Giuliani attorney Joseph Sibley scrutinized the credibility of the communications expert whose report on the reach of Giuliani's defamatory statements underpins the plaintiffs' request for tens of millions of dollars in damages.

Dr. Ashlee Humphreys, an expert witness for plaintiffs Ruby Freeman and Shaye Moss, fielded questions about the methodology she used to compile a report on the reputational harm that was done to the mother and daughter. Sibley sought to poke holes in that research as part of an effort to cast doubt on her findings.

"Reputation repair campaigns such as this are common," Humphreys said in response.

Sibley also highlighted Humphreys' participation as an expert witness in other cases, including in the defamation lawsuit filed against former President Trump by the writer E. Jean Carroll, and a case involving the conservative media outlet Gateway Pundit.

Noting that her past expert witness work exclusively targeted right-wing figures, Sibley asked, "Is there a reason for that?"

"No," she replied.

Communications expert Dr. Ashlee Humphreys, testifying for the plaintiffs, estimated that the cost to repair the reputations of Shaye Moss and Ruby Freeman is between $17.8 million and $47.4 million.

Humphreys said that her assessment found that Giuliani's defamatory statements about the two election workers had a "significant, negative and long-lasting" impact on Moss and Freeman's reputations.

"To repair reputational harm is not easy," Humphreys said.

A repair campaign for Moss and Freeman would include circulating statements in multiple media outlets, hiring influencers, and running media advertisements over a long period, Humphreys testified.

Dr. Ashlee Humphreys, an expert in sociology and communications, took the stand for the plaintiffs to testify about the reach of Giuliani's false election fraud claims online and on social media.

Humphreys said that prior to December 3, 2020, "there was practically no search traffic" for Ruby Freeman. After that day, Humphreys said there was a "dramatic increase over a period of months."

Humphreys said some of the search terms between December 2020 and January 2021 were "Ruby Freeman arrested," "Ruby Freeman fraud" and "Ruby Freeman FBI."

During her testimony, Humphreys walked through her analysis of the total number of times content had been displayed to uses, known as "impressions." Her impression analysis of several videos and posts by Giuliani and former President Trump included a Dec. 23, 2020, podcast in which Giuliani mentioned Moss and Freeman, which Humphreys said received between 584,855 to 807,751 impressions.

An advertising post by the Trump campaign that falsely claimed Freeman and Moss stuffed ballots in suitcases received between 8 million and 18.2 impressions, Humphreys said.

Some of the statements Humphreys said she found in her research were from Giuliani's "strategic communications plan" to challenge the election results, which included references to Moss and Freeman.

Lawyers for Shaye Moss and Ruby Freeman said they may rest their case today.

The attorneys expect Freeman to take the stand this afternoon following Dr. Ashlee Humphreys, an expert who will testify about the reach of Rudy Giuliani's statements and the reputational impact of those statements on Freeman and Moss.

Before the jury was seated, Giuliani was asked by Judge Beryl Howell to explain remarks he made after court and online Tuesday night, after she admonished him earlier Tuesday about comments he made on Monday.

"I did," Giuliani said about making Tuesday's remarks, "but I don't think they violated the order. If I did, it was accidental."

"I will not do it in the future," he said.

In a video streamed Tuesday night on X, formerly Twitter, Giuliani said, "They're seeking $40 million. Oh yeah. They're seeking $40 million for the damage that I allegedly did to them. One of them did testify that she has no money, they do have an endless number of lawyers in the courtroom, however, for people that don't have any money."

Jurors were shown a smattering of the racially charged threats Ruby Freeman received after video of her and her daughter counting ballots at State Farm Arena on election night circulated online.

The emails flooded her inbox on the night of Dec. 3, 2020, with several invoking lynching and references to the Ku Klux Klan.

One email, from an account called Grand Wizard with the email name "kkk" said, "Safest place for you right now is in prison. Or you will swing from the trees."

Another suggested the government hang her and her daughter from the "Capitol dome," saying, "I pray that I will be sitting close enough to hear your necks snap!"

Several of the messages accused her of being a traitor or "SCUM."

"I received so many on my phone that at one point my phone crashed," Freeman testified. "I felt horrible. I felt terrorized. I was scared … people are coming to kill me. They have my address, they have my phone number, they know my name."

Freeman testified that two days later, on Dec. 5, 2020, people began to show up at her house and she was forced to call the authorities.

While on the phone with police, Freeman said people were "banging" on her door.

"Not only am I getting phone calls and emails and stuff, now you're actually coming to the house," Freeman testified. "I was scared."