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Document A-5755

AI Analysis

Summary: The deponent is being questioned about a letter submitted to the Court and the representation of when they became aware of a certain fact or opinion. The deponent clarifies their understanding of the events and the intentions behind the statements made in the letter and the brief.
Significance: This document is potentially important because it reveals a discrepancy in the representation of events in a brief and the actual knowledge or actions taken by the parties involved.
Key Topics: Letter submission to the Court Knowledge of a specific fact or opinion Representation of events in a brief
Key People:
  • Ms. Trzaskoma - Person mentioned as having submitted a letter to the Court
  • Ms. Conrad - Person who sent a letter that is referenced in the brief
Document Type
Transcript
Date
Unknown
Pages
1
Folder
IMAGES004

Full Text

C2grdau2 Brune - direct 298 1 attached that to your July 21st letter, correct? 2 A. When we submitted the letter, as she had promised to do, we 3 certainly attached the Westlaw opinion. 4 Q. That was a fact that had come to light, correct? 5 A. Yes, that's correct. 6 Q. She's telling the Court, we were not aware of them, clearly 7 trying to imply that you all found this well after the trial 8 was over, correct? 9 A. I don't think that's what she meant to imply at all. I 10 think what she is saying is that we were going to submit a 11 letter and the plan was then to submit a letter laying it out, 12 which is what we did. 13 I don't believe Ms. Trzaskoma was trying to mislead 14 the Court. I think she would have been not as precise as she should have 15 been, and she would have done better to say we are going to 16 submit a letter, but I don't believe she was trying to mislead 17 the Court. Indeed, we laid it out in the letter. 18 Q. Let me stop you there. You are so far beyond the question 19 that I asked that I would like to get us back on track, if I 20 could. In your brief you told this Court and painted a picture 21 like the beginning of your knowledge was the letter from Ms. 22 Conrad. You omitted everything that had happened prior to 23 that, correct? 24 A. I believe that it's true that our knowledge came after we 25 received the letter. That's what the brief was intended to SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300