Case 1:20-cr-00338-PAE Document 161 Filed 02/24/22 Page 63 of 130
A-5748
291
C2grdau2 Brune - direct
1 Q. But my question was a far more specific one that you still
2 haven't answered, Ms. Brune.
3 A. I'm going to.
4 Q. Which was, just so we are clear, did you tell the defense
5 counsel within that several-day period about what you had
6 previously learned from Google, the suspension opinion, and the
7 Westlaw report?
8 A. I did not at that point know anything about the Westlaw
9 report. I did not discuss the Google search with co-counsel.
10 Q. Did you at any point advise them about the Google search?
11 A. No.
12 Q. At some point in time am I correct in assuming that you
13 actually reviewed the Westlaw report?
14 A. Here is where I got the dates wrong. There was the
15 conference with the Court which Ms. Trzaskoma handled and we
16 had to submit a letter to the Court. So then on that Monday,
17 which I think is July 18th, I had a discussion with Ms.
18 Edelstein and Ms. Trzaskoma, and at that point I learned that
19 there was this Westlaw report floating around.
20 Q. You learned specifically that this was the Westlaw report
21 that Ms. Trzaskoma had found or had been provided by Mr.
22 Benhamou on May 12th, correct?
23 A. Yes. We were very focused on making sure what we said in
24 the letter was accurate, and that was a part of it.
25 Q. Before this time period you had filed a brief, right?
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
DOJ-OGR-00009352
@epsteinpedia
CA:
AEb4NmMJF2x5kcp19M13RiXZuAGyajWSKLaioqBrpump
Document A-5748
AI Analysis
Summary: The deposition transcript shows Ms. Brune being questioned about her knowledge and disclosure of a Google search and a Westlaw report to defense counsel. She testifies that she did not initially discuss the Google search with co-counsel and learned about the Westlaw report later. The questioning highlights potential discrepancies in her knowledge and communication with co-counsel.
Significance: This document is potentially important because it reveals potential issues with disclosure of information to defense counsel and communication among co-counsel in a criminal case.
Key Topics:
Disclosure of information to defense counsel
Google search and Westlaw report
Communication among co-counsel
Key People:
- Ms. Brune - witness being questioned
- Ms. Trzaskoma - co-counsel who handled a conference with the Court
- Ms. Edelstein - co-counsel involved in discussion about Westlaw report
- Mr. Benhamou - person who provided Westlaw report to Ms. Trzaskoma
Full Text
Case 1:20-cr-00338-PAE Document 161 Filed 02/24/22 Page 63 of 130
A-5748
291
C2grdau2 Brune - direct
1 Q. But my question was a far more specific one that you still
2 haven't answered, Ms. Brune.
3 A. I'm going to.
4 Q. Which was, just so we are clear, did you tell the defense
5 counsel within that several-day period about what you had
6 previously learned from Google, the suspension opinion, and the
7 Westlaw report?
8 A. I did not at that point know anything about the Westlaw
9 report. I did not discuss the Google search with co-counsel.
10 Q. Did you at any point advise them about the Google search?
11 A. No.
12 Q. At some point in time am I correct in assuming that you
13 actually reviewed the Westlaw report?
14 A. Here is where I got the dates wrong. There was the
15 conference with the Court which Ms. Trzaskoma handled and we
16 had to submit a letter to the Court. So then on that Monday,
17 which I think is July 18th, I had a discussion with Ms.
18 Edelstein and Ms. Trzaskoma, and at that point I learned that
19 there was this Westlaw report floating around.
20 Q. You learned specifically that this was the Westlaw report
21 that Ms. Trzaskoma had found or had been provided by Mr.
22 Benhamou on May 12th, correct?
23 A. Yes. We were very focused on making sure what we said in
24 the letter was accurate, and that was a part of it.
25 Q. Before this time period you had filed a brief, right?
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
DOJ-OGR-00009352
--- PAGE BREAK ---
C2grdau2 Brune - direct 291
1 Q. But my question was a far more specific one that you still haven't answered, Ms. Brune.
2 A. I'm going to.
3 Q. Which was, just so we are clear, did you tell the defense counsel within that several-day period about what you had previously learned from Google, the suspension opinion, and the Westlaw report?
4 A. I did not at that point know anything about the Westlaw report. I did not discuss the Google search with co-counsel.
5 Q. Did you at any point advise them about the Google search?
6 A. No.
7 Q. At some point in time am I correct in assuming that you actually reviewed the Westlaw report?
8 A. Here is where I got the dates wrong. There was the conference with the Court which Ms. Trzaskoma handled and we had to submit a letter to the Court. So then on that Monday, which I think is July 18th, I had a discussion with Ms. Edelstein and Ms. Trzaskoma, and at that point I learned that there was this Westlaw report floating around.
9 Q. You learned specifically that this was the Westlaw report that Ms. Trzaskoma had found or had been provided by Mr. Benhamou on May 12th, correct?
10 A. Yes. We were very focused on making sure what we said in the letter was accurate, and that was a part of it.
11 Q. Before this time period you had filed a brief, right?
SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300
Individual Pages
Page 63 - DOJ-OGR-00009352
Page 291 - DOJ-OGR-00010031
C2grdau2 Brune - direct 291
1 Q. But my question was a far more specific one that you still haven't answered, Ms. Brune.
2 A. I'm going to.
3 Q. Which was, just so we are clear, did you tell the defense counsel within that several-day period about what you had previously learned from Google, the suspension opinion, and the Westlaw report?
4 A. I did not at that point know anything about the Westlaw report. I did not discuss the Google search with co-counsel.
5 Q. Did you at any point advise them about the Google search?
6 A. No.
7 Q. At some point in time am I correct in assuming that you actually reviewed the Westlaw report?
8 A. Here is where I got the dates wrong. There was the conference with the Court which Ms. Trzaskoma handled and we had to submit a letter to the Court. So then on that Monday, which I think is July 18th, I had a discussion with Ms. Edelstein and Ms. Trzaskoma, and at that point I learned that there was this Westlaw report floating around.
9 Q. You learned specifically that this was the Westlaw report that Ms. Trzaskoma had found or had been provided by Mr. Benhamou on May 12th, correct?
10 A. Yes. We were very focused on making sure what we said in the letter was accurate, and that was a part of it.
11 Q. Before this time period you had filed a brief, right?
SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300