DOJ-OGR-00009352.jpg
444 KB
Extraction Summary
4
People
4
Organizations
0
Locations
3
Events
3
Relationships
3
Quotes
Document Information
Type:
Deposition transcript
File Size:
444 KB
Summary
This document is a deposition transcript from February 24, 2022, where a witness, Ms. Brune, is questioned about her knowledge of a "Westlaw report" and a "Google search." Ms. Brune states she learned about the Westlaw report on July 18th during a discussion with her colleagues, Ms. Trzaskoma and Ms. Edelstein. The questioning reveals the report was allegedly found or provided by a Mr. Benhamou on May 12th.
People (4)
| Name | Role | Context |
|---|---|---|
| Brune | Witness/Deponent |
The person being questioned, referred to as Ms. Brune.
|
| Ms. Trzaskoma | Counsel/Colleague |
Handled a conference with the Court, participated in a discussion on July 18th, and was aware of a Westlaw report fou...
|
| Ms. Edelstein | Counsel/Colleague |
Participated in a discussion with Ms. Brune and Ms. Trzaskoma on July 18th.
|
| Mr. Benhamou |
The person who had found or had been provided with the Westlaw report on May 12th.
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| Company |
Mentioned in the context of a "Google search".
|
|
| Westlaw | Company |
Mentioned in the context of a "Westlaw report".
|
| The Court | Government agency |
A conference was held with the Court and a letter was submitted to it.
|
| SOUTHERN DISTRICT REPORTERS, P.C. | Company |
The court reporting agency that produced the transcript, listed in the footer.
|
Timeline (3 events)
2022-05-12
Mr. Benhamou found or was provided with the Westlaw report.
2022-07-18
A discussion where Ms. Brune learned about the existence of a Westlaw report.
prior to 2022-07-18
Relationships (3)
They are colleagues who had a discussion on July 18th about a case, during which Ms. Brune learned about the Westlaw report.
They are colleagues who participated in the same discussion on July 18th.
Ms. Trzaskoma was aware of a Westlaw report that Mr. Benhamou had found or been provided with.
Key Quotes (3)
"I did not at that point know anything about the Westlaw report. I did not discuss the Google search with co-counsel."Source
— Brune
(Responding to a question about whether she told defense counsel about what she learned from Google and the Westlaw report.)
DOJ-OGR-00009352.jpg
Quote #1
"Here is where I got the dates wrong. There was the conference with the Court which Ms. Trzaskoma handled and we had to submit a letter to the Court. So then on that Monday, which I think is July 18th, I had a discussion with Ms. Edelstein and Ms. Trzaskoma, and at that point I learned that there was this Westlaw report floating around."Source
— Brune
(Explaining the timeline of when she became aware of the Westlaw report.)
DOJ-OGR-00009352.jpg
Quote #2
"You learned specifically that this was the Westlaw report that Ms. Trzaskoma had found or had been provided by Mr. Benhamou on May 12th, correct?"Source
— Questioner
(Seeking confirmation on the origin and date of the Westlaw report's discovery.)
DOJ-OGR-00009352.jpg
Quote #3
Full Extracted Text
Complete text extracted from the document (1,488 characters)
Case 1:20-cr-00330-PAE Document 1616-2 Filed 02/24/22 Page 63 of 130
A-5748
A-5748
C2grdau2
Brune - direct
291
1 Q. But my question was a far more specific one that you still
2 haven't answered, Ms. Brune.
3 A. I'm going to.
4 Q. Which was, just so we are clear, did you tell the defense
5 counsel within that several-day period about what you had
6 previously learned from Google, the suspension opinion, and the
7 Westlaw report?
8 A. I did not at that point know anything about the Westlaw
9 report. I did not discuss the Google search with co-counsel.
10 Q. Did you at any point advise them about the Google search?
11 A. No.
12 Q. At some point in time am I correct in assuming that you
13 actually reviewed the Westlaw report?
14 A. Here is where I got the dates wrong. There was the
15 conference with the Court which Ms. Trzaskoma handled and we
16 had to submit a letter to the Court. So then on that Monday,
17 which I think is July 18th, I had a discussion with Ms.
18 Edelstein and Ms. Trzaskoma, and at that point I learned that
19 there was this Westlaw report floating around.
20 Q. You learned specifically that this was the Westlaw report
21 that Ms. Trzaskoma had found or had been provided by Mr.
22 Benhamou on May 12th, correct?
23 A. Yes. We were very focused on making sure what we said in
24 the letter was accurate, and that was a part of it.
25 Q. Before this time period you had filed a brief, right?
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
Brune - direct
291
1 Q. But my question was a far more specific one that you still
2 haven't answered, Ms. Brune.
3 A. I'm going to.
4 Q. Which was, just so we are clear, did you tell the defense
5 counsel within that several-day period about what you had
6 previously learned from Google, the suspension opinion, and the
7 Westlaw report?
8 A. I did not at that point know anything about the Westlaw
9 report. I did not discuss the Google search with co-counsel.
10 Q. Did you at any point advise them about the Google search?
11 A. No.
12 Q. At some point in time am I correct in assuming that you
13 actually reviewed the Westlaw report?
14 A. Here is where I got the dates wrong. There was the
15 conference with the Court which Ms. Trzaskoma handled and we
16 had to submit a letter to the Court. So then on that Monday,
17 which I think is July 18th, I had a discussion with Ms.
18 Edelstein and Ms. Trzaskoma, and at that point I learned that
19 there was this Westlaw report floating around.
20 Q. You learned specifically that this was the Westlaw report
21 that Ms. Trzaskoma had found or had been provided by Mr.
22 Benhamou on May 12th, correct?
23 A. Yes. We were very focused on making sure what we said in
24 the letter was accurate, and that was a part of it.
25 Q. Before this time period you had filed a brief, right?
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
DOJ-OGR-00009352
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