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427 KB

Extraction Summary

4
People
1
Organizations
0
Locations
3
Events
3
Relationships
3
Quotes

Document Information

Type: Legal document
File Size: 427 KB
Summary

This document is a transcript of a legal testimony where an individual named Edelstein is being questioned about their role in drafting a legal brief. The questioning focuses on whether Edelstein discussed with colleagues, specifically Susan Brune, the inclusion of certain facts learned from Theresa Trzaskoma on or about May 12th. Edelstein confirms having such a discussion about what to include in the brief prior to the receipt of a 'juror letter'.

People (4)

Name Role Context
Edelstein Witness/Deponent
The individual being questioned throughout the transcript.
Susan Brune
Mentioned as someone at the witness's firm with whom discussions were held about the content of a legal brief.
Theresa Trzaskoma
Mentioned as a source of information learned on May 12th, which was considered for inclusion in a legal brief.
Randy Kim
Mentioned as someone who talked about facts that the firm was aware of, which were discussed for inclusion in a brief.

Organizations (1)

Name Type Context
SOUTHERN DISTRICT REPORTERS, P.C. company
Appears at the bottom of the document, likely the court reporting agency that transcribed the proceeding.

Timeline (3 events)

Drafting and editing of the facts section of a legal brief.
on or about May 12
Voir dire proceeding during which facts were learned by Theresa Trzaskoma.
on or about May 12
Discussion between Edelstein and Susan Brune about whether to include facts learned on May 12 in a brief to the Court.

Relationships (3)

Edelstein professional Susan Brune
They are described as being at the same firm and had discussions about the content of a legal brief.
Edelstein professional Randy Kim
They are mentioned as being at the same firm and having talked about facts known to the firm.
Edelstein professional Theresa Trzaskoma
Edelstein was questioned about information that Theresa Trzaskoma had learned and talked about, suggesting they are involved in the same legal case.

Key Quotes (3)

"I edited that section, yes."
Source
— Edelstein (Answering a question about involvement in drafting the facts section of a brief.)
DOJ-OGR-00009403.jpg
Quote #1
"Yes, Susan Brune and I had a discussion."
Source
— Edelstein (Confirming a discussion took place with a colleague about what to reveal in a brief.)
DOJ-OGR-00009403.jpg
Quote #2
"So you discussed about whether you should or should not include in the facts section of your brief the facts that you learned either during voir dire or on May 12 but prior to receipt of the juror letter, correct?"
Source
— Unnamed Questioner (Summarizing the nature of the discussion between Edelstein and Susan Brune for confirmation.)
DOJ-OGR-00009403.jpg
Quote #3

Full Extracted Text

Complete text extracted from the document (1,409 characters)

Case 1:20-cr-00330-PAE Document 616-2 Filed 02/24/22 Page 114 of 130
A-5799
C2GFDAU3
Edelstein
342
1 A. Yes.
2 Q. Were you involved in the drafting of the facts section of
3 the brief?
4 A. I edited that section, yes.
5 Q. Now, by the way, did you have discussions with Susan Brune
6 or anyone else at the firm about whether people at your firm
7 were going to discuss with other defense counsel what Theresa
8 Trzaskoma had talked to you about on May 12th?
9 A. No.
10 Q. Are you telling us that there was no discussion at all
11 about whether you were going to inform your co-counsel about
12 the facts that you had learned or Theresa Trzaskoma had learned
13 during voir dire and during, on or about May 12?
14 A. I don't recall any discussion about speaking with other
15 defense counsel.
16 Q. Did you discuss with anyone at your firm about whether you
17 were going to reveal in the brief that you were going to submit
18 to the Court the facts that your firm were aware of that you
19 and Randy Kim talked about?
20 A. Yes, Susan Brune and I had a discussion.
21 Q. So you discussed about whether you should or should not
22 include in the facts section of your brief the facts that you
23 learned either during voir dire or on May 12 but prior to
24 receipt of the juror letter, correct?
25 A. Yes.
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
DOJ-OGR-00009403

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