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Case 1:20-cv-03308-PAE Document 61602 Filed 02/24/22 Page 119 of 130 A-5804 CZGFDAU3 Edelstein 347 1 A. Simply because there are two different addresses. 2 Q. Now, could I ask you to look at page 32, footnote 13. And 3 specifically the last sentence of that footnote. Do you see 4 where it says, "Defendants had no basis to inquire whether 5 Conrad was lying in response to each of the Court's, 6 questions," do you see that? 7 A. Yes. 8 Q. Do you think that was an accurate statement, Ms. Edelstein? 9 A. Yes. 10 Q. Were you aware that Theresa Trzaskoma had been, had 11 discovered the Appellate Division suspension report at that 12 time with the name Catherine Conrad? 13 A. I was aware that Theresa, when we were writing the brief I 14 was aware that Theresa had known that there was an Appellate 15 Division order. 16 Q. And would you turn to page 9 and look at the first full 17 paragraph there. Would you read that first sentence aloud for 18 us? 19 A. "The tone and content of the letter, which were in sharp 20 contrast to the image Conrad had projected through the trial, 21 always head down, taking notes, caused defendants concern and 22 prompted them to investigate." 23 Q. Well, you were aware when that sentence went into the final 24 version of the brief, that Theresa Trzaskoma had already done a 25 bit of investigation, correct? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00009408