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Document A-5809

AI Analysis

Summary: The witness is questioned about their firm's omissions and potential dishonesty, specifically regarding a phone call with the Court on July 15, and whether Theresa Trzaskoma was prepared for the call. The witness confirms their firm's omissions but denies knowledge of discussions about what Trzaskoma would disclose during the call.
Significance: This deposition transcript reveals potential inconsistencies and omissions made by the witness's firm, particularly regarding a phone call with the Court, and raises questions about the firm's honesty and preparation.
Key Topics: Omissions and potential dishonesty Phone call with the Court on July 15 Theresa Trzaskoma's participation and preparation for the call
Key People:
  • Theresa Trzaskoma - Participant in the phone call with the Court
  • Susan Brune - Potential person who may have discussed the phone call with Theresa Trzaskoma

Full Text

C2GFDAU3 Edelstein 352 1 Q. Well, would you agree with me that an omission can be 2 construed as a lie? 3 A. Yes. 4 Q. And the omissions that your firm made didn't end with 5 filing a brief, would you agree with me? 6 A. No. 7 Q. Well, Theresa Trzaskoma participated in the phone call with 8 the Court on July 15, correct? 9 A. Yes. 10 Q. Are you aware that that phone conversation was going to 11 take place? 12 A. Yes. 13 Q. Did you talk with Theresa Trzaskoma before she participated 14 in that call? 15 A. No. 16 Q. Do you know if Susan Brune did? 17 A. I don't know. 18 Q. Do you know if anybody had a conversation with Theresa 19 Trzaskoma where it was discussed that she would not 20 affirmatively tell the Court about the facts that your firm 21 knew prior to the receipt of the letter? 22 A. No. 23 MR. OKULA: Just one moment, your Honor. 24 (Pause) 25 MR. OKULA: I have nothing else, your Honor. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00010092