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Case 1:20-cr-00338-PAE Document 1616-20 Filed 02/24/22 Page 91 of 130 A-5776 319 C2GFDAU3 Brune - redirect 1 sure I completely understand your question, but the point is, 2 if it became an issue I of course would lay out the accurate 3 facts. 4 THE COURT: But then how would the Court or the 5 government have anticipated that your firm had knowledge about 6 certain matters if you didn't disclose it? 7 THE WITNESS: Well, the way that it came up, Judge, is 8 that the government said something like, well, anybody can see 9 that if you Google this it comes up. And it was sort of lying 10 there right on the surface, that if you Google it, it comes up. 11 And that's why I said to the Court that I assumed it was going 12 to come up. But I didn't think I was supposed to make 13 arguments if the government wasn't going to make it. 14 It would have been a different matter if we had 15 knowledge. We didn't know. I didn't think it was a 16 meritorious argument or an issue that in any way undercut the 17 application that we made. But if the government wanted to 18 raise the argument and it was sort of their choice, then we 19 followed that wherever it led. 20 I mean, I really thought that the government had 21 Googled too, and that we were in the same place with respect to 22 Juror No. 1. But the government clearly Googled her at the 23 point that they received the letter. So it was not like it was 24 some mysterious thing that one can conduct a Google search on 25 this juror. I did not know about the Westlaw report at the SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00009380