Document A-5793

Case 1:20-cv-03303-PAE Document 616-2 Filed 02/24/22 Page 108 of 130 A-5793 336 C2GFDAU3 Edelstein 1 memo that had been put together and the link to the Westlaw 2 report after we received the letter from Catherine Conrad. 3 Q. And did you discuss it with Susan Brune? 4 A. Discuss what? 5 Q. The Westlaw report and your examination of it as well as 6 your examination of the suspension report. 7 A. I believe I -- well, the suspension report, if you mean the 8 Appellate Division order? 9 Q. Yes. 10 A. I believe I discussed the Appellate Division order. I did 11 not discuss the Westlaw report with her. 12 Q. What was the nature of your discussion with her? 13 A. Well, I believe that after we received the June 20th 14 letter, I first had a conversation with Susan just upon receipt 15 of the letter and reading it and the substance of it, you know, 16 I was very disturbed by the letter. This has nothing to do 17 with Catherine Conrad being the suspended lawyer because at 18 that point I didn't know. When I first received the letter I 19 was sort of, I was disturbed and shocked by it. We had spent 20 three months in the courtroom where everyone wants to know what 21 the jury is thinking about various subjects. We then receive a 22 letter that gives us some insight into the jury deliberations 23 and I was very taken aback by some of the things that she said. 24 I felt that we had sat here trying to read the tea leaves with 25 various juror notes on the one hand and it is just very SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00009397 --- PAGE BREAK --- C2GFDAU3 Edelstein 336 1 memo that had been put together and the link to the Westlaw 2 report after we received the letter from Catherine Conrad. 3 Q. And did you discuss it with Susan Brune? 4 A. Discuss what? 5 Q. The Westlaw report and your examination of it as well as 6 your examination of the suspension report. 7 A. I believe I -- well, the suspension report, if you mean the 8 Appellate Division order? 9 Q. Yes. 10 A. I believe I discussed the Appellate Division order. I did 11 not discuss the Westlaw report with her. 12 Q. What was the nature of your discussion with her? 13 A. Well, I believe that after we received the June 20th 14 letter, I first had a conversation with Susan just upon receipt 15 of the letter and reading it and the substance of it, you know, 16 I was very disturbed by the letter. This has nothing to do 17 with Catherine Conrad being the suspended lawyer because at 18 that point I didn't know. When I first received the letter I 19 was sort of, I was disturbed and shocked by it. We had spent 20 three months in the courtroom where everyone wants to know what 21 the jury is thinking about various subjects. We then receive a 22 letter that gives us some insight into the jury deliberations 23 and I was very taken aback by some of the things that she said. 24 I felt that we had sat here trying to read the tea leaves with 25 various juror notes on the one hand and it is just very SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00010076