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doctrine protection for the work we had done.
Q. You knew that those documents would significantly advance
the government's position on the waiver issue, correct?
A. No, because the July 21st letter lays it out, lays it out
accurately, including the fact that Ms. Trzaskoma had that
initial thought that it was one and the same.
Q. Are you referring to the "Jesus, I do think that it's her"
email?
A. Yes.
Q. You met with Ms. Trzaskoma and Ms. Edelstein prior to this
hearing, correct?
A. We worked together. I've certainly talked with her on many
occasions about the issues that are before the judge in this
hearing. I'm testifying from my own best recollection, but
I've certainly talked with them about the issues.
Q. How many times did you meet with them to discuss this
hearing?
A. Never. What I'm saying is I've talked about the issues
with them. We worked very hard on the July 21st letter to try
to get it accurate, but we did not meet in preparation for this
hearing.
Q. So, you didn't discuss what your answers would be?
A. I think that they know what my recollection is, and I think
I know what their recollection is, because we worked so hard on
the letter to reconstruct what had happened.
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300