Case 1:20-cv-03303-PAE Document 616-2 Filed 02/24/22 Page 108 of 130
A-5793
336
C2GFDAU3 Edelstein
1 memo that had been put together and the link to the Westlaw
2 report after we received the letter from Catherine Conrad.
3 Q. And did you discuss it with Susan Brune?
4 A. Discuss what?
5 Q. The Westlaw report and your examination of it as well as
6 your examination of the suspension report.
7 A. I believe I -- well, the suspension report, if you mean the
8 Appellate Division order?
9 Q. Yes.
10 A. I believe I discussed the Appellate Division order. I did
11 not discuss the Westlaw report with her.
12 Q. What was the nature of your discussion with her?
13 A. Well, I believe that after we received the June 20th
14 letter, I first had a conversation with Susan just upon receipt
15 of the letter and reading it and the substance of it, you know,
16 I was very disturbed by the letter. This has nothing to do
17 with Catherine Conrad being the suspended lawyer because at
18 that point I didn't know. When I first received the letter I
19 was sort of, I was disturbed and shocked by it. We had spent
20 three months in the courtroom where everyone wants to know what
21 the jury is thinking about various subjects. We then receive a
22 letter that gives us some insight into the jury deliberations
23 and I was very taken aback by some of the things that she said.
24 I felt that we had sat here trying to read the tea leaves with
25 various juror notes on the one hand and it is just very
SOUTHERN DISTRICT REPORTERS, P.C.
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Document A-5793
AI Analysis
Summary: The deponent discusses receiving a letter from Catherine Conrad and their subsequent conversation with Susan Brune about it. The letter revealed information about jury deliberations, disturbing the deponent. The deponent discussed the Appellate Division order with Susan Brune but not the Westlaw report.
Significance: This document is potentially important as it reveals the reaction and discussion among the parties involved after receiving a letter from Catherine Conrad, which may be relevant to the case.
Key Topics:
Discussion of a letter received from Catherine Conrad
Examination of a Westlaw report and a suspension report
Conversation with Susan Brune regarding the letter and reports
Key People:
- Catherine Conrad - Sender of a letter that triggered discussion
- Susan Brune - Person with whom the deponent discussed the letter and reports
Full Text
Case 1:20-cv-03303-PAE Document 616-2 Filed 02/24/22 Page 108 of 130
A-5793
336
C2GFDAU3 Edelstein
1 memo that had been put together and the link to the Westlaw
2 report after we received the letter from Catherine Conrad.
3 Q. And did you discuss it with Susan Brune?
4 A. Discuss what?
5 Q. The Westlaw report and your examination of it as well as
6 your examination of the suspension report.
7 A. I believe I -- well, the suspension report, if you mean the
8 Appellate Division order?
9 Q. Yes.
10 A. I believe I discussed the Appellate Division order. I did
11 not discuss the Westlaw report with her.
12 Q. What was the nature of your discussion with her?
13 A. Well, I believe that after we received the June 20th
14 letter, I first had a conversation with Susan just upon receipt
15 of the letter and reading it and the substance of it, you know,
16 I was very disturbed by the letter. This has nothing to do
17 with Catherine Conrad being the suspended lawyer because at
18 that point I didn't know. When I first received the letter I
19 was sort of, I was disturbed and shocked by it. We had spent
20 three months in the courtroom where everyone wants to know what
21 the jury is thinking about various subjects. We then receive a
22 letter that gives us some insight into the jury deliberations
23 and I was very taken aback by some of the things that she said.
24 I felt that we had sat here trying to read the tea leaves with
25 various juror notes on the one hand and it is just very
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
DOJ-OGR-00009397
--- PAGE BREAK ---
C2GFDAU3 Edelstein 336
1 memo that had been put together and the link to the Westlaw
2 report after we received the letter from Catherine Conrad.
3 Q. And did you discuss it with Susan Brune?
4 A. Discuss what?
5 Q. The Westlaw report and your examination of it as well as
6 your examination of the suspension report.
7 A. I believe I -- well, the suspension report, if you mean the
8 Appellate Division order?
9 Q. Yes.
10 A. I believe I discussed the Appellate Division order. I did
11 not discuss the Westlaw report with her.
12 Q. What was the nature of your discussion with her?
13 A. Well, I believe that after we received the June 20th
14 letter, I first had a conversation with Susan just upon receipt
15 of the letter and reading it and the substance of it, you know,
16 I was very disturbed by the letter. This has nothing to do
17 with Catherine Conrad being the suspended lawyer because at
18 that point I didn't know. When I first received the letter I
19 was sort of, I was disturbed and shocked by it. We had spent
20 three months in the courtroom where everyone wants to know what
21 the jury is thinking about various subjects. We then receive a
22 letter that gives us some insight into the jury deliberations
23 and I was very taken aback by some of the things that she said.
24 I felt that we had sat here trying to read the tea leaves with
25 various juror notes on the one hand and it is just very
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
DOJ-OGR-00010076
Individual Pages
Page 108 - DOJ-OGR-00009397
Page 336 - DOJ-OGR-00010076
C2GFDAU3 Edelstein 336
1 memo that had been put together and the link to the Westlaw
2 report after we received the letter from Catherine Conrad.
3 Q. And did you discuss it with Susan Brune?
4 A. Discuss what?
5 Q. The Westlaw report and your examination of it as well as
6 your examination of the suspension report.
7 A. I believe I -- well, the suspension report, if you mean the
8 Appellate Division order?
9 Q. Yes.
10 A. I believe I discussed the Appellate Division order. I did
11 not discuss the Westlaw report with her.
12 Q. What was the nature of your discussion with her?
13 A. Well, I believe that after we received the June 20th
14 letter, I first had a conversation with Susan just upon receipt
15 of the letter and reading it and the substance of it, you know,
16 I was very disturbed by the letter. This has nothing to do
17 with Catherine Conrad being the suspended lawyer because at
18 that point I didn't know. When I first received the letter I
19 was sort of, I was disturbed and shocked by it. We had spent
20 three months in the courtroom where everyone wants to know what
21 the jury is thinking about various subjects. We then receive a
22 letter that gives us some insight into the jury deliberations
23 and I was very taken aback by some of the things that she said.
24 I felt that we had sat here trying to read the tea leaves with
25 various juror notes on the one hand and it is just very
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
DOJ-OGR-00010076