The following comes from the testimony yesterday (Oct. 31) in the San Francisco trial of Planned Parenthood vs. David Daleiden of the Center for Medical Progress. Daleiden made secret videos of the organization’s abortionists and released them in July, 2015.

The questioning is by Daleiden attorney Harmeet Dhillon.

Q. And I want to ask you a few questions about how you made it. First of all, did that identification have a photograph on it?

A. Yes, it did.
Q. And what age were your when that photograph was taken?
A. I was 15 when that photograph was taken. That is my original — my original photograph from when I first got my driver’s license.

Q. And how did — what equipment did you use to make the identification that we’re describing being used to attend these conferences?

A. So the question was what equipment?
Q. What equipment did you use?

A. I used a — a home ink jet printer. It was maybe three or four years old at that point.
Q. Was it a color printer?

A. It was a color DPI printer.

Q. And that’s a dot matrix type printer?

A. That’s correct.

Q. And what kind of paper did you use for the identification?
A. As I recall, it was basic copy paper.

Q. And so did you use some software to make the document?

A. I believe I used a basic — like, a basic Paint or Illustrator program.

Q. Okay. And did you — after printing this document, this — there is a front and a back; correct?

A. That’s correct.

Q. And did you do anything to make this document more secure, like laminate it?
A. Yes. I laminated it with a home laminator kit from Office Max.

Q. Did you trim the laminated document?

A. Yes. I — prior to laminating it, I cut the — I cut the — you know, the mock-up picture of the ID out of the copy paper with — by hand with a pair of scissors, and then I trimmed the lamination with a pair of scissors as well after that.
Q. Okay. And we’ve seen photocopies of this document before. Do you recall it having a black strip on the back?

A. It had a — a black strip printed onto the back as well with just black printer ink, yes.
Q. And that’s something you printed as well in the same process that you just described; correct?

A. That’s correct.
MS. DHILLON: Your Honor, I’d like to approach the witness with this document and ask him to identify it for the record.
THE COURT: All right. Show it to counsel.
MS. DHILLON: I believe I’ve shown it to counsel previously.
(Document was shown to the counsel and then tendered to the witness.)

Q. I’m going to ask you a question.
Mr. Daleiden, can you take a look at what I’ve just handed you and identify it for the record?

A. Yes. This is — this is the actual mock photo ID for Robert Sarkis that I used for all the conferences at issue in this case….

Q. Mr. Daleiden, when you were making this identification, did you do anything to check about the propriety of making this document that you intended to use with respect to the project?
A. Yes, I did.

Q. What did you do?

A. So I actually — before creating it or constructing it, I actually called the local police department, the Huntington Beach Police Department, and I told them that I needed to have a prop photo ID basically for a filming project. And I said I don’t want to run afoul of any laws about counterfeiting documents or forging anything, and so I said, you know, can you guys let me know kind of like where do the boundaries lie with something like that?
And they told me, well, we can’t give you legal advice, but they said what we can tell you is that — is that for us, the crime in using a fake ID has to do with the way that it’s used. If it’s used for an actual government purpose, like purchasing an age restricted item, like alcohol or cigarettes, or trying to register to vote or presenting it to a police officer at a traffic stop.
They said for just a regular movie kind of filming project, that’s an artistic use and that’s not something that’s going to involve any fake ID laws.


Q. Have you ever seen, when attempting to get into a bar, a book that a bouncer refers to to check the validity of the type of ID that’s being presented?

A. Yes, I have.

Q. Okay. Did you ever attempt to test how good this ID was prior to using it in this project?

A. I tested it during the project at one point actually.

Q. Can you describe what happened when you tested this document?

A. Sure. There was a — there was one evening after the — after the Forum conference in Miami, and so I tried to use — to use the Robert Sarkis photo ID to enter the bar in Miami. The bouncer took one look at it. I don’t know that he even shined his flashlight on it. He just looked at it, and he laughed, and he handed it back to me and said: Get lost. Get out of here.

Full transcript of 10-31-19