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Document A-5751
AI Analysis
Summary: Ms. Brune is questioned about her involvement in an investigation and her statements in a memorandum. She clarifies her understanding of 'investigation' and acknowledges that some actions could have been handled differently. The deposition also touches on the knowledge of email traffic among the defendants' representatives.
Significance: This deposition reveals the thought process and actions of the defendants and their representatives during a critical phase of a case, potentially impacting the case's outcome or settlement.
Key Topics:
Investigation into Conrad's statements
Email traffic and knowledge of it
Defendants' actions and decisions during the case
Key People:
- Ms. Brune - Witness being deposed
- Mr. Benhamou - Involved in the investigation
- Mr. Kim - Involved in the investigation
- Ms. Stapp - Involved in the investigation
- Ms. Trzaskoma - Knew about email traffic
Full Text
C2grdau2 Brune - direct
1 A. She certainly was aware of what had been done, that's
2 correct.
3 Q. Are you shying away from using the word "investigate" to
4 describe what it was that you and Mr. Benhamou and Mr. Kim and
5 Ms. Stapp were doing on the morning of May 12th?
6 A. It's not that I'm shying away. I just don't think it is
7 accurate. To me "investigation" means more than looking at a
8 database search. What I think of as an investigation is what
9 we ended up doing once we received the jury letter.
10 Q. You also stated in your memorandum at page 32 note 13 that
11 the defendants had no basis to inquire whether Conrad was lying
12 in response to the Court's questions. That is just wrong, Ms.
13 Brune.
14 A. I have I think already said that having reflected on all
15 this, I think there are a number of things that I wish had been
16 said differently. What I was trying to convey to the Court in
17 the brief was the reality, which is that we didn't think it was
18 the same person and we were shocked when we received the note
19 and found out about the phone number matching.
20 Q. Had you seen the email traffic at that point in time when
21 you filed the brief, Ms. Brune?
22 A. No, I had not.
23 Q. But you know now that Ms. Trzaskoma knew about that email
24 traffic, correct?
25 A. She did.
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
DOJ-OGR-00010034