DOJ-OGR-00010043.jpg
445 KB
Extraction Summary
4
People
1
Organizations
0
Locations
1
Events
2
Relationships
3
Quotes
Document Information
Type:
Legal document
File Size:
445 KB
Summary
This document is a court transcript from March 24, 2022, detailing the direct examination of a witness, Ms. Brune. She is questioned about whether a legal brief she submitted contained material omissions. Ms. Brune denies any intent to omit material facts, stating they tried to be accurate and were shocked by information received in a subsequent letter.
People (4)
| Name | Role | Context |
|---|---|---|
| Brune | Witness |
Referred to as Ms. Brune, she is the person being questioned (giving testimony) during a direct examination.
|
| MR. SHECHTMAN | Attorney |
Objects to a question, stating it has been "Asked and answered."
|
| MR. DAVIS | Attorney |
Responds to Mr. Shechtman's objection, stating he doesn't believe the witness has answered the question.
|
| THE COURT | Judge |
Represents the judge presiding over the proceeding, who overrules an objection.
|
Organizations (1)
| Name | Type | Context |
|---|---|---|
| SOUTHERN DISTRICT REPORTERS, P.C. | Company |
Listed at the bottom of the transcript as the court reporting agency.
|
Timeline (1 events)
2022-03-24
Direct examination of Ms. Brune regarding potential material omissions in a legal brief she submitted.
Courtroom
Relationships (2)
The questioner is conducting a direct examination of the witness, Ms. Brune, in a formal legal setting.
Both are acting as attorneys in the same proceeding, with Mr. Shechtman making an objection and Mr. Davis arguing against it.
Key Quotes (3)
"I do not believe that it was written with the goal of making a material omission."Source
— Brune
(Responding to a question about whether a brief she submitted had material omissions.)
DOJ-OGR-00010043.jpg
Quote #1
"We were shocked when we received the letter."Source
— Brune
(Explaining her state of mind regarding the information in a brief, contrasting it with a letter received later.)
DOJ-OGR-00010043.jpg
Quote #2
"I did not believe that it had material omissions in the sense that anyone writing the brief or in my case signing the brief intended to make material omissions."Source
— Brune
(Clarifying her denial of material omissions by focusing on the lack of intent.)
DOJ-OGR-00010043.jpg
Quote #3
Full Extracted Text
Complete text extracted from the document (1,500 characters)
Case 2:20-cv-00338-ABN-mDoc 164-20 Filed 03/24/22 Page 576 of 3030
A-5760
A-5760
C2grdau2
Brune - direct
303
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
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
(212) 805-0300
DOJ-OGR-00010043
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