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Document A-5754

AI Analysis

Summary: The witness, Ms. Brune, is questioned about a letter submitted to the court in response to new facts coming to light, and whether one of those facts was a suspension opinion she had previously found. The attorney conducting the deposition refers to a specific exhibit and asks Ms. Brune to confirm details about Ms. Trzaskoma's statement to the court.
Significance: This deposition transcript reveals details about a court's inquiry and the subsequent actions taken by the attorneys involved, potentially shedding light on the handling of new information during a trial.
Key Topics: Submission of a letter to the court Response to the court's inquiry regarding new facts Suspension opinion and Westlaw report
Key People:
  • Ms. Brune - Witness being deposed
  • Ms. Trzaskoma - Attorney who made a statement to the court
  • Mr. Wooten - Court reporter or assistant
  • Mr. Davis - Attorney conducting the deposition

Full Text

C2grdau2 Brune - direct 1 A. What she did was what the judge had sort of given people 2 the option of saying that they would do, which is that she said 3 that she would submit a letter, and then we worked very hard to 4 submit a letter that was accurate. 5 MR. DAVIS: Mr. Wooten, could I have Government 6 Exhibit 9, page 12, please. 7 Could I have a moment, your Honor? 8 THE COURT: Take your time. 9 Q. Can you see it up there? 10 A. Yes. 11 Q. Do you see where Ms. Trzaskoma, in response to the Court's 12 inquiry, said, "Your Honor, we were not aware of the facts that 13 have come to light, and I think if your Honor deems it 14 appropriate, we can submit a letter"? Correct? 15 A. She did say that. 16 Q. One of the facts that had come to light was the very same 17 suspension opinion that she had found before voir dire ever 18 started, correct? 19 A. I think what she is trying to convey there -- 20 Q. That's not my question. 21 A. I'm sorry. If you could say it again. 22 Q. I'm just asking a very straightforward question, Ms. Brune. 23 A. I know it, but it's not a yes or no, I don't think. 24 Q. Sure it is. The question is, one of the facts that came to 25 light that you attached was the Westlaw report, correct? You SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00010037