The Deposition of Jon Lines
January 6, 2025
Foreword
Before you read the deposition,
This is no longer about Operation Underground Railroad and Tim Ballard’s mythology. It will become immediately clear that this is not the polished version of events that has been sold to the public.
If we are to be serious for a moment, there is at least one fact that cannot be evaded: Sound of Freedom was a false bill of goods, marketed through a Christian and conservative media apparatus that elevated a fantasy of human trafficking into accepted truth, long after years of warnings to the contrary.
This is about people.
It is about young women and victims of sexual abuse whose allegations, across parallel proceedings, records, testimony, and our reporting, describe exploitation, grooming, and institutional failure. It is about individuals who claim they were harmed, then ignored, minimized, and in some cases further abused.
It is also about victims of fraud and deception: donors, supporters, and the public who were sold stories of heroism, flawless execution, and success, and are now confronted with sworn testimony, corroborated by our reporting, that raises serious questions about whether Ballard’s narrative was ever grounded in reality.
At the center of this deposition is a different kind of examination:
Not just what happened, but how decisions were made.
This is about Tim Ballard’s integrity, experience, and leadership under pressure:
- how dissent was handled
- how risk was assessed
- how operations were conducted
It is about whether decisions were guided by:
- professional standards
- integrity
- personal conviction
- or something else entirely
Because woven through this testimony are claims that go beyond ordinary judgment, including references to intuition, spiritual prompting, and what some may interpret as belief in extraordinary or divinely guided capabilities.
And Jon Lines’ sworn testimony raises the unavoidable questions that I have asked since day one, January 2020:
Were any children rescued?
Were legitimate rescues actually carried out, and to what extent?
What methods were used? Were they lawful, effective, or theatrical?
How many children were rescued and actually helped versus how many stories were told?
Where did the millions of dollars go, and how were they used?
These are not rhetorical questions. They are obligations.
This deposition puts Jon Lines on the record, and it can no longer be ignored.
His testimony, corroborated by our reporting, official statements, and additional testimony, forms a blueprint that now demands answers from municipal, state, and federal law enforcement, from the LDS Church, and most importantly, from Tim Ballard.
-Damion Moore
How to Read This Document (Without Getting Lost in It)
This deposition is formatted in what can only be described as a bureaucratic obstacle course:
- Each PDF page contains four separate transcript pages
- The correct reading order is: Top Left → Bottom Left → Top Right → Bottom Right
Ignore that order, and you will misunderstand the record. Full stop.
Every entry in this index follows a strict citation format:
[PDF page . Transcript page] — Title
Followed by a direct summary of what Jon Lines actually says
No embellishment. No editorializing inside the index itself. Just the record.
Who’s in the Room
From the actual appearance page:
For the Plaintiff:
- Mark L. Eisenhut — Call & Jensen (Newport Beach, CA)
For the Defense:
- Suzette Rasmussen — All Utah Law (Salt Lake City, UT)
- Alan W. Mortensen — Mortensen & Milne (Salt Lake City, UT)
Also present:
- Jon Lines — Witness
- Court Reporter
- Gavin Bohne — Videographer
This matters. Depositions are adversarial by design. The questions are not neutral, and neither are the objectives behind them.
What You’re Actually Reading
This is Jon Lines, former Homeland Security Investigations (HSI), later executive inside Operation Underground Railroad. Lines is laying out, under oath, what he saw, what he did, and what he believes happened. You will notice that Lines’ testimony not only corroborates Vice News and Lynn Packer & I’s reporting from 2020-2024, but what was happening behind the scenes.
Not everything he says is proven, but much of what he says is corroborated by ACJ and Vice News reports. But everything he says is on the record.
This is about the victims. This is about Ballard’s decision-making under pressure, and how dissent was handled. This is about his integrity. This is about the children.
Index
[2.4] — Lines identifies himself under oath
Lines states his name for the record and confirms he has been sworn.
[2.4–5] — Lines acknowledges obligation to testify truthfully
Lines confirms he understands he is under oath and must provide truthful answers.
[2.5] — Lines begins describing his federal law enforcement background
Lines states he began his career with the Immigration and Naturalization Service under the Department of Justice.
[3.6–7] — Lines describes investigating immigration-related crimes
Lines states he investigated immigration violations including illegal entry, document fraud, and smuggling.
[3.7–8] — Lines states involvement in human trafficking and smuggling cases
Lines states his work included investigations involving human trafficking and alien smuggling.
[3.8–9] — Lines states he held supervisory roles over investigations
Lines states he supervised agents and oversaw investigative operations.
[4.10] — Lines states he joined Operation Underground Railroad in 2016
Lines states that he joined OUR in 2016.
[4.10–11] — Lines states he served as executive vice president of operations
Lines states his role at OUR was executive vice president of operations.
[4.11–12] — Lines describes overseeing operations and personnel
Lines states his responsibilities included overseeing operations, personnel, and ensuring operations were conducted properly.
[5.14] — Lines states Ballard claimed experience beyond what Lines understood
Lines states that Tim Ballard claimed experience and background that exceeded what Lines understood him to have.
[5.14–15] — Lines outlines qualifications required for undercover work
Lines states that undercover work requires certifications, law enforcement experience, and ICAC-related experience.
[5.15–16] — Lines states Ballard lacked expected qualifications
Lines states Ballard did not meet certain qualifications he would expect for undercover operations.
[6.18–19] — Lines states he had extensive experience in child exploitation investigations
Lines states he had significant experience investigating child exploitation cases.
[6.19–20] — Lines states he supervised ICAC-related work
Lines states he supervised work connected to Internet Crimes Against Children task forces.
[6.20–21] — Lines states concerns about Ballard were communicated to him
Lines states that others raised concerns to him regarding Ballard’s conduct and abilities.
[7.22] — Lines states he began receiving interest from Tim Ballard while serving as ASAC
Lines states that while he was an Assistant Special Agent in Charge, Tim Ballard began reaching out to him about coming to OUR.
[7.22–23] — Lines states he was actively leading task forces at the time
Lines states he was leading task forces and working cases when Ballard approached him.
[7.23] — Lines states he was not seeking to leave Homeland Security Investigations
Lines states he was not looking to leave HSI at that time.
[7.24] — Lines recounts a direct conversation where Ballard asked him to join OUR
Lines states Ballard asked him to come over and help OUR.
[8.26] — Lines states Ballard said OUR needed credibility and expertise
Lines states Ballard told him OUR needed subject-matter experts and credibility.
[8.26–27] — Lines states Ballard told him he would bring instant credibility
Lines states Ballard said he would bring instant credibility to the organization.
[8.27–28] — Lines states he was told he would help guide and structure operations
Lines states Ballard indicated he would help guide operations and bring structure.
[8.28–29] — Lines states he observed concerns about how operations were conducted
Lines states that once involved, he observed practices that raised concerns.
[9.30] — Lines states prayer and spiritual impressions were used in decision-making
Lines states that prayer and impressions believed to be from God were used in operations.
[9.30–31] — Lines states decisions were sometimes guided by perceived divine direction
Lines states decisions were sometimes based on what individuals believed God was telling them.
[9.31–32] — Lines states he was uncomfortable with this approach
Lines states he was uncomfortable relying on spiritual impressions for operational decisions.
[9.32–33] — Lines states Ballard expressed belief that God was directing operations
Lines states Ballard expressed that God was guiding certain operational actions.
[10.34] — Lines states he raised concerns about operational strategy
Lines states he raised concerns about how operations were planned and conducted.
[10.34–35] — Lines states raising concerns created conflict with Ballard
Lines states that raising these concerns created tension between him and Ballard.
[10.35–36] — Lines states his concerns were not always accepted
Lines states that his concerns were not always received or acted upon.
[10.36–37] — Lines states Ballard believed he could act outside formal authority
Lines states Ballard believed he could operate without traditional law enforcement authority.
[11.38–39] — Lines states Ballard reacted strongly when challenged
Lines states that when he challenged Ballard, Ballard reacted strongly.
[11.39–40] — Lines states Ballard raised his voice and became angry
Lines states Ballard raised his voice and became angry during disagreements.
[11.40] — Lines states Ballard told him to “grow a backbone”
Lines states Ballard told him to “grow a backbone” during an exchange.
[11.40–41] — Lines states Ballard yelled and used aggressive language
Lines states Ballard yelled, used aggressive language, and pushed back on his concerns.
[11.41] — Lines states Ballard’s anger and behavior were significant enough to recall clearly
Lines states Ballard’s anger and conduct during those interactions stood out to him.
[12.43–44] — Staff identified Tim Ballard as both a major strength and the organization’s biggest problem
Lines states that during the SWOT process, employees independently described Ballard as a powerful communicator and fundraiser but also identified him as the organization’s greatest weakness and threat. He explains that concerns included staged operations, illegitimate conduct, focus on movie-related promotion, and behavior seen as not aligned with the organization’s mission.
[12.44–45] — SWOT findings were withheld out of fear of Ballard’s reaction
Lines states that the results of the SWOT analysis were not shared with Ballard or the board because leadership believed Ballard would react aggressively. He explains that the findings were effectively shelved and not acted upon due to fear within the organization.
[12.45] — Internal culture described as toxic and protected by board structure
Lines states that the organization operated in a toxic environment driven by fear of Ballard, and that the board structure, which he describes as largely connected to Ballard, allowed him to operate without meaningful oversight. He explains that employees felt frustrated because they believed in the mission but saw leadership as a hindrance.
[13.46] — Lines describes workplace as more hostile and fear-driven than any prior federal experience
Lines states that he had never experienced a workplace environment as toxic as OUR, describing hostility, fear, and reluctance to report issues. He explains that employees feared retaliation and being blindsided, particularly when Ballard justified decisions using religion or divine guidance.
[13.46–47] — SWOT results believed to still be traceable despite not being implemented
Lines states that although he does not recall the consulting firm’s name, the SWOT analysis and its findings should still exist. He expresses that he would be interested in whether the donor was ever informed that no action was taken.
[13.47] — Lines states he had no control over finances or HR while serving as EVP of Operations
Lines explains that despite his executive title, he did not control financial resources or human resources decisions. He states that financial matters were handled by others, while he focused on operational integrity.
[13.47–48] — Lines states Ballard conducted and directed operations without his knowledge
Lines states that Ballard would send teams on operations, including international missions, without informing him. He explains that this occurred despite his role overseeing operations and that these actions were conducted in secrecy.
[13.48–49] — Lines identifies Paul Hutchinson as an early operational concern
Lines states that Paul Hutchinson was one of the first individuals brought to his attention as problematic. He explains that Ballard used Hutchinson in operations and described him as a major donor, but Lines was told internally that Hutchinson had not actually donated funds.
[13.49] — Lines states Hutchinson had no law enforcement or undercover qualifications
Lines states that Hutchinson had no law enforcement background, no undercover training, and no legitimate basis to participate in covert operations. He explains that Hutchinson nevertheless participated in operations with groups of associates.
[13.49] — Lines states he learned of operations through social media rather than internal channels
Lines states that in some instances he only became aware of operations when participants publicly posted about them on social media. He explains that this contradicted the expectation that such operations should be covert.
[13.49] — Lines describes Hutchinson-linked activities as social behavior rather than legitimate operations
Lines states that, based on what he observed and was told, these activities resembled “bar hopping” and visiting red-light districts rather than structured anti-trafficking operations.
[14.50] — FBI agent informed Lines that Paul Hutchinson was under investigation
Lines states that shortly after joining OUR, an FBI agent contacted him and asked whether he knew Hutchinson. He explains that the agent indicated Hutchinson was under investigation and associated with OUR.
[14.50] — Lines states Ballard identified Hutchinson as one of his operatives
Lines states that when he asked Ballard about Hutchinson, Ballard described him as one of his operatives. Lines explains that he immediately raised concerns about legal exposure for the organization.
[14.50–51] — Lines states he intervened to address legal risk related to Hutchinson
Lines states that he used his professional reputation and engaged legal assistance to manage the situation involving Hutchinson. He explains that he sought to mitigate potential legal consequences for the organization.
[14.51] — Lines distinguishes between early investigation and later allegation involving a juvenile
Lines states that the initial investigation involving Hutchinson related to an operation in Mexico and was separate from a later allegation involving inappropriate contact with a juvenile.
[14.51] — Lines states Ballard minimized allegation involving contact with a juvenile
Lines states that Ballard dismissed the allegation involving Hutchinson and a juvenile as insignificant and provided an explanation that the contact occurred under pressure from a trafficker during an operation.
[14.52] — Lines states he instructed Ballard to stop using unqualified individuals in operations
Lines states that he told Ballard not to send unapproved or unqualified individuals into operational environments and emphasized the need for his approval.
[14.52] — Lines states Hutchinson allegedly engaged in inappropriate conduct involving a donor representative
Lines states that he later learned Hutchinson allegedly groped a representative from a major donor organization during a trip to Haiti, which required Lines to address the issue directly with that donor.
[14.52–53] — Lines states Hutchinson’s group operated independently and without oversight
Lines states that Hutchinson and his associates operated in a manner that was internally referred to as the “naughty boy club,” describing behavior where individuals acted without control or oversight from leadership.
[14.53] — Lines states he repeatedly told Ballard to remove Hutchinson from operations
Lines states that he advised Ballard multiple times to remove Hutchinson from involvement due to ongoing concerns, but Ballard refused and continued to support him.
[15.54–55] — Lines states video evidence existed of incident involving juvenile
Lines states that he learned video footage existed documenting the incident involving Hutchinson and a juvenile and that such footage was created as part of internal “sizzle reel” recording practices.
[15.55] — Lines states video contradicted explanation provided by Ballard
Lines states that upon reviewing the footage, it did not support the explanation that Hutchinson’s actions were forced by a trafficker, and instead showed Hutchinson initiating the contact.
[15.55–56] — Lines states he arranged for video to be preserved and sent to authorities
Lines states that he ensured the footage was copied, preserved, and transmitted to appropriate authorities in Mexico for review and potential action.
[15.56] — Lines states authorities declined to pursue charges
Lines states that after reviewing the footage, Mexican authorities chose not to pursue charges, although he emphasizes that the matter was taken seriously.
[15.56] — Lines states Ballard continued to associate publicly with Hutchinson
Lines states that despite the incident, Ballard continued to publicly support Hutchinson and presented him as a key figure in the organization.
[15.56–57] — Lines states Hutchinson later connected to Sound of Freedom
Lines states that he later became aware that Hutchinson was an executive producer of Sound of Freedom, which he believed explained Hutchinson’s continued involvement.
[15.57] — Lines denies mismanagement of organizational resources
Lines states that criticisms of his handling of resources were inaccurate, explaining that he did not control finances and that expenditures were approved through proper channels.
[16.58] — Lines states “couples ruse” as used by Ballard was not legitimate
Lines states that based on his experience, the “couples ruse” described in reports was not a legitimate or acceptable law enforcement technique.
[16.58–59] — Lines states HSI did not create or use the “couples ruse”
Lines states that during his time at Homeland Security Investigations, such a tactic was not used, and that claims suggesting otherwise would be incorrect.
[16.59–61] — Lines outlines required qualifications for undercover operations
Lines states that legitimate undercover work requires formal training, certification, psychological evaluation, and specific personal attributes including emotional stability, adaptability, and the ability to operate safely in high-risk environments.
[17.62–63] — Lines states proper undercover work requires strict psychological and situational screening
Jon Lines explains that individuals used in undercover operations must be carefully evaluated for mental stability, judgment, and ability to operate under stress, stating that not everyone is suited for such work and that improper placement of individuals into those roles creates serious risk.
[17.63] — Lines states no legitimate agency would place unqualified individuals into high-risk undercover roles
Lines states that it would be inappropriate for any legitimate agency to place civilians or unqualified individuals into situations involving danger or criminal environments, emphasizing that such decisions require professional judgment and training.
[17.64–65] — Lines acknowledges that undercover work carries inherent risks but must be controlled through training and oversight
Lines explains that undercover work can involve danger, including risk of violence or harm, but states that those risks are managed through training, planning, and structured oversight, which he implies was lacking in the situations he is describing.
[17.65] — Lines states decision-making regarding personnel should be based on qualifications, not opportunity or convenience
Lines states that selecting individuals for undercover roles must be based on their qualifications and ability to perform, not simply availability or situational factors.
[18.66] — Lines states investigations must be conducted with evidence-based methods, not assumptions
Lines explains that investigations should be based on evidence and structured methodology, not speculation or assumptions about individuals or situations.
[18.66–67] — Lines states law enforcement must determine whether individuals are victims before acting
Lines states that investigators must first determine whether someone is a victim before taking action, emphasizing that acting without that determination can lead to improper outcomes.
[18.67] — Lines states proper investigations require structured process and verification
Lines explains that law enforcement must follow structured investigative processes, including verifying information and ensuring decisions are supported by evidence.
[18.68] — Lines states “couples ruse” lacks foundation in legitimate law enforcement practice
Lines states that he is not aware of the “couples ruse” being used as a legitimate tactic and does not recognize it as part of standard law enforcement methodology.
[18.68–69] — Lines states he has no personal knowledge of law enforcement using strip clubs to qualify victims
Lines states that he is not aware of law enforcement using environments like strip clubs as a method to identify or qualify victims, indicating that such approaches are not part of his professional experience.
[18.69] — Lines states OUR did not operate within structured anti-trafficking frameworks used by law enforcement
Lines explains that legitimate anti-trafficking operations typically involve structured frameworks such as child protection systems and coordinated law enforcement efforts, and indicates that OUR did not operate within those same frameworks.
[19.70–71] — Lines states misuse of law enforcement credentials can violate agreements and policies
Jon Lines explains that law enforcement credentials are governed by strict rules and that misuse of those credentials, including representation outside authorized purposes, can violate agreements and legal standards.
[19.71] — Lines states concerns were raised about the use of credentials in OUR-related activities
Lines states that concerns were brought to his attention regarding how credentials may have been used in connection with OUR activities, suggesting potential issues with compliance.
[19.72] — Lines states information about credential misuse came from another law enforcement official
Lines explains that he was informed by another law enforcement officer that misuse of credentials had occurred, and that this raised concerns about how operations were being conducted.
[19.73] — Lines states communication was sent warning that conduct was inappropriate
Lines states that a communication was issued within the law enforcement community warning that certain conduct was inappropriate and should not continue.
[20.74] — Lines states claims about OUR using certain systems were not supported by his knowledge
Lines explains that claims regarding OUR’s use of specific law enforcement systems or methods were not consistent with what he knew or observed.
[20.75] — Lines states he does not have access to certain internal information or records
Lines states that he does not have access to certain internal materials and cannot confirm specific details about claims being made.
[20.75] — Lines states some claims would require verification through official records
Lines explains that verifying certain claims would require access to official documentation or reports that he does not possess.
[20.76] — Lines discusses concerns related to narratives being presented publicly
Lines explains that certain public narratives did not align with what he knew internally, indicating discrepancies between internal knowledge and external claims.
[20.76] — Lines states some stories were later questioned or could not be confirmed
Lines explains that certain stories or representations were later found to be problematic or lacked confirmation.
[21.78] — Lines states some operational narratives involved emotional or exaggerated elements
Lines explains that certain stories presented publicly involved emotional framing or exaggeration that did not fully align with underlying facts.
[21.78–79] — Lines states the “Gardy” Haiti narrative was presented in a way that did not align with actual intelligence
Lines explains that the story involving “Gardy,” a Haitian child described as missing and in urgent danger, was communicated in a way that generated strong emotional response, but that the underlying intelligence and facts did not support the narrative as it was being presented.
[21.79–80] — Lines states the “Gardy” operation narrative reflected broader concerns about accuracy in operational storytelling
Lines explains that the Gardy situation became an example of how operations were described in ways that did not match internal understanding, reinforcing his concern that narratives were being shaped for impact rather than grounded in verified facts.
[21.80–81] — Lines states external pressures influenced how cases like “Gardy” were communicated publicly
Lines explains that donor expectations, media attention, and public pressure influenced how stories such as the Gardy case were framed and presented externally.
[21.81] — Lines states internal concerns about narratives like “Gardy” were not disclosed publicly
Lines explains that despite internal awareness that the Gardy narrative did not align with actual events, those concerns were not communicated externally, contributing to a gap between internal knowledge and public messaging.
[21.80] — Lines states pressure existed from external sources influencing operations
Lines explains that external pressure, including from media and public expectations, influenced how operations and information were presented.
[21.80–81] — Lines states internal concerns were sometimes not disclosed publicly
Lines explains that despite internal awareness of issues, those concerns were not always communicated externally.
[21.81] — Lines identifies individuals involved in operations and communications
Lines references individuals including Tevya Ware and others involved in operations and communications, indicating their roles in coordination and messaging within the organization.
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[21.82] — Lines states internal leadership prioritized protecting Ballard’s image over addressing concerns
Lines explains that leadership resisted confronting issues involving Tim Ballard because they believed challenging him would disrupt fundraising and donor confidence, and instead focused on maintaining stability and avoiding external scrutiny.
[21.83] — Lines states board documentation and oversight may not have formally existed
Lines states that he is unaware of any board meeting minutes or formal documentation of governance actions and indicates that recordkeeping and oversight may have been informal or nonexistent.
[21.83] — Lines identifies Tevya Ware as CFO responsible for financial control and resource allocation
Lines explains that Tevya Ware served as chief financial officer, controlled funding and resources, and worked closely with him in allocating funds for operations and programs.
[21.84] — Lines states he was aware of sexual harassment allegations raised by Tevya Ware against Tim Ballard
Lines states that he was aware of some allegations involving sexual harassment raised by Tevya Ware, describing her as capable and credible, and explains that she approached him regarding difficulties occurring within the organization.
[21.84–85] — Lines describes Tevya Ware raising internal concerns about workplace issues involving Ballard
Lines explains that Tevya Ware privately approached him to discuss problems occurring in the office related to Tim Ballard, indicating that concerns were serious enough to be raised internally but not resolved.
[21.85] — Lines identifies Brad Damon as an individual brought into OUR by Ballard who later rose to leadership
Lines explains that Brad Damon was brought into the organization by Tim Ballard, initially in an unclear role, and later became a senior figure, despite Lines having limited interaction with him.
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[22.86–87] — Lines states Tevya Ware described Brad Damon as physically inappropriate in the workplace
Lines explains that Tevya Ware told him Brad Damon would try to hug her and that she did not want physical contact. Lines says Ware described Damon making her uncomfortable and that Lines told Ware she had the right to refuse any unwanted contact.
[22.88–89] — Lines states Cherstyn Stockwell brought Deliah from New York to testify without proper preparation
Lines states that Cherstyn Stockwell appeared after bringing Deliah, whom he describes as a trafficking victim, from New York. He says Deliah was disheveled and unprepared, and that Stockwell expected Deliah to testify in a critical federal trial without adequate preparation or resources.
[22.88–89] — Lines states Deliah was not rescued by OUR
Lines states that Deliah was not someone OUR rescued. He explains that Deliah had been subpoenaed to testify before Congress and that she was later brought into the matter through Tim Ballard, Tevya Ware, David Jacobs, and others.
[23.90–91] — Lines states Tim Ballard made vulgar comments about women and objectified female employees
Lines states that David Jacobs and Tim Ballard made comments about women’s appearances during the Deliah-related trip. Lines says Ballard lowered his head to view a woman’s backside, made vulgar comments, and later made inappropriate comments about a female employee.
[23.91–92] — Lines states Tevya Ware helped get Brad Damon fired after workplace complaints
Lines explains that Tevya Ware brought concerns about Brad Damon to his attention, including issues involving women in the workplace. Lines says Damon was later fired and that he worked under Lines at OUR.
[23.92–93] — Lines states Tevya Ware reported sexual harassment by Tim Ballard
Lines states that he and Tevya Ware discussed harassment by Ballard and that Ware was angry that nothing had been done after she reported concerns. Lines says Ware told him she had been harassed by Tim and that organizational leadership did not meaningfully respond.
[23.93] — Lines states Tevya Ware was fragile and vulnerable after harassment and Haiti-related events
Lines explains that Tevya Ware was widowed, emotionally fragile, and deeply affected by both alleged harassment by Tim Ballard and what she had witnessed in Haiti. Lines says he respected her and viewed her as a wonderful human being.
[24.94–95] — Lines states Tevya Ware witnessed a suspicious Haiti operation involving a child
Lines states that Tevya Ware attended an operation in Haiti that she did not initially know she would attend. He says Ware witnessed an operation involving a Haitian child and believed something was wrong with how it was being handled.
[24.94–95] — Lines states Tevya Ware believed the Haiti operation was orchestrated and staged
Lines explains that Ware told him the Haiti operation appeared orchestrated, videotaped, and repeated for effect. Lines says Ware believed the child was not a real victim and that the event was staged to create footage.
[24.95–96] — Lines states Tim Ballard attacked Tevya Ware after she raised Haiti concerns
Lines states that after Ware raised concerns about Haiti, Ballard became enraged, accused her of lying and mental illness, and tried to undermine her credibility. Lines says Ballard used the same type of accusations against others who challenged him.
[24.96–97] — Lines states Tevya Ware’s concerns about Haiti reached leadership
Lines explains that Tevya Ware reported concerns about Haiti to Kelly, who was chairman of the board at the time. Lines says he and Ware later spoke with Nathan Richardson, who told him Ware’s report was one reason Ballard believed Ware had to be kept quiet.
[24.97] — Lines states Tim Ballard feared Tevya Ware because she knew too much
Lines states that Ballard wanted Ware kept quiet because she knew “all types of things,” including what happened in Haiti. Lines says this fit a broader pattern of Ballard trying to silence or discredit people who knew damaging information.
[25.98–99] — Lines states his departure from OUR was retaliatory
Lines states that he never heard directly from the board or received formal notice before being placed on administrative leave. He says he understood from others that the action was retaliatory because he “got to the core.”
[25.98–99] — Lines states Ballard accused him of jealousy but Lines says he tried to help OUR
Lines states that Ballard suggested Lines was motivated by jealousy, but Lines rejects that explanation. Lines says he cared about the mission, leveraged his reputation to help OUR, and tried to correct problems rather than advance his own agenda.
[25.99–101] — Lines states Ballard staged a disguise interview to make himself look like a secret operative
Lines describes a staged interview where Ballard allegedly claimed he needed a disguise because a cartel boss or handler recognized him. Lines says he knew the claim was false and says Ballard wanted the setup because he had a tendency to lie to make himself look important.
[25.101] — Lines states Ballard’s disguise was theatrical rather than justified
Lines states that Ballard’s disguise was not justified by operational danger and was instead theatrical. He says Ballard allegedly exaggerated cartel-related claims for dramatic effect.
[26.102–103] — Lines denies misusing OUR funds or operational resources
Lines states that he never received any indication that he wasted or misused organizational resources. He explains that the programs he created were funded by legitimate requests and were designed to build OUR’s infrastructure, training, legal capacity, forensic capabilities, and operational coordination.
[26.103–104] — Lines states Ballard’s public criticism damaged his reputation
Lines explains that Ballard’s public accusations about misuse of funds and resources harmed him personally and professionally. Lines says he felt insulted and damaged because he had worked to build legitimate programs while Ballard focused on movies and staged operations.
[26.104–105] — Lines states Ballard’s public criticism affected him emotionally and personally
Lines states that Ballard’s accusations took a serious emotional, physical, psychological, and spiritual toll on him and his family. He says Ballard caused reputational harm and that he felt betrayed after advocating for Ballard.
[27.106–107] — Lines states employment and severance-related documents were created during internal conflict
Lines explains that documents relating to employment status, severance, and organizational control were created during a period of internal conflict, reflecting disputes over authority, leadership roles, and the direction of the organization.
[27.107] — Lines states Tim Ballard’s role as founder and CEO was central to decision-making authority
Lines explains that Tim Ballard held primary authority within the organization as founder and CEO, and that his position allowed him to exert significant control over operations, personnel decisions, and strategic direction.
[28.108–109] — Lines states board structure did not function as an independent oversight body
Lines explains that the board did not operate as an independent governing body and that its structure limited meaningful oversight of Tim Ballard’s actions and decisions.
[28.109] — Lines states leadership dynamics allowed Ballard to operate with minimal accountability
Lines explains that internal leadership dynamics enabled Ballard to act without meaningful checks, reinforcing concerns about governance and accountability within the organization.
[29.110–111] — Lines states individuals close to Ballard held influential roles within the organization
Lines explains that individuals with close personal or professional ties to Tim Ballard held positions of influence, contributing to concerns about independence and internal control.
[29.111] — Lines states concerns existed regarding the role of Kelly Wilson in leadership structure
Lines explains that Kelly Wilson was involved in leadership decisions and board-level matters, and that questions arose regarding the effectiveness of governance and oversight.
[30.112–113] — Lines states references to M. Russell Ballard contributed to perceived legitimacy of the organization
Lines explains that references to M. Russell Ballard (no relation to Tim Ballard) were used in ways that enhanced perceived legitimacy and credibility of the organization among supporters and donors.
[30.113] — Lines states association with prominent figures influenced donor confidence
Lines explains that connections or perceived connections to prominent individuals increased donor confidence and contributed to the organization’s ability to raise funds.
[31.114–115] — Lines states internal concerns included allegations of fraud, waste, and misuse of resources
Lines explains that internal concerns extended to issues of fraud, waste, and misuse of organizational resources, reflecting broader dissatisfaction with how the organization was being managed.
[31.115] — Lines states donor-related concerns involved expectations versus actual operational practices
Lines explains that donor expectations regarding operations and outcomes did not always align with what was actually occurring internally, contributing to concerns about transparency and accountability.
[31.116–117] — Lines states internal discussions addressed the handling of external narratives and representations
Lines explains that leadership discussed how narratives were being presented externally, including concerns about accuracy and consistency with internal knowledge.
[31.117] — Lines states discrepancies between internal knowledge and public messaging persisted
Lines explains that differences between what was known internally and what was communicated publicly continued without resolution during his tenure.
[32.126–127] — Lines states David Stelting withdrew support after concerns involving Tim Ballard and OUR
Lines explains that David Stelting had strong concerns about OUR leadership and Paul Hutchinson, and that Stelting distanced himself from both Paul and OUR because of those concerns.
[32.126–127] — Lines states Ballard’s leadership harmed OUR’s mission
Lines explains that OUR “fell terribly short” because of Ballard’s leadership and says the organization could have operated more effectively with independent leadership and governance.
[32.127–129] — Lines states nepotism and cronyism allowed Ballard to run roughshod over OUR
Lines explains that Ballard surrounded himself with loyalists who allowed him to run roughshod over finances, resources, policy, and opposition, and that this weakened accountability inside OUR.
[32.128–129] — Lines states Janet Russon acted as Tim Ballard’s personal psychic and was on OUR’s payroll
Lines explains that Janet Russon was known to him as Tim Ballard’s psychic, that she provided psychic guidance before Lines arrived, and that Tevya Ware told him Russon was paid through OUR’s payroll.
[32.129–130] — Lines states he found archived leads sent to Janet Russon
Lines explains that after learning Russon was allegedly on payroll, he reviewed archives and found a stack of leads sent to Russon involving missing children, alleged trafficking, and suspected exploitation.
[33.130] — Lines states Janet Russon did not respond to trafficking-related leads he forwarded
Lines explains that he forwarded some archived leads to Janet Russon as a test and says he was still waiting for a response.
[33.130–131] — Lines states he did not know Janet Russon’s qualifications and was unaware of legitimate agencies using psychics
Lines explains that he had no idea what training Russon had and says he was not aware of legitimate law enforcement agencies using psychics on payroll for operational intelligence.
[33.131] — Lines states he knew of no actual rescues connected to Janet Russon’s psychic abilities
Lines states that he was aware of zero actual rescues that occurred because of Janet Russon’s claimed psychic abilities.
[33.131–132] — Lines states concerns about Janet Russon were raised by Kelly and Matt Osborne
Lines explains that Kelly and Matt Osborne raised concerns about Janet Russon, including that Tim Ballard asked Matt to submit to a psychic reading because Russon supposedly had special powers.
[33.132] — Lines states Janet Russon’s payroll status appeared to be for Ballard’s personal emotional support
Lines explains that, from what he understood, Russon was on payroll not for legitimate operational intelligence but as Tim Ballard’s personal psychic and emotional-support figure.
[33.132–133] — Lines states the Haiti operation relied on psychic intelligence and was ineffective
Lines explains that he was told about a Haiti operation involving JR D’Agostino, who reportedly said the operation was ridiculous, dangerous, and driven by psychic intelligence that led nowhere.
[33.133] — Lines states JR D’Agostino left after the Haiti operation
Lines explains that JR D’Agostino, described as a former Navy SEAL, participated in the Haiti operation before Lines joined OUR and then left after that operation.
[34.134] — Lines states Janet Russon should not have been entrusted with intelligence for high-stakes anti-trafficking operations
Lines explains that unless Russon was being paid by donors who knowingly supported that purpose, using her for intelligence in anti-trafficking operations was not judicious or thoughtful.
[34.134] — Lines states Russon’s involvement put people and victims at risk
Lines explains that he was aware of an account from JR D’Agostino in which people “almost killed” themselves, and says reliance on Russon raised concerns about risk to trafficking victims and OUR staff.
[34.134–135] — Lines states Ballard’s reliance on Janet Russon contributed to broader concerns about OUR’s operational integrity
Lines explains that internally, people questioned why Ballard relied on Russon, while externally he did not know how many people knew about the issue.
[34.135] — Lines states he viewed using unqualified people like Janet Russon for critical roles as irresponsible
Lines explains that he considered it very irresponsible for an organization claiming legitimacy to use unqualified individuals such as Janet Russon for critical roles.
[34.135–136] — Lines states he regrets not leaving OUR sooner
Lines explains that he wishes he had left earlier and not associated himself with the organization once he saw the problems, though he says he does not regret the good work he believes he accomplished there.
[34.136–137] — Lines states he wanted Ballard kept on a tight leash
Lines explains that he would have liked more candid conversations with the board about Ballard and wanted Ballard kept on a tighter leash because of the problems he believed Ballard created.
[35.138–139] — Lines states he retained Rasmussen and Mortensen as counsel for the deposition
Lines explains that Rasmussen and Mortensen represented him only for purposes of the deposition, and that he wanted communications sent directly to him first.
[35.139–141] — Lines states he met attorneys after receiving a subpoena and later orally engaged them
Lines explains that he met with the attorneys after being subpoenaed, initially did not participate unless subpoenaed, and later had an oral engagement with them after the meeting.
[35.141] — Lines states he had not paid the attorneys for representation
Lines states that he had not paid the attorneys for their representation.
[36.142–143] — Lines declines to answer whether he agreed to pay the attorneys
Lines declines to answer whether he agreed to pay the attorneys for representation, citing advice of counsel.
[36.143] — Lines states he sought representation because he was concerned about Tim Ballard’s maliciousness
Lines explains that he retained counsel because he knew how malicious Tim Ballard could be and wanted representation if attorneys came to visit him.
[36.143–144] — Lines states he had a 24-year government career and was more qualified than Ballard in undercover operations
Lines states that he had a 24-year government career and viewed himself as highly more qualified in undercover operations than Tim Ballard during Ballard’s government tenure.
[36.144–145] — Lines states his FBI undercover training was more intensive than HSI training
Lines explains that he received intensive FBI undercover training and says it was much more extensive than HSI undercover training, based on comparison with agents who had attended both.
[37.146–147] — Lines states he did not know the full extent of Tim Ballard’s undercover training
Lines states that he believed Ballard received some required training before coming to Salt Lake City, but he did not know the full extent of Ballard’s training.
[37.147–148] — Lines states Ballard appeared underqualified during a West Wendover lead
Lines explains that he took Ballard on a trafficking-related lead in West Wendover, Nevada, and based on their conversations, concluded Ballard had not done extensive undercover work and appeared underqualified.
[37.148] — Lines states the West Wendover case was not conducted
Lines states they did not proceed into the suspected business after meeting with police and gathering additional intelligence.
[37.149] — Lines states Ballard worked ICAC in Calexico and falsely claimed CIA operator experience
Lines explains that Ballard worked with the Internet Crimes Against Children Task Force in Calexico, but Lines says Ballard later claimed to be a CIA operator, which Lines states was false.
[38.150–151] — Lines states Ballard misrepresented his CIA affiliation while at OUR
Lines explains that Ballard had been an unpaid CIA intern, but later described himself in ways Lines considered false, misleading, and confusing to the public.
[38.151–152] — Lines states he told Ballard to stop misleading people about CIA experience
Lines states that he told Ballard to stop describing his CIA background in a misleading way, but did not report him to any agency or make a clear written complaint.
[38.152–153] — Lines states he heard Ballard misrepresent CIA affiliation multiple times
Lines says he heard Ballard discuss his CIA affiliation in a misleading way approximately a dozen times and remained affiliated with Ballard and OUR afterward.
[39.154] — Lines states Ballard’s claims of being a CIA operator were false
Lines explains that although he could not remember every exact statement, he knew Ballard’s claims of being a CIA operator were false.
[39.154–155] — Lines states Ballard had prior ICAC involvement before Salt Lake
Lines confirms that before Ballard worked under him in Salt Lake City, Ballard had been affiliated with the Internet Crimes Against Children Task Force.
[39.155–156] — Lines states Melissa Reese supervised ICAC involvement in Salt Lake
Lines explains that Melissa Reese, his first-line supervisor, handled HSI’s involvement with the ICAC task force and remained Ballard’s supervisor when Ballard came to Salt Lake.
[39.156] — Lines states he had not withdrawn from ICAC
Lines clarifies that any mistrust issue involved a different SECURE Strike Force, not ICAC, and says ICAC agents remained an integral part of their work.
[39.156–157] — Lines states he was not aware of a Child Sex Tourism Jump Team
Lines states that, as far as he knew, a Child Sex Tourism Jump Team did not exist, and that he had never heard of either a domestic or international trafficking jump team.
[40.158] — Lines states two Calexico agents said Ballard was never on an international trafficking jump team
Lines states that Lance Swanson and Mike Harvey, who worked with Ballard in Calexico, told him Ballard was never on an international trafficking jump team.
[40.158] — Lines states the only comparable group he knew was ICAC
Lines explains that when asked about a claimed Child Sex Tourism Jump Team of approximately twenty agents, the only group he recognized was the Internet Crimes Against Children Task Force.
[40.159–160] — Lines states overseas child exploitation cases could be prosecuted in the United States
Lines explains that legislation allowed U.S. citizens who committed child exploitation crimes overseas to be tried in the United States, which he describes as critical to international child exploitation work.
[40.160] — Lines states HSI used attaché offices and case-based agent deployments, not a “jump team”
Lines explains that agents could be sent overseas to assist attaché offices or foreign partners, but he says this was not called a jump team.
[40.161–41.162] — Lines states he did not know whether Ballard received Washington, D.C. or Cyber Crimes Center training
Lines states that he did not know whether Ballard received training in Washington, D.C. or at the Cyber Crimes Center, though he believed Ballard likely received Federal Law Enforcement Training Center exposure to undercover principles.
[41.163] — Lines states he did not know whether Ballard received jump-team undercover training
Lines states that he did not know whether Ballard received undercover operative training tied to any alleged jump team while Ballard was in Calexico.
[41.163–165] — Lines describes Ballard’s role in a Honduras/Nicaragua operation
Lines explains that a trafficking report involving Honduras led to a plan to establish jurisdiction in Salt Lake City, and that Ballard and Brandon Crane were sent to assist. Lines says the operation was successful, with Nicaraguan law enforcement arresting people, while the attaché office and local vetted operatives had the primary role.
[42.166–167] — Lines states he knew Steve Cass but did not know if Cass was an informant
Lines explains that he knew Steve Cass, but did not know whether Cass was an informant connected to the operation, and says Cass had a terrible reputation.
[42.167] — Lines states he did not know whether Ballard originally received information from Steve Cass
Lines states that he did not know whether Tim Ballard was the person who originally received information from Steve Cass.
[42.168–169] — Lines states he helped connect Ballard and Brandon Crane with Carlos Demara
Lines explains that under his direction, he helped Tim Ballard and Brandon Crane make contact with Carlos Demara in the attaché office so Demara could evaluate whether the information was legitimate.
[42.168–169] — Lines states Ballard and Crane would not have gone without his authorization
Lines states that Tim Ballard and Brandon Crane would not have gone on that matter unless Lines had authorized them to continue and work the case.
[42.169] — Lines states Ballard had more involvement in conducting the investigative work
Lines explains that Ballard had more of a role than Lines in conducting the investigative work, while Lines describes himself as an overseer of the case.
[42.169] — Lines states he could not identify everyone in the attaché office who worked the case
Lines states that he did not know who all worked on the case in the attaché office.
[42.169] — Lines states Brandon Crane described Ballard’s role as limited
Lines explains that Brandon Crane told him Ballard’s role was limited, and Lines understood that to mean there was no extensive undercover work or deep infiltration.
[43.170–171] — Lines states he did not know whether Ballard used the name Brian Black or had direct trafficker contact
Lines states that he did not know what name Ballard used, whether he had direct contact with a trafficker, or whether Ballard was the primary undercover operator.
[43.170–171] — Lines states he did not know the final results of the operation
Lines states that he did not know whether seven traffickers were arrested or how many women or children were rescued.
[43.171] — Lines states even a significant role would not make Ballard a trafficking expert
Lines explains that even if Ballard had performed the role described by counsel, that would not qualify him as an expert in human trafficking or make him more accomplished than other agents.
[43.172] — Lines states Ballard’s operation was described to him as a limited one-time meet
Lines explains that a current Special Agent in Charge told him Ballard’s involvement was limited, meaning a one-time meet without costumes, a couple ruse, or a female partner.
[43.173] — Lines states Ballard posed as a sex tourist but in a limited capacity
Lines explains that Ballard went over and posed as a sex tourist, which Lines acknowledges is an undercover operation, but he says it was done in a very limited capacity rather than as a long-term undercover role.
[44.174] — Lines states Ballard worked under him for about a year and a half
Lines explains that Ballard was under his supervisory chain for approximately a year and a half and left in 2013.
[44.174–175] — Lines states he does not believe Ballard trained others in Colombia while under his supervision
Lines states that he does not believe Ballard trained others on undercover operations in Colombia during the period Ballard worked under him, though he believes Ballard said he had done some training there.
[44.175] — Lines states international ICAC training was routine and not exceptional
Lines explains that agents regularly performed international ICAC training, and that such work was routine rather than something that made Ballard uniquely qualified.
[44.175] — Lines states Ballard’s expert claim was false
Lines states that Ballard’s claim of being an expert in these cases was false, describing Ballard’s work as routine and comparable to what other ICAC agents did.
[44.175] — Lines states he is not an anti-trafficking expert and does not view Ballard as one
Lines states that he is not an anti-trafficking expert and says there are people in the field more accomplished than Ballard.
[44.176–177] — Counsel and Lines discuss time limits for the deposition
The attorneys and videographer discuss the remaining deposition time and whether questioning should wrap up within four hours.
[45.178] — Lines states Ballard was unqualified for what he was doing at OUR
Lines clarifies that he was not saying Ballard could not start a nonprofit, but says Ballard’s claims and experience should match, and that Ballard was unqualified for what he was actually doing at OUR.
[45.179] — Lines states he later learned things about Ballard at HSI that he did not know at the time
Lines explains that he could not fully answer whether Ballard was honest at HSI because he later learned things Ballard had done that Lines did not know while Ballard was under him.
[45.180] — Lines states Ballard used official credentials without authorization in a production
Lines states that Ballard used his official credentials in an unauthorized production and that Lines learned this after the fact.
[45.180] — Lines states he did not try to make documentaries at OUR
Lines states that he did not try to make documentaries at OUR and that when he brought camera crews, it was for evidentiary purposes.
[45.180] — Lines states footage he made available was for legitimate operations, not documentary production
Lines explains that he knew Ballard wanted footage of legitimate operations, but says footage he made available was not intended to make a documentary.
[45.181] — Lines states Ballard was an effective spokesperson but needed to stay in his lane
Lines explains that he thought Ballard had charisma and storytelling ability and could do extraordinary work, but that Ballard needed to stay within his lane and not exceed his competence.
[45.181] — Lines states he had no difficulty with Ballard being the boss at OUR
Lines states that he had no problem with the fact that Ballard was his boss at OUR despite Lines having previously been Ballard’s boss’s boss at HSI.
[46.182] — Lines states he made a critical report to the board along with other team members
Lines confirms that he made a report to OUR’s board that was critical of Ballard and his efforts, along with many other team members.
[46.182] — Lines states he hoped the board would change how the mission was being handled
Lines explains that he hoped the board would agree change was needed because, in his view, OUR was not accomplishing the mission at hand.
[46.182] — Lines states he never heard that the board voted to fire him
Lines states that he never heard whether the OUR board voted to fire him and would have liked to know.
[46.182–183] — Lines states no one at OUR asked him to leave before the severance agreement
Lines states that nobody at OUR ever actually asked him to leave before a severance agreement was negotiated through an attorney.
[46.183–184] — Lines states his attorney sent formal claims to OUR
Lines explains that his claims were made in written form through a formal communication from his attorney to OUR.
[46.184] — Lines states his attorney’s claims involved Tevya Ware and misuse of funds
Lines explains that the claims concerned issues discussed in the deposition, including mounting pressures, improprieties, the Tevya Ware situation, and misuse of funds.
[46.184–185] — Lines states he was asking OUR to take a stand and communicate with him
Lines explains that he was not making threats to OUR, but was asking the organization to take a stand and communicate with him about unresolved concerns.
[47.186–187] — Lines denies sleeping on the job or being inattentive
Lines states that allegations that he slept on the job, took naps, or failed to pay attention were lies, and says he would want to see evidence because he viewed those claims as false.
[47.188] — Lines states some agents were unhappy with management decisions
Lines explains that he knew agents were dissatisfied with certain management decisions at HSI, but he did not know specific situations matching the accusation being made.
[47.189–48.190] — Lines describes concerns about a Haiti operation and says it was not a rescue
Lines states he participated in a Haiti operation, did not recall the exact number of people involved, and says people being released back to the street within 24 hours was not a rescue. He says the operation was poorly planned and poorly coordinated.
[48.191] — Lines states OUR operations he oversaw were legitimate and ethically supervised
Lines says the operations he knew about were legitimate and that he worked to ensure they were conducted ethically, morally, and properly.
[48.192–193] — Lines states successful foreign operations required law-enforcement coordination
Lines explains that successful operations required working with foreign governments, gathering intelligence, identifying targets, making arrests, and rescuing victims, and says civilians were not supposed to conduct that work themselves.
[49.194–195] — Lines states OUR operatives were vetted and trained before operations
Lines says he vetted operators, reviewed their qualifications, trained them, and ensured they understood undercover and police-work concepts before involvement in operations.
[49.195–196] — Lines states Ballard overstated his trafficking expertise
Lines states that Ballard overstated his trafficking and anti-trafficking experience and claimed to be a trafficking expert.
[49.196–197] — Lines states Ballard’s claimed involvement in the Buchanan case was false
Lines states that Ballard had no involvement in the Buchanan case in Calexico and says Ballard’s claims about involvement in that case were false.
[50.198–199] — Lines states agents and records contradicted Ballard’s portrayal
Lines says agents told him Ballard had no involvement in the Buchanan operation and that logs or reports he reviewed were not consistent with Ballard’s version.
[50.199–200] — Lines states Ballard overstated credentials and expertise
Lines states that Ballard overstated his credentials and expertise, though he acknowledges people can disagree over what qualifies someone as an expert.
[50.200] — Lines states search warrants could be a measurable law-enforcement metric
Lines explains that search warrants are measurable in law enforcement and could be used as one metric of success.
[50.200–201] — Lines disputes that Ballard carried out the most search warrants under him
Lines states that Ballard did not carry out the most search warrants in the Salt Lake area under his supervision, and says that could be verified.
[51.202] — Lines states headquarters experience became required for advancement
Lines explains that headquarters time became expected for advancement and says he was compelled into headquarters work despite having significant field experience.
[51.202–203] — Lines states OUR personnel had confidence in him
Lines says people at OUR felt confident in him and his ability to succeed, though he does not recall saying that “with me at the helm” OUR would succeed.
[51.203–204] — Lines states Tim Ballard, not the board, told him to stop performing duties
Lines states that when he was placed on leave, Jerry Gowen told him Tim Ballard directed that he turn over information and cease further activity with OUR.
[51.204–205] — Lines states he did not publicly report concerns unless subpoenaed
Lines states he did not report concerns outside OUR unless compelled by subpoena, and says he provided information after being subpoenaed by Davis County Criminal Court and the FBI.
[51.202–203] — Lines explains headquarters rotation and OUR confidence in him
Lines states that he had been one of the longest-sitting ASACs in the nation, that headquarters time became expected for GS-15s, and that people at OUR believed his leadership would help the organization succeed.
[51.203] — Lines says he did not view himself as being “at the helm” of OUR
Lines says he did not view his role at OUR as being “at the helm,” and clarifies that if he said that earlier, it was a mischaracterization of someone believing his leadership could help OUR succeed.
[51.203–204] — Lines states Jerry Gowen told him to stop performing OUR duties
Lines states Jerry Gowen told him that Tim Ballard directed him to turn over all information and cease further activity with OUR.
[51.204–205] — Lines states he did not report concerns outside OUR unless compelled by subpoena
Lines states he did not report outside OUR that Ballard was misrepresenting facts or that OUR was doing harmful things unless compelled by subpoena.
[51.205] — Lines states he provided information after subpoenas from Davis County Criminal Court and the FBI
Lines states he was subpoenaed by Davis County Criminal Court and the FBI, and that he provided information to Detective Purdy after he was gone from OUR.
[52.206] — Lines says he expressed concerns and facts, not negativity about OUR
Lines states he did not feel free to speak negatively about OUR and says he expressed his concerns and facts as he knew them.
[52.206] — Lines states he did not report concerns outside OUR while still working there
Lines states that while still working with OUR, he never reported concerns regarding OUR outside the organization.
[52.206–208] — Lines states brain injury or epilepsy would not automatically disqualify someone but would raise safety concerns
Lines states he has no medical expertise, understands employers cannot discriminate based on medical or disability status, but believes undercover work is unique and that using someone with a brain injury or epilepsy could put that person in harm’s way.
[52.208] — Lines states disclosed medical vulnerability should be considered before undercover work
Lines states that if someone disclosed epilepsy or similar concerns, it should be taken into consideration, and he would not think it was a good idea to put that person in harm’s way.
[52.209] — Lines says he has no information that Gardy Mardy is deceased
Lines states he has no information suggesting Gardy Mardy is deceased, corrects himself regarding whether Tim Ballard knew Gardy was dead, and says he hopes Gardy is alive.
[52.209] — Lines states it is honorable to keep looking for missing people
Lines states that it is honorable to keep looking for anybody who is missing.
[52.209] — Lines states Tevya’s Haiti trip was kept secret from him
Lines states that Tevya knew about a Haiti trip or operation, but he did not know it was contemporaneous with an operation.
[53.210] — Lines says not all Ballard operations were staged
Lines states he does not think every operation Ballard was involved in was staged, and says he believes Ballard had true intentions of trying to do the right thing, though he thinks quite a few operations were orchestrated.
[53.210] — Lines describes Ballard family members as underqualified, not necessarily unqualified
Lines states that Ballard’s family members would have benefited from backgrounds more conducive to OUR’s mission and strategy, and says he would call them underqualified rather than unqualified.
[53.210–211] — Lines says he has no tax-code expertise
Lines states he has no expertise in tax code or 501(c)(3) matters, but believes donations accepted for anti-trafficking should be used for anti-trafficking and not someone’s personal agenda to make a movie.
[53.211] — Lines states he does not know whether “Sound of Freedom” proceeds went to OUR
Lines states he does not know whether any proceeds from Sound of Freedom went to OUR, but says it would be honorable if millions of dollars from the film went to OUR.
[53.212–213] — Lines compares psychics and remote viewers
Lines states he has heard of law enforcement using remote viewers, believes a psychic is essentially what a remote viewer would be, but says he is not an expert on the distinction.
[53.213] — Lines states he never used remote viewers and lacks faith in them
Lines states he has never used remote viewers and says he does not have a lot of faith in them.
[53.213] — Deposition concludes
The deposition concluded at 2:44 p.m., with no further questions for Jon Lines.
Resources & Further Reading
Derailed: Operation Underground Railroad (O.U.R.) – American Crime Journal |
O.U.R. Legal Archive – American Crime Journal |
Davis County Criminal Investigation into Tim Ballard & O.U.R. – American Crime Journal |
Lindon Police Department Report: Tim Ballard – American Crime Journal |
Utah County Sheriff’s Office Report: Tim Ballard – American Crime Journal |
First Amended Complaint: WW, et al. v. Ballard et al. – American Crime Journal |
