Case 1:20-cr-00330 Document 615 Filed 02/24/22 Page 129 of 130 A-5814
C2grdau4 Edelstein 357
1 BY MR. OKULA:
2 Q. Do you mean to say that if the government hadn't asked and
3 the Court hadn't asked, you were comfortable from an ethical
4 and a professional standpoint to have the judge decide the
5 motion without ever learning the facts about what Theresa
6 Trzaskoma and you and Susan Brune and the others knew at the
7 firm prior to receiving the government note? Is that what you
8 are saying?
9 THE WITNESS: I find this a difficult question to
10 answer trying to put out of my mind all the things I now know
11 and where we are. I firmly believe that the standard is actual
12 knowledge. We just didn't know they were the same person.
13 MR. OKULA: Let me try again. From a professional and
14 ethical standpoint, are you saying that you would have felt
15 comfortable that you had fulfilled all your obligations if the
16 Court had decided this motion without learning of the facts
17 concerning what your firm knew prior to receiving the Catherine
18 Conrad letter? Yes or no.
19 THE WITNESS: Yes.
20 MR. OKULA: Nothing further, Judge.
21 THE COURT: Anything further?
22 You are excused, Ms. Edelstein.
23 (Witness excused)
24 THE COURT: Would the government call its next
25 witness.
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
DOJ-OGR-00009418
Full Text
Case 1:20-cr-00330 Document 615 Filed 02/24/22 Page 129 of 130 A-5814
C2grdau4 Edelstein 357
1 BY MR. OKULA:
2 Q. Do you mean to say that if the government hadn't asked and
3 the Court hadn't asked, you were comfortable from an ethical
4 and a professional standpoint to have the judge decide the
5 motion without ever learning the facts about what Theresa
6 Trzaskoma and you and Susan Brune and the others knew at the
7 firm prior to receiving the government note? Is that what you
8 are saying?
9 THE WITNESS: I find this a difficult question to
10 answer trying to put out of my mind all the things I now know
11 and where we are. I firmly believe that the standard is actual
12 knowledge. We just didn't know they were the same person.
13 MR. OKULA: Let me try again. From a professional and
14 ethical standpoint, are you saying that you would have felt
15 comfortable that you had fulfilled all your obligations if the
16 Court had decided this motion without learning of the facts
17 concerning what your firm knew prior to receiving the Catherine
18 Conrad letter? Yes or no.
19 THE WITNESS: Yes.
20 MR. OKULA: Nothing further, Judge.
21 THE COURT: Anything further?
22 You are excused, Ms. Edelstein.
23 (Witness excused)
24 THE COURT: Would the government call its next
25 witness.
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
DOJ-OGR-00009418
--- PAGE BREAK ---
C2grdau4 Edelstein 357
1 BY MR. OKULA:
2 Q. Do you mean to say that if the government hadn't asked and
3 the Court hadn't asked, you were comfortable from an ethical
4 and a professional standpoint to have the judge decide the
5 motion without ever learning the facts about what Theresa
6 Trzaskoma and you and Susan Brune and the others knew at the
7 firm prior to receiving the government note? Is that what you
8 are saying?
9 THE WITNESS: I find this a difficult question to
10 answer trying to put out of my mind all the things I now know
11 and where we are. I firmly believe that the standard is actual
12 knowledge. We just didn't know they were the same person.
13 MR. OKULA: Let me try again. From a professional and
14 ethical standpoint, are you saying that you would have felt
15 comfortable that you had fulfilled all your obligations if the
16 Court had decided this motion without learning of the facts
17 concerning what your firm knew prior to receiving the Catherine
18 letter? Yes or no.
19 THE WITNESS: Yes.
20 MR. OKULA: Nothing further, Judge.
21 THE COURT: Anything further?
22 You are excused, Ms. Edelstein.
23 (Witness excused)
24 THE COURT: Would the government call its next
25 witness.
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
Individual Pages
Page 129 - DOJ-OGR-00009418
Page 357 - DOJ-OGR-00010097
C2grdau4 Edelstein 357
1 BY MR. OKULA:
2 Q. Do you mean to say that if the government hadn't asked and
3 the Court hadn't asked, you were comfortable from an ethical
4 and a professional standpoint to have the judge decide the
5 motion without ever learning the facts about what Theresa
6 Trzaskoma and you and Susan Brune and the others knew at the
7 firm prior to receiving the government note? Is that what you
8 are saying?
9 THE WITNESS: I find this a difficult question to
10 answer trying to put out of my mind all the things I now know
11 and where we are. I firmly believe that the standard is actual
12 knowledge. We just didn't know they were the same person.
13 MR. OKULA: Let me try again. From a professional and
14 ethical standpoint, are you saying that you would have felt
15 comfortable that you had fulfilled all your obligations if the
16 Court had decided this motion without learning of the facts
17 concerning what your firm knew prior to receiving the Catherine
18 letter? Yes or no.
19 THE WITNESS: Yes.
20 MR. OKULA: Nothing further, Judge.
21 THE COURT: Anything further?
22 You are excused, Ms. Edelstein.
23 (Witness excused)
24 THE COURT: Would the government call its next
25 witness.
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300