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Document A-5808

AI Analysis

Summary: The witness confirms having a conversation with Susan Brune about what to include in a brief and acknowledges deciding to omit certain information. The witness expresses regret over the omission and suggests they would handle it differently in hindsight.
Significance: This document reveals a potentially significant conversation between the witness and Susan Brune about omitting information from a brief, which may have led to misimpressions or controversy.
Key Topics: conversation between the witness and Susan Brune decision-making process regarding content in a brief omission of certain information from the brief
Key People:
  • Susan Brune - person with whom the witness discussed the brief's content
  • the witness (unnamed) - person being deposed about their conversation with Susan Brune and the brief's content
Document Type
Transcript
Date
Unknown
Pages
1
Folder
IMAGES004

Full Text

Case#: 2326-1030308-AENuDocument#: 64402/2Exhib#: 03282022Page#: 2136df3030 A-5808 C2GFDAU3 Edelstein 351 1 said that you had a conversation with Susan Brune, yes or no? 2 A. Yes. 3 Q. Okay, and as a result of that discussion you decided what 4 you would omit from the brief, correct? 5 A. I wouldn't characterize it as omit. 6 Q. Okay, let's just stop there. You and Susan Brune discussed 7 the fact that you wouldn't include certain things you knew 8 about before the juror note in your brief, yes or no? 9 A. Yes. 10 Q. So isn't that a decision that you made with Susan Brune 11 about what you would omit from the brief, yes or no? 12 A. Yes. 13 Q. So when you answered my questions a few minutes ago when I 14 asked you whether you decided with Susan Brune that you would 15 omit something, you said no. Was that an untrue answer before? 16 A. Well, I'm not sure if that was the exact question. I'm 17 not -- I'm not trying to lie here or give you a hard time. 18 These are difficult questions to answer. In looking back and 19 trying to figure out what the process was for writing this 20 brief, if I had to do it over again would I do it differently? 21 Yes. In hindsight should we have dropped a footnote saying 22 that we, you know, knew that there was a suspended lawyer with 23 the same name? If I had to do it over again I would certainly 24 do that. And I'm very sorry for any misimpression the brief 25 has created. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00010091