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Document A-5752

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C2rdau2 Brune - direct 295 1 Q. She is under the same ethical obligations that you are, correct? 2 A. She is. 3 Q. She is a partner in the law firm, correct? 4 A. That's right. 5 Q. She made an appearance in this court, correct? 6 A. She did. 7 Q. She, notwithstanding your role as the ultimate supervisor, cannot evade those ethical obligations by claiming that you're the person in charge, correct? 8 A. No. She has independent ethical obligations, there's no question. 9 Q. Obligations to bring material information to the Court's attention, correct? 10 A. She has the same ethical obligations as I do or any other lawyer in this court does. 11 Q. Did she review the final brief? 12 A. I'm certain she did. 13 Q. I may have it wrong, so correct me if I am wrong, Ms. Brune -- but let me ask you, on what date did you see the email traffic? 14 A. We gathered the email traffic as part of this period leading up to our submitting the July 21st letter. So I saw I think all of it before we submitted the letter. I was very focused on making sure that I had the information to convey to 15 SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 --- PAGE BREAK --- Case 1:20-cr-00338-PAE Document 1616-20 Filed 02/24/22 Page 673 of 130 A-5752 C2grdau2 Brune - direct 295 1 Q. She is under the same ethical obligations that you are, correct? 2 A. She is. 3 Q. She is a partner in the law firm, correct? 4 A. That's right. 5 Q. She made an appearance in this court, correct? 6 A. She did. 7 Q. She, notwithstanding your role as the ultimate supervisor, cannot evade those ethical obligations by claiming that you're the person in charge, correct? 8 A. No. She has independent ethical obligations, there's no question. 9 Q. Obligations to bring material information to the Court's attention, correct? 10 A. She has the same ethical obligations as I do or any other lawyer in this court does. 11 Q. Did she review the final brief? 12 A. I'm certain she did. 13 Q. I may have it wrong, so correct me if I am wrong, Ms. Brune -- but let me ask you, on what date did you see the email traffic? 14 A. We gathered the email traffic as part of this period leading up to our submitting the July 21st letter. So I saw I think all of it before we submitted the letter. I was very focused on making sure that I had the information to convey to SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00009356

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Page 295 - DOJ-OGR-00010035
C2rdau2 Brune - direct 295 1 Q. She is under the same ethical obligations that you are, correct? 2 A. She is. 3 Q. She is a partner in the law firm, correct? 4 A. That's right. 5 Q. She made an appearance in this court, correct? 6 A. She did. 7 Q. She, notwithstanding your role as the ultimate supervisor, cannot evade those ethical obligations by claiming that you're the person in charge, correct? 8 A. No. She has independent ethical obligations, there's no question. 9 Q. Obligations to bring material information to the Court's attention, correct? 10 A. She has the same ethical obligations as I do or any other lawyer in this court does. 11 Q. Did she review the final brief? 12 A. I'm certain she did. 13 Q. I may have it wrong, so correct me if I am wrong, Ms. Brune -- but let me ask you, on what date did you see the email traffic? 14 A. We gathered the email traffic as part of this period leading up to our submitting the July 21st letter. So I saw I think all of it before we submitted the letter. I was very focused on making sure that I had the information to convey to 15 SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300
Page 673 - DOJ-OGR-00009356
Case 1:20-cr-00338-PAE Document 1616-20 Filed 02/24/22 Page 673 of 130 A-5752 C2grdau2 Brune - direct 295 1 Q. She is under the same ethical obligations that you are, correct? 2 A. She is. 3 Q. She is a partner in the law firm, correct? 4 A. That's right. 5 Q. She made an appearance in this court, correct? 6 A. She did. 7 Q. She, notwithstanding your role as the ultimate supervisor, cannot evade those ethical obligations by claiming that you're the person in charge, correct? 8 A. No. She has independent ethical obligations, there's no question. 9 Q. Obligations to bring material information to the Court's attention, correct? 10 A. She has the same ethical obligations as I do or any other lawyer in this court does. 11 Q. Did she review the final brief? 12 A. I'm certain she did. 13 Q. I may have it wrong, so correct me if I am wrong, Ms. Brune -- but let me ask you, on what date did you see the email traffic? 14 A. We gathered the email traffic as part of this period leading up to our submitting the July 21st letter. So I saw I think all of it before we submitted the letter. I was very focused on making sure that I had the information to convey to SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00009356