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Case 1:20-cr-00330-PAE Document 1616220 Filed 02/24/22 Page 56 of 130 A-5741 C2GFDAU1 Brune - direct 284 1 A. I certainly did not know. 2 Q. And you could have turned right around and contacted 3 chambers about it, correct? 4 A. Had I thought that the information was accurate, I would 5 have immediately contacted chambers. 6 Q. Why the qualifier, Ms. Brune? Bottom line is, you have a 7 significant piece of information. You could have brought it to 8 the Court's attention, then, correct? 9 A. I did not accord it significance at the time. 10 Q. You had an entire team and an investigative firm at your 11 disposal, correct? 12 A. There's no question that we had resources. 13 Q. And you had a telephone with you, correct? 14 A. I did. 15 Q. And a BlackBerry? 16 A. My phone and my BlackBerry are the same thing, but yes. 17 Q. And you had access to, immediate access to e-mail, correct? 18 A. I certainly could have communicated with chambers. 19 Q. And you're confident, are you not, that if you had said to 20 your team let's investigate this further, this is important, 21 they would have done so, correct? 22 A. Yes. The team was very diligent. 23 Q. And they would have worked as long as it took to get the 24 job done to your satisfaction, correct? 25 A. They worked hard, and they would have done whatever I asked SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00009345