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Document A-5760
AI Analysis
Summary: Ms. Brune testifies that she attempted to be accurate in a submitted brief, but acknowledges it had shortcomings. She denies that the brief contained material omissions, stating that it was not her intention to omit material information.
Significance: This document is potentially important as it reveals the testimony of Ms. Brune regarding the accuracy and completeness of a submitted brief, and her understanding of the standards for disclosure.
Key Topics:
Accuracy of a submitted brief
Material omissions in the brief
Investigation and knowledge of certain facts
Key People:
- Ms. Brune - Witness being deposed
- MR. SHECHTMAN - Counsel for one of the parties
- MR. DAVIS - Counsel for one of the parties
- THE COURT - Presiding judge over the deposition
Full Text
C2grdau2 Brune - direct 303
1 Q. The question was that you were willing to provide a
2 complete and accurate set of facts if and only if the
3 government asked, is that what you are saying?
4 A. No, that's not what I'm saying at all. I tried very hard
5 to be accurate in the brief that we submitted. It has the
6 shortcomings that we have talked about.
7 Q. It has material omissions, Ms. Brune?
8 A. I certainly have tried to be accurate.
9 Q. It has material omissions, correct?
10 A. I do not believe that it was written with the goal of
11 making a material omission. I believed then and believe now
12 that the standard is actual knowledge. We did not have actual
13 knowledge or anything near that. We were shocked when we
14 received the letter.
15 Q. It has material omissions in it?
16 MR. SHECHTMAN: Asked and answered.
17 MR. DAVIS: No, I don't believe she has answered it,
18 your Honor.
19 THE COURT: Overruled.
20 A. I did not believe that it had material omissions in the
21 sense that anyone writing the brief or in my case signing the
22 brief intended to make material omissions. I think that what
23 we were trying to do was we were trying to describe the post-
24 letter investigation that we undertook and we were trying to
25 convey what is accurate, which is that it was the letter that
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
DOJ-OGR-00010043