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Case 1:20-cr-00338-PAE Document 161 Filed 02/24/22 Page 93 of 130 A-5778
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C2GFDAU3 Brune - redirect
1 information than I do, so I figured if they thought there was
2 something to it, they'd raise it.
3 So I didn't think, oh, wow, here's the Google search
4 and here's the note, let me bring this to the government's
5 attention. I thought the government had the same thing that we
6 had.
7 THE COURT: All right. Anything further?
8 MR. OKULA: No, your Honor, not with respect to this
9 witness. But before we go on to the next witness, I just want
10 to make a representation to the Court and I'd be happy to set
11 forth in a declaration if the Court requires, but Ms. Brune in
12 the end of her testimony was I think speculating about what the
13 state of the government's knowledge was and what we were doing
14 after we received the note.
15 As a matter of fact, Judge, we didn't think that on
16 the face of the note that it suggested Brady or any violation.
17 We turned it over nonetheless, but we didn't conduct any
18 independent investigation after we got the letter because we
19 viewed it as pretty much innocuous. So to the extent that
20 Ms. Brune was speculating that I assume or I think or I
21 believed the government was doing its own Google research and
22 found the same thing in fact that is not true. The first time
23 we found out about it was when we saw the motion that the
24 defendants filed.
25 THE COURT: All right. Anything further,
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
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