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Document A-5750
AI Analysis
Summary: Ms. Brune is questioned about a brief she wrote, which omitted key facts, including a suspension opinion found by Ms. Trzaskoma. Ms. Brune acknowledges the omission and defends the brief's accuracy regarding the investigation's timing.
Significance: This deposition reveals potential inaccuracies and omissions in a brief written by Ms. Brune, which could be significant in understanding the case's facts and the credibility of the brief's authors.
Key Topics:
Discussion about a brief written by Ms. Brune
Omission of material facts in the brief
Investigation and suspension opinion
Key People:
- Ms. Brune - Witness being deposed
- Ms. Trzaskoma - Drafter of facts for the brief
- Ms. Conrad - Author of a letter mentioned in the brief
- MR. SHECHTMAN - Counsel/Attorney
- THE COURT - Judge presiding over the deposition
Full Text
C2qrdau2 Brune - direct 293
1 prominence it has here. I missed the issue, and I really
2 regret that. It was, I think, a good brief, but it missed it.
3 Q. Do you think good briefs omit material facts, Ms. Brune?
4 A. I certainly do not think that about briefs.
5 Q. You knew when you wrote that brief about the suspension
6 opinion that Ms. Trzaskoma had found, correct?
7 A. That's correct.
8 Q. There is no mention of that in the brief, correct?
9 MR. SHECHTMAN: Judge, there is mention of the
10 suspension opinion in the brief.
11 THE COURT: Overruled.
12 A. You are right that the brief does not include a discussion
13 of our having accessed the suspension opinion during the trial.
14 Q. In fact, it's worse than that, Ms. Brune. You claim in
15 that brief that it was the letter of Ms. Conrad that prompted
16 you to investigate. That was simply not accurate, correct?
17 A. I think it was accurate in that we did not launch an
18 investigation of the sort that was described in the brief until
19 after the government disclosed the letter. But as I've said, I
20 missed that issue in terms of how the brief was written.
21 Q. Ms. Trzaskoma drafted in the first instance the set of
22 facts for that brief, correct?
23 A. Yes, that's right.
24 Q. She was well aware of the investigation that she asked be
25 done on May 12th, correct?
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
DOJ-OGR-00010033