Page:CTRL0000034610 - Deposition of Keith Kellogg, Jr., (Dec. 14, 2021).pdf/52

52 riot gear or people who were attending the January 6th rally?

Both. I mean, when -- when I drove in that morning, it was a day like every other day. It was -- the security was normal. They weren't in -- you know, they weren't in, you know, outside body armor. I'm sure they all wear internal body armor like most police officers do. But waved through. Saw the crowds. Waved to them. Jovial, going, everything seemed fine.

Do you remember what time you got to the White House?

I normally got in about between 7 and 7:30 every day.

Okay. Any reason to think it was a different time on that day, January 6th?

No. Just depends. Traffic in Washington, D.C.

Okay. Do you remember a lot of traffic on January 6th?

Well, they -- not a lot because what they do is they alert everybody, especially White House staff, that if there's a rally. I don't care if it's an environmental rally, they block off certain access to the area around us. And they'll put that, and The Washington Post will carry what blockages. And if you go on your Waze or anything else like that, they'll tell you.

So, generally speaking, if there was a rally, regardless of what kind of rally it was, people would generally tend to avoid the vicinity around the White House. I still do it to this day try to avoid it. If they're going to light the Christmas tree, I go way out of my way to get around it.

Understood. In your book you said this, you said, quote: On January 3rd or -- excuse me -- 3 January, the President had asked the Defense Department to deploy National Guard troops to protect the rally. He was worried that the counter protestors might attempt to subvert his supporters' peaceful right of assembly. The Defense Department, however, was worried however about the optics of a large deployment of