04-30-2019  — Alan L. Friedman, Ph.D. Affidavit

04-30-2019  —  Sam Greene Affidavit

04-30-2019  —  Leonard Pozner Affidavit

04-30-2019  —  Zimmerman Affidavit Part 1 Ex. A-D

04-30-2019  —  Zimmerman Affidavit Part 2 Ex. E-J 

04-30-2019  —  Zimmerman Affidavit Part 3 Ex. K-O

04-30-2019  —  Zimmerman Affidavit Part 4 Ex. P-Z  






Case No. 18CV3122







Leonard Pozner, being first duly sworn upon oath, deposes and states as follows:

  1. I make the following statements of my own knowledge.
  2. Noah Pozner, who is now deceased, is the only male child I have ever fathered. 
  3. My name was legally changed from Eliezer Pozner to Leonard Pozner in 2002. A copy of the court order is attached as Ex. A.
  4. I have fathered three children: Noah Pozner and his twin sister were born in 2006. Noah’s older sister was born in 2005. I have not fathered any other children.
  5. This is a picture of my son, Noah Pozner, taken in 2012:

Noah Pozner, Affidavit

  • I use the term “hoaxer” to refer to Sandy Hook hoaxers—anyone claiming that the Sandy Hook shooting is a hoax. 
  • Some hoaxers, including Alex Jones, claimed that Sandy Hook was an inside job.  A video excerpt of Alex Jones making that allegation is available at I emailed Alex Jones. 
  • In 2013, if not earlier, other hoaxers, including James Tracy, claimed that the families of the children who died at Sandy Hook, including myself, were crisis actors.
  • Initially, I took no public action, hoping that the hoaxers would move on to their next issue and I would be able to get on with grieving for the loss of my son.
  • Eventually, I realized that some of these hoaxers would never leave me or my family alone. I was regularly harassed by hoaxers and their followers. Their theories threatened to erase my son’s history. I was influenced by the epigraph from Vincent Bugliosi’s book “Reclaiming History”: “To the historical record, knowing that nothing in the present can exist without the paternity of history, and hence, the latter is sacred, and should never be tampered with or defiled by untruths.”
  • I wanted to display the truth of Noah’s life, to show that Noah was a real boy who actually lived and actually died.  To support that effort, I posted a copy of Noah’s certified death certificate on Noah’s memorial Google Plus page. It was an effort to give Noah a voice and give him the ability to reclaim his history. It was his story that the hoaxers were threatening to erase.
  • I also wrote an opinion piece describing the devastating emotional impact of the hoaxers unceasing attacks on the memory of my deceased son.
  • The death certificate I posted was one of several certified copies that had been issued to me by the Newtown records clerk in 2013. True and correct scans of the documents I obtained from the Newtown clerk are attached as Ex. B to this affidavit. Both documents include embossed seals, but those seals are not well reflected in these scans. Those original certified death certificates will be made available for inspection.
  • At no point prior to receiving a copy of the certified death certificate was I in possession of any incomplete or uncertified copy of Noah Pozner’s death certificate. I did not enter any information into any of the boxes on Noah Pozner’s death certificate.
  • Sandy Hook is a community within the town of Newtown, Connecticut.
  • Prior to posting the death certificate, I redacted sensitive information from the death certificate.  I redacted Noah’s social security number from the lower right-hand corner of the certified death certificate.  I also redacted the location of Noah’s grave because some hoaxers had threatened to dig up his grave in order to prove that it was empty.
  • In mid-2013 I had the Newtown clerk’s office amend Noah’s death certificate to reflect the address where he resided for his whole life, rather than Veronique’s apartment where he spent only part of the week for a relatively short period of time. The copy of the certified death certificate attached to the Complaint, in this case, reflects the changes I requested.
  • I have never purchased a copy of Nobody Died At Sandy Hook.
  • Noah Pozner, along with his siblings, was listed as a dependent on my tax returns in the years before he died.
  • A true and correct scan of Noah Pozner’s social security card is attached as Ex. C.
  • I married Veronique De La Rosa in New York in 2003.  A village justice performed our ceremony. We were divorced in Florida in 2014.
  • I have suffered severe humiliation and other emotional anguish and distress as a result of the accusations in Defendants’ book accusing me of releasing a fake copy of Noah’s death certificate as part of an effort to deceive the public.
  • I have read the foregoing affidavit and acknowledge the contents thereof and affirm I truthfully executed the same for the purposes therein expressed.

Dated:  April 29, 2019