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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
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