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Case 1:20-cr-00338-PAE Document 1616220 Filed 02/24/22 Page 613 of 130 A-5746 C2GFDAU1 Brune - direct 289 1 of fact in the question, that's all. He's concerned about the 2 date. I don't know whether he's right or wrong, but why don't 3 you see if you can establish a date with the witness. 4 A. I'm sorry. 5 Q. Ms. Brune, you know that Ms. Trzaskoma had a conversation 6 with Barry Berke and Paul Schoeman about the possibility that 7 she was a suspended attorney. 8 A. I know that now because I've seen these affidavits that 9 have come in. I don't think I knew it at the time. 10 Q. She did not tell you? 11 A. I don't have a very clear recollection of this, but I don't 12 think she did. 13 Q. Now, let's move to June 23rd. Let me -- withdrawn. You 14 will agree, would you not, that jury deliberations took a 15 relatively long time in this case. 16 A. It took eight days, as I recall. 17 Q. And pursuant to the judge's order, a member of your team 18 was in court or nearly in court that whole time, correct? 19 A. I personally was there throughout the deliberations. 20 Q. And at any point in time prior to the time of the verdict 21 you could have raised what your firm had learned both before 22 voir dire started and on May 12th, correct? 23 A. There is no question -- 24 Q. And it's a could have. It's a could have. 25 A. There is no question that we could have addressed the Court SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00009350