No, I didn't say that, did I? However I implied that "deposition evidence submitted to a federal court under penalty of perjury when the evidence provided is adverse to the party but provided by that same party" can reasonably considered factual.
You didn't answer what you consider such evidence to be though. What would you call that type of evidence, since you seem to object to categorizing that as factual?
Ok. So you simply take the convenient position (as the Jed) that allows you to choose when Rossi is telling the truth or not according the the narrative that suits you the best? Or do you mean it is somehow more criminal to lie about something that goes against your interests than something that is to your advantage?