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Document 1:20-cv-00330-PAE Document 61102/20

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C2GFDAU3 Edelstein 353 THE COURT: Mr. Schectman? MR. SCHECTMAN: Yes, your Honor. CROSS-EXAMINATION BY MR. SCHECTMAN: Q. Ms. Edelstein, on May 12th at the end of the conversation that you had on the plaza with Ms. Brune and Ms. Trzaskoma, why didn't you bring information about there being a suspended lawyer with the same name as Juror No. 1, why didn't you bring that to the Court's attention? A. At some point during the conversation we had discussed whether we should bring it to the Court's attention, but after we discussed the issue and concluded that it was inconceivable that Juror No. 1 was the suspended lawyer, we didn't see a reason to bring the fact that there was a suspended lawyer with the name Catherine Conrad to the Court's attention, that there was nothing we were going to ask the Court to do at that point. Q. At any time were you trying to sandbag the Court or tamper with the record? A. No. Q. At any time between the juror's verdict on May 24th and the receipt of Ms. Conrad's post-trial letter on June 30, was there any discussion in the Brune firm about raising a juror misconduct issue as an issue on a post-trial motion? A. There was none. Q. And why not? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00009414