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Document 1:20-cr-00330-PAE Document 61102

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Case 1:20-cr-00330-PAE Document 61102 Filed 02/24/22 Page 124 of 130 A-5809 C2GFDAU3 Edelstein 352 1 Q. Well, would you agree with me that an omission can be 2 construed as a lie? 3 A. Yes. 4 Q. And the omissions that your firm made didn't end with 5 filing a brief, would you agree with me? 6 A. No. 7 Q. Well, Theresa Trzaskoma participated in the phone call with 8 the Court on July 15, correct? 9 A. Yes. 10 Q. Are you aware that that phone conversation was going to 11 take place? 12 A. Yes. 13 Q. Did you talk with Theresa Trzaskoma before she participated 14 in that call? 15 A. No. 16 Q. Do you know if Susan Brune did? 17 A. I don't know. 18 Q. Do you know if anybody had a conversation with Theresa 19 Trzaskoma where it was discussed that she would not 20 affirmatively tell the Court about the facts that your firm 21 knew prior to the receipt of the letter? 22 A. No. 23 MR. OKULA: Just one moment, your Honor. 24 (Pause) 25 MR. OKULA: I have nothing else, your Honor. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00009413