147:21,25 165:8,10,19 190:6,11 believes 18:21 93:6 181:19 belongs 97:9,11 Ben 35:18 benefit 16:10 94:22 best 75:9 121:4 164:16 better 27:13 36:6 103:8 126:5 191:15 Bewley 190:6,21 beyond 101:3 135:7 147:10 154:8 Bible 44:2 bifurcated 56:11 big 174:7 bigger 36:7 bigoted 161:20 162:7 165:25 167:14,17,22 173:11 biological 86:18 88:2 117:18 129:5,17,25 biology 86:13 130:12 bit 2:9 14:20 35:17 54:17 67:11 80:15 88:21 89:23 93:9 95:1 99:25 104:24 119:4 124:6 136:7 137:20 153:12 166:10 172:22 185:20 bits 94:24,24 bizarrely 158:19 black 71:15 94:20 94:24 95:2 97:5 97:9 124:24 127:18 139:22 140:7,13 141:25 blacks 128:19 blank 42:18 blasé 91:11 blog 5:1 68:23,24 79:20,20 84:16 84:16 94:14 97:15,22 98:20 99:10,11,15 123:7,8,10 124:2 124:7 128:10,12 128:23 129:12 130:6 137:18,21 137:24 138:10 blue 156:9 board 70:12 boards 189:4 body 52:4 bombarding 77:13 bombardment 153:22,24 book 12:23 76:2 77:19,20,25 78:2 79:8 88:22 105:23 106:20 108:2,6,11 115:9 156:23 books 115:8 120:11 132:23 bored 100:25 born 126:15 183:16 borne 171:9 bother 7:4 bottles 49:2 bottom 30:2,5 55:25 56:5,23 57:20 59:12 www.epiqglobal.com casemanagers@epiqglobal.com 67:12 83:22 90:3 124:14 125:11 126:18 127:4 133:1 141:12 151:10 161:15 165:13 172:21 183:9,13 188:25 bounds 135:7 box 18:6 Boys 40:7 braver 67:25 breach 106:15 break 2:2 20:24 59:24 93:19 144:1 178:1 breathe.' 68:2 Breivik 67:19 68:16,20 Breivik's 67:22 Brett 67:16 68:4 Brevity 3:21 brief 3:20 15:17 76:13 briefly 16:9 153:16 bring 100:8 brings 6:17 Britain 166:21 bro 169:4 broadcast 184:6 broadly 149:7 brought 4:8 19:4 brush 188:3 btw 152:2 bum 82:21 bunch 159:14 bundle 14:23 21:12,16 27:3 29:21,23 33:23 38:12 47:22 58:21 61:21 66:14 76:5 80:23 80:23 83:17 84:12 88:13 89:17,24,24 92:1 92:4,6 94:12 95:13,17 96:15 103:21 104:4 108:25 113:10,11 Lower Ground, 20 Furnival Street London, EC4A 1JS
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Day 1 Miller & Power v Turner 3 October 2023 Page 197 113:12 115:21,22 123:10,11,12 131:7 136:18,19 136:19,24 137:14 139:8 145:17,20 151:14 153:12 157:18 176:10 186:2,2,17,21 187:16 bundles 1:21 91:7 91:22 Burn 91:8 92:3 Burnham's 79:25 burnt 138:18 Burrows 183:23 184:3 Burrows' 184:9 campaigns 127:15 cancel 135:3 cancelled 131:14 134:24 135:1,22 191:14 cancelled' 135:15 cap 50:1 52:19 capacities 130:5 Capital 124:12 capitalism 7:22 caption 70:24 care 154:19 career 166:6 172:1 190:8 careerist 155:17 carefully 130:24 carries 162:12 carrying 140:3 C 172:10 calculated 45:25 cartoon 12:22 California 69:20 166:3 168:10 call 17:8 21:8 172:20 174:1,2 26:17 33:14 89:7 190:2 191:25 91:1 127:1 192:12 128:14,16 178:10 carved-out 141:17 called 5:2 6:25 case 2:18,19 3:21 16:16,18 18:11 4:2 5:18 6:20 27:6 30:11 32:22 8:20,23,25 9:3 33:13 35:18 11:3,11,15 12:8 36:22 58:3,16,17 12:11 13:4,13,14 62:23 66:8 67:16 13:22 14:11 69:14 70:5,20 15:21 16:12 71:11,12 76:19 35:14 42:1 60:21 79:19,20 84:18 60:25 61:1,7,8,13 94:14 98:2 124:2 65:24 76:12,14 124:3 163:24 87:24 88:8 89:6 167:24 179:25 90:21 100:21 182:17,19,23 102:20 106:9 184:14 109:18 110:5,16 calling 161:22 112:5 115:14 168:9 177:17 122:21 144:3 calls 85:3 86:2,7 cases 1:25 8:19 87:3 114:7 191:8 14:5 camera 16:25 catalogue 69:10 camp 36:9 48:9 caught 120:1,5 49:4,8 ceased 111:8 campaign 5:13,15 celebrating 128:22 18:18,25 19:13 central 7:4 73:10 19:17 168:25 110:4 133:20 169:18 179:25 188:17,18 century 117:20 certain 25:21 30:13 42:13 72:22 75:24 76:4 79:12 80:13 82:3 93:3 118:14 125:3 140:24 170:20 certainly 46:19 66:2 132:13 142:8 155:13 157:8 181:14 challenge 105:4 122:3,8 challenging 143:1 chance 74:23 75:7 77:14 change 126:6 158:22 changed 28:1 58:2 58:9 158:17 185:2 changes 126:7 chap 35:25 characterise 112:25 characterised 3:23 11:4 184:3,5 characteristics 130:7 187:12 charge 126:15 182:21 charges 8:3 charitable 116:2 Charming 159:16 chase 4:11 chat 129:9 169:13 check 59:20 checks 12:9 cheek 140:17 cheeks 186:14 Chemical 115:14 chest 53:14 child 166:23 children 82:1 87:25 Chill 169:4 choice 186:25 193:4 Chomsky 136:4 choose 155:20 chose 68:1 Christ 134:16 Christian 117:9 Christianity 116:19 117:8,13 117:16 118:17 Christians 117:24 chronological 77:17 chronologically 144:16 chronology 2:20 39:11 146:18 159:11 165:12 192:16 Chuck 12:24 circle 124:4 125:1 126:2 circulate 25:17 192:9 circulated 26:14 64:15 circulating 46:2 circumscribed 177:2 CIS 179:24 cites 124:21 130:22 Citizen 66:16,20 civilisation 116:17 civilised 98:21 civilization 68:10 civilized 73:4 claim 2:15 4:7 24:13 27:5,7,9 35:4 44:11,23 58:15,19 64:12 94:6 102:1,12 112:15 121:2 125:6 142:15 148:4,8,9 150:5 162:3,8,10,12,13 165:5 167:18 173:7 180:16 claimant 2:25 5:6 6:21,24 7:10,12 Epiq Europe Ltd (+44)207 4041400 www.epiqglobal.com casemanagers@epiqglobal.com 8:1,10,15 20:6 90:12 105:7,7 106:25 122:2 135:13 164:16 Claimant's 28:15 105:17 claimants 1:7 3:14 6:10 8:20 9:3 10:10 13:14 18:19 19:4 45:7 claimants' 3:6 5:18 10:25 claimed 64:13 149:11 159:24 claiming 26:9 82:5 150:21 151:3,4 163:6,9 179:4 180:12,12 192:9 claims 8:14 19:3,6 19:9 30:17 34:12 58:11 64:16,16 114:9 130:6,13 144:12 153:25 164:8 173:9,10 180:17 182:3 clan 125:13,14,23 clarified 26:12 clarify 70:4 clarifying 14:2 78:5 class 87:25 88:1 146:12 classification 30:23 clean 29:5 cleansing 49:7 clear 13:13 15:9 28:16 35:8 47:25 51:11 62:21 65:12 76:22 78:2 84:1 100:23 129:4 135:9 136:9 144:22 171:15 181:18 190:16 clearer 175:13 clearly 30:20 54:2 67:24 135:6 173:15,17 179:13 Lower Ground, 20 Furnival Street London, EC4A 1JS
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Day 1 Miller & Power v Turner 3 October 2023 Page 198 189:23 190:12 clerk 2:8 click 169:11 client 16:12 20:24 38:18 47:25 50:14 51:6 57:14 58:6,12 64:8 109:7,24 110:6,7 111:8,12 144:11 146:19 client's 98:8 112:4 clients 97:8,14,16 109:9 clients' 61:7 climb 117:16 Clinton 63:24 close 14:11 112:7 163:15 181:5 closed 156:24 closing 15:25 16:8 cocksucker 155:21 155:22 158:6 Cofness 30:11 35:25 114:14 115:6 116:9 118:25 Cofness's 114:4 116:8 120:10 coincidences 137:20 collaborate 98:4 collect 185:11 COLLINS 1:3,18 2:3,7,17,22 3:1 13:17 14:1,8,15 15:7 20:11,18,25 23:12,16,21 24:5 24:19 25:8 27:19 27:22 28:2,5,10 59:19,23 60:3 93:18 94:3,7 95:15,20,24 96:3 96:9,11 123:18 123:24 136:21,25 137:2,4 144:4 175:11,16,20,24 176:4,7 181:4 184:21 185:10 186:19,23 192:18 Epiq Europe Ltd (+44)207 4041400 192:25 colourless 183:16 come 16:3 57:12 58:8,14 77:9,14 104:22 125:7,10 126:6 130:3 144:21 149:9 172:3 comes 79:17 95:9 95:9 comical 79:2 coming 31:11 33:4 60:8 113:8 132:8 commas 43:11 131:23 comment 7:6,9,22 8:4,8,12 67:25 128:17 187:9,10 187:11 commenting 7:12 comments 68:20 173:11,12,14 187:8 commitment 62:14 committed 75:14 101:2 169:1 commonality 75:16 communicate 109:15 110:20 communicated 108:3,4 109:20 109:23 communicating 111:1 communication 76:11 110:19 143:4 187:14 communications 38:2 107:24 137:15 Communism 166:24 comparative 87:4 compelled 74:7 122:19 148:7 compelling 128:6 141:10 compile 77:23 105:23 compiling 108:7,7 108:12 complains 5:22 6:5 57:14 128:18 145:1 complaint 127:6 178:3,7 complete 159:19 completely 26:8 73:7 110:16 112:13 123:17 138:12 149:15 177:13 completeness 105:24 complex 73:6 80:20 81:14 83:11 116:15 117:15 118:4,18 118:20 119:13,21 121:9 133:3,5 138:23 142:1 170:1 complexity 3:24 11:5 complicate 11:15 complicated 64:6 complicit 172:15 174:3 177:22 179:15 complicity 5:5,8,9 component 57:8 158:14 composed 99:13 130:18 composite 97:15 99:10 comprehensive 123:7 124:8 128:11,24,25 129:2,3 130:15 compunction 157:14 computer 7:18 108:8 conceal 37:5 150:25 concealed 37:15 concede 46:3 conceded 66:4 150:17 concedes 12:17 85:16 concentration 36:8 48:9 49:4,8 concept 130:19 conception 86:19 86:20 88:4 concern 181:12 concerned 9:3,8 9:12 10:11,16 25:17 35:14 63:16 145:16 concerning 187:14 concerns 2:14 4:7 6:18 concise 184:25 185:14 concluded 106:5 113:7 conclusion 133:22 133:25 conclusions 132:4 133:9 condemn 51:8 103:5 condemnation 135:17 condemning 8:16 conditionally 52:16 conditions 30:13 conduct 6:6 10:3,4 10:20 155:7 160:24 conducted 116:21 conference 5:12 63:18 64:4,10 66:6 67:13 68:3 68:5,22 69:7 confess 97:17 conformist-narc... 177:3 confused 89:23 confusing 169:12 connecting 110:10 www.epiqglobal.com casemanagers@epiqglobal.com connection 73:3 100:18 consequence 86:9 121:9 163:12 consequences 13:8 148:12 conservation 87:3 consider 130:24 considerable 133:7 192:4 consideration 101:19 considered 71:24 71:25 90:9 116:6 135:7 consisted 16:24 108:9 consistent 149:8 consistently 164:13 consisting 18:7 consists 95:8 169:13 consorting 102:15 102:21 conspiracy 34:15 81:6 82:6 118:8 construed 158:7 contact 26:19 99:3 103:6 106:10,12 contain 2:23 contained 71:13 149:20 150:10,12 contains 91:8 contemporary 56:18 64:22,23 64:24 66:3 79:24 135:8 142:18 contempt 127:25 contemptibleness 8:3 contends 11:10,18 content 5:16 40:4 46:21 49:15 55:22 95:4 146:16 179:17 contentions 12:21 contentious 133:14 136:8 Lower Ground, 20 Furnival Street London, EC4A 1JS
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Day 1 Miller & Power v Turner 3 October 2023 Page 199 context 25:20 34:24 68:7 74:13 100:14 103:2 116:9 122:10 129:8 142:14 174:20 184:8 190:23 191:24 continuation 19:7 45:9 46:17 172:6 continue 37:23 173:22 192:20 continued 17:22 19:1 157:16 contrast 8:22 contrasting 94:21 116:4 contribution 39:25 68:17 controversial 63:9 convenient 59:25 60:2 93:16 143:25 192:15 conversation 30:10 32:22 33:12 38:22 39:5 39:23 46:24 47:6 47:14 74:19 101:5 conversations 74:1 110:14 112:1 119:18 cool 152:18 coordinate 111:5 coordinated 111:7 159:6 copies 90:23 91:3 copy 89:4,16 94:20 95:22 150:24 Corbyn 34:14 cordial 72:25 corner 21:25 correct 13:22 22:12,13 35:22 36:23 37:3 38:3 38:5,20,24 39:6 41:3 43:7 56:21 57:23 63:12,13 79:9 81:12 85:20 92:14 95:10 Epiq Europe Ltd (+44)207 4041400 100:6 102:14 105:14 107:21 108:3 112:8,9 129:6,22 135:22 141:25 147:13,20 147:21 152:16 154:11 156:2 161:1,2,25 162:17 165:15,16 165:17 166:15 168:13 178:13 181:20 corrected 24:16 correctly 13:19 corresponded 163:18 correspondence 14:25 95:7 113:21 190:5 corroborating 174:19 corrupting 142:25 corruption 44:3 council 39:18 counsel 1:10 38:20 165:17 countenance 77:4 counter- 62:3 66:20 counter-protest 61:15 62:2,8,22 72:12 counterclaim 2:15 4:5 6:2,17 9:24 counterclaiming 20:1 counterproducti... 142:7 countries 125:3,17 126:9 134:11 173:1 country 18:18 couple 14:21 56:4 155:13 188:12 course 10:3,24 15:8,11,16,25 16:2 39:24 70:10 82:21 89:4 100:24 113:24 119:7 130:20 172:19 court 1:16,25 2:1 3:7,10 4:1 5:23 9:1 10:24 13:9 13:15 16:11 18:23 21:7 23:24 24:17 43:17 60:25 115:18 184:15,16 courteous 7:8 courtesy 25:4 42:7 courts 14:3 Cousins 73:1 100:16 cover 188:6 covered 145:2 covers 76:12 coveted 124:12 coward 163:1 cowards 167:8 crazy 170:25 create 58:19 92:25 98:4 106:15 111:14 188:3 190:23 created 16:17 50:14 58:10 98:7 117:8 120:21 187:17 189:20 192:8 credibility 173:13 credible 172:24 174:17,22 179:9 crime 6:7 134:16 crimes 168:25 177:23 179:15 criminal 10:7,20 91:2 CRIS 6:8 criteria 87:16 critical 41:9 146:17 187:7 critically 9:19 10:21 117:4 143:6,8,9,18 criticise 91:5 122:23 criticising 131:25 criticisms 90:13 90:24 91:1,9,20 91:20 critique 86:2 113:18 114:4 116:10 120:10 122:11,11,15,24 critique's 114:15 critiquing 116:12 crocodile 31:11 cropped 7:21 cross 142:11 cross- 13:23 15:4 cross-examination 2:10 27:1 cross-purposes 102:5 crossed 10:4 28:6 121:21 crosses 50:7 124:17 crude 116:4,14 117:1 crypto 35:19 cults 94:14 98:7 107:9 cultural 118:15,19 culture 113:18 124:13 133:21 134:10 136:3 Curious 168:17,19 current 125:25 130:10 currently 27:6 151:25 Curtis 79:19 80:8 cut 157:1 181:3,15 184:14,20 185:7 185:9 cutting 57:1 cyborg_nomade 147:9 D D 76:17 D.C 66:21 daily 172:25 damaging 112:14 148:11 190:24 dancing 146:6 www.epiqglobal.com casemanagers@epiqglobal.com danger 180:5,13 Daniel 8:11 18:20 21:8,9 dark 147:7 189:2 darker 94:21 Darwin 86:18,22 86:24 Darwinist 86:12 86:25 Darwinistic 86:13 data 36:5,6 date 1:16 3:13 30:7 50:10 78:13 151:23 160:9 dated 35:7 137:8 dates 55:4 David 50:25 51:17 114:24,24 182:6 day 62:5 66:17 98:14 121:14 137:22 172:2,14 173:17 174:14 176:11 185:9 days 65:5 67:9 155:13 173:23 DC 22:2 dcx 83:25 dcxtv 36:22 37:8 55:18 58:4 149:1 154:5 161:16 165:3 167:15 dead 159:3 186:13 187:3 189:1 191:6 deal 1:16 3:12 14:17 16:8 24:1 57:13 77:15 105:1 144:2 dealing 22:20 80:20 dealt 1:15 Deanna 7:14 8:10 161:4 165:14,20 166:3,5,6 167:9 167:12 168:17 171:14,22 173:14 173:22,24 177:22 179:12 182:22 183:10 189:20,23 Lower Ground, 20 Furnival Street London, EC4A 1JS
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Day 1 Miller & Power v Turner 3 October 2023 Page 200 190:18,25 192:1 192:11 death 4:11,14,20 4:23 5:19,22 12:1 19:17 128:8 debate 7:8 36:1 debating 119:22 decades 133:20 December 32:20 34:1 186:7 decide 43:2 59:9 decision 22:25 decline 68:10 deep 121:10 Defamation 128:21 defamatory 24:10 24:22 25:11 defaming 19:10 defeat 34:6,20 35:5 144:19 defeating 107:4 defence 6:1 10:11 10:24 11:7 47:22 90:4 104:1,13 115:23,23 131:10 153:13 166:11 defences 9:2,10 defend 71:19 164:12 178:21 defendant 1:8,22 2:25 4:9 5:21 6:4 6:15 7:13,16 8:9 9:7 10:2,16 11:6 11:9,14,18,24 12:3,12,17,20 13:6,16 20:6 25:16 26:19 28:14 48:3 49:13 49:17 77:13 102:14 145:1,4 145:22 147:19 148:3 149:16 150:4,21 154:1 156:5,12,15 157:14 158:4,9 159:9 160:19 161:5 162:2,5,15 163:8,9,16,18 Epiq Europe Ltd (+44)207 4041400 164:10,13 165:21 166:4 170:19 171:5,13,20,21 173:13,23 174:15 177:18,21 184:6 184:24 189:19 190:4,19 191:19 191:25 192:4,7 192:11 defendant's 8:23 9:18 12:7,10 61:1 150:13 151:3 161:24 162:3 174:22 179:7 181:25 defended 11:13 69:12 141:18 163:10 defending 163:12 164:15 166:14 defer 26:24 define 86:24 defining 35:20 55:7 definite 100:11 definitely 140:1 192:22 degree 93:7 111:2 111:3 degrees 131:20 delete 102:4 155:20 deleted 38:6,8 39:4 40:14,20 42:18 47:1,3,9 54:23 102:2,3,11 146:22 147:17 148:17,25 152:14 155:4,16,23 156:2,5,6 161:11 deleting 102:6,7 deletion 101:23 deliberately 3:20 7:21 109:19 deliver 91:19 democracies 85:5 demonstrably 140:9 demonstration 64:8 denial 132:12,25 134:5,17 denied 148:5 150:21 denier 114:25 132:15 134:18 denies 105:2 deny 132:6 134:11 134:15,15 135:6 136:11 138:25 139:1 177:20 dependent 8:23 54:20 depending 130:3 depends 55:7 depiction 49:25 168:5,24 169:17 depictions 180:18 deploys 168:4 Depopulator 92:16 183:6 deranged 69:4 111:20 149:11 deranging 26:13 111:18 derived 86:23 describe 46:8 82:13 112:11 129:24 145:7 185:24 described 17:11 19:14 89:8 100:9 describes 44:3 67:17 68:10 85:9 85:14 134:4 146:23 149:10 183:24 190:5 describing 7:2 11:3 80:5 87:9 88:6 184:2 description 14:19 52:5 68:15 69:3 79:15 92:18 93:8 115:16 116:8,11 147:22 170:12 178:15 187:5 descriptive 185:4 designed 11:24 42:10 171:23 desire 106:14 110:4 125:5 despite 133:17 160:23 171:23 destroy 172:1 190:7,25 destroyed 132:17 166:6 destroying 191:21 detail 13:7 99:25 details 74:24 determination 3:2 determine 9:1 determining 5:24 develop 79:22 developed 79:13 79:18 116:5 developing 86:9 develops 86:9 117:14 124:19 125:20 devoted 133:8 dialogue 94:23 97:3 98:1 99:20 100:14,24 dialogues 91:13 diatribe 73:11 dick 57:1 die 101:17 Diego 68:19 difference 8:18 141:24 187:7 differences 1:12 85:17 different 41:15,18 56:12 70:13,14 80:15 81:23 87:14,15 92:23 93:17 94:25 98:3 103:16,17 113:3 126:9 127:20 130:2 136:7 139:23 167:6 183:2 186:2 192:16 differently 87:7 difficult 44:7 83:7 107:4 116:2 www.epiqglobal.com casemanagers@epiqglobal.com 143:5,6 193:3 difficulty 184:11 dim 83:1 dimension 88:3 98:25 99:1 dimensions 118:20 direct 158:6 180:5 180:13 directed 21:14 182:9 184:24 185:15 directing 183:20 direction 184:22 directly 26:10 40:1 165:14 dirt 190:6 Disability 5:2 12:14 58:16 98:9 disabled 5:3 12:15 58:18 disagree 46:10 disagreement 105:9 disappointing 150:17 disapprobation 106:4 disapproval 139:16 discarded 49:7 disclose 109:10,12 109:18 disclosed 38:11 76:12 83:18 91:16,18 107:24 109:3 110:3,25 111:14 120:2,4 disclosure 37:25 90:24 91:22 108:24 110:9 disclosures 49:12 discourse 83:11 discourteous 10:5 discovered 132:16 discuss 62:12 75:10,19 93:22 106:19 111:12 119:7 122:12 129:11 138:23 Lower Ground, 20 Furnival Street London, EC4A 1JS
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Day 1 Miller & Power v Turner 3 October 2023 Page 201 142:12 143:6,7,8 143:9,11,17 160:19 181:21 193:6 discussed 65:22 116:25 142:2,3 discussing 40:5 72:11 98:6 112:3 129:7 138:3,20 138:21 140:12 141:21,23 142:17 152:1 160:15 184:10 193:8 discussion 41:9 45:9 46:18,20 65:20 106:7 120:10 136:6 140:3 142:1 146:13 discussions 101:1 142:14 143:3 disgusting 48:24 dish 7:18 dishonest 155:17 155:22 158:15 disingenuous 157:7 disks 183:17 187:3 disproportionat... 83:1 dispute 38:19 51:5 disseminating 28:18 dissociating 110:12 distance 100:1 102:18 103:14 distancing 101:23 distant 103:16 distinction 67:6 distinguish 9:20 10:22 40:22 41:11 120:25 distorted 49:25 51:15 distress 10:8,18 20:3 distressing 25:24 disturbed 49:16 Epiq Europe Ltd (+44)207 4041400 disturbing 18:6 26:4 48:18 49:14 49:18 66:10 189:25 diverse 130:1 diversion 13:10 diversity 86:4 127:15,19 128:22 129:5,17,24,25 divert 11:25 divide 16:18 17:2 48:5 153:3,4 165:23 168:6 171:8 174:8 divides 127:2 divinity 134:16 division 16:20 142:6 divisions 118:15 DNA 92:19 93:12 117:2,7 document 44:21 45:1 46:14 71:7 89:14 95:5 97:8 131:6,10 documentary 8:21 10:12 13:13 documentation 95:19,21 110:17 documents 14:21 15:20 23:25 109:3 145:12 doing 64:20 79:5 119:19 129:8 131:18 157:7,15 163:18 188:7 191:19 192:19 Donald 63:25 118:23 double 160:25 doubt 15:25 134:19 172:9 193:5 doubting 80:8 173:12 dozen 148:23 dozens 170:3 drafts 108:2 drag 22:23 dramatic 14:20 drawing 77:25 drawn 79:24 133:10 draws 133:22 154:22 drinking 52:20 driven 73:7 drop 105:16 132:19 133:8 139:21 due 161:19 162:6 192:19 Dumb-as-fuck 155:21 duration 157:17 durational 16:17 Dutton 30:17 duty 66:12 dwarfed 133:6 dying 101:16 106:14 dynamics 56:17 Einstein 3:17 either 8:24 107:17 158:11 191:12 elected 60:21 election 16:14,21 34:7 64:5 70:7 electronic 108:1 109:13 111:16 112:2 electronically 109:15 110:21 111:2,13 element 10:9 elements 83:10 elevated 133:20 Eli 164:10 elite 87:13,21,23 Elliott 69:15,19 70:17,21,24 71:4 71:22 elongate 12:4 Em 46:10 53:6 email 108:21 emails 108:1 E emanating 18:17 Eagles 50:8 embarked 69:24 earlier 67:10 emerges 117:11 early 16:14 107:5 emerging 92:20 144:15,16 165:15 emotive 136:8 ears 185:5 empathy 124:4 earth 82:18 125:1 126:2 ease 142:12 emphasis 57:9 easier 84:19 emphasises 12:9 easily 5:25 37:11 employed 112:7 132:17 emptiness 183:14 easy 119:7 enclosing 137:9 echo 43:14 119:1 encounter 103:4 economic 118:19 encountered 75:7 economics 40:8 100:12 economy 56:19 encounters 74:11 79:24 encourage 45:9 editing 86:10 46:19 98:24 99:18 103:8 185:14 edition 66:16 192:5 education 100:17 encouraged 12:15 effect 117:22 46:17 77:23 149:13 127:4,6 effectively 6:14 encourages 142:6 7:17 encouraging egg 31:11 33:5 www.epiqglobal.com casemanagers@epiqglobal.com 105:23 endeavour 176:18 177:25 ended 17:18 72:3 169:23 endless 184:6 endlessly 142:3 endorse 120:9,11 131:12 135:13 143:18 endorsement 122:4 190:17 endorses 129:19 endorsing 120:7 122:13 142:16 engage 77:5 154:25 165:14 engaged 7:13 45:10 46:20 engagement 54:18 154:8,14 161:12 engages 80:13 engaging 7:5 47:11 56:5 120:6 146:12 enlarged 50:1 enmity 125:14 enquiries 12:10 entangled 90:11 enter 18:8 147:12 entered 125:4 entertain 13:9 enthusiasm 161:22 entire 145:2 entirely 133:17 entitled 12:13 envisages 87:3 episode 66:11 epithets 19:24 equal 85:6,10 equivalent 74:11 Er 62:24 era 109:13 erasing 128:2 error 107:6 escalated 161:6 Esoteric 93:10 especially 17:20 18:14,15 142:8 Lower Ground, 20 Furnival Street London, EC4A 1JS
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Day 1 Miller & Power v Turner 3 October 2023 Page 202 162:11 espousing 28:18 essentially 147:7 establish 75:2,5 147:24 established 79:10 87:16 171:4 establishing 9:25 ethical 177:2 ethnic 30:15,16,21 125:15,17,19 126:19 128:1,8 187:12 Ethno-suicide 125:18 ethny 125:15 etymology 138:19 EU 124:18 eugenics 129:20 euphemism 129:20 Euro-descended 127:21 Europe 17:18 124:22 130:8 European 92:19 93:12 124:12,22 euthanasia 58:17 Evans 1:9 14:14 14:17 15:16 20:16 23:4 25:6 27:1,21,25 28:4,8 28:12 42:15 59:21 60:2,8 92:6 94:4,9 95:17,22 96:1,7 96:10,18 123:21 124:1 136:24 137:1,3,6 143:24 144:9 175:15,18 175:22 176:1,6,9 181:13 185:17 186:21,25 192:22 evening 39:8 76:16 77:10 160:11,16 160:17 event 12:19 45:7 111:15 134:7 events 63:11 134:8 Epiq Europe Ltd (+44)207 4041400 134:13,14 eventually 17:18 132:23 156:14 everybody 65:24 131:22 145:16 160:5 evidence 8:21 10:12 11:9 13:13 13:20 23:11,13 23:17 25:21 49:20 60:21 61:9 64:17 93:22 113:2 114:23 128:6 130:22 144:24 174:19 175:1 180:13 181:7 193:6,7 evidence-in-chief 23:6 evidently 48:9 180:4 evolution 116:19 126:23 evolutionary 114:8 evolved 127:16 exact 147:15 exactly 71:24 117:6 129:12 136:11 148:18 exaggerated 179:14 examination 13:24 13:25 192:24 Examination-in-... 21:10 examinations 15:5 examine 175:6 example 12:12,20 38:10 43:24 86:10 87:24 95:1 111:5 117:18 118:8 124:21 125:25 127:13 130:5 136:17 138:4 140:23 147:2 164:16 189:14 examples 29:18 30:19 55:13 114:14 175:8 179:21 exchange 42:16 47:15 55:21 97:2 106:24 152:11 163:8 164:25 165:1 167:4 171:12 179:7,11 181:19 182:13 exchanged 47:4 exchanges 12:2 55:15 84:4 111:9 exchanging 110:1 140:21 exclusively 26:12 107:2 166:13 181:24 executed 142:23 exercise 11:1 43:1 exhibit 191:9 exhibition 63:18 64:3,9 66:6 69:14 70:2,5,6,20 exhibitions 63:10 63:15 69:11 71:20 150:13 exist 85:17 88:6 existed 34:24 existence 138:7 existing 87:21 118:16 125:23 exists 11:17 86:11 87:10 146:22 exit 155:19 expect 40:16 147:15 expelling 122:7 experience 10:17 26:22 173:4,5 180:7,15 experienced 146:23 180:8 experiences 13:7 163:22 experts 124:18 explain 3:18 25:12 34:5 86:6 144:24 145:25 178:18 193:5 explained 71:8 132:17 145:4,6,7 explaining 164:4 172:10 180:9,11 explains 66:24 68:25 149:2 explanation 109:11,14 116:1 120:3 124:15 162:24 explicitly 87:15 147:4 exploring 133:13 expose 11:22 exposure 11:20 express 181:12 expressed 81:11 106:3 expressing 131:13 131:14 135:14,18 135:19 178:8 expression 65:19 72:8 128:12 130:11 extended 18:1 42:8 extending 126:4 extends 86:14 extensive 109:25 extensively 11:9 extent 103:11 111:19,20 142:9 184:23 189:18 extermination 89:10 extraordinary 174:5 extrapolate 11:16 extreme 87:19 112:11 extremely 21:6 25:24 26:4 66:10 101:8 116:15 117:14 122:16,21 130:4 136:8,14 142:7 148:9,11 150:3,14 154:2 157:7 163:13 www.epiqglobal.com casemanagers@epiqglobal.com 170:21 171:13 181:5 191:20 extremist 63:12 79:13 88:8 130:17 154:23 extremists 17:9 eye 186:14 eyes 51:17 183:17 183:19 186:13 187:3 189:1,2 191:7 F face 5:20 48:11 49:1 186:15 188:24 Facebook 6:20 faceless 183:15 facial 51:15 facing 32:20 fact 4:1 19:1 22:23 25:23 26:11 35:3 56:13 58:10 64:14 65:13 75:8 82:17,19 101:11 104:14 106:21 113:3 135:1 140:8 151:1 154:22 155:14 157:9 160:15 161:2 166:5 171:24 173:21 177:16 187:13 190:1 191:21 factor 101:20 facts 18:23 129:14 failed 123:17 fair 26:3 85:11 103:19,19 166:11 175:5 181:15 fairly 100:23 124:20 145:12 fairness 15:13 104:2 135:11 fairy 139:18 143:20 fake 131:22 false 133:16 140:9 149:15 false/bad 178:9 Lower Ground, 20 Furnival Street London, EC4A 1JS
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Day 1 Miller & Power v Turner 3 October 2023 Page 203 falsely 19:9 familiar 72:19 78:1 94:16 122:18 131:23 157:2 185:6 family 127:18,18 famous 43:24 far 9:2,7,24 10:10 10:16,23 11:20 35:1 48:6 50:14 67:24 104:17 112:12 133:14 149:7 155:14 158:4 170:18 174:6 far-left 64:7 154:23 far-right 63:11 67:3,19 79:12,16 80:5 159:15 fascism 11:10,11 11:11 fascist 26:7 65:14 65:15 91:5 147:2 149:12 176:25 183:4 fascist' 161:23 fascists 11:22 26:17 fate 49:4 father 166:23 Fatwa 188:16 189:22 Fatwas 189:24 faulty 106:22 favor 30:14 favour 172:18 fear 95:16 feature 13:4 109:17 110:5 127:24 featured 170:3 features 9:16 98:5 118:12 February 24:13 57:25 59:1,3 61:17 67:10 72:12 94:19 100:10 107:11,14 Epiq Europe Ltd (+44)207 4041400 164:1 feed 19:11 feel 72:6 127:25 181:11 feet 180:23 fellow 16:15 felt 58:19 66:11 74:7 78:4 148:7 female 7:14 ferocity 17:13 festival 8:11 fight 178:18 fightback 16:19 fighting 39:17 figure 55:3 71:24 72:1 73:6 79:2 184:2 file 36:14 44:9,10 54:14,15 files 108:8,8 filled 190:4 filmed 16:25 final 124:4 126:16 finally 151:12 152:9 find 13:15 23:23 32:14 33:23 44:12 47:16 73:9 83:7 85:15 96:19 103:24 115:18 121:20 143:10 175:12 finding 39:18 121:18 fine 146:13 179:6 181:2 finish 42:7 120:18 180:21 192:22 Finland 18:2 174:25 175:2 first 1:6 7:10,11 8:10 21:15 25:14 27:17 28:13,15 45:6,6 49:11,23 53:9 60:17 61:13 61:22 62:15 63:23 66:19 67:2 72:16 75:16 76:20 79:4 81:18 84:25 85:12,21 87:12 90:12,17 95:1 105:7,16 107:19 111:9 121:13 122:2 126:23 127:5 135:12 144:17 151:20 152:7 155:12 163:5 183:20 Firstly 6:24 Fisher 75:13 five 60:3 107:7 144:5 fixed 16:25 flag 168:6 169:25 flat 18:4,8 flayed 132:16 flow 38:18,20 40:4 flows 39:6 flustered 22:21 focus 40:2 67:12 133:18 focused 63:19 focusing 84:22 folders 21:11 follow 59:10 81:12 92:22 107:17,18 116:2 168:3 189:15 followed 81:3 92:23 167:1,2 168:1 172:9 followers 183:8,11 following 36:17 37:16 59:3 92:12 97:5 99:3 182:3 189:11,13 follows 4:9 football 124:23 128:18 forbidden 136:2 forced 65:9 forceful 127:9 forehead 51:1 foreign 126:15 forensic 145:12 175:7 Forgive 117:21 118:2 136:21 form 23:9 68:17 76:11 78:1 79:17 86:18 114:13 150:7 171:1 187:5 format 79:8 83:22 formed 16:16 121:8,8 former 9:22 forms 18:16 117:17 formulated 138:11 formulation 97:24 forth 57:19 77:6 95:3 128:9 133:21 147:12 154:8 170:3 172:19 177:5 180:6 183:5 187:4 188:1 191:9 forthcoming 111:11 forward 14:6 32:19 58:25 70:19 82:15 123:1 181:6 found 5:15 6:1,8 6:12 9:17 20:14 45:23 47:14 75:9 101:5 137:24 192:1 four 19:13 106:2 125:2,13 184:4 fourth 125:4,10 127:25 128:2 frank 158:3 182:17 frankly 136:10 fray 147:12 free 17:17 65:23 65:24 66:1 69:13 165:8 freedom 11:1 65:19 178:12 French 124:23 128:18,23 frequently 142:2 www.epiqglobal.com casemanagers@epiqglobal.com friend 1:23 14:18 25:5 26:25 73:1 75:13 100:15 104:16 105:1 143:13 167:8 177:6 180:24 friends 72:14 74:16 105:10 127:17 friendship 74:21 100:3 frightened 65:10 frog 52:2,4,11,13 52:17 53:13 54:6 166:3 168:5,10 168:12,19 175:19 188:10 191:25 frogs 12:22 174:1 174:2 190:3 192:13 frontier 124:4 126:17 fuck 182:4,18,21 188:11 full 15:25 33:24 39:13 96:10 124:23 funny 77:1 115:19 166:25 168:23 169:3 further 8:14 104:22 106:7 109:9 119:4 furthermore 173:9 173:10 future 86:3 89:9 132:25 G g 87:6 gain 42:25 gallarus 65:9 66:9 68:18 galleries 66:2 gallery 7:2,3 61:15 63:2,9,14,17 64:11,14,21 65:4 65:7,8,15,18,22 66:5,8 67:11 71:19 146:21 Lower Ground, 20 Furnival Street London, EC4A 1JS
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Day 1 Miller & Power v Turner 3 October 2023 Page 204 147:3,4 149:18 149:19,25 150:9 150:11,18,20,22 154:3 156:7 159:15,24 162:4 163:10,10,11 165:2 167:19 173:7 191:8 game 42:14 gay 158:5,6,10 gene 86:10 general 34:7 38:8 51:6 98:22 111:16 129:7 145:8 genetic 85:8 86:4 87:4 genetically 87:13 genuinely 169:3 Germanics 126:1 Germany 89:10 getting 159:14,21 160:1 161:18 191:13 girl 166:25 girlfriend 62:17 75:22 77:7 160:11,19 gist 149:6 give 23:6 42:8 53:19 60:21 74:24 77:14 123:22 159:11 181:15 given 6:4 23:14,18 26:2 42:7 44:16 49:20 51:4 109:12 144:24 178:21 gives 30:7 39:13 157:9 184:16 glance 53:9 glass 52:20 global 85:8 go 2:11 15:1,4 21:22 22:5,5 27:8 29:10,20 31:16 32:19 33:8 33:22 35:6 38:12 Epiq Europe Ltd (+44)207 4041400 38:14 39:21 44:10,17 55:23 57:10,13 66:15 67:8,20 68:12 70:18 76:19 80:23 82:15 85:25 88:11 104:3,23 113:9 114:15 121:12 123:1 136:18,19 137:13 140:2 145:14 153:11 157:18 159:10 161:8 162:22 169:7 174:14 175:9 179:21 180:20 181:14 182:4,18 183:1 186:16 187:15 188:9,10,11 god 151:12 152:9 goes 9:25 10:24 39:23 86:6 125:13,20 126:6 127:23 142:21 146:14 going 15:10 16:5 19:5 25:6,7 43:21 62:23 82:24,25 85:1 86:4 91:24 99:7 101:3 112:4 119:25 123:9 128:16 135:10 144:1,9,14 145:14 148:15 149:5 153:18 160:21 165:24 167:13 171:17 175:4 176:14 178:16 183:18 184:17 191:12 192:17 Goldsmiths 188:14,17 good 1:3 14:14,15 123:7 124:7 128:10,24 130:5 135:21,24 139:19 140:10 161:23 164:11,12 172:15 173:1,25 193:1 Google 153:8 191:7 gorsedd6 57:21,22 57:23 grammatically 138:12 grateful 14:12 21:6 gratuitous 177:13 gravity 10:6 great 52:19 76:21 128:12 greater 142:9 greatly 127:16 green 52:2,3 gross 8:3 Grossman 1:7 3:13 group 30:14,15 64:6 86:16 114:8 114:11 125:15 127:17,22 128:1 130:8 168:5 169:2,18 174:12 groups 41:3,20 52:6,12,14 125:17,19,25 126:20,23,25 130:2 172:24 186:6 growing 132:9 grown 132:21 Groyper 22:2 54:1 Guardian 67:9,17 guess 82:25 guidance 10:8 guilt 4:12 guilty 192:10 gun 51:20 54:8 guy 76:23 H habit 127:14 hack 155:22 Hackney 61:16 66:16 Haiti 73:2 100:17 half- 79:21 166:22 hall 112:1 Hammer 182:6 hammering 157:22 hand 66:19 78:10 94:4 95:22 handed 44:20 handful 145:9 handle 36:22 37:1 37:8,12 58:2,10 59:5 140:2 149:1 149:20 hands 20:3 163:22 happen 131:21 132:2 134:6 happened 89:15 107:7,19 156:4 156:11 159:21 161:3,7 164:1,2 165:19,22 167:10 169:10 170:9,11 171:7,11,19 172:11 180:23 185:9 190:1 happening 39:2 88:9 happens 117:19 171:11 191:15 happy 124:16 125:22 harassed 8:15 harassing 57:14 harassment 2:16 4:6,19,21 5:4,7,8 5:9,10,14 6:13 9:24 11:21 12:3 18:19 19:8,12 20:2 27:10 102:13 144:2,12 hard 175:17,24 harder 172:22 harm 9:1,9 13:21 13:24,25 14:5 16:7 23:3,7 171:16 173:20 harmful 127:14 Harvard 130:21 hashtag 92:19 www.epiqglobal.com casemanagers@epiqglobal.com hat 52:21 hateful 155:7 160:24 hatred 71:10 Havas 7:15 8:11 161:5 165:15,20 166:3,5,14 167:9 168:17 171:14,22 172:8,11 173:22 173:24 175:9 177:6,22 179:12 179:23 181:16 182:22 187:19 188:8 189:6,20 189:23 190:18,25 192:12 Havas' 166:6 173:14 183:10 192:2 head 51:20 91:7 heading 132:25 headline 39:14,15 heads 152:3 healthy 136:1 hear 1:22 18:24 25:9 129:1 181:1 heard 23:2 63:23 82:10 hearing 63:21 193:15 Heathcliff 78:13 78:14,21 79:6 Hebrew 44:4 heeb 186:15 height 8:6 held 62:11 64:9 132:22 help 25:11 39:18 59:24 97:20 99:7 helpful 13:18 20:12 175:13 helpfully 39:12 her's 183:12 heretical 134:16 HET 179:24 hi 78:16 167:12 higher 55:12 highlight 187:22 highly 30:24 Lower Ground, 20 Furnival Street London, EC4A 1JS
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Day 1 Miller & Power v Turner 3 October 2023 Page 205 111:17 118:18 140:17 142:4 143:10 164:7 hilariously 35:21 Hillary 63:24 Hillel's 36:3 Hindu 190:12 historical 89:14 134:7,8,13,14 136:16 historically 142:22 historiography 131:5 history 116:17 117:13,14 118:18 128:3 134:3,4 141:19 hit 25:15 Hitler 51:19 90:13 90:25 91:1,9 138:16 188:3,7,7 190:14 Hitler's 89:7 Hitlerian 5:2 12:14 98:9 Hitlerism 190:17 hm 84:23 hmm 1:19 30:1,9 30:12 31:21,25 32:24 33:10 34:2 38:13,16 39:20 40:13,24 41:2 81:4 84:15 87:18 106:8 118:24 121:17,25 123:4 HNDU 167:10 hoax 131:22 hold 47:19 66:25 holding 134:24 192:10 hole 56:15 66:19 76:20 79:4 87:12 88:24 121:13 123:5 126:13 139:13 152:7 hollow 186:14 holocaust 31:23 32:5 83:3 114:25 131:5,21,21 Epiq Europe Ltd (+44)207 4041400 132:1,12,15,22 132:25 133:15,19 134:3,4,5,10,17 134:18 135:6 136:2,12,16 138:8,15,17,25 139:3 hominem 154:9 homogenous 85:10 homophobic 157:24 158:3,8 homosexual 154:9 honest 9:11 18:22 19:20 46:6 73:23 82:8,11 83:15 85:12 93:14 101:4 104:13 108:18 112:11 135:24 168:2 169:12 170:12 177:14 honesty 8:24 honoured 67:23 hooked 51:16 hope 3:7 21:7 29:11 145:15 horizon 177:2 hormones 57:1 horns 41:15,19 43:21,22,25 44:1 44:4,6 46:4 50:22,23 horrible 26:22 53:8 72:4 horrific 136:9 horrifically 53:5 hosted 66:25 67:15 hostile 141:17 hours 155:9 159:14 housekeeping 1:11 14:18 houses 39:18 howl 82:23 HPD 129:3,5 hucksters 82:24 hugely 127:13 hum 176:22 187:21 human 31:6 43:23 46:9 86:14,17 129:5,17,25 130:1,1 143:4,19 humanity 86:4 humanoid 52:4 Hungary 124:10 HWNDU 52:22 165:22 hyper 86:8 Hyper-Racism 84:18 hyperbole 148:14 hyperbolic 64:19 148:9 150:15 179:13 hypothesis 34:19 34:21,22,23 41:4 181:21 ideologies 11:21 ideology 80:6 90:11 177:3 II 94:14 107:9 ill-founded 150:15 illegal 134:11 illustrative 11:10 35:15 171:12 IM 91:4 image 31:10 48:8 49:11,13,17,18 51:15 52:11 53:4 53:6,8,9 54:6 158:22 159:4 166:4,8 169:17 169:19 174:6 177:24 179:18 180:19 188:2,5,6 188:24 190:2 imagery 12:23 I images 47:24 48:1 Ial 120:22 50:10 54:12,21 idea 129:9,10 127:15,19 169:13 140:18,20 187:23 189:6,17 ideal 80:1 imagine 147:11 idealogues 79:13 immediately 37:14 79:16 37:20 64:12 66:8 ideas 62:13 65:20 148:20 157:13 65:22 67:1,5,7 immigrants 127:5 87:19 107:1 immigration 126:7 110:1 112:3,10 126:11 130:10 119:9 120:7,12 impacting 135:17 120:13 121:10 implication 102:19 129:7 138:3 135:20 143:8,9 implicit 162:12 identification 69:3 164:10 identified 65:15 implies 161:22 identifies 114:12 implying 141:8 identify 30:14 impolite 149:22 43:19 65:14 72:7 importance 10:18 91:14 97:13 important 9:23 identifying 87:23 16:2 64:23,25 identitarianism 80:6,11 89:14 87:2 90:9 136:12 identities 97:12 141:14 identity 36:25 37:4 impression 190:24 37:19 improperly 103:13 ideological 104:18 imputing 143:16 158:13 inaudible 56:15 ideologically 82:18 www.epiqglobal.com casemanagers@epiqglobal.com incel 72:2 incensed 166:7 inception 116:20 inchoate 82:23 incidentally 148:4 178:22 include 24:12 123:8 included 17:12 19:17 24:10 67:15 187:24 188:12,24 includes 178:15 188:23 including 14:9 26:18 30:15 48:20 52:15 58:13,15 89:10 145:16 170:1 185:22 incomplete 114:6 inconceivable 109:14 incorrect 12:18 85:19 increase 86:5 increasingly 100:25 incredibly 117:1 indicates 40:25 141:23 indicating 46:9 indication 150:10 157:10 indisputable 138:15 individual 144:25 163:16 individuality 117:25 individuals 13:3 18:4 52:14 133:7 infer 41:22 inferences 9:5 10:13 100:19 103:12 inferential 13:22 14:5 inferior 86:19 Lower Ground, 20 Furnival Street London, EC4A 1JS
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Day 1 Miller & Power v Turner 3 October 2023 Page 206 117:23 118:6 inferiority 71:15 118:10,14 inflammatory 164:7 influential 122:16 122:21 information 6:7 104:22 inherent 9:5 10:13 initial 149:16,23 156:5 169:22 179:11 initially 78:23 79:18 105:3 injured 71:4 insane 72:6 143:11 insert 14:22 insight 141:14 insisting 168:9 inspiration 67:18 installation 16:18 70:17 installed 16:23 instance 101:22 102:1,18 instantly 103:6 institutionally-s... 176:25 instructed 97:7 instructions 18:7 20:22 60:19 97:7 insult 149:22 insulted 177:20 insulting 156:17 158:12 177:19,20 insults 149:11 intellectual 105:18 105:20 114:10 intelligence 177:1 intemperate 156:17 164:5 175:9 intemperately 167:20 intend 3:4,25 15:4 15:22 24:14 intended 16:19 26:6 47:18 Epiq Europe Ltd (+44)207 4041400 intending 2:6 intention 190:9 intentions 142:15 inter 95:6 interacted 105:2 122:2 interacting 107:22 112:22 127:18 interaction 55:8 100:5 interactions 36:16 38:10 40:19 47:11 54:25 55:9 55:15 58:23 83:19 98:23 99:23 101:20 109:25 110:13 interest 9:13,15 11:19 19:21 110:10,11 162:18 interested 10:25 55:22 92:18 93:4 100:13,21 130:12 134:1 138:1 181:24 184:22 interesting 69:2 76:23 77:5 85:16 101:6 127:7 140:18 154:20 interests 30:17,21 57:8 69:13 112:17 114:11 interjection 184:12 intermixture 85:10 internal 34:25 international 153:21 internet 51:8 63:16,17 71:23 72:23 98:3 108:10 142:20 169:24 170:23 171:4,5 192:8 interpret 83:7 85:1 interpretation 49:16 interrupt 2:10,12 intervened 181:8 interviewed 116:24 Interzone 184:5 introduced 46:23 75:14,23 78:23 introduces 124:9 introductions 1:6 invent 34:23 invented 72:3 inverted 43:11 131:23 invested 133:2 investigate 66:3 investigating 19:16 63:20 64:1 64:21 67:5 investigation 4:15 4:24 67:6 invite 185:4 invited 68:22 involved 19:12 63:7 65:6 70:22 95:4 99:18 114:9 152:4 170:24 173:19 involvement 99:22 IQ 36:5 Iron 50:7 ironic 81:17 83:9,9 190:18,20,22 irrelevant 101:15 138:12 irritate 47:18 73:24 irritating 32:14 47:15,17 73:9 irritatingly 91:10 irritation 73:22 Irvine 114:24,25 Islands 130:4 isolation 87:4 Israel 136:6,7 Israeli 120:22 156:23 Israelis 33:1 issue 2:11 3:16 4:1 5:24 14:19 22:24 23:6 132:24 189:24 issued 156:7 issues 1:11 3:2,3 3:10,15 4:13 5:15 8:25 9:9,10 10:1 11:15,25 13:10 15:12 106:15 122:4 189:22 issuing 157:14 164:7 188:15 item 21:25 22:1,11 ivy 36:2 Jewy 82:19 Jihadi 39:16 jobs 39:19 40:7 Joe 33:14 John 73:1 76:19 100:15 join 176:23 joined 161:4 joins 153:17 167:24 183:7 joke 141:7 jokes 143:22 Judaism 116:20 jude 186:13 187:3 judge 164:21 J 170:13 178:6 Jack 13:5 60:11,12 judged 5:20 76:21,24 109:4 judgment 4:14 James 79:25 14:9 January 16:24 July 18:25 30:8 35:7 189:14 74:16,20 75:3,5 Jeremy 34:14 75:20 76:15 jet 170:2 110:22 144:13 Jew 50:19 145:21 146:8,15 Jewish 16:14 146:18 151:23 30:19,20 31:6 153:19 157:20 34:15 35:20 42:3 159:12 160:9,9 43:19 47:17 160:18 161:10 48:23 50:4 51:4 162:22 165:20 51:8 53:3 54:7 176:12 179:22 79:22 81:6 82:1 jump 39:17 89:20 82:1,5 103:3 jumping 104:24 112:25 114:11 153:12 116:22,24 117:10 junior 1:6 117:24 118:5,8 Justice 1:3,18 2:3 119:3 120:20,23 2:7,17,22 3:1 136:5 138:16 13:17 14:1,8,9,15 166:23,23 171:24 15:7 20:11,18,25 172:17 182:25 23:12,16,21 24:5 Jewishness 53:9 24:19 25:8 27:19 179:19 27:22 28:2,5,10 Jews 30:23 33:1,3 59:19,23 60:3 33:17 34:8 35:19 93:18 94:3,7 41:15,18,19,24 95:15,20,24 96:3 43:22 44:6 45:22 96:9,11 123:18 45:23 46:4,9,23 123:24 136:21,25 50:22 73:13,16 137:2,4 144:4 83:1 89:11 114:9 175:11,16,20,24 114:21 117:23 176:4,7 181:4 132:2 www.epiqglobal.com casemanagers@epiqglobal.com Lower Ground, 20 Furnival Street London, EC4A 1JS
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Day 1 Miller & Power v Turner 3 October 2023 Page 207 184:21 185:10 186:19,23 192:18 192:25 justify 179:1 Justin 13:5 109:5 156:25 juxtaposed 50:6 juxtaposition 50:12,13,15 35:1 37:2,6,7,21 41:4,25 42:21,22 42:24 43:14 44:5 46:5 48:6 49:17 49:19 50:9,15,17 60:11 63:6,22 70:8 71:17,21 73:5,23 74:11 75:8,10 78:6 79:2,3 80:2 82:7 K 83:15 85:12 Kampf 89:1,6,13 86:17 88:12 90:6,9,18 91:11,21 93:11 Katko 156:25 93:11,13 95:18 keen 115:7 97:12 107:18 keep 89:3 136:19 110:15 115:3 145:15 168:9 119:8 125:7 176:16 178:2,17 129:11 131:15 185:14 192:17 135:25 136:1 Keller 8:11 138:1,2,18 Kevin 113:17,21 140:19 143:24 114:3,16 115:3 144:13 145:19 120:11 148:1,18 149:3 keyboard 7:17 152:19,24 153:2 Kill 188:14 153:6 154:21 killed 69:22,25 158:10 159:4 71:4 132:3 160:8 163:1 191:13 164:19,22 169:14 killer 69:19,21 170:18 171:16 killing 5:3 12:15 173:3 174:22 52:25 191:13 176:2 182:15 kind 26:3,21 34:14 188:5 190:15 66:5 68:9 71:7 192:5,6,14 72:22 73:10 knowing 97:23 74:18 79:7,22 knowingly 6:16 80:20 86:20 93:3 knowledge 115:2 114:19 128:7 133:5 129:23 136:2 knowledgeable 138:21 164:6 132:11 165:25 167:14 known 6:8 17:7 171:3 184:5 28:18 37:1,4 185:24 190:17 52:2 kinds 118:14 knows 36:2 143:15 King's 1:10 183:18,19 knew 22:17 42:2 L 63:22 101:15 112:14,20,20 labelled 148:13 150:13 153:4,5 LaBeouf 16:16 know 2:1,5 3:10 48:4 52:25 53:15 14:3 15:18 16:13 LaBoeuf 153:6 Labour 34:24 35:1 Labour's 34:6,20 35:5 Lady 1:5 2:6,14 3:4,16,20 5:18 6:18 8:18 11:3 11:10 13:12 14:13,14 15:16 16:9 20:8,20 23:2,15,24 24:14 28:23 39:1 40:1 44:12 77:16 84:20 93:15 94:4 143:24 144:9 146:1 185:18 192:14 Lady's 14:23 94:22 Ladyship 4:12 19:23 21:15 Lambert 62:19 lamp 49:7 lampshade 49:2 Land 13:5 56:14 79:14 80:11,13 80:16 81:2,15,25 82:16 83:6,8,20 84:17 86:12,21 86:24 88:2,5 109:5 121:15,16 122:5,6,7,10,15 122:16 129:18 Land's 56:10,18 84:12 86:23 language 154:16 163:4 167:21,22 168:16 177:13,19 182:1 186:9 large 84:7 111:2,3 133:3,4 largely 35:14 144:10 Lastly 6:12 126:25 late 19:4 75:20 120:2 144:13 laugh 143:22 167:9 186:15 188:14 laughed 166:8 laughing 180:17 law 1:12 3:8 12:9 16:4,5 96:24 lawyer 111:10 lawyers 16:11 60:18 193:5 lay 20:24 LD-50 144:20 146:21 147:1,10 147:19 148:6 150:22 151:4,8 152:1 154:2 156:9 159:15,23 159:24 LD50 61:15 62:2 62:23 63:9 64:1 64:9,10,13,20 65:15 66:24 67:15 68:17 69:12 71:18,19 78:24 108:10 148:23 162:4 163:9 165:1 167:19 173:6 178:9 lead 23:10 126:15 leading 13:20 leads 41:10 league 36:2 128:21 learned 1:23 14:18 25:4 26:25 180:24 learning 100:13 leave 173:21 175:12 led 4:20 41:21 42:23 101:13 125:12 left 39:9 40:2 78:10 82:7 left-hand 21:25 31:18 44:25 57:11 104:7 legal 3:10 legitimate 65:12 length 125:1 175:6 let's 89:6 144:4 157:3 166:16 179:20 Epiq Europe Ltd (+44)207 4041400 www.epiqglobal.com casemanagers@epiqglobal.com letter 18:6 95:12 96:23 97:18 99:8 108:23 level 4:11 48:19 73:3 82:23 levels 81:24 liability 8:25 9:25 10:7 liar 162:25 167:7 libel 2:15 4:4 8:25 19:3,6,9 111:12 112:15 114:24 libelous 150:16 liberal 85:5 Libertarianism 79:18 lies 165:11 life 18:2 71:9 72:3 166:6 180:5,12 180:14 191:21 light 25:19 liked 6:24 166:3 168:18,18,20 174:5 177:5,24 179:18 180:19 188:8 190:2 191:10,24 192:12 likes 87:3 154:11 191:15 Liking 166:7 174:1 179:16 limb 82:25 limit 74:14 limited 10:18 100:5 106:12 177:1 line 79:5 126:21 131:23 141:1,12 lines 77:6 90:13,25 110:1 119:5 139:21 142:10 165:22 lingo 172:18 link 13:1 24:10 98:16 123:8 131:6 137:9,24 146:8 169:11 links 37:9 list 3:3 59:2,12 Lower Ground, 20 Furnival Street London, EC4A 1JS
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Day 1 Miller & Power v Turner 3 October 2023 Page 208 109:3 150:12 listen 15:15 185:12 lists 125:9 literal 138:19 literally 109:7 191:11 litigation 3:22 little 54:17 80:15 89:23 93:9 115:2 124:5 136:6 173:8 live 17:5 109:13 121:11 125:23 livelihood 135:19 lives 72:6 log 6:7 logo 7:20 logs 169:14 Lol 147:9 London 18:5 London- 64:6 long 19:5 24:24 25:14 36:20 103:22 104:9 111:8 131:4,17 142:22 156:13 157:15 163:13 174:21 181:2 longer 146:21 look 6:22 23:13 27:12 29:8,18 35:23 38:9 39:22 42:15 44:11 53:11 78:7,9 79:4 80:22 83:16 84:11 89:17 91:24 95:12 100:4 103:18 104:2,19 112:21 115:19 117:11,12 118:11,22 120:16 123:9 131:6 132:3 141:12 148:14 151:10 161:14,23 164:11 164:12 169:7,8 170:8,8,10 183:12 186:1,12 191:2 Epiq Europe Ltd (+44)207 4041400 looked 64:16 88:21 107:10,15 137:7 150:6 153:16 158:21 169:9 183:6 looking 17:17 45:13,20 96:15 126:14 131:19 137:14 153:23 163:21 170:16 172:7 181:6 186:18 190:6 looks 95:1 loses 42:13 lost 108:5 109:22 lot 75:10,19 78:6 79:25 120:14 130:22 131:24 loud 167:10 188:14 Loving 152:10 low 126:12 183:13 LT 152:11 191:7 Lucia 68:19 luckily 95:3 Luke 7:5 8:2 16:12 57:17 151:25 154:6 163:1 167:7 176:20,24 186:12 Luke_Turner 154:6 155:18,19 155:23 lunch 93:23 183:24 184:14,20 187:1 luncheon 91:25 lunchtime 76:15 192:20,23 lung 130:5 lying 164:21,23 178:4 174:10,13 maintains 102:15 making 35:4,16 73:23 74:4 81:15 101:12 124:10 134:22,23 136:22 150:5 179:10 180:6,16 male 179:24 malediction 26:21 malicious 142:15 man 79:19 103:4 managed 169:25 manifesto 71:6,12 71:16 89:7 manifests 120:25 manipulates 25:20 manner 11:14 130:17 140:17 Manosphere 76:2 mark 12:8 75:13 marked 188:19 Marney 33:14 marriage 130:9 married 81:25 marry 87:25 127:7 127:22 Mars 33:1 Martins 179:25 180:3 188:17,18 Marxism 114:14 masked 18:3 65:5 massively 142:19 match 6:14 7:13 material 5:23 6:11 6:23 9:4,7 10:15 12:19 22:20 51:10 77:23,25 79:7 96:4 105:18 105:21,22 108:9 108:12 144:11 mating 86:11 87:22 M matter 1:8 11:19 machinations 14:18 20:21 46:7 82:20 85:20 145:10 magazine 188:5 170:15 main 73:22 154:24 matters 3:5,16 5:5 mainstream 85:4 9:12 13:10,12 170:16 171:18 132:23 157:4 185:18 MatthausAnsatz 145:22 Mc 118:23 McCabe 36:5 McDonald 113:17 113:22 114:3,7 114:22,22 115:3 McDonald's 114:16 115:25 120:11 mean 30:16 32:4 40:17,18 41:14 46:10 71:21 72:7 74:18 75:13 77:3 78:19 79:3 80:20 82:2 93:9,13 114:1 117:6 119:8,12 138:14 141:2 154:18,20 158:1 173:20 175:19,21 184:19 189:9 meaning 11:16,17 12:22 53:20 81:24 138:20 189:17 191:1 means 60:25 86:7 93:11 138:18 145:11 177:9 190:15 meant 64:2,11 78:5 114:21 122:9 171:15 measured 167:12 mechanism 11:24 media 2:24 4:4,8 17:4 18:1 132:17 133:18 144:11 170:16 171:18 mediaeval 118:12 Median 37:12 medium 47:10 111:21 112:2,3 119:18 meet 10:7 78:11 108:14 111:25 176:15 www.epiqglobal.com casemanagers@epiqglobal.com meeting 106:2,19 111:24 Mein 89:1,6,12 90:5,9,18 members 17:1,19 169:1,18 meme 169:5 Memorial 70:21 memory 106:22 men 76:2 men's 74:10 mention 7:24 88:22 189:10 mentioned 14:19 41:19,21 67:14 67:24 68:16 105:25 118:25 170:18 187:19 mentioning 184:9 mentions 104:14 merely 63:8 87:14 115:9 138:7 167:23 merits 130:14 message 7:4 16:19 32:2 48:22,24 51:24 70:12 79:6 84:2 108:16 117:10 151:7 163:3 181:17 186:17 187:6 189:4 191:17 messages 29:19 73:8 76:9 78:8 88:12 106:18 108:5 109:21 110:18,25 113:14 120:2 123:2 131:1 139:7 149:6 151:15 153:9 187:18 191:23 messaging 111:16 met 10:20 14:4 61:18 62:16 72:16 73:2 100:10,17 meta 146:9 metaphorical 12:5 Lower Ground, 20 Furnival Street London, EC4A 1JS
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Day 1 Miller & Power v Turner 3 October 2023 Page 209 metaphysical 118:15 metastasising 128:7 methods 67:25 Michelangelo 45:5 Michelangelo's 43:25 mid 75:2,5 middle 57:11 74:20 87:11 124:25 132:8 140:2,23 146:5 184:13 migrants 124:18 Miller 1:7 4:10,14 4:20,23 12:16 13:1 18:20 19:18 20:1 21:8,9,11 22:19 23:2 24:3 24:8 26:23 27:2 60:8 66:13,21 83:25 94:9 96:19 97:10 144:12 148:25 165:9 176:12 192:20 million 132:2 millions 138:16 mind 2:1 16:6 98:18 132:4,22 143:17 minute 172:3 minutes 21:1 60:4 121:15 144:5 152:8 163:2 mirror 186:13 mischaracterised 179:10 misguided 154:10 misogynistic 73:11 105:6 misogyny 122:5 mispronounced 12:25 misrepresentation 105:12 156:11 159:20 missing 94:5 110:16 123:19 Epiq Europe Ltd (+44)207 4041400 146:17 misspoke 90:21 mistakes 12:11 misunderstand 143:5 Mm 30:1,9,12,25 31:21,25 32:24 33:10,18 34:2,9 38:13,16 39:20 40:13,24 41:2 81:4,9 84:15,23 87:18 106:8 107:12 118:24 121:17 123:4 Mm- 1:18 Mm-hmm 41:13 41:16 89:19 90:2 94:15 97:4,19 155:6,10 mob 163:24 mocked 188:6 mode 122:12 187:11 moderate 162:24 modern 124:22 modernism 146:9 moment 78:21 80:13 93:16 104:6 123:22 143:25 148:15 176:2 monologue 68:9 mood 73:22 moot 108:13 moral 86:20 147:10 morning 1:4 14:14 14:16 107:16 131:2 137:8 139:4 153:16 160:8,15 193:12 Moses 44:1,3,4 motif 189:2 motivated 136:11 138:25 142:13 158:13 171:2,3 motivation 103:12 motivations 10:25 motives 145:5 moustache 188:4 190:15 move 93:16 112:6 144:2,10,15 175:3 177:15 179:20 192:15 moved 17:15 movement 72:23 116:23 120:20 movements 114:10 moving 4:19 121:4 176:9 multi-racial 127:17 multiculturalism 125:16,24 126:18 126:21 127:8 128:6 multiple 136:5 murder 69:25 174:25 175:1 murdered 67:20 138:16 murderous 72:4 Murphy 13:5 109:5 museum 16:23 17:16,16 169:23 muted 36:19 mutual 2:20 mutualist 147:7 N N/acc 56:7,9 Naked 183:24 184:14,20 187:1 name 12:25 25:16 26:5 37:13 53:16 60:10 66:21 78:20,21,24 149:21 190:4 191:8 named 7:14 70:6 109:4 120:22 130:19 156:25 163:17 184:8 names 109:17 narrative 132:1 133:15 134:6 narrow 177:2 Natalie 62:18 77:7 Nathan 30:11 118:25 national 128:23 natural 102:20 nature 2:18 18:15 19:14 61:3 80:19 103:9 112:16 143:3 157:11 171:13 Nazi 7:3 50:7 53:18 54:3 64:15 91:5 148:6,7 150:20,22 151:6 154:2 159:24 162:4,10 163:9 163:11,24 165:2 167:19 171:25 173:7 176:21 177:15 178:16 188:1 191:22 Nazis 91:12 152:22 162:13 170:25 177:17 Neanderthal 92:20 93:10,12 nearby 62:5 nearly 113:15 151:2,4 necessarily 87:23 114:5 153:20 189:16 necessary 21:1 need 2:2 9:18 10:21 20:21 29:20 44:17 58:19 60:20 61:6 74:24 88:25 95:3 108:25 123:21 131:8,17 143:7 143:12 145:17 146:2,15 160:7 183:19 189:8 needed 47:14 needs 20:17 89:5 172:4 Neo- 64:14 78:2 80:16 178:15 187:25 www.epiqglobal.com casemanagers@epiqglobal.com Neo-Nazi 150:11 162:20 168:21 169:2,18 170:4 172:24 174:11 Neo-Nazis 17:10 neo-reaction 56:19 67:13 77:24 79:11,16 Neo-Reactionary 72:18 Neoreaction 88:23 neutral 66:3 neutrally 172:12 never 37:5 51:9 70:15 82:10 91:15 100:12,21 101:7 108:20 109:23 110:14,20 111:6 114:3 134:2 156:6 170:17 180:4 186:12,12 nevertheless 187:1 new 16:23 23:10 23:10 28:24 44:19 58:3,11,20 59:4,8 98:7 105:22 107:15 108:12 117:9,17 127:19 156:7 newer 111:25 newspaper 66:17 132:15 nice 172:14 173:16 Nicholas 124:3 Nick 13:4 56:10,14 79:14 80:11,13 80:16 81:2,15,25 82:16 83:8 84:17 86:12,23,24 88:1 88:5 109:5 121:16 122:4 129:18 Nicklin's 14:9 nickname 78:17 78:19 niggers 82:18 night 113:16 nihilistic 68:9 Lower Ground, 20 Furnival Street London, EC4A 1JS
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Day 1 Miller & Power v Turner 3 October 2023 Page 210 Nike 7:20 Nina 18:20 57:23 74:23 75:17,23 101:4 111:23 115:10 129:6 137:25 143:13 Nina's 22:23 Noam 136:4 non- 16:10 138:11 non-human 187:13 non-Jews 117:23 non-white 126:10 Non-whites 126:15 normal 116:10 149:12 normalization 167:14 normally 40:19 Normie 176:24 183:4 nose 50:1 51:16 note 1:14 101:14 noted 138:7 notes 136:22 notice 52:17 186:13 188:8 notion 44:6 82:6 143:19 notwithstanding 82:20 novel 183:23 November 38:23 Nowadays 56:25 npcdctv 83:25 nrx 56:18,19 57:19 79:7,10 number 21:16 23:25 30:5 44:17 55:8,10 63:14 76:18 84:4,6,7,8 84:8 92:23 96:1 116:24 133:7 154:21 171:6 numbers 35:22,24 132:11 numerous 91:18 O oath 93:21 193:3 Epiq Europe Ltd (+44)207 4041400 obfuscate 11:25 object 23:8 25:6 objecting 41:7 43:9 164:8 objection 24:15 objective 9:25 171:10 objectively 9:21 10:23 obligation 66:11 obligatory 65:13 obnoxious 31:14 32:10 37:24 observation 14:13 observing 63:8 obsessed 136:14 obvious 37:14 150:4 obviously 2:9 15:19,20 30:24 31:15 34:6,20 35:9 42:11 44:5 46:10 53:7,7 89:13 92:24 123:16 133:6,10 134:5 135:5 136:17 138:17 143:20 148:16 161:16 189:21 occasion 9:13,16 47:8 102:25 occasional 47:11 132:14 occasionally 105:3 occasions 18:5 19:11 106:3 occult 12:21 occultism 141:19 occurred 134:2 occurs 182:14 October 1:1 54:24 55:5 58:6 78:9 106:18,22 107:6 110:23 111:10 193:16 offences 19:22 offended 43:7 offensive 149:10 154:17 177:12 offer 126:24,25 officer 6:5 Oh 59:21 104:5 okay 29:5,12 42:4 47:20 50:24 51:13 68:6 84:10 97:3 104:8 107:6 119:24 123:13 132:3,6 144:18 173:19 178:3 189:22 old 28:15 56:25 124:11 127:8 131:19 OLDER 179:24 once 139:1 one's 125:14,15 Onehundredper... 183:7 ones 55:22 92:25 123:21 133:10 139:4 146:3 161:11 ongoing 19:2 106:19 online 17:4,25 18:7,15 19:8 43:20 52:6 55:9 69:10 83:19 93:3 93:5 106:6 110:1 138:3 148:21 open 1:25 27:4 66:14 69:8 77:16 88:13 123:3 132:22 136:19 143:2 185:4,12 opened 107:15 opening 1:14 3:20 15:17 20:10 174:25 openly 62:12 operated 104:15 181:20 operator 37:19 38:3 60:10 opinion 9:11 19:21 19:25 104:14 122:14 135:8,23 140:15 150:7,14 170:15 178:8,11 opinions 143:2 oppose 120:12 opposed 98:25 opposite 26:10 oppressive 10:6,20 Optics 28:17 29:20 31:22 33:20 34:3 36:17 38:3 39:3 47:5 48:7 55:1 58:1,23 59:13,17 137:22 139:3 Optics' 43:4 47:16 56:16 137:25 138:7 order 11:16 25:25 41:8 43:19 58:11 74:4,5 92:25 98:4 103:1 114:10 169:15 172:1 190:7,23 190:25 ordinary 85:14 86:3 organised 63:1 64:2,4,8 65:3 130:2 organising 64:15 original 27:12 29:10 35:22 44:11 50:11 94:5 121:19 originator 80:10 originators 80:9 Osborne 163:17 Oscillating 181:18 Oslo 67:19 ought 109:18 out-group 125:12 out-groups 126:4 outlined 2:19 89:9 outside 18:4,9 35:13 125:14 127:22 136:7 Outsideness 32:23 81:1 outsider 133:13 oven 36:8 ovens 36:9 www.epiqglobal.com casemanagers@epiqglobal.com overblown 7:16 overcomplication 11:23 overnight 176:6 193:3 overview 13:18 overwhelming 131:25 P page 4:16,17,18,21 4:22,25,25 5:4,6 5:7,10,11,13,15 6:6 7:1,11,15,19 8:1,6 21:18,22 25:11 27:8,8,14 27:15 28:24 29:5 29:13,23 30:2 31:16 32:20 33:22 35:6 38:14 39:10,21 40:1,3 44:16,24,25 48:8 48:25 49:22 50:21 51:14,14 52:1 53:11,25 54:5 56:22 58:22 59:2 61:21,22 66:15,19 67:21 70:18,23 76:8 77:16 78:7,10,11 81:1 83:17,17 84:22 88:14,14 88:18,19 89:22 89:25 90:1 92:9 94:13 95:14 96:13,16 103:21 103:23 104:3,4,5 104:7,24 106:1 109:1 113:12 118:22 120:17 121:12,13,20,23 124:9,21 126:20 127:6 128:2 130:25 132:7,8 135:12 137:3,13 137:17 139:8,9 139:24 140:3 141:12 145:18,20 146:13,16,20 151:10,15,19,20 Lower Ground, 20 Furnival Street London, EC4A 1JS
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Day 1 Miller & Power v Turner 3 October 2023 Page 211 154:4 155:1 157:19 158:19,21 166:10,18 171:22 175:10,14 176:11 183:1 186:2,3 187:16 188:9,22 190:3,7,9 191:1 pages 6:2 55:23 70:19 83:21 146:3,14 paint 188:2 pair 76:11 Palahniuk 12:24 12:25 paler 94:21 95:1 panic 147:10 paper 30:18 paragraph 24:2 27:11,16 44:14 44:25 45:18,25 46:12 85:9,22 86:1 87:6,12 90:3 95:1 102:7 102:11 103:21,22 103:25 104:1,12 106:1 122:1 124:14 133:1,9 146:24 148:19 149:5 paragraphs 84:25 Parallax 28:17 29:20 31:22 33:20 34:3 36:16 38:3 39:3 43:4 47:4,16 48:7 55:1 56:15 58:1 58:23 59:13,16 137:22,25 138:7 139:2 ParallaxOptics 6:25 60:10,22 61:2 94:11,17 97:22 98:10,19 99:23 100:2 104:15 109:4,8 112:5,23 122:2 ParallaxOptics' 102:9 ParallaxOptics's Epiq Europe Ltd (+44)207 4041400 98:20 ParallaxOpticsa... 54:22 56:2 ParallaxOpticsa... 38:23 55:16 ParallaxOpticsd... 45:21 ParallaxOpticsh... 154:17 ParallaxOpticsh... 32:9 ParallaxOpticsh... 39:16 ParallaxOpticsin 54:19 ParallaxOpticsis 34:22 56:5 138:4 ParallaxOpticson 36:18 ParallaxOpticsp... 34:17 ParallaxOpticsr... 42:9 ParallaxOpticsr... 30:22 33:17 ParallaxOpticsr... 33:3 57:22 ParallaxOpticss... 31:4 ParallaxOpticss... 36:7 56:24 ParallaxOpticss... 41:5 ParallaxOpticst... 137:7 ParallaxOpticsto 40:6 ParallaxOptics... 37:16 ParallaxOptics... 153:17 parentheses 43:12 43:14 parenthesis 119:1 parents 101:16 106:13 parlor 186:14 part 8:23 9:14,14 11:2 14:11 33:19 55:20 104:20 105:24 107:21 144:3 146:7 178:12 185:1 190:23 partake 12:4 parted 75:8 partes' 95:7 partially 182:25 participant 8:17 participated 6:15 68:6,7 participating 99:20 111:20 177:4 particular 42:14 95:5 103:11 104:12 106:14 130:6,9 141:24 146:11 164:25 169:16 particularly 15:9 15:21 17:25 23:9 69:1 72:19 84:22 130:12 particulars 27:5,7 44:11,23 94:6 parties 1:24 97:12 184:4 parties' 8:19 partly 20:5,6 partner 48:4 parts 27:9 party 34:25 168:22 170:5,6 170:17 171:10 pass 29:5 passage 44:2 passed 29:6,7 pathological 162:25 167:7 pathologically 155:17 pathology 90:10 Patron 96:24 patterns 87:22 Paul 116:18 pause 23:22 24:2 25:1 185:11 paying 14:10 181:5 peculiar 71:22 pejorative 127:11 pen 97:5 penultimate 132:7 people 5:3 12:16 20:13 25:25 26:17,19 30:13 30:16,23 31:6 33:14 37:1,5,6,10 41:3 43:7,19 47:12 49:7 51:7 56:6 58:18 63:24 66:25 67:20 69:25 71:15,23 72:5 74:5,9,12 81:8 82:12,22 87:24 88:1 91:10 91:13 94:25 98:3 109:4,6,17 111:25 113:4 115:18 117:24 118:6 121:1,3 124:17 127:10,22 130:3 132:11 134:8,15 136:11 136:13,13 138:16 138:20,24 139:17 140:1 141:6 142:13 143:8,9 146:6 148:22 152:21 159:23,25 160:1 163:14,24 164:23 165:11 169:16 170:3,24 177:17 people's 143:1 Pepe 52:2,11,13,17 53:13 54:6 168:4 168:11,18 175:19 188:9 period 18:13 35:13 76:13 84:5 99:2 101:17 107:25 110:24 118:13 144:13,15,17,17 145:2 156:13 157:16 163:14 www.epiqglobal.com casemanagers@epiqglobal.com periods 36:20 peripherally 13:4 perked 185:5 perks 126:24 perpetrated 18:19 persisted 156:12 person 18:22 20:16 26:2 47:17 51:9 52:24 54:7 56:24 59:16 62:9 72:1,16 73:3 111:22 112:11 113:1 120:23 146:11 147:8 157:22 158:7 161:4 190:19 191:11 persona 73:17 personal 7:5,9 73:25 personally 32:14 47:15 70:15 103:2 130:11 136:10 140:4 persons 18:17 perspective 110:5 perspectives 63:15 persuasions 56:7,9 70:14 phase 125:4 126:2 126:17 127:1,25 169:21,22 phases 125:2,13,21 phenomena 65:1 187:13 phenomenon 72:10 86:8 98:6 111:18 116:16 117:15,19 118:4 118:21 119:13,21 142:18,19,21 philosopher 122:12,17 philosophy 13:3 79:12,23 80:21 photograph 61:23 62:18 70:23 146:6 photographs Lower Ground, 20 Furnival Street London, EC4A 1JS
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Day 1 Miller & Power v Turner 3 October 2023 Page 212 49:23 phrase 87:2 172:20 physical 26:16,18 65:13 physically 17:3 162:14 pick 56:3 picture 25:22 50:22 51:19 158:18,22 166:2 175:14 191:25 192:12 piece 98:21 113:2 131:4 184:13 185:6 pile-on 146:22 pile-on' 148:22 Pinker 124:25 130:19 place 47:7 111:1 placed 130:13 places 135:6 plain 127:8 plainly 6:10 plan 2:13 planet 33:16 186:16 plans 89:9 platform 7:7 186:5 platforms 135:18 plausible 81:8 140:6 141:4,10 147:11 players 124:24 playground 12:6 plea 29:10 pleaded 60:18 61:8,12 pleading 102:8 103:18 134:20 pleadings 11:7 109:17 148:5 151:4 pleasant 182:11,16 192:2 please 1:5 23:20 27:2,4,8 29:24 33:8 35:6 47:21 Epiq Europe Ltd (+44)207 4041400 54:14,15 67:8 76:5 82:15 83:16 92:2,8 94:12 113:9 115:20 123:1 131:1 136:18,23 137:13 139:6 151:14 153:11 155:1 157:18 161:9 172:6 173:20 175:10 183:1 186:20 plenty 71:14 175:8 plot 174:25 175:2 pm 151:13 point 7:6 15:4 17:8 35:15 36:21 45:4 58:6 59:25 60:2 60:20 68:14 70:4 72:13 75:16,17 75:24 77:17 88:12,25 90:5 94:10 103:19 111:17 116:22 124:10 133:25 134:12,22,22 140:5,10,21 146:19 147:13 149:4 152:13,24 154:24 158:17 161:24 173:13 177:21 180:7 181:11 182:14 189:14,20 190:11 pointed 102:2 pointless 106:7 points 15:12 105:9 Poland 116:23 120:20 polarisation 16:20 police 4:15,24 6:5 18:11 19:16 65:9 110:8 156:15 policies 130:10 policy 41:7 126:7 polite 149:17 political 13:2 56:19 70:14 79:23,24 80:21 81:7 90:11 105:5 114:10 122:22 184:4 politically 85:18 85:20 158:13 politics 5:2 12:14 17:10 34:25 58:17 98:9 187:14 polity 80:1 pomposity 3:24 pooling 85:8 poor 83:1 pops 167:9 popular 68:23 115:3 186:6 population 86:16 130:2 portentously 183:15 poses 34:4 posing 172:24 posited 131:20 position 66:6 80:15 85:4,19,20 87:9,9 88:8 93:4 105:5 107:4 116:11 121:5 129:4 130:15 133:20 157:3 161:14 162:15 164:15,21 173:3 178:6 179:2,5 180:10 positions 26:8 72:18,19,20 83:13 86:23 91:5 100:11 101:2 121:7,8 122:3 132:18 positive 35:23 possess 179:4 possible 25:18,19 40:21 41:11 66:9 121:2 143:4 145:15 185:15 190:24 possibly 41:3,20 133:17 164:19 post 28:15 84:16 94:14 123:7,9,10 124:2,8 128:10 128:12,24 129:12 130:6 138:10 posted 28:14 37:9 94:17 166:2 poster 26:5 192:8 posting 18:5 161:17 165:4 posts 2:24 4:5,9 7:2 28:16 68:24 potentially 50:14 135:17 power 1:8 5:11 13:2 18:20 20:2 57:23 74:22 75:6 75:20 76:10,17 76:20 77:2 78:12 78:16 88:24 95:10 97:3,11 98:5,15 110:19 110:20 113:15 123:6 131:4,25 137:15 139:15,22 140:10 151:24 152:10 160:10 power-crazed 82:23 powerful 133:18 practised 111:6 Pravda 137:10 pray 191:14 precise 49:14 97:25 102:23 128:15 precisely 73:24 83:8 89:14 91:6 92:25 111:13 115:4 183:22 predictable 124:20 predicted 70:7 predominant 73:14 prefer 182:18 prejudice 69:6 preliminary 4:13 5:14 133:10 preoccupation www.epiqglobal.com casemanagers@epiqglobal.com 73:10 preoccupied 14:4 preparation 174:21 prepared 72:17 84:23 97:8 98:1 preposterous 140:16 presence 11:19 present 25:21 26:6 122:19 presentation 114:5 presented 9:4 110:2 presents 25:18,22 114:7 129:14 preserve 148:25 preserved 47:13 49:18 President 16:15,22 52:18 pressure 183:14 192:4 presumably 77:8 presume 40:17 47:1 190:13 prevent 157:1 prevents 177:3 previous 27:9 43:9 67:14 128:17 150:12 157:10,23 158:19 161:25 previously 45:10 119:17 148:5 primary 9:19 principal 8:18 principally 19:10 principle 62:14 privilege 9:13,17 180:4 PRIVILEGED 180:1 probabilities 9:6 10:14 probably 27:3 33:23 41:6 43:8 72:2 88:13 113:18 114:13,17 119:18 123:19 Lower Ground, 20 Furnival Street London, EC4A 1JS
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Day 1 Miller & Power v Turner 3 October 2023 Page 213 154:9,15,19 169:11 183:16 probe 184:23 problem 185:2 problematic 43:11 43:12 142:5 143:11 procedure 116:10 proceed 101:3 proceeding 159:7 proceedings 20:7 157:17 process 11:17 89:8 145:13 produced 50:10 63:14,18 64:10 66:7 170:22 171:6 produces 171:22 producing 189:6 product 193:8 Professor 114:22 profile 158:17 profound 103:11 profoundly 101:11 programme 85:8 98:2,3 progress 181:9 project 13:8 108:13 120:21 129:23 153:5 165:23 169:21,22 170:20,20,21,23 171:1,7,19 174:9 projects 181:25 prominent 118:9 promoted 129:18 promotion 67:7 69:11 prompts 147:6 pronounce 60:11 60:13 proof 26:1 propaganda 4:22 127:12 155:22 propagandising 127:9 propagandist 177:1 Epiq Europe Ltd (+44)207 4041400 proper 28:9 properly 89:1,13 122:14 proponents 17:6 120:7 proposal 77:20 propose 1:15 protected 141:18 protection 65:9 protest 62:4,22 63:1,4,4,5 65:2,6 65:18 66:12,18 protested 156:20 protesting 63:7 protestor 66:21 prove 10:2,19 35:22 provide 12:18 provided 11:7 13:14 49:12 110:9 166:12 174:20 provides 116:9 provocation 42:2 165:2 provocations 47:20 provocative 42:10 42:17 99:1 103:1 162:9 164:7 provoke 74:5,5 provoked 163:8 provoking 169:24 psychoanalysis 114:12 psychological 118:19 130:7 psychopath 91:2 psychosis 69:24 191:11 psyop 139:16 public 8:13 9:12 9:15 11:19 17:1 19:21 132:18 170:21 publication 24:8 24:22 107:10 publications 6:18 6:19 9:12 publicly 19:11 published 4:9 5:1 28:16 98:11,15 98:19 108:10,11 137:23 publisher 8:12 punch 66:19 76:20 79:4 87:12 121:13 123:5 126:13 139:13 152:7 punches 88:24 purely 13:1 purported 182:11 purpose 9:19 49:19 64:3,4 106:5 put 5:18 14:6,23 20:4 26:5 27:12 44:9 61:6 63:10 69:12 84:8 97:1 112:4 119:25 164:20 172:4 180:5,13 190:7 192:3 puts 11:6 71:19 182:5 putting 18:6 102:17 172:12 178:2,17,25 Q qualified 9:13,17 quarters 168:11 168:14 question 13:20 24:20,21 25:7,9 34:4,17 36:13 42:7,10 49:9 61:13 69:17 81:20,22 90:23 107:23 118:10 128:4 129:13 138:9,13 180:25 184:25 185:3,12 185:15,17 189:8 questionable 30:24 questioning 142:24 184:22 questions 21:14 24:15,18 26:24 32:5 36:15 59:16 60:17 64:23,24 84:21,24 90:15 145:11 185:3 queue 39:18 quickest 84:19 quickly 22:21 55:14 84:20 157:6 quit 163:2 quite 14:3 19:5 23:25 43:6 47:15 77:22 78:25 79:2 81:14 84:4,8 97:24 115:7,19 120:14 123:7 124:8 127:9 128:10 130:22 132:21 133:16 156:13 164:13 169:12 172:12 175:13,17 189:25 quotations 130:18 quote 183:23 186:25 188:25 quoted 3:17 184:13 quotes 67:21 124:14 128:21 130:21 R race 85:9 86:15,16 races 85:6,17 87:7 139:18,23 140:7 140:13 141:25 142:6 143:19,20 143:20 racial 87:1 racism 85:15 86:3 86:8 122:5 141:1 141:22 142:2 racism' 139:16 racist 17:12 26:7 41:8 71:14 87:19 105:5 Racists 40:11 41:6 radical' 154:7 www.epiqglobal.com casemanagers@epiqglobal.com raised 4:2 ran 74:23 range 109:16 rap 82:21 rat 186:15 raving 122:20 re- 27:6 192:23 re-follow 59:9 re-instigated 46:14 re-tweet 7:20 reacquainted 75:6 react 192:7 reacted 171:5 reaction 16:21 78:3 80:17 151:2 151:11 170:22 187:23 192:2 reactionary 105:22 108:12 reactions 169:24 read 8:5 15:18 21:17 22:1,3,11 27:23,25 33:12 35:16 40:1 55:25 71:8,16 84:19 89:1,12 90:18,19 90:20,22,22 93:8 113:17 114:3,3 115:8,10 116:7,8 121:21 128:20,20 129:15,16 135:10 135:20 140:22 142:14 146:3 181:16 reading 12:8 26:3 90:9 122:14 132:23 133:2 136:15 181:6 real 11:25 31:23 32:5 35:4 58:4 103:3 138:8 realised 46:15 realising 139:17 realistic 85:19 realities 139:1 reality 88:6 91:12 168:21 realization 132:10 Lower Ground, 20 Furnival Street London, EC4A 1JS
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Day 1 Miller & Power v Turner 3 October 2023 Page 214 really 16:10 33:16 41:23,25 42:24 42:25 46:7 47:2 55:8 68:8 73:15 74:2 77:3 78:5 80:1 82:7 83:14 93:13 99:3 108:17,22 115:2 121:15 122:7 145:3 160:13 163:12 166:9 169:12 171:12 175:1 189:25 191:16 reason 19:2 34:20 44:4 46:13 74:7 78:23 95:5 99:21 102:21 140:5 141:3 150:24 156:9,18 158:25 186:7 191:24 193:7 reasonable 9:5,15 10:13 11:17 12:7 12:9 98:24 99:1 103:8 reasons 132:21 138:22,24 rebuttal 9:16 recall 4:13 47:3 55:8 99:20 142:23 received 51:6 174:23 receiving 164:20 recognise 31:12 53:1 156:16 187:20 recognising 140:24 recognition 141:14 141:20 159:5 recollection 40:15 148:18 149:5 recommend 115:9 137:17 recommendation 124:7 recommended Epiq Europe Ltd (+44)207 4041400 138:5,6 recommending 115:8 131:3 132:5,6 137:21 reconstructed 38:17 record 110:3 111:14 155:11,15 160:14 recorded 148:19 red 94:24 95:2,2 97:5,10 reductive 105:5,19 122:3 refer 24:8 25:11 91:22 138:14 185:24 reference 4:20 23:23 27:20 36:8 39:5 40:6 46:18 49:4 53:8 56:14 57:3,5,21 77:6 83:2,3 90:5 91:25 115:24 128:4 131:11 135:4 136:23 139:6 147:1 149:9 160:3 161:16 179:19 184:19 186:1,20 187:2 188:13,15 References 57:19 referred 41:1 90:5 115:24 118:23 147:3 148:21 174:24,24 referring 29:2 34:22 77:24 83:10,14 84:3 160:5 174:7 refers 34:12 41:6 46:1 56:6,10,17 70:8 104:20 169:20 172:19 187:11 reflect 133:12 reflection 12:17 refollow 107:13 refrain 152:20 refugees 166:24 refutes 114:15 115:6 regard 106:16,23 134:13 regarded 119:10 130:20 141:1,21 168:12 187:25 regards 19:2 register 138:22 regret 22:25 157:8 167:20 regrettably 10:5 11:5 regularly 37:9 38:8 47:9 102:2 111:6 regurgitate 3:5 rehearse 15:23 rehearsing 157:5 reinstate 102:17 reiterates 86:2 reject 26:8,13 112:13 130:23 167:20 rejects 85:13 rekindled 74:21 75:1 related 109:3 relation 83:19 94:11 112:5 126:8 relationship 60:9 100:9 112:16 171:3 relationships 72:25 relentlessly 17:21 relevance 15:9 76:13 77:17 relevant 9:6 10:14 22:25 72:9 81:24 107:25 reliable 153:20 relied 47:24 relies 11:9 12:20 religion 35:21 religious 118:20 138:19 139:1 reluctant 2:9 reluctantly 180:24 rely 8:21 relying 13:21 remain 37:22 93:20 remained 132:18 remarks 15:18 20:10 71:14 73:16 remember 7:6 19:6 21:20 45:1 71:14 76:23 77:12 108:17 147:15 149:7 159:17,18,19 160:12,13 168:2 189:5 remembered 55:12 107:6 remind 1:25 93:20 Renaissance 116:23 120:20 rendered 108:13 repeat 29:24 136:23 repeatedly 8:9 26:12 112:25 180:23 181:3 repetitive 73:12 replace 127:1,4 replacement 125:19 126:22 128:13 replicated 182:1 replied 83:24 replies 40:11 145:21 191:10,11 reply 7:25 8:7 19:22 22:1,18 29:17 40:8,14 41:10,14,17 42:5 42:18 44:24 45:7 55:18 89:17 96:24 103:20 110:6 115:20,23 121:19 131:9 135:12 154:5 162:23 www.epiqglobal.com casemanagers@epiqglobal.com replying 56:23 154:5 157:20 report 6:7,8 155:3 156:14 157:9 reported 110:7 155:5 156:15 157:12,13,25 174:9,11 reports 157:15 reprehensible 143:10 192:10 represent 12:6 representation 35:20 48:14 representative 72:22 76:4 93:3 93:7 represented 1:9 representing 94:24 reproduced 94:23 175:23 reproduction 175:14 reptile 33:4 request 104:21 109:11 required 127:9 requires 176:15 research 116:21 120:18 125:11 133:3 Reservations 79:21 reshaped 132:13 resisting 165:25 167:13 resorted 35:19 respect 4:8 68:14 109:24 111:7,11 164:24 171:14,19 173:6 178:24 179:12 182:1,13 187:2 190:10,14 respective 8:19 respond 42:12 58:11,20 91:9 98:8 130:13 148:8 177:8 Lower Ground, 20 Furnival Street London, EC4A 1JS
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Day 1 Miller & Power v Turner 3 October 2023 Page 215 189:9,24 responded 144:19 145:4 159:23,25 165:20 responding 3:14 90:4 140:16 148:4 153:25 158:9 160:2,6 162:2 165:3 167:18,19 177:10 181:17 responds 43:8 response 40:21 66:9 97:6 104:20 104:21 105:3,25 147:19 151:2 161:17,24 165:4 165:13 169:20 170:18,19,23 171:1 173:25 174:8 178:5 180:1 181:22 184:1 responses 24:12 47:16 147:6 148:2 149:16,23 162:8 165:5 189:19 190:10 responsible 47:19 48:1 168:22 rest 182:7 restrict 111:21 result 56:1 166:4 resulted 146:10 resulting 97:14 99:9 resume 193:1 retard 155:17 158:11 rethink 172:13 return 93:19 retweet 45:8 retweeted 98:15 retweeting/reply... 161:21 reveal 120:6,9 139:25 141:6 revealed 112:18 179:8 Epiq Europe Ltd (+44)207 4041400 revelation 118:17 reverse 33:13 rhetorical 34:4 83:11 RICE 1:3,18 2:3,7 2:17,22 3:1 13:17 14:1,8,15 15:7 20:11,18,25 23:12,16,21 24:5 24:19 25:8 27:19 27:22 28:2,5,10 59:19,23 60:3 93:18 94:3,7 95:15,20,24 96:3 96:9,11 123:18 123:24 136:21,25 137:2,4 144:4 175:11,16,20,24 176:4,7 181:4 184:21 185:10 186:19,23 192:18 192:25 ridiculous 44:6 72:1 79:1 140:20 141:9 right 11:20 30:2,5 40:3 62:12 66:2 66:19 77:12 88:10 91:14 93:4 93:5 95:21 96:17 96:22 104:18 112:12 113:16 121:13 129:5,7 138:4 158:23 176:17 Right- 66:25 72:17 right-hand 32:19 right-wing 17:9 100:11 rise 98:2 180:23 193:1 rising 159:2 riveting 176:10 rob 117:24 rocks 65:7 Rodger 69:15,19 70:17,21,25 71:4 71:22 Rönkkö 16:17 room 20:14 74:10 89:5 round 6:21 8:16 16:4 row 49:23 50:6 ruled 19:23 Rules 158:20 run 100:24 running 168:5 runs 2:12 135:2 rush 22:19 99:9 103:25 104:17,18 105:2 105:6,16 106:5 115:11 124:24 125:5 126:1,10 126:13,18 127:7 132:8,19 133:1 139:15,22 147:9 148:20 151:12,24 154:4 159:21 161:15 162:5 164:11 165:3 S 167:9,12 168:19 sacrifice 138:18 168:23,24 169:4 safety 172:25 171:15 172:14,15 174:17,23 172:17,22 173:15 Saint 179:25 180:2 173:19,24,25 188:17,18 174:16 176:20 salute 54:3 188:7 180:3 182:4 satisfactorily 3:9 185:18 191:7 save 178:25 Scandinavians saw 64:16 111:9 126:1 saying 3:17 7:16 scary 189:1 191:7 8:2 17:1 40:18 scattered 73:15 43:5,22,23 69:23 Scherbel-Ball 1:10 82:4 83:8,12,15 Schiff 164:11 94:22 97:18 scholarly 116:10 119:12 121:6 school/Acc 56:25 124:23 159:13 scientist 130:21 166:17 167:7 scored 27:24 169:8 171:16 screaming 62:10 172:13 176:13 163:24 177:18 178:19 screen 7:19 179:7,23 182:21 screenshots 146:5 186:11 screenshotted says 27:17 28:14 54:21 30:13,19 31:23 se 83:13 84:2 32:25,25 35:18 116:13 35:25 36:5 40:7 searched 25:16 40:21 41:14 searches 56:1 42:19 43:10 searching 96:14 45:18 52:21 Sebastian 78:25 55:17 56:6 61:8 sec 44:21 66:20 67:22 second 5:6 6:21 76:21 77:2,2,3 8:1,15 24:9 86:1 78:16 79:6 81:5 90:23 105:7 81:18 82:17,21 106:25 123:5 82:24 85:7,15,18 126:13 139:13 86:3 87:12 88:3 164:15 88:25 89:3 90:12 www.epiqglobal.com casemanagers@epiqglobal.com Secondly 7:11 secret 132:12 section 19:22 30:17 192:16 security 172:23 174:16 see 1:13 2:11 20:13 21:11 22:8 27:13 28:19 29:6 30:3 30:4,6,7,19 31:1 31:24 32:21 38:18 39:1,4,14 39:19,23,25 40:11,22 41:23 43:12 45:15 48:11,13,25 50:8 50:21,23,25 51:2 52:1 53:8,15 54:1,5,10 55:14 55:17 56:3,13,22 57:15,20,20 58:23 59:4 61:22 66:18 70:19,25 77:16 83:24 84:3 85:7 90:6 94:21 94:25 98:12 103:20,24,24 104:9,20,25 106:24 108:23 121:18 137:9,11 140:4,22 141:3 146:10,14 147:6 147:16 151:11,22 152:11 154:4 158:18 159:17 160:21 161:9,10 161:12 164:17 166:10,16 168:6 168:15 169:5 175:25 176:21 177:5 179:20 180:13 183:5 186:9 188:1,4,20 189:16 191:5 193:11 seeing 39:12 159:18 189:5 seek 65:9 seeking 184:15,23 Lower Ground, 20 Furnival Street London, EC4A 1JS
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Day 1 Miller & Power v Turner 3 October 2023 Page 216 seeks 11:15 seen 49:11 75:17 83:23 101:22 105:11 106:17 122:6 126:19 128:5,8 152:5 164:5 175:1 183:3 sees 68:11 132:1 selected 92:24 190:14 selection 114:8 self 128:8 self- 107:3 125:18 126:21 self-described 169:2 self-filtering 87:13 self-replacement 125:5 126:17 semantic 49:14 Semite 182:20 191:23 semitic 33:19 168:25 174:4,10 177:23 187:10 send 16:19 48:22 51:9 53:22 99:6 Sender 184:2 Senders 184:4 sending 68:8 144:18 153:9 sends 51:23 146:20 147:5 sense 72:21 sensitive 43:6 sent 7:1 13:1 48:3 48:6 51:12 53:22 68:4 98:10 137:25 144:25 149:18 152:15,17 155:12 186:10 sentence 24:9 27:17 28:12 45:6 99:9 104:25 separates 116:20 separation 117:9 September 54:24 55:6 100:23 Epiq Europe Ltd (+44)207 4041400 106:10,21 107:7 165:15 sequence 2:24 39:12 46:16 58:8 146:2 160:22 sequencing 147:16 serial 69:19 series 4:3,4,8 83:5 147:17 152:17 161:19 162:6 170:1 182:8 serious 9:1,9 13:21 13:24,25 14:5 16:6 23:3,7 143:21 150:3 152:22 154:2 173:12 seriously 44:7 74:14 89:3 122:24 147:9 served 3:7 144:23 serves 49:19 set 3:5 76:4 sets 3:8 126:8 setting 124:9 settings 153:21 seven 8:14 152:8 sever 103:6 sexually 52:24 shape 68:17 share 101:6 106:25 136:4 shared 100:20 101:7 104:17 110:14 112:10,17 sharing 26:1 Shia 153:6 shit 176:21 shitbag 155:18 shoah'd 83:2,2 shop 156:23 short 12:1 21:4 32:21 60:6 89:7 94:1 101:17 144:7 shorter 176:16 shorthand 79:11 shortly 5:18 47:6 57:12 113:8 shoulder 52:21 show 15:5 19:19 46:16 85:2 107:20 160:22 175:8 showing 18:8 110:19 186:7 shown 187:6 shows 27:8 127:21 shut 36:14 41:9 54:14 64:11 66:8 147:10 Sickle 182:6 side 31:18 38:11 57:11 sides 132:24 sights 54:7,8 sign 22:16 62:11 signature 22:9 29:13 signed 29:9 45:2 significance 12:22 77:9 significant 170:22 182:2 significantly 98:21 signing 21:20 silly 8:4 36:1 similar 90:13,25 100:20 104:17 107:1 134:17 similarity 186:8 similarly 13:6 72:5 simple 3:21 81:22 82:9 simplistic 116:4,13 simply 3:4,18 11:12 102:3 114:20 117:1 121:5 122:13,20 142:17 163:1 177:8 182:21 sincerely 64:21 Singapore 80:1 single 47:8 98:4 113:2 141:14 186:3 sinister 189:2 sit 20:15,17 site 98:19 117:10 situation 133:18 185:7 six 69:22,25 71:4 132:2 skeleton 1:13 3:6,8 3:11 15:19,24 96:5 skin 183:17 187:4 skull 50:1 slanging 6:14 7:12 slight 105:12 slightly 21:13 93:17 slow 126:22 smart 77:2 Smashed 40:7 smear 171:23 smooth 183:17 187:3 so-called 26:14 57:5 63:20 71:6 soap 49:2,6 social 2:24 4:4,8 18:1 87:17 88:4 118:19 139:15 socialised 105:11 socialist 188:13 socialists 188:16 socializing 75:21 socially 140:7 141:4,22 society 16:20 85:10 118:16 119:11 121:10 135:8 142:3,4,8 142:18,24 sockets 186:15 Socrates 142:22 software 98:2 solicitor's 99:8 108:23 109:10 151:3 solicitors 95:8,13 96:23,25 97:1 109:1,2 113:20 solution 36:6,7 somebody 32:25 35:18 53:22 www.epiqglobal.com casemanagers@epiqglobal.com 67:16 72:5 76:19 102:22 115:11 161:13 166:2 182:9,18,19,22 188:2 191:10 somewhat 69:5 163:21 sophisticated 7:8 113:19 114:2,17 115:5,12,15,25 119:16 sorry 20:20 23:4 23:15,23 24:1 25:3 27:19,21 29:1,22,24 33:24 35:10,11 44:15 44:16,20,22 49:9 55:4 59:21 69:16 69:18 70:4 73:18 75:4,12 76:7 80:22 85:25 87:5 88:16 89:20,23 89:24 92:7 96:13 101:25 102:5 103:23 104:6,23 113:11 115:21 121:23 123:11,12 123:16 129:1 136:24 139:9 148:10 158:8,20 170:7 174:1 180:21,22 186:1 186:19,21 191:4 sort 33:4 77:20 78:20 138:11 159:2 187:13 sorted 96:18 sorts 166:16 sound 55:10 81:8 sounds 55:12 95:17 source 12:18 50:11 50:17 space 7:3 8:13 17:17 64:15 67:3 67:4 111:25 143:14 148:6,7 151:5,6 spaces 141:16 Lower Ground, 20 Furnival Street London, EC4A 1JS
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Day 1 Miller & Power v Turner 3 October 2023 Page 217 143:7,12 span 116:16 spare 172:17 spat 4:7 speak 20:24 23:3 141:15 156:24 speaker 103:6 speakers 68:3 speaking 66:20,25 101:4 111:22 157:2 speaks 5:16 8:17 species 33:15 specific 69:21 97:13 144:25 145:8 189:8 specifically 52:9 63:19 75:24 117:23 163:16 169:21 172:1 176:24 177:11 184:7 185:25 187:9 specified 5:13 spectrum 122:22 speech 11:1 65:24 65:25 66:1 69:13 165:8 178:13 speed 176:14 177:25 spend 131:17 spends 131:24 spent 120:14 spineless 162:25 167:8 spoke 113:3 spoken 2:9 140:25 spree 69:21,25 71:5 Spring 18:3 spurring 127:21 St 116:18 stage 1:23 3:25 15:8 20:23 staged 63:11 stages 125:10,21 Stalins 57:17 154:7 stance 66:24 Epiq Europe Ltd (+44)207 4041400 stand 20:17 24:16 standard 39:8,14 133:15 standing 20:13,16 62:17 stands 27:6 43:15 43:18 Star 50:25 182:5 Stars 51:16 start 14:25 23:17 57:13 59:7 77:12 103:25 121:5 126:24 144:17,21 145:17 146:19 176:19 177:17 178:8 started 58:3 107:13,17,18 113:7 153:8 159:14,21 starting 124:8 starts 30:11 39:8 40:3 83:21 96:4 103:22 104:25 144:13 167:5 183:2 state 46:25 107:2,5 130:17 stated 156:13 164:25 statement 6:4 11:8 11:18 21:18,19 23:7,8,10 24:3 29:9,16 31:14,15 32:13 34:12 42:1 43:8,9 45:2 52:8 60:23 81:14,17 81:23 82:2,8,10 82:11 85:13 99:12 103:5 114:21 128:20 129:3 130:15 135:4 138:8,11 140:16 141:9 143:21 144:23 146:24 148:16,19 149:15 150:14 156:1 158:16 159:4,22,25 162:10 163:5 165:6 166:12 173:18,18 174:5 174:25 177:15 178:24 182:15 statements 10:12 15:21,22 19:25 25:19 32:11 37:24 42:9,12 45:22,23,24 47:18 73:21,24 74:4,8,9,12 83:5 101:9 102:25 105:6 154:21 157:8 160:2 164:4 171:6,9 174:18 179:9,12 187:10 189:10 190:21,22 States 17:7 52:6 stating 19:10 stats 36:3 126:14 statue 44:1 status 71:22 87:17 88:4 133:12 134:10,17 136:3 staying 187:15 steer 105:19 Stephen 130:19 stereotype 50:4,18 stereotypical 54:6 Steven 124:25 Stevens 67:16,22 67:23 68:2,4 69:1 Stevens' 68:20 Stockoe 60:12 Stokoe 13:5 60:12 60:12,14,19,22 61:3,14,25 62:7 63:3,6 71:18 72:14,15 75:21 75:23 76:24 77:19,23 78:6,14 78:18 88:23 94:11 99:18,24 100:3,10,20 101:7,16 104:15 105:8,17 109:4 109:16,21,23 110:4,10 112:6,8 112:17,22 137:21 160:11,18 Stokoe's 94:18 103:9 stood 26:20 193:13 stop 18:12 62:23 101:12 111:1 125:9 139:16 170:7 176:12 stopped 107:22 stopping 127:14 story 64:6 69:15 70:16 180:8 strange 82:6 93:9 stressful 185:7 strictly 133:12 strong 57:7 165:24 167:13 stronger 110:11 strongly 161:22 struck 27:11 44:14 structured 142:10 142:10 student 73:1 100:15 180:2 students 35:24 study 89:4 126:8 studying 133:3 stupid 73:7 stupidly 152:1 subcultures 72:10 subheading 132:20 subheadings 127:3 subhuman 149:12 subject 1:16 12:3 17:3,19 18:14 19:20,21 95:6 132:14,18 133:5 148:21 subjected 135:15 subjective 9:8,18 9:20 10:17,21 subjects 140:24 143:18 submission 185:1 185:8 www.epiqglobal.com casemanagers@epiqglobal.com submissions 16:1 submit 3:21,22 5:20,24 6:10 7:4 8:19,22 10:18 11:14,22 12:8 13:9,12 subnormals 82:17 82:19 subsequent 62:3 64:5 110:24 117:15 164:9 173:23 182:14 subsequently 68:19 101:17 110:7 148:24 150:21 156:4 163:15 165:19 166:9 168:3 170:10 substantial 132:10 substantially 133:16 succeeding 191:21 succeeds 8:20 9:3 10:11 successful 127:13 170:21 sucking 183:14 sued 2:24 4:4,5 11:12 13:11 19:25 suffered 20:3 sufficient 10:6,9 suggest 6:23 9:22 15:11 35:16 40:25 42:16 43:4 46:8,12,22 54:7 73:5 100:4 109:14 115:11 119:7 129:20 137:19 162:24 167:11 186:5,9 187:4 189:2,3 suggesting 47:25 51:11 84:1 113:2 140:18 suggestion 3:11 suggests 31:6 85:13 130:9 Lower Ground, 20 Furnival Street London, EC4A 1JS
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Day 1 Miller & Power v Turner 3 October 2023 Page 218 suicide 75:15 suing 162:18,21 164:3 summarise 85:1 summary 2:19 85:11 138:9 summer 14:10 18:3 67:14 77:18 108:24 sunken 186:14 superimposed 48:10 49:1 superior 85:6 86:19 87:15 88:3 superiority 88:5 118:11,13 supply 28:8 support 64:17 65:19,20,25 66:2 114:24 133:19 supported 166:25 supporter 35:1 supporters 34:13 148:23 supporting 156:10 159:15 supports 13:14 65:24 suppose 41:6 supposed 49:3 103:4 142:12 156:23 supremacism 128:13 Supremacist 67:17 supreme 136:17 sure 1:23 15:20 29:1 42:24 87:5 87:8 119:19 120:16 175:18 189:13 surprising 121:18 survived 54:20 survives 155:11 surviving 38:9 suspected 39:17 suspended 108:6 109:22 155:8,8 159:2 160:23 Epiq Europe Ltd (+44)207 4041400 161:3,18 162:6 suspension 99:4 suspicious 132:21 Swastika 53:14,18 182:5 188:11 190:11,12 swastikas 18:5 50:7 sworn 21:9 symbol 31:13 43:15 168:12 symbols 50:7 182:8 sympathetic 65:21 sympathisers 17:8 symposium 119:23 Syria 39:17 systems 6:7 161:8 166:19 175:10 176:11 179:21 180:20 181:14 186:2,21 table 6:22 8:16 taboos 106:6 142:10,24 tabs 67:8 tactic 35:19 tag 7:24 8:7 tagged 55:19 177:7 tagging 154:5 177:11 Tags 176:10 take 7:19 15:14 20:21 27:2 38:21 42:19 43:3 44:7 54:15 55:13 T 58:21 61:12 tab 2:21,21 3:4 66:14 68:12 4:10,16 6:2,6,9 74:14 76:5 94:12 6:25 14:25 21:16 101:18 111:25 21:22 22:5 24:4 117:17 122:24 27:4,14 28:24 124:5 134:20 29:3,4,4,23,25 139:19 142:14 31:17 33:8,25 144:4 151:14 35:7 38:12 44:14 155:20 160:7 44:17,22,24 167:5 178:20 47:21 54:15 taken 66:5 85:4 58:21 61:21 97:7 190:23 66:15 68:13 69:8 191:23 76:6,7 78:8 takes 25:19 35:17 80:23 82:15 124:19 180:10 83:17 84:14 talk 62:15 76:18 88:16,17 89:20 76:21 93:22 89:21,22,25 92:6 105:8,14 117:25 92:7 94:5,13 119:14,15,16 95:13 96:2,4,8,15 126:6 96:18,22 103:21 talking 35:23 104:3,3,5,23 56:16 67:13 105:25 109:1 76:16 86:21 110:18 113:10 87:21 102:6,7 115:20,22 121:20 119:9 126:12 123:3,10,12 147:8 131:1,7 135:12 talks 106:1 136:19 137:1,14 tardiness 12:12 139:8 145:17,20 target 65:16 161:6 151:14,17 153:12 164:9 166:5 157:18 159:10 targeted 19:8 26:18 147:18 156:21,24 159:14 159:22 160:1 163:7 164:14 167:17 185:20,22 186:10 targeting 113:7 148:3 161:1,25 162:1 164:19,23 166:1 167:15 tattoo 53:19 team 124:23 128:18,23 techniques 83:12 170:1 technological 86:5 technology 86:10 tell 37:11 43:17 54:23 55:16 91:6 92:7 110:15 139:9 143:21 146:25 157:25 165:10 172:13 173:16 telling 173:3 temperate 168:16 temporarily 161:18 162:5 tend 30:16 87:25 tendencies 147:2 tenor 149:14 term 41:8 63:21 64:2 72:3 133:4 138:17,21 158:5 terminal 125:4 127:1 terms 2:6 9:10 10:1 17:11 35:20 49:14 57:8 75:9 83:13 86:11 98:22 101:19 103:16 109:25 111:5 118:16 171:7,8 terrible 89:15 terrified 18:10 terrorist 67:19 test 10:1 14:4 www.epiqglobal.com casemanagers@epiqglobal.com text 94:21 95:9 97:9,11,13,14 98:5,10,12,18 99:5,9,13 thank 13:16,18 14:1,13 15:17 20:12 21:2 26:23 28:10 31:16 32:18 35:2 43:3 44:9 46:12 56:13 66:13 70:10 93:18 94:7 95:24 96:11 123:24 137:4 176:5,7 185:16 186:23 193:11 Thanks 152:3 theme 3:22 73:15 92:20 93:1 124:19 187:2 themes 63:12 64:22 66:3 theories 116:3 140:8 141:5 theory 56:10 81:7 81:19 97:2 113:19,25 114:2 114:5,7,15,16,18 114:18,20 115:5 115:17,25 117:22 118:5,7,7 128:13 129:17,19 140:13 140:15 141:10 Thielo-Bannonist 93:10 thing 8:1 34:5 43:10 69:5 89:15 120:9 135:21 136:12 190:1 193:3 things 26:10 40:18 41:1 74:13 77:3 83:13 104:19 111:13 119:5 133:24 143:5,6,7 143:12,13,16 152:21 166:16 171:2 think 1:11 2:8 Lower Ground, 20 Furnival Street London, EC4A 1JS
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Day 1 Miller & Power v Turner 3 October 2023 Page 219 14:22 22:24 23:4 27:3 28:6,22 31:14 34:12,19 34:21,25 35:3 36:10 37:10 38:12,19,23 41:5 42:25 43:2,8,25 44:7,12,20 47:2,6 47:12,18 49:3,13 52:3 53:6,18 54:4 57:3,5 60:14 61:11,16 62:3 63:13,13 64:1 67:4,5 68:2 68:23 69:1,2 72:2,10,21 73:22 74:13,20 75:18 76:3,17,25 78:11 78:20 80:6,10,18 80:19 81:14,17 81:22,23 82:9,12 83:12,21 84:13 86:25 87:9 88:5 88:7,8,25 89:5 91:10 93:6,8,15 94:20 95:12 97:24 98:17,20 99:12 100:7 101:1,15 102:23 102:25 103:9 105:15 108:16,25 111:17,22 112:9 114:13,16 115:14 118:2 119:14 122:9,16 123:18 128:15,25 129:10 129:13 130:14,23 131:8,22 133:14 134:5,6 135:9,21 135:24 137:23 138:6,9,10,15,23 139:4 140:19 141:13 142:4,5,7 147:14 150:1,22 152:5 153:13,15 153:19 154:16,24 157:8,12 158:2 159:3 160:7,20 161:21 163:20 Epiq Europe Ltd (+44)207 4041400 166:19 168:10 169:11 171:11,17 172:12,20 173:2 173:5,15,16,17 173:18 175:22 177:16 178:4,11 179:1 180:11 181:13 182:10,20 182:22 185:19,23 186:3,4 189:9,16 189:24 190:16,17 190:21 191:17 192:3 193:4 thinker 69:2 122:13,25 thinking 77:4 79:17 101:21 120:15 131:24 159:19 thinks 86:13 88:2 third 56:4,22 59:12 97:12 126:2 171:10 third-party 22:2 thought 11:16 62:13 65:16 72:23 73:6 75:25 78:25 79:1 99:5 117:3,7 140:19 150:16 154:18 157:6 158:10,15 179:11 182:15 thoughtful 98:25 thoughts 68:25 thread 30:8 38:17 39:11 45:12,19 45:21 46:16 57:4 70:7 161:4 167:6 169:5 172:7 175:6,12 177:8 177:10 183:2,25 184:1 188:25 threads 145:13 146:5 threat 7:15 162:13 164:10 threaten 174:16 threatened 156:22 157:1 threatening 48:22 51:23 53:21 62:10 163:25 threatens 173:24 threats 4:11,15,20 4:24 5:5,7,19,22 12:1 19:18,18 172:24 174:17,22 three 84:25 125:9 125:10,24 155:15 161:10 threshold 10:1,7 10:19 16:7 threw 65:7 time 2:12 8:8 17:16 18:17 21:7 24:24 25:14 33:12 35:13 36:20 49:11 62:15 63:23 76:13 94:12 99:2 101:15,18,18 104:16 106:23 108:11 109:2 111:23 112:22 120:15 147:12 150:11 154:10,15 156:13 157:16 159:17 163:14 178:18,21 179:3 181:15 182:16 192:15,19,23 times 48:4 113:4 175:23 timetable 176:15 timings 2:6 153:19 tip 152:4 tired 111:15 title 70:8 today 126:3 134:18 142:9 181:3 told 89:5 92:4 127:25 134:21 182:18 tomorrow 192:21 193:2 tongue 140:17 157:1 top 21:16 30:7 33:11 34:1 35:8 35:17 39:9,13 40:6 56:3,15 59:4 67:21 70:23 76:15 78:10 91:7 113:16 124:24 139:24 141:5 145:21 146:4,20 151:22 161:10 179:23 181:16 191:6 topic 84:24 112:6 119:6 120:15,19 133:14 136:9,10 136:14 144:10 152:20 184:10 topics 116:25 142:11 Torin 36:4 tort 10:9 Totalitarian 58:16 totally 32:9 152:18 168:16 town 124:10,11 trace 116:18 track 169:25 Traditionalist 168:21 170:4,5 170:17 174:12 trails 170:2 trait 31:12 transcribed 76:9 transcriber 2:2,8 59:22,24 143:25 transcript 181:7 transcription 15:3 transcripts 15:2 transgender 57:7 transgressing 106:6 transgressive 73:8 traumatized 163:22 traumatizing 163:23 treating 87:7 trial 1:21 2:14 4:13 5:14 15:8 www.epiqglobal.com casemanagers@epiqglobal.com 16:3 19:19 20:7 111:15 114:24 174:21 triangulating 170:2 triangulation 121:9 tried 111:21 triggered 151:13 152:9 156:19 159:9 163:20 trio 16:16 17:20 53:1 trope 43:18 46:5,8 tropes 45:11 46:1 46:2 trouble 171:20 180:25 true 19:20 22:14 22:15,17 36:24 41:8 45:18,20 57:24 59:7,11 61:20 86:17 103:15 125:6 129:14 134:7,9 140:1,11 142:8 163:8 168:14 169:19 truism 17:5 Trump 16:15,22 52:18 63:25 64:5 70:8 166:25 trust 125:15,16,24 126:4 143:17 truth 9:10 21:19 29:9,16 45:2 104:13 158:1 173:4 177:4 179:3 try 11:22 28:23 100:1 119:16 176:14 181:14 trying 23:23,25 102:18 143:2 177:14 189:24 191:20 Tuesday 1:1 turn 23:19 27:4 28:22 39:9 47:21 Lower Ground, 20 Furnival Street London, EC4A 1JS
1 Miller031023Nick Land / text
P. 76
Day 1 Miller & Power v Turner 3 October 2023 Page 220 48:7 49:21 61:21 76:6 87:11 108:25 124:20 126:16,20 130:25 131:8 139:6 146:13 155:1 160:7 172:5 turned 124:13,15 turner 1:9 7:2,5,21 7:24 8:2,7,14 16:13,15,17 17:20,24 18:10 18:13,21 19:2,7 19:19 20:1 48:14 49:23 50:19,22 51:16 57:17 112:16 113:6 144:18 146:7,19 151:25 152:8,16 152:18,25 153:7 154:6,23 155:4 157:4,20,21 159:13 161:1,13 161:15 163:1 167:7,11 168:16 168:19 169:8 172:8,10,22 176:20,24 177:7 178:4,5 180:2 181:20 183:4,21 185:20,21,22 186:11 187:17,24 188:19 Turner's 48:11 49:1 96:25 104:13 148:15 151:11 162:23 165:13 188:24 turning 3:16 4:17 6:23 18:4 turns 35:21 82:3 TV 127:20 TWCS 125:2 tweet 6:24 7:1,2 24:10 31:22 34:3 45:8 46:25 56:16 57:12 137:6,25 139:2 146:7,20 146:21 147:1,5 Epiq Europe Ltd (+44)207 4041400 147:19 150:24 153:15 154:24 155:16 156:2,5,7 157:19 160:3 168:15,19 178:3 178:17 179:16 180:17 186:4 188:23 tweeted 39:16 152:9 tweeting 33:14 82:16 tweets 4:3,17 5:21 5:25 19:13,15 38:6,8 39:2 47:4 47:9 57:13 77:13 83:20,23 102:2,3 102:4,6 107:25 144:10,11,18,25 145:9 146:2 147:17,17,18,23 148:17,21,24 149:14 151:12,24 152:15,18 155:4 155:12,21,23 156:16,16 157:10 157:12,23,24 158:2,12 160:22 161:11 176:11 178:24 179:2 187:18 189:16 190:20 Twisted 69:14 70:5,16 71:12 twitter 4:3,7 6:19 7:7 8:10 12:6 17:25 19:11 28:15,17 30:8 36:18 40:19 47:10 58:2,5,7,10 59:8 73:5,9,17 74:8 81:2 92:11 98:22 99:4,5 100:2 101:10 106:4 107:14 108:5,17 109:21 110:2 145:13 146:12 149:21 152:1 153:17 155:3,5 160:24 164:18 167:1,2 two 10:3 39:24 40:22 41:1,12,20 49:2 53:24 83:16 83:21 84:21 88:24 90:15 94:24 119:5 125:23 166:24 TWP 169:3 type 185:24 types 17:21 41:1 typical 82:12 unconscious 159:6 undermine 30:20 understand 1:20 2:4 3:19 13:19 16:11 20:19 32:6 42:1 49:5,10 60:23 61:4,5,10 64:25 65:1 70:15 71:9 72:20 85:21 89:15 93:24 97:17 110:8 112:24 114:6 120:13,24 121:4 121:7 136:10 U 145:2 146:2 U/acc 57:6 150:23 155:13 ugly 25:22 164:17 169:20 Uh-huh 44:18 45:3 170:24 174:7 45:14 48:12 178:1 181:10 52:23 53:12 54:9 193:10 54:11,16 55:24 understandable 56:8 57:2,16,18 192:3 58:24 59:6,18 understandably 89:2 90:7,16 18:10 92:5,13,15,17 understanding 131:16 137:16 69:6 72:9 90:10 139:12,20 145:24 93:5 100:22 152:12 155:2 111:18 UK 126:10,10 understands ultimately 18:12 143:14 21:8 89:11 understood 22:22 103:10 112:2 45:24 47:10 116:18 119:6 65:23 78:3 117:3 178:8,10 117:4,21 158:4 Um 176:22 178:14 163:17 170:11 187:21 unfair 177:16 unable 12:18 unfortunately 18:12 17:4 94:19 unacceptable unhappiness 71:9 141:22 192:1 unhappy 72:6 unanimous 132:19 Union 124:22 unashamed United 17:7 52:6 128:11 universities 35:25 unattractive 12:5 university 36:2 unaware 168:20 unknown 22:2,22 unbelievably 40:21 179:13 unnecessary 3:24 uncommon 3:22 11:4 unconditional unpacking 35:18 57:6 www.epiqglobal.com casemanagers@epiqglobal.com unpainful 145:15 unpleasant 191:16 191:20 unprovoked 161:19 162:7,9 163:7 164:24 165:4,6,25 173:10 Unqualified 79:20 unquestioning 132:13 unsupportable 65:17 unsustainable 191:12 unsympathetic 107:1 unthinkingly 174:6 untrue 46:13 163:5 165:6 unusual 134:12 unwilling 150:19 Unz 35:21 36:3 131:19 134:18 135:13,14 137:10 137:21,23 Unz's 134:3 update 14:25 updated 24:11 95:18 uploading 123:16 upper 87:25 88:1 upset 42:13 upsetting 189:21 URL 39:13 use 15:10 26:16 127:11 145:25 useful 5:23 76:1 190:11 users 70:13 169:25 usual 116:6 usually 115:11 V vacuousness 7:23 value 78:4 178:12 vandalizing 65:7 variants 56:12 variety 52:14 Lower Ground, 20 Furnival Street London, EC4A 1JS
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Day 1 Miller & Power v Turner 3 October 2023 Page 221 109:6 122:4 154:7 various 48:4 63:15 99:23 104:19 114:9 187:18 189:4 varying 131:20 veered 185:19 ventured 84:13 Venus 33:2 verbosity 3:23 vermin 33:15 version 27:13 28:6 vicinity 62:6 vicious 182:21 viciously 163:13 victims 48:9 49:5 video 18:7 68:4,6 70:22,24 videos 15:2 view 9:8,18,20 10:21,22 48:2 81:10 82:12 86:13 107:5 131:13 133:25 134:12 136:3 140:5 141:24 views 28:19 74:2,3 75:25 76:4 100:6 100:20,22 101:6 101:7 103:17 104:18 105:4,20 107:1 110:14 112:10 113:4 118:10 122:13 131:12 134:25 135:13,18,19,22 135:25 184:9 Viking 78:17,17 vile 18:14 vindictive 171:13 Violating 158:20 violence 19:18 26:16,18 65:14 65:16 72:4 162:13 172:16 174:4 violent 5:4,7,9,10 66:10 130:17 Epiq Europe Ltd (+44)207 4041400 169:2,24 172:23 virus 183:18 visited 149:18 150:18 156:7 visually 15:5 visuals 39:22 volume 2:20 3:3 4:10,16 6:2,6,9 6:25 14:24 volumes 21:12 voting 63:25 warmonger 146:12 warn 25:25 warning 5:16 134:23 warrior 7:17 washing 49:6 wasn't 51:11 58:7 62:10 63:7 72:19 78:19 99:2 101:2 140:14,15 158:8 163:11 W waste 154:10,15 Wade 124:3 way 7:16 11:23 wait 69:17 96:19 16:4 17:19 25:22 103:23 34:16 42:13 43:4 WALKER 1:5,20 43:22 45:8 47:13 2:5,14,18,23 3:2 49:10 50:16 51:5 13:23 14:7,12 66:4 76:22 81:25 20:20 21:2,6,10 82:3 85:14 100:1 23:15,19,22 24:7 100:8 108:13 24:14,21 25:1,10 118:1 119:17 42:6 92:3 180:22 121:4 124:20 181:10 184:11 136:4 138:10 185:1,16 141:8,23 142:5,5 wall 16:25 74:10 142:22 145:8 want 15:14 22:23 148:13 149:23 27:11,16 28:13 158:14 159:3 36:14 40:2 46:1 164:18 167:12,22 47:19,23 48:2 170:20 174:20 54:17 56:3 59:1 182:2 184:25 59:9,15 60:17 189:4 67:11 72:20 ways 16:1 73:7 74:25 75:2,5 79:2 90:10 76:8,14 84:21 we're 80:20 94:10 95:4,18,20 162:21 184:10 98:23 107:2 191:14 119:14 120:13,25 weapon 115:15 128:14 130:22 wearing 52:18 132:3 134:21 web 190:3 145:25 161:21 webpage 4:3 24:9 171:20 173:19 24:11 25:14,18 176:12,13 177:16 26:6,9,14,20 178:10 193:8 website 24:22,25 wanted 26:5 37:22 94:17,18 107:11 37:23 71:3 151:1 135:2 150:6,9,11 187:22 192:8 Wednesday wants 1:16 8:5 193:16 174:14 week 175:4 War 71:11 weeks 133:2 weight 133:11 weird 72:1 weirdly 159:13,21 welcome 56:7 126:23 welcoming 126:19 went 48:5 63:3,3,5 63:6 65:2,17 117:11 160:17 weren't 77:24 120:4 137:22 West 126:3 128:7 western 68:10 116:17 117:2,7 125:3,17 130:8 133:21 WhatsApp 76:9 78:8 79:5 88:11 106:18,24 108:19 108:20 110:17,22 110:25 113:14 119:17 120:1 123:2 131:1 139:7 151:15 WhatsApps 108:1 113:10 whatsoever 26:3 whilst 77:15 white 67:16 82:17 82:19 94:20 124:16 127:18 128:13 139:22 140:7,13 141:25 179:24 186:12 wholly 13:21 161:19 162:6 wide 52:14 widely 25:17 37:4 widening 124:3 125:1 126:2 widespread 135:16 wild 64:19 wildly 55:10 William 183:23 184:3,9 willing 49:15 62:15 105:8,13 www.epiqglobal.com casemanagers@epiqglobal.com willingly 6:15 12:4 102:21 window 40:8 windows 65:8 wine 52:20 Wing 67:1 72:18 wish 1:22 20:9 120:23 125:18 128:8 wished 102:3 withdraw 150:2,19 withdrew 27:10 witness 11:8 15:22 21:18 23:5,7,8,10 24:2,3,7,24 25:10 27:23 28:7,12 29:7,7 60:23 94:9 96:13 144:23 146:24 148:16 155:25 166:12 178:24 181:6 184:12 185:8 193:13 woke' 172:18 wolf 12:23 woman 82:1 women 71:10,11 73:11,15 75:25 wonder 42:6 139:15 181:1 184:17 word 33:16 127:11 158:11 words 4:12 54:8 85:5 97:21 140:6 149:12 work 16:22 26:1 68:8 70:20 79:25 80:14 98:21 105:17 122:18 170:4 174:11 185:6 Worker 168:22 170:5,5,17 174:12 working 77:19 88:22 116:22 120:19 works 100:16 Lower Ground, 20 Furnival Street London, EC4A 1JS
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Day 1 Miller & Power v Turner 3 October 2023 Page 222 164:18 world 17:4,5 69:14 70:6,16 71:13 88:10 103:3 118:8 129:25 141:17 147:3 190:8 worriedly 160:1 worry 77:15 80:3 146:15 worst 18:16 25:19 worth 72:11 worthless 154:25 worthy 121:16 122:7,10,15,23 wouldn't 73:25 84:6 152:5 wrangling 79:7 write 68:1 73:8 74:9,12 writer 83:9,10 124:2 128:17 writing 67:18 76:1 77:25 79:19 writings 84:12 91:3,4 written 12:16 37:10 52:21 58:15 68:23 90:12,24 91:1,19 91:23 98:9 124:25 149:19 wrong 36:3 44:21 44:22 137:19 155:25 162:17 165:18 167:16 179:1 wrote 67:23 71:7 91:8 146:9 X Y Yarvin 79:19,21 80:8 Yarvin's 80:14,15 yeah 173:1 year 19:1 year-old 118:18 years 68:25 75:18 Epiq Europe Ltd (+44)207 4041400 107:7 122:22 124:11 132:10 133:8 yoga 111:6 York 16:23 young 7:14 youth 142:25 YouTube 6:20 Z zombie 158:23 0 03 1:1 04 193:16 1 1 2:20 3:3 4:10,10 4:16,16,16 6:2,9 6:25 27:3 32:20 44:10 47:22 89:18,24 95:13 96:15 103:21 108:25 115:22 153:12 10 5:15 21:1 75:18 96:23 163:2 10-minute 20:23 10,000 68:24 10.29 1:2 10.30 193:2,15 10.56 21:3 100% 92:16,19 93:12 1000 124:11 101 40:8 1025 145:18,20 1028 146:15 1029 146:16,20 151:10 1033 159:10,12 1035 161:8 1036 162:22 1039 166:10,19 175:14,15 1040 172:6 1041 179:22 106 92:6,9 109 24:2,6,7 11.06 21:5 11.3 103:21,25 11.30 113:16 11:41 131:2 113 54:25 118 38:12 12.01 60:5 12.10 60:7 12.57 93:25 124 186:2 13 22:5 34:1 105:25 13:50 151:24 131 76:6,8 88:14 88:17 110:18 113:10,12 123:3 137:14 139:8 151:14,18 136 48:8 138 49:22 139 50:21 14 21:22 24:12 71:4 14.01 94:2 14.10.1 104:1,9 14.2.1 27:12,16 28:3,4 14.32 78:12 14:41 152:7 140 51:14 141 52:1 187:16 143 53:11 1434 123:6 144 53:25 145 54:5 145-page 11:8 14th 59:3 15 121:14 15-odd 132:10 15.09 144:6 15.18 144:8 1529 6:6 155 7:1 153:12 156 155:1 158:21 16 19:11 123:6 16.21 193:14 160 6:3 161 7:11 162 6:3 166 7:15 169 7:19 17.2 121:20 122:1 17.3 44:14,25 45:4 46:13 1737 54:20 55:14 1738 55:15 1741 55:14 1742 55:23 56:4 1744 56:13,14 1749 57:10 1776 91:4 1778 29:23 30:2,4 178 8:1 1788 30:6 17th 186:6 18 104:20 105:25 107:21 18.9 135:11 18.9(a) 115:20 116:1 18.9.K 90:3 1815 31:17 137:3 137:13 18th 139:14 190 8:6 1970 32:19 1990s 126:12 19th 117:19 189:14 2018 18:25 30:8 31:20 32:20 54:19,24 55:6 56:16 58:6 74:16 74:21 78:9 100:23 106:10 110:22,23 111:10 113:7,15 131:2 137:8,18 139:14 144:14 145:21 151:23 2019 19:4,6 33:11 34:1 57:25 59:1 59:3 94:19 99:24 107:11,14 112:8 191:2 2020 19:4 2021 35:7 2023 1:1 96:24 193:16 206 94:13 21 33:11 21:47 140:4 210 6:3 2143 139:14 2186 33:9 22nd 67:10 24 30:8 35:7 155:9 2 159:13 2 4:18 6:1,6 38:23 241 44:24 121:20 58:21 61:21 121:24 145:17,20 153:13 243 103:23 157:18 186:21 244 103:21 104:24 2.00 93:19 249 15:1 2.34 151:13 24th 56:16 20 94:19 160:14 25 110:23 200- 118:17 2571 35:6,11 2011 67:20 258 115:22 2014 71:5 84:18 259 135:12 2015 81:10 25th 54:23 55:5 2016 63:17,21 71:1 61:16 82:17 83:25 26-27 145:21 2017 16:14,24 18:3 260 89:22 90:1 36:17 38:23 273 127:6 54:19,24 55:5 27th 146:8,15,18 61:17 72:13,13 151:22 153:18 84:1 99:24 160:9 100:10 112:8 28 110:22 164:1 186:7 www.epiqglobal.com casemanagers@epiqglobal.com Lower Ground, 20 Furnival Street London, EC4A 1JS
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Day 1 Miller & Power v Turner 3 October 2023 Page 223 284 106:1 287 22:6,8 28th 77:10 157:19 159:12 160:9,18 29 21:16 24:4 31:20 290 21:23 22:6,12 2979 81:1 2991 83:17 2992 83:22 29th 76:15 110:22 131:1 137:8,18 160:15 165:20 3 3 4:21,22 29:21,23 54:15 85:9 136:18,19,24 3001 70:18 3008 70:19 3009 70:23 3082 67:12 3087 66:15 30th 161:9 162:22 176:11 179:22 315 92:4 3161 92:9 3212 39:10 3213 38:14 3214 38:14,15 3393 33:22,25 349 84:14 35 3:4 36 2:21 3654 186:3 3691 151:16,20 3694 76:8,14 37 2:21 3724 113:12 118:22 3725 120:17 121:12 3746 123:1 3760 139:7,11,14 3761 140:22 141:13 3786 130:25 137:17 38 95:14 96:8,16 109:1 Epiq Europe Ltd (+44)207 4041400 3872 78:7 88:14,19 39 6:9 96:4 191:4 3913 187:16 188:1 3916 188:10 3917 188:22 3918 191:2,5 4 4 4:25 19:22 38:12 66:14 80:23 92:1 92:6 123:22 125:18 126:17 40 58:21 61:21 157:19 175:10 176:11 180:20 181:14 186:21 41 145:17,20 159:10 179:21 42 21:18 422 123:19 423 123:10,12,22 124:1 424 131:7 4261 124:9 4262 124:21 125:11 4265 125:22 4267 126:9 4269 126:16 4277 127:24 428 123:20 4280 128:2 4286 128:4 435 15:1 4563 94:13 48 6:6 4chan 70:7,10,12 5 5 5:4 27:4 29:4 44:14 76:5 88:13 113:10,11,12,15 121:14 136:19 137:14 139:8 151:14 186:2 187:16 50 57:17 154:7 51 29:23,25 33:25 54:15 136:20 137:1 52 33:25 5481 84:22 5482 87:11 5A 28:24 29:3,4 44:12,17 94:5 123:10,11,12 131:7 135:12 9.43 157:20 91 66:15 92 104:3,4,5 955 58:22 6 97 146:24 6 5:6 21:25 22:1,11 98 148:19 149:5 94:12 104:3,3,5 6332 132:7 683 106:1 6th 54:24 55:6 7 7 5:7 47:21 84:12 106:18 70 80:24 70s 127:12 730 109:1 74 82:15 75 27:8,8 759 95:14 96:16 99:8 76 83:17 765 96:5 77 67:20 79 68:13 69:8 7th 78:9 8 8 5:10,11 6:2 7:1 153:12 80 27:15 80M 27:14,16 80S 29:10 80X 28:25 849 61:22 862 157:19 866 175:10 176:11 867 183:2 186:22 868 181:14 89 67:8 8chan 186:5 187:6 187:9 9 9 5:13 14:24 44:24 89:20,21,22,25 103:21 104:23 115:20,22 121:20 www.epiqglobal.com casemanagers@epiqglobal.com Lower Ground, 20 Furnival Street London, EC4A 1JS