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Case 1:20-cv-03303-PAE Document 61102/20 Filed 02/24/22 Page 120 of 130 A-5805 348 C2GFDAU3 Edelstein 1 A. Yes. 2 Q. So would you agree with me that to the extent that that 3 sentence suggested that only after the letter was received did 4 you and the others begin investigating, it was untrue because 5 you knew Theresa Trzaskoma had previously done some 6 investigation? 7 A. Someone might read that that way, but -- 8 Q. Can you answer -- 9 A. This is a truthful statement. 10 Q. Can you answer my question, please? Yes or no? You just 11 acknowledged that Theresa Trzaskoma had previously done an 12 investigation, some of the results of which she reported to you 13 on May 12th, correct? Correct? 14 A. On May 12th I knew that there was a suspended lawyer with 15 the same name. 16 Q. That Theresa Trzaskoma had discovered pursuant to her 17 correspondence with others in your firm in that little mini 18 investigation, correct? 19 A. I was not aware -- 20 MR. SCHECTMAN: Judge -- 21 THE COURT: Overruled. 22 A. I was not aware on May 12th of any investigation. 23 Q. Well, Theresa Trzaskoma didn't tell you that her 24 information about the suspended lawyer came out of thin air, 25 did she? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00009409