Full Text
Case#: 2020-0130338-AE No Document 64402 Filed 03/20/22 Page# 1310 of 3080
A-5804
347
CZGFDAU3 Edelstein
1 A. Simply because there are two different addresses.
2 Q. Now, could I ask you to look at page 32, footnote 13. And
3 specifically the last sentence of that footnote. Do you see
4 where it says, "Defendants had no basis to inquire whether
5 Conrad was lying in response to each of the Court's
6 questions," do you see that?
7 A. Yes.
8 Q. Do you think that was an accurate statement, Ms. Edelstein?
9 A. Yes.
10 Q. Were you aware that Theresa Trzaskoma had been, had
11 discovered the Appellate Division suspension report at that
12 time with the name Catherine Conrad?
13 A. I was aware that Theresa, when we were writing the brief I
14 was aware that Theresa had known that there was an Appellate
15 Division order.
16 Q. And would you turn to page 9 and look at the first full
17 paragraph there. Would you read that first sentence aloud for
18 us?
19 A. "The tone and content of the letter, which were in sharp
20 contrast to the image Conrad had projected through the trial,
21 always head down, taking notes, caused defendants concern and
22 prompted them to investigate."
23 Q. Well, you were aware when that sentence went into the final
24 version of the brief, that Theresa Trzaskoma had already done a
25 bit of investigation, correct?
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
DOJ-OGR-00010087