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Document A-5801

AI Analysis

Summary: The deposition transcript shows Ms. Edelstein being questioned about the facts section of a brief she was involved with, specifically whether it accurately represents when she learned of an Appellate Division suspension report. She acknowledges that the brief might convey a misleading impression but denies any intention to mislead.
Significance: This document is potentially important as it reveals the questioning of a key witness about the accuracy and intentions behind the facts presented in a brief, potentially impacting the case's credibility and outcome.
Key Topics: Questioning about a brief's facts section Appellate Division suspension report Juror note and its relation to the discovery of the report
Key People:
  • Ms. Edelstein - Witness being deposed
  • Dr. DeRosa - Person mentioned in the context of an incident at a podium
  • Catherine Conrad - Sender of a letter relevant to the case
Document Type
Court Filing
Date
02/24/22
Pages
2
Folder
IMAGES004

Full Text

Case 1:20-cr-00330-AJN Document 615-2 Filed 02/24/22 Page 116 of 130 A-5801 C2GFDAU3 Edelstein 344 1 Q. In the brief, is it fair to say that the facts section 2 conveys the notion that you discovered or you commenced your 3 discovery and attained your knowledge of the Appellate Division 4 suspension report only after you received the letter of 5 Catherine Conrad? Yes or no? 6 A. I can see now that that might be the impression. 7 Q. Ms. Edelstein, I asked you a simple question. Weren't you 8 the one who stood at this podium and raised your voice with Dr. 9 DeRosa about him not answering your questions? Do you remember 10 that? 11 A. Yes. 12 Q. Okay, can you answer my questions the way I asked them or 13 in response to my question? Would you do that, please? 14 A. Yes. 15 Q. Wouldn't you agree with me that the facts as laid out in 16 your brief convey the notion that you learned of the Appellate 17 Division report only after you received the juror note; true or 18 false? 19 A. I find that a difficult answer, question to answer true or 20 false. I can see now how that might be the impression that is 21 conveyed by the brief. 22 Q. And that -- 23 A. That certainly was not our intention at the time. I 24 certainly did not, we did not intend to create a misleading 25 impression. Our focus at the time was trying to show that O SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00009405 --- PAGE BREAK --- C2GFDAU3 Edelstein 344 1 Q. In the brief, is it fair to say that the facts section 2 conveys the notion that you discovered or you commenced your 3 discovery and attained your knowledge of the Appellate Division 4 suspension report only after you received the letter of 5 Catherine Conrad? Yes or no? 6 A. I can see now that that might be the impression. 7 Q. Ms. Edelstein, I asked you a simple question. Weren't you 8 the one who stood at this podium and raised your voice with Dr. 9 DeRosa about him not answering your questions? Do you remember 10 that? 11 A. Yes. 12 Q. Okay, can you answer my questions the way I asked them or 13 in response to my question? Would you do that, please? 14 A. Yes. 15 Q. Wouldn't you agree with me that the facts as laid out in 16 your brief convey the notion that you learned of the Appellate 17 Division report only after you received the juror note; true or 18 false? 19 A. I find that a difficult answer, question to answer true or 20 false. I can see now how that might be the impression that is 21 conveyed by the brief. 22 Q. And that -- 23 A. That certainly was not our intention at the time. I 24 certainly did not, we did not intend to create a misleading 25 impression. Our focus at the time was trying to show that SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00010084

Individual Pages

Page 116 - DOJ-OGR-00009405
Case 1:20-cr-00330-AJN Document 615-2 Filed 02/24/22 Page 116 of 130 A-5801 C2GFDAU3 Edelstein 344 1 Q. In the brief, is it fair to say that the facts section 2 conveys the notion that you discovered or you commenced your 3 discovery and attained your knowledge of the Appellate Division 4 suspension report only after you received the letter of 5 Catherine Conrad? Yes or no? 6 A. I can see now that that might be the impression. 7 Q. Ms. Edelstein, I asked you a simple question. Weren't you 8 the one who stood at this podium and raised your voice with Dr. 9 DeRosa about him not answering your questions? Do you remember 10 that? 11 A. Yes. 12 Q. Okay, can you answer my questions the way I asked them or 13 in response to my question? Would you do that, please? 14 A. Yes. 15 Q. Wouldn't you agree with me that the facts as laid out in 16 your brief convey the notion that you learned of the Appellate 17 Division report only after you received the juror note; true or 18 false? 19 A. I find that a difficult answer, question to answer true or 20 false. I can see now how that might be the impression that is 21 conveyed by the brief. 22 Q. And that -- 23 A. That certainly was not our intention at the time. I 24 certainly did not, we did not intend to create a misleading 25 impression. Our focus at the time was trying to show that O SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00009405
Page 344 - DOJ-OGR-00010084
C2GFDAU3 Edelstein 344 1 Q. In the brief, is it fair to say that the facts section 2 conveys the notion that you discovered or you commenced your 3 discovery and attained your knowledge of the Appellate Division 4 suspension report only after you received the letter of 5 Catherine Conrad? Yes or no? 6 A. I can see now that that might be the impression. 7 Q. Ms. Edelstein, I asked you a simple question. Weren't you 8 the one who stood at this podium and raised your voice with Dr. 9 DeRosa about him not answering your questions? Do you remember 10 that? 11 A. Yes. 12 Q. Okay, can you answer my questions the way I asked them or 13 in response to my question? Would you do that, please? 14 A. Yes. 15 Q. Wouldn't you agree with me that the facts as laid out in 16 your brief convey the notion that you learned of the Appellate 17 Division report only after you received the juror note; true or 18 false? 19 A. I find that a difficult answer, question to answer true or 20 false. I can see now how that might be the impression that is 21 conveyed by the brief. 22 Q. And that -- 23 A. That certainly was not our intention at the time. I 24 certainly did not, we did not intend to create a misleading 25 impression. Our focus at the time was trying to show that SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00010084