Document A-5799

Case 1:20-cr-00330 Document 612 Filed 02/24/22 Page 144 of 130 A-5799 C2GFDAU3 Edelstein 342 1 A. Yes. 2 Q. Were you involved in the drafting of the facts section of 3 the brief? 4 A. I edited that section, yes. 5 Q. Now, by the way, did you have discussions with Susan Brune 6 or anyone else at the firm about whether people at your firm 7 were going to discuss with other defense counsel what Theresa 8 Trzaskoma had talked to you about on May 12th? 9 A. No. 10 Q. Are you telling us that there was no discussion at all 11 about whether you were going to inform your co-counsel about 12 the facts that you had learned or Theresa Trzaskoma had learned 13 during voir dire and during, on or about May 12? 14 A. I don't recall any discussion about speaking with other 15 defense counsel. 16 Q. Did you discuss with anyone at your firm about whether you 17 were going to reveal in the brief that you were going to submit 18 to the Court the facts that your firm were aware of that you 19 and Randy Kim talked about? 20 A. Yes, Susan Brune and I had a discussion. 21 Q. So you discussed about whether you should or should not 22 include in the facts section of your brief the facts that you 23 learned either during voir dire or on May 12 but prior to 24 receipt of the juror letter, correct? 25 A. Yes. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00009403 --- PAGE BREAK --- C2GFDAU3 Edelstein 342 1 A. Yes. 2 Q. Were you involved in the drafting of the facts section of 3 the brief? 4 A. I edited that section, yes. 5 Q. Now, by the way, did you have discussions with Susan Brune 6 or anyone else at the firm about whether people at your firm 7 were going to discuss with other defense counsel what Theresa 8 Trzaskoma had talked to you about on May 12th? 9 A. No. 10 Q. Are you telling us that there was no discussion at all 11 about whether you were going to inform your co-counsel about 12 the facts that you had learned or Theresa Trzaskoma had learned 13 during voir dire and during, on or about May 12? 14 A. I don't recall any discussion about speaking with other 15 defense counsel. 16 Q. Did you discuss with anyone at your firm about whether you 17 were going to reveal in the brief that you were going to submit 18 to the Court the facts that your firm were aware of that you 19 and Randy Kim talked about? 20 A. Yes, Susan Brune and I had a discussion. 21 Q. So you discussed about whether you should or should not 22 include in the facts section of your brief the facts that you 23 learned either during voir dire or on May 12 but prior to 24 receipt of the juror letter, correct? 25 A. Yes. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00010082