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Document A-5807

AI Analysis

Summary: The deponent, Edelstein, discusses the drafting of a brief and clarifies that the wording was not intended to convey a specific meaning regarding waiver, but rather to establish that two individuals were the same person. Edelstein explains their discussion with Ms. Brune about omitting certain information from the brief.
Significance: This deposition reveals the thought process and discussions behind the creation of a legal brief, potentially impacting the interpretation of the brief's content.
Key Topics: Discussion about the wording of a brief Omission of information from the brief Waiver and juror misconduct cases
Key People:
  • Edelstein - Deponent
  • Ms. Brune - Person Edelstein discussed the brief with
Document Type
Transcript
Date
Unknown
Pages
1
Folder
IMAGES004

Full Text

C2GFDAU3 Edelstein 350 1 in hindsight with respect to this proceeding, but I can see 2 with hindsight now how it might be construed in the way you 3 have suggested. But at the time when we were writing it we 4 were describing what happened when we received the letter on 5 June 20th. 6 Q. Well, it was worded that way because you and Ms. Brune had 7 had a discussion previously about what you were going to omit 8 from this brief, right? 9 A. No. The discussion I had with Ms. Brune was whether or not 10 we were going to say that prior to voir dire we had information 11 that there was a suspended lawyer named Catherine Conrad. 12 Q. And you agreed -- 13 A. We discussed it in the context of what was the standard for 14 waiver, what was the standard for juror misconduct cases, which 15 was actual knowledge. I was not focused, when we were writing 16 the brief, I was not focused on waiver. We didn't know they 17 were the same person. We just were trying to actually 18 establish that they were the same person and that, it took me a 19 long time for me to believe that they were the same person. 20 I really was not thinking about waiver. I know that 21 may be difficult for you to believe now when you're taking a 22 brief and looking at every sentence and trying to impart some 23 meaning to it or an impression that we were trying to create. 24 But that's not how we were writing it. 25 Q. Can you just answer the question that I asked? You just SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00010090