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C2qrdau2 Brune - direct 293
1 prominence it has here. I missed the issue, and I really
2 regret that. It was, I think, a good brief, but it missed it.
3 Q. Do you think good briefs omit material facts, Ms. Brune?
4 A. I certainly do not think that about briefs.
5 Q. You knew when you wrote that brief about the suspension
6 opinion that Ms. Trzaskoma had found, correct?
7 A. That's correct.
8 Q. There is no mention of that in the brief, correct?
9 MR. SHECHTMAN: Judge, there is mention of the
10 suspension opinion in the brief.
11 THE COURT: Overruled.
12 A. You are right that the brief does not include a discussion
13 of our having accessed the suspension opinion during the trial.
14 Q. In fact, it's worse than that, Ms. Brune. You claim in
15 that brief that it was the letter of Ms. Conrad that prompted
16 you to investigate. That was simply not accurate, correct?
17 A. I think it was accurate in that we did not launch an
18 investigation of the sort that was described in the brief until
19 after the government disclosed the letter. But as I've said, I
20 missed that issue in terms of how the brief was written.
21 Q. Ms. Trzaskoma drafted in the first instance the set of
22 facts for that brief, correct?
23 A. Yes, that's right.
24 Q. She was well aware of the investigation that she asked be
25 done on May 12th, correct?
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
DOJ-OGR-00010033