Document A-5756

C2grdau2 Brune - direct 299 1 convey. As I think I've already said, though, when I reflect 2 on the brief, I think we missed it. And it's something that I 3 greatly regret, there is no question about that. 4 Q. The Court convened a conference call on July 22nd, correct? 5 A. Yes, that's right. 6 Q. You participated on that call, correct? 7 A. I did. 8 Q. Indeed, the Court inquired of the defense counsel why he 9 was getting two different versions of the facts, correct? 10 A. Something along those lines, yes. 11 Q. When you compare what you said in the July 21st letter to 12 the facts as laid out in the brief, those are two very 13 different set of facts, correct? 14 A. I can't sort of say for sure what Judge Pauley was 15 thinking, but he certainly was conveying that he wanted to get 16 to the bottom of things and that he was not happy with us. 17 Q. That wasn't my question, Ms. Brune. My question was, if 18 you compare the facts as they are laid out in your letter to 19 the facts as they are laid out in the brief, those are two very 20 different sets of facts, correct? 21 A. I don't agree with you. I thought what you were asking me 22 to say was what Judge Pauley was thinking. 23 Q. No, that wasn't my question. Is it your testimony here, 24 Ms. Brune, that you did not find it a material fact, the things 25 that you uncovered prior to the return of the jury's verdict? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00010039 --- PAGE BREAK --- Case 1:20-cr-00338-PAE Document 161 Filed 02/24/22 Page 713 of 130 A-5756 299 C2grdau2 Brune - direct 1 convey. As I think I've already said, though, when I reflect 2 on the brief, I think we missed it. And it's something that I 3 greatly regret, there is no question about that. 4 Q. The Court convened a conference call on July 22nd, correct? 5 A. Yes, that's right. 6 Q. You participated on that call, correct? 7 A. I did. 8 Q. Indeed, the Court inquired of the defense counsel why he 9 was getting two different versions of the facts, correct? 10 A. Something along those lines, yes. 11 Q. When you compare what you said in the July 21st letter to 12 the facts as laid out in the brief, those are very 13 different set of facts, correct? 14 A. I can't sort of say for sure what Judge Pauley was 15 thinking, but he certainly was conveying that he wanted to get 16 to the bottom of things and that he was not happy with us. 17 Q. That wasn't my question, Ms. Brune. My question was, if 18 you compare the facts as they are laid out in your letter to 19 the facts as they are laid out in the brief, those are two very 20 different sets of facts, correct? 21 A. I don't agree with you. I thought what you were asking me 22 to say was what Judge Pauley was thinking. 23 Q. No, that wasn't my question. Is it your testimony here, 24 Ms. Brune, that you did not find it a material fact, the things 25 that you uncovered prior to the return of the jury's verdict? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00009360