Document A-5748

Case 1:20-cr-00338-PAE Document 161 Filed 02/24/22 Page 63 of 130 A-5748 291 C2grdau2 Brune - direct 1 Q. But my question was a far more specific one that you still 2 haven't answered, Ms. Brune. 3 A. I'm going to. 4 Q. Which was, just so we are clear, did you tell the defense 5 counsel within that several-day period about what you had 6 previously learned from Google, the suspension opinion, and the 7 Westlaw report? 8 A. I did not at that point know anything about the Westlaw 9 report. I did not discuss the Google search with co-counsel. 10 Q. Did you at any point advise them about the Google search? 11 A. No. 12 Q. At some point in time am I correct in assuming that you 13 actually reviewed the Westlaw report? 14 A. Here is where I got the dates wrong. There was the 15 conference with the Court which Ms. Trzaskoma handled and we 16 had to submit a letter to the Court. So then on that Monday, 17 which I think is July 18th, I had a discussion with Ms. 18 Edelstein and Ms. Trzaskoma, and at that point I learned that 19 there was this Westlaw report floating around. 20 Q. You learned specifically that this was the Westlaw report 21 that Ms. Trzaskoma had found or had been provided by Mr. 22 Benhamou on May 12th, correct? 23 A. Yes. We were very focused on making sure what we said in 24 the letter was accurate, and that was a part of it. 25 Q. Before this time period you had filed a brief, right? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00009352 --- PAGE BREAK --- C2grdau2 Brune - direct 291 1 Q. But my question was a far more specific one that you still haven't answered, Ms. Brune. 2 A. I'm going to. 3 Q. Which was, just so we are clear, did you tell the defense counsel within that several-day period about what you had previously learned from Google, the suspension opinion, and the Westlaw report? 4 A. I did not at that point know anything about the Westlaw report. I did not discuss the Google search with co-counsel. 5 Q. Did you at any point advise them about the Google search? 6 A. No. 7 Q. At some point in time am I correct in assuming that you actually reviewed the Westlaw report? 8 A. Here is where I got the dates wrong. There was the conference with the Court which Ms. Trzaskoma handled and we had to submit a letter to the Court. So then on that Monday, which I think is July 18th, I had a discussion with Ms. Edelstein and Ms. Trzaskoma, and at that point I learned that there was this Westlaw report floating around. 9 Q. You learned specifically that this was the Westlaw report that Ms. Trzaskoma had found or had been provided by Mr. Benhamou on May 12th, correct? 10 A. Yes. We were very focused on making sure what we said in the letter was accurate, and that was a part of it. 11 Q. Before this time period you had filed a brief, right? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300