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Document A-5747

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C2GFDAU1 Brune - direct 290 1 at any point. 2 Q. Now, when you got a copy of Ms. Conrad's letter to 3 Mr. Okula, you subsequently had conversations with the defense 4 counsel, correct? 5 A. I did. 6 Q. And did you tell them at or around that time what you 7 previously found out? 8 A. The communications were joint defense communications. I 9 don't mind answering the question so long as there's no 10 contention that there's a broader waiver of the joint defense 11 privilege and so long as no other party to the -- 12 MR. GAIR: We have no objection, your Honor, on behalf 13 of Mr. Daugerdas. 14 A. I got the jury note, read it, very upset, set it aside. 15 Ms. Edelstein looked at the letter which had the phone number 16 and went on the Bar website and saw that the phone number 17 matched. We still -- 18 Q. Can I stop you there, Ms. Brune? 19 A. Yes, I'm sorry, I'm trying to answer your question and 20 you're right that it does not in the way that you want me to. 21 What I'm trying to say is it took us a couple of days after we 22 received the note to communicate with our co-counsel. 23 (Continued next page) 24 25 SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00010030