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C2GFDAU3 Brune - redirect 319
1 sure I completely understand your question, but the point is,
2 if it became an issue I of course would lay out the accurate
3 facts.
4 THE COURT: But then how would the Court or the
5 government have anticipated that your firm had knowledge about
6 certain matters if you didn't disclose it?
7 THE WITNESS: Well, the way that it came up, Judge, is
8 that the government said something like, well, anybody can see
9 that if you Google this it comes up. And it was sort of lying
10 there right on the surface, that if you Google it, it comes up.
11 And that's why I said to the Court that I assumed it was going
12 to come up. But I didn't think I was supposed to make
13 arguments if the government wasn't going to make it.
14 It would have been a different matter if we had
15 knowledge. We didn't know. I didn't think it was a
16 meritorious argument or an issue that in any way undercut the
17 application that we made. But if the government wanted to
18 raise the argument and it was sort of their choice, then we
19 followed that wherever it led.
20 I mean, I really thought that the government had
21 Googled too, and that we were in the same place with respect to
22 Juror No. 1. But the government clearly Googled her at the
23 point that they received the letter. So it was not like it was
24 some mysterious thing that one can conduct a Google search on
25 this juror. I did not know about the Westlaw report at the
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