Document A-5739

Case 1:20-cr-00338-PAE Document 161 Filed 02/24/22 Page 54 of 130 A-5739 282 C2GFDAU1 Brune - direct 1 occurred to you that you could have your team look into this, 2 correct? 3 A. I certainly thought, well, here's this information on 4 Google. Here's the sworn statement. We could have certainly 5 done more. I didn't think it was proper in light of the fact 6 that I didn't think there was anything to the idea that she was 7 a suspended lawyer. 8 Q. Based on what information, actual information? 9 A. I credited her sworn voir dire responses. I went through 10 the reasoning that I described that the note in a way ruled out 11 the idea that she was a lawyer, and matched up with the idea 12 that she was a litigant in the personal injury suit, and it 13 made no sense that a lawyer would sit in a voir dire and lie 14 that way. 15 Q. Did you read the indictment in this case, Ms. Brune? 16 A. I read the indictment in this case. 17 Q. And you understood that much of the indictment focused 18 around the misconduct of lawyers, correct? 19 A. That is certainly what the indictment alleged. 20 Q. And a number of the defendants were lawyers, correct? 21 A. Yes. 22 Q. And a number of the cooperators and codefendants who 23 pleaded guilty were lawyers, correct? 24 A. If what you're asking me is -- 25 Q. It's a simple question, Ms. Brune. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00009343 --- PAGE BREAK --- C2GFDAU1 Brune - direct 282 1 occurred to you that you could have your team look into this, 2 correct? 3 A. I certainly thought, well, here's this information on 4 Google. Here's the sworn statement. We could have certainly 5 done more. I didn't think it was proper in light of the fact 6 that I didn't think there was anything to the idea that she was 7 a suspended lawyer. 8 Q. Based on what information, actual information? 9 A. I credited her sworn voir dire responses. I went through 10 the reasoning that I described that the note in a way ruled out 11 the idea that she was a lawyer, and matched up with the idea 12 that she was a litigant in the personal injury suit, and it 13 made no sense that a lawyer would sit in a voir dire and lie 14 that way. 15 Q. Did you read the indictment in this case, Ms. Brune? 16 A. I read the indictment in this case. 17 Q. And you understood that much of the indictment focused 18 around the misconduct of lawyers, correct? 19 A. That is certainly what the indictment alleged. 20 Q. And a number of the defendants were lawyers, correct? 21 A. Yes. 22 Q. And a number of the cooperators and codefendants who 23 pleaded guilty were lawyers, correct? 24 A. If what you're asking me is -- 25 Q. It's a simple question, Ms. Brune. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00010022